FINAL

ENVIRONMENTAL ASSESSMENT/

OVERSEAS ENVIRONMENTAL ASSESSMENT

FOR

RED HILL DEFUELING AND FUEL RELOCATION

JOINT BASE PEARL HARBOR-HICKAM, 

OAHU, HAWAII

AUGUST 2023
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Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

Abstract -i

ABSTRACT

Designation: Environmental Assessment/Overseas Environmental Assessment

Title of Proposed Action: Red Hill Defueling and Fuel Relocation

Location: Joint Base Pearl Harbor-Hickam (JBPHH), Oahu, Hawaii

Affected Region: City and County of Honolulu, Oahu, Hawaii

Lead Action Proponent: Commander, Joint Task Force Red Hill

Co-Action Proponent: Defense Logistics Agency

Point of Contact: Naval Facilities Engineering Systems Command (NAVFAC) Pacific

Environmental Planning Division (EV2)

Attn: Jill Sears

258 Makalapa Drive, Suite 100

Pearl Harbor, Hawaii 96860-3134

Date: August 2023

The Joint Task Force Red Hill (JTF-RH) and Defense Logistics Agency (DLA) have prepared this 

Environmental Assessment/Overseas Environmental Assessment (EA/OEA) in accordance with the 

National Environmental Policy Act (NEPA), Executive Order (EO) 12114, and Council on Environmental 

Quality (CEQ) and Department of Navy regulations. The Proposed Action is the gravity-based defueling of 

the Red Hill Bulk Fuel Storage Facility (RHBFSF) and relocation of flowable fuel by tanker ship.

This EA/OEA evaluates the potential direct, indirect, and cumulative environmental impacts of the Proposed 

Action on the human environment, including to: public health and safety, water resources, marine biological 

resources, hazardous materials and waste, air quality and greenhouse gases. In accordance with EO 12114 

and the Department of Defense’s implementing regulations in 32 Code of Federal Regulations (CFR) Part 

187, this EA/OEA evaluates the potential for significant environmental harm from the Proposed Action

alternatives in ocean waters beyond the territorial limits of the United States (U.S.).

Reader’s Note:

JTF-RH and DLA honor native Hawaiian culture and respect the importance of diacritical marks in clarifying 

pronunciation and meaning in the Hawaiian language. However, to ensure functionality of reading 

assistance technology, this document does not apply diacritical marks to text.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

Abstract -ii

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Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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EXECUTIVE SUMMARY

ES.1 Proposed Action

The Proposed Action is the gravity-based defueling of Red Hill Bulk Fuel Storage Facility (RHBFSF) 

underground storage tanks and associated pipelines, and relocation of the flowable fuel by tanker ship.

This Environmental Assessment/Overseas Environmental Assessment (EA/OEA) addresses gravity-based 

defueling of the RHBFSF at Joint Base Pearl Harbor-Hickam (JBPHH) and relocation of the flowable fuel 

to other United States Department of Defense (DoD) fuel supply locations in the Pacific region or sale of 

the fuel to commercial entities utilizing DoD contracting authorities. The Joint Task Force Red Hill (JTF-RH) 

and Defense Logistics Agency (DLA) prepared this EA/OEA pursuant to the National Environmental Policy 

Act (NEPA), as amended (42 United States Code [USC] section 4321 et seq.) and its implementing 

regulations issued by the Council on Environmental Quality (40 Code of Federal Regulations [CFR] Part 

1500 - 1508) and Executive Order (EO) 12114.

ES.2 Purpose and Need for the Proposed Action

The purpose of the proposed gravity-based defueling action is to comply with State of Hawaii Department 

of Health (DOH) Emergency Orders (DOH, 2021a; DOH 2022a), the Environmental Protection Agency 

(EPA) 2023 Administrative Consent Order (EPA, 2023f), and U.S. Secretary of Defense (SECDEF) Lloyd 

J. Austin III’s order on March 7, 2022 to defuel and permanently close the RHBFSF (DoD, 2022A).

Defueling RHBFSF is needed to protect local water supplies from further contamination. Additionally, the 

DoD needs to defuel the facility as a first step in the process of full closure and remediation of RHBFSF.

ES.3 Alternatives Considered

The JTF-RH and DLA developed alternatives for safe defueling and relocating the fuel for analysis based 

upon the following reasonable alternative screening factors:

1. Defueling must occur in a safe and expeditious manner in accordance with: DOH Emergency 

Order of 6 December 2021; SECDEF Memo of 7 March 2022, DOH Superseding Emergency 

Order of 6 May 2022; DoD Defueling Plan of 1 June 2022; DoD Defueling Plan Supplements 1A

and 1B of 7 and 28 September 2022; and DoD Defueling Plan Supplement 2 of 16 May 2023.

2. Defueling operation must not unduly burden the Oahu commercial fuel supply chain.

3. Transfer of fuel from RHBFSF to the fuel loading pier must occur through DoD‐owned, existing 

infrastructure.

4. Fueling transfer from RHBFSF must not utilize public roadways to minimize traffic impacts and 

reduce risk of accidents and spills.

5. Fuel tanker loading must occur at an operational pier that can accommodate a tanker ship, and 

has existing infrastructure to accommodate F-76, JP-5, or F-24 fuel types.

6. If fuel is relocated for DoD use, it must be directed to locations within the DoD fuel supply chain 

with infrastructure to safely offload and store fuel in the type and quantity needed by the DoD at 

the time of defueling. 

7. Relocation and/or commercial sale of fuel must be both economical and a responsible use of the 

taxpayer’s resources.

JTF-RH and DLA are considering two action alternatives that meet the purpose and need of the Proposed 

Action and a No Action Alternative. Both the No Action Alternative and the two action alternatives utilize 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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existing infrastructure at RHBFSF and JBPHH to remove the fuel from RHBFSF and load it onto tanker 

ships. The No Action Alternative and the two action alternatives would include removal of flowable fuel from

the associated pipelines (i.e., unpacking). Removal of residual amounts of fuel products that do not flow 

under the force of gravity, such as sludge (unrecoverable tank bottoms) and any fuel within low points of 

the facility and pipelines, would occur after the gravity-based defueling stage, and is not included in the 

scope of environmental analysis of this EA/OEA. RHBFSF will transition to DoD’s closure phase after the 

gravity-based defueling stage. 

Alternative 1, the No Action Alternative, is the distribution of flowable fuel from RHBFSF to JBPHH

customers at regular demand rates for routine use. This alternative would ultimately remove all flowable 

fuel from RHBFSF because it would not receive any re-supply of fuel. Under the No Action Alternative, 

flowable fuel would remain in the tanks at RHBFSF for approximately ten to fourteen months after DOH 

approval of the gravity-based defueling operation.

Alternative 2 is the relocation of the approximately 106 million gallons of flowable fuel from RHBFSF to 

existing locations within the DoD fuel supply chain by ocean transit. The fuel removal operation involves 

gravity flow of the fuel from RHBFSF through existing DoD piping and associated infrastructure to a fuel 

loading pier at JBPHH. A maximum of eleven refined product tanker ship transits are required to receive 

and transport the flowable fuel from RHBFSF. After exiting Pearl Harbor, tanker ship transits one through 

ten would transit within existing commercial shipping lanes to one or more (up to nine) existing DoD fuel 

support points throughout the Pacific. The fuel deliveries to these locations would occur in lieu of routine or 

planned fuel supply deliveries.

Potential receiving locations (Figure ES-1) for the ten fuel deliveries include: 

• Campbell Industrial Park, West Oahu, Hawaii

• Point Loma, California 

• Selby, California

• Vancouver, Washington

• Manchester, Washington 

• Sasebo, Japan 

• Subic Bay, Philippines 

• Port of Singapore

• Darwin, Australia 

The quantity of fuel and number of deliveries to each location depends on DoD fuel inventory needs at the 

time of defueling. For planning and analysis purposes, the EA/OEA evaluates an upper bound, or maximum 

number, of transits for each receiving location (see Section 2.3.2 in the EA/OEA).

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of flowable fuel 

from RHBFSF combined with the relocation of the remaining portion of the fuel to existing locations within 

the DoD fuel supply chain by ocean transit. A maximum of eleven tanker ships would be required to receive 

and relocate the flowable fuel from RHBFSF.

With Alternative 3, up to ten tanker loads of fuel from RHBFSF may be commercially sold in accordance 

with Section 2922e of Title 10, United States Code, which authorizes the sale of certain fuel sources. Sale 

of fuel would need to coincide with defueling schedule. Therefore, the amount of fuel sold would be 

determined by commercial interest and purchasers’ ability to receive the fuel at the time of gravity-based 

defueling. The portion of fuel that is not sold would be relocated from RHBFSF to existing locations within 

the DoD fuel supply chain by ocean transit. Relocation of fuel would be accomplished using the same 

process as Alternative 2. Potential DoD fuel supply chain receiving locations and maximum number of 

tanker transits to each location are the same as Alternative 2.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Figure ES-1. Location of Potential Fuel Receiving Sites

Under both Alternatives 2 and 3, an eleventh tanker or barge would be staged at the JBPHH fueling pier 

for approximately two to five weeks to receive flowable tank bottoms and fuel from the underground surge 

tanks and pipeline unpacking process (estimated to be 2 million gallons of fuel or a portion thereof). Fleet 

Logistic Center, Pearl Harbor (FLC) would sample and test this fuel to determine whether it meets 

specifications for DoD requirements and it would then be sold or relocated.

All three alternatives incorporate Best Management Practices (BMPs) for the safe transfer and relocation 

of fuel from RHBFSF that reduce potential environmental impacts by avoiding, minimizing, or eliminating 

impacts. These BMPs are described in Section 2.5 of the EA/OEA.

ES.4 Summary of Environmental Resources Evaluated in the EA/OEA

The process for identifying resources analyzed in this EA/OEA is summarized in Section 3, Introduction, of 

the EA/OEA. Resources relevant to the Proposed Action and analyzed in detail include:

• Public Health and Safety

• Water Resources

• Marine Biological Resources

• Hazardous Materials and Waste

• Air Quality and Greenhouse Gases
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Resources that were not analyzed in detail are also described and explained in the introduction to Section 

3 of the EA/OEA.

ES.5 Summary of Potential Environmental Impacts of the Action Alternatives 

and Major Mitigating Actions

Public Health and Safety. A minimal increase of demand for emergency services may result from the 

addition of approximately ten workers per shift during the defueling and tanker ship loading operations with 

Alternatives 2 and 3. Demand would be extremely small and not likely to have measurable impacts to 

existing service capacity. Tanker loading would be accomplished by a team of trained military and civilian 

workers from FLC and Port Operations. Common workplace hazards associated with this type of maritime 

work include slips, trips, and falls, machinery and equipment hazards (e.g., hoist), exposure to hazardous 

chemicals, and fire hazards (OSHA, 2023). The use of BMPs, training, and adherence to occupational 

safety and health regulations, standards, and instructions would reduce the likelihood and severity of a 

potential workplace accident.

Alternatives 2 and 3 would add up to four vessel movements per week (i.e., two round-trip transits) in Pearl 

Harbor. The additional vessels would account for an approximate ten percent increase in vessel traffic 

during the defueling operation. BMPs including notifying the Harbormaster in advance of tanker 

arrival/departure, maintaining communications with the Harbormaster, and use of tugboats to assist tankers 

would reduce the risk of vessel accidents. Overall, with the use of BMPs and adherence to procedures, 

Alternatives 2 and 3 would have less than significant effects to public health and safety.

Water Resources. The potential for spills within the RHBFSF, pipelines, and Underground Pump House 

(UGPH) during the defueling operation would be reduced through the repairs and training described in 

Section 3.2.1.3 of the EA/OEA. While there is no evidence of ongoing releases of fuel from the RHBFSF to 

the environment, the potential exists for possible releases to occur for a longer period of time (ten to fourteen

months) with the No Action Alternative than with Alternatives 2 or 3, which would defuel the tanks in 

approximately three to four months from the time DOH authorizes defueling. Essentially, the No Action 

Alternative would extend the period of time where fuel resides in the tanks, where it could pose additional 

threat to the groundwater and drinking water quality. Under Alternatives 2 and 3, use of tanker ships may 

marginally increase potential for spills to affect marine waters around Oahu, in international waters, and at 

receiving locations. Vessel fueling at the JBPHH pier would follow standard operating procedures and 

BMPs (including spill response procedures and training) to reduce the risk of spills. Statistically, the historic 

spill rate worldwide for tanker ship spills is 0.0005 percent. Although rare, a tanker ship spill has the potential 

to be a high-volume, extended duration (i.e., catastrophic) release of fuel into to the marine environment. 

Tanker ships would be double-hulled in accordance with the International Convention for the Prevention of 

Pollution from Ships (MARPOL) which reduces the potential for spills from accidental grounding and 

allision/collision. Tanker operators are required to follow applicable environmental and safety regulations 

which further reduces the likelihood of catastrophic spills. Fuel deliveries to receiving locations would be in 

lieu of regular deliveries, resulting in no overall risk increase from fuel unloading. Overall, with the use of 

BMPs for tanker fuel transfer/loading and adherence to provisions of the DOH order, Alternatives 2 and 3

would have less than significant effects to water resources.

Marine Biological Resources. Potential stressors to marine biological resources from the Proposed Action

include elevated underwater noise from vessels and vessel collisions with marine species. Although not 

considered reasonably likely to occur, the risk of a fuel spill was also considered. The temporary, lowfrequency and lower intensity sound levels of the tanker ships that would be used for Alternatives 2 and 3

would not result in an increased likelihood of acoustic injury to marine mammals, sea turtles, or fishes. 

Sound levels would not significantly disrupt breeding, feeding, or sheltering for any Endangered Species 

Act (ESA) listed species encountered. The likelihood of a vessel collision with a protected marine species 

is extremely remote because of the low probability that individual animals would overlap in space and time 

with the eleven one-way tanker transits. Additionally, the relatively slow speed of the vessels further reduces 

the chance of ship strike with marine mammals, sea turtles, and fishes. Vessels would employ measures 

to avoid and reduce the potential for vessel collisions and interactions with protected species (Table 2.5-1, 

BMP-11). A tanker spill during transit has a low probability of occurrence, and the response teams and 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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BMPs available at all ports (e.g., equipment maintenance protocols, contingency plans, fueling restrictions) 

further reduce the potential for a spill during fuel loading and unloading. Overall, with the use of BMPs, 

Alternatives 2 and 3 would have less than significant effects to marine biological resources. 

Hazardous Materials and Waste. In the event of a fuel release, workers could be exposed to the fuel 

during incident response and spill cleanup activities. JBPHH has spill response procedures to address 

potential spills and to limit their effects to human health and the environment. Spilled fuel and contaminated 

absorbents or debris would be managed in accordance with the waste management plan. Propeller wash 

from tanker ships and tugboats could temporarily resuspend contaminated sediments in Pearl Harbor. 

BMPs limiting the disturbance of sediments, including low ship speed and use of tugboats to assist tanker 

ships through Pearl Harbor, would minimize environmental exposure to the extent that no significant 

adverse effects related to contaminated sediments are expected to occur. With the use of BMPs, 

Alternatives 2 and 3 would result in a less than significant increase to the potential for human or 

environmental exposure to hazardous materials or waste.

Air Quality and Greenhouse Gases. Emissions from tanker ship transits would be temporary and would 

not significantly affect air quality at JBPHH or any of the receiving locations. Ports in California (Point Loma 

and Selby) are non-attainment for some air pollutants. However, emissions at those sites would fall below 

de minimis levels and Records of Non-Applicability for Clean Air Act General Conformity are provided in 

Appendix E of the EA/OEA. Tanker ship operators would follow the MARPOL regulations for low sulfur fuels 

and the lower sulfur content fuels required within 200 nautical miles of the U.S. pursuant to the North 

American Environmental Control Area. Under the minimum transit case, the action would emit 13,994 tons

of greenhouse gases (GHGs). Under the maximum case, the action would emit 50,792 tons, equivalent to 

the annual operation of 6,429 U.S. homes. Anticipated air quality impacts from Alternatives 2 and 3 are not 

expected to interfere with the attainment of National Ambient Air Quality Standards (NAAQS), hinder a 

nonattainment area’s progress to attainment, increase the frequency or severity of existing poor air quality, 

or appreciably increase human health risks from hazardous air pollutant (HAP) exposure in areas where 

sensitive receptors and/or public presence are expected.

Table ES-1 provides a tabular summary of the potential impacts to resources associated with each of the 

alternative actions analyzed.

Table ES-1. Summary of Impacts

Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

Public Health and 

Safety

There may be a small 

increase in vessel traffic in 

Pearl Harbor if JP-5 stock 

rotation was required due to 

low demand for JP-5 fuel at 

JBPHH. This would result in 

a negligible increase in 

vessel traffic. The No Action 

Alternative would have no 

significant adverse effects

on public health and safety.

A minimal increase of 

demand for emergency 

services may result from the 

addition of approximately 

ten workers per shift during 

the defueling and tanker 

ship loading operations.

The additional tanker ships 

entering Pearl Harbor would

account for an approximate 

ten percent increase in 

vessel traffic during the 

defueling operation. 

Overall, with the use of 

BMPs and adherence to 

procedures, Alternative 2 

would have less than 

significant adverse effects to 

public health and safety.

Effects would be the same 

as Alternative 2.
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Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

Water Resources Defueling would occur over 

a longer period of time than 

Alternative 2, which could 

pose additional threat to 

groundwater and drinking 

water sources should 

releases from RHBFSF 

occur. Completed repairs to 

RHBFSF and use of BMPs 

for fuel transfers would 

reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 1 would have 

less than significant effects 

to water resources.

Defueling RHBFSF 

expeditiously would reduce 

potential for system 

releases that could further 

adversely affect local 

groundwater and drinking 

water supplies. Relocation 

of fuel via tanker may 

marginally increase potential 

for spills affecting marine 

waters on Oahu, 

international waters, and 

receiving location water 

bodies. Statistically, 

occurrences of catastrophic 

spills from oil tankers are 

low (0.0005 percent spill 

rate). Propeller wash from 

vessels at ports could cause 

short-term suspension of 

sediments, causing 

localized turbidity that would 

settle within days. 

Completed repairs to 

RHBFSF and use of BMPs 

for fuel transfers would 

reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 3 would have 

less than significant effects 

to water resources.

Effects would be similar to 

those under Alternative 2. 

Defueling RHBFSF via 

commercial sale would 

occur over a similar 

expeditious timeframe as 

Alternative 2, reducing 

potential for releases that 

could adversely affect local 

groundwater and drinking 

water supplies. 

Commercially-operated 

tanker ships would adhere 

to international maritime

safety and environmental 

regulations that reduce 

potential for catastrophic 

spills at ports and at sea. 

Propeller wash from vessels 

at ports could cause shortterm suspension of 

sediments, causing 

localized turbidity that would 

settle within days. 

Completed repairs to 

RHBFSF and use of BMPs 

for fuel transfers would 

reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 3 would have 

less than significant effects 

to water resources.

Marine Biological 

Resources

The amount of fuel 

transferred to tanker ships 

for overseas deliveries 

would likely be substantially 

less than under Alternatives 

2 and 3. 

Tanker ships would use low 

speeds and BMPs to reduce 

the potential for vessel 

collisions with marine 

species and fuel spills. 

Alternative 1 would have 

less than significant effects 

to marine biological 

resources.

The likelihood of a vessel 

collision with a protected 

marine species is extremely 

remote because of the low 

probability that individual 

animals of an ESA-listed 

species would overlap in 

space and time with the 

eleven one-way tanker 

transits. Additionally, the 

relatively slow speed of the 

vessels further reduces the 

chance of ship strike with 

marine mammals, sea 

turtles, and fishes. A tanker 

spill during transit has a low 

probability of occurrence, 

and the response teams and 

BMPs available at all ports.

Overall, with the use of 

BMPs, Alternative 2 would 

have less than significant 

effects to marine biological 

resources. 

Under Alternative 3, impacts 

to marine biological 

resources would be similar 

to those described for 

Alternative 2. The transit 

route and destination of sold 

fuel is at the discretion of 

the non-federal entity 

purchaser and not a federal 

action. Similar to Alternative 

2, the temporary and slowmoving presence of the 

maximum of eleven tanker 

ships would reduce the risk 

of impacts to marine 

biological species from 

vessel noise or collision. 

With the use of BMPs, 

Alternative 3 would result in 

a less than significant 

effects to marine biological 

resources.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

Hazardous 

Materials and 

Waste

Inadvertent fuel releases 

that could be associated 

with Alternative 1 would 

mostly consist of small spills 

at points of consumption 

where fuel is transferred or 

dispensed. JBPHH has spill 

response procedures to 

address potential spills and 

to limit their effects to 

human health and the 

environment. Spilled fuel 

and contaminated 

absorbents or debris would 

be managed in accordance 

with the waste management 

plan.

With the use of BMPs, 

Alternative 1 would result in 

a less than significant 

increase to the potential for 

human or environmental 

exposure to hazardous 

materials or waste.

Inadvertent fuel releases 

during fuel loading and 

unloading processes would 

mostly consist of small 

amounts of fuel escaping 

from the flexible hose and 

flexible hose connection 

points on the fueling pier 

and tanker ship. JBPHH has 

spill response procedures to 

address potential spills and 

to limit their effects to 

human health and the 

environment. Spilled fuel 

and contaminated 

absorbents or debris would 

be managed in accordance 

with the waste management 

plan. With the use of BMPs, 

Alternative 2 would result in 

a less than significant 

increase to the potential for 

human or environmental 

exposure to hazardous

materials or waste.

Effects would be the same 

as Alternative 2.

Air Quality and 

Greenhouse Gases

Emissions from fuel storage 

and transfers would reflect 

the status quo and baseline 

levels, as deliveries would 

occur through existing 

processes on JBPHH. 

Effects on air quality would 

be less than significant.

Relocation of fuel via tanker 

ships would emit criteria 

pollutants, (HAPs, and 

greenhouse gases from the 

combustion of fuel by tanker 

ships and tugboats. 

Anticipated air quality 

impacts from Alternative 2 

are not expected to interfere 

with the attainment of 

NAAQS, hinder a 

nonattainment area’s 

progress to attainment, 

increase the frequency or 

severity of existing poor air 

quality, or appreciably 

increase human health risks 

from HAP exposure in areas 

where sensitive receptors 

and/or public presence are 

expected. Records of NonApplicability for the General 

Conformity Rule for 

nonattainment areas in 

California (Point Loma and 

Selby) found pollutants 

would be well below de 

minimis levels. Emission of 

greenhouse gases would be 

short-term and a small 

fraction of those generated 

by international shipping 

activities.

While the ultimate 

destinations under 

commercial sales is not 

known, from an economic 

standpoint, the purchaser 

would likely transport fuel 

the shortest distance 

practicable. Under this 

assumption, the transport 

emissions would likely be 

less than the maximum case 

under Alternative 2. 

Anticipated air quality 

impacts from Alternative 3 

are not expected to interfere 

with the attainment of 

NAAQS, hinder a 

nonattainment area’s 

progress to attainment, 

increase the frequency or 

severity of existing poor air 

quality, or appreciably 

increase human health risks 

from HAP exposure in areas 

where sensitive receptors 

and/or public presence are 

expected.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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The analysis provided in Section 3 of the EA/OEA describes how, in accordance with NEPA, the Proposed 

Action would not result in significant impacts to the human environment. In accordance with E.O. 12114, 

the Proposed Action would not cause significant harm to the human or biological environment in ocean 

waters beyond the territorial limits of the U.S.

ES.6 Public and Agency Participation and Intergovernmental Coordination

JTF-RH and DLA released the Draft EA/OEA (DEA/DOEA) for public and agency comment on June 9, 

2023. The DEA/DOEA was made available on the JTF-RH website. A notice of availability was published

in the Honolulu Star-Advertiser on June 9, 11, and 14, 2023. The public comment period ran from June 9, 

2023 to June 30, 2023. 

A public meeting was held on June 15, 2023 between 4 p.m. and 8 p.m. at the Keehi Lagoon Memorial, 

Harry and Jeannette Weinberg Memorial Hall, 2685 N. Nimitz Hwy, Honolulu, HI 96819. Twenty-seven

individuals attended the public meeting. Public meeting attendees were provided the opportunity to submit 

written comments or record verbal comments. Comments were also accepted online through the JTF-RH 

website and in writing by mail.

A total of 29 substantive comments were received during the DEA/DOEA public comment period. All 

substantive comments were fully considered by JTF-RH and DLA during preparation of the Final EA/OEA 

and prior to rendering a decision on the Proposed Action. Comments received resulted in minor 

clarifications to the Proposed Action and analyses. Public comments and responses are included in 

Appendix A.

JTF-RH and DLA completed informal consultation with the National Marine Fisheries Service (NMFS) 

pursuant to Section 7(a)(2) of the Endangered Species Act (ESA) for the Proposed Action. JTF-RH and 

DLA developed a Biological Evaluation (BE) to assess the potential impacts to federally listed threatened 

and endangered species and submitted the BE to NMFS on May 19, 2023. NMFS reviewed the BE and 

provided questions for further discussion and recommendations for additional Best Management Practices 

(BMPs). JTF-RH and DLA submitted a revised BE to NMFS on June 9, 2023. Utilizing the most current 

data and the best available science and implementing BMPs, JTF-RH and DLA determined that the 

Proposed Action may affect, but is not likely to adversely affect, any ESA-listed species or designated 

critical habitat in the action area. NMFS concurred with the JTF-RH and DLA determination that the 

Proposed Action may affect, but is not likely to adversely affect, any ESA-listed species or designated 

critical habitat in the action area. NMFS’ Letter of Concurrence dated August 15, 2023 is provided in 

Appendix B.

JTF-RH and DLA notified the State of Hawaii Office of Planning and Sustainable Development on June 

14, 2023 by email that the Proposed Action would be consistent with the de minimis Activities List under 

the Coastal Zone Management Act, and therefore not subject to further review by the Hawaii Coastal Zone 

Management Program. The Hawaii Coastal Zone Management Program acknowledged receipt of the 

notification on June 19, 2023.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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ENVIRONMENTAL ASSESSMENT/OVERSEAS ENVIRONMENTAL ASSESSMENT

RED HILL DEFUELING AND FUEL RELOCATION, 

JOINT BASE PEARL HARBOR-HICKAM, 

OAHU, HAWAII

TABLE OF CONTENTS

1 PURPOSE OF AND NEED FOR THE PROPOSED ACTION.......................................... 1-1

1.1 Introduction.....................................................................................................................................1-1

1.2 Purpose and Need for the Proposed Action ..................................................................................1-1

1.3 Background ....................................................................................................................................1-1

1.4 Location and Surrounding Environment.........................................................................................1-2

1.5 Scope of Environmental Analysis...................................................................................................1-4

1.6 Relevent Laws and Regulations.....................................................................................................1-4

1.7 Public and Agency Participation and Intergovernmental Coordination..........................................1-4

1.8 Permits and Approvals ...................................................................................................................1-5

2 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES .................................. 2-1

2.1 Description of the Proposed Action................................................................................................2-1

2.2 Screening Factors ..........................................................................................................................2-1

2.3 Alternatives Carried Forward for Analysis......................................................................................2-1

2.4 Alternatives Considered But Not Carried Forward for Detailed Analysis.......................................2-6

2.5 Best Management Practices ..........................................................................................................2-7

2.6 Mitigation Measures .....................................................................................................................2-13

3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ................... 3-1

3.1 Public Health and Safety................................................................................................................3-2

3.2 Water Resources ...........................................................................................................................3-7

3.3 Marine Biological Resources........................................................................................................3-18

3.4 Hazardous Materials and Waste..................................................................................................3-30

3.5 Air Quality and Greenhouse Gases .............................................................................................3-35

4 CUMULATIVE IMPACTS................................................................................................. 4-1

4.1 Cumulative Effects Analysis...........................................................................................................4-3

5 SUMMARY AND CONCLUSIONS ON THE IMPACTS OF THE PROPOSED ACTION 

AND ALTERNATIVES............................................................................................................ 5-1

5.1 Irreversible or Irretrievable Commitments of Resources ...............................................................5-3

5.2 Unavoidable Adverse Impacts .......................................................................................................5-3

5.3 Relationship Between Short-Term Use of the Environment and Long-Term Productivity.............5-4

5.4 Consistency with Federal Policies and Executive Orders..............................................................5-4
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

x

6 CONSULTATION AND COORDINATION ....................................................................... 6-1

6.1 List of Agencies Consulted.............................................................................................................6-1

6.2 List of Agencies Notified.................................................................................................................6-1

7 LIST OF PREPARERS AND REVIEWERS ..................................................................... 7-1

8 REFERENCES ................................................................................................................ 8-1

TABLES

Table 2.3-1. Potential Receiving Locations for Fuel from RHBFSF...........................................................2-4

Table 2.4-1. Alternatives Considered but Eliminated from Further Study..................................................2-6

Table 2.5-1. Best Management Practices..................................................................................................2-7

Table 3.3-1. ESA-Listed Marine Mammals Present in U.S. Waters or on the High Seas of the ROI......3-21

Table 3.3-2. ESA-Listed Sea Turtles Present in the U.S. Waters or on the High Seas of the ROI .........3-23

Table 3.3-3. ESA-Listed Fishes Present in U.S. Waters or on the High Seas of the ROI.......................3-24

Table 3.5-1. General Conformity De Minimis Levels ...............................................................................3-36

Table 3.5-2. Vessel Transit Distances between JBPHH and Potential Receiving Locations ..................3-41

Table 3.5-3. Combined Emission Factors for Tanker Transits ................................................................3-42

Table 3.5-4. Maximum case: Emissions from Tanker Transits Including Hotelling (International Receiving 

Locations).........................................................................................................................................3-43

Table 3.5-5. Minimum Case: Emissions from Tanker Transits Including Hotelling (U.S. Receiving 

Locations).........................................................................................................................................3-44

Table 3.5-6. Local Emissions Occurring at JBPHH and Receiving Locations.........................................3-45

Table 4-1. Past, Present, and Future Actions or Trends Relevant to Cumulative Effects.........................4-1

Table 5-1. Comparison of Alternatives.......................................................................................................5-1

Table 1. de minimis Levels for Criteria Pollutants in the San Diego Air Basin .............................................2

Table 2. Emissions Under Alternative 2 or Alternative 3, Two Vessel Trips to Point Loma .........................3

Table 1. de minimis Levels for Criteria Pollutants in San Francisco Bay Area Air Basin .............................5

Table 2. Emissions Under Alternative 2 or Alternative 3, Two Vessel Trips to Selby...................................6

FIGURES

Figure 1-1. Red Hill Bulk Fuel Storage Facility Locaton ............................................................................1-3

Figure 2-1. Location of Potential Fuel Receiving Sites ..............................................................................2-3

Figure 3.1-1. Waimalu and Moanalua Aquifer Location.............................................................................3-4

Figure 3.2-1. Aquifer Systems Near RHBFSF ...........................................................................................3-9

Figure 3.2-2. Oahu Regional Hydrologic Units ..........................................................................................3-9

Figure 3.2-3. Causes of Large Tanker Ship Spills, 2010-2022................................................................3-13

Figure 3.3-1. Potential Fuel Receiving Locations and Vessel Transit Routes.........................................3-20

Figure 3.4-1. Areas Designated for Remediation Under CERCLA at the Pearl Harbor Sediment Site...3-31

Figure 3.5-1. Emission Sources Associated with Vessel Transit.............................................................3-42
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

xi

APPENDICES

Appendix A PUBLIC COMMENTS AND RESPONSES

Appendix B ENDANGERED SPECIES ACT – NOAA/NMFS CONSULTATION LETTER OF 

CONCURRENCE

Appendix C COASTAL ZONE MANAGEMENT ACT COORESPONDENCE

Appendix D SUPPLEMENTAL INFORMATION FOR MARINE BIOLOGICAL RESOURCES

Appendix E CLEAN AIR ACT GENERAL CONFORMITY NON-APPLICABILITY ANALYSES AND 

AIR EMISSIONS WORKSHEETS
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

xii

ACRONYMS AND ABBREVIATIONS

Acronym or 

Abbreviation

Definition

ABS American Bureau of Shipping

ACM Asbestos-containing material

AFFF Aqueous film-forming foam

AIS Automatic Identification System

AOC Administrative Order on Consent

BE Biological Evaluation

BMP Best Management Practices

CAA Clean Air Act

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980

CFR Code of Federal Regulations

CO Carbon monoxide

CO2 Carbon dioxide

COC Contaminants of Concern

CWA Clean Water Act

CWB Hawaii Department of Health Clean Water Branch

CZMA Coastal Zone Management Act

dB Decibels

dB re 1μPa-m Decibels referenced to a pressure of one micro Pascal at one meter

DEA/DOEA Draft Environmental Assessment/Draft Overseas Environmental Assessment

DERP Defense Environmental Restoration Program

DLA Defense Logistics Agency

DoD United States Department of Defense

DOH State of Hawaii Department of Health

DOT United States Department of Transportation

EA Environmental Assessment

ECA Environmental Control Area

EEZ Exclusive Economic Zone

EFH Essential Fish Habitat

EO Executive Order

EPA Environmental Protection Agency

ESA Endangered Species Act

FLC Fleet Logistics Center, Pearl Harbor

FORFAC Fuel Oil Reclamation Facility

ft. Foot/feet

GHG Greenhouse Gas

HAP Hazardous Air Pollutant

HAR Hawaii Administrative Rules

HNL Daniel K. Inouye International Airport

HNS Hazardous and Noxious Substances

HRS Hawaii Revised Statutes

Hz Hertz
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Acronym or 

Abbreviation

Definition

IMO International Maritime Organization

in Inch(es)

INRMP Integrated Natural Resources Management Plan

ISGOTT International Safety Guide for Oil Tankers and Terminals

ITOPF International Tanker Owners Pollution Federation

JBPHH Joint Base Pearl Harbor-Hickam

JTF-RH Joint Task Force Red Hill

LBP Lead-based Paint

LNAPL Light Non-aqueous Phase Liquids

M Million

MARPOL International Convention for the Prevention of Pollution from Ships

MEC Munitions and Explosives of Concern

MMPA Marine Mammal Protection Act

MSC Military Sealift Command

NAAQS National Ambient Air Quality Standard

NAVFAC Naval Facilities Engineering Systems Command

Navy United States Department of the Navy

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants

NM Nautical Miles

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

NO2 Nitrous dioxide

NOx Nitrogen oxides

NPDES National Pollutant Discharge Elimination System

NPL National Priorities List

NRT National Response Team

OEA Overseas Environmental Assessment

OPRC 90 International Convention on Oil Pollution Preparedness, Response and Co-operation 1990

OPRC-HNS Protocol on Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and 

Noxious Substances

PACFLT United States Pacific Fleet

PCB Polychlorinated Biphenyls

PHNSY Pearl Harbor Naval Shipyard

PIC Person in Charge

PM2.5 Particulate Matter less than or equal to 2.5 microns

PM10 Particulate Matter less than 10 microns

POL Petroleum, Oil, Lubricants

PSD Prevention of Significant Deterioration

PTS Permanent Threshold Shift

RCRA Resource Conservation and Recovery Act

RHBFSF Red Hill Bulk Fuel Storage Facility

ROI Region of Influence

SCC Social Cost of Carbon

SECDEF United States Secretary of Defense
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

xiv

Acronym or 

Abbreviation

Definition

SIP State Implementation Plan

SO2 Sulfur dioxide

SOx Sulfur oxides

TPY Tons Per Year

TSCA Toxic Substances Control Act

TTS Temporary Threshold Shift

UGPH Underground Pump House

UIC Underground Injection Control

U.S. United States

USC United States Code

USCG United States Coast Guard

USFWS United States Fish and Wildlife Service

USTs Underground Storage Tanks

UTF Upper Tank Farm

VOC Volatile Organic Compound

WHO World Health Organization

μg/m3 microgram per cubic meter
1-1

1 PURPOSE OF AND NEED FOR THE PROPOSED ACTION

1.1 INTRODUCTION

This Environmental Assessment/Overseas Environmental Assessment (EA/OEA) addresses gravity-based 

defueling of the Red Hill Bulk Fuel Storage Facility (RHBFSF) at Joint Base Pearl Harbor-Hickam (JBPHH)

and the relocation of flowable fuels to other Department of Defense (DoD) fuel supply locations in the Pacific

region or sale of the fuel to commercial entities utilizing DoD contracting authorities. The Joint Task Force 

Red Hill (JTF-RH) and Defense Logistics Agency (DLA) prepared this EA/OEA pursuant to the National 

Environmental Policy Act (NEPA), as amended (42 United States Code [USC] section 4321 et seq.) and its 

implementing regulations issued by the Council on Environmental Quality (40 Code of Federal Regulations 

[CFR] Part 1500 - 1508) and Executive Order (EO) 12114.

The goal of this EA/OEA is to ensure that comprehensive consideration is given to potential environmental 

impacts that may result from the Proposed Action, or any reasonable alternative action, upon the human

environment. 

1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION

The purpose of the proposed gravity-based defueling action is to comply with State of Hawaii Department 

of Health (DOH) Emergency Orders (herein, DOH Emergency Orders, 2021 and 2022), the Environmental 

Protection Agency (EPA) 2023 Administrative Consent Order, and United States Secretary of Defense

(SECDEF) Lloyd J. Austin III’s order on March 7, 2022 (herein, SECDEF Memo, 2022) to defuel and 

permanently close the RHBFSF (DoD, 2022A).

Defueling RHBFSF is needed to protect local water supplies from further contamination. Additionally, DoD 

needs to defuel the facility as a first step in the process of full closure and remediation of RHBFSF.

1.3 BACKGROUND

Dating back to the 1920s, the United States (U.S.) Department of the Navy (herein, the Navy) recognized 

the vulnerability of its aboveground fuel tanks at Pearl Harbor and began planning for massive underground 

fuel storage in the late 1930s. The RHBFSF was conceived to protect vital fuel supplies from hostile forces. 

Work began to construct this secret facility the day after Christmas 1940 and the project was completed in 

September 1943 by a workforce of 3,900 working round-the-clock shifts. Initially, the facility supplied fuel 

to the ships and submarines going to the forward lines, as well as all the Navy’s support activities in Hawaii. 

In later years, it also supplied fuel to aircraft. It has provided fuel for the Navy continuously since completion 

in 1943 (NPS, 2015).

In January 2014, during the course of refilling Red Hill Storage Tank #5, following routine maintenance and 

repair work, the Navy identified an estimated fuel release of up to 27,000 gallons of JP-8 jet fuel from the 

tank and reported the release to the DOH. 

The Navy then drained the tank and collected samples from existing monitoring wells. Results taken in and 

around Tank 5 indicated a spike in levels of hydrocarbons in soil vapor and groundwater. Drinking water 

monitoring results confirmed compliance with federal and state safety standards for drinking water both 

before and after the January 2014 release. 

In response to the January 2014 fuel release from the facility, EPA and DOH negotiated an enforceable 

agreement, also known as an Administrative Order on Consent (AOC), with the Navy and the DLA. The 

Order required the Navy and DLA to take actions, subject to DOH and EPA approval, to address fuel 

releases and implement infrastructure improvements to protect human health and the environment.

On May 6, 2021, a pressure surge event occurred during routine fuel movement operations at RHBFSF.

The pressure surge event caused a pipeline joint failure that released over 19,000 gallons of JP-5 jet fuel 

onto the tunnel floor located between the underground storage tanks. The fuel ran down the tunnel floor 
1-2

into containment trenches and into a fire suppression system fluid sump. The sump pumps pushed fuel 

down the tunnel in a fire suppression system fluid drain pipeline, where the fuel remained until the drain 

pipeline ruptured on November 20, 2021. This ruptured drain pipeline resulted in fuel spilling into the tunnel 

system near the Red Hill drinking water system shaft (EPA, 2023a).

In late November 2021, the petroleum release from RHBFSF contaminated the Red Hill drinking water well. 

Hundreds of families, living on JBPHH and the Army's Aliamanu Military Reservation and Red Hill Housing, 

reported petroleum odors coming from residential tap water supplied by the Navy water system. Residents 

reported health symptoms arising from the contaminated drinking water.

Approximately 93,000 Navy water system users were impacted by the contaminated drinking water, many 

of whom relocated to temporary housing during the drinking water crisis.

EPA coordinated with the Navy, Army, and DOH in an Interagency Drinking Water System Team to restore 

safe drinking water to the affected residents and workers. The team launched in December 2021 and 

completed work to restore the drinking water system in March 2022.

Following the November 2021 contamination of JBPHH’s drinking water system, the DOH issued an 

emergency order to the Navy that required the Navy to cease all operations at the facility and defuel the 

eighteen operational underground fuel storage tanks. The DOH Emergency Order was issued on December 

6, 2021 (DOH, 2021a) and then a Superseding Emergency Order was issued on May 6, 2022 (DOH, 

2022a).

On March 7, 2022, SECDEF Lloyd J. Austin III, directed the DoD to defuel and permanently close the 

RHBFSF (DoD, 2022A).

In January 2023, EPA proposed a settlement (EPA, 2022a) with the Navy and the DLA which requires steps 

to ensure the safe defueling and closure of RHBFSF. The EPA 2023 Administrative Consent Order does 

not replace the 2015 AOC between EPA, DOH, Navy, and DLA which requires the investigation and 

cleanup of releases. 

The DoD stood up JTF-RH on September 30, 2022 to ensure the safe and expeditious defueling of Red 

Hill. JTF-RH completed a critical preliminary step in the defueling process, from October 25 to November 

3, 2022 removing over a million gallons of fuel from the facility's fuel pipelines. The operation, known as 

unpacking, concluded without any issues involving the handling, transport or storage of the fuel. JTF-RH is 

overseeing all necessary repairs, modifications and enhancements to the Red Hill infrastructure to reduce 

risk of spills or accidents during the gravity-based defueling phase.

Fuel product stored at RHBFSF is owned by DLA Bulk Petroleum Supply Chain Services Division. DLA 

provides contract support for the DoD’s bulk petroleum needs, including worldwide acquisition of fuelrelated services such as government-owned, contractor-operated defense fuel support points, contractorowned and -operated defense fuel support points, alongside aircraft fuel delivery, lab testing and 

environmental compliance, assessment, and remediation (DLA, 2023).

1.4 LOCATION AND SURROUNDING ENVIRONMENT

The RHBFSF sits on 144 acres on JBPHH on Oahu, Hawaii, on land just to the east of the intersection of 

Highway H201 and Highway H3, located approximately 2.7 miles north of the Daniel K. Inouye International 

Airport and 1.4 miles east of Aloha Stadium (Figure 1-1). The RHBFSF is located in a ridge of volcanic rock 

known as Red Hill, or Hawaiian name Kapukaki, on the western edge (leeward side) of the Koolau 

Mountains that divides South Halawa Valley and Moanalua Valley. The site is surrounded by Federal, State, 

and residential property. The majority of the surface topography of the site lies at an elevation of 

approximately 200 to 500 feet (ft.) above mean sea level. The Red Hill ridge extends southwesterly toward 

JBPHH and provides protective cover not only for the underground fuel storage facility, but also for the long 

tunnel that connects the fuel storage facility with the Underground Pump House (UGPH).
1-3

Figure 1-1. Red Hill Bulk Fuel Storage Facility Locaton

The Waimalu and Moanalua Aquifers, which are underground sources of drinking water, are located near 

the facility. The Waimalu Aquifer covers an area of 15,193 acres and the Moanalua Aquifer covers an area 

of 4,442 acres (EPA, 2022a).

The RHBFSF consists of a complex of 20 vertical fuel storage tanks beneath a minimum of 100 ft. of 

volcanic rock (ASCE, 2023). Each tank is 100 ft. in diameter and 250 ft. high, which is large enough to 

enclose a 20-story building. Tank interiors are lined with quarter-inch steel plates surrounded by reinforcedconcrete. Each tank has a storage capacity of approximately 12.5 million gallons. In total, the tanks at the 

facility have a capacity of 250 million gallons. However, the tanks presently contain approximately 104 

million gallons across three fuel types: 

• F-24: used in non-navy aircraft; this is a kerosene-based product used largely by the commercial 

airline sector but with additives to inhibit icing and corrosion.

• F-76: marine diesel primary fuel for ships

• JP-5: jet propulsion fuel used in Naval aircraft

Near Pearl Harbor, a pumping station at the end of the pipelines controls the filling of the tanks as well as 

dispensing fuel to ships and to nearby Upper Tank Farm (UTF) at JBPHH. Three gravity-fed pipelines run 

2.5 miles inside a tunnel to fueling piers at JBPHH (CNRH, 2023). Only a small portion (approximately 5 

percent or less) of the pipeline distance is direct buried; meaning 95 percent or more of the lines run above 

ground or within tunnels where they can be readily visually inspected. 
1-4

1.5 SCOPE OF ENVIRONMENTAL ANALYSIS

This EA/OEA includes an analysis of the potential environmental impacts associated with the movement of 

fuel from the RHBFSF to a fueling pier at JBPHH, fuel loading onto tanker ships, and fuel relocation by 

ocean transit. The scope of the analysis is limited to actions for which the DoD has discretion over. The 

analysis of the action alternatives in this EA/OEA will begin once the fuel exits a series of valves and 

manifolds downstream from the Red Hill UGPH that direct fuel flow to the JBPHH fueling piers. The analysis 

will end when the fuel leaves Military Sealift Command (MSC) contracted vessels at the destination DoD 

fuel support points, or when the fuel is commercially sold.

This EA/OEA will not analyze emptying the fuel from Red Hill tanks since this is mandated in the DOH 

Emergency Orders, 2021 and 2022, and therefore is nondiscretionary. Defueling must be completed 

expeditiously to protect water supplies from further contamination and to comply with DOH Emergency 

Orders, 2021 and 2022 and EPA 2023 Administrative Consent Order.

DoD will undertake several stages of actions to fully close and remediate the RHBFSF. Follow-on actions

beyond the scope of this EA/OEA, such as RHBFSF closure, site remediation, and potential beneficial 

non-fuel re-use of the facility, are also necessary but are predicated on the successful gravity-based 

defueling action occurring first. The DoD is actively evaluating and developing alternatives for future 

follow-on actions which will be subject to additional future environmental compliance actions as 

applicable. To the extent possible and known with currently available information, this EA/OEA will 

evaluate the potential impacts of follow-on actions in Section 4, Cumulative Effects. 

The process for identifying resources analyzed in this EA/OEA is summarized in Section 3, Introduction. 

Resources analyzed in detail include:

• Public Health and Safety

• Water Resources

• Marine Biological Resources

• Hazardous Materials and Waste

• Air Quality and Greenhouse Gases

Resources that were not analyzed in detail are described and explained in the introduction to Section 3, 

Affected Environment and Environmental Consequences.

1.6 RELEVENT LAWS AND REGULATIONS

JTF-RH and DLA have prepared this EA/OEA based on federal law and documents the Proposed Action’s 

compliance with all applicable Executive Orders, statutes, regulations (see Section 5.4).

1.7 PUBLIC AND AGENCY PARTICIPATION AND INTERGOVERNMENTAL 

COORDINATION

JTF-RH and DLA released the Draft EA/OEA (DEA/DOEA) for public and agency comment on June 9, 

2023. The DEA/DOEA was made available on the JTF-RH website. A notice of availability was published 

in the Honolulu Star-Advertiser on June 9, 11, and 14, 2023. The notice described the Proposed Action, 

solicited public comments on the DEA/DOEA, provided dates of the public comment period, and provided 

the web address for where the DEA/DOEA was located. The public comment period ran from June 9, 2023 

to June 30, 2023.

A public meeting was held on June 15, 2023 between 4 p.m. and 8 p.m. at the Keehi Lagoon Memorial, 

Harry and Jeannette Weinberg Memorial Hall, 2685 N. Nimitz Hwy, Honolulu, HI 96819. Twenty-seven 

individuals attended the public meeting. Public meeting attendees were provided the opportunity to submit 

written comments or record verbal comments. Comments were also accepted online through the JTF-RH 

website and in writing by mail.
1-5

A total of 29 substantive comments were received during the DEA/DOEA public comment period. All 

substantive comments were fully considered by JTF-RH and DLA during preparation of the Final EA/OEA 

and prior to rendering a decision on the Proposed Action. Comments received resulted in minor 

clarifications to the Proposed Action and analyses. Public comments and responses are included in 

Appendix A.

JTF-RH and DLA completed informal consultation with the National Marine Fisheries Service (NMFS) 

pursuant to Section 7(a)(2) of the Endangered Species Act (ESA) for the Proposed Action. JTF-RH and 

DLA developed a Biological Evaluation (BE) to assess the potential impacts to threatened and endangered 

species and submitted the BE to NMFS on May 19, 2023. NMFS reviewed the BE and provided questions 

for further discussion and recommendations for additional Best Management Practices (BMPs). JTF-RH 

and DLA submitted a revised BE to NMFS on June 9, 2023. Utilizing the most current data and the best 

available science and implementing BMPs, JTF-RH and DLA determined that the Proposed Action may 

affect, but is not likely to adversely affect, any ESA-listed species or designated critical habitat in the action 

area. NMFS concurred with the JTF-RH and DLA determination that the Proposed Action may affect, but 

is not likely to adversely affect, any ESA-listed species or designated critical habitat in the action area. 

NMFS’ Letter of Concurrence dated August 15, 2023 is provided in Appendix B.

JTF-RH and DLA notified the State of Hawaii Office of Planning and Sustainable Development on June 14, 

2023 by email that the Proposed Action would be consistent with the de minimis Activities List under the 

Coastal Zone Management Act, and therefore not subject to further review by the Hawaii Coastal Zone 

Management Program. The Hawaii Coastal Zone Management Program acknowledged receipt of the 

notification on June 19, 2023. Correspondence with the Hawaii Coastal Zone Management Program is 

included in Appendix C.

1.8 PERMITS AND APPROVALS

JTF-RH and DLA completed informal consultation with the NMFS pursuant to Section 7(a)(2) of the ESA.

NMFS consultation documentation is included in Appendix B.

JTF-RH and DLA notified the State of Hawaii Office of Planning and Sustainable Development that the 

Proposed Action would be consistent with the de minimis Activities List under the Coastal Zone 

Management Program, and therefore not subject to further review by the Hawaii Coastal Zone Management 

Program. Correspondence with the Hawaii Coastal Zone Management Program is included in Appendix C.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

2-1

2 DESCRIPTION OF PROPOSED ACTION AND 

ALTERNATIVES

2.1 DESCRIPTION OF THE PROPOSED ACTION

The Proposed Action is the gravity-based defueling of the RHBFSF and relocation of the flowable fuel to 

other DoD fuel supply locations in the Pacific region or sale of the fuel to commercial entities utilizing DoD 

contracting authorities.

2.2 SCREENING FACTORS

JTF-RH and DLA thoroughly evaluated available methods and infrastructure for safe defueling and fuel 

transfer from RHBFSF. The defueling process requires several phases: 1) remove the fuel from the tanks, 

2) transport it from RHBFSF to other transportation nodes, such as ports, and 3) deliver it to end points for 

DoD use or commercial sale. Site screening criteria for pipelines, transportation nodes, and end point 

alternatives were considered using the following criteria: 

1. Defueling must occur in a safe and expeditious manner in accordance with: DOH Emergency 

Orders 2021 and 2022; SECDEF Memo 2022; DoD Defueling Plan of 1 June 2022; DoD Defueling 

Plan Supplements 1A and 1B of 7 and 28 September 2022; and DoD Defueling Plan Supplement 

2 of 16 May 2023.

2. Defueling operation must not unduly burden the Oahu commercial fuel supply chain.

3. Transfer of fuel from RHBFSF to the fuel loading pier must occur through DoD‐owned, existing 

infrastructure.

4. Fueling transfer from RHBFSF must not utilize public roadways to minimize traffic impacts and 

reduce risk of accidents and spills.

5. Fuel tanker loading must occur at an operational pier that can accommodate a tanker ship, and 

has existing infrastructure to accommodate F-76, J-P5, or F-24 fuel types.

6. If fuel is relocated for DoD use, it must be directed to locations within the DoD fuel supply chain 

with infrastructure to safely offload and store fuel in the type and quantity needed by the DoD at 

the time of defueling. 

7. Relocation and/or commercial sale of fuel must be both economical and a responsible use of the 

taxpayer’s resources.

2.3 ALTERNATIVES CARRIED FORWARD FOR ANALYSIS

This EA/OEA analyzes the No Action Alternative and two action alternatives. Both the No Action Alternative 

and the two action alternatives utilize existing infrastructure at RHBFSF and JBPHH to remove the fuel from 

RHBFSF and load it onto tanker ships. The No Action Alternative and the two action alternatives would

include unpacking the associated pipelines. Removal of residual amounts of fuel products that do not flow 

under the force of gravity, such as sludge (unrecoverable tank bottoms) and any fuel within low points of 

the facility and pipelines, would occur after the gravity-based defueling stage, and is not included in the 

scope of environmental analysis of this EA/OEA. RHBFSF will transition to DoD’s closure phase after the 

gravity-based defueling stage. 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

2-2

Alternative 1: No Action Alternative

Under the No Action Alternative, the fuel within RHBFSF 

would be supplied to JBPHH customers at regular demand 

rates for routine use. This alternative would ultimately 

remove all flowable fuel from RHBFSF because it would not 

receive any re-supply of fuel. 

Under the No Action Alternative, flowable fuel would remain 

in the tanks at RHBFSF for approximately ten to fourteen

months after DOH approval of the gravity-based defueling 

operation. Fuel from RHBFSF would be transferred to the 

Upper Tank Farm UTF or to fueling piers at JBPHH through 

existing infrastructure. Fuel from the UTF would then be 

sent by pipeline to Hickam Field, fuel loading piers, and 

truck loading racks for distribution to customary defense 

customers for consumption. A low demand for JP-5 fuel at 

JBPHH would require JP-5 movement by vessel to points 

of immediate consumption as part of a stock rotation 

program to increase the rate of JP-5 consumption. 

Additionally, JP-5 may be regraded to F-24 or F-76 for 

consumption at JBPHH.

Under the No Action Alternative, the existing locations 

within the DoD fuel supply chain that may receive relocated 

fuel from RHBFSF as part of Alternatives 2 and 3 would 

continue to receive their routine or planned fuel deliveries 

by tanker ships from other fuel sources.

The No Action Alternative does not meet the purpose and need for the Proposed Action because it does 

not expeditiously defuel RHBFSF as it could take as long as fourteen months to execute. However, as 

required by NEPA, the No Action Alternative is carried forward for analysis in this EA/OEA. The No Action 

Alternative will be used to analyze the consequences of not executing the Proposed Action, and will serve 

to establish a comparative baseline for analysis of the action alternatives.

Alternative 2: Relocation

Alternative 2 is the gravity-based defueling and relocation of the approximately 106 million gallons of 

flowable fuel from RHBFSF to existing locations within the DoD fuel supply chain by ocean transit. The 

flowable fuel that would be relocated includes 104 million gallons presently in the RHBFSF tanks, plus an 

estimated 2 million gallons of fuel from the pipeline packing process and emptying of the underground surge 

tanks. The fuel removal operation involves gravity flow of the fuel from RHBFSF through existing DoD piping 

and associated infrastructure to a fuel loading pier at JBPHH. This alternative would defuel RHBFSF within 

approximately three to four months after DOH approval of the gravity-based defueling process.

A maximum of eleven refined product tanker ship transits are required to receive and transport all the 

flowable fuel from RHBFSF. The tanker ships would be medium-range type vessels that are approximately 

600-ft. long with a capacity of approximately 11 million gallons. No new construction is required to support 

fuel movement from RHBFSF to the fueling pier. Tanker ships would arrive at Pearl Harbor and be guided 

by tugboats to the JBPHH fueling pier. Tanker ships may also use harbor pilots to help safely navigate 

through Pearl Harbor. Ship speeds in Pearl Harbor are typically ten nautical miles per hour (knots) or less, 

to prevent collision, and five knots or less when piloting vessels in areas of known turtle presence. Once 

docked, several safety and procedural checks will be conducted. These safety and procedural checks are

described in Section 2.5. The tanker loading operation would then commence under the direction of the 

assigned Person in Charge (PIC) and in compliance with the Operations Order, a standard operating 

procedure for fuel loading evolutions. Tanker loading would take up to three days per tanker. A maximum 

of two tankers per week would be loaded at the same fueling pier. 

Flowable fuel is defined as fuel that readily flows 

under gravity from the storage tanks through the 

pipelines. Any bottom sediment or sludge in the tanks 

which would require mechanical cleaning or 

scraping would be removed during subsequent 

remediation phases of the Red Hill facility closure.

Flowable tank bottom is a subset of flowable fuels, 

used to describe the column of fuel in the bottom ten 

(10) ft. of the RHBFSF tanks. 

Low points are defined as those portions of the tanks 

and pipelines where fuel will not flow under the force 

of gravity alone. 

Unpacking is defined as the process of defueling the 

pipelines that transfer fuel from the tanks to the pier. 

The pipelines have capacity to hold approximately 

1.3 million gallons of fuel. Conversely, packing is 

defined as filling the pipelines with fuel. 

Unrecoverable Tank Bottoms is defined as the semisolid material that settles on the bottom of tanks over 

long periods of time (nominally the bottom four 

inches(in) for the RHBFSF) and within the low 

points in the pipeline system that must be removed 

through mechanical means (such as scraping or 

shoveling). Some dismantlement of pipelines, valves 

and various other components could be necessary to 

remove sludge in the RHBFSF system.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

2-3

Tanker ships would depart the fueling pier guided by tugboats through Pearl Harbor. After exiting Pearl 

Harbor, tanker ship transits one through ten would transit within existing commercial shipping lanes to one 

or more (up to nine) existing DoD fuel support points throughout the Pacific. The fuel deliveries to these 

locations would occur in lieu of routine fuel supply deliveries. Each prospective DoD fuel support point would 

have adequate facilities and piers/systems to receive fuel from tanker ships. Potential receiving locations 

(Figure 2-1) for the ten fuel deliveries include: 

• Campbell Industrial Park, West Oahu, Hawaii

• Point Loma, California 

• Selby, California

• Vancouver, Washington

• Manchester, Washington 

• Sasebo, Japan 

• Subic Bay, Philippines 

• Port of Singapore

• Darwin, Australia 

Figure 2-1. Location of Potential Fuel Receiving Sites 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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The quantity of fuel and number of deliveries received at each location would depend on DoD fuel inventory 

needs at the time of defueling. An upper bound, or maximum number, of transits for each receiving location 

was determined in consultation with DLA to use for planning and analysis purposes. The upper bound of 

transits took into account fuel types and projected volume of fuel storage available at a potential receiving 

location. Table 2-1 provides transit and offload information for each potential receiving location.

Table 2.3-1. Potential Receiving Locations for Fuel from RHBFSF 

Potential Receiving 

Location

Maximum 

Number of 

Tankers to Each 

Location

Estimated Transit 

Distance (nautical 

miles)

Estimated 

Transit 

Duration 

(days)

Offload Point

Campbell Industrial 

Park, West Oahu, 

Hawaii

5 13 <1 day (1 hour) Seven Point Multipoint 

Mooring (MPM) System (2 

miles offshore)

Naval Base Point 

Loma, California

2 2280 7 days Navy Pier located at Dock 

Street

Selby Terminal, 

California

2 2120 6 days Fuel Pier at Point Davis

Port of Vancouver, 

Washington

1 2350 7 days Pier at Terminal 2, Berth 5

Manchester, 

Washington

1 2480 7 days Navy Pier on Olympic 

Drive Manchester, WA

US Naval Fueling 

Station Sasebo, Japan

2 4060 12 days Navy Fuel Piers in 

Sasebo Harbor

Subic Bay, Philippines 5 4830 14 days Petroleum Oil Lubricants 

(POL) Pier

Port of Singapore 5 6230 18 days Fueling Piers

Port of Darwin, 

Australia

2 5190 15 days East Arm Wharf Berth 4

Note: Transit distances are approximate based on the most direct route from Oahu; routes/distances could vary in practice based 

on weather conditions and other factors.

Tanker ships would use established commercial shipping routes and open water ship speeds 

(approximately fifteen knots) during open ocean transit to its destination. Transit times would depend on 

the distance from JBPHH to the port of destination as shown in Table 2-1. MSC would contract tanker ships 

based on commercial market availability at the time of defueling. 

Tanker ships would be double-hulled and have a certified oil discharge monitoring and control system 

(monitoring system), as well as other safety and environmental design features, as required by U.S. Coast 

Guard regulation Title 33, Section 157 “Rules for the Protection of the Marine Environment Relating to Tank 

Vessels Carrying Oil in Bulk.” (See https://www.ecfr.gov/current/title-33/chapter-I/subchapter-O/part-157). 

These ships have an Automatic Identification System (AIS), which is a broadcast system that acts like a 

transponder to provide real-time ship name, course, speed, classification, call sign, registration number and 

other information. AIS allows maritime authorities to track and monitor vessel movements in accordance 

with International Maritime Organization (IMO) International Convention for the Safety of Life at Sea.

Upon arrival at the receiving location, fuel would be offloaded, stored, and managed through the receiving 

entity’s standard practices and operating procedures.

The eleventh tanker or barge would be staged at the JBPHH fueling pier for approximately two to five weeks 

to receive flowable tank bottoms and fuel from the underground surge tanks and pipeline unpacking process 

(estimated to be 2 million gallons of fuel or a portion thereof). Fleet Logistic Center, Pearl Harbor (FLC) 

would sample and test this fuel to determine whether it meets specifications for DoD requirements. Based 

on results of testing and fuels inventory at the time of defueling, two options for distribution of this remaining 

fuel would be available:
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Flowable Tank Bottoms Option A: Upper Tank Farm

With Option A, fuel that meets specifications for DoD requirements may be pumped from the eleventh 

tanker or barge back through existing piping and infrastructure to the UTF for consumption at JBPHH. The 

removal of flowable fuel from RHBFSF would be complete following the transfer of fuel from the eleventh 

tanker or barge to the UTF under Option A. The RHBFSF would then transition to the Navy for follow-on 

closure activities beyond the scope of the Proposed Action and not included in this EA/OEA, which includes 

site remediation and potential beneficial non-fuel re-use.

Flowable Tank Bottoms Option B: Commercial Sale

With Option B, fuel loaded onto the eleventh tanker or barge after line unpacking would be transported and 

sold to a commercial entity. Transit route and destination of the eleventh tanker would not be known until 

the time of sale. The removal of flowable fuel from RHBFSF would be complete following the loading and 

departure of the eleventh tanker under Option B. The RHBFSF would then transition to the Navy for followon closure activities beyond the scope of the Proposed Action and not included in this EA/OEA, which 

includes site remediation and potential beneficial non-fuel re-use.

Alternative 3: Commercial Sale and Relocation

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of flowable fuel 

from RHBFSF combined with the relocation of the remaining portion of the fuel to existing locations within 

the DoD fuel supply chain by ocean transit. The flowable fuel that would be relocated includes 104 million 

gallons presently in the RHBFSF tanks, plus an estimated 2 million gallons of fuel from the pipeline packing 

process and emptying of the underground surge tanks. A maximum of eleven tanker ships would be 

required to receive all of the flowable fuel from RHBFSF.

With Alternative 3, up to ten tanker loads of fuel from RHBFSF may be commercially sold in accordance 

with Section 2922e of Title 10, USC, which authorizes the sale of certain fuel sources. Sale of fuel would 

need to coincide with defueling schedule. Therefore, the amount of fuel sold would be determined by 

commercial interest and purchasers’ ability to receive the fuel at the time of gravity-based defueling.

As in Alternative 2, movement of fuel from RHBFSF would be accomplished by gravity flow of the fuel

through existing DoD piping and associated infrastructure to a fuel loading pier at JBPHH. Tanker ships 

would arrive at Pearl Harbor and be guided by tugboats to the JBPHH fueling pier. Fuel sold commercially 

would be loaded onto purchasers’ commercially-operated tanker ship(s) using the same pace and 

procedure as Alternative 2. The DoD’s role in the transaction is fulfilled after fuel is loaded. Tanker ships 

would then depart the fueling pier guided by tugboats through Pearl Harbor, and transit to destinations 

determined by the fuel purchaser. The transit route and destination of sold fuel is at the discretion of the 

non-federal entity purchaser and not a part of the federal action, and therefore is not analyzed in this 

EA/OEA.

