Smoke Impact Codes

Code Description
1 No Visual Impairment
Slight Odor of Smoke
2 Visible smoke present
Odor may or may not be present
3 Visible smoke with some visual impairment
Visibility greater than 500 feet
4 Visual impairment
Visibility 500 feet or less intermittently (for periods of one to two minutes)
5 Heavy smoke
Poor visibility
steadily 100 to 500 feet
6 Heavy smoke
Visibility less than 100 feet
7 Very heavy smoke
No Visibility

2013 Cane Burning Permit

Here’s the pdf of the HC&S Agricultural Burn Permit

2013 Permit 01

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Subject to Hawaii Revised Statutes (HRS), Chapter 342B; Hawaii Administrative Rules (HAR), Chapter 11-60.1; and all the following conditions unless modified or replaced by any attached special conditions:

1. Permittee shall notify the Maui Police Central Dispatch at (808) 244-6400 and the fire station nearest to your bum location at least one hour prior to each burn.

2. BURNING IS NOT allowed during a “no-burn” period declared by the Department of Health (DOH) under §11-60.1-55, HAR.

3. Permittee shall provide an adequate water source to the bum location which will prevent the Hre from spreading to areas adjacent to burn location.

4. An inspection shall be conducted on all accessible areas of each Field prior to burning. Any batteries, abandoned vehicles, wastes handled or processed by sugar factory operations, tires, petroleum wastes, appliances, furniture, logs greater than 4″ in diameter, hazardous wastes, 55 gallon drums and other similar items which may have been deposited in the burn area and identified by the inspection shall be removed prior to any bum. Burning of agricultural wastes that are not generated from the burn location is prohibited. In the pre-burn checklist document that the inspection was conducted prior to burning of the field.

5. Fire shall be attended or supervised by an adult in accordance with Exhibit 1 (HC&S Bum Procedures) which is attached hereto and incorporated herein.

6. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 1 (HC&S Burn Procedures): 105, 107, 109, 112, 113, 116, 117, 118, 202, 204, 208, 209, 210, 211, 212, 213, 214, 300, 302, 305, 306, 307, 309, 314, 401, 402, 403, 404, 405, 408, 409, 410, 411, 412, 413, 414, 416, 418, 500, 501, 505, 506, 508, 509, 510, 511, 512, 602, 605, 609, 611, 700, 701, 702, 706, 707, 709, 710, 711, 712, 714, 715, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 802, 803, 806, 807, 808, 813, 815, 819, 821, 823, 902, 903, 904, 905, 906, 907, 908, 909, 910, 911, 912, 913, 914, 915, 918, 919, 921, and 922; which are attached hereto and incorporated herein.

7. The following fields, which are nearest to roadways and Kahului airport, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 2: 105, 107, 113, 204, 208, 210, 211, 212, 300, 306, 401, 404, 405, 413, 500, 501, 505, 506, 508, 509, 511, 602, 605, 609, 611, 700, 701, 702, 706, 707, 709, 710, 711, 712, 714, 715, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 902, 906, 908, 911, 912, 913, 914, 915, and 919; which are attached hereto and incorporated herein.

8. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with Exhibit 3; 109, 112, 116, 117, 118, 202, 209, 213, 214, 302, 305, 307, 309, 314, 402, 403, 408, 409, 410, 411, 412, 414, 416, 418, 510, 512, 802, 803, 806, 807, 808, 813, 815, 819, 821, 823, 903, 904, 905, 907, 909, 910, 918, 921, and 922; which are attached hereto and incorporated herein.

9. The following fields, as indicated in the 2013 Harvesting Schedule and map submitted by the permittee, shall be burned in accordance with the schedule below:
Peak traffic hours are 7:00 a.m. — 8:30 a.m. and 3:30 p.m. — 5:00 p.m. All flames must be extinguished by the end of the burn period.


 

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a. The following Fields may be burned between the hours of 3:00 a.m. and 6:00 a.m.: 605, 609, 709, 710, 711, 712, 714, and 715.

b. The following field may be burned between the hours of 4:O0 a.m. and 6:00 a.m.: 413.

c. The following field may be burned in the summer months (June, and July) between the hours of 4:00 a.m. and 6:00 p.m., excluding peak traffic hours and in all the other months
between 4:00 a.m. and 6:00 a.m.: 204.

d. The following fields may be burned between the hours of4:00 a.m. and 6:00 p.m.: 813, 815, 819, 909, and 910.

e. The following Fields may be burned between the hours of4:00 a.m. and 6:00 p.m., excluding peak traffic hours: 105, 107, 208, 212, 300, 306, 401, 404, 405, 410, 500, 501, 505, 506, 508, 509, 511, 602, 611, 700, 701, 702, 706, 707, 716, 717, 718, 719, 737, 741, 743, 745, 747, 749, 751, 753, 757, 761, 763, 765, 767, 902, 908, 911, 912, 913, 914, 915, and 919.

f. The following Field may be burned under trade wind conditions between the hours of 4:00 a.m. and 10:00 a.m., excluding peak traffic hours and under Kona wind conditions between the hours of 8:30 a.m. and 3:30 p.m.: 906.

g. The following Fields may be burned between the hours of 6:00 a.m. and 6:00 p.m., excluding peak traffic hours: 210, 211.

h. The following field may be burned between the hours of 6:00 a.m. and 6:00 p.m., excluding peak traffic hours, except during Makawao Union Church services or Sundays: 113.

i. All other Fields, as indicated in the 2013 Harvesting Schedule, map submitted by the permittee, or listed in condition #6, shall be burned between 6:00 a.m. and 6:00 p.m.
10. Only controllable amounts shall be burned and under conditions that will minimize visible ground level smoke from entering any residence, business, or public area. With the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of Fields listed under Condition 7 in accordance with Exhibit 2, ifa burn has begun and visible ground level smoke enters any residence, business, or public area, permittee shall not burn additional Fields that day which would affect such impacted areas until meteorological conditions improve. If a decision is made to conduct additional burning under this provision, permittee shall notify DOH by telephone prior to the day’s next burn and shall document the justification for conducting additional burns on a Burn Justification Log. This documentation shall include the location of the original burn and of residences, businesses, or public areas that were impacted by visible ground level smoke, the planned location of any subsequent burns that day, a description of any problems encountered during the original burn which may have contributed to visible ground level smoke in a residence, business, or public area and any corrective actions implemented to address them, any changes in meteorological or Field conditions since the initial burn, and identification of downwind areas most likely to be impacted by the next burn.

11. Visible ground level smoke entering any residence, business, or public areas, with the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of fields listed under Condition 7 in accordance with Exhibit 2, or smoke impacts from fires not caused by the permittee (e.g., malicious fires, brush fires), shall not exceed a Public Impact Code of 3, as described in Exhibit 1. After completion of the burn, smoldering piles shall be promptly addressed in compliance with Exhibit 1.

12. Permittee shall submit a written report to DOH within five (5) working days after any deviation from the permit requirements, including the procedures specified in Exhibits 1, 2 and 3 and accompanying attachments. The report shall identify the probable cause of the deviation and any corrective actions or preventive measures taken.

13. Permittee shall monitor all burns and maintain a record of the meteorological conditions and plume behavior throughout each burn. To the extent practical, photos shall be taken of the plume behavior. A copy of each Pre—Burn Checklist, Exhibit 2/Exhibit 3 Checklist, Burn Monitor Log and the Daily Weather and Dispersion Forecast shall be submitted to the DOH, either in hard copy or electronically, within seven (7) days after Friday of each week or upon request.

14. All records, including support information, shall be true, accurate, and maintained in a permanent form suitable for inspection, retained for a minimum of three (3) years following the date of such records, and made available to the DOH or its representatives upon request.

15. Permittee shall keep a copy of this permit at the burn site during the burn and shall make it available for inspection upon request.

16. For the purpose of determining compliance with this permit, the DOH or its duly authorized representatives shall be granted access to the property at reasonable times, pursuant to HRS,

§342B—41, Inspection of Premises. The DOH shall not be denied access to burn sites.
The DOH reserves the right to terminate, suspend, reopen, or amend this permit, subject to HAR $11-60.1-57 (e). Violation of any condition of this permit, any section of Chapter 342b, HRS, or any section of Chapter 11-60.1 HAR, may result in fines no greater than $10,000.00 or each day of each violation, pursuant to §342b-47(b), HRS. In addition, a violation may be reason for amendment, suspension, or revocation of this permit.


HC&S Fields via USDA
HC&S Fields via USDA (May be out of date)

 

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Hawaiian Commercial & Sugar Company
2013 Agricultural Burning Permit – Exhibit 1


This exhibit describes general procedures to be followed for pre—harvest burning of sugarcane in order to minimize public exposure to visible smoke impacts. Included are procedures to be followed prior to, during, and after each burn. The Harvesting Manager (or his designated alternate) shall ensure that all fields are burned in accordance with these procedures. Additional requirements are specified for individual fields in Exhibits 2 and 3 and these requirements shall also be followed.

A. Actions to be taken prior to burning:

(l) Assessment of field location and actions for sensitive downwind areas — Prior to burning any field, the Harvesting Manager shall review the location of the field with respect to certain sensitive areas to determine the types of public notifications necessary and any restrictions on when the field can be burned.

(a) Public Notification Procedures
Public notifications specified for each burn are listed in the attached Cane Burn Notification listing (Attachment la) and are described below.

• Written Notices: For those fields for which written notices are specified in Attachment la, attempts will be made to deliver flyers to residential premises, schools, churches, and other facilities. By law mailboxes cannot be used for this purpose, and some residences may not be accessible (e. g., due to dogs, locked gates, etc.) or may have no other provisions for receiving written notices; therefore, reasonable efforts will be made to leave written notices where they are likely to be seen by occupants of the premises. Where multiple dwellings may be present on a single residential property, the notification attempt will be made to the dwelling most readily accessible from the street. Where a particular residential area is specified in the “Written Notice” column of Attachment la, HC&S shall make reasonable efforts to ensure that all residential premises in the specified area receive written burn notifications. Where the words “Adjacent Residents” appear in the “Written Notice” column, HC&S shall make reasonable efforts to deliver notices only to those homes immediately adjacent to the field. A sample flyer is included as Attachment lb.

• Telephone Notifications: Telephone notifications will be attempted at least two hours prior to scheduled burns for those individuals who have specifically requested such notifications. A call list is maintained for these individuals and is updated as new requests are received. Reasonable attempts at phone notifications will be made; notifications may be precluded when no one answers the phone, there is no answering machine or voice mail, the number is out of service, or in similar circumstances.

• Road Signs and Guards: For fields adjacent to roads and highways, signs and/or traffic guards shall be posted as indicated in the Cane Burn Notification listing to alert approaching motorists.


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• Police and Fire: The Maui Police Department Central Dispatch and the nearest fire station shall be notified prior to each burn as specified in the Agricultural Burning Permit. Notifications shall be made at least one hour prior to burning.

