Please help Sara Steiner Jackson in her years long fight against PGV!!

 https://www.facebook.com/100000432255222/posts/5440588939298794/?d=n

MY MOM IS A EXTREME HERO OF MINE 😭😭😭🙏🏻 PLEASE SHARE THIS EVERYWHERE #AOLEPGV #WEAREPUNA #ITSTIMEWEBREATHE 

(Link above is the link to her Facebook post with her court reply announcement and link to her legal gofund me . My mom is a paralegal doing this for years and years in her free time . She never has time for herself and she is not rich by any means . She does this out of her own pockets and with the help of amazing people who support her . Please , if you can , help show support . Her gofund me link is in the link posted above , and her PayPal is at bottom of this letter here below , thanks guys xo jazzy) 

This is what this "stoner" was doing for 4/20:

STEINER REPLY TO DOH AND PGV 

RESPONSIVE POSITION STATEMENTS AND EXHIBITS filed 10/5/2021

1. It is my renewed position that PGVs 2014 renewal NSP to Air Pollute Puna was "administratively approved by the DOH inaction and expired in 2019 and PGV is operating since December 2020 illegally without permission to air pollute Puna and the DOH MUST shut them down immediately pursuant to HRS § 324B for failure to maintain a valid air pollution permit and failure to timely fill out an application for permission to pollute Puna residents.

2. Despite DOH wanting to limit the scope of the hearing to only the air pollution permit without emergency responses or requirements, it is my renewed position that I get to tell the Hearing Officer all about how PGV terrorized the community for weeks during May 2018 and how PGV did not follow their 1992 Emergency Response Plan in 2018;  a) they did not remove the 60K gallons of explosive Pentane  b) they did not "disassemble and remove" operating equipment out of the way of the "slow-moving" lava that "doesn't erupt from the same place twice" (ala 1987 EIS).  c) PGV did not "secure their wells" pursuant to their 1992 Emergency Response Plan.  d) PGV did nothing until the Governor ordered them too and the State had to pay to have PGV's emergency equipment: quench pump, metal plugs and mud, flown in not once, but perhaps even twice during the eruption .... 

3. PGV's attorney would love to have me labeled a conspiracy theorist and discredit me with their Exhibits PGV-074 and 080.  So, what if I posted some controversial stuff on Facebook? I certainly discovered a lot of truth in those first Exopolitic sites and they led me to research the truth about geothermal induced seismicity and how the rest of the world, besides Hawaii, deals with it.  It is called "seismic monitoring" and protocol where NOT to locate injection wells: in areas of high natural seismicity, over hidden faults, over known faults and, in an area susceptible to large natural earthquakes (M7.7 Kalapana 1975 and M6.9 Kalapana 2018) and where the island is slumping naturally into the ocean!  Anyway, because PGV is using Facebook posts, I get to use Facebook posts to bolster my position of PGV incompetence during the eruption.  See Exhibit "ST22", where an ex-PGV employee named Bob Culnan Facebooks posts already on May 9 about the metal pipes at PGV wellheads bending in the heat of the eruption and when is PGV going to do something about it and a May 11, 2018 Washington Post interview with Bob Culnan about PGV's lack of emergency response.

4. PGV plans on using EPA's opinion [PGV-067] which claims there is no harm to the environment from 10-20 or even 30 PGV injection wells crisscrossing hidden faults all in couple acre footprint because EPA doesn't have to consider the induced seismicity of geothermal wells.  IN DIRECT OPPOSITION, THE EPA does have to consider induced seismicity from other injection wells, just not geothermal wells,.  EPA's "expert opinion" is that since PGV supposedly "hasn’t contaminated the water table yet" and they stay "under fracture pressure" and "produce and inject into the same reservoir" they do no harm.   HELLO - WHETER THE EPA ADMITS IT OR NOT, PGV'S MICROFRACTURES EXIST AND ARE CUMULATIVE AND WEAKEN THE GROUND.  The EPA rebuttal is further addressed in the Larry Wood rebuttal [See Exhibit ST 17] along with an KML-enhanced Google Maps showing PGV and the fractures they created and exploit and the earthquakes they created in an area downrift from their plant which did not experience seismicity until PGV started their cooling and quenching operations May 9, 2018.

