Thomas Heberle

We do not believe that the staging areas as described in section (b) (2) are practical or safe. Compliance with the RNA, requires commercial vessels departing from Ala Wai Harbor or Kewalo Basin to cross the exclusionary zone in order to reach their assigned staging area to the west. Likewise, recreational vessels departing from Keehi Lagoon will also need to cross the exclusionary zone to reach their designated staging area. In order to have a safe transit route for larger vessels departing from Honolulu Harbor, it is important to prevent all other vessels from entering and crossing the exclusionary zone. A safer way to designate staging areas would be by berth location, and by vessel size, with a maximum vessel size specified for vessels wishing to remain in either of the 2 staging areas. We therefore strongly recommend that section (b) be revised to something like: (1) No person or vessel, other than a vessel departing or entering Honolulu Harbor may enter into an exclusionary area 3.7 nautical miles long by one (1) nautical miles wide, centered lengthwise and along a line running seaward at 208 degrees southwest of Honolulu Harbor Front Range Light. Loitering or lingering in the exclusionary zone is prohibited. (2) All vessels departing from Kewalo Basin and Ala Wai Harbor wishing to remain in the RNA must stage east of the exclusionary zone. All vessels departing from Keehi Lagoon wishing to remain in the RNA must stage west of the exclusionary zone. Vessels departing from Honolulu wishing to remain in the RNA may stage either to the east or to the west of the exclusionary zone. (3) Tugs with barges in tow, and vessels larger than 100 gross tons are prohibited from staging in either of the two staging areas in the RNA, and shall stage off-shore of the designated RNA staging areas.