Can the Trump Administration save Honolulu from wasting $2.5B on Sand Island Sewage Plant?
by Andrew Walden
Can the Trump Administration save Honolulu from wasting $2.5B on an unnecessary Sand Island sewage treatment upgrade?
On December 5, 2024, his last day in office, Councilmember Calvin Say proposed Resolution 287. Approved by Honolulu Council members December 11, 2024, Resolution 287 urges the Blangiardi Administration to request modification of the 2010 Consent Decree which mandates the Sand Island project.
The cost of the Sand Island upgrade aligns with the Council’s dispute with the Blangiardi administration over the amount of sewer fee increases to be forced upon Oahu ratepayers.
The Blangiardi administration has since October been pushing a 224% increase in sewer fees to fund $10.1B in sewer projects--including Sand Island.
On May 27, 2025, the Council Budget Committee, 4-1, approved a 160% sewer rate hike. Backers of the council plan insist funding for the Sand island project is part of their proposal.
But if the Trump administration agrees to amend the consent decree, the council’s fee hikes would conveiniently provide funds for all of the lesser projects which have been ‘Christmas Treed’ onto the Sand Island project.
Introduced as testimony at the Council Budget Committee hearing, the following letter to EPA from members of the ‘Department of Environmental Services’ Sewer Fee Advisory Group for the City and County of Honolulu’ has all the details.
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TO: Jamie Piziali, Municipal Ombudsman Office of the Municipal Ombudsman U.S. Environmental Protection Agency
Aloha Municipal Ombudsman Piziali,
My name is Frank Doyle, I am currently a member of the Department of Environmental Services’ Sewer Fee Advisory Group for the City and County of Honolulu (CCH). During my 42 years of satisfying and rewarding service to the CCH, I served as the Director of the Department of Environmental Services, as well as Chief of the Divisions of Collection System Maintenance and Wastewater Treatment and Disposal. I am presently collaborating with a group of science and engineering colleagues seeking to reinstate the 301(h) Waiver from secondary treatment for Sand Island Wastewater Treatment Plant that was originally included in the City’s NPDES Permit for that facility.
We understand that we may request the assistance of the Municipal Ombudsman when we have not had success with the existing EPA avenues for addressing our Clean Water Act concerns. Over the past 15 years, our group and others, have requested in writing and oral testimony to Federal, State and City bodies that the 2010 Consent Decree be modified to remove the requirement for secondary treatment at the Sand Island WWTP and the 301(h)Waiver be reinstated. To date, our concern has not been resolved through regular avenues, and therefore our request for assistance to you. This letter provides our argument for the reinstatement of the Waiver and, given the new administration’s effort to reduce wasteful spending, the opportunity for private citizens to make our appeal and for it to be heard.
In 2010, the CCH was required to enter a Consent Decree with the EPA mandating secondary treatment at the Sand Island WWTP by 2035. Since 1981, this treatment plant has been providing advanced primary treatment with its effluent being discharged into the deep ocean, approximately 1.5 miles offshore at a depth of 240 feet. Until 2010, the Sand Island WWTP operated under an EPA permit that waived secondary treatment because CCH was able to demonstrate no harm to public health or the ocean environment resulting from advanced primary treatment and deep ocean discharge. Over the past 40 years, oceanographic monitoring has confirmed these findings. Additionally, the CCH has not been cited for any public health issues in the near shore waters of Māmala Bay, nor for any environmental impacts within the zone of mixing at the effluent discharge. This validates there are no public health or environmental issues to be mitigated by the addition of secondary treatment at Sand Island WWTP.
Since entering the Consent Decree, the City has completed billions of dollars of improvements to sewer collection system and treatment plant operations and has essentially complied with the Decree requirements except for its largest project, secondary treatment at Sand Island remaining. During negotiations and after the Consent Decree was enacted, argument has been made that secondary treatment was unjustified.
Despite all the evidence presented, the EPA denied the CCH’s application for a 301 (h) waiver from secondary treatment at Sand Island WWTP in 2010. This denial was based on the agency’s unfunded mandate for secondary treatment at all municipal sewage treatment plants throughout the United States regardless of unique geographic circumstances. The Alliance of EPA Regulators and various Environmental groups that advocate for increased regulation, including Best Available Treatment, has over the past 50 years placed a tremendous financial burden on communities throughout the country by calling for increased regulation of air, water and sewage facilities, without exception. In some cases, such as Sand Island WWTP, the regulations have been unwarranted, costing taxpayers billions of dollars at the State, County and City government levels. In addition, the annual and ever-increasing costs for operating and maintaining these facilities to meet these requirements are very expensive, and in some cases unaffordable to many communities.