(b) Restrictions on Burning — Schools and Churches
Fields which are upwind of abutting schools shall not be burned while school is in session. Burns will be scheduled so that they are completed at least one hour prior to the start of school or else will be conducted after school hours. The Harvesting Manager shall maintain and make available to the Department of Health a list of all known schools located adjacent to HC&S fields (Attachment 1c) and their normal hours of operation, including any summer school_and after school programs. If necessary, permission will be requested from the Department of Health to burn such adjacent fields after 1800 in order to prevent any smoke impacts. Fields upwind of adjacent churches shall not be burned during scheduled services. As noted above, notification to the person responsible for these facilities will be attempted two days prior to scheduled burns.

(c) Restrictions on Burning — Public Roadways
The following public roadways may be impacted by smoke during burning and are considered potentially hazardous roadways:
Hana Highway
Haleakala Highway
Mokulele Highway/Puunene Avenue
Pulehu Road
North Kihei Road
Haliimaile Road
Baldwin Avenue
Kuihelani Highway/Dairy Road
Honoapiilani Highway
Fields adjacent to these roadways shall not be burned during peak traffic periods (0700- 0830 and 1530-1700) unless otherwise authorized in the permit. In order to minimize traffic impacts and potentially hazardous conditions, HC&S will request approval from the Department of Health to burn most fields adjacent to these roadways between the hours of 0400 to 0600. As noted above, signs will be posted and/or roadways may be manned by traffic control guards (private security or off-duty police officers) for these fields. The Police Department shall be notified prior to burns that may impact traffic on roads and highways.

(d) Restrictions on Burning – Public Recreation Areas
There shall be no burning of fields directly upwind from adjacent public recreation areas on Sundays. For the purposes of this exhibit, “adjacent” means adjoining the field being burned. To the extent practicable when reasonable advance notification has been provided, efforts shall be made to adjust the harvesting schedule in order to further reduce the potential for smoke to impact planned and organized public activities (e. g.,


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fairs, carnivals, charity walks, athletic events, etc.) in downwind areas adjacent to fields scheduled for burning.

(e) Restrictions on Burning – Airport
In order to minimize impacts on airport operations, HC&S will request approval from the Department of Health to burn fields adjacent to the airport or located in the airport approach path between the hours of 0300 to 0600. The airport control tower shall be notified by telephone prior to burns in the vicinity of the airport as noted in the Cane Burn Notification listing.

(f) Exhibit 2 and Exhibit 3 Burn Conditions
All burns shall be conducted in accordance with the conditions and limitations specified in Exhibit 2 or Exhibit 3, as applicable.

(2) “No Burn” declarations — Upon issuing a “no burn” declaration, the Department of Health representative will notify the HC&S Harvesting Manager (or his designated alternate) via cellular telephone. Prior to burning, the Harvesting Supervisor in charge of the burn shall contact the Harvesting Manager (or his designated alternate) to determine whether the Department of Health has declared a “no burn” period. Burning shall not be conducted during any “no burn” period declared by the Department of Health.

(3) Red Flag Warnings – A Red Flag Warning is an advisory from the National Weather Service intended to inform fire fighting and land management agencies when weather conditions may pose an increased risk of wildfire ignition and propagation. A Red Flag Warning is advisory in nature, not regulatory. However, local fire agencies may, at their discretion, impose a ban on outdoor burning when warranted by local conditions. Upon receipt of any notice from the Maui Fire Department (MFD) that a ban on outdoor burning is in effect on Maui, the Harvesting Manager shall ensure that burning does not occur in the areas covered by the ban until MFD advises that the ban has been lifted.

(4) Assessment of meteorological conditions — Prior to burning, the Harvesting Manager shall review available meteorological data, including wind speed and direction, to determine likely smoke plume behavior and whether conditions are suitable for burning. Burning shall only be conducted under conditions that will minimize ground level visible smoke from entering residences, businesses, or other areas to which the public has unrestricted access. The following sources of data shall be considered:

• Western Weather Group (WWG) smoke management weather and dispersion forecast (obtained daily through computer link)

• Existing weather conditions from HC&S weather stations, especially those nearest to the burn location

• Wind data from field measurements at the burn site

• Rainfall data from the area of the field to be burned

• Records and experience from past burns indicating historical weather data and corresponding smoke plume behavior

• National Weather Service forecast


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(5) Assessment of predicted dispersion in area of field being burned – The WWG daily weather and dispersion forecast shall include predicted conditions for smoke dispersion at the scheduled burn time and for later in the day in the area of each field planned to be burned on that day. When smoke dispersion for a particular field is predicted to be “poor” at the scheduled burn time, that field shall not be burned on the day covered by the forecast except that burning may be considered later in the day if the forecast predicts that dispersion for that field will improve to “fair” or better. Dispersion conditions predicted for a particular field shall only affect burn decisions made for that field, and will not
necessarily preclude burning in other fields.

(6) Assessment of temperature inversions – The WWG daily weather and dispersion forecast shall include the predicted likelihood of a morning temperature inversion in the area of each field planned to be burned on that day. When a “moderate” or “strong” morning inversion is predicted in the area of a particular field, that field shall not be burned until after the inversion is predicted to break (typically around mid-morning). Inversion conditions predicted for a particular field shall only affect burn decisions made for that field, and will not necessarily preclude burning in other fields elsewhere on the plantation.

(7) Assessment of rainfall – The WWG daily weather and dispersion forecast shall include information regarding rainfall measured within the previous 24 hours at the weather station nearest to each field scheduled to be burned. Additionally, manual rain gages may be sited in or near fields scheduled to be burned. When rainfall over the previous 24 hours recorded in or nearest to a field is 0.1 inches or more, that field shall not be burned until the vegetative mat in the field has been checked for moisture to confirm that the field is dry enough to burn.

(8) Assessment of vog – The WWG daily weather and dispersion forecast shall include predictions for vog to impact air quality on Maui based on data from the University of Hawaii Vog Measurement and Prediction Project (VMAPP) website. When the VMAPP tables of model predicted values indicate that sulfur dioxide and/or sulfate aerosol concentrations in Kihei will result in “moderate” (indicated by a rating of “yellow” on the WWG forecast) or “unhealthy” (indicated by a rating of “red” on the WWG forecast) air quality on the day covered by the forecast, burning shall not be conducted. A rating of “green” on the WWG forecast indicates that air quality is predicted to remain in the “good” range despite any potential vog impacts, and burning in compliance with other applicable permit requirements is therefore permissible.

If the VMAPP website is not functioning or the table of model predicted values is not posted, has not been updated, or is clearly erroneous at the time that the WWG daily forecast is prepared, then the forecaster shall indicate “NA” (not available) for vog data. In that event, this assessment of vog shall not be required for that day’s burns. The VMAPP website is maintained by the University of Hawaii and HC&S has no control over the continued availability of data on this site. In the event that maintenance of the VMAPP website is discontinued, or the information available on the VMAPP website is


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significantly changed or the format modified such that compliance with this provision is not feasible, then compliance with this provision of Exhibit 1 shall no longer be required as part of the pre—burn assessment. HC&S shall retain the flexibility to evaluate whether a new or modified vog forecasting tool is sufficiently reliable and suitable for incorporation into its pre-burn assessment procedures.

(9) Assessment of existing air quality – Within one hour prior to each burn, the Harvesting
Manager shall check the current Air Quality Index (AQI) for the Department of Health’s Kihei air monitoring station posted on the Department of Health’s Hawaii Ambient Air Quality Data (HAAQD) website (go to http://emclweb.doh.hawaii.gov/air—guality/ and click on “Air Monitoring Sites” and then “Maps”).

• If the AQI at the Kihei air monitoring station is in the “good” range (indicating air quality meets state and federal standards), burning may be conducted as normal in compliance with all other applicable permit requirements.

• If the AQI at the Kihei air monitoring station is within the “moderate” range (indicating air quality meets state and federal standards), then additional caution shall be exercised to avoid burning under marginal conditions which could result in further degradation of the AQI (i.e., into the “unhealthy” range). The Harvesting Manager shall evaluate whether predicted conditions for dispersion and other meteorological conditions warrant calling a voluntary “no burn”. Burning when the AQI is in the “moderate” range shall be conducted in compliance with all other applicable permit requirements.

• If the AQI at the Kihei air monitoring station falls within any “unhealthy” range, no burning shall be conducted until air quality improves and the AQI is again within the “good” or “moderate” range.

• If the HAAQD website is not functioning, or the current AQI for the Kihei station is not posted or is clearly erroneous at the time that the website is checked, then no assessment of the AQI shall be required in order for the burn to proceed. The HAAQD website and the Kihei air quality monitoring station are maintained by a government agency and HC&S has no control over the continued availability of the data they provide. In the event that operation of the HAAQD website or the Kihei air quality monitoring station is discontinued, or the information available from these sources is significantly changed or the format modified such that compliance with this provision is not feasible, then compliance with this provision of Exhibit 1 shall no longer be required as part of the pre-burn assessment. HC&S shall retain the flexibility to evaluate whether a new or modified air quality forecasting tool is sufficiently reliable and suitable for incorporation into its pre—burn assessment procedures.

(10) Inspection and removal of unauthorized materials – An inspection shall be conducted of all accessible areas of each field prior to burning. Any batteries, abandoned vehicles, factory wastes, tires, petroleum products, appliances, furniture, hazardous wastes, 55-gallon drums, or other similar items which may have been deposited in the burn area and which are identified during the inspection shall be removed from the burn area prior to any burn. Any logs greater than four inches in diameter which may have been deposited in the burn area and which are identified during the inspection, with the exception of those from any plants


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found growing in the field, shall be removed from the burn area prior to any burn. Inspections will normally be conducted during cutting of firebreaks within one day of the scheduled burn.

(11) Protection of irrigation system infrastructure – Drip irrigation systems are installed in each field, consisting of buried PVC irrigation mainlines and above-ground irrigation system risers in valve lines located along field edges, subsurface polyethylene drip tubing used to apply water to the crop, and polyethylene oval hose used to supply water from the risers to the drip tubing at the field edges. Permanently installed PVC piping is expensive and time-consuming to replace, so extensive efforts are made to protect these irrigation system components from damage during harvesting. Prior to each burn, action shall be taken as follows to minimize the potential for accidental damage or burning of irrigation
infrastructure:

• Except at field edges where it connects to the remainder of the irrigation system, the majority of drip irrigation tubing is buried during installation and is thereby protected from burning.

• Once irrigation of the field has been halted in preparation for harvest, oval tubing located at the field edges shall be disconnected and pulled from the field prior to the field being burned.

• During preparation for burning, sugarcane at the field edges shall be pushed into the fields, away from the irrigation riser line, to create a “fire line” in order to prevent damage to or destruction of the irrigation risers when the field is burned. “Fire line” cane may also be hauled out of the field rather than pushed into the field, or the field edge may be “notched” (i.e., cane pushed or hauled out only in the area around each riser) to protect the irrigation risers. Alternate means of protecting the risers may be developed and employed, provided that they are equally effective at preventing the risers from burning.

B. Actions to be taken during the burn:
(1) Monitoring and recordkeeping – The Harvesting Manager shall designate an individual to monitor each burn and document meteorological conditions and plume behavior, including any visible smoke impacts on public areas. The Burn Monitor shall continue to monitor the burn and record observations for a minimum of one hour from the start of the burn and until all visible smoke has passed overhead beyond public areas or out to sea and any ground level visible smoke impacts to public areas have dissipated. If necessary, the Burn Monitor shall follow the smoke plume to determine the extent of any ground level visible smoke impacts in public areas. In addition to recording observations of the burn, the Burn Monitor shall take a photograph during each observation, when practicable (for example, photos shall not be required when precluded by darkness).

