{"id":312214,"date":"2026-01-19T12:00:43","date_gmt":"2026-01-19T12:00:43","guid":{"rendered":"https:\/\/www.transcend.org\/tms\/?p=312214"},"modified":"2026-01-18T06:50:57","modified_gmt":"2026-01-18T06:50:57","slug":"hawaii-the-us-army-is-quietly-walking-away-from-o%ca%bbahu-to-gain-leverage-over-the-pohakuloa-training-area","status":"publish","type":"post","link":"https:\/\/www.transcend.org\/tms\/2026\/01\/hawaii-the-us-army-is-quietly-walking-away-from-o%ca%bbahu-to-gain-leverage-over-the-pohakuloa-training-area\/","title":{"rendered":"HAWAII: The US Army Is Quietly Walking Away from O\u02bbahu to Gain Leverage over the P\u014dhakuloa Training Area"},"content":{"rendered":"
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Jan. 24, 2024 – Pohakuloa Training Area – Bangalore torpedoes and M18 claymore mines were detonated during a live-explosives training exercise that deposit explosive residues (RDX, HMX, TNT byproducts, metals, etc.) into the fragile environment.<\/p><\/div>\n

An analysis of the Hawaii State\u2019s rejection of the US Army\u2019s Final Environmental Impact Statement, focusing on issues related to toxic contamination.<\/em><\/p><\/blockquote>\n

12 Jan 2026\u00a0<\/em>– While public attention has focused on the Hawai\u02bbi Board of Land and Natural Resources\u2019 rejection of the Army\u2019s Final Environmental Impact Statement (FEIS<\/a>)\u00a0 for the P\u014dhakuloa Training Area, an equally consequential decision has unfolded largely out of public view. Under its own Record of Decision, the U.S. Army is preparing to vacate thousands of acres of state-leased land on O\u02bbahu\u2014a move that reshapes the broader negotiations over military land use across the state.<\/p>\n

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On August 4, 2025, the Army signed its Record of Decision<\/a> (ROD) for the Environmental Impact Statement governing its O\u02bbahu training leases. Buried in its conclusions is a stunning outcome: the Army has chosen the No Action Alternative<\/em> for both Kawailoa-Poamoho Training Area and M\u0101kua Military Reservation, meaning the leases will expire in 2029 and military use will cease.<\/p>\n

At Kahuku Training Area, the Army selected Alternative 2<\/em>, retaining only a portion of the land.<\/p>\n

Extracted from the vague language, the decision means the Army will give up all 4,390 acres at Poamoho, all 782 acres at M\u0101kua, and approximately 700 acres at Kahuku. Approximately 5,872 acres of land will return to the state. At Kahuku, the Army will retain 450 of the 1,150 acres it currently leases.<\/p>\n

None of this has been reported in local or national media. Instead, spotty coverage has focused almost exclusively on the controversy surrounding P\u014dhakuloa on Hawai\u02bbi Island, leaving the false impression that all Army leases remain open for negotiation. They do not.<\/p>\n

Under the Army\u2019s final Record of Decision, there is no approved path to renew the M\u0101kua or Poamoho leases. \u00a0<\/strong>The Army\u2019s obscure language and unwillingness to publicize its departure have hidden its decision to leave. This is part of their strategy.<\/p>\n

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For decades, the Army\u2019s O\u02bbahu training areas have been great political and environmental liabilities. Litigation, cultural access disputes, wildfire risk, unexploded ordnance, and unresolved contamination\u2014especially PFAS\u2014have generated sustained public opposition. These sites sit close to population centers and are under constant public scrutiny. From the Army\u2019s perspective, the political cost of holding them now outweighs their training value.<\/p>\n

M\u0101kua\u2019s downsizing follows the same strategic thinking. \u00a0Live-fire training there has been suspended since 2004 following court rulings and legal settlements, yet the site remains a powerful symbol of environmental harm and broken trust with Native Hawaiian communities. Shrinking M\u0101kua allows the Army to claim responsiveness without surrendering control. It is a concession that costs little, feigns cooperation, and avoids confronting the deeper question: why should the Army remain here at all?<\/p>\n

Recognizing the destructive impact M\u0101kua has on the island\u2019s land and water, and the reduced importance it has to the Army, the greater Oahu community must demand\u00a0 complete abandonment.<\/p>\n

These quiet withdrawals set the stage for the Army\u2019s real priority, the P\u014dhakuloa Training Area on the Big Island. Unlike the O\u02bbahu sites, P\u014dhakuloa is central to the Army\u2019s Indo-Pacific strategy. It has immense operational value. From the Army\u2019s perspective, P\u014dhakuloa is non-negotiable, while the other leased lands are expendable.<\/p>\n

Expect the Army to point to the land it is relinquishing on O\u02bbahu as evidence of good faith, using those \u201csacrifices\u201d to strengthen its hand in negotiations over P\u014dhakuloa.<\/p>\n

The Army\u2019s actions do not signal a withdrawal from Hawai\u02bbi. They represent a calculated consolidation\u2014quietly abandoning politically costly lands on O\u02bbahu in order to defend long-term control of P\u014dhakuloa. The state should recognize this strategy for what it is and respond accordingly.\u00a0 Hawai\u02bbi has more leverage now and it \u00a0should use it.<\/p>\n

The Board of Land and Natural Resources\u2019 5\u20132 rejection reflected a determination that the Army\u2019s Final Environmental Impact Statement\u00a0 FEIS did not meet Hawai\u02bbi law, did not protect public trust lands, and did not justify continued military occupation without enforceable cleanup, accountability, and cultural protections.<\/p>\n

The state is under no obligation to weaken its stance as it considers what comes next at P\u014dhakuloa.\u00a0 The state must strengthen its resolve.<\/p>\n

If great injustice prevails, and Hawai\u2019i is forced to accept the continued toxic Army occupation, the new lease should only cover a probationary period of a year or two and it must be armed with enforceable, transparent requirements addressing both legacy and ongoing contamination. These are the issues the Army consistently avoids documenting or committing to remediate under binding standards. They have desecrated the land, and they are intent on continuing to do so.<\/p>\n

We are witnessing the 21st century intersection of popular will and imperial overreach.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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P\u014dhakuloa is the cornerstone of the Army\u2019s Indo-Pacific strategy. Unlike the O\u02bbahu sites, it has fewer immediate neighbors and far greater operational importance. From the Army\u2019s perspective, P\u014dhakuloa is non-negotiable. As the Army seeks to retain long-term control of P\u014dhakuloa, it is likely to offer modest, carefully scripted and managed \u201cconcessions\u201d, like slightly expanded cultural access, additional monitoring wells they control, and, perhaps, stronger language on fire prevention.<\/p>\n

The Army will seek to avoid enforceable reporting and cleanup obligations for a host of chemicals, especially PFAS. They will reject demands that the Hawai\u2019i Department of Health or third parties be granted access to the base to independently conduct environmental testing. The Army will endeavor to control environmental testing protocols and the publication of data.<\/p>\n

The Army\u2019s goal is to appear responsive while preserving the core training mission intact, but this is impossible. Preparing for war is dirty business and it creates dirty air, soil, and water that make people sick. \u00a0It just does.<\/p>\n

If the state\u2019s arm is twisted and Hawaii is forced to cry uncle, the state should riddle the lease with enforceable standards and expectations for both legacy and ongoing contamination at Pohakuloa. These are the things the Army doesn\u2019t want to discuss. The Army can be expected to continue its path of obstinance and non-compliance.<\/p>\n

If a new lease is thrust upon the state, it must legally compel full transparency by the U.S. Army regarding the exact locations, extent, and concentrations of contamination present on the Island of Hawai\u02bbi. The lease must demand the construction of a modern wastewater treatment plant with additional filter systems to remove PFAS. The lease must require the Army to fully remediate the substantial environmental damage it has caused, consistent with the most protective international health standards, rather than current weak, federal screening levels. It must further mandate independent third-party monitoring of all identified contaminants, with public reporting, enforceable deadlines, and multi-million-dollar penalties for noncompliance. Critically, the lease must include a clear termination clause requiring the Army to cease operations and vacate the island if contamination limits, monitoring requirements, or remediation obligations are violated.<\/p>\n

Anything short of these requirements would amount to continued occupation without accountability, shifting long-term environmental and severe public-health risks onto the people of Hawai\u02bbi while insulating the Army from responsibility.<\/p>\n

Descriptions of these areas and their accompanying contamination must be included in the new lease. Cleanup protocols and timetables must be included in the lease for each of these areas of contamination, while regular quarterly testing of the contaminants listed below that are known to exist in multiple locations throughout the sprawling facility must be set in motion.<\/p>\n

