Comments to the DEA on Kawaihae Harbor Improvements 2026

We submitted our comments, questions, and suggestions to HDOT Harbors regarding their new project at Kawaihae Harbor. You can view the Draft Environmental Assessment,DEA, here. You can also read about it in the newspaper here.

The image below shows the scope of work for this project.

Here are our highlights and summary.

Section 3.15, Secondary and Cumulative Impacts, does not cover the construction of Pier 3.

Cummulative Impacts

HAR § 11-200.1-2 defines cumulative impacts as incremental impact of the proposed action when combined with other past, present, and reasonably foreseeable future actions. This means individually minor impacts could become collectively significant.

According to the HAR 11-200.1-2 above, Pier 3, as mentioned in the Hawaiʻi Island Commercial Harbors 2035 Master Plan, would fall under “reasonable foreseeable future action.”

We understand that this DEA is limited to the Scope of Work presented, and comments and questions should be confined to it. However, the cumulative impact of future Pier 3 cannot be ignored. We believe that dredging more than five acres of coral reef and removing the Cultural Access to the beach west of APE 1 would likely violate federal coral protection requirements and would therefore be illegal. Mitigating five acres of coral reef by relocating it to another site would likely fail, as there is no suitable location to support and protect it.

We are familiar with Executive Order 13089, Coral Reef Protection (PDF), which is still in effect states:

“calls for all federal agencies whose activities may affect coral reef ecosystems to:

• identify such actions;
• use their programs and authorities to protect and enhance coral reef ecosystems; and
• ensure that any actions they authorize, fund, or carry out will not degrade the condition of coral reef ecosystems”

HDOT Harbors projects are primarily funded by the federal government. Therefore, we believe HDOT must redesign its current and future improvement projects and, at a minimum, update its master plan to meet federal funding requirements. Constructing a new Pier 3 at a different location will have cumulative effects on existing and upcoming projects.

Building Pier 3 at its proposed site will destroy at least 5 acres of healthy reefs. To “protect and enhance the coral reef ecosystem,” a less damaging design for Pier 3 could involve a finger pier extending into the harbor basin, starting where Pier 2C is planned. Cities like Honolulu, Hilo, and others in the U.S. have similar piers due to limited space or other reasons. See the following example for the planned design of Hilo Harbor.

The “cumulative impacts” of redesigning and relocating Pier 3 will cause the nearby cargo staging and storage yard to move. This major redesign will likely impact upcoming harbor projects, possibly including this one.

In my professional experience, we prioritize careful planning and design in both private and public sectors. Overlooking proper planning or poor design can result in litigation and financial difficulties for our clients and ourselves. We would never plan or design projects that break local or federal laws. It is especially troubling how HDOT has, for decades, planned to dredge and build a pier over a coral reef without first verifying whether one exists at the proposed site.

According to the HCH Master Plan 2025, Phase 3 improvements, including Pier 3 of Kawaihae Harbor, will cost hundreds of millions of taxpayers’ dollars. We urge HDOT to exercise due diligence and plan carefully.

To understand the purpose of this and future EA reports, we need answers. We appreciate the effort that went into preparing over a hundred pages for the DEA of this project. The information is well organized and thorough. This project is “not in water,” and the findings seem to support that; if BMPs (best management practices) are rigorously implemented, this project would cause minimal harm to the marine environment. Hypothetically, how would an EA statement be prepared for the construction of Pier 3 as planned in the near future? Would the EA findings block construction? Or would that EA just be a formality to rubber-stamp the destruction of another 5 acres of coral reef in the harbor?

Not In-Water

Discussion

We notice that the term “not in-water” is often used in the DEA related to this project. This seems to reassure the public that this and any harbor project labeled with this term would have minimal impact on the marine environment where the harbor is located. However, based on long-term observation, historical evidence, and HDOT Harbors’ culture and attitude, we understand that such reassurance is superficial and insincere.

The decision to dredge the largest coral reef on the island to build a harbor, mainly for the benefit of a few at the expense of many, including the reef ecosystem, will always have a negative cumulative impact on the marine environment.

The reef outside the harbor’s breakwall has not yet recovered since the construction of the harbor began in 1957.

Pelekane Bay, situated at the base of Hawaii’s most important Heiau, is now land.

Soon, a beloved beach in Coral Flats will be replaced by a container yard. The reef beyond this beach, which has survived multiple dredging events in the harbor basin, will be dredged to thirty-five or forty feet to make way for Pier 3. Unless HDOT Harbors chooses a less damaging approach required by law, such as building a finger pier away from the reef.

