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Senator Ronald D. Kouchi
415 S Beretania St # 214
Honolulu, HI 96813
August 8, 2017
Re: Constituency Letter from 53 Kaua‘i Residents, West Kaua‘i Fishers and Ni‘ihauans:
Requesting Your Support to Urge Agencies Toward a More Inclusive,
Less Toxic Approach to Lehua Conservation Efforts
Aloha Senator Kouchi:
We hope that this letter from your West Kaua‘i constituency finds you well.
Last week, Department of Agriculture Chair Scott Enright announced that the intended aerial drop of diphacinone pesticide on Lehua by the Department of Land and Natural Resources and US Fish and Wildlife Service would not go forth as scheduled.
The decision was preceded by a strong letter urging caution and more deliberation, sent by our West Kaua‘i State Representative Dee Morikawa to Mr. Enright and DLNR Chair Suzanne Case, and copied to Governor David Ige on August 2.
Representative Morikawa rekindles the possibility that Hawaii can come up with more innovative, less toxic approaches to the protection and survival of species than an aerial drop of approximately 11.5 tons of the anticoagulant pesticide, diphacinone, through a large, swinging bucket in winds up to 35 mph across the entire island. Under the plan, diphacinone would also be aerially dropped below the high tide mark and into the waters along Lehua's entire coast. Our research shows that up until 2007, it was illegal to apply diphacinone "directly to water" and "to intertidal areas below the mean high water mark" due to its high toxicity to aquatic life.
Lehua's ecosystem is a Hawaii treasure, linked through land and marine food webs where the poisoning or exposure of one species has the potential of moving through the food chain (with the possible result of “secondary poisoning”) with unknown longterm consequences. These interdependencies are largely under-researched.
Lehua is not only a seabird sanctuary. It is also a legally designated State Wildlife Sanctuary and Conservation District harboring Federally protected and endangered monk seals, green sea turtles, and three species of birds, all protected under the Endangered Species Act.
Lehua's marine waters also harbor at least one rare species of coral, dolphins, manta rays, and migrations of humpback whales. Coral systems are plentiful there.
In-Depth Studies of Alternatives Needed Now. The importance of a comprehensive study of a range of less toxic alternatives will now be key, and we ask that you rally policymaking and agency colleagues to support such work. Instead of dismissing alternatives summarily (as they were in the state and federal Final EA's), in-depth, seriously considered, solution-oriented feasibility studies on a range of less harmful alternatives are required.
With the right scientific advisors, including knowledgeable members of our westside community, our state agencies can develop approaches that protect species within a delicate, interdependent ecosystem, not only migratory birds to the potential detriment of other endangered and threatened species. Perhaps the solution will lie in not one, but several approaches that may be more gradual and realistically sustainable in the longterm.
Urging Deliberation in Light of Inconclusive Deaths of Whales and Fish. Given the inconclusive deaths of two whales and a large scale fish die-off following the failed 2009 diphacinone drop, the incentive for finding alternatives to the aerial drop of pesticides in Lehua's waters is even greater. The Final EA expressly states that it does not contain any research on the effect of diphacinone on whales, dolphins and other cetacean species. Even the former Pesticide Branch head in 2009 directed his staff "not to issue aerial application permits that might result in pellets entering into marine ecosystems until the EPA develops study protocols for such ecosystems."
As fishers, cultural gatherers and Ni‘ihauans, our lives are deeply intertwined with the ecosystems supported on and around Lehua. At a public meeting held at Waimea Neighborhood Center on July 25, 2017, our westside community expressed our frustration and demanded that our knowledge be reflected in the ultimate restoration plan for the ecosystems of Lehua. This has not happened thusfar.
We hope that Representative Morikawa's stance on inclusion and alternatives is unwavering, and that you support those values in your actions on this issue. Together we can find a better way forward that acknowledges the linked fate of our ecosystems and our island's people.
James H. Largo
James M. Largo
Benjamin Domingo Jr.