With Alternative 3, the portion of fuel that is not sold would be relocated from RHBFSF to existing locations 

within the DoD fuel supply chain by ocean transit. Relocation of fuel would be accomplished using the same 

process as Alternative 2. Potential DoD fuel supply chain receiving locations and upper bound of tanker 

transits to each location are the same as outlined in Alternative 2, shown in Table 2-1. A combined 

maximum of ten tanker loads of fuel would be commercially sold or relocated within the DoD fuel supply 

chain with Alternative 3 (e.g., three sold and seven relocated).

With Alternative 3, the process for removing flowable tank bottoms would be the same as Alternative 2, 

including staging the eleventh tanker/barge at the fueling pier for approximately two to five weeks to receive 

the flowable tank bottoms and fuel from the pipeline unpacking process. This remaining fuel would be 

distributed in the same manner as Alternative 2, with Flowable Tank Bottoms Options A: UTF and Option 

B: Commercial Sale remaining the same for Alternative 3.

The removal of flowable fuel from RHBFSF would be complete following the execution of Flowable Tank 

Bottoms Option A or B. The RHBFSF would then transition to the Navy for follow-on closure activities
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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beyond the scope of the Proposed Action and not included in this EA/OEA, which includes site remediation 

and potential beneficial non-fuel re-use.

2.4 ALTERNATIVES CONSIDERED BUT NOT CARRIED FORWARD FOR 

DETAILED ANALYSIS

Additional alternatives were considered, but eliminated from further evaluation because they did not fulfill 

the minimum objectives and screening criteria to achieve the purpose and need for the Proposed Action as 

detailed in Table 2-2.

Table 2.4-1. Alternatives Considered but Eliminated from Further Study 

Name of Alternative Why Alternative was Excluded

Transfer of Fuel from 

Red Hill to 

Transportation Nodes on 

Oahu via road (e.g., use 

of tanker trucks )

Large tanker trucks for fuel typically hold between 9,000 and 9,800 gallons. With 

approximately 104 million gallons to transport from the bulk tanks at RHBFSF, this alternative 

would require between 10,600 and 11,560 trucks. This number of vehicle trips would increase 

the defueling time significantly and increase traffic and air pollution in the area. This action 

would involve thousands of fuel transfer actions that would be prone to spills and would not 

meet screening criteria number one. To achieve the defueling timeline goals and to limit 

environmental impacts, the use of tanker trucks for this action was eliminated from further 

study in this EA/OEA.

Sale of and Transfer of 

Fuel to Honolulu Airport 

on Oahu

DLA considered selling fuel from RHBFSF to commercial entities on Oahu, including the 

Daniel K. Inouye International Airport located within 3.5 miles of the RHBFSF. DLA 

exchanged correspondence with the airport management about this alternative. However, the 

airport uses Jet-A fuel, and the fuels available from RHBFSF are not formulated for

commercial aircraft operations. Of the three fuel types at RHBFSF (see Section 1.4), the 

closest type to Jet-A is F-24; however, the military additives in F-24 may adversely affect 

some commercial fuels operations at the airport which does not wish to pursue this 

alternative.

Sale of and Transfer of 

Fuel to Oil-fueled Electric 

Plants on Oahu

In 2021, approximately 65 percent of utility-scale electric generation came from fuel oil power 

stations. The Kahe, Waiau, and Campbell Industrial Park stations (owned by Hawaiian

Electric) in Honolulu County provide up to 1230 MW of power. However, the best use for the 

fuels from RHBFSF would be for their intended military applications if they are deemed to 

meet quality specifications. DLA’s directive mandates the most economical and beneficial use 

of fuels within the Defense Fuel Supply System. For any fuels that do not meet specifications 

for DoD use, DLA would accept bids from private entities to sell the fuel but would not restrict 

sales to Hawaii in order to meet screening criteria number seven and receive the best price

and value for the government

Donation of Fuel By DLA Directive 5105.22, DLA is required to ensure the best value supply chain support to 

the customer for all managed commodities and services DLA provides. DoD Manual 4140.25-

M “DoD Management of Bulk Petroleum Products, Natural Gas, and Coal” requires DLA to: 

store and distribute petroleum products in an economical and efficient manner; maintain 

essential and properly positioned inventories in support of peacetime and wartime 

requirements; and to provide efficient financial management and effective use of resources 

for DoD bulk petroleum while eliminating duplication of effort. Because defense fuels from 

Red Hill remain a needed commodity within the fuel supply chain, donating fuel from 

RHBFSF would not be an efficient or financially-sound practice. Furthermore, DLA does not 

have the authority to designate this fuel as government surplus or to donate it to private 

entities. This alternative would fall outside DLA’s legal authority and conflicts with screening 

criteria number 7 in Section 2.2. For these reasons, this alternative was eliminated from 

further evaluation. 

Removal of Fuel from 

RHBFSF tanks using a 

vacuum truck

Using vacuum trucks would require thousands of truck transits. Larger-scale vacuum trucks 

can hold 8,000 gallons; requiring approximately 13,000 truck-loads. The number of vehicle 

trips required would increase the defueling time significantly and increase traffic and air 

pollution in the area. This action would involve thousands of fuel transfer actions that would 

be prone to spills and would not meet screening criteria number one. To achieve the 

defueling timeline goals and to limit environmental impacts, the use of vacuum trucks for this 

action was eliminated from further study in this EA/OEA.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Name of Alternative Why Alternative was Excluded

Use of multiple fueling 

piers

DLA considered the possibility of fueling tanker ships at JBPHH simultaneously at more than 

one pier to reduce the time to defuel the RHBFSF. However, because there is only one 

pipeline from the UGPH, splitting the fuel flow between two locations would cut the rate of 

flow in half, ultimately not saving appreciable time. Screening criteria number one in Section 

2.2 requires defueling from RHBFSF to be completed in a safe manner. The number of 

appropriately-trained staff for fueling operations on the pier is limited. Transferring fuel to a 

single vessel may take up to three days, requiring more than one shift. With these intense 

periods of activity, it is important to allow rest for employees between shifts so they can 

remain focused and vigilant. Expanding fuel transfer to more than one pier or more than one 

vessel of at time was considered by JTF-RH as potentially unsafe based on worker 

availability and therefore does not meet screening criteria number one. 

Movement of fuel to 

Campbell Industrial Park, 

West Oahu using

commercial pipeline

DLA considered the use of commercial petroleum pipelines to move fuel from RHBFSF to 

Campbell Industrial Park in West Oahu. The pipelines run from the Kapolei area in western 

Oahu to the Daniel K. Inouye International Airport (HNL) via Sand Island/Port of Honolulu 

area, and can be accessed via an existing connection with JBPHH. Transfer of fuel using 

these pipelines would require approximately fifteen days of uninterrupted use to drain one 

RHBFSF tank, or approximately 72 days to move all the fuel from RHBFSF. These 

commercial pipelines are critical to commercial operations, including the HNL airport. Limited 

storage capacities and significant usage at HNL airport require a continuous supply. The 

extended use of the commercial pipeline by DoD to move fuel from RHBFSF to Campbell 

Industrial Park contracted storage is not feasible because it would unduly burden the Oahu 

commercial fuel supply chain and therefore does not meet screening criteria number three 

described in Section 2.2.

Transport of fuel on 

aircraft

The highest capacity Air Force KC model military tanker aircraft has a maximum payload of

356,000 pounds (or 52,740 gallons) of aviation fuel. Relocating all the fuels from RHBFSF 

using this as a primary method would require at least 1,970 individual aircraft fueling events, 

which may increase the potential for spills during transfers. Overall, this alternative would not 

be expeditious and would not meet screening criteria number one described in Section 2.2.

Storage in Commercial 

Tankers offshore of 

Oahu

Storing the fuel in commercial tankers offshore Oahu for an extended period of time while the 

fuel is waiting to be consumed was determined not to be economical and a responsible use of 

taxpayer’s resources, and therefore does not meet screening criteria number 7 described in 

Section 2.2. It is more cost effective to relocate the fuel within the DoD supply chain once it is 

loaded onto the tankers. Relocating the fuel within the DoD fuel supply chain would also 

reduce other DoD costs associated with the purchase and transport of routine or planned fuel 

deliveries to the potential receiving locations. For these reasons, this alternative was 

eliminated from further evaluation.

2.5 BEST MANAGEMENT PRACTICES

Best Management Practices (BMPs) reduce potential impacts by avoiding, minimizing, or eliminating 

impacts. BMPs are existing policies, practices, and measures that JTF-RH and DLA would adopt to reduce 

the environmental impacts of designated activities, functions, and processes. 

BMPs are distinguished from mitigation measures because they are inherently part of the Proposed Action. 

Recognition of these practices prevents unnecessarily evaluating impacts that are unlikely to occur. Table

2.5-1 lists BMPs that JTF-RH and DLA would implement as part of the Proposed Action.

Table 2.5-1. Best Management Practices

Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

BMP-1; Tanker 

ship

arrival/departure

safety

Ship 

movement 

accident

avoidance

• JBPHH Port Operations would be notified in advance of arrival and 

departure dates for tanker ships.

• Tanker captain would communicate with the JBPHH Harbormaster upon 

arrival to Pearl Harbor in accordance with base policy.

• Tanker ships would be guided by tugboats from Pearl Harbor to and from

the fueling pier.
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Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

BMP-2; Prestaging spill 

control 

products, 

equipment and 

watch standers.

Prevent 

spread of 

potential fuel 

spills at the 

pier

• Oil-absorbent booms would be pre-deployed around the tanker and the 

area immediately around the pier. Additional booms would be readily 

available for deployment. 

• Skimmer boats would be pre-staged to immediately begin removing the 

fuel contained within the oil-absorbent boom(s). 

• Rovers and/or watch standers would be on the pier to inspect and 

perform leak checks. There are Rovers on duty 24 hours per day, seven 

days per week.

• Rovers would complete checklists documenting their visual inspections 

twice per shift. Checklists would be reviewed by the Fuel Operations 

Supervisor.

• Spill kits, absorbents and small portable pumps would be readily available 

and pre-staged.

• In the event of a spill at the pier, notification and response procedures 

contained in the Commander Navy Region Hawaii Integrated Contingency 

Plan would be followed.

BMP-3; 

Preparation for 

defueling (prefueling checks)

Avoidance of 

unsafe work 

practices; 

prevention of 

spills; 

The transfer of fuel from RHBFSF to vessels would follow the established 

DFSP Pearl Harbor Bulk Terminal Operation, Maintenance, Environmental 

and Safety Plan (that governs the specific event’s Operations Order) for the 

issuance of fuel to marine vessels from shore facilities. 

Several documents would be filled out by the team performing pier fueling 

operations, including but not limited to: a declaration of inspection certificate, 

hose inspection sheet, tanker/barge material inspection form, transfer record, 

running gauge record, barge ullage report, notice of readiness (provided by 

the vessel).

The transfer process first requires approval by the base Commanding Officer. 

A series of checks would then be performed:

• The Person in Charge (PIC) would hold a pre-transfer conference and 

complete and sign the FLC Fuel Form 703-04, Declaration of Inspection 

before the issue operation begins.

• PIC establishes communication with the vessel’s captain or vessel PIC.

• Sump containments would be inspected for standing water or fuel.

• All fueling hoses would undergo tightness testing.

• Prior to any fuel movement operation, would review and conduct a line 

pack and pressure test on the piping identified in the Operations Order; 

Team members walk the pipeline to evaluate its condition.

• Control Room Operator at the UGPH ensures that the emergency 

shutdown system (e.g., shutoff buttons, voice communications) are in 

position and operable.

• In coordination with the UGPH Control Room, pipeline valves would be

opened sequentially in radio communication with team members who 

verbally confirm valve openings.

• As the pipeline is pressurized, the visual inspectors and Control Room 

Operator would evaluate system pressure gages and verify pipeline 

integrity.

BMP-4; Vessel 

fueling 

procedures

Prevention of 

spills;

Prevention of 

accidents.

• The terminal PIC and vessel PIC must be on duty at the terminal during 

the entire transfer operation.

• The PIC and fueling team would periodically check for leaks and any 

sheen on the water next to the pier. 

• Throughout the fuel transfer operation, the PIC and fueling team would 

periodically observe the surface of the water between the vessel and the 

shore for sheen. Any sign of oil on the water will be reason to terminate the 

operation.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

• PIC would conduct occasional checks of the valve pits that are in use for 

indication of leaks.

• On regular intervals, the PIC would confirm the ship’s received quantities 

with Navy’s calculated quantities to determine any inconsistencies (a 

possible indicator of leaks).

• The Control Room Operator would monitor fuel system pressure gauges 

for pipeline tightness.

BMP-5; Fueling 

operation

temporary shutdown authority

Prevention of 

spills or 

accidents.

• The terminal PIC has the authority to shut down any operation if vessel 

personnel violate any of the rules in the Operations Order at any time or 

refuse to correct unsatisfactory conditions promptly. Safety officials 

(JBPHH, Fleet Logistics Center Pearl Harbor, Occupational Safety and 

Health Administration [OSHA]) also have the authority to shut down unsafe 

operations.

• At the discretion of the terminal PIC and/or vessel PIC, all operations 

would cease in the event of an electrical storm (within five miles), high 

winds, earthquake, tsunami watch or warning, terror threat or incident, or 

other accident that may cause the operation to potentially be unsafe.

BMP-6; System 

redundancy 

measures

Prevention of 

spills or 

accidents

• UGPH equipped with backup electrical power. 

• Fuel lines from RHBFSF to fueling pier equipped with automatic fuel 

handling equipment, including remotely operated valves that can stop fuel 

flow at multiple valve station locations upstream and downstream of the 

UGPH.

BMP-7; JBPHH 

Personnel 

training and rest 

periods

Prevention of 

spills or 

accidents

• Personnel implementing and monitoring the fuel transfer from the RHBFSF 

to vessels at the JBPHH pier would have pre-requisite training to conduct 

the operations outlined in the operations order

• Personnel would have previously received annual spill response training

and review spill response as part of weekly safety trainings. 

• Personnel implementing and monitoring fuel transfer at JBPHH would be 

assigned to shifts that allow for adequate rest. A health risk assessment

will be performed by JTF-RH occupational health and safety professionals 

to review and validate staffing plans. 

BMP-8; 

Hazardous 

waste 

management

Prevention of 

releases of 

hazardous 

substances; 

Reduction of 

hazardous 

waste 

generation

• Hazardous and non-hazardous wastes including any contaminated spill 

response materials or debris would be handled, transported, disposed of in 

accordance with applicable federal and state regulations.

• Spill contaminated materials would be packaged in U.S. Department of 

Transportation (DOT) approved containers marked and labeled in 

accordance with DOT and EPA requirements.

• Where possible, dispose of non-hazardous wastes such as oilcontaminated absorbents at the Honolulu Program of Waste Energy 

Recovery (H-Power). Non-hazardous wastes that are to be disposed of at 

local permitted facilities must meet all requirements of the destination

facility.

BMP-9; 

Shipment

tracking

Marine 

Accidents and 

prevention of 

spills

• Position reports are transmitted from the tanker ships to MSC daily while in 

transit. Reports include tanker ship location, direction, and speed. Position 

reports would include information on any diversions or delays.

• DLA inventory management system is updated when fuel shipment is 

received at destination.

BMP-10; 

Protection of 

marine species 

in Pearl Harbor

Protection of 

marine 

protected 

species in 

Pearl Harbor

• Personnel will not attempt to disturb, touch, ride, feed, or otherwise 

intentionally interact with any protected species.

• Personnel will stay more than 150 ft. away from protected marine species 

including sea turtles and Hawaiian monk seals.

Personnel will document and report to the JBPHH Natural Resources 

Manager all sightings of ESA-listed species during the fuel-loading process. 

The JBPHH Natural Resources Manager will share reports with NMFS. 
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Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

• Any protected species that are injured or killed will be reported to the 

JBPHH Natural Resources Manager immediately (within 24 hours at the 

latest). 

• If an ESA-listed marine species is determined to have been disturbed, 

harassed, harmed, injured, or killed, it will be immediately reported to the 

JBPHH Natural Resources Manager will ensure that this information is 

reported to NMFS within one business day.

• If an injured, sick, or dead protected marine species is observed, 

personnel will notify the JBPHH Natural Resources Manager who will 

contact NMFS and notify the stranding response program in real-time.

BMP-11; 

Protection of 

marine species 

from vessel 

collisions

Prevent

vessel 

collisions with 

marine 

species

Vessels in Pearl Harbor will employ measures to reduce potential vessel 

collisions and interactions with marine species:

• Operational and maintenance standards for vessels will be practiced, 

and vessel operations will only occur during ocean conditions that do not 

compromise safe operation with contingency plans to cancel or delay the 

action for favorable weather conditions.

• Vessel operators will halt or alter course to remain at least 150 ft. from 

ESA-listed marine species and, to the extent practicable, marine 

mammals.

• Vessels shall operate at speeds safe for the location and conditions. Per 

the Navy Region Hawaii Port Environmental Manual (CNRH 2018): 

Within Pearl Harbor, this is ten knots or less. Operators will be 

particularly vigilant to watch for turtles at or near the surface in areas of 

known or suspected turtle activity and, if practicable, reduce vessel 

speed to five knots or less.

• To the extent practicable, if approached by an ESA-listed marine species 

or marine mammal, the vessel operator will put the engine in neutral if 

the animal is within 150 ft. (45.7 m) of the vessel, until the animal has 

moved at least 50 ft. (15.2 m) away, and then engage the engine and 

slowly move way to 150 ft. (45.7 m) or more from the animal.

• Vessel operators will not encircle or trap marine mammals or ESA-listed 

marine species between multiple vessels or between vessels and the 

shore.

• Vessels will take reasonable steps to alert other vessels in the vicinity of 

marine species.

• Vessels will follow established transportation channels whenever 

practicable.

• Vessels will not allow lines to remain in the water, and no trash or other 

debris will be thrown overboard, thereby reducing the potential for 

marine mammal entanglement.

Transiting vessels will employ measures to reduce potential vessel collisions 

and interactions with marine species:

• To the extent practicable, all transiting vessels shall adhere to all 

voluntary speed restrictions in areas where the risk of vessel strikes is 

high, as identified in the NMFS Concurrence Letter provided in Appendix 

B.

• Vessels shall be up to date on all regional speed restrictions.

• To the extent practicable during transit, vessel operators will halt or alter 

course to remain at least 500 yards from whales and 200 yards from 

other marine mammals. A safe distance shall also be kept between the 

vessel and sea turtles.

Vessels in receiving port locations will employ measures to reduce potential 

vessel collisions and interactions with marine species:

• Operational and maintenance standards for vessels will be practiced, 

and vessel operations will only occur during ocean conditions that do not 
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Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

compromise safe operation with contingency plans to cancel or delay the 

action for favorable weather conditions.

• Vessels shall operate at speeds safe for the location and conditions.

• Vessels shall, at all times, proceed at a safe speed to take proper and 

effective action to avoid collision and be stopped within a distance 

appropriate to the prevailing circumstances and conditions.

• Vessels at receiving ports shall comply with all local speed requirements 

and port regulations.

• Vessel operators will not encircle or trap marine mammals or ESA-listed 

marine species between multiple vessels or between vessels and the 

shore.

• Vessels will take reasonable steps to alert other vessels in the vicinity of 

marine species.

• Vessels will follow established transportation channels whenever 

practicable.

• Vessels will not allow lines to remain in the water, and no trash or other 

debris will be thrown overboard, thereby reducing the potential for 

marine mammal entanglement.

BMP-12; Foul 

weather 

preparation

Prevention of 

spills or 

accidents

As practicable, operations will be conducted during calm sea states with work 

stoppages during high surf, winds, and currents. In the event of approaching 

foul weather (e.g., tropical storms and hurricanes), equipment will be either 

removed from the fueling pier or adequately secured. Hurricane season in the 

Pacific is from 1 June to 30 November, however tropical storms can and do 

occur year-round. Hawaii utilizes the National Weather System’s warning and 

watch advisories, and Navy Region Hawaii adheres to the following Condition 

of Readiness (COR) Levels to forecast destructive force winds (50 miles per 

hour): 

i. COR V: Lowest condition of hurricane readiness; destructive force 

winds are not expected. 

ii. COR IV: first condition of heightened hurricane readiness; within 72 

hours. 

iii. COR III: within 48 hours. 

iv. COR II: within 24 hours. 

v. COR I: within 12 hours. 

In order to provide 48 hours leeway preparation, work activities will 

immediately begin the appropriate removal and/or securement of all in water 

equipment, vessels and barges once a COR III is triggered.

BMP-13; 

Biosecurity

Prevention of 

introduction of 

alien or 

invasive 

species

Vessels will comply with requirements of the Navy Region Hawaii Port 

Environmental Manual to prevent the introduction of alien or invasive species 

into the harbor: 

• Prior to entering Pearl Harbor and more than 12 nautical miles (NM)

offshore, wash down anchors, anchor chains, anchor chain lockers, and 

other items that may have been subject to marine growth or collection of 

sediment, mud, and silt at another port. This will avoid introduction of 

alien species into Hawaii's nearshore environment. 

• If ballast water has been loaded from an area that is potentially polluted 

or within 3 NM from any shore, conduct a ballast water exchange outside 

12 NM from Hawaii to prevent the introduction of water-borne alien 

species into Hawaii's nearshore environment. 

• Rat guards shall be placed by ship’s company on all mooring lines and 

other connecting lines, such as service lines, between the ship, piers, 

and seawalls immediately upon berthing and during the entire time the 

vessel lies alongside a pier. 
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Best 

Management 

Practice

Impacts 

Reduced/

Avoided

Description

• Ensure that all stores, equipment, supplies, personal items, etc., 

originating from New Guinea, Australia, or Guam are inspected for the 

brown tree snake. This inspection may be accomplished during onloading of such stores or while underway. In the event the presence of 

an alien species is suspected, the item should not be off-loaded. Port 

Operations should be notified immediately, and the item should be 

quarantined until the item can be inspected and cleared. If a snake is 

sighted aboard ship, aircraft, or during training exercises on land, 

restrain, contain, or kill the snake until appropriate authorities arrive. 

Immediately notify JBPHH security of all snake sightings at 911. 

It is critical that all attempts be made to prevent the introduction of alien or 

invasive species into receiving port locations.

• Vessels must comply with all requirements implemented at the receiving 

port locations to prevent the introduction of alien or invasive species.

U.S. and International Regulations and Standards for Tanker Ships

Tanker ship operators will also comply with standard operating procedures and comply with applicable 

regulations. DoD commercial fuel transport contracts provide limited ability to impose additional BMPs 

outside of DoD ports and instead rely on compliance with U.S. and international regulations. These U.S. 

and international regulations for tanker ships provide several safeguards and mandatory procedures to 

prevent pollution. Some of these safeguards and procedures would include (but are not limited to):

• Tankers ships will comply with the US standard for the storage and transport of liquid cargo in 33 

CFR, Chapter I, Subchapter 0, Part 157 which includes details on specific ship build, regulatory 

standards and spill containment procedures. These regulations for oil tankers are among the most 

detailed, environmentally focused and strictly enforced regulations in the maritime industry. Plan 

reviews, certifications, and inspections of tankers are performed by the U.S. Coast Guard (USCG), 

or a USCG-certified class society (e.g., American Bureau of Shipping [ABS]). 33 CFR, Chapter I, 

Subchapter 0, Part 157 is comprehensive and gives direction on (but not limited to):

o Design, equipment and installation of tank vessels

o Detailed on-load/offload operation guidance

o Crude oil management 

o Oil spill mitigation and response

o Penalties for oil spills

• Tankers ship operators will comply with international regulatory guidelines including those of the 

International Safety Guide for Oil Tankers and Terminals (ISGOTT). The ISGOTT aligns tanker 

industry standards providing best technical guidance on oil tanker and terminal operations.

• Tanker ships will comply with additional regulatory compliance and oil spill response programs 

including:

o Condition Assessment Programs - specialized surveys performed by Ship Classification 

Societies (such as ABS) that detail assessment of a ship's actual condition, based upon 

strength evaluation, and fatigue strength analysis as well as detailed on-site systematic 

inspection of hull, machinery and cargo systems. A mitigation inspection program through 

the last five years of service (maximum twenty years' service for tankers) is mandatory.
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o Vessel Response Plans or Shipboard Oil Pollution Emergency Plans - International 

Convention for the Prevention of Pollution from Ships (MARPOL) requires owners and 

operators to prepare in the event of an oil spill.

• Tanker ships will comply with environmental/marine species regulations that are specific to local 

zones. These are well known to the international maritime industry passing through these waters 

with up to date warnings of specific sightings or required increased vigilance issued by the USCG 

Captain of the Port.

2.6 MITIGATION MEASURES

Mitigation measures are measures to reduce or offset anticipated adverse effects. They are distinguished 

from BMPs because they are implemented solely for the Proposed Action (not routinely implemented) and 

are often the result of action-specific consultation with regulatory agencies at the local, State or Federal 

level. Mitigation measures are often tracked at a more robust level within the DoD to ensure they are fulfilled 

in accordance with applicable agreements.

BMPs identified in Tables 2.5-1 are sufficient to avoid and minimize anticipated adverse impacts from the 

Proposed Action. Therefore, no mitigation measures are required for the Proposed Action.
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3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES

This section presents a description of the environmental resources and baseline conditions that could be 

affected from implementing any of the alternatives and an analysis of the potential direct and indirect effects 

of each alternative.

All potentially relevant environmental resource areas were initially considered for analysis in this EA/OEA. 

In compliance with NEPA, the Council on Environmental Quality (CEQ) guidance, EO 12114, and 

Department of Navy guidelines; the discussion of the affected environment (i.e., existing conditions) focuses 

only on those resource areas potentially subject to impacts. Additionally, the level of detail used in 

describing a resource is commensurate with the anticipated level of potential environmental impact. 

This section addresses public health and safety, water resources, marine biological resources, hazardous 

materials and waste, and air quality and greenhouse gases.

In accordance with CEQ memorandum CEQ-NEPA-2020-01 dated September 14, 2020 (CEQ, 2020), the 

DoD and JTF-RH and DLA considered whether the defueling action could be deemed an emergency action. 

To address the public interest in this action and the need to defuel quickly and safely, JTF-RH and DLA 

chose to prepare a concise, focused EA/OEA as recommended by this CEQ memorandum. To focus the 

analysis, potential impacts to the following resource areas were not analyzed in detail in this EA/OEA as

they are anticipated to be negligible or non-existent:

• Cultural Resources: Defueling of the RHBFSF through existing pipelines and relocation by fuel 

tanker would involve no activities with the potential to affect historic buildings, archaeological sites, 

or traditional cultural properties. Cultural resources would not be affected by the Proposed Action.

Consistent with 36 CFR § 800.3(a)(1), if the undertaking is a type of activity that does not have the 

potential to cause effects on historic properties, no further obligations under Section 106 of the 

National Historic Preservation Act (NHPA) apply. Under the Programmatic Agreement (PA) among 

the Commander Navy Region Hawaii, the Advisory Council on Historic Preservation, and the 

Hawaii State Historic Preservation Officer regarding Undertakings in Hawaii signed October 2012, 

which covers the RHBFSF, an undertaking that does not have the potential to cause effects on 

listed, contributing or eligible properties, does not require further review under the PA and the 

National Historic Preservation Act. All such undertakings and determinations made will be 

documented, recorded, and reported in accordance with reporting requirements of this PA.

• Geological Resources: Defueling and relocation of fuel from RHBFSF would not require any 

grading, digging, drilling, or other types of subsurface disturbance. Geologic resources would not 

be affected by the Proposed Action.

• Terrestrial Biological Resources: Defueling and relocation of fuel from RHBFSF would not remove, 

modify, physically disturb, or disrupt any terrestrial vegetation, terrestrial wildlife, or terrestrial 

special status species such as migratory birds or seabirds. Terrestrial biological resources would 

not be affected by the Proposed Action.

• Visual Resources: The action would involve existing infrastructure and the temporary docking of 

fuel tankers at an existing fueling pier. Large vessels routinely dock at the JBPHH fueling pier. No 

permanent changes to visual resources would occur.

• Land Use: Defueling and relocation of fuel from RHBFSF would use existing infrastructure and 

existing fuel receiving locations around the Pacific. Defueling itself would not change land use at 

Red Hill; however, the site’s closure and potential re-uses (uses that are unknown at this time) may 

involve land use changes that would be subject to separate environmental compliance actions.

• Utilities: Defueling and relocation of fuel from RHBFSF would use existing infrastructure that is 

designed to accommodate fuel loading/unloading operations for large vessels. The action would 

not cause any utility service disruptions, nor create any new demand on utilities.

• Airspace: The action would not increase aviation operations nor affect airspace.
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• Noise: Defueling at RHBFSF would use existing pipelines and the existing UGPH where outside 

noise levels are negligible and not perceivable by the community. Because tanker ships are fueled 

by gravity, the fueling transfer process does not generate noise levels perceptible to local 

residential areas. The arrival of tankers and use of tugboats may generate occasional noise from 

safety horns and vessel motors but such noises are considered part of the existing environment 

(routine and commonplace) in Pearl Harbor as large vessels are fueled or deliver fuel at this pier 

on average fourteen times per month. 

• Road Transportation: Relocation of fuel from RHBFSF would not occur with road vehicles for the 

reasons described in Table 2.4-1. The process would be managed by existing workforce where no 

increase in daily vehicle trips on Oahu are expected.

• Socioeconomics: Fuel relocation would occur within the existing DoD fuel supply chain. Any 

relocation or commercial sale of the fuel would be conducted within existing DLA acquisition 

regulations and would not affect local economies on Oahu or potential receiving locations. 

Additionally, any commercial sale under the Proposed Action would comprise a minor Federal 

revenue stream within the DoD when compared to the DLA’s annual 3.4 billion gallons of net 

petroleum sales (DLA, 2022). 

• Environmental Justice: Defueling and relocation of fuel from RHBFSF would use existing 

infrastructure and fueling processes on JBPHH. Relocated fuels would be delivered to existing 

defense fuel support points in the U.S. or overseas or existing commercial fuel storage facilities. 

The process would not introduce environmental impacts to low-income or minority populations.

• Climate Change/Resiliency: Defueling and relocation of fuel from RHBFSF would be a one-time 

action (albeit over the course of several months) limited to a maximum of eleven tanker transits. 

No new facilities or infrastructure would be constructed as part of the Proposed Action that would 

require consideration of the effects of climate change. Emissions of greenhouse gases (GHGs) are 

analyzed under Air Quality and Greenhouse Gases Section 3.5.

3.1 PUBLIC HEALTH AND SAFETY

This discussion of public health and safety includes consideration for any activities, occurrences, or 

operations that have the potential to affect the safety, well-being, or health of members of the public. A safe 

environment is one in which there is no, or optimally reduced, potential for death, serious bodily injury or 

illness, or property damage. The primary goal is to identify and prevent potential accidents or impacts on 

the general public. Public health and safety risks considered in this EA/OEA pertain to community 

emergency services, workforce safety, and environmental health and safety risks to children and the 

general public.

Community emergency services are organizations which ensure public safety and health by addressing 

different emergencies. The three main emergency service functions include police, fire and rescue service, 

and emergency medical service.

Environmental health and safety risks to children are defined as those that are attributable to products or 

substances a child is likely to come into contact with or ingest, such as air, food, water, soil, and products 

that children use or to which they are exposed. Safety risks to children may also include physical hazards 

from vehicles and moving equipment, access to attractive nuisances (e.g., construction site), or disruptive 

noise.

Regulatory Setting

The regulatory setting for public health and safety includes laws and regulations pertaining to the 

transportation and treatment of hazardous materials and waste exposure, contaminants in the air and water, 

noise pollution, workforce safety, and the health and safety of children and vulnerable populations.

EO 13045, Protection of Children from Environmental Health Risks and Safety Risks, requires federal 

agencies to “make it a high priority to identify and assess environmental health and safety risks that may 
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disproportionately affect children and shall ensure that its policies, programs, activities, and standards 

address disproportionate risks to children that result from environmental health risks or safety risks.”

Affected Environment

The “region of influence” (ROI), or area where impacts were assumed likely to occur, for the public health 

and safety analysis includes areas at JBPHH where the Proposed Action would take place. This includes 

areas of fueling infrastructure, the fueling pier, and the tanker transit routes in Pearl Harbor. There are no 

residential areas included in the ROI. 

JBPHH is a secure military installation, with access limited to military personnel, civilian employees, 

contractors, and military families. The public is allowed access to JBPHH Main Base for specific purposes 

(e.g., special events, media coverage, visiting houseguests), but entry requires a background check and a 

sponsor. The public can access the nearby Pearl Harbor National Memorial, the USS Arizona Memorial, 

the Battleship Missouri Memorial, and the Pearl Harbor Aviation Museum, but public access does not 

include the ROI. JBPHH security would prevent the public and children from accessing areas of the ROI 

including the UGPH, fueling infrastructure, and the fueling pier. Emergency services, including fire, health, 

and security, are provided by the trained military and civilian staff at JBPHH.

Impacts to public health related to underground sources of drinking water were considered for communities 

of Oahu that receive drinking water pumped from the Waimalu and Moanalua aquifers, which are located 

near RHBFSF (Figure 3.1-1). About 99 percent of Hawaii’s domestic water supply comes from groundwater 

sources (USGS, 2016). Section 3.2.2.1 provides additional details on groundwater near RHBFSF.
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Figure 3.1-1. Waimalu and Moanalua Aquifer Location

Public health and safety impacts were not assumed likely to occur at the potential receiving locations 

because fuel deliveries to these locations would occur in lieu of routine or planned fuel supply deliveries. 

Therefore, the Proposed Action would not affect the safety, well-being, or health of children or other 

members of the public at these locations.

Environmental Consequences

The public health and safety analysis addresses issues related to the health and well-being of the public in 

the ROI. Specifically, this section provides information on hazards associated with implementation of the 

Proposed Action that could affect people living, working, or recreating in the ROI.

Potential risks to public health and safety that may occur as a result of the action alternatives include 

increased demand on emergency services, increased potential for occupational accidents, and increased 

vessel traffic and potential for vessel accidents. Impacts related to the potential for worker exposure to 

hazardous substances (e.g., fuel) are discussed in Section 3.4. Impacts related to air quality are discussed 

in Section 3.5.

Long-term beneficial effects to public health that were considered include the reduced potential for impacts 

to underground sources of drinking water as a result of RHBFSF defueling and follow-on actions including 

closure. 

Ambient noise resulting from the Proposed Action would not be perceivable by local residential areas. 

Tanker ships are fueled by gravity, the fueling transfer process does not generate noise levels perceptible 

to local residential areas where children would be present. The arrival of tankers and use of tugboats may 

generate occasional noise from safety horns and vessel motors, but such noises are considered part of the 

existing environment in Pearl Harbor.

Security measures in place at JBPHH would prevent children from accessing areas of the ROI where they 

may be exposed to environmental health and safety risks including hazardous substances or physical 

hazards. Therefore, these effects to children were not further analyzed.

Drinking Water Contamination

The potential for impacts to human health through contamination of Oahu drinking water supplies was also 

considered. Exposure to water containing petroleum can cause adverse effects on the respiratory system, 

gastrointestinal tract, nervous system, skin, and ears, nose, and throat (Troeschel et al., 2022). In addition 

to the adverse physical health effects, people affected by previous contaminated drinking water incidents 

reported mental health symptoms such as anxiety, agitation/irritability, and difficulty sleeping (Troeschel et 

al., 2022). 

The ROI at JBPHH and the potential fuel receiving location at Campbell Industrial Park, West Oahu are 

both located below the Underground Injection Control (UIC) line, meaning that these locations are outside 

of areas identified by DOH as underground sources of drinking water. Practically, this means that a potential 

fuel spill at the JBPHH fueling pier or the Campbell Industrial Park receiving location would not impact

underground aquifers that are used as sources of drinking water. For maps depicting areas below the UIC 

line, see: https://health.hawaii.gov/sdwb/underground-injection-control-program/. 

A large fuel spill during defueling from the RHBFSF tanks or pipelines, or from the pipeline in the 

underground tunnel connecting RHBFSF to the UGPH, could potentially contaminate underground sources 

of drinking water. DoD developed a Red Hill Defueling Plan and Supplements 1A, 1B, and 2 to address 

system deficiencies, identify repairs, develop defueling procedures, and implement spill prevention 

measures. The plan also includes preparedness measures for spill containment and response. Measures 

required by this plan will reduce the likelihood and severity of a spill during the defueling operation so that 

the risk of a spill impacting underground sources of drinking water would be considered highly unlikely. The 

EPA and DOH are providing oversight of the defueling process. This phase of the defueling operation is 
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considered nondiscretionary (see Section 1.5), and is not considered in the analysis of action alternatives. 

To view the Red Hill Defueling Plan and Supplements 1A, 1B, and 2 see: 

https://cnrh.cnic.navy.mil/Operations-and-Management/Red-Hill/DoD-RHBFSF-Defuel-Plan/.

3.1.3.1 Alternative 1: No Action Alternative

Under the No Action Alternative, flowable fuel at RHBFSF would be drawn down over a period of 

approximately ten to fourteen months after DOH approval of the gravity-based defueling operation. Fuel 

from RHBFSF would be transferred to the UTF or to fueling piers at JBPHH through existing infrastructure. 

Fuel from the UTF can then be sent by pipeline to Hickam Field, fuel loading piers, and truck loading racks 

for distribution to customary defense customers for consumption. 

A low demand for JP-5 fuel at JBPHH may require JP-5 movement by vessel to points of immediate 

consumption as part of a stock rotation program to increase the rate of JP-5 consumption. Additionally, JP5 may be regraded to F-24 or F-76 for consumption at JBPHH. Existing locations within the DoD fuel supply 

chain that may receive relocated fuel from RHBFSF as part of Alternatives 2 and 3 would continue to receive 

their regular fuel deliveries by tanker ships from other fuel sources.

Under the No Action Alternative, there would be no change to the demand on emergency services or 

potential for occupational accidents because these actions represent routine operations at JBPHH. There 

may be a small increase in vessel traffic in Pearl Harbor if JP-5 stock rotation was required due to low 

demand for JP-5 fuel at JBPHH. This increase in vessel traffic would be an average of less than one vessel 

movement per month. There are typically about 2,000 annual naval vessel and submarine movements 

(i.e., one-way trips) in Pearl Harbor. Therefore, the JP-5 stock rotation vessels would account for a less 

than one percent increase in vessel traffic, and could be considered negligible. The No Action Alternative 

would have no significant adverse effects on public health and safety.

The No Action Alternative would have a long-term beneficial impact on underground sources of drinking 

water because it would ultimately defuel the RHBFSF tanks. Flowable fuel would be removed over the 

course of an estimated ten to fourteen month period from the time DOH authorizes defueling, thereby 

eliminating the risk of fuel spills from the facility that could contaminate Oahu drinking water supplies.

3.1.3.2 Alternative 2: Relocation

Alternative 2 is the relocation of flowable fuel from RHBFSF by tanker ships to existing locations within the 

DoD fuel supply chain by ocean transit.

Under Alternative 2, a minimal increase of demand for emergency services may result from the addition of 

approximately ten workers per shift during the defueling and tanker ship loading operations. The increase 

in operations has the potential to result in an increase in injuries from workplace accidents and therefore 

could increase demand on emergency services, resulting in slower response times for the general public. 

However, the added demand would be extremely small and not likely to have measurable impacts to 

existing service capacity. 

Compliance with occupational safety and health regulations, standards, and instructions would minimize 

the potential for workplace accidents. Tanker loading would be accomplished by a team of trained military 

and civilian workers from FLC and Port Operations. Workers would moor the ship at the fueling pier, deploy 

oil-absorbent booms around the ship, connect/disconnect the flexible hoses from the pipeline to the tanker 

ship, and perform various inspections throughout the fuel loading process. The use of a hoist, hand tools, 

and power tools would be required to lift and connect the flexible hose to the tanker. Common workplace 

hazards associated with this type of maritime work include slips, trips, and falls, machinery and equipment 

hazards (e.g., hoist), hazardous chemicals, and fire hazards (OSHA, 2023). If potentially unsafe conditions 

such as adverse weather or worker fatigue are encountered during fuel loading operations, the PIC has the 

authority to cease operations (Table 2.5-1, BMP-5). Additionally, trained safety, medical, and environmental 

health professionals from the JTF-RH Quality Assurance directorate will provide secondary oversight 

throughout the defueling operation. The use of BMPs, training, and adherence to occupational safety and 

health regulations, standards, and instructions would reduce the likelihood and severity of potential 

workplace accidents. 
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Under Alternative 2, there would be an increase of up four additional vessel movements per week (i.e., two 

round-trip transits) in Pearl Harbor. There are typically about 2,000 annual naval vessel and submarine 

movements in Pearl Harbor. The additional vessels would account for an approximate ten percent increase 

in vessel traffic during the defueling operation. BMPs including notifying the Harbormaster in advance of 

tanker arrival/departure, maintaining communications with the Harbormaster, and use of tugboats to assist 

tankers would reduce the risk of vessel accidents (BMP-1).

Tanker ships would transit through established shipping lanes to industrial port facilities that routinely 

receive fuel deliveries by tanker ship. With Alternative 2, there would be no change to public health or safety 

risk at receiving locations because fuel deliveries from RHBFSF would occur in lieu of routine or planned 

fuel supply deliveries by similar type tanker ships. 

Overall, with the use of BMPs and adherence to procedures, Alternative 2 would have less than significant 

adverse effects to public health and safety.

Alternative 2 would have a long-term beneficial impact on underground sources of drinking water because 

it would facilitate the expeditious defueling of RHBFSF in approximately three to four months from the time 

DOH authorizes defueling, thereby eliminating the risk of fuel spills from the facility that could harm human 

health through contamination of Oahu drinking water supplies.

3.1.3.3 Alternative 3: Commercial Sale and Relocation

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of flowable fuel 

from RHBFSF combined with the relocation of the remaining portion of the fuel to existing locations within 

the DoD fuel supply chain by ocean transit. A maximum of eleven tanker ships would be required to receive 

all of the flowable fuel from RHBFSF. 

With Alternative 3, up to ten tanker loads of fuel from RHBFSF may be commercially sold in accordance 

with Section 2922e of Title 10, USC, which authorizes the sale of certain fuel sources. Sale of fuel would 

need to coincide with gravity-based defueling schedule. Therefore, the amount of fuel sold would be 

determined by commercial interest and purchasers’ ability to receive the fuel at the time of gravity-based 

defueling. Fuel sold commercially would be loaded onto purchasers’ commercially-operated tanker ship(s) 

using the same pace and procedure as Alternative 2. 

Under Alternative 3, the impacts to public health and safety would be the same as described for Alternative 

2. The same number and type of tanker ships would transit through Pearl Harbor to the JBPHH fueling pier 

to receive fuel. Tankers would be loaded using the same workforce and procedure as Alternative 2; 

therefore, the potential for increase in demand for emergency services, workplace accidents, and vessel 

traffic and would be the same. 

Overall, with the use of BMPs and adherence to procedures, Alternative 3 would have less than significant 

adverse effects to public health and safety.

Alternative 3 would have the same a long-term beneficial impact on underground sources of drinking water 

as Alternative 2 because it would also facilitate the expeditious defueling of RHBFSF in approximately three 

to four months from the time DOH authorizes defueling. This would eliminate the risk of fuel spills from the 

facility that could harm human health through contamination of Oahu drinking water supplies.
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3.2 WATER RESOURCES

Water resources include marine waters, groundwater, surface water, wetlands, floodplains, and drainages. 

This section identifies the existing condition of water resources and analyzes the impacts of the Proposed 

Action on those resources. Biological resources associated with marine waters are discussed in the Marine 

Biological Resources Section.

The Proposed Action is centered on the defueling of the RHBFSF through the base’s existing pipelines, 

transfer of that fuel to tanker ships at a pier on JBPHH, and transit of the fuel to other locations. The 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. This 

analysis will describe the affected environment and analyze the potential for adverse effects for each 

alternative.

Regulatory Setting

3.2.1.1 Water Quality

The DOH Clean Water Branch (CWB) is the state agency responsible for protecting and restoring surface 

water resources for human and environmental health. The CWB implements surface water pollution control 

programs delegated from the EPA in support of the Clean Water Act (CWA) and the State’s goals to protect 

and restore surface waters to fishable and swimmable standards for the purpose of protecting human and 

environmental health. The components addressed within the CWB include Water Quality Standards, 

Enforcement and Compliance, National Pollutant Discharge Elimination System (NPDES) permits, Water 

Quality Certifications, surface water quality monitoring and assessment, Total Maximum Daily Loads, and 

Polluted Runoff Control. These programs are intended to work in concert to ensure Hawaii’s surface water 

resources are protected and restored. In addition, the DOH also addresses CWA components within the 

Safe Drinking Water Branch, which monitors and protects drinking water resources, and the Wastewater 

Branch, which administers engineering functions related to water pollution control and wastewater systems 

and treatment (DOH, 2018).

3.2.1.2 Underground Storage Tanks

Underground storage tanks (USTs) are regulated by the EPA under 42 USC Chapter 82, Subchapter IX. In 

1988, EPA published technical requirements for USTs containing petroleum or hazardous substances 

defined under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980

(CERCLA). These requirements included leak detection, leak preventions, and corrective action for all 

USTs containing regulated substances. The UST provisions of the Energy Policy Act of 2005 also focused 

on preventing releases, including additional provisions regarding inspections, operator training, delivery 

prohibition, secondary containment and financial responsibility (EPA, 2023b). In 2015, EPA strengthened 

these regulations and included the state approval program. The State of Hawaii has an approved UST 

program and it is the lead implementing agency for the UST program in Hawaii with broad statutory authority 

to regulate the installation, operation, maintenance, and closure of USTs, as well as UST releases under 

Hawaii Revised Statutes (HRS) 342L-1 through 342L-53.

3.2.1.3 Preparation for Defueling Pursuant to DOH and EPA Orders

As discussed in Section 1.3, JTF-RH and DLA must complete defueling of the RHBFSF pursuant to DOH 

and EPA orders. The JTF-RH is overseeing all necessary repairs, modifications and enhancements to the 

Red Hill infrastructure to reduce risk of spills or accidents during the defueling phase. Independent thirdparty contractors compiled a list of 253 repairs, enhancements and modifications which was submitted by 

the Navy to the DOH to address the RHBFSF, the UGPH, and entire length of pipeline including at the line 

at the Navy’s pier. This list was made available on the DOH website and includes repairs including but not 

limited to: replacing and repairing pipe components, valves, fittings and seals; inspecting and repairing 

dents in pipes; adding or repairing pipe supports and braces; and replacing deficient pressure gauges 

(DOH, 2022b). A third-party quality validator is reviewing all repairs to ensure they are done correctly. DOH 

conditionally approved DoD’s Third-Party Quality Validation Plan on January 27, 2023. As of June 28, 2023, 
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all 253 repairs were successfully accomplished (JTF-RH, 2023a). Progress and approvals of these repairs 

are posted on the ‘Defueling Dashboard’ on the JTF-RH website.

Table 2.5-1 describes best management practices that JTF-RH, DLA, and defueling operations staff would 

follow to avoid or minimize potential fuel spills during fuel transfers. A comprehensive interagency Spill Drill

focused on containing and remediating a worst-case scenario fuel spill was conducted on July 13, 2023 to 

evaluate the JTF-RH’s methods and identify any areas for improvement (JTF-RH, 2023b). Lessons learned 

from the Spill Drill will be used to refine spill response protocols, update training programs, and enhance 

interagency coordination.

3.2.1.4 International Marine Pollution Regulations 

The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main international 

convention covering prevention of pollutions of the marine environment from ships from operational or 

accidental causes. MARPOL violations can lead to criminal and civil penalties and fines. In 1992, MARPOL 

Annex I made it mandatory for large tankers to be fitted with double hulls with few exceptions. Annex II 

regulates control of pollution by noxious liquid substances in bulk. Annex III regulates prevention of pollution 

by harmful substances carried by sea in packaged form. Annex VI regulates pollution by sewage from ships. 

Annex V prevents pollution by garbage from ships and Annex VI prevents air pollution from ships.

Affected Environment

The RHBFSF is located in a ridge of volcanic rock known as Red Hill on the western edge (leeward side) 

of the Koolau Mountains that divides South Halawa Valley and Moanalua Valley. The site is surrounded by 

Federal, State, and residential property. The majority of the surface topography of the site lies at an 

elevation of approximately 200 to 500 ft. above mean sea level. The Red Hill ridge extends southwesterly 

toward JBPHH and provides protective cover not only for the underground fuel storage facility, but also for 

the long tunnel that connects the fuel storage facility with the UGPH.

3.2.2.1 Groundwater near RHBFSF

The Waimalu and Moanalua Aquifers, which are underground sources of drinking water, are located near 

the facility (Figure 3.2-1). The Waimalu Aquifer is part of the Pearl Harbor regional aquifers system and 

covers an area of 15,193 acres. The Moanalua Aquifer is part of the Honolulu regional aquifers system and 

covers an area of 4,442 acres (EPA, 2022a) (Figure 3.2-2).

The Navy, the U.S. Geological Survey, the Hawaii State Commission on Water Resource Management, 

DOH, the University of Hawaii, EPA, and the Honolulu Board of Water Supply have been studying 

groundwater flow below and surrounding the RHBFSF to understand the regional hydrogeology in order to 

assess transport of contamination relative to potable water wells in the area. While remediation is not the 

subject of the Proposed Action (this phase will be addressed in future actions), the flow rates and direction 

of groundwater in the vicinity of RHBFSF are relevant to potential spills that could occur during defueling. 

Fuel contamination from RHBFSF poses a risk to public drinking water sources including three major 

sources that are located within 1.5 miles of the facility (Figure 3.2-1). Two of the most productive potable 

water sources are Maui-type wells (skimming tunnels) that draw water from the water table surface. 

Because fuels are Light Non-aqueous Phase Liquids (LNAPL), they ‘float’ and move across the aquifer 

surface, fuel-contaminated water can potentially enter these skimming wells (WRRC, 2022). The geology 

in the area is challenging and complex in terms of assessing groundwater flow, as there are disjointed 

layers of different rock and soil types with very different permeabilities, thicknesses, and orientations. 

Compounding the difficulty, fuel has both free phase LNAPL (floating) and dissolved phase components, 

resulting in contaminants that can move throughout groundwater at different depths (WRRC, 2022). The 

Navy, the U.S. Geological Survey, the Hawaii State Commission on Water Resource Management, DOH, 

the University of Hawaii, EPA, and the Honolulu Board of Water Supply are all actively working to gain a 

better understanding of the groundwater flow in this area.
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Figure 3.2-1. Aquifer Systems Near RHBFSF

Figure 3.2-2. Oahu Regional Hydrologic Units

Source: Board of 

Water Supply, 

2019
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3.2.2.2 Surface Water and Wetlands near RHBFSF

The Halawa Stream runs relatively east-west along the northern edge of the RHBFSF. It ultimately flows 

directly west to Pearl Harbor adjacent to the JBPHH pier that will be used to load tanker ships. According 

to the State’s 2020 assessment (DOH, 2020), this stream is considered impaired because water quality 

standards for total nitrogen, nitrate and nitrite-nitrogen, total phosphorus and turbidity are not being attained.

The Moanalua Stream runs along the southern edge of RHBFSF and flows south to Keehi Lagoon east of 

the airport. It is impaired for total nitrogen, turbidity and trash.

The pipeline runs underground in a tunnel from RHBFSF to the UGPH. Along that route, the closest wetland 

(within the JBPHH Makalapa housing area) is approximately 950 ft. away. The only above-ground piping 

along the route occurs after the UGPH for approximately 700 ft. along a paved area and drainage swale

that is 900 ft. from the harbor. The drainage swale is a planned collection point in the event of a discharge 

from this section of above-ground piping. A dam is in place to protect release to Halawa stream in the event 

of a piping rupture along the drainage swale. If the release was unable to be contained by the dam, a 

containment boom is in place across Halawa stream as an additional protective measure. Once at the pier, 

fuel lines run along the pier in a concrete trench (secondary containment) covered with steel grating.

3.2.2.3 Pearl Harbor Estuary and Marine Waters

Pearl Harbor is a navigable water of the United States and receives saltwater input from the Pacific Ocean 

via Mamala Bay and the Main Channel of Pearl Harbor. As is typical of an estuarine environment, water in 

the harbor is more saline nearest the ocean and less saline away from the ocean. DOH divides Pearl Harbor 

into two individual assessment units, one as “Pearl Harbor Estuary” (essentially Pearl Harbor) and another 

as “Pearl Harbor coastal water body” (Mamala Bay), and each has individual water quality standards. 

HDOH classifies the waters of the harbor as an inland estuary, Class 2. The objective/definition of a Class 

2-designated water is to protect its use for recreational purposes, propagation of fish, shellfish, and other 

aquatic life, and agricultural and industrial water supplies, shipping, and navigation (DOH, 2020).

Pearl Harbor naturally experiences sediment fluctuations from storms, tides, floods, winds, waves, and 

currents. These natural oceanic events can mobilize sediment and carry it in suspension over great 

distances (Erftemeijer et al., 2012). As events subside, sediment will settle out of suspension and deposit 

in new locations. The Pearl Harbor estuary is a working harbor, with vessel movements and industrial 

waterfront activities occurring daily that result in increased levels of turbidity. The Pearl Harbor Estuary 

lochs are areas with naturally persistent levels of high turbidity due to regularly occurring vessel traffic and 

the presence of unconsolidated, fine silt on the bottom fed by rivers, streams, and storm water

conveyances. Vessel transit occurs at high levels every day, with the majority of vessel traffic involving 

commissioned Navy ships and a small fleet of recreational crafts. Transiting-vessels resuspend benthic 

sediments by creating turbulence in the water column and marine bottom environment with the vessel’s 

propellers. An effect known as “propeller wash”. Resuspension is limited to localized scouring from 

maneuvering vessels operating at high power, with re-suspended sediments most likely settling at or near 

the point of disturbance. Based on typical vessel traffic routes within the Main Channel of Pearl Harbor, the 

rate of sediment resuspension is estimated to be approximately 52 tons per day (Navy, 2018).

Additionally, the watershed surrounding the Pearl Harbor Estuary regularly experiences heavy rain events. 

Sediment-laden runoff from disturbed upland areas affected by urbanization, commercial development, and 

agriculture also increases turbidity, resulting in increased benthic sedimentation. In July 2020, DOH listed 

both Pearl Harbor assessment units as impaired water bodies for failing to attain their respective water 

quality standards. Water chemistry surveys were conducted by Naval Facilities Engineering Systems 

Command (NAVFAC) Pacific in Pearl Harbor in 2016–2017 and 2018–2019 during a variety of weather and 

rainfall conditions (storm event sampling was added during the last two years of surveys in 2018 and 2019). 

Water quality constituents that were evaluated were consistent with the DOH report from July 2020. 

Comparison of the water chemistry data collected during the study to DOH-specific water quality standard 

criteria indicates that overall, the waters of Pearl Harbor are within attainment of DOH water quality 

standards (at the time of the study). The only instances of non-attainment are in surface waters immediately 

following storm events. These are limited to the upper 6.6 ft. to 9.8 ft. of the water column in the Main 

Channel and do not extend beyond the mouth of the harbor (NAVFAC PAC, 2020). The DOH 2020 Integrate 
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Report acknowledges that additional data are needed to evaluate water quality within Pearl Harbor (DOH, 

2020). Benthic sediments containing COCs (Contaminants of Concern) (including copper, lead, mercury, 

and total Polychlorinated Biphenyls (PCBs) area also present in CERCLA sediments within the Pearl Harbor 

Sediment Site.

3.2.2.4 Water Quality at Receiving Locations

Most of the potential receiving locations for the fuel (described in Section 2.3.2) are located in industrialized 

areas adjacent to water bodies considered impaired regarding water quality. This section describes the 

most current water quality status at receiving locations and potential stressors in the region that contribute 

to water quality effects.

Campbell Industrial Park, West Oahu, Hawaii

Fuel transfer would occur through an offshore mooring that transfers oil and refined products through a 

hose between a buoy and commercial refinery/storage facilities onshore. There is no published water 

quality data for the offshore waters in this area. A fuel spill that occurred as a result of a hose failure in 1998 

was estimated at approximately 4,900 gallons. This spill resulted in tarballs and dead oiled birds at Kauai’s 

Barking Sands, Polihale, Nukoli, Fujii and Kipu Kai beaches. The US Coast Guard, Tesoro and various spill 

response contractors conducted the cleanup on Kauai. Moreover, Tesoro conducted restoration and paid 

natural resource damages pursuant to a 2001 Consent Decree (USGS, 2023). This type of spill is not 

reasonably foreseeable, but is described here to indicate the potential for natural resources damages that 

could occur if a similar fuel spill were to happen as a result of the Proposed Action. It is not a reflection on 

the current water quality at the Campbell Industrial Park, West Oahu oil transfer buoy. Additionally, the 

Honouliuli wastewater treatment plant, near the community of Ewa Gentry, treats up to 51 million gallons 

of raw wastewater daily. Through a series of treatment systems, approximately half of the 2021 wastewater 

was treated and beneficially reused or distributed to recharge the aquifer. Water not reused is discharged 

via a Barbers Point deep ocean outfall (about 200 ft. deep and 9,300 ft. offshore) (Honolulu, 2023). 

While the State does not publish water quality data for the off-shore area around the fuel mooring at West 

Oahu, the presence of fuel storage, a refinery, and wastewater treatment plant in the vicinity make the 

waters in the area susceptible to releases that can impair water quality.

Point Loma, California (San Diego Bay)

The DFSP at Point Loma lies about 1.5 miles north of the mouth of San Diego Bay and is directly across 

from the airfield at Naval Air Station North Island. San Diego Bay is listed as impaired for fishing and 

shellfish harvesting by the State with issues identified as mercury, PCBs and Toxic Organic Chemicals 

(EPA, 2022b). Probable sources contributing to its impairment include but are not limited to: accidental 

spills, atmospheric deposition of toxics, illegal dumps or other inappropriate waste disposal, and urban 

runoff/storm sewers.

Selby, California (San Pablo Bay)

San Pablo Bay is listed as impaired for aquatic life and fish/shellfish consumption by the State with issues 

identified as dioxins, mercury, metals, nuisance plants or animals (Foreign), PCBs, and pesticides. The 

probable sources contributed to impairment are listed as unknown (EPA, 2022c). 

Vancouver, Washington (Columbia River)

The Hayden Island-Columbia River is listed as impaired for fish and aquatic life, fishing, private domestic 

water supply, and public domestic water supply with issues identified as temperature and total dissolved 

gas, pesticides, dioxins, PCBs and polycyclic aromatic hydrocarbons (EPA, 2022d).

Manchester, Washington (Puget Sound)

According to the Washington Geospatial Open Data Portal, the water quality adjacent to the Manchester 

Defense Fuel Supply Port is listed as impaired for dissolved oxygen; another zone to the northeast is listed 
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as impaired for bacteria (Washington State, 2023). Approximately 3,300 ft. to the north of the Manchester 

Defense Fuel Supply Point is a marine protected area called the Orchard Rocks Conservation Area. This 

area is closed to fishing, harvesting, and possession of fish and shellfish. Closure does not affect the harvest 

of clams, oysters, and mussels by tideland owners and their families. The natural bedrock and boulders 

provide habitats for rock associated fish and invertebrate species. Dominant invertebrates include red rock 

crab, spider crabs, red sea cucumber, and orange sea cucumber. Harbor seals frequently visit the site and 

are often seen hauled out on the exposed rocks at low tide. California sea lions are also commonly observed 

at the site and may be seen hauled out on nearby navigational buoys (Carta, 2023).

Sasebo, Japan (Sasebo Bay)

Sasebo Port is a large deep-water port located on the western coast of Kyushu, Japan’s third largest island. 

Aside from the naval berths, the port area is home to numerous heavy industries and also has berths for 

tanker operations. It is a busy fishing and commercial port, and it is home to shipbuilding and related 

industries that dominate the local economy. Approximately 200 vessels visit the port annually.

Subic Bay, Philippines

Subic Bay is a bay on the west coast of the island of Luzon in the Philippines, about 62 miles northwest of 

Manila Bay. Its shores were formerly the site of a major United States Navy facility, U.S. Naval Base Subic 

Bay, now an industrial and commercial area known as the Subic Bay Freeport Zone. Fuel transfer at the 

Subic Bay Freeport Zone would occur at the Port POL (Petroleum, Oil, Lubricants) Pier.

Philippine maritime territorial waters cover about 85 million square miles, wherein 103,000 square miles 

are coastal waters and 747 million square miles are oceanic waters within the exclusive economic zone

(EEZ). 

The Philippines has one of the biggest plastic pollutant loads on the planet, with 0.28 to 0.75 million tons of 

plastic escaping into the waters each year from coastal locations in Manila Bay together with hundreds of 

thousands of tons of plastic waste that are dumped in the country’s rivers (Filipenco, 2023). Water quality 

in Subic Bay is highly impaired by partially treated sewage, nutrient inflows from changes in land use, and 

inadequate treatment of industrial wastes.

Port of Singapore

The Port of Singapore is currently the world's second-busiest port in terms of total shipping tonnage, it also 

transships a fifth of the world's shipping containers, half of the world's annual supply of crude oil, and is the 

world's busiest transshipment port. 

Singapore has about 232 square miles of territorial seas, with about 3.7 square miles of coral reef, 2.4 

square miles of mangroves, and about 2 square miles of mud flats. Over the past century, Singapore has 

undertaken major projects to expand the main island and protect its shores from storms and rising seas. 

Land reclamation and island building projects have led to the destruction of more than 80 percent of 

mangroves and associated wetlands bordering the island. This activity has led to high levels of pollution 

and suspended sediment impairment of surrounding nearshore waters. 

Aquaculture and shipping are the main sources of contaminant emission into offshore territorial waters. 

Nutrient inputs from nearshore aquaculture operations likely contributes to increases in eutrophication. 

Shipping activities (mainly the wake and propeller wash from the passage of large vessels) and dredging 

for channel maintenance mobilize sediments, increasing turbidity. 

Darwin, Australia

According to the Darwin Harbour Water Quality Report of 2021, the harbor’s water quality was graded very 

good in 2021 with an overall grade of ‘A’. An exception was Buffalo Creek Estuary which was impacted 

mainly by wastewater discharge from the Leanyer-Sanderson sewage treatment plant, which is not located 

in the vicinity of the potential receiving location. (Northern Territory, 2021). 
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3.2.2.5 Tanker ship Spill Statistics

The International Tanker Owners Pollution Federation (ITOPF) is a not-for-profit organization established 

to promote an effective response to marine spills of oil, chemicals and other hazardous substances. The 

ITOPF published Oil Tanker Spill Statistics 2022 annual report in January 2023 (ITOPF, 2023) that provides 

data on accidental spills of oil from tankers since 1970. Historically, information from published sources 

related mostly to large spills, often resulting from collisions, groundings, structural damage, fire or 

explosions. Over the last two decades, there have been an average of six tanker spills per year. Three of 

the seven incidents in 2022 were classified as ‘large’ spills. The total volume of oil lost to the environment 

from tanker spills in 2022 was approximately 15,000 metric tons. While all oil spills are harmful to the 

environment, to put this into context, when contrasted with the 2.95 billion metric tons of oil that is 

transported each year, the 2022 spill quantity equates to 0.0005 percent of all fuel transported annually.

The number of oil spills from tankers has decreased significantly over the last five decades. Spills in excess 

of 7 metric tons have reduced by over 90 percent since 1970. There has however been little change in the 

last decade. Figure 3.2-3 provides tanker spill causes from 2010 to 2022.

