Movement of Plastic-baled 

Garbage and Regulated (Domestic) 

Garbage from Hawaii to Landfills 

in Oregon, Idaho, and Washington. 

Final Biological Assessment, 

February 2008 
 

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Table of Contents 

I. Introduction and Background on Proposed Action 3 

II. Listed Species and Program Assessments 28 

Appendix A. Compliance Agreements 85 

Appendix B. Marine Mammal Protection Act 150

Appendix C. Risk of Introduction of Pests to the Continental United States via Municipal 

Solid Waste from Hawaii. 159

Appendix D. Risk of Introduction of Pests to Washington State via Municipal Solid Waste 

from Hawaii 205

Appendix E. Risk of Introduction of Pests to Oregon via Municipal Solid Waste from 

Hawaii. 214

Appendix F. Risk of Introduction of Pests to Idaho via Municipal Solid Waste 

from Hawaii. 233
 

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I. Introduction and Background on Proposed Action 

This biological assessment (BA) has been prepared by the United States Department of 

Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) to evaluate the 

potential effects on federally-listed threatened and endangered species and designated critical 

habitat from the movement of baled garbage and regulated (domestic) garbage (GRG) from the 

State of Hawaii for disposal at landfills in Oregon, Idaho, and Washington. Specifically, garbage 

is defined as urban (commercial and residential) solid waste from municipalities in Hawaii, 

excluding incinerator ash and collections of agricultural waste and yard waste. Regulated 

(domestic) garbage refers to articles generated in Hawaii that are restricted from movement to 

the continental United States under various quarantine regulations established to prevent the 

spread of plant pests (including insects, disease, and weeds) into areas where the pests are not 

prevalent. Together, these comprise garbage and regulated (domestic) garbage, referred to as 

GRG in this BA. The movement of GRG would be approved by APHIS after compliance 

agreements between APHIS, the State of Washington, Idaho, or Oregon, the State of Hawaii, and 

specific applicants are agreed upon and signed in accordance with APHIS regulations (7 Code of 

Federal Regulations (CFR) § 330.400). The regulations allow GRG from Hawaii to be moved to 

the continental United States if it is compressed, packaged, shipped, and disposed of in a manner 

that the APHIS Administrator determines is adequate to prevent the introduction or 

dissemination of plant pests, and if it is moved in compliance with all applicable laws for 

environmental protection. 

Proposed Action: Baled GRG will be transported on barges pulled by tugboat from Hawaii to 

the mainland where the barges will enter the Columbia River and continue up the river to 

specified ports on the river. The baled waste will be transloaded from the barge to an asphalt or 

concrete staging area then will be loaded onto trucks or rail cars and transported to specified, 

approved landfills in Washington, Oregon, and Idaho (see figure 1 for potential landfills). 

APHIS may authorize this activity under compliance agreement with applicants that have 

requested APHIS approval. 
 

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Figure 1. Potential landfills in Oregon, Washington, and Idaho to receive baled GRG from 

Hawaii. 

Duration of the proposed action: APHIS expects that the proposed actions will continue for 

the foreseeable future, as long as the destination landfills maintain required permits to continue 

functioning and there is capacity in the landfills to accept waste. For example, the Regional 

Disposal Company (owner and operator of the Roosevelt Regional Landfill in Washington) has 

an agreement with Klickitat County, Washington to operate the landfill until 2041. The 

Columbia Ridge Landfill in Gilliam County, Oregon, has an estimated remaining service life 

(permitted site capacity) of approximately 50 years. 

At this time, no applicant has specified a timeframe for the proposed action; however, 

compliance agreements between APHIS, PPQ and the waste management companies are 

renewed every 3 years. If there are changes to be made to the agreement, those are included at 

that time if they are agreed upon by both the companies and PPQ (and PPQ would also need to 

make sure any changes meet PPQ regulations, etc.,). If the effects of the proposed action 

change in a manner or to an extent not previously considered APHIS will re-initiate consultation 

at that time. 
 