5. After reviewing PGV's "Quenching Log" and new media coverage of the eruption, my position is further bolstered that PGV and their "experts" were "CLUELESS" and experimented for weeks injecting cold water and salt water into 2000 degree wells trying to save their stockholder's investments - to hell with the environment or the rest of us living around the plant.  Look at the daily media descriptions of the admitted incompetence of the USGS,/HVO/ UH geologists, the State and County of Hawaii, Civil Defense, the imported "mud driller" and one Charlene Wardlow (who conveniently used to be a vice president of Ormat before she got the job working for the state of California).  I have attached Charlene Wardlow's article and more than several media examples of the same idiotic story of 10 out of 11 wells have been quenched and plugged while at the same time threatening that the wells could still blow up.  PGV RAN AROUND LIKE A HEADLESS CHICKEN injecting water here and there because the water was exploding off into steam every time they filled the dam wells.  So, they just kept doing it over and over and over again, each gallon of water exploding into steam equal to 8 sticks of dynamite.

6. In further support of discrepancies about PGV's fluid injections during the 2018 eruption, I present a report filed in 2020 by Ormat, Nevada titled "Damage and Repair of Puna Well KS-14" [Exhibit ST24] where the data regarding fluid injection into KS-14 does not in any way comport with the information provided in PGV-070 or the news media articles of May 2018.

7. I believe PGV knows EXACTLY how the land has fractured since Catherine Kenedi's 2006-9 monitoring experiment, because I believe they kept her seismometer network after she left [Mike Kaleikini Depo pg 173-4].  You have already seen the email from Ms. Kenedi where she says the system should still have been operating until the lava flow and she was gonna check and get back to me (in one of my Environmental Court briefs).  Q: WHERE IS THE DATA FROM THE PUNA BOREHOLE NETWORK FROM 2010 TO 2018? A: PGV HAS IT!

8. My position is the 1987 EIS, as well as the EPA in 2021, stated that PGV would be working with both HVO and USGS (1987 EIS mentions "Hawaii Geophysics" which may be some Hawaii University program?) and in 2021 the EPA thinks the USGS/HVO has working seismometers in the area to monitor seismicity in the LERZ.  What I am telling Hearing Officer Jacobson is that NOBODY in the USGS/HVO or University of Hawaii Center for the Study of Active Volcanoes or the University of Hawaii Geothermal Program has ever studied the seismicity in the LERZ since PGV appeared except for 1995 (Cooper & Dustman) and 2009 (Catherine Kenedi).  See Exhibit ST26 showing Hawaii Volcano Observatory/USGS Seismicity logs from 3/21/22 from seismometers KLUD, KIND and JOKA PROVING an earthquake in the Lower Lower East Rift Zone that shows up on KIND and KLUD (see upper right hand corners of graph) but does not show up on JOKA.  In 1995, Cooper & Dustman said it was "fruitless" to rely on USGS/HVO to monitor small earthquakes in the LERZ because HVO/USGS doesn't report them as earthquakes unless they show up on seismometers uprift PERIOD.  In 2010

9. RE: PGV-068 - Don Thomas has offered his expert opinion as an 'unpaid layperson" in 2021 (who has been pushing geothermal since the 80's) that PGV's quenching operations would not cause explosions because when you inject super-heated water into a super-hot critical environment it doesn't explode.  Hello, Mr. Thomas, PGV was not injecting superheated 30000 hot water, they were injecting cold water and salt water into hot dry wells, they even admitted they were "cooling" and "quenching" the resource with cold water and then salt water, so supercritical theory does not apply here.  See the Larry Wood rebuttal to Don Thomas as Exhibit ST18.