(a) Burn Monitor Log – The Burn Monitor shall record the following information on the Burn Monitor Log (Attachment le) for each burn:

• The number of the field to be burned and the number of acres burned


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• The date and time the burn was started and the wind speed and direction at the burn site at the start of the burn

• The smoke pattern exhibited by the plume throughout the burn; a listing of smoke pattern codes is included as Attachment lf

• Any significant shifts in wind speed and direction which occur during the burn

• A description of any observed visible smoke impacts in public areas, including a Public Impact Code from “0″ (no evidence of smoke in the area) to “7″ (very heavy smoke); a listing of smoke pattern codes is included as Attachment lf

• The date and time the burn was completed (i.e., date and time when all flames have been extinguished)

• The time that the photograph of each observation was taken (all photographs shall be appended to the Burn Monitor Log).

(b) Maui Vortex – The WWG forecast includes a prediction of whether formation of a characteristic circulating wind pattern near the southern edge of the plantation, called the “Maui vortex”, is likely to occur. The Maui vortex can impact downwind dispersion of smoke from the burn. When formation of the Maui vortex is predicted and meteorological conditions during the burn include slow or stagnant winds, reasonable efforts shall be made to monitor wind conditions in the vicinity of the vortex after completion of the burn for indications of vortex formation. Monitoring of wind conditions shall include observing wind data from the Kihei, Field 415, and Kula Ag Park stations. The Burn Monitor shall resume monitoring for ground level smoke impacts if such impacts are anticipated to result from vortex formation.

(c) Special Burn Monitoring — At its sole discretion, HC&S may choose to conduct special burn monitoring beyond what is specifically required by this Exhibit, using additional personnel besides the designated Burn Monitor, in order to better document conditions during and after the burn. Such monitoring will typically be conducted during burns upwind of especially sensitive areas or to attempt to substantiate complaints from a particular area. When conducted, such special monitoring may be recorded at the end of the Burn Monitor Log for the subject burn. Documentation of special burn monitoring should include the location(s) of the special monitor(s), the period of time during which the monitor was at each location, a description of any smoke impacts observed by the monitor(s), and other relevant information.

(2) Suspension of burns due to smoke impacts – In the event that any ground level visible smoke is observed entering any residence, business, or public area (conditions corresponding to a public nuisance code of “2″ or greater) during or after a burn, the Burn Monitor shall immediately notify the Harvesting Manager or the Harvesting Supervisor in charge of the burn. The Harvesting Manager or Supervisor shall ensure that no additional burns are conducted that day which would impact the affected area until meteorological conditions improve. (Note: This requirement shall not apply to fields burned in accordance with Exhibit 2 where ground level smoke impacts are limited to public roads or the airport.)


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(3) Resumption of burning after visible smoke impacts – When visible smoke impacts to public areas warrant that no additional burns should be conducted which would impact the affected area until meteorological conditions improve (per Section B.(2) above), additional burns may be conducted on the same day only after all of the following conditions have been met:

(a) Smoke impacts to public areas from the earlier burn (other than smoke impacts to public roads and/or the airport from burning an Exhibit 2 field) did not exceed a Public Impact Code of three (3). [StopCaneBurning note: Code 3 = "Visible smoke with some visual impairment Visibility greater than 500 feet"]

(b) The Harvesting Manager has determined that conditions under which any subsequent burns would be conducted are unlikely to result in visible smoke impacts to the same public area(s) affected by the earlier burn. (Note: This requirement shall not apply to smoke impacts to public roads and/or the airport from burning an Exhibit 2 field.)

(c) The Harvesting Manager has documented the determination required under Section B.(3)(b) above on a Burn Justification Log (Attachment lg). Documentation shall include:

• The time and location of the original burn;

• Identification of any public areas that were impacted by ground level visible smoke as a result of the burn and a description of the smoke impacts (e. g., duration, Public Impact Code);

• The planned location of any subsequent burns to be conducted on the same day;

• A description of any problems encountered during the initial burn which may have contributed to ground level smoke in public areas;

• Corrective actions or preventative measures implemented to address problems identified during the initial burn;

• Any changes in meteorological or field conditions since the initial burn that are expected to improve smoke dispersion; and

• Identification of downwind areas most likely to be impacted by the next burn.

(d) The Harvesting Manager or Harvesting Supervisor in charge of the burn has notified the Department of Health by telephone of the intent to conduct additional burns.

(5) Attendance to fires and conduct of burns – The date, time, and acreage to be burned shall be determined by the Harvesting Manager. The Harvesting Supervisor at the burn site shall be responsible for controlling the burn and shall assign men and equipment to the burn as necessary depending upon wind conditions, field location, dryness of the surrounding area, and proximity to public areas. A supervisor shall remain at the burn site until all flames are extinguished and smoke emissions are minimized.

(a) Controlling fires – Fire breaks are used to isolate the specific area of cane to be harvested and are cleared prior to burning. The size and location of firebreaks will be determined by the Harvesting Supervisor depending upon field location and wind conditions. Under normal conditions, a 15-foot wide firebreak will be cleared; however, a firebreak up to 50 feet wide may be cleared to avoid a “jump fire” into standing cane, rangeland, or nearby structures. In fields immediately adjacent to residences, firebreaks shall be adequate to protect adjacent property and the area surrounding the acreage to be burned shall be watered down prior to burning. In the event that the field is too close to residences or other structures to be safely burned, a portion of the field shall be harvested unburned. The Harvesting Supervisor at the burn site shall determine the speed and direction of burning by controlling firing of the field, utilizing backfire techniques, and remaining alert to changes in wind conditions. Water trucks and firebreak equipment shall be maintained at the burn site during the burn to help prevent uncontrolled fires. (b) Contingency Plans – Training in dealing with contingencies shall be a part of the Harvesting Department’s continuing training program. In the event of a ‘jump fire” or other unforeseen accident, the following steps shall be taken:

• Notify the Fire Department and Police Department

• Dispatch additional water trucks and rakes to the burn site

• Notify all harvesting crews to assist in dealing with the emergency

• Complete additional notifications and actions required under the plantation fire protection manual as necessary.

(c) Variable Winds — Burning in the Pulehu area can be hazardous due to highly variable wind conditions during the day and the proximity to frequently dry rangelands. HC&S may request approval from the Department of Health to burn certain fields in this area during early morning hours (0400 to 0600) to take advantage of more consistent downslope drainage winds. However, such early morning burns shall only be conducted under meteorological conditions that will also minimize smoke impacts on public areas. If such conditions cannot be met during early morning hours, then normal daytime burns in these areas will be required.

(d) Minimizing Smoke Impacts – Only controllable amounts shall be burned and under conditions that will minimize ground level visible smoke from entering any nearby building, public road, highway, beach, or any area to which the public has unrestricted access. With the exception of smoke impacts to roadways and/or the Kahului airport resulting from the burning of fields listed in Exhibit 2 and smoke impacts from fires not caused by the permittee (e.g., malicious fires, brush fires), ground level visible smoke entering any residence, business, or public areas shall not exceed a Public Impact Code of three (3), as determined by the HC&S Burn Monitor or by DOH staff.

C. Actions to be taken at the completion of the burn:

(1) Extinguishing flames and minimizing smoke impacts – The following measures shall be implemented to minimize the potential for ground level smoke impacts to public areas due to smoldering.

(a) A supervisor shall remain at the burn site until all flames are extinguished and smoke emissions are minimized. After the fire has burned out (i.e., all flames have been extinguished), personnel and equipment shall remain in the field as necessary to minimize smoke emissions from smoldering piles.


Page 12

(b) Water wagons shall be used to extinguish smoldering piles and, if necessary, rakes and cranes shall be used to break up the smoldering piles. These “mop up” operations shall be completed within two hours after the end of the burn and repeated as needed thereafter for compliance with Section C.(l)(d) below.

(c) Once emissions following the burn have been reduced to the point where smoke is no longer visible passing beyond HC&S field boundaries and into public areas, equipment may leave the field.

(d) The Harvesting Supervisor responsible for the burn shall ensure that the field is checked periodically for flare-ups or excessive smoldering (i.e., smoldering which results in visible smoke passing beyond HC&S field boundaries and into public areas). Periodic checks shall be made at least once per hour during the first four hours following completion of the burn. After that, checks for smoldering shall be made at maximum intervals of four hours until harvesting of the field is completed (i.e., all cane to be harvested has been removed from the field). More frequent checks may be made in fields that are located close to public areas.

(e) In the event of a flare-up, water wagons and rakes, if necessary, shall be returned to the field to re-extinguish all flames and smoldering. Action shall be initiated to address flare-ups or excessive smoldering within one hour of discovery.

(f) Actions taken for compliance with these provisions relating to smoldering shall be documented in the Post-Burn Smoldering Log (Attachment lh)

(g) In order to reduce the potential for smoldering piles and resultant ground level smoke after the burn is completed, consideration shall be given during burn preparations to hauling out “fire line” cane (i.e., removing it from the field unburned instead of pushing into the field to be burned) and/or “notching” valve lines (risers) when practicable.

(2) Clearing of burned fields – To the extent possible, burned cane located closest to adjacent residences, roadways, and other public areas shall be cleared first in order to minimize smoke impacts. Fire line cane will also be hauled out of these areas when possible. Clearing of burned fields shall be done so that the cane is moved away from these sensitive areas whenever possible.

D. Recordkeeping and Reporting

(1) Recordkeeping – For each burn, records shall be maintained as described below. To help ensure legibility of scanned documents, all records required by this Exhibit l shall be completed in pen. All records, including supporting information, shall be maintained in a true, accurate, and permanent form suitable for inspection, retained for a minimum of three (3) years from the date of such records, and made available to the Department of Health or their representative(s) upon request.


Page 13

(a) Pre-Burn Checklist (Attachment ld) — For each burn, a Pre-Burn Checklist shall be completed. This checklist documents the completion of all pre-burn inspections, notifications, and other requirements that are mandatory for every field. The completed checklist for each burn shall be maintained in the harvesting records.

(b) Exhibit 2/ Exhibit 3 Checklist- For each burn, either an Exhibit 2 Checklist (for fields where smoke impacts to certain public areas, such as roads and airports, cannot be avoided) or an Exhibit 3 Checklist (for all other fields) shall be completed. This checklist documents additional, field-specific requirements for each burn. The completed checklist for each burn shall be maintained in the harvesting records.

(c) Burn Monitor Log (Attachment le) — For each burn, the burn location, start and end times, wind speed and direction, and information on smoke plume behavior and smoke impacts throughout the burn shall be recorded on the Burn Monitor Log (see additional details under B.(l)). All photographs taken during burn monitoring shall be appended to and considered part of the Burn Monitor Log; photographs may be maintained in electronic format. The completed Burn Monitor Log for each burn shall be retained in the harvesting records.

(d) Burn Justification Log (Attachment lg) — When a burn has resulted in visible smoke impacts to a public area (other than smoke impacts to public roads and/or the airport from burning an Exhibit 2 field), the Harvesting Manager’s determination that a subsequent burn on the same day is not expected to impact the same public area shall be documented on the Burn Justification Log. The Burn Justification Log, when required, shall be retained with the records for the subsequent burn in the harvesting records.

