I have worked on environmental mitigation efforts in the fires in Santa Cruz, California, and as well have worked on Maui for years helping to build 16 school and community gardens across Maui and Lanai.
There has been a lot of talk today about monitoring the disaster that will happen when it rains. What isn't getting enough attention is that this disaster can be avoided by taking the right action now. We can absolutely mitigate this disaster. In Santa Cruz, we were able to collect data showing an 80% reduction in toxic chemicals after filtration using correct materials (compost, charcoal, biochar) in erosion socks placed around every burnsite to capture and filter water before it enters the environment.
The top priority needs to be to cover every burned building and vehicle with either the soiltac or tarps or both, then getting funding and all hands on deck mobilization of everyone with the ability to gather materials, fill erosion socks and place them on the down slope of every burnsite and multiple layers of filtration around every storm drain and runoff point onto shoreline or open soil.
Given the limited time before a potential rain event, Soiltac looks like the best option. In consideration of concerns about the product I have collected as much information about it as possible, including comments directly from the CEO of Soilworks addressing concerns in the community. None of the concerns appear to be valid, and seem to be coming more from a lack of communication and knowledge. Seeing how well it has worked to hold all the ash in place in Kula this product would do an amazing job of keeping toxic ash out of the environment. To clarify, I am an organic farmer and 100% the use of any toxic chemicals on the environment, and still think this is the best solution.
My team and I have written up an action plan based on all the knowledge we have gained from keeping multiple recent wildfires of how to do a comprehensive mitigation of chemicals entering the environment that goes above and beyond the standard practices which have not been used in such a sensitive environment as Lahaina. Happy to share all knowledge we can to get things in place before it rains.
If you do this you can, and get these measures in place before the next rain we can highly mitigate the disastrous impact on environment all the chemicals would have entering the ocean and groundwater.
Mahalo,
Christopher Justice Carlson
globalevolution@gmail.com
707-235-8383
My house in Kula burned down the same day as the Lahaina fires.
Needless to say, it was an unspeakable shock, and the ramifications
keep coming in layers even nearly two months later.
A few weeks after the fire, our Kula community met with the EPA and
Army Corps of Engineers to discuss “debris removal” options, because
we canʻt move forward with ANYthing until we get the piles of fire
debris off our land. Although I know the Army Corps is experienced and
would do a good job, I was hoping to just rent a giant construction
container and do the job myself with a small team of guys and a rented
back hoe. The EPA and Army Corps were pushing for all the burn sites
on my block to use Soiltak - a plastic polymer spray that would “batten down”
the ashes and make it safer and easier for the debris to be removed. Being a
pretty strong environmentalist, I did not want a plastic polymer sprayed anywhere
near my land.
And then I started hearing about “Bill 86” - this is a Bill the County
devised to “theoretically” make it possible for private individuals, such as myself,
to use “alternate methods” for debris removal, but in fact, the Bill makes it nearly
impossible for private owners to do this job on their own, because Bill 86 is
filled with so many rules and regulations, a normal individual such as myself would
never be able to follow all the regulations without getting totally bogged down.
The Bill passed last week, and I realized I pretty much had no choice at this point
but to go with the Army Core Of Engineers, and they were really pushing the idea
of getting the Soiltak sprayed on our burn sites.
I want my land cleared as quickly as possible, and I suspect the Corps will either
*require* the Soiltak for them to do the job, or at the very least, favor the people who
have accepted the Soiltak option. So, in order to move forward, despite my earlier
resistance, I let the EPA come and spray the Soiltak on my burn site. First, I want to
say that they were VERY agreeable to not spraying any plants or grass near the burn site,
they listened to my directions and honored them to the letter. In fact, the spray was so
simple and minimal, I donʻt even SEE it now that itʻs done. They were very careful to not
let any “overspray” get on my bare land, or places where plant life still lives.
So after being very against the idea, and even worried about it, I found the Soiltak
application process to be literally painless, and now I am eligible to have the debris
pile removed by the Army Corps, and it will be safer for them to do so, as the ash will
not be flying around so much when they come to do the removal.
If things go well, and the Army Corps comes to remove the fire debris in the next month
or two, the Soiltak will not have time to disintegrate into my land. It will be carried away
with all the other toxic debris and deposited wherever the County makes room for such
things. So for the time being, Iʻve gone from “dead set against it”, to actually glad that I
let them spray the Soiltak. If the Army Corps moves relatively quickly, I know I will not
regret my change of heart.
