Interested parties are hereby notified that an application has been received for a Department of
the Army (DA) permit for certain work in waters of the United States as described below and shown
on the attached drawings.
APPLICANT: Natalia Palamo, Senior Engineer, American Samoa Government, Department of Port
Administration, American Samoa Government, P.O. Box 1539, Pago Pago, American Samoa 96799
AGENT: William Gordon, Tinai, Gordon & Associates, Limited, P.O. Box 9581, Apia, Samoa
WATERWAY: Pago Pago Harbor, Pacific Ocean
LOCATION: Malaloa Wharf, Pago Pago Harbor, Island of Tutuila, American Samoa (Latitude:
-14.274540° S; Longitude: -170.693671° W)
PROPOSED ACTIVITY: The applicant proposes to perform three geotechnical investigative borings to assess the existing subgrade soil conditions and confirm the founding depth of firm bearing materials for end-bearing piles in Pago Pago Harbor at the Malaloa Wharf. Based upon the findings of the geotechnical investigations, the applicant would then select one of two design options for constructing an extension of the existing Malaloa Wharf. The proposed work would involve dredging approximately 10,930 cubic yards (cy) of harbor sediments to provide access to the shoreward side of the new wharf structure, installing sheet piles, and discharging about 10,276 cy of dredged material into 0.48 acres of navigable waters of the U.S.
AUTHORITY(S): This permit application will be reviewed under Section 404 of the Clean Water Act (“CWA”; 33 USC § 1344) and Section 10 of the Rivers and Harbors Act of 1899 (“RHA”; 33 USC § 403). The Corps’ public interest review will consider the U.S Public Notice of Application for Permit Environmental Protection Agency’s guidelines set forth under Section 404(b)(1) of the Clean Water Act (40 CFR part 230).
EVALUATION FACTORS: The decision whether to issue a permit will be based on an evaluation of the probable impacts, including cumulative impacts, of the proposed activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefits, which reasonably may be expected to accrue from the proposal, must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered, including the cumulative effects thereof; among those are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership, and, in general, the needs and welfare of the people.
The Corps is soliciting comments from the general public, Federal, Territory and local agencies and officials, and other interested parties in order to consider and evaluate the impacts of this activity. Any comments received will be considered by the Corps to determine whether to issue, modify, condition or deny a permit for the work. To make this decision, comments are used to assess impacts on endangered species, historic properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are used in the preparation of an Environmental Assessment and/or an Environmental Impact Statement pursuant to the National Environmental Policy Act. Comments are also used to determine the need for a public hearing and to determine the overall public interest of the activity.
PROJECT DESCRIPTION: The applicant proposes to conduct three geotechnical investigative borings that would assess the existing subgrade soil conditions and confirm the founding depth of firm bearing materials for end-bearing piles in Pago Pago Harbor at the Malaloa Wharf. Following completion and analysis of the geotechnical borings, the ASG-DPA would commence dredging and filling activities to construct an approximate 453-foot-long and 46-foot-wide wharf extension. Based on the geotechnical findings, the work would involve one of two designs: (1) a sheet pile wharf or (2) a pier extension on piles. The former is the applicant’s preferred alternative, but is considered to be the worst case scenario in terms of dredging and filling impacts on the aquatic environment. Therefore, this public notice addresses the sheet pile wharf alternatives since it represents the greatest impact to navigable waters of the U.S. The sheet pile alternative would require the dredging of approximately 10,930 cy of harbor sediments within an approximate 1.12-acre area resulting in 1.12 acres of temporary impacts to navigable waters of the U.S. In addition, the work would entail placing (discharging) 10,276 cy of dredged sediments at the western edge of the existing wharf for the base of the new wharf extension that would permanently impact 0.48-acre of navigable waters of the U.S. An additional 0.81 acre of navigable waters of the U.S. would be temporarily affected by placing discharging) dredged material into the inner access channel as it is being dredged (see “Construction Methodology” below for details). Steel sheet pile sections would enclose the new wharf extension on three sides, and would connect to the west end of the existing wharf structure. The sheet piles would be vibrated to a specified depth and supported at the top by tie rods attached to continuous double channel waters. The wharf would be filled with dredged sand and imported granular material and a reinforced concrete slab would be placed on the grade deck (refer to Attachment).
