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HomeMy WebLinkAboutPublic Comments and Responses to the IRSWMP (Appendix I) - 2009APPENDIX I Comments Received from the Public About Plan Update with Responses This appendix provides comments received at two public meetings about the draft Integrated Resources and Solid Waste Plan (IRSWMP) update and correspondence submitted to the Solid Waste Division, and responses to those comments. The comments shown are transcribed from a tape recording of the meeting. Minor changes have been made to the transcription to improve clarity. Public Meeting, Kona Outdoor Circle, Kailua Kona, September 29, 2009 Ben Purell, student, West Hawaii Explorations Academy "I'm here to give my opinion about the landfill, or expanding the landfill. I don't think it's a very good idea because if we do that we're just going to get the idea that we can just make more trash, and put it into the expanded landfill. All sorts of toxins go into making those objects so when we put them in the ground and bury them, those toxins are just going to go out into the ground, soil, and water supply. Also we use resources to make these objects: we can't continue living this disposable lifestyle, can we not make a change now and choose to make this change instead of being forced to make this change later? I think that we should make this change now." Response: The IRSWMP includes many programs targeted to reducing the amount of waste going into landfills. Analysis conducted for the plan indicates that there will be some residual materials that remain after our zero waste efforts requiring disposal for the foreseeable future. Thus, some method of treatment or disposal will be necessary. After an estensive review of treatment and disposal options (including mass -burn waste to energy, distributed combustion, plasma arc gasification, gasification, pyrolysis, mechanical - biological treatment, and off - island disposal), the IRSWPM update is recommending investigating the feasibility and cost of expanding the South Hilo Sanitary Landfill (SHSL). Once those studies are complete, then decide to either expand that landfill or truck waste from East Hawaii to the West Hawaii Sanitary Landfill (WHSL). The IRSWMP recommends evaluating new conversion technologies during the next 5 -year planning cycle. Finally, as the County makes continued progress on the path to zero waste, less and less material will need to be treated or disposed of in landfills. 2. Skyler Bell, student, West Hawaii Explorations Academy "I'm against the landfill. About three million tons of waste is dumped into a landfill and about 62 to 75% of that waste can be recycled. Millions of dollars is spent on something that doesn't help us or our environment. If we keep taking advantage of our planet and what it gives us, then someday it will be gone and we will have nothing. When we build landfills some of the nasty, yucky water leaches into our ocean. We can spend that money on PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC something that needs it like schools are helping people. We don't need to stink up the island with a bigger landfill, so think of how you can help." Response: State law requires that the County manage waste materials in a manner that protects public health. The Solid Waste Division (SWD) supports the sentiment expressed in this comment, but until such a time that we have truly achieved zero waste, it must make provisions to manage the residual wastes that remain in a responsible manner. 3. Anuhea Kahikina, student, West Hawaii Explorations Academy "There are lots of people in Hawai'i, which means that there's a lot of waste that is generated. There is so much waste being produced that the people in charge think that the only way to solve this problem is to expand landfills. This landfill will cost millions of dollars to build. With all that money we can give it to scientists who could find a way to get rid of waste in a natural way. This will help in getting our landfill clean and ready to bring in more waste. This way we will not have so much waste on our beautiful island. We only need one landfill and that is the one we have now. Did you know that if we make this new landfill that the rubbish on this island will increase by who knows how much? This is where we do not want to be. Our goal at our school is to work toward zero waste and to get there, the answer is not to make a bigger landfill. That is just making it worse for our living and for the kids in our next lifetime." Response: See responses to comments 1. and 2. 4. Grace Hartman, student, West Hawai'i Explorations Academy "I'm against expanding the landfill. A landfill is a structure to hold trash, designed so the trash doesn't make contact with the ocean or any water resource. But that smart thinking is not helping because it is polluting Hawaii and many other state's environments. And guess what, about 75% of that waste can be recycled. And instead of making a 2.8 million dollar check for the fine O'ahu has to pay for landfill violations and expecting to get another landfill that will cost about the same amount, you could spend it on go -green machines, incinerators, or spend some extra time thinking of new ways to help keep pollution away from our planet. We at the school that I'm going to are getting 17 Fridays taken away because of budget cuts that the government had to make. Instead of three million tons of waste, we can make 250 million tons of profitable recycling. We should really reconsider our actions and the idea of expanding the landfill because if we do, we will just be creating a very tangled web, ... is that what we want? No, so what are we asking, we could make Hawai'i smell and look beautiful like the beautiful, lush, green island it really is. Doesn't that sound like the better and more pleasing solution ?" Response: See responses to comments 1. and 2. 5. Hailey Ellison, student, West Hawaii Explorations Academy "Did you know there are about 1,400 landfills in America? About 80% of that can be composted, reused, or recycled. Most people think wow, that's a lot, instead of actually doing something to help. Most people just think that one person won't make a difference, they're wrong. If everyone started recycling, reusing, and composting, it would reduce more than half of what goes into our landfill. Have you ever thought of what would happen in the future if we just keep piling our waste on the earth? The whole earth would be covered PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 2 with trash. This is really important to me as a kid, because when I grow up, I don't want the earth to be filled with waste. So, next time you throw something away, think about ways you could reuse, recycle it, and if it's food, compost it. I'm from and I want to change the world." Response: See responses to comments 1. and 2. Lina Mochizuki, student, West Hawaii Explorations Academy "I don't think that expanding the Hilo landfill or trucking other trash to Kona landfill will solve our problem. Our problem is that we produce too much trash, or we can recycle most of it. The way we can fix this problem is to educate people about waste reduction. At our school, we recycle and compost and I think that we are getting closer and closer to zero waste. I hope that we can have zero waste on Hawaii in a couple more years." Response: See responses to comments 1. and 2. 7. Hannah Shimizu, student, West Hawaii Explorations Academy "Do you like Hawaii? Do you? Well I do. Seeing the blue sea and seeing the bright green trees, seeing the sunset as red as a ruby is a rare sight in the world. And we can lose that valuable resource if we are not careful. There are a lot of problems from building a landfill; one of them is that landfills are known to be leaking. This is very harmful and effects the environment, animals, and even people's health. And tourists come here because there are a lot of natural features here, and if tourists stop coming here because it's all trashy, then we will lose business in Hawai i. I think that's a problem for everybody. Thank you for listening." Response: See responses to comments 1. and 2. Wilena Peebles, teacher, West Hawaii Explorations Academy "I think that we need to look at the big picture when we make plans like this. I know that we're having a fiscal crisis, I know that we're having problems, but the population is bigger today than it was yesterday. The population only ever increases, we have minor ups and downs but in the long run, we have a large population increase, and solving this problem will never be easier than it is right now. It's only going to get harder the more people we have on the planet, and if we don't make the hard choices now then my students will have to pay the price in forty years. We're all going to have to sacrifice for them: they're willing to sacrifice themselves, but we need to take this moment to make the hard choice and do some things that we necessarily don't want to do for their future. Thank you." Response: Thank your for your comment supporting making difficult choices now to improve future conditions on our planet. 