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(November 7, 2016)
Department of Land and Natural Resources, Division of State Parks
1151 Punchbowl Street, Room 310
Honolulu, HI 96813
Tetra Tech, Inc.
737 Bishop Street, Suite 2340
Re: Draft Environmental Assessment, Hanakāpīʻai Stream Bridge Project
The Hanalei-to-Ha'ena Community Association (HHCA) submits the following comments on the Draft Environmental Assessment (DEA) for the proposed Hanakāpīʻai Stream Bridge Project (“Bridge”). As the HHCA’s members live in the three communities that are located closest to the proposed Bridge, many of the members have extensive experience and insights related to the trail.
1. The HHCA strongly disagrees with the unfounded assertions, made throughout the DEA, that the Bridge would not be growth-inducing. To the contrary, we believe that the proposal to construct this bridge without simultaneously addressing its very clear growth-inducing impacts, will result in more people crossing the Hanakāpīʻai Stream during unsafe conditions, and expose more people to the hazards of dangerous surf at Hanakāpīʻai Beach and dangerous conditions on the Hanakāpīʻai Falls Trail.
There are more than a dozen places in the DEA where the assertion that the Bridge would not be growth-inducing should be corrected.
A. DEA Assertion: “The proposed bridge is not expected to increase the number of visitors accessing Hanakāpīʻai. In recent years, there has been an increase in number of visitors on the trail going to Hanakāpīʻai Beach and Hanakāpīʻai Falls, which can be attributed to an overall increase in visitors to Kaua’i, as well as increased recreation and physical activities such as hiking and promotion by social media and online destination sites.” (Page 12)
Response: Unless and until daily caps on the use of the Kalalau Trail are instituted and enforced, the construction of the Bridge will encourage more tourists to use the trail as it is obvious that they will be informed (and rightfully so) by tourist guides, “social media and online destination sites” that the formerly hazardous crossing of the Hanakāpīʻai Stream has been eliminated. Not only will this information encourage more tourists to make use of the Kalalau Trail, but it will also encourage a greater number of ill-prepared tourists to make use of the Trail, increasing hazardous behaviors and putting a greater number of both tourists and rescue personnel at risk.
B. DEA Assertion: “The scenic route and coastal areas of Hanakāpīʻai are the attractions for most visitors, whereas the stream and proposed bridge are part of the trail system that connects visitors to these areas. Therefore, the relatively simple bridge design is not expected to be an added attraction to Hanakāpīʻai... The proposed bridge is not anticipated to attract an increase in the number of visitors to Hanakāpīʻai, as this may be attributable to other factors such as promotion of not easily accessible scenic areas and fascination with Kaua’i’s natural resources.” (Page 12)
Response: This statement diverts attention from the real issue. It is obviously true that the bridge itself would not be an attraction, any more than a widened highway to a difficult-to-access scenic area is an attraction. But in both cases, the new infrastructure facilitates and encourages increased visitation to the scenic area.
C. DEA Assertions: “The bridge is intended to provide a means for stranded hikers to get out of Hanakāpīʻai during times of high stream levels caused by severe weather events.” (Page 12). “During heavy rain and flash flooding events, the bridge would provide a safe option for hikers to leave Hanakāpīʻai.” (Page 21)
Response: What these statements obscure is the fact that the bridge will also provide a means for additional hikers, who would otherwise be deterred from crossing Hanakāpīʻai Stream by greater-than-minimal stream levels, to cross the Stream to Hanakāpīʻai Beach and the Hanakāpīʻai Falls Trail, increasing the number of people who will then be exposed to hazards at the beach and on the trail.
D. DEA Assertion: “Additionally, the two mile hike from the Kalalau trailhead to Hanakāpīʻai is rigorous, and unprepared and inexperienced hikers are likely to be deterred and limited by the difficulty of the trail as opposed to being attracted by a bridge.” (Page 12)
Response: First: if it were true that “unprepared and inexperienced hikers are likely to be deterred and limited by the difficulty of the trail”, there would be no rescue problem in the first place and therefore no need for the Bridge. So the DEA’s assertion does not hold water. Second: contrary to the DEA’s assertion, by eliminating the Hanakāpīʻai Stream crossing as a barrier to unprepared and inexperienced hikers, the bridge would enable and encourage more of those hikers to (i) take the trail during rainy conditions; and (ii) continue to Hanakāpīʻai Beach and to the Hanakāpīʻai Falls Trail, exposing more people to hazards.