Figure 3.2-3. Causes of Large Tanker Ship Spills, 2010-2022

Trends from the ITOPF Report indicate that spills resulting from grounding and hull failure have declined

since 2010 but that allision/collision, equipment failures, and fire/explosion causes have risen in the same 

time period. During the 1970-2022 reporting period, 50 percent of large spills occurred while the vessel was 

underway in open water. For spills occurring underway in inland waters or ports/harbors, allisions/collisions 

and groundings accounted for 99 percent of spills. Approximately 9 percent of large spills occurred during 

loading and discharging activities which normally take place in ports and oil terminals.

3.2.2.6 Spill Response Capabilities at Receiving Locations

The International Convention on Oil Pollution Preparedness, Response and Co-operation 1990 (OPRC 90) 

is the international instrument that provides a framework designed to facilitate international co-operation 

and mutual assistance in preparing for and responding to major oil pollution incidents. The Protocol on 

Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances 

(OPRC-HNS), 2000 extends this regulatory framework to address pollution incidents involving hazardous 

and noxious substances, i.e. chemicals. 

Countries or member states that are party to OPRC 90 and OPRC-HNS Protocol are required to establish 

a national system for responding to oil and Hazardous and Noxious Substances (HNS) pollution incidents, 
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including a designated national authority, a national operational contact point and a national contingency 

plan. This needs to be backstopped by a minimum level of response equipment, communications plans, 

regular training and exercises (IMO, 2023). OPRC 90 and OPRC-HNS provide the mechanism for Parties 

to request assistance from any other state Party, when faced with a major pollution incident. Overall, 

member states that are party to OPRC 90 and OPRC-HNS provide verification of their spill response 

capabilities and are well positioned to handle large spills on their own and can readily request help from 

other member states when needed.

The U.S. is a member state of OPRC 90 but not OPRC-HNS. In terms of HNS, response bilateral 

agreements are in place between the U.S. and Canada and the U.S. and Mexico for environmental 

emergencies. 

Of the foreign port countries identified under Alternative 2, all meet the OPRC 90 and HNS Protocols except 

for the Philippines (e.g., Subic Bay). 

A recent account of a tanker ship accident in the Philippines in February 2023 sheds some insight on that 

nation’s spill response resources. On February 28, 2023, the MT Princess Empress was transporting 

238,000 gallons of fuel oil when it capsized and sank near Naujan (approximately 150 miles south of Subic 

Bay, Philippines) (CNN Philippines, 2023). The oil slick is reported to stretch 75 miles resulting in damage 

to multiple areas and shorelines. The resulting pollution and full fishing ban has wreaked havoc on the 

coastal villages of the province, which are reliant on fishing and tourism for income. Despite not being a 

member state to the OPRC 90, other countries have assisted in the cleanup. In response to the Philippine 

government’s request, the U.S. National Response Team (NRT) was activated on March 8, 2023. The NRT 

is a network of 15 federal agencies providing guidance, assistance, and resources for managing pollution 

incidents. Overall, the response team for this spill includes the Philippine Coast Guard, the U.S. NRT 

(including the National Oceanic and Atmospheric Administration, U.S. Navy, U.S. Coast Guard), the Japan 

Disaster Relief Team, and United States Agency for International Development (NOAA, 2023).

Environmental Consequences

3.2.3.1 Alternative 1: No Action Alternative

Under the No Action Alternative, flowable fuel at RHBFSF would be drawn down over a period of 

approximately ten to fourteen months after DOH approval of the gravity-based defueling operation. 

Flowable fuel from RHBFSF would be transferred to the UTF or to fueling piers at JBPHH through existing 

infrastructure. Fuel from the UTF can then be sent by pipeline to Hickam Field, fuel loading piers, and truck 

loading racks for distribution to customary defense customers for consumption. 

A low demand for JP-5 fuel at JBPHH would require JP-5 movement by vessel to points of immediate 

consumption as part of a stock rotation program. Additionally, JP-5 may be regraded to F-24 or F-76 for 

consumption at JBPHH. Existing locations within the DoD fuel supply chain that may receive relocated fuel 

from RHBFSF as part of Alternative 1 would continue to receive their regular fuel deliveries by tanker ships 

from other fuel sources.

The potential for spills within the RHBFSF, pipelines, and UGPH would be reduced through the repairs 

conducted described in Section 3.2.1.3. While there is no evidence of ongoing releases of fuel from the 

RHBFSF to the environment, the potential exists for possible releases to occur for a longer period of time 

(ten to fourteen months) with the No Action Alternative versus Alternatives 2 or 3, which would remove 

flowable fuel in approximately three to four months from the time DOH authorizes defueling. Essentially, 

the No Action Alternative would extend the period of time where fuel resides in the tanks, where it could 

pose additional threat to groundwater and drinking water quality.

The amount of fuel to be transferred to tanker ships from Pearl Harbor for overseas deliveries would likely 

be substantially less than the amounts proposed under Alternatives 2 and 3. Use of tanker ships may

marginally increase potential for spills to affect marine waters when compared to this alternative, which is 

more likely to affect onshore water resources such as streams, wetlands and aquifers. Potential fuel spills 

that could be associated with Alternative 1 would likely occur at points of transfer which are generally paved, 
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such as on airfields and truck fuel transfer areas. Transfers of fuel to vessels have greater potential for 

spills to marine waters (e.g., Pearl Harbor) then land-based fuel transfers; however, vessel fueling would 

follow standard operating procedures and BMPs described in Table 2.5-1 to reduce the risk of spills. 

Vessels receiving fuel at the JBPHH pier would be surrounded by oil-absorbent booms to contain and 

capture any spills that might occur. Additionally, all tankers would be towed by tug within Pearl Harbor to 

prevent the allision/collision; allision/collision is statistically the highest cause of tanker spills worldwide.

It is important to note that fuel transfer and use would occur at typical defense customer distribution points 

using non-RHBFSF stored fuel in the absence of Alternative 1, as these are routine actions. JBPHH has 

fueling and spill response standard operating procedures to address potential spills and to limit their effects 

to the environment.

With the use of BMPs and adherence to provisions of the DOH Emergency Orders, Alternative 1 would 

have less than significant effects to water resources.

3.2.3.2 Alternative 2: Relocation

The expeditious gravity-based defueling of RHBFSF under Alternative 2 would reduce the potential for 

releases from the RHBFSF that could further contaminate groundwater sources and drinking water 

supplies. Alternative 2 would be the first step in the process DoD would take to close the RHBFSF as a fuel 

storage facility and to remediate groundwater. 

Under Alternative 2, potential for releases within the RHBFSF, pipelines, and UGPH would be reduced 

through the repairs conducted described in Section 3.2.1.3. 

Use of tanker ships to relocate flowable fuel from RHBFSF may marginally increase potential for spills to 

affect marine waters on Oahu, in international waters, and at receiving locations. Vessel fueling at the 

JBPHH pier would follow standard operating procedures and BMPs described in Table 2.5-1 to reduce the 

risk of spills. Vessels at the JBPHH pier would be surrounded by oil-absorbent booms to contain and capture 

any spills that might occur until spill response teams arrive on the scene. Additionally, all tankers would be 

towed by tug within Pearl Harbor to prevent the allision/collision; allision/collision is statistically the highest 

cause of tanker spills worldwide. The likelihood of a tanker spill is extremely low (0.0005 percent historic 

spill rate worldwide) based on tanker spill statistics provided by ITOPF (see Section 3.3.2.5). However, any 

tanker spill has the potential to cause a high-volume, extended duration (i.e., catastrophic) release of fuel 

into the marine environment. Of the possible causes of large accidents, hull failure would be unlikely, as 

fuel vessels must be double-hulled in accordance with MARPOL regulations. The destination ports under 

this alternative are well-established with adequate channel water depth to avoid potential for grounding. 

Very busy ports, such as Singapore, may pose a higher potential for collision-related spills, but collisions 

could be avoided by following appropriate navigation and communication procedures. Root causes of spills 

such as human error, adverse weather, and fire/explosion can occur more unpredictably. These causes 

account for nearly half of spill events worldwide since 2010. Vessel operators are required to follow all 

applicable environmental and safety regulations, which further reduces the likelihood of a catastrophic spill.

There would be no overall risk increase from fuel unloading because fuel deliveries to receiving locations 

would be in lieu of routine or planned deliveries. On-site teams would respond in the event of a spill at a 

receiving location. Nearly all receiving locations, with the exception of Darwin, are located in areas with 

impaired water quality. Potential small spills which could be addressed quickly at any of the receiving 

locations are unlikely to have a significant adverse effect on water quality. Large spills, although unlikely, 

could further contaminate and exacerbate existing poor water quality in the port area for weeks or months 

until the spill and its effects are fully remediated. Receiving locations in the U.S. and other OPRC 90 

member states are more likely to have the personnel and equipment available to respond well to spills of 

all sizes within their waters. Coastal areas where fishing is a primary source of income and subsistence 

could be especially adversely affected in the event of a large spill. Although the MT Princess Empress

accident is only one example, it is probable that if such a large spill occurred under Alternative 2 in the 

Philippines, the NRT would be activated to assist in the response. Based on tanker spill statistics from 

ITOPF, the probability of a significant oil spill are very low under this alternative.
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Propeller wash from vessels arriving and departing ports could resuspend bottom floor sediments by 

creating turbulence in the water and bottom environment with the vessel’s propellers. Resuspended 

sediments would create localized turbidity during short periods of time and would likely not cause significant 

effects to water quality. 

Overall, with the use of BMPs for tanker fuel transfer, Alternative 2 would have less than significant effects 

to water resources.

3.2.3.3 Alternative 3: Commercial Sale and Relocation

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of flowable fuel 

from RHBFSF combined with the relocation of the remaining portion of the fuel to existing locations within 

the DoD fuel supply chain by ocean transit. A maximum of eleven tanker ships would be required to receive 

all of the flowable fuel from RHBFSF. 

With Alternative 3, up to ten tanker loads of fuel from RHBFSF may be commercially sold in accordance 

with Section 2922e of Title 10, USC, which authorizes the sale of certain fuel sources. Sale of fuel would 

need to coincide with defueling schedule. Therefore, the amount of fuel sold would be determined by 

commercial interest and purchasers’ ability to receive the fuel at the time of gravity-based defueling. Fuel 

sold commercially would be loaded onto purchasers’ commercially-operated tanker ship(s) using the same 

pace and procedure as Alternative 2. The transit route and destination of sold fuel is at the discretion of the 

non-federal entity purchaser. However, it is likely the destination would be similar to those analyzed under 

Alternative 2 and the same BMPs would be followed at the JBPHH pier for fuel loading. Commercial tankers 

used under this alternative would need to be certified as meeting MARPOL safety and environmental 

requirements.

Use of tanker ships may marginally increase potential for spills to affect marine waters both on Oahu, in 

international waters, and at receiving locations. Vessel fueling at the JBPHH pier would follow standard 

operating procedures and BMPs described in Table 2.5-1 to reduce the risk of spills. Vessels at the JBPHH 

pier would be surrounded by oil-absorbent booms to contain and capture any spills that might occur until 

spill response teams arrive on the scene. Additionally, all tankers would be towed by tug within Pearl Harbor 

to prevent the allision/collision; allision/collision is statistically the highest cause of tanker spills worldwide. 

While spills from tanker ships is statistically very low, any tanker spill has the potential to be catastrophic 

and release thousands of gallons of fuel into the marine environment. Of the possible causes of large 

accidents, hull failure would not be likely, as fuel vessels must be double-hulled in accordance with 

MARPOL regulations. It is likely the destination ports under this alternative would be well-established with 

adequate channel water depth to avoid potential for grounding. Very busy ports may pose a higher potential 

for collision-related spills but collisions could be avoided by following appropriate navigation and 

communication procedures. Root causes of spills such as human error, adverse weather, and fire/explosion 

can occur more unpredictably and these causes account for nearly half of spill events worldwide since 

2010. Vessel operators would be required to follow all environmental and safety regulations which would 

reduce factors that could result in catastrophic spills.

Spills at receiving locations would be addressed by their on-site response teams. Small spills which are 

addressed quickly at any of the receiving locations would likely not have a significant adverse effect on 

water quality. Large spills, although unlikely, could further contaminate and exacerbate existing poor water 

quality in the port area for weeks or months until the spill and its effects are fully remediated. Receiving 

locations in the U.S. and other OPRC 90 member states are more likely to have the personnel and 

equipment available to respond well to spills of all sizes within their waters. Coastal areas where fishing is 

a primary source of income and subsistence could be especially adversely affected in the event of a large 

spill. Statistically, the probability of a significant oil spill are very low under this alternative.

Propeller wash from vessels arriving and departing ports could resuspend bottom floor sediments by 

creating turbulence in the water and bottom environment with the vessel’s propellers. Resuspended 

sediments would create localized turbidity during short periods of time and would likely not cause significant 

effects to water quality.
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With Alternative 3, the portion of flowable fuel from RHBFSF that is not sold would be relocated to existing 

locations within the DoD fuel supply chain by ocean transit described under Alternative 2. For this portion 

of the action, the effects would be the same as those for Alternative 2.

Overall, with the use of BMPs for tanker loading, Alternative 3 would have less than significant effects to 

water resources.
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3.3 MARINE BIOLOGICAL RESOURCES

Biological resources include living, native, or naturalized plant and animal species and the habitats within 

which they occur. Plant associations are referred to generally as vegetation, and animal species are 

referred to generally as fauna or wildlife. Habitat can be defined as the resources and conditions present in 

an area that support a plant or animal. This section addresses potential impacts that could result from the 

Proposed Action on the following categories of marine biological resources: 

• Marine vegetation 

• Essential Fish Habitat (EFH)

• Marine fauna (including fishes, coral, and non-coral benthic invertebrates)

• Protected Species (including marine mammals and ESA-listed sea turtles and fishes)

Regulatory Setting

3.3.1.1 Endangered Species Act

The purpose of the ESA is to conserve the ecosystems upon which threatened and endangered species 

depend and to conserve and recover listed species. Section 7 of the ESA requires federal agencies to 

consult with the NMFS and/or the U.S. Fish and Wildlife Service (USFWS) to ensure that any action it 

authorizes, funds, or carries out in the U.S. or upon the high seas is not likely to jeopardize the continued 

existence of any listed species, or result in the destruction or adverse modification of critical habitat of such 

species.

Under the ESA, critical habitat is defined as specific geographic areas that contain features essential to the 

conservation of an endangered or threatened species and that may require special management and 

protection. Critical habitat may also include areas that are not currently occupied by the species but would 

be needed for its recovery. Critical habitat cannot be designated on any areas owned, controlled, or 

designated for use by the DoD where an Integrated Natural Resources Management Plan (INRMP) has 

been developed that, as determined by the Department of Interior or Department of Commerce Secretary, 

provides a benefit to the species subject to critical habitat designation.

JTF-RH and DLA completed informal consultation with NMFS pursuant to Section 7(a)(2) of the ESA for 

the Proposed Action. NMFS concurred with the JTF-RH/DLA determination that the Proposed Action may 

affect, but is not likely to adversely affect, any ESA-listed species or designated critical habitat in the action 

area. NMFS’ Letter of Concurrence dated August 15, 2023 is provided in Appendix B.

3.3.1.2 Marine Mammal Protection Act

All marine mammals are protected under the provisions of the Marine Mammal Protection Act (MMPA). The 

MMPA prohibits any person or vessel from “taking” marine mammals in the U.S. or the high seas without 

authorization. The MMPA defines “take” to mean “to harass, hunt, capture, or kill or attempt to harass, hunt, 

capture, or kill any marine mammal.”

3.3.1.3 Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act provides for the conservation and 

management of U.S. Fisheries. Under the Act, EFH consists of the waters and substrate needed by fish to 

spawn, breed, feed, or grow to maturity. An area within EFH that is considered particularly important and/or 

sensitive is known as Habitat Area of Particular Concern (HAPC). Regional Fishery Management Councils, 

established under the Act, are responsible for preparing and amending fishery management plans for each 

fishery under their authority that requires conservation and management. Federal actions that would 

adversely affect EFH (i.e., direct or indirect physical, chemical, or biological alterations) are subject to 

consultation requirements with NMFS. An adverse effect to EFH includes adverse changes to waters or 

substrate, species and their habitat, other ecosystem components, and quality and/or quantity of EFH.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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3.3.1.4 Executive Order 12114 Evaluation

The analysis of the Proposed Action in areas beyond U.S. waters considers the potential for the action to 

cause significant environmental harm. Tanker transits of fuel to international receiving locations would be 

considered normal operations, with deliveries from RHBFSF occurring in lieu of routine or planned fuel 

supply deliveries. Similar to the potential impacts in U.S. waters that are described in Section 3.3.3, the 

Proposed Action is not expected to cause significant environmental harm to marine biological resources in 

areas beyond U.S. waters.

Affected Environment

The ROI for marine biological resources includes areas of Pearl Harbor where gravity-based defueling 

operations would occur, the waters that encompass the vessel transit routes to the nine potential fuel 

receiving locations, and the marine areas at the fuel receiving locations. Detailed descriptions of Pearl 

Harbor and receiving locations are provided in Appendix D.

Pearl Harbor is an estuary, defined as an area where fresh water emanating from land mixes with ocean 

water. The northern portion of the harbor receives freshwater input from perennial streams that flow into 

Pearl Harbor, creating an estuarine environment with a muddy bottom. The water in Pearl Harbor becomes 

more saline as it nears the mouth of the harbor due to saltwater input from the Pacific Ocean via Mamala 

Bay and the Main Channel of Pearl Harbor. The area near the mouth of Pearl Harbor is characterized by 

oceanic conditions or higher salinity conditions and, as a result of this salinity gradient, coral species 

diversity and density is lower at the northern portion of the harbor than near the entrance channel because 

corals primarily prefer the salinity of ocean waters.

Pearl Harbor is one of the Navy’s busiest ports, completing about 65,000 boat runs and transporting 2.4 

million passengers each year. Tour boats manned by Navy personnel transport more than two million 

visitors to the USS Arizona Memorial each year (CNRH, 2023). The Proposed Action would require a 

maximum of eleven tanker transits through Pearl Harbor to the JBPHH fueling pier where tanker ships

would be loaded with fuel. Tanker ships one through ten would transit to existing locations within the DoD 

fuel supply chain using established commercial shipping routes. The transit routes of these vessels from 

Pearl Harbor to the nine potential receiving locations were estimated based on commonly used commercial 

shipping lanes (Figure 3.3-1). Transit route and destination of the eleventh tanker would not be known until 

the time of sale (see Section 2.3.2). Tanker ships would operate at speeds safe for the location and 

conditions. While transiting the open ocean, tanker ships would travel at an average of fifteen knots. 

Tankers would reduce speeds in nearshore harbor areas, comply with regional speed restrictions, and to 

the extent practicable, follow voluntary speed restrictions in areas where the risk of vessel strikes is high 

(Table 2.5-1, BMP-11). Within Pearl Harbor, this is typically ten knots or less, to prevent collision, and five 

knots or less when piloting vessels in areas of known turtle presence.

3.3.2.1 Marine Vegetation

Marine vegetation includes plants occurring in marine or estuarine waters. These may include mangroves, 

algae, and various grasses. The Proposed Action will use existing facilities and infrastructure, as well as 

established commercial shipping routes to relocate fuel from RHBFSF. Affects to marine vegetation are not 

anticipated because it would not be removed, modified, or disrupted by the Proposed Action. Therefore, 

impacts to marine vegetation were not further analyzed.

3.3.2.2 Essential Fish Habitat

EFH includes all types of aquatic habitat including wetlands, coral reefs, seagrasses, and rivers; all 

locations where fish spawn, breed, feed, or grow to maturity. Congress established the EFH mandate in 

1996 to improve the nation’s main fisheries law, the Magnuson-Stevens Fishery Conservation and 

Management Act, highlighting the importance of healthy habitat for federally managed fisheries. NMFS 

works with the regional fishery management councils to identify the essential habitat for every life stage of 

each federally managed species using the best available scientific information. EFH has been described 

for approximately 1,000 managed species to date. 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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The Proposed Action would have no effect on EFH present in the ROI because of the low number of tanker 

transits, moderately slow vessel speeds, and routine nature of fuel loading and unloading operations at 

JBPHH and receiving locations.

Figure 3.3-1. Potential Fuel Receiving Locations and Vessel Transit Routes

3.3.2.3 Marine Fauna

Marine fauna includes species of fishes, coral, and non-coral benthic invertebrates. Protected marine 

mammals, sea turtles, and fishes with the potential to be affected by the Proposed Action are discussed in 

Section 3.3.2.4. It is anticipated that ESA-listed marine invertebrates would not overlap in space and time 

with the Proposed Action due to their demersal nature and are, therefore, not analyzed further in this 

document. 

Fishes

Fishes are vital components of the marine ecosystem. Fishes are generally defined as various aquatic 

vertebrates possessing gills. An extensive and diverse list of fishes exists in the Pacific Ocean. ESA-listed

fishes are discussed in Section 3.3.2.4.

Coral

Corals are invertebrates that are related to anemones, jellyfish, and hydras. They are made of invertebrate 

polyps and can generally be categorized as either hard or soft. Hard corals have calcium carbonate 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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skeletons, grow in colonies, and are reef-building animals that live in symbiosis with phytoplankton called 

zooxanthellae. Soft corals are flexible, have calcareous particles in their body walls for structural support, 

can be found in both tropical and cold ocean waters, do not grow in colonies or build reefs, and do not 

always contain zooxanthellae.

Corals would not be affected by the Proposed Action because of their demersal nature and distribution 

within the water column, coupled with the low number of tanker transits and moderately slow vessel speeds.

Therefore, effects to coral were not further analyzed.

Non-Coral Benthic Invertebrates

Animals that live on the sea floor are called benthos. Most of these animals lack a backbone and are called 

invertebrates. Typical benthic invertebrates include sea anemones, sponges, corals, sea stars, sea urchins, 

worms, bivalves, crabs, and many more.

Non-coral marine invertebrate species would not be affected by the Proposed Action because of their 

demersal nature and distribution within the water column, coupled with the low number of tanker transits 

and moderately slow vessel speeds. Therefore, effects to non-coral marine invertebrates were not further 

analyzed.

3.3.2.4 Protected Species

Marine Mammals

Regulation over marine mammals within the U.S., its EEZ, or on the high seas is maintained by NMFS and 

the USFWS. NMFS maintains regulation over whales, dolphins, porpoises, seals, and sea lions. The 

USFWS maintains regulation over certain other marine mammal species, including walruses, polar bears, 

dugongs, sea otters, and manatees. All marine mammals are protected under the provisions of the MMPA. 

Marine mammals are frequently seen within waters outside of Pearl Harbor and throughout the Pacific 

Ocean. The Proposed Action would not result in the “take” of any marine mammals present in the ROI 

under MMPA.

Threatened and Endangered Species

JTF-RH and DLA completed informal consultation with NMFS pursuant to Section 7(a)(2) of the ESA for 

the Proposed Action. NMFS concurred with the JTF-RH/DLA determination that the Proposed Action may 

affect, but is not likely to adversely affect, any ESA-listed species or designated critical habitat in the action 

area. NMFS’ Letter of Concurrence dated August 15, 2023 is provided in Appendix B. Threatened and 

endangered (i.e., ESA-listed) marine mammals and designated critical habitat present in the U.S. EEZ or 

on the high seas areas of the ROI are listed in Table 3.3-1. Between 2012 and 2022, eight Hawaiian monk 

seals were documented inside Pearl Harbor. Eleven additional species of ESA-listed marine mammals 

were identified to be potentially present in the vessel transit routes or potential fuel receiving locations in 

U.S. Waters or on the high seas. These include nine whales, one seal, and one sea lion (Table 3.3-1).

Table 3.3-1. ESA-Listed Marine Mammals Present in U.S. Waters or on the High Seas of the ROI

Common

Name

Scientific

Name

Designation 

Unit*

ESA Listing 

Status

Transit routes the 

species may be 

present in

Designated critical 

habitat overlaps 

with transit routes

Cetaceans (i.e., whales, dolphins, porpoises)

Blue Whale Balaenoptera 

musculus

Throughout 

Range

Endangered All Transits No

False Killer 

Whale

Pseudorca 

crassidens

Main Hawaiian 

Island Insular 

distinct 

population 

segment (DPS)

Endangered All Transits All Transits
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Common

Name

Scientific

Name

Designation 

Unit*

ESA Listing 

Status

Transit routes the 

species may be 

present in

Designated critical 

habitat overlaps 

with transit routes

Fin Whale Balaenoptera 

physalus

Throughout 

Range

Endangered All Transits No

Gray Whale Eschrichtius 

robustus

Western North 

Pacific DPS

Endangered Point Loma, Selby, 

Vancouver, 

Manchester, 

Sasebo

No

Humpback 

Whale

Megaptera 

novaeangliae

Central America 

DPS

Endangered Point Loma, Selby, 

Vancouver, 

Manchester

Point Loma, Selby, 

Vancouver, 

Manchester

Humpback 

Whale

Megaptera 

novaeangliae

Mexico DPS Threatened Point Loma, Selby, 

Vancouver, 

Manchester

Point Loma, Selby,

Vancouver, 

Manchester

Humpback 

Whale

Megaptera 

novaeangliae

Western North 

Pacific DPS

Endangered Sasebo, Subic Bay No

Killer Whale Orcinus orca Southern 

Resident DPS

Endangered Selby, Vancouver, 

Manchester

Selby, Vancouver, 

Manchester

North Pacific 

Right Whale

Eubalaena 

japonica

Throughout 

Range

Endangered Point Loma, Selby, 

Vancouver, 

Manchester, 

Sasebo

No

Sei Whale Balaenoptera 

borealis

Throughout 

Range

Endangered All Transits No

Sperm Whale Physeter 

macrocephalus

Throughout 

Range

Endangered All Transits No

Pinnipeds (i.e., seals, sea lions, walruses)

Guadalupe 

Fur Seal

Arctocephalus 

townsendi

Throughout 

Range

Threatened Point Loma, Selby, 

Vancouver, 

Manchester

No

Hawaiian 

Monk Seal

Neomonachus 

schauinslandi

Throughout 

Range

Endangered All Transits All Transits

Steller Sea 

Lion

Eumetopias 

jubatus

Western DPS Endangered Point Loma, Selby, 

Vancouver, 

Manchester

Selby

Note: *Certain ESA-listed species have a population or group of populations that is discrete from other populations of the species 

and significant in relation to the entire species. These population groups are known as distinct population segments (DPS).

Sea Turtles

All species of sea turtles present in the ROI are designated as either threatened or endangered under the 

ESA. Sea turtles are highly migratory and often utilize the waters of more than one country in their lifetimes. 

The USFWS and NMFS share federal regulation for sea turtles with the USFWS having lead responsibility 

on the nesting beaches and NMFS, the marine environment. 

Two ESA-listed sea turtle species have been documented in Pearl Harbor. These populations include the 

threatened Central North Pacific Distinct Population Segment of green sea turtle (Chelonia mydas) and the 

endangered (throughout its range) hawksbill sea turtle (Eretmochelys imbricata). Green sea turtle presence 

can be considered common within Pearl Harbor. However, the distribution and density varies from location 

to location. Based on past surveys, occurrence of green sea turtles is documented with relatively more 

observations in the entrance channel and outside Pearl Harbor (Navy, 2020d; Navy Region Hawaii, 2020d; 

NAVFAC PAC, 2016; UH ARL, 2021). Green sea turtles are concentrated along the margins of the channel 

leading into Pearl Harbor compared to other locations, and more sea turtles occurred in the channel south 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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of Pearl Harbor in the cool season (November to April) than during the warm season (Navy, 2017). 

Hawksbill sea turtles are infrequent and occur in low numbers. 

Three additional species of ESA-listed sea turtles were identified to be potentially present in the vessel 

transit routes or potential fuel receiving locations in the U.S. Waters or on the high seas (Table 3.3-2).

Table 3.3-2. ESA-Listed Sea Turtles Present in the U.S. Waters or on the High Seas of the ROI

Common

Name

Scientific

Name

Designation Unit* ESA Listing 

Status

Transit routes the 

species may be 

present in

Designated 

critical habitat 

overlaps with 

transit routes

Green Sea 

Turtle

Chelonia 

mydas

Central North Pacific 

DPS

Threatened All Transits No

Green Sea 

Turtle

Chelonia 

mydas

Central South Pacific

DPS

Endangered Darwin No

Green Sea 

Turtle

Chelonia 

mydas

Central West Pacific

DPS

Endangered Sasebo, Singapore, 

Subic Bay, Darwin

No

Green Sea 

Turtle

Chelonia 

mydas

East Indian – West 

Pacific DPS

Threatened 

(Foreign**)

Sasebo, Singapore, 

Subic Bay, Darwin

No

Green Sea 

Turtle

Chelonia 

mydas

East Pacific DPS Threatened Point Loma, Selby, 

Vancouver, 

Manchester

No

Green Sea 

Turtle

Chelonia 

mydas

Southwest Pacific 

DPS

Threatened 

(Foreign)

Darwin No

Hawksbill 

Sea Turtle

Eretmochelys 

imbricata

Throughout Range Endangered All Transits No 

Leatherback 

Sea Turtle

Dermochelys 

coriacea

Throughout Range Endangered All Transits Selby, 

Vancouver, 

Manchester

Loggerhead 

Sea Turtle

Caretta 

caretta

North Pacific Ocean 

DPS

Endangered All Transits No

Loggerhead 

Sea Turtle

Caretta 

caretta

Southeast IndoPacific Ocean DPSThreatened 

(Foreign)

Darwin, Singapore No

Loggerhead 

Sea Turtle

Caretta 

caretta

South Pacific Ocean 

DPS

Endangered 

(Foreign)

Darwin No

Olive Ridley 

Sea Turtle

Lepidochelys 

olivacea

All Other Populations Threatened All Transits No

Olive Ridley 

Sea Turtle

Lepidochelys 

olivacea

Mexico’s Pacific 

Coast Breeding 

Population 

Endangered Point Loma No

Note: *Certain ESA-listed species have a population or group of populations that is discrete from other populations of the species 

and significant in relation to the entire species. These population groups are known as distinct population segments (DPS).

**Foreign ESA species occur only in the exclusive economic zone (EEZ) and/or territorial waters of foreign countries.

Fishes

ESA-listed fishes and designated critical habitat present in the U.S. Waters or on the high seas areas of 

the ROI are listed in Table 3.3-3. These include two rockfish, four salmon, two sharks, one manta ray, and 

three other species of fish. 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Table 3.3-3. ESA-Listed Fishes Present in U.S. Waters or on the High Seas of the ROI

Common 

Name

Scientific

Name

Designation Unit* ESA Listing 

Status

Transit routes the 

species may be 

present in

Designated 

critical habitat 

overlaps with 

transit routes

Bocaccio 

Rockfish

Sebastes 

paucispinis

Puget 

Sound/Georgia 

Basin DPS

Endangered Manchester Manchester

Chinook 

Salmon

Oncorhynchus 

tshawytscha

California Coastal 

ESU

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Central Valley 

Spring - Run ESU

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Lower Columbia 

River ESU

Threatened Vancouver, 

Manchester

Vancouver

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Puget Sound ESU Threatened Vancouver, 

Manchester

Manchester

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Sacramento River 

Winter - Run ESU

Endangered Point Loma, 

Selby, Vancouver, 

Manchester

Selby

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Snake River Fall -

Run ESU

Threatened Vancouver, 

Manchester

Vancouver

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Snake River 

Spring/Summer 

Run ESU

Threatened Vancouver, 

Manchester

Vancouver

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Upper Columbia 

River Spring - Run 

ESU

Endangered Vancouver, 

Manchester

Vancouver

Chinook 

Salmon

Oncorhynchus 

tshawytscha

Upper Willamette 

River ESU

Threatened Vancouver, 

Manchester

Vancouver

Chum 

Salmon

Oncorhynchus 

keta

Columbia River 

ESU

Threatened Vancouver, 

Manchester 

Vancouver

Chum 

Salmon

Oncorhynchus 

keta

Hood Canal

Summer - Run 

ESU

Threatened Manchester Manchester

Coho 

Salmon

Oncorhynchus 

kisutch

Central California 

Coast ESU

Endangered Point Loma, 

Selby, Vancouver, 

Manchester

No

Coho 

Salmon

Oncorhynchus 

kisutch

Lower Columbia 

River ESU

Threatened Vancouver, 

Manchester

Vancouver

Coho 

Salmon

Oncorhynchus 

kisutch

Oregon Coast ESU Threatened Vancouver, 

Manchester

No

Coho 

Salmon

Oncorhynchus 

kisutch

Southern Oregon 

and Northern 

California Coast 

ESU

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Eulachon Thaleichthys 

pacificus

Southern DPS Threatened Selby, Vancouver, 

Manchester

Vancouver

Giant Manta 

Ray

Manta 

birostris

Throughout Range Threatened All Transits No
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Common 

Name

Scientific

Name

Designation Unit* ESA Listing 

Status

Transit routes the 

species may be 

present in

Designated 

critical habitat 

overlaps with 

transit routes

Green 

Sturgeon

Acipenser 

medirostris

Southern DPS Threatened Point Loma, 

Selby, Vancouver, 

Manchester

Selby, 

Vancouver, 

Manchester

Oceanic 

White Tip 

Shark

Carcharhinus 

longimanus

Throughout Range Threatened All Transits No

Scalloped 

Hammerhead 

Shark

Sphyrna 

lewini

Eastern Pacific 

DPS

Endangered Point Loma, 

Selby, Vancouver, 

Manchester

No

Scalloped 

Hammerhead 

Shark

Sphyrna 

lewini

Indo – West Pacific 

DPS

Threatened Sasebo, Subic 

Bay, Singapore, 

Darwin

No

Sockeye 

Salmon

Oncorhynchus 

nerka

Ozette Lake ESU Threatened Manchester No 

Sockeye 

Salmon

Oncorhynchus 

nerka

Snake River ESU Endangered Vancouver, 

Manchester 

Vancouver

Steelhead Oncorhynchus 

mykiss

California Central 

Valley DPS

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Steelhead Oncorhynchus 

mykiss

Central California 

Coast DPS

Threatened Point Loma,

Selby, Vancouver, 

Manchester

No

Steelhead Oncorhynchus 

mykiss

Lower Columbia 

DPS

Threatened Vancouver, 

Manchester 

Vancouver

Steelhead Oncorhynchus 

mykiss

Middle Columbia 

River DPS

Threatened Vancouver, 

Manchester 

Vancouver

Steelhead Oncorhynchus

mykiss

Northern California 

DPS

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Steelhead Oncorhynchus 

mykiss

Puget Sound DPS Threatened Vancouver, 

Manchester 

No

Steelhead Oncorhynchus 

mykiss

Snake River Basin 

DPS

Threatened Vancouver, 

Manchester 

Vancouver

Steelhead Oncorhynchus 

mykiss

South - Central 

California Coast 

DPS

Threatened Point Loma, 

Selby, Vancouver, 

Manchester

No

Steelhead Oncorhynchus 

mykiss

Southern California 

DPS

Endangered Point Loma, 

Selby, Vancouver, 

Manchester

No

Steelhead Oncorhynchus 

mykiss

Upper Columbia 

River DPS

Threatened Vancouver, 

Manchester 

Vancouver

Steelhead Oncorhynchus 

mykiss

Upper Willamette 

River DPS

Threatened Vancouver, 

Manchester 

Vancouver

Yelloweye 

Rockfish

Sebastes 

ruberrimus

Puget 

Sound/Georgia 

Basin DPS

Threatened Manchester Manchester
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Critical Habitat

The Main Hawaiian Island Insular DPS of false killer whale has designated critical habitat identified as 

island-associated marine habitat with four characteristics: 1) Adequate space for movement use within shelf 

and slope habitat; 2) Prey species of sufficient quantity, quality, and availability to support individual growth, 

reproduction, and development, as well as overall population growth; 3) Waters free of pollutants of a type 

and amount harmful to Main Hawaiian Island insular false killer whales; and 4) Sound levels that will not 

significantly impair false killer whales’ use or occupancy. Section 3.3.3.2 analyzes the effects of underwater 

noise on designated critical habitat of the Main Hawaiian Island Insular DPS of false killer whale.

It is anticipated that there would be no effect from the Proposed Action on the designated critical habitat of 

all other ESA-listed species identified in Tables 3.3-1, 3.3-2, and 3.3-3. Tanker ship occurrence in space 

and time is short. Critical habitat elements that are part of the substrate are not expected to interact with 

the transiting vessels and the physical and biological essential features for which these habitats were 

designated will not be affected.

Environmental Consequences

This section discusses the potential short- and long-term effects to marine biological resources that could 

result from the action alternatives and the No Action Alternative. The effects analysis evaluated the potential 

for beneficial or adverse impacts in consideration of BMPs listed in Table 2.5-1.The effects analysis is 

focused on impacts to protected marine fauna including ESA-listed marine mammals, sea turtles, and fishes

because affects to marine vegetation, EFH, and other marine fauna from the Proposed Action are not 

expected, as described in Section 3.3.2. Potential stressors associated with the Proposed Action include 

elevated underwater noise from vessels and vessel collisions with marine species. A detailed analysis of 

potential stressors and environmental consequences is included in Appendix D. Although not considered 

reasonably likely to occur, the risk of a fuel spill affecting marine biological resources present in the ROI 

was also considered.

3.3.3.1 Alternative 1: No Action Alternative

Under the No Action Alternative, a low demand for JP-5 fuel at JBPHH may require JP-5 movement by 

vessel to points of immediate consumption as part of a stock rotation program. The amount of fuel 

transferred to tanker ships for overseas deliveries would likely be substantially less than under Alternatives 

2 and 3. The destinations of any JP-5 stock rotation movements under the No Action Alternative are likely 

to be one or more of the nine potential fuel receiving locations analyzed in Alternative 2.

The amount of fuel to be transferred to tanker ships in Pearl Harbor for overseas deliveries would likely be 

substantially less than the amounts proposed under Alternatives 2 and 3, marginally reducing the potential 

for spills to affect marine resources when compared to Alternatives 2 and 3. Additionally, the No Action 

Alternative would use vessels for fuel movement only if a low demand for JP-5 fuel at JBPHH requires stock 

rotation. Less vessel transits would reduce the likelihood of impacts to marine species from elevated 

underwater noise levels and vessel collisions. Vessels that would move JP-5 would be similar type tanker 

ships that would be used in Alternatives 2 and 3. Tanker ships would use the same low speeds and BMPs 

as Alternatives 2 and 3 (see Section 3.3.3.2). Therefore, Alternative 1 would have less than significant 

effects to marine biological resources.

3.3.3.2 Alternative 2: Relocation

Underwater Noise

Several factors influence the underwater noise emissions of individual vessels, such as vessel speed, draft, 

size, and loading (MacGillivray et al., 2019). The vessel’s propulsion system is the dominant source for 

sounds below 200 hertz (Hz). Most ocean-going vessels have two-stroke engines that connect directly to 

the ship’s hull, and due to vibrations, transmit noise underwater.

With Alternative 2, tanker ships used to relocate fuel produce lower sound levels compared to larger 

commercial vessels (e.g., bulk carrier), with dominant sound frequency levels around 40-60 Hz and sound 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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levels of approximately 180 decibels referenced to a pressure of one micro Pascal at one meter (dB re 

1μPa-m). In deep water, underwater sound decays by about 60 decibels (dB) within the first 500 meters of 

distance from a large ship, with the majority of decay within the first 100 meters (Bowles et al., 2007). Sound 

levels from a transiting vessel would be lower than the thresholds for continuous sound likely to cause

acoustic injury including permanent threshold shift (PTS) or temporary threshold shift (TTS) in marine 

mammals and sea turtles.

Little data exist on the effects of vessel noise on hearing in fishes. TTS has been observed in fishes exposed 

to elevated background noise and other continuous sources. As noted in the ANSI Sound Exposure 

Guideline technical report (Popper et al., 2014), some fish species with a swim bladder that is involved in 

hearing may be more susceptible to TTS from long-duration, continuous noise depending on the duration 

of the exposure. However, it is not likely that TTS would occur in any ESA-listed fish species in Table 3.3-

3 because these fish either have a swim bladder not involved in hearing or do not have a swim bladder.

Additionally, underwater noise produced by the tanker ships would be temporary and not considered a longduration or continuous noise source. Fishes that are exposed to vessel noise in their natural environment, 

even in areas with higher levels of vessel movement, would only be exposed for a short duration (seconds 

or minutes) as vessels are transient and pass by.

Vessel noise also has the potential to mask low-frequency sounds that animals depend on for 

communication, navigation, and finding mates or prey. The likelihood of such an encounter with an ESAlisted species is extremely remote because of the low probability that individual animals overlap in space 

and time with the eleven one-way tanker transits. Effects would be limited temporary and recoverable 

behavioral disturbance to marine mammals, sea turtles, or fishes.

The temporary, low-frequency and lower intensity sound levels by the tanker ships that would be used for 

Alternative 2 would not result in an increased likelihood of acoustic injury (i.e., PTS or TTS) to marine 

mammals, sea turtles, or fishes. Sound levels would not significantly disrupt breeding, feeding, or sheltering 

for any ESA-listed species encountered. Therefore, the risk of elevated underwater noise is not likely to 

adversely affect an ESA-listed marine mammal, sea turtle, or fish and potential effects would be

insignificant. 

Underwater noise has the potential to adversely affect the Main Hawaiian Island Insular DPS of false killer 

whale critical habitat characteristic for sound, and scientific evidence indicates that permanent or chronic 

noise sources can degrade the conservation value of the underwater habitat. For the limited anticipated 

vessel transits, the Proposed Action would result in increased underwater sound levels that would be low 

frequency, transient in nature, and not significantly impair false killer whales. Therefore, the Proposed 

Action is not likely to adversely affect any essential feature or characteristic of the Main Hawaiian Islands

false killer whale critical habitat in any meaningful way, and the potential effects would be insignificant.

Vessel Collision

While surfacing to breathe or rest, marine fauna including marine mammals, sea turtles, and certain fish

species are at risk of a collision with moving vessels. The type and severity of injury depends upon the size 

of the vessel, the speed and direction of the vessel if in motion, the part of the vessel that strikes the animal 

(i.e. hull vs. propeller), and the part of the animal’s body that was impacted. Depending on these factors, a 

vessel collision has the potential to cause serious injury or death. Collision avoidance success is dependent 

on the animal’s ability to identify and locate the vessel from its radiated sound and the animal’s ability to 

maneuver away from the vessel in time.

Collisions with vessels is considered a major threat for green sea turtles (NMFS & USFWS, 1998). Higher 

vessel speeds are more likely to cause impacts, particularly in shallow waters where turtles are abundant 

and in turbid waters (Hazel et al., 2007). The National Oceanic and Atmospheric Administration (NOAA) 

Fisheries (2023) estimated 37.5 vessel strikes of sea turtles per year from an estimated 577,872 trips from 

vessels of all sizes in Hawaii. Using this estimate, this calculates to a 0.04 percent probability of a vessel 

strike for all vessels and trips, many of which are not reducing speeds or employing lookouts for listed 

species. Based on turtle stranding data from Pearl Harbor from 2006-2020, 34 incidents identified the cause 

of stranding to be boat impact. 
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Whales engaged in surface activities (e.g., feeding, breeding, and resting) may not notice an approaching 

vessel (Silber et al., 2010). Generally, mysticetes (i.e., baleen whales) are larger animals with less ability 

to maneuver away from and to avoid vessels. In addition, mysticetes do not typically aggregate in large 

groups and are therefore difficult to detect visually from the water surface. Between 1988 and 2007, 21 blue 

whale deaths were reported along the California coast, and many of these showed evidence of ship strike 

(Berman-Kowalewski et al., 2010).

When generally compared to mysticetes, odontocetes (i.e., toothed whales) are quicker and more capable 

of physically avoiding a vessel strike. Since some species occur in large groups, odontocetes are typically 

seen when closer to the water surface. However, ESA-listed killer whales (Van Waerebeek et al., 2007; 

Visser and Fertl, 2000) and sperm whales (Jaquet and Whitehead, 1996; Watkins et al., 1999; Gannier and 

Marty, 2015) are potentially susceptible to vessel strikes.

Ship strikes are not a global threat to pinniped populations, and pinnipeds in general appear to suffer fewer 

impacts from ship strikes than cetaceans (Kovacs et al., 2015). This may be due, at least in part, to the 

large amount of time they spend on land (especially when resting and breeding), and their high 

maneuverability in the water. Ship strikes are not a major concern for pinnipeds in general, including the 

threatened Guadalupe fur seal or for the endangered Hawaiian monk seal (Antonelis et al., 2006; Marine 

Mammal Commission, 2002; NMFS, 2014).

Vessels do not normally collide with adult fishes, most of which can detect and avoid them. Manta rays are 

presumed to be susceptible to vessel strikes due primarily to their large size, slow swimming speed, and 

distribution in the upper portion of the water column (Couturier et al., 2012; NMFS, 2016). Very little 

quantitative information on the frequency of manta ray vessel strikes is available and no information exists 

on the impact of injuries and mortalities resulting from vessel strikes to the overall health of the population 

(NMFS, 2016). 

Tanker ships that would be used with Alternative 2 would travel on the open ocean at an average speed of 

fifteen knots, which would be considered “super slow” compared to other commercial vessels (Bonney and

Leach, 2010). Tankers would reduce speeds in nearshore harbor areas. Within Pearl Harbor, this is typically 

ten knots or less, to prevent collision, and five knots or less when piloting vessels in areas of known turtle 

presence. This temporary and slow-moving presence of the maximum of eleven tanker ships would not 

result in an increased likelihood of injury nor would it significantly disrupt breeding, feeding, or sheltering 

for marine mammals, sea turtles, or fishes encountered. Species or life stages that are demersal (living 

close to the sea floor), as well as critical habitat elements that are on or part of the substrate, would not 

interact with the transiting vessels and any adverse effects are so low as to be discountable. Additionally, 

the likelihood of a vessel collision with a protected marine species is extremely remote because of the low 

probability that individual animals would overlap in space and time with the eleven tanker transits. 

Therefore, the risk of a vessel collision from the tanker transits in Alternative 2 is not likely to adversely 

affect an ESA-listed marine mammal, sea turtle, or fish and is discountable. The relatively slow speed of 

the vessels further reduces the chance of ship strike with marine mammals, sea turtles, and fishes. Vessels 

would employ measures to avoid and reduce the potential for vessel collisions and interactions with 

protected species (Table 2.5-1, BMP-11). 

Fuel Spills

Oil and other chemical spills can have damaging effects on marine fauna species directly through exposure 

to oil or chemicals and indirectly due to pollutants’ impacts on prey and habitat quality (Engelhardt, 1983; 

Marine Mammal Commission, 2010; Matkin et al., 2008; Seminoff et al., 2015). With Alternative 2, a fuel

spill affecting marine biological resources including ESA-listed species and critical habitat present in the 

ROI was not considered reasonably likely to occur. Fuel loading at the JBPHH fueling pier would follow 

standard operating procedures and BMPs (Table 2.5-1, BMP-2, -3, -4, -5, -6, -7) to reduce the risk of spills. 

When the tanker ships are docked at the JBPHH pier, oil-absorbent booms would surround the vessels, 

contain, and capture any spills that might occur until spill response teams arrive on the scene. Additionally, 

all tankers would be assisted by tug within the harbors to prevent allision/collision, which is statistically the 

highest cause of tanker spills worldwide. There is a very low likelihood of a spill from tanker ships during 

transit in the open ocean. Section 3.2.2.5 provides more information on tanker ship spill statistics. 
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Receiving locations would have response teams and BMPs available (e.g., equipment maintenance 

protocols, contingency plans, fueling restrictions) to further reduce the potential for a spill during fuel 

unloading. Additionally, it is unlikely that ESA-listed marine fauna species will have a high presence or 

abundance at the fuel unloading piers and ports, further limiting potential exposures to ESA-listed species.

Overall, with the use of BMPs, Alternative 2 would have less than significant effects to marine biological

resources.

3.3.3.3 Alternative 3: Commercial Sale and Relocation

Under Alternative 3, impacts to marine biological resources would be similar to those described for 

Alternative 2. The same number of tanker ships would transit through Pearl Harbor to the JBPHH fueling 

pier to receive fuel. Tankers would be loaded using the same procedure and BMPs as Alternative 2. Tanker 

ships used in Alternative 3 would be similar to those used in Alternative 2, including similar size and speeds. 

Therefore, the risk of underwater noise from vessels, vessel collision with marine species, and fuel spills in 

Pearl Harbor would be the same as described Alternative 2.

The transit route and destination of sold fuel is at the discretion of the non-federal entity purchaser and not 

a federal action. While it is not possible to reasonably predict where the fuel would go, it is reasonable to 

assume that tanker transits would overlap with some of the ESA-listed species identified in Tables 3.3-1, 

3.3-2, and 3.3-3. Similar to Alternative 2, the temporary and slow-moving presence of the maximum of 

eleven tanker ships would reduce the risk of impacts to protected species from vessel noise or collision. 

Vessel operators would be required to follow all environmental and safety regulations which would reduce 

factors that could result in catastrophic oil spills.

With the use of BMPs, Alternative 3 would result in a less than significant effects to marine biological 

resources.
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3.4 HAZARDOUS MATERIALS AND WASTE

This section discusses potential interaction of operational activities of the Proposed Action with hazardous 

materials, hazardous waste, toxic substances, and contaminated sites. 

Regulatory Setting 

Hazardous materials are defined by 49 CFR section 171.8 as “hazardous substances, hazardous wastes, 

marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous 

Materials Table, and materials that meet the defining criteria for hazard classes and divisions in 49 CFR 

part 173.” Transportation of hazardous materials is regulated by the U.S. Department of Transportation 

(DOT) regulations. 

Hazardous wastes are defined by the Resource Conservation and Recovery Act (RCRA), as amended by 

the Hazardous and Solid Waste Amendments, as: “a solid waste, or combination of solid wastes, which 

because of its quantity, concentration, or physical, chemical, or infectious characteristics may (A) cause, or 

significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating 

reversible, illness; or (B) pose a substantial present or potential hazard to human health or the environment 

when improperly treated, stored, transported, or disposed of, or otherwise managed.” In Hawaii, the DOH 

Solid & Hazardous Waste Branch regulates the handling hazardous waste materials and used oil 

generators and handlers.

Special hazards are those substances that might pose a risk to human health and are addressed separately 

from other hazardous substances. Special hazards include asbestos-containing material (ACM), PCBs, and 

lead-based paint (LBP). EPA is given authority to regulate special hazard substances by the Toxic 

Substances Control Act (TSCA). Asbestos is also regulated by EPA under the Clean Air Act (CAA), and 

the CERCLA. 

The DoD established the Defense Environmental Restoration Program (DERP) to facilitate thorough 

investigation and cleanup of contaminated sites on military installations (active installations, installations 

subject to Base Realignment and Closure, and formerly used defense sites). The Installation Restoration 

Program and the Military Munitions Response Program are components of the DERP. The Installation 

Restoration Program requires each DoD installation to identify, investigate, and clean up hazardous waste 

disposal or release sites.

Affected Environment 

The ROI for hazardous materials and hazardous waste includes the areas at JBPHH and potential receiving 

locations where fuel loading, transit, and unloading operations would occur. At JBPHH, this includes areas 

surrounding the fuel piping, associated infrastructure, and fueling pier where human or environmental 

exposure to hazardous materials, hazardous waste, toxic substances, and contaminated sites is possible. 

The ROI at JBPHH is located below the UIC line, meaning that it is outside of areas identified by DOH as 

underground sources of drinking water. For maps depicting areas below the UIC line, see: 

https://health.hawaii.gov/sdwb/underground-injection-control-program/.

The ROI also includes the tanker transit routes and areas surrounding the fuel delivery points where human 

or environmental exposure to hazardous materials, hazardous waste, toxic substances, and contaminated 

sites is possible. At the Campbell Industrial Park, West Oahu location, fuel transfer would occur through an 

offshore mooring that transfers oil and refined products through a hose between ships and the 

refinery/storage onshore. At the other receiving locations, fuel transfer would occur though a flexible hose 

connecting the tanker ship to the receiving entity’s fuel receiving infrastructure location on a pier or wharf.

The ROI includes tanker transits through the Pearl Harbor Naval Complex site listed on the EPA’s CERCLA 

National Priorities List (NPL). The NPL identifies priority sites of known releases or threatened releases of 

hazardous substances, pollutants, or contaminants throughout the United States and its territories (EPA, 

2023c). The Pearl Harbor Sediment Study conducted by the Navy in 2015 identified sediments impacted 

by chemical contamination from naval activities (i.e., ship maintenance and repair) in the southern 
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Southeast Loch area (Figure 3.4-1). Localized areas of copper, mercury, lead, and total PCBs were 

reported with subsurface sediment exceedances based on risk to human health/ecological receptors and 

site-specific background levels. Tanker ships transiting through Southeast Loch to the fueling pier would 

briefly transit above these contaminated sediments.

Ongoing remediation is occurring within Pearl Harbor that includes focused dredging of sediments 

containing high COC concentrations, enhancing the rate of natural recovery of sediments with moderate 

COC concentrations, monitoring natural recovery of sediment with low COC concentrations, and limiting 

the bioavailability of COCs within the sediment. 

Figure 3.4-1. Areas Designated for Remediation Under CERCLA at the Pearl Harbor Sediment Site
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Environmental Consequences

The hazardous materials and waste assessment determined the extent to which action alternatives could 

increase the risk of release hazardous materials or waste, particularly if it increases the potential for human 

exposure. Human or environmental exposure to hazardous materials or hazardous wastes from the 

Proposed Action could primarily result from contact with inadvertent fuel releases or spill cleanup materials 

during fuel transfer operations or spill response efforts. Possible routes of exposure to fuel include inhalation 

of vapors, skin and eye contact, and ingestion. Health effects from exposure to fuels may include irritation 

to unprotected skin, eye and upper respiratory irritation, fatigue, breathing difficulty, headaches, dizziness, 

and sleep disturbances (VA, 2023).

Exposure to contaminants resulting from the resuspension of contaminated sediments in Pearl Harbor 

during tanker transits was also considered. Possible routes of exposure to contaminated sediments include 

skin and eye contact and ingestion. The areas of Pearl Harbor where tanker ships may encounter 

contaminated sediments are not used for recreational swimming or watersports where there is prolonged 

contact with or submersion in the water (e.g., surfing, wakeboarding).

Fuel that does not meet specifications for DoD use would be managed according to Option A: Upper Tank 

Farm or Option B: Commercial Sale, as described in Section 2.3.2, and is not considered a waste product. 

The Proposed Action does not involve any ground-disturbing elements or in-water work that could result in 

dispersion or resuspension of contaminated soils or sediments, or the disturbance of munitions and 

explosives of concern (MEC). No construction and demolition debris containing hazardous materials such 

as asbestos-containing material (ACM), PCBs, or LBP is expected to be produced.

3.4.3.1 Alternative 1: No Action Alternative

Under the No Action Alternative, flowable fuel at RHBFSF would be drawn down over a period of 

approximately ten to fourteen months after DOH approval of the gravity-based defueling operation. 

Flowable fuel from RHBFSF would be transferred to the UTF or to fueling piers at JBPHH through existing 

infrastructure. Fuel from the UTF can then be sent by pipeline to Hickam Field, fuel loading piers, or truck 

loading racks for distribution to customary defense customers for consumption. 

A low demand for JP-5 fuel at JBPHH may require JP-5 movement by vessel to points of immediate 

consumption as part of a stock rotation program. Additionally, JP-5 may be regraded to F-24 or F-76 for 

consumption at JBPHH. Existing locations within the DoD fuel supply chain that may receive relocated fuel 

from RHBFSF as part of Alternatives 2 and 3 would continue to receive their regular fuel deliveries by tanker 

ships from other fuel sources. 

Inadvertent fuel releases that could be associated with Alternative 1 would mostly consist of small spills at 

points of consumption where fuel is transferred or dispensed. JBPHH has spill response procedures to 

address potential spills and to limit their effects to human health and the environment. Spilled fuel and 

contaminated absorbents or debris would be managed in accordance with the waste management plan 

(Table 2.5-1, BMP-8), which includes procedures to properly collect, store, manage, and dispose of waste 

resulting from an oil spill response. Recoverable fuel would be processed through the JBPHH Fuel Oil 

Reclamation Facility (FORFAC) or processed as off-specification petroleum for reclamation through a 

permitted used oil processor. Contaminated solid wastes such as absorbents or debris that were 

characterized as non-hazardous would be disposed of at a permitted solid waste facility. Contaminated 

wastes and decontamination solutions that are characterized as hazardous would be disposed of at a 

permitted Treatment, Storage, and Disposal Facility.

Propeller wash from vessels moving JP-5 to points of immediate consumption could resuspend 

contaminated sediments around navigational channels and piers, thereby temporarily affecting water 

quality (SSC Pacific, 2016). Propeller wash could also contribute to vertical mixing, dispersion, and gradual 

dilution of contaminated sediments with clean sediments (Navy, 2018). Resuspension is limited to localized 

scouring from maneuvering vessels operating at high power, with resuspended sediments most likely 

settling at or near the point of disturbance. Impacts would be limited to short term resuspension of 

contaminated sediments in Pearl Harbor. Human exposure to resuspended contaminated sediments would 
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not be expected because these areas are not used for recreational swimming or watersports where there 

is prolonged contact with or submersion in the water. BMPs limiting the disturbance of sediments, including 

low ship speed and use of tugboats to assist tanker ships through Pearl Harbor (Table 2.5-1, BMP-1), would 

minimize environmental exposure to the extent that no significant adverse impacts related to contaminated 

sediments are expected to occur.

With the use of BMPs, Alternative 1 would result in a less than significant increase to the potential for human 

or environmental exposure to hazardous materials or waste.

3.4.3.2 Alternative 2: Relocation

Alternative 2 is the relocation of approximately 106 million gallons of flowable fuel from RHBFSF to existing 

locations within the DoD fuel supply chain by ocean transit. A maximum of eleven tanker ships would be 

required to receive all of the flowable fuel from RHBFSF.

Fuel Loading and Unloading

Inadvertent fuel releases during fuel loading and unloading processes would mostly consist of small 

amounts of fuel escaping from the flexible hose and flexible hose connection points on the fueling pier and 

tanker ship. In the past three years, there was one incident at JBPHH where overfilling a vessel resulted in 

the release of approximately five gallons of fuel, and one incident where a pipeline failure resulted in the 

release of approximately 100 gallons of fuel. In the event of a fuel release, workers could be exposed to 

the fuel during incident response and spill cleanup activities. These type of incidents would be avoided 

during the RHBFSF gravity-based defueling operations by complying with operation, maintenance, 

environmental, and safety plans as well as strict personnel oversight and employing BMPs (Table 2.5-1, 

BMP-2, -3, -4, -5, -7). Personnel involved in the fuel loading operation would utilize personal protective 

equipment (PPE) including personal flotation device, steel toed shoes, safety glasses, and chemical 

resistant work gloves during the operation. Additional PPE would be donned by responders in the event of 

a spill in accordance with spill response procedures.

Inadvertent releases of fuel from the pipeline and flexible hose connection on the JBPHH fueling pier would 

be collected by a basin containment system that is routed to the FORFAC where fuel products would be 

separated and recovered for commercial sale or proper disposal. If fuel is inadvertently spilled into the water

it would be contained inside the oil-absorbent booms which would be deployed around tanker ships prior 

to beginning the fuel loading operations. Water Resources Section 3.2.3.2 provides details on impacts to 

water resources from a spill.

JBPHH has spill response procedures to address potential spills and to limit their effects to human health 

and the environment. Spilled fuel and contaminated absorbents or debris would be managed in accordance 

with the waste management plan (Table 2.5-1, BMP-8), which includes procedures to properly collect, store, 

manage, and dispose of waste resulting from an oil spill response. Recoverable fuel would be processed 

through the FORFAC or processed as off-specification petroleum for reclamation through a permitted used 

oil processor. Contaminated solid wastes such as absorbents or debris that were characterized as nonhazardous would be disposed of at a permitted solid waste facility. Contaminated wastes and 

decontamination solutions that are characterized as hazardous would be disposed of at a permitted 

Treatment, Storage, and Disposal Facility.

Fuel unloading at destination locations would be accomplished in accordance with the receiving entity’s 

standard practices and operating procedures. Spills at receiving locations would be addressed by their onsite response teams.

Tanker Transits

Tanker ships relocating fuel from RHBFSF would use existing navigational channels to transit through 

Mamala Bay to the Pearl Harbor Main Channel and into Southeast Loch to arrive at the JBPHH fueling pier. 

Up to two round-trip tanker transits per week would occur during the gravity-based defueling process, for a 

maximum of eleven total round-trip transits. Propeller wash from tanker ships and tugboats could resuspend 
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contaminated sediments around navigational channels and piers, thereby temporarily affecting water 

quality (SSC Pacific 2016). Propeller wash could also contribute to vertical mixing, dispersion, and gradual 

dilution of contaminated sediments with clean sediments (Navy, 2018). Resuspension is limited to localized 

scouring from maneuvering vessels operating at high power, with resuspended sediments most likely 

settling at or near the point of disturbance. In 2022, there was an average of fourteen fueling evolutions per 

month for tankers, ships, and barges of varying size, draft, and fuel capacity at the JBPHH fueling pier. 

Impacts from the additional two tanker ships per week would be limited to short term resuspension of 

contaminated sediments in Pearl Harbor. Human exposure to resuspended contaminated sediments would 

not be expected because these areas are not used for recreational swimming or watersports where there 

is prolonged contact with or submersion in the water. BMPs limiting the disturbance of sediments, including 

low ship speed and use of tugboats to assist tanker ships through Pearl Harbor (Table 2.5-1, BMP-1), would 

minimize environmental exposure to the extent that no significant adverse impacts related to contaminated 

sediments are expected to occur.

With Alternative 2, there would be no change to the potential for human or environmental exposure to 

hazardous materials or waste at receiving locations because fuel deliveries from RHBFSF would occur in 

lieu of routine or planned fuel supply deliveries by similar type tanker ships. 

With the use of BMPs, Alternative 2 would result in a less than significant increase to the potential for human 

or environmental exposure to hazardous materials or waste.

3.4.3.3 Alternative 3: Commercial Sale and Relocation

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of flowable fuel 

from RHBFSF combined with the relocation of the remaining portion of the fuel to existing locations within 

the DoD fuel supply chain by ocean transit. A maximum of eleven tanker ships would be required to receive 

all of the flowable fuel from RHBFSF. 

With Alternative 3, up to ten tanker loads of fuel from RHBFSF may be commercially sold in accordance 

with Section 2922e of Title 10, USC, which authorizes the sale of certain fuel sources. Sale of fuel would 

need to coincide with defueling schedule. Therefore, the amount of fuel sold would be determined by 

commercial interest and purchasers’ ability to receive the fuel at the time of gravity-based defueling. Fuel 

sold commercially would be loaded onto purchasers’ commercially-operated tanker ship(s) using the same 

pace and procedure as Alternative 2. 

Under Alternative 3, the risk of release of hazardous materials or waste would be the same as described 

for Alternative 2. The same number of tanker ships would transit through Pearl Harbor to the JBPHH fueling 

pier to receive fuel. Tankers would be loaded using the same procedure as Alternative 2; therefore, the risk 

of human or environmental exposure resulting from an inadvertent fuel release would be the same. Tanker 

ships used in Alternative 3 would be similar to those used in Alternative 2, including similar size and speeds; 

therefore, the risk of exposure to resuspended contaminated sediments in Pearl Harbor would be the same 

as described Alternative 2.

With the use of BMPs, Alternative 3 would result in a less than significant increase to the potential for human 

or environmental exposure to hazardous materials or waste.
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3.5 AIR QUALITY AND GREENHOUSE GASES

This section discusses potential impacts to air quality and the contribution of greenhouse gases (GHGs) 

that could result from the Proposed Action. Many factors influence a region’s air quality, including the type 

and quantity of pollutants and how they are emitted into the atmosphere, the size and topography of the air 

basin, and the local meteorological conditions. 

Most air pollutants originate from human-made sources, including mobile sources (e.g., aircraft, fuelburning vehicles) and stationary sources (e.g., concrete batch plants, refineries, power plants), as well as 

indoor sources (e.g., some building materials and cleaning solvents). Natural sources, such as volcanic 

eruptions and forest fires, also release pollutants into the air. The concentration of various pollutants in the 

atmosphere comprises air quality at a location.

