Comm No 0001.06 - Response from DEM - Regulatory Powers

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Douglass Shipman Adams, Chair September 28, 2018 Page 3 3. The benefits and burdens of enforcing and regulating County policies. DEM currently regulates and enforces County programs within Solid Waste, recycling and Wastewater. The benefits of properly regulating the activities of entities within the County of Hawai`i s maintaining a clean and environmentally compliant environment. There is an obligation of government to establish standards that are understood and publically available. Once the obligations of all citizens, both personal and corporate, have been established, the enforcement of these requirements is critical. Violation of a rule/regulation with no penalty for ignoring such a rule is counterproductive and results in general dismissal of all law/regulation. The burden to the County is financial. The obligation to enforce county (HCC) law and to implement regulations requires additional personnel. For example, in order for DEM's Solid Waste Division to enforce a new litter program (of which the authority does not currently reside in DEM), or for DEM' s Wastewater Division to enforce grease trap or grease interceptor rules, would require an estimated 10 additional personnel within DEM. The associated annual cost (loaded cost) is estimated below: • Inspectors: 6 • Supervisors: 2 • Clerk IIIs: 2 $870,000 annual cost. Thank you for the opportunity to provide this response.