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Singer: Geothermal exploration needs environmental review

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Sydney Ross Singer | Medical Anthropologist, Biologist, Author

In an attempt to encourage geothermal energy production, the DLNR is proposing a change to its Environmental Assessment (EA) exemption list to allow geothermal exploration wells to be drilled anywhere without any public comment or Environmental Assessment.

Once a good site for geothermal energy production is found, the EA process would then apparently kick in. Of course, after money and time are invested in finding a potential geothermal resource site, there will probably be enough steam to roll over any public opposition.

Getting geothermal energy from a live volcano may entail awesome technology and be a great way to wean ourselves from fossil fuels. But the public has been burned by geothermal energy in the past. With the proposed exemptions to allow exploration well drilling without an environmental assessment, the public is again being marginalized and will be put into the position of trying to stop a project that has already begun.

The Environmental Council is reviewing the proposed DLNR exemptions for geothermal well drilling. If the Council finds the exemption is inappropriate, it can fail to “concur” with the proposal and send it back to the DLNR.

For those who care about their right to comment on geothermal exploration and wish to encourage the Environmental Council not to concur, there is a 30 day comment period that ends April 6, 2012.

To read the proposed exemption list, visit: oeqc.doh.hawaii.gov/Shared%20D…

Send comments to the Environmental Council, 235 S. Beretania St., #702, Honolulu, Hawaii 96813, or email to environmental.council@doh.hawa….

Bottom line: we need new energy resources. But the public also need to stay part of the environmental review process of geothermal energy exploration, or our rights will go up in smoke.

Singer’s comment for proposed DLNR exemptions update:

I would like to comment on the proposed exemption list update proposed by the DLNR to provide “ground truth and to determine the economic viability of a geothermal resource.”

I applaud the efforts of the DLNR to seek alternative sources of energy, and geothermal energy is a reasonable source of energy for our volcanically active island. However, while these efforts are commendable, the proposed EA exemptions have several problems and the Environmental Council should not concur with these exemptions.

Exemption Class #5

Conduct geothermal exploration activity that includes non-invasive geophysical operations for testing and analysis. Activities conducted under this exemption shall comply with all applicable codes, rules, regulations, guidelines or standards.

Comment:

What else might be included under this exemption for geothermal exploration activity in addition to non-invasive geophysical operations? The scope of whatever else might be included is not described. According to the wording, it could also include invasive operations.

Additionally, if there are codes, rules, regulations, guidelines or standards that would apply to such activities, these should be specifically stated. Which federal and/or state and/or county codes, rules, regulations, guidelines or standards would potentially apply? It is not clear which codes, rules, etc., exist to control these geothermal exploration activities.

Keep in mind that any activity that has codes, rules, regulations, guidelines or standards has the potential for adverse impacts, or such codes, rules, regulations, etc., would not be necessary. This further suggests that an exemption would not be appropriate for such activities, since potentially adverse impacts are possible.

Exemption Class #5

Conduct geothermal exploration activity that includes exploration wells for the extraction and removal of minerals of such types and quantity that is reasonable required for testing and analysis. Activities conducted under this exemption shall comply with all applicable codes, rules, regulations, guidelines or standards. Geothermal exploration wells constructed under this exemption would not be developed to serve geothermal resources unless an EA or EIS is completed in accordance with HRS Chapter 343.

Comment:

The existence of a geothermal well near residential areas may have significant impacts, and geothermal resource development in lower Puna has already created a history of public anxiety, disturbance, litigation, and suspected health and environmental impacts. The process of drilling exploration wells also entails some hazards, especially since this is an active volcano and unintended consequences may result. Residents and homeowners living near or down wind from these exploration wells may be negatively impacted by this exploration process. Clearly, the location of these wells is significant and should requires an EA or EIS prior to exploration well construction.

Why go through the expense of exploration when the public might object to the location during the EA process? It seems wiser to get public comment in an EA process prior to bringing exploratory wells into potentially contentious areas. If the public deeply and reasonable objects to a potential site for a geothermal well, it makes no sense to explore in that area.

In addition, the EA process is to be performed at the earliest possible time in a process to comply with HRS Chapter 343. This would be prior to drilling exploratory wells in areas that have not yet been reviewed for public, cultural, and environmental impacts.

Exemption Class #10

1. Issuance of mining or surface leases on State or reserved lands pursuant to HRS Chapter 182-4, 182-5, or 171-13, for purposes of conducting geothermal exploration activities. Activities conducted under this exemption shall comply with all applicable codes, rules, regulations, guidelines or standards. Geothermal activities in mining lease areas issued under this exemption shall not proceed beyond the exploration phase unless an EA or EIS is completed in accordance with HRS Chapter 343.

Comment:

This exemption has the same problems as those discussed above. Impacts from geothermal exploration could extend far beyond State or reserved land boundaries. And the use of public lands for geothermal exploration should require public comment, since mining and geothermal resource development may entail potentially significant impacts on the environment and the public use of public lands.

Summary:

While geothermal energy is a potentially beneficial alternative to fossil fuel dependence, it has potentially significant impacts on residents and homeowners living near or around such facilities. The public needs to be able to participate in the site selection of such facilities, and this requires an EA prior to exploration.

In other words, it doesn’t only matter whether a site is viable for geothermal energy production when conducting exploration activities. It also matters what impact such a site will have on the public, environment, and culture. All these must be explored prior to site exploration for geothermal activity. A geothermal facility should not be explored in an area that will be a source of contention, litigation, and public disapproval.

I suggest that the DLNR first perform an EA and/or EIS on the general plan of exploring geothermal resources at general locations in order to clear the way for private interests to develop exploration wells and conduct geophysical research around those areas. Supplemental EA’s can later address the details of geothermal resource development at specific sites.

Conclusion:

The EA process is necessary to ensure public involvement in activities that have potentially significant impacts. Exemptions from this process are only appropriate and in compliance with HRS Chapter 343 when they clearly have no or only minimal significant impacts.

Drilling into a live volcano to generate geothermal energy has already been shown to have potentially negative impacts. Exploration of where a well might be located requires more than geophysical considerations. What also needs exploration are the cultural, environmental, health, property rights, esthetic, and other potential impacts that should be done through the EA process.

I therefore urge the Environmental Council to NOT concur with these proposed exemptions. We can develop alternate and sustainable energy resources while at the same time respecting the law and the public’s right to comment on such potentially significant activities.

Thank you for your consideration of the above comments.

Sincerely,
Sydney Ross Singer

(Sydney Ross Singer is a medical anthropologist and director of the Institute for the Study of Culturogenic Disease.)

2 Responses to “Singer: Geothermal exploration needs environmental review”

  1. John Floyd says:

    You state, “The EA process is necessary to ensure public involvement in activities that have potentially SIGNIFICANT impacts.” That is the main reason for exempting the exploration process from EA’s and EIS’s which are cost and time prohibitive. Numerous tests may be required before locating a potential source. The mere testing for potential thermal activity has minimal impact. Once it’s determined that there is potential, by all means require an EA or EIS before proceeding further.

  2. Drilling Equipment Man says:

    I think that’s a fair, I think just about everybody is protective of their home. You certainly don’t want something to put that at risk. Though with all these kinds of things, you do need to consider viable alternatives too.

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