I donʻt want Soiltak to reach the ocean.... but I donʻt want the toxix fire debris
to reach the ocean either - so letʻs get it sprayed in Lahaina, and then quickly
removed to the assigned dump site. MAHALO!
Aloha Committee Chair Johnson, Vice-Chair Sinenci and Council Members,
My name is Makana. I am a community, cultural and environmental advocate and professional entertainer dedicated to the perpetuation of Hawaiian traditions. I am urging the full securing of the toxic ash in Lahaina as an immediate priority and action, increasing the scope of filtration socks to filter and abate stormwater runoff, and establishment of temporary retention basins. In order to prevent a secondary broad scale ecological disaster, the County and community cannot risk delay achieving 100% coverage to secure the toxic ash in place, nor any lengthy and ineffective individual opt in/opt out process.
Lahaina has not yet experienced a heavy rain post-fire. Although Lahaina is on the leeward coast and generally only experiences a few days of significant rainfall between October and January, they do happen, and there are also low pressure systems that can form and bring heavy rains. At present such a rain event could redistribute significant amounts of highly toxic ash and even debris into other locations including:
-private and public properties makai of and adjacent to the burnzones
-storm drains
-waterways
-the groundwater supply
-and the ocean.
Due to the large footprint of the burn zone and the significant amount of properties affected, the potential for a catastrophic ocean pollution event is high and deserves our immediate attention and action. Asbestos, arsenic and lead are just 3 of countless industrial chemicals and metals present in the ash. Were the ash inert (IT IS NOT) the sheer volume of ash itself could smother nearshore reef systems inciting severe ecological repercussions. Communities like Paradise, California and NYC (in the wake of 9/11) continue to experience residual health effects even years after the initial exposure events. We should work fast to protect the people and environment of West Maui from current exposure to carcinegous elements.
There are solutions that have been presented and discussed.
ON SOILTAC:
The most feasible action available- and by no means the only action necessary- which is funded and approved by the EPA and can be applied by the Army Corp of Engineers, is a binding agent that will secure the top layer of toxic ash in place until the phase of scraping and removal. By binding the top layer of ash in the footprint of all burned structures prior to a significant rain event, the County could prevent what in worse case scenario would essentially be a town-sized portion of toxic ash pouring into the ocean.
An ash binding spray called Soiltac was proposed by the EPA early on in the response process, but has been delayed partly due to concerns about its potential effects on the environment and human health, as well as the logistical issue of allowing property owners access to their properties and whether it could and should be sprayed prior to or following such. We should evaluate those concerns with information below obtained from the EPA, SoilWorks, LLC the maker of Soiltac, and homeowners in Kula who have already opted to have their properties sprayed with Soiltac.
Soiltac is one of a group of products known as “soil stabilizers” generally used on roadways to secure dust and dirt or to control erosion. Versions of this product have been used in Hawaiʻi for decades, at places like Nanea Golf Club in Kona and Mauna Kea.
A powdered formulation falls under the scope of a patent that was brought up in a previous letter by Council persons Paltin and Sinenci to the EPA. The Soiltac intended to be used to secure ash is a liquid version with a formulation distinctly different from the powdered version. Further, the patent in question is owned by a supplier to the maker of Soiltac and is not specific to the product itself.
Concerns around UV deterrents and microplastics were voiced. The liquid Soiltac version contains no UV-resistant additives. Soiltac is not a thermalplastic and is not related to polyvinyl chloride acetate or polyvinylpyrrolidone. It cannot breakdown into microplastics. In response to a recent inquiry, CEO of SoilWorks Chad Falkenberg wrote:
“Soiltac is designed to bind and stabilize surfaces, not to degrade and fragment into microplastics like many disposable plastics. We acknowledge the concerns about the impact of certain UV-resistant additives on coral reefs, especially given the issues with some sunscreens in Hawaii. We want to assure you, unequivocally, that Soiltac does not contain any UV-resistant additives.
