Hawai‘i votes down Army’s environmental impact statement on Pōhakuloa Training Area

Neither the Army nor the state addressed dangerous levels of PFAS.

Leases for this facility and three others are set to expire in 2029.

By Pat Elder
May 16, 2025

Peace, justice, and environmental healing can only occur when the Army leaves for good.

On May 9, 2025, the Hawai‘i Board of Land and Natural Resources voted to reject the Army’s environmental impact statement to retain its lease on state land for the Pōhakuloa Training Area on Hawai‘i Island.

The decision was based on the inadequate environmental report prepared by the Army. The Army’s half-hearted environmental impact statement reflects the Trump administration’s disregard of cultural and environmental concerns.

Board Chair Dawn Chang made it clear that the decision was limited to the Army’s environmental report while not addressing a continuation of the Army’s lease for the 23,000-acre site set to expire in 2029.

The Pōhakuloa Training Area is located on Hawaiʻi Island (the Big Island) and includes lands considered sacred by Native Hawaiians who say live-fire exercises have destroyed sacred archaeological and cultural sites, along with the environment.

The state of Hawai‘i entered into a terrible “deal” by leasing the 23,000 acres to the Army back in 1964. That lease, for $1, expires on August 16, 2029. (1,555 days and counting).  The Army has offered to return 3,300 acres while retaining 19,700 acres, a ploy designed to placate and divide the opposition. It won’t work.

The two sides are worlds apart. Wayne Tanaka, director of Sierra Club of Hawai‘i, said, “Pohakuloa has been bombed, burned, and polluted for over six decades — and we now have a once-in-a-lifetime chance to finally say no more to such abuse of our ‘aina.”

Col. Rachel Sullivan, commander of U.S. Army Garrison Hawaii, said in a statement that “the Army is committed to continuing its environmental and cultural stewardship in support of the U.S. Army Pacific training strategy while maintaining an enduring partnership with the Hawai‘i Island community.”

Offensive propagandistic statements like this fly everywhere across the country, but not in Hawaii.

Healani Sonoda-Pale, a wonderful, native Hawaiian activist, told the AP the vote was a real shift.  “I think the shift here happened because of the Red Hill spill. The military lost a lot of trust and respect.” Healani is right. The military has lost the trust and respect of many, but not among those who count the most.

Hawaii’s congressional delegation and Governor Josh Green have already taken sides with the Army. The people may have stood up at Pōhakuloa, but it doesn’t matter to these empowered folks who simply talk the talk.

Hawaii’s congressional delegation issued a joint statement saying they “believe there can be a path forward that accounts for the critical importance of Hawaii’s role in our country’s national security strategy and fundamentally respects and responds to the needs of the people of Hawaii.”

How will this work, exactly? Banning live fire exercises would be a start. 

A soldier readies a 155 mm high-explosive artillery round for firing at the  Pohakuloa Training Area. Several thousand 155 mm rounds are fired here annually. It’s bad behavior.

A single 155 mm round can release a wide range of deadly contaminants. The explosive contains compounds like TNT, RDX, or HMX, which are toxic to both humans and the environment. These chemicals can persist in soil and leach into groundwater. The propellant used to fire the round typically contains substances such as perchlorate, nitroglycerin, or nitrocellulose, all of which can contaminate groundwater, affect thyroid function, and poison aquatic life. The primer and casing may also introduce heavy metals like lead, copper, and antimony into the environment, which can bioaccumulate and pose long-term health risks to wildlife and humans.

When the round detonates, it releases airborne pollutants such as nitrogen oxides (NOx), volatile organic compounds (VOCs), carbon monoxide (CO), and fine particulate matter that have an uncanny ability to deposit in our lungs.

Depleted Uranium

The Army says it used about 2,000 rounds of depleted uranium at Pōhakuloa during the 1960s. Depleted uranium, a radioactive heavy metal, is used by the Army in armor-piercing munitions and armor plating. The residue from those weapons used 50 years ago remains in the soil of the impact zone and can be aerosolized in the dust clouds that are stirred up during live-fire exercises or the frequent fires.  Depleted Uranium is made up of more than 99% Uranium-238. It has a half-life of 4.5 billion years, and it is associated with kidney disease, lung cancer, bone cancer, liver damage, and reproductive and developmental toxicity.

The August 2022 wildfire at Pōhakuloa burned 17,712 acres of land. Over the past 50 years, nearly 1,261 wildfires have been recorded by PTA firefighting personnel. The Army says it is serious about protecting the environment.

