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Home My WebLink About2018-10-24 EMC Meeting Agenda and Director's Informational Report ENVIRONMENTAL MANAGEMENT COMMISSION COUNTY OF HAWAIʻI MEETING AGENDA DATE: October 24, 2018 TIME: 9:00 a.m. PLACE: Hawaiʻi County Building 25 Aupuni Street, Suite 1501 Hilo, Hawaiʻi 1. CALL TO ORDER 2. APPROVAL OF MINUTES OF SEPTEMBER 26, 2018 3. STATEMENTS FROM THE PUBLIC ON AGENDA ITEMS 4. UNFINISHED BUSINESS a. Chair’s update on the Environmental Management Commission’s report to the Charter Commission. 5. NEW BUSINESS a. Presentation by Roy Takemoto, Executive Assistant to the Mayor, on the process of sewering an improvement district (requested by Commissioner Gaffney). b. Discussion regarding the Environmental Assessment for the proposed Pāhala Wastewater Treatment Plant (requested by Chair Bennett). c. Discussion on how the County of Hawaiʻi could assume the authority from the State Department of Health for recycled water systems (requested by Commissioner Gaffney). d. Brief introduction and recommendation for a policy and motions tracking process for the Commission (requested by Chair Bennett). 6. REPORTS/CORRESPONDENCE Director’s Informational Report. (Note: The report and agenda are posted online on the County Calendar and on the County’s website under Boards and Commissions, Environmental Management Commission (http://records.co.hawaii.hi.us/weblink/Browse.aspx?startid=8405&dbid=1). The Director will provide informational updates on the following: a. Status of the proposed Pāhala and Nāāʻlehu Wastewater Treatment Plants. As the County of Hawaiʻi is being sued (Sandra L. Demoruelle v. Dora Beck et al., Civil No. 18-1-00206), discussion of the Pāhala and Nāālehu projects will be ʻ limited. b. Update on education outreach components included in new contracts. c. Brown water advisory data provided to the County Council’s Environmental Management Committee on October 2, 2018. d. Photograph of the State Department of Health’s warning sign that the Department of Environmental Management displays when there is a sewage release. e. Report on Hawaiʻi County Charter Commission matters involving the Department. 7. FUTURE AGENDA ITEMS Commissioners can suggest items they would like placed on the next agenda. 8. ANNOUNCEMENTS The next meeting is scheduled for November 28, 2018, at the West Hawaiʻi Civic Center at 74-5044 Ane Keohokalole Highway, Building G, Kailua-Kona, Hawaiʻi. 9. ADJOURNMENT The regular meeting place is accessible to persons with disabilities. To request an auxiliary aid or language translation, please call 961-8083 five days prior to the meeting date. Comments may be sent to the Department of Environmental Management, 345 Kekūanāoʻa Street, Suite 41, Hilo, Hawaiʻi 96720, or emailed to cohdem@hawaiicounty.gov. Notice to lobbyists: If you are a lobbyist, you must register with the Hawaiʻi County Clerk within five days of becoming a lobbyist. \[Article 15, Section 2-91.3(b), Hawaiʻi County Code.\] A lobbyist means “any individual engaged for pay or other consideration who spends more than five hours in any month or $275 in any six-month period for the purpose of attempting to influence legislative or administrative action by communicating or urging others to communicate with public officials.” \[Article 15, Section 2-91.3(a)(6), Hawaiʻi County Code.\] Registration forms and expenditure report documents are available at the Office of the County Clerk-Council, 25 Aupuni Street, Hilo, Hawaiʻi 96720. 2 DIRECTOR’S INFORMATIONAL REPORT TO THE ENVIRONMENTAL MANAGEMENT COMMISSION OCTOBER 24, 2018 CURRENT LEGISLATION ITEM DESCRIPTION CURRENT STATUS Bill 192 Bill 192 seeks to amend Chapter 2, 10/16/18: Hearing before the Article 40, Section 2-202, and Chapter 14 Council’s Environmental of the Hawaiʻi County Code by Management Committee resulted establishing an Environmental Quality in amendments which will be Control program to mitigate nuisance finalized at the next Council factors at County facilities managed by meeting on 11/1/18. If passed, the DEM, such as improperly handled refuse bill will be referred to the EMC for and wastewater, feral cats, dogs, and comment and recommendation. other animals abandoned or released at DEM facilities. (The bill was introduced by Councilmember Eileen O’Hara.) DIRECTOR’S INFORMATIONAL UPDATES AND ISSUES BROUGHT UP AT THE PREVIOUS MEETING 1. Status of the proposed Nāālehu and Pāhala ʻWastewater Treatment Plants: Community meetings were held in Pāhala on October 8, 9, and 10. On October 8, the subject included the C. Brewer properties connected to the LCC and the connection of these homes to new sewer lines in Pāhala. On October 9, the subject included homes newly accessible to the proposed sewer lines and the required connection to the new sewer lines in Pāhala. On October 10, the meeting was for a review of the Environmental Assessment for the proposed wastewater treatment plant in Pāhala. 