Construction Methodology. Dredging of the inner access channel would be carried out concurrently with the construction of the new wharf extension. Wharf construction would begin from the western edge of the existing wharf with construction of a soil berm that coincides with the centerline of
the new wharf deck. The fill material used for the berm would be comprised of a mixture of imported rock to provide better stability, and sand dredged from the inner access channel.
The berm would provide a working platform from which a crane would position itself, set up, and drive the new steel sheet piles along both sides of the berm for the length of the new wharf. As platform construction and sheet pile driving proceeds at the wharf site, a pair of temporary, parallel soil berms would be constructed within the inner access channel. Material excavated from the seabed would be used to construct the temporary berms, with the balance of the material transferred to the wharf extension for use as fill material. Once partial dredging of the inner access channel reaches the westernmost limit, the temporary berms would be removed and the material hauled to the wharf. Surplus dredged material would be transported off site for disposal at the ASG-owned landfill site located in Futiga. Imported granular material specified for the wharf slab sub-base would be sourced from existing, privately-operated quarries on the Island.
Construction Schedule. The applicant estimates the total length of in-water construction work would be approximately three months.
Best Management Practices (BMPs). Turbidity containment devices (silt curtains) would be placed around the area of construction, including the dredging footprint and the areas where fill material would be placed and sheet piles installed for the wharf extension. The silt curtains would be located a minimum of 25 feet from the edge of the dredging or the boundary of the placement of fill material. The curtains would be supplied in 100-foot-long sections with anchor buoys also positioned on 100- foot centers. The silt curtains would extend to the seafloor and be removed upon completion of all in-water work. In addition to silt curtains, the applicant proposes to implement numerous other standard BMPs, as recommended by the National Oceanic and Atmospheric Administration-National Marine Fisheries Service (NMFS), for the protection of federally listed marine species and avoidance and minimization of adverse effects on essential fish habitat. Avoidance and minimization measures that are considered to be part of the applicant’s proposed action are further discussed below under section titled “Mitigation”.
Proposed Activity(s) Requiring DA Authorization. The applicant has applied for DA authorization to conduct work in navigable waters of the U.S. and discharge dredged and fill material into waters of the U.S. that would permanently impact a total of 0.48-acre of waters of the U.S. and temporarily affect 1.93 acres of waters of the U.S. Table 1 below summarizes the anticipated impacts to waters of the U.S.
Table 1 – Summary of Impacts to Waters of the U.S. Option 1 (Applicant’s Preferred Alternative) – Sheet Pile Wharf Extension
PROJECT PURPOSE AND NEED:
Applicant’s Proposed Project Purpose and Need: According to the DA permit application (ENG Form 4345), the purpose of the project is to provide an extension to the existing wharf that will accommodate fishing vessels, such as longliners and purse seiners, that enter into port to unload their catch at the tuna cannery.
Corps’ Basic and Overall Project Purpose: The basic project purpose is defined by the Corps and is used to determine whether a project is “water dependent” and requires access or proximity to, or siting within, a special aquatic site1 in order to fulfill its basic purpose. An activity that is not water dependent (that is, does not require siting in a special aquatic site) may still be authorized as long as the U.S. Environmental Protection Agency’s Section 404(b)(1) Guidelines (“404(b)(1) Guidelines”) presumption against such discharges is successfully rebutted, the discharge meets other criteria of the 404 (b)(1) Guidelines, the activity is not contrary to the public interest, and it satisfies all other statutory and regulatory requirements. For the proposed Malaloa Wharf Extension project, the basic project purpose is “navigation for interstate commerce”, a non-water dependent activity that does not require siting in a special aquatic site.
1 Special aquatic sites include sanctuaries and refuges, wetlands, mud flats, vegetated shallows, coral ol complexes (40 CFR 230.40-45)
The overall project purpose serves as the basis for the Corps' 404(b)(1) alternatives analysis and is determined by further defining the basic project purpose in a manner that more specifically describes the applicant's goals for the project, and which allows a reasonable range of alternatives to be analyzed. The overall project purpose is used to evaluate less environmentally damaging practicable alternatives and applies to all waters of the U.S., not just special aquatic sites. The Section 404(b)(1) Guidelines state that an alternative is practicable if it is available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes. The Corps has generally concurred with applicant’s stated project purpose (above) and as such, has determined the overall project purpose for evaluation of alternatives under the Section 404(b)(1) Guidelines as follows:
“To improve fishing vessel access and increase operational efficiencies in Pago Pago Harbor by accommodating longliners and purse seiners that enter the harbor to unload daily catches for processing at the tuna cannery”.