ProPublica\u2019s Freedom of Information Act work with the Department of Defense produced one of the most powerful revelations of military contamination ever assembled. By obtaining and organizing thousands of DoD records, ProPublica exposed the true national scale of toxic legacy pollution, unexploded ordnance, fuels, solvents, and heavy metals\u2014at hundreds of active and former military installations across all 50 states and U.S. territories.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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See ProPublica\u2019s 2017 report on Pohakuloa.<\/strong><\/a> \u00a0<\/strong>In its 2017 investigation of the P\u014dhakuloa Training Area, ProPublica identified 24 contaminated sites on the installation. This report examines each site to determine how\u2014or whether\u2014it is addressed in the Army\u2019s FEIS and to evaluate its likelihood of PFAS contamination.<\/p>\n

(1) PU’U PA’A SITE \u00a0Site ID: PTA-003-R-01<\/strong><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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The Pu\u2019u Pa\u2019a Site is shown in the center of the map.<\/em><\/strong><\/p>\n

The Pu\u2019u Pa\u2019a Site is comprised of 13,542 acres and was used by the DoD from 1943 to 2000. \u00a0The property is privately owned and is currently being addressed by Army under the\u00a0Defense Environmental Restoration Program (DERP),\u00a0 managed by the U.S. Army Corps of Engineers, focused on cleaning up contaminated sites and unexploded ordnance.<\/p>\n

The Army says<\/a> the cleanup will be completed by 2039 and that its estimated cost will be $32 million.<\/p>\n

Pu\u02bbu Pa\u02bba is part of the former\u00a0Waikoloa Maneuver Area\u00a0on the Island of Hawai\u02bbi.\u00a0 Pu\u02bbu Pa\u02bba was returned to private ownership after military use continued through the 1990s. Today, Pu\u02bbu Pa\u02bba is privately owned land held by Parker Ranch or Parker Ranch\u2013controlled entities and lies outside the state-leased Pohakuloa Training Area.<\/p>\n

The site poses an ongoing public safety risk from accidental detonation and raises environmental concerns related to munitions constituents such as RDX, HMX, TNT, perchlorate, and metals that can persist in soil and dust and potentially migrate.<\/p>\n

The Pu\u2019u Pa\u2019a Munitions Response Area is managed separately by the U.S. Army Garrison \u2013 Hawaii. This is because the Pu\u2019u Pa\u2019a Local Training Area continued to be used by the Army and the Army National Guard through the 1990s before the property was returned to private ownership, which made the property ineligible for the Formerly Used Defense Sites (FUDS) program. \u00a0FUDS properties must have been returned before 1987.<\/p>\n

Although the U.S. Army Corps of Engineers is involved in implementing investigation and removal work at Pu\u02bbu Pa\u02bba, the site is not a FUDS site, and the Army\u2014not the Corps\u2014retains programmatic control, funding authority, and responsibility for the pace of remediation under CERCLA.<\/p>\n

The Hawai\u2019i Department of Health Hazard Evaluation and Emergency Response Office is charged with the responsibility to ensure that DoD actions are consistent with the Hawaii Environmental Response Law (HERL), Hawaii Revised Statues (HRS) 128D.\u00a0 See the Explosives Safety Guidance<\/em><\/strong><\/a> to Help Protect You from Munitions.<\/em><\/strong><\/p>\n

Although Pu\u02bbu Pa\u02bba is being managed primarily as a munitions response area, the site\u2019s long operational history and routine fire-response needs make PFAS use, especially AFFF use highly plausible. The absence of PFAS discussion in available decision documents should be treated as a data gap, not evidence of absence. The Pu\u2019u Pa\u2019a Waikoloa Maneuver Area is not addressed in the Army\u2019s Final Environmental Impact Statement, (FEIS)<\/a>.<\/p>\n

(2) FORMER BAZOOKA RANGE Site ID: PTA-004-R-01 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

The Former Bazooka Range measures approximately 60 acres. The site used a rail-mounted moving target for weapons practice. In 2015, the site underwent a surface-only cleanup action that removed 71,300 pounds of material documented as safe, 2,000 pounds of range-related debris, and 81 separate Munitions & Explosives of Concern. The debris was heavily concentrated within an approximately 11-acre central location.<\/p>\n

In 2017, surface soil at this site was sampled and analyzed for explosive material and MC metals. Analysis of the soil samples detected concentrations of MC metals above USEPA Region 9 RSLs for Risk-Based Soil Screening for protection of groundwater but below State DOH Tier 1 EALs.<\/p>\n

The metals were either below background levels or only above USEPA Region 9 RSLs for protection of groundwater. Due to the arid conditions, lack of streams, and depth of groundwater at the site, which creates a low potential for contaminant mobilization via leaching, as well as the lack of groundwater wells and surface water development in the State-owned land, the metals are not considered COCs that potentially pose an unacceptable risk to site users and warrant further investigation.<\/p>\n

Subsurface soils were not evaluated because historical records and land use did not suggest that subsurface soil impacts have occurred.<\/p>\n

The Army\u2019s own sampling found munitions-constituent metals above EPA Region 9 screening levels designed specifically to protect groundwater\u2014then dismissed the exceedances by asserting, without supporting measurements, that arid conditions and deep groundwater make leaching unlikely.<\/p>\n

The Army\u2019s logic further relies on the absence of wells and streams\u2014confusing lack of monitoring infrastructure with lack of risk\u2014while ignoring heavy storm-driven recharge, preferential pathways in fractured volcanic terrain, and transport via disturbed soils and dust. In plain terms: they exceeded a groundwater-protection screen and chose not to look any deeper.<\/p>\n

No land use restrictions have been imposed on the former bazooka range.<\/p>\n

Although the former Bazooka Range is being managed primarily as a munitions response area, the site\u2019s long operational history and routine fire-response needs make PFAS use, especially AFFF use very likely. The absence of PFAS discussion in available decision documents should be treated as a data gap, not evidence of absence.<\/p>\n

(3) HUMUULA SHEEP STATION-West Site ID: PTA-001-R-01 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

Humu\u02bbula Sheep Station\u2013West is a Training and Maneuver Area. Maneuver areas commonly contain chemical residues from pyrotechnics, illumination rounds, simulators, flares, and propellants used during training. These materials can introduce perchlorate, polycyclic aromatic hydrocarbons (PAHs) such as naphthalene, and munitions-constituent metals including copper, lead, antimony, and barium into surface soils. Repeated soil disturbance and dry conditions increase the likelihood that these contaminants persist, migrate as dust or runoff, and pose long-term exposure risks that are not captured by limited surface-soil screening alone.<\/p>\n

Pyrotechnics involve heavy uses of PFAS. See: CSWAB.<\/a><\/p>\n

Humu\u02bbula Sheep Station\u2013West (Site ID PTA-001-R-01) has been formally designated by the Army as a CERCLA site.<\/p>\n

(4) LANDFILL 2 Site ID: POTA-06 <\/strong>(Described in FEIS)<\/a>.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Landfill 2 POTA \u2013 06 is located adjacent to Bradshaw Army Airfield. The two combine as an expected PFAS hotspot. <\/em><\/strong><\/p>\n

The former POTA-06 landfill was opened in 1979 and closed in October 1993.\u00a0 LANDFILL 2 \u00a0is a recognized CERCLA waste site within P\u014dhakuloa Training Area. As a buried landfill associated with decades of military operations, it represents a presumptive source of heavy concentration of PFAS, metals, petroleum hydrocarbons, solvents, and other contaminants that can persist and migrate through soil and groundwater. Any conclusion that this site does not warrant further investigation must be supported by site-specific subsurface data, not generalized assumptions about aridity or current land use.<\/p>\n

According to the FEIS, \u201cTo remedy landfill POTA-06, which is on the State-owned land in TA 6, the Army at one time monitored methane emissions from the landfill. After eight sampling events indicated that no methane was being produced from the landfill, the DOH approved the elimination of methane monitoring in May 2012.\u201d<\/p>\n

The assertion that Landfill POTA-06 produced no methane after eight sampling events\u2014and therefore warranted termination of methane monitoring\u2014lacks credibility, as methane generation is a well-established and often intermittent byproduct of landfills containing organic material, with emissions that can vary spatially and temporally and are not reliably ruled out by a limited number of discrete sampling events.<\/p>\n