Regulatory Setting and International Standards

3.5.1.1 U.S. National Standards

The Clean Air Act (CAA) is the primary federal statute governing the control of air quality. The CAA 

designates six pollutants as “criteria pollutants” for which the EPA has established National Ambient Air 

Quality Standards (NAAQS) to protect public health and welfare. The criteria pollutants are carbon 

monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone, suspended particulate matter less than 

or equal to ten microns in diameter, fine particulate matter less than or equal to 2.5 microns in diameter 

(PM2.5), and lead. CO, SO2, NO2, lead, and some particulates are emitted directly into the atmosphere from 

emissions sources. Ozone, some NO2 and particulates are formed through atmospheric chemical reactions 

from other pollutant emissions that are influenced by weather, ultraviolet light, and other atmospheric 

processes. Ozone is not emitted directly, but is formed in the atmosphere from precursor chemicals, 

primarily nitrogen oxides (NOx) and volatile organic compounds (VOCs), in the presence of sunlight. 

Potential impacts of a project on ozone levels are evaluated in terms of NOx and VOC emissions.

NAAQS are classified as primary or secondary. Primary standards protect against adverse health effects; 

secondary standards are designed to protect public welfare, such as prevent damage to farm crops, 

vegetation, and buildings. Some pollutants have long-term and short-term standards. Short-term standards 

are designed to protect against acute, or short-term, health effects, while long-term standards were 

established to protect against chronic health effects. Ambient air is defined as that portion of the 

atmosphere, external to buildings, to which the general public is exposed. Each ambient air quality standard 

has its own criteria, known as the “form” of the standard, related to if and how many times it may be 

exceeded before the NAAQS is considered violated.

Areas that are in compliance with the NAAQS are designated as attainment areas. Areas that do not meet 

NAAQS for criteria pollutants are designated “nonattainment areas” for that pollutant. Areas that have 

transitioned from nonattainment to attainment are designated as maintenance areas and are also required 

to adhere to maintenance plans to ensure continued attainment.

The CAA requires states to develop a general plan to attain and maintain the NAAQS in all areas of the 

country and a specific plan for each nonattainment or maintenance pollutant (including the pollutant’s 

precursor) to achieve (nonattainment) or maintain (maintenance) compliance with the appropriate NAAQS 

for that pollutant. These plans, known as State Implementation Plans (SIPs), are developed by state and 

local air quality management agencies and submitted to the EPA for approval.

States establish their own ambient air quality standards that may be more stringent than those set by federal 

law and for non-criteria pollutants. Section 3.5.2 describes relevant air quality and standards of ports 

affected by the Proposed Action and alternatives.

EPA has identified 188 hazardous air pollutants (HAPs) [also referred to as toxic air pollutants or air toxics] 

that are known or suspected to cause cancer or other serious health and environmental effects. NAAQS 

have not been established for HAPs because EPA’s strategy is to use reductions of HAP emissions from 

stationary industrial, mobile, and indoor sources as a means to providing nationwide health protections. 
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National emission standards exist for HAPs, which are regulated under Section 112(b) of the 1990 CAA 

Amendments. The National Emission Standards for Hazardous Air Pollutants regulate HAP emissions from 

stationary sources (40 CFR part 61 and part 63). A National Emission Standards for Hazardous Air 

Pollutants NESHAP (Subpart Y) was implemented for marine loading terminals that load crude oil or 

gasoline; thus, it is does not apply to the Proposed Action that loads JP-5 (refined kerosene) and other lowvolatile fuels such as F-24 and F-76.

3.5.1.2 General Conformity

Federal actions proposed in U.S. nonattainment or maintenance areas are subject to the EPA General 

Conformity Rule that requires a conformity analysis to determine if the Proposed Action will conform to the 

approved SIP, the plan to bring the area into compliance by a future date and maintain compliance. A 

conformity applicability analysis is the first step of a conformity evaluation and assesses if a federal action 

must be supported by a conformity determination. This is typically done by quantifying applicable direct and 

indirect emissions that are projected to result due to implementation of the federal action. Indirect emissions 

are those emissions caused by the federal action and originating in the region of interest, but which can 

occur at a later time or in a different location from the action itself and are reasonably foreseeable. If the 

results of the applicability analysis indicate that the total emissions would not exceed the de minimis

emissions thresholds, a conformity determination is not required and the conformity evaluation process is 

completed. De minimis levels (in tons per year [TPY]) vary by pollutant and also depend on the severity of 

the nonattainment status for the air quality management area. De minimis threshold emissions are 

presented in Table 3.5-1. Vessel emissions within 3 NM of a state seaward boundary are evaluated for 

CAA conformity for state nonattainment and maintenance areas (Navy, 2013).

Table 3.5-1. General Conformity De Minimis Levels

Pollutant Area Type TPY

Ozone (VOC or NOX) Serious nonattainment 50

Severe nonattainment 25

Extreme nonattainment 10

Other areas outside an ozone transport region 100

Ozone (NOX) Marginal and moderate nonattainment inside an ozone transport region 100

Maintenance 100

Ozone (VOC) Marginal and moderate nonattainment inside an ozone transport region 50

Maintenance within an ozone transport region 50

Maintenance outside an ozone transport region 100

Carbon monoxide, SO2

and NO2

All nonattainment & maintenance 100

PM10 Serious nonattainment 70

Moderate nonattainment and maintenance 100

PM2.5 Serious nonattainment 70

All nonattainment & maintenance 100

Direct emissions, SO2, 

NO2 (unless determined not to 

be a significant precursor), 

VOC or ammonia (if determined 

to be significant precursors)

All nonattainment & maintenance 100

Lead All nonattainment & maintenance 25

VOC = Volatile Organic Compounds; NOX = Nitrogen Oxides; NO2 = Nitrogen Dioxide; SO2 =Sulfur Dioxide; PM10 = Particulate 

Matter 10 microns or less; PM2.5 = Particulate Matter 2.5 microns or less; Pb = Lead; TPY = tons per year
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3.5.1.3 Executive Order 12114 Evaluation

The analysis of health-based air quality impacts under EO 12114 includes emission estimates covering all 

Federal actions outlined under the EA/OEA that occur beyond U.S. territorial seas (greater than 12 NM). 

Where the receiving country does not promulgate its own de minimis thresholds, EO 12114 air quality 

evaluation would use the federal CAA “major source” threshold of 250 TPY emissions level as a screening 

level threshold of significance as described below.

The U.S. Prevention of Significant Deterioration (PSD) Program was adopted in the CAA under 40 CFR 

section part 52.21. The PSD Program applies to major stationary sources of air pollutants located in 

attainment areas, requiring that a source demonstrate that it does not significantly deteriorate the air quality 

in attainment areas. Under PSD, a “major source” is defined as a facility that emits equal to or greater than 

250 TPY of a criteria pollutant or regulated precursor, except for 28 source categories where the threshold 

is 100 TPY. As such, in attainment areas, the major emitting facility threshold of 250 or 100 TPY of a 

pollutant is the threshold of increased concern; therefore, this threshold is also a suitable screening 

threshold. These thresholds serve as screening level thresholds of significance. That is, where emissions 

of a pollutant are below the threshold for a nonattainment, attainment or maintenance area, as applicable, 

they would not be significant—absent compounding factors, such as proximity of sensitive receptors. Where 

those emissions exceed the applicable threshold discussed above, they demand a harder look at factors 

such as region of dispersal. It should be noted that the thresholds are conservative in that they are designed 

to apply to stationary sources. However, this EA/OEA will apply these stationary source requirements to 

sources that may be diffused and dispersed. It should also be noted that by increasing and decreasing with 

the air quality of a region, these thresholds consider other activities in the region in the past and present. 

As such they are measures of cumulative impacts.

To determine potential significance, international air emissions were compared to the 100 TPY Prevention 

of Significant Deterioration (PSD) threshold where the country of the receiving location does not promulgate 

its own de minimis thresholds. The 100 TPY value was selected to be conservative and because of the 

Proposed Action’s similarity to one of the 28 source categories subject to this limit under the PSD Program 

(e.g., petroleum storage transfer units). Because tankers are mobile sources, emissions would disperse 

during travel and not result in localized concentrations of pollutants that could harm human health. 

3.5.1.4 International Standards

Since 1987, WHO has periodically issued health-based air quality guidelines to assist governments and 

civil society to reduce human exposure to air pollution and its adverse effects (WHO, 2021).The WHO air 

quality guidelines were last updated in 2021.The guidelines provide health-based levels for the major 

health-damaging air pollutants. These guidelines are not legally binding standards; however, they do 

provide WHO Member States with an evidence-informed tool that they can use to inform legislation and 

policy. Ultimately, the goal of these guidelines is to provide guidance to help reduce levels of air pollutants. 

Consulting firm IQAir found that no countries fully met the WHO’s air quality standards for particulate matter 

concentrations (based on surveys of 107 cities). For frame of reference, the U.S. was found to have an 

average PM2.5 concentration two times higher than the WHO’s recommendation of five micrograms/square 

meter (Choi, 2022). 

3.5.1.5 Greenhouse Gases

GHGs are gas emissions that trap heat in the atmosphere. These emissions occur from natural processes 

and human activities. Scientific evidence indicates a trend of increasing global temperature over the past 

century due to an increase in GHG emissions from human activities. The climate change associated with 

this global warming is predicted to produce negative economic and social consequences across the globe. 

CEQ guidance recommends federal agencies consider both the potential effects of a Proposed Action on 

climate change, as indicated by its estimated greenhouse gas emissions, and the implications of climate 

change for the environmental effects of a Proposed Action. 

GHGs include carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur 

hexafluoride, and other fluorinated gases including nitrogen trifluoride and hydrofluorinated ethers. Each 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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GHG is assigned a global warming potential. The global warming potential is the ability of a gas or aerosol 

to trap heat in the atmosphere. The global warming potential rating system is standardized to CO2, which 

has a value of one. 

To put carbon emissions in context, the average U.S. home generates 53 tons of CO2-equivalent annually. 

Additionally, the social cost of carbon (SCC) (in dollars) can be calculated that reflects the damage done to 

society by each additional ton of carbon emissions. EO 13990, Protecting Public Health and the 

Environment and Restoring Science to Tackle the Climate Crisis (White House, 2021) emphasizes the 

importance of ensuring federal agencies “capture the full costs of greenhouse gas emissions as accurately 

as possible, including taking global damages into account.” The U.S. Interagency Working Group set an 

interim SCC of $51/ton in February 2021. In November 2022, the EPA proposed a fourfold increase to 

$190/ton.

3.5.1.6 Ocean Shipping Emissions

Ocean-going vessels are a large and growing contributor to diesel emissions worldwide. While emissions 

of new automobiles have reduced greatly over the last twenty years and are transitioning to electricpowered models, ocean vessels lag in terms of use of renewable or low-carbon intensity fuels and are one 

of the largest anthropogenic sources of air pollution. However, some port authorities (for examples, Port of 

San Diego and Port of Aukland) are already using, or in the process of purchasing, electric tugboats to 

reduce their vessel emissions and carbon footprint.

The International Maritime Organization (IMO) implemented a series of regulations and operational practice 

guidance to reduce emissions from international ocean shipping. In 2010, the IMO officially accepted the 

North American Environmental Control Area (ECA), beginning in August, 2012. At that date, the sulfur 

content of fuel was be limited to 1 percent sulfur within 200 nautical miles (NM) of the coastline; in 2015, 

this limit dropped to 0.1 percent sulfur. Also, Tier III NOX emission standards, requiring advanced emission 

controls such as Selective Catalytic Reduction systems, were required for vessels built in and after 2016. 

The U.S. West Coast and Hawaii are included in the ECA.

Outside of ECAs, IMO implemented additional caps on sulfur in fuel oil in 2020. Known as “IMO 2020”, the 

rule limited sulfur in fuel for ships to 0.50 percent (by mass) - a significant reduction from the previous limit 

of 3.5 percent (IMO, 2020). However, this sulfur emission cap is still five time higher than the 2015 ECA 

limit. IMO 2020 applies to all ships, whether they are on international voyages, between two or more 

countries; or domestic voyages, solely within the waters of a Party to the MARPOL Annex. 

Greenhouse gas emissions are not regulated by IMO. However, CO2 reduction for ocean-going vessels is 

achievable through operational practices, such as slow-steaming or the use of alternative fuels, like 

biofuels. GHG emission reductions are also possible through network design by reducing vessel-cargo 

travel distances (S. Greene, et. al., 2020).

Affected Environment

3.5.2.1 Hawaii (JBPHH and Campbell Industrial Park, West Oahu) 

The air quality ROI includes the west, central, and south side of the island of Oahu in Honolulu County, 

where JBPHH is located, and the State of Hawaii for GHGs and climate change effects. The latest data 

from the Department of Health (DOH, 2021b) indicates the state is in attainment except for exceedances 

for SO2 in communities near the volcano on Hawaii Island, which is considered by the EPA as a natural, 

uncontrollable event. Because the State is in attainment of the NAAQS, it is not subject to the CAA’s 

General Conformity Rule. 

3.5.2.2 California (Point Loma and Selby Terminal)

Point Loma

Naval Base Point Loma is located in San Diego County. The county is in federally-designated severe 

nonattainment for 8-hr ozone; unclassifiable for PM10, and in attainment for other criteria pollutants. State 

designations are nonattainment for 8-hour ozone, 1-hour ozone, PM10, PM2.5 and attainment for other 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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pollutants (San Diego, 2023). In 2021, monitoring stations throughout the county showed up to 10 days 

per year when the maximum 1-hour and 8-hour ozone standards were exceeded. 

Selby Terminal

The Selby Terminal is located eighteen miles north of San Francisco on the northwest edge of Contra Costa 

County next to the Carquinez Strait. Air quality is managed by the Bay Area Air Quality Management 

District. 

The county is nonattainment for 8-hr ozone (marginal) and PM2.5 by federal standards. By state standards, 

the county is in nonattainment for ozone, PM2.5 and PM10 (CARB, 2023). Ozone is a primary problem in 

summer and fine particle pollution in the winter. The area around Selby Terminal is considered an 

overburdened community in terms of environmental and health stressors. In July 2022, Air District 

regulations set more stringent health risk limits and public noticing requirements for projects located in 

overburdened communities. The Selby Terminal is located adjacent to the Phillips 66 Rodeo Refinery. On 

March 20, 2023, the Bay Area Air Quality Management District released revised fence-line air monitoring 

plans for several refineries, including the Phillips 66 site. 

3.5.2.3 Washington (Port of Vancouver, Manchester)

All areas of Washington are in attainment and currently meet air quality standards, except a small area in 

Whatcom County (the Intalco aluminum smelter and area around it for sulfur dioxide) (EPA, 2023d).

3.5.2.4 Overseas

Sasebo, Japan

Sasebo is located in the southern portion of Japan on its western-most boundary. Sasebo Naval Base 

occasionally experiences unhealthy levels of “yellow haze”, made of PM2.5 particles, a combination of desert 

sand and pollution blowing in from central China (Stripes, 2013). 

Subic Bay Philippines

Air pollution in the Philippines is governed by the Philippine Clean Air Act of 1999 (Republic Act No. 8749) 

(Philippines, 1999). This regulation sets forth National Ambient Air Quality Guideline values for particulate 

matter, sulfur dioxide, nitrogen dioxide, ozone, carbon monoxide and lead. It also identifies de minimis 

levels for permitting of stationary sources where emissions greater or equal are considered significant and 

subject to Rule X: CO 100 TPY; NOX 40 TPY; SO2 40 TPY; TSP 25 TPY; PM10 15 TPY; VOCs 40 TPY; 

H2S 10 TPY.

The Philippines was ranked 69th out of 131 countries for air quality in 2022 by the research firm IQAir (GMA

News, 2023). The report showed that based on its average PM2.5 concentration, air quality in the country 

has slightly improved to 14.9 microgram per cubic meter (μg/m3) from 15.6 μg/m3 in 2021. However, IQAir 

stressed that this number was still three times higher than the annual air quality guideline value set by the 

WHO. In 2022, Taguig (south of Manila) was particularly tagged as the country’s most polluted city, while 

Balanga City (20 miles east of Subic Bay) was considered as the cleanest. Citing its 2016 figures, IQAir 

pointed out that 80 percent of the country’s air pollution came from motor vehicles, while the remaining 20 

percent was from stationary sources like factories and the open burning of organic matter. 

Port of Singapore

The main sources of air pollution in Singapore are emissions from the industries and motor vehicles. From 

time to time, transboundary smoke haze from land and forest fires in the region also affect Singapore’s air 

quality, particularly during the Southwest monsoon period from August to October. Singapore enjoys better 

air quality than many cities in Asia, comparable with that of cities in the United States and Europe. 

Singapore’s Pollutant Standards Index has remained in the ‘Good’ and 'Moderate' range for much of 2019 

(NEA, 2023). 
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Trend shows that the levels of PM10 and PM2.5 have been decreasing over the past decade. Industries and 

motor vehicles are the major sources of PM10 and PM2.5 in Singapore. Over the years, a multi-pronged 

approach involving the tightening of vehicular emission standards, fuel quality standards, and stringent 

enforcement action against smoke emissions from motor vehicles and industries, have reduced domestic 

emissions of particulate matter. 

Port of Darwin Australia

The Port of Darwin is located on the northern shore of the Northern Territory State on the Timor Sea. Like 

the rest of Australia, Darwin generally experiences relatively healthy air quality most of the year round, in 

comparison to global locations. However, as in the rest of the country, Darwin is also vulnerable to 

experience short-term air pollution spikes from extreme events such as bushfires and dust storms, which 

can significantly affect air quality for short periods of time (IQAir, 2023). Although some exceedances of 

short-term standards were recorded for PM10 and PM2.5, all air monitoring stations were compliant with the 

National Environment Protection (Ambient Air Quality) Measure goals (NTEPA, 2020). 

Environmental Consequences

This analysis evaluates the potential short- and long-term effects on air quality that could result from 

estimated direct and indirect emissions associated with the action alternatives and No Action Alternative.

Implementation of the action alternatives would generate short-term, temporarily-emitted air pollutants 

emissions from combustion of fossil fuels for propulsion during ship transits. Fuel transfers may also release 

minor and temporarily-emitted fugitive emissions. Fugitive emissions are those that escape due to small 

unintended leaks in a system or from vapors from pressurized equipment.

3.5.3.1 Method for Estimating Air Pollutant Emissions for Tanker Operations

The primary source of air pollutants under the Proposed Action would be emissions from the combustion 

of fuel by the propulsion system of a medium-range tanker. 

Tanker operating modes are categorized as transit (vessel operations between JBPHH and potential 

receiving locations), maneuvering (slow speed vessel operations while in port areas), and hotelling (also 

known as berthing or moored a pier). For simplicity, hotelling emissions are considered the same as 

“anchorage” for ship activity at anchor at or near a pier, but not moored to the pier.

Two types of engines are found on ocean-going vessels, main engines and auxiliary engines: 

• The main engine is a very large diesel engine used primarily to propel the vessel at sea. Main 

engines are used during the transit and maneuvering modes. 

• Auxiliary engines on ocean-going vessels provide power for uses other than propulsion (except for 

diesel-electric vessels). Typically, an ocean-going vessel will have a single, large main engine used 

for propulsion, and several smaller auxiliary “generator-set” engines. Auxiliary engines are used 

during all three operating modes. 

In addition to the engines, most ships have auxiliary boilers to provide steam heat for a variety of uses, 

including fuel heating and hot water. Some crude oil tankers also use boilers for moving crude oil product 

on and off the ship. Boilers are used during slow speed vessel operations or in port. For the purposes of 

this analysis, it is assumed that boilers are operated during maneuvering, and hotelling/anchorage. 

To calculate emissions for a certain transit, pollutant emission factors for each engine or boiler source 

during each operating mode (transit, maneuvering, and hotelling) are multiplied by the load factor (auxiliary 

boiler only) and anticipated duration of operation. The emission factors and calculations in this section 

followed the methodology outlined in the 2011 California Air Resources Board “Emissions Estimation 

Methodology for Ocean-Going Vessels (CARB, 2011) and emission factors from the 2020 EPA Ports 

Emissions Inventory Guidance (EPA, 2022e). Emissions assume use of low sulfur fuel (0.1 percent sulfur) 

for portions of transits within ECAs; for international transit, emissions assume use of 0.5 percent sulfur 
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fuel. To be conservative, auxiliary boilers were assumed to use heavy fuel oil. Air pollutant emissions for 

each transit route were calculated in tons. 

General conformity analysis in the U.S. includes vessel sources within 3 nautical miles (NM), as this is a 

distance where emissions could be encountered by human populations and could become concentrated at 

levels that could affect local air quality. Local emissions for ports in the U.S. and internationally were 

calculated on a 3 NM basis. The majority of emissions would occur locally at the piers during fuel transfer 

(e.g., vessel emissions during hotelling and fugitive emissions from fuel transfer). Based on the most direct 

routes, the distances each vessel would transit within 12 and 3 NM of each country on route to each 

potential receiving location are estimated in Table 3.5-2. 

Table 3.5-2. Vessel Transit Distances between JBPHH and Potential Receiving Locations 

Receiving 

Location

Transit 

Distance 

within 200 

NM of Hawaii 

(NM)*

Transit 

Distance 

Outside 200 

NM of either 

Oahu or 

Receiving 

Location

Transit 

Distance 

between 12 

and 200 NM of 

Receiving 

State or 

Country

Transit 

Distance 

within 12 

NM of 

Receiving 

Location 

(NM)**

Transit within 

3 NM of 

Receiving 

Location

Total 

Transit 

Distance 

(NM)

Campbell 

Industrial 

Park, West 

Oahu, HI

13 0 NA NA 13 13

Point Loma, 

CA

226 1855 188 13 6 2282

Selby, CA 226 1668 188 34 25 2116

Port of 

Vancouver, 

WA

226 1830 188 99 90 2343

Puget 

Sound, WA

226 1928 188 141 132 2483

Sasebo, 

Japan

335 3330 188 203 17 4056

Subic Bay, 

Philippines

335 3936 188 370 12 4829

Port of 

Singapore

335 5626 188 82 17 6231

Darwin, 

Australia

212 4740 230 30 3 5192

Note: Numbers in orange bold assume use of 0.5% sulfur fuels (e.g., non-ECA zones); NA = Not applicable

* Vessel distance within ECA of Hawaii, all within 3 NM of shoreline.

** 3 NM distance is a subset of the 12 NM distance for U.S receiving locations.

VOCs can be released as fugitive emissions from the vessel during loading and transit. EPA estimates that 

ocean vessel loading releases 0.005 lbs/1,000 gallons transferred for kerosene (note: JP-5 is a type of 

refined kerosene) or number 2 fuel oil and approximately 0.005 lbs/week-1,000 gallons transported (EPA, 

2008). During fueling transfers and vessel transits, fugitive emissions are apportioned based on time within 

each phase.
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Figure 3.5-1. Emission Sources Associated with Vessel Transit 

Table 3.5-3 Provides emission factors for transit per hour that combine emissions from main engines, 

auxiliary engines, boilers, and fugitive emissions.

Table 3.5-3. Combined Emission Factors for Tanker Transits

Sulfur 

Content

CH4 CO CO2 NOX PM10 PM2.5 VOC SOX HAPs

0.1 % S 0.001 0.017 11.397 0.202 0.005 0.005 0.010 0.035 0.0009

0.5 % S 0.001 0.017 11.397 0.202 0.007 0.007 0.010 0.060 0.001

Units: tons/hour; S = Sulfur; CH4 = Methane; CO = Carbon Monoxide; CO2 =Carbon Dioxide; VOC = Volatile Organic 

Compounds; NOX = Nitrogen Oxides; SOx = Sulfur Oxides; PM10 = Particulate Matter 10 microns or less; PM2.5 = Particulate Matter 

2.5 microns or less.

Note: US EPA 2017 National Emissions Inventory developed HAP fractions for commercial marine vessels based on fractions of 

PM2.5 and VOCs. HAP emissions were estimated with a 0.0213 ratio to PM2.5 and 0.0807 to VOC (BOEM, 2021). Maneuvering 

emission factors are equivalent to transit emission factors.

To determine potential localized effects on air quality at receiving locations, emissions were estimated 

based on time the vessel is within 3 NM each receiving location (Figure 3.5-1). Emission calculation 

worksheets are provided in Appendix E. California ports (Selby and Point Loma) are in non-attainment 

areas. Accordingly, the Navy conducted an analysis of air emissions within the state and its regulated 

waters (all waters within 3 NM of the California baseline) (Navy, 2013). Records of Non-Applicability for 

Clean Air Conformity for Point Loma and Selby, California are also provided in Appendix E.

3.5.3.2 Alternative 1: No Action Alternative

Under the No Action Alternative, flowable fuel from RHBFSF would be transferred to the UTF or to fueling 

piers at JBPHH through existing infrastructure. Fuel from the UTF would then be sent by pipeline to Hickam 

Field, fuel loading piers, and truck loading racks for distribution to customary defense customers for 

consumption. A low demand for JP-5 fuel at JBPHH would require JP-5 movement by vessel to points of 

immediate consumption as part of a stock rotation program. 

Because fueling for customary defense points of use at JBPHH is standard practice, it is considered part 

of the existing conditions and would not change air pollutant emissions associated with fuel transfers at 

JBPHH. Fugitive emissions of VOC from fuel transfer would occur across various locations at JBPHH over 

a ten to fourteen month period at the same locations used in standard practice, they are not expected to 
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appreciably increase impacts above the status quo. Use of fuels from RHBFSF under this alternative would 

reduce the need to import fuel from overseas during the defueling timeframe, offsetting vessel deliveries to 

JBPHH. 

As part of the stock rotation program, there were four JP-5 shipments from JBPHH to Naval Base Point 

Loma from 2020 through 2022 totaling 12.76 million (M) gallons. Stock rotation of JP-5 from JPBHH is an 

existing practice and any JP-5 relocated from RHBFSF would not increase baseline emissions. 

Overall, the effect to air quality at and in the vicinity of JBPHH from the No Action Alternative would be less 

than significant.

3.5.3.3 Alternative 2: Relocation

As described in Chapter 2, the maximum number of tankers to receive and relocate the flowable fuel from 

RHBFSF is eleven. The number of vessels traveling to each receiving location may vary but are bounded 

by the delivery numbers in Chapter 2. The longer the transit time, the more air pollutants would be emitted 

by vessel engines and boilers, with longer durations for fugitive emissions from the vessel. Therefore, the 

analysis evaluates the maximum emission case and the minimum emission case to provide a range.

The maximum emission case is comprised of the eleven transits with the most emissions. Based on the 

maximum deliveries for each location and their distances, the maximum case for emissions (Table 3.5-4) 

would be: 5 tankers to Port of Singapore; 2 tankers to Port of Darwin; and 4tankers to Subic Bay.

The minimum case is comprised of the eleven transits with the least emissions. The minimum emissions 

case (Table 3.5-5) would be: 5 tankers to Campbell Industrial Park, West Oahu; 2 tankers to Naval Base 

Point Loma; 2 tankers to Selby Terminal; 1 tanker to Port of Vancouver; and 1 tanker to Puget Sound. 

These receiving locations represent the minimum case because their travel distances are shorter than 

foreign locations but they also are subject to the lower sulfur content fuel limit within the North American 

ECA.

Table 3.5-4. Maximum case: Emissions from Tanker Transits Including Hotelling (International 

Receiving Locations)

Destination CO GHGs 

CO2e 

NOX PM10 PM2.5 VOC SOX HAPs No. of 

Trips/ 

Multiplier

JBPHH 11th

Tanker 

Additional 

Emissions

0.39 781 4.68 0.57 0.55 0.33 10.53 0.03 1

Subic Bay, 

Philippines (per 

trip)

5.62 4010 67.32 2.49 2.32 3.37 23.15 0.32 4

Port of 

Singapore (per 

trip)

7.19 5079 86.19 3.16 2.94 4.30 28.77 0.41 5

Darwin, 

Australia (per 

trip)

6.03 4287 72.20 2.68 2.50 3.61 24.81 0.34 2

Total Maximum 

Case Scenario 

(for all trips)

70.9 50792 849.3 31.7 29.5 42.5 296.6 4.0 Total 

trips =11

CO2e= Carbon Dioxide equivalent

Notes: Units = U.S. tons; US EPA 2017 National Emissions Inventory developed HAP fractions for commercial marine vessels 

based on fractions of PM2.5 and VOCs. HAP emissions were estimated with a 0.0213 ratio to PM2.5 and 0.0807 to VOC (BOEM, 

2021); VOCs calculated as Reactive Organic Gases. Individual route trip emissions include JBPHH emissions for that single 

tanker. Because the 11th tanker could reside longer at JBPHH than the others, its emissions were calculated separately.
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Table 3.5-5. Minimum Case: Emissions from Tanker Transits Including Hotelling (U.S. Receiving 

Locations)

Destination CO GHGs

CO2e

NOX PM10 PM2.5 VOC SOX HAPs No. of 

Trips/

Multiplier

JBPHH 11th 

Tanker 

Additional 

Emissions

0.39 781 4.68 0.57 0.55 0.33 10.53 0.03

0.39

Campbell 

Industrial Park, 

West Oahu (per 

trip)

0.2 170.9 2.0 0.2 0.1 0.1 2.2 0.0 5

Point Loma, CA 

(per trip) 2.8 2068.7 33.0 1.3 1.2 1.7 12.7 0.2 2

Selby, CA (per 

trip) 2.6 1942.1 30.8 1.2 1.1 1.6 12.1 0.1 2

Port of 

Vancouver, WA 

(per trip)

2.8 2115.2 33.8 1.3 1.2 1.7 12.8 0.2 1

Puget Sound, 

WA (per trip) 2.99 2222 35.73 1.35 1.26 1.80 13.29 0.17 1

Total Minimum 

Case Scenario 

(for all trips)

17.8 13994.2 211.9 8.9 6.0 10.8 97.4 1.0 Total 

trips = 11

CO2e= Carbon Dioxide equivalent

Notes: Units = U.S. tons; US EPA 2017 National Emissions Inventory developed HAP fractions for commercial marine vessels 

based on fractions of PM2.5 and VOCs. HAP emissions were estimated with a 0.0213 ratio to PM2.5 and 0.0807 to VOC (BOEM, 

2021); VOCs calculated as Reactive Organic Gases. Individual route trip emissions include JBPHH emissions for that single 

tanker. Because the 11th tanker could reside longer at JBPHH than the others, its emissions were calculated separately.

Tankers would be towed by tugboat within Pearl Harbor. Receiving locations in the U.S. and overseas may 

elect to use tugboats for safety reasons. Therefore, emissions from tugboats were included in the 

calculations in Table 3.5-4 and Table 3.5-5 and in local emissions by ports shown Table 3.5-6. Emission 

worksheets are provided in Appendix E.

The total emissions cases are provided for comparison purposes and to illustrate the overall emissions at 

and between JBPHH and receiving locations. Because tankers are mobile sources, emissions would 

generally disperse due to wind while at sea. Tanker emissions during ocean transits would occur over long 

distances where they would be dispersed and unlikely to impact the general public. Conversely, pollutant 

emissions emitted within 3 NM of the receiving area’s coast and hotelling at piers are more likely to affect 

ambient air quality and has greater potential to impact the general public and sensitive populations nearby. 

Where local air quality is already considered to be impaired (e.g., nonattainment or frequent unhealthy air 

days), the addition of emissions has greater potential to cause adverse effects. However, the short (3 days) 

and infrequent (at 5 or less occurrences) would cause minor, transient effects for both criteria pollutants 

and HAPs.

In terms of local effects at JBPHH and receiving locations, Table 3.5-6 provides emissions occurring at 

those locations under the maximum scenario of shipments and compares those total emissions against the 

General Conformity de minimis thresholds as applicable (see Sections 3.5.1.2). It should be noted that the 

emissions provided for each listed receiving location are summed as if all the arrivals (maximum shipments) 

occurred simultaneously. Because tankers would depart at no more than twice a week from Oahu, the 

shipments would occur over the span of several days or weeks depending on the receiving location, where 
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emissions would have time to disperse between shipments and only cause occasional and temporary minor 

impacts on air quality.

Table 3.5-6. Local Emissions Occurring at JBPHH and Receiving Locations

Receiving Location 

and Designation 

Status

CO GHGs 

CO2e 

NOX PM10 PM2.5 VOC SOX HAPs*

JBPHH, Oahu, HI 1.94 2872.50 22.59 2.06 1.92 1.35 34.84 0.11

De Minimis Levels 100 NA 100 100 100 100 100 25

Campbell Industrial 

Park, West Oahu, HI

0.91 854.73 10.01 0.78 0.65 0.48 11.23 0.04

De Minimis Levels 100 NA 100 100 100 100 100 25

Naval Base Point 

Loma, CA

(Severe Non-Attainment 

8-hour Ozone, PM2.5, 

State Non-Attainment 

PM10)

0.21 337 2.40 0.25 0.23 0.15 4.29 0.01

De Minimis Levels 100 NA 25 70 100 25 100 25

Selby Terminal, CA

(Non-Attainment for 8-hr 

Ozone and PM2.5. State 

PM10 Non-Attainment)

0.27 381 3.17 0.28 0.26 0.19 4.59 0.02

De Minimis Levels 100 NA 100 70 100 50 100 25

Port of Vancouver, 

WA

0.24 265 2.90 0.17 0.16 0.16 2.44 0.01

De Minimis Levels 100 NA 100 100 100 100 100 25

Puget Sound, WA 0.31 313 3.75 0.19 0.18 0.20 2.58 0.02

De Minimis Levels 100 NA 100 100 100 100 100 25

US Naval Fueling 

Station Sasebo, 

Japan

0.24 362 2.85 0.28 0.26 0.17 4.61 0.02

De Minimis Levels 100 NA 100 100 100 100 100 25

Subic Bay, 

Philippines

0.56 877 6.61 0.67 0.63 0.41 11.39 0.04

De Minimis Levels 100 NA 40 15 NA 40 40 25

Port of Singapore 0.61 906 7.12 0.69 0.65 0.43 11.54 0.04

De Minimis Levels 100 NA 100 100 100 100 100 25

Port of Darwin, 

Australia

0.20 330 2.28 0.26 0.24 0.15 4.45 0.01

De Minimis Levels 100 NA 100 100 100 100 100 25

Notes: Units in U.S. tons; local emissions are those occurring within 3 NM of affected state or country. Where a country has no 

published de minimis levels, US de minimis levels are shown for comparison purposes. * The National Emission Standards for 

Hazardous Air Pollutants (NESHAP) describes a major source as any with the potential to emit over 25 tons/year of HAPs.
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As shown in Table 3.5-6, the Proposed Action would not exceed de minimis levels at JBPHH or any 

receiving locations. Receiving locations in nonattainment areas (Selby and Point Loma) would not result in 

any exceedances of General Conformity de minimis emissions thresholds; therefore, conformity 

determinations are not required. Naval Base Point Loma is located in a severe nonattainment area for 8-

hour ozone (precursors NOx and VOC) and has the highest potential for adverse impacts; however, only 

up to two shipments would occur there, resulting in minor, temporary impacts. CAA General Conformity 

Applicability Analysis documentation for Selby and Point Loma are provided in Appendix E.

Carbon dioxide emissions contribute to global warming and their total emissions, wherever they occur, can 

contribute to climate change. For context, the high emissions case would emit greenhouse gases to the 

equivalent of the annual operation of 6,429 U.S. homes (using EPA estimate of 7.9 tons/year for an average 

U.S. home). With the social cost of carbon at $51/ton of CO2 emitted, the high and low case would equate 

to $2.59 M and $0.71 M respectively of monetized climate change damages. At the proposed $190/ton, the 

high and low case would be $9.65 M and $2.66 M respectively. In 2020, there were over 14,000 oil and 

chemical tankers worldwide (Equasis, 2020) and over 16,000 observed tanker vessel calls to U.S. ports 

(DOT, 2022). The Proposed Action would include up to eleven tanker deliveries, representing 0.07 percent 

of annual U.S. tanker deliveries. Emissions of greenhouse gases from tanker transits would be unavoidable 

but represent a very small fraction of international shipping emissions worldwide annually.

Overall, this alternative would emit criteria pollutants and hazardous air pollutants that would contribute to 

local air pollution and greenhouse gases that would contribute to global air pollution. The eleven transits 

would comprise a small percentage of annual global tanker ship traffic and the redistribution of fuel from 

RHBFSF would displace shipments that would have likely occurred without the action.

Anticipated air quality impacts from Alternative 2 are not expected to interfere with the attainment of 

NAAQS, hinder a nonattainment area’s progress to attainment, increase the frequency or severity of 

existing poor air quality, or appreciably increase human health risks from HAP exposure in areas where 

sensitive receptors and/or public presence are expected.

3.5.3.4 Alternative 3: Commercial Sale and Relocation

Under Alternative 3, the DLA would enter into sales agreements with commercial entities to receive some 

or all of the flowable fuel. Commercial tankers would arrive at the JBPHH pier to receive the fuel and then 

transport it to a destination of their choice. While it is not possible to reasonably predict where the fuel would 

go, it is reasonable to assume that from an economic standpoint, the commercial purchaser would provide 

the best bid if their shipping costs were considered reasonable and justifiable based on its anticipated 

destination. Assuming this is the case, transport emissions would be likely less than the maximum case 

scenario under Alternative 2.

It is also assumed that the commercial shipper would adhere to IMO regulations and North America ECA 

requirements as applicable to reduce sulfur emissions. Port emissions would likely be accounted for in the 

receiving location’s air quality planning strategies and regulations. As with Alternative 2, the sale of the fuel 

would likely offset the purchase of fuel from other locations, offsetting transits from other locations. Overall, 

the effects to air quality from Alternative 3 would contribute a very small portion to the global emissions 

from tanker ship annual transits.

Anticipated air quality impacts from Alternative 3 are not expected to interfere with the attainment of 

NAAQS, hinder a nonattainment area’s progress to attainment, increase the frequency or severity of 

existing poor air quality, or appreciably increase human health risks from HAP exposure in areas where 

sensitive receptors and/or public presence are expected.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

4-1

4 CUMULATIVE IMPACTS

Cumulative impacts are the result of two or more individual effects that, when considered together, 

compound or increase the overall impact. Cumulative impacts can arise from the individual effects of a 

single action or from the combined effects of past, present and/or future actions. Therefore, cumulative 

impacts can result from individually minor actions that collectively amount to significant actions over time.

Projects proposed, underway, or recently completed at RHBFSF, JBPHH, and other actions related to the 

action alternatives were reviewed during the analysis of cumulative impacts (Table 4-1). Projects at 

potential fuel receiving locations were not considered for the cumulative impact analysis because fuel 

deliveries associated with the Proposed Action would occur in lieu of routine or planned fuel deliveries; 

therefore, effects from tanker transits and fuel unloading at these locations would not contribute to 

cumulative impacts.

Table 4-1. Past, Present, and Future Actions or Trends Relevant to Cumulative Effects

Title Description Implementation

Timeframe

Ongoing Ship Traffic in 

Pearl Harbor

Pearl Harbor is one of the Navy’s busiest ports, completing about 65,000 

boat runs and transporting 2.4 million passengers each year. Tour boats 

manned by Navy personnel transport more than two million visitors to the 

U.S.S. Arizona Memorial each year. There are typically about 2,000 

annual naval vessel and submarine movements (i.e., one-way trips) in the

harbor to support JBPHH missions.

JBPHH continued to receive regular fuel deliveries by tanker ship to 

resupply the UTF after operations at RHBFSF ceased in late 2021. In the 

future, deliveries of fuel to JBPHH by tanker ship have the potential to

decrease if there is an increase in the amount of fuel delivered by tanker 

ship to the Campbell Industrial Park, West Oahu storage facility then 

transferred to JBPHH by commercial pipeline.

Ongoing

Red Hill Shaft 

Recovery and 

Monitoring

In response to contamination of drinking water supplies, the Navy installed 

a hybrid zeolite-granular activated carbon treatment system near the Red 

Hill Shaft, which is pumping approximately 5,000,000 gallons of water a 

day through the treatment system and then discharging the treated water 

into Halawa stream. The Navy samples water quality before and after 

treatment to evaluate the effectiveness of the treatment system and to 

ensure that water discharged into Halawa stream meets water quality 

standards (EPA, 2023e). Recovery and monitoring efforts also include 

expansion of the groundwater monitoring well network at RHBFSF and 

Red Hill Shaft. The Navy is using data collected from the monitoring wells 

to identify and track possible contamination migration and evaluate 

effectiveness of remediation.

January 2022-

December 2025 

(Navy, DOH, & 

EPA, 2022)

RHBFSF Soil 

Contamination 

Remediation

The Navy remediated areas near the Adit 3 exterior entrance to RHBFSF 

that were contaminated during the November 2021 fuel release. The Navy 

conducted a site assessment and soil borings in January and April 2022, 

followed by excavations of soil and a leach tank in May 2022 with

confirmation sampling. Based on results of sampling, the Navy completed 

a second round of excavations in September-October 2022. The Navy 

submitted a closure report recommending no further action to regulators 

for review in February 2023.

April 2022-February 

2023

RHBFSF Oily Waste 

Disposal Facility Risk 

Evaluation and 

Response Actions

The Navy is conducting a site investigation, environmental risk evaluation, 

and response actions required to close and remediate the former oily 

waste disposal facility at RHBFSF.

July 2016-August 

2024

RHBFSF Line 

Unpacking

JTF-RH completed a fuel line unpacking operation that removed an 

estimated 1,058,187 gallons of fuel from the pipelines connecting the 

RHBFSF with fuel points on JBPHH. Fuel was removed using gravity flow 

and pumps for fuel transfer from low points. The fuel removed from the 

pipelines remained on JBPHH for operational use.

October-November 

2022
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4-2

Title Description Implementation

Timeframe

RHBFSF Repairs JTF-RH completed 253 repairs to RHBFSF, the UGPH, and the fuel 

pipelines that will be used for defueling. Repairs include but are not 

limited to: replacing and repairing pipe components, valves, fittings and 

seals; inspecting and repairing dents in pipes; adding or repairing pipe 

supports and braces; and replacing deficient pressure gauges. A third 

party is completing validatation on the quality of the completed repairs. 

December 2022-

August 2023; 

Repairs completed

and validated prior 

to defueling

Fueling Pier Repairs The Navy is conducting structural repairs at the fueling pier that includes 

repairing piles by cleaning and repairing rebar and installing fiberglass 

jackets with cathodic protection. Repairs also include cleaning and 

repairing spalls at pile caps, beams, underdeck and deck. 

Riser valve replacement project will replace fuel riser valve components 

and platform and apply a corrosion protective coating to the new riser 

valves.

Structural Repairs: 

March 2020-

January 2024

Riser Valves: 2024

Red Hill Water 

Treatment Facility

The Navy would construct a new drinking water treatment facility for 

removing potential contaminants at the Red Hill water supply shaft and 

ensure that treated water continues to meet all Federal and State drinking 

water standards. The water treatment facility would be constructed on 

existing Navy property near the Red Hill water supply shaft. Granular 

activated carbon treatment would continue to be used for the treatment of 

the potential contaminants that may impact the Red Hill water supply.

June 2024-June 

2027

RHBFSF Closure The Navy will permanently close the RHBFSF underground storage tanks, 

four surge tanks, and associated valves and piping systems at the 

RHBFSF, following the Hawaii underground storage tank regulations, 

Chapter 11-280.1 of the Hawaii Administrative Rules (HAR). The Navy 

has submitted a Tank Closure Plan to EPA and DOH (Navy, 2022b). 

Closure will also include management of sludge and waste material and 

site assessment. The Navy has currently proposed closing the tanks in 

place with the option for beneficial reuse (ensuring no storage of

hazardous materials).

January 2024-

September 2027

RHBFSF Beneficial 

Reuse

The Navy is evaluating options for beneficial non-fuel reuse of the 

RHBFSF tanks using an inclusive, science-based approach that will 

collect ideas from interested parties. Studies collecting ideas from various 

community, academic, and political stakeholders are ongoing. The Navy 

will closely coordinate with DOH and EPA on the final proposed beneficial 

non-fuel reuse of the facility.

Beneficial non-fuel 

reuse plans would 

be implemented 

after Tank Closure 

Operations 

conclude in 

September 2027

Pearl Harbor Sediment 

Site 

The site is part of the Pearl Harbor Naval Complex National Priorities List, 

which identifies priorities among known releases or threatened releases of 

hazardous substances, pollutants, or contaminants throughout the United 

States and its territories. The Pearl Harbor Sediment Site comprises six 

remediation areas of the harbor, identified as Decision Units (Navy, 2018). 

Selected remedies for the Pearl Harbor Sediment Site include the 

following: 

Dredging of sediments containing high contaminant of concern (COC) 

concentrations.

Enhancing the rate of natural recovery of sediments with moderate COC 

concentrations by incorporating a clean sand cap.

Monitoring natural recovery of sediment with low COC concentrations.

Limiting the bioavailability of COCs within the sediment through the use of 

activated carbon during the natural recovery period.

Projected 

completion 2026-

2028
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

4-3

Title Description Implementation

Timeframe

Hotel Pier Release 

and Response

In March 2020, the Navy observed a slow discharge of petroleum into 

Halawa Stream and Pearl Harbor from a wharf located at a petroleum 

pipeline manifold area near Hotel Pier at JBPHH. 

In September 2020, the Navy excavated an area between the pipeline 

manifold and the discharge location into Pearl Harbor to determine the 

source of the leak. Additional investigations conducted in December 2020 

determined the leak to be un-weathered JP-5 fuel presumably originating 

from a leaking underground fuel pipeline at the manifold area located at 

the mouth of Halawa Stream where Halawa Stream enters Pearl Harbor.

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 (Navy, 2021). 

The fuel pipelines and infrastructure that will be used for the Proposed 

Action are not involved in the Hotel Pier Release. This release is subject 

to separate environmental compliance actions which can be reviewed at 

https://health.hawaii.gov/ust/documents-related-to-hotel-pier/.

March 2020-Present

Pearl Harbor Naval 

Shipyard (PHNSY) Dry 

Dock 5 Construction

The Navy will construct and operate a graving dry dock sized to 

accommodate current and future class fast-attack submarines at Pearl 

Harbor Naval Shipyard, including auxiliary facilities and utilities. 

Construction activities will include dredging, fill, pile driving, installation of 

new temporary and permanent in‐water structures, demolition of existing 

landside structures, and construction of new temporary and permanent 

landside facilities.

Marine traffic in Pearl Harbor from construction-related vessels will 

increase, including longer transit times to allow safe navigation around 

construction equipment, moored barges, and materials vessels.

April 2023-Janaury 

2028

JBPHH Wastewater 

Treatment Plant 

Upgrade 

The Navy plans to upgrade the wastewater treatment plant at JBPHH. The 

new plant will operate in full compliance with all applicable laws and 

regulations related to the discharge of treated wastewater into the ocean. 

In addition, the Navy will develop a plan to prevent and respond to 

potential infrastructure failures at the plant, should they occur. 

Complete by Winter 

2025-2026 

4.1 CUMULATIVE EFFECTS ANALYSIS

Public Health and Safety

Actions described in Table 4-1 could increase vessel traffic and demand for emergency services at JBPHH,

resulting in additive adverse effects to maritime safety, such as vessel collisions, if they occur at the same 

time as the Proposed Action. Timelines for both the Proposed Action and future actions are dependent on 

many factors; based on current information available, it was assumed that there may be some temporal 

overlap of the Proposed Action with PHNSY Dry Dock 5 Construction, Pearl Harbor Sediment Site dredging, 

and Fueling Pier Repairs. BMPs including vessel communication with the Harbormaster and use of safety 

plans would also be used during these actions so that there would be no significant increase in human 

health risk to JBPHH workers, residents, or members of the general public.

Vibration from pile driving has the potential to damage structures if vibration amplitudes are sufficiently 

large. However, structure damage is generally limited to structures in close proximity of the driven pile, 

typically within a pile length (Caltrans, 2013). Geotechnical engineering and vibration analyses for the pile 

driving activities associated with the PHNSY Dry Dock 5 Construction project indicate that damage to 

structures from vibration would be limited to an approximately 200-foot threshold from the pile driving 

activity. The fueling pier and associated infrastructure that would be used for the Proposed Action are 

located more than one mile (5,280 ft.) from the pile driving sites; therefore, safety impacts related damage 

of the fueling pier and infrastructure from pile-driving vibration would not occur.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Cumulative impacts to drinking water quality from present and future actions involving soil and groundwater 

clean-up, recovery, remediation, and monitoring at RHBFSF are discussed in Section 4.1.2.

Water Resources

Actions described in Table 4-1 involving soil and groundwater clean-up, recovery, remediation, and 

monitoring at RHBFSF would cumulatively result in improved quality of groundwater and drinking water 

supplies on Oahu. Similarly, remediation and infrastructure improvement efforts at JBPHH, including the 

ongoing work at the Pearl Harbor Sediment Site, Hotel Pier Release and Response efforts, and the JBPHH 

Wastewater Treatment Plant Upgrade, would result in improved marine water quality in Pearl Harbor. 

Cumulative impacts from the increased vessel traffic and use of in-water construction equipment in Pearl 

Harbor for the PHNSY Dry Dock 5 Construction project could result in additive effects to marine waters. 

There are typically about 2,000 annual naval vessel and submarine movements (i.e., one-way trips) in the 

harbor. These vessels can create turbulence in the water column and marine bottom environment from 

propeller wash, leading to resuspension of sediments that temporarily increase turbidity. High levels of 

vessel traffic concentrated in time can prolong turbidity in the short-term. High levels of vessel traffic can 

result in a commensurate increase potential for inadvertent spills to the harbor. BMPs to reduce the potential 

for spills identified for the Proposed Action, including use of oil-absorbent booms, fueling procedures, and 

vessel communication with the Harbormaster, would also be used during these actions to reduce 

cumulative effects to less than significant.

Marine Biological Resources

Cumulative impacts from current and future actions involving dredging, in-water construction, and increased 

vessel traffic in Pearl Harbor could result in additive effects to protected species present in Pearl Harbor if 

the actions have similar stressors to protected species as those identified by the Proposed Action, including 

vessel noise, vessel collision, and fuel spills. There are typically about 2,000 annual naval vessel and 

submarine movements (i.e., one-way trips) in the harbor. Navy vessels transiting in Pearl Harbor use strict 

BMPs to avoid collisions with protected species and prevention of oil spills. Similarly, the PHNSY Dry Dock 

5 Construction Project has developed BMPs, conservation measures, and mitigations in consultation with 

NMFS to avoid, reduce, and mitigate impacts to protected species during dredging and in-water 

construction. The Proposed Action is a one-time action, and would not continue to increase vessel 

movements in Pearl Harbor following completion of defueling of RHBFSF. The Proposed Action would not 

significantly contribute to the cumulative effects.

Hazardous Materials and Waste

Dredging, in-water construction, and increased vessel traffic in Pearl Harbor from the PHNSY Dry Dock 5 

Construction project could result in additive effects from resuspension of contaminated sediments. There 

are typically about 2,000 annual naval vessel and submarine movements in the harbor. The Proposed 

Action is a one-time action, and would not continue to increase vessel movements in Pearl Harbor following 

completion of defueling of RHBFSF. Therefore, the resuspension of contaminated sediments from vessel 

transits associated with the Proposed Action would not significantly contribute to the cumulative effects. 

Dredging of marine sediments associated with the Pearl Harbor Sediment Site would reduce potential 

impacts from resuspension of contaminated sediments by removing contaminants in the Southeast Loch. 

This would result in an overall benefit to environmental and human health by removing and disposing 

contaminated sediments.

Air Quality and Greenhouse Gases

Current and future construction projects and increased vessel traffic in Pearl Harbor could result in additive 

effects to air quality if actions overlap in time and occur within close proximity to the Proposed Action. There 

are typically about 2,000 annual naval vessel and submarine movements in the harbor. The Proposed 

Action is a one-time action, and would not continue to increase vessel movements in Pearl Harbor following 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

4-5

completion of defueling of RHBFSF. Therefore, emissions from vessel transits associated with the 

Proposed Action would not significantly contribute to the cumulative effects.

The PHNSY Dry Dock 5 Construction project, which may overlap in time with the Proposed Action, is 

located approximately 1.3 miles from the JBPHH fueling pier. This project will implement multiple BMPs to 

avoid and reduce impacts from fugitive dust, vehicle emissions, on-site construction activities, and power 

requirements (Navy, 2022a).
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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5 SUMMARY AND CONCLUSIONS ON THE IMPACTS OF THE 

PROPOSED ACTION AND ALTERNATIVES

Based on the analysis of environmental impacts of the Proposed Action and the No Action Alternative, this 

EA/OEA concludes that no significant adverse environmental impacts are expected as a result of the 

Proposed Action. Table 5-1 summarizes the potential impacts that could result from the alternatives 

evaluated.

Table 5-1. Comparison of Alternatives

Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

Public Health and 

Safety

There may be a small 

increase in vessel traffic in 

Pearl Harbor if JP-5 stock 

rotation was required due to 

low demand for JP-5 fuel at 

JBPHH. This would result in 

a negligible increase in 

vessel traffic. The No Action 

Alternative would have no 

significant adverse effects on 

public health and safety.

A minimal increase of 

demand for emergency 

services may result from the 

addition of approximately ten

workers per shift during the 

defueling and tanker ship 

loading operations.

The additional tanker ships 

entering Pearl Harbor would

account for an approximate 

ten percent increase in 

vessel traffic during the 

defueling operation. 

Overall, with the use of BMPs 

and adherence to 

procedures, Alternative 2 

would have less than 

significant adverse effects to 

public health and safety.

Effects would be the same as 

Alternative 2.

Water Resources Defueling would occur over a 

longer period of time than 

Alternative 2, which could 

pose additional threat to 

groundwater and drinking 

water sources should 

releases from RHBFSF 

occur. Completed repairs to 

RHBFSF and use of BMPs 

for fuel transfers would 

reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 1 would have less 

than significant effects to 

water resources.

Defueling RHBFSF 

expeditiously would reduce 

potential for system releases

that could further adversely 

affect local groundwater and 

drinking water supplies. 

Relocation of fuel via tanker 

may marginally increase 

potential for spills affecting 

marine waters on Oahu, 

international waters, and 

receiving location water 

bodies. Statistically, 

occurrences of catastrophic 

spills from oil tankers are low 

(0.0005 percent spill rate). 

Propeller wash from vessels 

at ports could cause shortterm suspension of 

sediments, causing localized 

turbidity that would settle 

within days. Completed 

repairs to RHBFSF and use 

of BMPs for fuel transfers 

would reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 3 would have less 

than significant effects to 

water resources.

Effects would be similar to 

those under Alternative 2. 

Defueling RHBFSF via 

commercial sale would occur 

over a similar expeditious 

timeframe as Alternative 2, 

reducing potential for 

releases that could adversely 

affect local groundwater and 

drinking water supplies. 

Commercially-operated 

tanker ships would adhere to 

international maritime safety 

and environmental 

regulations that reduce 

potential for catastrophic 

spills at ports and at sea. 

Propeller wash from vessels 

at ports could cause shortterm suspension of 

sediments, causing localized

turbidity that would settle 

within days. Completed 

repairs to RHBFSF and use 

of BMPs for fuel transfers 

would reduce the risk of spills 

during the defueling 

operation. Overall, 

Alternative 3 would have less 

than significant effects to 

water resources.
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Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

Marine Biological 

Resources

The amount of fuel 

transferred to tanker ships for 

overseas deliveries would 

likely be substantially less 

than under Alternatives 2 and 

3. 

Tanker ships would use low 

speeds and BMPs to reduce 

the potential for vessel 

collisions with marine species

and fuel spills. Alternative 1 

would have less than 

significant effects to marine 

biological resources.

The likelihood of a vessel 

collision with a protected 

marine species is extremely 

remote because of the low 

probability that individual 

animals of an ESA-listed 

species would overlap in 

space and time with the 

eleven one-way tanker 

transits. Additionally, the 

relatively slow speed of the 

vessels further reduces the 

chance of ship strike with 

marine mammals, sea turtles, 

and fishes. A tanker spill 

during transit has a low 

probability of occurrence, and 

the response teams and 

BMPs available at all ports.

Overall, with the use of 

BMPs, Alternative 2 would 

have less than significant 

effects to marine biological 

resources. 

Under Alternative 3, impacts 

to marine biological 

resources would be similar to 

those described for 

Alternative 2. The transit 

route and destination of sold 

fuel is at the discretion of the 

non-federal entity purchaser 

and not a federal action. 

Similar to Alternative 2, the 

temporary and slow-moving 

presence of the maximum of 

eleven tanker ships would 

reduce the risk of impacts to 

marine biological species 

from vessel noise or collision. 

With the use of BMPs, 

Alternative 3 would result in a 

less than significant effects to 

marine biological resources.

Hazardous 

Materials and 

Waste

Inadvertent fuel releases that 

could be associated with 

Alternative 1 would mostly 

consist of small spills at 

points of consumption where 

fuel is transferred or 

dispensed. JBPHH has spill 

response procedures to 

address potential spills and 

to limit their effects to human 

health and the environment. 

Spilled fuel and contaminated 

absorbents or debris would 

be managed in accordance 

with the waste management 

plan.

With the use of BMPs, 

Alternative 1 would result in a 

less than significant increase 

to the potential for human or 

environmental exposure to 

hazardous materials or 

waste.

Inadvertent fuel releases 

during fuel loading and 

unloading processes would 

mostly consist of small 

amounts of fuel escaping 

from the flexible hose and 

flexible hose connection 

points on the fueling pier and 

tanker ship. JBPHH has spill 

response procedures to 

address potential spills and 

to limit their effects to human 

health and the environment. 

Spilled fuel and contaminated 

absorbents or debris would 

be managed in accordance 

with the waste management 

plan. With the use of BMPs, 

Alternative 2 would result in a 

less than significant increase 

to the potential for human or 

environmental exposure to 

hazardous materials or 

waste.

Effects would be the same as 

Alternative 2.

Air Quality and 

Greenhouse 

Gases

Emissions from fuel storage 

and transfers would reflect 

the status quo and baseline 

levels, as deliveries would 

occur through existing 

processes on JBPHH. Effects 

on air quality would be less 

than significant.

Relocation of fuel via tanker 

ships would emit criteria 

pollutants, hazardous air 

pollutants (HAPs), and 

greenhouse gases from the 

combustion of fuel by tanker 

ships and tugboats. 

Anticipated air quality 

impacts from Alternative 2 

are not expected to interfere 

with the attainment of 

NAAQS, hinder a 

nonattainment area’s 

While the ultimate 

destinations under 

commercial sales is not 

known, from an economic 

standpoint, the purchaser 

would likely transport fuel the 

shortest distance practicable. 

Under this assumption, the 

transport emissions would 

likely be less than the 

maximum case under 

Alternative 2. Anticipated air 

quality impacts from 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

5-3

Resource Area Alternative 1: No Action 

Alternative

Alternative 2: Relocation Alternative 3: Commercial 

Sale and Relocation

progress to attainment, 

increase the frequency or 

severity of existing poor air 

quality, or appreciably 

increase human health risks 

from HAP exposure in areas 

where sensitive receptors 

and/or public presence are 

expected. Records of NonApplicability for the General 

Conformity Rule for 

nonattainment areas in 

California (Point Loma and 

Selby) found pollutants would 

be well below de minimis 

levels. Emission of 

greenhouse gases would be 

short-term and a small 

fraction of those generated 

by international shipping 

activities.

Alternative 3 are not 

expected to interfere with the 

attainment of NAAQS, hinder 

a nonattainment area’s 

progress to attainment, 

increase the frequency or 

severity of existing poor air 

quality, or appreciably 

increase human health risks 

from HAP exposure in areas 

where sensitive receptors 

and/or public presence are 

expected.

The analysis provided in Section 3 of the EA/OEA describes how, in accordance with NEPA, the Proposed 

Action would not result in significant impacts to the physical or biological environment. In accordance with 

E.O. 12114, the Proposed Action would not cause significant harm to the human or biological environment 

in ocean waters beyond the territorial limits of the U.S.

5.1 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES

Resources that are irreversibly or irretrievably committed to an action are those that are used on a longterm or permanent basis. This includes the use of non-renewable resources such as metal and fuel, and 

natural or cultural resources. These resources are irretrievable in that they would be used for this action

when they could have been used for other purposes. Human labor is also considered an irretrievable 

resource. Another impact that falls under this category is the unavoidable destruction of natural resources 

that could limit the range of potential uses of that particular environment.

Under the action alternatives, flowable fuel from RHBFSF would be relocated for use at other defense fuel 

supply points. The method of relocation (tanker ship movements) would consume fuel irretrievably. 

Because these shipments would displace other routine or planned deliveries to these destinations, the net 

effect compared to the status quo in terms of transit fuel and labor would be negligible. 

Gravity-based defueling of RHBFSF itself would commit labor and resources irretrievably. The action would 

be a first step towards closure of the RHBFSF which would alter the way DoD fuel is stored and disbursed 

at JBPHH and the Pacific region. However, the decision to close RHBFSF has already been made through 

the order issued on March 7, 2022 by U.S. Secretary of Defense, Lloyd J. Austin III (SECDEF Memo, 2022). 

The gravity-based defueling under the Proposed Action is a result of the closure decision.

5.2 UNAVOIDABLE ADVERSE IMPACTS

The action alternatives would unavoidably result in emissions of air pollutants and greenhouse gases 

associated with tanker ship transits to other defense fuel supply points. These emissions would occur 

temporarily and would not impair overall air quality. 

Similarly, vessel movements may cause localized turbidity in marine waters in shallower waters but these 

effects would be short-term and less than significant. 

The transfer and movement of fuel via tanker ships may result in fuel spills to marine waters, but statistically 

such spills are rare (see Section 3.2.2.5). Many causes of spills are largely avoidable through proper 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

5-4

training, through routine inspection and maintenance of equipment and vessels, by following spill prevention 

procedures, and abiding by appropriate and vigilant navigation procedures. Some tanker ship spills could

be considered unavoidable, such as those occurring due to unforeseen rapid weather changes, human 

error, or unexpected equipment failures or fires/explosions. However, adverse impacts from fuel spills, 

should they occur, could range from minor to significant depending on the amount spilled, its location and 

proximity to humans and marine species.

5.3 RELATIONSHIP BETWEEN SHORT-TERM USE OF THE ENVIRONMENT 

AND LONG-TERM PRODUCTIVITY

The Proposed Action would be one of the first steps towards closing and remediating the RHBFSF. The 

short-term action of defueling RHBFSF and relocating fuel would provide long-term benefits to water quality 

and avoidance of potentially harmful health effects to residents receiving potable water from the vicinity. 

The Proposed Action would provide long-term protection of the Waimalu and Moanalua aquifers.

5.4 CONSISTENCY WITH FEDERAL POLICIES AND EXECUTIVE ORDERS

The Proposed Action is consistent with various federal policies and Executive Orders, including but not 

limited to: the National Environmental Policy Act; National Historic Preservation Act; Clean Water Act; Clean 

Air Act; Endangered Species Act; Migratory Bird Treaty Act; Sikes Act; EO 11988 – Floodplain Management 

EO 11990 – Protection of Wetlands; EO 12898 – Environmental Justice in Minority Populations and LowIncome Populations; EO 13045 – Protection of Children from Environmental Health Risks and Safety Risks; 

EO 13186 – Protection of Migratory Birds, and EO 14057 - Federal Sustainability Plan. 

Among those that may be particularly relevant to this EA/OEA are the following:

Federal Policies

5.4.1.1 Endangered Species Act

The purpose of the ESA of 1973 is to conserve and protect ecosystems upon which threatened and 

endangered species depend and to conserve and recover listed species. Section 7 of the ESA requires 

action proponents to consult with the USFWS and/or NMFS to ensure that their actions are not likely to 

jeopardize the continued existence of federally listed threatened and endangered species, or result in the 

destruction or adverse modification of designated critical habitat.

