Posted by: lokahipath | January 24, 2011

Cultural Impact Assessment Request

January 24, 2011

Hope Kallai
Malama Moloa`a
POB 655
Kilauea, HI 96754

Jeffrey Pantaleo,
Cultural Resources Specialist
United States Department of Agriculture (USDA)
Natural Resources Conservation Service (NRCS)
Pacific Islands Area State Office
P.O. Box 50004
Honolulu, HI 96850-0050

Re: Cultural Impacts
EQIP Brush Management Project 08021
Paradise Ranch, LLC/Waioli Corp
Lepeuli, Kauai

Aloha e Mr. Pantaleo:

We are very concerned about the impacts to significant cultural resources by this federally funded EQIP Brush Management project for commercial cattle pasture expansion on Waioli Corp lands in Lepeuli, Kauai (also known as Larsen’s Beach) managed by Bruce Laymon, Paradise Ranch, LLC. This project is designed to “enhance the vigor of the native plant community – by removing alien invasive plants that reduce the wildlife habitat integrity. Species to be benefited – beach Naupaka”!!!!

The ahupua`a of Lepeuli was home to several hundred Hawaiians for many hundreds of years. The area is an important navigational vortex with celestial pa and sunrise lookout points and was home to ali`i and lesser chiefs of the Kamehameha lineage (post 1819).

Lepeuli and the Ka`aka`aniu Reef fronting the entire ahupua`a, was the most intensively managed and documented marine resource in Hawai`i Nei, known for the abundance and quality of limu kohu (Asparagopsis taxiformis). Tons were consumed for hundreds of years; tons were sold in the markets of Honolulu Chinatown for many years; many present-day Hawaiians only eat limu kohu from Ka`aka`aniu. Harvest and utilization of limu is core to the traditional Hawaiian diet. Ka`aka`aniu Reef is still an important subsistence and sustenance fishing and gathering area to many cultures, ages and classes of people because of the quality of the reef.

Lepeuli is critical reproductive habitat for `Ilio-holo-i-ka-uaua, the endangered Hawaiian monk seal (Monachus schauinslandi), important for pupping and rearing areas. Four out of 5 pups born on Kauai in the last years were born at Lepeuli. The habitat importance of this seal nursery area will increase with global sea rise in the Northwestern Hawaiian Islands. Females born at Lepeuli are returning to pup at Lepeuli.

Lepeuli also is known nesting area for honu, the threatened green sea turtles (Chelonia mydas); moli, the Laysan albatross (Phoebastria immutabilis); and `ua`u kani, the wedge-tailed shearwaters (Puffnus pacificus). All of these are ground nesters and will be extirpated from this site by cattle trampling on them, as will the native plant community, including one of the largest ulei, the Ko`olau Rose (Osteomeles anthyllidifolia), stands on Kauai.

Lepeuli has significant archaeology, known human burials, concentrations of kuleana (both houselots and agricultural sites), important trails and cultural byways, significant plantation history, historic schools, historic churches and stores – all with potential to be negatively impacted by this federally funded commercial cattle project.

The lateral coastal Alaloa, State Historic site 50-30-04-1034, has been surveyed in adjacent Moloa`a Bay Ranch. It is ancient, and went around the whole island of Kauai like a lei. It has been identified in the Waipake ahupua`a, contiguous to the west. Kuleana filings document and delineate access throughout these coastal ahupua`a on a lateral trail through Lepeuli. Federal funds are being used to close off this trail (that has always been open) by the location of this fence. Why? How?

The State of Hawaii DLNR State Historic Preservation Division has relocated the skeletal remains of three individuals (from their traditional resting place by the beach) upslope in Lepeuli, into the area intended for commercial cattle pasture. (!) This is unconscionable. Applicant and his attorney have neglected to perform any cultural impact assessment or provide a Burial Treatment Plan for these human remains. This area must be fenced off ASAP. More human remains are to be expected. The large NW swells of December, 2010 exposed a significant archaeological site in coastal Lepeuli. The UH Manoa Archaeological Field School was able to collect charcoal for radio-carbon dating. Preliminary age dates have confirmed that this is a pre-contact site, dating to 1600 B.C.E., with amazing stratigraphy. Many rock walls, auwai and other features are visible throughout the makai portion of the ahupua`a. This was a significant pre-historic Hawaiian community and is in remarkable preservation currently.

Lepeuli has experienced significant Big Wave Events, like tsunami. There have been at least 3 events with over 30’ waves that have hit Lepeuli since the 1860’s, with run-ups of over 750’. There has been significant erosion, as documented by USGS and the Smithsonian, yet applicant claims NONE. There has not been a certified shoreline in over 30 years.

This project is full of errors, misstatements and inconsistencies on the applications. A Kauai county SMA was issued based on some of these inconsistencies. The additional information and corrections sent to the state of Hawaii for CDUA 3525 was reviewed for over 6 months yet this new data has not been included in the federal NRCS Conservation Plan or the county SMA permit. The applicant only considered the impact of the installation of T posts (for barbed wire) and about 6 inches around the fence as the area of impact, not the secondary and cumulative impacts of the conversion of native coastal habitat into commercial cattle grassland. I believe federally funded projects must consider Secondary and Cumulative impacts, such as erosion, nutrification of the reef, cessation of traditional culture and diet, elimination of pupping habitat, cattle trampling seabirds, increased foot traffic on the beach from trail closure, loss of history before any impacting action.

The Paradise Ranch EQIP Project has not been given proper scrutiny under the National Historic Preservation Act of 1966, and the National Environmental Policy Act (NEPA). This federally funded project causes disparate environmental injustice to specific races and economic classes of people. The proverbial HARD LOOK must be taken on this project, by rational minds of science, not attorneys. We cannot erase our history to put cows on steep coastal scarps. Locating cattle on 20 steep highly erodible acres at the cost of precious resources (especially since the project has 600 flat acres) is ridiculous and contrary to the mission of NRCS.

Can you please tell me how a rational Cultural Impact Assessment can be performed on this project, antecedent to any more impacting actions? Why are federal funds being used to close off an ancient public trail? If you are not the correct person, could you please recommend someone who could take a serious look at this crazy project? Please contact me if you need any further information or would like to take a look at this project site. Mahalo piha for your time and consideration.


Hope Kallai



%d bloggers like this: