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Date: Thursday, June 29, 2023 9:03:43 PM

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Name Your information Kirsten Kagimoto

Title Strategic Communications Manager

Agency or

Organization Sierra Club of Hawaiʻi

Address PO Box 2577

Honolulu US 96803

Email kirsten kagimoto@sierraclub org

Comments

Aloha, 

Thank you for the opportunity to comment on the Red Hill Defueling and Fuel Relocation Draft Environmental Assessment/Overseas Environmental Assessment (“EA/OEA”)

The Sierra Club of Hawai‘i has a long history of protecting our islands’ natural and cultural resources, access to clean water systems, and the health and welfare of our

communities We recognize that the draft environmental assessment for the movement of fuel from the Red Hill Bulk Fuel Storage Facility marks a potential shift towards

greater transparency in Department of Defense operations; however, the Sierra Club of Hawaiʻi expresses its concern regarding a need for the EA/OEA to incorporate the spirit

and directives of Executive Order 12898 (“EO 12898”), in assessing the potential impacts of Alternative #2 on proposed relocation sites and adjacent communities – especially

those that have experienced past exceedances in environmental and public health limits 

While the EA/OEA purports to be consistent with the policy considerations behind EO 12898, further consideration of the environmental justice effects of the proposed

relocation is strongly recommended EO 12898 seeks the achievement of environmental justice by “identifying and addressing, as appropriate, disproportionately high and

adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations ”(1) Accordingly, further work must

be done to ensure that the EA/OEA reflects the full meaning of environmental justice, which includes every individual's explicit right to a healthy environment being freely

exercised, “whereby individual and group identities, needs, and dignities are preserved, fulfilled, and respected in a way that provides for self actualization and personal and

community empowerment ”(2) Given that communities proposed to receive environmentally hazardous fuel under the EA/OEA have been disproportionately burdened by

environmental injustices, including those arising from US military actions and activities, the EA/OEA must assess how these disproportionate burdens may be exacerbated by

the added threats and risks of the proposed movement and storage of fuel 

In addition, an essential component of environmental justice is community engagement, inclusion, and agreement to actions that could place them at disproportionate risk of

harm All such individuals should be entitled to active participation throughout the decision-making process No community should be denied crucial knowledge regarding

projects that exacerbate their vulnerability to environmental impacts, especially when such impacts may be compounded by prior impacts and future threats such as the climate

impacts (3) 

Alternative #2 in the EA/OEA insufficiently assesses and addresses the environmental justice ramifications of its proposal to relocate fuel to existing locations within the DoD

fuel supply chain, to communities that have historically experienced disproportionate harms to their surrounding environment We advise the Navy to consider Alternative #2 as

a sorely needed 

opportunity to acknowledge and assess past and present environmental and subsequent socioeconomic harms, and ways to mitigate any potential exacerbation of such harms -

including but not limited to remedial actions that address the disproportionate burdens that recipient communities have experienced and continue to experience Anything less

than preventative and restorative measures in the relocation plan, with full transparency, outreach, and engagement for destination communities, risks perpetuating and

amplifying existing environmental injustices 

A quick review of proposed sites for receiving fuel in Alternative #2 reveals the following entrenched environmental injustices: 

--West Oʻahu (Campbell Industrial Park): West Oʻahu residents have been subject to health inequities for decades due to poor air and water quality from various “community

disamenities” - including the siting of power facilities and Oʻahu’s primary landfill in the region (which have notably been used to process (burned) and store highly hazardous

military waste) In the recent past, the EPA has also found Campbell Industrial Park facilities to be in violation of the Clean Air and Resource Conservation and Recovery Act

for improper management of hazardous waste (4) The impact is so acute in this area that a study found that the life expectancy estimate of residents in the Waianae zip code to

be ten years less than the rest of Oʻahu;(5) many of these residents are working class communities of color with the highest percentage of Native Hawaiians on the island

Further west, military occupation and use of the Mākua Military Reservation have raised significant concerns about the environmental health impacts of military training in the

area, which has also deprived Native Hawaiians of their physical and spiritual connections with their ancestral lands in Mākua Valley 

From an environmental justice perspective, it should be acknowledged that the historical and present presence of the military in West Oʻahu has riddled the area with

contaminated land and waters, causing physical, spiritual, and cultural harms to people and the environment, and the threat of exacerbating these harms through the potential

storage of fuel in the region must be assessed and mitigated through community consultation and remedial actions 