(5) FORMER FFTA PIT Site ID: POTA-01<\/strong><\/p>\n

The Former Firefighter Training Area Pit (POTA-01) at P\u014dhakuloa Training Area is a documented Fire\/Crash Training Area where fuels were historically burned for emergency response training. Such sites are associated with massive\u00a0 PFAS contamination from the use of aqueous film-forming foam (AFFF) during firefighting exercises.<\/p>\n

It is impossible to match\u00a0 this area, POTA-01 with the fire training areas described in the current PFAS preliminary assessment \/ site inspection. The Army changes its designations of these toxic areas, confusing the public.<\/p>\n

The Former FFTA Pit is not addressed in the FEIS.<\/p>\n


\n(6) FORMER STG AREA BEHIND BLDG T-31 Site ID: POTA-02 <\/strong><\/p>\n

The Former Small-Arms Training and Gunnery Area behind Building T-31 (POTA-02) at P\u014dhakuloa Training Area is a legacy small-arms training area where weapons firing and related activities historically occurred adjacent to support facilities. Such areas commonly contain munitions debris and metals (including lead, copper, and antimony) in surface soils, with risks heightened by erosion, dust generation, and disturbance. \u00a0Like the other live fire sites, they are associated with the use of firefighting foams containing PFAS.<\/p>\n

This site is left out of the FEIS.<\/p>\n


\n(7) ARTILLARY FIRING AREA POWDER BURN Site ID: POTA-04<\/strong><\/p>\n

The Artillery Firing Area \u2013 Powder Burn at P\u014dhakuloa Training Area is a legacy training location where excess artillery propellant (powder charges) was intentionally burned or detonated during live-fire operations. These activities can leave residual energetic compounds, perchlorate, and metals in soil, along with buried or surface munitions debris, posing long-term environmental and safety concerns.<\/p>\n

The current burn pan is within PTA immediately south of TA 13 along the southern boundary of the State owned land (i.e., adjacent to but not on State-owned land). The burn pan is a low-lying rectangular-shaped area located on a graded \u2018a\u2018a lava flow. The burn pan has been in operation since the late 1990s\/early 2000s. Military units dispose of excess propellant bags\/increments incidental to artillery firing training through on-site powder burns at the completion of training.<\/p>\n

Although the Army does not associate the burn pan as a PFAS source, aqueous AFFF commonly accompanied live-fire and artillery training activities at Army installations nationwide.<\/p>\n

This site is left out of the FEIS.<\/p>\n


\n(8) IMPACT AREA Site ID: POTA-07<\/strong><\/p>\n

Decades of live-fire training in the approximately 51,000-acre federally owned impact area have left a complex toxic legacy that includes explosive compounds, heavy metals, and perchlorate from propellants and pyrotechnics, as well as petroleum hydrocarbons from fuels and lubricants. It\u2019s not good.<\/p>\n

The Hawai\u02bbi Board of Land and Natural Resource determined that impacts originating in this area, including wildfire emissions, unexploded ordnance (UXO), and resulting contamination, directly affect state trust lands and shared ecosystems.<\/p>\n

The Army\u2019s FEIS failed to analyze the impact area.<\/p>\n


\n(9) Petroleum, Oil, Lubricants (POL) STORAGE AREA Site ID: POTA-09<\/strong><\/p>\n

The POL Storage Area is associated with historical storage and handling of fuels, oils, and lubricants. Such sites are well-documented sources of petroleum hydrocarbons, BTEX compounds, (Benzene, Toluene, Ethylbenzene, Xylene), PAHs such as naphthalene, metals, and often chlorinated solvents used in fuel-system maintenance. Any conclusion that this site does not warrant further investigation must be supported by subsurface soil and groundwater data, not generalized assumptions about site conditions or current land us.\u00a0 AFFF has always been an integral part of these programs on Army facilities.<\/p>\n

This site is left out of the FEIS.<\/p>\n

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(10) UNDERGROUND STORAGE TANKS SITES (7) Site ID: POTA-10 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

The Underground Storage Tanks (UST) Sites (7) (POTA-10) at P\u014dhakuloa Training Area consist of multiple locations where fuel and petroleum products were historically stored in buried tanks to support training operations. Leaks and releases from these tanks are commonly associated with petroleum hydrocarbons TPH, BTEX contamination in soil and potentially groundwater. Although the tanks have been removed or closed, these sites represent legacy contamination on state-owned land leased to the Army.<\/p>\n

PFAS contamination is associated with underground storage tanks, not necessarily through fuel releases, but through the widespread historical use of PFAS-containing materials in seals, gaskets, O-rings, hoses, coatings, lubricants, and other UST system components that degrade and leach into surrounding soils over time.<\/p>\n


\n(11) MAINTENANCE AREA (WSC #5) Site ID: POTA-11<\/strong><\/p>\n

The Maintenance Area (WSC #5) at P\u014dhakuloa Training Area is a legacy support area where vehicle and equipment maintenance historically occurred, activities commonly associated with releases of petroleum hydrocarbons, solvents, lubricants, metals, and degreasers like\u00a0 trichloroethylene (TCE) into surrounding soils. Such areas can pose long-term environmental risks through soil contamination and potential migration to groundwater, particularly where historic practices lacked modern containment. Located on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA-based environmental restoration program, contributing to broader concerns about cumulative contamination and the adequacy of cleanup at PTA.<\/p>\n

Maintenance areas on Army installations are associated with the storage and use of AFFF. This area is not addressed in the FEIS.<\/p>\n

\u00a0<\/strong><\/p>\n

(12) AMMUNITION STG MAGAZINES (8) \u00a0Site ID: POTA-12<\/strong><\/p>\n

The Ammunition Storage Magazines (8) (WSC #8) at P\u014dhakuloa Training Area comprise multiple facilities used to store military munitions and explosives in support of training operations. While not firing ranges, such areas are commonly associated with explosive residues, propellants, perchlorate, and metals from handling, storage, and occasional spills or deterioration of munitions, as well as buried debris from past operations. Situated on state-owned land leased to the Army, these sites are addressed within the Army\u2019s CERCLA-based environmental restoration and munitions management framework, underscoring ongoing concerns about legacy contamination, investigation rigor, and long-term stewardship at PTA.<\/p>\n

Like the other sites that involve handling of munitions and explosives, these areas are associated with AFFF storage and usage.\u00a0 These sites are not addressed in the Army\u2019s FEIS.<\/p>\n


\n(13) FOAM STORAGE SHED \u00a0Site ID: POTA-13<\/strong><\/p>\n

The Foam Storage Shed (WSC #9) at P\u014dhakuloa Training Area is a legacy support site used to store firefighting foams, historically including aqueous film-forming foam (AFFF). Spills, leaks, or equipment rinsing at such facilities are a well-documented source of PFAS contamination in soil and potentially groundwater, even where active use has ceased. Located on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA environmental restoration framework, making it a focal point for concerns about PFAS investigation, cleanup adequacy, and long-term monitoring at PTA.<\/p>\n

There is no mention of this obvious PFAS-related site in the FEIS.<\/p>\n


\n(14) UNDERGROUND STORAGE TANKS SITE Site ID: POTA-14<\/strong><\/p>\n

The Underground Storage Tanks Site (WSC #10) at P\u014dhakuloa Training Area is a legacy fuel-storage location where petroleum products were historically stored in buried tanks to support military operations. Releases from aging or improperly closed tanks are commonly associated with petroleum hydrocarbons (TPH) and BTEX compounds, with the potential to contaminate surrounding soils and, under certain conditions, groundwater. Situated on state-owned land leased to the Army, this site is managed under the Army\u2019s CERCLA-based environmental restoration program, contributing to ongoing concerns about legacy fuel contamination and long-term stewardship at PTA.<\/p>\n

These sites are not addressed in the Army\u2019s FEIS.<\/p>\n


\n(15) FORMER TRANSFORMER STG AREA \u00a0Site ID: POTA-15 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

The Former Transformer Storage Area (WSC #13) at P\u014dhakuloa Training Area is a legacy site where electrical transformers were historically stored and handled, activities commonly associated with releases of polychlorinated biphenyls (PCBs) as well as petroleum oils and metals from leaks or spills. Even small releases can result in persistent soil contamination with long-term human and ecological risks. Located on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA-based environmental restoration program, raising ongoing concerns about investigation thoroughness, cleanup standards, and long-term monitoring at PTA.<\/p>\n

The Army says in the FEIS that discharges from pad-mounted transformers are small quantities, resulting from slow corrosion of transformer components due to weather exposure. Slow discharges tend to be absorbed rapidly into the soil surrounding the transformer pad and have minimal potential of entering waterways or storm drainage systems.<\/p>\n