JTF-RH and DLA completed informal consultation with the National Marine Fisheries Service (NMFS)

pursuant to Section 7(a)(2) of the ESA for the Proposed Action. JTF-RH and DLA determined that the 

Proposed Action would have no effect on ESA-listed species or designated critical habitat under regulation 

of USFWS.

5.4.1.2 Coastal Zone Management Act

The CZMA of 1972, as amended (16 USC 1451 et seq.), is administered by the State of Hawaii Office of 

Planning and Sustainable Development. The CZMA program objectives and policies are to provide coastal 

recreational opportunities; preserve and protect historic, scenic and coastal ecosystem resources; provide 

economic uses; reduce coastal hazards; improve public awareness in coastal zone management; and 

manage development within the coastal zone.

The CZMA requires federal agencies to conduct their planning, management, development, and regulatory 

activities in a manner consistent with the State’s CZMA program. The Proposed Action would have 

insignificant direct or indirect coastal effects. Correspondence indicating the project elements within the de 

minimis list under the CZMA is included in Appendix C.
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Executive Orders

5.4.2.1 Executive Order 12114 – Environmental Effects Abroad of Major Federal Actions

EO 12114 (44 FR 1957), Environmental Effects Abroad of Major Federal Actions, directs federal agencies 

to be informed of and take account of environmental considerations when making decisions regarding major 

federal actions outside the United States, its territories, and possessions. The EO requires environmental 

consideration of actions with the potential to significantly harm the global commons, which are the 

geographic areas outside the jurisdiction of any nation, including the oceans beyond the territorial sea, 

which the United States defines as 12 NM. The purpose of EO 12114 is for agency decision makers to be 

informed of pertinent environmental considerations and to take environmental considerations into account,

with other pertinent considerations of national policy, in making decisions.

In accordance with EO 12114 and the DoD’s implementing regulations in 32 CFR Part 187, this EA/OEA 

evaluates the potential for significant environmental harm from the Proposed Action in ocean waters beyond 

the territorial limits of the United States. As described in Section 3, the Proposed Action and alternatives 

would not pose a significant harm abroad.

5.4.2.2 Executive Order 13045 – Protection of Children from Environmental Health Risks 

and Safety Risks

EO 13045 requires federal agencies to “make it a high priority to identify and assess environmental health 

and safety risks that may disproportionately affect children and shall ensure that its policies, programs, 

activities, and standards address disproportionate risks to children that result from environmental health 

risks or safety risks.” As analyzed in Section 3.1, the Proposed Action would have no disproportionate 

health or safety risks to children.
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6 CONSULTATION AND COORDINATION

6.1 LIST OF AGENCIES CONSULTED

Ronald Salz, Ph.D.

National Marine Fisheries Service 

Office of Protected Resources Headquarters 

1315 East-West Highway 

Silver Spring, Maryland 20910

6.2 LIST OF AGENCIES NOTIFIED

Ms. Debra Mendes

Hawaii Coastal Zone Management Program

State of Hawaii Office of Planning and Sustainable Development

235 South Beretania Street, 6th Floor

Honolulu, Hawaii 96813
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7 LIST OF PREPARERS AND REVIEWERS

PREPARERS

Jill Sears, CSP, CHMM, Supervisory Physical Scientist, Environmental Planning, NAVFAC Pacific

Dorothy Peterson, P.E., Former Environmental Planning Team Lead, NAVFAC Headquarters

Brittany Bartlett, Natural Resources Management Specialist, Marine Resources, NAVFAC Pacific

Michele Bejder, Ph.D., Supervisory Natural Resources Management Specialist, Marine Resources, 

NAVFAC Pacific

Darrel Frame, P.E., CAPT, CEC, USN, NAVFAC Pacific

Mathew Hamilton, GIS Specialist, NAVFAC Northwest

Jonathan Crain, Community Planner/GIS Specialist, NAVFAC Northwest

Peter C. Len, P.E., GISP, Asset Utilization Product Line Coordinator, NAVFAC Hawaii

REVIEWERS

Elizabeth Scheimer, Natural Resources Management Specialist, Environmental Planning, NAVFAC Pacific

Ian Bordenave, Biologist, Environmental Planning, NAVFAC Pacific

Travis Hylton, P.E., BCEE, D.WRE, Environmental Director, NAVFAC Pacific

J. Carter Watterson, Senior Natural Resources Specialist, NAVFAC Headquarters

Noor M. James, LTC, LG, USA, JTF-RH J3/5

Stacey Christenbury, Supervisory Environmental Protection Specialist, DLA Energy

Bruce Blank, Deputy Commander, DLA Indo-Pacific

William M. Jakubowicz, CDR, SC, USN, Commander, DLA Energy East Pacific

Meagan Ostrem, Operations/NEPA Manager, Navy Region Hawaii

William Manley, Environmental Coordinator, Navy Region Hawaii
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https://www.stripes.com/news/pollution-from-china-spawns-unhealthy-haze-at-sasebo1.migrated.

Troeschel A.N., B. Gerhardstein, A. Poniatowski, et al. (2022). Notes from the Field: Self-Reported Health 

Symptoms Following Petroleum Contamination of a Drinking Water System — Oahu, Hawaii, 

November 2021–February 2022. MMWR Morb Mortal Wkly Rep 2022;71:718–719. Retrieved 

from https://www.cdc.gov/mmwr/volumes/71/wr/mm7121a4.htm?s_cid=mm7121a4_w.

USCG (United States Coast Guard). (2001). Title 33, Chapter I, Subchapter O, Part 157, Rules for the 

Protection of the Marine Environment Relating to Tank Vessels Carrying Oil in Bulk. Effective 

December 3, 2001. Retrieved from https://www.ecfr.gov/current/title-33/chapter-I/subchapterO/part-157.

USGS (United States Geological Survey). (2016). Groundwater in Hawaii. Accessed on April 21, 2023. 

Retrieved from https://dlnr.hawaii.gov/mk/files/2016/11/B.17w-USGS-Ground-Water-inHawaii.pdf.

USGS. (2023). Tesoro Hawaii Single Point Mooring Hose Fuel Oil Spill, Case Description. Accessed on 

April 12, 2023. Retrieved from https://www.cerc.usgs.gov/orda_docs/CaseDetails?ID=911.

VA (U.S. Department of Veteran Affairs). (2023). Fuels (Petroleum, Oils, Lubricants). Accessed on April 

18, 2023. Retrieved from 

https://www.publichealth.va.gov/exposures/fuels/index.asp#:~:text=Symptoms%20of%20exposur

e%20to%20fuels,convulsions%2C%20coma%20and%20even%20death.

Van Waerebeek, K. O. E. N., A. N. Baker, F. Félix, J. Gedamke, M. Iñiguez, G. P. Sanino, G. P. and Y. 

Wang Y. (2007). Vessel collisions with small cetaceans worldwide and with large whales in the 

Southern Hemisphere, an initial assessment. Latin American Journal of Aquatic Mammals, 43-69.

Visser, I. N., and D. Fertl. (2000). Stranding, re-sighting, and boat strike of a killer whale (Orcinus orca). 

Aquatic Mammals, 26, 232-240.

Washington State. (2023). Washington State Geospatial Open Data Portal. Water Listings. Accessed on 

April 12, 2023. Retrieved from https://geo.wa.gov/datasets/waecy::waterlistings/explore?location=47.556159%2C-122.514172%2C13.37.
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Watkins, W. A., Daher, M. A., Dimarzio, N. A., Samuels, A., Wartzok, D., Fristrup, K. M., & Spradlin, T. R. 

(1999). Sperm whale surface activity from tracking by radio and satellite tags 1. Marine Mammal 

Science, 15(4), pp. 1158-1180.

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in the Moanalua/Red Hill/Halawa Region: Evaluating Rates, Directions, and Contamination 

Risks,” Mr. Robert Whittier and Dr. Donald Thomas. March 18. Accessed on April 13, 2023. 

Retrieved from https://www.wrrc.hawaii.edu/groundwater-flow-in-the-moanalua-red-hill-halawa-.
A-1

APPENDIX A – PUBLIC COMMENTS AND 

RESPONSES
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-2

APPENDIX A

PUBLIC COMMENTS AND RESPONSES

This appendix includes a description of the public comments received on the Draft Environmental 

Assessment/Overseas Environmental Assessment (DEA/DOEA) during the public comment period. A total 

of ten submittals ranging from brief statements to lengthy letters were received. No form letters were 

received. Submittals were received from:

• Hawaii State Senator Kurt Fevella

• Office of Hawaiian Affairs

• Two organizations, including Sierra Club of Hawaii and Earthjustice

• Four individuals from the general public

• Two anonymous individuals

Each submittal was reviewed, and the individual comments (i.e., the substantive portion of the text in the 

submittal that addresses a single subject) were extracted. A substantive comment is one that provides new 

information about the Proposed Action, an alternative, or the analysis; identifies a different way to meet the 

need; points out a specific flaw in the analysis; suggests alternate methodologies and the reasons why they 

should be used; makes factual corrections; or identifies a different source of credible research that, if used 

in the analysis, could result in different effects. From the ten submittals, 29 discrete comments were 

extracted. Each comment was assigned an identification number then coded by topic. Comments were 

received on the following topics:

• Scope of the EA/OEA – 1 comment

• Public participation – 4 comments

• Screening criteria – 1 comment

• Alternatives – 9 comments

• Best Management Practices – 5 comments

• Cultural resources – 2 comments

• Environmental justice – 1 comment

• Water resources – 1 comment

• Hazardous materials and waste – 1 comment

• Air quality and greenhouse gases – 2 comments

• Cumulative impacts – 2 comments

Table A-1 presents the 29 public comments and responses by topic. If changes or updates were included 

in the Final EA/OEA as a result of a comment this is noted in the response. Comments have been edited 

for spelling, grammar, and added context as necessary for clarity.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Table A-1: Public Comments and Responses by Topic

Topic ID# Commenter Comment* Response

Scope of the 

EA/OEA

06 Meredith 

Wilson

If Joint Task Force Red Hill (JTF-RH) considers the job of 

defueling not done “until the last drop” and that includes the 

sludge and fuel within the low points of facility, why are they not 

included in the scope of this Environmental Assessment?

This EA/OEA does not analyze emptying the 

residual fuel from RHBFSF tanks and pipelines 

since this is mandated in the Hawaii Department 

of Health (DOH) Emergency Orders, 2021 and 

2022, and therefore is nondiscretionary. The U.S. 

Department of Defense (DoD) will undertake 

several stages of actions to fully close and 

remediate the Red Hill Bulk Fuel Storage Facility 

(RHBFSF). Follow-on actions beyond the scope 

of this EA/OEA, including removal of the residual 

fuel in the RHBFSF tanks and pipelines, are also 

necessary but are predicated on the successful 

gravity defueling action occurring first. DoD is 

actively evaluating follow-on actions which will be 

subject to additional future environmental 

compliance actions as applicable.

Public 

Participation

23 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

OHA observes that the comment period for the Draft EA (DEA) is 

set at 21 calendar days. Pursuant to 45 CFR 900.303, NEPA 

environmental assessment documents must be available for 

public comment for not less than 15 calendar days. While 

technically the JTH-RH is in compliance with the regulation, OHA 

suggests that going forward a 30-day public comment period be 

the absolute minimum given the length of these documents, 

technical details and the heightened level of public interest in Red 

Hill related defueling and remediation actions [emphasis added]. 

Indeed, 45 CR 900.303(c) does allow for a longer period of public 

comment by the project's "Approving Official". Arguably, an 

additional 9 calendar days for public comment would not have 

been detrimental to the overall project timeline. This would further 

provide parity with the State of Hawai'i's own HRS 343 process 

as 30-days is the minimum standard for DEA comment periods.

Comment acknowledged. It is important to note 

that JTF-RH and DLA did not receive any 

requests for extension of the Draft EA/OEA public 

comment period.

Public 

Participation

24 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

As was the case with the current effort, OHA further supports at 

least two public meetings as part of the release of NEPA 

documents for later RHBFSF closure and remediation actions as 

we anticipate those dialogues to be much more interactive and 

public-focused. Notes or summaries of each meeting should then 

be posted onto the Defueling Dashboard. In an effort to assist the 

JTF-RH with outreach efforts to the Hawaiian community, OHA 

would also appreciate advance notice of public comment periods 

and meetings so that we may jointly disseminate the information 

via our social media outlets and monthly newspaper, Ka Wai Ola, 

in a manner that allows for the full comment period to be realized.

Comment acknowledged. This recommendation 

will be forwarded to the Department of the Navy 

as they are responsible for future follow-on 

actions including closure and remediation of 

RHBFSF which will be subject to additional future 

environmental compliance actions as applicable. 

Although NEPA regulations do not require any 

public meetings for Environmental Assessments 

(EAs), the Action Proponents made the decision 

to hold a public meeting to increase public 

participation in the decision-making process.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Topic ID# Commenter Comment* Response

Public 

Participation

25 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

Further, the Navy may want to direct JTF-RH and DLA to craft an 

actual NEPA public participation plan as an optional tool for 

RHBFSF closure and remediation actions under 32 CFR 775.11 

as a means to establish set protocols (i.e., meeting 

minutes/notes, comment periods) for public engagement 

processes in writing and help manage public expectations.

Comment acknowledged. This recommendation 

will be forwarded to the Department of the Navy 

as they are responsible for future follow-on 

actions including closure and remediation of 

RHBFSF which will be subject to additional future 

environmental compliance actions as applicable.

Public 

Participation

28 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

Honolulu Board of Water Supply (BWS) has vast experience in 

maintaining and operating Oahu's civilian water system. Further, 

they have been actively involved in public meetings and outreach 

ever since the 2021 fuel leak. Within the DEA, OHA observes that 

BWS maps and their 2019 Informational Briefing are cited as 

references. In the June 20th public meeting, the JTH-RH team 

verbally indicated that their team continues to work with BWS on 

RHBFSF related actions.

However, while consultation with BWS is reported to be occurring 

and BWS documents are cited in the DEA as reference materials, 

there is no direct mention of their thoughts or concerns on the 

current defueling action. Despite BWS's independent ability to 

provide comments along with the general public, OHA believes 

that given BWS's expertise, ongoing consultations with BWS 

should be reasonably described or summarized within the DEA to 

help further instill public confidence in the repairs and 

demonstrate Navy cooperation with local authorities. JTH-RH 

could take this a step further by providing a Defueling Dashboard 

link to any of the more recent BWS consultation or public meeting 

summaries or notes. BWS should be viewed as a valued Statelevel government partner and Oahu water expert. Thus, there is 

no question that including descriptions or summaries of current 

consultation events with BWS for the defueling plan would be 

beneficial to the JTH-RH team and the greater effort to instill 

public trust.

We believe this recommendation to integrate BWS concerns is inline with DLA's current NEPA policy to "invite cooperation and 

assistance from federal, state, regional, and local authorities ...”

during the planning process of an EA document. Further, such 

disclosure and continued consultation with BWS would be in-line 

with 32 CFR 775.10, which encourages the Navy to establish 

"close and harmonious planning relations with local and regional 

agencies...” for "environmental related problems."

BWS leadership regularly engages with JTF-RH 

in venues such as the Defueling Information 

Sharing Forum (DISF) to discuss topics and 

concerns with defueling, to include matters within 

the scope of this EA/OEA. Furthermore, JTF-RH 

sent the June 9, 2023 JTF-RH press release that 

invited public review and comment on the Draft 

EA/OEA directly to the BWS Information Officer 

via email.

Screening 

Criteria

05 Meredith 

Wilson

Where are the U.S. Indo-Pacific Command Fragmentary Orders 

of 5 and 23 Jan 2023 located? This screening factor does not 

seem familiar.

Your comment prompted a more detailed review 

of the U.S. Indo-Pacific Command fragmentary 

order 05 and its relationship to the Proposed 

Action. Upon further consideration, fragmentary 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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Topic ID# Commenter Comment* Response

order 05 does not include any additional 

requirements that would be incorporated as 

screening factors for determining reasonable 

action alternatives. The reference to fragmentary 

order 05 was removed from Chapter 2, Section 

2.2 in the Final EA/OEA.

Alternatives 02 Kurt 

Fevella, 

Hawaii 

State 

Senator

I concur with Section 2.4: Alternatives Considered But Not 

Carried Forward For Detailed Analysis that tanker trucks should 

not be used to transfer fuel from the RHBFSF to Pearl Harbor via 

roadways.

Comment acknowledged.

Alternatives 04 Kurt 

Fevella, 

Hawaii 

State 

Senator

Exploring every avenue to retain the resource within the State of 

Hawaii should be pursued without jeopardizing the health and 

safety of our people and our vital resources.

Comment acknowledged.

Alternatives 07 Meredith 

Wilson

There needs to be cameras installed or a type of leak tracking for 

the five percent or less buried pipeline that cannot be visually 

inspected.

All underground pipe locations are on Joint Base 

Pearl Harbor Hickam (JBPHH) and are between 

the Underground Pump House (UGPH) and the 

fueling pier. There is no feasible way to install 

cameras in these locations to identify leaks. All 

underground piping along the defuel path is 

tightness tested annually in January to confirm its 

integrity. In preparation for defueling operations, 

the annual requirement for tightness testing of the 

pipeline will be reset to August so that the pipeline 

integrity is confirmed in August 2023 prior to 

defueling.

Alternatives 08 Meredith 

Wilson

Why is the fuel from the unpacking process and the 4-inch tank 

bottoms the only fuel being tested?

Testing of the final tanker/barge that would 

receive the flowable tank bottoms (bottom 10 feet 

of tank) and fuel from the underground surge 

tanks and pipeline unpacking process is required 

to determine the final specification of the fuel 

because it will be a mixture of three fuel types 

stored at RHBFSF.

All fuels will be tested to confirm specification and 

suitability for future military use prior to relocation 

or sale.

Alternatives 09 Meredith 

Wilson

With commercial sale of fuel, the purchasers’ tanker ships will not 

have the same oversight as tanker ships used for fuel relocation 

and that is problematic.

Commercial sale of certain fuel sources is 

authorized Section 2922e of Title 10, United 

States Code. Purchasers’ tanker ships would be 

required to comply with U.S. and International 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-6

Topic ID# Commenter Comment* Response

regulations and standards as applicable. Chapter 

2, Section 2.5.1 includes a description of the U.S. 

and International regulations and standards for 

tanker ships.

Alternatives 18 Marti 

Townsend, 

Earthjustice

The Draft Environmental Assessment (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 page 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.

Disposition or elimination of the fuel from 

RHBFSF does not meet screening criteria number 

7 described in Section 2.2 because it is not 

economical or a responsible use of taxpayer’s 

resources. There is a need for fuel within the DoD 

supply chain and the fuel has a monetary value to 

both the Government and/or to commercial 

industry. Any amount of fuel from RHBFSF that is 

disposed of or eliminated (i.e., donated or given 

away to non-DoD entities at no cost) would need 

to be purchased again and transported by the 

DoD to fulfill current and future DoD fuel supply 

chain requirements. Costs of purchasing and 

transporting new fuel would be greater than costs 

to relocate the fuel from RHBFSF to locations 

within the existing DoD fuel supply chain. The 

DoD does not have the authority to donate or give 

the fuel away without remuneration, however, it 

does have the authority to sell the fuel to 

commercial and private purchasers. This is 

considered in Chapter 2, Section 2.3.3 Alternative 

3: Commercial Sale and Relocation.

Alternatives 19 Marti 

Townsend, 

Earthjustice

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 page 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 

Transferring the fuel to commercial tanks on Oahu 

is included in Alternative 2 and 3. 

With Alternative 2, the relocation of fuel by tanker 

ship to contractor-owned and operated tanks at 

the Campbell Industrial Park is considered. The 

DoD’s fuel storage space available on Oahu is 

sized to meet the current and planned 

requirements of the Services. Constructing or 

acquiring new storage facilities to accommodate 

fuel from RHBFSF would not meet screening 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-7

Topic ID# Commenter Comment* Response

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.

criteria number 1 which requires the expeditious 

defueling of RHBFSF. Transfer of fuel to tanks on 

Oahu other than by tanker ships (e.g., via 

commercial pipeline or tanker trucks) was 

considered in Chapter 2, Table 2.4-1 and 

determined to not meet screening criteria.

With Alternative 3, commercial entities who 

purchase the fuel can transfer it by tanker ship to 

commercial fuel storage facilities if they so desire.

Storing the fuel in commercial tankers offshore 

Oahu for an extended period of time while the fuel 

is waiting to be consumed was determined to not 

be economical and a responsible use of 

taxpayer’s resources, and therefore does not 

meet screening criteria number 7. It is more cost 

effective to relocate the fuel within the DoD supply 

chain once it is loaded onto the tankers.

Relocating the fuel within the DoD fuel supply 

chain would also reduce other DoD costs 

associated with the purchase and transport of 

routine or planned fuel deliveries to the potential 

receiving locations. Discussion of this alternative 

was added to Chapter 2, Table 2.4-1 in the Final 

EA/OEA.

Alternatives 27 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

Prior to the initiation of defueling operations, the DEA describes 

that at least 253 repairs 4 were needed on fuel pipelines, the 

underground pump house, and RHBFSF facility. These repairs 

were requested within DOH and EPA orders. To ensure the 

quality of the repairs, the DOH approved a Third-Party Quality 

Validation Plan for a third-party quality validator to inspect the 

work. While the progress and approvals of these repairs are 

posted on the online "Defueling Dashboard", specific details (i.e., 

photos, repair narrative) are not included.

During the June 20, 2023 public meeting, the JTH-RH team 

verbally confirmed that repair specific information and 

subsequent third-party quality validator reports are not currently 

available on the online Defueling Dashboard. However, it was 

implied that some of that information may be available upon 

request. OHA advises that the DEA disclose that such requests 

can be made by interested parties. Further, given the BWS's 

experience and role in maintaining Oahu's civilian water system, 

OHA would advise that they be provided with an opportunity to 

review the third-party quality validator reports prior to initiating the 

defueling action [emphasis added]. Additionally, an explicit note 

The 253 repairs that were completed prior to 

defueling include repairs to fueling pipelines and 

infrastructure. As such, the third-party quality 

validation reports were submitted for review and 

approval to the U.S. EPA and the Hawaii 

Department of Health, who have regulatory 

authority and expertise in fueling pipelines and 

infrastructure.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-8

Topic ID# Commenter Comment* Response

or link on the Defueling Dashboard could be added for individuals 

that want to request more information regarding specific repairs. 

OHA believes these recommendations will aid with upholding 

project transparency.

Alternatives 29 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

OHA acknowledges that both Alternatives 2 and 3 would 

effectively result in the most expeditious means to evacuate fuel 

from RHBFSF. However, while Alternative 2 allows for a level of 

environmental review over the nine listed fuel relocation area 

possibilities, this cannot be done for Alternative 3 as it is unknown 

where sold fuel would be transported to by commercial buyers. 

Thus, arguably, OHA believes there is a greater level of 

environmental oversight associated with Alternative 2 in 

comparison to Alternative 3. Given this consideration, OHA has 

reservations with utilization of Alternative 3.

Commercial sale of certain fuel is authorized by 

Section 2922e of Title 10, United States Code. 

Commercial purchasers would be required to 

comply with U.S. and International tanker ships 

regulations and standards as applicable. Chapter 

2, Section 2.5.1 includes a description of the U.S. 

and International regulations and standards for 

tanker ships.

Best 

Management 

Practices

01 Kurt 

Fevella, 

Hawaii 

State 

Senator

All best management practices should be followed to ensure the 

safe and immediate defueling should be used.

Comment acknowledged.

Best 

Management 

Practices

03 Kurt 

Fevella, 

Hawaii 

State 

Senator

A description of the mitigation measures to address a potential 

catastrophic event, spill, accident, etc. should be included.

Best Management Practices (BMPs) included in 

the Proposed Action that will reduce the risk of 

spills and accidents are identified in Chapter 2, 

Table 2.5-1. BMPs identified that reduce the 

likelihood of a high-volume, extended duration 

spill (i.e., catastrophic spill) include BMP-1, -2, -3, 

-4, -5, -6, -7, - 9, and -12. Commander Navy 

Region Hawaii has an Integrated Contingency 

Plan (ICP) required by the Environmental 

Protection Agency (EPA) and the United States 

Coast Guard (USCG) detailing procedures for 

planning, notification, and response to discharges 

including a worst-case oil or hazardous substance 

discharge. Chapter 2, Table 2.5-1, BMP-2 has 

been updated in the Final EA/OEA to include 

reference to the Commander Navy Region Hawaii 

ICP.

Additionally, as discussed in Chapter 2, Section 

2.5.1, tanker ships will comply with regulatory 

compliance and oil spill response programs 

including Condition Assessment Program and 

Vessel Response Plans or Shipboard Oil Pollution 

Emergency Plans. Spill response capabilities at 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-9

Topic ID# Commenter Comment* Response

the potential receiving locations are discussed in 

Chapter 3, Section 3.2.2.6.

Best 

Management 

Practices

20 Marti 

Townsend, 

Earthjustice

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.

DoD commercial fuel transport contracts provide 

limited ability to impose additional BMPs outside 

of DoD ports and instead rely on compliance with

U.S., international, and receiving port regulations 

and requirements., U.S. and international 

regulations for tanker ships provide several 

safeguards and mandatory procedures to prevent 

pollution and respond to releases, including 

compliance with oil spill response programs such 

as Condition Assessment Programs, Vessel 

Response Plans, and Shipboard Oil Pollution 

Emergency Plans. Details of these mandatory 

safeguards and procedures are located in 

Chapter 2, Section 2.5.1. Chapter 2, Table 2.5-1, 

BMP-11 and -13 have been updated to include 

requirements at receiving ports.

Best 

Management 

Practices

21 Marti 

Townsend, 

Earthjustice

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 Underground 

pump house (UGPH), Joint Base Pearl Harbor-Hickam (JBPHH), 

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 page 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 page 2-7.) The 

DEA 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.

There are two Red Hill Rovers and one Kuahua 

(Pearl Harbor) Rover on duty 24 hours per day, 

seven days per week. The Rovers use an 

extensive checklist to verify completion of 

independent visual inspections of their assigned 

areas twice per shift. Rovers will immediately 

report any leaks or abnormalities to the Control 

Room Operator (CRO) via handheld radio or 

phone. The Rover and CRO will also record 

conditions in their shift logs. Checklists completed 

by the Rovers are reviewed by the Fuel 

Operations Supervisor to provide quality control. 

This information has been added to Chapter 2, 

Table 2.5-1, BMP-2 in the Final EA/OEA.

Best 

Management 

Practices

22 Marti 

Townsend, 

Earthjustice

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 above-ground piping 

along the route occurs after the UGPH for approximately 700 ft. 

The referenced above-ground piping is part of the 

pipeline connecting the UGPH to the fueling pier 

on JBPHH. The 700 ft. above-ground section runs 

along a drainage swale. The drainage swale is a 

planned collection point in the event of a 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-10

Topic ID# Commenter Comment* Response

along a largely paved area that is 900 ft. from the harbor.” (DEA 

page 3-10.) The DEA does not provide a Best Management 

Practice or mitigation measure that addresses this possibility, 

which may seem remote, but could be significant if fuel escapes 

from this area.

discharge from this section of above-ground 

piping. As such, there are measures in place 

within the swale to capture and contain a potential 

release. A dam is in place to protect release to 

Halawa stream in the event of a piping rupture 

along the drainage swale. If the release was 

unable to be contained by the dam, a containment 

boom is in place across Halawa stream as an 

additional protective measure. In the event of a 

pipeline break during the defueling operation, 

response will be conducted in accordance with 

the Facility Response Plan. Pump trucks would be 

used to remove fuel from land; waterborne oil 

collection vessels would be used to collect fuel 

from the Halawa stream. Chapter 3, Section 

3.2.2.2 has been updated to include this 

information.

Cultural 

Resources

10 Meredith 

Wilson

Page 3-1 of the DEA/DOEA states “Defueling involves no 

activities with potential to affect traditional cultural properties.” To 

quote a letter from Hawaii State Legislature to Navy leadership 

on Oct. 18, 2021: “Joint Base Pearl Harbor-Hickam occupies the 

land and nearshore waters historically known as Puuloa. During 

the Kingdom of Hawaii, Puuloa was operated as a fishpond that 

fed the residents of Oahu until it was forcibly given to the U.S. 

military in 1887 via the ‘Bayonet Constitution.’ Because it is 

operating on traditional Hawaiian lands and waters, it is 

absolutely critical that the U.S. military conduct itself with the 

highest level of respect and transparency.”

Comment acknowledged.

Cultural 

Resources

26 Sylvia M. 

Hussey, 

Ed.D., 

Office of 

Hawaiian 

Affairs

In regard to cultural resources and historic properties, the DEA 

states that "defueling through existing pipelines and relocation by 

fuel tanker would involve no activities with the potential to affect 

historic buildings, archaeological sites, or traditional cultural 

properties." Section 5.4 further states that the proposed action is 

consistent with the National Historic Preservation Act (NHPA). 

Yet, there is no other mention of any effort to initiate NHPA 

Section 106 consultations with Native Hawaiian organizations 

(NHOs).

However, OHA does acknowledge that while not disclosed in the 

DEA, the JTH-RH team verbally revealed in the June 20th public 

meeting that NHPA Section 106 would not be triggered for the 

current action due to an existing NHPA Programmatic Agreement 

(PA) for JBPHH that indicates routine operations, like defueling 

operations via existing infrastructure, are not considered Federal 

undertakings. Thus, the current action would not be subject to the 

The Proposed Action was determined to not have 

the potential to cause effects to historic 

properties. Consistent with 36 CFR § 800.3(a)(1), 

if the undertaking is a type of activity that does not 

have the potential to cause effects on historic 

properties, no further obligations under Section 

106 of the National Historic Preservation Act 

(NHPA) apply. Under the Programmatic 

Agreement (PA) among the Commander Navy 

Region Hawaii, the Advisory Council on Historic 

Preservation, and the Hawaii State Historic 

Preservation Officer regarding Undertakings in 

Hawaii signed October 2012, which covers the 

RHBFSF, an undertaking that does not have the 

potential to cause effects on listed, contributing or 

eligible properties, does not require further review 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-11

Topic ID# Commenter Comment* Response

Section l 06 consultation process. OHA believes that such a 

decision should've been publicly disclosed in writing within the 

DEA and a link provided to the actual PA on the Defueling 

Dashboard. Further, any signatory of the PA should be apprised 

of the situation via a written letter to ensure there aren't any 

objections [emphasis added]. As JBPHH may be operating under 

several NHPA related PAs, it is unclear to OHA what the specific 

language or condition is for the PA that was cited for the current 

defueling effort.

While defueling via existing infrastructure may indeed be 

perceived as routine, OHA believes the Navy has a responsibility 

to ensure the utmost level of transparency and collaboration is 

achieved for defueling and RHBFSF closure actions to aid in 

rebuilding public trust.

under the PA and the NHPA. All such 

undertakings and determinations made will be 

documented, recorded, and reported in 

accordance with reporting requirements of this 

PA. Chapter 3 of the Final EA/OEA has been 

updated to include this information.

Environmental 

Justice

17 Kirsten 

Kagimoto, 

Sierra Club 

of Hawaii

While the EA/OEA purports to be consistent with the policy 

considerations behind E.O. 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 

Due to the limited number of shipments of fuel 

from RHBFSF to locations that receive fuel in the 

ordinary course of business, as identified in 

Alternatives 2 and 3, we anticipate negligible 

impacts to human health or the environment from 

the Proposed Action. The Action Proponents of 

this EA/OEA considered E.O. 12898 and 

determined that the Proposed Action would not 

have “disproportionately high and adverse human 

health or environmental effects on low-income or 

minority populations.” Pertinent to our 

consideration are the following factors: Fuel 

shipments in the Proposed Action would be in lieu 

of routine or planned fuel supply deliveries to 

existing locations within the DoD fuel supply 

chain; the Proposed Action does not require any 

construction to increase the maximum ullage (i.e., 

fuel storage space available) required to 

accommodate storage of fuel being relocated 

from RHBFSF; and, fuel relocated from RHBFSF 

does not have an inherently greater risk to 

communities than fuel from routine fuel supply 

deliveries. 

The vast majority of activities in the Proposed 

Action occurs in and around Oahu, Hawaii, 

whereas other locations may only receive a few 

tankers of fuel, if any. For this reason, JTF-RH 

and the DLA have concentrated community 

engagement and outreach efforts on Oahu. JTFRH continues to engage with the local Hawaiian 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-12

Topic ID# Commenter Comment* Response

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.

community as well as representatives at the state 

and federal levels. Notable recent engagements 

include hosting a National Environmental Policy 

Act (NEPA) Public Meeting on June 15, 2023, 

participating in the DOH-hosted Fuel Tank 

Advisory Committee (FTAC) Open House and 

meeting June 5 and 6, 2023, as well as 

participation in various neighborhood boards 

when there are relevant defueling milestones 

updates. Other recent community outreach 

milestones include an interview with Vice Admiral

John Wade, Commander of JTF-RH, and the 

Honolulu Star-Advertiser Spotlight, an update to 

the Governor’s Water Committee, and an update 

to various Native Hawaiian Organizations, to 

include the Office of Hawaiian Affairs. We 

successfully launched the JTF-Red Hill mobile 

application, leveraging technology to quickly and 

consistently connect with the community. Users 

have access to real-time updates, news, and 

events related to defueling. Additionally, the U.S. 

Department of the Navy (Navy) and DLA have 

committed to continued community involvement 

through the Community Representation Initiative, 

a requirement of the EPA 2023 Consent Order, 

which independently represents the interests of 

the community. 

Water 

Resources

11 Meredith 

Wilson

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 and 

sediment is already an issue in this area.

Chapter 2, Table 2.5-1, BMP-4; Vessel fueling 

procedures has been updated to provide 

additional detail on the procedure for visual 

inspection of waters required by the Defense Fuel 

Supply Point (DFSP) Pearl Harbor Bulk Terminal 

Operation, Maintenance, Environmental and 

Safety Plan. The procedure requires periodic 

observation of the surface of the water between 

the vessel and the shore for sheen throughout the 

duration of the fuel transfer operation. Any sign of 

oil on the water will be reason to terminate the 

operation.

Propeller wash from vessels arriving and 

departing ports could resuspend bottom floor 

sediments by creating turbulence in the water and 

bottom environment with the vessel’s propellers. 

Resuspended sediments would create localized 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-13

Topic ID# Commenter Comment* Response

turbidity during short periods of time and would 

likely not cause significant effects to water quality.

Hazardous 

Materials and 

Waste

12 Meredith 

Wilson

In past 3 years, overfilling a vessel has resulted in approximately 

five gallons spilled and pipeline failure has resulted in 

approximately 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 March 2020 to July 2021, how 

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

environment?

The fuel pipelines and infrastructure that will be 

used for the Proposed Action are not involved in 

the commenter-referenced release of petroleum 

from a wharf located near Hotel Pier. This release 

is subject to separate environmental compliance 

actions which can be reviewed at 

https://health.hawaii.gov/ust/documents-relatedto-hotel-pier/. This information has been added to 

Chapter 4, Table 4-1.

Air Quality and 

Greenhouse 

Gases

13 Meredith 

Wilson

National Emission Standards for hazardous air pollutants (HAPs) 

were implemented for marine loading terminals that only 

[emphasis added] load crude oil or gasoline, not [emphasis 

added] kerosene, which is the JP-5 classification. EPA should 

hold Navy accountable to these same HAP standards for this 

particular fuel movement in efforts to align and streamline with 

the Clean Air Act.

The final rule for National Emission Standard for 

Hazardous Air Pollutants (NESHAP) for Marine 

Tank Vessel Loading Operations (40 CFR Part 63 

Subpart Y) is not applicable to the fuel types to be 

relocated by the Proposed Action including JP-5 

(refined kerosene), F-24, and F-76.

Air Quality and 

Greenhouse 

Gases

14 Meredith 

Wilson

Since VOCs can be released as “fugitive emissions” from vessel 

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

measured?

It is not feasible to directly measure fugitive 

emissions of Volatile Organic Compounds (VOCs) 

from the Proposed Action. The emissions factors 

published by the Environmental Protection 

Agency (EPA) in AP-42, Compilation of Air 

Pollutant Emissions Factors, Fifth Edition, Volume 

I; Chapter 5: Petroleum Industry, 5.2 

Transportation and Marketing of Petroleum 

Liquids were used to estimate fugitive emissions 

of VOCs, as described in Chapter 3, Section 

3.5.3.1. The EPA develops and compiles the 

emissions factors in AP-42 from source test data, 

material balance studies, and engineering 

estimates.

Cumulative 

Impacts

15 Meredith 

Wilson

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 [emphasis added] 

defueling, this is where the biggest concern lies. 

• On March 17, 2020, petroleum was observed and kept 

going for 22 days until it “stopped on its own” (not by a 

concerted resolution), but resumed on June 2, 2020. 

(quote from Honolulu Civil Beat 8 Oct 2021 article) 

• This fuel was originally thought to be from historical 

plume, but upon December 2020 investigation (albeit 

only after [emphasis added] a June 30, 2021 letter from 

The fuel pipelines and infrastructure that will be 

used for the Proposed Action are not involved in 

the commenter-referenced release from a wharf 

located near Hotel Pier. This release is subject to 

separate environmental compliance actions which 

can be reviewed at 

https://health.hawaii.gov/ust/documents-relatedto-hotel-pier/. This information has been added to 

Chapter 4, Table 4-1.
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

A-14

Topic ID# Commenter Comment* Response

DOH requesting to do so), it was found to be “unweathered” i.e., fresh JP-5 from leaking underground 

pipeline. 

• With this track record of the inability to identify and stop 

leaks, how can we trust that the same will not continue? 

• As of January 2021, the pipeline at Hotel Pier failed two 

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 February 2, 2021 site visit from contractor 

PENCO “almost immediately” confirmed an active leak, 

Navy’s stance still [emphasis added] 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?

Cumulative 

Impacts

16 Meredith 

Wilson

“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” (from DEA/DOEA Chapter 4, Table 

4-1). 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?

Oil-absorbent booms enclose the area of the 

Hotel Pier release to contain and recover any oil 

that reaches the water. Booms and observation 

wells are routinely checked and a monthly report 

is submitted to the DOH. Latest monthly reports 

show zero (0) gallons of capture in the area. The 

fuel pipelines and infrastructure that will be used 

for the Proposed Action are not involved in this 

release. In the event of a release during the fuel 

loading operation, it could be readily distinguished 

from the Hotel Pier release based on size and 

location of the visible oil sheen. Separate and 

independent oil-absorbent booms would be predeployed around the tanker and the area 

immediately around the pier to contain and 

prevent the spread of any potential releases 

during the fuel loading operation. JTF-RH and 

DLA are committed to transparency and are 

working closely with regulators including DOH and 

EPA who will oversee execution of the defueling 

operation.

Notes: *Comments have been edited for spelling, grammar, and context as necessary for clarity.
B-1

APPENDIX B – ENDANGERED SPECIES ACT –

NOAA/NMFS CONSULTATION

LETTER OF CONCURRENCE
Refer to NMFS No: OPR-2023-01108

M.A. Link

Brigadier General, U.S. Army

Deputy Commander, Joint Task Force Red Hill

and

Captain Brian J. Anderson, U.S. Navy

Commander, Defense Logistics Agency Energy

Joint Task Force Red Hill

1025 Quincy Avenue, Suite 900

Joint Base Pearl Harbor

Hickam, Hawaii 96860

RE: Concurrence Letter for the Endangered Species Act Section 7 Informal Consultation for 

the Red Hill Defueling and Fuel Relocation Project 

Dear Brigadier General Link and Captain Anderson: 

The National Marine Fisheries Service (NMFS) Endangered Species Act (ESA) Interagency 

Cooperation Division (hereafter referred to as “we” or “us”) received your May 19, 2023, request 

for concurrence with the U.S. Navy’s determination that the proposed Red Hill Defueling and 

Fuel Relocation Project may affect, but is not likely to adversely affect, any ESA-listed species 

or designated critical habitat in the action area. This response to your request was prepared by 

NMFS pursuant to ESA section 7(a)(2), implementing regulations at (50 CFR part 402), and 

agency guidance for preparation of letters of concurrence. 

This letter underwent pre-dissemination review using standards for utility, integrity, and 

objectivity in compliance with agency guidelines issued under section 515 of the Treasury and 

General Government Appropriations Act of 2001 (Data Quality Act, 44 U.S.C. 3504(d)(1) and 

3516). A complete record of this informal consultation is on file electronically with the NMFS 

Office of Protected Resources in Silver Spring, Maryland. 

Background and Consultation History 

In September 1943, the Navy completed construction of the underground Red Hill Bulk Fuel 

Storage Facility (RHBFSF) in Pearl Harbor, Hawaii. Initially, the facility supplied fuel to Navy 

ships and submarines during World War II, and continued to supply Navy ships, aircraft and 

submarines with fuel after the war. In January 2014, the Navy identified an estimated fuel release 

of up to 27,000 gallons of jet fuel from one of the storage tanks. In response to the release, the 

U.S. Environmental Protection Agency (EPA) and Hawaii Department of Health (DOH) 

08/15/2023
2 

negotiated an enforceable agreement, also known as an Administrative Order on Consent, with 

the Navy and the Defense Logistics Agency (DLA). The Order required the Navy and DLA to 

take actions, subject to DOH and EPA approval, to address fuel releases and implement 

infrastructure improvements to protect human health and the environment. 

In May 2021, a pressure surge event occurred during routine fuel movement operations at the 

RHBFSF. The pressure surge event caused a pipeline joint failure to release over 19,000 gallons 

of jet fuel onto the tunnel floor between the underground storage tanks. The fuel ran down the 

tunnel floor into containment trenches and into a fire suppression system fluid sump. The sump 

pushed fuel down the tunnel into a fire suppression system fluid drain pipeline where the fuel 

remained until the drain valve on the pipeline ruptured in November 2021. This ruptured drain 

valve resulted in fuel spilling into the tunnel system near the Red Hill drinking water system 

shaft resulting in contamination of drinking water. The contaminated drinking water affected 

approximately 93,000 Navy water system users, and forced many to relocate to temporary 

housing. 

The DOH, the Hawaii state agency responsible for regulating underground fuel storage tanks, 

issued an emergency order on December 6, 2021, directing JTFRH to cease all operations at the 

facility and to defuel the 18 operational underground fuel storage tanks (order was reissued in 

May 2022). At the direction of U.S. Secretary of Defense, the Joint Task Force agreed to comply 

with DOH's emergency order to defuel the tanks at RHBFSF (NAVFAC 2023). In January 2023, 

EPA proposed a settlement (i.e., proposed Consent Order) with the Navy and DLA that required 

steps to ensure safe defueling and closure of the RHBFSF. On June 30, 2022, the Joint Task 

Force Red Hill (JTFRH) was established to provide oversight for all necessary repairs, 

modifications and enhancements to the Red Hill infrastructure to reduce risk of spills or 

accidents during the defueling phase of the project. The JTFRH removed over one million 

gallons of fuel from the facility's fuel pipelines in late October and early November 2022. 

The history of this consultation is as follows: 

x On March 23, 2023, representatives from Naval Facilities Engineering Systems 

Command (NAVFAC) Pacific, NMFS Office of Protected Resources Interagency 

Cooperation Division, and NMFS Pacific Islands Regional Office (PIRO) Protected 

Resources Division held a pre-consultation meeting to discuss the Red Hill Defueling and 

Fuel Relocation Project. NAVFAC Pacific biologists shared project information and 

inquired about the preferred consultation approach and ESA-species lists. 

x On March 24, 2023, NMFS determined that the Office of Protected Resources, 

Interagency Cooperation Division (hereafter referred to as “we” or “us”) would be the 

lead NMFS office for this consultation. 

x On March 28, 2023, NAVFAC provided a draft ESA species list for NMFS to review. 

We responded with our comments and recommendations on April 5, 2023. 

x On April 6, 2023, NAVFAC sent us a revised species list. 
3 

x On May 1, 2023, NAVFAC and NMFS held a pre-consultation meeting to discuss the 

geographical extent of the action area and the impacts assessment, and whether to include 

foreign ESA-listed species (i.e., species that do not occur within U.S. waters or on the 

high seas) in the consultation. 

x On May 15, 2023, NAVFAC provided us with a final species list. The Action Proponents 

(i.e., JTFRH and DLA) reaffirmed their understanding that ESA section 7 consultation 

does not apply to species that occur only within a foreign country’s Exclusive Economic 

Zone (EEZ) or territorial waters. As a result, the Action Proponents did not include such 

species in their final species list as part of their informal consultation package. We 

indicated to the Action Proponents that, for Federal actions with stressors that extend 

from U.S. waters or the high seas into a foreign country’s EEZ or territorial waters, the 

Federal action agency is obligated to meet its ESA section 7(a)(2) responsibility and 

consult on the action as a whole, including the effects of the action on foreign ESA-listed 

species. For this consultation, while ESA section 9 prohibitions do not apply and would 

not apply in foreign waters, ESA-listed foreign species should be included because 

impacts to these species could occur as part of the proposed action given that the action 

area and influence of stressors from the proposed action are within the range of these 

species. 

x On May 19, 2023, NAVFAC sent us an email indicating that the JTFRH and DLA were 

requesting informal consultation regarding the proposed relocation of fuel from the 

RHBFSF to various existing fuel storage locations within the Department of Defense 

(DoD) fuel supply chain by ocean transit. Their initiation package included a cover letter 

and a Biological Evaluation (BE). We reviewed the BE and provided comments, 

including recommended additional mitigation measures, to minimize the risk of vessel 

strike to NAVFAC on May 26, 2023. 

x On June 1, 2023, NAVFAC and NMFS met to discuss follow up questions pertaining to 

our review of the Red Hill Defueling and Fuel Relocation BE. 

x On June 9, 2023, NAVFAC sent us a revised BE. We reviewed the revised BE, and on 

June 16, 2023, confirmed that NAVFAC’s consultation package for the Red Hill 

Defueling and Fuel Relocation action contained all the information needed to proceed 

with ESA section 7 informal consultation. 

In August 2019, the USFWS and NMFS (i.e., the Services) enacted a series of regulations that 

modified how the Services implemented the ESA. On July 5, 2022, the U.S. District Court for 

the Northern District of California issued an order vacating the 2019 regulations that were 

revised or added to 50 CFR part 402 in 2019 (“2019 Regulations,” see 84 FR 44976) without 

making a finding on the merits. On September 21, 2022, the U.S. Court of Appeals for the Ninth 

Circuit granted a temporary stay of the district court’s July 5 order. On November 14, 2022, the 

Northern District of California issued an order granting the government’s request for voluntary 

remand without vacating the 2019 regulations. The District Court issued a slightly amended 

order 2 days later on November 16, 2022. As a result, the 2019 regulations remain in effect, and 
4 

we are applying the 2019 regulations here. For purposes of this consultation and in an abundance 

of caution, we considered whether the substantive analysis and conclusions articulated in the 

letter of concurrence would be any different under the pre-2019 regulations. We have determined 

that our analysis and conclusions would not be any different. 

Proposed Action 

The proposed action is the relocation of the 106 million gallons of fuel from RHBFSF to existing 

locations within the DoD fuel supply chain by ocean transit. The proposed action is expected to 

occur from October 2023 until January 2024 (NAVFAC 2023). The fuel removal operation 

involves gravity flow of the fuel from RHBFSF through existing DoD piping and associated 

infrastructure to a fuel-loading pier at Joint Base Pearl Harbor-Hickam (JBPHH). The proposed 

action would defuel RHBFSF within approximately four months after DOH approval of the 

defueling process. 

In order to comply with the defueling order, the JTFRH proposed utilizing a maximum of 11 

refined product tanker ships to redistribute the remaining fuel to existing DoD fuel support points 

throughout the Pacific. A maximum of 11 transits are required to receive and transport all fuel 

from RHBFSF. The tanker ships will be medium-range type vessels that are approximately 600-

feet long with an approximately 11 million gallon storage capacity (NAVFAC 2023). 

Tanker ships relocating fuel from RHBFSF will use existing navigational channels to transit, 

guided by tugboats, through Mamala Bay to the Pearl Harbor Main Channel and into Southeast 

Loch to arrive at the JBPHH fueling pier (NAVFAC 2023). Up to 2 round-trip tanker transits per 

week will occur during the gravity-based defueling process, for a maximum of 11 total roundtrip transits (NAVFAC 2023). Once docked, several safety and procedural checks will be 

conducted, as described in Best Management Practices (BMPs) below. The next morning, the 

tanker loading operation will commence under the direction of the assigned Person in Charge 

and in compliance with an operations order, a standard operating procedure for fuel loading 

evolutions. Tanker loading could take up to 3 days per tanker. A maximum of 2 tankers per week 

could be loaded (NAVFAC 2023). 

Tanker ships will depart the fueling pier guided by tugboats through Pearl Harbor. After exiting 

Pearl Harbor, tanker ships (one through ten) will transit within existing commercial shipping 

lanes to one or more (up to 9) existing DoD fuel support points throughout the Pacific (Table 1). 

The proposed action includes the vessel transit routes through the large marine ecosystem of the 

high seas. An estimated 24,700 nautical miles of ocean transit passage by tankers will be 

conducted as part of the proposed action (NAVFAC 2023). Upon arrival at the receiving 

locations, fuel will be offloaded, stored, and managed in compliance with the receiving entity’s 

standard practices and operating procedures. 

The fuel deliveries will occur in lieu of currently routine and anticipated fuel supply deliveries. 

Each prospective DoD fuel support point has adequate facilities and piers/systems to receive fuel 

from tanker ships. 
5 

Table 1. Potential receiving locations for Red Hill fuel (NAVFAC 2023) 

Potential Receiving 

Location 

Maximum 

Number of 

Tankers to Each 

Location 

Estimated Transit 

Distance (nautical 

miles)** 

Estimated 

Transit 

Duration 

(days)** 

Offload Point 

West Oahu, Hawaii 

Campbell 

Industrial Park 

5 13 <1 day (1 hour) Seven Point Multipoint 

Mooring System (2 miles 

offshore) 

Am closing Naval 

Base Point Loma, 

California 

2 2280 7 days Navy Pier located at Dock 

Street 

Selby 

Terminal, 

California 

2 2120 6 days Fuel Pier at Point Davis 

Port of Vancouver, 

Washington 

1 2350 7 days Pier at Terminal 2, Berth 5 

Manchester, 

Washington 

1 2480 7 days Navy Pier on Olympic 

Drive Manchester, WA 

US Naval Fueling 

Station Sasebo, Japan 

2 4060 12 days Navy Fuel Piers in 

Sasebo Harbor 

Subic Bay, Philippines 5 4830 14 days Petroleum Oil Lubricants 

(POL) Pier 

Port of Singapore 5 6230 18 days Fueling Piers 

Port of Darwin, 

Australia 

2 5190 15 days East Arm Wharf Berth 4 

**Note: Transit distances are approximate based on the most direct route from Oahu; routes/distances could vary in 

practice based on weather conditions and other factors. 

The quantity of fuel and number of tankers received at each location depends on the fuel 

inventory needs of the DoD at the time of defueling. For planning and analysis purposes, an 

upper bound of transits for each receiving location was determined in consultation with DLA in 

Table 1 for consideration in this consultation. 

Military Sealift Command will contract commercial tanker ships to transport fuel based on 

commercial market availability at the time of defueling. Vessels will follow established shipping 

routes and maintain established shipping speeds (typically around 15 knots [kts] or 15 nautical 

miles per hour) during transit in open water to their destinations (NAVFAC 2023). Transit times 

will depend on the distance from JBPHH to the destination port as shown in Table 1. 

An eleventh tanker will be staged at the JBPHH fueling pier for approximately 2 to 5 weeks to 

receive flowable tank bottoms and fuel from the underground surge tanks and the pipeline 

unpacking process (estimated to be 2 million gallons of fuel or a portion thereof). The vessel, if 

delayed, will moor at a different Pearl Harbor pier or in the vicinity of Pearl Harbor at the 

direction of the Harbormaster (NAVFAC 2023). Fleet Logistic Center Pearl Harbor would 

sample and test the fuel transported to the tanker to determine whether it meets specifications for 

DoD requirements. If the fuel meets DoD specifications it will be transported to one of the 
6 

receiving ports in Table 1, and the eleventh tanker transit would be considered part of the 

proposed action for this consultation. 

Best Management Practices 

Oil Spill 

The proposed action will involve the use of double-hulled commercial tanker ships with a 

certified oil discharge monitoring and control system (monitoring system), as well as other safety 

and environmental design features, as required in accordance with U.S. Coast Guard (USCG) 

regulation Title 33, Section 157 (NAVFAC 2023). These contracted commercial vessels will also 

have an Automatic Identification System (AIS), which is a system that acts like a transponder to 

provide real-time ship name, course, speed, classification, call sign, registration number, and 

other information. This system allows maritime authorities to track and monitor vessel 

movements in accordance with the International Maritime Organization’s International 

Convention for the Safety of Life at Sea (IMO 2023). 

Tanker ship operators will also comply with standard operating procedures in compliance with 

applicable regulations. Once a tanker ship leaves a DoD port, their operations are outside the 

authority of DoD to impose BMPs; however, U.S. and international regulations for tanker ships 

provide several safeguards and mandatory procedures to prevent pollution. Some of these 

safeguards and procedures include (but are not limited to): 

x Tankers ships will comply with the U.S. standard for the storage and transport of liquid 

cargo (see 33 CFR, Chapter I, Subchapter 0, Part 157), which includes details on specific 

ship build, regulatory standards and spill containment procedures. These regulations for 

oil tankers are among the most detailed, environmentally focused and strictly enforced 

regulations in the maritime industry. 

x Plan reviews, certifications, and inspections of tankers are performed by the USCG, or a 

USCG-certified class society (e.g., American Bureau of Shipping [ABS]). Regulations in 

33 CFR, Chapter I, Subchapter 0, Part 157 are comprehensive and give direction on (but 

not limited to): 

o design, equipment and installation of tank vessels; 

o detailed on-load/offload operation guidance; 

o crude oil management ; 

o oil spill mitigation and response; and 

o penalties for oil spills. 

x Tanker ship operators will comply with international regulatory guidelines including 

those of the International Safety Guide for Oil Tankers and Terminals (ISGOTT). The 

ISGOTT aligns tanker industry standards providing best technical guidance on oil tanker 

and terminal operations. 

x Tanker ships will comply with additional oil spill response programs, including: 

o Condition Assessment Programs - specialized surveys performed by Ship 

Classification Societies (such as ABS) that assess a ship's actual condition, based 

upon strength evaluation, and fatigue strength analysis, as well as detailed on-site 
7 

systematic inspection of hull, machinery and cargo systems. A mitigation 

inspection program through the last 5 years of service (maximum twenty years' 

service for tankers) is mandatory. 

o Vessel Response Plans or Shipboard Oil Pollution Emergency Plans - 

International Convention for the Prevention of Pollution from Ships (MARPOL) 

requires owners and operators to prepare in the event of an oil spill. 

x Tanker ships will comply with environmental/marine species regulations that are specific 

to local zones. These are well known to the international maritime industry passing 

through these waters with up to date warnings of specific sightings or required increased 

vigilance issued by the USCG Captain of the Port (NAVFAC 2023). 

Vessel Strike 

The following general BMPs will be implemented as part of the proposed action to mitigate the 

risk of vessel strike: 

x Vessels shall be up to date on all regional speed restrictions, including those described 

above (NAVFAC 2023). 

x To the extent practicable during transit, vessel operators will halt or alter course to 

remain at least 500 yards from whales and 200 yards from other marine mammals. A safe 

distance shall also be kept between the vessel and sea turtles (NAVFAC 2023). 

x To the extent practicable, when underway, the mitigation zone shall be observed and if a 

marine mammal or sea turtle is observed, the vessel shall maneuver to maintain distance, 

to the extent practicable (NAVFAC 2023). 

The proposed action includes vessels transiting along the west coast of the Continental US. 

These locations have numerous vessel speed mandates and voluntary speed reduction areas. 

The action agency has agreed to adhere to the voluntary vessel speed rules in these areas, as 

described below (NAVFAC 2023). Transiting vessels will employ measures to reduce potential 

vessel collisions and interactions with marine species. 

Vessels transiting through Greater Farallones and Cordell Bank National Marine Sanctuaries 

have coordinated with the Channel Islands National Marine Sanctuary to issue voluntary Vessel 

Speed Reduction (VSR) requests from May 1 through December 15 to slow vessels during the 

period of peak whale abundance in the San Francisco and southern California regions to reduce 

vessel strike risk (Figure 1). NOAA's Office of National Marine Sanctuaries issued a 10-knot 

speed request in partnership with NMFS, USCG, and the EPA. In 2023, the San Francisco region 

VSR zone was expanded to include the Monterey Bay National Marine Sanctuary, and the 

southern California VSR zone was expanded to include recent International Maritime 

Organization modifications to the Santa Barbara Channel Traffic Separation Scheme (TSS) and 

Area To Be Avoided (ATBA). 
8 

Transiting vessels will employ the following measures when transiting in the area of the 

Admiralty Inlet and Puget Sound to reduce potential vessel collisions and interactions with 

marine species: 

x Tankers transiting to the receiving ports located in Vancouver, WA and Manchester, WA 

will pass through Admiralty Inlet and Puget Sound. These routes include areas designated 

as critical habitat for the endangered Southern Resident killer whale. 

x To the extent practicable, all transiting tanker vessels shall adhere to all voluntary speed 

restrictions in areas where the risk of vessel strike is high (e.g., seasonal [October 24 to 

January 22] Southern Resident killer whale critical habitat restrictions). 

x When it is safe and operationally feasible, tanker vessels are encouraged to transit the 

slowdown area at or below 11 knots. 

x The slowdown area covers the shipping lanes from Admiralty Inlet by Port Townsend 

south to Kingston and Mukilteo (Figure 2). 

Vessels in Pearl Harbor will employ the following measures (NAVFAC 2023) to reduce 

potential vessel collisions and interactions with marine species: 

x Operational and maintenance standards for vessels will be practiced, and vessel 

operations will only occur during ocean conditions that do not compromise safe operation 

with contingency plans to cancel or delay the action for favorable weather conditions. 

x Vessel operators will halt or alter course to remain at least 150 feet (45.7 meters) from 

ESA-listed marine species and, to the extent practicable, marine mammals. 

x Vessels shall operate at speeds safe for the location and conditions. Per the Navy Region 

Hawaii Port Environmental Manual (Navy 2023) Within Pearl Harbor, this is 10 knots or 

less. Operators will be particularly vigilant to watch for turtles at or near the surface in 

areas of known or suspected turtle activity and, if practicable, reduce vessel speed to 5 

knots or less. 

x To the extent practicable, if approached by an ESA-listed marine species or marine 

mammal, the vessel operator will put the engine in neutral, if the animal is within 150 

feet (45.7 meters) of the vessel, until the animal has moved at least 50 feet (15.2 meters) 

away and then engage the engine and slowly move 150 feet (45.7 meters) or more from 

the animal. 

x Vessel operators will not encircle or trap marine mammals or ESA-listed marine species 

between multiple vessels or between vessels and the shore. 

x Vessels will take reasonable steps to alert other vessels in the vicinity of marine species. 

x Vessels will follow established transportation channels whenever practicable. 
9 

Figure 1. 2023 NOAA/USCG/EPA voluntary Vessel Speed Reduction Zone for the San Francisco and 

Monterey Bay regions.

Figure 2. Admiralty Inlet and North Puget Sound Voluntary Ship Slowdown
10 

Potential Stressors to ESA-listed Species 

The proposed action involves multiple activities, each of which can create stressors. Stressors are 

any physical, chemical, or biological modifications to land, water, or air caused by the action and 

its associated activities. We deconstruct the proposed action to identify potential stressors that 

could result from the proposed activities. The effects of these potential stressors on ESA-listed 

species and designated critical habitat in the action area are discussed below. 

The potential stressors that may result from the proposed action are: 

1. Vessel-based stressors associated with tanker ships in transit from the JBPHH fuelloading pier in Pearl Harbor, Hawaii to the selected receiving locations (see Table 1 

above) and from tugboats used to guide tankers through Pearl Harbor and the receiving 

ports. Potential vessel-based stressors include: 

o vessel noise and visual disturbance; and 

o vessel strike. 

2. Oil spill stressors resulting from 1) accidental discharge during the transfer of fuel from 

the RHBFSF bulk tanks through existing DoD piping and associated infrastructure to a 

fuel-loading pier at JBPHH, and onto the tanker ships, or 2) accidental discharge of fuel 

from the tanker ship at any point during transit to the fuel receiving destination port. 

Action Area 

The use of the term “action area” refers to all areas to be affected directly or indirectly by the 

Federal action and not merely the immediate area involved in the action (50 CFR §402.02). The 

definition of action, referred to in the previous definition, is all activities or programs of any kind 

authorized, funded, or carried out, in whole or in part, by Federal agencies in the United States or 

upon the high seas. Examples include but are not limited to: ... d) actions directly or indirectly 

causing modifications to the land, water, or air” (50 CFR §402.02). For this reason, the action 

area is typically larger than the project footprint and extends out to a point where no measurable 

modifications to land, water, or air from stressors resulting from the proposed action occur. 

The action area proposed by the Joint Task Force and DLA begins at JBPHH and extends to 4 

DoD fuel support ports located along the west coast of the continental United States, and 4 

foreign fuel support ports in the Western Pacific, as shown in Figure 3. 
11 

Figure 3. Map of all potential fuel receiving locations and estimated vessel transit routes (NAVFAC 2023)

The origination and offload locations in the U.S. Eastern Pacific are (Figure 4): 

x JBPHH Fuel Pier, Oahu, HI; 

x West Oahu, HI; 

x Naval Base Point Loma, San Diego, CA; 

x Selby Terminal, CA; 

x Port of Vancouver, Kitsap Naval Base, WA; and 

x Manchester, WA. 
12 

Figure 4. Map of potential fuel receiving locations and estimated vessel transit routes to Eastern Pacific ports 

(NAVFAC 2023)

The origination and offload locations for the 4 DoD fuel support ports in the Western Pacific are

(Figure 5): 

x U.S. Naval Fueling Station Sasebo, Sasebo Japan; 

x Subic Bay, Philipines; 

x Port of Singapore, Singapore; and 

x Port of Darwin, Darwin Australia. 
13 

Figure 5. Map of potential fuel receiving locations and estimated vessel transit routes to Western Pacific ports 

(NAVFAC 2023) 

Red Hill 

The U.S. Navy originally completed the RHBFSF in 1943 to replace aboveground storage tanks 

that were vulnerable to air attack. The Red Hill facility includes 20 underground fuel storage 

tanks. Each tank is 100 feet (30 meters) in diameter and 250 feet (76 meters) in height and can 

store 12.5 million U.S. gallons (47.3 million liters) of fuel, for a total storage capacity of 

approximately 250 million U.S. gallons (946 million liters). The fuel stored at the Red Hill 

facility is used by ships and aircraft based at JBPHH. The facility's location within the Red Hill 

ridge, about 2.5 miles (4.0 kilometers) from Pearl Harbor, was selected to allow fuel to flow 

from the storage tanks to Pearl Harbor by gravity (see Figure 6). 

Pearl Harbor 

Pearl Harbor is 8 miles (13 kilometers) from Honolulu, Oahu, HI. Naval Station Pearl Harbor 

provides berthing and shore side support to surface ships and submarines, as well as maintenance 

and training. Pearl Harbor can accommodate the largest ships in the fleet, including for dry dock 

services, and is now home to over 160 commands. The Harbor is home to a wide variety of ship 

and vessel classifications, ranging from military ships to locally owned crafts (Navy 2023). 

West Oahu 

The West Oahu, HI receiving location is Seven Point Multipoint Mooring System located 2 

miles (3.2 kilometers) offshore of Barbers Point. Fuel transfer is through an offshore mooring 
14 

that transfers oil and refined products through a hose between a buoy and commercial 

refinery/storage facilities onshore (NAVFAC 2023). 

