October 3, 2019
No matter what someone’s beliefs and/or opinions are on the Thirty Meter Telescope (TMT) project and astronomy on Maunakea, it is important to know the facts. If all sides are faithful to the facts, we have a better chance of learning together and finding the best path forward.
The “10 QUESTIONS ABOUT MAUNA KEA WHOSE ANSWERS MIGHT SURPRISE YOU,” posted on the Kanaeokana, Kula Hawaiʻi Network website that is being widely shared on social media and elsewhere, is not based on facts.
Part of Kanaeokana’s stated mission is to “develop and strengthen a Native Hawaiian education system.” This goal cannot be achieved by promoting a biased and inaccurate narrative to advocate for one side of what is one of the most important and divisive issues facing Native Hawaiians and Hawaiʻi today, possibly in decades.
Below are the corrections of misleading statements and misstatements made in that post.
1. Is the State of Hawaiʻi giving a repeat offender an opportunity to execute bigger violations on Mauna Kea? | 2. Is the building permit the TMT project received out of the ordinary? | 3. Do two “wrongs” make a “right?” | 4. Do all Mauna Kea structures need to go through the same permitting process? | 5. Are government officials attempting to erase Native Hawaiians’ rights to engage in cultural practices reserved by law? | 6. Are government officials preparing to treat as military targets people exercising their free speech rights or their rights to engage in traditional Hawaiian cultural and religious practices? | 7. Does the State of Hawaiʻi have clear title to Mauna Kea and legitimate rights to determine who can use it? | 8. Are government officials putting the water supply of Hawaiʻi Island residents at risk? | 9. Is Mauna Kea the only place where the TMT can do its best work for astronomers? | 10. Is Mauna Kea the best place to house the TMT
1. Is the State of Hawaiʻi giving a repeat offender an opportunity to execute bigger violations on Mauna Kea?
Yes. In 1998, 2005, 2014, and 2017 the University of Hawaiʻi (UH) faced critical audits for their mismanagement of Mauna Kea. These violations were so bad that the Office of Hawaiian Affairs successfully defended a motion for dismissal in its lawsuit against UH, the Department of Land and Natural Resources (DLNR), and the State of Hawaiʻi for their collective mismanagement of Mauna Kea. The lawsuit is ongoing. No accountability or oversight measures are in place to ensure that UH will fix its failings. Yet the DLNR and State are placing in UH’s hands the management of TMT, a project bigger than the collective 13 existing telescopes that UH has already demonstrated they cannot manage properly.
The University of Hawaiʻi has acknowledged and apologized for the shortcomings of its management of Maunakea in the last century. That history and the early audits beginning in 1998 in no way reflect the realities today.
The great advances in UH’s management of Maunakea since the 1998 state audit are well documented in subsequent independent audits. The comprehensive follow-up by the state auditor in 2014 observed:
“We found that UH has developed several management plans that provide a comprehensive framework for managing and protecting Mauna Kea while balancing the competing interests of culture, conservation, scientific research and recreation.”
This dramatic turnaround began with the 2000 Master Plan directing UH’s shift of stewardship responsibility to Hawaiʻi Island and the creation of the Office of Maunakea Management (OMKM) at UH Hilo. The community-based Mauna Kea Management Board and Kahu Kū Mauna Native Hawaiian advisory council provide guidance and counsel to UH on management matters and cultural stewardship. The highly regarded Maunakea Ranger program protects the mauna and the people who visit.
The subsequent development of the Maunakea Comprehensive Management Plan (CMP) and its four subplans involved years of consultation and community outreach. The State Board of Land and Natural Resources (BLNR) approved the CMP in 2009 and both the BLNR and the UH Board of Regents separately approved the subplans in 2009 and 2010. The CMP provides overarching management guidelines for Maunakea and the subplans address public access, cultural resources management, natural resources management and decommissioning of observatories as well as management of construction activities, education and outreach.
In 2017, 19 years after the 1998 audit that was critical of UH’s management, UH’s stewardship of Maunakea was independently lauded when it earned the Hawaiʻi Historic Foundation’s highest recognition of projects, the Preservation Commendation. Historic Hawaiʻi Foundation Executive Director Kiersten Faulkner commented that:
- “The preparation of this plan and implementation of regular, annual monitoring without a statutory requirement demonstrates the Office of Maunakea Management’s commitment to stewardship and best practices in cultural resource understanding, protection and preservation. We congratulate you on your exemplary preservation efforts.”
