Loading...
HomeMy WebLinkAboutCOM 0200.008 2014-2016 •,441LL'.7... William P.Kenoi = ,,,`� BJ Leithead Todd •'�� %-•'� •' Director Mayor • re+r; • G Walter K.M.Lau q;;,;+�` John A.Medeiros Managing Director Deputy Director Countof%limn i DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 345 Kekuanao`a Street,Suite 41 •Hilo,Hawai'i 96720 (808)961-8083•Fax(808)961-8086 cohdem@co.Hawai'i.hi.us hunSwww.Hawai icounty.govlenvironmental-inxinement/ MEMORANDUM o Date September 11,2015 To Dru Kanuha,Chair& Hawai'i County Councilmembers C? `" N From BJ Leithead Todd, DIRECTOR Pp-1 v Subject : Director's Response and Comments on Bill 33 and its proposed amendments Communication 200.5 from Councilmember Margaret Will proposes a number of amendments to Bill 33. Item No. 1. Proposed amendment to SECTION 1 Findings and Purpose. The Director objects to the purpose of allowing commercial haulers to haul to transfer stations as opposed to the two landfills. Both the South Hilo Sanitary Landfill (SHSL)and the West Hawai'i Sanitary Landfill (WHSL)at Pu'uanahulu are designed and operated to accommodate commercial traffic. They have scale houses to weigh the rubbish and scale attendants that keep track of all incoming and outgoing traffic. Commercial haulers are weighed and ticketed and billed based on weight. This is particularly important at Pu'uanahulu as the County's contract with Waste Management Incorporated requires the County to pay them a fee based upon the tonnage that is landfilled at Pu'uanahulu. The County currently charges a fee of$85 per ton to commercial haulers. The money derived from these fees help underwrite about 25%of the cost of the Solid Waste Division. It is unclear what impact, converting from a system where we currently weigh all the commercial rubbish to a system of a flat per year or a quarterly fee for small haulers,would have on revenues as we have no basis to determine what tonnage this would represent. Transfers stations are not designed to handle commercial rubbish. They do not have scales to weigh the rubbish. They are not manned by enough staff to check and verify all loads coming in. Typically,transfer stations are manned by one Solid Waste Facility Attendant(SWFA),with the exception of busier transfer stations that may have two attendants. For example,the Hilo Transfer Station has four chutes and usually has two vehicles unloading rubbish at each chute. While we may have two SWFA's stationed there,they must also routinely check on the 2-bin recycling containers located some distance away,direct traffic,compact trailers when they are full and call in for Equipment Operator (EOIII) personnel to come and haul full trailers or bins away and replace them with empty trailers or zoo �( County of Hawaii is an Equal Opportunity Provider and Employer. COMM. NO. -O(_) Ref. To: Ref. Dote SEP /- 6 2015 bins. They are responsible for cleaning,weed whacking and other responsibilities related to running a transfer station. Our personnel work four 10 hour days. However,our transfer stations are open from 6 a.m.to 6 p.m. We currently have security guards open stations at 6 a.m. and watch traffic until about 8 a.m. and cover the stations from 4 p.m.to 6 p.m. Although our workers report to work at 6:45 a.m., receiving daily assignments,checking equipment and travelling to the transfer station sites can take an hour to an hour and a half depending on the distance the transfer station is located from the baseyard. Some transfer stations can be as far away as 30 miles from a baseyard. This also means that in order to return to the baseyard and clean their equipment, refill their gas,SWFA's need to leave the transfer stations around 4 p.m. in order to return to the baseyard and do the end of the day check of their trucks and equipment. Because most of our transfer stations are in rural areas and are not open every day,the SWFA assigned to an open transfer station will periodically have to make a run to closed transfer stations to check on whether trash has been left at the gates or if there are any other issues that may arise. On some days,we can find ourselves shorthanded if workers are on vacation or out on sick leave. If allowing commercial rubbish to be dumped at transfer stations as opposed to the landfills or sort station is implemented,one has to assume that this will result in more rubbish coming in to the transfer stations. This will mean that trailers and bins fill up faster which in turn will require the County to haul more trash in from the transfer stations thus increasing the department's cost in equipment,fuel and personnel. There is no information available to the department to determine how much additional trash would be delivered to the transfer stations and what the resulting impact on operations would be. Without this information,the department cannot determine what its manpower and