Figure 6. JBPHH Red Hill Fuel Locations (NAVFAC 2023)

Naval Base Point Loma, California 

Naval Base Point Loma located on San Diego Bay in San Diego, California, provides support to 

U.S. Pacific Fleet afloat and shore-based tenant commands. Port Operation’s primary focus is to 

provide safe, efficient, and timely hotel services to home-ported and visiting submarines, surface 

ships, and mine counter vessels. The secondary mission includes a facility response team that 

provides immediate oil spill response for over 4 square nautical miles (7.4 square nautical 

kilometers) of San Diego Bay (NAVFAC 2023). 

The Port of San Diego, established in 1962, is responsible for the management of San Diego Bay 

and 34 miles of waterfront, serving 5 member cities (Chula Vista, Coronado, Imperial Beach, 

National City, and San Diego). The Port of San Diego oversees 2 maritime cargo terminals, 2 

cruise ship terminals, 16 public parks, various wildlife reserves and environmental initiatives, a 

Harbor Police Department, and the leases of 600 tenant businesses around San Diego Bay 

(NAVFAC-SW 2013). 

Selby Terminal, California

The Selby Terminal is a deep-water terminal located in northern California, within the San Pablo 

Bay. The Selby Terminal serves as a critical facility for the storage, handling, and distribution of 

various refined petroleum products, such as gasoline, diesel, jet fuel, and other fuels. The 

terminal includes storage tanks, loading and unloading facilities, and related infrastructure to 

handle the movement of petroleum products to and from tanker trucks, railcars, and barges. 
15 

Selby Terminal, located in the north of San Pablo Bay, is a shallow tidal estuary that forms the 

northern extension of the San Francisco Bay. Its waters are a mixture of fresh waters from the 

Sacramento, San Joaquin, Petaluma and Napa rivers, as well as the Central Valley, and saltwater 

from the Pacific Ocean (NAVFAC 2023). 

Port of Vancouver, Washington 

Port of Vancouver in Washington State is a significant seaport on the Columbia River that 

handles a variety of cargo, including petroleum and fuel products. The port serves as a vital 

transportation hub for the region, connecting industries and communities to global markets. 

The Port of Vancouver contains numerous fueling facilities and storage depots for petroleum 

products, including gasoline, diesel, and other fuels. The Port of Vancouver is a deep-water port 

located 106 miles (170 kilometers) from the Pacific Ocean. It is on over 2,000 acres (8.0 

kilometers squared) along the Columbia River. The Port is comprised of 5 terminals and 13 

berths. With between 400 and 500 vessel calls, this port handles 8 million tons of cargo, annually 

(NAVFAC 2023). 

The Hayden Island-Columbia River is listed as impaired for fish and aquatic life, fishing, private 

domestic water supply, and public domestic water supply with issues identified as temperature 

and total dissolved gas, pesticides, dioxins, PCBs and polycyclic aromatic hydrocarbons (EPA, 

2022d). 

Manchester, Washington Naval Base Kitsap 

The Manchester Fuel Depot, part of Naval Base Kitsap, is managed by the Navy’s Fleet 

Logistics Center Puget Sound Fuel Department and, sits on approximately 2 miles (3.2 

kilometers) of Puget Sound shoreline and is approximately 7 miles (11.2 kilometers) west of 

Seattle, Washington. Naval Base Kitsap is a major naval installation located on the Kitsap 

Peninsula. It is the third-largest Navy base in the U.S. and serves as a homeport for a significant 

portion of the U.S. Pacific Fleet. The base provides support to various surface ships, submarines, 

and aircraft, as well as playing a crucial role in supporting strategic nuclear deterrence 

(NAVFAC 2023). 

The Navy's Fleet Logistics Center Puget Sound (FLC PS) Fuel Department is one of the units 

operating within Naval Base Kitsap. It is responsible for managing and operating the fueling 

facilities that supply fuel to naval vessels and aircraft in the Puget Sound region. FLC PS Fuel 

Department ensures the safe storage, handling, and distribution of various types of fuels required 

by naval assets, including aviation fuel, marine diesel fuel, and other petroleum products. These 

fuels are essential for maintaining the readiness and mobility of the Navy's vessels and aircraft 

based at Naval Base Kitsap and other facilities in the area (NAVFAC 2023). 

U.S. Naval Fueling Station Sasebo, Sasebo, Japan 

Naval Base Fuel Depot Sasebo is a strategically important facility located in Sasebo, Japan. It 

serves as a critical storage and distribution center for fuel and petroleum products to support the 
16 

operations of the United States Navy in the Indo-Pacific region. The depot plays a vital role in 

ensuring the readiness and mobility of naval assets, including warships and aircraft, operating in 

the area. Its strategic location in close proximity to major shipping routes and potential conflict 

zones enhances its significance for naval logistics and operations. As a result, it is subject to 

stringent security measures and operates in coordination with the Japanese government to 

maintain regional stability and readiness. Aside from the naval berths, the port area is home to 

numerous heavy industries and has berths for tanker operations. It is a busy fishing and 

commercial port, and it is home to shipbuilding and related industries that dominate the local 

economy. Approximately 200 vessels visit the port annually (NAVFAC 2023). 

Subic Bay, Philippines 

Subic Bay is a bay on the west coast of the island of Luzon in the Philippines, about 62 miles 

northwest of Manila Bay. Its shores were formerly the site of a major United States Navy 

facility, U.S. Naval Base Subic Bay. After the closure of the U.S. naval base in 1992, the port 

was turned over to the Philippine government, and is now managed by the Subic Bay 

Metropolitan Authority as an industrial and commercial area known as the Subic Bay Freeport 

Zone. Fuel transfer at the Subic Bay Freeport Zone would occur at the Port POL (Petroleum, Oil, 

Lubricants) Pier. The fuel port serves as a critical logistics center for the Philippine Navy and 

visiting foreign naval forces in the region. It plays a crucial role in ensuring the energy supply 

and operational readiness of naval ships and aircraft in the Indo-Pacific area. Due to its strategic 

location, the port continues to be of regional importance and contributes to maritime security and 

stability in Southeast Asia. It operates under strict security protocols and adheres to international 

environmental standards to maintain the safety and sustainability of its operations (NAVFAC 

2023). 

Port of Singapore, Singapore 

The Port of Singapore is currently the world's second-busiest port in terms of total shipping 

tonnage. It also transships a fifth of the world's shipping containers, half of the world's annual 

supply of crude oil, and is the world's busiest transshipment port. The Singapore Bunkering 

Anchorage is a critical refueling point for vessels passing through the Strait of Malacca, one of 

the world's busiest and most important shipping lanes. It is strategically situated in the southern 

part of Singapore's territorial waters, offering a safe and convenient location for ships to take on 

fuel supplies. The fueling pier operates 24/7 and serves a wide range of vessels, including 

container ships, tankers, bulk carriers, and other types of maritime traffic. Vessels can obtain 

various types of marine fuels, such as fuel oil and marine gas oil, from licensed bunker suppliers 

operating in the area. The Singapore Bunkering Anchorage is known for its efficient bunkering 

operations, high-quality fuel products, and strict adherence to international safety and 

environmental standards. It plays a crucial role in supporting global trade by ensuring vessels 

have access to reliable and timely refueling services during their voyages through the region 

(NAVFAC 2023). 
17 

Port of Darwin, Darwin, Australia 

Port of Darwin, located in Australia's Northern Territory, is a significant seaport that handles 

various types of cargo, including fuel and petroleum products. The port is strategically 

positioned, serving as a gateway to Australia's northern regions and providing access to 

international trade routes. The fuel piers in the Port of Darwin are essential facilities for the 

efficient and safe handling of fuel shipments. They are equipped to accommodate a wide range 

of vessels, including tankers, cargo ships, and naval vessels, ensuring a steady supply of fuel for 

local consumption and supporting the needs of passing ships. The fuel piers are operated by 

specialized terminal operators or fuel suppliers who adhere to strict safety and environmental 

regulations. These regulations are established by the Australian government and international 

authorities to ensure the proper handling and transportation of hazardous materials. The Port of 

Darwin's fuel piers also play a crucial role in supporting the region's economic and defense 

activities, as they facilitate the refueling of commercial vessels, military assets, and other 

maritime vehicles operating in the area (NAVFAC 2023). 

ESA-listed Species and Designated Critical Habitat that May Be Affected

The ESA-listed species and designated critical habitat within the action area that may be affected 

by the proposed action are shown in Table 2 below. 

Table 2. ESA-listed species and critical habitat that may be affected by the proposed action

Species ESA Status Critical Habitat Recovery Plan 

Marine Mammals – Cetaceans 

Blue Whale (Balaenoptera musculus) E – 35 FR 18319 -- -- 07/1998 

10/2018 

Fin Whale (Balaenoptera physalus) E – 35 FR 18319 -- -- 75 FR 47538 

07/2010 

Gray Whale (Eschrichtius robustus) – 

Western North Pacific DPS 

E – 35 FR 18319 -- -- -- -- 

Humpback Whale (Megaptera 

novaeangliae) – Central America DPS 

E – 81 FR 62259 86 FR 21082 11/1991 

Humpback Whale (Megaptera 

novaeangliae) – Mexico DPS 

T – 81 FR 62259 86 FR 21082 11/1991 

Humpback Whale (Megaptera 

novaeangliae) – Western North Pacific DPS 

E – 81 FR 62259 86 FR 21082* 11/1991 

Killer Whale (Orcinus orca) – Southern 

Resident killer whales DPS 

E – 70 FR 69903 

Amendment 80 FR 

7380 

71 FR 69054 

86 FR 41668 

73 FR 4176 

01/2008 

North Pacific Right Whale 

(Eubalaena japonica) 

E – 73 FR 12024 73 FR 19000* 78 FR 34347 

06/2013 
18 

Species ESA Status Critical Habitat Recovery Plan 

Sei Whale (Balaenoptera borealis) E – 35 FR 18319 -- -- 12/2011 

Sperm Whale (Physeter macrocephalus) E – 35 FR 18319 -- -- 75 FR 81584 

12/2010 

False Killer Whale (Pseudorca crassidens) 

– Main Hawaiian Islands Insular DPS 

E – 77 FR 70915 83 FR 35062 -- -- 

Southern Right Whale (Eubalaena 

australis) (foreign) 

E – 35 FR 18319 -- -- -- -- 

Marine Mammals – Pinnipeds 

Guadalupe Fur Seal (Arctocephalus 

townsendi) 

T – 50 FR 51252 -- -- -- -- 

Steller Sea Lion (Eumetopias jubatus) – 

Western DPS 

E – 55 FR 49204 58 FR 45269* 73 FR 11872 

2008 

Hawaiian Monk Seal (Neomonachus 

schauinslandi) 

E – 41 FR 51611 80 FR 50925 72 FR 46966 

2007 

Spotted Sea (Phoca largha Southern DPS 

Threatened (foreign) 

75 FR 65239 -- -- -- -- 

Marine Reptiles 

Leatherback Turtle (Dermochelys coriacea) E – 35 FR 8491 44 FR 17710 and 77 

FR 4170 

05/1998 – U.S. 

Pacific 

Green Turtle (Chelonia mydas) – Central 

North Pacific DPS 

T – 81 FR 20057 -- -- 63 FR 28359 

Green Turtle (Chelonia mydas) – Central 

West Pacific DPS 

E – 81 FR 20057 -- -- 63 FR 28359 

Green Turtle (Chelonia mydas) – East 

Pacific DPS 

T – 81 FR 20057 -- -- 63 FR 28359 

Green Turtle (Chelonia mydas) – Central 

South Pacific DPS 

E – 81 FR 20057 -- -- 63 FR 28359 

Green Turtle (Chelonia mydas) – East 

Indian – West Pacific DPS (foreign) 

T – 81 FR 20057 -- -- 63 FR 28359 

Green Turtle (Chelonia mydas) – Southwest 

Pacific DPS (foreign) 

T – 81 FR 20057 -- -- 63 FR 28359 

Hawksbill Turtle (Eretmochelys imbricata) E – 35 FR 8491 

-- -- 

63 FR 28359 and 

05/1998 – U.S. 

Pacific 

Loggerhead Turtle (Caretta caretta) – North 

Pacific Ocean DPS 

E – 76 FR 58868 -- -- 63 FR 28359 

Loggerhead Turtle (Caretta caretta) – 

Southeast Indo-Pacific Ocean DPS (foreign) 

T – 76 FR 58868 -- -- 63 FR 28359 
19 

Species ESA Status Critical Habitat Recovery Plan 

Loggerhead Turtle (Caretta caretta) – South 

Pacific Ocean DPS (foreign) 

E – 76 FR 58868 -- -- 63 FR 28359 

Olive Ridley Turtle (Lepidochelys olivacea) 

All Other Areas 

T – 43 FR 32800 -- -- -- -- 

Olive Ridley Turtle (Lepidochelys olivacea) 

Mexico's Pacific Coast Breeding Colonies 

E – 43 FR 32800 -- -- 63 FR 28359 

Dusky Sea Snake (Aipysurus fuscus) –

(foreign) 

80 FR 60560 -- -- -- -- 

Fishes 

Bocaccio (Sebastes paucispinis) – Puget 

Sound/Georgia Basin DPS 

E – 75 FR 22276 

and 82 FR 7711 

79 FR 68041 81 FR 54556 

10/2017 

Chinook salmon (Oncorhynchus 

tshawytscha) – California Coastal ESU 

T – 70 FR 37160 70 FR 52488* 81 FR 70666 

Chinook salmon (Oncorhynchus 

tshawytscha) – Central Valley Spring-Run 

ESU 

T – 70 FR 37160 70 FR 52488* 79 FR 42504 

Chinook salmon (Oncorhynchus 

tshawytscha) – Lower Columbia River ESU 

T – 70 FR 37160 70 FR 52629 78 FR 41911 

Chinook salmon (Oncorhynchus 

tshawytscha) – Puget Sound ESU 

T – 70 FR 37160 70 FR 52629 72 FR 2493 

Chinook salmon (Oncorhynchus 

tshawytscha) – Sacramento River WinterRun ESU 

E – 70 FR 37160 58 FR 33212 79 FR 42504 

Chinook salmon (Oncorhynchus 

tshawytscha) – Snake River Fall-Run ESU 

T – 70 FR 37160 58 FR 68543 80 FR 67386 (Draft) 

Chinook salmon (Oncorhynchus 

tshawytscha) – Snake River Spring/Summer 

Run ESU 

T – 70 FR 37160 64 FR 57399 81 FR 74770 (Draft) 

11-2017-Final 

Chinook salmon (Oncorhynchus 

tshawytscha) – Upper Columbia River 

Spring-Run ESU 

E – 70 FR 37160 70 FR 52629 72 FR 57303 

Chinook salmon (Oncorhynchus 

tshawytscha) – Upper Willamette River 

ESU 

T – 70 FR 37160 70 FR 52629 76 FR 52317 

Chum salmon (Oncorhynchus keta) – 

Columbia River ESU 

T – 70 FR 37160 70 FR 52629 78 FR 41911 

Chum salmon (Oncorhynchus keta) – Hood 

Canal Summer-Run ESU 

T – 70 FR 37160 70 FR 52629 72 FR 29121 

Coho salmon (Oncorhynchus kisutch) – 

Central California Coast ESU 

E – 70 FR 37160 64 FR 24049* 77 FR 54565 
20 

Species ESA Status Critical Habitat Recovery Plan 

Coho salmon (Oncorhynchus kisutch) – 

Lower Columbia River ESU 

T – 70 FR 37160 81 FR 9251 78 FR 41911 

Coho salmon (Oncorhynchus kisutch) – 

Oregon Coast ESU 

T – 73 FR 7816 73 FR 7816* 81 FR 90780 

Coho salmon (Oncorhynchus kisutch) – 

Southern Oregon and Northern California 

Coasts ESU 

T – 70 FR 37160 64 FR 24049* 79 FR 58750 

Eulachon (Thaleichthys pacificus) –

Southern DPS 

T – 75 FR 13012 76 FR 65323 9/2017 

Green Sturgeon (Acipenser medirostris) – 

Southern DPS 

T – 71 FR 17757 74 FR 52300 2010 (Outline) 

8/2018- Final 

Sockeye salmon (Oncorhynchus nerka) – 

Ozette Lake ESU 

T – 70 FR 37160 70 FR 52630* 74 FR 25706 

Sockeye salmon (Oncorhynchus nerka) – 

Snake River ESU 

E – 70 FR 37160 58 FR 68543 80 FR 32365 

Steelhead (Oncorhynchus mykiss) – 

California Central Valley DPS 

T – 71 FR 834 70 FR 52487* 79 FR 42504 

Steelhead (Oncorhynchus mykiss) – Central 

California Coast DPS 

T – 71 FR 834 70 FR 52487* 81 FR 70666 

Steelhead (Oncorhynchus mykiss) – Lower 

Columbia River DPS 

T – 71 FR 834 70 FR 52629 78 FR 41911 

Steelhead (Oncorhynchus mykiss) – Middle 

Columbia River DPS 

T – 71 FR 834 70 FR 52629 74 FR 50165 

Steelhead (Oncorhynchus mykiss) – 

Northern California DPS 

T – 71 FR 834 70 FR 52487* 81 FR 70666 

Steelhead (Oncorhynchus mykiss) – Puget 

Sound DPS 

T – 72 FR 26722 81 FR 9251* 84 FR 71379 

Steelhead (Oncorhynchus mykiss) – Snake 

River Basin DPS 

T – 71 FR 834 70 FR 52629 81 FR 74770 (Draft) 

11-2017-Final 

Steelhead (Oncorhynchus mykiss) – SouthCentral California Coast DPS T – 71 FR 834 70 FR 52487* 78 FR 77430 

Steelhead (Oncorhynchus mykiss) – 

Southern California DPS 

E – 71 FR 834 70 FR 52487* 77 FR 1669 

Steelhead (Oncorhynchus mykiss) – Upper 

Columbia River DPS 

T – 71 FR 834 70 FR 52629 72 FR 57303 

Steelhead (Oncorhynchus mykiss) – Upper 

Willamette River DPS 

T – 71 FR 834 70 FR 52629 76 FR 52317 

Yelloweye Rockfish (Sebastes rubberimus) 

– Puget Sound/Georgia Basin DPS 

T – 75 FR 22276 

and 82 FR 7711 

79 FR 68041 81 FR 54556 (Draft) 

10/2017 

Giant Manta Ray (Manta birostris) T – 83 FR 2916 -- -- -- -- 
21 

Species ESA Status Critical Habitat Recovery Plan 

Oceanic Whitetip Shark (Carcharhinus 

longimanus) 

T – 83 FR 4153 -- -- -- -- 

Scalloped Hammerhead Shark (Sphyrna 

lewini) – Eastern Pacific DPS 

E – 79 FR 38213 -- -- -- -- 

Scalloped Hammerhead Shark (Sphyrna 

lewini) – Indo West Pacific DPS (foreign) 

E – 79 FR 38213 -- -- -- -- 

Banggai cardinalfish (Pterapogon 

kauderni)(foreign)

E- 81 FR 3023 -- -- -- -- 

Chinese Sturgeon (Acipenser sinensis) 

(foreign) 

E- 79 FR 31222 -- -- -- -- 

Sakhalin Sturgeon (Acipenser 

mikado)(foreign)

E- 79 FR 31222 -- -- -- -- 

Dwarf Sawfish (Pristis clavata) (foreign) E- 79 FR 73977 -- -- -- -- 

Green Sawfish (Pristis zijsron) (foreign) E- 79 FR 73977 -- -- -- -- 

Narrow Sawfish (Anoxypristis cuspidate) 

(foreign)

E- 79 FR 73977 -- -- -- -- 

Marine Invertebrates 

Black Abalone (Haliotis cracherodii) E – 74 FR 1937 76 FR 66805* -- -- 

White Abalone (Haliotis sorenseni) E – 66 FR 29046 -- -- 73 FR 62257 

Sunflower Sea Star (Pycnopodia 

helianthoides) 

T - 88 FR 16212 

(proposed) 

-- -- -- -- 

Chambered Nautilus (Nautilus pompilius) 

(foreign) 

T- 83 FR 48976 -- -- -- -- 

E=endangered; T=threatened; FR=Federal Register

* Indicates that designated critical habitat does not overlap with the action area

Analysis of Effects 

An action warrants a "may affect, not likely to adversely affect" finding when its effects are 

wholly beneficial, insignificant or discountable. Wholly beneficial effects have an immediate 

positive effect without any adverse effects to the species or habitat. Insignificant effects relate to 

the size or severity of the impact and include those effects that are undetectable, not measurable, 

or so minor that they cannot be meaningfully evaluated. That means the ESA-listed species may 

be exposed to stressors caused by the action, but the response would not be measurable. 

Discountable effects relate to the likelihood of a species or critical habitat being exposed to a 

stressor. For an effect to be discountable, it must be extremely unlikely to occur. 
22 

For the vessel-based stressors, our effects analysis is organized by taxa (i.e., marine mammals, 

marine reptiles, and fish) because the species within each taxa often respond to these stressors in 

similar ways. Differences among species within a given taxa, in terms of likelihood of exposure 

or anticipated types of response, are discussed, and we provide a more detailed effects analysis 

for some species within a taxa, as needed to reach our effects determination. For the marine 

invertebrates that may be affected by the proposed action (i.e., black abalone, white abalone, 

sunflower sea star, and chambered nautilus), there is no pathway to effects from vessel-based 

stressors (i.e., vessel noise, disturbance or strike) associated with the proposed action. 

For our analysis of the effects of an oil spill, we assess the likelihood of a spill occurring that 

would result in adverse effects to the marine environment. Because we determined that such a 

spill is extremely unlikely to occur (i.e., discountable), there was no need to further evaluate how 

ESA-listed species or critical habitat physical and biological features (PBFs) would respond to, 

or be adversely affected by, such a spill. 

Effects of Vessel Noise and Visual Disturbance 

Vessel transits as part of the proposed action will contribute to elevated underwater sound levels 

as vessel traffic increases, and have the potential to impact ESA-listed marine mammals, sea 

turtles, sea snakes, and fishes within the action area. Potential impacts of vessel noise on ESAlisted species include masking of other biologically relevant sounds, physiological stress, and 

changes in behavior. Masking occurs when one sound (i.e., noise), interferes with the detection, 

discrimination, or recognition of another sound (i.e., signal). The quantitative definition of 

masking is the amount, in decibels, an auditory detection or discrimination threshold is raised in 

the presence of a masker (Erbe et al. 2015). Masking can effectively limit the distance over 

which a marine mammal can communicate, detect biologically relevant sounds, and echolocate 

(Navy 2019). Masking only occurs in the presence of the masking noise and does not persist 

after the cessation of the noise. 

In addition to sound, vessels associated with the proposed action may cause visual disturbances 

to ESA-listed species that spend time near the surface, such as marine reptiles and marine 

mammals, and more generally disrupt their behavior. In many cases, particularly when responses 

are observed at great distances, it is thought that animals are likely responding to sound more 

than the visual presence of vessels. Nonetheless, it is generally not possible to distinguish 

responses to the visual presence of vessels from those to the noise associated with vessels. 

Moreover, at close distances, animals may not even differentiate between visual and acoustic 

disturbances created by vessels and simply respond to the combined disturbance. 

Vessel noise can result from several sources including propeller cavitation, vibration of 

machinery, flow noise, structural radiation, and auxiliary sources such as pumps, fans and other 

mechanical power sources. Kipple and Gabriele (2007) measured sounds emitted from 38 vessels 

ranging in size from 14 to 962 feet at speeds of 10 knots and at a distance of 500 yards (457.2 

meters) from the hydrophone. Sound levels ranged from a minimum of 157 to a maximum of 
23 

182 decibels re one micro pascal (182 dB re 1 μPa-m), with sound levels showing an increasing 

trend with both increasing vessel size and with increasing vessel speed. Vessel sound levels also 

showed dependence on propulsion type and horsepower. 

Sounds emitted by large vessels, including tanker ships, can be characterized as low frequency, 

continuous, or tonal, and Sound Pressure Levels at a source will vary according to speed, burden, 

capacity and length (Richardson et al. 1995b; Kipple and Gabriele 2007; McKenna et al. 2012). 

Typical large vessel-radiated noise is dominated by tonals related to blade and shaft sources at 

frequencies below 50 Hertz (Hz) and by broadband components related to cavitation and flow 

noise at higher frequencies (approximately around the one-third octave band centered at 100 Hz; 

(Urick 1983; Richardson et al. 1995a; Mintz and Filadelfo 2011; MacGillivray et al. 2019). Ship 

types also have unique acoustic signatures characterized by differences in dominant frequencies. 

Bulk carrier noise is predominantly near 100 Hz while container ship and tanker noise is 

predominantly between 40 and 60 Hz (McKenna et al. 2012). Tankers have less acoustic energy 

in frequencies above 300 Hz, unlike the container and bulk carrier. Sound produced by vessels 

will typically increase with speed (MacGillivray et al. 2019; Wladichuk et al. 2019). During 

transit, the tanker ships for the proposed action will operate at speeds around 15 knots or 15 

nautical miles per hour (NAVFAC 2023). 

As part of the proposed action, a maximum of 11 tanker ship transits will occur from the Pearl 

Harbor fueling pier to one of the receiving ports shown in Table 1. Sound levels within Pearl 

Harbor will be elevated because of the transit of these tankers and by the tugboats used to guide 

the tankers through the harbor. A maximum of 2 tankers will be loaded per week (NAVFAC 

2023). Pearl Harbor is home to a wide variety of ship and vessel classifications, ranging from 

large military ships to locally owned crafts, and is one of the Navy’s busiest ports, completing 

about 65,000 boat runs and transporting 2.4 million passengers between Ford Island and other 

harbor locations, annually (NAVFAC 2023). In addition, tankers and cargo ships routinely 

transit through Pearl Harbor. Given the relatively low level of vessel activity for the proposed 

action, it is unlikely that the proposed action will have an appreciable impact on ambient noise 

levels above the already elevated baseline noise levels in Pearl Harbor. Outside of Pearl Harbor, 

vessel noise resulting from the proposed action will be widely dispersed in the open ocean along 

the transit routes to the 9 potential receiving port locations. While vessel noise within the 

receiving ports will increase because of the proposed action, most ports will receive a maximum 

of 2 tankers. Three potential receiving ports could receive up to 5 or 6 tankers, no more than 2 

per week, because of the proposed action: West Oahu, Hawaii; Subic Bay, Philippines; and Port 

of Singapore. Similar to Pearl Harbor, we do not anticipate that this small number of tanker 

transits will have an appreciable impact on ambient noise levels above the already elevated 

baseline noise levels in these receiving port locations. The shipping channels leading into and out 

of the proposed receiving ports are already heavily trafficked by large commercial ships. As 

such, noise from 2 to 6 additional tankers (and no more than 2 tankers per port per week) is not 

expected to substantially increase noise levels above background or ambient conditions. 
24 

Marine Mammals 

Odontocetes have been shown to make short-term changes to vocal parameters such as intensity 

(Holt et al. 2008) as an immediate response to vessel noise, as well as increase the pitch, 

frequency modulation, and length of whistling (May-Collado and Wartzok 2008). Likewise, 

modification of multiple vocalization parameters has been shown in belugas residing in an area 

known for high levels of commercial traffic. These animals decreased their call rate, increased 

certain types of calls, and shifted upward in frequency content in the presence of small vessel 

noise (Lesage et al. 1999). Another study detected a measurable increase in the amplitude of 

their vocalizations when ships were present (Scheifele et al. 2005). Killer whales off the 

northwestern coast of the U.S. have been observed to increase the duration of primary calls once 

a threshold in observed vessel density (e.g., whale watching) was reached, which has been 

suggested as a response to increased masking noise produced by the vessels (Foote et al. 2004). 

Mysticetes have been shown to both increase and decrease calling behavior in the presence of 

vessel noise. An increase in feeding call rates and repetition by humpback whales in Alaskan 

waters was associated with vessel noise (Doyle et al. 2008). Melcon et al. (2012) documented 

that blue whales increased the proportion of time spent producing certain types of calls when 

vessels were present. Conversely, decreases in singing activity by humpback whales have been 

noted near Brazil due to boat traffic (Sousa-Lima and Clark 2008). Based on passive acoustic 

recordings and, in the presence of sounds from passing vessels, Melcon et al. (2012) reported 

that blue whales had an increased likelihood of producing certain types of calls. Castellote et al. 

(2012) demonstrated that fin whales’ songs had shortened duration and decreased bandwidth, 

center frequency, and peak frequency in the presence of high shipping noise levels. It is not 

known if these changes in vocal behavior corresponded to other behaviors. Right whales were 

observed to shift the frequency content of their calls upward while reducing the rate of calling in 

areas of increased anthropogenic noise (Parks et al. 2007) as well as increasing the amplitude 

(intensity) of their calls (Parks 2009; Parks et al. 2011). Although humpback whales off Australia 

did not change the frequency or duration of their vocalizations in the presence of ship noise, their 

source levels were lower than expected based on source level changes to wind noise, potentially 

indicating some signal masking (Dunlop 2016). Increased vessel noise decreased the modeled 

acoustic communication area of humpback whales off Australia and group social interactions 

were significantly reduced in number (Dunlop 2019). Clark et al. (2009) estimated the noise 

from the passage of 2 vessels could reduce the optimal communication space for North Atlantic 

right whales by 84 percent (see also Hatch et al. 2012). 

Pinniped reactions to vessels are variable and reports include a wide spectrum from avoidance 

and alert, to cases where animals in the water are attracted, and cases on land where there is lack 

of significant reaction suggesting habituation to or tolerance of vessels (Richardson et al. 1995b). 

Specific case reports in Richardson et al. (1995b) vary based on factors such as routine 

anthropogenic activity, distance from the vessel, engine type, wind direction, and ongoing 
25 

subsistence hunting. As with reactions to sound reviewed by Southall et al. (2007), pinniped 

responses to vessels are affected by the context of the situation and by the animal’s experience. 

The available information, as discussed above, suggests that marine mammals are either not 

likely to respond or are expected to respond only briefly if exposed to noise from tanker ships. 

The estimated sound levels for the tanker ships used to relocate fuel as part of the proposed 

action are significantly lower than the thresholds for continuous sound likely to cause hearing 

loss, long-term injury or significant behavioral effects in marine mammals. Expected behavioral 

responses include brief avoidance behavior, changes in respiration rate, or changes in vocal 

patterns. Most avoidance responses would consist of slow movements away from vessels the 

animals perceive are on an approaching course, perhaps accompanied by slightly longer dives. 

Most of the changes in behavior would consist of a temporary shift from behavioral states that 

have low energy requirements (resting or milling) to behavioral states with higher energy 

requirements (active swimming or traveling) and then returning to the resting or milling 

behavior. 

We expect individuals that exhibit a temporary behavioral response will return to baseline 

behavior immediately following exposure to the vessel noise. For behavioral responses to result 

in energetic costs that result in long-term harm, such disturbances need to be sustained for a 

significant duration or extent where individuals exposed would not be able to select alternate 

habitat to recover and feed. Given the small amount of vessel activity proposed, and the 

temporally and spatially dispersed nature of this potential stressor, we do not expect prolonged 

vessel noise exposures or preclusion of individuals from feeding, breeding, or sheltering habitat. 

For these reasons, and given the short duration of vessel noise stressors and the infrequency of 

this stressor, we do not expect marine mammal reactions to vessel noise to have any measurable 

adverse effects to individuals exposed to this stressor. 

In summary, ESA-listed marine mammals are either not likely to respond to vessel noise or 

visual disturbance resulting from the proposed action or, if they do respond, the response will not 

likely result in a measureable disruption of normal behavior patterns, which include, but are not 

limited to, breeding, feeding or sheltering. Additionally, any temporary masking from tanker 

ships or tugboats are expected to be of short duration and not result in changes to an animal’s 

ability to communicate or detect biologically relevant cues. The background noise levels in the 

action area independent of the proposed action mean the small percentage of vessel traffic the 

proposed tankers and tugboats represent in the action area will not measurably increase sound 

levels. Therefore, the effects of vessel noise and visual disturbance on ESA-listed marine 

mammals from vessel activity as part of the proposed action are considered insignificant. Thus, 

we concur with JTFRH and DLA that this stressor may affect, but is not likely to adversely affect 

ESA-listed marine mammals in the action area. 
26 

Marine Mammal Critical Habitat 

Next, we consider the effects of vessel sound resulting from the proposed action on designated 

critical habitat for ESA-listed marine mammals. Of the species that may be affected by the 

proposed action (see Table 2), we found only one that has a PBF of critical habitat with a sound 

component that may be affected by vessel noise. Critical habitat for the Main Hawaiian Island 

insular false killer whale was designated on July 24, 2018, with an effective date of August 23, 

2018 (83 FR 35062). The designation includes waters from the 45 meter depth contour to the 

3,200 meter depth contour around the Main Hawaiian Islands. Parts of the designation are 

excluded for national security or economic reasons (Figure 7). 

The designated critical habitat includes one PBF essential for conservation of the species, with 

the following four characteristics: 

1. Adequate space for movement and use within shelf and slope habitat. 

2. Prey species of sufficient quantity, quality, and availability to support individual growth, 

reproduction, and development, as well as overall population growth. 

3. Waters free of pollutants of a type and amount harmful to Main Hawaiian Island insular 

false killer whales. 

4. Sound levels that would not significantly impair false killer whales’ use or occupancy 

(NMFS 2018b). 

There is no pathway to effects from the stressor vessel sound to the first 3 characteristics shown 

above. Regarding the characteristic specific to sound levels (#4 above), the final rule to designate 

critical habitat further defined this feature as sound levels that inhibit the Main Hawaiian Island 

insular false killer whale’s “...ability to receive and interpret sound for the purposes of 

navigation, communication, and detection of predators and prey. Such noises are likely to be 

longఆlasting, continuous, and/or persistent in the marine environment and, either alone or added 

to other ambient noises, significantly raise local sound levels over a significant portion of an 

area” (83 FR 35062). 

The final biological report developed in support of the final rule discussed the complexity of 

analyzing how human activities may change an animal’s use of an area (NMFS 2018b). The 

biological report emphasized that “...the duration of the offending or masking noise will 

determine whether the effects or degradation to the habitat may be temporary or chronic, and 

whether such alterations to the soundscape may alter the conservation value of that habitat” 

(NMFS 2018b). 
27 

Figure 7. Designated critical habitat for Main Hawaiian Islands Insular DPS false killer whale (NMFS 

2018b). 

The introduction of a permanent or chronic noise source can degrade the value of habitat by 

interfering with the sound-reliant animal’s ability to gain benefits from that habitat, impeding 

reproduction, foraging, or communication (i.e., altering the conservation value of the habitat; 83 

FR 35062). However, for the proposed action, any vessel sound that could be introduced into 

false killer whale critical habitat would be short-term and temporary. Our analysis of the effects 

of vessel sound on marine mammal species concluded ESA-listed marine mammals in the action 

area (including the Main Hawaiian Island insular false killer whale) are either not likely to 

respond to vessel noise or, if they do respond, the response is not likely to result in a measureable 

disruption of normal behavior patterns. We based this conclusion on the temporally and spatially 

dispersed nature of this potential stressor, and thus determine that vessel noise from this action 

will not result in disruptions of normal behavior patterns or masking that could be meaningfully 

evaluated. We do not anticipate vessel noise to generate sounds that would significantly impair 

false killer whales’ use or occupancy by inhibiting their ability to receive and interpret sound for 

the purposes of navigation, communication, and detection of predators and prey. Therefore, 

effects of vessel noise on the sound level characteristic of the PBF of Main Hawaiian Island 

insular false killer whale designated critical habitat are so minor that the effects cannot be 

meaningfully evaluated, and are thus insignificant. We concur with JTFRH and DLA that the 
28 

effects of vessel noise resulting from the proposed action may affect, but are not likely to 

adversely affect Main Hawaiian Island insular false killer whale designated critical habitat. 

Marine Reptiles 

Sea turtles and sea snakes could be exposed to a range of vessel noises within their hearing 

capabilities. Compared to marine mammals that are highly adapted to use sound in the marine 

environment, marine reptiles are less dependent on sound and their hearing is more limited in 

range to very low frequencies. Depending on the context of exposure, responses of sea turtles 

and sea snakes in the action area to vessel noise disturbance could include startle responses, 

avoidance, or other behavioral reactions, physiological stress responses, or no measurable 

response at all. 

Limited information is available on how or if marine reptiles may respond to noise from tanker 

ships or tugboats. Hazel et al. (2007) suggested that sea turtles may rely more on visual than 

auditory cues when reacting to approaching vessels. Additionally, there is evidence that reptiles 

may rely primarily on senses other than hearing for interacting with their environment, such as 

vision (Narazaki et al. 2013) and magnetic orientation (Avens and Lohmann 2003; Putman et al. 

2015). This suggests that, if sea turtles were to respond to a vessel, the animals might not 

respond to the vessel based on noise alone. Popper et al. (2014) noted that available information 

on the effects of vessel noise or other continuous sounds on sea turtles is lacking. The only 

potential effect Popper et al. (2014) suggested could occur from vessel noise was a behavioral 

response or masking, with a higher likelihood of a behavioral response occurring the closer the 

sea turtle is to the vessel. Any masking of biologically important sounds for sea turtles and sea 

snakes would be temporary, occurring only when a vessel and sea turtle or sea snake are in close 

proximity to one another. The short, temporary exposure to vessel noise would not have any 

measurable effects on individuals, if exposed. 

If a sea turtle or sea snake responded behaviorally to noise from a tanker or tugboat, most 

responses would consist of slow movements away from vessels the animals perceive are on an 

approaching course. Changes in behavior would likely consist of a temporary shift from 

behavioral states that have low energy requirements (resting or milling) to behavioral states with 

higher energy requirements (foraging, active swimming or traveling) and then returning to the 

resting or milling behavior shortly thereafter. Any behavioral responses to vessel noise are 

expected to be temporary (e.g., a startle response, brief avoidance behavior) and we do not 

expect these reactions to have any measurable effects on individuals. We expect individual sea 

turtles and sea snakes that exhibit a temporary behavioral response will return to baseline 

behavior immediately following exposure to the vessel noise. 

For these reasons, vessel noise and visual disturbance are expected to cause minimal disturbance 

to ESA-listed sea turtles and sea snakes. If a sea turtle or sea snake detects a vessel and avoids it, 

these responses are expected to be temporary while the vessel transits through the area where the 
29 

sea turtle or sea snake it is present. Marine reptile responses to vessel noise disturbance are 

expected to be minor, and a sea turtle or sea snake is expected to return to normal behaviors and 

baseline stress levels shortly after the vessel passes. As a result, we find that the likely effects 

from exposure to vessel noise and visual disturbance resulting from the proposed action on ESAlisted sea turtles and sea snakes are insignificant and, thus, we concur with JTFRH and DLA that 

this stressor may affect, but is not likely to adversely affect ESA-listed sea turtles and sea snakes. 

Fishes 

In general, information regarding the effects of vessel noise on fish hearing and behaviors is 

limited. All fish species can detect vessel noise because hearing range includes the lowfrequency content of this acoustic source. As a result, ESA-listed fishes could be exposed to a 

range of vessel noises, depending on the source and context of the exposure. Tanker ships 

produce low frequency, broadband underwater sound below 1 kHz. Sound produced from 

tankers is unlikely to result in direct injury, hearing impairment, or other trauma to fishes, given 

the general characteristics of vessel noise. In addition, in the near field, fish are able to detect 

water motion, as well as visually locate an oncoming vessel. In these cases, most fishes located 

in close proximity that detect the vessel visually, via sound, or water motion will be capable of 

avoiding the vessel or moving away from the area affected by vessel sound. Thus, fish are more 

likely to react to vessel noise at close range than to vessel noise emanating from a greater 

distance. These reactions may include physiological stress responses, or avoidance behaviors. 

Vessel noise resulting from the proposed action would be intermittent, temporary and localized, 

and responses are not expected to compromise the general health or condition of individual fish. 

The only impacts expected from exposure to vessel noise for fishes would be temporary and 

short-term, and may include auditory masking, physiological stress, or minor changes in 

behavior. 

Vessel noise may affect fish behavior by causing them to startle, swim away from an occupied 

area, change swimming direction and speed, or alter schooling behavior (Engas et al. 1995; 

Engas et al. 1998; Mitson and Knudsen 2003). Physiological responses have also been 

documented for fish exposed to increased boat noise. Nichols et al. (2015) demonstrated 

physiological effects of increased noise (playback of boat noise) on coastal giant kelpfish. The 

fish exhibited stress responses when exposed to intermittent noise, but not to continuous noise. 

These results indicate variability in the acoustic environment may be more important than the 

period of noise exposure for inducing stress in fishes. However, other studies have also shown 

exposure to continuous or chronic vessel noise may elicit stress responses indicated by increased 

cortisol levels (Scholik and Yan 2001; Wysocki et al. 2006). These experiments demonstrate 

physiological and behavioral responses to various boat noises that could affect species’ fitness 

and survival but may also be influenced by the context and duration of exposure. It is important 

to note that most of these experimental exposures were continuous, not intermittent, and the fish 

were unable to avoid the sound source for the duration of the experiment because these were 

controlled studies. In contrast, wild fish are not hindered from movement away from a sound 
30 

source, and are less likely to be subjected to accumulation periods that lead to the onset of 

hearing damage as indicated in these studies. In other cases, fish may eventually become 

habituated to the changes in their soundscape and adjust to the ambient and background noises. 

Therefore, exposure to vessel noise for fishes could result in short-term behavioral or 

physiological responses (e.g., avoidance and stress). Given the small amount of vessel activity 

proposed, and the temporally and spatially dispersed nature of this potential stressor, we expect 

vessel noise would only result in brief periods of exposure for fishes. As such, we do not expect 

this stressor to accumulate to levels that would result in a detectable or measurable response. 

Therefore, the likely effects of vessel noise on ESA-listed fish in the action area are considered 

insignificant, and we concur with JTFRH and DLA that this stressor may affect, but is not likely 

to adversely affect ESA-listed fish. 

Effects of Vessel Strike 

Marine Mammals 

While all marine mammals are potentially at risk of vessel strike, based on historical records 

large whales are significantly more vulnerable to this stressor as compared to smaller cetaceans 

or pinnipeds. Their much smaller size and greater maneuverability make smaller cetaceans and 

pinnipeds less susceptible to vessel strike in general. Worldwide ship strike records that show 

strikes of smaller, more agile marine mammals from the shipping sector and larger vessels are 

extremely rare. Vessel strikes of Southern Resident killer whales are rare events given their small 

population size and the species’ maneuverability, although there have been 2 confirmed and 1 

probable occurrence since 2005. The 2 confirmed cases involved smaller vessels (tugboat and 

whale watching boat) operating within the inland waterways of the Salish Sea. We have no 

information regarding vessel strikes of Southern Resident killer whales by tanker ships or other 

large commercial vessels. No vessel-strike related injuries or deaths of false killer whales have 

been documented in Hawaiian waters (Carretta 2021), although Baird (2009) reported blunt 

trauma on one individual that may have been caused by a propeller strike. Similarly, there are no 

confirmed vessel strikes of Hawaiian monk seals on record, although, in 1986, 2 seals were 

found with injuries consistent with vessel strike trauma (Carretta 2021). We could not find any 

information regarding vessel strikes of Guadalupe fur seals in the action area, and vessel strike 

has not been identified as a cause of stranding of this species (McCue et al. 2021). Likewise, 

vessel strike is not identified as an important threat affecting Stellar sea lions in the NMFS 2008 

recovery plan for this species (NMFS 2008). In summary, vessel strike of the smaller ESA-listed 

cetaceans and pinnipeds occurring within the action area are very rare events. There are no 

historical records indicating that tanker ships have struck any of these species, and we could not 

find any information indicating that vessel strike from large commercial vessels represents a 

significant threat to these species. In addition, the Action Proponents have proposed to 

implement mitigation measures (see Best Management Practices above) to further minimize the 

risk of vessel strike to marine mammals in general. These include: operating tanker ships and 
31 

tugboats at speeds of 10 knots or less within Pearl Harbor (NAVFAC 2023); adhering to all 

voluntary speed restrictions in areas where the risk of vessel strikes is high (see Best 

Management Practices for details); and remaining at least 200 yards from marine mammals (500 

yards from whales) during vessel transits, to the extent practicable. Therefore, the likelihood of a 

Southern Resident killer whale, Main Hawaiian Island insular false killer whale, Hawaiian monk 

seal, Guadalupe fur seal, or Western DPS Stellar sea lion being struck by a vessel because of the 

proposed action is extremely unlikely, and thus considered discountable. 

The relative risk of a large whale vessel strike within a particular area is primarily a function of 

animal density and the magnitude of vessel traffic (e.g., Fonnesbeck et al. 2008; Vanderlaan et 

al. 2008). Other factors, such as vessel speed, size, and maneuverability can also influence both 

the probability of a vessel strike occurring and the outcome (i.e., minor injury, serious injury, 

mortality) when a strike occurs. In general, smaller vessels have greater maneuverability that 

allows them to change course more quickly to avoid a collision once a marine mammal is sighted 

on the surface. Vessel crew serving as lookouts on deck may also be more effective at spotting 

whales within the full 360-degree radius mitigation zone on smaller vessels as compared to 

larger vessels where the view of the water may be obstructed. Vessel configuration, number and 

location of lookouts, and lookout experience in sighting marine mammals are also factors that 

may determine the effectiveness of lookouts at mitigating vessel strike risk. Smaller vessels are 

more likely to anticipate head-on collisions by nature of the location of a forward bridge. The 

bridges of tankers and container ships are generally located hundreds of feet aft and are high 

above the water; this can result in a line of sight well beyond the bow that obscures the direct 

view in the immediate path of the vessel (Jensen and Silber 2003). Vessel size also plays a role 

in the anticipated outcome when a large whale vessel strike occurs. Kelley et al. (2021) found 

that, while vessels of all sizes can cause lethal injuries to whales, large vessels (i.e., greater than 

20 meters) produce much larger stresses even when travelling at reduced speeds (i.e., 10 knots). 

The tanker ships used to move fuel for the proposed action are medium-range type vessels that 

are approximately 600-feet long. Due to their large size, lower maneuverability, likely difficulty 

in observing whales within a full 360-degree radius mitigation zone around the ship, and smaller 

crew, the proposed tankers for this action represent the type of vessel with an elevated large 

whale strike risk. Jensen and Silber (2003) analyzed 292 records of known or probable ship 

strikes of all large whale species from 1975 to 2002. Of the 134 cases of known vessel type, they 

reported 8 cases (6.0%) from tankers. Captains of large ships, such as container ships, tankers, 

and cruise ships may not be aware that a collision with a whale has occurred and, thus, do not 

report the incident. It is also likely that some captains do not report known vessel strikes out of 

apathy or fear of enforcement consequences (Jensen and Silber 2003). While vessel strikes by 

tankers and other large vessels often go unnoticed by the crew, there have been recorded 

instances of tanker ships entering port with a whale carcass draped across their bow (Jensen and 

Silber 2003). 
32 

In addition to the volume of vessel traffic and vessel size, a correlation between vessel speed and 

the risk of striking a whale, and of killing a struck whale, has been shown in several studies. 

Laist et al. (2001) found a direct relationship between the occurrence of a whale strike and the 

speed of the vessel involved in the collision. Redfern et al. (2019), Rockwood et al. (2020) and 

Rockwood et al. (2021) developed ship strike models indicating that increased cooperation with 

voluntary vessel speed limits in shipping lanes near major California ports could substantially 

reduce whale-strike mortality rates. Slower moving vessels may allow whales increased 

opportunities for avoidance due to a combination of maneuverability and detection (Gende et al. 

2019). A faster vessel will travel a greater distance compared to a slower moving vessel over a 

set period, such as when whales are submerged between surfacing events, on deep dives, or 

during time lags related to decision-making and communications on the bridge following 

detection (Gende et al. 2019). These factors can all result in an increased susceptibility of large 

whales to vessel strike with increasing vessel speed. Vessel speed can also influence whale 

avoidance by influencing detection probability. Case studies of large whale behavioral avoidance 

suggest that blue whales may respond to close encounters with large vessels by altering their 

diving behavior rather than moving horizontally at the surface (McKenna et al. 2015; Szesciorka 

et al. 2019). In one case study of a close vessel encounter with a blue whale, Szesciorka et al. 

(2019) noted that the ship’s reduced speed (i.e., 11.3 knots) may have played a role by giving the 

whale enough time to respond to the nearby vessel. A behavioral dive response may not be as 

effective at avoiding vessels traveling at higher speeds (McKenna et al. 2015). Higher vessel 

speeds increase the risk that a whale could have been struck at the surface or get close enough to 

the ship’s draft that the propeller suction effect created by the ship’s hydrodynamic flow could 

pull the whale toward the hull (Szesciorka et al. 2019). A whales’ behavioral state has been 

shown to influence the context-dependent behavioral response to acoustic stressors. Feeding 

whales are more likely to be distracted and, thus, may be less capable of detecting and avoiding 

approaching vessels (Szesciorka et al. 2019). 

Some whale populations within the action area are more vulnerable than others to vessel strikes, 

largely based on differences in distribution relative to shipping traffic (NMFS 2020). Blue, fin, 

humpback, and gray whales are particularly vulnerable to vessel strike because they migrate 

along the U.S. West coast and utilize coastal areas for feeding. For example, blue whale 

populations seasonally reside in coastal feeding grounds that overlap with shipping routes off 

southern California, which significantly increases the risk of vessel strike. From 1998-2019 the 

total estimated number of observed or assumed mortality and serious injury attributed to vessel 

strikes off the U.S. west coast was approximately 17 blue whales (NMFS West Coast Region 

stranding database cited in NMFS 2020). Vessel strikes were implicated in the deaths of 7 fin 

whales from 2015-2019, or 1.4 whales per year (Carretta 2021). The average observed annual 

mortality of sei whales due to vessel strike was 0.2 sei whales per year for the period 2012-2016 

(Carretta 2021). There were 14 observed vessel strike incidents involving humpback whales in 

U.S. West Coast waters during 2016-2020 (Carretta 2022). 
33 

The magnitude of the threat to large whale populations from vessel strike along the U.S. West 

Coast is likely larger than indicated based on reported incidents due to undocumented vessel 

strikes (NMFS 2011). Rockwood et al. (2017) estimated ship strike mortality of blue, fin, and 

humpback whales using an encounter theory model that considered whale density, vessel traffic 

characteristics, and whale movement patterns. Using the estimates from Rockwood et al. (2017), 

Carretta (2021) estimated that the vessel strike detection rate (i.e., carcass 

recovery/documentation rate) is approximately 1% for blue whales, 4.1% for fin whales, and 

10% for humpback whales. The model-estimated number of annual vessel strike deaths along the 

U.S. West Coast was 18 blue whales, 43 fin whales, and 22 humpback whales. These estimates 

include only the seasonal period from July through November when large whales are most likely 

to be present in the U.S. West Coast EEZ. Accounting for undocumented vessel strikes, 

Rockwood et al. (2021) estimated that in their study area off Southern California from 2012–

2018, on average 8.9 blue, 4.6 humpback, and 9.7 fin whales were killed from vessel strikes 

during summer/fall (June–November) each year. In addition, they estimated that, on average, 5.7 

humpback whales were killed from vessel strike during winter/spring (January–April) per year 

(Rockwood et al. 2021). 

As discussed above, the volume of vessel traffic is one of the most important risk factors in terms 

of large whale vessel strike. Vessel traffic is extensive throughout much of the North Pacific 

Ocean, as thousands of vessels make tens of thousands of trips on an annual basis. Vessel traffic 

densities were highest along nearly all Asian and North American mainland coastlines, including 

areas that serve as coastal migratory corridors or important feeding grounds for many large 

whale species (Figure 6). Relative densities of vessels are shown in Figure 8 for the months 

November through January to best align with the timeline for the proposed action. 

The west coast of the U.S. has some of the heaviest commercial vessel traffic associated with 

some of the largest ports in the country, including Los Angeles/Long Beach, San Francisco, 

Seattle, and the Columbia River. Tens of thousands of large commercial vessels travel in and out 

of these busy ports each year (Redfern et al. 2013). Starcovic and Mintz (2021) analyzed vessel 

traffic patterns for commercial shipping and military vessel activity in Navy training and testing 

areas from 2014-2018. Navy training and testing areas that overlap with the action area for this 

consultation include Hawaii, Southern California and the Pacific Northwest (Figure 7 and Figure 

8). The average annual number of vessel transits during this period (2014-2018) for these Pacific 

Ocean areas combined, by vessel type, were as follows: 8,300 bulk carrier transits; 9,618 Cargo 

transits; and 4,284 tanker transits (plus about 14,000 smaller vessel transits and 1,000 military 

vessel transits). For the proposed action, a maximum of 11 tanker vessel transits (i.e., could be 

fewer if some tankers transit to foreign ports in the West Pacific) would be made to receiving 

ports within Hawaii or along the U.S. West Coast. 
34 

Figure 8. Relative densities of vessel activity from November through January, shown as hours of operation 

per 10 × 10 kilometer grid cell (Silber et al. 2021). Actual densities for the red (highest) areas ranged from 8.4 

to 34,205 hours per month. 

Proportionally, the 11 tankers for the proposed action represent about 0.25% of the total annual 

tanker transits (4,284), and about 0.05% of the annual large vessel (i.e., bulk carriers, cargo 

vessel, and tankers) transits (22,202) within the combined Hawaii and U.S. West Coast Navy 

training and testing areas. The 11 tanker transits proposed likely account for an even smaller 

proportion of all vessel transits in Hawaii and along the U.S. West Coast because Starcovic and 

Mintz (2021) only include transits within the Navy training and testing areas (as depicted in 

Figure 9 and Figure 10). 

Therefore, the 11 tanker transits for the proposed action makes up an extremely small proportion 

(i.e., less than 0.05%) of the total number of large vessel transits in Hawaii and along the U.S. 

West Coast. Although vessel strike is one of the major ongoing threats to ESA-listed large 

whales in some portions of the action area, the actual number of whales struck in a given year is 

relatively small, compared to the total number of vessel transits per year. Vessel strike is a 

significant risk to large whale populations due to the sheer volume of vessel activity, and 

particularly activity by large, fast moving vessels. However, the risk of a vessel strike from a 

single transit or even a small number of transits (e.g., 11 for the proposed action) is extremely 

low. 
35 

Figure 9. Navy Hawaii-Southern California Training and Testing (HSTT) study area 

In general, with the exception of non ESA-listed Hawaii DPS of humpback whales, vessel strikes 

of other large whale species in Hawaii are extremely rare events (Carretta 2021; Carretta 2022). 

Carretta (2021) used recorded strike data and estimated vessel strike detection rates to model the 

estimated number of annual vessel strike mortalities along the U.S. West Coast. After accounting 

for undocumented strikes, his model estimated 18 blue whale, 43 fin whale, and 22 humpback 

whale vessel strike mortalities. While strikes of other species have been documented (e.g., sei 

and gray whales), these 3 species represent the large majority of ESA-listed large whale vessel 

strikes along the West Coast. Based on the best available information regarding the estimated 

annual number of large whale vessel strikes (from Carretta 2021), and number of large vessel 

transits in Hawaii and along the U.S. West Coast (from Starcovic and Mintz 2021), we anticipate 

the ESA-listed large whale strike rate (i.e., strikes per large vessel transit) is extremely small 

(i.e., likely less than 0.01 strikes per large vessel transit). 

For the proposed action, up to 6 of the vessel transits could remain within Hawaii waters (Pearl 

Harbor to West Oahu, Hawaii). It is extremely unlikely that an ESA-listed large whale would be 

struck during transits within Hawaii waters. This conclusion is supported by the anticipated low 

strike rate plus the fact that humpback whales in this region are not part of an ESA-listed DPS, 

and the occurrence of other large whale species (i.e., ESA-listed species) along this transit route 

is likely a very rare event. A maximum of 7 vessel transits could also be made to receiving ports 

along the U.S. West Coast (see Table 1). Given the extremely small anticipated large whale 
36 

Figure 10. Navy Northwest Training and Testing (HSTT) study area 

strike rate (from above), we also conclude that the risk of an ESA-listed large whale vessel strike 

during West Coast tanker transits (up to 7 combined) is extremely small. In addition, for the 

proposed action, tankers will be traveling along the U.S. West Coast from late October through 

mid-January. Because these represent months when ESA-listed large whales are less likely to 

occur along the West Coast, the strike rate during the months (i.e., late fall through early winter) 

when the proposed action will take place is likely even smaller than the annual rate that our 

analysis above is based upon. 

The proposed action includes 4 foreign ports: U.S. Naval Fueling Station Sasebo, Japan; Subic 

Bay, Philippines; Port of Singapore; and Port of Darwin, Australia. Up to 11 tanker vessel 

transits could be made to foreign ports as part of the proposed action; including up to 6 to 

Singapore and up to 5 to the Philippines. Compared to the U.S. portion of the action area, we 
37 

have relatively little information regarding large whale vessel strike risk in these foreign waters. 

The IWC maintains an online global ship strike database, which enables the general public to 

submit reports on ship strikes (www.iwc.int/ship-strikes). Information compiled in the IWC 

database derive from publicly available evidence, including peer-reviewed research articles, 

scientific and technical reports, online newspaper articles and videos, social media platforms, 

IWC National Progress Reports, as well as direct witness reports (Winkler et al. 2020). For the 

period from 1820-2019, the IWC database includes 933 cetacean ship strike records classified as 

either definite (64.8%), probable (16.6%), or possible (18.5%) ship strike. For the South China 

Sea, which includes the receiving ports in the Philippines and Singapore, there were 13 ship 

strike records (1.4% of total) in the IWC database (Winkler et al. 2020). By country, there was 

only 1 record (0.1%) from Singapore, 5 (0.5%) from Japan, 35 (3.8%) from Australia, and none 

from the Philippines (Winkler et al. 2020). In comparison, ship strike records from the U.S. 

account for nearly 26% of global records in the IWC database. To address identified gaps and 

unreported data for Australia in the IWC database, Peel et al. (2018) conducted a search of 

historical national and international print media archive databases to discover reports of vessel 

strikes Australian waters. They found a significant number of previously unrecorded reports of 

vessel strikes that resulted in a revised estimate of about 15% of global vessel strikes occurring 

in Australian waters (Peel et al. 2018). We recognize that the foreign portion of the action area 

may be underrepresented in the global ship strike database due to regional differences in 

reporting, stranding probabilities, and undocumented strike rates. However, based on the 

available information, there is no indication that the large whale strike rate (i.e., strikes per vessel 

transit) would be appreciably greater in the foreign portion of the action area compared to the 

anticipated strike rate in the U.S. portion. Therefore, similar to U.S. transits, we expect the risk 

of an ESA-listed large whale vessel strike during tanker transits (up to 11 combined) to foreign 

receiving ports to be extremely small. 

The risk of a large whale vessel strike because of the proposed action is likely further reduced 

(i.e., below the extremely low risk from our analysis above) due to the implementation of 

proposed vessel strike mitigation measures. Within Pearl Harbor, the tanker ships and tugboats 

used for the proposed action will operate at speeds of 10 knots or less in accordance with the 

Navy Region Hawaii Port Environmental Manual (NAVFAC 2023). To the extent practicable, 

all transiting vessels shall adhere to all voluntary speed restrictions in areas where the risk of 

vessel strikes is high (see Best Management Practices above for details on these areas and 

voluntary restrictions). In addition, to the extent practicable, during transit vessel operators will 

halt or alter course to remain at least 500 yards from whales (NAVFAC 2023). The mitigation 

zone will be observed at all times when underway and, if a marine mammal is observed within 

the zone, the vessel will maneuver to maintain distance, to the extent practicable (NAVFAC 

2023). 

In summary, although vessel strikes of large whales by oil tankers have been documented in the 

past, we find that the risk of an ESA-listed large whale vessel strike resulting from the proposed 
38 

action is extremely low due to: 1) the anticipated low strike rate (i.e., large whale strikes per 

large vessel transit) based on historical strike records and vessel traffic information, 2) the very 

small number of tanker transits proposed for this action, and 3) the proposed vessel strike 

mitigation measures. Therefore, any effects of vessel strike to ESA-listed large whales because 

of the proposed action are extremely unlikely to occur and are considered discountable. We also 

conclude any effects of vessel strike to Southern Resident killer whale, Main Hawaiian Island 

insular false killer whale, Hawaiian monk seal, Guadalupe fur seal, or Western DPS Stellar sea 

lion because of the proposed action are extremely unlikely to occur and are considered 

discountable. In conclusion, we concur with JTFRH and DLA that vessel strike associated with 

the proposed action may affect, but is not likely to adversely affect any ESA-listed marine 

mammals in the action area.

Marine Reptiles 

Vessel strike could potentially affect ESA-listed sea turtles and sea snakes in the action area. 

ESA-listed sea turtle and sea snake species found in the action area can be at or near the surface 

in open ocean and coastal areas, whether resting, feeding or periodically surfacing to breathe. 

Therefore, all ESA-listed sea turtles and sea snakes considered in the opinion are potentially at 

risk of vessel strike. Marine reptile vulnerability to vessel strike increases with vessel speed. 

Turtles may use auditory cues to react to approaching ships rather than visual cues, making them 

more susceptible to strike as ship speed increases (Hazel et al. 2007). Hazel et al. (2007) found 

that vessel operators could not rely on turtles at the surface to actively avoid being struck for 

vessel speeds greater than 4 kilometers per hour. High-speed vessel movements in nearshore and 

inshore waters present a greater risk of vessel strike because of the higher concentrations of sea 

turtles and sea snakes in these areas and the difficulty for vessel operators to see them and avoid 

collisions during high speed activities. 

Unlike whales, which are more susceptible to strike from very large vessels (i.e., bulk carriers, 

cargo vessels, and tankers), sea turtles and sea snakes, due to their smaller size and high densities 

in nearshore areas, are susceptible to vessel strike from a wide range of vessel sizes and types. 

For the proposed action, tugboats will guide tankers transiting through port areas. The 

origination port of Pearl Harbor, as well as all of the receiving ports for the proposed action are 

heavily trafficked, industrialized areas. Tugboats will operate primarily in deep water shipping 

channels used by many large commercial vessels, including cargo ships, container ships, and 

tankers. Sea turtle and sea snake densities in these areas are expected to be very low given the 

water depth, physical disturbance, and noise levels produced by large commercial vessels, and 

poor water quality in many of the receiving ports (see Action Area above for more details on 

receiving ports). Tugboats are expected (or required in some areas) to travel at slow speeds 

within port areas, thus further reducing the likelihood of a sea turtle or sea snake vessel strike. 

Given the small number (and relatively short distances) of the tugboat transits proposed, the very 

low densities of sea turtles and sea snakes anticipated in areas where tugboats will be used, and 
39 

the anticipated slow speeds tugboats will travel most of the time, we find an ESA-listed sea turtle 

or sea snake strike by a tugboat to be extremely unlikely to occur (i.e., discountable). 

We anticipate the highest risk of sea turtle or sea snake vessel strike will occur in the nearshore 

and inshore areas of the transit routes as tankers are leaving the origination port of Pearl Harbor 

or approaching one of the receiving ports. Although sea turtles, such as leatherbacks and 

loggerheads, are commonly found in offshore, pelagic environments, their densities in these 

areas are expected to be extremely low given the relatively small population sizes of these ESAlisted species in relation to the size of the open ocean areas they utilize. While ESA-listed sea 

turtles could be struck during tanker transits in the open ocean, given the small number of 

transits proposed and anticipated low densities of sea turtles in these areas, we find this risk so 

low as to be considered discountable. 

Considering that all 11 tanker transits would originate in Pearl Harbor and up to 6 transits could 

be made from Pearl Harbor to West Oahu, we anticipate the highest risk of a sea turtle vessel 

strike will be in the nearshore and inshore areas within Hawaii waters. Although sea turtle vessel 

strikes have been documented in nearshore and inshore areas along the U.S. West Coast, 

densities of sea turtles in and around the proposed receiving ports are much lower as compared to 

Hawaii (Eguchi and Seminoff 2011). Sea turtle stranding reports are also less common along the 

U.S. West Coast, as compared to Hawaii, and many of these stranding are from San Diego Bay 

(Eguchi and Seminoff 2011), where a maximum of 2 tanker transits (to Point Loma) will occur 

as part of the proposed action. 