PFAS is associated with former transformer storage areas due to the historical use of AFFF for fire suppression, PFAS-containing electrical insulation, fluorinated seals and gaskets, PTFE-based lubricants, and PFAS-treated spill response materials, all of which can degrade and leach into surrounding soils over time.<\/p>\n


\n(16) 43 SEPTIC TANKS\/12 LEACH WELLS Site ID: POTA-16 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

The 43 Septic Tanks \/ 12 Leach Wells at P\u014dhakuloa Training Area represent a widespread legacy of a dangerous wastewater disposal system used to support housing, training, and support facilities across the installation. Such systems are commonly associated with releases of PFAS, nutrients, pathogens, petroleum residues, solvents, metals, and emerging contaminants, with leach wells posing a direct pathway to groundwater in Hawai\u02bbi\u2019s highly permeable volcanic soils. These sites are located on state-owned land leased to the Army.<\/p>\n

The 2025 FEIS states that the Army continues to rely on cesspools and that they are regulated by the Hawaii Department of Health.\u00a0 The law calls for their abolition by 2050. The Army previously operated “large-capacity cesspools”\u00a0 at PTA, which were banned by the EPA in 2005. The Army continued using them until a\u00a02016 <\/strong>enforcement action\u00a0forced their closure.<\/p>\n

“Small-capacity” cesspools at a massive military installation like PTA should be held to higher standards than residential systems due to the potential for industrial or chemical runoff, including\u00a0PFAS contaminants. It is good to see kmovement in the legislature on this matter.<\/p>\n

(17) UNDERGROUND STORAGE TANKS BLDG 186 Site ID: POTA-17<\/strong><\/p>\n

The Underground Storage Tanks at Building 186 at P\u014dhakuloa Training Area are a legacy fuel-storage site associated with historic operations and facility support activities. Leaks or releases from these tanks are commonly linked to petroleum hydrocarbons (TPH) and BTEX compounds, which can persist in soil and pose a risk to groundwater in Hawai\u02bbi\u2019s permeable volcanic geology. Situated on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA-based environmental restoration program, contributing to broader concerns about legacy fuel contamination, investigation adequacy, and long-term stewardship at PTA.<\/p>\n

The tanks are associated with PFAS, while these sites are not addressed in the Army\u2019s FEIS.<\/p>\n


\n(18) VEHICLE REFUELING AREA\u00a0 Site ID: POTA-18\u00a0 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

The Vehicle Refueling Area at P\u014dhakuloa Training Area is a legacy operational site where fuels were routinely transferred and stored to support military vehicles and equipment. Such areas are commonly associated with petroleum hydrocarbons (TPH), BTEX compounds, and fuel additives in soil from chronic spills and leaks, with the potential to migrate toward groundwater in Hawai\u02bbi\u2019s highly permeable volcanic terrain. Located on state-owned land leased to the Army, the site is managed under the Army\u2019s CERCLA-based environmental restoration program, underscoring ongoing concerns about legacy fuel contamination, cleanup adequacy, and long-term monitoring at PTA.<\/p>\n

Vehicle refueling areas are credible PFAS source zones because PFAS were historically used not only in firefighting foams, but throughout fuel-handling, safety, and maintenance operations.\u00a0 PFAS-containing materials are embedded in fluoropolymer-lined hoses, gaskets, O-rings, valve seals, and flexible connectors designed for chemical resistance.<\/p>\n

\u00a0<\/strong><\/p>\n

(19) EQUIPMENT STORAGE AREA Site ID: POTA-19<\/strong><\/p>\n

The Equipment Storage Area at P\u014dhakuloa Training Area is a legacy support site used to store military vehicles, machinery, and materials in support of training operations. Such areas are commonly associated with PFAS, petroleum hydrocarbons, lubricants, solvents, metals, and battery-related contaminants from leaks, spills, and long-term outdoor storage on unpaved surfaces. Situated on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA-based environmental restoration program, contributing to ongoing concerns about cumulative contamination and the adequacy of investigation and long-term stewardship at PTA.<\/p>\n

This site is not addressed in the FEIS.<\/p>\n


\n(20) ABANDONED LANDFILL 1 \u00a0Site ID: POTA-03<\/strong><\/p>\n

The Abandoned Landfill 1 at P\u014dhakuloa Training Area is a legacy disposal site where solid waste from military operations was historically buried or dumped without modern liners or leachate controls. Such landfills are commonly associated with mixed contaminants, including petroleum hydrocarbons, solvents, metals, unexploded debris, and PFAS-containing materials, with leachate posing a long-term risk to soil and groundwater in Hawai\u02bbi\u2019s highly permeable volcanic geology. Located on state-owned land leased to the Army, the site is managed under the Army\u2019s CERCLA-based environmental restoration program, underscoring persistent concerns about uncharacterized waste, inadequate cleanup, and long-term environmental stewardship at PTA.<\/p>\n

We don\u2019t know when this landfill was in service. Because Abandoned Landfill 1 is described as a \u201clegacy disposal site,\u201d this likely means it was associated with solid waste disposal practices that pre-date modern environmental controls. On Army installations, such landfills were commonly established and used from the 1950s through the 1970s or early 1980s. Solid waste containing PFAS began to be disposed of in landfills in the 1960’s while AFFF was introduced in the early 1970’s.<\/p>\n

This important site is not addressed in the Army\u2019s FEIS.<\/p>\n


\n(21) HUMUULA SHEEP STATION-EAST HUMUULA SHEEP STATION-EAST Site ID: PTA-001-R-02 <\/strong>(Described in FEIS)<\/a>.<\/p>\n

\u00a0<\/strong>Humu\u02bbula Sheep Station\u2013East is a Training and Maneuver Area within the Army\u2019s P\u014dhakuloa Training Area on Hawai\u02bbi Island that has been used for decades for ground troop and vehicle maneuvers rather than concentrated live-fire training. Although not primarily a firing range, repeated military use can leave munitions debris, petroleum residues, metals, and compacted or eroded soils, with dust generation and runoff posing ongoing environmental concerns. The area lies on state-owned land leased to the Army and is managed as part of PTA\u2019s broader training footprint, making it relevant to cumulative-impact, stewardship, and lease-renewal debates surrounding the installation.<\/p>\n

While not expected to be as heavily impacted by PFAS as the Humu\u02bbula Sheep Station\u2013West, the military activities here are likely associated with AFFF usage.<\/p>\n


\n(22) BRADSHAW FIELD STORAGE AREA Site ID: POTA-08<\/strong><\/p>\n

The Bradshaw Field Storage Area (WSC #2) at P\u014dhakuloa Training Area is a legacy support site used for the storage of military equipment, materials, and supplies associated with training operations. Activities at such storage areas are commonly linked to PFAS, petroleum hydrocarbons, lubricants, solvents, metals, and battery-related contaminants from leaks, spills, and long-term outdoor storage. Located on state-owned land leased to the Army, the site is addressed under the Army\u2019s CERCLA-based environmental restoration program, contributing to ongoing concerns about legacy contamination, investigation adequacy, and long-term environmental stewardship at PTA.<\/p>\n

This site is not mentioned in the Army\u2019s FEIS.<\/p>\n


\n(23)\u00a0 KULANI BURN PILE Site ID: PTA-002-R-02<\/strong><\/p>\n

The Kulani Burn Pile at P\u014dhakuloa Training Area is a legacy waste-disposal site where debris and surplus materials were historically open-burned, a practice commonly associated with residual ash, metals, petroleum byproducts, and partially combusted compounds in surface soils. Open burning can leave persistent contamination and mobilize pollutants through windblown dust and runoff, particularly in PTA\u2019s exposed, high-elevation environment. Burn piles are historically associated with high concentrations of PFAS. \u00a0The important site is located on state-owned land leased to the Army and it does not appear in the Army\u2019s FEIS.<\/p>\n

(24) KULANI BOYS’ HOME KULANI BOYS’ HOME Site ID: PTA-002-R-01\u00a0 <\/strong>Kulani Boys\u2019 Home is a historic former juvenile correctional facility located adjacent to the P\u014dhakuloa Training Area that has been impacted by nearby military training and disposal activities, including unexploded munitions, munitions debris, and contamination associated with burning and live-fire operations in the surrounding Kulani area. The proximity of the former residential facility to active and legacy military sites underscores long-standing public safety and environmental concerns, particularly regarding UXO hazards, and soil contamination.<\/p>\n

Live fire operations are associated with AFFF use. This site does not appear in the Army\u2019s FEIS.<\/p>\n