Regarding the Office of Hawaiian Affairs (OHA) lawsuit, one of its two claims has already been dismissed. The fact that the second claim was not dismissed out of hand does not even suggest, much less prove, validity; the simple filing of a lawsuit does not establish fact. OHA’s claim is considered to be completely without merit by UH and the State, which are vigorously disputing them in the courts where it will be evaluated.
2. Is the building permit the TMT project received out of the ordinary?
Consider this: Can you think of any other 18-story (or even 8-story) structure on Hawaiʻi Island, where building codes confine projects to a 7-story limit? Can you recall any 5-acre building being erected in a protected historic district that’s doubly safeguarded as a conservation district (e.g., the Nā Pali Coast on Kauaʻi, Kaʻena on Oʻahu, the northeastern side of Molokaʻi, and valleys such as Waimanu and Waipiʻo on Hawaiʻi Island)? Aside from the H3 Tetsuo Harano Freeway, which the U.S. Congress in 1986 exempted from an environmental law that the courts had determined H3 plans would violate (Section 4(f) of the Department of Transportation Act of 1966), TMT’s permit is unique. Even NASA didn’t get the same special treatment that TMT enjoys. In 2005, NASA’s much smaller planned Outrigger Telescopes Project, was halted. NASA’s Final Environmental Impact Statement determined that “the impact of past, present, and reasonably foreseeable future activities on cultural and biological resources is substantial, adverse, and significant.” As such, the project was not forwarded. If NASA’s far smaller undertaking was cancelled, how is it that the substantially larger TMT project is being green lighted?
TMT followed all applicable laws and regulations in gaining approval for the project. A permit was issued, and construction plans approved after environmental impacts had been reviewed at every level and found to be in full compliance with applicable laws and regulations. In particular, the Environmental Impact Statement for the project went through a rigorous public process, and was not challenged by anyone. A full discussion of the extensive efforts undertaken to ensure TMT’s full compliance with all legal requirements can be found in the conservation district use permit (CDUP) issued for the project (PDF).
It is not true that development is not permitted in the conservation district. The conservation district is categorized into five different subzones, in each of which certain land uses are allowed. Each type of subzone has slightly different rules and levels of protection. Examples mentioned—Waipiʻo, Kaʻena, and the Nā Pali Coast—are in the Protective subzone, the most environmentally sensitive category and thereby subject to a higher level of protection. The summit of Maunakea is in the Resource subzone where certain types of land uses are specifically allowed with permits such as aquaculture facilities, quarries and mines, single-family homes and astronomy facilities. Building a facility in the conservation district requires a great deal of additional review and the issuance of a CDUP, which is the process that TMT followed. The CDUP for the TMT project was approved by the Board of Land and Natural Resources (BLNR) and upheld by the Hawaiʻi Supreme Court as valid and in compliance with all legal and regulatory requirements.
From the Department of Land and Natural Resources (DLNR) website:
- The Conservation District has five subzones: Protective, Limited, Resource, General and Special. The first four subzones are arranged in a hierarchy of environmental sensitivity, ranging from the most environmentally sensitive (Protective) to least sensitive (General). The Special subzone defines a unique land use on a specific site.
The use of Conservation District lands is regulated by Title 13 Chapter 5 of the Hawaiʻi Administrative Rules and Chapter 183C of the Hawaiʻi Revised Statutes. These rules and regulations identify land uses that may be allowed by discretionary permit as well as impose fines for violations.
The observatories on Maunakea are located in the resource subzone of the conservation district, where astronomy facilities are explicitly allowed with a management plan and permit approved by BLNR, under HAR § 13-5-24. The TMT project has met both requirements: (1) a comprehensive management plan for Maunakea, as discussed in the next paragraph, was accepted by the university and approved by BLNR; and (2) a CDUP issued by BLNR after 44 days of hearings where more than 20 parties presented evidence, presented and cross-examined witnesses, and participated in the crafting of the final decision and order adopted and issued by BLNR.
To learn more about Hawaiʻi’s conservation district subzones visit the Office of Conservation and Coastal Lands (DLNR) site.