9. Sarah Bedaris, teacher, West Hawaii Explorations Academy "WHEA is a public charter school, and its mission is to educate Hawai i s children about the environment. One of the things that I've been able to see is partnerships that our school and other schools have been able form with people like Angela Kang from the County who works with all different types of schools. There is a lot of waste just in schools alone. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC Partnerships that we can form at the County level with the State and Federal governments should be coordinated. It seems silly to me that we duplicate so much of the same service. "And speaking of the school, doing energy and waste audits was something that we're going to be doing at our school with the idea of transporting that to other schools so that they can see the amount of waste at a school is tremendous, not just in the cafeteria which all could be composted, but the amount of paper alone could be turned into a business. I'm thinking that there should be more opportunity that the money being spent on this kind of short -term mitigation could be used as seed money or a portion of it to develop new businesses, create more opportunities for small business that are struggling or to support entrepreneurs that have new ideas to develop, but it takes a little seed money, so backing off some of these traditional ideas and opening ourselves up to more creative opportunities in small business parks perhaps more opportunities might provide answers. "The last thing I want to talk about is, that it's really a long way from where most people live to Pu'uanahulu. I don't know how many miles it is but it is a long drive, and every day there's an illegal dump somewhere along there because it's too far for people to even get to Keauhou or Kelakehe. So the point is, for people to go all the way to Pu'uanahulu to deliver green waste especially if they live in South Kona, would be a burden, and the amount of gas that one would use to get there, when we already have overcrowded roads as it is, would almost... it would almost cancel out the benefit from going all the way to a facility that far. Thank you." Response: The ISWMP update recommends working with the state to change collection contracts at schools to allow recycling. The IRSWMP update also supports initiatives to use recyclable materials to make new products within the County rather than shipping them off - island. The challenge is to make remanufacturing work here with the County's relatively small population and geographic isolation. In response to green waste, the County would like to work with the private sector to identify green waste drop -off, mulching and /or composting opportunities closer to Kailua -Kona than at the Pu'uanahulu landfill. 10. Marni Herkes "I'd love to see a letter from the Department of Health that says that you can expand the Hilo landfill before you spend any more consultant money doing this. I was an engineer, I was on the site - selection committee for the Pu'uanahulu landfill site - selection process, and I was on the site - selection committee for the one in Hilo, and the Department of Health said "no, we'll never approve one," so I want you to make them say that they will say that they will approve a landfill in Hilo, or an extension of the one that's there now before you spend any money because that's a waste of money. We don't need engineering studies for when they say "no." I agree about having green waste opportunities closer in than Pu'uanahulu. Sending everyone there is probably the worst thing that you could do, residents and big trucks: don't put us on the road to drive out there, it's not cost - effective. "I wonder if you've thought about working with the private sector on green waste; We have composting programs, we do education, we do a ton of education, we raise money and we provide classes, so that will fit with what you've got. Also, the reuse center, there's a lot of stuff we can reuse. I don't know if you know it, but there is a reuse center at and people that staff the facility tell us whether we can do the reuse or whether we can throw it in the bin, but there's a lot of stuff that's left there, and it's a constant turn -over so it really PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC works. There's a lot of electronic recycling, the outdoor circle thrift shop has several people who work on recycling equipment - yeah, electronics, and there's also, by Costco, there's an electronics place; I carried some in my car for about three months trying to get there, but I think that there's a lot of things that... a lot of simple things that need to be done, that can be done, "I'm on the board of a group called the Kohala Center and we got a national science foundation grant to do industrial ecology, which was a new word for me, on the island of Hawaii, so we'll have some answers. We'll do a materials flow study, then students at Yale will do the industrial ecology study, so they may be able to discover some new markets. I know that this is a big project, so thank you very much." Response: The County SWD is awaiting comments on the IRSWMP update from the State Department of Health and will be in contact with them regarding expanding the SHSL. For green waste, see response to comment 9. The SWD is intrigued by the study being conducted by the Kohala Center and other efforts that look to improve local markets for recyclable materials and organics. 11. Talon Wilson, student, West Hawaii Explorations Academy "I'm against the landfill because who knows, maybe in the future people will continue with this same idea -'I'll keep expanding and making landfills', and pretty soon our whole island will be just one huge landfill that people just throw their trash on. Thank you." Response: Thank you for your comment regarding landfills. 12. Flynn Briggs "Hi everybody, I thank you guys for coming here because I learned about this meeting from you guys, and this is a really sad thing. I've lived here most of my life, I been working on these lands most of my life. I've part of creating parks; I've been there since the very beginning, I'm on many Boards related to saving beaches for all the people here, and to prevent invasive development and non - friendly development for all of us. Through all these years I've seen is that we always don't get enough input from our communities and we all need this input so you know how we feel and so you can design a plan that's good for all of us. Now you guys say that you do come out with bulletins to inform us about these meetings but, you know, it's really easy to put up a sign at the green waste facility to tell us about these meetings, just out front out or at the waste sites themselves, it's not that hard. I would do that myself if I knew that that was an opportunity, and I think that the business communities and the young children would attend. I think that there's a lot more people to be heard here besides the few of the people that are here. "I went through a series of meetings a few years ago with our Councilmen and some of the waste management people, and they knew that, they didn't pass the same information on to you. During these meetings, we developed solutions for the green waste, we have solutions to other problems that were going to concur, and do you guys know about it? It seems like you don't, I mean, I ask why? Do you guys talk among each other, or do you not? I mean are you guys partners? I don't know, I question that. But putting people on the roads with big trucks hauling green waste to Pu'uanahulu may endanger your family members and everybody else. Putting toxic waste in the air also is not good, so I really challenge you guys to bring more meetings to this community, and I'd like to see our elected representatives PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 5 appear representing us with this problem, like our councilmen in all our districts. There's problems that we've discovered in south that there should be addressed. How are people living down south going to drive all the way to Pu'uanahulu? They're not, and so I stress to you that this does deserve more future meetings and not just table -top this deal and make it at the beginning of the year. Or at least make an opening page for it, because I think there's a lot of problems that's going to come forth that we all could create good ideas for you. Because there's a significance in every district that there's problems for this and that and we need to address each one of those because you say this is built by the people, well make it built by the people, not just from you guys. Thank you very much." Response: For green waste, see response to comment 9. The County does extensive advertising for its public meetings. Putting sites at our recycling and transfer stations is a good idea that we will consider in the future. 