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Previous Actions and History of Consultation: Currently, there are two companies that have 

been approved to move GRG from Honolulu, Hawaii to Roosevelt Regional Landfill in Klickitat 

County, Washington – Hawaii Waste Systems (HWS) and Pacific Rim Environmental 

Resources, Inc. (PRER). Each applicant has signed two compliance agreements, one for the 

handling of GRG at its point of origin and one for handling it at its destination (see appendix A 

for examples of compliance agreements). These compliance agreements detail conditions and 

provisions for the movement and transport of bales and the actions to be taken in the event of a 

breach in the bale wrapping or a spill. While the compliance agreements for HWS and PRER 

are not identical, they are substantially similar in all aspects affecting pest risk. That is, the 

compliance agreements are constructed to reduce pest risk to the lowest level possible. Key 

items that will be included in the compliance agreements are reduction of agricultural waste and 

yard waste, compression and baling standards to ensure compact and air-tight baling, handling 

procedures, spill response procedures, and final landfill disposal standards. Although 

compliance agreements are in place, no baled GRG has yet been barged to the Roosevelt 

Regional Landfill by either company to date. 

APHIS previously consulted with the U.S. Fish and Wildlife Service (FWS) once and the 

National Marine Fisheries Service (NMFS) twice on specific parts of this action. APHIS 

prepared a BA regarding the proposed rule (now final regulation 7 Code of Federal regulations 

Section 330.402 and 403) that governs the interstate movement of baled GRG from Hawaii to 

the continental United States. On September 11, 2006, APHIS received a concurrence letter 

from NMFS indicating that the administrative amendments of the proposed rule were not likely 

to adversely affect several whale and sea turtle species. The concurrence was based on the 

understanding that all site-specific compliance agreements associated with the actual movements 

of baled GRG from Hawaii would undergo individual section 7 consultations at the time they 

were proposed. APHIS then submitted a BA to both FWS and NMFS that analyzed a specific 

proposal to approve the barging and trucking of baled waste from Oahu to the Roosevelt 

Regional Landfill in Klickitat County, Washington, by two waste management companies, HWS 

and PRER. APHIS received concurrence from both agencies (letters dated December 15, 2006 

(FWS) (USFWS Reference: 13260-2007-I-0023) and December 18, 2006 (NMFS)) on that 

proposed action and compliance agreements were finalized for both companies. Now, additional 

companies are proposing to transport GRG via barge from Hawaii to landfills in Washington and 

other states, including Oregon and Idaho and more companies may request approval from 

APHIS for such activity. Also, HWS and PRER have submitted amendments to their initial 

requests. APHIS believes that the reinitiation of section 7 consultation with each slight 

adjustment of each proposal would be burdensome to both APHIS, FWS, and NMFS and may 

appear as “piecemealing” the consultation. APHIS believes that all current and future proposals 

for movement of baled GRG can be considered and addressed in one consultation if a “worst 

case scenerio” approach is used in considering effects of the action on federally listed species 

and critical habitat. Therefore, this BA will consider the movement of a maximum amount of 

baled GRG by any company from the State of Hawaii to any qualified landfill in Washington, 

Oregon, or Idaho under compliance agreement from APHIS. The standards required for the 

original applicants (HWS and PRER) in regards to baling, handling, spill response, and disposal 

would apply to any company that requests to barge GRG from Hawaii to Washington, Oregon, 

or Idaho. APHIS will keep track of each proposal/approval to ensure that the amounts of GRG, 

or barge, rail, or truck traffic considered in this BA are not exceeded. APHIS will re-initiate 
 

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consultation with FWS and NMFS if a proposal would cause exceedance of the amounts of GRG 

exported from Hawaii, number of barge trips, or amount of rail or truck traffic that were 

considered in this document. APHIS will also re-initiate consultation if new effects not 

considered in this BA are discoverered or if new species are listed or critical habitat is 

designated that could be affected by this action. 

Action Area: The action area for this project encompasses the ocean route from Hawaii to the 

mainland, the barge-navigable portion of the Columbia River, and rail and truck routes in 

Oregon, Washington, and Idaho.

Hawaii 

Description: The State of Hawaii is one of the smaller states with only 10,941 square miles of 

territory spread over six larger tropical islands and a number of smaller ones. It is also 

physically separated from the mainland of the United States by 2,300 miles of Pacific Ocean. Its 

tropical nature and isolated location have provided Hawaii with many unique attributes, as well 

as some unique challenges. The nearshore environments around the islands of the Hawaiian 

archipelago include a large array of marine animals, corals and plants, some of which are 

endemic and found nowhere else. This area includes the Hawaiian Islands Humpback Whale 

National Marine Sanctuary, which is comprised of five separate areas abutting six of the major 

islands of the State of Hawaii (figure 2). A primary attraction of this marine sanctuary is the 

large congregation of humpback whales that winter in the area. Beyond the nearshore 

environments surrounding Hawaii is open ocean inhabited by resident and migratory pelagic 

fish, birds, sea turtles, and marine mammals. See appendix B for a list of marine mammals of 

Hawaii, Washington, and Oregon protected under the Marine Mammal Protection Act.
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 7

CPHST. 2006b. The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal 

Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), Plant 

Protection and Quarantine, USDA-APHIS, Raleigh, NC. 8 pp. 

