After careful review and consultation with biologists, I strongly contend that Turtle Bay Resort’s surveys of flora and fauna, in its draft supplemental environmental impact statement (DSEIS), are incomplete and inaccurate.

They do not address:

» The issues of animals and plants listed under the Endangered Species Act; Hawaiian monk seals, green sea turtles, Hawaiian stilts, moorhens, coots, ducks, ohai (sesbania-tomentosa) and others.

» The presence of migratory birds such as bristle thighed curlews, golden plovers, wandering tattlers, ruddy turnstones, sanderlings, dowitchers, yellowlegs and others protected under the Migratory Bird Treaty Act.

» The presence, and sensitivity to light, of shearwaters and petrels.

The surveys also:

» Deny that the property contains or is adjacent to critical habitat.

» Did not attempt inventories of invertebrates or freshwater aquatic resources.

» Assume that Hawaiian owls and bats are not present. Best practices are to assume they are present, since their presence is documented on adjacent properties (at the First Wind project and James Campbell National Wildlife Refuge).

» Did not investigate "the fragile ecosystem" of Punahoolapa Marsh and then declared that no endangered plants were found.

» Incorrectly maintain that there are no endangered plants on the property.

The DSEIS lacks discussion of preservation and restoration of dune habitat, overgrown with invasive species through neglect, a predator control program and, as suggested more than 20 years ago by the U.S. Fish and Wildlife Service, restoration of the marsh. The existing resort has no functional education programs for staff to prevent the destruction of protected birdlife, or to coordinate wildlife emergencies with state and federal authorities.

I attended the open house event at Turtle Bay Resort last month. The consultant who did the "near shore study" was asked why he inventoried only the turtles at Kawela Bay when they are present all along the coastline. He replied that he didn’t know how to do that and asked me to explain to him how to do it. I told him it was not my job.

He was asked why he also restricted his surveys of Hawaiian monk seals to Kawela, when everyone knows they haul out and pup on the eastern end of the property. He replied that he was the first person to see a Hawaiian monk seal here in the main Hawaiian islands and was familiar with what they looked like. That’s great, but it did not answer the question.

The consultants who did the animal and plant studies were not at the open house. These are the biologists who didn’t want to investigate the plants in part of the Punahoolapa Marsh because they were afraid of disturbing the fragile ecosystem and then — guess what — didn’t find any endangered wetland plants or indeed any endangered plants anywhere on the property.

Without proper surveys of flora and fauna, impact assessment of the proposed action on the coastal wetland and dune habitats is meaningless. Mitigation in the form of undefined "education programs," run largely by volunteers, is insufficient. This is not full disclosure.

This area of coastal wetland, while degraded by the presence of a hotel, condos and golf courses, does contain important ecosystems that are rare and fragile enough to warrant protection and restoration. Any expansion of the current footprint of Turtle Bay Resort is untenable with the presence of protected animal and plant species in the SEIS lands and incompatible with their long-term survival.