There is also the potential for sea turtles and sea snakes to be struck by tankers transiting through 

the nearshore and inshore areas approaching the proposed foreign receiving ports. We could not 

find any information regarding the risk of ESA-listed sea turtle or sea snake vessel strike in these 

areas. Therefore, for our analysis, we estimate the strike rate (i.e., sea turtle vessel strikes per 

vessel transit) for the U.S. nearshore and inshore areas where we have information on both turtle 

strandings and vessel activity to make this calculation. We then consider this strike rate, along 

with other relevant information, to inform our determination regarding the risk of sea turtle 

vessel strike in the nearshore and inshore foreign water areas where tankers may be transiting. 

As part of the sea turtle vessel strike analysis for the Navy’s HSTT action, NMFS (2018a) 

combined information from sea turtle stranding reports with estimated stranding probabilities 

(i.e., proportion of total strandings observed and recorded in database) to estimate the annual 

number of sea turtle vessel strikes for the Main Hawaiian Islands and San Diego Bay. Based on 

historical information, these areas likely account for the vast majority of sea turtle vessel strikes 

within the Navy’s HSTT action area (Chaloupka et al. 2008; Eguchi and Seminoff 2011; NMFS 

2018a). NMFS (2018a) estimated 250 green sea turtle lethal vessel strikes (by all vessels) occur 

annually in Hawaiian waters. Based on historical stranding data, green sea turtles accounted for 

over 95% of all sea turtle strandings in Hawaii (Chaloupka et al. 2008; NMFS 2015). In NMFS 

(2018a), we conservatively estimated 264 sea turtle (all species) lethal vessel strikes occur 
40 

annually in Hawaiian waters. For San Diego Bay, NMFS (2018a) estimated the annual number 

of sea turtle lethal vessel strikes (by all vessels) is 15 turtles (all green turtles). Therefore, the 

NMFS (2018a) combined annual estimate of sea turtle lethal vessel strikes in Hawaii and 

Southern California for the Navy’s HSTT action was 279 turtles. 

Several studies have reported live sea turtles with vessel strike injuries. This indicates that, under 

some circumstances (e.g., very small vessels, slow moving vessels, or a partial vessel strike only 

grazing a fin or outer shell), vessel strike can result in non-lethal effects to sea turtles that neither 

strand nor are killed by the interaction. However, for the proposed action, if a tanker were to 

strike a sea turtle or sea snake we would expect the impact would result in mortality given the 

size and speed of the vessel. 

The NMFS (2018a) estimate of the annual number of lethal sea turtle vessel strikes in Hawaii 

and Southern California (i.e., 279 turtles) is extremely small compared to the annual number of 

vessel transits in these areas. From Starcovic and Mintz (2021), the average annual number of 

vessel transits during this period (2014-2018) for the entire Navy HSTT area was over 23,000. 

While this estimate includes all sizes and types of vessels, it only reflects vessels equipped with 

AIS technology and only those transits when the AIS transceivers were on and operating 

properly. Based on the best available information regarding the estimated annual number of sea 

turtle vessel strikes and number of vessel transits in Hawaii and Southern California, we 

conclude that the ESA-listed sea turtle strike rate (i.e., strikes per vessel transit) is extremely 

small (i.e., likely less than 0.013 strikes per vessel transit). The proposed action includes up to 11 

tanker transits to various U.S. receiving ports. Multiplying the strike rate (0.013) by the number 

of transits, we get 0.14 strikes. Therefore, based on our estimated strike rate, an ESA-listed sea 

turtle strike by a tanker transiting from Pearl Harbor to one of the U.S. receiving ports is 

extremely unlikely to occur and, thus, discountable. 

The proposed action includes 4 foreign receiving ports: U.S. Naval Fueling Station Sasebo, 

Japan; Subic Bay, Philippines; Port of Singapore; and Port of Darwin, Australia. Up to 11 tanker 

vessel transits could be made to these foreign ports as part of the proposed action, including up to 

6 to Singapore and up to 5 to the Philippines. Compared to the U.S. portion of the action area, we 

have very little information regarding sea turtle vessel strike risk in these foreign waters. While 

we did find a few published papers on sea turtle strandings in Australia and Japan, this 

information was not very useful for our analysis due to: 1) the narrow geographic scope of these 

studies did not overlap with our action area, and 2) the lack of detailed information regarding the 

cause of stranding, including very little information on vessel strike. Based on the available 

information, there is no indication that the sea turtle strike risk would be appreciably greater in 

the foreign portion of the action area as compared to the anticipated strike risk in the U.S. 

portion. Therefore, similar U.S. transits, we expect the risk of an ESA-listed sea turtle vessel 

strike during tanker transits (up to 11 combined) to foreign receiving ports to be very low. 

Because we have no information specific to vessel strike of sea snakes, we use sea turtle 

information as a proxy for other ESA-listed marine reptiles, and we assume vessel strike risk for 
41 

the ESA-listed dusky sea snake (foreign species) is no greater than for the ESA-listed sea turtles 

for which we have vessel strike information. 

We expect the greatest risk to sea turtles and sea snakes from vessel strike in the nearshore and 

inland portions of the transit routes as the tankers are approaching the ports. While sea turtle 

nesting beaches and foraging area have been identified throughout the action area, we found no 

information indicating that nesting beaches or foraging areas are located within, or near, any of 

the receiving ports for the proposed action. Tanker transit routes will primarily follow existing 

shipping lanes in deeper waters where there is heavy commercial shipping traffic, making it 

extremely unlikely that they will transit through shallow water foraging areas or nearshore areas 

adjacent to known sea turtle nesting beaches. As discussed above, sea turtles and sea snakes are 

more likely to avoid heavily trafficked areas near major ports such as shipping channels and 

industrialized harbors, further reducing the risk of sea turtle or sea snake exposure to strike from 

a tanker vessel. 

The risk of a sea turtle or sea snake vessel strike because of the proposed action is further 

reduced (i.e., below the very low risk from our analysis above) due to the implementation of 

proposed vessel strike mitigation measures. Within Pearl Harbor, the tanker ships and tugboats 

used for the proposed action will operate at speeds of 10 knots or less in accordance with the 

Navy Region Hawaii Port Environmental Manual (NAVFAC 2023). Within Pearl Harbor, tanker 

operators and crew will watch for turtles at or near the surface in areas of known or suspected 

turtle activity and, if practicable, reduce vessel speed to 5 knots or less. To the extent practicable, 

if approached by an ESA-listed sea turtle within Pearl Harbor, the vessel operator will put the 

engine in neutral, if the animal is within 150 feet (45.7 meters) of the vessel, until the animal has 

moved at least 50 feet (15.2 meters) away, and then engage the engine and slowly move 150 feet 

(45.7 meters) or more from the animal (NAVFAC 2023). Outside of Pearl Harbor, vessel 

operators will be instructed to keep a safe distance from turtles and maneuver as needed to 

maintain a safe distance (NAVFAC 2023). To the extent practicable, transiting vessels will 

adhere to all voluntary speed restrictions in areas where the risk of vessel strike is particularly 

high (see Best Management Practices above for details on these areas and voluntary restrictions) 

(NAVFAC 2023). Although these voluntary restrictions are primarily in place to mitigate whale 

strikes, sea turtle and sea snake strikes may be mitigated due to the lower vessel speeds. 

In summary, although tankers and tugboats represent a potential vessel strike risk to ESA-listed 

sea turtles and sea snakes, we find that the risk of an ESA-listed sea turtle or sea snake vessel 

strike resulting from the proposed action is extremely unlikely due to: 1) the anticipated low 

strike rate (i.e., sea turtle vessel strikes per vessel transit) based on historical strike records and 

vessel traffic information, 2) the proposed tanker routes in relation to anticipated areas of higher 

sea turtle or sea snake densities, 3) the small number of tanker and tugboat transits proposed for 

this action, and 4) the proposed vessel strike mitigation measures. Given the extremely low risk, 

we determine that any effects of vessel strike to ESA-listed sea turtles and sea snakes because of 

the proposed action are extremely unlikely to occur and are, therefore, discountable. We concur 
42 

with JTFRH and DLA that ship strike associated with the proposed action may affect, but is not 

likely to adversely affect, ESA-listed sea turtles and sea snakes in the action area.

Fishes 

Several of the ESA-listed fish species considered in this opinion spend at least some time in the 

upper portions of the water column where they may be susceptible to vessel strike. Oceanic 

whitetip sharks can be found at the ocean surface and down to at least 152 meters deep, but most 

frequently stay between depths of 25.5 and 50 meters (Carlson and Gulak 2012; Young et al. 

2017). Tagging and diet studies indicate that adult and juvenile steelhead are surface-oriented, 

spending most of their time in the upper portions of the water column (Daly et al. 2014). Walker 

et al. (2007) summarized information from a series of studies off British Columbia looking at the 

vertical distribution of steelhead and found the species spends 72% of its time in the top 1 meter 

of the water column, with few movements below 7 meters. Scalloped hammerhead sharks may 

occur in the upper portions of the water column as well. Though tagging studies indicate giant 

manta rays are capable of descending to depths of hundreds of meters, they also occur in surface 

waters, making them susceptible to vessel strike. As a large, slow-moving fish, giant manta rays 

near the surface may be more susceptible to vessel strike as compared to faster moving and more 

agile species such as sharks or steelhead. 

Despite these species’ utilization of the upper portion of the water column for at least some of 

their life history, in most cases, we would anticipate the ESA-listed fishes considered in this 

opinion would be able to detect vessels and avoid them. Fish are able to use a combination of 

sensory cues to detect approaching vessels, such as sight, hearing, and their lateral line (for 

nearby changes in water motion). A study on fish behavioral responses to vessels showed that 

most adults exhibit avoidance responses to engine noise, sonar, depth finders, and fish finders 

(Jørgensen et al. 2004), reducing the potential for vessel strikes. Misund (1997) found that fish 

ahead of a ship showed avoidance reactions at ranges of 160–490 feet (50–350 meters). When 

the vessel passed over them, some fish responded with sudden escape responses that resulted in 

movement away from the vessel laterally or through downward compression of the school. 

Sturgeon, in general, are more susceptible to vessel strike than other species due to their large 

body size. Strikes of sturgeon often occur in shipping channels and inland waterways where 

these benthic dwelling fish cannot avoid large vessels drafts or suction forces from the 

propellers. Although vessel strike has been documented and identified as a risk factor for other 

ESA-listed sturgeon species (ASSRT 2007; SSSRT 2010), we are not aware of any reported 

incidences of green sturgeon vessel strike in the action area. In addition, green sturgeon densities 

in areas tankers will transit through are anticipated to be extremely low. 

Given the low abundance of the ESA-listed fish species in the action area, particularly in the 

Hawaii inshore portions where all tanker transits will originate, the ability of these species to 

maneuver to avoid any oncoming vessels, the small number of vessel transits associated with the 

proposed action, and the lack of documented cases of tanker vessels striking these species (or 
43 

any other fish species), it is extremely unlikely that a vessel associated with the proposed action 

will strike an ESA-listed fish. The effects of vessel strike to ESA-listed fish species resulting 

from the proposed action are, thus, discountable. Therefore, we concur with JTFRH and DLA 

that ship strike associated with the proposed action may affect, but is not likely to adversely 

affect, any ESA-listed fish species in the action area. 

Effects of Oil Spill 

Exposure to petroleum hydrocarbons released into the marine environment via oil spills 

represents a serious potential health risk to ESA-listed species. There are 2 potential pathways 

through which an oil spill can occur because of the proposed action: 1) accidental discharge 

during the transfer of fuel from the RHBFSF bulk tanks through existing DoD piping and 

associated infrastructure to a fuel-loading pier at JBPHH, and onto the tanker ships, and 2) 

accidental discharge of fuel from the tanker ship at any point during transit to the fuel receiving 

destination port. 

Vessel fueling at the JBPHH pier will follow standard operating procedures and implement 

BMPs described in the Proposed Action (see above) to minimize the risk of spills. Prior to 

commencing fuel-loading activities, all equipment will be checked to reduce any risk of leaks or 

discharge. In addition, a contingency plan to control and contain accidental, toxic spills will be 

developed for the proposed action (NAVFAC 2023). Petroleum, spill-containment devices (e.g., 

absorbent pads, containment booms, etc.) will be located on-site in sufficient quantity, and 

available for immediate deployment at all times (NAVFAC 2023). The proposed BMPs will 

reduce the likelihood of fuel from entering the marine environment, minimizing the risk of 

potential exposure to ESA-listed species (NAVFAC 2023). 

The transfer of fuels to vessels will follow the Defense Fuel Support Point Pearl Harbor Bulk 

Terminal Operation, Maintenance, Environmental and Safety Plan for the transfer of fuel to 

marine vessels from shore facilities. The team performing pier fueling operations will fill out a 

declaration of inspection certificate, hose inspection sheet, tanker/barge material inspection form, 

transfer record, running gauge record, barge ullage report, and notice of readiness (provided by 

the vessel). Sump containments will be inspected for standing water or fuel, and all fueling hoses 

will undergo tightness testing. Prior to any fuel movement operation, the team will review and 

conduct a line pack and pressure test on the piping and walk the pipeline to evaluate its 

condition. The Control Room Operator will ensure that vital elements of the emergency 

shutdown system (e.g., shutoff buttons, voice communications) are in position and operable. As 

the pipeline is pressurized, the visual inspectors and Control Room Operator will evaluate system 

pressure gages and verify pipeline integrity. During the transfer of fuel, the team will 

periodically check for leaks and any sheen on the water next to the pier, and will conduct 

occasional checks of the valve pits that are in use for indication of leaks. 
44 

Although oil spills involving tanker vessels in transit do occur, major spill events are relatively 

rare. In general, the number of oil spills from tankers has decreased significantly over the last 5 

decades: spills in excess of 7 tonnes (15,432 pounds) have been reduced by over 90% since 1970 

(ITOPF 2023). In the past 5 years (2018-2022), the global annual average number of medium oil 

spills (i.e., between 7 and 700 tonnes) from tankers was about 4, and the global annual average 

number of large oil spills (i.e., greater than 700 tonnes) from tankers was less than 2 (ITOPF 

2023). Considering the small number of tanker spills greater than 7 tonnes annually, and the tens 

of thousands of annual global oil tanker transits annually, we find the risk of a spill greater than 7 

tonnes resulting from one of the 11 tanker transits for the proposed action to be extremely 

unlikely to occur (i.e., discountable). 

Tanker ships used will be double-hulled in accordance with MARPOL regulations, significantly 

reducing the risk of hull failure. Tankers will have a certified oil discharge monitoring and 

control system (monitoring system), as well as other safety and environmental design features, as 

required in accordance with USCG regulations Title 33, Section 157 “Rules for the Protection of 

the Marine Environment Relating to Tank Vessels Carrying Oil in Bulk” (National Archives 

2023). In addition, the destination ports contain adequate channel water depth to avoid the 

potential for vessel grounding (NAVFAC 2023). Although very busy ports may pose a higher 

potential for collision-related spills, collisions will be avoided by following appropriate 

navigation and communication procedures (NAVFAC 2023). To further prevent allision (the act 

of one moving object dashing against or striking upon another object) or collision (when 2 

moving parts strike each other), all tankers will be towed by tug within the harbors (NAVFAC 

2023). Tanker ship operators will comply with international regulations/guidelines, including 

those of the International Safety Guide for Oil Tankers and Terminals. 

While oil spills from tanker operations represent a serious threat to marine ecosystems, we do not 

anticipate an oil spill affecting ESA-listed species or critical habitat because of the proposed 

action. The standard operating procedures and BMPs proposed for this action will significantly 

reduce the likelihood of an accidental discharge during the transfer of fuel from the bulk tanks 

onto the tanker ships. Although there is the potential for an oil spill to occur during tanker 

transits, based on global tanker oil spill occurrence data, the probability of a spill occurring 

during one of the 11 tanker transits for the proposed action is extremely low. All tankers will be 

towed by tugboats within the harbors to further reduce the risk of a collision-related spill. 

In summary, based on the best available information, we determine that the effects of oil spillrelated stressors to ESA-listed species and critical habitat because of the proposed action are 

extremely unlikely to occur, and, therefore, discountable. Thus, stressors associated with an oil 

spill resulting from the proposed action may affect, but are not likely to adversely affect, any 

ESA-listed species or critical habitat in the action area.
45 

Conclusion 

Based on this analysis, the NMFS ESA Interagency Cooperation Division concurs with JTFRH 

and DLA that the proposed action may affect, but is not likely to adversely affect ESA-listed 

species or designated critical habitat in the action area. 

Reinitiation of Consultation

Reinitiation of consultation is required and shall be requested by the Federal agency, or by 

NMFS, where discretionary Federal involvement or control over the action has been retained or 

is authorized by law and (1) new information reveals effects of the action that may affect an 

ESA-listed species or designated critical habitat in a manner or to an extent not previously 

considered; (2) the identified action is subsequently modified in a manner that causes an effect to 

the ESA-listed species or designated critical habitat that was not considered in this concurrence 

letter; or if (3) a new species is listed or critical habitat designated that may be affected by the 

identified action (50 CFR §402.16). 

Upon completing the defueling of all storage tanks at Red Hill Bulk Fuel Storage Facility, Fleet 

Logistic Center Pearl Harbor will sample and test the last of the fuel remaining in the tanks to 

determine whether it meets specifications for DoD requirements, or if it will be sold 

commercially (NAVFAC 2023). Because the quality of this remaining fuel is currently unknown, 

the Action Proponents have indicated that there is some level of uncertainty regarding the 

receiving port for the 11th tanker (NAVFAC 2023). If the receiving port for the 11th tanker is one 

of the ports identified in Table 1, the effects of the 11th tanker have been fully assessed in our 

analysis section for this consultation. However, if the 11th tanker transits to a receiving port not 

previously identified, this would qualify as a modification of the proposed action that would 

require reinitiation of consultation (i.e., reinitiation trigger 2 above). 

Please direct questions regarding this letter to Dr. Ron Salz, Consulting Biologist, 301-427-8487 

and ron.salz@noaa.gov, or me at (240) 723-6321, or by email at tanya.dobrzynski@noaa.gov. 

Sincerely, 

Tanya Dobrzynski 

Chief, ESA Interagency Cooperation Division 

Office of Protected Resources 

cc: Brittany Bartlett (NAVFAC Pacific) 

 Dr. Michelle Bejder (NAVFAC Pacific) 

 Ron Dean (NMFS PIRO) 

DOBRZYNSKI.TANY

A.JANINE.13658465

17

Digitally signed by 

DOBRZYNSKI.TANYA.JANINE.1365

846517 

Date: 2023.08.15 10:26:54 -04'00'
46 

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C-1

APPENDIX C – COASTAL ZONE MANAGEMENT 

ACT COORESPONDENCE
From: Mendes, Debra L

To: Sears, Jill R CIV USN NAVFAC PAC PEARL HI (USA)

Cc: Frame, Darrel E CAPT USN NAVFAC PAC PEARL HI (USA); Sullivan, Patrick J CAPT USN INDOPACOM JTF RED

HILL (USA); Christenbury, Stacey A CIV DLA ENERGY (USA); Blank, Bruce A CIV DLA ENERGY (USA); Nihipali,

Justine W; CleanWaterBranch; Lum, Darryl C; Chen, Edward

Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Red Hill Defueling and Fuel Relocation: Notification to use Navy

CZMA de Minimis Activity list

Date: Monday, June 19, 2023 12:43:15 PM

Jill Sears,

This acknowledges receipt of the notification by the Naval Facilities Engineering System Command

(NAVFAC) Pacific of the use of the CZMA De Minimis List for the subject proposed Red Hill Defueling

and Fuel Relocation. This Hawaii CZM Program acknowledgement does not represent an

endoresement of the proposed activity.

Thank you.

Debra Mendes

Hawaii Coastal Zone Management Program

From: Sears, Jill R CIV USN NAVFAC PAC PEARL HI (USA) <jill.r.sears.civ@us.navy.mil> 

Sent: Wednesday, June 14, 2023 9:53 AM

To: Mendes, Debra L <debra.l.mendes@hawaii.gov>

Cc: Frame, Darrel E CAPT USN NAVFAC PAC PEARL HI (USA)

<darrel.e.frame.mil@us.navy.mil>; Sullivan, Patrick J CAPT USN INDOPACOM JTF RED HILL

(USA) <patrick.j.sullivan7.mil@us.navy.mil>; Christenbury, Stacey A CIV DLA ENERGY (USA)

<Stacey.Christenbury@dla.mil>; Blank, Bruce A CIV DLA ENERGY (USA)

<Bruce.Blank@dla.mil>

Subject: [EXTERNAL] Red Hill Defueling and Fuel Relocation: Notification to use Navy CZMA

de Minimis Activity list

Dear Ms. Mendes,

Per the Department of Business, Economic Development & Tourism (DBEDT) letter dated

July 9, 2009, this email notification is being provided to the State CZM office in compliance

with "Project Mitigation / General Conditions" when the Department of the Navy de minimis

list under CZMA is used for projects that require an environmental assessment.

Naval Facilities Engineering System Command (NAVFAC) Pacific, on behalf of the Joint Task

Force Red Hill (JTF-RH) and Defense Logistics Agency (DLA) is preparing an Environmental

Assessment (EA) for Red Hill Defueling and Fuel Relocation from Joint Base Pearl HarborHickam. The Project’s Draft EA was released to the public on 9 June 2023. The public

comment period will conclude on 30 June 2023. Project information and relevant "Project

Mitigation / General Conditions" are provided below. Please additional information on the

JTF-RH Environmental Assessment website: https://www.pacom.mil/JTF-Red-Hill/NEPAComment/
Proposed Action:

The Proposed Action is the gravity-based defueling of Red Hill Bulk Fuel Storage Facility

(RHBFSF) underground storage tanks and associated pipelines, and relocation of the

flowable fuel by tanker ship.

Background:

The purpose of the proposed gravity-based defueling action is to comply with State of

Hawaii Department of Health (DOH) Emergency Orders, the Environmental Protection

Agency (EPA) 2023 Consent Order, and U.S. Secretary of Defense Lloyd J. Austin III’s order on

March 7, 2022 to defuel and permanently close the RHBFSF.

Defueling RHBFSF is needed to protect local water supplies from further contamination.

Additionally, the Department of Defense (DoD) needs to defuel the facility as an initial step

in the process of full closure and remediation of RHBFSF.

JTF-RH and DLA are considering two action alternatives (Alternatives 2 and 3) that meet the

purpose and need of the Proposed Action. Both action alternatives utilize existing

infrastructure at RHBFSF and Joint Base Pearl Harbor-Hickam (JBPHH) to remove the fuel

from RHBFSF and involve no new construction.

Alternative 2 is the relocation of the approximately 106 million gallons of flowable fuel from

RHBFSF to existing locations within the DoD fuel supply chain by ocean transit. The fuel

removal operation involves gravity flow of the fuel from RHBFSF through existing DoD piping

and associated infrastructure to a fuel loading pier at JBPHH. A maximum of eleven refined

product tanker ship transits are required to receive and transport the flowable fuel from

RHBFSF. Tanker ships would transit within existing commercial shipping lanes to one or more

(up to nine) existing DoD fuel support points throughout the Pacific. The fuel deliveries to

these locations would occur in lieu of routine or planned fuel supply deliveries.

Potential receiving locations for fuel deliveries include: West Oahu, Hawaii (Campbell

Industrial Park); Point Loma, California; Selby, California; Vancouver, Washington;

Manchester, Washington; Sasebo, Japan; Subic Bay, Philippines; Port of Singapore, and

Darwin, Australia. The quantity of fuel and number of deliveries to each location depends on

DoD fuel inventory needs at the time of defueling.

Alternative 3 is the commercial sale of a portion of the approximately 106 million gallons of

flowable fuel from RHBFSF combined with the relocation of the remaining portion of the fuel

to existing locations within the DoD fuel supply chain by ocean transit. Up to ten tanker loads

of fuel from RHBFSF may be commercially sold in accordance with Section 2922e of Title 10,

United States Code, which authorizes the sale of certain fuel sources. The portion of fuel

that is not sold would be relocated from RHBFSF to existing locations within the DoD fuel

supply chain by ocean transit. Relocation of fuel would be accomplished using the same

process as Alternative 2.

Applicability of De Minimis Activities under CZMA:
The Proposed Action falls within:

#2 Utility Line Activities: Acquisition, installation, operation, construction, maintenance, or

repair of utility or communication systems that use rights of way, easements, distribution

systems, or facilities on Navy/Marine Corps controlled property.

#14 Mission Changes: Mission changes, base closures/relocations/consolidations, and

deployments that would cause long term population increases or decreases in affected

areas.

The relevant mitigation/conditions include:

1) Navy/Marine Corps controlled property refers to land areas, rights of way, easements,

roads, safety zones, danger zones, ocean and naval defensive sea areas under active

Navy/Marine Corps control.

14) The National Environmental Policy Act review process (Environmental Assessment) will

be completed.

16) State CZM office notified on use of de minimis list for an EA.

The mitigation/conditions not relevant to the Proposed Action include:

10) Any under-layer fills used in the project shall be protected from erosion with stones (or

core-lac units) as soon after placement as practicable.

· No under-layer fills will be used for the Proposed Action.

11) Any soil exposed near water as part of the project shall be protected from erosion (with

plastic sheeting, filter fabric, etc.) after exposure and stabilized as soon as practicable (with

vegetation matting, hydro seeding, etc.).

· No soil will be exposed near water as part of the Proposed Action.

12) Section 106, of the National Historic Preservation Act (NHPA), consultation requirements

must be met. Also, follow guidelines in the area-specific Integrated Cultural Resources

Management Plan (ICRMP) if applicable.

· Defueling of the RHBFSF through existing pipelines and relocation by tanker ship

would involve no activities with the potential to affect historic buildings,

archaeological sites, or traditional cultural properties. Cultural resources would not

be affected by the Proposed Action. Therefore, Section 106 NHPA consultation is not

required for the Proposed Action.

Please let me know if you have any questions. If the information provided is acceptable,

please acknowledge receipt of this notification on use of the CZMA de minimis list.

Thank you,

Jill Sears

Physical Scientist

Environmental Planning

Naval Facilities Engineering Systems Command Pacific

Email: jill.r.sears.civ@us.navy.mil

Phone: (808) 472-1197

DSN: (315) 472-1197
D-1

APPENDIX D – SUPPLEMENTAL INFORMATION 

FOR MARINE BIOLOGICAL RESOURCES
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

D-2

APPENDIX D

SUPPLEMENTAL INFORMATION FOR MARINE 

BIOLOGICAL RESOURCES

This appendix provides supplemental information to that which is provided in the Environmental 

Assessment/Overseas Environmental Assessment (EA/OEA). This section includes (1) a description of the 

fuel loading location (Pearl Harbor, Hawaii); (2) a description of the potential fuel receiving locations; (3) 

detailed information on the potential marine biological stressors and environmental consequences that 

could occur as a result of the Proposed Action; and (4) references.

TABLE OF CONTENTS

1 FUEL LOADING LOCATION: PEARL HARBOR, HAWAII ................................................ 4

2 FUEL RECEIVING LOCATIONS........................................................................................ 6

2.1 Campbell Industrial Park, West Oahu, Hawaii .................................................................................. 6

2.2 Naval Base Point Loma, California ................................................................................................... 6

2.3 Selby Terminal, California ................................................................................................................. 7

2.4 Port of Vancouver, Washington ........................................................................................................ 8

2.5 Manchester, Washington .................................................................................................................. 9

2.6 U.S. Naval Fueling Station, Sasebo, Japan....................................................................................11

2.7 Subic Bay, Philippines.....................................................................................................................11

2.8 Port of Singapore ............................................................................................................................13

2.9 Port of Darwin, Australia .................................................................................................................14

3 DETAILED EFFECTS ANALYSIS.....................................................................................15

3.1 Underwater Noise ...........................................................................................................................15

3.1.1 Fishes .............................................................................................................................................................15

3.1.2 Marine Mammals ............................................................................................................................................18

3.1.3 Cetaceans (Whales, Dolphins)........................................................................................................................19

3.1.4 Pinnipeds (Seals, Sea Lions)..........................................................................................................................21

3.1.5 Sea Turtles......................................................................................................................................................21

3.1.6 Environmental Consequences ........................................................................................................................22

3.2 Vessel Collision...............................................................................................................................23

3.2.1 Fishes .............................................................................................................................................................24

3.2.2 Ceteceans (Whales, Dolphins)........................................................................................................................24

3.2.3 Pinnipeds (Seals, Sea Lions)..........................................................................................................................25

3.2.4 Sea Turtles......................................................................................................................................................26

3.2.5 Environmental Consequences ........................................................................................................................26

4 REFERENCES ..................................................................................................................27
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FIGURES

Figure D-1: Pearl Harbor, Hawaii and West Oahu, Hawaii fuel receiving location.......................................5

Figure D-2: Naval Base Point Loma, California receiving location. ..............................................................7

Figure D-3: Selby Terminal, California receiving location............................................................................. 8

Figure D-4: Port of Vancouver, Washington receiving location. ................................................................... 9

Figure D-5: Manchester, Washington receiving location. ...........................................................................10

Figure D-6: U.S. Naval Fueling Station, Sasebo, Japan receiving location................................................11

Figure D-7: Subic Bay, Philippines receiving location. ...............................................................................12

Figure D-8: Port of Singapore receiving location. .......................................................................................13

Figure D-9: Darwin, Australia receiving location.........................................................................................14

TABLES

Table D-1: Acoustic Exposure Criteria for Non-impulsive Continuous Sounds: Marine Mammals ............18

Table D-2: PTS, TTS, and Behavioral Thresholds for Sea Turtles Exposed to Impulsive and NonImpulsive Sounds................................................................................................................................22

Table D-3: Estimated Source Levels of Noise Components From Vessels. ..............................................23
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1 Fuel Loading Location: Pearl Harbor, Hawaii

Pearl Harbor (Figure D-1) is located on the southern coast of the island of Oahu, Hawaii. It is one of the 

Navy’s busiest ports, completing about 65,000 boat runs and transporting 2.4 million passengers each year. 

Tour boats manned by Navy personnel transport more than two million visitors to the U.S.S. Arizona 

Memorial each year (CNRH, 2023). 

Pearl Harbor is an estuary, defined as an area where fresh water emanating from land mixes with ocean 

water. The northern portion of the harbor receives freshwater input from perennial streams that flow into 

Pearl Harbor, creating an estuarine environment with a muddy bottom. The water in Pearl Harbor becomes 

more saline as it nears the mouth of the harbor due to saltwater input from the Pacific Ocean via Mamala 

Bay and the Main Channel of Pearl Harbor. The area near the mouth of Pearl Harbor is characterized by 

oceanic conditions or higher salinity conditions (DoN, 2022). 

Marine vegetation observed within Pearl Harbor includes algae (crustose coralline algae, turf algae, 

cyanobacteria, and macroalgae) and seagrass. Gorilla ogo (Gracilaria salicornia), which is classified as 

invasive by the State of Hawaii Division of Aquatic Resources (DAR), occurs in dense mats in shallow 

nearshore areas throughout Pearl Harbor. Recent fish surveys identified at least 41 species in 16 families 

(NAVFAC PAC, 2020; DoN Region Hawaii, 2020a, 2021), with all being typical Hawaiian reef fishes.

No Endangered Species Act (ESA)-listed invertebrates are known to occur within Pearl Harbor. Six native 

species of stony corals are present within Pearl Harbor (crust coral [Leptastrea purpurea], lace coral 

[Pocillopora damicornis], rice coral [Montipora capitata], finger coral [Porites compressa], ringed rice coral 

[M. patula], and lobe coral [Porites lobata]). The most common corals are crust coral and lace coral, which 

are found in every benthic environment in Pearl Harbor except the soft sediment of the harbor floor. One 

soft coral, branched pipe coral (Carijoa riisei) was observed at several locations within Pearl Harbor during 

recent Navy surveys. Branched pipe coral is an introduced species that is considered invasive in Hawaii by 

the State of Hawaii DAR (DoN, 2022). Two invasive octocorals have also recently been found in Pearl 

Harbor (Unomia stolonifera and Capnella cf. spicata).Non-coral marine invertebrates included sponge, 

bryozoans, bivalves, anemones, zoanthids, worms, and sea cucumbers. The orange keyhole sponge, 

which is classified as invasive by the State of Hawaii DAR, is abundant throughout the harbor. Other 

introduced species found within Pearl Harbor include erratic bryozoan (Schizoporella errata), sea frost 

worm (Salmacina dysteri), Christmas tree hydroid (Pennaria disticha), lacy tubeworm (Filograna implexa), 

white bushy bryozoan (Amathia distans), and feather duster worm (Sabellastarte spectabilis).

Two ESA-listed sea turtle species have been documented in Pearl Harbor. This includes the threatened 

Central North Pacific Distinct Population Segment (DPS) of green sea turtle (Chelonia mydas) and the 

endangered hawksbill sea turtle (Eretmochelys imbricata). Green sea turtles are common within Pearl 

Harbor, however their distribution and density varies from location to location. Based on past surveys, 

occurrence of green sea turtles observed relatively more in the entrance channel and outside Pearl Harbor. 

Hawksbills are infrequent and occur in low numbers in Pearl Harbor. 

Additionally, the ESA-listed (endangered) Hawaiian monk seal is (Neomonachus schauinslandiare) are 

historically known to enter Pearl Harbor on occasion. Between 2012 and 2022, eight Hawaiian monk seals 

were documented inside Pearl Harbor (DoN, 2022). Between 1998 and 2000, non-ESA listed marine 

mammals observed within Pearl Harbor or within the vicinity included humpback whales and a potential 

pygmy sperm whale/unidentified whale (NAVFAC PAC, 2016). 
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Figure D-1: Pearl Harbor, Hawaii and West Oahu, Hawaii fuel receiving location.
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2 Fuel Receiving Locations

The Proposed Action includes proposed transit routes to the following receiving locations: 1) Campbell 

Industrial Park, West Oahu, Hawaii, 2) Naval Base Point Loma, California, 3) Selby Terminal, California, 4) 

Port of Vancouver, Washington, 5) Manchester, Washington, 6) United States (U.S.) Naval Fueling Station, 

Sasebo, Japan, 7) Subic Bay, Philippines, 8) Port of Singapore, and 9) Port of Darwin, Australia. 

2.1 CAMPBELL INDUSTRIAL PARK, WEST OAHU, HAWAII

The West Oahu, Hawaii receiving location (Figure D-1) is Seven Point Multipoint Mooring (MPM) System 

located two miles offshore of Barbers Point. Fuel transfer would occur through an offshore mooring that 

transfers oil and refined products through a hose between a buoy and commercial refinery/storage facilities 

onshore at the Campbell Industrial Park. 

2.2 NAVAL BASE POINT LOMA, CALIFORNIA

Naval Base Point Loma (Figure D-2), located in San Diego, California on San Diego Bay, provides support 

to the U.S. Pacific Fleet afloat and shore based tenant commands. Port Operation’s primary focus is to 

provide safe, efficient, and timely hotel services to home-ported and visiting submarines, surface ships, and 

mine counter vessels. The secondary mission includes a facility response team for immediate oil spill 

response for over four nautical square miles of San Diego Bay (Commander, Navy Region Southwest, 

2023).

San Diego Bay, in the southwestern corner of California, is a 15-mile (24 km2) long, 0.2 to 3.6 miles (0.4 to 

5.8 km) wide embayment separated by a sand spit extending from Imperial Beach to approximately Point 

Loma, California (Largier, 1995; NAVFAC SW and the Port of San Diego, 2013). 

Water temperature is highest in the bay in July and August and temperatures are lowest in January and 

February. Surveys conducted in 1993 found temperatures to range from at 59.2°F (15.1°C) to 84.7°F 

(29.3°C) (Lapota et al., 1993; NAVFAC SW and the Port of San Diego, 2013). At the entrance of the bay 

salinity levels are similar to those of the ocean. However, as the bay continues to move away from the 

entrance channel, the area known as South Bay may produce salinities as high as 37 practical salinity unit 

(psu) in late summer, or as low as 22 psu following heavy rains (Ford, 1968; Ford and Chambers, 1973; 

NAVFAC SW and the Port of San Diego, 2013). 

Marine mammal surveys from February 2007 recorded five marine mammal species in the bay: harbor 

seals, California sea lions, bottlenose dolphins, Pacific white-sided dolphins and common dolphins (Merkel 

and Associates, 2008). 

Of note is the Port of San Diego, established in 1962, is responsible for the management of San Diego Bay 

and 34 miles of waterfront, serving five member cities (Chula Vista, Coronado, Imperial Beach, National 

City, and San Diego). The Port of San Diego oversees two maritime cargo terminals, two cruise ship 

terminals, 16 public parks, various wildlife reserves and environmental initiatives, a Harbor Police 

Department, and the leases of 600 tenant businesses around San Diego Bay (NAVFAC SW and the Port 

of San Diego, 2013). 
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Figure D-2: Naval Base Point Loma, California receiving location.

2.3 SELBY TERMINAL, CALIFORNIA

The Selby Terminal (Figure D-3) is a deep-water terminal located in northern California, within the San 

Pablo Bay (IndustryNet, 2023). San Pablo Bay is a shallow tidal estuary that forms the northern extension 

of the San Francisco Bay. Its waters are a mixture of fresh waters from the Sacramento, San Joaquin, 

Petaluma and Napa rivers, as well as the Central Valley, and the salt water from the Pacific Ocean. The 

bay is comprised of the open bay, mudflats and intertidal habitat, and tidal marsh. The open waters act as 

a migratory corridor for many fishes and invertebrates, and a foraging and resting habitat for birds. Over 

300 species of wildlife may occur within the San Francisco Bay estuary, inclusive of San Pablo Bay 

(USFWS, 2001). The San Pablo Bay National Wildlife Refuge, developed in 1974, aims to conserve and 

restore the bay wetlands for endangered species and migratory birds.
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Figure D-3: Selby Terminal, California receiving location.

2.4 PORT OF VANCOUVER, WASHINGTON

The Port of Vancouver (Figure D-4), founded in 1912, is 106 miles from the Pacific Ocean and is a deepwater port located on over 2,000 acres along the Columbia River. The Port is comprised of five terminals 

and 13 berths. With between 400 and 500 vessel calls annually, this port handles eight million tons of cargo 

annually. Port activities generate $3.8 billion in annual economic activity and support more than 3,900 direct 

jobs and over 24,000 regional jobs (Port of Vancouver USA, 2023).

The 258,000 square mile Columbia River drains more water to the Pacific Ocean than any other river in 

North or South America, with increased flows in the late spring and early summer (due to snowmelt), and 

lower flows in the fall and winter months (Marts, 2022; American Rivers, 2023). Vancouver, Washington 

and Portland, Oregon act the upper limit for oceangoing navigation. The river provides drinking water, 

irrigates 600,000 acres of farmland is a great source of hydroelectric power, producing a third of potential 

U.S. hydropower (Marts, 2022; America Rivers, 2023).

Many amphibians, birds, fish, mammals, and reptiles utilize the river, including endangered species of 

salmon, trout, and sturgeon (Columbia River Inter-Tribal Fish Commission, 2021).
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Figure D-4: Port of Vancouver, Washington receiving location.

2.5 MANCHESTER, WASHINGTON

The Manchester Fuel Depot (Figure D-5), which is a part of Naval Base Kitsap and managed by the U.S. 

Navy’s Fleet Logistics Center (FLC) Puget Sound Fuel Department, sits on approximately two miles of 

Puget Sound shoreline and is approximately seven miles west of Seattle, Washington (Fuel Department 

Fleet and Industrial Supply Center Puget Sound, Manchester Fuel Department, 2006; Smith, 2021). The 

mission of the depot is to provide bulk fuel and lubricants to military and government vessels activities, 

providing fuel support for the U.S. and allied forced throughout Puget Sound and the Pacific (Smith, 2021). 

The Pacific Northwest’s Puget Sound is the second largest estuary (EPA, 2023) in the U.S, in which 

saltwater from the Pacific Ocean mixes with freshwater runoff from the Olympic and Cascade Mountain 

watersheds. Puget Sound is polyhaline with salinity ranging from 24 to 30 parts per thousand (ppt.). It is a 

complex system of interconnecting basins with two connections to the Strait of Juan de Fuca, and thus the 

Pacific Ocean – the primary Admiralty Inlet and the minor Deception Pass (Lincoln, 2020). The Sound has 

an average depth of 450 ft. (maximum 930 ft.; Puget Sound Estuarium, 2023) and is part of a larger marine 

ecosystem, the Salish Sea (EPA, 2023). Puget Sound is composed of three basins (Whidbey Basin, South 

Sound, and the Main Basin). Additionally, Hood Canal is found to the west of Puget Sound (Puget Sound 

Estuarium, 2023).
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Puget Sound is home to hundreds of marine mammals, fishes, and marine invertebrates. Approximately 

3,300 ft. to the north of the Manchester Defense Fuel Supply Point is a marine protected area called the 

Orchard Rocks Conservation Area. This area is closed to fishing, harvesting, and possession of fish and 

shellfish. Closure does not affect the harvest of clams, oysters, and mussels by tideland owners and their 

families. The natural bedrock and boulders provide habitats for rock associated fish and invertebrate 

species. Dominant invertebrates include red rock crab, spider crabs, red sea cucumber, and orange sea 

cucumber. Harbor seals frequently visit the site and are often seen hauled out on the exposed rocks at low 

tide. California sea lions are also commonly observed at the site and may be seen hauled out on nearby 

navigational buoys (Carta, 2023).

Figure D-5: Manchester, Washington receiving location.
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2.6 U.S. NAVAL FUELING STATION, SASEBO, JAPAN

The Port of Sasebo (Figure D-6) is located on the western coast of Kyushu in Nagasaki Prefecture. It is a 

large-sized, deep-water port. Aside from the naval berths, the port area is home to numerous heavy 

industries and has berths for tanker operations. It is a fishing and commercial port, and is home to 

shipbuilding and related industry. Approximately 200 vessels visit the port annually.

Figure D-6: U.S. Naval Fueling Station, Sasebo, Japan receiving location.

2.7 SUBIC BAY, PHILIPPINES

The Philippine Coastal Storage and Pipeline Corporation (PCSPC) is located on a 160-hectare (1.6 km2; 

.6 mi2) facility in Subic Bay Freeport Zone (Figure D-7) and includes a marine terminal, fuel storage, and 

tank truck loading facilities. PCSPC is responsible for the overseeing of petroleum storage and pipeline 

facilities. The POL (Petroleum, oil and lubricants) pier is the marine terminal that occupies 7.2 hectares 

(.072 km2; .027 mi2) and includes two jetties, complete with marine loading arms and stations for berthing 

to discharge and load petroleum products (PCSCP, 2023). 
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Subic Bay (an embayment of the South China Sea) is a bay on the west coast of the island of Luzon in the 

Philippines (Britannica, The Editors of Encyclopedia, 2023). Until 1992, the U.S. operated Subic Bay Naval 

Station on the southeast coast of the bay. However, the area has since been re-developed into Subic Bay 

Freeport Zone, housing manufacturing plants, tourist facilities, and an international airport. One of the top 

tourism destinations Philippines, Subic Bay possesses a deep harbor protected by mountains and the 

Grande Island. Since 2012, U.S. warships have begun to have limited access to the port facilities 

(Britannica, The Editors of Encyclopedia, 2023). 

Subic Bay has a diverse load of marine species and is considered one of the best shipwreck diving locations 

in the Philippines. Water temperatures range from (79 - 86°F (26 - 30°C) and visibility ranges from 2 – 30 

m (7 - 98 ft.) (Dive Report, 2023). Although dated, in January and February of 1965 the U.S. Naval 

Oceanographic Office conducted a limited environmental survey in Subic Bay to measure environmental 

parameters. Salinity values ranged from 33.49 to 34.47 ppt. Core samples taken found high contents of 

clay and silt and maximum current speed was 0.4 knots (kts). The influence of tidal currents are thought to 

be responsible for the fluctuation of higher density waters through the entrance channel to Subic Bay on 

either slope of predicted high water (Kenney, 1970).

Figure D-7: Subic Bay, Philippines receiving location.
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2.8 PORT OF SINGAPORE

The Port of Singapore (Figure D-8), located on the southern end of Malay Peninsula, is the largest publicly 

owned port in the world (Ship Technology, 2020). It provides connectivity with 123 countries and 600 ports 

(Ship Technology, 2020), handling a wide variety of cargo, including containers and conventional and bulk 

cargo (Ship Technology, 2020; Maritime and Port Authority of Singapore, 2023). It is the busiest container 

transshipment hub and, in 2019, the port handled 37.2 million twenty-foot equivalent units (TCUs) of 

containers and 626.2 million tonnes of cargo (Ship Technology, 2020).

The Singapore Strait is an approximately 65 mile (105 km) long, ten mile (16 km) wide channel between 

the Strait of Malacca and South China Sea, and includes Johore Strait at the north (Britannica, The Editors 

of Encyclopedia, 2017). Because it provides the deep-water passageway to the Port of Singapore, the 

Singapore Strait is one of the world’s busiest commercial routes, with around 2,000 merchant ships traveling 

through the area daily (Liang and May-E, 2017).

Figure D-8: Port of Singapore receiving location.
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2.9 PORT OF DARWIN, AUSTRALIA

The Port of Darwin (Figure D-9), situated within Darwin Harbor, is located in Darwin, Northern Territory, 

Australia and operates commercial wharf facilities at East Arm Wharf and cruise and naval vessels at the 

Hill Wharf facility. The East Arm Wharf, the port handles containers and general cargo, bulk liquids, bulk 

materials, live exports, and heavy lift oversized cargos. The East Arm Wharf is comprised of four berths 

along 865 m of quay line (Landbridge Darwin Port, 2023). Darwin Harbor is a semi-diurnal, macro-tidal 

estuarine embayment (two high and two low tides every day), with tidal variations up to 8 m and a range of 

3.7 m. The harbor is comprised of mangroves, sandy beaches, tidal flats, rocky shore, and coastal cliffs, 

and has a high diversity of tropical marine biota (Tonyes, 2015).

Figure D-9: Darwin, Australia receiving location.
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3 Detailed Effects Analysis

The following section include an analysis of the likelihood and consequences of potential effects from the 

Proposed Action on fishes, marine mammals, and sea turtles. The Proposed Action would have no effect 

on marine invertebrates due to their demersal nature. Therefore, marine invertebrates are not discussed 

moving forward.

Section 7(a)(2) of the ESA of 1973, as amended (16 U.S. Code [U.S.C.] Section 1531 et seq.), requires 

federal agencies to consult with the National Marine Fisheries Service (NMFS) to ensure that any action it 

authorizes, funds, or carries out in the U.S. or upon the high seas is not likely to jeopardize the continued 

existence of any listed species, or result in the destruction or adverse modification of critical habitat of such 

species. Therefore, a separate biological evaluation was conducted for those species listed under the ESA.

The biological evaluation considered potential effects from the Proposed Action that may result from 

exposure to environmental stressors including elevated underwater sound levels and vessel collisions. A 

Letter of Concurrence (LOC) from NMFS was received on August 15, 2023 and is included in Appendix B.

NMFS also considered potential effects that may result from exposure oil spills in their LOC. A discussion 

of fuel spills is included in Chapter 3, Section 3.3.3.2 of the Environmental Assessment/Overseas 

Environmental Assessment.

3.1 UNDERWATER NOISE

The vessel transits for the Proposed Action will contribute to elevated underwater sound levels with 

increased vessel traffic, and thus have the potential to impact marine mammals, sea turtles, and fishes 

inside Joint Base Pearl Harbor-Hickam (JBPHH) and along the proposed shipping routes. The potential 

effects of elevated sound levels on marine mammals, sea turtles, and fishes may include:

• Direct, physiological effects – hearing sensitivity reduction, hearing damage, tissue injury, or 

mortality. 

• Direct, behavioral effects – disruptions to feeding, mating, breeding or nursery activities in such a 

way that impacts the survival or abundance of populations.

• Indirect effects – disruptions to the abundance and behavior of prey species; long-term change to 

population survival. 

A permanent threshold shift (PTS) occurs when an animal experiences a shift in their hearing threshold 

caused by extreme, prolonged or repeated exposure to high sound levels that results in permanent and 

irreversible damage (Richardson et al., 1995). A temporary threshold shift (TTS) occurs when an animal’s 

hearing threshold is temporarily increased (i.e., temporarily less sensitive to sound) during and immediately 

after exposure to a loud sound source (Richardson et al., 1995). TTS may have a duration of minutes to 

days to weeks, after which time full recovery is expected. 

3.1.1 Fishes

Fishes have two sensory systems, which can detect sound in the water: the inner ear, which functions 

similarly to the inner ear in other vertebrates, and the lateral line, which consists of a series of receptors 

along the body of a fish (Popper and Schilt, 2008). The lateral line detects particle motion at low frequencies 

below 1 hertz (Hz) up to least 400 Hz (Coombs and Montgomery, 1999; Hastings and Popper, 2005; Higgs 

and Radford, 2013; Webb et al., 2008). Additionally, some fishes possess additional morphological 

adaptations or specializations that can enhance their sensitivity to sound pressure, such as a gas-filled 

swim bladder (Astrup, 1999; Popper and Hastings, 2009). The swim bladder can enhance sound detection 

by converting acoustic pressure into localized particle motion, which may then be detected by the inner ear 

(Radford et al., 2012). Fishes with a swim bladder generally have better sensitivity and can detect higher 

frequencies than fishes without a swim bladder (Popper and Hastings, 2009; Popper et al., 2014). In 

addition, structures such as gas-filled bubbles near the ear or swim bladder, or even connections between 

the swim bladder and the inner ear, also increase sensitivity and allow for high-frequency hearing 

capabilities and better sound pressure detection. 
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Although many researchers have investigated hearing and vocalizations in fish species (Ladich and Fay, 

2013; Popper et al., 2014), hearing capability data only exist for just over 100 of the currently known 34,000 

marine and freshwater fish species (Eschmeyer and Fong, 2016). Therefore, fish hearing groups are 

defined by species that possess a similar continuum of anatomical features, which result in varying degrees 

of hearing sensitivity (Popper and Hastings, 2009). Categories and descriptions of hearing sensitivities are 

further defined in this document (modified from Popper et al. 2014) as the following: 

• Fishes without a swim bladder – hearing capabilities are limited to particle motion detection at 

frequencies well below 1 kilohertz (kHz). 

• Fishes with a swim bladder not involved in hearing – species lack notable anatomical 

specializations and primarily detect particle motion at frequencies below 1 kHz. 

• Fishes with a swim bladder involved in hearing – species can detect frequencies below 1 kHz and 

possess anatomical specializations to enhance hearing and are capable of sound pressure 

detection up to a few kHz. 

• Fishes with a swim bladder and high-frequency hearing – species can detect frequencies below 1

kHz and possess anatomical specializations and are capable of sound pressure detection at 

frequencies up to 10 kHz to over 100 kHz. 

Little data exist on the effects of vessel noise on hearing in fishes. However, TTS has been observed in 

fishes exposed to elevated background noise and other continuous sources (e.g., white noise). Caged 

studies on pressure-sensitive fishes show some hearing loss after several days or weeks of exposure to 

increased background sounds, although the hearing loss seems to recover (e.g., Scholik and Yan, 2002; 

Smith et al., 2004a; Smith et al., 2006). 

As noted in the American National Standards Institute (ANSI) Sound Exposure Guideline technical report 

(Popper et al., 2014), some fish species with a swim bladder that is involved in hearing may be more 

susceptible to TTS from long-duration, continuous noise (e.g., broadband white noise) depending on the 

duration of the exposure (i.e., thresholds based on continuous exposure of twelve hours). 

Masking refers to the presence of a noise that interferes with a fish’s ability to hear biologically important 

sounds including those produced by prey, predators, or other fishes. Masking occurs in all vertebrate groups 

and can effectively limit the distance over which an animal can communicate and detect biologically relevant 

sounds. Human-generated continuous sounds (e.g., vessel noise) have the potential to mask sounds that 

are biologically important to fishes. Researchers have studied masking in fishes using continuous masking 

noise but masking due to intermittent, short duty cycle sounds has not been studied. 

Masking could lead to potential fitness costs depending on the severity of the reaction (Radford et al., 2014; 

Slabbekoorn et al., 2010). For example, masking could result in changes in predator-prey relationships 

potentially inhibiting a fish’s ability to detect predators and therefore increase its risk of predation (Simpson 

et al., 2015; Simpson et al., 2016). Masking may also limit the distance over which fishes can communicate 

or detect important signals (Codarin et al., 2009; Ramcharitar et al., 2001, 2006). If the masking signal is 

brief (i.e., a few seconds or less), biologically important signals may still be detected, resulting in little effect 

to the individual. If the signal is longer in duration (i.e., minutes or hours) or overlaps with important 

frequency ranges for a particular species, more severe consequences may occur, such as the inability to 

attract a mate and reproduce. Holt et al. (2014) were the first to demonstrate the Lombard effect in one 

species of fish, a potentially compensatory behavior where an animal increases its vocalizations in 

response to elevated noise levels. The Lombard effect is currently understood to be a reflex, which may be 

unnoticeable to the animal or may lead to increased energy expenditure during communication. 

Although there is evidence of masking because of exposure to vessel noise, the ANSI Sound Exposure 

Guideline technical report (Popper et al., 2014) does not present numeric thresholds for this effect. Instead, 

relative risk factors are considered, and the probability of masking occurring is higher at near to moderate 

distances from the source (i.e., up to hundreds of meters (m)), and decreases with increasing distance 

(Popper et al. 2014). A fish must first be able to detect a sound above its hearing threshold and above the 

ambient noise level before a physiological stress reaction can occur. The initial response to a stimulus is a 

rapid release of stress hormones into the circulatory system, which may cause other responses such as 
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elevated heart rate and blood chemistry changes. Although an increase in background sound has been 

shown to cause stress in humans and animals, only a limited number of studies have measured biochemical 

responses by fishes to acoustic stress (e.g., Goetz et al., 2015; Madaro et al., 2015; Remage-Healey et al., 

2006; Smith et al., 2004b; Wysocki et al., 2006, 2007), and the results have varied. Researchers studied 

physiological stress in fishes using predator vocalizations, continuous, and impulsive noise exposures.

A stress response observed in fishes includes the production of cortisol (i.e., a stress hormone) when 

exposed to sounds such as boat noise, tones, or predator vocalizations. Nichols et al. (2015) found that 

giant kelpfish (Heterostichus rostratus) had increased levels of cortisol with increased sound level and 

intermittency of boat noise playbacks. A sudden increase in sound pressure level or an increase in overall 

background noise levels can increase hormone levels and alter other metabolic rates indicative of a stress 

response, such as increased ventilation and oxygen consumption (Pickering, 1981; Simpson et al., 2015, 

2016; Smith et al., 2004a, 2004b). Although results varied, chronic or long-term (i.e., days or weeks) 

exposures of continuous man-made sounds can lead to a reduction in embryo viability (Sierra-Flores et al., 

2015) and slowed growth rates (Nedelec et al., 2015). 

However, not all species tested to date show these reactions. Smith et al. (2004b) found no increase in 

corticosteroid, a class of stress hormones, in goldfish exposed to a continuous, band-limited noise (0.1 to 

10 kHz) with a sound pressure level of 170 decibel referenced to a pressure of 1 microPascal (dB re 1 μPa) 

for one month. Wysocki et al. (2007) exposed rainbow trout to continuous band-limited noise with a sound 

pressure level of about 150 dB re 1 μPa for nine months with no observed stress effects. Growth rates and 

effects on the trout’s immune systems were not significantly different from control animals held at a sound 

pressure level of 110 dB re 1 μPa. 

Fishes may have physiological stress reactions to sounds that they can hear. Generally, stress responses 

are more likely to occur in the presence of potentially threatening sound sources, such as predator 

vocalizations or the sudden onset of impulsive signals. Stress responses are typically brief (i.e., a few 

seconds to minutes) if the exposure is short or if fishes habituate or learn to tolerate the noise that is being 

presented. However, exposure to chronic noise sources can lead to more severe impacts such as reduced 

growth rates, which may lead to reduced survivability for an individual. It is assumed that any physiological 

response (e.g., hearing loss or injury) or significant behavioral response is also associated with a stress 

response.

Vessel traffic contributes to noise in the ocean and has the potential to affect fishes. Several studies 

demonstrated and reviewed avoidance responses by fishes (e.g., herring and cod) to the low-frequency 

sounds of vessels (De Robertis and Handegard, 2013; Engås et al., 1995; Handegard et al., 2003). Misund 

(1997) found fishes ahead of a ship that showed avoidance reactions at ranges of 50 to 150 m. When the 

vessel passed over them, some species of fish responded with sudden escape responses that included 

lateral avoidance or downward compression of the school.

Behavioral reactions are quite variable depending on a number of factors, such as the type of fish, its life 

history stage, behavior, time of day, and the sound propagation characteristics of the water column (Popper 

et al., 2014; Schwarz and Greer, 1984). Reactions to playbacks of continuous noise or passing vessels 

noted, in addition to the basic startle and avoidance responses, increased group cohesion, changes in 

vertical distribution in the water column, changes in swim speeds, and changes in feeding efficacy, such as 

reduced foraging attempts and increased mistakes (i.e., lowered discrimination between food and non-food 

items) (e.g., Bracciali et al., 2012; De Robertis and Handegard, 2013; Handegard et al., 2015; Nedelec et 

al., 2015; Neo et al., 2015; Payne et al., 2015; Purser and Radford, 2011; Sabet et al., 2016; Simpson et 

al., 2015, 2016; Voellmy et al., 2014a; Voellmy et al., 2014b). 

During exposures to vessel noise, juvenile Ambon damselfish (Pomacentrus amboinensis) and European 

eels showed slower reaction times and lacked startle responses to predatory attacks which subsequently 

increased their risk of predation during both simulated and actual predation experiments (Simpson et al., 

2015, 2016). In contrast, larval Atlantic cod showed a stronger anti-predator response and were more 

difficult to capture during simulated predator attacks (Nedelec et al., 2015). Although behavioral responses 

such as these were often noted during the onset of most sound presentations, these behaviors did not last 

long and animals quickly returned to baseline behavior patterns. In fact, in one study, when given the 
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chance to move from a noisy tank (with sound pressure levels reaching 120 to 140 dB re 1 μPa) to a quieter 

tank (sound pressure levels of 110 dB re 1 μPa), there was no evidence of avoidance. The fish did not 

seem to prefer the quieter environment and continued to swim between the two tanks comparable to control 

sessions (Neo et al., 2015). However, many of these reactions are difficult to extrapolate to real world 

conditions due to the captive environment in which testing occurred.

Most fish species should be able to detect vessel noise due to its low-frequency content and their hearing 

capabilities. The ANSI Sound Exposure Guideline technical report (Popper et al., 2014) suggests that fishes 

have a high to moderate probability of reacting to nearby vessel noise (i.e., within tens of meters) with 

decreasing probability of reactions with increasing distance from the source (hundreds or more meters).

3.1.2 Marine Mammals

In 2018, NMFS released technical guidance that provided received sound levels (or acoustic thresholds), 

above which individual marine mammals were predicted to experience changes in their hearing ability 

(NMFS, 2017). In this guidance, NMFS recognized five functional hearing groups for all marine mammals, 

and each group was assigned acoustic thresholds for underwater sound that cause a PTS and TTS. In 

addition, the guidance provided separate acoustic thresholds for impulsive sound sources and nonimpulsive/continuous sound sources (i.e., vessel noise). Table D-1 presents dual criteria for underwater, 

acoustic impact thresholds for PTS onset from impulsive sounds and one criterion for PTS from nonimpulsive sounds, as well as thresholds for TTS and behavioral impacts for impulsive and non-impulsive 

sounds. 

Table D-1: Acoustic Exposure Criteria for Non-impulsive Continuous Sounds: Marine Mammals

Acoustic Aspect Hearing Group Value

Underwater PTS Onset 

Acoustic Threshold for Nonimpulsive sounds

Low-frequency cetaceans (baleen whales) (SEL24h) 199 dB re 1 μPa

Underwater PTS Onset 

Acoustic Threshold for Nonimpulsive sounds

Mid-frequency cetaceans (dolphins, toothed 

whales, beaked whales, bottlenose whales) (SEL24h) 198 dB re 1 μPa

Underwater PTS Onset 

Acoustic Threshold for Nonimpulsive sounds

High-frequency cetaceans (true porpoises, 

Kogia, river dolphins, Cephalorhynchid, 

Lagenorhynchus cruciger and L. australis)

(SEL24h) 173 dB re 1 μPa

Underwater PTS Onset 

Acoustic Threshold for Nonimpulsive sounds

Phocid pinnipeds (underwater) (SEL24h) 201 dB re 1 μPa

Underwater PTS Onset 

Acoustic Threshold for Nonimpulsive sounds

Otariid pinnipeds (underwater) (SEL24h) 219 dB re 1 μPa

Underwater TTS Onset 

Acoustic Thresholds for NonImpulsive Sounds

Low-frequency cetaceans (baleen whales) (SEL24h) 179 dB re 1 μPa

Underwater TTS Onset 

Acoustic Thresholds for NonImpulsive Sounds

Mid-frequency cetaceans (dolphins, toothed 

whales, beaked whales, bottlenose whales) (SEL24h) 178 dB re 1 μPa

Underwater TTS Onset 

Acoustic Thresholds for NonImpulsive Sounds

High-frequency cetaceans (true porpoises, 

Kogia, river dolphins, Cephalorhynchid, 

Lagenorhynchus cruciger and L. australis)

(SEL24h) 153 dB re 1 μPa

Underwater TTS Onset 

Acoustic Thresholds for NonImpulsive Sounds

Phocid pinnipeds (underwater) (SEL24h) 181 dB re 1 μPa
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Acoustic Aspect Hearing Group Value

Underwater TTS Onset 

Acoustic Thresholds for NonImpulsive Sounds

Otariid pinnipeds (underwater) (SEL24h) 199 dB re 1 μPa

Underwater Behavioral Onset 

Acoustic Thresholds 

(Underwater)

All marine mammal species (SPLRMS) 120 dB re 1 μPa 

Notes: PTS = permanent threshold shift; TTS = temporary threshold shift; dB = decibel; μPa = micropascual; h= hours (Source: 

NMFS, 2017).

Any stimulus in the environment can cause a behavioral response in marine mammals. These stimuli 

include noise from anthropogenic sources such as vessels, sonar, air guns, or pile driving, but could also 

include the physical presence of a vessel or aircraft. However, these stimuli could also influence how or if 

a marine mammal responds to a sound such as the presence of predators, prey, or conspecifics. 

Furthermore, the response of a marine mammal to an anthropogenic sound may depend on the frequency, 

duration, temporal pattern and amplitude of the sound as well as the animal’s prior experience with the 

sound and their behavioral state (i.e., what the animal is doing and their energetic needs at the time of the 

exposure; NRC, 2003). The distance from the sound source and whether it is approaching or moving away 

can also affect the way an animal responds to a sound (Wartzok et al., 2004).

As previously described, masking occurs when one sound interferes with the detection or recognition of 

another sound. The quantitative definition of masking is the amount in decibels an auditory detection or 

discrimination threshold is raised in the presence of a masker (Erbe et al., 2016). Masking can effectively 

limit the distance over which a marine mammal can communicate, detect biologically relevant sounds, and 

echolocate [toothed whales (odontocetes)]. Masking only occurs in the presence of the masking noise and 

does not persist after the cessation of the noise. Masking can lead to vocal changes (e.g., Lombard effect, 

increasing amplitude, or changing frequency) and behavior changes (e.g., cessation of foraging, leaving an 

area) to both signalers and receivers in an attempt to compensate for noise levels (Erbe et al., 2016). 

Furthermore, masking is more likely to occur in the presence of broadband, relatively continuous noise 

sources, such as vessels. 