Federal Motor Carrier Safety Administration. 2007. Crash Statistics. Federal Motor Carrier Safety 

Administration (FMCSA), U.S. Department of Transportation. Last accessed July 06, 

http://ai.fmcsa.dot.gov/CrashProfile/StateCrashProfileMain.asp. 

Hazardous Materials Information System. 2007a. Hazardous Materials Safety: Serious incidents. Office 

of Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, 

http://hazmat.dot.gov/pubs/inc/data/tenyr_orig_serious.pdf. 

Hazardous Materials Information System. 2007b. Hazardous Materials Safety: Total incidents. Office of 

Hazardous Materials Safety, U.S. Department of Transportation. Last accessed July 26, 2007, 

http://hazmat.dot.gov/pubs/inc/data/tenyr.pdf. 

Office of Safety Analysis. 2001. Railroad Safety Statistics: Final Report 2000. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

150 pp. 

Office of Safety Analysis. 2003. Railroad Safety Statistics: Final Report 2001. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

158 pp. 

Office of Safety Analysis. 2004. Railroad Safety Statistics: Final Report 2002. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

150 pp. 

Office of Safety Analysis. 2005a. Railroad Safety Statistics: Final Report 2003. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

159 pp. 

Office of Safety Analysis. 2005b. Railroad Safety Statistics: Final Report 2004. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

161 pp. 

Office of Safety Analysis. 2006a. Railroad Safety Statistics: Final Report 2005. Office of Safety 

Analysis, Federal Railroad Administration, U.S. Department of Transportation, Arlington, VA. 

150 pp. 

Office of Safety Analysis. 2006b. Three-year accident rate trends. Office of Safety Analysis, Federal 

Railroad Administration. Last accessed July 27, 

http://safetydata.fra.dot.gov/OfficeofSafety/Query/Default.asp?page=inctally2.asp. 

Office of Safety Analysis. 2007. 3.07 Accidents By State/Railroad. Office of Safety Analysis, Federal 

Railroad Administration, U.S. Department of Transportation. Last accessed July 3, 2007, 

http://safetydata.fra.dot.gov/OfficeofSafety/Query/default.asp?page=incabbr.asp. 

U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar Year 2001, 

Part 5. Corps of Engineers, United States Army, Washington, D.C. 98 pp. 

U.S. Army Corps of Engineers. 2006a. Waterborne Commerce of the United States, Calendar Year 

2005: Part 4–Waterways and Harbors; Pacific Coast, Alaska and Hawaii. Institute for Water 

Resources, U.S. Army Corps of Engineers, Washington, D.C. 207 pp. 

U.S. Army Corps of Engineers. 2006b. Waterborne Commerce of the United States, Calendar Year 

2005: Part 5–National Summaries. Institute for Water Resources, U.S. Army Corps of Engineers, 

Washington, D.C. 99 pp. 
 

8

MSW that is disposed of at the Waimanalo Gulch municipal landfill has primarily been collected 

by private waste haulers and commercial self-haulers. For the most part, it includes waste 

generated at businesses, institutions, multi-family residences, and condominiums. Waste 

collected from single-family households and some apartments and commercial facilities is 

collected by County Refuse Division trucks and is sent to the incinerator along with some of the 

MSW from private waste haulers. The waste stream that is deposited at Waimanalo Gulch 

consists of the following types of materials (R.M. Towhill Corp., 1999): 

 Paper...................................................................8.9% 

 Including: 

 Cardboard............5.2% 

 Low grade paper....2.2% 

Plastics.................................................................5.0% 

 Including: 

 Film plastics.....2.5% 

 Rigid plastic....1.4% 

Metal...................................................................12.3% 

Glass.....................................................................0.5% 

Other inorganics ......................................................20.0% 

 Including: 