13. Kevin Purell You don't have questions in your survey about how to raise fees or how to pay for something, not all of this is about how to get us to recycle. I think you have quite a number of good programs already on this island for recycling. I don't think we need new ones. I think we need to expand what's there already. And if I pay a water bill and am used to paying water bill, in other communities there's a small fee on the water bill, I'd be willing to pay $5 every two months, that's about $30 a year and maybe that fee fluctuates, maybe it goes up, I'd probably be willing to pay more for me not to have to do the bag -thing (pay -as- you- throw), or me to keep recycling local. The two things I see in what you keep saying, pay as you throw, we aren't use to a system like in Seattle where you have a garbage can and that move recyclables and you had plastic bins given to you by the city, right, to do the recyclables because their landfills were filling up. And your first question in here asked do I want to retain recycling programs and pay for it by charging for disposal, that's seems the opposite, you should be charging for the throwing out of non - recyclables. It's not worded that way, you put in recyclables with transfer stations in all situations, the charges should be on what can't be recycled. So to me, something should be addressed regarding nominal fees for everybody, which would keep the recycling open, keep our transfer stations open." Response: Various funding options to pay for waste management programs are addressed in Section 10 of the IRSWMP update. The wording in the survey must have been confusing, because the intent of the pay -as- you -throw program is as you suggest: charge for what is not recycled. 14. No name recorded. "This is just one example, the City of San Diego by the City Charter, can not charge individuals for recycling and garbage: it's paid for on the tax bill. They have a three bin system and it works city -wide. Now apartment houses, condominiums, commercial sites, they charge. Here, commercial sites don't have room for more than one bin, so they don't recycle anybody's stuff. So here, commercial sites can't recycle because they have only one bin." Response: Space constraints can be a challenge for multi family housing, businesses and institutions. However, there are many creative ways to implement recycling at those types of buildings. Some steps proposed in the IRSWMP update include waste audits, outreach, and material bans. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 6 Public Meeting, Aupini Center Conference Room, Hilo, September 30, 2009 15. Bob Jacobson "I think that because of our financial problems and economic problems, we'd do much better by trying to ramp the programs up right now, and put our efforts into recycling and zero waste implementation. The sooner that we implement the zero waste program, the better. I think if you look at the zero waste Implementation Plan that you would see that there are a lot of jobs to be generated, and I think that by trying to do this now, sooner rather than later, would actually help the people here now and maybe we'd be able get more bang from our buck by doing it right now. So, we may not have lots of money to do it, but I think we need to find that money and start the zero waste program and implement it, because there's money for haulers, there's money for all of us to do this. I think there's ways to do it, and the prices of some of the materials are starting to rise now; scrap metals and paper are starting to go up. So I think this is the time we should do it sooner rather than later. Thank you." Response: Thank you for your comment supporting moving aggressively to implement zero waste programs. 16. James Weatherford "I think as a formal comment I should say that I'm speaking as a member of the community who has in the past found much to disagree with the County's policy in this area, but I have mostly a different attitude on this particular plan, and most of my comments are positive. A couple of general comments, is that the website has been very helpful and keeping up with it during the process, I think that's been very valuable, not only the website, it was actually the documents were posted and it was kept up to date and running, which is good. I think that the focus on the 5 -year implementation period gives the plan a real clear vision, maybe something that hasn't been available before:, there's two very broad, very strong points there I believe. "I was looking careful at the residuals management strategy which I think defines a lot of what comes out of here, and it looks like an overall balance that's very straight- forward. During the discussion of looking at trucking waste or the lateral expansion of the South Hilo Sanitary Landfill, as an economist also, I seem to be drawing out of that, and would suggest that it's a good idea that you're look at a cost - benefit analysis to compare those two. It didn't expressly say that but it seemed to be what you were getting at. You were going to do a feasibility and cost study on one, and then do another one and compare them. There certainly needs to be a side by side comparison there, I think. There are a couple of points that were introduced that I think were real basic and essential. I was very glad to see the concept of reducing the volume of waste entering the landfills, which is very fundamental and again, I think we haven't pushed that enough in the past... entering the landfills or doing anything else... and the Plan's proposed strategy of pursing zero waste and continue landfilling, those two core things are identified as being less costly than new technologies, and I think that was very good to focus on. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 7 "Also, I think a way you're being very honest in this report is you point out that there are some things that require changes to behavior that could be controversial. I believe it's good to get right up front with that at the outset, which you've done. It'll take a lot of political will on the part of the mayor and the council and I hope the mayor does really get behind this plan that's coming out in his administration. "I think it is good to compare this to the previous plan updates, which you do cover in your report, particularly the 2002 update. Overall there's several more measure in this plan update, than in the 2002 update. There were about three things in the 2002 update that I'm not sure are well covered here in this update. I'll touch on those briefly, and one that I couldn't find anywhere was a real effort to enhance the local markets for recyclable materials. This was in the 2002 update, and I don't know that I saw that come out at all in this one: I think this is very important. There was a statement in there that they do now encourage local markets and that green waste, glass, paper, and tires are currently used locally; I might suggest a little editing there that you would say "currently a portion of the green waste, glass, paper, and tires are used locally" because it kind of appears that every bit of it is, the way it's written. Second point from the 2002 update that I thought was in an earlier draft of this one and I don't think I found now, dealt with construction and demolition waste. I thought I saw earlier that there was a C &D ordinance proposed, but I'm not sure there is now, in the final version. So it seemed like there wasn't as much emphasis in this 2009 as there was in 2002 on the construction - demolition waste, and as your figures show, almost none of that is getting reused or recycled now, it's almost all going in the landfill - a great opportunity. The third one, there is some in this update draft and perhaps the most important recommendation that you have, and this is for the county to get involved and lead by example. It's one of your recommendations there that says that "implementing programs within the County departments to improve waste - reduction practices." I think this is a very, very strong part of your draft plan, right here, is for the county to lead by example. "A couple of other points that have come to mind during the discussion here, and one that was raised, is I ran into a friend on the way here, one point you've raised is the on -site composting. I'm very glad to see that. In my own reading, and for the last few years as I've looked at what's available, I've come to the conclusion that this is just absolutely what's got to happen, evidently it really is quite the trend elsewhere. "Regarding the pay as you throw, philosophically, if you have to recognize that those who are now dumping have an incentive not to do so because there's no charge to take it to the landfill, yet they dump anyway. Pay as you throw will not change that behavior, one way or the other. So that requires something else. In regards to the pay as you throw, another example, we had a chance to visit New Zealand, they call them rate - payers there or property tax - payers, by paying their taxes they actually receive a year's supply or six months at a time, six month's supply of bags of a special color and label on them, they were charged nothing and then others were charged, whether it's someone picking up or the self -haul. "Finally, on my way here, I ran into an acquaintance of mine who was off to the mayor's talks and couldn't come here, and this person was saying that with the changes that have happened on Oahu dealing with bale and barge, evidently the mayor was challenged and a company there now is setting up their own scales to open up the market. That person's take on this that the whole integrated management plan process is becoming moot. I didn't really PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 8 agree, but just to let you know a little feedback that I received on the way over here. But I guess my principle comment is its really good to see, I think, a lot of honesty and a lot of real practical, straight- forward components coming out of this. There are a few things maybe to polish up, particularly the C &D and some things like that, but it's really good. Thank you." Response: Thank you for your comment in support of various aspects of the IRSWMP update. Regarding the three issues you compared with the 2002 plan update: 1.) the IRSWMP update proposes a number of market development initiatives including changing county procurement policies to help support local markets, programs to support on -site management of organics, and promoting reuse and extended producer responsibility initiatives; 2.) we'll check the wording related to current local markets; 3.) The C&D ordinance you refer to is on page 3 -17, which proposes requiring a waste reduction plan as a condition for obtaining building permits. Finally, the Oahu flow control issues you reference also pertains to the County of Hawaii. The IRSWMP update has no specific recommendations, but it does discuss issues related to flow control on pages 9 -6 and 9 -7. 