(e) Post-Burn Smoldering Log (Attachment lh) — All post—burn field checks for smoldering and associated corrective actions shall be recorded on the Post-Burn Smoldering Log. The completed Post-Burn Smoldering Log shall be retained in the harvesting records.

(f) Daily Weather and Dispersion Forecast (Attachment lj), Weather Data — Copies of each daily smoke management weather and dispersion forecast shall be maintained in the harvesting records. A complete record of data output from HC&S weather stations is maintained in the weather computer memory.

(2) Reporting
(a) Weekly Report – Within seven (7) days after the end of each week, the Harvesting Manager or his designee shall submit to the Department of Health Clean Air Branch (Honolulu) a copy of each of the records listed in Section D.(l) above for each burn conducted during the week. Records may be submitted electronically or by hard copy. For the purposes of this reporting requirement, Friday shall be considered the end of the week.

(b) Reporting of Deviations — Within five (5) working days after any deviation from a permit requirement, including the procedures specified in Exhibits 1, 2, and 3 and


Page 14

accompanying attachments, HC&S shall submit a written report to the Department of Health, Clean Air Branch (Honolulu) identifying the deviation, the probable cause, and any corrective actions or preventive measures implemented as a result. The Permit Deviation Report Form (Attachment lk) shall be used for this purpose, and a copy of each report shall be retained in the harvesting records.

E. Weather station locations and operation

(l) Locations and data collected – HC&S operates both fixed and mobile weather stations for collecting weather data to be used in making burn determinations. Each station provides data on rainfall, wind speed and direction, temperature, and relative humidity. Fixed weather stations are listed in the attached table (Attachment li) and locations are shown on the harvest map.

(2) Mobile station, use of alternate stations — The mobile weather station will normally be located near sensitive downwind areas for each burn. In the event that any weather station specified for use in making burn determinations in Exhibit 2 or 3 is out of service, either the mobile station or the nearest alternate station will be used instead.

(3) Data readouts, station maintenance – Weather stations provide readouts to a central computer located at the HC&S Main Office. Weather station outputs are also provided directly to Western Weather Group for use in preparing the daily smoke dispersion forecast. Readouts from each weather station are checked daily during the harvest season and any station that provides readings which appear to be inconsistent or unreasonable is serviced as soon as is practicable to ensure proper operation. Each station’s sensors are cleaned regularly to ensure optimum performance. Each station is calibrated quarterly to ensure that all sensors operate properly.

Attachments to Exhibit 1
Attachment la — Cane Burn Notification Listing
Attachment lb — Sample Written Notice
Attachment lc — List of Schools Adjacent to HC&S Su garcane Fields
Attachment ld — Pre—Burn Checklist
Attachment le — Burn Monitor Log
Attachment lf- Smoke Pattern Codes and Public Impact Codes
Attachment lg — Burn Justification Log
Attachment lh — Post-Burn Smoldering Log
Attachment li — Listing of Weather Stations
Attachment lj — Sample WWG Daily Weather and Dispersion Forecast
Attachment lk — Permit Deviation Report Form


Page 15-18 are illegible


 

Page 20

Attachment lc
List of Schools Adjacent to HC&S Sugar Cane Fields
As required by Exhibit 1 to the agricultural burning permit, the following is a list of operating hours for schools located adjacent to HC&S sugar cane fields which could be impacted by smoke from agricultural burning. As required by the permit, burning of fields adjacent to these schools will not be conducted while school is in session or within one hour of the start of school.

School Hours
Doris Todd Memorial Christian Schools (Paia) 0750-1400 no after school or summer programs
Kaahumanu Hou School (Puunene Avenue) 0800-1500 no after school or summer programs
Paia School (Paia) 0750-1730 includes after school program; no
summer program
Anuenue Pre-School (Baldwin Avenue, Paia) 0700-1700 one month off in summer

Rev 3/2013


Page 21

Hawaiian Commercial and Sugar Company
Pre-Burn Checklist

Field:
Date:
Start Time:
End Time:

Prior to burning, verify each item below is completed and initial in the space provided.
Permitted Field: The Harvesting Supervisor in charge of the burn has confirmed that the field planned to be burned is listed on the current Agricultural Burnin Permit. (Check against the permit or a certified copy of the harvest schedule.)

“No Burn” Declaration: Contacted Harvesting Manager prior to burn, verified Department of Health has not notified Harvesting Manager of a declared “No Burn” period in effect.

Restrictions on Burn Times: All restrictions on burn times (e.g., for highways, churches, schools, etc.) will be complied with.

Vog Forecast: WWG vog forecast is in “green” range or is not available (NA). Do not burn if vog forecast is in “yellow” or “red” range. Circle forecast condition: GREEN YELLOW RED NA

Air Quality Index: AQI was checked on AirNOW website within one hour of burn and AQI is in “good” or “moderate” range, or is not available (NA). Circle AQI below:
GOOD – (OK to burn) MODERATE — (burn only with CAUTION) NA OTHER

Public Notifications: Make reasonable attempt to complete all notifications specified in the Cane Burn Notification Listing. (For items not specified in the Cane Burn Notification Listing, enter NA in the box.)

Delivery of written notices to nearby residential premises, churches, schools, and/or businesses (per Cane Burn Notification List) made or attempted at least two days prior to burn.

Telephone notifications to designated call lists (per Cane Burn Notification List) made or attempted at least two hours prior to scheduled burn (check with Burn Monitor to verif completion).

Signs and/or security guards/police posted on affected roadways (per Cane Burn Notification List).

Maui Police Central Dispatch and fire station nearest the burn have been notified at least one hour prior to burn (delay start of burn if necessary to meet this re-notification requirement). Record time of call in box at left.

Inspection of Fields:
Accessible areas of field to be burned have been inspected for materials not authorized to be burned. Unauthorized materials include logs greater than four inches in diameter (unless from plants found growing in the field) and any batteries, abandoned vehicles, factory wastes, tires, petroleum products, hazardous wastes, 55—gallon drums, appliances, furniture, or other similar items.

Any unauthorized materials found during the inspection have been removed from the burn area.

Farm Manager responsible for the field to be burned has confirmed that calcium hypochlorite containers have been
removed from areas located in or within 50 feet of the burn area.

Fire line cleared or valve lines notched to prevent inadvertent damage or burning of irrigation risers.

Confirmed oval hose has been removed from along field edges to prevent burning.

Assessment of Meteorological Conditions:

Weather data, including Western Weather Group smoke management and dispersion forecasts, HC&S weather station data, and past burn records reviewed, assessment of likely smoke plume behavior completed.

Existing meteorological conditions are anticipated to minimize ground level visible smoke from entering residences, businesses, or other public areas.

Checked WWG predicted dispersion conditions. Dispersion is predicted to be “fair” or better in field to be burned. Do not burn if “poor” dispersion is predicted.

Checked WWG predicted temperature inversion conditions. No “strong” or “moderate” temperature inversion was predicted for this field at the time of this burn. If a “strong” or “moderate” inversion is predicted at the scheduled burn time, burning must be delayed until the inversion has broken.

Checked rainfall in/near field. If rainfall in previous 24 hours was 0.1 inches or more, checked field mat and confirmed field is dry enough to burn.

Harvesting Supervisor Certification (Supervisor must review and sign prior to start of burn):

All pre-burn procedures required for this field under Exhibit l and either Exhibit 2 or Exhibit 3, as applicable, have been completed. I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated b the Department of Health as public record.

Signature:

Attachment ld RW 3/20|3


Page 22

Hawaiian Commercial & Sugar Company
Burn Monitor Log

Date:
Field:
Acres Burned:
Burn Wind Measured Start Time: Speed/Direction: From:
Burn Wind Measured End Time: Speed/Direction: From:

While monitoring this burn, did you observe visible smoke (Public Impact Code >= 2) in any residence, business, school, public road, highway, beach, or other area to which the public has unrestricted access?
YES NO

If yes, notify Harvesting Superintendent or Harvesting Supervisor and enter time of notification at right. Time:

Except for smoke in public roads or at the airport when burning Exhibit 2 fields, visible smoke in public areas requires that no further burning shall be conducted in the area until conditions improve.

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.
Signature of Burn Monitor:

Record smoke observations made during the burn below. If visible smoke is observed, indicate extent and duration of visible smoke.

Time:
Location:
Wind Speed/Direction:
Observations:
Public Areas Impacted
Roads/Highways:
Residential/Commercial
Other:
Smoke Plume Code:
Public Impact Code:
Photo Taken? (Yes/No)
Time of Photo:
Time: Location:
Wind Speed/Direction:
Observations: Public Areas Impacted
Roads/Highways:
Residential/Commercial/Other:

Smoke Plume Code:
Public Impact Code:
Photo Taken? (Yes/No)
Time of Photo:

NOTE: THIS IS A TWO PAGE FORM. ATTACH CONTINUATION SHEETS AS NEEDED.

Attachment 1e
RW 3/2013


Page 23

Hawaiian Commercial & Sugar Company
Burn Monitor Log
Continuation Sheet, Page __ of __
Date: Field: Acres Burned:
Record smoke observations made during the burn below. If visible smoke is observed, indicate extent and duration of visible smoke.
Time: Location: Wind
S eed/Direction:
Observations: Public Areas Impacted
Roads/Highways:
ResidentiaI/Commercial/Other:

Smoke Plume Code: Public Impact Code: Photo Taken? (Y es/No) Time of Photo:
Time: Location: Wind
Speed/Direction:
Observations: Public Areas Impacted
Roads/Highways:
Residential/Commercial/Other:

Smoke Plume Code: Public Impact Code: Photo Taken? (Yes/No) Time of Photo:
ATTACH ADDITIONAL CONTINUATION SHEETS AS NEEDED
Attachment 1e REV 3/ZOB


Page 25

Hawaiian Commercial & Sugar Company
Burn Justification Log

Completion of this form is required prior to conducting additional burns after a previous burn conducted on the same day has resulted in visible smoke impacts (Public Impact Code of two (2) or greater) to a public area other than smoke impacts to a public road or to the Kahului airport resulting from burning an Exhibit 2 field. The Harvesting Manager or his designee must complete and sign this form to document his/her determination that conditions under which any subsequent burns would be conducted are unlikely to result in visible smoke impacts to the same public area(s) affected by the earlier burn.

Provide the following information regardin the original burn:
Field:
Acres Burned:
Time of Burn:

What public areas were impacted by visible smoke as a result of this burn (other than roads, airport from Exhibit 2 fields)?

Describe the visible smoke impacts from this burn (extent, duration, public impact code).

Describe any problems encountered during this burn which may have contributed to ground level visible smoke in public areas (e.g., unexpected changes in wind conditions, unexpected temperature inversion, dispersion not as predicted, unexpected rainfall, field wetter than anticipated, unanticipated delays in firing field, etc.).

Provide the following information for the proposed additional burn:
Field:
Acres to Be Burned:
Planned Time of Burn:

What corrective actions or preventative measures, if any, have been implemented to address problems encountered during the earlier burn in an effort to reduce visible smoke impacts (if none, explain)?

Describe any changes in meteorological conditions or differences in field conditions since the earlier burn that are expected to improve smoke dispersion and reduce the potential for smoke impacts to the same area.

Identify public areas downwind of the planned burn that are most likely to be impacted in the event of inadequate smoke dispersion.

Notify the Department of Health by telephone of the intent to conduct additional burns.

Call time:
Name of person who took call:

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.
Name (Harvesting Manager or designee)
Signature
Date

Attachment lg Rev 3/2013


Exhibit 2

2013 Agricultural Burning Permit- Exhibit 2

This exhibit describes specific procedures to be followed for pre-harvest burning of sugarcane in identified problem fields to be harvested during the 2013 season. Problem fields are those fields that, due to their location, cannot be harvested without some visible smoke impacts on neighboring areas, such as public roads and the Kahului Airport. However, the procedures included in this exhibit are intended to ensure that visible smoke entering public areas is kept to a minimum.

The Harvesting Manager shall ensure that all fields listed in Exhibit 2 are burned in accordance with these procedures in addition to those described in Exhibit l (except as noted in Exhibit l, Section B(2); see Section B below).

A. Identification of fields – Exhibit 2 procedures are being submitted for the following fields or groups of fields which are scheduled to be harvested during the 2013 harvesting season or are included on the list of “unscheduled fields”:

• Hana Highway Field 107
• Hana Highway Fields 105, 212, 611
• Hana Highway Field 210
• Baldwin Avenue Field 113
• Baldwin Avenue Field 204
• Baldwin Avenue Field 208
• Baldwin Avenue Field 211
• Haleakala Highway Fields 300, 306, 500, 501, 508, 509, 602
• Pulehu Road Fields 401, 404, 405, 413, 505, 506, 700, 701, 702, 706
• Pulehu Road Field 511
• Mokulele Highway Fields 707, 716, 717, 718, 902, 908, 911, 912, 914, 915
• Kuihelani Highway Fields 719, 749, 751, 753, 757, 765, 767, 919
• Honoapiilani Highway Fields 737, 741, 743, 745, 747, 761, 763
• North Kihei Road Field 906
• North Kihei Road Field 913
• Kahului Airport Fields 605, 609, 709, 710, 711, 712, 714, 715

The location of each field listed above is shown on the field map submitted with the 2013 burn permit application. Burn procedures specific to each field are described in the attached exhibits.

B. Suspension of burns due to changes in wind conditions – Burning in problem fields shall be undertaken only under the meteorological conditions specified in this exhibit. Monitoring and record keeping procedures during the burn shall be as described in Section B(1) of Exhibit 1 except that average wind speed and direction shall also be measured and recorded on the Exhibit 2 checklist prior to the start of each fire within a field. The Harvesting Supervisor in charge of the burn shall monitor wind conditions during each burn. In the event that the wind speed or direction changes

Page 1 of 18 Rev 3/2013


Page 33

during the burn, the Harvesting Supervisor shall re-evaluate wind conditions to determine whether the conditions specified in this exhibit are still being met. If the specified conditions are no longer met, the Harvesting Supervisor shall ensure that no further burns are conducted in that field until the required conditions are again met.

C. Use of weather station data for burn decisions – HC&S operates both fixed and mobile weather stations for collecting weather data to be used in making burn determinations. The weather stations to be used for making burn decisions in a field are specified in the Exhibit 2 checklist for that field. In the event that any weather station specified for use in making burn determinations in Exhibit 2 is out of service, either the mobile station or the nearest alternate station will be used instead.

When determining whether wind speeds are within the limits specified in the Exhibit 2 checklist, the Harvesting Supervisor in charge of the burn shall consider the average wind speed being recorded by the appropriate weather station(s). If, at the time that a burn determination is being made, winds are occasionally gusting at speeds in excess of the maximum speed specified for burning in the exhibit, the Harvesting Supervisor shall monitor wind speeds prior to burning sufficiently to confirm that average wind speeds are not increasing above the maximum speed specified in the exhibit.

Allowable wind directions for burning are stated from a given direction. That is, when a northerly wind direction is specified, allowable winds are blowing from the north toward the south. In addition, allowable winds are specified in the exhibit as a range of directions starting from the first direction listed and moving clockwise through the second direction listed. Thus, if the exhibit specifies winds must be “north/northeast to southeast”, then the allowable wind directions would be from a heading of north/northeast (22.5 degrees on a compass) through east (90 degrees) to southeast (135 degrees).

Page 2 of 18 Rev 3/2013


EXHIBIT 2 Burn Procedures for Field 107
(adjacent to Hana Hi hway)

Reason for listing as problem fields: Close proximity to Hana Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions for the portion of the field located below Lower Hamakuapoko Road:
• North to northeast tradewinds less than 25 miles per hour

Burning will be undertaken only under the following wind conditions for the portion of the field located above Lower Hamakuapoko Road:
• Tradewinds (North to east) less than 25 miles per hour
• Southeast to south winds less than 15 miles per hour

Weather data to determine optimum wind conditions will be from the Paia Division weather stations nearest to the field being burned.

(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (to take advantage of light drainage winds at this time of day), or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Hana Highway.

4. Phone calls will be attempted to the Paia and Kuau phone notification lists.

5. Attempts will be made to deliver written notices to Kuau residential premises two days prior to the burn.

6. Approximately seven acres of cane directly adjacent to residences will be harvested unburned. The remainder of the portion of the field located below Lower Hamakuapoko Road will also be harvested unburned if wind conditions are not favorable for burning at the time of harvest.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.
Supervisor Signature:
Page 3 of 18 Rev 3/2013


EXHIBIT 2

Burn Procedures for Fields 105, 212, 611
(adjacent to Hana Highway)

Reason for listing as problem Fields: Close proximity to Hana Highway

Spe al burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:
• Tradewinds (north to east) less than 25 miles per hour
• Southeast to south winds less than 15 miles per hour

Weather data to determine optimum wind conditions will be from the Paia Division weather stations nearest to the Field being burned. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (to take advantage of light drainage winds at this time of day), or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Hana Highway.

4. Phone calls will be attempted to the Paia ( Fields 104, 105), Kuau (Fields 104, 105, 108) and Spreck sville ( Fields 600, 611) phone notification lists. Phone call will be made to the Kahului Airport Control Tower ( Field 611).

5. Attempts will be made to d iver written notices to Kuau ( Fields 104, 105) and Sprecklesville ( Fields 600, 611) residential premises two days prior to the burn. For Field 212, attempts will be made to d iver written notices to adjacent residential premises and to the Hongwanji mission two days prior to the burn.

7. To minimize the potential for smoke impacts to nearby residences, approximately 25 acres of cane located along Hana Highway in Field 105 will be harvested unburned.

6. After completion of the burn, water trucks will be sent into the Field to extinguish remaining smoldering piles to iminate smoke emissions as soon as possible. Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre·Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and b ief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 4 of 18 Rev 3/2013


EXHIBIT 2
Burn Procedures for Field 210
(adjacent to Hana Highway)

Reason for listing as problem fields: Close proximity to Hana Highway (This field is also located near residences in the Kuau area.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north/northwest to northeast) less than 20 miles per hour Weather data to determine optimum wind conditions will be from a weather station located in field 107. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0600 and 1800, excluding the peak traffic hours of 0700-0830 and 1530-1700, to minimize traffic disruptions.

3. Attempts will be made to deliver written notices to adjacent Kuau residential premises.

4. Phone calls will be attempted to the Paia and Kuau phone notification lists.

5. Signs and/or guards will be posted on Hana Highway.

6. Approximately 20 acres nearest the highway will be harvested unburned. The remainder of the field will also be harvested unburned if wind conditions are not favorable for burning at the time of harvest.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible. Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre·Burn Checklist to be filed in the harvesting records.
Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge ofthe facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 5 of l8 Rev 3/2013


EXHIBIT 2
Burn Procedures for Field 113
(adjacent to Baldwin Avenue)

Reason for listing as problem fields: Close proximity to Baldwin Avenue (These fields are also located near Makawao Union Church and residences in the Upper Paia area.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north to east) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 15 miles per hour

Weather data to determine optimum wind conditions will be from weather stations in fields 110 and 201.
(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700) to minimize traffic disruptions.

3. Attempts will be made to deliver written notices to Makawao Union Church and to adjacent residential premises two days prior to the burn.

4. No burning will be done during scheduled church services or on Sunday.

5. Signs and/or guards will be posted on Baldwin Avenue.

6. Phone calls will be attempted to the Paia phone notification list.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible. Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 6 of 18 Rev 3/2013


Page 37

EXHIBIT 2
Burn Procedures for Field 204
(adjacent to Baldwin Avenue)

Reason for listing as problem fields: Close proximity to Baldwin Avenue (These fields are also located near Paia School)
Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northeast to east) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 20 miles per hour

Weather data to determine optimum wind conditions will be from the weather stations in fields 107, 200, 205, and/or 213.
(Record wind data below prior to the start of each burn.)

2. During the summer months of June and July burning will be conducted between 0400 and 1800, excluding the peak traffic hours of 0700-0830 and 1530-1700, to minimize traffic disruptions.

3. During all months other than June and July burning will be conducted between 0400 and 0600 before classes begin to avoid smoke impacts on the school.

4. Attempts will be made to deliver written notices to adjacent residential premises (Fields 200, 204), to Paia School (Fields 200, 204), and to Holy Rosary Church (Field 200).

5. Phone calls will be attempted to the Paia phone notification list.

6. Signs and/or guards will be posted on Baldwin Avenue.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible. Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:


Page 38

EXHIBIT 2 Burn Procedures for Field 208
(adjacent to Baldwin Avenue)

Reason for listing as problem fields: Close proximity to Baldwin Avenue (These fields are also located near the Skill Village subdivision.)
Special burn procedures to minimize smoke impacts:

1. Fields 103, 106, and 207 will be burned only under the following wind conditions:

• Tradewinds (north to east) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 15 miles per hour

For field 208, harvesting of approximately 25 acres of the field may impact Skill Village homes; therefore, burning of this portion of the field will be undertaken only under the following wind conditions:

• Tradewinds (north to east) less than 20 miles per hour

The remainder of the field may be burned under any conditions except south or southeast winds.

Weather data to determine optimum wind conditions for buming these fields will be from the Paia Division weather stations nearest the field being burned.
(Record wind data below prior to the start of each burn.)

2. Attempts will be made to deliver written notices to Skill Village residential premises (Fields 207, 208), to Doris Todd School (Field 207) and to Holy Rosary Church (Field 208) two days prior to the burn.

3. Phone calls will be attempted to the Paia phone notification list.

4. Signs and/or guards will be posted on Baldwin Avenue.

5. Burning of field 208 will be conducted between 0400 and 1800, excluding the peak traffic hours of 0700-0830 and 1530-1700, to minimize traffic disruptions.

6. Due to proximity to Doris Todd School, fields 103, 106, and 207 will be harvested only during the summer months.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 8 of 18 Rev 3/2013


Page 39

EXHIBIT 2
Burn Procedures for Field 211
(adjacent to Baldwin Avenue)

Reason for listing as problem fields: Close proximity to Baldwin Avenue (This field is also located near residences in the Lower Paia area.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northwest to north/northwest winds less than 20 miles per hour

• Southwest to west winds less than 15 miles per hour

Weather data to determine optimum wind conditions will be from the weather station in field 107 and/or 213.
(Record wind data below prior to the start of each burn.)

2. Approximately 25 acres nearest the adjacent residences will be harvested unburned. The remainder of the field will also be harvested unburned if wind conditions are not favorable for burning at the time of harvest.

3. Burning will be conducted between 0600 and 1800, excluding the peak traffic hours of 0700-0830 and 1530-1700, to minimize traffic disruptions.

4. Attempts will be made to deliver written notices to Lower Paia residential premises.

5. Phone calls will be attempted to the Paia phone notification list.

6. Signs and/or guards will be posted on Baldwin Avenue.

7. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records. Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 9 of 18 Rev 3/2013


Page 7 of 18 Rev 3/2013


Page 40

EXHIBIT 2
Burn Procedures for Fields 300, 306, 500, 501, 508, 509, 602 (adjacent to Haleakala Highway)
Reason for listing as problem fields: Close proximity to Haleakala Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north to east) less than 25 miles per hour between 0400 and 0600.

• Mauka drainage winds (east/southeast to south/southeast) less than 15 miles per hour between 0400 and 0600.

• Tradewinds (north to east) and mauka winds (east/southeast to south/southeast) less than 25 miles per hour after 0830.

Weather data to determine optimum wind conditions will be from the closest weather station(s) located in fields 300, 301, 313, 502, and/or 602.
(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (to take advantage of light drainage winds at this time of day), Or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530 to 1700), to minimize traffic disruptions.

3. Phone calls will be attempted to Kamehameha School (Fields 300, 301) and to the Pukalani phone notification list (Field 301).

4. Signs and/or guards will be posted on Haleakala Highway (All Fields). Signs and/or guards will also be posted on Haliimaile Road (Field 300).

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 10 of 18 Rev 3/2013


Page 41

EXHIBIT 2
Burn Procedures for Fields for Field 401, 404, 405, 413, 505, 506, 700, 701, 702, 706 (adjacent to Pulehu Road)

Reason for listing as problem fields: Close proximity to Pulehu Road and/or Hansen Road

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north to east) less than 20 miles per hour between 0400 and 0600.

• Mauka drainage winds (east/southeast to south/southeast) less than 15 miles per hour between 0400 and 0600.

• Tradewinds (north to east) and mauka winds (east/southeast to south/southeast) less than 25 miles per hour after 0830.

Weather data to determine optimum wind conditions will be from the closest weather station(s) located in field 401, 606, 800, and/or 807. (Record wind data below prior to the start of each burn.)

2. Field 413 will be burned between 0400 and 0600 (to take advantage of light drainage winds at this time of day). For all other fields, burning will be conducted between 0400 and 0600, or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530 to 1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Pulehu Road (All Fields) and on Omaopio Road (Fields 401, 405).

4. Phone calls will be attempted to Kamehameha School (Fields 401, 413). Phone call will be made to the Kahului Airport control tower (Field 606).

5. Attempts will be made to deliver written notice to Puunene School (Field 706).

6. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated
by the Department of Health as public record.

Supervisor Signature:

Page 11 of 18 Rev 3/2013


Page 42

EXHIBIT 2
Burn Procedures for Field 511
(adjacent to Pulehu Road)

Reason for listing as problem fields: Close proximity to Pulehu Road (This field is also located near the Maui County Landfill and Ameron Quarry.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northwest to east) less than 20 miles per hour

• Southeast to south winds less than 20 miles per hour Weather data to determine optimum wind conditions will be from the weather station located in fields 504 and 604.

(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0700 (to take advantage of light drainage winds at this time of day and to reduce impact to local businesses), or between 0830 and 1800 (excluding the peak traffic hours of 1530 to 1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Pulehu Road.

4. Attempt will be made to deliver written notification to the Ameron Quarry two days prior to the burn.

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 12 of 18 Rev 3/2013


Page 43

EXHIBIT 2
Burn Procedures for Fields 707, 716, 717, 718,
902, 908, 911, 912, 914, 915
(adjacent to Mokulele Highway)

Reason for listing as problem fields: Close proximity to Mokulele Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north to east) less than 25 miles per hour

• Mauka drainage (east/southeast to south/southeast) winds less than 20 miles per hour

Weather data to determine optimum wind conditions will be from the closest weather station(s) located in fields 707, 817, 903, 906, 911, and/or 921. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (to take advantage of light drainage winds at this time of day), or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Mokulele Highway.

4. Phone calls will be attempted to the Kihei phone notification list (Fields 820, 900, 908, 911, 912, 914, 915, 916, 917). Phone call will be made to the Kahului Airport control tower (Fields 708, 716, 717, 718).

5. Attempts will be made to deliver written notices to Puunene School (Field 707), the Maui Humane Society (Fields 901, 914), Maui Hardwoods (Fields 708, 717, 900), residential premises in Hale Piilani and Kihei Villages subdivisions (Field 820), and Sugar Beach residential premises (Fields 916, 917) two days prior to the burn.

6. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in
the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 13 of 18 Rev 3/2013


Page 44

EXHIBIT 2
Burn Procedures for Fields 719, 749, 751, 753, 757, 765, 767,
919 (adjacent to Kuihelani Highhway )

Reason for listing as problem fields: Close proximity to Kuihelani Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northwest to east) less than 25 miles per hour

• Southeast to south winds less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the closest weather station(s) located in fields 749, 903, 906, and/or 921. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (and to take advantage of light drainage winds at this time of day), Or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700) to minimize traffic disruptions

3. Signs and/or guards will be posted on Kuihelani Highway (All Fields) and on Honoapiilani Highway (Fields 749, 751, 753, 757, 765, and 767).

4. Phone calls will be attempted to the Maalaea phone notification list (All Fields).

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.
Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 14 of 18 Rev 3/2013


Page 45

EXHIBIT 2
Burn Procedures for Fields 737, 741, 743, 745, 747, 761
and 763 (ad’acent to Honoa iilani Hi hwa )

Reason for listing as problem fields: Close proximity to Honoapiilani Highway, Maalaea subdivision condos and North Kihei Road

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northwest to east) less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather station located in field 749. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 0600 (to take advantage of light drainage winds at this time of day), or between 0600 and 1800 (excluding the peak traffic hours of 0700-0830 and 1530-1700), to minimize traffic disruptions.

3. Signs and/or guards will be posted on Honoapiilani Highway.

4. Phone calls will be attempted to the Maalaea phone notification list.

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 15 of 18 Rev 3/2013


Page 46

EXHIBIT 2 Burn Procedures for Fields 906
(adjacent to North Kihei Road)

Reason for listing as problem fields: Close proximity to North Kihei Road (This field is also located near the Maalaea condominiums.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northwest to north) less than 25 miles per hour

• Kona winds (southeast to southwest) less than 15 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations located in field 906. (Record wind data below prior to the start of each burn.)

2. Burning under tradewind conditions will be conducted between 0830 and 1000 to minimize traffic disruptions, except that field 9061 (portion of the field southwest of the gulch adjacent to Reservoir 91) may also be burned between 0400 and 0700 to minimize traffic disruptions on North Kihei Road. Burning under Kona wind conditions will be between 0830 and 1530.

3. Attempts will be made to deliver written notices to Maalaea residential premises.

4. Phone calls will be attempted to the Maalaea phone notification list.

5. Signs and/or guards will be posted on North Kihei Road.

6. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 16 of 18 Rev 3/2013


Page 47

EXHIBIT 2
Burn Procedures for Fields 913
(adjacent to North Kihei Road)

Reason for listing as problem field: Close proximity to North Kihei Road (This field is also close to Kealia Pond National Wildlife Refuge and the Maalaea Power Plant.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken under the following wind conditions:

• Tradewinds (northwest to east) less than 25miles per hour

• Southeast to south winds less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations located in field 906 and/or 757. (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 1800, excluding the peak traffic hours of 0700-0830 and 1530-1700, to minimize traffic disruptions.

3. Attempts will be made to deliver written notices to Maalaea condominium residents two days prior to the burn.

4. Signs and/or guards will be posted on North Kihei Road.

5. Phone calls will be attempted to the Maalaea phone notification list.

6. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible. Place a checkin the box after each item is verified completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre-Burn Checldist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 17 of 18 Rev 3/2013

Page 48

EXHIBIT 2
Burn Procedures for Fields 605, 609,
709, 710, 711, 712, 714, 715 (adjacent to Kahului Airport)

Reason for listing as problem fields: Potential to impact Kahului Airport, close proximity to Hana Highway, Kuihelani Highway/Dairy Road, Puunene Avenue, Hansen Road, Pulehu Road, and/or Haleakala Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Any winds less than 15 miles per hour with the exception of southerly winds blowing toward residences in Spreckelsville; Field 714 shall not be burned when winds are blowing towards the Kuihelani subdivision or the First Assembly of God Church

• Winds above 15 miles per hour are acceptable only if blowing from west/northwest to north/northeast Weather data to determine optimum wind conditions will be from the weather station located in field 602, 604, 606, 611, 707 and/or at the airport (near field 709). (Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0300 and 0600 in order to prevent hazards to air traffic.

3. The airport control tower will be notified via telephone the day before the burn (All Fields).

4. Signs and/or guards will be posted on Hana Highway (fields 604, 605, 607, 608, 609, 610, and 709), Pulehu Road (Field 710), Hansen Road (Fields 711 and 712), Haleakala Highway (Fields 604, 605, 610), and Kuihelani Hi ghway/Dairy Road (Fields 714, 715).

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Place a check in the box after each item is veriiied completed. Record wind data at the start of each burn in the table below. Attach this form to the completed Pre·Burn Checklist to be filed in the harvesting records.

Wind Data for Burn in Field Date:
Time Wind Speed Wind Time Wind Speed Wind
Direction Direction

I certify that I have knowledge of the facts herein set forth, that the same are true, accurate, and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Department of Health as public record.

Supervisor Signature:

Page 18 of 18 Rev 3/2013


Page 49

2013 Agricultural Burning Permit – Exhibit 3

This exhibit describes specific procedures to be followed for pre-harvest burning of sugarcane in all fields to be harvested during the 2013 season with the exception of those identified in Exhibit 2.

Burn procedures specific to each field are described in the attached Exhibit 3 checklists. The Harvesting Manager shall ensure that all fields not listed in Exhibit 2 are burned in accordance with these procedures in addition to those described in Exhibit 1. Exhibit 3 checklists specify wind conditions under which each field may be burned. Along with wind speed and direction in the field at the time of the burn, various other factors can affect the potential for ground level smoke to impact public areas during and after the burn, including plume rise (determined in part by field moisture and the presence of temperature inversions), dispersion conditions, transport winds outside of the field being burned, the location/elevation of the field, and smoldering after completion of the burn. These other factors are addressed in Exhibit 1. Together, the Exhibit 1 and Exhibit 3 procedures are intended to minimize ground level visible smoke entering areas to which the public has unrestricted access.

A. Identification of fields – Exhibit 3 procedures are being submitted for all fields or groups of fields which are scheduled to be harvested during the 2013 harvesting season or are included on the list of “unscheduled fields” with the exception of those listed in Exhibit 2. The location of each field is shown on the field map submitted with the 2013 burn permit application.

B. Suspension of burns due to changes in wind conditions – Burning shall be undertaken only under the meteorological conditions specified in this exhibit. Monitoring and record keeping procedures during the burn shall be as described in Section B(1) of Exhibit 1 except that average wind speed and direction shall be measured and recorded on the Exhibit 3 checklist prior to the start of each fire within a field. The Harvesting Supervisor in charge of the burn shall monitor wind conditions during each burn. In the event that the wind speed or direction changes during the burn, the Harvesting Supervisor shall re-evaluate wind conditions to determine whether the conditions specified in this exhibit are still being met. If the specified conditions are no longer met, the Harvesting Supervisor shall ensure that no further burns are conducted in that field until the required conditions are again met.

C. Use of weather station data for burn decisions – HC&S operates both fixed and mobile weather stations for collecting weather data to be used in making burn determinations. The weather stations to be used for making burn decisions in a field are specified in the Exhibit 3 checklist for that field. In the event that any weather station specified for use in making burn determinations in Exhibit 3 is out of service, either the mobile station or the nearest alternate station will be used instead.

Page l of 27 Rev 3/2013


Page 50

When determining whether wind speeds are within the limits specified in the Exhibit 3 checklist, the Harvesting Supervisor in charge of the burn shall consider the average wind speed being recorded by the appropriate weather station(s). If, at the time that a burn determination is being made, winds are occasionally gusting at speeds in excess of the maximum speed specified for burning in the exhibit, the Harvesting Supervisor shall monitor wind speeds prior to burning sufficiently to confirm that average wind speeds are not increasing above the maximum speed specified in the exhibit.

Allowable wind directions for burning are stated from a given direction. That is, when a northerly wind direction is specified, allowable winds are blowing from the north toward the south. In addition, allowable winds are specified in the exhibit as a range of directions starting from the first direction listed and moving clockwise through the second direction listed. Thus, if the exhibit specifies winds must be “north/northeast to southeast”, then the allowable wind directions would be from a heading of north/northeast (22.5 degrees on a compass) through east (90 degrees) to southeast (135 degrees).

Page 2 of 27 Rev 3/2013


Page 51

EXHIBIT 3 Burn Procedures for Field 109

Areas of Primary Concern: Haiku, Maliko Gulch, Kuau Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:
• North to southeast winds less than 25 miles per hour Weather data to determine optimum wind conditions will be from the weather stations in field 107, 109, and/or 110
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Kuau phone notification list

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 3 of 27 Rev 3/2013


Page 52

EXHIBIT 3 Burn Procedures for Field 112

Areas of Primary Concern: Haiku, Paia

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North to southeast winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 102, 107, 109, 110 and/or 116
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Paia phone notification list

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 4 of 27 Rev 3/2013


Page 53

EXHIBIT 3 Burn Procedures for Fields 116, 118

Areas of Primary Concern: Maunaolu, Makawao, Haiku, Paia

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northeast to southeast winds less than 20 miles per hour Weather data to determine optimum wind conditions will be from the weather stations in fields 102, 110, 116, 200 and/or 201 (Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Paia phone notification list

3. Attempts will be made to deliver written notices to Maunaolu College (fields 116 and 118) and adjacent residential premises (field 116) two days prior to the burn.

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 5 of 27 Rev 3/2013


Page 54

EXHIBIT 3 Burn Procedures for Field 117

Areas of Primary Concern: Maunaolu, Makawao, Haiku, Paia

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northeast to southeast winds less than 25 miles per hour Weather data to determine optimum wind conditions will be from the weather stations in fields 102, 110, 116 and/or 200 (Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Paia phone notification list

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 6 of 27 Rev 3/2013


Page 55

EXHIBIT 3 Burn Procedures for Field 202

Areas 0f Primary Concern: Maunaolu, Haliimaile, Paia, Skill Village

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North to southeast winds less than 25 miles per hour Weather data to determine optimum wind conditions will be from the weather stations in fields 200, 201, and/or 205 (Record wind data below prior to the start of each burn.)

2. After completion of the bum, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 7 of 27 Rev 3/2013


Page 56

EXHIBIT 3 Burn Procedures for Field 209

Areas of Primary Concern: Baldwin Beach, Spreckelsville, Skill Village, Pukalani

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North to east winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in
fields 205, 213, 602, and/or 611 (Record wind data below prior to the start of each burn.)

2. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 8 of 27 Rev 3/2013


Page 57

EXHIBIT 3 Burn Procedures for Fields 213, 214

Areas of Primary Concern: Baldwin Beach, Paia, Skill Village, Spreckelsville

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Field 213 north to southeast winds less than 25 miles per hour

• Field 214 north to east winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 107, 205, 213, and/or 611
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Paia phone notification list (field 214)
a
3. Attempts will be made to deliver written notices to Lower Paia residential premises (field 214) two days prior to the burn.

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 9 of 27 Rev 3/2013


Page 58

EXHIBIT 3 Burn Procedures for Fields 302, 307

Areas of Primary Concern: Pukalani, Kamehameha School, Omaopio/Kula Meadows, Kalialinui Gulch

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northeast to southeast winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in
fields 301, 311, 313, and/or 401 (Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Pukalani phone notification list (field 302) and to Kamehameha School (fields 302 and 307).

3. Additional fire line will be cleared along Kalialinui Gulch to reduce the potential for a jump fire (field 307).

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 10 of 27 Rev 3/2013


Page 59

EXHIBIT 3 Burn Procedures for Fields 305, 309

Areas of Primary Concern: Pukalani, Kamehameha School, Omaopio/Kula Meadows

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Any winds less than 25 miles per hour except southwest to northwest winds
Weather data to determine optimum wind conditions will be from the weather stations in
fields 301, 311, 313, 501, and/or 504 (Record wind data below prior to the start of each burn.)

2. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 11 of 27 Rev 3/2013


Page 60

EXHIBIT 3 Burn Procedures for Field 314

Areas of Primary Concern: Pukalani, Haliimaile, Maunaolu

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northeast to southeast winds less than 30 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in
fields 200, 201, 205, and/or 300 (Record wind data below prior to the start of each burn.)

2. Phone call will be made to Kamehameha School.

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 12 of 27 Rev 3/2013


Page 61

EXHIBIT 3 Burn Procedures for Fields 410

Areas of Primary Concern: Close proximity to Upcountry communities of Pukalani, Omaopio, Kula

Meadows; unpredictable/variable winds after 0800
(These fields were formerly listed as Exhibit 2 fields.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Winds north/northeast to south/southeast less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations located in fields 401 and/or other Keahua Division weather stations nearest the field.
(Record wind data below prior to the start of each burn.)

2. During the hours between 0200 and 0800, winds in this area typically blow south/southeast to east/southeast (away from populated areas), whereas after 0800 they tend to blow toward populated areas.

Due to unpredictable winds after 0800, burning will be conducted between 0400 and 0700 and completed as quickly as possible to minimize hazardous conditions. If conditions are favorable (blowing away from populated areas), however, field 400 may also be burned between 0830 and 1800, excluding the peak traffic hours of 1530-1700 to minimize traffic disruptions on nearby Omaopio Road.

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 13 of 27 Rev 3/2013


Page 62

EXHIBIT 3 Burn Procedures for Fields 402, 403

Areas of Primary Concern: Pukalani, Kamehameha School, Omaopio/Kula Meadows

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Any winds less than 25 miles per hour except southwest to north/northwest
winds
Weather data to determine optimum wind conditions will be from the weather stations in fields 311, 400, 401 and/or 800
(Record wind data below prior to the start of each burn.)

2. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 14 of 27 Rev 3/2013


Page 63

EXHIBIT 3 Burn Procedures for Fields 408, 409

Areas of Primary Concern: Pukalani, Omaopio/Kula Meadows, Lower Kula, Pulehu Road

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North/northwest to southeast winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 401, 414, 800, 805, and/or KAP
(Record wind data below prior to the start of each burn.)

2. After completion of the bum, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 15 of 27 Rev 3/2013


Page 64

EXHIBIT 3 Burn Procedures for Fields 411, 412, 414

Areas of Primary Concern: Kihei, Upcountry Communities

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northwest to south/southwest winds less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 414, 415, 805, 823, and/or KAP
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Kihei phone notification list.

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 16 of 27 Rev 3/2013


Page 65

EXHIBIT 3 Burn Procedures for Fields 416, 418

Areas of Primary Concern: Kihei, Upcountry Communities, Waiakoa Gulch and adjoining ranch lands

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North to east winds less than 15 miles per hour

• East to southwest winds less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 414, 415, and/or 823
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Kihei phone notification list.

3. Extra precautions will be taken as warranted by wind conditions to prevent a jump fire into the gulch and ranch lands adjoining field 416.

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 17 of 27 Rev 3/2013


Page 66

EXHIBIT 3 Burn Procedures for Fields 510, 512

Areas of Primary Concern: Haleakala Highway, Pukalani/Omaopio

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North/northwest to east/southeast winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in
fields 501, 504, 602, and/or 604 (Record wind data below prior to the start of each burn.)

2. After completion of the bum, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 18 of 27 Rev 3/2013


Page 67

EXHIBIT 3 Burn Procedures for Fields 802, 803, 806, 807, 808

Areas of Primary Concern: Kihei, Pulehu Gulch

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North to southeast winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 401, 800, 805, 807, and/or 813
(Record wind data below prior to the start of each burn.)

2. After completion of the bum, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 19 of 27 Rev 3/2013


Page 68

EXHIBIT 3 Burn Procedures for Field 813

Areas of Primary Concern: Kihei

(This field was former listed as an Exhibit 2 field.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northeast to east/southeast) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather station in field 807, 818, or 906.
(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 1800.

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 20 of 27 Rev 3/2013


Page 69

EXHIBIT 3 Burn Procedures for Fields 815, 819

Areas 0f Primary Concern: Adjacent National Guard Armory and Hawaiian Cement plant, Kihei

(These fields were formerly listed as Exhibit 2 fields.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (northeast to east) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather station in field 818 or field 911.
(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 1800 (early burns prefeired to lessen potential for impact on businesses in area).

3. Phone calls will be attempted to the Kihei phone notification list (Field 819).

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 21 of 27 Rev 3/2013


Page 70

EXHIBIT 3 Burn Procedures for Field 821

Areas of Primary Concern: Kihei, Maalaea

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Northeast to east winds less than 25 miles per hour

• North to northeast winds less than 15 mile per hour

• South to northwest winds less than 15 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 911, 813, and/or 823
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Kihei phone notification list.

3. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 22 of 27 Rev 3/2013


Page 71

EXHIBIT 3 Burn Procedures for Field 823

Areas of Primary Concern: Kihei, Sugar Beach

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• East/southeast to southwest and southwest to northwest winds less than 15 miles per hour (avoid burning during tradewind conditions)
Weather data to determine optimum wind conditions will be from the weather stations in fields 805, 823, 415, and/or KH-I
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Kihei phone notification list.

3. Attempts will be made to deliver written notifications to residential premises in the Hale Piilani subdivision two days prior to the burn.