Gypsum wallboard....7.0% 

 Asphalt roofing........1.4% 

 Asphalt paving.........1.9% 

 Concrete................2.9% 

 Sand/soil/dirt..........4.0% 

Other wastes...........................................................6.4% 

 Including: 

Furniture/mattresses.....5.1% 

Appliances.................1.0% 

 Yard Waste..............................................................6.0% 

 Wood .....................................................................31.2% 

 Including: 

 Treated wood.......13.9% 

 Pallets/crates..........7.6% 

 Untreated lumber....5.8% 

 Untreated plywood...2.6% 

 Stumps.................1.3% 

 Other organics...............................................................9.6% 

 Including: 

 Carpet................4.5% 

 Food.................1.6% 

There are other sources of GRG in Hawaii besides that destined for Waimanalo Gulch municipal 

landfill. However, any alternative sources of GRG (i.e., Hilo or other cities or islands of Hawaii) 

must meet the APHIS requirement of APHIS regulations pertaining to the regulation of garbage 

generated in Hawaii (7 CFR part 330.402 and 403). Specifically, garbage is defined as urban 
 

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(commercial and residential) solid waste from municipalities in Hawaii, excluding incinerator 

ash and collections of agricultural waste and yard waste. Regulated (domestic) garbage refers to 

articles generated in Hawaii that are restricted from movement to the continental United States 

under various quarantine regulations established to prevent the spread of plant pests (including 

insects, disease, and weeds) into areas where the pests are not prevalent. Together, these 

comprise garbage and regulated (domestic) garbage, referred to as GRG in this BA. 

Description of APHIS Risk Assessments, Regulations, and Other Aspects of 

the Proposed Action 

Potential for Escape of Plant Pests: The opportunity for GRG to carry plant pests has been a 

major concern for APHIS and is the primary reason that APHIS has regulatory interest in 

Hawaiian GRG that may be transported to the continental United States. The opportunity for 

such pests to be introduced into an environment where they are not normally found and where 

they could potentially do environmental harm is of concern. The compression, baling, and 

wrapping process that is required for all GRG to be shipped to the continental United States is 

designed to reduce the potential for impact to an insignificant risk. By prohibiting agricultural 

and yard waste (other than incidental amounts (<3%) that may be present in GRG despite 

reasonable efforts to maintain source separation), much of the risk of pest presence in the GRG is 

eliminated, resulting in an insignificant risk of pest introduction and establishment in the 

continental United States. A review of the composition of the GRG from Oahu that could 

potentially be shipped to the mainland United States indicates that the greatest potential for pest 

presence would be in any yard waste, stumps, sand/soil/dirt, and food that could be in the GRG. 

The USDA, Center for Plant Health Science and Technology (CPHST) developed several risk 

assessments (attached as appendices C-F in this document) that evaluate the effectiveness of the 

compressing and packing technology for processing GRG to keep plant pests from entering and 

successfully establishing in the States of Washington, Oregon, and Idaho, and in the continental 

United States.2

 This is because injurious plant pests (quarantine pests) exist in Hawaii that are 

not currently present or widely distributed within and throughout the continental United States. 

Under the circumstances, it was necessary to determine the risk and likelihood of introduction 

and establishment of these pests in the continental United States, and whether there would be 

potential economic and environmental impacts. APHIS analyzed the plant pest risk of 

introduction and subsequent establishment of plant pests from properly compressed, baled, and 

wrapped Hawaiian GRG and found that risk to be insignificant (see appendices C-F). 

This risk is considered insignificant for the following reasons: Any pests that remain in the GRG 

(e.g., in the incidental amounts (<3%) of yard and agricultural waste and soil with weed seeds 

and food) would be subjected to the compression, baling, and wrapping processes. Compression, 

baling, and wrapping of GRG results in crushing and oxygen deprivation of pests. When bales 

 2

 Risks to animal health have not been considered in the context of the risk assessment process because there are 

currently no known exotic animal diseases in Hawaii that would pose a threat of entry into the continental United States, 

including the State of Washington. 
 

10

are wrapped to the point of being airtight, as required, internal temperatures begin to rise and 

conditions inside the bale become anoxic within several days, thus depriving pests of oxygen. 