17. Steve Araujo "The haulers should not be required to do curb -side recycling. If they want to just continue to haul trash, they should be able to just haul trash and let the customer do the recycling if they want to. But they should not be hog -tied into doing something that they don't want to do. So maybe you folks could change that part of the plan, because the County does not own our individual businesses. Individual business run the way they want to run, not the way... as long it's legal; that's number one. "Number two, keep in mind that the pay -as- you -throw and the property tax is double - dipping, keep that in mind in your plan, okay, because double- dipping is illegal. And on turning green waste to compost, a lot of the hog- farmers take all the garbage from the supermarkets and restaurants; this business this should not be ripped out from them, this is their livelihood; they use it to feed their pigs to make money. "When it comes to County recycling contracts, who gets the contracts for the recycling, that also should be implemented in the plan. In order for the County to save money, this should be an entrepreneurship not the County subsidizing the recycler. I mean the recycler will be getting all the recyclables for free, all they have to do is pick them up at each transfer station. So they're not paying anything for it, so the County should not subsidize this. It should be an entrepreneurship where a business picks it up, takes it to the shop, where they process it, ship it out, and get paid on what they make after they ship it out; that's fair enough for the County and the business.. "Regarding building and construction waste, right now the metal from a construction job would go to the metal recycling, everything else would end up in the landfill because there is no C &D facilities. So for planning department to also have the permitee draft a plan makes absolutely no sense. All they would be doing is putting a hindrance on the applicant, and stretching the process along, because like I say, scrap metal or landfill; there's nothing in between. And even though we think there's a lot of wood and stuff, the stuff is treated; in Hawaii, no one builds without treated lumber, and green waste won't accept it, so it does go to the landfill. That's it for now. Thank you." PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 9 Response: The County understands your position about not wanting to make haulers offer recycling services; however the Solid Waste Advisory Committee and SWD staff believe that this will both help expand recycling services and be a business opportunity for haulers. Currently, County solid waste operations are funded both by property taxes and tip fees. Pay- as -you- throw is just another revenue source: the money to pay for programs must come from somewhere. The County would like to find a way to support local piggeries assuming it can be done in a cost - effective manner that complies with applicable requirements. This will be one of many options that would be considered should it arise during implementation of the IRSWMP update. The County contract for collection and marketing of recyclables compensates its contractor on a sliding scale that varies with the price of materials. The pricing was established as the result of a competitive bidding process. Currently, market prices for materials do not pay for the entire cost of collection, processing, and shipping materials to markets. You're correct that the proposed waste reduction plans for new construction projects must recognize market realities. In addition to metal, there is also significant potential for building deconstruction and reuse of various materials recovered during construction and /or demolition. 18. Jesse Law, Sustainable Island Products "I started my business to help Hawaii remediate the landfill issue, it was actually the inspiration for my wholesale distribution company which distributes biodegradable products and supplies to restaurants, hotels, and schools. And I'm doing about 96 tons a year right now of product going into the market and because I have no end -use market for my product to go soil in Hawai i, it's all going to landfill currently. So as someone who actually started trying to assist in the problem that you're trying to address with the integrated solid waste management plan, I'm very interested in this as is all of my customers and businesses that have purchased these products. They purchase my products mainly because they believe in non -toxic and compostable products. "While the end -use equation here is not yet developed, my interest and participation in these meetings over the last year has been to try and figure this out. When the RFP for the commercial composting facility was cancelled, I was really kind of upset and so were a lot my customers. I'm trying to make sure that there's something there as an incentive or as a end -life equation for these compostable materials and supplies. "I think that Styrofoam and plastic cause cancer to both people and the environment, and they should be phased out eventually. I'm trying to show that there's incentive for that as a business but without this last part of the deal, I'm involved in a moot business, and so the interest there is how might compostable be considered inside of the composting facilities, and also with the potential combination with food scraps for processing either privately or at a publicly operated facility. That's my interest and 96 tons a year is a lot to be diverted, there's potential there and that's just me, I've got nine distributors in the market now, I'm carrying these products since my inception two years ago, that weren't doing it before, so I'm sure that cumulatively there's a lot more potential diversion available to Hawaii in that single category, so that's my interest. Response: The postponement of the green waste composting request for proposal was an early result of the current national and global economic crisis now affecting Hawaii County. The SWD hopes PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 10 that its financial situation improves shortly so that composting can proceed in the future to provide a market for your products and others. 19. Glen Hisashima, former State worker. "I like your program but there's one major component that's missing, that's the enforcement part. In order to get a program to work, its gotta have teeth, if you don't have teeth, it won't work, and the enforcement should come from the top down. The Department's gotta enforce the rules they make. I have sub - chapter 20 I presume, and it clearly states things that the department's supposed to do, they're not doing it. How you gonna expect the lower people to abide by the laws if they don't follow their own rules? That's why I'm more of an enforcement kind of person. I like what you folks said, but where is the enforcement part, the component? If you're not going to enforce, you're going to get people doing what they want. "Number two I'm looking at is the credibility of the departments in the County gotta be addressed. I'm gonna ask for an audit of all the departments for wasting money; you need money, they're wasting money, and I can tell you that. I come from the State of Hawaii as a former employee, and I looked at what's happening today. State employees getting laid off to balance the budget. Now to budget the County budget, and this is going to be part of it, are they going to lay off County workers? I would say yes to that. I've watched the news, 44 million dollars next year, where they gonna get that from? Enforcement, there's money in it. It says, any violation is a thousand dollars. Piecemeal, a thousand dollars here and there; I grew up personally through the tipping fee. How many people are not paying it? I got the numbers. The last time I saw it was about... it was a year ago, I counted over three million dollars not collected; who do I blame as a tax payer? The County, why? Just like I blame the State of Hawaii for not collecting on any fines and money that is owed, that's all revenue. "Why is it the lower people are going to have to pay more? Just came from a meeting last night, very upsetting proposal, fifty thousand dollars per person to put up a sewage