Public Comments and Responses to the IRSWMP (Appendix I) - 2009

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time. The Plan Update's $82 per ton cost estimate therefore is not a credible estimate of either short- or long -term costs for purposes of comparing landfill options. When properly adjusted, the per ton cost estimate will be at least equivalent to and perhaps substantially more than the $99 per ton cost the City & County of Honolulu is now paying to ship solid waste to a landfill in Washington state. Second, the Plan Update fails to account for the traffic and safety concerns and costs associated with trucking all of East Hawai'i s trash to the West Hawaii Landfill. The County previously has claimed traffic impact from trash hauling will be "minimal" because there will be "only' a dozen or so waste truck round trips a day from Hilo to South Kohala. As the Plan Update notes, that works out to at least 4,455 trips a year, with the trucks running 362 days a year. The County is not realistically assessing the impact on residents: these are huge, 20 -ton trucks. With their weight and size, they will have difficulty with the curves and grades of the Hawaii Belt Road and Waikoloa Road, and will hasten the deterioration of those roads. The trucks will slow traffic for all other drivers, including residents commuting from East Hawaii to West Hawai'i. Traffic is already heavily congested through Waimea town, and these trucks will only add to the delays. These huge trucks will pass nearby schools in both Waimea and Waikoloa, and create dangers for schoolchildren and other residents. Any traffic accident with these trucks would have terrible consequences. And, no matter how they are designed or maintained, these unsightly trucks will occasionally spill waste and debris onto the roadway. Third, the Plan Update fails to account for the economic and social impacts of having the island's only landfill right next to the island's primary resort area. The Kohala Coast resorts create thousands of jobs for island families, and help provide the tax revenues to fund many of the County's services. By trucking trash and dumping it on the resorts' doorstep, the County recklessly risks jeopardizing the long -term economic health of the island's tourism industry. The Big Island' tourism industry is already facing severe challenges, and KCRA considers the current economic situation to be near a crisis. Fourth, the Plan Update fails to account for the environmental related costs of trash hauling to West Hawai'i. Under the County's previously proposed plan, more than 70,000 additional tons of waste would be dumped each year into the West Hawai'i Landfill. The county has never studied whether such an increase in the amount and frequency of dumping would increase dust, noise, odor, or other emissions from the West Hawai'i Landfill, or how that might affect the nearby resorts or residents. The County also has never studied whether dumping and compacting waste in quantities far larger than originally projected could have any short -term or long -term impacts on soil or water quality around the West Hawaii Landfill. Even after KCRA and numerous other citizens objected to the County's Environmental Impact Statement for the East Hawaii Sort Station, the County never conducted those necessary studies. Any program to begin large -scale hauling of trash from East Hawaii to the West Hawai'i Landfill would be subject to legal challenge under state environmental laws. The Plan Update does not estimate either the costs required to conduct the necessary environmental studies, or the costs arising from legal challenges. Fifth, the Plan Update fails to account for all costs associated with shortening the life of the West Hawaii Landfill. The Plan Update acknowledges that if waste from East Hawaii is added the West Hawaii Landfill's capacity would be exhausted "11 years sooner," but in fact the West Hawaii Landfill could be full much earlier than that if the island's population PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 21