Two Hawaii state agencies have submitted blistering comments regarding the future of the Pohakuloa military training area on the Big Island.

Both the Department of Land and Natural Resources and the Office of Conservation and Coastal Lands list a range of adverse impacts the military site is having to animals, archeological assets, and cultural resources, among other things.

“It is inappropriate to conduct this type of warfare practice upon Conservation District land adjacent to areas designated as critical habitat” for the Palila “and a recreational campground for the people of Hawaii,” the coastal lands office said in its comments.

Palila is a critically endangered honeycreeper whose remaining habitat lies in dry, high-elevation forest and shrubland covering a small portion of Mauna Kea.

The state’s comments, submitted June 7, are formal responses to the military’s draft environmental impact statement for Pohakuloa, an Army training area about halfway between Hilo and Kawaihae Harbor. Located on a high plateau and surrounded by the Mauna Kea, Mauna Loa and Hualalai volcanoes, Pohakuloa is accessible from the Saddle Road that connects the island’s leeward and windward sides.

The Army is hoping to retain its presence on up to 23,000 acres of state land at Pohakuloa, the largest contiguous live-fire range and maneuver training area in Hawaii. Its current lease, issued in 1964, expires in August 2029 unless renewed.

As part of the required environmental review process, the Army issued a two-volume document set providing detailed information about Pohakuloa. Upon release, a 60-day public comment period ensued that ended on June 7.

In their written comments, the Department of Land and Natural Resources castigated the Army for issuing a report that contains major data gaps, relies on outdated studies, fails to specify adequate mitigation, and falls short of meeting minimum requirements of Hawaii state laws.

“The information is insufficient and would appear that the applicant has made little to no effort to fill in any data gaps,” the department said.

For example, the Army needs to clarify how it intends to protect nene, Hawaii’s endangered state bird, and endangered hoary bats, Hawaii’s only remaining native land mammal. The state wants the Army to explain how it would shield these animals from being struck by live-fire or being hurt by loud noises or explosions.

“It would appear that the continuation of military training exercises could continue to impact the Hawaiian hoary bat and its habitat. However, neither of these are addressed,” according to DLNR.

After reviewing the Army’s documents, the Office of Conservation and Coastal Lands said it “was alarmed” at the number of dump sites at Pohakuloa. The existence of these dumps seems to contradict what’s allowed within a Conservation District, the agency wrote.

The office questioned whether a military training site should even exist within a conservation district, a land designation established to conserve, protect and preserve important cultural and natural resources.

In response to a part of the study where the Army said that Pohakuloa’s ongoing activities have complied with conservation district rules, the office was blunt, saying: “This is an incorrect statement.”

Military activity that involves maneuvers, ammunition, artillery and mortar systems, depleted uranium, explosives, firing points, hazardous material and waste seem inconsistent with the conservation district, according to the agency.

“It appears that military training is in direct conflict of the Conservation District designation,” the agency wrote.

Another red flag it picked up on: the Army document lacks any provisions for restorative actions such as reforestation or cleanup of unexploded munitions, information that should be included.

Army and DLNR officials declined interview requests.

(UPDATE: On Wednesday morning, the Army offered Civil Beat a response. It said the state-owned lands leased by the Army at Pohakuloa were designated as a Conservation District after the lease was executed in August 1964. Military training on the leased land is a preexisting use that predates the Conservation District rules and the military’s use of Pohakuloa is lawful under the Army’s interpretation of Hawaii administrative rules.)

The Army’s draft environmental impact statement contains a range of options for the lease extension. Its preferred alternative is full access to the 23,000 acres of state-owned land for training purposes.

Short of that, another possibility would be for the Army to retain access to 19,700 acres, or 10,100 acres along with 11 miles of select roads and training trails. Finally, the “no action alternative” would have the Army’s presence at Pohakuloa end when the lease expires.

After the Army reviews the public comments on Pohakuloa, it will issue a final environmental impact statement at a date yet to be determined.

Pohakuloa is used by the Army, Marine Corps, Navy, Army Reserve, Hawaii Army National Guard, Hawaii Air National Guard, Hawaii Police Department and others.

A massive wildfire sparked at Pohakuloa on Aug. 10 left 26.5-square-miles of charred land, according to DLNR. As of last week, it was 90% contained.

Read DLNR’scomments:

Read OCCL’s comments: