Construction of the stalled Thirty Meter Telescope could face considerable delay — perhaps as much as three or more years — if new federal regulatory hurdles are placed in front of the $2.4 billion astronomy project planned for Hawaii’s tallest mountain.

An executive summary memo prepared by the office of the president of the University of California describes the project’s latest obstacles and challenges ahead of a meeting today that aims to update the Board of Regents on the TMT project.

The UC is one of TMT’s partners, having committed $175 million for construction and additional funds once it becomes operational.

According to the memo, the TMT’s recent move to join up with the Giant Magellan Telescope and the U.S. National Optical-Infrared Laboratory to obtain major funding from the National Science Foundation will trigger a federal environmental impact statement and National Historic Preservation Act Section 106 consultation.

The only other time those same requirements were seen on Mauna Kea came in 2003 for the proposed NASA-funded Keck Telescope Outriggers Project, also a UC project.

The Outriggers proposal ended up being delayed for three years and was ultimately withdrawn following challenges by the Mauna Kea Hui, the same group that has been a thorn in the side for the TMT.

Asked for comment, TMT Vice President Gordon Squires issued a statement that said no on-site activities will be initiated this year due to the coronavirus pandemic “and other factors.”

Squires added that TMT is awaiting the results of the U.S. Decadal Survey next year, which will set the priorities for the astronomy community for the next 10 years and help guide the National Science Foundation in making its funding decisions.

“This is one important step of many toward seeking funding from the NSF,” he said.

Kealoha Pisciotta, Mauna Kea Hui leader, said Wednesday that her group and others who oppose the TMT are prepared to challenge the project’s federal EIS and National Historic Preservation Act consultations.

“If they do a poor job, we will sue,” she declared.

The UC memo also suggests the project isn’t expected to achieve “first light” until about 2033. If that’s true, the TMT might not be planning to commence the expected decade-long construction until 2023.

The proposed partnership with the Giant Magellan Telescope, planned for Chile, is described as “a major re-baselining effort” designed to provide American astronomers with viewing coverage in both the Northern (TMT) and Southern (GMT) hemispheres.

Under the proposal, the National Science Foundation would contribute $850 million to each project. The memo adds that the NSF funding is not certain at this point.

According to the memo, the federal EIS and the National Historic Preservation Act reviews will offer “another opportunity to evaluate environmental and cultural impacts in detail and identify any necessary mitigations.”

“As has been the case for past decade, the Project will respect the need for these processes to reach their conclusions,” it said.

Other challenges outlined by the memo:

>> The master lease held by the University of Hawaii for the Mauna Kea astronomy zone expires in 2033 and there is no guarantee it will be renewed. UH is working on renewing the lease, but there is a risk the site won’t be available beyond 2033. “We are monitoring this development closely,” the memo said.

>> The necessary permits have been obtained to build TMT at its backup site in the Canary Islands if need be. But in order to make a location change there would need to be unanimous agreement among the TMT partners and the National Science Foundation in case they become a partner.

For months groups of Polynesian and other indigenous students have been campaigning to persuade the UC to divest from the TMT. They have argued that the land is sacred to Native Hawaiians and that it is unethical for the university to support the project.

Today’s Board of Regents meeting on the Zoom app will feature speakers from both the TMT International Observatory board of directors, including TIO Chairman Henry Yang, chancellor of UC Santa Barbara, and those who oppose the project, including Pisciotta, Laulani Teale and Noe Noe Wong-Wilson.

The meeting starts at 7 a.m. Hawaii time.