2. Update on education outreach components included in new contracts. 3. Brown water advisory: Data was provided to the County Council’s Environmental Management Committee on October 2, 2018. A copy of a brown water PowerPoint has been provided to commissioners for information (it was not presented to the Council’s EM Committee). 4. A photograph of the State Department of Health’s warning sign when there is a sewage release has been provided to commissioners. 5. Report on Hawaiʻi County Charter Commission matters involving DEM or EMC: The Director’s submittal to the Charter Commission’s request for clarification has been provided to commissioners. SOLID WASTE DIVISION PROJECTS AND UPDATES 1. OPERATIONS A. COMMERCIAL DRIVERS LICENSING (CDL) TRAINING: • Heavy equipment training has been ongoing for all personnel at both the SHSL and WHSL who indicated they wanted training. B. WEST HAWAI‘I SANITARY LANDFILL: th • SWD is working with WMH to put together an event to recognize the 25 anniversary of the opening of the WHSL. The event is to be held on Friday, October 26, 2018, and will start at 11:00 a.m. at the WHSL office area. C. EQUIPMENT SWD is working with the contractor who is providing new landfill equipment to help facilitate a delivery date for the new truck tractors and trailers. 2. ADMINISTRATION • The Recycling Section’s new Recycling Specialst I, Sanne Berrig, started work on October 1, 2018. • SWD has been putting together the 2019-2020 budget. 3. SOLID WASTE CAPITAL IMPROVEMENTS • A completed restated contract with Hawaiian Earth Recycling was finalized and signed by all parties. • A notice to proceed with the design was given to our organics processing contractor, Hawaiian Earth Recycling. This design will be for the organics receiving facility at the West Hawaiʻi Organics Facility. • SWD is in the process of answering questions that were submitted regarding the Environmental Assessment being conducted for the upcoming East Hawaiʻi Organics Facility sited at the Shipman Business Park in Keaʻau. 4. RECYCLING SECTION A. ORGANICS DIVERSION PROGRAM: The Amended and Restated Service Agreement for greenwaste and composting services was approved and accepted by both Hawaiiian Earth Recycling and the County during September 2018. B. INTEGRATED SOLID WASTE MANAGEMENT PLAN UPDATE: The 2019 County of Hawaiʻi Integrated Solid Waste Management Plan (ISWMP) update will be prepared in compliance with Hawaiʻi Revised Statutes (HRS) Chapter 342G, which requires counties in Hawai‘i to update and revise their solid 2 waste management plans every 10 years. The last update to the County of Hawai‘i’s ISWMP was completed in 2009. The update to the ISWMP will include an evaluation of local needs and conditions to determine the most effective combined strategy for managing solid waste while protecting human health and the environment. The plan will outline the components of an effective solid waste management strategy and identify short and long term goals, while providing a framework for implementation. As required by HRS Chapter 342G, Mayor Kim appointed members to the Solid Waste Advisory Committee (SWAC). The County’s SWAC is comprised of eight members and has been meeting monthly. Input from the SWAC members during the ISWMP update process is crucial to ensure that the completed plan effectively identifies and addresses the County of Hawai‘i’s unique solid waste challenges. C. TRANSFER STATION RECYCLABLES (“TWO-BIN”) COLLECTION AND RECYCLING: The current contract will end on September 30, 2018, and a supplemental extension request is being routed. The SWD is now enforcing the ban on illegal commercial usage of self-haul resident-only recycling bins at recycling and transfer stations. There is a light-duty person monitoring the Hilo and Kealakehe RTS site and redirecting commercial loads. Commercial generators/collectors should work directly with recycling companies to manage recyclables, as they are prohibited from the recycling and transfer stations. Redesign of the Hilo site is proposed to better handle traffic and customers. The SWD is working with the vendor to update and replace signage and repair ramps. A follow-up meeting will be held with the vendor to discuss more restrictive worldwide recycling market and trade conditions and how these may impact local collections. Ongoing discussions continue. D. DO-IT-YOURSELF (DIY) USED MOTOR OIL RECYCLING: • IFB 3725 was awarded to Hawai‘i Petroleum and expires on August 31, 2019. The NTP was issued on September 24, 2018. • A list of island-wide year-round collection locations (six) is on our website at http://www.Hawaiizerowaste.org/recycle/motor-oil. Residents can also recycle DIY used motor oil at all County Household Hazardous Waste Collection Events. Used motor oil (UMO) is not accepted at the recycling and transfer stations. The DOH ended funding of the program in FY2015. DEM has funded the continuation of the UMO program in the FY2018 Budget. E. REUSE CENTERS: • RFP 3693 resulted in contract award to Transfer Station Thrift Store LLC for all seven locations. • The County operates seven Reuse Centers at Recycling and Transfer Stations located in Hilo, Kea‘au, Pāhoa, Kealakehe, Keauhou, Waimea, and Wai‘ōhinu. 3 F. ELECTRONICS RECYCLING: • The IFB 3514 contract awarded to Mr. K’s R&R expires April 17, 2019. • Residents are allowed no-charge household electronics recycling on Saturdays at Mr. K’s R&R. Businesses, non-profits, schools, and others are offered discounted fees on Saturdays. An acceptable list and more information is at http://hawaiizerowaste.org/recycle/e-waste. Mr. K’s is open and accepting electronics daily. • Mr. K’s again offered a “free” electronics collection event for businesses and agencies on September 29, 2018, partially sponsored by his recyclers and the County of Hawai‘i. Both June and September collections were very successful, but required significant County funding. Mr. K’s is not planning similar future events. • The County provides free monthly electronic recycling collections in Hilo, Kona, Waimea and Wai‘ōhinu for residential electronics only. Details of the County collections and any changes to private collections will be posted on our website at http://hawaiizerowaste.org/recycle/e-waste. • Currently, no manufacturer offers convenient on-island take-back of electronics. Manufacturers only offer this convenience on O‘ahu to comply with the Electronic Waste and Television Recycling & Recovery Act mandatory take-back provisions. A stronger EPR law requiring convenient on- island manufacturer sponsored take-back should be considered. The DOH awarded the County grant funding in FY2019, partially reimbursing SWD electronics recycling expenditures. G. HOUSEHOLD HAZARDOUS WASTE (HHW): • June’s Kealakehe and Hilo HHW turnouts and quantities collected were similar to December 2017. • The next HHW Collection Events are scheduled for December 1, 2018, in Hilo and December 8, 2018, in Kealakehe. More information is available at http://www.hazardouswaste.org/recycle/household-hazardous-waste/. H. GREEN WASTE DIVERSION: • The State Department of Agriculture finalized a permanent rule (HAR § 4-72- 13) prohibiting the interisland transport of ‘ōhi‘a plant material to prevent the spread of Rapid Ōhiʽʽa Death caused by Ceratocystis lukuohia or Ceratocystis huliohia. They also recommend not transporting ‘ōhi‘a plant material from an infected area to a non-infected area. DEM has recommended that people not bring any ‘ōhi‘a plant material to our greenwaste collection sites and recommends composting on-site. • The County’s contract with Hawaiian Earth Recycling continues greenwaste recycling. Enhanced mulch is available at the East Hawai‘i Organics Facility. The mulch is treated for invasive species at EHOF since the modified State Department of Health permit was issued. The SWD relocated the greenwaste recycling at the Waimea Recycling and Transfer Station to make it more convenient for residents. 