equipment needs would be.Additional costs to the Division would be for the construction of infrastructure that would be needed at each of the site that would be potentially collecting commercial waste. This could potentially also include additional personnel in other labor classifications that have not yet been established. Additionally,the proposed bill fails to amend the definition of transfer station which is "a facility designed to collect household rubbish from the surrounding community and to transport this refuse to a suitable disposal facility." Item No.2. Proposed Amendment to SECTION 3 of Bill 33 proposing an amendment to Section 20-31 of the Hawaii County Code. Proposed amendment to the definition of"Compostable". The department objects to the proposed amendment as it is unnecessary and deletes"biodegradable plastics"from the definition of compostables. Some types of plastics are considered biodegradable and are currently considered to becompostable and we would not want to remove these from this section. Item No.3. Proposes amendment to change the definition of"refuse"in Section 20-31 of the Hawai'i County Code. The Department opposes this amendment. By changing the definition of refuse to exclude compostables and other recyclables,a host of unintended consequences result. For example,Section 20-36 enumerates restrictions on refuse removal businesses. It requires that those engaged in the business keep their vehicles in a clean inoffensive and sanitary condition.Section 20-36(a). It requires that refuse be handled and hauled in a manner to prevent scattering, spilling or leaking of the refuse. Section 20-36(b). By removing recyclables and compostables from the definition of refuse,these restrictions no longer apply to their hauling. Similarly the exclusion would render Section 20-41 which prohibits dumping refuse on vacant land, public places or on the premises of another inapplicable to compostables and recyclables. County of Hawai'i is an Equal Opportunity Provider and Employer. The proposed amendment is also problematic as it changes the definition of"refuse" but does not change the definition of"rubbish". By excluding compostable and recyclables from the definition of "refuse"the bill could have the result of allowing residential properties to stockpile such items as they are no longer required to haul them away pursuant to Section 2-32(a). Item 4. Proposes amending Section 20-35 of the Hawaii County Code to have a fee of$1200 per year for commercial haulers to haul to transfer station loads of six cubic yards or less. The department objects to the amendment as it is opposed to commercial haulers being allowed at transfer stations. Additionally, if a fee is proposed, it should be placed in Section 20-49 Fee Schedule, instead of Section 20-35 in order to keep all fees in the same section.There is also no basis from which this dollar amount is brought forward. The Department has no way of knowing if this fee is adequate to cover the costs of the impacts to our facilities. Item No.5. Proposes to amend Section 20-36 of the Hawai'i County Code by allowing commercial haulers to take refuse to transfer stations. The department objects to this for the above mentioned reasons. Additionally, in the case of the Hilo Transfer Station it makes no sense. The SHSL and the Sort Station are located a short distance away. The Hilo Transfer Station is the busiest on the island and residential customers are frequently in a long line waiting to dump their rubbish. It makes no sense to have commercial haulers go to the transfer station when the scale house and the landfill are a short distance away. Item No.6. Proposes amendment to Chapter 20 Hawai'i County Code by creating new section regarding disposal of compostable or recyclables when a container is unavailable. The department is opposed to commercial haulers dumping any rubbish at transfer stations at this time. Item No 7. Proposes amendments to Section 20-43 of the Hawaii County Code. The department is opposed to commercial hauling of any materials to transfer stations. Item No.8. Proposes an amendment to Section 20-52 of the Hawai'i County Code. The department supports the intent of the amendment but believes that instead of this amendment, Article 5, Disposal of Materials Collected by the County at Transfer Stations Section 20-50 through Section 20-52 of the Hawaii County Code should be deleted in its entirety. Thank you for allowing the department to comment on this Bill. If you have further questions, please don't hesitate to contact me. cc: Billy Kenoi, Mayor Wally Lau, Managing Director Randy Kurohara, Deputy Managing Director John Medeiros, Deputy Director Greg Goodale,SWD Chief Mike Kaha,SWD Deputy Chief Linda Peters, Recycling Coordinator Renee Schoen,Corporation Counsel EMC County of Hawai'i is an Equal Opportunity Provider and Employer.