“The application rate that is recommended for Lahaina is 100 gallons of Soiltac concentrate +11 parts water. This is a very light application designed to create a light surface crust, preventing particulates from becoming airborne and to reduce water erosion. This is very different from a Soiltac treatment on roads where we would be using heavy application rates of Soiltac up to 1,000 gallons per acre for topical treatments and 6” deep mixed-in applications ranging from 2,000 to 4,000 gallons per acre to stabilize and improve their load-bearing capacity... You will find that heavy application rates significantly modify the permeability of the ground and greatly increase surface water, runoff, and require that the design of the road includes proper crown and drainage, while the recommended low application rates are still permeable by air and water and do not negatively impact surface water runoff.”
Some community members had concerns that Soiltac would be “tilled into the soil”. To be clear, this is not part of the proposed ash application process. The spray is intended to only be applied to the top layer of ash and burned surfaces to fix contaminants at the surface and prevent them from easily becoming air or waterborne.
Soiltac has already been applied to ash on some of the properties destroyed by fire in Kula. Homeowner Andre Fehlmann offers this insight as to his decision to spray: “The ashes are way more toxic than what they ever could/would spray. Next phase of cleanup will remove it all. Up here (in Kula), it was looking out for the neighbors who would live in the toxic ashes otherwise.” Pamela Poland, another Kula homeowner who lost her home to the fire said: “I was dead set against it (Soiltac) for a variety of reasons, but I finally caved for a different variety of reasons, and I was pleasantly surprised at how simple it is, and how the EPA guys were more than willing to avoid any plant life, grasses, etc, and make sure it ONLY went on the center of the burn site. They listened to my directions and honored them to the letter.”
AIR QUALITY: Beyond mitigating influences of rain, securing ash in place facilitates a healthier air environment by keeping the ash from becoming airborne. Already many residents have been repeatedly exposed to airborne toxic ash. Optimally, to protect the health of the residents who have lost their homes and are visiting their property, it is in their best interest to minimize exposure to airborne by utilizing Soiltac to create a surface crust to cap the dangerous toxins. This surface crust can be easily manipulated and broken apart for anyone needing to disturb the area in search of belongings. Even in extreme cases where property owners disturb the majority of their property by breaking most of the surface crust created by Soiltac, they are still benefiting during the process by whatever crust is left undamaged. In addition, areas that are broken are typically broken into small pieces or fragments rather than their original fine particulate size, further supporting the ability of Soiltac to reduce toxic airborne particulates.
Concerns around plants and animals:
Plants: any overspray on plants or vegetation only leaves a film thin enough to be permeable by water and air, thus does not affect photosynthesis. This is due to the extremely light application rate as previously mentioned.
Animals: It may be in the best interest of cats and other animals persisting in the burnzone to walk on top of a Soiltac surface crust, rather than in the debris, and then cleaning themselves and digesting all of the toxins.
The soil stabilizer will only be sprayed onto the footprint of burned structures, and will be completely removed with other debris when FEMA does its phase 2 cleanup sometime in a period of months from now.
ALTERNATIVES TO SOILTAC:
WATER: Wetting down ash was suggested as an alternative to Soiltac as as an effective method to keep the ash in place. Not only does this fail to address concerns around a rain event, it can exacerbate leaching, requires repeat applications, is expensive and places further demand on already strained water resources.
TARPS: In California, Soiltac was not yet available following the wildfires. The community (and eventually government) was compelled to mobilize a large labor force to attempt to cover every single burn site with tarps secured by sandbags. In Lahaina, there is an estimated 15 million sq ft that would need to be covered by approximately 25,000 tarps and 150,000 sandbags, as well as PPE and training of a workforce which would be exposed to toxic chemicals during the work.
ON FILTRATION AND MANAGING STORM WATER RUNOFF: not included here due to website comment character limitation. Full testimony attached as PDF.
The bottomline is that the County should immediately acknowledge the severe health and environmental threat of airborne dust and ash and the potential for such to enter groundwater and the ocean. Low pressure systems will become increasingly active and could at any time bring heavy rain events to West Maui. We have a limited window to enact measures to mitigate both types of hazard. It is a blessing to have had this much time to prepare to act. Letʻs eliminate delay that risks decades of deeper and broader contamination, long term toxic clean-up site status, air and water borne transmitted health hazards and ecological destruction.