4 I. SCHOOL RECYCLING AND TOURS: • Requests for school and HCC/UHH tours of SWD facilities continue. Many are scheduled in November to coincide with Hawai‘i (America) Recycles Day. These tours are helpful in educating the next generation on recycling and sustainability. Several tours have already taken place for various schools island wide. J. SPECIAL EVENT RECYCLING: • The Recycling Section continues to offer free rental HI-5 Event Recycling Bins for fundraisers at community, sports or family events. Bins can be requested via an online application form at http://www.hawaiizerowaste.org/event-planning. Please submit applications for reservations well in advance of events to make sure bins are available and to schedule pick-up/drop-off. The hawaiizerowaste.org website also provides helpful resources for planning zero-waste events. K. HI-5 CERTIFIED REDEMPTION CENTERS (CRCs) • IFB 3552 is to “Provide Certified Redemption Center Services at County Recycling & Transfer Stations 2018-2019.” Atlas Recycling will continue to operate at Kealakehe, Kea‘au, Keauhou, Ocean View, Volcano, and Waimea. Business Services Hawaiāwī, Hilo, Honoka‘a, ʻi will continue to operate at H and Puakō. L. RECYCLING EDUCATION AND OUTREACH: • The Recycling Section’s website, www.hawaiizerowaste.org, completed its transition to a mobile-ready format with enhanced location features. The Recycling Section is researching upgrades to the website to improve functionality and customer experience. • Information is continually updated on the site. • Staff continues to give presentations to community organizations. The biggest th event was the 30 Earth Day Fair at UH-Hilo on April 20, 2018, where hundreds of students attended. The Recycling Section participated in the World Ocean Day on June 8, 2018, by staffing an exhibit table. • Out of the Sea Media Arts was contracted with as a result of professional services procurement for Recycling Education Program Development services. The contractor is developing various education campaigns for UMO, the Polystyrene Food Service Ware ban, and a general update to recycling. M. TIRE RECOVERY/RECYCLING EDUCTION AND OUTREACH: • The contractor has completed the third round one-year follow-up of tire retailer/wholesaler education and site inspections, educating tire retailers/ wholesalers of their responsibility to charge a disposal fee for tires sold, and to accept used tires from, customers when tires are being replaced. Two-year follow-up site visits are planned for April 2019. 5 • The contractor completed an initial and second round of consumer education (media release, radio, newspaper, social media, posters/flyers, etc.) during the September through December 2017 period, encouraging consumers to leave used tires at the retailer when purchasing new ones, as customers already paid the mandatory fee for disposal. • More information is at: http://www.hawaiizerowaste.org/recycle/tires/ 5. DERELICT AND ABANDONED VEHICLE (DAV) PROGRAM • Towing and Vehicle Disposal Contracts are in place island-wide. ᵒ Zone 1 Towing (N. & S. Hilo, Puna, and parts of Kaū): Ken’s Towingʻ ᵒ Zone 2 Towing (N. & S. Kona and parts of Kaū): Diamond Auto Workzʻ ᵒ Zone 3 Towing (N. & S. Kohala and Hāmākua): Diamond Auto Workz ᵒ Hilo Vehicle Disposal: HMP dba Business Services Hawai‘i ᵒ Kona Vehicle Disposal: Big Island Scrap Metal ᵒ Pu‘uanahulu (W. Hawaiʻi) Vehicle Disposal: Big Island Scrap Metal • DAV coordinators continue to meet with the Hawaiʻi Police Department, Traffic Services Section, to explore ways of improving the tagging and removal of abandoned vehicles. • An auction for abandoned vehicles was held in May. ᵒ Total cars auctioned: 53 ᵒ Total cars sold: 23 ᵒ Total sales: $8,357 ᵒ Cost savings: 23 cars x $675 = $15,525 (this is what it would have cost the County if we had to dispose of them). • Monthly towing numbers: AV Towing 2018-19 Hilo W. Hawai‘i July 2018 23 58 Aug 2018 31 61 Sept 2018 89 61 Oct 2018 Nov 2018 Dec 2018 Jan 2019 Feb 2019 Mar 2019 Apr 2019 May 2019 June 2019 July 2019 The total tow request sent for the month of September 2018 was 159; however, 9 vehicles were not on location at the time of arrival. 