Cave Conservationist

The Newsletter of Cave Conservation and Management

Volume 15 No. 2 August 1, 1996


Published by the NSS Section on Cave Conservation and Management


BLM/YATES ENERGY SETTLEMENT | ISHA (International Subterranean Heritage Association) | PUNA Road Status | NEVERSINK MANAGEMENT PLAN

The Cave Conservationist is the official publication of the Conservation and Management Section of the National Speleological Society. Distribution is free to members of the Section. Section membership costs $5 annually and should be mailed to the Secretary. (A membership form for your convenience is included on page 19.) Additional complimentary copies are distributed on a temporary basis at the discretion of the Section to NSS members, internal organizations, cave owners, and others involved in cave conservation projects. Opinions expressed are not necessarily those of the either the Section or the NSS and should be attributed to the author or, in the case of uncredited articles, to the Editor.

POSTMASTER: Send address changes to Evelyn Bradshaw, 10826 Leavells Road, Fredericksburg, VA 22407-1261.

SUBMISSIONS: Articles and other Cave Conservationist correspondence should be sent to the Editor. Submissions on computer disks should be made with 3.5" IBM compatible diskettes, or via the Internet. Microsoft Word, Word Perfect 6.0-3, or straight ASCII format is preferred. Do not format materials for multiple columns! Diskettes will not be returned unless requested. Arrangements may be made for transmission via modem; call or write the publisher for details. Or send an E-Mail message, or your article, to the Publisher via the Internet to rstitt@halcyon.com. Note: if you send diskettes or articles to the Publisher, be sure to notify the Editor that you have done so, and send him a hard copy.

Copyright 1997 NSS Conservation and Management Section, except as noted. Internal organizations of the National Speleological Society may reprint any item first appearing in the Cave Conservationist so long as proper credit is given and a copy of the newsletter containing the material is mailed to the Editor. Other organizations should contact the Editor.

Printed by members of the D.C. Grotto and the Potomac Speleological Society.

Cover illustration is the Puna Cave Area in Hawaii, submitted by Bill Halliday.

Visit our World Wide Web site on the Internet at http://www.halcyon.com/samara/nssccms/.

NATIONAL SPELEOLOGICAL SOCIETY
Conservation & Management Section Officers - 1996-97

President and Publisher: Rob Stitt
1417 9th Ave. West
Seattle
, WA 98119

(206)
283-2283 rstitt@wingedseed.com

Editor and Vice-President: Jay R. Jorden,
11201 Country Road 132
Celina, TX 75009-2527
(214)382-2458
jjorden@mcimail.com

Secretary-Treasurer: Evelyn Bradshaw,
10826 Leavells Road
Fredericksburg, VA 22407-1261

(703)898-9288
ebradshw@interserf.net

Directors at Large: John Hoffelt
208 Cheatham Dr.
Smyrna, TN 37167-4766
(615)459-6594 HOFFELJ@aol.com
George N. Huppert
1830 Green Bay St.
La Crosse, WI 54601
(608)787-0499
Huppert@mail.uwlax.edu


Table of Contents


Table of Contents 2

Notes from the President 2

BLM/YATES ENERGY SETTLEMENT 3

ISHA International Subterranean Heritage Association Comments on IUS Guidelines 3

PUNA Road Status as of the end of 1995. 8

NEVERSINK MANAGEMENT PLAN 19

Membership Form 19


Notes from the President


Well, it's been a busy year. Even though this issue is dated August 1, you aren't getting it until December or later. Most of the stuff in this issue is about stuff that took place before August 1, and has some historical or educational value.

I've cut out a lot of stuff to make this issue a reasonable size, particularly about the Puna situation. As of today (November 22) everything there should be under control (at least Bill Halliday hasn't sent me any new stuff.)

There will be two more issues coming out with more 1996 stuff in it, possibly even along with this issue. I've just changed jobs, cutting my commuting time in half, so I should have a bit more time to keep this stuff coming out.

In the meantime, check out the Section World Wide Web page at www.wingedseed.com/samara/nssccms/

From the Cavers Digest via John Lyles

Date: Mon, 4 Mar 1996 13:16:37 -0700


BLM/YATES ENERGY SETTLEMENT


This message is from David Jagnow, NSS Conservation Chairman. It announces the US Department of Interior, Bureau of Land Management settlement with Yates Energy of New Mexico, concerning their drilling claims near Lechuguilla Cave.

Cavers:

I just received the following news brief from the BLM via mail. There was no date on this release. It obviously puts their best possible spin on the BLM/Yates Energy settlement. The main problem with this settlement is that they have waived the enhanced drilling stipulations that the Dark Canyon EIS spent so much time and effort to develop. I will comment further when I get additional information:


BLM NEWS ROSWELL DISTRICT, 1717 W. 2nd, ROSWELL, NM 88221 CONTACT: Howard Parman, 505-627-0212

BLM Settlement Enforces Cave Protection Zone

The Bureau of Land Management (BLM) announced today that it has reached an out-of-court settlement with Yates Energy Corporation (Yates) concerning drilling in Dark Canyon near Lechuguilla Cave. In September and November of 1994, Yates filed two lawsuits against BLM claiming that the Record of Decisions for the Dark Canyon Environmental Impact Statement (EIS) and four additional applications for permit to drill (APD) constitute a "takings" of beneficial use of Leases NM-62161 and NM-81894. Since these decisions were issued (January 31, 1994 and May 20, 1994), lease NM-81894 has expired.

According to the settlement agreement, the federal government will pay $2.2 million to Yates Energy Corporation, establish a no-surface occupancy restriction for two-thirds of lease NM-62161 (the area within the Cave Protection Zone), and allow drilling from the two locations identified in the Dark Canyon EIS as 1G and 2G. Any well drilled from these locations, must be below the cave-bearing Guadalupe Reef Complex (approximately 3,000 feet deep) before directional drilling will be allowed. A "closed mud" system will be required in addition to some other requirements to protect visual resources. One of the conditions of approval specifies that a BLM inspector be on-site throughout the drilling process.

The settlement resolves controversy of drilling for oil and gas in Dark Canyon while protecting caves on both BLM managed lands and the adjacent Carlsbad Caverns National Park. Lechuguilla Cave, a spectacular cave located within the national park boundaries, is located nearby.

Since the drilling locations are outside the Cave Protection Zone, BLM will apply standard conditions of approval for drilling, casing, on-site monitoring and plugging and abandonment. [Publishers Note: See the next issue for an update on this before taking any rash action. When this is going to press in December, the issue is moot, since the well has been drilled and abandoned.]


ISHA International Subterranean Heritage Association
Comments on IUS Guidelines


Publisher's Note: The following material was prepared by ISHA as comments on the proposed IUS Guidelines that were published in issue 14-4 of the Cave Conservationists.

International Non Governmental Organization

COMMENTS ON THE

Draft Document for

Guidelines for Cave and Karst Protection

proposed by the

Commission on National Parks and Protected Areas

of the

IUCN

The World Conservation Union

PRELIMINARY REPORT

December 31, 1995

Synthesized and edited by

Philippe AXELL

President, ISHA


Contributions to this report have been made by organizations and individuals who are not members of ISHA as well as ISHA members. Therefore the views expressed in this report do not necessarily reflect those of ISHA.


Contributions to this report have been made by:

BELGIUM

G. DEBLOCK, President, SOBERES.

R. DELFOSSE, Former president of the Protection and Access Commission - Belgian Speleological Union.

J. HAECK, President, Soci Royale Belge d'Etudes Gogiques et Archogiques.

L. HAESEN, Vice-President, Belgian Speleological Union.

D. MATTART, Soci Royale Belge d'Etudes Gogiques et Archogiques.

FEDERATION OF RUSSIA

V. MALTSEV, Cave and Karst Protection in former USSR, currently in Federation of Russia.

FRANCE

M. BAKALOWICZ, CNRS Laboratoire Souterrain de Moulis, COST 65

C. JUBERTHIE, CNRS Laboratoire Souterrain de Moulis.

A. MANGIN, CNRS Laboratoire Souterrain de Moulis.

M.P. VEUILLEZ, President - CPEPESC.

GERMANY

M. LAUMANNS, President, Federation of the German Cave and Karst Researchers.

NETHERLANDS

H. DE SWART, President, Speleo Nederland.

J. ORBONS, President, IUS - Artificial Cavities Commission.

Additional data and quotes have been extracted from documents or publications provided by:

COMMISSION OF THE EUROPEAN UNION

DG XII - COST 65

? Karst groundwater protection - Final report ?, 1995

? Karst groundwater protection - Guidelines ?, 1995

COUNCIL OF EUROPE

? European Convention on the Protection of the Archeological Heritage ?, 1992

? Convention on the Conservation of European Wildlife and Natural Habitats ?, 1987

? Recommandations N? 36 (1992) sur la Conservation des Habitats Souterrains ?, 1992

? Les Habitats Souterrains et leur Protection ? by Christian Juberthie, 1992

CPEPESC

Commission Permanente d'Etude et de Protection des Eaux, du Sous-sol et des Cavernes,

France.

? La Protection des Anciennes Mines - Contribution ࠬa Protection du Patrimoine Gogique ? by Denis Morin, 1995

MINISTRY OF THE ENVIRONMENT

DIREN Toulouse

France.

? Rapport sur la Protection des Grottes et des Mines ? by Patrick Cabrol, 1989

ISHA - The International Subterranean Heritage Association

ISHA is an international non-governmental organization (NGO) founded in 1994. Based in Belgium, it was designed to bring together other concerned NGO's, associations, federations, societies and individual members throughout the world. ISHA is an international organization charged with the study, conservation and sustainable development of the world's Subterranean Heritage.

