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Mr. Ramzi I. Mansour SUBJECT: HO`OMALU AT WAIKOLOA(WAIKOLOA WORKFORCE RENTAL HOUSING)HRS §201H- 38 APPLICATION-WAIKOLOA,HAWAII September 30, 2022 Page 2 services,plus landfill diversion and recycling priorities,for the County of Hawai`i. We thank you for your comments. In acknowledgement, the requested exemption for solid waste fees has been removed from the final 201H application that will be submitted for Ho`omalu. Exhibit 19 Waikoloa Workforce Rental Project Draft Construction Schedule Project Completion Identified as January 2026 Concerns for the DEM-SWD • This timeline gives the Department of Environmental Management and its Solid Waste Division 4 years to develop a comprehensive plan to resolve anticipated Solid Waste issues relating to the planned 228-unit project of which 142 units are currently zoned for Residential Properties o Concern #1 - Residential Solid Waste Disposal is offered free of charge at West Hawaii Sanitary Landfill. The nearest facility is the Puako Transfer Station located approximately 8 miles North of this Ho'omalu Housing Project. The West Hawaii Sanitary Station Landfill, located 1 mile south of this Ho'omalu Housing Project, accepts residential waste at a fee of$116 per ton (2,000 lbs. per ton). There is no current consideration for upgrades to nearby County Solid Waste facilities to accommodate the additional 228-unit project. As an apartment rental project, solid waste disposal would not occur by individual tenant visits, but rather by a commercial contractor utilizing the West Hawaii Sanitary Landfill or Pu'uanahulu Landfill. It is hoped that the subject property can accommodate more affordable homes than the 142 it is now zoned for, and we acknowledge that this may accordingly generate more trash than 142 homes'. However, the project is in alignment with County goals to provide more affordable housing options for residents and moreover, is not in itself expected to drive population growth. Exhibit 24 Traffic Assessment Concerns for the DEM-SWD Page S (Comment) "...no growth in traffic was assumed in the vicinity between Years 2019 and 2022." • The Traffic Assessment provided for review references State of Hawaii, Department of Transportation, Highways Division data collected from its HDOT RIMS Traffic Station Analyzer o Concern#2-The referenced materials were collected in January of 2019. It should be noted that the Department of Environmental Management - Solid Waste Division began its Final Closure Project of the South Hilo Sanitary Landfill in August of 2019 with completion of the Landfill Closure Project in June of 2020. This Ho'omalu Housing Project should consider updating its data to ensure additional 1 Following recent updates to the site plan,the final 201H application for Ho'omalu will reflect a total of 229 rather than 228 units.