Wrapped bales sit in a staging area for 5 days prior to loading them onto a barge for transport to 

the continental United States. This allows time for anoxic conditions to develop within the 

bales. When coupled with the time required to barge the bales to the destination landfill, it is 

clear that any pests that have survived the packaging process will have been exposed to anoxic 

conditions for between two and three weeks. Once arriving at the landfill destination, the bales 

will be transloaded to an asphalt or concrete staging area. Bales may remain at the staging area 

for a few weeks before being transloaded to trucks or rail cars and sent to the landfill. Once 

placed in the landfill, they will be covered with six inches of dirt on that same day and will be 

buried by 7 feet of material within a short time of their arrival. 

As long as bales are not punctured, any pests that do survive the trip to to the landfill (most 

likely weed seeds and pathogens on rotting food) cannot escape the bale and are buried at the 

landfill, thus posing no risk to the environment. If bales are punctured or torn open during 

handling, they will either be re-wrapped or patched, depending upon the severity of the puncture, 

according to the detailed requirements outlined in the compliance agreements to restore their 

airtight condition. Because of the insignificant risk of plant pest escape and establishment in the 

continental United States, there will be no effect on listed species or critical habitat from the 

introduction of non-indigenous plant pests. 

Potential for Escape of “Hitchhiking” Pests:The Pest Risk Assessments, prepared by APHIS, 

indicate that overall, the transportation of urban solid waste from Hawaii in plastic-wrapped, 

airtight bales poses a low risk of pest establishment; and that the greatest risk is from hitchhikers. 

Thus, the PRA specific for the movement to Oregon recommends that the bales be certified 

mollusk-free by the company. The PRA specific for the movement to Idaho also recommends 

inspection and certification. Included in all Compliance Agreements will be a requirement that 

the company provide inspection at each transloading location as well as the final offloading 

point. The companies are required by the compliance agreement to ship bales that do not carry 

hitchhikers. There is no specific method required by APHIS to achieve this standardbesides 

inspection, although other methods may be used as well. If a mollusk is found on a pallet a or 

bale at any of these inspection points on the mainland, the company is required under the 

Compliance Agreement, to separate it on a solid, flat, impervious surface made of asphalt or 

concrete, circle the bale with salt, and contact local PPQ immediately so that proper action can 

be taken to mitigate any potential pest risk. The Compliance Agreements also require that the 

staging area for bales in Hawaii as well as on the mainland be a solid, flat, impervious surface 

made of asphalt or concrete. 

Before handling and transport of Hawaiian GRG bales, company employees are required to be 

trained in various procedures for complying with the agreement, including training on Hawaiian 

plant pests. If a company is found to be in violation of any part of the Compliance Agreement, 

then the Compliance Agreement may be cancelled in accordance with 7 Code of Federal 

Regulations 330.403(d). 
 

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Hawaii side generic compliance agreement:

COMPANY will ensure that the Staging Area be kept clean and free of loose garbage and soil. 

The Staging Area shall be clearly marked and physically separated from the Transport Area. 

Operational procedures pertinent to the Staging and Transport areas shall be posted in a location 

visible to all COMPANY personnel and authorized representatives. 

COMPANY shall develop and enforce plans for pest exclusion and eradication programs to 

control pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, 

mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu, 

Hawaii. 

COMPANY personnel or their authorized representative shall conduct an inspection of each bale 

upon placement onto the barge. Bales shall be inspected for any punctures, ruptures, or tears and 

external contaminants (i.e. soil, garbage, mollusks) upon placement onto the barge. The date and 

identification of the personnel responsible for the inspection and authorization for forward 

movement shall be indicated in the bale manifest. 

Mainland side generic compliance agreement:

 

The staging and transport area shall be kept clean and free of loose garbage and soil. The areas 

will be controlled for birds, rodents, mollusks, and any other pests that may be attracted to the 

bales. 

All Garbage and Regulated (domestic) Garbage must be protected from birds, rodents, and 

mollusks during staging and transport. The bales of Garbage and Regulated (domestic) Garbage 

will be isolated from close proximity to exposed fresh fruits, plants, or other activities which 

may attract hitchhiking plant pest. Barriers will be erected if this occurs due to unusual and 

unavoidable circumstances if the operations cannot be moved. 

If bales are palletized, each pallet will be inspected thoroughly to ensure no hitchhiking 

mollusks. Pallets found to contain hitchhiking mollusks will be separated immediately. The 

infested pallets will be safeguarded within a circle of salt on a level, solid, and impervious 

surface of asphalt or cement, and local PPQ will be notified promptly. 