General Site and Project Area Conditions. Pago Pago Harbor is a relatively large and deep inlet along the southeast shore of Tutuila Island forming an extensive naturally protected deep water harbor. There is natural sedimentation caused by highly erosive soils on steep slopes and increased surface runoffs due to extensive urbanization. Nearshore water quality has also been severely degraded by nutrient and chemical discharges by the
tuna canneries and other historical industrial and commercial activities adjacent to the harbor.
Biological Resources. There is only one species of seagrass on the Island of Tutuila, Halophila ovalis, occurring in very narrow, pot-sized beds in the Pago Pago Harbor. This species is usually observed as very small patches near the shore of sediment-laden habitats. Almost nothing is known of its ecology in American Samoa except that the species is characterized by high turn-over based on observations.
Coral reef and hard bottom structures together comprise approximately 44% of the area within Pago Pago Harbor. Coral reef structures comprise approximately 33% of the area and include aggregate reef (~18%) and aggregated patch reefs (~15%). In addition, a large portion (approximately 37%) of
the benthic habitat within the Pago Pago Harbor is covered by mud. Also of note, 15% of the mapped benthic habitat within the harbor is of unknown structure type due to high turbidity.
A benthic survey of the proposed Malaloa Wharf Extension project area was conducted on August 2, 2018 by use of a remotely operated underwater device (ROV) (DMWR 2018). The results of this survey confirmed the presence of expected indicators of a highly stressed environment. Based on the ROV video and still photos captured from the video, ASG-Department of Marine and Wildlife Resources (DMWR) characterized and quantified the habitat types using Coral Point County with Excel Extensions (CPCe) software. Six substrate/habitat categories were identified with varying percent cover: sand, pavement, rubble (89.2%), dead coral with algae (7.3%), live hard corals (1.4%), coralline algae (0.8%), other live (1.0%), and macroalgae (0.4%). Two species of corals were noted by DMWR biologists, but they are not federally listed, nor have they been petitioned as endangered or threatened. Relatively undisturbed coral reefs in American Samoa have approximately 30% live coral cover. The live hard coral cover found at this location is drastically low (1.4%) compared to the mean, suggesting the water quality in the project area is degraded and subject to anthropogenic disturbances that adversely impact habitat suitability for corals.
DMWR also conducted underwater monitoring of the deeper area adjacent to the proposed wharf extension. DMWR documented their observations with underwater photos and then analyzed the benthos from ten randomly-generated points from 163 photos/frames (total of 1,630 data points). Fifty- two (52) photo-quadrats were analyzed and resulted in classified substrate from 520 randomly-assigned points. Following analysis, six substrate/habitat categories were identified in the action area with varying percent cover. The benthos characteristics of the deeper seaward side of the proposed project include coral (0.06%), macroalgae (20.25%), other live (0.25%), dead coral with algae (0.49%), and sand/pavement/rubble (78.96%). The presence of acroalgae (Halimeda) is often an indicator of nutrient input. The cover of the benthos categories indicate a highly stressed environment within areas that surround Malaloa Wharf, including those areas proposed for dredging and filling.
On April 3, 2019, DMWR performed an additional in-water survey (snorkeled) of the project site that specifically targeted the submerged areas proposed for dredging (DMWR 2019). During this survey, the DMWR observed the presence of coral colonies within the dredging footprint and quantified the
number of colonies as well as recorded their GPS locations. Table 2 below lists the coral species and abundance within the proposed project action area.
Table 2 – Observed Coral Species and Number of Colonies
Although there is no suitable nesting or haul out habitat features for sea turtles in the action area, one transient hawksbill sea turtle (Eretmochelys imbricata) was previously observed swimming within the proposed project area. Fish species observed within the project area were mostly of site‐attached damselfishes, cardinal fishes, some generalist‐feeding butterfly fishes, wrasses, surgeon fishes and a bream that is usually found in sandy/muddy areas.