\u00a0<\/strong><\/p>\n

Other sites identified in the FEIS<\/strong><\/p>\n

The FEIS identified three former ranges: a Former Bazooka Range, Former Tank Gunnery Range, and Potential Former Burn Pan. No land use restrictions have been imposed on any of these sites.\u00a0 The Army considers these ranges to be operational, although live fire is not currently conducted.<\/p>\n

The Army says these locations have the potential to contain Munitions and Explosives of Concern (MEC). This term is used to describe military munitions that pose an explosive safety hazard due to their physical condition, location, or lack of accountability. MEC include: Unexploded Ordnance (UXO), Discarded Military Munitions (DMM), and Munitions Debris with Explosive Potential.<\/p>\n

The Former Bazooka Range<\/strong>, including the High Mortar Concentration Area, contains 60 acres.\u00a0 In 2015, the site underwent a surface-only cleanup action that removed 71,300 pounds of material documented as safe, 2,000 pounds of range-related debris, and 81 MEC items. \u00a0Subsurface military munitions at this site have not been addressed.<\/p>\n

In 2017, surface soil at this site was sampled and analyzed for explosive material and MC metals. Analysis of the soil samples detected concentrations of MC metals above USEPA Region 9 standards for protection of groundwater.<\/p>\n

The Army concludes, \u201c Due to the arid conditions, lack of streams, and depth of groundwater at the site, which creates a low potential for contaminant mobilization via leaching, as well as the lack of groundwater wells and surface water development in the State-owned land, the metals are not considered contaminants of concern that potentially pose an unacceptable risk to site users and warrant further investigation.<\/p>\n

The Army\u2019s determination of no further action at the Former Bazooka Range is not supported by the facts or by sound environmental science. Although a surface-only cleanup removed debris and visible munitions, subsurface military munitions\u2014the primary long-term source of contamination\u2014remain unaddressed. Subsequent soil sampling detected munitions-related metals at concentrations exceeding USEPA Region 9 standards for protection of groundwater, yet these exceedances were dismissed based on assumptions about arid conditions, deep groundwater, and the absence of monitoring wells.<\/p>\n

It\u2019s the same argument again.. In Hawai\u02bbi\u2019s fractured volcanic terrain, however, episodic heavy rainfall, preferential flow paths, and perched water zones can mobilize contaminants despite low average rainfall, and the lack of wells reflects a lack of monitoring, not a lack of risk.<\/p>\n

The no-action finding fails to account for the cumulative and enduring environmental harm associated with unresolved subsurface munitions and metal contamination at the site. And, of course, firefighting foams and PFAS in various components are also expected to be part of the scene.<\/p>\n

The Former Tank Gunnery Range<\/strong><\/p>\n

This site was operational as a tank gunnery range in the 1950s and possibly up until the early 1960s<\/p>\n

There are no records of a cleanup action being performed at this site. In 2017, surface soil was sampled and analyzed for explosive material and MC metals. The soil samples contained no concentrations of these contaminants above USEPA Region 9 RSLs.<\/p>\n

The Army says subsurface soils were not evaluated because historical records and land use did not suggest that subsurface soil impacts have occurred.<\/p>\n

The assertion that subsurface soil impacts are unlikely at a former tank gunnery range because historical records and land use do not suggest such impacts is difficult to support. Tank gunnery operations in the 1950s involved repeated live-fire exercises using high-energy munitions that routinely resulted in buried fragments, ricochets, and unexploded ordnance.<\/p>\n

A tank gunnery range is reasonably expected to contain a broad suite of contaminants tied to decades of live-fire and support activities. These include munitions and explosives of concern, energetic compounds such as TNT, RDX, HMX, DNTs, nitroglycerin, and nitrocellulose from high-explosive and propellant residues.<\/p>\n

These chemicals are readily absorbed through ingestion of contaminated water, inhalation of dust or vapors, and dermal contact, and several are known or suspected carcinogens.<\/p>\n

Munitions-constituent metals including lead, copper, antimony, zinc, barium, chromium, nickel, and tungsten are shed from projectiles, fragments, and primers.<\/p>\n

The tank gunnery range spread perchlorate from propellants, igniters, tracers, and pyrotechnics. \u00a0Polycyclic aromatic hydrocarbons (PAHs), notably naphthalene, are produced from detonations.<\/p>\n

Where armor-piercing testing occurred or was possible, depleted uranium (DU) must also be examined, although the Army doesn\u2019t mention it in their Environmental Impact Statement.<\/p>\n

Depleted Uranium<\/strong><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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See Radioactive Materials, p 3–17<\/a> in the Army\u2019s FEIS.<\/p>\n

The Army\u2019s FEIS acknowledges that depleted uranium (DU) was used at the P\u014dhakuloa Training Area (PTA) during training involving the Davy Crockett Weapon System between 1962 and 1968. According to the FEIS, DU was present\u00a0 in the M101 20-millimeter spotting rounds fired to aim the weapon prior to launching high-explosive practice projectiles. Each spotting round contained approximately 0.5 pound of a depleted uranium\u2013molybdenum alloy. The Army reports that no more than 400 rounds were fired at PTA, corresponding to a total potential DU deposition on the order of 200 pounds. Depleted uranium is chemically toxic and radiologically hazardous, with a half-life measured in billions of years.<\/p>\n

The Army states that these rounds were fired at four ranges within PTA. Of these, three ranges are entirely on U.S. Government-owned land, while one range\u2014Range 13 on Training Area 9\u2014is partially on State-owned land.<\/p>\n

The Army distinguishes between state-owned and federally owned land while this has no environmental relevance. Radiation does not respect jurisdictional lines. Wind, stormwater runoff, soil disturbance, wildfire, and human activity do not stop at survey boundaries.<\/p>\n

The Army\u2019s reliance on ten surface soil samples to dismiss the presence of DU is also alarming. The absence of DU\u00a0 in a small number of surface samples does not demonstrate absence of contamination. No systematic subsurface DU investigation has been conducted, despite the acknowledged firing of hundreds of DU projectiles.<\/p>\n

Former Burn Pan<\/strong><\/p>\n

\u201cApproximately 0.4 acre of the site was used as a burn pan prior to the mid-1990s. A burn pan is an area where excess military munition propellant is ignited for disposal treatment.<\/p>\n

The Army claims they do not know materials were disposed of at this site. In 2017, surface soil was sampled and analyzed for polycyclic aromatic hydrocarbons, explosive material, and MC metals. The soil samples contained concentrations of naphthalene (a polycyclic aromatic hydrocarbon) and copper (a metal) above the USEPA Region 9 RSLs but below State DOH Tier 1 EALs.<\/p>\n

The Army does not share the results of this sampling.<\/p>\n

\u201cAdditionally, copper is not a concern because the pathway for leaching to groundwater is incomplete due to site conditions and the lack of groundwater wells and surface water development in the State-owned land.\u201d<\/p>\n

Seriously?\u00a0 The assertion that copper is \u201cnot a concern\u201d because the leaching pathway to groundwater is incomplete due to site conditions and the absence of groundwater wells or surface water development reflects a fundamental misunderstanding of contaminant transport and risk assessment. The lack of groundwater wells does not interrupt a pathway; it merely prevents detection.<\/p>\n

Declaring copper harmless because it has not been measured in groundwater substitutes administrative convenience for environmental protection and improperly shifts risk to future generations.<\/p>\n

Army burn pans, or pits, were routinely used for firefighting training and, following the adoption of AFFF in the early 1970s, regularly involved repeated discharges of PFAS-containing foam directly onto unlined ground, making these sites among the most significant PFAS source areas on military installations. The Army left this most significant out of the FEIS narrative.<\/p>\n

No mention of trichloroethylene (TCE)<\/strong><\/p>\n

A review of all publicly available Army environmental documents for P\u014dhakuloa Training Area, including the Final Environmental Impact Statement, shows no mention of trichloroethylene (TCE).<\/p>\n

Storage areas and landfills are well-documented historical sources of chlorinated solvents, like TCE. The absence of any publicly available analytical data accompanying the FEIS raises serious concerns that relevant contaminants were not evaluated.<\/p>\n

The Hawai\u02bbi Board of Land and Natural Resources\u2019 (BLNR) rejection of the U.S. Army\u2019s Final Environmental Impact Statement (FEIS) <\/strong><\/p>\n

The FEIS consists of four volumes containing 3,598 pages:<\/p>\n

Final EIS \u2013 Vol. I<\/a>
\nFinal EIS \u2013 Vol. 2<\/a>
\nFinal EIS \u2013 Vol. 3<\/a>
\nFinal EIS \u2013 Supporting Documents<\/a><\/p>\n