--Selby, California: Selby most notably houses the Selby Slag, a 66-acre, 2 5 million ton slag pile loaded with toxic heavy metals, a state Superfund site This highly

contaminated stretch of San Francisco Bay waterfront land is laced with huge amounts of health-damaging lead, zinc, copper, arsenic, antimony, cadmium, and nickel (6)

Additionally, there are numerous oil refineries, chemical plants, and steel plants in Selby, practices that are known to be large polluters Further exposure to potential hazards

would potentially exacerbate dwindling resources for this community, and such threats should be assessed and mitigated through community consultation and remedial action

--Puget Sound, Washington: The Puget Sound has experienced a number of environmental issues especially related to the health of their aquatic ecosystems As reported by the

Department of Ecology, industrial activities like agriculture, manufacturing, and wastewater treatment have all contributed to toxic pollution, acidification, and bacterial

pollution in Puget Sound (7) Given that two-thirds of the state’s population lives in the Puget Sound region, assessing the disproportionate risk to these communities in the fuel

relocation process is critical 

--Vancouver, Washington: Vancouver already ranks as one of the cities with the greatest environmental health risks to residents due to lead exposure, proximity to Superfund

sites, diesel emissions, and various air quality issues The EA/OEA must assess the threat of exacerbating these health risks under Alternative #2, as well as options for

mitigating such risks through community consultation and remedial actions 

--Manchester, Washington: The Manchester Fuel Depot is the Pentagon’s largest single fuel station in the US, storing approximately 1 8 million barrels of fuel (8) This site has

confirmed or suspected contamination and is in the state cleanup process under Washington’s Model Toxics Control Act The facility sits on approximately two miles of

shoreline and is separated by a 26-acre tidal lagoon, Little Clam Bay, and a county road The property also contains a perennial stream, Beaver Creek, which runs through the

north end of the facility and various man-made spill containment ponds In June 2023, it was reported that two types of per- and polyfluoroalkyl substances (PFAS) that exceed

an advised environmental standard were detected at Naval Base Kitsap-Manchester in 2022 The surrounding community is awaiting answers for the water tests underway In

the meantime, they must be consulted and options for mitigating the risks of exacerbating their current environmental challenges - including through remedial actions - must be

assessed 

--Sasebo, Japan: Sasebo was a small fishing village militarized by the Imperial Japanese Navy that was later greatly destroyed during World War II and reestablished by the

Allied forces and US Fleet Activities (9) Sasebo remains a US Navy installation today that primarily serves to repair US and Japanese naval ships (10) Navy ship repairs often

require large quantities of hazardous and toxic materials, which, when coupled with the waterfront location of shipyards that provide pathways for potential pollutants to enter

directly into the aquatic environment, are greatly problematic (11) The Sasebo community must be consulted as part of the EA/OEA process and options to mitigate the

exacerbation of existing threats to their environment, health, and welfare must be assessed 

--Port of Singapore: The Port of Singapore is the top maritime capital of the world as well as one of the busiest Emissions from ships as well as other sources of air and water

pollution, noise, odors and visual impact are among the main environmental impacts of the port Community consultation and remedial actions to mitigate additional

environmental threats and impacts must be assessed 

--Subic Bay, Philippines: The legacy of the US military in the Subic Bay is one of toxic waste spilled and pumped into waterways and buried in landfills for decades (12) The

area's inhabitants have experienced toxic pollution and environmental health issues since the 1990s A study in 2000 for the Philippine Senate also linked the toxins to

"unusually high occurrences of skin disease, miscarriages, stillbirths, birth defects, cancers, heart ailments and leukemia (13) Subsistence fishers have been dislocated due to the

pollution to the bay over the past decade Community consultation and remedial actions to mitigate additional environmental threats and impacts arising from the movement and

storage of fuel under Alternative #2 must be assessed 
--Darwin, Australia: Darwin residents have already dealt with years of PFAS contamination as a result of extensive military presence in the port It has been confirmed that

recreational activities should be avoided in the two nearby creeks, which are popular fishing spots, particularly with local Indigenous groups (14) Homegrown produce on

residential properties in the area could pose a health risk because of PFAS concentration in the soil as well Community consultation and remedial actions to mitigate additional

environmental threats and impacts arising from the movement and storage of fuel under Alternative #2 must be assessed 

Given the historical and present environmental injustices at and surrounding the proposed fuel receiving sites, much of which are the result of military activities, the Joint Task