6 6. SORT STATION UPDATE (FY 18-19) Total Tons Taken Total Tons Month/Year to Sort Station Diverted Jul 2018 1,350.04 0.00 Aug 2018 1,895.74 0.00 Sept 2018 1,167.65 0.00 Oct 2018 Nov 2018 Dec 2018 Jan 2019 Feb 2019 Mar 2019 Apr 2019 May 2019 Jun 2019 Totals 4,413.43 0.00 Per the Solid Waste Division, Total Tons Diverted has been zero for some time because they have not been conducting active sorting. Much of this is due to the storage of tires in the Sort Station collected during the dengue outbreak. Waste is received at the Sort Station early in the day, then the remainder is sent to the landfill. Just recently is the SWD at the point where they have enough space in the sort station to receive waste. 7. MONTHLY LANDFILL TONNAGES (FY 18-19) Month/Year SHSL WHSL Jul 2018 6,141.14 14,593.45 Aug 2018 6,411.82 13,824.53 Sept 2018 6,184.31 13,558.78 Oct 2018 Nov 2018 Dec 2018 Jan 2019 Feb 2019 Mar 2019 Apr 2019 May 2019 Jun 2019 Totals 18,737.27 41,976.76 7 8. MONTHLY TRANSFER STATION TONNAGES (FY 18-19) Month/Year SHSL WHSL Jul 2018 3,422.47 4,434.41 Aug 2018 3,448.69 4,206.27 Sept 2018 3,373.07 4,100.10 Oct 2018 Nov 2018 Dec 2018 Jan 2019 Feb 2019 Mar 2019 Apr 2019 May 2019 Jun 2019 Totals 10,244.23 12,740.78 The above table is to include data on the waste disposed of in the landfill (not the greenwaste or recycling data). WASTEWATER DIVISION PROJECTS AND UPDATES 1. COMPLIANCE • TREATMENT AND DISPOSAL: No report. • COLLECTION SYSTEM: No report. 2. OPERATIONS A. TREATMENT/COLLECTION SYSTEMS AND PUMPING STATIONS/ FORCE MAINS: • Unscheduled repairs/upgrades/replacement of failing equipment due to age and prolonged wear and tear continue where necessary throughout the wastewater facilities. B. SAFETY PRACTICES/TRAINING: • WWD Administration continues to review and update the Emergency Response Procedures and the Standard Safety Procedures, and the weekly safety meeting agendas. 3. ADMINISTRATION A. VACANT POSITIONS IN OPERATIONS: • Trades Helper (temporary: Hilo – 1 position; Kona – 1 position): recruitment in progress 8 • Operator I (Hilo - 1 position): recruitment in progress. • Operator II (Hilo - 1 position): recruitment in progress. • Operator IV (Hilo - 1 position): recruitment in progress. • Temporary Storekeeper (Hilo): recruitment in progress. B. VACANT POSITIONS AT RAILROAD OFFICE: • Wastewater Deputy Division Chief: recruitment in progress. 4. WASTEWATER CAPITAL IMPROVEMENTS A. NĀ‘ĀLEHU LARGE CAPACITY CESSPOOL REPLACEMENT: • Alternative potential sites are being investigated. • Public outreach meetings are to be scheduled after completion of the comment period for the Pāhala draft EA. • The State EA process is to be completed prior to purchase of land for the treatment/disposal facility. • Closure of the large capacity cesspools as mandated by the EPA will occur once the treatment and disposal system has been constructed and properties have been connected to the new collection system. • The project is funded by Clean Water State Revolving Funds (CWSRF) monies. B. PĀHALA LARGE CAPACITY CESSPOOL REPLACEMENT: • Public outreach meetings were held on October 8, 9, and 10, 2018. • As a result of EPA funding for this project, the NEPA process in addition to the State EA process are required. Both processes are to be completed prior to selection of land for the treatment/disposal facility. ᵒ The draft EA was submitted to OEQC on 9/12/18 for publication on 9/23/18. • Closure of the large capacity cesspools as mandated by the EPA will occur once the treatment and disposal system has been constructed and properties have been connected to the new collection system. • The project is funded by Clean Water State Revolving Funds (CWSRF) monies and partially by a federal EPA grant. C. LONO KONA SEWER IMPROVEMENT DISTRICT: • Project was awarded on July 27, 2018. • Loan closing is in progress. Construction NTP will take place after loan closing. Date of loan closing has not been scheduled. • Issuance of NTP will take place upon loan closing. • The USDA Rural Development has obligated loan and grant funds of $2,437,000 and $4,024,800 respectively to this project. DEM is working with USDA to finalize a Subsequent Loan $3,699,000 and Subsequent Grant $1,071,000. Low construction bid received was $8,531,814.43. D. KEALAKEHE AERATION UPGRADE AND SLUDGE REMOVAL: • Final approval of the project will be issued pending the review and acceptance of all close-out documents. 