plant; not at this time, it's a good idea, not at this time; your plan, not at this time. Our people are suffering, period. How you'd gonna recoup the revenue, 44 million plus what's happening now. Everybody says recession is over, people gotta understand, recession may be over for the east coast, by the time it reaches Hawai i, how long more is it going to be? How... more are we gonna lose? A lot of people here cannot afford the kind of money. I'm looking at, since I'm retired, one set income, how I'm I going to do this? I might have to go back to my old traditional way of doing things, find a 55 gallon drum, make sure I don't burn over 25 pounds of paper, use the ashes as fertilizer, bury my cans in my property, that's how we used to before. Is that what you guys want us to do? I think that every meeting I came to, there's no majority of the local people, or people here are real interested in this, look at the room, how many you have, what's the numbers? It's not enough numbers. I don't know if they don't care, I don't know if they don't want to participate, but I've been to a lot of meetings saying what I gotta say, but it's only me against you folks. I've come to the term that I agree with what you guys are saying but I think it's the wrong time. Thank you." Response: The County recognizes that these are difficult economic times and the speed of implementation of various programs will depend on available funds. The County also recently conducted an audit of all of its departments and is aggressively pursuing collection of any bills outstanding. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 20. Julie Jacobson from Puna "I've been following the overall issue for a little over a decade, and I think the thing that bothered me back then is one of the things that is still with us now, and I think that's the environmental threat of pay as you throw. And I think it will be because it will be invisible in our environment, owing to our hundreds and hundreds of rural roads and hundreds of rural... 55 thousand rural lots in Puna alone. I think that the rage that some people have expressed here is that if they sense it as an additional tax, an additional burden, that they're going to be angry and frankly they're going to take it out on, what they think is taking it out on the government or the world at large, but what will be affected is that place where that piece of trash falls, and we won't know it. It's going to happen hundreds and hundreds and thousands and thousands of times. It's an environmental disaster to cause that to us. If we find other ways that will prevent that phenomenon, and I generally believe people are good at heart and mean well, but I think there's a real underlying discouragement people feel now, and a rage people feel in the issues. "Having picked up trash for over a decade, and I go to the another subject: I wish we could just put the incinerator issue to rest and not say we have to rehash it every five years. I feel like we've discussed this at other meetings, but basically the directions you take and the effort you go to go to using a incinerator or something like that, are just the opposite of what you do towards zero waste, reducing waste. These types of facilities need quantity, we have a relatively small population, you'd need a lot of material to make it profitable, regardless of all the bigger economic issues, so to me it seems like we would make a solid plan and really aim ourselves at solid waste if we say we're giving it... just kind of like if we as a nation would aim towards renewable energies and not oil drilling and more extracting industries. Our whole plan should go that way, and not listen to people with an economic incentive to work towards big technology, when I see the bulk of the people benefiting from the zero waste approach. "I think there's a lot of like you say, job opportunities with zero waste, and there's a lot of room for minor engineering kinds of things to make easier, minor engineering designs for contraptions to put your waste in, to make it so it's not so stinky. If you take them so far, a lot of little things we can do to make more people participate in the zero waste approach. So I appreciate all you've done toward that goal and say if you drop pay as you throw, and you drop any thought of an incinerator or these big technologies, or the mechanical - biological treatment facilities and spread it all over the ground, which is almost worse in my mind than an incinerator, just kind of say no once and for all as a County that this is not what we want. Be final about it and don't try to walk in two camps that aren't compatible. Thank you very much." Response: The SWD recognizes the risk of increased illegal dumping that may accompany a pay -as- you -throw campaign. Over 7,000 communities have implemented pay -as- you -throw (PAYT) systems in North America, many of which were rural communities with ongoing illegal dumping concerns. The most common experience in such communities is that no substantial ongoing increase in illegal dumping occurs if education and enforcement issues are addressed properly. Thus, the IRSWMP Update recommends increasing education, improving enforcement capabilities, and allowing for a reasonable phase -in period for PAYT. The SWD will look for opportunities to provide assistance to low income residents. The SWD is also considering other funding mechanisms besides PAYT. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 12 Rapid advances in conversion technologies are occurring world wide, including in Europe and other countries that have adopted many zero waste programs. The SWD believes it is prudent to investigate periodically the progress of those technologies to see if one eventually becomes appropriate for implementing in the County, thus significantly reducing or eliminating the use of landfills for that portion of the waste materials that cannot be cost - effectively reduced, reused, or recycled. 21. Jesse Law, Sustainable Island Products "I have one additional comment. One thing that I don't think hasn't been investigated is the cost to the County of shipping and whether or not something should be negotiated with the shippers that take these recyclables and /or bale and barge trash products out of Hawai i. That goes to your reduction on source, which is all of this waste that's our problem is coming from somewhere, so if we interrupt where it's coming from first, and reduce the costs of how it's going back for recycling, I think everyone's paying a 30% unregulated tax on every product they consume in Hawaii that comes in from the mainland as a percentage of cost on that product from shipping 20 -30% on average, probably. So just something to note that if Matson is sending containers empty back to the mainland, why are they still charging so much, and what percentage of that cost is being incurred by the taxpayer to move product back to the mainland? I think it's still in the 2,500 to 3,000 dollar range per container, which seems still too high, if you're looking at the fact that they're going to take them back empty anyway, if we don't send something back." Response: It would be great if such a rate could be negotiated. Absent legislation (that would probably be subject to legal challenge under the Interstate Commerce Act), the price charged for shipping containers of recyclables and other materials from the County to the Mainland is the result of private market conditions and contracts. If the price gets too high, eventually another shipping company could offer a lower rate and win that business. Until such a time, it is difficult to see how such lower rates might be obtained. 22. Steven Araujo "I was wondering, was there any air quality tests done at Hilo Landfill to determine how much methane is coming out of the landfill? I mean this whole thing has been all on global warming, pollution, and all of that, so I was wondering if any air quality tests have been done? And I was also wondering, was there any kind of comparison done between the amount of pollution created by recycling, starting from the home - consumer driving to the recycle center, to the actual recycling of the product when it reached back to its original form at its distributer. Have you compared the air quality from Hilo Landfill to that? That would be a very interesting comparison. Thank you." Response: If we understand the question correctly, you are interested in landfill gases. As required by state and federal regulations, the SWD does test for potential migration of landfill gases through soil and around on -site structures. The SHSL is equipped with six soil -pore gas monitoring probes that have been constructed around the perimeter of the landfill, which are monitored four times per year. It also monitors around structures quarterly. To date, no measurable concentrations of methane have been identified in the soil -pore gas monitoring probes or in the vicinity of any onsite structures. Appendix G of the IRSWMP update reports on an evaluation of various residuals management options. Exhibit 4 (objective 2A) reports estimates of the greenhouse gasses produced by various options (reported as CO2 equivalents). Analysis done in preparing these estimates (not shown in the PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 13 exhibit) revealed that off - island recycling results in fewer greenhouse gas emissions than landfilling, even when accounting for emissions associated with shipping recyclables to the mainland. This occurs because of the emissions savings that results from recycling materials rather than extracting raw materials to develop new products. Written Comments Submitted on the IRSWMP Update 23. Iolani Hawk, 10/02/09, Friday Please rethink the intended cut in hours and cost to put rubbish where it belongs. It needs to be as easy as possible for those people who are neglectful in attending to their disposal of waste. The illegal dumping along roadsides and the entire Ocean View area will become worse. This creates health and vector problems, not just eyesores. What needs to be done to enlighten the powers that be? Feel free to forward this email where it can do the most good. Response: The County will consider your comment as it evaluates the best mix of operating hours and funding, and the potential effects of those actions. 