The Board of Land and Natural Resources\u2019 (BLNR) raised serious and well-founded concerns regarding a broad range of Army activities\u2014including the desecration of ancestral and culturally significant lands, the ignition of recurrent wildfires, and the perpetuation of economic and environmental inequities. Those issues, though grave, are not the primary subject of this analysis. The discussion that follows is limited to the Board\u2019s findings as they relate to contamination, environmental health, and the Army\u2019s failure to adequately characterize and disclose toxic risks associated with continued military use of public trust lands.<\/p>\n

The P\u014dhakuloa Training Area (PTA) covers approximately 132,000 acres on Hawai\u02bbi Island, including a vast federally owned live-fire impact area and approximately 23,000 acres of State of Hawai\u02bbi land leased to the U.S. Army. The lease expires on August 16, 2029. The Army proposes to retain up to 22,750 acres of State-owned land in support of continued military training.<\/p>\n

On May 9, 2025, the Hawai\u02bbi Board of Land and Natural Resources (BLNR) voted 5\u20132 to reject the Army\u2019s Final Environmental Impact Statement (FEIS) for the proposed retention of State-owned lands at the P\u014dhakuloa Training Area (PTA). The Board determined that the FEIS failed to satisfy the disclosure and analytical requirements of the Hawai\u02bbi Environmental Policy Act (HEPA), Chapter 343, Hawaii Revised Statutes<\/a><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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The Army\u2019s desecration of lands on the Big Island represents a dangerous constitutional clash between federal overreach and the state of Hawai\u02bbi\u2019s sovereign authority to protect its lands, waters, and people.<\/em><\/strong><\/p>\n

In light of the deficiencies described in the preceding section of this report, the Hawai\u02bbi Board of Land and Natural Resources had no reasonable alternative but to reject the Army\u2019s Final Environmental Impact Statement. The Board\u2019s decision was grounded in the Army\u2019s failure to satisfy the legal and procedural requirements of Hawai\u02bbi Revised Statutes Chapter 343, particularly its obligation to fully disclose and rigorously evaluate environmental impacts. The BLNR concluded that the FEIS did not adequately analyze the consequences of continued military use of state-leased lands or the federally owned impact area and instead relied on outdated, incomplete, or missing data.<\/p>\n

BLNR expressed alarm over the inadequate analysis of impacts to biological resources, the absence of clear information regarding cleanup obligations upon the return of the land, and unresolved conflicts with Conservation District land-use purposes. The people of Hawai\u02bbi are fortunate to be served by a board that acted with honesty, courage, and integrity in issuing its historic rejection of the Army\u2019s pseudo-scientific Final Environmental Impact Statement.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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After hearing hours of passionate testimony from community members, the Board of Land and Natural Resources (BLNR) voted not to accept the United States Army\u2019s Final Environmental Impact Statement (FEIS) for the proposed retention of state-owned lands at P\u014dhakuloa Training Area (PTA) on Hawai\u02bbi Island.\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 <\/em><\/strong>May 9, 2025 – BLNR<\/em><\/strong><\/a><\/p>\n

A primary deficiency identified by BLNR is the Army\u2019s failure to evaluate environmental desecration within the federally owned impact area. Although the Army limited its analysis to lands leased from the State, BLNR concluded that this approach improperly constrained the FEIS\u2019s area of influence. Under HEPA, an environmental review must consider all reasonably foreseeable impacts of the proposed action, including those occurring on adjacent or connected lands<\/em> when activities function as a single operational unit.<\/p>\n

Decades of live-fire training in the approximately 51,000-acre federally owned impact area have left a complex toxic legacy that includes explosive compounds such as TNT, RDX, and HMX. Heavy metals including lead, copper, antimony, tungsten, and depleted uranium residues are prevalent. \u00a0Perchlorate from propellants and pyrotechnics, as well as petroleum hydrocarbons from fuels and lubricants abound. These chemicals are associated with munitions, flares, and firefighting activities. We will examine PFAS in a later section.<\/p>\n

Many of these contaminants persist in soil and sediments, can be mobilized by wind, wildfire, and intense rainfall, and pose long-term risks to groundwater, ecosystems, and human health.<\/p>\n

Firing a single 5.56 \u00d7 45 mm NATO round is an environmental catastrophe in itself. The bullet contains a copper jacket, steel penetrator, and a lead core, along with propellant residues of nitrocellulose-based powders. Together, they contribute to neurological, cardiovascular, and developmental health effects with chronic exposure. One bullet..<\/p>\n

When fired in large quantities, these materials fragment and accumulate in soils, contributing to lead, copper, antimony, and other metal contamination at firing points and downrange impact areas.<\/p>\n

BLNR determined that impacts originating in this area, including wildfire emissions, unexploded ordnance (UXO), and resulting contamination, directly affect state trust lands and shared ecosystems. By excluding the impact area from\u00a0 analysis, the FEIS failed to disclose cumulative and indirect effects that are inseparable from continued military use of the leased lands. BLNR concluded that such segmentation undermines the purpose of environmental review and prevents informed decision-making.<\/p>\n

Where is the Army\u2019s data?<\/strong><\/p>\n

It is conspicuously absent.<\/p>\n

Volume III of the FEIS contains the entire Preliminary Assessment and Site Inspection of PFAS for Pohakuloa Training Area and Kilauea Military Reservation, Hawaii, 2023. We will examine this in detail in a subsequent section.<\/p>\n

A review of the Schofield Barracks Federal Facilities Agreement (FFA)<\/strong><\/a>, executed in 1992, documents the routine use, release, and monitoring of several dozen toxic compounds at that installation, including chlorinated solvents, fuels, metals, PCBs, explosives-related compounds, and other hazardous substances. Given the shared command structure, overlapping logistics, and decades of similar training and maintenance activities, most\u2014if not all\u2014of these compounds can reasonably be expected to have been used, released, or disposed of at the P\u014dhakuloa Training Area as well.<\/p>\n

Yet, the Army\u2019s Final Environmental Impact Statement references only a small subset of these contaminants, and then, only in passing, without presenting corresponding sampling results, baseline concentrations, or trend data. The absence of comprehensive contaminant data prevents meaningful assessment of environmental conditions at PTA and undermines the FEIS\u2019s claim to disclose the full scope of environmental impacts, as required under Hawai\u02bbi Environmental Policy Act. The Army\u2019s response is preposterous.<\/p>\n

At Schofield Barracks, the examination of dozens of chemical compounds occurred as part of the initial CERCLA (Superfund) process that preceded the Federal Facilities Agreement (FFA). The P\u014dhakuloa Training Area has never been designated a Superfund site, although it much larger, more intensively used for live fire, and more heavily contaminated than Schofield Barracks. Let\u2019s briefly look at the toxins examined\u00a0 at Schofield Barracks the Army ignored at P\u014dhakuloa.<\/p>\n

Organic Compounds in the Schofield Barracks FFA:<\/strong><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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The Army\u2019s FEIS on PTA provides no meaningful analysis of any of the compounds above.\u00a0 A handful of these toxins are mentioned in passing by the Army.\u00a0 See the notes below, along with corresponding pages from the FEIS Vol I.<\/p>\n

One member of the BLNR approved the Army\u2019s FEIS while another abstained.<\/p>\n

Asbestos<\/strong> \u2013 the Army\u2019s FEIS rules out the presence of Asbestos on state-leased lands. FEIS Vol I 3-112<\/strong><\/a><\/p>\n

PCB\u2019s <\/strong>– Based on a Polychlorinated Biphenyl (PCB) survey conducted in the early 1990s, no transformers or other equipment containing PCBs were located on the State-owned land FEIS Vol I 3-112<\/strong><\/a><\/p>\n

Antimony, Lead, and Zirconium –<\/strong> Soil samples collected from the BAX Target V-10 area contained concentrations of Contaminants of Concern (antimony, lead, and zirconium) that potentially pose unacceptable risks to site users. FEIS Vol I 3-111<\/strong><\/a>\u00a0 However, the Army provides no data, no mitigation strategies, and concludes, \u201cThe arid conditions, lack of perennial or intermittent streams, depth to groundwater, and the Army Training Land Retention at P\u014dhakuloa Training Area Final Environmental Impact Statement\u2019s relatively conservative models used to establish the screening levels limit the groundwater pathway.\u201d<\/p>\n