The Outrigger project mentioned in the “Answer” above is not comparable to TMT. In the case of the Outrigger project, a Hawaiʻi court ruled that a comprehensive management plan (CMP) was a prerequisite to that project’s development, in addition to existing management plans. Therefore, the project was cancelled because there was no CMP at the time.
A CMP was developed for Maunakea and approved by BLNR in 2009. Again, TMT met all of its regulatory and statutory requirements, and Hawaiʻi’s highest court upheld that process following BLNR approval.
3. Do two “wrongs” make a “right?”
Perhaps more “wrongs” matter. It seems 13 “wrongs” make a “right” for the Board of Land and Natural Resources (BLNR) and the Hawaiʻi State Supreme Court. The Supreme Court had to determine if the 5-acre, 18-story TMT plans would harm the cultural, historic, and environmental resources of the historic district and conservation zone of Mauna Kea. If it would, TMT’s conservation district use permit granted by the BLNR would have to be overturned. Instead of contending that the TMT would not cause harm, the Supreme Court adopted the BLNR’s argument that the 13 telescopes had created so much damage that one more project couldn’t make the problem worse, even though the TMT would be built on an untouched, pristine northern plateau of Mauna Kea. As dissenting Supreme Court Justice Michael Wilson affirmed, such twisted logic “violates norms of environmental law.” It also runs counter to ethics about truth telling and plain common sense. This questionable ruling is what State Attorney General (AG) Clare Conners insists (in a June 20, 2019 press conference) “must be respected.”
The university and the observatories have followed the law and obtained the requisite approvals from numerous state and county agencies. Citing a dissenting opinion instead of the majority opinion of the Hawaiʻi Supreme Court demonstrates an intent to mislead about the law, and how it should be interpreted.
Opponents like to cite Justice Wilson’s dissenting opinion because it supports their viewpoint in opposition to TMT. But that dissenting opinion is without legal effect because all other members of the Court rejected that opinion. Among other strict requirements, it should be noted that the 13 telescopes today will be reduced to 9 since the conservation district use permit (CDUP) approved by the Board of Land and Natural Resources (BLNR) and upheld by the Hawaiʻi Supreme Court requires that the university permanently decommission three telescopes on Maunakea as soon as reasonably possible, and that at least two additional facilities be permanently decommissioned by December 31, 2033. No new observatories can be constructed on those five sites.
4. Do all Mauna Kea structures need to go through the same permitting process?
No. In 1968, UH built its UH 2.2-meter Telescope without a permit. That same year the Air Force Cambridge Research Laboratories built a facility without a permit. (It was later transferred to the UH Institute for Astronomy in 1970 and still later to the UH Hilo Department of Physics in 2003.) Following public protests about the unlawful and inappropriate use of Mauna Kea, the BLNR did not order UH to dismantle the unpermitted structures. Instead, in 1977 the BLNR issued after-the-fact permits for the telescopes—one of the more notable chapters in the larger story of 50 Years of Mismanaging Mauna Kea. In contrast, on June 19, 2019, government officials tore down two hale built on Mauna Kea well off of existing roadways and far from the planned TMT construction and staging areas. In a recent June 20, 2019 press conference held by state officials, a reporter asked, “Did the structures interfere? Would they interfere with any construction activities that will be happening?” DLNR Chair Suzanne Case said, “Uh, potentially. They were removed because they were unauthorized structures.” In other words, the structures lacked building permits. The reporter followed up by asking, “Will that make the construction easier for them to be gone?” AG Conners replied, “Yes, it is a safety and security reason. We do need to ensure that those structures are not erected, for safety and security reasons.” Conners didn’t explain whose safety and security were improved when the structures were destroyed.
The original “answer” twists facts in an effort to mislead.
All telescopes currently on Maunakea have proper permits, so this claim is misleading at best. The way the question is posed ignores the fact that permitting procedures have changed over the last 50 years.
The first three astronomy facilities were constructed shortly after the General Lease that included the Mauna Kea Science Reserve was granted to the University of Hawaiʻi in 1968: the 88” Telescope Facility (completed 1970); 24” Planetary Patrol Telescope (completed 1968); and the 24” Air Force Telescope (completed 1968). According to a staff report to the Board of Land and Natural Resources (BLNR) regarding after-the-fact permits, decision makers concluded that the 1968 General Lease assumed construction of the observatories was permitted in conjunction with the purposes of the Mauna Kea Science Reserve. All three astronomy facilities obtained building permits from the County of Hawaiʻi prior to construction.
