In an area as remote and relatively undeveloped as Ka’u is, natural resources are abundant. The development of a space launch facility at Palima Point or elsewhere in the district cannot help but have a disruptive impact on the natural environment. Impacts can be acute – sudden death should a bird be in the path of a cloud of spilled poisonous gas. They may be long-term: gradually weakened immune systems and increased susceptibility to infection resulting from lower-level, more chronic exposures.
To take the measure of the resources potentially harmed, consultants were hired by the EIS contractor, MCM Planning, to survey the Palima Point area for birds and mammals (Leonard Freed), for plants (Winona Char), and for marine life (Richard Brock).
Char surveyed the vicinity of the proposed launch pads and other areas that might harbor sensitive native plant communities and rare plants. The “heavily disturbed” areas were avoided, as were the actively cultivated macadamia orchards. Altogether, 35 native plant species were found in two of seven vegetation types identified on the site: pioneer vegetation on lava, and coastal vegetation. Of those 35 species, just 11 were identified as endemic -that is, found only in Hawai’i. None of them, Char reports, is officially listed as threatened or endangered, nor is any proposed or a candidate for such listing.
Birds in the Bush
Freed observed two ‘io, or Hawaiian hawks, during his survey – the only endangered bird species he encountered. The ope’ape’a, or Hawaiian hoary bat – Hawai’i’s only native land mammal, and also an endangered species – was not detected on the site, but was detected close by. “These off-site locations are sufficiently close to the project sites that bats may be expected, at least occasionally, in the forested areas on the site….Tree cover and wild gulch habitat, which occur on the project site, appear to be important for [bat] roosting… Small patches of mixed forest near Kamehame Hill may provide a situation for over-water foraging in this portion of the project site.”
Freed identified several other species of endangered or threatened native birds that might reasonably be expected to use or fly over the Palima Point site: the koloa, or Hawaiian duck; the dark-rumped petrel and Newell’s shearwater (both of which may be part of breeding populations on the slopes of Mauna Loa and Kilauea, above the project site); the band-rumped storm petrel; the black-necked stilt; the American coot; and the nene, or Hawaiian goose.
The native Hawaiian owl, or pueo, was suspected by Freed to be breeding on the site. “I have seen a pueo in a collapsed lava tube… south of the project site… Given the similarity of the habitat with that on the project site, the owl would be expected on the project site and would be expected to have a breeding population in the area.”
The DEIS contains no study of terrestrial invertebrates. Freed, however, suggests that this should be done. The island of Hawai’i has several lava tubes in which a specialized subterranean fauna of insects and spiders has evolved. While this project site has never been investigated for the presence of cave arthropods, there are lava tubes on the site and some of these may contain cave communities, including possible species endemic to the site. In addition, numerous native Hawaiian arthropods are candidates for federal listing as endangered or threatened species and some of these may be present on the project site.
Freed notes that the spaceport’s impact on endangered species is not confined to the Palima Point area but extends upslope as well. He then lists nine species of “endangered, threatened, and candidate” birds as well as one mammal (the hoary bat) that are thought to have populations on the slopes of Mauna Loa and Kilauea. In addition to the endangered species listed earlier, they include the following forest birds: the ‘akiapola’au, the Hawai’i creeper, the Hawai’i akepa, and the o’u.
And a New Goby?
The survey of marine resources by Brock confirmed that the offshore area was well used by the green sea turtle (Chelonia mydas), a threatened species, and the hawksbill turtle (Eretomchelys imbricata), a federally endangered species. A sandy beach at Kamehame Hill is used by hawksbills as a nesting site.
Brock counted 87 species of fish in a biological zone characterized by the presence of Porites lobata as the dominant coral. The other biological zone, or biotope, is characterized by large boulders; some 72 species were observed during a “limited amount of time” Brock had for this survey “With further observation time,” he writes, “it is expected that more species would be seen.” Many of the fish were of importance to commercial, recreational, or subsistence fishing. Along the shore, which is hardly used now except by people fishing for recreation or subsistence, opihi gathering is a common activity.
The survey of the one anchialine pool in the population control zone of the proposed spaceport site turned up what may be Brock’s most interesting find: an unidentified species of goby, a small native Hawaiian fish. According to Brock, this species “is a common and conspicuous element of Station 6 [the northern end of the anchialine pond]. It attains a length of about 7 cm and is dusky brown above, light tan color beneath, separated by a striking yellow horizontal stripe running the length of the body.” Brock found that it “does not show any interest in ‘bait’.” “In 1990,” he adds, “we spent more than 8.5 man-hours trying to capture a specimen for identification purposes,” without success.
