Comment from Frank J Doyle, City and County of Honolulu

(LETTER SENT VIA USPS ON DECEMBER 6, 2006) December 6, 2006 Docket No. APHIS-2006-0172 Regulatory Analysis and Development PPD, APHIS Station 3-A-03.8 4700 River Road Unit 118 Riverdale, Maryland 20737-1238 Gentlemen: Subject: Docket No. APHIS-2006-0172 Environmental Assessment for Movement of Plastic-Baled Municipal Solid Waste from Honolulu, Hawaii to Roosevelt Regional Landfill, Washington Thank you for the opportunity to comment on your environmental assessment regarding interstate movement of garbage from Hawaii. We offer the following. 1. Please advise who initiated the request for an environmental assessment. 2. Please advise if these types of environmental assessments are done routinely by your agency and the process to have an environmental assessment initiated. 3. Please advise what measures will be taken to assure that unacceptable waste (hazardous waste, yard waste, and agricultural waste) will be segregated from waste to be baled; the wrapping film is intact; and appropriate procedures are followed. We recognize the profit incentive provides a strong urge to get best efficiency; however, the same profit motive could tempt the processor to cut corners and skimp on the quality of services. The City discourages the U.S. Department of Agriculture from moving forward with the approval to allow shipping of plastic-baled municipal solid waste from Honolulu, Hawaii to Roosevelt Regional Landfill, Washington. December 6, 2006 Page 2 Traditionally, refuse disposal services have been the responsibility of government agencies either directly or indirectly. One of local government?s prime responsibilities is unquestionably to secure efficient and environmentally acceptable solid waste disposal services for its community. Recent initiatives by the private sector to become more involved in community solid waste disposal services have delayed the implementation of City capital improvement projects and increased their cost. The private sector?s primary incentive, as in any business, is profit. The City?s incentive is to furnish a basic public health service as economically as possible. Moving forward with this environmental assessment would decrease the City?s ability to plan for financially feasible solid waste disposal options and increase costs to Oahu?s citizens for solid waste disposal. As in any community, we struggle over many reasons, both real and subjective, as we decide where to site a landfill for Oahu?s garbage. This document, to allow shipping of garbage off island, is offered in the guise of assistance to give more time to establish a local landfill, but in actuality, gives a false sense of security that a decision does not have to be made in a timely manner. The City has the ability to provide this basic public health service to its constituents without having to go forward with shipping of any garbage. Again, thank you for the opportunity to comment. Sincerely, FRANK J. DOYLE, P.E.