However, according to leading authorities and the developers themselves, the mall could certainly increase traffic, air pollution, water and energy consumption, produce more sewage and solid wastes, inject wastewater into the aquifer, threaten wildlife and natural areas, as well as increase surface runoff and other pollutants that could damage the Pupukea Marine Life Conservation District, one of only 11 such legally protected sites in the Islands.

These wide-ranging factors and common sense dictate that the City and County of Honolulu require the comprehensive analysis of a full environmental impact statement, or EIS, before the project proceeds in the development process. Mayor Jeremy Harris and the director of the Department of Planning & Permitting, Eric Crispin, should immediately direct the developer to conduct an EIS for its proposed mall.

As many people know, the North Shore Sustainable Communities Plan, the O'ahu General Plan and the Hawai'i State Plan call for the North Shore to be a rural community for the benefit of both residents and visitors.

The area proposed for the mall is designated in the Honolulu Land Use Ordinance zoning scheme as a B-1 Neighborhood Business District. The purpose and intent of B-1 is "to provide (for) relatively small areas which serve the daily retail and other business needs of the surrounding population."

The area proposed for the mall is also designated in the North Shore Sustainable Communities Plan as a "Rural Community Commercial Center" that should contain a "small cluster of commercial and service businesses which serve primarily the immediate community." The plan also declares that uses in this area should be scaled to be compatible with the area's rural character and surrounding land uses.

In seeming contrast to the reasonable guidance put forth in these relevant policies, the proposed mall would:

• Consist of six one- and two-story buildings.

• Involve project costs estimated at $17 million.

• Include a commercial bus stop and unloading area requiring the widening of Kamehameha Highway.

• Take up the bulk of a 2.7-acre property.

• Host at least 53 businesses.

• Include a sewage treatment plant and underground injection of waste as well as a 90,000-gallon reservoir for runoff and other wastewater.

• Contain an underground parking garage with more than 200 stalls.

• Bring more than 3,300 vehicle trips into and out of the property per day.

The environmental assessment, or EA, completed by the developer to date states there will be increased storm water surface pollution and runoff, and highlights issues with sewage and sewage treatment. The assessment also points to increased traffic congestion and widening of Kamehameha highway, increased use of infrastructure, possible contamination of the aquifer and pollution of the near-shore waters as possible consequences of the mall.

While the EA for the mall touches on some important issues, many serious concerns were not adequately addressed or thought out. Thus, there are ongoing, unresolved issues regarding natural resources, the nature of the proposed development, construction impacts, infrastructure concerns, cumulative impacts and community concerns.

Importantly, nowhere does the EA assess the current recreational uses of Shark's Cove, particularly the shallow end that will most likely be affected by runoff and overflows from the project. This area is highly used by families, particularly those with babies and small children, because it is safer and shallow.

Given the special vulnerability of this segment of the population, the community is concerned about the lack of assessment of the potential health impacts from the runoff, overflow, and use of effluent from its sewage treatment plant. In addition, the community wants to know what the procedures are for spills from the system during the inevitable periods of breakdown.

We have all suffered the consequences of recent sewage spills, beach closures, and threats to human safety. Everyone agrees that it is essential to plan for dealing with human waste, trash and dirty water. Because of these and other experiences, no one appreciates unplanned and irresponsible development that is not well thought out.

Therefore, at its October meeting, the North Shore Neighborhood Board formally made several recommendations to the city planning and permitting department, including:

• The government should require the completion of a full EIS (including a socio-economic impact section) for the proposed development and not issue a "finding of no significant impact."

• The City Council, Planning & Permitting, the Department of Health and other applicable agencies and entities should carefully examine the regulatory and legal issues posed by the proposed development. This examination should also look at the potential for adverse affects on the nearshore waters and the potential impact on traffic.

The community's concerns have been heightened by additional questions and accusations that have developed as the project has been discussed. In particular, complaints about the developer's track record have surfaced at the Waikiki Neighborhood Board and elsewhere.

Board members reportedly said the developer misled them into thinking the development of the 2100 Kalakaua property would feature establishments that catered more to locals. "And what did we get?" asked Rep. Galen Fox. "Niketown. A big box that has nothing to do with Hawai'i."

"We'd like the developers to stick with what they promised," Fox added.

Similarly, the developer's environmental assessment for the Pupukea mall has been described by experts as misleading and disingenuous. No reasonable citizens would want a project like this in their community without adequate planning and safeguards when these types of allegations are clouding the situation.

Members of the North Shore community cannot believe that it is a crime to raise legitimate questions about poorly planned development, potential pollution, runoff, threats to clean water and the aquifer, infrastructure overload and traffic gridlock. We feel the government and concerned residents have an obligation to protect our health and safety and to ensure that natural areas are protected for our children and grandchildren to enjoy.

We are bewildered by people who are willing to risk the safety of children and families by advancing an effort without proper analysis and review.

Until questions are answered regarding the developer's credibility and an environmental impact statement is completed demonstrating sound scientific evidence that the public will be protected, the community will continue to look to the government for responsible leadership and support on this critical issue.

Therefore, the developer should be directed to conduct an EIS for its proposed mall.

Meanwhile, the community will also continue to protect, preserve and enhance the North Shore's global treasures. Given the growing chorus requesting an EIS, and what is at stake, these steps are only reasonable.