TMT Hearing: Cultural Impact Assessment ‘Falsified’

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tmt sunset

An artist’s rendering of the Thirty Meter Telescope at sunset. TMT photo.

A former employee of Cultural Surveys Hawaii who was in charge of authoring the cultural impact assessment (CIA) for the Thirty Meter Telescope (TMT) project’s environmental impact statement (EIS) said the document was falsified.

Brian Kawika Cruz took the stand as a witness for KAHEA: The Hawaiian-Environmental Alliance as the contested case hearing for the state Board of Land and Natural Resources Conservation District Use Application (CDUA) on the TMT project continued from Feb. 27 through March 2.

Cruz’s findings from his six to eight months of research led him to advise project proponents “to strongly consider no further development, including the TMT Observatory Project and the Mid-Level Facilities at Hale Pohaku, take place on Maunakea.”


The CIA also included mitigation and remedial measures suggested by participants in the study that project proponents should consider.

Cruz, who has written over 40 to 50 CIAs, submitted the CIA draft to Jim Hayes of Parsons Brinckerhoff Engineering Services, the main firm responsible for the EIS. Two days later, Cruz said that Hayes told him to remove his recommendations.

Cruz said in all of the CIAs he’s ever written, he has never been asked to remove any of his recommendations—it’s something that’s unheard of, he said.


Before the Final EIS (FEIS) is published, a Draft EIS (DEIS) is published in order to hold a 45-day public commentary period so that all the information is considered and receives response through public hearings, written testimonies and community meetings.

Then, according to Cruz’s written direct testimony, the FEIS will typically contain the information from the DEIS along with the data collected from the 45-day period.

Cruz refused to remove his recommendations, but when the DEIS was published on May 23, 2009, his recommendations were absent. He believes the 45-day period might have produced different results had the public been able to consider his recommendations.


Cruz said he thinks Parsons Brinckerhoff removed the data and recommendations because it may have disrupted the project’s construction permit approval.

Cruz added that when Parsons Brinckerhoff submitted the FEIS on May 8, 2010, his recommendations in the CIA portion found their way back into the document, appearing as if they were always there.

When petitioner Billy Freitas asked Cruz if the DEIS was falsified, he answered yes. When Freitas asked him if he believed the FEIS was flawless, Cruz answered he believes it was flawed.


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