At Sand Island WWTP, Phase I construction of secondary facilities to treat 20 million gallons per day is underway at a cost of $500 million. Phase II will expand secondary capacity to 80 million gallons per day at an estimated construction cost of $2.5 billion, which will add unwarranted and unjustified financial burdens to taxpayer financial woes in perpetuity. As a group of Hawaii environmental scientists and wastewater engineers, we are requesting EPA and if necessary, Congress, to reinstate the CCH’s previous 301 (h) Permit Waiver of secondary treatment at Sand Island WWTP, like that accomplished by the City of San Diego in 2019. At that time, San Diego obtained an exemption to the Clean Water Act for its Point Loma Plant effluent discharge and was able to reinstate the Permit Waiver for secondary treatment for that plant. We understand there are wastewater treatment facilities in Alaska, Maine and the territories of American Samoa and Guam that have Waivers from secondary treatment as well.
Our group seeks to remove these unjustified regulations that ignore the science underlying the unique oceanographic features associated with the Sand Island WWTP. The cost of secondary treatment at the Sand Island WWTP cannot be justified based on public health and environmental protection, which can be the only basis for justifying a project of this costly magnitude.
In its effort to reduce proposed Sewer Fee charges, the Honolulu City Council on December 11, 2024, adopted Resolution 287 “urging the Administration to initiate discussions with the U.S. Environmental Protection Agency, the State of Hawaii Department of Health and other pertinent parties to terminate, modify or extend the compliance deadlines of the 2010 Consent Decree relating to the City and County of Honolulu Wastewater system”. By this action the Council is basically seeking relief from the 2010 Consent Decree requirements and specifically the requirement to provide secondary treatment of sewage at the SIWWTP. The removal of the requirement to provide secondary treatment at the SIWWTP would reduce the cost of the Sewer Free increase by approximately 25 percent.
Our group supports Council Resolution 287. Further we believe that Consent Decree Paragraph 97 MODIFICATION may well serve as a vehicle for the City Administration to move forward with Council Resolution 287. Paragraph 97 states: “The terms of this Consent Decree, including compliance schedules, may be modified, as provided in this Paragraph, by a subsequent written agreement signed by the United States, the State, and CCH. Time extensions and modifications to proposed project scopes shall not be construed as material modifications to this Consent Decree. Any non-material modifications to the Consent Decree may be made, without Court approval, by a written agreement signed by the United States, the State, and CCH, and shall be effective upon service to all the Parties; provided, however, the Intervenors may raise the issue of the materiality of the modification by invoking dispute resolution pursuant to Section XII (Dispute Resolution) of this Decree.”
In addition, we understand that the Water Infrastructure Improvement Act (WIIA) (HR 7279), allows municipalities to use Integrated Planning to meet CWA requirements. The City Department of Environmental Services (ENV) has completed its Integrated Planning Feasibility Study Final Report which recommended ENV pursue an integrated planning process. It is our understanding that ENV intends to prepare a more comprehensive and detailed Integrated Planning document. We are encouraged that through this process the CCH may revisit its CWA obligations and schedules for both wastewater and storm water to rearrange projects that prioritize community defined objectives and maximize their investments to achieve greater water quality and human health benefits. We are confident that through the Integrated Planning process, the EPA’s review of Consent Decree requirements, for Honolulu and other Cities, may save millions in unjustified expenditures and provide real benefits for dollars spent.
As private citizens who have a deep concern for our community, we believe we have a right to expect responsible stewardship by our governmental leaders and therefore are reaching out to you with our concerns. Kindly provide detailed guidance on the required steps for the City to obtain a waiver from secondary treatment at Sand Island.
Colleagues in our group who have endorsed this letter include:
Dr. James Kumagai, PhD, PE • Former Deputy Director of Environmental Programs, Hawaii Department of Health • Principal Investigator, Water Quality Program for Oahu (1971) WEF Fellow
Dr. Hans Krock, PhD, PE • Emeritus Professor of Ocean and Resources Engineering, University of Hawaii at Mānoa • Architect of Water Quality Standards for the State of Hawaii
Dr. Victor Moreland, PhD, PE • Former Research Associate at the Water Resources Research Center, University of Hawaii at Mānoa • Certified Grade 4 Wastewater Treatment Plant Operator, State of Hawaii
Mr. Eassie Miller, MS, PE • Former Wastewater Operations Superintendent, City and County of Honolulu • Former Chief of the Division of Wastewater Reclamation, County of Maui • Certified Grade 4 Wastewater Treatment Plant Operator, State of Hawaii
Dr. Michael J. Chun, PhD, PE • Former Director of Public Works, City and County of Honolulu
Mahalo nui loa for hearing our concerns and for any guidance you can provide to our group as we continue to press forward with this matter.
Me ka haahaa,
Frank Doyle
LINK: Testimony May 27, 2025 Council Budget Ctte hearing
LINK: Resolution 287