The National Park
One of the largest natural resources in the area is the Hawai’i Volcanoes National Park, whose southern boundary virtually abuts the spaceports proposed population control zone. The park is protected not only by federal law, but also has been, since December 11, 1987, a World Heritage Site, as designated by UNESCO.
The park’s Ka’u Desert is a nationally designated wilderness area, which is protected by federal law establishing the National Wilderness Preservation System. That law provides that the designated wilderness be “protected and managed so as to preserve its natural conditions” and ensure that it “generally appears to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable.”
The UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage, recognizes that “the loss, through deterioration or disappearance, of any of these most prized possessions constitutes an impoverishment of the heritage of all the peoples in the world.” Countries that have signed the convention (including the United States) agree to do all they can to “ensure the identification, protection, conservation, presentation, and transmission to future generations of the cultural and natural heritage” sites within each country’s borders.
Are They All at Risk?
Of the nearly 2,000 pages that make up the 10-volume Draft EIS (and technical appendices), roughly 100 are devoted to what is described as an “Ecological Risk Assessment.” (This is Volume VIII, Appendix B, prepared by Risk Science Associates of Corte Madera, California.)
The risk assessment is largely given over to efforts to determine whether any of the endangered species that could be found along the transportation corridor or in a 15-kilometer “zone of ecological concern” radius landward around Palima Point might be injured by exposure to the gases emitted during accidental spills or “launch anomalies.”
The analysis is handicapped by extremely limited data concerning the ways in which these species are affected by exposure to toxic chemicals. The best that the analysts can do is to come up with laboratory data on species that might serve as surrogates.
“While an immense amount of energy was expended in locating appropriate toxicity data,” the report states, “large data gaps still exist. First, all of the available data were on laboratory species, none of which are ecological receptors at Palima Point. Species differ in their sensitivity to different toxins; even closely related species vary in their responses to different compounds. Second, there was no breadth in the taxonomic groups tested; the vast majority of eco-toxicity data available … were on inbred strains of mammals. Thirdly, laboratory toxicity tests can rarely be extrapolated to the field. Lastly, the most common toxicity values encountered were LD50 and LC50 type data [relating to the dose or concentration of a chemical that is fatal to half the animals tested]. While these types of data are useful when comparing the relative toxicity of compounds, they cannot be used to identify adverse effects (besides death) at lower concentrations. How sublethal, chronic, and acute effects impact population dynamics and community and ecosystem structure can be extremely difficult to model; it is exactly these types of effects that may be operating at concentrations below the LD50 level.”
What’s Sauce for the Goose
To compensate for the lack of data, the authors calculated acceptable exposure levels by throwing in what was supposed to be a margin or safety- an “uncertainty factor,” or UF as they called it. The levels at which chemicals are thought to be harmful to laboratory animals were reduced by an order of magnitude. Even with this, they note, “so little toxicological data were available for most of the COCs [chemicals of concern], it is difficult to conclude whether the UFs used in this assessment are overly or underly [sic] conservative.”
At times in the Risk Science Associates’ analysis, human exposure levels are used as a fallback in attempting to determine possible harm to endangered birds. For example, in the discussion of risks associated with normal launches, the study states: “it is reasonable to assume that at least for short-term exposures of approximately one hour duration that mammalian and avian species are not significantly more sensitive than humans to Al203” (aluminum oxide, which is released in particulate form during normal launches). Therefore, the study continues, “it seems unlikely that exposures to concentrations of Al203 less than the human EEGL [emergency exposure guideline levels] would result in measurable adverse effects to biota.”1
‘Great Uncertainty’
Should a launch failure result in release of the hypergolic fuels, concentrations of nitrogen tetroxide and unsymmetrical dimethyl hydrazine would have “a higher probability of producing adverse effects in sensitive biotic receptors. Simultaneous exposure to all of these carcinogens (as would be the case in a deflagration event) could result in additive toxicological effects. This remains an area of great uncertainty.”