MITIGATION: The applicant’s proposed mitigation (i.e., avoidance, minimization, and compensation) may change as a result of comments received in response to this public notice, the applicant's response to those comments, and/or the need for the project to comply with the Section 404(b)(1) Guidelines and the public interest review factors. In consideration of the above, the proposed mitigation sequencing as applied to the proposed project is summarized below.
Avoidance and Minimization. To avoid and minimize impacts to the aquatic environment, the applicant has proposed BMPs that would be included in the contract documents and implemented during the construction of the proposed project. These BMPs are considered to be part of the applicant’s
proposed action and include, but are not limited to, the following measures:
• Turbidity containment devices (silt curtains) will be placed around the area of construction, including the dredging footprint and the areas where fill material will be placed for the wharf extension.
• The project manager will designate competent observers to survey the areas adjacent to the proposed action for sea turtles and federally listed marine mammals. Surveys for federally listed marine species will be made prior to the start of work each day, and prior to resumption of work following any break of more than one half hour. Periodic additional surveys throughout the work day are strongly recommended. Observers will monitor for the presence of protected species each day of active construction from 30 minutes prior to commencement of work until 30 minutes after shut-down.
• All work will be postponed or halted when sea turtles and/or federally listed marine mammals are within 150 feet of the proposed work area, and will only begin/resume after the animal(s) have voluntarily departed the area. With the exception of pile-driving and heavy lifting, if sea turtles and/or federally listed marine mammals are within 150 feet of the work area after work has already begun, that work may continue if, in the best judgment of the project supervisor, the activity would not affect the animal(s). For example; wholly above-water work or divers performing surveys or minor underwater work would likely be permissible, whereas in-water operation of heavy equipment would not be prudent.
• Any pile driving will be postponed or halted when any federally listed marine mammals are within 300 feet, and any sea turtles are within 150 feet of the proposed work.
• Any pile driving will employ soft-start or ramp-up techniques (slow increase in hammering intensity), at the start of each work day or following any break of more than 30 minutes.
• Construction work will not be conducted after dark unless work has proceeded uninterrupted since at least 1 hour prior to sunset, and no sea turtles or federally listed marine mammals have been observed near the 150- and 300-feet safety ranges.
• Special attention will be given to verify that sea turtles and/or federally listed marine mammals are not present in the area where equipment or materials (i.e. piles, spuds, or anchors) are expected to contact the substrate before that equipment/material may enter the water.
• To the extent practicable, equipment and material will be lowered to the bottom in a controlled manner. This can include the use of cranes, winches, or other equipment that affect positive control over the placement and rate of decent. Visual monitoring will occur and include ongoing inspections for turbidity outside of the confines of the silt curtain(s). In the event that turbidity is observed outside of the silt curtains, work will stop, and the silt curtains will remain in place until the turbidity dissipates. Silt curtains will be inspected after dissipation and prior to returning to project operations;
• In-water tethers, as well as mooring lines for vessels and marker buoys will be kept to the minimum lengths necessary, and will remain deployed only as long as needed to properly accomplish the required task.
• When piloting vessels, vessel operators will alter course to remain at least 300 feet from whales, and at least 150 feet from other marine mammals and sea turtles.
• Reduce vessel speed to 10 knots or less when piloting vessels at or within the ranges described above. Operators shall be particularly vigilant to watch for turtles at or near the surface in areas of known or suspected turtle activity, and if practicable, reduce vessel speed to 5 knots or less.
• If despite efforts to maintain the distances and speeds described above, a marine mammal or turtle approaches the vessel, the engine will be put in neutral until the animal is at least 50 feet away, and then slowly move away to the prescribed distance.
• Marine mammals and sea turtles will not be encircled or trapped between multiple vessels or between vessels and the shore.
• No construction personnel will attempt to feed, touch, ride, or otherwise intentionally interact with any ESA-listed marine species.
• All equipment and material will be free of contaminants of any kind including: excessive silt, sludge, anoxic or decaying organic matter, clay, dirt, oil, floating debris, grease or foam or any other pollutant that would produce an undesirable condition to the shoreline or water quality. The equipment will be brought to the site in clean condition;
• A contingency plan to control toxic materials will be developed and followed to prevent toxic materials from entering or remaining in the marine environment during the project.