Aloha my name is Christopher Justice Carlson,
I have worked on environmental mitigation efforts in the fires in Santa Cruz, California, and as well have worked on Maui for years helping to build 16 school and community gardens across Maui and Lanai.
There has been a lot of talk today about monitoring the disaster that will happen when it rains. What isn't getting enough attention is that this disaster can be avoided by taking the right action now. We can absolutely mitigate this disaster. In Santa Cruz, we were able to collect data showing an 80% reduction in toxic chemicals after filtration using correct materials (compost, charcoal, biochar) in erosion socks placed around every burnsite to capture and filter water before it enters the environment.
The top priority needs to be to cover every burned building and vehicle with either the soiltac or tarps or both, then getting funding and all hands on deck mobilization of everyone with the ability to gather materials, fill erosion socks and place them on the down slope of every burnsite and multiple layers of filtration around every storm drain and runoff point onto shoreline or open soil.
Given the limited time before a potential rain event, Soiltac looks like the best option. In consideration of concerns about the product I have collected as much information about it as possible, including comments directly from the CEO of Soilworks addressing concerns in the community. None of the concerns appear to be valid, and seem to be coming more from a lack of communication and knowledge. Seeing how well it has worked to hold all the ash in place in Kula this product would do an amazing job of keeping toxic ash out of the environment. To clarify, I am an organic farmer and 100% the use of any toxic chemicals on the environment, and still think this is the best solution.
My team and I have written up an action plan based on all the knowledge we have gained from keeping multiple recent wildfires of how to do a comprehensive mitigation of chemicals entering the environment that goes above and beyond the standard practices which have not been used in such a sensitive environment as Lahaina. Happy to share all knowledge we can to get things in place before it rains.
If you do this you can, and get these measures in place before the next rain we can highly mitigate the disastrous impact on environment all the chemicals would have entering the ocean and groundwater.
Mahalo,
Christopher Justice Carlson
globalevolution@gmail.com
707-235-8383
COMMENTS ON SOILTAK FROM KULA HOMEOWNER
My house in Kula burned down the same day as the Lahaina fires.
Needless to say, it was an unspeakable shock, and the ramifications
keep coming in layers even nearly two months later.
A few weeks after the fire, our Kula community met with the EPA and
Army Corps of Engineers to discuss “debris removal” options, because
we canʻt move forward with ANYthing until we get the piles of fire
debris off our land. Although I know the Army Corps is experienced and
would do a good job, I was hoping to just rent a giant construction
container and do the job myself with a small team of guys and a rented
back hoe. The EPA and Army Corps were pushing for all the burn sites
on my block to use Soiltak - a plastic polymer spray that would “batten down”
the ashes and make it safer and easier for the debris to be removed. Being a
pretty strong environmentalist, I did not want a plastic polymer sprayed anywhere
near my land.
And then I started hearing about “Bill 86” - this is a Bill the County
devised to “theoretically” make it possible for private individuals, such as myself,
to use “alternate methods” for debris removal, but in fact, the Bill makes it nearly
impossible for private owners to do this job on their own, because Bill 86 is
filled with so many rules and regulations, a normal individual such as myself would
never be able to follow all the regulations without getting totally bogged down.
The Bill passed last week, and I realized I pretty much had no choice at this point
but to go with the Army Core Of Engineers, and they were really pushing the idea
of getting the Soiltak sprayed on our burn sites.
I want my land cleared as quickly as possible, and I suspect the Corps will either
*require* the Soiltak for them to do the job, or at the very least, favor the people who
have accepted the Soiltak option. So, in order to move forward, despite my earlier
resistance, I let the EPA come and spray the Soiltak on my burn site. First, I want to
say that they were VERY agreeable to not spraying any plants or grass near the burn site,
they listened to my directions and honored them to the letter. In fact, the spray was so
simple and minimal, I donʻt even SEE it now that itʻs done. They were very careful to not
let any “overspray” get on my bare land, or places where plant life still lives.
So after being very against the idea, and even worried about it, I found the Soiltak
application process to be literally painless, and now I am eligible to have the debris
pile removed by the Army Corps, and it will be safer for them to do so, as the ash will
not be flying around so much when they come to do the removal.