24. Craig Rehm Regarding your $2.00 charge per bag trash tax. My concern is that this charge would increase litter on the island and in the ocean because I fear many people will just dump their trash along the road or in stream beds rather than pay the fee. I have many neighbors who only take their trash to the transfer station once a month to save on gas. I fear they may with the new fee now never take their trash as they may feel they cannot afford the new fee and will merely dump the trash nearby. Please reconsider this well meaning idea. After all the transfer stations were built to help stop this sort of littering in the first place. There is a reason Honolulu has free trash pickup. It would be nice if everyone would comply with the law but that is just not the reality and I am sure the police have enough to do without having to do trash patrol. The other problem is enforcement at the transfer station and its costs. Response: Please see the first paragraph of the response to comment 20 above. 25. Robert Keapa, 10 /01/09, Thursday Lives at Kaalualu between Waiohinu and Naalehu. He lived for a time in Arizona and Oregon, went to school there and worked for the park and forest services in these states - they had PAYT and all the garbage ended up illegally dumped in the parks and forests. He is an advocate for enforced recycling and this is the primary approach that the County should take for waste disposal. The county should be responsible to find a way to use the recyclables to make other products -he spoke of glasscrete and how it was used in one of these two states on the highways and made visibility at night much better. He felt it was the County's responsibility, not private industry, to make things out of recyclables for further use. Response: Please see the first paragraph of the response to comment 20 above. As noted in the IRSWMP Update the County makes an effort to use recycled products and it is recommended that they increase their use of recycled materials. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 14 26. Comments About Pay as You Throw Trash Program (No Name), 10/20/09 There is no argument here that recycling is the correct course; however, I have read the recent 10/01/09 Honolulu Advertiser article, "Big Island Sees Trash as Revenue Source." The article suggests a new initiative where residents would have to pay $2 per bag of trash they drop off at the Island's Transfer station. The article stated that such an initiative would be a financial incentive for people to reduce their own waste and to help drive recycling and pay for the new additional services that will help the county move toward zero waste. Here are comments regarding this. If this incentive is implemented I fear that it will only discourage accessing the transfer stations at all and encourage random dumping of rubbish in abandoned areas by those without the ability to pay this fee. Has any study been done on the cost to the average household? In my family of 3 an average of 3 to 5 bags a week is not unusual ($6 to $10). My family could pay $520 per year. We simply don't want to encourage people to dump their rubbish out on our public or private roads. This is difficult to enforce and many private landowners are victimized when dumping occurs by others on their property. I believe there is more work to be done to encourage recycling but restricting access to the transfer station to those who can pay isn't the solution. Open access to the transfer station with behavior rules on what behavior is correct when you go there is the best way to go. News Article Attached: "Big Isle sees trash as revenue source. ", by Chelsea Jensen, West Hawaii Today. Response: Please see the first paragraph of the response to comment 20 above. 27. David Yamakawa, 10/21/09 There are people who are unwilling and/or unable to pay the $2.00 per bag that is suggested. So instead they will dump their rubbish wherever they can, as long as they can get away with it, and we will need to hire workers and purchase trash trucks to pick up their rubbish. In the meantime, where they dump their rubbish will become an unsightly mess to look at. Also, who will determine how much to charge for rubbish that can not fit in a bag, for example a sofa, or old broken chairs? Sorry you are just opening a "can of worms," it does not seem there was much thought put into this $2.00 a bag suggestion. Response: Please see the first paragraph of the response to comment 20 above. The PAYT system envisions a "tag" system for bulky goods. Tags would be sold along with bags and local retail outlets. 28. William C. Sargent, 10/14/09 I had given up writing letters as our politicians on this island seem not to care about what is logical and don't listen to anyone, but on this issue I feel I must speak out. The idea of charging for trash disposal will cost more than they can take in and it will devastate our PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 15 island. The island has large numbers of people who struggle to put food on the table, pay for gas, clothes for their kids, pay for medications, and pay for medical care. If they cannot afford to pay for trash, where will it go? It will end up in our lava fields and our open spaces. This will create an eyesore for tourists and us. Who will want to come to Vog /trash Island? In the past we were offered a way to dispose of our trash for free, but our politicians felt this was wrong. Now they want to charge $2.00 per bag. Please do not implement this mistake. Response: Please see the first paragraph of the response to comment 20 above. 29. Richard Fucik, 10/05/09 This is to testify against the proposed fee - per -bag to dispose at the transfer station. A fee will result in roadside, vacant lot and other random dumping. The health hazards will be enormous not to mention the degrading effect on property values and tourism. Who wants to visit somewhere where garbage is strewn everywhere. We already have enough problems with those just too lazy to drive to the stations. Witness the recent cleanup of the Puako area, where tons of trash was collected even though a transfer station is close by. Just think of what will happen if a fee is charged to use the transfer station. Disaster!!! There are many horror stories from other communities who have tried pay -as- you -go disposal schemes, every time they had to be quickly rescinded due to the avalanche of wayside dumping. Charging a fee for properly dumping at a transfer site is a negative incentive. It punishes those who pay the fee and rewards those who avoid the fee and dump elsewhere. The cost of operating the transfer station should be collected in mandatory fees, most commonly thru the water bill. If you have already paid for it then you will be more likely to dump in the station rather than along the road. Now comes the incentive part. To encourage people to separate recyclables and reduce the amount of trash going to landfills, incentives should be offered. The cost of the incentives would come from the mandatory user fee. Perhaps a fun scratch off card given out at the recycle center with random cash prizes, redeemable at the HI5 recycle centers; or an entry card for a periodic drawing for a trip to Vegas, etc. In summary, don't make using the transfer station a punishment thru the negative incentive of a per bag user fee. Incentivize recycling thru a positive incentive with a low cost, but fun reward program. Consider also that we could join Oahu and ship our waste to the mainland site. This would alleviate pressure on our landfills and would be relatively inexpensive since we would just piggyback on their program. Response: Please see the first paragraph of the response to comment 20 above. Incentivizing recycling is a good idea and will be considered where feasible. 