Force-Red Hill and US Defense Logistics Agency is urged to complete a thorough assessment of the impacts of fuel relocation on these sites’ environment and surrounding

communities - including ways in which these injustices may be exacerbated by the threat of fuel movement and storage It is essential that the Navy is transparent in the

relocation process and both assesses and takes restorative or remedial actions to fulfill the spirit and directives of EO 12898, and ensure earnest trust is built with communities

both nationally and internationally Restorative measures should be taken to mitigate any anticipated impacts to ensure that similar detrimental events like the fuel releases and

forever chemical spills at the Red Hill Bulk Fuel Storage Facility do not harm the land, water, and people of any area Importantly, nearby communities that may be subject to

fuel relocation should be notified and meaningfully engaged in the decision making process before the arrival of fuel 

Thank you for the opportunity to submit comments and for providing additional information on the Red Hill Defueling and Fuel Relocation Draft Environmental

Assessment/Overseas Environmental Assessment 

(1)Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Populations, 59 Fed Reg Vol 59 (Feb 16, 1994) 

(2)https://www nmhealth org/publication/view/help/309/#:~ text=Environmental%20justice%20refers%20to%20the,and%20personal%20and%20community%20empowerment

(3)Vecinos para el Bienestar de la Comunidad Costera v FERC, 6 F 4th 1321, 1329 (D C Cir 2018), ruling that the analysis of the project’s impacts on communities would

extend well beyond the project sites 

(4)https://www epa gov/newsreleases/epa-fines-par-hawaii-refining-facilities-over-chemical-safety-hazardous-waste 

(5)https://www cdc gov/pcd/issues/2018/18_0035 htm 

(6)https://www sunflower-alliance org/comment-on-selby-slag-remediation-april-12/ 

(7)https://ecology wa gov/Water-Shorelines/Puget-Sound/Issues-problems 

(8)https://www kitsapsun com/story/news/local/2017/12/05/manchester-fuel-depot-plans-replace-wwii-era-underground-storage-tanks/915357001/ 

(9)https://www pearlharborhistoricsites org/blog/sasebo 

(10)https://www navsea navy mil/Home/RMC/SRF-JRMC/Japan-Tours/WorkingInJapan/SRFJRMCSaseboOperations/ 

(11)https://www oecd org/sti/ind/46370308 pdf 

(12)https://globaldale files wordpress com/2011/11/toxic_wastes_facts-figures-nov-12-2011 pdf 

(13)https://mandalaprojects com/ice/ice-cases/subic htm 

(14)https://www theguardian com/australia-news/2017/jul/27/seafood-in-popular-darwin-fishing-spots-contaminated-by-toxic-foam

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From: noreply@dma.mil

To: JTF-RH NEPA

Subject: Form

Date: Friday, June 30, 2023 2:07:21 PM

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Name Your information Marti Townsend

Title

Agency or Organization Earthjustice

Address 850 Richards Street

Honolulu US 96813

Email mtownsend@earthjustice.org

Via Webpage Submission 

Commander Mark Sohaney 

Joint Task Force Red Hill 

1025 Quincy Avenue, Suite 900 

Joint Base Pearl Harbor-Hickam, HI 96860 

https://www.pacom.mil/JTFRed-Hill/NEPA-Comment/ 

Re: Response to request for public comment regarding the Draft

Environmental Assessment/Overseas Environmental Assessment

for Red Hill Defueling and Fuel Relocation 

Dear Commander Sohaney: 

Earthjustice Mid-Pacific (“Earthjustice”) submits these comments

in response to the public comment period announced by the Joint

Task Force – Red Hill (“JTF-RH”) on June 9, 2023. Earthjustice

is a non-profit environmental law firm that has been working in

Hawai’i since 1988 to protect the island’s natural and cultural

resources. Since then, Earthjustice has led campaigns that have

ranged from safeguarding human health and to holding the

military and state actors accountable for damage to Hawai’i’s

imperiled environment. 

The Red Hill Bulk Fuel Storage Facility (“RHBFSF”) is the

military fuel facility that contaminated Oahu’s sole source aquifer

and the primary source for drinking water for a majority of the

island. Over the course of its near-80 years of operation, RHBFSF

has released at least 200,000 gallons of jet fuel into the

environment. In 2021, a series of fuel leaks released at least

19,000 gallons of fuel into the Navy’s drinking water system,

which serves 93,000 people. Many residents reported significant

health symptoms after exposure to the contaminated water; for
Comments

some the health impacts have not dissipated. The State of Hawai’i

Department of Health, Environmental Protection Agency, and the

United States Secretary of Defense understood the urgency and

respectively required the Navy to defuel the facility’s storage

tanks. 

The DEA presents actions for the Red Hill Defueling and

Relocation project (“defueling project”) that would purportedly be

executed in a “safe and expeditious manner.” However,

Earthjustice raises certain questions regarding the extent to which

the proposed actions are safe and expeditious and whether safer

and more expeditious actions are available. 