When a question was raised about the need for a BLNR permit, UH, in cooperation with the Department of Land and Natural Resources (DLNR), subsequently sought a permit from BLNR. In a 1976 memorandum from DLNR staff to BLNR, staff reported that the after-the-fact permit “would provide a clean bill of health for all existing activities on the summit[.]” In addition, it would help, lay the foundation for what every future applicant may expect to encounter.”
All subsequent astronomy facilities did, in fact, obtain a Conservation District Use Permit from BLNR prior to construction. The TMT project was approved after complying with all applicable procedures, as confirmed by the Hawaiʻi Supreme Court.
The unpermitted structures removed in June 2019 by the Department of Hawaiian Homelands (DHHL) and DLNR, like the Puʻu Huluhulu structure recently removed on September 6, 2019 by DHHL, did not abide by any current building and permitting procedures. Unlike TMT, the builders of these unpermitted structures went through no governmental or community approval process.
5. Are government officials attempting to erase Native Hawaiians’ rights to engage in cultural practices reserved by law?
Based on government officials’ comments at their June 20, 2019 press conference, the only right they acknowledge that Native Hawaiians possess is the right to freedom of speech. AG Conners set up a binary choice for Hawaiians saying, “There is a difference…between lawful speech and unlawful conduct.” Governor Ige similarly proclaimed, “To those of you who want to exercise your constitutional right of free speech to express your opinion on this project, we welcome your voice and we remind you of your obligation to conduct yourself in compliance with laws and without endangering the lives of others.” However, freedom of speech is not the only right that Mauna Kea protectors can exercise on Mauna Kea. The State of Hawaiʻi Constitution, Article 12, Section 7, and Judge Robert Klein’s Public Access Shoreline Hawaiʻi ruling, ensure legal protections for Native Hawaiians to engage in traditional cultural, subsistence, and religious activities—which are at the heart of their efforts to protect Mauna Kea from a mega undertaking. Such practices are the core reasons the Mauna Kea protectors built two ahu in 2015, which government officials also recently demolished.
The university has always upheld Native Hawaiian rights to engage in cultural practices on Maunakea, not just in principle, but with human and financial resources. By physically maintaining the roadway the university has enabled greater access for cultural practitioners than ever before. And UH’s Maunakea Rangers help ensure the personal safety of cultural practitioners and others on the mauna. UH conducts rigorous, annual monitoring of more than 260 historical, archaeological and cultural sites, including shrines, ahu and burials based on long term monitoring and burial plans approved by the State Historic Preservation Division. The sites were identified in an extensive archaeological inventory survey that the university completed for the 11,288-acre Maunakea Science Reserve and access road.
The current UH management plans and proposed draft of the administrative rules for Maunakea clearly state that Native Hawaiian rights are to be upheld.
6. Are government officials preparing to treat as military targets people exercising their free speech rights or their rights to engage in traditional Hawaiian cultural and religious practices?
KAHEA confirmed that the DLNR contracted the LRAD Corporation to use its LRAD 100X MAG-HS system from June 15, 2019 through December 15, 2019. The LRAD Corporation boasts that their sound cannons “have proven highly effective for many military applications.” Its technology “focuses sound in a 15 degree – 30 degree beam” to deliver “scalable, non-lethal, non-kinetic deterrent tones” that can “disperse hostile crowds” and “establish large standoff zones” allowing its users to “safely initiate EOF [escalation of force] protocol.” “Created for the U.S. Military after the terrorist attack on the USS Cole in 2000, LRADs were designed as acoustic weapons meant to repel anyone exposed to them. By emitting sound at an almost-intolerable amplitude, they force people in the device’s path to flee,” according to NBC News. In a December 5, 2014 Black Lives Matter event, the New York City police used an LRAD sound cannon “to emit a series of sharp, piercing beeps directed at people who in some cases were less than 10 feet away. Soon afterward, six of those who were nearby at the time and said they had developed migraines, sinus pain, dizziness, facial pressure and ringing in their ears filed a lawsuit challenging the police’s use of the device,” reported the New York Times. Despite two failed NYPD attempts to have the lawsuit dismissed, the plaintiffs are proceeding with their case alleging excessive use of force.