30. Louise Winn, 10/05/09 I am writing to express my concern regarding the pay -as- you -throw system for disposing of household waste. While this has a good chance of success in urban areas such as Hilo, PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 16 Waimea, and Kailua -Kona, it will have unintended consequences in rural areas such as Kau, South Kona, and Puna. I have worked with this issue through community groups, your department, the police, county prosecutors, large, private landowners, and many others since 1996. At that time the pressing issue was dumping of white goods and green waste wherever and whenever there was an open area along the rural roads. It took many years, but now that the transfer stations have green and white goods dumping areas this problem has been greatly alleviated. There has also been a big increase in recycling for the same reason -it is convenient and free. However, local folks will draw the line at paying for household garbage dumping. If you look around the grocery stores you will find mostly mainland transplants who have grown up with garbage service and recycling using the cloth bags faithfully to prevent accumulating so much plastic. This is not yet a habit with enough people to expect that adding yet another kind of bag will be successful. Hauling household rubbish to "the dump' has been free for one hundred years. Most rural people will not be willing to pay for bags. I guarantee we will begin to again see roadside and backyard dumping, backyard incinerators, and this time it will be a public health hazard since this time it will include all manner of rotting food, small batteries and who knows what else. Until the actual cultural change occurs this will just be another excuse for scofflaws, however well intentioned your ideas. I urge extreme caution with implementing this. Bags should not cost anything. Bags should be available everywhere - grocery stores, transfer stations, Wal -Mart. Until everyone will commit to at least using the cloth bags for shopping, we will not see cooperation with pay -as -you- throw. Let's accomplish one cultural change at a time. Response: Please see the first paragraph of the response to comment 20 above. 31. Gregory P. Gauthier, 09/30/09 I sincerely appreciate your efforts in trying to fund our solid waste disposal here in Hawai i County. The September 30th addition of the West Hawaii Today discussed an apparent proposal to charge fees for filling a particular type of garbage bag that would be used to dump at our transfer stations. I vehemently disagree with that proposal and would like to explain why. • There will be an increase in roadside dumping of garbage, especially on rural roads. This in turn will affect quality of life issues for many residents and may likely increase the budget for the county roads division. • There will be a decrease in refuse disposal areas in public spaces owned by private entities, such as shopping malls. Those people who desire to throw away their rubbish while in their car during their normal course of business will likely find somewhere else to place that garbage. Those private entities who provide that particular amenity will be dissuaded from continuing to do so as it has become a cost issue. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 17 I am certain that there are those that legitimately perceive that by charging fees for each bag of garbage, the market will encourage more recycling. That is a reasonable argument for reasonable people during reasonably good economic times. The people who dump appliances, furniture, and batteries near my houses in Waimea and Orchidland are likely less than reasonable. They do so out of convenience. It is my perception that those people and more will begin to dump all of their solid waste in the same areas. I will be forced to call the police. The police will show up and have to file a report (another cost). I certainly will be less likely to pick up the rubbish as a good Samaritan because now I will have to pay for that privilege. Indeed we should pay for our rubbish. But we should pay through the taxes on those goods which support the production of rubbish. Nowadays, that would be all consumer items except fresh produce. We should not pay for the rubbish at the back end, but at the front end. We should have a rating system for consumer goods that taxes those items which produce the most waste the highest. The price would be paid before the rubbish is thrown on either of my streets. Please do not charge a fee for rubbish. If we must pay, we should pay at the front end, either through higher taxes, or on specific products that are considered less than environmentally friendly as it relates to the solid waste they produce. Response: Please see the first paragraph of the response to comment 20 above. 32. Donald Rice, 10/13/09 I have grave concerns regarding your plans to implement a pay -as- you -throw (PAYT) system. Some of the reasons are as follows: Current restrictions on plastic containers and lids (that they must be #1, #2, or #5) are ridiculous in this day and age. Every other jurisdiction that I've been associated with does not have such a limited selection of recyclable plastic. Our family has to put in dumpsters numerous other types of plastics that could be recycled. This is perhaps our biggest source of bulk items that end up going in our trash instead of being recycled. The same is true with regard to wax coated containers. They are recyclable elsewhere but not here. Something needs to be done about Styrofoam. If people have to pay to dispose of it we will find it all over the island as it takes up a tremendous amount of bulk space that people are unlikely to want to pay for. 4. There has got to be an Ocean View transfer station. Implementing a PAYT system without such a station will result in staggering amounts of trash being dumped all over our community. In summary, the idea of a PAYT system is excellent, but I don't think it can be productively implemented at this time. At least in our part of the island, there are too many people who do not have adequate financial resources to pay for trash disposal. Even now, we have garbage all over the place from people who refuse to go to transfer stations. I believe that this will reach epidemic proportions under a PAYT system. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 18 Response: Please see the first paragraph of the response to comment 20 above. 33. Michael L. Last, 10/13/09 The comments below address solid waste reduction. They are those of the author, who is acting as an individual resident and not representing anyone else. He is not affiliated in any way with any waste collection firm, recycler, or environmental organization. His sole purpose is to have a logical and sound system of solid waste reduction that is applied to all parties in an equitable manner. As an example, a jug that contains milk is just as detrimental (when disposed of in a landfill) as one that is sold with flavored water inside. A. Eliminate the one cent (1 cent) fee imposed on the purchase of recyclable bottles and cans. Upon redemption, the amount returned is only 83.3% of that which was remitted (one cent fee and the five cent (5 cent) deposit). I am unaware of any other state or local government that mandates less than 100% be refunded upon return of a recyclable item. Prior to the deposit bill being introduced, I would collect aluminum cans and transport them to a recycling vendor. There the money I received was in payment for my efforts to collect, store and transport the cans. Now, for this same effort, what is my payment? The return of the money I gave in the first place ... but only five cents returned for every six I paid!! I now refuse to purchase any item that is subject to a fee. (I can accept the deposit.) I will however purchase any item in a plastic or glass container, as long as I don't pay anything extra for the fee or deposit, and when I'm done, I'll be sure and have it end up in the landfill. B. Impose the same deposit amount on any and all bottles and cans ( "vessel ") REGARDLESS of the contents! A plastic vessel filled with a carbonated drink is subject to the deposit (and fee), yet this same vessel which contains milk is NOT subject to any additional payment. To use the argument that milk is a necessity for life, and thus not subject to the additional charges, is not valid. Water is a life sustaining liquid -not milk, but the State of Hawaii elects to impose the fee and deposit on this vital nutritional source. Any and all containers (of the same composition) should be subject to recycling without regard to what is initially held- and with the equivalent amount of deposit. Impose a fully (100 %) refundable deposit on each motor vehicle registered in the County of Hawaii. Currently there is no deposit associated with the initial registration of a motor vehicle; therefore when a vehicle no longer becomes operational sometimes it ends up abandoned on the public right -of -way. However, the fee to remove these vehicles is borne by each and every person who registers their cars and trucks. Collected along with the State and County weight tax, the State fee, and beautification fee, is the County fee. Incorporated in the County fee is $12.00 designated for abandon vehicle disposal. Therefore, each year everyone pays $12 per registered vehicle to have the car or truck removed from the street or highway. It doesn't matter that you don't abandon vehicles; you pay the $12 each and every year regardless! If there was a refundable deposit (in lieu of the'abandon vehicle disposal fee') collected upon initial registration, and the ENTIRE amount was refunded only when one of three conditions were satisfied, we'd see a lot less 'junk cars' around the island. The three ways to get your deposit