A. The DEA fails to explore certain alternatives that pose less

risks to the environment as well as alternatives that could further

expedite the defueling project. 

The DEA presents the following alternatives: (1) “No Action

Alternative,” (2) “Relocation,” and (3) “Commercial Sale and

Relocation.” These alternatives preserve the fuel by either selling

the fuel to Joint Base Pearl Harbor-Hickam, transporting the fuel

to various Department of Defense (“DoD”) fueling points, or a

combination of transporting a portion the fuel to the DoD fueling

points and the commercial sale of the remaining portion.

Additionally, the DEA lists alternatives that were considered but

not given a full analysis. Of the eight alternatives listed, there is

no alternative for disposing of the fuel. 

Disposing the fuel may seem similar to the alternative already

considered and dismissed in the DEA related to donating the fuel.

The DEA dismissed the donation alternative because “donating

fuel from RHBFSF would not be an efficient or financially-sound

practice.” (DEA at 2-6.) However, disposal of the fuel could still

be an efficient and financially-sound practice for removing the

risk of fuel over the water supply. Given the scale of relocation

efforts, involving eleven tanker ships and a multitude of personnel

assigned to each step of the process, eliminating the fuel in

RHBFSF or at a nearby location could be a more cost-effective

alternative than the relocation alternative and the commercial sale

and relocation alternative. Moreover, the disposal alternative

reduces the risk of fuel leaks, reduces the emissions associated

with transporting the fuel overseas, and could be completed

within a shorter timeframe than relocation and commercial sale

and relocation. 

The DEA also neglects the alternative of storing the fuel in

commercial tankers. Storing the fuel in commercial tankers is

similar to the no action alternative as it stores the fuel on island

for what may be an extended time period. The DEA dismisses the

no action alternative as a viable alternative because it “does not
expeditiously defuel RHBFSF as it could take as long as fourteen

months to execute.” (DEA 2-2, emphasis added.) The commercial

tanker alternative is different from the no action alternative as it

may still meet the purpose and need for the Proposed action

because industry demand will not dictate how long the fuel will

stay in RHBFSF. The fuel in RHBFSF will be transferred to the

commercial tankers, which would mark the completion of the

plan. Transferring the fuel to commercial tankers could be a more

expeditious and environmentally sound process than the

relocation and the commercial sale and relocation alternatives

because it will not include the additional step of transporting the

fuel to locations within the DoD fuel supply chain. 

B. The DEA fails to provide adequate details on the process and

procedures for leak checks. 

RHBFSF has a long history of accidental fuel releases due in

large part to the facility’s age, complexity, and poor maintenance,

as well as insufficient training, experience, and overall expertise

of the personal operating the facility. The DEA acknowledges that

“[t]he chief environmental concern related to water resources is

the potential for fuel spills at any point in the process, where fuel

could potentially further contaminate water resources, including

drinking water sources.” (DEA 3-7.) Given this overriding

concern, the DEA should properly detail best management

practices to avoid fuel spills and discuss mitigation measures for

fuel spills that may occur away from fueling piers or receiving

locations. 

Although each alternative of the defueling plan involves removing

the fuel and transporting the fuel through an existing DoD

pipeline system, the DEA discusses fuel spills primarily in the

context of defueling from RHBFSF tanks and pipelines, the

pipeline in the underground tunnel connecting RHBFSF to the

UGPH, the Joint Base Pearl Harbor-Hickam, fuel receiving

locations, and at the fueling pier. The DEA claims that large fuel

spills from RHBFSF facilities and the underground pipeline could

potentially lead to water contamination, but that fuel spills would

be highly unlikely given the mitigation measures included in the

defueling plan. Additionally, the DEA provides best-management

practices to “[p]revent spread of potential fuel spills at the pier.”

(DEA 2-7.) This subset of practices included “[r]overs and/or

watch standers” who “would be on the pier to inspect and perform

leak checks.” (DEA 2-7.) The EA lacks important detail on how

the watch standers will operate, including methods or frequency

of leak checks. The DEA must clarify, among other details,

whether these leak checks will only be executed with visual

checks, whether multiple personnel will be used to ensure the

accuracy of the checks, and how often the leak checks will be

performed. 
The DEA dismisses the possibility of water contamination as a

result of fuel spills from the above-ground piping. The DEA

minimizes the significance of above-ground piping to the

project’s environmental consequences as “[t]he only aboveground piping along the route occurs after the UGPH for

approximately 700 ft. along a largely paved area that is 900 ft.

from the harbor.” (DEA 3-10.) The DEA does not provide a bestmanagement practice or mitigation measure that addresses this

possibility, which may seem remote, but could be significant if

fuel escapes from this area. 

