Summary of Issues

EIS Public Scoping Meetings
Waimanalo Gulch Sanitary Landfill Expansion

COMBINED ISSUES BY TOPIC AREA FOR CONSIDERATION: DEVELOPED AT EIS SCOPING MEETINGS IN WAIANAE, KANEOHE, DOWNTOWN HONOLULU AND KAPOLEI REGARDING THE EXPANSION OF WAIMANALO GULCH SANITARY LANDFILL – issues that are bolded are those that were received in writing on the comment sheets that are not duplicative of what is already listed

General
· The 2001 EIS should not be used as the basis for this EIS
· EIS needs to clearly illustrate what expansion is taking place
· Need to provide number of years of continuing operation as well as the number of acres the expansion will take
· Need to clarify the location, size of the area and what the current zoning is. Documents need to be very clear and specify the boundaries
· Need to look at mainland sewage sludge studies
· New ash area that is covered in EIS needs to be specified where and size
· Impact of other new proposed private sites such as Nanakuli B – do not need both
· Need to identify impacts to RFP process
· Need to consider federal draft rules for shipping of waste
· Need to look seriously at all sites available around the island
· Need to discuss worst case scenario contingencies including earthquake etc.
· Need to determine how the DEIS will tie-in to the City’s comprehensive, Solid Waste Integrated Management Plan (SWIMP) update that the city is supposed to prepare
· There is a need to be aware that other areas of the island have hosted landfill sites in the past until their capacity was reached i.e. Aikahi, Kawaianui Marsh, Kapa`a Quarry etc. – they have not all been on the Leeward side
· The EIS needs to reflect the current status at the landfill not the preferred status
· There was a concern expressed about the ability of a local planning firm to be neutral on this issue with all the political pressure
· Need to include all Federal, state and local laws that affect landfill operations
· Need to address Waste Management’s 1999 contract with Mayor Harris
· Need clarity between airspace and landfill
· Need to explain why the community should believe the City at this point and why promises have not been kept
· HPOWER has never failed an EPA test on its ash – need to know why DOH has not approved reuse for concrete etc.
· Need to deal with the reality that because of our tourist economy or per person generation of waste is 7 pounds per day instead of the national average of 4 pounds
· Need to consult the County of Hawai`i who has just completed review of 61 alternatives and chosen 3 proven technologies to address this same issue
· EIS needs to comply with all EIS rules and statutes – including those that require “good faith”
· Must not just address expansion but cumulative impacts since the 1980s

Closure of Landfill
· EIS needs to focus on closing of Waimanalo Gulch now or as soon as possible – should not just go for life of area but should have a plan to reduce waste stream as quickly as possible to provide for closing sooner rather then later
· Review all alternatives available to reduce the waste stream with the intent of closing the landfill as soon as possible
· Need to consider the fact that many landowners and developers were fully aware of the landfill’s existence pre-development of their current homes and projects and moved in anyway
· Landowners in the area maintain that they were told the landfill would close in ’08 when they bought and had depended on these representations in making their decisions
· Need for active recycling program that would cut down the need for a landfill; need for a sensible plan that would allow for the earliest possible closure of the landfill
· Need for finite planning – Hawai`i should be at the cutting edge and shouldn’t worry about costs to keep it a paradise
· City must explain why we are here – other meetings have been held in the past which promised closure of the landfill by 08 and it is still open
· EIS needs to provide factual/historic information for the issue of the promised closure in 2008 and the issuance of an operating permit that required closure in ‘08
· Need a comprehensive closure plan for the existing Waimanalo Gulch landfill site irrespective of the proposed closure date
· Need to address the State Land Use Commission Decision and Order calling for closure in 2008
· Need to address the conflicting position of the 1984/1985 EIS which stated that only 57+/- of the 200 or so acres owned were feasible for utilization as a landfill due to the slope angles of the hillsides.

Environmental
· Need to explain what the relationship will be between the newly created topography of the expanded landfill, and the prevailing wind patterns of the area including any impact on ocean currents and near shore water temperatures
· Need to review Hawaiian Electric Company’s wind study and explain the logic of the increase in height of the landfill in light of the wind energy study
· Need an assessment of the static stability of the landfill both ash and solid waste areas including consideration of past history as well as the dynamic stability of the landfill recognizing the fact that we live in a seismically active area
· Need to address how much of the mountain land space is being shaved for the landfill
· Need to address environmental impacts of potential hazards
· Need to understand how 20 years of further capacity will be provided without excavation as previously stated – if there is excavation need to address where the soil will go
· Need to review recent State of Hawai`i Supreme Court case (Hokulia) regarding State DOH responsibility for water quality in relation to how it is being affected by the landfill e.g. ocean run off
· If expansion moves forward, storm water retention basins, leachate and gas monitoring systems are needed
· Address future ash monofills
· Need to know chemical composition of ash
· The location of potential hazards such as asbestos within the landfill need to be identified
· Address unknown effects to the land, water, and air
· Need to address odor issues – will the expansion take sludge and if so for how long
· How is the liner tested and how secure is it needs to be addressed
· The ability of the rock berm to handle the expansion needs to be discussed
· Needs to address the need for a surface water management plan
· Need fugitive trash plan designed to end this problem

Infrastructure
· Impact to landfill when H-POWER is down is an issue
· Impact on highway; road blockages, etc.
· Maintenance issues along Farrington Highway with heavy truck use – standards for adequate maintenance of this highway