• Appropriate materials to contain and clean potential spills will be stored at the work site, and be readily available.
• All project-related materials and equipment to be placed or operated in the water will be free of pollutants.
• The project manager and heavy equipment operators will perform daily pre-work equipment inspections for cleanliness and leaks. All heavy equipment operations will be postponed or halted should a leak be detected, and will not proceed until the leak is repaired and equipment cleaned.
• Fueling of land-based vehicles and equipment will take place at least 50 feet away from the water (and away from drains), preferably over an impervious surface. Fueling of vessels will be done at approved fueling facilities.
• A plan will be developed and followed to prevent debris and other wastes from entering or remaining in the marine environment during project construction. All debris, unsalvageable dock materials, and general wastes will be properly contained and disposed of at an approved upland
disposal site. All materials will be free from any objectionable sludge, oil, grease, scum, excessive silt, organic material or other floating material;
• Runoff, turbidity and siltation from project-related work will be minimized and contained through the appropriate use of erosion control practices, effective silt containment devices, and the curtailment of work during adverse weather and tidal/flow conditions. The contractor will be
required to install and maintain full- depth turbidity curtains around the project sites during the course of the construction.
Compensation. Compensatory mitigation can be required by the Corps to ensure an activity requiring a Section 404 of the CWA permit complies with the Section 404(b)(1) Guidelines. Compensatory mitigation can also be required for projects requiring authorization under Section 404 of the CWA
and/or Section 10 of the RHA to ensure the activity is not contrary to the public interest. The Corps can also require compensatory mitigation to satisfy other legal requirements (see 33 CFR 320.4(r) and 332.1(c)-(d)).
According to the applicant’s mitigation statement on the DA permit application (ENG Form 4345), compensatory mitigation is not warranted for the proposed project because a silt boom would be placed around the perimeter of the site, landward and seaward of the activity, for the duration of the construction. However, subsequent to this statement, the applicant consulted with the DMWR and was informed that a recent survey of the proposed dredging and construction footprint revealed a reef bank supporting approximately 647 coral colonies. As a result of this information, the applicant augmented the mitigation statement to include additional mitigation that would involve measures to further avoid, minimize and possibly compensate for adverse impacts on coral colonies.
Working on behalf of ASG-DPA, the DMWR prepared a draft mitigation plan to offset the unavoidable functional losses of the coral colonies. The draft Malaloa Wharf Extension Project Mitigation Plan (DMWR 2020) proposes to relocate over 600 coral colonies from the dredging site and develop a pilot
coral reef nursery at a receptor site preferably located within the Pago Pago watershed. According to the draft plan, the identification of a suitable mitigation site would adhere to the decision-making tree and guidelines prescribed by Edwards and Gomez (2001). The Permittee-responsible draft mitigation plan is currently under review by the Corps and will be circulated to federal resource agencies for review and comment as soon as is practicable. Should the Corps determine compensatory mitigation is appropriate and practicable, a final compensatory mitigation plan addressing the
required elements at 33 CFR 332 would need to be approved by the Corps before issuance of a final individual permit decision.
WATER QUALITY CERTIFICATION: A final DA permit decision for the proposed work will not be issued until an individual water quality certification (WQC), or waiver thereof, as required under Section 401 of the Clean Water Act has been issued by the American Samoa Government, Environmental
Protection Agency (ASG-EPA). Based on information contained in the DA permit application, the applicant submitted a Section 401 WQC application to the ASG-EPA and received an individual certification on October 2, 2018. Since a DA permit decision has not yet been made, the conditions
contained within the 401 WQC would be incorporated by reference into the DA permit should the Corps’ final permit decision be to issue a DA permit (with or without special conditions).
COASTAL ZONE MANAGEMENT ACT CERTIFICATION: Section 307(c)(3) of the Coastal Zone Management Act of 1972, as amended (16 U.S.C. 1456(c)(3)) requires the lead federal action agency to certify that the described activity affecting land or water uses in the coastal zone complies with the State/Territory’s Coastal Zone Management (CZM) Program. A final DA permit decision for the proposed work will not be issued until the applicant obtains a Federal consistency concurrence from the ASG- Department of Commerce (ASG-DOC). The applicant submitted an application to the ASG-DOC for CZM federal consistency review and received concurrence on May 13, 2019. Since a DA permit decision has not yet been made, the conditions contained within the ASG-DOC’s CZM consistency concurrence would be incorporated by reference into the DA permit should the Corps’ final permit decision be to issue a DA permit (with or without special conditions).