Despite false allegations and speculation about the use of military sonic weapons, the Department of Land and Natural Resources (DLNR) confirmed that low-end LRAD equipment was purchased solely for communication with large crowds and not for use as a weapon. Restraint has been practiced by both sides; the protest leaders have advocated Kapu Aloha, which has been met with restraint and respect by law enforcement. The way the arrests were carried out on July 17, 2019 is an example of that.
7. Does the State of Hawaiʻi have clear title to Mauna Kea and legitimate rights to determine who can use it?
No. The Mauna Kea summit is ceded land—that is, part of the roughly 1.8 million acres seized from the Hawaiian Kingdom government and Queen Liliʻuokalani by a cabal of sugar businessmen and missionary descendants with U.S. military backing—an undertaking that President Grover Cleveland called “an act of war.” The cabal gave the stolen property to the U.S., and the U.S. in 1959 transferred 1.4 million acres of the property to the State of Hawaiʻi for purposes such as “the betterment of the conditions of native Hawaiians,” as stipulated in Section 5(f) of the Admission Act. As such, Hawaiians have more than a spiritual connection to the Mauna Kea summit. They have historical, political, and economic claims to these lands as well.
The University of Hawaiʻi recognizes the illegal overthrow of the Kingdom of Hawaiʻi and acknowledges its impacts, as did the United States Congress in 1993. Nonetheless, court decisions up to and including rulings by the U.S. Supreme Court affirm that the State of Hawaiʻi possesses the legal authority to lease the land. The Admissions Act § 5(f), which created the State of Hawaiʻi public trust lands commonly referred to as ceded lands, identifies multiple purposes for these lands and these purposes are affirmed in the Constitution of the State of Hawaiʻi. The first of the purposes is the “support of the public schools and other public educational institutions,” and the second of these purposes is the “betterment of the conditions of Native Hawaiians.” As the sole provider of public higher education in the state, the University of Hawaiʻi is clearly identified as an intended beneficiary of the public land trust.
8. Are government officials putting the water supply of Hawaiʻi Island residents at risk?
Yes. If we take a look at Oʻahu’s struggle, the risks for Hawaiʻi are clear. Long ago the Navy assured Oʻahu residents that Navy fuel storage tanks were safe. They were dead wrong. The Sierra Club confirmed that “at least 200,000 gallons of fuel have leaked into the surrounding environment” of Kapūkaki (aka Red Hill). Hawaiʻi County and Department of Health officials certainly are aware of the leaky Navy tanks and Oʻahu’s troubled water supply. Yet they are turning a blind eye and placing Hawaiʻi water sources in similar danger. The existing telescopes on Mauna Kea involve multiple hazardous materials—fuel, hydraulic fluid, paints and related solvents, oil and lubricants, and mercury. Many Hawaiʻi Island residents rely on water that filters through Mauna Kea, beginning at the summit where the telescopes sit. TMT will include two 5,000 gallon tanks installed two stories below ground level, one for chemical waste, the other for human waste. How and when would anyone know that the tanks are leaking toxic liquid into the water sources families depend on? Why would the Department of Health gamble with the health and safety of Hawaiʻi Island’s water supply?
Regarding the alleged threat to the island’s freshwater supply, comprehensive research by expert hydrologists confirms that TMT and the existing 13 telescopes pose no danger to the aquifer. Although groundwater is the primary source of drinking water in Hawaiʻi, there are no wells extracting groundwater near the summit of Maunakea. The nearest wells are located approximately 12 miles away in Waikii Ranch along Saddle Road.
Furthermore, according to 2017 Contested Case Hearing Findings of Fact, Conclusions of Law, and Decision and Order (PDF), [at page 94, item 506 and attachments] the water supply comes from rainfall at a significantly lower elevation, about 8,000 feet, rather than the 14,000 foot summit of Maunakea. The site of the telescopes is so high that any rainfall in that area would take thousands of years to seep through the ground and enter the water table, and any contaminants would be filtered out before reaching the water table. Furthermore, there are no wells extracting groundwater near the summit of Maunakea. The nearest wells are located approximately 12 miles away at the Waikii Ranch 8,000 feet below the summit (more information and research on the hydrology of Hawaiʻi Island is attached).
The chart presented in the “answer” misleadingly appears to be a cross section of the mauna, and the elevation scale on the left side of the chart measures up to 2,000 meters; the mauna is twice that high, about 4,000 meters. Thus, the chart appears to be a cross section along Saddle Road about 6,000 feet below the summit.