Economic Issues
· Economic impacts
· Costs of closing landfill
· Need a solution to address lost revenues to the city should the solid waste go to a private landfill – tipping fees

Explore alternatives
· Need to look at all alternatives that are appearing (i.e., Plasma ARC gasification, etc.) and determine how these alternatives fit in with everything else that the City is doing – including how they can reduce the waste stream to allow for the earliest closing possible of the landfill
· Need to explore all viable alternatives
· Need to look at other places, especially Europe, and how they dispose of their waste, the kinds of incentives/taxes/sanctions they use to reshape people’s attitudes at the curbside
· Expansion should be limited to a specific time and coupled with a plan to reduce the waste stream
· Need to address things that can be done to reduce the amount of waste that goes to the landfill – curbside recycling, alternative technologies, etc.
· Need to increase HPOWER and explore reuse of ash – HPOWER type facilities could be decentralized and built anywhere
· Need to address trans-shipping of waste
· Need to address providing a funding stream to address alternatives
· Need to speed up action on alternatives
· Plasma Arc Gasification – Jacoby Inc.
· Need to address the implementation of the comprehensive and mandatory island-wide recycling program (proposed to be done by December 2006)
· Alternatives looked at must be explained including why they are rejected – the exploration must be rigorous

Facilities Management
· Need to look at as a facilities management problem and apply technologies correctly (especially as pertains to smells and debris)
· The EIS should address the status of all violations and what has been done regarding violations – need to close violations prior to new EIS and permit
· Hours of operation need to be clear and adhered to – the community recently expressed concerns about night operations taking place and the impact of the lighting on houses and neighborhoods
· Need to address overfilling of landfill site
· Need to look at rubbish control and sludge issues
· Need a specific operational plan for soil cover
· Explain the contracts between the city and Waste Management Inc and the timing of these contracts.
· There should be a clearly identified, separate (physically divided) MSW and ash monofill cells for the expansion
· A separate area should be identified for asbestos disposal
· A full discussion of all management techniques must be included

Monitoring and Enforcement
· Need to provide for air quality monitoring, testing as it corresponds to traffic at the site, and along the route to/from the site
· Need to examine enforcement capability and capacity of DOH – including the lack of resources required for monitoring, enforcement, reporting, and accountability
· Major dirt and dust issues; monitoring doesn’t work – need for more data collection
· Need to consider past problems with the landfill (i.e., EPA violations, leachate collection system) and be sure the DEIS identifies ways to assure that they do not happen again
· Need to address and explain the $2.8 million fine that has been imposed on the landfill by the Department of Health and assure that these types of practices/violations do not continue in the expansion
· Need to assure that a system is in place to hold the operator accountable
· Monitoring should be adequate so that after the fact permit modification should not happen – example the permit modification needed for the leachate sump pump system
· Need to monitor methane gas levels
· Need to have rigid standards and adequate monitoring to ensure the health and safety of the community
· Need regular monitoring by the Department of Environmental Services
· Need to address who will be responsible for enforcement of things in the EIS and what guarantees will be made in the EIS
· Need to include status of compliance with current permit – by modifying the permit, are we negating prior violations which should not be allowed
· Need to assure timely reporting by the operator and public access to these reports – consider webcam on site for monitoring purposes

Leachate
· Need to also address leachate and its impact to groundwater, runoff to ocean, subsidence and slippage resulting from seismic activity, methane fires, and EPA violations relating to gas collection systems
· Need to look back and forward – what has been/will be done to take care of leachate problems and make sure these do not reoccur in the future
· Need to address leachate pumped out to the sewer treatment plant and what happens to it and what is its effect on the final outflow water quality from the sewer treatment plant
· Need to discuss comprehensively the leachate management system – including possible failure of the geo-membrane lining system and how it will be taken care of

Environmental Justice
· Need to address “environmental justice” along the Leeward Coast and as it pertains to this landfill, including the multitude of existing private and proposed sites in the area

Health impacts
· Need to include discussion of potential health hazards
· Who is liable for the health costs to residents should the landfill cause health problems
· When considering expansion, need to discuss EPA finding regarding gas collection system issues
· Compensation to neighbors for health impacts
· Impact of multiple landfills, both public and private, on air quality needs to be addressed
· Higher standards are needed for dust and debris and possible impacts to health

Community issues
· The DEIS needs to deal with the lack of sensitivity to cultural sites and issues
· What communities will benefit - who will be selected and how will the compensation benefits committees be set up also needs to be addressed
· Need to include impact of non-closure of Waimanalo Gulch on for-profit businesses in the area or planning to locate in the area
· Smells, trash escape, floating dust, truck traffic and speeding, trash on road, visual blight all need to be addressed
· Landfill should not be going above the ridge lines, which can be seen from Waianae
· One of the conditions of the permit was to allow for ridgeline and site views being maintained
· No trucks should be parked on Farrington Highway waiting for entrance to the facility
· Trucks should be cleaned when leaving facility so there is no mud or dirt dropped on the highway
· Route along Farrington Highway should be kept clean of rubbish or dirt generated by the facility
· There should be identification of how the WGSL will be maintained facing Farrington Highway, landscaped to reflect surrounding areas, park-like upkeep, greenbelt, setbacks, etc.