OBJECTIVES

  • To contribute to the emergence of a greater understanding of our Subterranean Heritage as well as a greater appreciation by the general public of its value, significance, riches and fragility; in particular, through education as well as through media attention and other communications efforts.
  • To complete a "status report" of our global Subterranean Heritage, with the aim of creating a basis for determining the requirements of a sensible and sustainable policy for the conservation and harmonious development of this patrimony.
  • To contribute to the establishment and/or the harmonization of recommendations, directives, treaties, conventions, and laws - on the international, national, and regional levels - that are aimed at conserving the integrity of our global Subterranean Heritage and regulating its visitation, development and exploitation through responsible, consistent and sustainable management.

OBJECT OF THIS PRELIMINARY REPORT

The Working Group on Cave and Karst Protection of the IUCN Commission on National Parks and Protected Areas (CNPPA) has released in October 1995 a draft document called "Guidelines for Caves and Karst Protection ".

This document has been released for comments by all organizations or individuals concerned. The deadline for major comments is December 31, 1995.

It is the first time that IUCN publishes a Subterranean Heritage oriented document and this is good news for the conservation of the Subterranean Heritage. The guidelines could create the basis for a global conservation policy for the Subterranean Heritage all over the world.

At ISHA, we think this is a major step in the development of our objectives and welcome this excellent work made by the working group during the past four years. The importance and the potential impact of the final text of these guidelines implies that it should be based on the broadest consensus amongst all parties concerned by the Subterranean Heritage.

This is why ISHA is addressing this preliminary report to the Working Group on Cave and Karst Protection summarizing comments and suggestions not only from its members but also from other concerned organizations around the world.

Due to the very short deadline, it has not been possible to collect the comments from all organizations and individuals contacted by ISHA before December 31, 1995. Therefore a second and final report will be addressed to CNPPA/IUCN in February 1996.

This first preliminary report is summarized from documents and comments received by ISHA prior to December 28, 1995. It only reflects the various remarks received and not the point of view of ISHA.

Comments on the CNPPA Working Group for Cave and Karst Protection.

  • The draft document was prepared by a working group of 23 people, few of which are specialists in karstology. There are only 3 Europeans (2 British and one Slovene) and two North-Americans amongst the working group while these two continents or sub-continents represent the largest speleological community in the world (both in terms of scientific researchers and sport cavers).
  • Amongst the working group, it appears that representatives of countries such as Australia, Venezuela, New Zealand, Jamaica, Madagascar, Mauritius, Philippines, etc... are over represented compared to the rest of the world.
  • Conservation problems related to human visiting of caves, or surface land management are very different in Europe and North America than they are in the above mentioned countries. The density of visitors to caves (tourists and cavers) is much higher in Europe and North-America than any other place (i.e.: 6 million visitors in French show caves per annum, 30 federated cavers per cave in Belgium, etc...). Population density over karstic areas is also much higher in Europe than in any other part of the world.
  • Karst groundwater supply protection in densely populated Europe is a major issue that is not solved by the proposed guidelines as they are not applicable to densely populated areas. (see table 1)
  • It is felt that the CNPPA should have contacted the numerous scientific institutions and organizations concerned with cave and karst conservation - other than CNPPA members - in order to obtain the latest scientific information and data on the subject, prior to the writing of the draft guidelines. This can be done via the IUS - International Union of Speleology.
  • It is felt that the CNPPA working group should have consulted the existing documents on the topic (i.e.: the European Union - COST 65 Guidelines on Karst Groundwater protection, the Malta Convention on the protection of Archeological Sites or the Convention on the Conservation of European Subterranean Wildlife Habitats, etc...) to avoid conflicting guidelines to be published.

Table 1 (source: COST 65 - Final report)

COUNTRY

PERCENT of karst water in total water supply

Austria

50

Belgium

31 (46 of groundwater)

Croatia

36

Estonia

16

France

25

Germany

6,3

Hungary

2,8

Ireland

5

Italy

23 of groundwater

Poland

4

Portugal

10

Romania

2

Slovakia

27

Slovenia

50

Spain

12,5

Switzerland

15

Turkey

1,5

United Kingdom

20

General comments on the guidelines.

  • The publication by IUCN/CNPPA of the Guidelines for Cave and Karst Protection is welcomed by all the people and organizations who have contributed to this report. It is considered as a major step forward in the efforts for a better understanding and the conservation of the subterranean heritage.
  • The fact that surface land management is included as part of the protection scheme is considered as a very positive approach to subterranean heritage and resources management and conservation.
  • In general, it is not the content of the guidelines (with one or two exceptions) that is discussed but the main structure. The draft text does not include a hierarchical structure allowing to establish priorities and/or clearly identify actors, problems and remedies.
    • The field of application of the guidelines is not clear. Are ? caves ? to be considered only as karstic caves or does it apply to any natural or artificial cavity?
    • The guidelines are too vague, too general. Some guidelines are applicable to other environments.
    • There is no distinction between patrimonial values (archeology, mineralogy, biodiversity, etc...) and resources values (water supply, etc...).
    • The patrimonial values are under-considered as compared to resources values.
  • The threats to caves and karst (chapt. III) are not clearly identified. The origin of these threats is not identified.
  • Some guidelines are too dogmatic (i.e.: 12, 29, etc...) and may result in wrong interpretation.
  • The ? actors ? in caves and karst management are not identified although referred to in many of the guidelines.

Comments on Artificial Cavities.

  • The "artificial" subterranean heritage is not considered in the document (man-made galleries, mines, underground quarries, etc. often representing subterranean habitats for bats or other lifeforms or scientific interest for geologists, paleontologists, archeologists, etc.). The cultural value of troglodyte dwellings, subterranean towns but also of very ancient mines and quarries cannot be separated from a global conservation policy of the Subterranean Heritage. This artificial subterranean heritage is often linked closely to underground waters (phreatic layers, underground reservoirs or streams, etc.) used for drinking water supply near highly populated areas.
  • Generally speaking, old mines are more often threatened than natural caves. They are also usually located in more densely populated areas, therefore preventing any protected area system to be installed. A special attention should be given to the protection of this particular type of cavities.
  • Artificial cavities can be found not just in Karst areas, but also far outside them.
  • Mineral neoformations (young speleothems), sometimes exceptional, are often found in artificial cavities.
  • Artificial cavities conservation can often be related to archeological sites protection laws and conventions. It should therefore be recommended that such legal texts be used for the conservation of artificial cavities where applicable.

Comments on subterranean biology.

  • The scientific interest of the biological aspect of caves protection is not really indicated in the draft text.
  • Subterranean biology and biodiversity is not sufficiently mentioned in the draft guidelines. The text does not consider the guidelines published by the Council of Europe in the Convention on the Conservation of European Subterranean Wildlife Habitats (1992).
  • It is not clear if the CNPPA guidelines cover all subterranean wildlife habitats - including non karstic and artificial cavities -, or exclusively karstic cavities.
  • It is not possible to dissociate karstic and non-karstic subterranean habitats in a protection guidelines text.

Comments on non-karstic cavities.

  • Non-karstic natural cavities (lava tubes, ice caves, seashore caves, etc.), although mentioned in the document's comments, are not accounted for in the guidelines.
  • This patrimony also represents essential natural values, both for scenic and scientific interest (see above comments on subterranean habitats). Guidelines for the conservation of non-karstic cavities should be added to the IUCN guidelines or included in further guidelines.

Comments on cave and karst management.

  • In section V, Management at the regional and site level, there is no guideline on WHO should manage protected karstic areas. This could be interpreted as if only official authorities or owners are qualified for the management of the subterranean heritage. This could also be interpreted as if all human (caving and research) activities should be avoided.
  • Due to the complex structure of karst areas and aware of the fact that most of the subterranean interchanges of liquid and gaseous substances and most of the speleological phenomena are still not well known to man, a serious, responsible and continuous research in karst areas both in scientific and in physical survey work should be encouraged.
  • The absence of representatives of national, regional or local speleological and scientific organizations in the management of karstic or subterranean sites would be most damaging to the effort made by the speleological and the scientific community to the discovery, the better understanding and the conservation of our subterranean heritage.
  • Management at national or regional level should not be attributed to a single organization or authority, but rather include representatives of all parties concerned, such as speleological organizations, scientific institutions, show caves associations and concerned environmental authorities and/or organizations.

International structures.

  • The creation of a data base listing cave and karst areas included within protected areas and also identifying unprotected areas which deserve recognition is very favorably received by all parties concerned. However, it is felt that such data base should include the entire subterranean heritage (karstic and non-karstic, natural and cultural).

NOTE: One of the 3 main objectives of ISHA is the establishment of a global status report of the world's subterranean heritage in such a data base. This project is currently under development and a partnership will be proposed in the near future to IUCN, IUS, WCMC and UNESCO.

  • Research and monitoring centers for the natural subterranean heritage should be created on a sub-continental level in all major karstic areas of the world to collect and pre-process data in their area. Such centers should be located preferably within existing scientific structures already engaged in the study of the subterranean environment. (i.e.: Subterranean Laboratory of Moulis - France, E. Racovitza Institute in Romania, Karst Research Institute in Postojna - Slovenia, etc...).
  • The research and monitoring centers would be responsible not only for providing data to the data base, but also to conduct research tasks as well as expertise in their local areas for the conservation and management of karstic areas.
  • The conservation of the subterranean cultural heritage may require different policies from the natural heritage (i.e.: the preservation of the karstification process may not be advisable for the conservation of prehistoric cave paintings). A specific research and monitoring center should be established for the conservation and study of prehistoric caves environment due to the special aspect of this world heritage.

Public access to caves.

  • A complete environmental impact study should be performed prior to any kind of cave fitting for tourism or any extension of existing show cave. This study should include the eventual protection of certain sectors at site level. Continuous monitoring of the cave environment during the exploitation should be performed.
  • This kind of impact study could be conducted or supervised by the local research and monitoring center mentioned above.
  • A social and economical study should also be conducted prior to the opening of any new show cave to avoid a non sustainable development of karstic areas in the tourism sector.

Public awareness.

  • The acceptance and observance of regulations is generally much easier when the public understands the reasons for the various measures. Educational campaigns explaining the value of the subterranean heritage may greatly enhance public awareness.
  • Educational training for show caves personnel, educators, nature tour operators, etc... may be achieved by special courses, workshops and joint field trips.
  • Campaigns organized at an international and national level may be complemented with activities at the local council or community level. Distribution of educational videos, leaflets and posters will also contribute towards creating an awareness in the long term. This could perhaps be achieved through an international agreement to a year dedicated to the conservation of the subterranean heritage and resources, especially for those countries or regions where the understanding of patrimonial and environmental issues by the general public is poor.

Conclusion.

The current deadline is not sufficient to contact all organizations or specialists concerned by the conservation of the subterranean heritage in order to make significant changes to the draft guidelines.

The importance of the subterranean heritage and resources extends beyond the notion of protected areas as it implies economical, social, cultural and environmental values that have not yet raised international attention.

It would therefore be advisable that the publication of international guidelines by a body such as IUCN be as complete as possible, and not limited to certain aspects of karstic areas only, in order to provide international, regional and national authorities with a single clear text applicable to all aspects of the subterranean heritage and resources.

The notion of sustainable management and conservation of the subterranean heritage and resources is closely linked to other major issues such as scientific research, biodiversity, cultural heritage or water supply. It also implies cultural, educational, social and economical human activities.

It has been widely suggested that the CNPPA/IUCN considers delaying the publication of the guidelines until a broader consultation with other parties concerned is achieved by the extension of the working group to non CNPPA members. This extension of the working group could be organized by the different Commissions of the International Union of Speleology (IUS) and by the International Subterranean Heritage Association (ISHA) in cooperation with the CNPPA.

The results of the additional work performed by this extended working group could be presented for comments at the International Congress of Speleology to be held in Switzerland in 1997.

Should the above suggestion be impossible, the following comments have been suggested:

  • Consider the above comments, as well as other comments received, for changes in the next draft guidelines.
  • Add to the guidelines that they do not apply to artificial cavities and non-karstic cavities.
  • Add to the guidelines that they do not apply to subterranean wildlife and habitats.
  • Add to the guidelines that they do not apply to caves of cultural and archeological value.

It has also been suggested that IUCN considers the publication of separated guidelines on the 3 following topics:

  • artificial cavities and non-karstic cavities,
  • subterranean wildlife and habitats,
  • cultural and archeological subterranean heritage (in conjunction with UNESCO).

PUNA Road Status as of the end of 1995.


December 31, 1995

Hawaii Speleological Survey

of the
National Speleological Society

WILLIAM R. HALLIDAY

P.0. 90x 1525

Chairman

Hilo. HI 96721

March 3, 1996

Hon. Stephen Yamashiro

Office of the Mayor

25 Aupuni Street

Hilo, HI 96720

Re: Draft Environmental Assessment Puna Emergency Access Road

Dear Mayor Yamashiro:

This letter is written after review of the Draft Environmental Assessment for the Puna Emergency Access Road, and supersedes previous correspondence about this proposed road.

As Chairman of the Hawaii Speleological Survey of the National Speleological Society, I commend you, your County staff, and your consultant Dr. Ron Terry, for formulating and including plans to protect significant caves crossed by this road.

In my opinion, the details specified in this Draft Environmental Assessment provide adequate protection for these caves. From the speleological standpoint, no Environmental Impact Statement is needed for it. I am confident that other leading vulcanospeleologists will join me in this conclusion. The Hawaii Speleological Survey thus anticipates and concurs in your preparation of a Negative Declaration/Final Environmental Assessment containing these details.

In this Draft Environmental Assessment I noticed several errors or misunderstandings about peripheral matters which should be corrected in the final document. These are specified in the attached appendix. Primarily these concern differentiation between lava tubes and lava tube caves, with misunderstandings about the number and size of caves in Puna and the large number of them which are not burial caves, and about legal protection for lava tube caves in Hawaii. If the Hawaii Speleological Survey can provide further information or be of service in some other way, please do not hesitate to call on us. The H.S.S. is a nonprofit public service organization and makes no charge for any service other than excessive photocopying.

Again our commendation and thanks for developing this acceptable method of protecting these world?class caves without impeding the road project.

Sincerely yours,

William R. Halliday, Chairman

cc: HSS ExCom and recipients of previous correspondence


APPENDIX

1) Differentiation of caves from lava tubes.

The Draft EA (and also Mr. Norman Olesen's letter to the President of the National Speleological Society dated 26 December 1995, in the Appendix of the Draft EA) suffers from repeated confusion between lava tubes and lava tube caves. Several sections need to be rewritten, and correct terms need to be substituted in several places.

In the last paragraph on page 15, it is notably incorrect to assert "...in all probability dozens of other caves, mostly modest in dimension, underlie the area, as they do virtually all pahoehoe covered areas of the Big Island." On the basis of unpublished field data of the H.S.S. and present geological knowledge of the area from other sources, it will be surprising if more than three or four other significant caves underlie this Draft EA area.

Caves are defined as natural underground spaces, large enough for human entry, and with some portion in essentially total darkness. Some open, roofed lava tubes are caves, others are too small or too short. As indicated below, in Hawaii this differentiation is especially important.

On page 12, paragraph 1, the first two sentences are basically correct although the second sentence specifies only one of several mechanisms for the formation of lava tubes. The third sentence is incorrect, conflicting with the second sentence. It could be corrected by substituting:

...an open segment of a roofed lava tube is often left?

The fourth sentence of this paragraph is especially erroneous. Almost no open, roofed lava tubes less than 12 inches in diameter qualify as caves. In fact, very few open, roofed lava tubes less than 3 or 4 feet in diameter qualify as caves in this area.

The remainder of this paragraph is accurate but the last sentence is irrelevant and misleading. It is quite true that there are "many thousands of lava tubes" in Hawaii County. However, most of these are too small or too short to be considered caves. On the basis of scientific exploration of about 100 caves and 50 miles of mapping in all of north Puna, we believe that the final count of significant caves in this-the world's greatest lava cave area-will be about 200, not "thousands." This is approximately the same as in Mammoth Cave National Park, Kentucky, which many experts consider the world's greatest limestone cave area.

To differentiate correctly between lava tubes and lava tube caves, the phrases tube(s) and lava tube(s) should be changed to lava tube cave(s) or cave(s) in the following locations:

page 12, line 3 (twice)

page 13, lines 1, 2, 4, 7, 7?8, 10, 16, 29 (twice), 30 and last

page 14, lines 5, 6, 13, 20, 21?22, 23. (Note: the term lava tube is correct in line 1. Many burials are understood to be in lava tubes which are not caves.)

page 15, lines 28, 29, 30, 33, 35

page 16, lines 5, 6, 10, 21, 24, 25, 31

page 17, lines 1, 5, 7, 17, 18, 20

page 20, lines 16, 25

page 21, line 10

page 31, lines 25, 27, 28, 30

page 32, line 3.

2) Legal protection for Hawaiian caves.

It is incorrect to say (page 17): "The caves do not enjoy legal protection of any sort within this area."

The Hawaii State Environmental Policy (Chapter 344, section 3, (1) provides that it shall be the policy of the state to conserve the natural resources, so that land, water, mineral, visual, air and other natural resources are protected by...preserving or augmenting natural resources,

of which caves are an example (page 13 of this Draft EA and the cited Community Management Associates, Inc., 1995). As such, caves and sections of caves are natural resources in their own right and some contain other natural resources.

Caves subject to the Environmental Assessment process are protected under Title 11 Ch. 200 Subch. 5, section 12(b) (1) and sometimes (2) and (7)?(11). This statement on page 17 needs to be corrected accordingly. It should be noted that a similar misstatement appears in the letter dated 26 December 1995 from Mr. Norman Olesen to Dr. Stephan Kempe in the Appendix of the Draft EA.

Especially considering the dreadful past record of devastation of caves and parts of caves throughout Hawaii County (such as Jaggars Cave in Hawaii Volcanoes National Park, Eldon English Cave in Puna, Roadcut Cave in Kau, once?celebrated Laniakea Cave in Kailua?Kona, and even parts of Kaumana Cave County Park in the suburbs of Hilo, it would be very inappropriate for the final document to imply in any way that Hawaii County has so many caves that the cited state policy should be ignored.

Further, the details of this Draft EA demonstrate that Hawaii County has moved admirably from being the major existing threat to major lava tube caves of Puna to protecting them as valuable resources. The final paragraph on page 17 should be rewritten in a less negative tone, reflecting this admirable advance, giving credit where credit is due, and urging private landowners to follow its example. If Hawaii County requirements for grading permits, sewage disposal and the like are really out of compliance with the cited state policy, as seems to be implied on page 17, these should be brought into compliance with all due deliberate speed.

In a similar vein, a section on Mitigation Measures for Geological Impacts should parallel the similar section for biological impacts. It should read:

Every effort will be made to avoid collapsing major lava tube caves. If a section of a lava tube cave with potential geologic value must be collapsed, a culvert allowing passage for geologists and other scientists will be emplaced.

This would be in conformity with the first indented subparagraph on page 15.

3) Misunderstandings about troglobites.

Hawaiian troglobites inhabit extensive subterranean interstitial spaces in addition to caves and smaller lava tubes, and the final document should reflect this.

Further, some caves beneath cultivated areas and even beneath bare pahoehoe lava contain significant ecosystems. Others do not. Generalizations in the final document should not be limited to caves beneath ohia forests (as is the case in this Draft EA).

On page 13, line 3 (Biology section) should be corrected to read approximately:

' ...make their home in open roofed tubes and interstitial spaces

In the next line, the word cave should be deleted in two places.

Also on page 13, the sentence regarding preservation of natural vegetation should read:

...vegetation above some cave ecosystems....

On page 16, line 31 should read:

...may also affect subterranean fauna..

 

On page 14, line 13, will should be changed to may, and many should be changed to some. (Note: many Hawaiian lava tube caves have few or no vulnerable geological features or biology.)

On page 16, regarding "Impacts to Biology", it should be mentioned that increasing the width and/or thickness of pavement tends to dehydrate underlying cave environments and thus may subdivide sparse populations of subterranean fauna.

In line 3, page 17, the word new should be added before the word entrance, and in the previous line, the word unusual should be substituted for potential. (Note: virtually every Puna lava tube cave has potential biological value, but most contain only common troglobites. Also the entrance to be collapsed according to the present wording is likely to be on private property, yards to miles distant.)

4) Impacts to Geological Resources Mitigation Measures.

On pages 15, 16, and 17 are several misunderstandings about occurrences of "archaeological, historical, or burial site findings" in caves in this area, about the need for mitigation measures for geological impacts, and about "the traditional Hawaiian attitude."

Roughly 83% of the near?100 Puna caves known to the Hawaii Speleological Survey records are NOT burial caves. Taken in 40?foot increments (the width of the proposed road in Hawaiian Acres Subdivision), approximately 99% of the lengths of known Puna caves have no burial sites, nor archaeological or historical findings. The likelihood of such "findings" in a previously unknown length of cave opened by road excavation here obviously is even less.

The state of Hawaii does NOT require investigation by DLNR of newly?opened lava tube caves if no such "findings" are present. The specifications of current state contracts are as follows:

Whenever the Contractor encounters possible archaeological, historical, or burial site findings, the Contractor shall immediately suspend the operation and inform the Engineer verbally and follow up with a written letter. The Engineer will contact the Department of Land and Natural Resources (DLNR) and other agencies to evaluate such findings and decide the course of action. The contractor shall not resume operations suspended without the prior written acceptance of the Engineer...The archaeologist will decide the limits of the site. Also the Archaeologist will decide, with the Engineer, the best means for protecting the site from further disturbances which requires further investigation of salvage as determined by the SHPO (State Historic Preservation Officer). Protection may include barricades, roping off, temporary fencing, or other means.

-Dept. of Transportation, 1996. Notice of Determination, Negative Declaration for the proposed Keaau?Pahoa Road, Keaau Town Section (Project No. 130B?01?92). p. 20?21.

As shown above in this Appendix, statistically it is extremely unlikely that such provisions would be applicable to the proposed road. Except as otherwise noted, the H.S.S. however sees only minor problems with the mitigation measures on pages 17 and 31; it is commendable for the County to consult with DLNR even when it is not required to do so. In fact, the H.S.S. is prepared to offer field assistance to DLNR, when desired, so that DLNR can make more extensive investigations than otherwise might be possible. Conversely, the presence of significant geological resources in such caves is more probable than not. The H.S.S. usually is prepared to inventory such resources and advise on them, no short notice. We suggest that such inventories and guidance be included as Mitigation Measures for Geological Impacts. This would obviate any question of destruction of uninventoried geological resources.

Unfortunately, the last sentence in "Impacts to Geological Resources" is unintelligible and apparently incorrect. It should be rewritten, reflecting the new data in this Appendix and Dr. Stephan Kempe's correction of the misapprehension that only "smaller caves" are likely to be encountered during excavation.

Regarding "traditional Hawaiian attitudes", the statement on line 2 of page 14 needs to be rewritten. Extensive documentation exists concerning the variations in traditional Hawaiian attitudes toward burials. These ranged from those cited in this Draft EA to especially deplorable theft of bones for the purpose of obtaining the mana which accompanied them, or, alternately, to deliberately desecrate the remains of one's enemies. Even today, the kupuna advising Hawaii Volcanoes National Park does not agree within itself on whether Park officials should administratively exclude haoles from burial caves in that Park. The final document should not imply County favoritism toward any faction of Native Hawaiians until and unless the County Council takes formal action or according to law.

5) General corrections and clarifications.

  1. addition of missing reference (cited on page 7: Trusdell and Moore, 1991) on page 35.
  2. correction of name of Lower U`ilani Cave throughout.
  3. For uniformity, references to the State Historic Preservation Division (SHPD) should he changed to DLNR.
  4. The sanctity of burial areas is not a "resource value" as asserted in paragraph 2 of page 17, and a proper term should he used.
    Also in the previous line, the word some should replace the word many, thus conforming with the indented paragraph at the top of page 14.
  5. Regarding use of the term "pseudo stalactite" on page 14, this term is not used in the mainstreams of volcanology nor speleology. It is not comprehensible in the context of this Draft EA. Either its meaning should be explained, or (preferably) it should be replaced by a standard term such as those in Charles V. Larson's Illustrated Glossary of Vulcanospeleoloqy.
  6. Keala Cave's length. The statement on page 13 is incorrect. Its length is 5.3 miles. It may be the second longest cave in Hawaii (data are lacking on several others), but it is not the second longest lava tube cave in the world.
  7. Kazumura Cave's length. Mapped length (including all known passages) is 36.88 miles. Depth is 3603 feet.
  8. Squeezeups (page 14, line 11) are among the least vulnerable of cave features, and are uncommon in caves in this area. A commoner and/or more vulnerable type of feature (such as lava stalagmites) should be cited instead.
  9. Line 5 of page 14's next?to?the?last paragraph has an extra be. It should be deleted, to read:

...excavation will not be necessary...

Hawaii Notices FEBRUARY 23, 1996

(3) Puna Emergency Access Road

District: Puna

TMK: 1?6?13:81; 1-6-45:073; 1?6?65:109

Applicant: County of Hawaii

Office of the Mayor

25 Aupuni Street

Hilo, Hawaii 96720

Contact: Norman Oleson (961~565)

Accepting Authority: County of Hawaii

Office of the Mayor

25 Aupuni Street

Hilo, Hawaii 96720

Contact: Norman Olesen (961?8565)

Consultant: Ron Terry, Ph.D. (982?5831)

HCR 9575

Keaau, Hawaii 96749

Public Comment Deadline: March 25, 1996

Status: DEA First Notice, pending public comment. Address comments to the applicant with copies to the consultant and OEQC.

The County of Hawaii proposes to fund construction improvements and assume maintenance and liability for an emergency access road that would connect State Highway 11 to State Highway 130, passing through the Hawaiian Acres and Ainaloa subdivisions. The route begins at Old Volcano Trail (a County road) and 8 Road near Kurtistown in Hawaiian Acres; then proceeds along 8 Road to F Road; along F Road to 9 Road; southeast along 9 Road to parcel 1?6-45:073 (the connector lot); northeast 0.3 miles across the connector lot to Ainaloa Blvd.; and then along Ainaloa Blvd. to its junction with Highway 130. The County will assume ownership and responsibility for the entire right?of?way associated aisle each road.

The primary purpose of the project is to provide a paved road connecting Highway 130 and Highway 11 in order to improve Police Department, Fire Department, and ambulance services. It would also provide a bypass in case of accidents or Civil Defense emergencies that closed Highway 130 between Ainaloa and Keaau. Especially useful would be the ability of Hawaiian Acres residents who are prevented by flooding along the subdivision roads that connect to Highway 11 to exit via Ainaloa Blvd. The road would also be open for public travel and would serve residents for travel within and between the Hawaiian Acres and Ainaloa Subdivisions.

Because the proposed project crosses essentially perpendicular to the gradient of an extensive field of pahoehoe lava known as the `Ai La`au Flows, many lava tubes are crossed. These include several named tubes with impressive diameters and lengths, including Kazumura, Keala and U`ilani Caves.

DRAFT ENVIRONMENTAL ASSESSMENT

PUNA EMERGENCY ACCESS ROAD

TMK (3rd) 1?6?13:81, 1?6?45:073 & 1?6?65:109

PUNA DISTRICT, HAWAII ISLAND, STATE OF HAWAII

APPLICANT:

County of Hawaii, 25 Aupuni Street, Hilo Hawaii 96720

CONSULTANTS:

Ron Terry Ph.D., HCR 9575, Keaau, Hawaii 96749

APPROVING AGENCY:

Office of the Mayor, 25 Aupuni Street, Hilo, Hawaii, 96720

CLASS OF ACTION:

Use of County funds

This document is prepared pursuant to the Hawaii Environmental protection Act, Chapter 343, Hawaii Revised Statutes (HRS), and Title 11. Chapter 200, Hawaii Department of Health Administrative Rules (HAR).