- Photo: Councilman Tim Richards

According to the Army’s Draft Environmental Impact Statement, (pp 3-36),  On the night of July 20, 2022, a fire erupted in the Pōhakuloa impact area following a training exercise involving pyrotechnic munitions.

Pyrotechnic munitions, such as flares and signaling devices, are widely used by the Army for illumination, marking, obscuration, and signaling. They are deadly because they often contain barium, strontium, lead, chromium, and antimony that can all be lifted into the air during the combustion of pyrotechnic munitions. The pyrotechnic munitions also contain dioxins and furans.

For the most part, firefighters were forced to stand by and watch as thousands of acres burned because fires in the impact area caused unexploded ordinance (UXO) to detonate and launch deadly shrapnel thousands of feet. The Leilani fire was contained, with 1,557 acres burned by July 29, 2022; however, crews continued to work on hot spots for five days. On August 10, 2022, due to strong winds (30-40 mph), a re-ignition of the original fire occurred. It spread west onto adjacent State land. The fire burned approximately 17,712 acres in total. It was contained on August 23, 2022.

(Thanks to the brilliant reporting by  Kawaiola News.)

The fire re-ignited 12 days later, likely due to self-ignition, a known risk associated with the use of pyrotechnic munitions, especially under extreme heat, and direct sunlight.

The Army’s disgusting and dangerous cesspools

Historically, the U.S. Army operated eight large-capacity cesspools at Pōhakuloa. These cesspools collected and discharged untreated sewage, likely to include PFAS compounds and other contaminants, directly into the ground, posing risks to groundwater and the environment. In 2005 the EPA banned such cesspools.  However, the Army continued using them beyond the ban, leading to a 2016 enforcement action by the Obama EPA. The Army agreed to close or replace all eight cesspools and paid a $100,000 fine.

These cesspools circumvented the expensive treatment process to allow the Army to discharge untreated sewage directly into the ground, posing risks to vulnerable people, groundwater, and the environment. 

Other Military Sites with non-compliant cesspools in Hawaii
that were shut down by the EPA:

·        Kīlauea Military Camp (Hawaiʻi Island) (Army)

·        Schofield Barracks – Oʻahu (Army)

·        Wheeler Army Airfield – Oʻahu (Army)

·        Kūmakani Military Reservation – Oʻahu (Army)

·        Tripler Army Medical Center – Oʻahu (Army)

·        Joint Base Pearl Harbor-Hickam - Oʻahu (Navy)

According to the EPA, “cesspools collect and discharge untreated raw sewage into the ground, where disease-causing pathogens and harmful chemicals can contaminate groundwater, streams, and the ocean.

The Army says it is committed to “stewardship of the environment.”

 Why aren’t more people livid?

Probably because they don’t know how bad it is.

Where’s the indignation? The Navy poisoned 93,000 people in Honolulu and consistently lied about it. The Army pretends it never used PFAS at most bases in the state. Deadly levels of Vinyl Chloride, Benzene, Ethyl Benzene, and Xylene poison Hawaii’s groundwater. Many areas were soaked with Agent Orange while the dioxin remains harmful.  The military used depleted uranium at various locations. They sprayed the islands with deadly pesticides that keep on killing.

Groundwater samples at Joint Base Pearl Harbor–Hickam have shown PFOS concentrations reaching 2,500,000 parts per trillion (ppt), which is 625,000 times higher than the EPA’s maximum contaminant level of 4 ppt, perhaps set to take effect in 2029.

The military can do whatever it wants to do because the governor and the congressional delegation lack the political courage to defend human health and the environment. It’s going to change, and Hawaii will lead this revolution.

The Army is also looking to renew leases at Kahuku Training Area, Kawailoa-Poamoho Training Area and Mākua Military Reservation, all on the island of Oahu, where profoundly contaminated Joint Base Pearl Harbor is located. Army officials representing these bases will appear before the Hawai‘i Board of Land and Natural Resources in June 2025. All of the leases expire on August 16, 2029.

Jim Albertini

Jim Albertini is a prominent peace and social justice activist based in Hilo on the Big Island, about 35 miles from Pōhakuloa. He founded the Malu 'Aina Center for Non-Violent Education and Action in 1979.  The center promotes sustainable organic farming and serves as a hub for anti-war and anti-nuclear activism.

Malu ‘Aina sponsors a weekly peace vigil on Fridays in downtown Hilo. The vigil was started on September 12, 2001 to urge restraint not vengeance. They have continued every week since then.