Arsenic<\/strong> is mentioned once. \u201cRelease mechanisms for potential contamination from training activities may include off-range flow of surface water, erosion, and deposition (via surface water) of soil, and infiltration into groundwater, if Standard Operating Procedures and Best Management Practices are not followed. The Phase II Environmental Condition of the Property (ECOP) surface soil sampling concluded that the contaminants detected in soils [i.e., antimony, arsenic, cobalt, copper, iron, 1-methylnaphthalene, lead, manganese, naphthalene, selenium, silver, total petroleum hydrocarbons (TPH) as diesel range organics, and residual range organics, and zirconium] have a low likelihood to become mobilized off-site due to the low rainfall in the area, lack of streams, and absence of a developed drainage system across the State-owned land.\u201d 3-107\u00a0 <\/strong>FEIS Vol I 3-112<\/strong><\/a><\/p>\n

The Final Environmental Impact Statement refers to a Phase II Environmental Condition of the Property (ECOP); however, that document does not appear in the Final EIS Supporting Documents or elsewhere in the publicly accessible administrative record.<\/p>\n

Compound-by-compound scientific analysis exposes the distortionary and dangerous narrative the Army relies upon to minimize known contamination pathways and human health risks.<\/p>\n

Antimony<\/strong><\/a> can become mobile under oxidizing conditions and through disturbance-driven dust and sediment transport. Its migration is not dependent on surface streams and is well documented at active and former firing and impact ranges.<\/p>\n

Arsenic<\/strong><\/a> is a toxic metalloid whose mobility is highly sensitive to oxidation-reduction\u00a0 conditions, soil disturbance, and episodic rainfall events. Even when naturally occurring, arsenic can be mobilized from surface soils into groundwater and biota when land is repeatedly disturbed.<\/p>\n

Cobalt<\/strong><\/a> is used in metal alloys and energetic materials and commonly co-occurs with explosive residues. It is readily mobilized when iron and manganese oxides dissolve, a process that occurs during wet-dry cycling and soil disturbance.<\/p>\n

Copper<\/strong><\/a> \u00a0\u00a0The assertion that copper has a low likelihood of off-site mobilization due to low rainfall, lack of streams, or absence of engineered drainage is scientifically incorrect. Copper is primarily transported bound to fine sediments and organic matter and can be mobilized through erosion, dust, and episodic storm events\u2014pathways that do not require perennial streams or developed drainage systems.<\/p>\n

Iron<\/strong><\/a>\u00a0 The claim that iron has a low likelihood of off-site mobilization due to low rainfall, lack of streams, and absence of drainage infrastructure is scientifically unsound. Iron and iron-associated elements can be mobilized and redistributed through erosion of fine sediments, dust transport, and redox-driven geochemical processes, none of which require perennial streams or engineered drainage systems.<\/p>\n

Lead<\/strong><\/a> is a well-established firing-range contaminant that migrates primarily through dust, erosion, and fine particulate transport. Its movement off-site has been documented at numerous military installations regardless of average rainfall or drainage infrastructure.<\/p>\n

Manganese<\/strong><\/a> The claim that manganese has a low likelihood of mobilizing off-site due to low rainfall, lack of streams, or absence of drainage infrastructure is inaccurate. Manganese is part of dynamic environmental cycles and can be mobilized and transported through wind-blown dust and particulate matter, soil erosion, and atmospheric deposition, none of which require perennial streams or engineered drainage systems.<\/p>\n

Selenium<\/strong><\/a> exists in highly mobile forms and readily migrates through soils under oxidizing conditions. It bioaccumulates and biomagnifies, making even low-level mobilization environmentally significant.<\/p>\n

Silver<\/strong><\/a> is associated with munitions and pyrotechnic residues and is primarily transported via fine particles and dust. Wind-driven and disturbance-related transport pathways are sufficient to move silver off-site.<\/p>\n

Zirconium<\/strong><\/a> is commonly used in munitions alloys and pyrotechnics and serves as an indicator of ordnance-related contamination. While less mobile than some metals, its presence confirms explosive sources rather than benign background conditions.<\/p>\n

1-Methylnapthalene<\/strong><\/a> is a semi-volatile petroleum hydrocarbon that can volatilize, sorb to dust, and migrate during storm events. Its transport occurs through air and soil pathways, not solely through surface water.<\/p>\n

Napthalene<\/strong><\/a> is highly volatile and readily migrates from soil to air, creating inhalation and vapor-intrusion exposure pathways. Its mobility is independent of rainfall, streams, or engineered drainage systems.<\/p>\n

Total Petroleum Hydrocarbons (TPH \u2013 Diesel and Residual Range Organics)<\/strong>
\nTPH represents a mixture of hydrocarbons with varying mobility, toxicity, and persistence, including semi-volatile and carcinogenic fractions. Treating TPH as a single, immobile substance obscures real exposure and transport risks.<\/p>\n

By asserting that this diverse suite of metals, metalloids, and organic contaminants has a \u201clow likelihood\u201d of off-site mobilization, the Army substitutes pseudo-scientific, generalized assumptions for compound-specific fate and transport analysis. Many of these contaminants migrate through dust, sediment, redox cycling, volatilization, and episodic storm events. These are pathways entirely independent of average rainfall, surface streams, or engineered drainage. This unsupported conclusion obscures well-established mechanisms of contaminant transport and fails to provide the disclosure required for informed decision-making under Hawai\u02bbi environmental law.<\/p>\n

We\u00a0 have also witnessed the Army\u2019s bull-headed refusal to recognize the propensity of PFAS compounds like PFOS to attach to minute particulate matter and become airborne. They appear to be living in their own scientific universe.<\/p>\n

Chromium<\/strong> is mentioned in passing, as a part of studies.<\/p>\n

Lead<\/strong> \u2013 \u201cPotential lead and other contaminants associated with the use of military munitions would continue to accumulate in soils at firing points and ranges, and surface water flow and wildfires would continue to represent potential pathways for contaminant mobilization. Because there are limited surface water and groundwater pathways on the State-owned land and impact area, which is U.S. Government-owned land, and the Army would continue to follow range debris cleanup management procedures, the risk of contaminants mobilizing is limited.\u201d FEIS Vol I 3-123<\/strong><\/a><\/p>\n

The Army must be living in a parallel universe. \u00a0The Army\u2019s claim that lead from munitions poses only a \u201cminor\u201d and \u201climited\u201d risk is inconsistent with decades of scientific evidence and the Army\u2019s own experience at other ranges. Lead does not degrade, dissipate, or become inert over time; it accumulates in soils at firing points and impact areas, where repeated use can drive concentrations into the thousands of parts per million. Hawai\u02bbi\u2019s high-permeability volcanic soils, intense rainfall, surface runoff, and frequent wildfires increase, rather than limit, the mobilization of lead and associated metals into surface water and groundwater. The assertion that there are \u201climited pathways\u201d ignores well-documented mechanisms such as erosion, ash transport, dust inhalation, and dissolved transport under changing redox conditions.<\/p>\n

The following statements from the Army suggest either a disregard for well-established scientific principles or an assumption that the State would not rigorously scrutinize the Army\u2019s claims. The deficiencies are sufficiently apparent that even a basic review reveals their flaws, raising serious questions about the level of scientific care applied in preparing the FEIS.<\/p>\n

The Army<\/strong> – Debris from artillery training is contained within PTA training areas, ranges, firing points, and impact areas that are not open to the public and are closely monitored by the Army. The Army monitors the potential for offsite migration of contamination under the Operational Range Assessment Program and has determined groundwater and surface waters are unlikely to be contaminated by explosive residues.\u00a0 <\/strong>FEIS Vol II\u00a0 D-20<\/strong><\/a><\/p>\n

This is ridiculous, especially when the Army won\u2019t share data.<\/p>\n

The Army \u2013<\/strong> \u201cThe closest drinking water well is 4,260 to 4,280 feet deep at the Waiki\u2018i Ranch (14 miles from PTA\u2019s main gate). The state monitors all drinking water sources for water quality.\u201d FEIS Vol II\u00a0 D-20<\/strong><\/a><\/p>\n

The argument that contamination does not pose a significant risk because the nearest current<\/em> drinking water well is 14 miles away and more than 4,200 feet deep is not a defensible standard under the\u00a0National Environmental Policy Act (NEPA). \u00a0 Environmental impact analysis must consider possible future uses.<\/p>\n

The Army \u2013<\/strong> \u201cSince August 1989, the State of Hawai\u2018i Department of Health has issued \u201cGroundwater Contamination Maps\u201d for Hawai\u2018i. According to these maps, most of the well locations where contamination is detected on the island of Hawai\u2018i are located along the eastern coast, and groundwater quality generally diminished towards the coasts due to increased saltwater intrusion.\u201d \u00a0FEIS Vol II\u00a0 D-20<\/strong><\/a><\/p>\n