C. Conclusion 

In sum, Earthjustice has serious concerns regarding the DEA’s

dismissiveness of certain action alternatives and possible harms

for the Proposed Action. The potential for significant health

impacts after previous instances of contamination necessitates full

and meaningful analysis of impacts. We look forward to proper

disclosure of the project’s methods and mitigation measures in

future environmental review documents. If you would like to

discuss these comments further or have any questions, please feel

free to contact me by email at mtownsend@earthjustice.org or by

telephone at . 

Sincerely, 

/s/ Marti Townsend 

/s/ Cresencia Meno 

EARTHJUSTCE

--------------------------

Ref Id: p1wweUm5CUq6qzTZgqMw9g 

(b) (6)

Comments

Hawaiian lands and waters, it is absolutely critical that the U.S.

military conduct itself with the highest level of respect and

transparency.” 

3-10) If in July 2020, DOH listed both Pearl Harbor units (estuary

and marine waters/Mamala Bay) for failing to attain water quality

standards, there should be a laid-out standard how visual

inspection of waters upon defueling will take place.

Turbidity/sediment is already an issue in this area. 

3-33) In past 3 years, overfilling a vessel has resulted in ~5 gal.

spilled & pipeline failure ~100 gallons, but does this include the

issue at Hotel Pier beginning in March 2020? If a total of 7,700

gallons were reportedly “recovered” from Mar 2020-Jul 2021,

how can the public be assured of what was actually released into

the environment? 

3-35) National Emission Standards for hazardous air pollutants

(HAPs) were implemented for marine loading terminals that

ONLY load crude oil or gasoline, NOT kerosene, which is the JP5 classification. EPA should hold Navy accountable to these same

HAP standards for this particular fuel movement in efforts to

align & streamline with the Clean Air Act. 

3-41) Since VOCs can be released as “fugitive emissions” from

vessel during loading & transit, how is it possible for these to be

measured? 

4-3) This overview of the issues at Hotel Pier is not inclusive. For

this to be the pier to take on the sole task of ALL defueling, this is

where the biggest concern lies. 

-On 17 Mar 2020, petroleum was observed and kept going for

(22) days until it “stopped on its own” (not by a concerted

resolution), but resumed on 2 June 2020. (quote from Honolulu

Civil Beat 8 Oct 2021 article) 

-This fuel was originally thought to be from historical plume, but

upon Dec 2020 investigation (albeit only AFTER a 30 June 2021

letter from DOH requesting to do so), it was found to be “unweathered” a.k.a. fresh JP-5 from leaking underground pipeline. 

-With this track record of the inability to identify & stop leaks,

how can we trust that the same won’t continue? 

-As of Jan 2021, the pipeline at Hotel Pier failed (2) leak

detection tests and DOH did not find this out until May 2021. Any

leak detection test results must be reported to DOH immediately. 

-Even after a Feb 2, 2021 site visit from contractor PENCO

“almost immediately” confirmed an active leak, Navy’s stance

STILL was not to acknowledge Red Hill pipeline was source of

the leak. This oil spill cleanup company was later hired—was

their job even completed? 

-“The Navy continues to perform work to recover residual oil
from the ground, mitigate migration of oil to the water, and

recover any oil that does reach the water”—How could the

operators even tell the difference between a potentially still active

Hotel Pier pipeline leak and upcoming defueling issue? How can

the public trust that Hotel Pier isn’t a readymade scapegoat? 

Thank you to all those who worked tirelessly on this report. There

is a ton of information here about endangered species and

overseas/port details that were incredibly helpful.

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From: noreply@dma.mil

To: JTF-RH NEPA

Subject: Form

Date: Tuesday, June 20, 2023 3:54:12 PM

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Name Your information

Title

Agency or Organization

Address

US 

Email

Comments

The Red Hill facility should be completely shut down and all

equipment dismantled and removed to include the transportation

pipes from the site. Furthermore, a full environmental cleanup

should be completed as multiple spills have occurred over the

years at the site into the soil which has already impacted the

watershed and water supply of the surrounding area and has the

potential to continue to contaminate surrounding water sources as

the contaminants spread through the aquifer. The only way to

fully decontaminate the site is to fully dismantle and remove the

structures and equipment first. Re-use is not an option and should

not be considered as material left in place will prevent full clean

up in accordance with federal law.

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