E. DEA Assertion: “If and when (emphasis added) elements of the Ha‘ena Master Plan are successfully implemented, visitation to Hanakapi’ai will actually decrease.
Response: The key part of this statement is “if and when.” But State Parks’ top management has repeatedly warned the participants in the Ha’ena Master Plan process that, even if the BLNR does approve the proposed Ha’ena Master Plan and its daily visitation limits, it is very unlikely that those limits will actually be implemented until some time in the distant future, based on lack of funding for both infrastructure (the cost to implement a daily permitting system) and manpower (the cost to operate and enforce such a system).
In addition: while a daily visitor limit would reduce trail use on peak days, it would not bind during the non-peak days, including bad weather days during the rainier season, when visitation is below the proposed 900 person per day limit. On those days - precisely the days when the hazards are greatest - the proposed Hanakāpīʻai Stream bridge would facilitate increased usage of the Kalalau Trail, Hanakāpīʻai Beach and Hanakāpīʻai Falls Trail, increasing hazardous outcomes.
F. DEA Assertion: “It is unlikely that the bridge would cause an increase in foot traffic because under normal conditions, the Hanakāpīʻai Stream crossing is approximately 1-foot deep with relatively slow moving water, which is manageable for most hikers who have the fitness and balance to traverse the first 2 miles of the Kalalau Trail to reach Hanakāpīʻai. The crossing becomes dangerous only under heavy rain conditions and the bridge is intended to provide a safe option to leave this section of the trail.” (Page 21)
Response: To the contrary: the bridge will enable, encourage and attract more people to use the Kalalau Trail (people who currently would not embark on a hike because the weather made it questionable as to whether they might be able to cross Hanakāpīʻai Stream) to visit Hanakāpīʻai Beach or Hanakāpīʻai Falls, exposing them to more risks at those locations.
G. DEA Assertion: “Hikers continuing inland to Hanakāpīʻai Falls or further along the coastal Kalalau Trail, will encounter additional stream crossings without bridges.” (Page 21)
Response: Indeed, this is the problem that the DEA does not honestly confront: hikers who would be able to take the trail to Hanakāpīʻai Falls (or simply visit Hanakāpīʻai Beach) during dangerous conditions, solely because the proposed bridge made it possible to cross a swollen Hanakāpīʻai Stream rather than turn back (or not embark on the hike in the first place).
H. DEA Assertion: “The number of hikers in these areas [beyond Hanakāpīʻai Stream] are not expected to increase due to the proposed bridge.” (Page 21)
Response: This statement defies credibility. By eliminating the primary barrier to Hanakāpīʻai Falls and Hanakāpīʻai Beach, the Hanakāpīʻai Stream bridge will certainly increase the number of hikers in those areas.
I. DEA Assertion: “With increased visitors to the Hāʻena State Park and the Nāpali Coast State Wilderness Park and their impacts upon park resources, DLNR recognizes the need to manage this situation. A proposed Management Plan for Nāpali Coast SWP will provide the guidance on management options supported by the community. In concert with implementation of the Hāʻena State Park Master Plan, this will regulate visitation, because increased traffic on the trail could result in degradation of the natural environment and cultural resources as well as a diminished sense of isolation and immersion in nature that many hikers seek in the state park.” (Page 22)
Response: As we noted earlier, State Parks’ leadership has already warned community members who have been participating in the Ha’ena State Park Master Plan process that it will be many years (if ever) before the visitor limits in that Plan can be implemented. The odds of timely implementation of such limits in a “proposed Management Plan for Nāpali Coast SWP,” which does not even exist yet, are even smaller.
So the proposed Hanakāpīʻai Stream bridge would be built long before such limits are implemented, resulting in increased exposure of a larger number of visitors (even less-prepared than today, as they would not be stopped by the Hanakāpīʻai Stream) to the hazards of Hanakāpīʻai Beach and the Hanakāpīʻai Falls Trail.
J. DEA Assertion: “The Division of State Parks, however, does not believe that keeping the dangerous conditions at Hanakāpīʻai Stream is the best way to manage park usage. Abstaining from constructing a bridge at Hanakāpīʻai Stream would not be the most effective way of managing visitation because visitors have already invested effort in hiking the two miles to reach Hanakāpīʻai Valley. They are presently undeterred by the inconvenience of fording the stream. The ideal place, however, to regulate visitation is at the trailhead at Hā‘ena State Park, which is being proposed by the Division of State Parks (Personal Communication, Division of State Parks, 2015).” (Page 22)
Response: In this statement, the DEA admits that some visitors today are undeterred by the inconvenience of fording the stream. Providing a bridge over Hanakāpīʻai Stream can only increase that number, exposing more people to the hazards at Hanakāpīʻai Beach and the Hanakāpīʻai Falls Trail.
We agree that the ideal place to regulate visitation is at the trail head. State Parks would do far better to spend its funds to implement a trailhead management system rather than spend its funds on a bridge that, without a trailhead management system, will result in increased trail usage and increased visitor exposure to hazards.
K. DEA Assertion: “In the case that the proposed bridge causes an increase in the number of visitors, the issue of managing park visitation is already being addressed by the Division of State Parks through the Hā‘ena State Park proposed MP and associated Draft Environmental Impact Statement submitted in July 2015. In the MP, Division of State Parks cites an increasing number of visitors over the past 30 years which could have detrimental effects on the natural and cultural resources in the area (see Table 3-1). In response, Hā‘ena State Park proposes for the first time to impose limits on the number of visitors allowed to enter the park to 900 people per day. Because hikers have to pass through Hā‘ena State Park to reach the Kalalau Trailhead, access to the trail and Hanakāpīʻai would be limited to 900 daily visitors as well. (DLNR Division of State Parks 2015).” (Page 22)
Response: Pointing to the proposed Ha’ena State Park visitation limit as a remedy for the bridge’s growth inducing (and risk increasing) impact is disingenuous. As we noted earlier, State Parks’ top management has repeatedly stated that the likelihood of implementing any daily visitor limit in the next few years is minimal, due to lack of funding for both the infrastructure and the employees to implement and enforce the limit.
L. DEA Assertion: “Because the timeframe of getting the [HāʻenaState Park] MP approved and then implemented is longer than that of this bridge approval and construction, there would likely be a period during which the bridge exists but the limitations do not. Given the urgency of the health and human safety threat, the bridge is needed to improve the safety of hikers in the park and decrease the cost of rescuing stranded individuals.” (Page 22)
Response: To the contrary, constructing the bridge without first implementing the daily visitor limits would be irresponsible, as it would decrease rather than increase the overall safety of park users. Supposed “urgency” should not be used as an excuse to move forward with a poorly-conceived project.
2. Even if there the Bridge had no growth-inducing impacts, it would increase, not decrease, visitors’ exposures to risks. Even if the Bridge did not result in any increase in Kalalau Trail usage (a premise that is neither realistic nor believable, as noted above), the Bridge would result in an larger number of poorly-prepared visitors (those who would normally turn back at Hanakāpīʻai Stream when its water level was beyond minimal) being exposed to the risks at Hanakāpīʻai Beach and along the Hanakāpīʻai Falls Trail (the latter being a day hike that far more day hikers would take if the Hanakāpīʻai Stream crossing was made trivial by the Bridge).
As the DEA notes (on Page 14) “the vast majority of hikers access the beach as their final destination.” But the DEA also states (on Page 8): “Hanakāpīʻai Beach is one of the most dangerous beaches on the island, with at least 30 drownings occurring since 1970 (Blay 2011). Strong rip currents swiftly pull swimmers away from the beach and down the coast to the west, where there is no safe beach access for over 3 miles.”
The Bridge would make Hanakāpīʻai Beach more accessible to those day-hikers who currently turn back at the Hanakāpīʻai Stream by eliminating the current barrier associated with crossing the Hanakāpīʻai Stream. And further, it would expose them to the beach hazards on the days when the weather conditions are worst (the days when they would currently turn back). It makes no sense to construct a Bridge that would create such increased hazards. Yet this serious negative impact of the proposed project is completely ignored in the DEA.