PPQ does conduct compliance checks, and with most new operations, those checks are more 

heavy and frequent at the beginning of the program. This provides opportunity to address any 

concerns and ensure that the company is meeting the standards set in the Compliance 

Agreement. If the company is operating according to the Compliance Agreement, then PPQ 

compliance checks become less frequent. The frequency of those checks will be determined 

byPPQ locally. 

See appendices C-F for APHIS risk assessments regarding transport of GRG from Hawaii to the 

continental United States, and specifically, Washington, Oregon, and Idaho. 
 

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APHIS Regulations Pertaining to the Regulation of Garbage Generated in Hawaii: 

Sec. 330.402 Garbage generated in Hawaii 

 (a) Applicability. This section applies to garbage generated in households, commercial 

establishments, institutions, and businesses prior to interstate movement from Hawaii, and 

includes used paper, discarded cans and bottles, and food scraps. Such garbage includes, and is 

commonly known as, municipal solid waste. 

 (1) Industrial process wastes, mining wastes, sewage sludge, incinerator ash, or other wastes 

from Hawaii that the Administrator determines do not pose risks of introducing animal or plant 

pests or diseases into the continental United States are not regulated under 

this section. 

 (2) The interstate movement from Hawaii to the continental United States of agricultural 

wastes and yard waste (other than incidental amounts (less than 3 percent) that may be present in 

municipal solid waste despite reasonable efforts to maintain source separation) is prohibited. 

 (3) Garbage generated onboard any means of conveyance during interstate movement from 

Hawaii is regulated under Sec. 330.401. 

 (b) Restrictions on interstate movement of garbage. The interstate movement of garbage 

generated in Hawaii to the continental United States is regulated as provided in this section. 

 (1) The garbage must be processed, packaged, safeguarded, and disposed of using a 

methodology that the Administrator has determined is adequate to prevent the introduction or 

dissemination of plant pests into noninfested areas of the United States. 

 (2) The garbage must be moved under a compliance agreement in accordance with Sec. 

330.403. APHIS will only enter into a compliance agreement when the Administrator is 

satisfied that the Agency has first satisfied all its obligations under the National Environmental 

Policy Act and all applicable Federal and State statutes to fully assess the impacts associated 

with the movement of garbage under the compliance agreement. 

 (3) All such garbage moved interstate from Hawaii to any of the continental United States 

must be moved in compliance with all applicable laws for environmental protection. 

Sec. 330.403 Compliance agreement and cancellation. 

 (a) Any person engaged in the business of handling or disposing of garbage in accordance 

with this subpart must first enter into a compliance agreement with the Animal and Plant Health 

Inspection Service (APHIS). Compliance agreement forms (PPQ Form 519) are available 

without charge from local USDA/APHIS/Plant Protection and Quarantine offices, which are 

listed in telephone directories. 

 (b) A person who enters into a compliance agreement, and employees or agents of that person, 

must comply with the following conditions and any supplemental conditions which are listed in 

the compliance agreement, as deemed by the Administrator to be necessary to prevent the 

dissemination into or within the United States of plant pests and livestock or poultry diseases: 

 (1) Comply with all applicable provisions of this subpart; 

 (2) Allow inspectors access to all records maintained by the person regarding handling or 

disposal of garbage, and to all areas where handling or disposal of garbage occurs; 

 (3)(i) If the garbage is regulated under Sec. 330.401, remove garbage from a means of 

conveyance only in tight, covered, leak-proof receptacles; 
 

13

 (ii) If the garbage is regulated under Sec. 330.402, transport garbage interstate in packaging 

approved by the Administrator; 

 (4) Move the garbage only to a facility approved by the Administrator; and 

 (5) At the approved facility, dispose of the garbage in a manner approved by the Administrator 

and described in the compliance agreement. 

 (c) Approval for a compliance agreement may be denied at any time if the Administrator 

determines that the applicant has not met or is unable to meet the requirements set forth in this 

subpart. Prior to denying any application for a compliance agreement, APHIS will provide 

notice to the applicant thereof, and will provide the applicant with an opportunity to demonstrate 

or achieve compliance with requirements. 