In similar fashion, spills of UDMH and nitrogen tetroxide at the spaceport site might expose birds within the “zone of ecological concern” to concentrations high enough to inflict harm. Transportation accidents that released hydrazine, nitrogen tetroxide or UDMH to the atmosphere might also be expected to pose a threat to any birds or plants nearby. “Within 20 meters of the highway, estimated concentrations of all three substances were above levels that could potentially produce adverse effects,” the study says. “However,” it continues, only nitrogen tetroxide concentrations were “still unacceptably high at 1 km from the site” of the spill.
Risk Science Associates’ study suffers from a lack of local knowledge. The three most sensitive habitats within Hawai’i Volcanoes National Park are described as “the bird park, and Kipuka Puaulu and Kipuka Ki.” But “the bird park” is actually Bird Park, which is coterminus with Kipuka Puaulu. And, while the concern expressed for protecting the alala, or Hawaiian crow, is laudable, the report’s authors seem to be unaware that the alala has not been seen for 27 years in the area along Highway 11.
In any case, over and above the acute responses to high concentrations of lethal gas, the DEIS suggests that exposures to such toxic chemicals as may be released from the spaceport could cause some species of endangered birds to develop an increased susceptibility to infection. In addition, “the effect of low (but inaudible) frequency noise levels” – such as might be associated with some spaceport operations – “on reproductive behavior and development is uncertain. Generally, faunal species (particularly birds) would be most sensitive early in the breeding season during the nest site selection phase, when noise could cause the birds to abandon the site.”
Not Considered
The mention of noise impacts is found in the summary of the DEIS; it does not appear in the Ecological Risk Assessment, which does not address noise at all. In addition to the “low (but inaudible)” frequencies mentioned above, birds may be subjected to a variety of other intrusive noises. Freed has noted that some birds can become accustomed to heavy construction machinery notwithstanding the racket produced. Other types of noises – loud, explosive blasts, for example – might well produce different responses. When efforts were made to breed alala at Mauna Kea State Park, adjoining the Army’s Pohakuloa Training Area, the alala seemed to stop all mating activity when ordnance exploded nearby. On the other hand, nene being bred at the same facility seemed unfazed.
Under some conditions, sounds from launch activities might be expected to focus in the Ka’u Forest Reserve. Sound waves normally diminish with distance from the source. However, on occasion, the waves can bounce off low clouds and become focused at a distant point, causing a condition known as caustic focusing. What the impact will be on birds and upon the ope’ape’a (the Hawaiian hoary bat) is virtually unknown.
Disturbed Wilderness
The spaceport would be visible from some areas in the Ka’u Desert wilderness of Hawai’i Volcanoes National Park during daytime hours. At night, lights associated with spaceport operations would produce “visible glow and/or direct observation of lighting associated with operations,” according to a two-page “Summary of Lighting Impacts on Hawai’i Volcanoes National Park” (Appendix B to Volume Ix of the DEIS, prepared by Engineering-Science, Inc.). Staff from Engineering-Science report that they met with park staff on January 27, 1993 and visited an overlook in the park “While we indicated the impact on the nighttime sky would be very small… Dan [Taylor, chief of natural resources at the park] made it clear that he felt the proposed facility was not compatible with the adjacent National Park.”
Another possible impact would be from falling debris in the event of an aborted launch. Maps depicting debris patterns from aborted Delta II launches indicate that under some wind conditions, debris could land in the Ka’u Desert.
Then there is the noise. According to the “Acoustical Noise Impact Evaluation” Volume VII, Appendix B, prepared by D.L. Adams Associates, Ltd.), “rocket noise will persist above 80 [decibels] overall for over 3 minutes at Pahala, Punalu’u, Na’alehu, Mauna Loa Sanctuary; and the National Park.” Initial noise levels will be even higher. According to that study, the maximum sound pressure levels at the park are expected to reach 96 decibels – about as loud as the sound you would hear if you were standing 15 meters from an operating jackhammer.
1 The EEGL standard is developed for emergency workers – those people responding to spills and other hazardous situations. It is far less protective of human health than the SPEGLs (short-term public exposure guideline levels). If one is to err on the side of caution in using human exposure standards as a guideline for avian exposures, SPEGLs would be a more reasonable standard than EEGLs. In any case, the idea that birds are no more sensitive “receptors” than humans would seem to be undercut by the canary-in-the-coalmine system of warning miners when oxygen levels were dangerously low.
Volume 4, Number 2 August 1993