3. The Alternatives considered in the DEA are insufficient.
In addition to the proposed project itself being deficient (as neither its growth-inducing impacts nor its exposure of visitors to hazards on the Kalalau side of the Hanakāpīʻai Stream are considered or mitigated), the Alternatives to the Bridge are woefully incomplete. Other than the “No Action” Alternative, the DEA considers only minor variations on the proposed Bridge, rather than considering other alternatives for achieving the ostensible goal (i.e., reducing the need to conduct rescue operations) of the Bridge project.
The DEA Alternatives should be expanded to at a minimum include a hiker behavior modification/trailhead management alternative, as it is clear that the irresponsible behavior of hikers is the root of the problem and just as clear that changing such behavior can be the focus of the solution.
As the DEA notes on Page 11, “[p]reviously, responders would immediately attend to stranded persons who were injured or in imminent danger, then wait for the flooding to recede to help the hikers out of the valley. Recently, however, an increasing number of hikers do not wait for the water to subside and have attempted to cross the flooded stream.” Imposing very significant penalties on trail users who do not comply with orders to not cross the Hanakāpīʻai Stream would both deter much of such behavior and support the costs of a notification and enforcement program.
The DEA Alternatives should therefore include, for the interim period until the permanent systems for management of daily visitor access to HāʻenaState Park and Nāpali Coast SWP are put into place: real-time management of trail access at the Ke’e trailhead and at the Hanakāpīʻai Stream crossing by assigning park rangers at those locations; authorizing those rangers to order trail closures (including closure Hanakāpīʻai Stream crossing); increased signage (including real-time updates) emphasizing the risks at Hanakāpīʻai Stream and Hanakāpīʻai Beach; and implementation of severe financial penalties for trail users who violate closure orders atthe trailhead or the stream. Successful implementation of these measures would make the proposed bridge completely unnecessary.
4. Construction Impacts on the neighboring communities: Should it ultimately be determined that the Bridge be built (as part of a more-complete proposal that addresses the problems that we have noted above), we note that the DEA states that the construction zone would in part be accessed by helicopter. We have had much experience in the past with non-tour helicopters flying noisily over our communities, and we therefore note that as a construction impact mitigation measure, all helicopter activity associated with the project must be required to be routed far from the Hanalei, Wainiha and Ha’ena residential communities.
In conclusion: the proposed Hanakāpīʻai Bridge project is ill-conceived and incomplete. Although the Bridge is being marketed as a project to purportedly increase safety, it would not do so. On a very superficial level, the Bridge might seem to be warranted by safety concerns. But the Bridge would actually result in increased visitor exposure to harms, as it is only half-a-project, lacking concurrent implementation of the measures needed to: (i) prevent its growth-inducing effects, and (ii) prevent visitors who would currently turn back at Hanakāpīʻai Stream from proceeding over the proposed bridge and exposing themselves to significant harms at Hanakāpīʻai Beach and the Hanakāpīʻai Falls Trail. Because so many key elements are missing from the Bridge project, it would provide no more of an increase in safety than would a new bridge on an urban highway built without lane-striping, traffic control/speed limit/warning signs or guardrails.
Until the Bridge’s inducements of increased visitation and increased hazardous behavior are fully addressed (through concurrent implementation of daily limits on the use of the Kalalau Trail, through real-time closure - and enforcement of such closure - of the Trail and/or the Hanakāpīʻai Stream crossing to day hikers when stream level rises are imminent, and through implementation of severe financial penalties for those who violate closure orders), both the project and the DEA are incomplete and the proposed FONSI is unjustified.
For the reasons stated above, we strongly disagree with the Anticipated Finding of No Significant Impact.
Finally: we note that the HHCA was neither formally consulted on the Draft EA, nor was it included on the DEA Distribution List (Page 26). For more than 25 years, the HHCA has represented the Hanalei, Wainiha and Ha’ena communities and has consistently provided constructive input on matters impacting those communities. We hereby request that the HHCA be added to the Distribution List, and that the HHCA be provided with two hard-copies of all future documents related to this matter, including the SMA Major Use Permit Application and Conservation District Use Permit Application, should the project move forward.
Joel Guy, President Caren Diamond, Chair
Hanalei-to-Ha’ena Community Association Hanalei-to-Ha’ena CommunityAssociation Land Use Committee