The Army muddles coastal groundwater conditions with inland hydrogeology. The Army cites statewide \u201cGroundwater Contamination Maps\u201d showing contamination concentrated near the coast and diminished quality due to saltwater intrusion, then uses this to assert that inland groundwater beneath State-owned land is \u201clikely of higher quality.\u201d<\/p>\n

The Army<\/strong> \u2013 \u201cDetected contamination levels are below federal and state drinking water standards and do not pose a significant risk to humans.\u201d FEIS Vol II D-18\u00a0 <\/strong><\/a><\/p>\n

The FEIS contains no analytical groundwater dataset that would allow a reviewer to independently verify the Army\u2019s claim..<\/p>\n

The Army<\/strong> \u2013 \u201cGroundwater quality beneath the State-owned land is likely of higher quality due to its distance inland from the coast. \u00a0The EIS provides additional information available on groundwater resources on the State-owned land. Two small-diameter holes were drilled for testing within the U.S. Government-owned land at PTA and were not designed to develop potable water. A non-aerially extensive perched aquifer was encountered in the test hole drilled near the main base at a depth of between 700 to 1,181 feet below ground surface. A more aerially extensive perched aquifer is believed to be present at approximately 1,800 feet below ground surface below the State-owned land. PTA is a remote facility, there are currently no plans to develop potable water within the State-owned land. Potable water is currently trucked to PTA from 40 miles away.\u201d \u00a0 <\/strong>FEIS Vol II D-18\u00a0 <\/strong><\/a><\/p>\n

A perched aquifer is a shallow body of groundwater that sits above the main\u00a0 aquifer, separated from it by a layer of low-permeability material such as clay, or volcanic ash. The perched aquifer at Pohakuloa is vulnerable to contamination because it is shallow and directly connected to toxic military surface activities.<\/p>\n

The Army acknowledges encountering perched aquifers at depths between 700\u20131,181 feet and a more extensive perched system at approximately 1,800 feet, yet dismisses their significance because the test holes were not designed to produce potable water? Is that it?<\/p>\n

Identifying these aquifers without characterizing their water quality, connectivity, or vulnerability to contamination contradicts established best practices. This is a critical failure. Perched aquifers are well-documented conduits for contaminant transport and serve as recharge pathways to deeper aquifers.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Big Island Video News 6\/21\/16<\/em><\/strong><\/a><\/p>\n

Speaking of perched aquifers, the Army has historically used large-capacity cesspools at PTA.<\/p>\n

We gained a sense of cesspools earlier in this report when we read that FEIS states that the Army continues to rely on cesspools and likely will be permitted to do so until 2050, unless legislation is passed to change this.<\/p>\n

Cesspools are a Neanderthal-era method of waste disposal, little more than a hole in the ground where human and toxic wastes are dumped and left to seep untreated into surrounding soil and groundwater. Like cave dwellers digging a trench outside their shelter, cesspools rely on gravity and the porous earth to disperse sewage. There is no containment, no meaningful filtration, and no treatment of pathogens, nutrients, or synthetic chemicals. It is entirely incompatible with the protection of drinking water aquifers.<\/p>\n

For years, the U.S. Environmental Protection Agency warned the Army that its continued use of cesspools on Hawai\u02bbi Island posed an unacceptable threat to groundwater and violated basic public-health protections, yet the Army resisted, delayed, and minimized the problem. EPA orders to inventory, permit, and ultimately close these primitive waste disposal systems were met with foot-dragging and procedural deflection, even as untreated sewage continued to percolate directly into some of the most permeable volcanic geology on Earth. The Army\u2019s belligerence\u2014treating cesspool closure as an administrative inconvenience rather than an urgent environmental hazard\u2014left regulators repeatedly sounding the alarm while contamination risks persisted beneath State lands and downstream communities.<\/p>\n

Cesspools provide a way for PFAS and other toxins to hitchhike a subterranean ride to contaminate wells, streams and coastal areas. For Native Hawaiians, these water reserves are sacred resources. This spiritual connection is driving the Army off of the Big Island.<\/p>\n

The history of cesspools at P\u014dhakuloa\u2014and the Army\u2019s belligerent resistance to shutting them down\u2014reveals more than regulatory noncompliance; it exposes an institutional psychology. For decades, the Big Island\u2019s training grounds functioned as the Army\u2019s personal proving ground, a vast colonial landscape where it could detonate weapons, dump waste, poison people, and externalize risk without adult supervision. This is how the Army has operated everywhere. Fort Ord, California; Aberdeen Proving Ground, Maryland; Anniston Army Depot, Alabama. The names change, but the pattern is consistent: catastrophic contamination, delayed accountability, and regulators trained to defer rather than confront. For generations, states and the EPA largely served as rubber stamps while the Army exercised free reign over land it did not own and communities it did not answer to. The cesspools were an exception to the rule.<\/p>\n

There is no record indicating a prior U.S. state government has formally rejected a federal military environmental impact statement in the way Hawai\u02bbi\u2019s Board of Land and Natural Resources (BLNR) has done in 2025, making this an extraordinary, unprecedented, action.<\/p>\n

What is happening in Hawai\u02bbi is deeply threatening to the Army\u2019s worldview. For the first time, a state has drawn a line and refused to ratify the fiction that military necessity excuses permanent environmental ruin. Sources close to the command say the Army is not particularly worried\u2014not because it is confident in its pseudo-science, but because it assumes ultimate power will prevail. If pushed, they believe the federal government will simply seize the land through condemnation. That\u2019s their ultimate trump card.<\/p>\n

The Army is blowing toxic smoke.\u00a0 It must be stressed that across Volumes I, II, and III of the Army\u2019s FEIS, there are no tables listing groundwater contaminant concentrations (e.g., PFAS, explosives, perchlorate, VOCs, metals) beneath the state-owned PTA lands.\u00a0 There are no sampling results expressed in units, like \u00b5g\/L, ppb, ng\/L, ppt. There is no identification of the location of specific wells, borings, or monitoring points with analytical data.<\/p>\n

Without current baseline data, the BLNR concluded that the Army could not adequately assess the magnitude of environmental impacts, nor could decision-makers meaningfully compare alternatives. The reliance on future studies deprived the Board and the public of critical information needed to understand the environmental consequences of continued military occupation of public trust lands.\u00a0\u00a0 BLNR p. 10<\/a><\/p>\n

The BLNR\u2019s 5\u20132 vote to reject the Army\u2019s Final Environmental Impact Statement for P\u014dhakuloa Training Area reflects a determination that the document failed to meet the disclosure and analytical requirements of Hawai\u02bbi law.<\/p>\n

To conclude, the FEIS did not fully evaluate impacts in the federally owned impact area, relied on incomplete and outdated data, failed to disclose the full range of environmental implications and responsible scientific opinion, inadequately addressed impacts to biological resources, and omitted critical analysis of cleanup obligations. Until these deficiencies are remedied through comprehensive, transparent, and scientifically robust analysis, BLNR concluded that acceptance of the FEIS\u2014and renewal of the Army\u2019s lease of state public trust lands would be legally and environmentally unsound.<\/p>\n

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This project is supported by financial assistance from the Sierra Club of Hawaii.<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Go to Original – militarypoisons.org<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

12 Jan 2026\u00a0– An analysis of the Hawaii State\u2019s rejection of the US Army\u2019s Final Environmental Impact Statement, focusing on issues related to toxic contamination.<\/p>\n","protected":false},"author":4,"featured_media":312225,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[57],"tags":[3143,2642,1817,2914,2009,1258,1309,86,897,1150,112,1914,1436,95,70],"class_list":["post-312214","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-militarism","tag-anti-hegemony","tag-anti-imperialism","tag-anti-militarism","tag-anti-nato","tag-anti-war","tag-chemical-waste","tag-hawaii","tag-occupation","tag-pacific-islands","tag-pacific-ocean","tag-pentagon","tag-polynesian-culture","tag-radioactive-waste","tag-us-military","tag-usa"],"_links":{"self":[{"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/posts\/312214","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/users\/4"}],"replies":[{"embeddable":true,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/comments?post=312214"}],"version-history":[{"count":5,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/posts\/312214\/revisions"}],"predecessor-version":[{"id":312227,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/posts\/312214\/revisions\/312227"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/media\/312225"}],"wp:attachment":[{"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/media?parent=312214"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/categories?post=312214"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.transcend.org\/tms\/wp-json\/wp\/v2\/tags?post=312214"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}