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Home My WebLink AboutCOM 0482.289 2024-2026P /counci l bill 85 CDMM, yg2 � c-) From: Georjean Adams ZA oC-� Sent: Tuesday, December 2, 2025 7:36 AM o ?c- To: Council Testimony [ Cc: Hustace, James; Mahinakai50 e) C Subject: Bill 83 Draft 2 Testimony for December 3, 2025 r Zr F- M E3 Y I remain opposed to Bill 83 Draft 2 primarily because there are no available compose collection and processing facilities in the County that meet the requirements of the bill that would serve a substantial majority of people on island, nor is there likely to be in the foreseeable future without significant support from the County. To pass this impractical and misleading bill is a disservice to the County and to our goal of solid waste reduction and recommendations made in the 2019 Integrated Solid Waste Management Plan. At worst, it will result in contaminated compost that will add to our landfilled solid waste and/or environment. At best, it supports reusable food/serviceware which should reduce waste going to the landfill - if an economically sustainable reuse infrastructure can be shown to survive here. To that end, I recommend deleting paragraph (d) underthe definition of "Reusable." If reusable serveware is indeed part of an "established system" as provided in (c), it shouldn't matter what food -safe material is used. "Reusable" refers to foodware or serviceware that is repeatedly returned to the food service provider or to a reuse service provider for ieuse and: (a) Explicitly designed and marketed to be used multiple times for the same product or for another foodware use in a supply chain without undergoing a change in form; (b) Designed for durability to function in its original condition to ensure the foodware can be conveniently and safely reused for multiple cycles; (c) Part of an established system to be repeatedly recovered, inspected, cleaned, and reissued into the supply chain for reuse for multiple cycles -,-,and My previous comments, attached, stand. Bill83 should be postponed and modified untilthe County (and DEM) can show that there is comprehensive life cycle management infrastructure in place. Georjean Adams Kamuela, Hawaii Comm. r Ref. To: Ref. Date DEC - 3 2025 ---------- Forwarded message --------- From: Georjean Adams Date: Sun, Nov 16, 2025 at 4:20 PM Subject: Bill83 Draft 2 Testimony To:<counciltestimony(clhawaiicounty gov> Cc: Hustace, James <iames hustace(cOhawaiicounty 2ov> I oppose Bill83 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 County 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 Bill 83 compliant materials should make any unqualified marketing claim of "compostable" per the FTC "Green Guides" prohibiting misleading environmental marketing claims [Refer to 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 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 Date: Mon, Oct 6; 2025 at 2:01 PM Subject: Bill 83 Draft 1 Testimony To:<counciltestimony(o)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, Bill 83 is misleading and inappropriate in requiring use of the specified alternatives for which THERE ARE NO VIABLE MUNICIPAL/INDUSTRIAL COMPOST FACILITIES ON HAWAII ISLAND TO SAFELY MANAGE THESE WASTES. As a result, these polystyrene and "compostable" wastes will continue to be landfilled at the West Hawaii Sanitary Landfill, straining its capacity and likely contributing to methane production and release from the landfill counter to the climate goals of the state and county. (For those worried about microplastics in landfill leachate, 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 County know 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