 (d) Any compliance agreement may be canceled, either orally or in writing, by an inspector 

whenever the inspector finds that the person who has entered into the compliance agreement has 

failed to comply with this subpart. If the cancellation is oral, the cancellation and the reasons for 

the cancellation will be confirmed in writing as promptly as circumstances allow. Any person 

whose compliance agreement has been canceled may appeal the decision, in writing, within 10 

days after receiving written notification of the cancellation. The appeal must state all of the facts 

and reasons upon which the person relies to show that the compliance agreement was wrongfully 

canceled. As promptly as circumstances allow, the Administrator will grant or deny the appeal, 

in writing, stating the reasons for the decision. A hearing will be held to resolve any conflict as 

to any material fact. Rules of practice concerning a hearing will be adopted by the 

Administrator. This administrative remedy must be exhausted before a person can file suit in 

court challenging the cancellation of a compliance agreement. 

 (e) Where a compliance agreement is denied or canceled, the person who entered into or 

applied for the compliance agreement may be prohibited, at the discretion of the Administrator, 

from handling or disposing of regulated garbage. 

GRG Baling Process: In Hawaii (all islands), trucks collect waste and take it to a sorting 

facility. GRG for baling and transportation to the mainland United States is prohibited from 

containing more than incidental amounts (less than 3%) of agricultural and yard wastes. From 

the sorting area it is moved to a compression baler where it is unloaded and fed into the baler for 

compression, baling, and wrapping. GRG is compressed to 1,000 kilograms per cubic meter. 

All bales of GRG are wrapped with a minimum of four layers of low density impermeable plastic 

film to provide an airtight and leak-proof enclosure. Wrapped bales weigh between 1.7 to 4 tons. 

 From the compression baler bales are then sent to a staging area until they are loaded onto a 

barge for the trip to the mainland. 

Barge and tug description: The applicants use barges that range in length from 400 to 450 feet 

long and between 80 and 100 feet wide. Barges are powered by tugs that are 3,000 to 4,000 

horsepower and range in length from 90 to 130 feet. The average towing speed across the ocean 

is 6 to 9 knots and the maximum tow speed is 11.6 knots. Barges will transport approximately 

5000-9000 tons of GRG per barge. Bales will be secured to barges by straps or other methods to 

prevent loss of bales during ocean crossing and river transport. 

Barges carry no fuel or oil. Tugs carry between 100,000 and 200,000 gallons of fuel and 500 

gallons of oil. No fuel or oil will be discharged during the voyage; an appropriate quantity of 

fuel will be loaded in Hawaii such that the remaining fuel is sufficient for the trip up the 
 

14

Columbia River but not so excessive that a discharge is required to make draft for passage 

though the locks. 

Ocean routes of travel: The applicants have indicated that the tug/barge route that will be 

traveled (in a westbound context) is such that the barge will travel up the Columbia River and 

out into the Pacific Ocean approximately 25 miles, where it will turn south. They will travel 

south parallel to the coast until near Eureka, California. There, they will make the turn west for 

Hawaii in a fairly straight southwesterly line. There could be some variation in the route taken 

however. The full route from Hawaii to the Columbia River is roughly 2,500 miles. See figure 3 

for a general map of the barge/tug route. 

Figure 3. General route map for barging GRG from Hawaii across the Pacific Ocean to the 

mouth of the Columbia River. 

Ballast Water: The tugs have internal ballast tanks to provide trim and stability for the ocean 

crossing. The tugs draw water from the ocean as required to meet trim and stability 

requirements. Tug ballast water is drawn from the sea and discharged at sea.

Barges are ballasted only during the loading and unloading phase alongside the dock. As barge 

cargo is unloaded, the stability of the barge shifts, requiring the barge to ballast for trim and 

stability. Similarly, as the barge is loaded, the center of gravity shifts requiring the barge to 

ballast to accommodate the weight change. All water taken on to ballast barges for loading or 
 

15

unloading is released into the same water body that it was taken from. No ballast water is 

carried in the barge ballast tanks for the voyage across the ocean. Thus, there will be no effect 

on any listed species or critical habitat as a result of ballast water discharge. 

Hull Fouling: Both barges and tugs use the industry standard ablative coating system to prevent 

hull fouling. The ablative coating provides a slick surface to which fouling organisms cannot 

adhere. Currently, barges and tugs are using IntercleneTM, formula BRA 572, from International 

Paint. However, the specific anti-fouling coating used could vary in the future. Underwater 

moving equipment is further protected with sacrificial zinc anodes. However, APHIS has no 

authority to regulate hull fouling prevention. 