PART 1: ACTION DESCRIPTION

1.1 Project Location

The County of Hawaii proposes to fund construction improvements and assume maintenance and liability for an emergency access road that would connect State Highway 11 to State Highway 130, passing through the Hawaiian Acres and Ainaloa subdivisions.

The route begins at the junction of Old Volcano Trail (a County road) and 8 Road near Kurtistown in Hawaiian Acres; then proceeds southeast 0.5 miles along 8 Road to F Road, northeast 0.3 miles along F Road to 9 Road, southeast 0.50 miles along 9 Road to parcel 1?6?45:073 (hereafter referred to as the connector lot); northeast 0.3 miles across the connector lot to Ainaloa Blvd.; and then northeast 3.1 miles along Ainaloa Blvd. to its junction with Highway 130 (all distances approximate) (Fig. l). The total length of roadway is approximately 8.7 miles.

The County will assume ownership and responsibility for the entire right?of way associated with each road. which has a width of 60 feet in Ainaloa and 40 feet in Hawaiian acres.

1.2 Purpose and Objectives of Project

The primary purpose of the project is to provide a paved road connecting Highway 130 and Highway 11 in order to improve Police Department, Fire Department, and ambulance services. It would also provide a bypass in case of accidents or Civil Defense emergencies that closed Highway 130 between Ainaloa and Keaau. Especially useful would be the ability of Hawaiian Acres residents who are prevented by flooding aeolian the subdivision roads that connect to Highway 11 to exit via Ainaloa Blvd. The road would also be open for public travel and would serve residents for travel within and between the Hawaiian Acres and Ainaloa Subdivisions.

The project proposal developed as a combination of several ideas generated within the Hawaii County Fire Department, the Office of the Mayor, and the Hawaiian Acres and Ainaloa Community Associations.

The dedication of the road (albeit to emergency standards only) would enable future capacity and safety improvements to be paid for with fuel tax maintenance funds.

1.3 Project Description

Except for the connector lot mentioned above (a distance of approximately 1,800 feet), the road already exists. The project would widen, pave and otherwise improve the road as appropriate to meet the following standards

  • Two paved 8?foot travel lanes. with center stripe,
  • Two paved 2?foot shoulders, striped for separation from travel lanes;
  • 2?inch AC pavement;
  • Sight distance appropriate to 25 MPH road.

All surfacing on the existing roads would be done over compacted base course that was installed about 30 years ago and has become overgrown from lack of maintenance. The new section on the connector lot would require grading and a base course in addition to paving. Because this section is an entirely new road. slightly higher standards requiring 20 feet of paved lanes, 6?foot shoulders, and 2?inch AC pavement over 4 inches of base course with 6 inches of sub?base (if necessary) will be applied.

Most road work would take place in Hawaiian Acres and in the connector lot, because Ainaloa Blvd. currently meets the above standards in most places and requires only minor widening and striping. Ainaloa Blvd and much of Road 8 (approximately 60 percent of the total route) are already paved.

Several sections of the road require safety modifications in order to meet minimum sight distance safety requirements. Because the roads are all straight, no adjustment of horizontal alignment is necessary. Blind hills impair sight distance in several locations. which will be improved mostly through placement of fill. A very limited area of cutting is required.

The road would have a posted speed limit of 25 MPH.

A County Capital Improvement Fund of $1,000,000 has been authorized to bring the route up to County emergency standards. These funds can only be applied after the County acquires ownership of the road.

1.4 Alternatives

Several alternatives to the proposed project have also been examined, as required by sound planning principles and State law. This section briefly describes the Alternatives considered. Section 2 contrasts the environmental impacts of the Alternative retained for further consideration with the impacts of the proposed project where they differ.

1.4.1 No Action

The roads would remain in private hands under the No?Action Alternative. No connection between Hawaiian Acres and Ainaloa would be built. County emergency services would remain difficult to provide in the area, and traffic attempting to exit Hawaiian Acres during floods would, as now, be obliged to cross the most flood?prone roads. No County funds would be expended, and no long term commitment to maintaining roads in the area would be incurred. It is reasonable to expect, however, that the project would eventually proceed in some form through private funding.

1.4.2 Alternatives Evaluated and Dismissed From Further Consideration

Several approaches to providing emergency access were considered but withdrawn because of feasibility or cost considerations. Alternate routes were initially evaluated, including the following:

  1. Substituting Orchidland Drive for Ainaloa Boulevard;
  2. Utilizing 9 Road for a longer segment of the route;
  3. Extending the route along 8 Road to G Road and from there to Ainaloa;
  4. Eliminating the jog down F Road and 9 Road by purchasing the lots extending between 8 and 9 Roads midway between F and G Roads.

Although each of these routes had some advantages, all were estimated to cost significantly more because of the need to create and/or upgrade longer segments of roadway. The length of such segments varied from a minimum of 0.35 miles under D and a maximum of 3.05 miles under A. The additional costs associated with these routes were not precisely calculated but were estimated to equal or substantially exceed $300,000. It is relevant to note that none of the dismissed alternative routes would avoid any of the basic environmental impacts associated with the proposed project

Also considered was the possibility of providing a County road in compliance with conventional road standards for lane and shoulder widths; curbs, gutters and sidewalks; and drainage structures. Cost estimates for this level of roadway exceeded $17 million, which was far in excess of the County's ability to provide assistance. This design would have better accommodated high levels of traffic, although it also would have encouraged greater levels of traffic (see Section 2.4.1).

Finally, delaying action on the project was considered. This was rejected because of the risk of relying on a similar County Council appropriation in the future and the lack of obvious advantages.

1.5 Ownership

The roads in each subdivision comprise one TMK. 1?6?13:81 for Hawaiian Acres, and 1?6?65:109 for Ainaloa. Under the proposed project, those segments of these roads that are part of the route would have their metes and bounds registered separately and transferred to County control. The County would assume ownership and control over the entire right?of?way associated with each road. No subdivision would be necessary. The connector lot, T~1K 1?6?45:073, is privately owned and must be purchased or condemned.

1.6 Land Use Designation and Controls

The route passes through areas within the State Land Use Agricultural District. Zoning in Ainaloa is A?la (Agriculture 1 acre) with some Open zoning, and in Hawaiian Acres is A3a (Agriculture 3 acre) with some A?5a (Agriculture 5 acres). Roads are permitted uses within these Land Use Districts and zoning classifications.

1.7 Agency public Consultation

As part of the consultation process for this Environmental Assessment (EA), the following agencies and organizations were contacted:

County:

 

Planning Department

Department of Public Works

County Council

Fire Department

Police Department

Civil Defense Agency

State:

 

Historic Preservation Division

Highways Division

Federal:

 

Fish and Wildlife Service

Geological Survey

Private:

 

Ainaloa Community Assoc.

Hawaiian Acres Community Assoc.

Hawaii Speleological Survey

Sierra Club

Copies of replies from those agencies and organizations with substantive comments are provided as Appendix 1 (and Appendix 2 for communications related to caves). Comments are discussed in the appropriate sections of the Environmental Assessment.

Two public meetings were held specifically to gather comments and information for this EA. These occurred in Ainaloa and Hawaiian Acres on January 10 and 11, 1996, respectively. Appendix 3 contains the sign?in sheets from these meetings along with a joint summary of concerns and questions that arose at the matinees. Input from these meetings is also discussed in the appropriate sections of the text.

Part 2: Environmental Setting, Impacts and Proposed Mitigation Measures

2.1 Basic Geographic Setting (omitted)

2.2.1 Drainage (omitted)

2.2.2 Lava Flow and Earthquake Hazards (omitted)

2.2.3 Flora, Fauna and Ecosystems (omitted)

2.2.4 Air Quality Noise and Scenic Resources

Environmental Setting

Air pollution in the area is minimal, although air quality is subject to periodic deterioration due to volcanic emissions ("vog") during southerly winds. Ambient noise is usually low., in this rural area. Construction and agricultural activity may raise local noise to high levels for periods of hours to days. The scenery varies from suburban to rural agricultural to semi?wilderness .

Impacts

Road paving and other road work will produce localized air pollution through fugitive dust and exhaust from construction vehicles. Because of the relatively sparse settlement and the dispersive effects of wind, these effects are expected to be minor.

Mitigation

The County should restrict construction activity in the easement to daylight hours to the greatest extent feasible. Professional traffic control should be utilized as necessary. Dust and noise control should be implemented during construction. Best management practices should be observed to control excess runoff during construction.

2.2.5 Cave Resources

Soon after the County officials publicized the project, they began to hear concerns about impacts to lava tube caves. Members of the Hawaii Speleological Survey (HSS), including its chairman, Dr. William Halliday, met with a representative of the Mayor s Office to supply information on cave resources, to urge careful examination of impacts and to suggest mitigation measures.

Dissatisfied with what they perceived as inadequate consideration of its viewpoint, the HSS alerted individuals and organizations throughout the world. As a result, the County has received a large file of correspondence on the caves, which is reproduced in this EA as Appendix 2. The ensuing dialogue between the County of Hawaii and concerned citizens and organizations has helped provide information to the County and to clarify misunderstandings about the methods and context of the project. Because of the volume of correspondence and sincere concern on this issue, this EA provides an extended discussion of the topic.