back: 1. Verify that the vehicle was sold - submit notice of transfer; 2. Verify that it was taken to a recycler- obtain a receipt; 3. Verify that it was taken out of state - supply shipping documents. Period! Then there would be an incentive for correctly disposing of a vehicle. Also, if there was a bounty ( "deposit ") on each vehicle, and PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 19 someone still wanted to junk it along the road, someone will quickly come along, remove the vehicle to a recycler and collect the deposit. The one thing I can't stress enough is NOT to refund anything less than 100 %. No disposal fee withheld. But maybe the other way, having everyone remit $12 each year is a more logical way for the County's Solid Waste Division. Response: Thank you for your comments about deposits for containers and vehicles. Assessing deposits for motor vehicles is an interesting concept. You may want to consider submitting your comments to the State of Hawai'i as well. 34. Bays Deaver Lung Rose Holma, Bruce D. Voss, 10/27/09 The Kohala Coast Resort Association ( "KCRA "), through its counsel, respectfully submits the following comments to the draft County of Hawaii Integrated Resources and Solid Waste Management Plan Update, "The Path to Zero Waste" (the "Plan Update "), issued August 2009: KCRA is a private, non - profit organization, founded in 1984, for the purpose of maintaining a standard of quality development for the Kohala Coast. He Kohala Coast resorts offer more than 4,300 hotel and condominium units, comprise more than 40 percent of the hotel rooms and condos available on the Island of Hawai'i, and directly employ more than 6,000 people - about 10 percent of the island's non - agricultural workforce. KCRA has been involved with the solid waste issue on the Island of Hawaii since its inception. It opposed the placement of any landfill at Puuanahulu and is on record as being consistently and adamantly opposed to any long haul trucking of trash from East Hawai'i to the West Hawaii Sanitary Landfill at Puuanahulu in West Hawai'i (the "West Hawai'i Landfill "). KCRA appreciates the substantial time and effort spent by the Department and members of the Solid Waste Advisory Committee on the Plan Update. KCRA supports programs to reduce the volume of waste entering the island's landfills, and making improvements to existing infrastructure to accommodate those new waste reduction programs. KCRA also supports investigating the feasibility and cost of expanding the existing South Hilo Sanitary Landfill, with an initial 7 -acre lined landfill cell and then expanding the landfill into the adjacent 75 -acre quarry. As the Plan Update states, such expansion would provide an additional 55 years of capacity at the South Hilo landfill, to handle East Hawai'i s trash. KCRA remains strongly opposed, however, to the Plan Update's apparent "default" option of trucking trash from East Hawaii to the West Hawaii Landfill if the other alternatives are insufficient to accommodate East Hawai'i s waste stream. KCRA believes the Plan Update vastly understates the economic, social, health, safety, permitting and environmental costs of trucking East Hawai'i s trash to the West Hawai'i Landfill. First, the estimated $82 per ton cost of transferring waste from East Hawaii to the West Hawai'i Landfill is premised on some extremely optimistic assumptions regarding equipment costs, labor costs, fuel expenses, and repair and maintenance. Given the scope and intensity of the proposed trucking operation, those transportation - related costs are likely to be far higher than projected in the Plan Update, and will substantially increase over PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 20 time. The Plan Update's $82 per ton cost estimate therefore is not a credible estimate of either short- or long -term costs for purposes of comparing landfill options. When properly adjusted, the per ton cost estimate will be at least equivalent to and perhaps substantially more than the $99 per ton cost the City & County of Honolulu is now paying to ship solid waste to a landfill in Washington state. Second, the Plan Update fails to account for the traffic and safety concerns and costs associated with trucking all of East Hawai'i s trash to the West Hawaii Landfill. The County previously has claimed traffic impact from trash hauling will be "minimal" because there will be "only' a dozen or so waste truck round trips a day from Hilo to South Kohala. As the Plan Update notes, that works out to at least 4,455 trips a year, with the trucks running 362 days a year. The County is not realistically assessing the impact on residents: these are huge, 20 -ton trucks. With their weight and size, they will have difficulty with the curves and grades of the Hawaii Belt Road and Waikoloa Road, and will hasten the deterioration of those roads. The trucks will slow traffic for all other drivers, including residents commuting from East Hawaii to West Hawai'i. Traffic is already heavily congested through Waimea town, and these trucks will only add to the delays. These huge trucks will pass nearby schools in both Waimea and Waikoloa, and create dangers for schoolchildren and other residents. Any traffic accident with these trucks would have terrible consequences. And, no matter how they are designed or maintained, these unsightly trucks will occasionally spill waste and debris onto the roadway. Third, the Plan Update fails to account for the economic and social impacts of having the island's only landfill right next to the island's primary resort area. The Kohala Coast resorts create thousands of jobs for island families, and help provide the tax revenues to fund many of the County's services. By trucking trash and dumping it on the resorts' doorstep, the County recklessly risks jeopardizing the long -term economic health of the island's tourism industry. The Big Island' tourism industry is already facing severe challenges, and KCRA considers the current economic situation to be near a crisis. Fourth, the Plan Update fails to account for the environmental related costs of trash hauling to West Hawai'i. Under the County's previously proposed plan, more than 70,000 additional tons of waste would be dumped each year into the West Hawai'i Landfill. The county has never studied whether such an increase in the amount and frequency of dumping would increase dust, noise, odor, or other emissions from the West Hawai'i Landfill, or how that might affect the nearby resorts or residents. The County also has never studied whether dumping and compacting waste in quantities far larger than originally projected could have any short -term or long -term impacts on soil or water quality around the West Hawaii Landfill. Even after KCRA and numerous other citizens objected to the County's Environmental Impact Statement for the East Hawaii Sort Station, the County never conducted those necessary studies. Any program to begin large -scale hauling of trash from East Hawaii to the West Hawai'i Landfill would be subject to legal challenge under state environmental laws. The Plan Update does not estimate either the costs required to conduct the necessary environmental studies, or the costs arising from legal challenges. Fifth, the Plan Update fails to account for all costs associated with shortening the life of the West Hawaii Landfill. The Plan Update acknowledges that if waste from East Hawaii is added the West Hawaii Landfill's capacity would be exhausted "11 years sooner," but in fact the West Hawaii Landfill could be full much earlier than that if the island's population PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 21 or business activity grows more rapidly than projected. When the County first proposed the existing West Hawaii Landfill, it told residents it was building the landfill for the benefit of West Hawai i. Any program to truck East Hawaii s trash would break the County's promise to KCRA and all of West Hawai i s residents. West Hawaii is not, and should never be, the "dumping ground" for East Hawai i. In commenting on the County's prior Environmental Impact Statement for the East Hawai i Sort Station, KCRA stated: "KCRA reiterates that it fully supports the County of Hawaii s efforts to reduce the island's waste stream, including recycling and the sort station concept... But KCRA cannot support a massive and costly waste - trucking proposal that endangers the health, safety, and well being of all West Hawaii residents." KCRA stands by that statement and once again strongly urges the County of Hawaii to devote its full efforts and resources to extending the life of the South Hilo Landfill and pursuing waste reduction technology to ensure that the trucking of trash from East Hawaii to West Hawaii will never occur. KCRA appreciates the opportunity to comment on the Plan Update. Response: The County of Hawaii believes that cost estimates presented in the IRSWMP Update are reasonable, planning -level estimates. Actual costs will vary. The County is very sensitive to the community issues surrounding both expansion of the South Hilo Sanitary Landfill and trucking waste from East Hawaii to West Hawaii, and would seek to minimize community and environmental impacts from whichever solution is eventually adopted. PUBLIC COMMENTS AND RESPONSES APPENDIX IDOC 22