If things go well, and the Army Corps comes to remove the fire debris in the next month
or two, the Soiltak will not have time to disintegrate into my land. It will be carried away
with all the other toxic debris and deposited wherever the County makes room for such
things. So for the time being, Iʻve gone from “dead set against it”, to actually glad that I
let them spray the Soiltak. If the Army Corps moves relatively quickly, I know I will not
regret my change of heart.
I donʻt want Soiltak to reach the ocean.... but I donʻt want the toxix fire debris
to reach the ocean either - so letʻs get it sprayed in Lahaina, and then quickly
removed to the assigned dump site. MAHALO!
Pamela Polland
214 Kulalani Drive
Kula, Maui
Aloha Committee Chair Johnson, Vice-Chair Sinenci and Council Members,
My name is Makana. I am a community, cultural and environmental advocate and professional entertainer dedicated to the perpetuation of Hawaiian traditions. I am urging the full securing of the toxic ash in Lahaina as an immediate priority and action, increasing the scope of filtration socks to filter and abate stormwater runoff, and establishment of temporary retention basins. In order to prevent a secondary broad scale ecological disaster, the County and community cannot risk delay achieving 100% coverage to secure the toxic ash in place, nor any lengthy and ineffective individual opt in/opt out process.
Lahaina has not yet experienced a heavy rain post-fire. Although Lahaina is on the leeward coast and generally only experiences a few days of significant rainfall between October and January, they do happen, and there are also low pressure systems that can form and bring heavy rains. At present such a rain event could redistribute significant amounts of highly toxic ash and even debris into other locations including:
-private and public properties makai of and adjacent to the burnzones
-storm drains
-waterways
-the groundwater supply
-and the ocean.
Due to the large footprint of the burn zone and the significant amount of properties affected, the potential for a catastrophic ocean pollution event is high and deserves our immediate attention and action. Asbestos, arsenic and lead are just 3 of countless industrial chemicals and metals present in the ash. Were the ash inert (IT IS NOT) the sheer volume of ash itself could smother nearshore reef systems inciting severe ecological repercussions. Communities like Paradise, California and NYC (in the wake of 9/11) continue to experience residual health effects even years after the initial exposure events. We should work fast to protect the people and environment of West Maui from current exposure to carcinegous elements.
There are solutions that have been presented and discussed.
ON SOILTAC:
The most feasible action available- and by no means the only action necessary- which is funded and approved by the EPA and can be applied by the Army Corp of Engineers, is a binding agent that will secure the top layer of toxic ash in place until the phase of scraping and removal. By binding the top layer of ash in the footprint of all burned structures prior to a significant rain event, the County could prevent what in worse case scenario would essentially be a town-sized portion of toxic ash pouring into the ocean.
An ash binding spray called Soiltac was proposed by the EPA early on in the response process, but has been delayed partly due to concerns about its potential effects on the environment and human health, as well as the logistical issue of allowing property owners access to their properties and whether it could and should be sprayed prior to or following such. We should evaluate those concerns with information below obtained from the EPA, SoilWorks, LLC the maker of Soiltac, and homeowners in Kula who have already opted to have their properties sprayed with Soiltac.
Soiltac is one of a group of products known as “soil stabilizers” generally used on roadways to secure dust and dirt or to control erosion. Versions of this product have been used in Hawaiʻi for decades, at places like Nanea Golf Club in Kona and Mauna Kea.
A powdered formulation falls under the scope of a patent that was brought up in a previous letter by Council persons Paltin and Sinenci to the EPA. The Soiltac intended to be used to secure ash is a liquid version with a formulation distinctly different from the powdered version. Further, the patent in question is owned by a supplier to the maker of Soiltac and is not specific to the product itself.
Concerns around UV deterrents and microplastics were voiced. The liquid Soiltac version contains no UV-resistant additives. Soiltac is not a thermalplastic and is not related to polyvinyl chloride acetate or polyvinylpyrrolidone. It cannot breakdown into microplastics. In response to a recent inquiry, CEO of SoilWorks Chad Falkenberg wrote:
“Soiltac is designed to bind and stabilize surfaces, not to degrade and fragment into microplastics like many disposable plastics. We acknowledge the concerns about the impact of certain UV-resistant additives on coral reefs, especially given the issues with some sunscreens in Hawaii. We want to assure you, unequivocally, that Soiltac does not contain any UV-resistant additives.