Existing Environment

Lava tubes are an integral and common element of extrusive volcanic landscapes in shield volcanoes such as Kilauea and Mauna Loa. They are formed by the crusting over of active surface flows and provide an efficient means to transfer molten lava from the flow source to its terminus. After the molten lava drains away, a lava tube is often left behind These caves vary in diameter from inches to tens of feet, and in length from several feet to over ten miles. They may contain multiple branches and layers braided together in a complex fashion. A lava tube system formed as one unit is often separated into multiple caves through collapse of intervening sections. Although their number cannot be ascertained precisely, it is certain that many thousands of lava tubes lie within the pahoehoe flows, which together with a`a flows and limited areas of ash compose the surface mosaic of the volcanoes.

Because the proposed project crosses essentially perpendicular to the gradient of an extensive field of pahoehoe lava flows known as the `Ai La`au Flows (ca. 340 years B.P. see Section 2.1), many lava tubes are crossed. These include several named tubes with impressive diameters and lengths, including Kazumura, Keala and U`ilani Caves. The HSS has submitted an application to nominate U`ilani Cave to the Hawaii Natural Area Reserve System based on its geological features.

For this EA, the HSS provided information on the location and characteristics of the following caves: Kazumura, Keala, Fern's. Pirate's, D?Road complex, and Uilani. The author of this EA and representatives of the Hawaii County Planning Department and the Department of Public Works (DPW) consulted with local speleologists, the United States Geological Survey (USGS), the U.S. Fish and Wildlife Service (USFWS), the State Historic Preservation Division (SHPD), and the University of Hawaii to determine resources of and impacts to these caves and others that might be encountered along the route.

NOTE: No map of caves is provided in the EA because of mutual agreement among the consulted parties (including the State Historic Preservation Division and the Hawaii Speleological Survey) that such information might lead to unauthorized visitation and desecration of burials contained within. Disclosure might also burden the owners of thc cave entrances with requests for visitation.

Lava tubes are valuable resources in several distinct ways:

Geology. The morphology and features of lava tubes provide important information on the mechanics and histories of eruptions. Apart from their scientific value, excellent examples of lava tubes may also be worthy of preservation for their geologic and educational interest to the general public.

Recreation. A growing number of cave enthusiasts with a variety of interests are known to be exploring lava tubes in Hawaii. Some ecotourism advocates see lava tubes as a unique and compelling tourist attraction. Cave explorers have reportedly connected collapsed sections of Kazumura Cave to make it the longest known traversable lava tube on Earth (approximately 35 miles) with the greatest elevation change of any cave in the United States (3,630 feet). Keala Cave is reportedly the second longest such cave. "Record setting" features such as these have attracted worldwide attention from cave enthusiasts and professional speleologists.

Biology. Rare communities of specialized invertebrates. many unique to Hawaii. make their homes in lava tubes. Of greatest concern are the troglobites, which are obligatory cave animals living in the lightless zone. The cave ecosystem relies on energy sources from the surface and soil that enter via plant roots percolating groundwater, and animals that accidentally find their way into (but not out of) the caves. The `ohi`a (Metrosideros polymorpha) tree supplies a major input of nutrients to the system, and preservation of natural vegetation above cave ecosystems is considered vital to ecosystem health (Dr. Fred Stone, pers. comm., December 1995). F.G. Howarth (1981) analyzed species found in Kazumura Cave as part of the Hawaii International Biological Program research effort in the 1970s. He discovered blind crickets, plant hoppers. mites and spiders among the 31 taxa of animals within the cave, most of which are accidentals. Since that time, biologists have discovered additional species in this and other Puna caves (Dr. Fred Stone. pers. comm., December 1995).

Species Diversity. Howarth noted that species diversity within lava tubes in Hawaii is highest in tubes of one hundred to several thousand years old. and in large, complex tubes with less human disturbance in the surface zone. Puna caves, especially those found in protected or undisturbed areas, meet these criteria. Although no species enjoying statutory protection under federal or state regulations (e.g., listed endangered species) is found within these caves, preservation of sufficient habitat to support Hawaii's unique cave fauna must be an integral part of efforts to preserve biodiversity in the Hawaiian Islands.

Hawaiian Culture. Native Hawaiians utilized caves for a variety of activities, including shelter, water collection facilities, shrines, and work areas. Evidence of this use persists in many sites. Lava tubes served for centuries as burial sites for Native Hawaiians. Hundreds of burials have been recorded within lava tubes on the Island of Hawaii. The traditional Hawaiian attitude requires that such remains should not be disturbed, viewed or even visited, and this has become State policy through the actions of the State of Hawaii Burial Council. which often requests that lava tubes containing such remains be sealed off to prevent entry. No single opinion exists in the Hawaiian community regarding entry into lava tubes in general, although meetings and discussions generated by publicity over speleological interest in caves has demonstrated that some individuals and groups are uncomfortable with unlimited access.

These resource values may conflict. Any visitation (even by careful scientists) may damage delicate cave features such as pseudo?stalactites and squeeze?ups, and may also damage cave organisms or habitat. Heavy use by recreational visitors (however sensitive) to caves will take a toll on the geological features and biology of many lava tubes. Most disturbing is the conflict between the wishes of many Native Hawaiians to exclude most visitation and the growing demand of recreational users to explore more and more caves on a more frequent basis. According to State Historic Preservation Officer Don Hibbard in his 18 December 1995 reply to HSS Chairman Halliday (see Appendix 2):

"...[you] note that scientific and other visitors to these caves contribute considerable sums to the economy of Hawaii Island. We note that our division does not encourage viewing lava tubes as an economic resource because uncontrolled visitation could and has damaged historic properties within lava tubes. A number of Native Hawaiians have also expressed concern that such visits are disrespectful when so many lava tubes were used for burial."

Locations and Nature of Impacts

After a thorough, section?by?section review of the known cave locations and the type of construction activities planned above them, there is a consensus that the structural effects on all but U`ilani and Pirate's Cave will be minimal. A reconnaissance of the proposed route by the Deputy Director of the Hawaii County Department of Public Works has determined that cutting or excavation will be not be necessary in the areas of Hawaiian Acres over Keala, Kazumura. Fern's or the D?Road caves, a concern stated repeatedly in HSS communications. This means that fill emplacement and paving will be the only modification of the surface, which most agree should strengthen, not weaken, the caves.

One cave that may require collapse is Pirate's Cave, a low, broad cave that very shallowly underlies one of the project roads. In a letter of December 1995, Dr. Halliday expressed the opinion that Pirate's Cave was of minor importance and could be collapsed if necessary without objection by HSS (see Appendix 2).

In the Ainaloa Portion of the project, DPW engineers examined U`ilani Cave to investigate reports that the cave ceiling was unstable and close to the surface, posing a potential disaster. This section of the cave has been partially filled by road construction debris and substantial amounts of household garbage, old tires, etc. In the portion of the cave that passes under the road, there is no indication of recent or imminent collapse. It is possible that some structural modification of the cave will ultimately be necessary, as determined by periodic inspections which the County will implement under its bridge maintenance program. Such a modification would probably alter the interior of the cave. However, as Dr. Halliday has stated in his monograph of this cave system:

"One obvious option for protecting vehicular traffic on Ainaloa Blvd. is placement of additional constructional fill in the cave. If this is done, it is likely that this would complete the filling of the cave passage at this point. In my opinion, this would do no significant harm to the cave, provided it is done in a manner consistent with the principal resources and values of the cave and access to them for those with need for that access. This is because additional clean fill in this short segment of the cave can do no further harm to the cave: past damage there is already maximal. In fact, if old garbage and trash is removed, the cave environment actually would be improved." (1993:3, see end of Appendix 2).

In the connector link between Ainaloa Blvd. and 9 Road in Hawaiian Acres, it is not likely that any substantial caves will be located, according to Dr. Stephan Kempe, a speleologist concerned with preserving Puna cave resources. In his letter to the Mayor's Office of 5 January 1996. he states:

"The planned extension itself is in all probability free of major caves because it follows the northern edge of the Ainaloa Flow..."

In addition to known caves, in all probability dozens of other caves, mostly modest in dimension, underlie the area, as they do virtually all pahoehoe?covered areas of the Big Island. Over 300 miles of private and public roads, ranging from multi?lane highways to dirt tracks, form a dense matrix over the `Ai La`au flows, which are rife with lava tubes. During road construction large lava tubes are sometimes encountered (on rare occasions with damaging results). For the most part the lava tubes lie far enough beneath the surface to avoid substantial disturbance. Because the project will take place on existing roads with a history of over 30 years of travel by heavy equipment including bulldozers and fire trucks, it is unlikely that large lava tubes will be uncovered. However, as pointed out by Dr. Kempe (Ibid.), there can be no guarantee that no damage whatsoever will result. Mitigation efforts will include a search for tubes in the limited area where cutting will occur (see below).

Impacts and Mitigation Measures

Impacts to Geological Resources: The loss of natural features or scientific value would be negligible. The small segments of U`ilani and Pirate's Caves that may be affected are already well documented and have been adversely modified by placement of fill, trash, etc. Even considering the potential to encounter smaller lava tubes in the very limited sections contemplated for excavation, less than 0.001 percent of the mapped length of lava tubes in this section of Puna would be disturbed.

Mitigation Measures for Geological Impacts. None proposed.

Impacts Related to Exposure to Hazards: During road construction, Pirate's Cave and any other lava tubes encountered near the surface will be evaluated on a case?by?case basis to determine whether collapse, fill or other structural modification is required. U`ilani Cave has been inspected by Hawaii County engineers and is not considered unsafe at the present time. No structural modifications are currently proposed. although the cave will be more closely examined during modification of the road shoulders (the only construction activity proposed as part of this project along Ainaloa Blvd.).

