HomeMy WebLinkAboutCOM 0482.218 2024-2026P/ Comd l
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GOMN.982
From:
Georjean Adams
Sent:
Sunday, November 16, 2025 4:20 PM
To:
Council Testimony
Cc:
Hustace, James
Subject:
Bill 83 Draft 2 Testimony
I oppose Bill 83 Draft 2 as long as the County has no municipal/industrial compost facilities
that can take "compliant" foodware and serviceware as required by the proposed ban on
plastics.
If the Bill is nevertheless adopted, Section 20-05-05 Education program should be amended
to include providing information that compliant materials cannot be composted in the
Count at this time and must be landfilled due to the lack of private and/or public facilities
that meet CMA or BPI certification requirements. Furthermore, no provider of Bill83
compliant materials should make any unqualified marketing claim of "compostable" per the
FTC "Green Guides" prohibiting misleading environmental marketing claims [Referto 16 CFR
Part 260 found at https•//www ftc gov/sites/default/files/attachments/press-releases/ftc-
issues-revised-green-guides/greenguides.pdf]. Specifically Section 260.7 states:
§ 260.7 Compostable Claims.
(a) It is deceptive to misrepresent,
directly or by implication, that a
product or package is compostable.
(b) A marketer claiming that an item
is compostable should have competent
and reliable scientific evidence that all
the materials in the item will break
down into, or otherwise become part of,
usable compost (e.g., soil -conditioning
material, mulch) in a safe and timely
manner (i.e., in approximately the same
time as the materials with which it is
composted) in an appropriate
composting facility, or in a home
compost pile or device.
(c) A marketer should clearly and
prominently qualify compostable claims
to the extent necessary to avoid
deception if:
(1) The item cannot be composted
safely or in a timely manner in a home
compost pile or device; or
(2) The claim misleads reasonable
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Ref. To:
Ref. Dale_ ��y 1 9 2025
consumers about the environmental
benefit provided when the item is
disposed of in a landfill.
(d) To avoid deception about the
limited availability of municipal or
institutional composting facilities, a
marketer should clearly and
prominently qualify compostable claims
if such facilities are not available to a
substantial majority of consumers or
communities where the item is sold. [comment - having NO facilities
guarantees deception]
We already suffer from public misperception that our Transfer Station recycling operations
are a joke - ie, that everything goes to the landfill or gets dumped in the ocean. This bill will
only appear to substantiate that erroneous belief.
As stated in my comments to the Council's Policy Committee on Environment and Natural
Resource Management (attached), this bill is premature until we have holistic life cycle
management infrastructure for the island.
Georjean Adams
Kamuela
---------- Forwarded message ---------
From: Georjean Adams <georieanC@gmaiLcom>
Date: Mon, Oct 6, 2025 at 2:01 PM
Subject: Bill83 Draft 1 Testimony
To:<counciltestimony@hawaiicounty.gov>
I oppose the draft Bill 83 amending Chapter 20 of the HCC Relating Plastic and Polystyrene Waste to be
considered at the October 8, 2025, meeting of the Policy Committee on Environment and Natural
Resource Management.
As with the current ban on polystyrene food serviceware, Bill83 is misleading and inappropriate in
requiring use of the specified alternatives for which
THERE ARE NO VIABLE MUNICIPALANDUSTRIAL COMPOST FACILITIES ON HAWAII ISLAND TO
SAFELY MANAGE THESE WASTES.
As a result, these polystyrene and "compostable" wastes will continue to be landfMed at the West
Hawaii Sanitary Landfill, straining its capacity and likely contributing to methane production and release
from the landfill cbunterto the climate goals of the state and county. (For those worried about
microplastics in landfill [eachate, most of it is from fibers and technology for screening out microplastics
is under development.) About the only benefit of this bill is that litter composed of "legal" food
serviceware will contaminate the environment for "only" around a year before biodegrading compared to
long-lived plastic food serviceware litter. Surely the Council is not saying it's OK to litter these
"degradable" products? Instead, the Council should be encouraging safe reuse and/or recycling of food
serveware and, most importantly, enforcing proper disposal in a sanitary landfill at end of life.
Question - Does the Countyknow whether or not the polystyrene ban has resulted in home composters
contaminating and/or degrading their compost under the false impression that CMA or BPI -certified
products are backyard compostable?
I recommend the Council hold off on banning plastics until there is a recyclables landfill ban ordinance
in place, as proposed by myself and the Environmental Management Commission, that will phase in
Landfill restrictions only when DEM is able to show that mandated substituted wastes can actually be
recycled on island.
Georjean Adams
Kamuela, Hawaii
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