Dairy draft EIS misses important items

“You don’t need a weatherman to know which way the wind blows.” — Bob Dylan

For years I have lived in the Denver metropolitan area. Most of the time the wind blows from the southwest over the mountains and down into Denver. However, in the winter when an upslope weather condition sets up in eastern Colorado, the wind switches to the northeast, and you don’t need a weatherman to tell you snow is coming. That is because about 50 miles northeast of Denver there are dairies and cattle-feeding operations and when the wind blows from that direction their odors permeate Denver. That’s right — from over 50 miles away!

So when a dairy is locating in a warm and humid climate (not high and dry like Colorado) less than 3 miles upwind from Poipu/Koloa, it is guaranteed visitors and residents will not be smelling floral fragrances and ocean air!

The HDF (Hawaii Dairy Farm) dairy, hoping for an operating permit at Mahaulepu, is, by all accounts, ill-advised, and, according to their own spokesperson, “an experiment” (TGI guest commentary, July 24). While their self-serving DEIS (draft environmental impact statement full of advertisements/editorial comments on their claimed expertise) is huge (giving the appearance of being thorough), with just a casual read one soon realizes while it is slick, it is full of vagaries and hype. On closer reading, one quickly learns the DEIS grossly under-evaluates and sometimes outright ignores critical features of their site:

w Existing ditches not evaluated: Their DEIS notes there is an extensive drainage-ditch network running throughout the pastures and only 10 percent of the total waste generated on site will be washed into their effluent ponds. HDF reports the other 90 percent will lie on the pastures where it falls. The recovered 10 percent will also be reapplied through irrigation and pumpout of manure sludge solids onto pastures every four to five weeks — that’s at least 2 million pounds of wet manure each month per HDF’s DEIS.

However, the DEIS admits in the 18 months of its investigation, “(ditches) were not fully explored nor was it determined how they presently all interconnect.” The one thing HDF did say, however, “surface waters draining from the project site meet Waiopili Ditch, and will eventually reach the ocean” (DEIS Volume 2, Surface Water and Marine Assessment, page 2).

Intense storm water run-off will exit the property through this understudied ditch system, taking with it cattle manure, urine and other bacteria to the ocean, endangering not only the nearby drinking water, but further contaminating an already polluted stream, and making enjoyment of Mahaulepu Beach a thing of the past for resident and visitors.

w Odor modeling inadequate: HDF’s DEIS limited their odor evaluation to computer modeling. Studies have shown that computer modeling is inadequate to accurately determine at what levels odors become offensive. Rather, odor modeling requires extensive testing using human subjects. Although not near any resort or densely populated community, a similar-sized dairy herd currently exists on the Big Island that could have provided real data, but this DEIS chose to only rely on subjective computer modeling.

w Federal Clean Water Act: The DEIS was written specifically for a dairy herd of 699 cows. Of note, the federal Clean Water Act (CWA) mandates additional significant requirements for a herd size of 700 or greater. The cows are coming pregnant and the DEIS admits the dairy will quickly grow to 900 cows and ultimately to a herd size of 2,000. However, nowhere does HDF discuss the additional CWA requirements for its “commitment” to a herd of 2,000 cows.


David Howell, PE, MBA, is a property owner in Koloa. During his career he participated in preparing, evaluating and submitting several EIS documents in the Rocky Mountain area.


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