10. PGV offers their exhibit PGV-077, a USGS Volcano Watch article dated 4/18/2019 "What caused - or didn't cause the 2018 Kilauea eruption" which only examines the first 4 days of seismicity of the entire eruption.  See Larry Wood's rebuttal [Exhibit ST27] which then goes on to compare the earthquakes for the next several weeks of the eruption and showed exactly that PGV activity did impact the 2018 eruption separate and apart from the summit activities which had died down to nothing by May 9 at 6:00pm.

11. Finally, PGV was ordered to do an EIS by the PUC in March 2021.  Over a year later, on April 7, 2022 the Hawaii Tribune Herald  article shows that PGV has not even begun the process and is questioning it:

...the PUC's approval was contingent on several conditions placed on both PGV and Hawaiian Electric by the PUC and the state Consumer Advocate.

Mike Kaleikini, PGV's senior director of Hawaiian Affairs, said the PUC condition most significant to the power plant is that construction of an expansion at the facility cannot begin until an environmental review is fully completed.

The environmental review has itself been a longstanding roadblock for the amended agreement.  

In March 2021, the PUC suspended the PPA matter entirely until a supplemental environmental review could be completed.  Although the PUC lifted the suspension in November, the environmental review still has not begun after several back-and-forth communications between the PUC and Hawaii County over who will actually conduct the review.

"Right now we're still evaluating the PUC's decision," Kaleikini said. "We're assessing the conditions and the economics of it all.  We should know more about what it means for us in a few weeks." (emphasis added).

 So what the heck does that mean?  It isn't economically feasible for PGV to take the time and money to disclose the harm of their operations in an Environmental Impact Statement?  Is it because they know they won't pass environmental review because you don't place injection wells into active volcanic rift zones over hidden faults and in areas of natural high seismicity?  It has been a few weeks since April 7, so let us have the answer on the EIS question PGV!!!

IN CONCLUSION

 I can find plenty more articles which show the Hearing Officer the worldwide negative impacts of geothermal operations underground, phreatomagmatic eruptions caused when water and lava mix underground, the incompetence of PGV during the eruption, the lack of seismic monitoring of PGV by HVO/USGS or the University of Hawaii, the explosive properties of water in volcanic hydrothermal systems or anything else the Hearing Officer needs to see to prove PGV should not be granted any more permission to harm Puna for even one more day! 

 For the above excellent reasons and incorporating my entire filings and exhibits in this contested case, I ASK HEARING OFFICER JACOBSON TO GRANT SUMMARY JUDGMENT AGAINST PGV INCLUDING REVOCATION OF PGV'S 2014 PERMISSION TO OPERATE IN APRIL 2022 AND AN ORDER TO IMMEDIATELY FILE AN APPLICATION FOR THE 46MW PLANT because:

A. The DOH is allowing PGV to operate illegally for the last 2 years without a valid air pollution permit since their 2014 renewal application expired 5 years later in 2019.  PGV must shut down immediately as all their permits from all other agencies are invalidated by the non-existence of an active NSP Air Pollution.

B. In the alternative, if PGV finds they want to "operate legally" they must file a renewal application to the Department of Health immediately with all the information needed for an expanded 46MW plant.  The PUC has already approved the PGV expansion to 46MW so why is PGV waiting to submit a proper NSP application to the DOH for its well-known proposed expansion in 2022?

C. If PGV plans on continuing to sell power to HELCO, they must file a NSP renewal application I am demanding the contested case on PGV's 46MW expansion right now!  WE ARE NOT GOING TO HOLD A FAIR AND TRANSPARENT CONTESTED CASE ON AN 7-YEAR-OLD EXPIRED PERMIT APPLICATION.  IT IS PROPER FOR PGV TO FILE A RENEWAL NSP BECAUSE THE PUC APPROVED THEIR PPA, DEPENDANT ON AN EIS WHICH IS ALSO DEPENDANT ON PGV HAVING A VALID AIR POLLUITON PERMIT.

 DATED: Pahoa, Hawaii, April 20, 2022.

 /s/ Sara Steiner_________

 Sara Steiner, pro se Resident "Objector"

NOTE:

Larry Wood needs a new laptop with better processing capabilities and myself has fees for copying and mailing copies of motions and exhibits to Honoluu.

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