Regarding the comparison to Red Hill, Red Hill is an 18-tank, bulk fuel storage facility that is capable of holding millions of gallons of jet fuel and diesel ship fuel. TMT’s system consists of three tanks that can hold a total of twelve thousand gallons.
TMT’s fuel storage area and piping will be double-walled and equipped with leak monitors and was never intended to hold nearly the same amount of fuel as the Red Hill tanks. As further detailed in the Final Environmental Impact Statement for the project, TMT is being designed to leave zero waste on the mountain. It is a total closed wastewater system, meaning all waste will be collected and transported down the mountain for treatment and/or disposal. No wastewater will be released in the summit area. TMT will also recycle and reuse solid and non-hazardous water materials as much as possible. TMT has also eliminated the use of mercury project-wide.
9. Is Mauna Kea the only place where the TMT can do its best work for astronomers?
No. La Palma in the Canary Islands is a prime alternative. The Canary Islands are a group of seven islands in the Atlantic that sit off the coast of Morocco but are politically part of Spain. An article entitled, “La Palma is another favorite destination for the world’s astronomers,” reports that “it is one of the best places in the world to observe the night sky. It sits more than 7,800 feet above sea level, putting it above the inversion layer where clouds usually form.” It also is endowed with “clear skies, perfect weather and near zero light pollution.” As reported in El Pais (English version), “Gary Sander, the project manager of the TMT, said: ‘…We would be very happy to build it in the Canaries. With the TMT on La Palma we could do marvelous astronomy.’” TMT’s La Palma web page boasts that La Palma is one of only “two privileged places,” including Mauna Kea, “that meet the best astrophysical conditions in the world.” Mauna Kea is not unique in being able to fulfill astronomers’ hopes for TMT?
The best sites in the Canary Islands simply do not measure up to Maunakea in terms of viewing conditions or number of high quality nights.
Located above approximately 40 percent of Earth’s atmosphere, Maunakea has a climate that is particularly stable, dry and cold; all of which are important characteristics for capturing the sharpest images and producing the best science. In addition, the atmosphere over Maunakea offers exceptional conditions for astronomical measurements with adaptive optics, which will be equipped on TMT.
Astronomers measure the quality of a site in several ways, one of the most important of which is simply called “seeing.” This is a measure of atmospheric distortion, the amount of turbulence in the atmosphere above the telescope that distorts or blurs the image. In short, it is a measure of how much stars twinkle at the site. Seeing is measured in terms of the smallest discernible detail in arcseconds. A good site will have seeing of less than one arcsecond. Chile is considered to be one of the best places on Earth for astronomy and superior to the Canary Islands. About 70 percent of the global astronomical infrastructure is located there. The best Chilean sites have seeing that averages around 0.7 arcseconds at best. Maunakea can have seeing that averages around 0.4 arcseconds when it is good, nearly twice as good as Chile.
10. Is Mauna Kea the best place to house the TMT?
If we take seriously the words of AG Conners (in a June 20, 2019 press conference), the answer is clearly, “no.” She reminds us that “Mauna Kea has very limited resources. Restroom facilities are limited. Water is rationed. The roads are unimproved. And even under normal conditions they can be dangerous. And altitude is also a danger on Mauna Kea. As we know in the recent weeks, altitude sickness can come on quickly and it can cause physical damage. Medical facilities are not available on Mauna Kea. And therefore it is difficult to respond to the quick onset of altitude sickness, which can be potentially life-threatening.” Interestingly, Conners’ comments were aimed at dissuading Mauna Kea protectors from venturing to Mauna Kea. No similar cautions were directed at construction workers or astronomers.
There are protocols in place to minimize the effects of altitude sickness for workers on Maunakea, such as overnighting at the mid-level facilities to acclimate. Careful training is provided so those who work on the mauna have full understanding if not experience with the effects of altitude and appropriate emergency procedures. Routine procedures for those who work on the mauna involve medical emergency training and equipment, and supplies like oxygen. This preparation reduces the risks of altitude sickness for those regularly working on the mountain. There are more risks to those who do not routinely travel to high altitudes and who do not have training. It is also important to note that emergency resources on Maunakea are limited, and these limited resources are strained when very large groups ascend the mountain without prior notice or preparation.