Mitigation Measures for Exposure to Hazards. U`ilani Cave will be monitored as part of the Hawaii County Bridge Maintenance program. Periodic evaluations of its stability, including debris measurements and cave roof inspections, will take place. Structural modifications will be designed and built as necessary, in consultation with the State Historic Preservation Division. For other areas. the USGS has offered to perform magnetic surveys to determine the precise location and approximate depth of lava tubes in the following sections: along the areas proposed for cutting, in the lot connecting Ainaloa Blvd. to 9 Road, and above Keala, Kazumura and the D Road complex. This location will help ensure that no lava tubes are inadvertently collapsed and that the geologic hazard potentially posed by as yet undetected lava tubes is identified and mitigated.

Impacts to Recreation: Other than the section of Pirate's Cave under the roadway, which is occasionally used by children, no loss of recreational cave areas would occur. It should be noted that all current recreation takes place on private lands often without owner's permission, and is not sanctioned by the County or community associations.

Mitigation Measures for Impacts to Recreation: None are proposed.

Impacts to Biology: The construction of a road above a lava tube may also affect cave fauna by removing vegetation whose roots penetrate into the tube to provide nutrients, altering the flow of water and introducing pollutants. Because a road already exists above all but 0.31 miles of the proposed route, these effects will be negligible. If a section of a cave is collapsed, the potential for alien species introductions increases, and airflow between segments may be lost.

Mitigation Measures for Impacts to Biology: If a section of a lava tube with potential biological value must be collapsed, a culvert allowing airflow passage will be emplaced and the entrance sealed to prevent alien species introduction.

Impacts to Hawaiian Culture: The principal Hawaiian cultural issue pertains to archaeological features found within the lava tubes, especially those related to burials. As stated before, many native Hawaiians feel that the sanctity of burial areas is violated by visitation of lava tubes. In this sense, the greatest impact on this resource value has been the enthusiasm of those who seek to explore caves.

Mitigation for Impacts to Hawaiian Culture: If any caves are unearthed during construction, the County of Hawaii will immediately contact the State Historic Preservation Division (SHPD) for determination the appropriate level of archaeological research. If human remains are found, the SHPD in coordination with the Hawaii Burial Council will determine the appropriate disposition of remains. If at some future date U`ilani Cave must be structurally modified, SHPD will be consulted for guidance. Section 3.3.2 contains further details.

Scale and Significance of Impacts

It is possible that by the end of the proposed project, no lava tubes will have been collapsed and physical effects on lava tubes will have been essentially zero. However, as stated above, it may be necessary for road safety to collapse, fill or place supporting structures within small portions of U`ilani Cave, Pirate's Cave, and smaller tubes that may be encountered along the route

Such modifications would not represent a significant impact as defined in Chapter 343. HRS, and Title 11, Chapter 200, HAR, which govern environmental impact analysis for such projects. No natural or cultural resources would be lost, no rare or endangered species or community would be substantially affected, nor would any other significant impacts occur, as specified in Part 5 of this EA.

It should be noted that the entire region surrounding the proposed project is an agricultural subdivision, crisscrossed by hundreds of miles of roads and driveways and occupied by hundreds of homes. The caves do not enjoy legal protection of any sort within this area, and may be legally collapsed or used for a variety of purposes such as depositing yard wastes or storage. Although the County, State and federal governments do not authorize such uses, they have no authority to prevent them. Apart from these activities, lot grading associated with home construction and agriculture is substantial and will only grow in scale. According to one estimate, over 585 private landholdings exist over Kazumura Cave alone (William McClellan, pers. comm., January 1996). The environmental effects of paving/repaving of an existing road must be evaluated within this land use context.

[pages 18-19 have been omitted]

Mitigation Measures

The following mitigation measures are proposed:

  • Monitoring of the crime rate within the subdivisions by Keaau Police in order to determine whether an increase ensues after road construction. The Hawaii County Police Department has an expressed a willingness to keep these statistics. If justified, additional police patrols should be implemented
  • Increased reliance and participation in Neighborhood Watch programs

The No?Action alternative would reduce access for criminals but also for police.

2.3.2 Archaeology and Historic Sites

Environmental Setting

Recent inventory surveys have yielded abundant physical evidence that pre?Contact and early post?Contact Hawaiians used inland Puna extensively for habitation, gathering, temporary shelters, burials and other purposes. The rain forest environment provided plant and animal material for cordage, feather work, medicine, dyes and ceremonial items. In addition, lava tubes were also used for various purposes, especially burial, which have in some cases left behind sites of historic and/or cultural significance. The fact that the proposed route is located on the Ainaloa lava flow, only 340 years in age, reduces but does not eliminate the possibility that substantial historic sites may exist in Hawaiian A or Ainaloa.

Although historic sites may be present in the region traversed by the road. they are not expected on or near the road itself, because the entire route (except the connector lot) bulldozed to a width of 40?60 feet during the creation of the subdivision. The road has since experienced regular maintenance and brush clearing and is highly unlikely to contain any traces of its original surface or immediate subsurface. No known lava tube sections with the potential to be impacted by the project are known to contain burials or other historic features, as discussed in Section 2.2.5 above.

Impacts and Mitigation Measures

The County of Hawaii has coordinated with the State Historic Preservation Division (SHPD) to determine the appropriate level of archaeological research. The consultation has not yet determined the research/mitigation program. At this point, the County proposes the following:

?[pages 22-29 omitted, not relevant to cave resources]

PART 3: SUMMARY OF ENVIRONMENTAL IMPACTS AND PROPOSED MITIGATION MEASURES

Listed below are impacts and proposed mitigation measures for categories in which impacts are apparent. Refer to Part 2 for detailed discussions.

3.1 Short Term Impacts

Construction Impact: Short term Impacts will result from land clearing and construction activities. The impacts will consist of temporary noise. dust and exhaust from machinery and heavy equipment.

Mitigation: The County should restrict construction activity in the easement to daylight hours to the greatest extent feasible. Professional traffic control should be utilized as necessary. Dust and noise control should be implemented during construction. Best management practices should be observed to control excess runoff during construction.

3.2 Long Term Impacts

Traffic Impact:

The proposed road would greatly improve traveling conditions for many residents of Hawaiian Acres. However, both Average Daily Traffic and peak?hour traffic can be expected to increase due to a combination of several factors related to within?subdivision, between?subdivisions and extra?subdivision trips.

Mitigation:

  • The potential for speeding can be countered by a police presence, which should be especially prominent during a short period after the road is opened. Alternate measures such as road rippling should be considered if the speeding problem persists.
  • The County should monitor Average Daily Traffic (ADT) and peak hour traffic. Alternatively, County personnel could train the Road and Traffic subcommittees of the community associations to perform these tasks.
  • Information from these activities can provide a baseline for future road planning and would help alert the County to potential traffic volume-related problems. Additional mitigation measures may be instituted as necessary. The eventual upgrading of the road to full County standards could be considered if justified by traffic volume and community consensus.
  • The traffic impact will be mitigated by State projects currently in planning or construction that will add full turning lanes on Highway 10 at Ainaloa and a left turn lane from Highway 11 onto Kuauli Street, and also if and when some of the road projects described in Section 3.7 4 are completed.

Impacts to Natural Resources:

Because the proposed project would take mostly within an existing road corridor. the potential to destroy or disrupt native species and communities is minimal. The proposed project has been evaluated with respect to the characteristics and location of caves. No cutting will take place in any areas of known caves and the limited degree of road work necessary on the existing road above these caves should not cause any structural harm to the caves below, with the possible exception of Pirate's Cave and U`ilani Cave. Pirates's Cave has been evaluated as minor, already disturbed. and of limited value.

Mitigation:

U`ilani Cave will be monitored as part of the Hawaii County Bridge maintenance program. Periodic evaluations of its stability, including debris measurements and cave roof inspections, will take place. Structural modifications will be designed and built as necessary. in consultation with the State Historic Preservation Division. For other areas. the USGS has offered to perform magnetic surveys to determine the precise location and approximate depth of lava tubes in the following sections: along the areas proposed for cutting, in the lot connecting Ainaloa Blvd. to 9 Road, and above Keala, Kazumura and the D Road complex. This location will help ensure that no lava tubes are inadvertently collapsed and that the geologic hazard potentially posed by as yet undetected lava tubes is identified and mitigated.

If a section of a lava tube with potential biological value is required to be collapsed, a culvert allowing airflow passage will be emplaced and the entrance sealed to prevent alien species introduction.

Impacts to Archaeology and Historic Sites:

Although historic sites may be present in the region traversed by the road, they are not expected on or near the road itself, because the entire route (except the connector lot) was bulldozed to a width of ~0?60 feet during the creation of the subdivision. The road has since experienced regular maintenance and brush clearing and is highly unlikely to contain any traces of its original surface or immediate subsurface. No lava tubes that are expected to be impacted by the project are known to contain burials or other historic features, as discussed in Section 2.2.5 above.

Mitigation Measures

The County of Hawaii has coordinated with the State Historic Preservation Division (SHPD) to determine the appropriate level of archaeological research. The consultation has not yet determined the research mitigation program. At this point, the County plans to have its personnel or contractor accompany SHPD personnel on a site inspection of the connector lot and Pirate's Cave to determine if an archaeological inventory is necessary. If appropriate, the County will contract with an archaeologist to inventory features, determine significance and suggest appropriate treatments (e.g., preservation or data recovery). Because the connector lot must be condemned, right?of?entry has not yet been acquired. If it is determined during engineering studies that alterations of Pirate's Cave or U`ilani Cave are necessary, the County w ill consult with SHPD for the appropriate level of archaeological research.