CULTURAL RESOURCES & HISTORIC PROPERTIES: Section 106 of the National Historic Preservation Act (NHPA) of 1966, requires Federal agencies to take into account the effects of their undertakings on historic properties and afford the Advisory Council on Historic Preservation a reasonable opportunity to comment on such undertakings. The Department of the Interior – Office of Insular Affairs (DOI-OIA) is the lead federal agency for the proposed Malaloa Wharf Extension project. As the lead federal agency, DOI-OIA will act on the Corps’ behalf to identify whether historic properties, or properties eligible for listing on the National Register of Historic Places, are present within the area of potential effect, and as appropriate, will consult with the American Samoa Historic Preservation Officer (ASHPO). A DA permit decision for the proposed activity will not be issued until the consultation process is completed and the lead federal agency provides documentation to the Corps of its compliance with Section 106 of the NHPA. In addition, this public notice is being coordinated with the ASHPO and the public. Any comments that the ASHPO or the public may have concerning unknown archeological or historic properties, including properties of traditional religious or cultural importance, and that may be affected by the proposed undertaking, will be considered in our public interest review determination, EA, and final permit decision.
ENDANGERED SPECIES: Section 7 of the Endangered Species Act (ESA) of 1973, as amended, requires Federal agencies to consult with NMFS and/or U.S. Fish and Wildlife Service (USFWS) on all federal actions that may affect species listed (or proposed for listing) as threatened or endangered or that may destroy or adversely modify their designated critical habitat. The DOI-OIA is the lead federal agency for the proposed Malaloa Wharf Extension project. As the lead federal agency, DOI-OIA will act on the Corps’ behalf to identify threatened and endangered species that are known to occur or have the potential to occur within or near the action area and as appropriate, consult with NMFS and/or USFWS. A DA permit decision for the proposed activity will not be issued until the consultation process is completed and the lead federal agency provides documentation to the Corps of its compliance with Section 7 of the ESA.
ESSENTIAL FISH HABITAT: Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), requires Federal agencies to consult with the NOAA Fisheries on all actions, or proposed actions, permitted, funded, or undertaken by the agency, that may adversely affect essential fish habitat (EFH). The DOI-OIA is the lead federal agency for the proposed Malaloa Wharf Extension project. As the lead federal agency, DOI-OIA will act on the Corps’ behalf to identify the presence of EFH and determine the potential for adverse effects to EFH. A DA permit decision for the proposed project will not be issued until the EFH consultation process is completed and the lead federal agency provides documentation to the Corps of its compliance with Section 305(b)(2) of the MSA, including agency responses to EFH conservation recommendations should they be provided to DOI-OIA by NMFS.
PUBLIC HEARING: Any person may request, in writing, within the comment period specified in this notice, that a public hearing be held to consider this application. Requests for public hearings must state clearly and concisely, the reasons and rationale for holding a public hearing. The District Engineer will then decide whether a hearing should be held.
COMMENT AND REVIEW PERIOD: Comments on this public notice must be made in writing and submitted via conventional mail or electronic mail (e-mail). Comments received during the review period will be made part of the record and will be considered by the Corps in determining whether it would be in the public interest to authorize this proposal.
Comments sent by conventional mail should include your name, return mailing address, phone number, and reference to DA File No. POH-2018-00162 and be sent to:
U.S. Army Corps of Engineers, Honolulu District Regulatory Office (CEPOH-RO)
Attn: Susan A. M. Gayagas / Building 230
Fort Shafter, Hawaii 96858-5440
Alternatively, comments sent electronically may be emailed to email@example.com. If using email, you must include the DA File No. “POH-2018-00162” in the subject heading of the email along with your name, mailing address and phone number. In order to be accepted, e-mail comments
must originate from the author’s e-mail account.
All comments, whether transmitted by conventional mail or e-mail, must be received by our office by the close of business (5:00 p.m. Hawaii-Aleutian Standard Time) on May 20, 2020.
This public notice is issued by the Chief, Regulatory Office.