“The application rate that is recommended for Lahaina is 100 gallons of Soiltac concentrate +11 parts water. This is a very light application designed to create a light surface crust, preventing particulates from becoming airborne and to reduce water erosion. This is very different from a Soiltac treatment on roads where we would be using heavy application rates of Soiltac up to 1,000 gallons per acre for topical treatments and 6” deep mixed-in applications ranging from 2,000 to 4,000 gallons per acre to stabilize and improve their load-bearing capacity... You will find that heavy application rates significantly modify the permeability of the ground and greatly increase surface water, runoff, and require that the design of the road includes proper crown and drainage, while the recommended low application rates are still permeable by air and water and do not negatively impact surface water runoff.”
Some community members had concerns that Soiltac would be “tilled into the soil”. To be clear, this is not part of the proposed ash application process. The spray is intended to only be applied to the top layer of ash and burned surfaces to fix contaminants at the surface and prevent them from easily becoming air or waterborne.
Soiltac has already been applied to ash on some of the properties destroyed by fire in Kula. Homeowner Andre Fehlmann offers this insight as to his decision to spray: “The ashes are way more toxic than what they ever could/would spray. Next phase of cleanup will remove it all. Up here (in Kula), it was looking out for the neighbors who would live in the toxic ashes otherwise.” Pamela Poland, another Kula homeowner who lost her home to the fire said: “I was dead set against it (Soiltac) for a variety of reasons, but I finally caved for a different variety of reasons, and I was pleasantly surprised at how simple it is, and how the EPA guys were more than willing to avoid any plant life, grasses, etc, and make sure it ONLY went on the center of the burn site. They listened to my directions and honored them to the letter.”
AIR QUALITY: Beyond mitigating influences of rain, securing ash in place facilitates a healthier air environment by keeping the ash from becoming airborne. Already many residents have been repeatedly exposed to airborne toxic ash. Optimally, to protect the health of the residents who have lost their homes and are visiting their property, it is in their best interest to minimize exposure to airborne by utilizing Soiltac to create a surface crust to cap the dangerous toxins. This surface crust can be easily manipulated and broken apart for anyone needing to disturb the area in search of belongings. Even in extreme cases where property owners disturb the majority of their property by breaking most of the surface crust created by Soiltac, they are still benefiting during the process by whatever crust is left undamaged. In addition, areas that are broken are typically broken into small pieces or fragments rather than their original fine particulate size, further supporting the ability of Soiltac to reduce toxic airborne particulates.
Concerns around plants and animals:
Plants: any overspray on plants or vegetation only leaves a film thin enough to be permeable by water and air, thus does not affect photosynthesis. This is due to the extremely light application rate as previously mentioned.
Animals: It may be in the best interest of cats and other animals persisting in the burnzone to walk on top of a Soiltac surface crust, rather than in the debris, and then cleaning themselves and digesting all of the toxins.
The soil stabilizer will only be sprayed onto the footprint of burned structures, and will be completely removed with other debris when FEMA does its phase 2 cleanup sometime in a period of months from now.
ALTERNATIVES TO SOILTAC:
WATER: Wetting down ash was suggested as an alternative to Soiltac as as an effective method to keep the ash in place. Not only does this fail to address concerns around a rain event, it can exacerbate leaching, requires repeat applications, is expensive and places further demand on already strained water resources.
TARPS: In California, Soiltac was not yet available following the wildfires. The community (and eventually government) was compelled to mobilize a large labor force to attempt to cover every single burn site with tarps secured by sandbags. In Lahaina, there is an estimated 15 million sq ft that would need to be covered by approximately 25,000 tarps and 150,000 sandbags, as well as PPE and training of a workforce which would be exposed to toxic chemicals during the work.
ON FILTRATION AND MANAGING STORM WATER RUNOFF: not included here due to website comment character limitation. Full testimony attached as PDF.
The bottomline is that the County should immediately acknowledge the severe health and environmental threat of airborne dust and ash and the potential for such to enter groundwater and the ocean. Low pressure systems will become increasingly active and could at any time bring heavy rain events to West Maui. We have a limited window to enact measures to mitigate both types of hazard. It is a blessing to have had this much time to prepare to act. Letʻs eliminate delay that risks decades of deeper and broader contamination, long term toxic clean-up site status, air and water borne transmitted health hazards and ecological destruction.
Mahalo, Makana