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 23 of 27 Rev 3/2013


Page 72

EXHIBIT 3 Burn Procedures for Fields 903, 904, 905, 921, 922

Areas of Primary Concern: Maalaea, Kihei, Kuihelani Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• North/northwest to northeast winds less than 25 miles per hour

• Southwest to northwest winds less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 749, 757, 903, 906, and/or 921
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Maalaea phone notification list (fields 905, 921, 922).

3. Signs and/or guards will be posted on Kuihelani Highway (fields 921, 922).

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 24 of 27 Rev 3/2013


Page 73

EXHIBIT 3 Burn Procedures for Field 907

Areas of Primary Concern: Maalaea, North Kihei Road, Honoapiilani Highway

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• For the entire field, southwest to west winds less than 15 miles per hour

• For the top portion of the field (between Honoapiilani Highway and Upper Maalaea Road), northwest to north/northwest winds less than 25 miles per hour

• For the makai portion of the field (below the hauler road), northwest to north winds less than 25 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in fields 749, 757, and/or 906
(Record wind data below prior to the start of each burn.)

2. Phone calls will be attempted to the Maalaea phone notification list.

3. Attempts will be made to deliver written notifications to Maalaea condominium residences two days prior to the burn.

4. Signs and/or guards will be posted on North Kihei Road

5. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 25 of 27 Rev 3/2013


Page 74

EXHIBIT 3 Burn Procedures for Fields 909, 910

Areas of Primary Concern: Kihei, Maalaea
(These fields were formerly listed as Exhibit 2 fields.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Tradewinds (north/northwest to northeast) less than 20 miles per hour

• Kona winds (southeast to southwest) less than 20 miles per hour
Weather data to determine optimum wind conditions will be from the weather station in field 807, 818, or 906.
(Record wind data below prior to the start of each burn.)

2. Burning will be conducted between 0400 and 1800.

3. Phone calls will be attempted to the Kihei phone notification list

4. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 26 of 27 Rev 3/2013


Page 75

EXHIBIT 3 Burn Procedures for Field 918

Areas 0f Primary Concern: Maalaea condominiums
(This field was formerly listed as an Exhibit 2 field.)

Special burn procedures to minimize smoke impacts:

1. Burning will be undertaken only under the following wind conditions:

• Kona winds, southeast to southwest, less than 20 miles per hour

• North/northwest to north/northeast winds less than 15 miles per hour
Weather data to determine optimum wind conditions will be from the weather stations in field 906
(Record wind data below prior to the start of each burn.)

2. Approximately 35 acres directly adjacent to the condominiums will be harvested unburned. The remainder of the field will be harvested unburned if wind conditions are not favorable for buming at the time of harvest.

3. Phone calls will be attempted to the Maalaea phone notification list.

4. Attempts will be made to deliver written notifications to Maalaea condominium residences two days prior to the burn.

5. Signs and/or guards will be posted on Maalaea Road

6. After completion of the burn, water trucks will be sent into the field to extinguish remaining smoldering piles to eliminate smoke emissions as soon as possible.

Page 27 of 27 Rev 3/2013

MoveOn.org Gives Us a Grant!

Due to our member’s great response in voting for our cause, Stop Cane Burning was awarded a grant by MoveOn.org!  They’re giving us up to $400 to buy bumper stickers and informational cards to hand out to the public.  These cards tell folks how to report smoke at ground level:

Front of card:

BanTheBurnBigCardBleed
Back of card:

BanTheBurnCardBack

Bumper sticker:
BanTheBurn

Email info @ StopCaneBurning.org to find out how you can pick up a bumper sticker or cards to hand out.

Or download and print out the leaflet yourself: Make a Report Leaflet (2 per page)

Results of EPA/Dept of Health Meeting

We met with the EPA and Hawaii Dept. of Health.

Good news first. Your voices were heard and not only did the EPA and DOH meet with us, they said they were going to make changes to the burn permit. (We asked them not to issue a burn permit at all but that was rejected.)

Here are the terms that we were led to believe may be in the permit:

1. Clearer, more enforceable no-burn days based on meteorological conditions and Vog – NOT on the bogus system used now (are 4 peaks obscured when Blake Shiigi goes out and looks)

2. Fewer exemptions that fields have from the conditions on the face of the permit. The permit starts out saying no burns prior to 9am, no visible smoke shall enter buildings or roadways. Then it has 2 pages of fine print exempting field after field.

3. No burns before 8 or 9am

4. Designation of field #s in burn announcements so that the community can keep HC&S honest and be the watchdogs since DOH is inadequately staffed (I’ll just leave that word “inadequately” to cover a lot)

5. Some attempt to get a quicker feedback loop so that HC&S does not light a second fire after the first one drops smoke on our homes, schools and businesses. At this time, we complain, HC&S ignores us and lights another fire and Blake Shiigi sends a report to Oahu by barge or something and a week later they go, “Oh gee I guess we should have told HC&S not to light another fire that day”

Now here’s the bad news:

Last year (2012) HC&S was cited ONLY ONE TIME – and that was for burning a field not covered in that year’s permit. No citations for smothering Ma’alaea in smoke, No citations on the days Kihei Elementary, Pukalani Elementary and the Waldorf school called in complaints, no citations for all the times we were smothered. I find that impossible to believe.

Now for you folks who have had run-ins with Blake. I have to say other than hiding from me and refusing to reply to me, he has been civil even in the face of me contradicting him and attempting to pin him down to an answer. But then again, I am pretty impervious to people trying to shut me up :-)

But one person attending the meeting was irate with him and (in front of his bosses) talked about how he disrespects and belittles people who complain about smoke and how he denies there is smoke when it is right there in front of him.

I believe when people meet with us in person, they are owed civility and yes, I felt bad for Blake having to listen to this even though it was true. At the same time, it WAS something that needed to be said.

I came away thinking that there would not be any public meetings held by Dept of Health because they are well aware of the anger in our community about their abdication of their role as the protector of public health. Frankly they are scared of facing that anger…and I don’t blame them. Hopefully (but I’m not holding my breath) they will understand that they need to step up and do their job in order to diffuse that anger.

Cane burning is slated to begin Mid-March. At that time we’ll swing our campaign into high gear, distributing more bumper stickers and getting information cards out to affected residents so they know where to complain.

Together we can clear the smoke!

Karen

Ban the Burn Bumperstickers Are Here!


$1 if you can pick them up in Pa’ia. If you want us to mail them $2 includes mailing.

Or buy through Redwood Games and we’ll mail it to you:

Research: Ag Burning Damages Health

Fine Particulate Pollution and Human Health

In the last two decades, the impact on human health from exposure to fine particulate matter (“PM”) pollution has become increasingly well documented in the scientific literature. According to a principal researcher in the field, that body of work has established “reasonably compelling evidence that ambient particulate matter air pollution contributes to cardiopulmonary morbidity and mortality.” See overview of research here.

Twice in the last decade the American Heart Association has convened expert panels to analyze this “growing body of epidemiological and clinical evidence” to provide healthcare professionals and regulatory agencies alike “with a comprehensive review of the literature,” and to inform public health and regulatory policies.

In 2004, an AHA expert panel drew on the available scientific evidence to conclude that, “at the very least, short-term exposure to elevated PM significantly contributes to increased acute cardiovascular mortality, particularly in certain at-risk subsets of the population. Hospital admissions for several cardiovascular and pulmonary diseases acutely increase in response to higher ambient PM concentrations. The evidence further implicates prolonged exposure to elevated levels of PM in reducing overall life expectancy on the order of a few years.” See AHA panel report here.

A wealth of post-2004 investigations have come to a similar conclusion: air pollution, including fine particulate air pollution stemming from agricultural and other biomass burning, harms human health by compromising respiratory or cardiovascular functioning, among other critical aspects of well-being, with especially severe impacts among children, the elderly, and persons with existing pulmonary or cardio-vascular disease. Correlatively, more recent studies on the impact of eliminating or reducing exposure report a range of positive health outcomes. One such recent study in the New England Journal of Medicine found a measurable increase in life expectancy following a reduction in fine particulate pollution. Access studies by the following researchers: Arbex (2004), Dominici (2006), Miller (2007), Peters (2001), Pope (2002), Pope (2004), Pope (2006), Pope (2009).

In order to summarize and evaluate the post-2004 studies, the AHA again convened a panel of experts. The panel’s update was published in mid-2010, and it served to reinforce the 2004 conclusion that air pollution laden with fine particulates imposes untenable risks of illness and death to exposed populations. In addition, several new conclusions were reached, including the following:

  • Even short-term exposure to PM2.5 “can trigger cardiovascular disease-related mortality and nonfatal events, including myocardial ischemia and MIs, heart failure, arrhythmias, and strokes.”
  • Certain population subsets may be especially vulnerable to PM2.5-associated cardiovascular morbidity and mortality, including the elderly, persons with preexisting coronary artery disease, persons with diabetes, women, and persons who are obese.
  • There does not appear to be a discernably “safe” threshold for PM2.5 exposure.

In addition, the 2010 AHA panel summarized the evidence identifying biological mechanisms by which particulate pollution exposure likely exacerbates existing cardiovascular disease, triggers acute cardiovascular events, or instigates or accelerates chronic disease. The panel found that there is strong evidence for the proposition that such pollution “[augments] the development and progression of atherosclerosis” and “some support for a potential effect on several other CVDs [cardiovascular diseases], including hypertension, heart failure, and diabetes.” See the AHA panel’s 2010 update here.

In the last two years, research into the public health impacts of particulate pollution has continued at a furious pace. Scientists and medical researchers probe both the biological and physiological mechanisms by which this type of pollution impairs human health and attempt to evaluate the fuller measure of impacts on human populations.

One recent study in the latter category raises especially significant concern. In a study of the Canadian population, a group of 15 scientists found associations between PM2.5 pollution and ischemic heart disease even with “exposure to concentrations of PM2.5 as low as only a few micrograms per cubic meter.” The group, as well, found a near linear increase in mortality from cardiovascular disease as the ambient concentration of PM2.5 increased. See the study of the Canadian population here.

In sum, the scientific and medical literature establishes that particulate pollution, such as that generated in the burning of Maui’s sugar cane fields or from its other industrial operations, presents significant to highly serious risks to persons downwind of the emissions. The severity of these health risks depends on a number of factors, including the concentration of particulates in the pollution airstream, the length of exposure, and the medical condition and health of persons forced to inhale the cane soot. There is no evidence found so far that any amount of smoke (particulates) are “safe”.

No Burn Days Called

Notice that only a few no-burn days are called when HC&S is actually burning (March – October/November).  Notice too that in 2008 and 2009 a lot more days were called – almost 8 times as many.  Was Blake Shiigi in charge of calling no-burn days these two years?  Was the weather so very different in those years?  These are questions we need to research.

Bottom line: No-burn days are not being called as often as they should.

Sugar in the Raw(tm) Healthy?

In order to dry up the sugarcane to ready it for burning, A&B’s company, HC&S sprays Round-Up all over the cane. So when you are eating that so-called healthy raw sugar just remember that a few days prior to harvest, it was drenched in herbicide. Then it was burned, making people sick.

Healthy? Every time you buy a packet of “Sugar in the Raw” or “Maui Brand” sugar, you are responsible for this corporate public health impact. And most likely eating some of Monsanto’s Round-up with your coffee.