New 16 acres of reinforced concrete will increase surface water runoff. We understand this by examining how the built environment, like cities, influences flooding. But where will all that water, which can carry pollutants from cargo yards and parking lots (there are always oil patches in any parking space), go if there’s no plan to collect and divert it away from the ocean?

We appreciate that BMPs will be considered and implemented to reduce potential runoff during construction. However, we often see harbor employees spraying herbicide along the same drainage channel that flows directly into the ocean.
The public has “cultural access” to the Coral Flats and surrounding waters, but there have never been restrooms or running water. This raises health concerns for visitors and affects the water quality where they swim. For the past few years, the water supply to public restrooms at the SBHS and the Surf Park has been cut off due to storms like the one in May 2024. Besides the military’s water supply, the rest of the peninsula has been without water. This situation could last up to six months. This is neither comfortable nor efficient for taxpayers who use the facilities and pay for the harbor improvements.

Another issue to consider regarding health and sanitation concerns is that a small number of houseless people live within the harbor and on DLNR property. They are getting by as best as they can, and it is a safe place for them. Stigmatizing them is not acceptable; however, providing public restrooms and running water for washing and bathing is not too much to ask, given the millions of dollars Matson is entitled to in benefits from HDOT Harbors. Investing in your local environment and people is important.

Summary

We sincerely appreciate the opportunity to comment on the DEA and the Harbor as a whole. There is no process for citizens to submit suggestions for basic public amenities, such as restrooms and running water. There is certainly no other way to oppose the destruction of a coral reef and a beach that generations of Hawaiians have enjoyed.

Our main concerns, based on our comments, are as follows:

• The Cumulative Impact per HAR § 11-200.1-2 clearly applies to the construction of Pier 3 in Phase Three of Kawaihae Harbor, as outlined in HCHMP 2035. Phase three is the most expensive part of the harbor projects. Based on the language in this DEA, which explains the purpose and need to grow and expand to improve Matson’s comfort and efficiency, we expect HDOT Harbors to put in the same level of effort to achieve this goal. Without redesigning Pier 3 as a finger pier extending from the proposed Pier 2C and away from the coral reef, HDOT Harbors will destroy 5 acres of that reef, erase a beloved beach, and violate coral protection laws.
• Kawaihae Harbor’s documents or previous EAS often omitted the Kawaihae Reef. However, this DEA acknowledged the role of the coral reef at this harbor but minimized its importance as a cultural and historical resource. The destruction of over 200 acres of coral reef was so extensive that it should not have been overlooked. The location of Pu’ukohola Heiau, next to the reef, was likely intentional, and the harbor could not exist without the reef. Without recognizing the reef’s significance, it would be easier to neglect its conservation and protection.
• The number of Hawksbill sea turtles observed and documented at seventeen since 2019 was not conclusive because these observations were made by us infrequently, maybe three or four times a year. There could be many more that frequent the harbor. The data compiled by Hawaiian Hawksbill Conservation suggest that hawksbill turtles prefer the habitat provided by harbors, both here and in Kona. Other endangered or threatened species were also observed in the harbor basin. The harbor environment acts as a nursery and is also home to larger-than-normal-sized species.

• Storm runoff and flash floods clearly damage infrastructure at both the harbor and the nearby DLNR property. It’s evident that these events have become more frequent in recent years. A road was washed away, and there are no plans to repair it. Pelekane Bay has turned into land. We believe that BMPs should be implemented as part of a comprehensive, long-term plan to better address or reduce these issues, rather than relying on continuous patchwork fixes. This should be a priority project for HDOT Harbors and DLNR.
• Any project at the harbor, whether in water or not, can impact the marine environment and coral reef ecosystems. It all began with the decision to destroy the coral reef at this site. Harbor construction caused irreversible environmental damage. Conversely, the environment—through storm runoff and flash floods—damages the built environment because it is located at the base of deep gulches from the watershed above.
• This project with acres of reinforced concrete will only speed up water runoff into the ocean unless measures are taken to collect and separate pollutants.

Here is our PDF in its entirety.

Public comments on the document are due by May 26, 2026. Comments can be sent to kawaihae@hdrinc.com.

Contact for DEA:
If you have any questions, please contact Ms. Celia Shen, Harbors Planner, Planning Section,
at (808) 587-2013 or via email at celia.y.shen@hawaii.gov. You may also contact our
consultant, Ms. Noelle Besa Wright, of HDR, Inc., at (808) 697-6297 or via email at
kawaihae@hdrinc.com.