Jim was excited by the prospect for change when the state board rejected the Army’s environmental impact statement, (EIS) on May 9, 2025. He explained, “We had a big turnout to testify against the Army's final EIS. 1,500 written testimonies. 140 oral testimonies, and nearly 70 organizations standing in solidarity to oppose the Army's final EIS. I was very moved by all the young Kanaka Maoli who testified against the military's EIS.  They spoke with deep passion and insight.  It was a great day.”

It was a great and historic day!

Kanaka Maoli refers to "Native Hawaiian" or "True people of the land." We can all learn from the Kanaka Maoli.

Jim tells it like it is. “Pohakuloa is a military training ground for global nuclear war and the end of human civilization. Thousands of nuclear weapon spotting rounds have been fired at PTA, contaminating the land with highly toxic depleted uranium oxide particles of radiation. B-52 and B-2 strategic nuclear bombers fly non-stop training missions from Guam, Louisiana, and Missouri to bomb PTA. Millions of live rounds, involving a wide range of weapon systems, have been fired at PTA for 80 years. Such bombing and shelling does not protect Hawaii. Instead, it endangers the health and safety of Hawaii’s people and future generations.”

Melodie Aduja, Co-chair of the Environmental Caucus of the Democratic Party of Hawaii, has been battling the Army over its contamination of Pōhakuloa for many years. She said, "The Army’s environmental impact statement wasn’t just inadequate—it was a blatant act of deception. After decades of contamination, destruction, and broken promises, Hawai‘i has finally said ‘enough.’ The military’s reckless stewardship of Pōhakuloa has left behind toxic legacies that will outlive us all—radioactive depleted uranium, carcinogenic PFAS, and the desecration of sacred Hawaiian lands.

The Environmental Caucus of the Democratic Party of Hawai‘i submitted comments in 2020, raising concerns about the Army’s failure to address environmental hazards. Following the Hawai‘i Supreme Court’s ruling in Ching v. Case (2019) that mandated the cleanup of Pōhakuloa, has the Army done any of it? Not even.

If the Army truly respected this ‘āina, it wouldn’t be fighting to keep bombing it—it would be fighting to clean it up."

The Army’s record of PFAS contamination at the Pōhakuloa Training Area.

Although not specifically mentioned by state officials in its rejection of the environmental impact statement, the Army failed to address the dangerous levels of PFAS at the Pōhakuloa Training Area in its environmental impact statement. It’s enough to send them packing.

PFAS Soil results at the Pōhakuloa Training Area 

The PFAS Soil results look tiny because they are presented in parts per million rather than the customary parts per billion. (Water concentrations are reported in parts per trillion.)  Final Preliminary Assessment and Site Inspection of Per-and Poly Fluoroalkyl Substances Table 7 –  Pōhakuloa Training Area and Kilauea Military Reservation, Hawaii, July 2023

The Army produces data like this for public consumption and buries it in a labyrinth of technical reports to make it nearly impossible for most people to understand it or even find it. I’ll try to explain this particular abomination. The Army graphic above addresses PFAS in the soil near Building 39, the former fire station, at the Pōhakuloa Training Area. This site was the fire training area where massive amounts of fire-fighting foams were used. See the Google image below.

The red X, east of the fire station, is the epicenter of the greatest environmental crime in the history of the Big Island. The Army created fire pits and filled them with jet fuel. They ignited the inferno and doused the flames using AFFF containing PFAS. The Army says it did not sample groundwater because it is a thousand feet below the surface. We’ll examine this below.

Five different PFAS compounds were reported from the samples taken from the surface soil to a depth of two feet. We’ll examine the PFOS levels. PFOS had a concentration of 1.7 mg/kg.

·        1.7 mg/kg is 1.7 milligrams per kilogram.

·        1.7 mg/kg is equivalent to 1.7 parts per million.

·        1.7 parts per million is 1,700 parts per billion..

·        which is the same as 1,700,000 parts per trillion.

As far as PFOS in the soil is concerned, Pohakuloa is among the most highly contaminated places on earth. Ask the Army if this is true. The Army’s fire training area at Fort Ord may be the only base that is worse in this regard, but Fort Ord is in California where the state allows the Army to do whatever it wants to do, and most people are oblivious about the quality of their “wai” or “kai.”

1,700,000 parts per trillion is a frightening level. Carcinogenic PFOS may attach itself to soil and become airborne, settling in Hawaiian lungs and homes as dust. It can travel many miles in the air to poison surface water and the sea. Unlike European nations, the US EPA does not regulate airborne PFOS. The DOD would not stand for it. They dictate environmental policy in the U.S. in this regard.