If any artifacts charcoal, human remains, or lava tubes are encountered during construction. work w ill immediately cease and SHPD will be consulted to determine the appropriate research and mitigation. If human remains are found. the SHPD in coordination with the Hawaii Burial Council will determine the appropriate disposition of remains. If at some future date U`ilani Cave must be structurally modified, SHPD will be consulted for guidance.

Impacts on Public Services:

The proposed project would greatly facilitate the provision of emergency services not only in Hawaiian Acres and Ainaloa but in Puna in general. It would also provide a bypass in case of accidents or Civil Defense emergencies that closed Highway 130 between Ainaloa and Keaau. The road is supported by the Fire and Police Departments and the Civil Defense Agency.

Secondary Impacts

The proposed project will not involve substantial secondary impacts, such as population changes or effects on public facilities. The level of impacts that would result would: a) not be substantial because of the relatively small degree of influence the road would exert; b) not involve a large area; and c) not be unintended, because the entire area is zoned for such use.

Mitigation

Any potential secondary impacts can be mitigated by continual attention to sensible development of Puna, infrastructure in keeping with the rural atmosphere of the district. These efforts are underway on a number of fronts, including the Puna Community Development Plan.

3.3 Impacts of the No?Action Alternative

The roads would remain in private hands under the No?Action Alternative. No connection between Hawaiian Acres and Ainaloa would be built. County emergency services would remain difficult to provide in the area, and traffic attempting to exit Hawaiian Acres during floods would, as now, be obliged to cross the most flood?prone roads.

The No?Action Alternative would avoid impacts related to traffic volume. but at the cost of continuing very substandard road conditions. Safety would continue to be a problem for roads burdened with blind hills and narrow lanes (particularly 8 Road).

The No?Action Alternative would have substantially the same impacts as the proposed project in terms of drainages flora and fauna, and historic sites. because it is believed that Hawaiian Acres would eventually pave most of the route and many additional roads by itself County funds to ameliorate drainage problems near the road, however, would not be available. The protection to rare and endangered species and historic sites afforded by County involvement is considerably greater than if the subdivisions undertook improvements privately.

PA RT 4: ANTICIPATED DETERMINATION

The proposed project will not significantly alter the environment and impacts will be minimal. Therefore, it is anticipated that a negative Declaration will be filed, and that the preparation of an Environmental Impact Statement is not warranted.

PART 5: FINDINGS AND REASONS

  1. The proposed project will not involve an irrevocable commitment or loss or destruction of any natural or cultural resources. Only a small section of an agriculturally?zoned lot will be committed to a use other than the current use, which is roadway.
  2. The proposed project will not curtail the range of beneficial uses of the environment.
  3. The proposed project will not conflict with the State's long?term environmental policies.
  4. The proposed project will not substantially affect the economic or social welfare of the community or State. It will help provide emergency services and allow better transportation for Hawaiian Acres and Ainaloa residents
  5. The proposed project does not substantially affect public health in any detrimental way.
  6. The proposed project will not involve substantial secondary impacts, such as population changes or effects on public facilities. Some secondary impacts may occur as a result of the road's tendency (among many unrelated factors) to influence in filling of home construction in the agricultural lots. The level of impacts that would result would: a) not be substantial because of the relatively small degree of influence the road would exert; b) not involve a large area; and c) not be unintended, because the entire area is zoned for such use.
  7. The proposed project will not involve a substantial degradation of environmental quality.
  8. The proposed project will not substantially affect any rare, threatened or endangered species of flora or fauna or habitat. No endangered species of flora or fauna are known to exist on the project site, other than the possibility of use by the wide?ranging species Hawaiian hawk or `io (Buteo solitarius), and the `ope`ape`a or Hawaiian hoary bat (Lasiurus cinereus semotus). Mitigation measures have been developed in the unlikely event that such species are disturbed.
  9. The proposed project is not one which is individually limited but cumulatively may have considerable effect upon the environment or involves a commitment for larger actions.
  10. The proposed project will not detrimentally affect air or water quality or ambient noise levels.
  11. Although the proposed project is located in an zone exposed to some earthquake and volcanic hazard, there are no reasonable alternatives. The proposed action is intended partly to mitigate hazard exposure for residents isolated by flooding by providing an alternate evacuation risk. The project would provide better County emergency services to a broad area

For the reasons above, the proposed project will not have any significant effect in the context of Chapter 343, Hawaii Revised Statues and section 11?200?12 of the State Administrative Rules.

REFERENCES

Community Management Associates, Inc. 1992. Puna Community Development Plan Technical Reference Report. Hilo: Hawaii County.

_____1995. Puna Community Development Plan (October 1995 Draft). Hilo: Hawaii County

Furumoto. A.S., N. Nielsen and W R. Phillips. 1973. A study of Past Earthquakes Isoseismic Zones of Intensity and Recommended Rules for .Structural Design for Hawaii. Honolulu: Hawaii Institute of Geophysics.

Gagne. W., and L. Cuddihy. 1990. "Vegetation," pp. 45?114 in W.L. Whinier, DR. Herbst, and S.H. Sohmer. eds., .Manual of the Flowering Plants of Hawaii. 2 vols. Honolulu: University of Hawaii Press.

Giambelucca, T.W., Nullet. M. A., and T. A. Schroeder. 1986. Rainfall Atlas of Hawaii. Honolulu: Hawaii Department of Land and Natural Resources.

Hawaii County Planning Department. 1989 General Plan, County of Hawaii. Hilo: Hawaii County.

Hawaii State Department of Transportation (DOT). 1991. Island of Hawaii Long Range Highway Plan. Prep. for DOT and County of Hawaii by Parsons Brinckerhoff Quade and Douglas. Honolulu.

_____. 1992. Traffic Summary Island of Hawaii. Honolulu: DOT.

Hawaii Office of State Planning (OSP). 1991. Hawaii State Plan Honolulu: OSP.

Heliker. C. 1990. Volcanic and Seismic Hazards on the Island of Hawaii. Washington: U.S. GPO.

Howarth. F.G. 1981. "Community structure and niche differentiation in Hawaiian lava tubes," pp. 337?366 in Dieter Mueller-Dombois. et al. eds. Island Ecosystems. Biological organization in selected Hawaiian Communities. Stroudsburg, PA: Hutchinson Ross.

Moore, R.B., and F.A. Trusdell. 1991. Geologic Map of the Lower East Rift Zone of Kilauea Volcano, Hawaii. U.S. Geological Survey Misc. Investigation Series Map I?2225. Washington.

U.S. Bureau of the Census. 1991. 1990 Census of Population, General Population Characteristics. 1990 CP-1-13. Washington: GPO.

U.S. States Soil Conservation Service. 1973. Soil Survey of Island of Hawaii. State of Hawaii. Washington: ACEDIA.

University of Hawaii at Manoa, Dept. of Geography. 1983 . Atlas of Hawaii. 2nd ed. Honolulu: University of Hawaii Press.


NEVERSINK MANAGEMENT PLAN


SOUTHEASTERN CAVE CONSERVANCY, INC.

Adopted August 27, 1995

The following management plan was approved by the Board of Directors of the Southeastern Cave Conservancy on August 12, 1995. The intent of this plan is to protect the property and to preserve the good relationship that the SCC has established with the surrounding landowners. The Board recognizes that many cavers and organizations throughout the country have supported the acquisition of the property, and wishes to make access as open as possible. Please observe the rules and encourage others to do the same so that this unique and beautiful natural site may be enjoyed by all.

  1. While membership is not required for access to the Neversink property, the Conservancy strongly recommends that visitors be members of the Conservancy. Membership in the National Speleological Society is also encouraged.
  2. Permission is not required to visit the property.
  3. Use only the designated parking area and trail. Our access corridor is only 40 feet wide from the road to the main property. Please respect our neighbors and stay on the SCC property.
  4. Due to limited parking facilities, no more than six (6) vehicles at a time may be in the parking area. There is no parking allowed along the road or outside the designated area. We do not own that property. To minimize impact, the Conservancy prefers that groups visiting the pit be small. Please try to keep the number of people at the pit at one time to twelve (12) or fewer. The SCC realizes that this may not always be possible. The intent is to avoid having a crowd at the pit for reasons of both conservation and safety.
  5. Use of the property for any type of commercial activity, including caving or other recreational activities, is not allowed.
  6. Camping, hunting, open fires, and consumption of alcohol are not allowed on the property.
  7. To avoid parking and over-use problems during caving conventions and special events, access to the property will be limited during those events to prearranged trips organized through the convention or event.
  8. Please keep noise to a minimum, and be discreet while changing.

The latest SCC news and announcements can be found on our web page at

http://www.msm.edu/groups/scc.html

(404) 822-0003 putnam@msm.edu

Bill Putnam

1865 Eagle Summit Court

Lawrenceville GA 30243


Membership Form


If you are not already a member of the Conservation and Management Section of the National Speleological Society, you are invited to join. Dues are $5.00 a year, payable to the NSS Cons/Mgmt Section. Members receive the newsletter regularly and are entitled to vote at the annual meeting.

r

Yes, I would like to join the Conservation/Management Section. Here are my dues in the amount of $________ (dues of $5/year may be prepaid for up to three years).

Name______________________________________

NSS No.________

Address_______________________________________________

 

City_____________________________

State_____________

ZIP_________________

Please send this form with check/money order to the Secretary-Treasurer:
Evelyn Bradshaw,
10826 Leavells Road, Fredericksburg, VA 22407-1261.

 

 


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