9 • With respect to the Endangered Species Act for Hawaiian Stilts and Coots, the County has executed a contract with Hoʻomaluo LLC to continue the predator control and bird monitoring of endangered bird species. • The project is funded by CWSRF monies, which are being increased from $18 million to $23 million. E. KEALAKEHE WWTP EFFLUENT R-1 UPGRADE: • 60% plans are to be submitted in November. • The environmental process for the R-1 system is ongoing. A draft EIS is anticipated to be published in November 2018 followed by a 45-day comment period. • The long range plans for R-1 quality effluent began in 2007 as a phased approach. Phase I, which installs a reuse line between the Kohanaiki area and Kealakehe Parkway, is planned under the State DOT’s Phase II Queen Ka‘ahumanu Highway Project (see item C above). • The DOH has earmarked SRF monies in the amount of $54 million to fund both design and construction of the R-1 upgrade at the Kealakehe WWTP. F. NORTH KONA SEWER PUMP STATION • This new sewer pump station will be located on the mauka side of Queen Kaʻahamanu Highway. It is to receive wastewater from a portion of the area below Ane Keohokalole Highway between Hina Lani Street and Kealakehe Parkway. The wastewater will be pumped to the Kealakehe WWTP via new forcemains tentatively scheduled to be installed by late 2020. • The pre-design phase, including the archaeological and permitting assessments, has begun. The Preliminary Engineering Report (PER) is in process, and once the design concept is determined, a follow-up meeting will be scheduled with Hawaiian cultural groups and archaeologists to discuss impacts to the Māmalahoa Trail. G. WASTEWATER EQUIPMENT REPLACEMENT PROJECTS: • Pua Sewage Pump Station (SPS) Upgrade: Design of the upgrade to the Pua SPS is in progress. It includes a complete renovation to include the structural, electrical, and mechanical upgrades to the pump station. Cause for renovation is due to deterioration of the wet well from H2S; electrical component damage due to H2S corrosion, and the overall age of the facility; and mechanical damage due to faulty discharge line valves due to hydraulic surging. Work is to include upgrading the HVAC; replacing/upgrading components of the electrical system; replacing corroded duct work; upgrading the wet well level control system; and improving on safety issues by eliminating fire and electrical hazards to achieve compliance with NFPA 820 and 70E. The project is funded by CWSRF monies. • ZOM Dilution and Assimilative Capacity Study: Field work for the Dilution and Assimilative Capacity Study for the Pāpa‘ikou and Kula‘imano WWTPs has been completed, and a draft report was submitted August 31, 2018. 10 H. ULU WINI WASTEWATER TREATMENT PLANT: • WWD continues to maintain stability of the treatment plant with the goal of achieving consistent process data and meeting the regulatory as well as expected effluent limits. The treatment system currently meets DOH regulatory requirements, and nutrient removal is taking place. The longer term goal is to cut down on operation and maintenance. • Progress on the design plans and specifications (for the installation of the immediately planned treatment plant upgrades aimed at maintaining treatment plant stability and reliability plus lowered operations and maintenance cost for the next several years) is on hold due to the Office of Housing and Community Development’s notification to the Department that they are working with a consultant to assess the condition of the treatment plant. • The State DOH is being kept apprised of the progress. I. SEWER RATE STUDY UPDATE: • Work on the Sewer Rate Study continues. DEM is currently working with the consultant on finalizing the rate study. J. UPDATE ON WATER SHUT-OFF FOR NON PAYMENT OF SEWER BILLS: • DEM is currently drafting administrative rules for the implementation of water shut-off for non-payment of sewer fees. The Department of Water Supply (DWS) is also drafting amendments to its rules to allow for water shut-off due to non-payment of sewer fees. Both DEM and DWS rules need to be amended for the water shut-off to be implemented. In the meantime, we continue to work with delinquent customers to bring their accounts current and refer accounts to the Office of the Corporation Counsel to pursue judgments when necessary. K. FISCAL SUSTAINABILITY PLAN/ASSET MANAGEMENT PROGRAM • PG Environmental has completed the data collection for all of the critical assets, and is now working on the criticality analysis. The next deliverable will be the Draft Condition Based Assessment due early November. 11