People are threatened when the wind blows at Pōhakuloa.

The Army says, “Many of the PFAS constituents found in AFFF (at Pōhakuloa) are surfactants which do not volatilize.” This is true, however, many PFAS compounds do volatilize, including PFOA and Fluorotelomer alcohols, (FTOHs).

PFOA may sublime into the air. In other words, the inhalation of PFOA is possible inside buildings. PFOA isn’t technically considered volatile, yet it lifts into the air. FTOHs are types of PFAS commonly found in AFFF and other military and industrial applications.  FTOHs are semi-volatile organic compounds. This means they can evaporate from solid surfaces like soil or sand into the air.

The Army reported on five of the 40 PFAS compounds typically reported in a standard targeted analysis. They did not report test results for fluorotelomer alcohols at Pōhakuloa.

The Army says the groundwater exposure pathways (via drinking water ingestion and dermal contact) for on-installation site workers and residents are considered to be “incomplete,” although they aren’t addressing pathways to human ingestion like volatility or the poisoned food and fish.   

The Army says groundwater originating where PFAS foams were used at Pōhakuloa “likely flows southwest downgradient toward the sea and discharges at or near the coast.” They admit that the absence of land use controls that prevent potable use of off-post groundwater may impact health off base.

As groundwater flows downslope toward the ocean, the depth of the water table becomes much shallower. This raises concerns about the potential for contaminants—such as depleted uranium (DU), PFAS, heavy metals, and explosive residues to migrate downward. The Army says the depth provides a natural barrier, but without groundwater monitoring between the location of the scene of the crime and the ocean, we won’t know.

Women who are pregnant or may become pregnant should not drink the water or eat the fish, and neither should anyone else. The state must install monitoring wells in downslope areas to check for deadly contaminants. 

Kilauea Military Reservation PFAS soil data

The Army’s site inspection of the Pōhakuloa Training Area also includes cursory PFOS soil data on the Kilauea Military Reservation, also on the Big Island.

KMC-BLD59-2-SO  12/13/2022 
Soil in parts per trillion

PFOS          51,000
PFOA          1,600
PFBS          53
PFNA          1,000
PFHxS        610
__________________________

The Army says it is studying PFAS at six locations on the Big Island

Table ES-1. Summary of AOPIs Identified during the PA, PFOS, PFOA, PFBS, PFNA, and PFHxS Sampling at PTA and KMR, and Recommendations  AOPI’s are Areas of Potential Interest. It is ridiculous that the Army would use this terminology when they’ve already admitted to the existence of PFAS at these sites. NS means not sampled.

There are five sites at the Pōhakuloa Training Area where the Army has provided grossly inadequate documentation. This alone ought to preclude the extension of the Army’s lease of lands on the Big Island.

This graphic illustrates the process the Army follows regarding PFAS “cleanup” steps described in the Comprehensive Environmental Response, Compensation, and Liability Act of 1980. (CERCLA)  

Typically, preliminary assessments and site inspections are published separately, over a period of a year or longer. The Air Force began initiating preliminary assessments of PFAS in 2010. The Navy followed suit in 2014. The Army half-heartedly got going on the CERCLA process in 2017.  A preliminary assessment involves reporting a locations on bases that likely used PFAS foams. A site inspection is a much more detailed report that identifies analytical results of PFAS in various environmental media.

The Army has dumbed down the entire process. They have always been the least transparent of all the branches regarding environmental reporting. The preliminary assessment and the site inspection were published as a single 109-page document for the Pōhakuloa Training Area in July 2023.  Some Navy and Air Force site inspections alone are more than 1,000 pages long.

The Army got an extraordinary late start on the CERCLA process at Pōhakuloa. The Army says the  next phase of the process, the “remedial investigation/feasibility study will take up to 6 years and that the “remedial design/remedial action phase will take another 4 years. This means we will have to wait until 2033 until they begin to clean anything up. And then they say it will be another 30 plus years (2063+) to complete the clean-up.

Of course, this is all entirely ridiculous! The Army doesn’t know how to clean it up! They don’t know what they’re doing. No one has a plan that safeguards human health or the environment. We can’t access these chemicals deep in the ground. If we could, we can’t burn them, bury them, or spread them on farm fields.

The state should refuse to renew the Army’s lease. This would start the process of protecting human health and restoring the island from its diseased condition.

