HomeMy WebLinkAboutCOM 0800.006 2010-2012 NSY OF H4
William P.Kenoi `o°. 'r9''•.
Mayor .. �y6i;, Sherman Warner
,,I,4 Chair
• ;'4% ' ' ' Dora Beck,P.E.
Acting Director
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ENVIRONMENTAL MANAGEMENT COMMISSION
25 Aupuni Street•Hilo,Hawai'i 96720-4252
(808)961-8083•Fax(808)961-8086
October 29, 2012
Dominic Yagong, Chairman
and Members of the Hawai'i County Council
Hawai'i County Building
25 Aupuni Street __
Hilo, HI 96720 c-='
Re: Bill No. 286
Amending HCC Chapter 20, Art. 3,
Relating to disposal of commercial cooking oil waste and commercial fats, oils and
greases
Dear Chairman and Council Members,
By unanimous vote of members present at the Environmental Management Commission
("EMC") meeting of October 24, 2012, the EMC decided to forward to the Hawai'i County
Council a positive recommendation on the above-referenced Bill No. 286 (Draft 2), subject to
the comments and recommendations below.
The EMC generally supports the intent of this bill, to encourage recycling of commercial cooking
oil waste and commercial FOG waste to the extent recycling options are available, and reduce
the amount of such materials going into landfills.
1. The EMC respectfully recommends that SECTION 1 of Bill No. 286 be amended so
that the new language declaring prohibited materials specifically state that "commercial" cooking
oil waste is prohibited, as is already stated in SECTION 3 of the Bill. Hence, the SECTION 1
new language would read: "Notwithstanding the foregoing, commercial cooking oil waste and
commercial FOG waste are considered prohibited materials in any amount in any form."
(recommended new language underlined)
2. The EMC has concerns that there are some commercial UCO or FOG wastes which,
due to contamination with sewage or other materials, are not acceptable for commercial
recycling. There are also other such materials like animal fats and shortenings which are not
acceptable for recycling. As now written, Bill No. 286 would prohibit such non-recyclable
UCO/FOG wastes from being landfilled, increasing the likelihood of such wastes being illegally
dumped.
Comm. No/.
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Ref. To: --.6.1Alj..(
rxti. Guts UL 13 1 612
Therefore, the EMC respectfully recommends that Bill No. 286 be revised to allow for non-
recyclable UCO/FOG wastes to continue to be landfilled, subject to all solid waste facility permit
conditions and other regulations. Consideration should also be given for commercial generators
who have no commercial recycling options within distance to the nearest landfill, or some other
reasonable distance limit. Some possible language, such as the following, could be added to
the end of the prohibitory language in SECTION 1 and SECTION 3, as follows:
"The foregoing prohibition shall apply only to the extent that there are legally permitted
commercial recyclers who are willing and able to accept such materials for recycling, by way of
either pick-up at the place of generation, or drop-off within driving distance from the place of
generation which is less than to the nearest county landfill." (or other distance limit)
OR:
"The foregoing prohibition shall not apply to commercial cooking oil wastes or
commercial FOG wastes which: (1) Legally permitted commercial recyclers are not willing or
able to accept for recycling, or(2)Which no legally permitted commercial recycler is willing to
collect either by way of pick-up at the place of generation, or by way of drop-off within driving
distance from the place of generation which is less than to the nearest county landfill. (or other
distance limit). "
3. Finally, the EMC respectfully recommends that the Council hold public hearings on
Bill No. 286 to ensure that the input of stakeholders such as waste generators, waste haulers
and commercial recyclers is fully received and considered.
Thank you for the opportunity to review and comment on this Bill.
er;y,
///)
yA,A,,,/,, _ ; , L_.._... t 4."7 -,_
c___ rman Warner
Chair
cc: William Kenoi, Mayor
Bill Takaba, Managing Director
Dora Beck, P.E., Acting DEM Director
EMC Commissioners