For example, right whales were observed to shift the frequency content of their calls upward while reducing 

the rate of calling in areas of increased anthropogenic noise (Parks et al., 2007), as well as increasing the 

amplitude (intensity) of their calls (Parks et al., 2009, 2011). Right whales also had their communication 

space reduced by up to 84 percent (%) in the presence of vessels (Clark et al., 2010). Although humpback 

whales did not change the frequency or duration of their vocalizations in the presence of ship noise, their 

source levels were lower than expected based on source level changes to wind noise, potentially indicating 

some signal masking (Dunlop, 2016).

3.1.3 Cetaceans (Whales, Dolphins)

Baleen whales are filter-feeding whales that demonstrate a variety of responses to vessel traffic and noise, 

from not responding at all to both horizontal (swimming away) and vertical (increased diving) avoidance 

(Baker et al., 1983; Gende et al., 2011; Watkins, 1981). Other common responses include changes in 

vocalizations, surface time, swimming speed, swimming angle or direction, respiration rates, dive times, 

feeding behavior, and social interactions (Au and Green, 2000; Richter et al., 2003; Williams et al., 2002).

The likelihood of a behavioral response may be driven by the distance or speed of the vessel, the animal’s 

behavioral state, or by the prior experience of the individual or population. When baleen whales do respond 

to vessels, behavioral responses can be minor changes in breathing patterns (e.g., Baker et al., 1983; 

Jahoda et al., 2003), or can be a decrease in overall presence, as was observed during a construction 

project in the United Kingdom, when fewer minke whales were observed as vessel traffic increased 

(Anderwald et al., 2013). Avoidance responses can be an alteration in swim patterns or direction by 

increasing speed and heading away from the vessel (Jahoda et al., 2003), or by increasing swim speed, 

changing direction to avoid, and staying submerged for longer periods of time (Au and Green, 2000). 
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In terms of cost to individual animals, whales may choose to stop vocalizing and move away from the sound 

source rather than adjusting their calls. Most whales in these studies continued singing after 30 minutes 

passed, suggesting that the behavioral impacts from the ship noise were temporary and recoverable. The 

long-term consequences of vessel noise are not well understood. 

Overall, baleen whale responses to vessel noise and traffic are varied but are generally minor, and 

habituation or disinterest was the documented predominant, long-term response. When baleen whales avoid 

ships, they may alter their swim and dive patterns to move away from the vessel, but no strong reactions 

observed. In many cases, the whales do not appear to change their behavior at all. This may result from 

habituation by the whales but may also result from reduced received levels near the surface due to 

propagation, or due to acoustic shadowing of the propeller cavitation noise by the ship’s hull. Behavioral 

responses are evidence that individual animals are most likely compensating or overcoming the increased 

underwater noise in the environment. However, these responses are mostly temporary, recoverable, and 

ceasing once the noise source ends.

Most odontocetes (toothed whales) react neutrally to vessels, although both avoidance and attraction 

behaviors have been observed (Hewitt, 1985, Würsig et al., 1998). Sperm whales generally reacted only to 

vessels approaching within several hundred meters; however, some individuals displayed avoidance 

behavior, such as quick diving (Magalhães et al., 2002; Würsig et al., 1998) or a decrease in time spent at 

the surface (Isojunno and Miller, 2015). One study showed that after diving, sperm whales showed a 

reduced timeframe before they emitted the first click than prior to a vessel interaction (Richter et al., 2006). 

Odontocetes may make short-term changes to vocal parameters, such as intensity as an immediate 

response to vessel noise, as well as increase the pitch, frequency modulation, and length of whistling (MayCollado and Wartzok, 2008), with whistle frequency increasing in the presence of low-frequency noise and 

whistle frequency decreasing in the presence of high-frequency noise (Gospić and Picciulin, 2016). Killer 

whales are also known to modify their calls during increased noise. For example, the source level of killer 

whale vocalizations was shown to increase with higher background noise levels associated with vessel 

traffic (i.e., the Lombard effect; Holt et al., 2008). In addition, calls with a high-frequency component have 

higher source levels than other calls, which may be related to behavioral state, or may reflect a sustained 

increase in background noise levels (Holt et al., 2011). On the other hand, long-term modifications to 

vocalizations may be indicative of a learned response to chronic noise, or of a genetic or physiological shift 

in the populations. This type of change has been observed in killer whales off the northwestern coast of the 

U.S. between 1973 and 2003. This population increased the duration of primary calls once a threshold in 

observed vessel density (i.e., whale watching) was reached, which is suggested as being a long-term 

response to increased masking noise produced by the vessels (Foote et al., 2004).

While in general, the louder the sound source the more intense the behavioral response, it was clear that 

the proximity of a sound source and the animal’s experience, motivation, and conditioning were also critical 

factors influencing the response (Harris et al., 2018; Southall et al., 2016). Ellison et al. (2011) outlined an 

approach to assessing the effects of sound on marine mammals that incorporates contextual-based factors 

and not just the received sound level. These contextual-based factors include what activity the animal is 

engaged, the nature and novelty of the sound (i.e., is this a new sound from the animal’s perspective), and 

the distance between the sound source and the animal. “Exposure context” greatly influenced the type of 

behavioral response exhibited by the animal (see technical report Criteria and Thresholds for U.S. Navy 

Acoustic and Explosive Effects Analysis (Phase III) (NAVFAC PAC, 2017b)). Forney et al. (2017) 

determined that an apparent lack of response (e.g., no displacement or avoidance of a sound source) may 

not necessarily mean that there is no cost to the individual or population, as some resources or habitats 

may be of such high value that animals may choose to stay, even when experiencing stress or hearing loss. 

Rather, Forney et al. (2017) recommended considering both the costs of remaining in an area of noise 

exposure. These costs include TTS, PTS or masking, which could lead to an increased risk of predation or 

other threats or a decreased capability to forage. The costs of displacement included potential increased 

risk of vessel strike or bycatch, increased risks of predation or competition for resources, or decreased 

habitat suitable for foraging, resting, or socializing. 

Odontocete responses to vessel noise are varied, although many odontocete species seem to be more 

sensitive to vessel presence and vessel noise, and these two factors are difficult to tease apart. Some 
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species, in particular killer whales, may be sensitized to vessels and respond at further distances and lower 

received levels than other delphinids (oceanic dolphins). In contrast, many odontocete species also 

approach vessels to bow ride, indicating either that these species are less sensitive to vessels, or that the 

behavioral drive to bow ride supersedes any impact of the associated noise. With these broad and disparate 

responses, it is difficult to assess the impacts of vessel noise on odontocetes.

3.1.4 Pinnipeds (Seals, Sea Lions)

Pinniped behavioral reactions to vessels are variable, and reports included a wide spectrum of possibilities, 

from avoidance and alert to cases where animals in the water are attracted, and cases on land where there 

is lack of significant reaction suggesting habituation to or tolerance of vessels (Richardson et al., 1995). 

Specific case reports in Richardson et al. (1995) vary based on factors such as routine anthropogenic 

activity, distance from the vessel, engine type, wind direction, and ongoing subsistence hunting.

The hearing abilities of most pinniped species are poorly understood. Although Hawaiian monk seals 

produce low-frequency vocalizations while on shore, production of underwater calls have not been 

opportunistically observed by divers (Sills et al., 2022), nor confirmed in previous research (Southall et al., 

2019). Hawaiian monk seals produced vocalizations underwater in a captive study that correlated with a 

period of annual reproductive activity (Sills et al., 2022). 

A recent study determined that monk seals have a functional hearing range in-air of 100 hertz (Hz) to 33 

kilohertz (kHz) with lower sensitivity than other seal species. With respect to peak sensitivity in water, this 

monk seal showed elevated thresholds compared to other phocid (true seals) species but had more 

sensitive hearing than another Hawaiian monk seal tested over 30 years prior (Thomas et al., 1990). 

Results of the two 2021 studies (Ruscher et al., 2021; Sills et al., 2022) demonstrated that Hawaiian monk 

seals hear better at low frequencies than previously documented, displaying elevated underwater 

thresholds and a narrower frequency range of hearing. In addition, it appeared from the studies that 

monachid seals have less sensitive hearing that other phocids. Even so, Hawaiian monk seals may be 

more vulnerable to the effects of anthropogenic sounds in the environment than previously known (Sills et 

al., 2022). 

3.1.5 Sea Turtles

Based on the best available scientific data, the Navy derived guidance that provided reasonable threshold 

values upon which potential effects to sea turtles from impulsive and non-impulsive sound were evaluated 

(NAVFAC PAC, 2017b). The NMFS acoustic spreadsheet (NMFS, 2020, Version 2.0) and multi-species 

spreadsheet (NMFS, 2021) also included these acoustic thresholds for sea turtles. Unweighted, peak 

pressure thresholds for TTS and PTS were developed for sea turtles based on auditory sensitivity in marine 

mammals (NAVFAC PAC, 2017a). Popper et al. (2014) recommended applying sound exposure level (SEL) 

based impact thresholds developed for fishes without a swim bladder to sea turtles, which was adjusted 

based on an 11- dB difference found between the SEL-based, non-impulsive TTS threshold and the SELbased, impulsive TTS thresholds for marine mammals. Based on guidance provided in NMFS acoustic 

thresholds, sea turtles may respond behaviorally to underwater sound pressure levels, root mean square 

(SPLRMS) of 175 dB re 1 micropascual (μPa) or greater (NMFS 2020b, Version 2.0). This acoustic threshold 

is considered the behavioral threshold, and the adjusted weighted SELs and behavioral threshold for sea 

turtles are shown below (Table D-2).
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Table D-2: PTS, TTS, and Behavioral Thresholds for Sea Turtles Exposed to Impulsive and NonImpulsive Sounds

Auditory Effect Impulsive Impulsive Non-Impulsive/continuous

Unweighted

SPL Threshold

re 1 μPa

Weighted

SPL Threshold

re μPa2•s

Weighted

SPL Threshold

re μPa2•s

PTS 232 dB Peak 204 dB SELcum 220 dB SELcum

TTS 226 dB Peak 189 dB SELcum 200 dB SELcum

Behavior 175 dB RMS 175 dB RMS 175 dB RMS

Notes: μPa = micropascual; s = second; PTS= permanent threshold shift; TTS= temporary threshold shift; dB = decibel; SELcum= 

cumulative sound exposure levels; RMS= root mean square 

Source: NAVFAC PAC 2017a, NMFS 2021.

Sea turtle auditory sensitivity levels and functional morphology are not clearly defined nor well understood 

in the scientific literature. Morphological investigations demonstrated that sea turtles are poor auditory 

receptors to airborne sound and have adaptations for underwater sound reception, such as subtympanal 

fat with density like seawater and middle ear air retention (Piniak et al., 2016; Popper et al., 2014). 

Underwater audiograms for six sub-adult and two juvenile green turtles showed hearing sensitivities that 

were specialized for low-frequency levels (Bartol and Ketten, 2006). Similarly, another study produced 

underwater, auditory evoked potential audiograms for five juvenile green sea turtles with the same peak, 

low-frequency hearing sensitivity but with a wider hearing range overall (Piniak et al., 2016). The green sea 

turtles had lower SPL thresholds in air than underwater at (relatively) higher frequencies (i.e., >400 Hz). 

Hawksbill sea turtle hatchlings were capable of hearing underwater sounds at frequencies of between 50 

and 1,600 Hz, with maximum sensitivity at 200 to 400 Hz (Piniak, 2012). Hearing below 80 Hz is less 

sensitive but still possible (Lenhardt, 1994).

Information on the importance of acoustic stimuli for sea turtles is lacking, especially to determine impacts 

from natural and anthropogenic sound sources (e.g., explosions, sonar, or pile driving sound; Popper et al. 

2014). Sea turtle susceptibility to PTS has not been investigated, and TTS evidence in sea turtles is limited 

to scattered records and anecdotal accounts. Sea turtle behavioral responses to sounds were investigated 

mostly with seismic sound sources (NAVFAC PAC, 2017b; NMFS 2017) – an impulsive sound, whereas 

vessel noise is non-impulsive. 

An early study documented sea turtle behavioral changes following exposure to seismic airgun sound 

(Moein et al., 1994). Kept in sea cages, the juvenile loggerhead turtles (Caretta caretta) increased their 

swim speed and showed the first signs of a behavioral response when airgun levels exceeded SPLrms 166 

dB re 1 μPa. When airgun levels were increased above SPLRMS 175 dB re 1 μPa, the turtles’ swimming 

behavior became more erratic and suggested that the animals were in an agitated state. Based on these 

results, it may be that turtles would choose to swim away from or avoid loud noise, since it may cause 

agitation. It is important to note that exposure studies were undertaken with captive animals in controlled 

environments, and the results must be extrapolated carefully to open-water marine areas with different 

sound propagation and where animals may swim away freely from the sound source (Nelms et al., 2016). 

Furthermore, sea turtles rely more on visual cues than auditory input and are less sensitive to acoustic 

disturbances than cetaceans (Hazel et al., 2007)

3.1.6 Environmental Consequences

The worldwide merchant fleet of modern, commercial ships over 100 gross tonnage (GT) comprises 

approximately 100,000 ships with a combined total of about 830 million GT (McKenna et al., 2011). 

Commercial vessel types depend on the goods carried, and the different cargo influences the design and 

operating conditions of different ships. For carrying bulk goods, specifically designed ships include both 

bulk carrier and tanker ship-types, and these ship types comprise about 35% of global fleet. Categories of 
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tankers include crude oil tankers, product, or chemical tankers (UNCTD, 2008). The largest of the crude oil 

tankers transport unrefined crude oil from the location of extraction to refineries, while product tankers carry 

refined petrochemicals. Chemical tankers are similar in size to product tankers and carry chemical products, 

and general cargos occupy the largest single category (32%) in the world merchant fleet (UNCTD, 2008). 

Several factors influence the underwater noise emissions of individual vessels, such as vessel speed, draft, 

size, and loading. In addition, large commercial vessels in the same category may generally travel at 

different speeds and have different, baseline noise emissions due to vessel design, and the sources of 

underwater noise are from the propeller, machinery, and the hull design (MacGillivray et al., 2019). The 

vessel’s propulsion system is the dominant source for sounds below 200 Hz. Most of the ocean-going 

vessels have two-stroke engines that connect directly to the ship’s hull, and due to vibrations, transmit noise 

underwater. Propeller cavitation in slow-speed, diesel engines create tones from approximately 100 to 

1,000 Hz, and large ships typically produce the greatest noise at low frequencies, in the 10 to 300 Hz 

frequency band (Richardson et al., 1995). The noise consists of narrowband tonal sounds below 50 Hz and 

broadband sounds that have greatest energy between 50 to 150 Hz. Commercial vessels (>135 m) typically 

cruise at speeds between 16 to 17 kts and emit noise with estimated source levels between 155-190 dB re 

1μPa at 1 m (Table D-3). A 54,000 GT container ship had the highest broadband source level at 188 dB re 

1μPa at 1m; while a 26,000 GT chemical tanker had the lowest at 177 dB re 1μPa at 1m. Bulk carriers had 

higher source levels near 100 Hz, while container ship and tanker noise (which will be used in the Proposed 

Action) was predominantly below 40 Hz (McKenna et al., 2012). 

Table D-3: Estimated Source Levels of Noise Components From Vessels.

Vessel Type Dominant Frequency (Hz) Source Level (dB re 1μPam) Frequency Range

Outboard 630 156 100 Hz – 3 kHz

Trawler 100 158 50 Hz – 1 KHz

Conventional Tug 1,000 164 10 Hz – 1 kHz

Tanker 60 180 -

Bulk Carrier 100 173 -

Supertanker 6.8 190 50 Hz – 300 Hz

Notes: Hz = Hertz; dB= decibel; μPa= micropascual; m= meter

(Source: Bowles et al. 2007)

The tanker ships used for relocating fuel with Alternatives 2 and 3 would have a total internal cargo volume 

of about 25,487 GT, a length of 180 m, a beam (i.e., width measured at widest point) of 32 m, and a draft 

(i.e., how shallow the boat will enter the water) of 10.275 m. Based on published data, the tanker ships 

would produce lower sound levels compared to larger commercial vessels, and with dominant sound 

frequency levels around 40 to 60 Hz. These sound levels are significantly lower than the thresholds for 

continuous sound likely to cause PTS or TTS in marine mammals and sea turtles. Furthermore, in deep 

water, underwater sound decays by about 60 dB within the first 500 m of distance from a large ship, with 

most of the decay within the first 100 m (Bowles et al., 2007). Therefore, it is not anticipated that the 

underwater noise from the tanker ships used to transport the fuel would cause either TTS or PTS, but may 

cause temporary and recoverable behavioral disturbance. While commercial vessel sounds are unlikely to 

cause serious injury to marine species, ship noise has the potential to mask sounds that animals depend 

on for communication, navigation, and finding mates or prey. 

The overall number of eleven, one-way vessel trips to deliver the fuel is low compared to the hundreds of 

commercial ships that transit to these locations every day, further reducing the likelihood of overlap in space 

and time with the tanker ships and marine fauna. 

3.2 VESSEL COLLISION

While surfacing to breathe, rest or forage, marine mammals, sea turtles, and some large, slow moving 

species of fish (e.g., manta ray) may be at risk of a collision with moving vessels. The type and severity of 

injury depends upon the size of the vessel, the speed and direction of the vessel if in motion, the part of the 
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vessel that strikes the animal (i.e., hull vs. propeller), and the part of the animal’s body that was impacted. 

Depending on these factors, a vessel collision has the potential to cause serious injury or death. 

Vessel speed is a significant factor in the likelihood of a lethal vessel/whale collision: the greater the speed 

at impact, the greater the risk of mortality (Conn and Silber, 2013; Gende et al., 2011; Silber et al., 2010; 

Vanderlaan and Taggart 2007; Woitzik et al., 2016). Vanderlaan and Taggart (2007) found that the chance 

of lethal injury to a large whale from a vessel strike increases from about 20% at 8.6 kts to 80% at 15 kts. 

For large vessels, speed and angle of approach can influence the severity of a strike. Based on modeling, 

Silber et al. (2010) found that whales at the surface experienced impacts that increased in magnitude with 

the ship’s increasing speed.

3.2.1 Fishes 

Vessels do not normally collide with adult fishes, most of which can detect and avoid them. However, there 

are a few notable exceptions to this assessment of potential vessel strike impacts on fish groups. Large 

slow-moving fishes, may occur near the surface in open-ocean and coastal areas, thus making them more 

susceptible to ship strikes which may result in blunt trauma, lacerations, fin damage, or mortality (Braun et 

al., 2015; Couturier et al., 2012; Deakos et al., 2011; Graham et al., 2012; Miller and Klimovich, 2017). 

Species, such as manta rays, are presumed to be susceptible to vessel strikes due primarily to their large 

size, slow swimming speed, and distribution in the upper portion of the water column (Couturier et al., 2012; 

NMFS, 2016). Very little quantitative information on the frequency of vessel strikes is available and no 

information exists on the impact of injuries and mortalities resulting from vessel strikes to the overall health 

of the population (NMFS, 2016). 

3.2.2 Ceteceans (Whales, Dolphins)

Vessel strikes from commercial, recreational, and military vessels are known cause serious injury and 

occasional fatalities to cetaceans (Abramson et al., 2011; Berman-Kowalewski et al., 2010; Laggner, 2009; 

Van der Hoop et al., 2012, 2013; 2015). Reviews of the literature on ship strikes mainly involve collisions 

between commercial vessels and whales (Jensen et al., 2003; Laist et al., 2001). Ship strikes are a growing 

concern for most marine mammals, and mortality may be a more significant concern for species that occupy 

areas with high levels of vessel traffic because the likelihood of encounter would be greater (Currie et al., 

2017, Rockwood et al., 2017, Van der Hoop et al., 2013, 2015). For example, while some risk of a vessel 

strike exists for all the U.S. west coast waters, 74% of blue whale, 82% of humpback whale, and 65% of fin 

whale known vessel strike mortalities occur in the shipping lanes associated with the ports of San Francisco 

and Los Angeles/Long Beach (Rockwood et al., 2017).

Since 1995, the U.S. Navy and Coast Guard reported all known or suspected vessel collisions with whales 

to NMFS. The assumed under-reporting of whale collisions by vessels other than U.S. Navy or U.S. Coast 

Guard makes any comparison of data involving vessel strikes heavily biased. NMFS documented this 

under-reporting (Bradford and Lyman, 2015), including unreported vessel strikes by civilian vessels. From 

2007-2012, NMFS provided a five-year data period of ship strikes in Hawaii, including 37 reported vessel 

collisions between humpback whales and vessels other than those characterized as “military”, and two 

attributed to the Navy (Bradford and Lyman, 2015). From 2010 through 2014, seven marine mammal vessel 

or boat strikes reported off San Diego (Carretta et al., 2022) included two California sea lions, one fin whale, 

two gray whales, and two humpback whales. For the U.S. West Coast between 2011 and 2015, 65 nonNavy vessel strikes involved marine mammals: 32 pinnipeds, 28 large whales, and five smaller cetaceans 

(Carretta et al., 2017). Vessel strikes have been documented for almost all the mysticete (i.e., baleen whale) 

species (Van der Hoop et al., 2012, 2013, 2015). 

In southern California, evidence of significant mortality of baleen whales (mostly from data on blue, fin, and 

humpback whales) from commercial ship strikes in the Santa Barbara Channel of Southern California 

prompted a detailed analysis of factors and resolutions. There are approximately 6,500 commercial vessels 

annually using the Santa Barbara Channel (NOAA Fisheries, 2023a). For San Diego Bay and its entrance 

channel, about 225 commercial ships transit the bay per day, most during daylight hours, plus an unknown 

but potentially equal number of recreational vessels moving in and out of San Diego Bay. Underwater noise 
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from passing ships is expected every few minutes in the North Bay (Lapota et al., 1993). An additional large 

number of vessels also transit farther offshore along the coast heading to ports beyond those in Southern 

California. Stranding locations appeared to be concentrated near major southern California ports, 

suggesting an increased likelihood of commercial vessel interactions (Berman-Kowalewski et al., 2010). 

This area appeared to be highly problematic, largely because it represented an overlap of important feeding 

grounds for these species of whale with a major shipping lane to/from Southern California ports (Abramson 

et al., 2011). Between 1988 and 2007, 21 blue whale deaths were reported along the California coast, and 

many of these showed evidence of ship strike (Berman-Kowalewski et al., 2010). In 2007, NOAA declared 

an Unusual Mortality Event (UME) for endangered blue whales in Southern California from commercial 

vessel ship strikes in that year. Several recommendations have been put forward to reduce the potential 

for future ship strikes in the area of southern California commercial ports, including continuing and 

expanding scientific studies, considering changing shipping patterns and lanes, and adaptive management 

approaches.

Research suggested that the increasing noise in the ocean made it difficult for whales to detect approaching 

vessels, which has indirectly raised the risk of vessel strike (Elvin and Taggart, 2008). For example, right 

whales showed little overall reaction to the playback of sounds of approaching vessels, suggesting that 

some whales perform only a last-second flight response (Nowacek et al., 2004). It is possible that some 

individuals habituate to low-frequency sounds from shipping and fail to respond to an approaching vessel 

(NMFS, 2017). Whales engaged in surface activities (e.g., feeding, breeding, and resting) may not notice 

an approaching vessel (Silber et al., 2010). 

Generally, mysticetes are larger animals with less ability to maneuver away from and to avoid vessels. In 

addition, mysticetes do not typically aggregate in large groups and are therefore difficult to detect visually 

from the water surface. Mysticetes that occur within the Alternative 2 transit routes have varying patterns 

of occurrence and distribution, which overlap with the commercial shipping routes through which the tanker 

ships may travel.

In general, odontocetes (i.e., toothed whales) move quickly and seem to be less vulnerable to vessel strikes 

than other cetaceans. However, killer whales (Van Waerebeek et al., 2007; Visser and Fertl, 2000) and 

sperm whales (Jaquet and Whitehead, 1996; Watkins et al., 1999, Gannier and Marty, 2015) are potentially 

susceptible to vessel strikes.

Available literature suggests based on their smaller body size, maneuverability, larger group sizes, and 

hearing capabilities, most odontocetes (except for sperm whales) are not as likely to be struck by a tanker 

ship. When generally compared to mysticetes, odontocetes are more capable of physically avoiding a 

vessel strike, and since some species occur in large groups, odontocetes are seen when are closer to the 

water surface. Overall, collision avoidance success is dependent on a marine mammal’s ability to identify 

and locate the vessel from its radiated sound and the animal’s ability to maneuver away from the vessel in 

time. Sperm whales may be vulnerable to vessel strikes as they spend extended periods of time “rafting” 

at the surface in order to restore oxygen levels within their tissues after deep dives (Jaquet and Whitehead, 

1996, Watkins et al., 1999). Based on hearing capabilities and dive behavior, sperm whales may not be 

capable of successfully completing an escape maneuver, such as a dive, in the time available after 

perceiving a fast-moving vessel, supporting the suggestion that vessel speed is a critical parameter for 

sperm whale collision risks (Gannier and Marty, 2015).

3.2.3 Pinnipeds (Seals, Sea Lions)

Vessels have a potential to cause behavioral disturbance to pinnipeds, although at variable levels related 

to the context of the situation and the animal’s experience (Richardson et al., 1995; Southall et al., 2016). 

Reactions include a wide spectrum of effects, from avoidance and alert, and from animals in the water that 

were attracted, to animals on land with a lack of significant reaction suggesting habituation to or tolerance 

of vessels (Richardson et al., 1995). Physical disturbance to hauled-out harbor seals caused by 

approaching cruise ships (Blundell and Pendleton, 2015; Jansen et al., 2015; Young et al., 2014) and by 

the presence of powerboats and kayaks that stopped, lingered, or moved slowly along haul-out sites 

(Johnson and Acevedo-Gutiérrez, 2007) have been documented. It is unlikely that the Proposed Action’s 

tanker ships would cause a disturbance to pinnipeds on land because the vessels would not purposefully 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

D-26

approach pinnipeds on land. At sea, vessel presence may result in minor and insignificant changes in 

behavior in pinnipeds. 

Ship strikes are not a major concern for pinnipeds in general, including the threatened Guadalupe fur seal 

or the endangered Hawaiian monk seal (Antonelis et al., 2006; Marine Mammal Commission, 2002; NMFS, 

2014). From 2010 to 2014, reported sources of human-related injury and mortality for the U.S. West Coast 

documented eleven California sea lions, fifteen harbor seals, and two northern elephant seals having 

injuries caused by boat propellers or small boat collisions (Carretta et al., 2022). Mortalities of pinnipeds 

(specifically harbor seals and gray seals) initially hypothesized to be injuries from ducted propellers were 

caused by gray seal predation, cannibalism, and infanticide (Brownlow et al., 2016). Pinnipeds in the water 

generally appear less responsive (Richardson et al., 1995) than those at haul-out sites. In some 

circumstances, individual animals respond to vessels with the same behavioral responses as predator 

encounters. 

For Hawaiian monk seals, vessel traffic in the Main Hawaiian Islands is recognized as a risk for collisions, 

despite only a single recorded mortality in 2015 that was deemed most likely due to boat strike (Carretta et 

al., 2022). The chance that such a rare encounter would result in serious injury is extremely remote because 

of the low probability that a Hawaiian monk seal would overlap with the limited number of vessel movements 

(i.e., eleven) within Pearl Harbor from the Proposed Action. 

3.2.4 Sea Turtles

Vessel collisions are a major threat for sea turtles (NMFS and USFWS, 1998). Research suggested that 

sea turtles might not consistently detect and avoid vessels traveling at speeds over 2 kts (Hazel et al., 

2007). Studies showed that when a vessel was traveling at a slow speed (i.e., <2 kts), the proportion of 

green sea turtles (either on the sea surface or in shallow coastal waters) that avoided approaching vessels 

by moving away from the vessels track was significantly greater than if the vessel was moving at moderate 

to fast speeds (Hazel et al., 2007). While the potential for vessel strikes at various speeds has not been 

quantified, higher vessel speeds were more likely to cause impacts, particularly in shallow waters where 

turtles were abundant and in turbid waters. Therefore, the success of avoiding a vessel strike with a sea 

turtle is largely dependent on the speed of the approaching vessel and the prevailing water clarity, rather 

than vessel type. 

The U.S. Navy and NMFS estimated that 250 sea turtles are struck by vessels in Hawaii (NAVFAC PAC, 

2017a). To estimate the rate of vessel strikes, the Navy used ship hours (number of hours that vessels 

were at sea), but it only included vessels 65 ft. long and larger. Additionally, there was an estimated 37.5 

vessel strikes of sea turtles per year from an estimated 577,872 trips from vessels of all sizes in Hawaii 

(NOAA Fisheries 2023b). Using this estimate, this calculates to a 0.04% probability of a vessel strike for all 

vessels and trips, many of which are not reducing speeds or employing lookouts for listed species. Based 

on turtle stranding data from Pearl Harbor from 2006-2020, 34 incidents identified the cause of stranding 

to be boat impact. Of the total 283 turtle stranding reports from Pearl Harbor during this time, the strandings 

attributed to boat impacts represents 8.8% of all possible stranding events (NMFS 2021, Unpublished).

3.2.5 Environmental Consequences

The tanker ships in Alternatives 2 and 3 would travel at an average speed of around 15 kts. By comparison, 

this is slower than most commercial vessels, where full speed for a container ship is typically 24 kts (Bonney 

and Leach 2010). Given the advent of “slow steaming” by commercial vessels in recent years due to 

increasing fuel prices (Barnard, 2016; Maloni et al., 2013), a vessel speed reduction to 21 kts would be 

considered “slow”, with eighteen kts considered as “extra slow”, and fifteen kts considered “super slow” 

(Bonney and Leach, 2010). Compared to these average speeds of other commercial vessels, the tanker 

ships used in the Proposed Action would have significantly slower speeds, further reducing the likelihood 

of a collision with a marine species. In addition, the overall number of eleven, one-way, vessel trips to 

deliver the fuel is low considering the hundreds of commercial ships that transit to these locations every 

day, reducing the likelihood of overlap in space and time with the tankers and a marine species. 
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

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E-1

APPENDIX E – CLEAN AIR ACT GENERAL 

CONFORMITY NON-APPLICABILITY ANALYSES 

AND AIR EMISSIONS WORKSHEETS
E-2

RECORD OF NON-APPLICABILITY

FOR CLEAN AIR ACT CONFORMITY

SAN DIEGO COUNTY

The Proposed Action, including the two action alternatives described below, falls under the Record of NonApplicability (RONA) category and is documented with this RONA. 

The U.S. Environmental Protection Agency (USEPA) published Determining Conformity of General Federal 

Actions to State of Federal Implementation Plans; Final Rule on November 30, 1990 (58 Federal Register 

[FR] 63214; 40 Code of Federal Regulations [CFR] Parts 6, 51, and 93). The U.S. Department of the Navy 

(Navy) published Navy Guidance for Compliance with the Clean Air Act (CAA) General Conformity Rule 

(30 July 2013), as referenced in Chief of Naval Operations Manual 5090.1. These publications provide 

implementing guidance to document CAA Conformity Determination requirements. Federal regulations 

state that no department, agency, or instrumentality of the Federal Government shall engage in, support in 

any way or provide financial assistance for, license to permit, or approve any activity that does not conform 

to an applicable implementation plan. It is the responsibility of the federal agency to determine whether a 

federal action conforms to the applicable implementation plan, before the action is taken (40 CFR Section 

51.850[a]). 

The General Conformity Rule applies to federal actions proposed within areas that are designated as either 

nonattainment or maintenance for a National Ambient Air Quality Standard (NAAQS) for any of the criteria 

pollutants. Emissions of criteria pollutants within an area that is designated as attainment are exempt from 

general conformity analyses. 

Federal actions within nonattainment or maintenance areas may be exempt from conformity determinations 

if their emissions of criteria pollutants do not exceed designated de minimis thresholds for the criteria 

pollutants (40 CFR Section 51.853[b]). The San Diego Air Basin has been determined by USEPA to be a 

serious and moderate nonattainment area for 8-hour O3 under the 2008 and 2015 standards, respectively. 

The State has classified the area as non-attainment for Particulate Matter (PM)2.5 and PM10. The 

applicable de minimis thresholds for San Diego Air Basin are listed in Table 1. 

Table 1. de minimis Levels for Criteria Pollutants in the San Diego Air Basin

Criteria Pollutants de minimis Thresholds (tons per year [tpy])

Volatile Organic Compounds (VOC) 25

Oxides of Nitrogen (NOx) 25

PM2.5 100

PM10 70

Note: VOC and NOx emissions are used to represent O3 generation because they are precursors of O3. 

PROPOSED ACTION 

Action Proponent: Joint Task Force Red Hill and Defense Logistics Agency

Title of Proposed Action: Red Hill Defueling and Fuel Relocation

Project Location: San Diego Bay 

Proposed Action and Emissions Summary: JTF-RH and DLA are proposing to relocate the fuel from Red 

Hill Bulk Fuel Storage Facility at Joint Base Pearl Harbor Hickam, Oahu, Hawaii. One of the potential 

receiving locations is Point Loma, San Diego Bay.

JTF-RH and DLA have identified two action alternatives: 

• Alternative 2: Relocation 
E-3

• Alternative 3: Commercial Sale and Relocation

Under both Alternatives 2 and 3, up to two (2) tanker shipments would arrive at the port at Point Loma. 

Air Emissions Summary:

The proposed transit and off-loading of fuel from two tanker vessels under Alternatives 2 and 3 would result 

in temporary air emissions from tankers over a period of up to 3 days per trip. Emissions from vessel 

transit/maneuvering within 3 nautical miles (NM) and hotelling from the tanker’s engines and boilers would 

emit criteria pollutants and HAPs. Fugitive emissions (volatile organic compounds) would also occur during 

ship transit and off-loading of fuel at the pier. Emissions also include the use of two tugboats to assist the 

tanker to the port.

In Table 2, VOCs and NOx, precursors for ozone, were evaluated against de minimis criteria in Table 1. 

Emissions were estimated as those occurring within 3 NM of California for this destination port. 

Table 2. Emissions Under Alternative 2 or Alternative 3, Two Vessel Trips to Point Loma

Mode VOCs NOX PM2.5 PM10

One Trip Transit 3 NM 0.006 0.121 0.003 0.003

One Trip Tugboats Point

Loma

0.003 0.144 0.003 0.006

One Trip Hotelling at pier

(including fugitive emissions 

for fuel transfer)

0.067 0.936 0.110 0.113

One Trip Total 0.076 1.202 0.115 0.123

Total for 2 Trips 0.152 2.403 0.230 0.245

De minimis threshold 25 25 100 70

Exceeds de minimis level? No No No No

Note: Units = U.S. tons; VOCs = volatile organic compounds; NOx =nitrogen oxides.

As shown in Table 2, the estimated increase in emissions due to implementation of Alternative 2 or 3 is 

below the applicable General Conformity de minimis levels. As such, a General Conformity Determination 

is not required.

Proposed Action Exemptions

The Proposed Action is exempt from the General Conformity Rule requirements based on the determination 

that the emissions are well below the de minimis threshold for all applicable pollutants.

Emissions Evaluation Conclusion

JTF-RH and DLA conclude that de minimis thresholds for affected pollutants would not be exceeded as a 

result of implementing the Proposed Action. The emissions data supporting that conclusion is shown in 

Table 2 above. The calculations, methodology, data and references are contained in this appendix. 

Therefore, JTF-RH and DLA conclude that further formal Conformity Determination procedures are not 

required, resulting in this RONA.
E-4

Prepared by: Naval Facilities Engineering 6\VWHPVCommand Pacific 

RONA Approval for Alternatives 2 and 3, San Diego County (Point Loma) 

Signature: 

Name: 

Date: 

Position: 

CHRISTENBURY.S

TACEY.A.13961422

91

Digitally signed by 

CHRISTENBURY.STACEY.A.139

6142291

Date: 2023.08.17 19:50:55 -04'00'

Stacey Christenbury

August 17, 2023

Supervisory Environmental Protection Specialist
E-5

RECORD OF NON-APPLICABILITY

FOR CLEAN AIR ACT CONFORMITY

SELBY, CONTRA COSTA COUNTY 

The Proposed Action, including the two action alternatives described below, falls under the Record of NonApplicability (RONA) category and is documented with this RONA. 

The U.S. Environmental Protection Agency (USEPA) published Determining Conformity of General Federal 

Actions to State of Federal Implementation Plans; Final Rule on November 30, 1990 (58 Federal Register 

[FR] 63214; 40 Code of Federal Regulations [CFR] Parts 6, 51, and 93). The U.S. Department of the Navy 

(Navy) published Navy Guidance for Compliance with the Clean Air Act (CAA) General Conformity Rule 

(30 July 2013), as referenced in Chief of Naval Operations Manual 5090.1. These publications provide 

implementing guidance to document CAA Conformity Determination requirements. Federal regulations 

state that no department, agency, or instrumentality of the Federal Government shall engage in, support in 

any way or provide financial assistance for, license to permit, or approve any activity that does not conform 

to an applicable implementation plan. It is the responsibility of the federal agency to determine whether a 

federal action conforms to the applicable implementation plan, before the action is taken (40 CFR Section

51.850[a]). 

The General Conformity Rule applies to federal actions proposed within areas that are designated as either 

nonattainment or maintenance for a National Ambient Air Quality Standard (NAAQS) for any of the criteria 

pollutants. Emissions of criteria pollutants within an area that is designated as attainment are exempt from 

general conformity analyses. 

Federal actions within nonattainment or maintenance areas may be exempt from conformity determinations 

if their emissions of criteria pollutants do not exceed designated de minimis thresholds for the criteria 

pollutants (40 CFR Section 51.853[b]). Contra Costa County is in nonattainment for 8-hr ozone (marginal) 

and particulate matter (PM) 2.5 by federal standards. By state standards, the county is in nonattainment for 

ozone, PM2.5 and PM10. The applicable de minimis thresholds for San Francisco Bay Area Air Basin are 

listed in Table 1. 

Table 1. de minimis Levels for Criteria Pollutants in San Francisco Bay Area Air Basin

Criteria Pollutants de minimis Thresholds (tons per year [tpy])

Volatile Organic Compounds (VOC) 50

Oxides of Nitrogen (NOx) 100

PM2.5 100

PM10 70

Note: VOC and NOx emissions are used to represent O3 generation because they are precursors of O3. 

PROPOSED ACTION 

Action Proponent: Joint Task Force Red Hill (JTF-RH) and Defense Logistics Agency (DLA)

Title of Proposed Action: Red Hill Defueling and Fuel Relocation

Project Location: Selby, Contra Costa County

Proposed Action and Emissions Summary: JTF-RH and DLA are proposing to relocate the fuel from Red 

Hill Bulk Fuel Storage Facility at Joint Base Pearl Harbor Hickam, Oahu, Hawaii. One of the potential 

receiving locations is Selby, San Pablo Bay.

JTF-RH and DLA have identified two action alternatives: 

• Alternative 2: Relocation 
E-6

• Alternative 3: Commercial Sale and Relocation

Under Alternative 2 or 3, up to two (2) tanker shipments would arrive at the port at Selby. 

Air Emissions Summary:

The proposed transit and off-loading of fuel from two tanker vessels under Alternative 2 or 3 would result 

in temporary air emissions from tankers over a period of up to 3 days per trip. Emissions from vessel 

transit/maneuvering within 3 nautical miles (NM) and hotelling from the tanker’s engines and boilers would 

emit criteria pollutants and HAPs. Fugitive emissions (volatile organic compounds) would also occur during 

ship transit and off-loading of fuel at the pier. Emissions also include the use of two tugboats to assist the 

tanker to the port.

In Table 2, VOCs and NOx, precursors for ozone, were evaluated against de minimis criteria in Table 1. 

Emissions were estimated as those occurring within 3 NM of California for this destination port. 

Table 2. Emissions Under Alternative 2 or Alternative 3, Two Vessel Trips to Selby

Mode VOCs NOX PM2.5 PM10

One trip - Transit 3 NM 0.025 0.505 0.012 0.013

One trip - Tugboats 

Selby

0.003 0.144 0.003 0.006

One trip -Hotelling at pier

(including fugitive 

emissions for fuel 

transfer)

0.067 0.936 0.116 0.119

One trip Total 0.095 1.585 0.130 0.139

Total for 2 Trips 0.190 3.170 0.260 0.277

De minimis threshold 50 100 100 70

Exceeds de minimis 

level?

No No No No

Note: Units = U.S. tons; VOCs = volatile organic compounds; NOx =nitrogen oxides.

As shown in Table 2, the estimated increase in emissions due to implementation of Alternative 2 or 3 are 

below the applicable General Conformity de minimis levels. As such, a General Conformity Determination 

is not required.

Proposed Action Exemptions

The Proposed Action is exempt from the General Conformity Rule requirements based on the determination 

that the emissions are well below the de minimis threshold for all applicable pollutants.

Emissions Evaluation Conclusion

JTF-RH and DLA conclude that de minimis thresholds for affected pollutants would not be exceeded as a 

result of implementing the Proposed Action. The emissions data supporting that conclusion is shown in 

Table 2 above. The calculations, methodology, data and references are contained in this appendix. 

Therefore, JTF-RH and DLA conclude that further formal Conformity Determination procedures are not 

required, resulting in this RONA.
E-7

Prepared by: Naval Facilities Engineering 6\VWHPVCommand Pacific 

RONA Approval for Alternatives 2 and 3, Contra Costa County (Selby) 

Signature: 

Name: 

Date: 

Position: 

CHRISTENBURY.S

TACEY.A.13961422

91

Digitally signed by 

CHRISTENBURY.STACEY.A.139

6142291

Date: 2023.08.17 19:54:00 -04'00'

Stacey Christenbury

August 17, 2023

Supervisory Environmental Protection Specialist
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-8

TANKER EMISSION FACTORS -TRANSIT MODE

Main Engines Transit Mode 

g/hr (13034 kw tanker)

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx

medium speed 0.1% SO2 1042.72 14337.4 8406930 172048.8 3258.5 2997.82 8472.1 5213.6

Medium speed 0.5% SO2 1042.72 14337.4 8406930 172048.8 4952.92 4561.9 8472.1 27110.72

Auxiliary Engines Transit 

Mode g/hr (@561 kw)

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx

medium speed 0.1% SO2 50.5224 617.496 387338.4 7802.904 140.34 129.1128 291.9072 224.544

Medium speed 0.5% SO2 50.5224 617.496 387338.4 7802.904 213.3168 196.476 291.9072 1178.856

Aux Boiler Emission 

Factors g/hr at 1593 kw

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx

Heavy Fuel Oil 47.79 318.6 1545210 3345.3 1274.4 1242.54 175.23 26284.5

Combined Emission 

factors for Transit 

(tons/hour)

CH4 CO CO2 NOx PM10 PM2.5 ROG/VOC* SOx

Fuel Type 0.1 % SO2 0.001 0.017 11.397 0.202 0.005 0.005 0.010 0.035

Fuel Type 0.5 % SO2 0.001 0.017 11.397 0.202 0.007 0.007 0.010 0.060

*includes 0.00016 tons/hr fugitive emissions from fuel storage during transit

**HAPs based on US EPA 2017 National Emissions Inventory developed HAP fractions for commercial marine vessels based on fractions of PM2.5 and VOCs. HAP emissions were 

estimated with a 0.0213 ratio to PM2.5 and 0.0807 to VOC (BOEM, 2021).

Note: 1 ton = 907185 grams
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-9

TANKER EMISSION FACTORS – HOTELLING MODE

Hotelling Mode: Auxiliary 

Engines g/kw-hr

CH4 CO CO2 Nox PM10 PM2.5 ROG SOx HAPs

medium speed 0.1% SO2 0.09 1.1 690 13.9 0.25 0.23 0.52 0.4 0.0469

Medium speed 0.5% SO2 0.09 1.1 690 13.9 0.38 0.35 0.52 2.1 0.0494

Hours Destination (608 kw) CH4 CO CO2 Nox PM10 PM2.5 ROG SOx HAPs

72 Any U.S. port 0.004 0.053 33.303 0.671 0.012 0.011 0.025 0.019 0.0023

72 International Ports 0.004 0.053 33.303 0.671 0.018 0.017 0.025 0.101 0.0024

Hotelling Mode: Auxiliary Boiler 

Emission Factors g/kw-hr

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Heavy Fuel Oil 0.03 0.2 970 2.1 0.8 0.78 0.11 16.5 0.0255

Hotelling Times 

(hours)

Destination (1593 kw); 

Case using Heavy Fuel 

Oil

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

72 Any port 0.004 0.025 122.638 0.266 0.101 0.099 0.014 2.086 0.0032

HOTELLING - FUGITIVE EMISSIONS

Volume (gallons) Mode VOC emission rate (lbs/1000 

gallons fuel)

VOC emitted (tons)

 11,000,000 Gallons loaded 0.005 0.03

 11,000,000 Gallons unloaded 0.005 0.03

Volatile organic compounds can be released as fugitive emissions during vessel loading and transit. EPA estimates that ocean vessel loading releases 0.005 lbs/1000 gallons 

transferred for kerosene or number 2 fuel oil and approximately 0.005 lbs/week-1000 gallons transported (EPA, 2008).

All source emissions CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling at JBPHH 0.008 0.078 155.941 0.936 0.113 0.110 0.067 2.105 0.005

Hotelling at U.S. Destination Port 0.008 0.078 155.941 0.936 0.113 0.110 0.067 2.105 0.005

Hotelling at International Port 0.008 0.078 155.941 0.936 0.119 0.116 0.067 2.187 0.006
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-10

Calculations for Medium Range Tanker: Case using only 0.5% sulfur fuel internationally (outside ECA)

Distance 

outside 

ECA

Transit 

Times 

International 

(hours)

Destination CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPS

1855 123.7 Naval Base 

Point 

Loma, 

California

0.16 2.08 1409.5 24.97 0.88 0.82 1.24 7.44 0.12

1668 111.2 Selby 

Terminal, 

California

0.14 1.87 1267 22.46 0.79 0.74 1.11 6.69 0.11

1830 122.0 Port of 

Vancouver, 

Washington

0.15 2.05 1390 24.64 0.87 0.81 1.22 7.34 0.12

1928 128.5 Puget 

Sound, 

Washington

0.16 2.16 1465 25.96 0.91 0.85 1.29 7.73 0.12

3721 248.1 Sasebo, 

Japan

0.31 4.18 2827 50.09 1.76 1.64 2.48 14.92 0.24

4494 299.6 Subic Bay, 

Philippines

0.38 5.04 3415 60.50 2.13 1.98 3.00 18.02 0.28

5896 393.1 Port of 

Singapore

0.49 6.62 4480 79.38 2.79 2.60 3.94 23.65 0.37

4980 332.0 Port of 

Darwin

0.42 5.59 3784 67.04 2.36 2.20 3.32 19.97 0.32
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-11

DESTINATION PORT TRANSIT EMISSIONS WITHIN 12 NM AND 3 NM

Combined 

Emission 

factors for 

Transit 

(tons/hour)

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Fuel Type 

0.1 % 

SO2

0.001 0.017 11.397 0.202 0.005 0.005 0.010 0.035 0.001

Fuel Type 

0.5 % 

SO2

0.001 0.017 11.397 0.202 0.007 0.007 0.010 0.060 0.001

Vessel 

distance 

within 12 

NM of Port

Time of 

transit 

within 

12 NM 

(hours)

Destination Sulfur 

Content 

in Fuel

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

13 1 Naval Base Point 

Loma, California

0.1% 

sulfur

0.001 0.015 9.878 0.175 0.004 0.004 0.009 0.030 0.001

34 2 Selby Terminal, 

California

0.1% 

sulfur

0.003 0.038 25.834 0.458 0.012 0.011 0.023 0.079 0.002

99 7 Port of 

Vancouver, 

Washington

0.1% 

sulfur

0.008 0.111 75.222 1.333 0.034 0.032 0.066 0.231 0.006

141 9 Puget Sound, 

Washington

0.1% 

sulfur

0.012 0.158 107.135 1.898 0.048 0.045 0.094 0.329 0.008

203 14 Sasebo, Japan 0.5% 

sulfur

0.017 0.228 154.244 2.733 0.096 0.090 0.136 0.814 0.014

370 25 Subic Bay, 

Philippines

0.5% 

sulfur

0.031 0.415 281.134 4.981 0.175 0.163 0.247 1.484 0.025

82 5 Port of 

Singapore

0.5% 

sulfur

0.007 0.092 62.305 1.104 0.039 0.036 0.055 0.329 0.005

30 2 Port of Darwin 0.5% 

sulfur

0.003 0.034 22.795 0.404 0.014 0.013 0.020 0.120 0.002
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-12

Vessel 

distance 

within 3 

NM of 

Destination 

Country

Time of 

transit 

within 3 

NM 

(hours)

Destination Sulfur 

Content 

in Fuel

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

6 0.6 Naval Base 

Point Loma, 

California

0.1% 

sulfur

0.001 0.010 6.838 0.121 0.003 0.003 0.006 0.021 0.001

25 2.5 Selby Terminal, 

California

0.1%

sulfur

0.003 0.042 28.493 0.505 0.013 0.012 0.025 0.087 0.002

90 9.0 Port of 

Vancouver, 

Washington

0.1% 

sulfur

0.011 0.152 102.576 1.817 0.046 0.043 0.090 0.315 0.008

132 13.2 Puget Sound, 

Washington

0.1% 

sulfur

0.017 0.222 150.445 2.666 0.068 0.064 0.132 0.462 0.012

17 1.7 Sasebo, Japan 0.5% 

sulfur

0.002 0.029 19.375 0.343 0.012 0.011 0.017 0.102 0.002

12 1.2 Subic Bay, 

Philippines

0.5% 

sulfur

0.002 0.020 13.677 0.242 0.009 0.008 0.012 0.072 0.001

17 1.7 Port of 

Singapore

0.5% 

sulfur

0.002 0.029 19.375 0.343 0.012 0.011 0.017 0.102 0.002

3 0.3 Port of Darwin 0.5% 

sulfur

0.000 0.005 3.419 0.061 0.002 0.002 0.003 0.018 0.000
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-13

EMISSIONS WITHIN US ECA

Vessel 

Distance 

within 

ECA 

(200NM 

US)

Transit 

Time 

within 

200 NM 

(hours)

Destination Sulfur 

Content 

in Fuel

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

13 1 Campbell 

Industrial Park, 

West Oahu

0.1% 

sulfur

0.001 0.017 11.397 0.202 0.005 0.005 0.010 0.035 0.001

427 28 Naval Base 

Point Loma, 

California

0.1% 

sulfur

0.036 0.479 324.444 5.749 0.147 0.137 0.285 0.995 0.026

448 30 Selby Terminal, 

California

0.1% 

sulfur

0.038 0.503 340.400 6.031 0.154 0.144 0.299 1.044 0.027

513 34 Port of 

Vancouver, 

Washington

0.1% 

sulfur

0.043 0.576 389.788 6.906 0.176 0.165 0.342 1.196 0.031

555 37 Puget Sound, 

Washington

0.1% 

sulfur

0.047 0.623 421.701 7.472 0.191 0.178 0.371 1.294 0.034

335 22 Sasebo, Japan 0.1% 

sulfur

0.028 0.376 254.540 4.510 0.115 0.108 0.224 0.781 0.020

335 22 Subic Bay, 

Philippines

0.1% 

sulfur

0.028 0.376 254.540 4.510 0.115 0.108 0.224 0.781 0.020

335 22 Port of 

Singapore

0.1% 

sulfur

0.028 0.376 254.540 4.510 0.115 0.108 0.224 0.781 0.020

212 14 Port of Darwin 0.1% 

sulfur

0.018 0.238 161.082 2.854 0.073 0.068 0.142 0.494 0.013

Combined Emission factors for Transit (tons/hour)

Sulfur Content in Fuel CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Fuel type 0.1 % 0.001 0.017 11.397 0.202 0.005 0.005 0.010 0.035 0.001

Fuel Type 0.5 % SO2 0.001 0.017 11.397 0.202 0.007 0.007 0.010 0.060 0.001
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-14

SUBIC BAY EMISSIONS (TONS)

SUBIC BAY Single 

Trip Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboat JBPHH 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within 200 

NM of Oahu (ECA)

0.03 0.38 255 4.51 0.12 0.11 0.22 0.78 0.02

Transit to Subic Bay 

(Outside ECA)

0.38 5.04 3415 60.50 2.13 1.98 3.00 18.02 0.28

Tugboat Subic 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Subic Bay 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

Totals 0.42 5.62 3998 67.32 2.49 2.32 3.37 23.15 0.32

LOCAL Air 

Emissions; Max 

Subic Bay 3 NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.02 14 0.24 0.01 0.01 0.01 0.07 0.00

Tugboats 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

total per event 0.01 0.11 175 1.32 0.13 0.13 0.08 2.28 0.01

Max Trips =5 5 5 5 5 5 5 5 5 5

total all events 0.05 0.56 876 6.61 0.67 0.63 0.41 11.39 0.04

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/ VOCs SOx HAPs

Subic Bay Local

Totals

0.56 877 6.61 0.67 0.63 0.41 11.39 0.04
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-15

SASEBO EMISSIONS (TONS)

SASEBO Trip Emissions CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats Oahu 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within ECA of Oahu 0.03 0.38 255 4.51 0.12 0.11 0.22 0.78 0.02

Remaining Transit to 

Sasebo (Outside ECA)

0.31 4.18 2827.3 50.09 1.76 1.64 2.48 14.92 0.24

Tugboats Sasebo 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Sasebo 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

Totals 0.36 4.75 3410 56.91 2.13 1.98 2.85 20.05 0.27

LOCAL AIR 

EMISSIONS; Max 3 

NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.03 19.4 0.34 0.01 0.01 0.02 0.10 0.00

Tugboats Sasebo 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

total per event 0.01 0.12 181 1.42 0.14 0.13 0.09 2.31 0.01

Max trips =2 2 2 2 2 2 2 2 2 2

total all events 0.02 0.24 362 2.85 0.28 0.26 0.17 4.61 0.02

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Sasebo local 

Totals

0.24 362 2.85 0.28 0.26 0.17 4.61 0.02
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-16

PORT OF SINGAPORE EMISSIONS (TONS)

Singapore Single 

Trip Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats JBPHH 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within ECA of 

Oahu

0.03 0.38 255 4.51 0.12 0.11 0.22 0.78 0.02

Remaining Transit to 

Singapore (Outside 

ECA)

0.49 6.62 4479.9 79.38 2.79 2.60 3.94 23.65 0.37

Tugboats Singapore 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Singapore 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

Totals 0.54 7.19 5063 86.19 3.16 2.94 4.30 28.77 0.41

LOCAL AIR 

EMISSIONS; Max 3 

NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.03 19 0.34 0.01 0.01 0.02 0.10 0.00

Tugboats Singapore 0.00 0.01 5.54 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

total per event 0.01 0.12 181 1.42 0.14 0.13 0.09 2.31 0.01

Max trips =5 5 5 5 5 5 5 5 5 5

total all events 0.05 0.61 904 7.12 0.69 0.65 0.43 11.54 0.04

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Singapore Local 

Total

0.61 906 7.12 0.69 0.65 0.43 11.54 0.04
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-17

DARWIN EMISSIONS (TONS)

Darwin Single 

Trip Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats JPBHH 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within 

ECA of Oahu

0.02 0.24 161 2.85 0.07 0.07 0.14 0.49 0.01

Remaining 

Transit to Darwin 

(Outside ECA)

0.42 5.59 3784 67.04 2.36 2.20 3.32 19.97 0.32

Tugboats Darwin 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Darwin 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

Totals 0.45 6.03 4274 72.20 2.68 2.50 3.61 24.81 0.34

LOCAL AIR 

EMISSIONS; Max 

3 NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.01 3.4 0.06 0.00 0.00 0.00 0.02 0.00

Tugboats Darwin 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.12 0.12 0.07 2.19 0.01

total per event 0.01 0.10 165 1.14 0.13 0.12 0.07 2.22 0.01

Max trips =5 2 2 2 2 2 2 2 2 2

total all events 0.02 0.20 330 2.28 0.26 0.24 0.15 4.45 0.01

CO GHGs

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Darwin local 

totals

0.20 330 2.28 0.26 0.24 0.15 4.45 0.01
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-18

OAHU EMISSIONS (TONS)

Oahu Emissions 

(single trip)

CH4 CO CO2 NOx PM10 PM2.5 ROG/VOCs SOx HAPs

JBPHH 

Arrival/departure 

transits single vessel

0.003 0.034 22.8 0.404 0.010 0.010 0.020 0.070 0.002

Hotelling JBPHH 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats JBPHH 0.00 0.03 11 0.29 0.01 0.01 0.01 0.04 0.00

Transit to Campbell 

Industrial Park, West 

Oahu

0.00 0.02 11 0.20 0.01 0.00 0.01 0.03 0.00

Transit within 12 NM of 

Oahu

See 

above

Hotelling Campbell 

Industrial Park, West 

Oahu

0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Local Air Emissions; 

All tankers at JBPHH

CH4 CO CO2 NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Vessel 

Arrival/Departure x11

0.03 0.37 250.74 4.44 0.11 0.11 0.22 0.77 0.02

Hotelling and 

Tugboats at JBPHH x 

11 vessels

0.09 1.18 1837 13.47 1.38 1.26 0.80 23.55 0.07

11th vessel extended 

hotelling

0.04 0.39 779.71 4.68 0.57 0.55 0.33 10.53 0.03

Total all tankers at 

JBPHH

0.16 1.94 2867.77 22.59 2.06 1.92 1.35 34.84 0.11
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-19

Portion Only To Campbell 

Industrial Park, West 

Oahu

CH4 CO CO2 NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Transit to Campbell 

Industrial Park, West Oahu

0.001 0.017 11.4 0.202 0.005 0.005 0.010 0.035 0.001

Tug to keep tanker in place 0.000 0.086 3.326 0.864 0.038 0.015 0.020 0.106 0.002

Hotelling at Campbell 

Industrial Park, West Oahu

0.01 0.08 155.94 0.94 0.11 0.11 0.07 2.11 0.01

Totals CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

total per 

event

0.18 170.9 2.00 0.16 0.13 0.10 2.25 0.01

Max trips to 

Campbell 

Industrial 

Park, West 

Oahu =5

5 5 5 5 5 5 5 5

total all 

Oahu

2.85 3722.50 32.60 2.84 2.57 1.83 46.08 0.16

Breakout by 

location

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Only 

JBPHH

1.94 2872.50 22.59 2.06 1.92 1.35 34.84 0.11

Only 

Campbell 

Industrial 

Park, West 

Oahu

0.91 856.14 10.01 0.78 0.65 0.48 11.23 0.04
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-20

POINT LOMA EMISSIONS (TONS)

Pt Loma Single Trip 

Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.008 0.078 156 0.94 0.113 0.110 0.067 2.11 0.005

Tugboats JBPHH 0.000 0.029 11 0.29 0.013 0.005 0.007 0.04 0.001

Transit within ECA of 

Oahu and Pt Loma

0.036 0.479 324 5.75 0.147 0.137 0.285 1.00 0.026

Intl Transit to Pt Loma 

(Outside ECA)

0.156 2.082 1409 24.97 0.878 0.818 1.238 7.44 0.124

Tugboats Pt Loma 0.000 0.014 6 0.14 0.006 0.003 0.003 0.02 0.000

Hotelling Pt Loma 0.008 0.078 156 0.94 0.113 0.110 0.067 2.11 0.005

Totals 0.21 2.76 2062 33.03 1.27 1.18 1.67 12.70 0.16

LOCAL AIR 

EMISSIONS; Max 3 

NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.01 7 0.121 0.003 0.003 0.006 0.02 0.00

Tugboats Pt Loma 0.00 0.01 5.5 0.144 0.006 0.003 0.003 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.936 0.113 0.110 0.067 2.11 0.01

total per event 0.01 0.10 168 1.202 0.123 0.115 0.076 2.14 0.01

Max trips =2 2 2 2 2 2 2 2 2 2

total all events 0.02 0.21 337 2.403 0.245 0.230 0.152 4.29 0.01

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Point Loma Local 

Totals

0.21 337 2.40 0.25 0.23 0.15 4.29 0.01
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-21

SELBY EMISSIONS (TONS)

Selby Single Trip 

Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 155.94 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats at JBPHH 0 0.03 11.09 0.29 0.01 0.01 0.01 0.04 0.00

Transit within ECA of 

Oahu and Selby

0.04 0.50 340.40 6.03 0.15 0.14 0.30 1.04 0.03

Intl Transit to Selby 

(Outside ECA)

0.14 1.87 1267.38 22.46 0.79 0.74 1.11 6.69 0.11

Tugboats at Selby 0 0.01 5.54 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Selby 0.01 0.08 155.94 0.94 0.12 0.12 0.07 2.19 0.01

Totals 0.19 2.57 1936.30 30.79 1.19 1.11 1.56 12.08 0.14

LOCAL AIR 

EMISSIONS; Max 3 

NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.00 0.04 28.49 0.505 0.013 0.012 0.025 0.09 0.00

Tugboats at Selby 0.00 0.01 5.54 0.144 0.006 0.003 0.003 0.02 0.00

Hotelling at pier 0.01 0.08 155.94 0.936 0.119 0.116 0.067 2.19 0.01

total per event 0.01 0.13 189.98 1.585 0.139 0.130 0.095 2.29 0.01

Max trips =2 2 2 2 2 2 2 2 2 2

total all events 0.02 0.27 379.96 3.170 0.277 0.260 0.190 4.59 0.02

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Selby Local Totals 0.27 381 3.17 0.28 0.26 0.19 4.59 0.02
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-22

PORT VANCOUVER EMISSIONS (TONS)

Port Vancouver Single 

Trip Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats at JBPHH 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within ECA of 

Oahu and Port 

Vancouver

0.04 0.58 390 6.91 0.18 0.16 0.34 1.20 0.03

Intl Transit to Port 

Vancouver (Outside 

ECA)

0.15 2.05 1390 24.64 0.87 0.81 1.22 7.34 0.12

Tugboats Port 

Vancouver

0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Port Vancouver 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Totals 0.21 2.83 2109 33.85 1.29 1.20 1.71 12.80 0.16

LOCAL AIR 

EMISSIONS; Max 

3 NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.01 0.15 103 1.82 0.05 0.04 0.09 0.31 0.01

Tugboats 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

total per event 0.02 0.24 264 2.90 0.17 0.16 0.16 2.44 0.01

Max trips =1 1 1 1 1 1 1 1 1 1

total all events 0.02 0.24 264 2.90 0.17 0.16 0.16 2.44 0.01

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Port Vancouver 

Local Totals

0.24 265 2.90 0.17 0.16 0.16 2.44 0.01
Final EA/OEA Red Hill Defueling and Fuel Relocation, JBPHH August 2023

E-23

PUGET SOUND EMISSIONS (TONS)

Puget Single Trip 

Emissions

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Hotelling Oahu 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Tugboats JBPHH 0.00 0.03 11.1 0.29 0.01 0.01 0.01 0.04 0.00

Transit within ECA of 

Oahu and Puget

0.05 0.62 422 7.47 0.19 0.18 0.37 1.29 0.03

Intl Transit to Puget 

(Outside ECA)

0.16 2.16 1465 25.96 0.91 0.85 1.29 7.73 0.12

Tugboats Puget 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling Puget 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

Totals 0.22 2.99 2215 35.73 1.35 1.26 1.80 13.29 0.17

LOCAL AIR EMISSIONS; 

Max 3 NM

CH4 CO CO2 NOx PM10 PM2.5 ROG SOx HAPs

Transit 3 NM 0.02 0.22 150 2.67 0.07 0.06 0.13 0.46 0.01

Tugboat 0.00 0.01 5.5 0.14 0.01 0.00 0.00 0.02 0.00

Hotelling at pier 0.01 0.08 156 0.94 0.11 0.11 0.07 2.11 0.01

total per event 0.02 0.31 312 3.75 0.19 0.18 0.20 2.58 0.02

Max trips =1 1 1 1 1 1 1 1 1 1

total all events 0.02 0.31 312 3.75 0.19 0.18 0.20 2.58 0.02

CO GHGs CO2e

CO2 & CH4

NOx PM10 PM2.5 ROG/VOCs SOx HAPs

Puget Sound 

Local Totals

0.31 313 3.75 0.19 0.18 0.20 2.58 0.02