Let’s look at the PFAS records of the three Army installations whose leases expire in 2029.

Kahuku Training Area – Oʻahu 

·        1,170 acres of state-leased land

·        Used for helicopter training and large-scale ground maneuvers. The Army is preparing an environmental impact statement for lease renewal.

The Army says the Kahuku Training Area warrants no further action regarding the use of PFAS, although reading through the narrative suggests the use of PFAS in the wash rack and in the firefighting foams.

From p. 33 – “KTA has a septic tank for the wash rack, which was installed circa 2013. Detergents and waxes are not used at the wash rack and no fire truck has been used (or deployed AFFF) at KTA since the new wash rack became operational.” This statement leaves open the likelihood that KTA used PFAS prior to 2013.

p. 34 – “Two Black Hawk helicopters collided at KTA during a night training exercise on 12 February 2001. Honolulu County Fire Department personnel confirmed that, since 2000, they have not responded to any calls at KTA in which AFFF was used."

This leaves open the possibility that PFAS may have been used in crashes prior to 2000. The Army claims there were no known or documented areas where AFFF was used (including at fire response sites), stored, or disposed of at KTA.

Makua Military Reservation – Oʻahu

  • 760 acres.

  • Historically used for live-fire training, an activity that accompanies the use of AFFF. In December 2023, the DOD announced that it would permanently end live-fire training at Mākua.

The Army has closed the books on the use of PFAS at Makua Military Reservation. On P. 34, the Preliminary Assessment says, “Makua Military Reservation has designated helicopter landing pads. Helicopters were required to be on the installation for firefighting purposes when live-fire training occurred. Live-fire training ceased at MMR in 2004 and, in 2011, the Army announced that live-fire training would not be resumed at MMR (GSL 2015). Army helicopters used for firefighting used AFFF to extinguish petroleum-based fires.

Based on available electronic records dating as far back as 2000, Honolulu County Fire Department personnel confirmed that, since 2000, they have not responded to any calls at MMR in which AFFF was used. There are no available records to indicate AFFF was used, stored, or disposed of, and no interviewees had knowledge of AFFF use, storage, or disposal, at helipads on the installation.”

The Army is not saying AFFF was not used historically, and it is not saying the carcinogens are not being used today. P 36 - “Documentation specific to AFFF may have been limited (e.g., each AFFF use, procurement records, documentation of AFFF used during crash responses or fire training activities) due to lack of recordkeeping requirements for the full timeline of common AFFF practices.”

Because the Army claims it kept lousy records it will assume there was no use of PFAS to close the books on this facility. It’s another Catch-22.

This same rationale and the exact same words are used at more than three dozen Army installations across the country. It is done to eliminate areas from further investigation or to exit the congressionally mandated  CERCLA process altogether. CERCLA is also known as the Superfund. It is the Comprehensive Environmental Response, Compensation, and Liability Act.

The PFAS report for Makua Military Reservation contains additional boilerplate language, “Anecdotal accounts of AFFF use (and therefore likely PFOS, PFOA, and PFBS use) were limited to available installation personnel, whose knowledge of AFFF use may have been restricted by their time spent at the installation or previous roles held that limited their relevant knowledge of potential AFFF (or other PFAS-containing material) use.” It’s boilerplate language.

Now, we get a little closer to the truth. There is anecdotal evidence of the use of AFFF at the Makua Military Reservation. However, the report concludes like the others, “There were also no known or documented areas where AFFF was used (including at fire response sites), stored, or disposed of at Makua Military Reservation.”

Kawailoa-Poamoho Training Area  – Oʻahu

·        4,370 acres

·        Features rugged terrain used for helicopter training. The Army is conducting an EIS for lease renewal.

The Kawailoa-Poamoho Training Area on Oʻahu is primarily utilized for low-altitude helicopter flight training, leveraging its rugged terrain and dense vegetation to simulate realistic conditions. The Army says there is no evidence of PFAS-containing materials used, stored, and/or disposed of at this location. There may not be, but we cannot trust them.

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“The question is whether any civilization can wage relentless war on life without destroying itself, and without losing the right to be called civilized.” ― Rachel Carson

Thank you for reading. Please forward to people who are likely to work for change in beautiful and wonderful Hawaii.

Please support our work. We are raising money to pay for environmental testing at the Army’s Fort Ord, California. It is more contaminated than the Pōhakuloa!  We’ve already raised $6,500. A few thousand dollars would go a long way. Please get in touch if you can help us out. Every dollar makes a difference.

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