Based on information received from Dan Brown, U.S. Fish and Wildlife Service, Pacific Region, 

Ecological Services, many of these treatments may result in copper leaching. Dissolved copper 

is known to cause olfactory impairments in salmonids. Copper can disrupt and damage the 

olfactory system of salmonids and cause a decreased capacity to detect important chemical cues 

in the environment, including but not limited to the location of prey, predator avoidance and 

locating natal streams. This sense of smell is critical for salmonids to complete to their complex 

life history behaviors including homing, foraging, and predator avoidance. Thus, there is 

potential for these sublethal impacts on the olfactory function to reduce individual salmon 

chances of survival and reproduction. To address the potential for effects of copper leachate 

from aquatic vessels , APHIS has prepared a risk assessment on the potential risk of copper 

exposure to salmonids in the Columbia River from barges containing baled GRG from Hawaii. 

This assessment is included in the “Fish Species That Occur in the Columbia River That Could 

be Affected by Transport of GRG by Barge” section. 

Estimate of Barge Trips Across Ocean: A total of 980,000 tons of GRG annually has been 

requested by applicants for transport to landfills in Washington, Idaho, and Oregon by the 

companies that have requested APHIS permission for this action and additional companies could 

request APHIS permission to transport more to the mainland United States. In the 2005 calendar 

year, 1,425,752 tons of municipal solid waste were disposed of in the State of Hawaii, either by 

landfilling or incineration (OSWM, 2006). However, the State of Hawaii has indicated that it 

will only allow 300,000 tons of GRG to be exported off-island, regardless of what applicants 

have proposed. Thus, if a barge carries 5,000 tons of GRG, this would result in approximately 

60 barge trips per year, slighly more than 1 per week. In this BA, APHIS will assume that there 

will be 100 barge trips of GRG from Hawaii per year across the Pacific Ocean to the mainland 

United States as a worst case scenerio, equaling 500,000 tons of GRG. However, an important 

aspect of the proposed action is that these tugs and barges traveled to Hawaii loaded with 

construction or other materials and would be returning to the mainland United States empty 

regardless of whether this proposed action is approved by APHIS. It is not cost-effective to send 

empty barges to Hawaii simply for the purpose of picking up baled GRG to return to the 

mainland. Thus, no net increase in barge traffic across the Pacific Ocean is expected from this 

action. Nonetheless, the potential effects of barge travel to listed and other marine species are 

discussed below, in section III, and in appendix B. 
 

16

Potential Effects from Ocean Tug/Barge Travel: The potential direct and indirect effects 

from the ocean travel include striking marine animals by barge/tug combination, increased 

marine debris, and disturbance of species. 

Columbia River Travel: The Columbia and Snake Rivers carry 50 million tons of cargo per 

year to and from the Pacific Ocean along a 465-mile waterway. A series of eight locks facilitates 

the passage of ships from the ocean to as far inland as Lewiston, Idaho. These locks are part of 

the same projects and reservoirs that produce hydropower and help control flooding. From the 

ocean to Portland, Oregon and Vancouver, Washington, dredging assures that a 40-foot-deep 

open river channel remains open year-long for ocean-going vessels. This 106-mile segment then 

connects with a 359-mile segment that extends to Lewiston, Idaho. Within this second segment, 

a 14-foot-deep channel for barges and other craft is kept open. To maintain this channel depth, 

maximum and minimum reservoir elevations are set. These elevations are determined within the 

context of meeting needs for electrical generation, flood control, and the release of water to help 

fish passage. In addition to its importance for shipping, the Columbia River is known for its 

fishery resources. Historically, it contained huge salmonid stocks that supported the indigenous 

peoples of the area. Over the years, treaties have recognized and maintained the importance of 

Indian fishing and hunting rights. While greatly reduced from historic levels, salmon and other 

fish stocks remain an important resource in the Columbia River. 

Potential Effects from Columbia River Tug/Barge Travel: A direct effect of the proposed 

action could be an increase in barge traffic on the Columbia River. A U.S. Army Corps of 

Engineers (2004) study indicated that the net volume of tonnage for the Columbia Basin was 

54,390,000 (short) tons of freight (all commodities), with over 1,113,000 tons going between 

Vancouver and The Dalles and 2,231,000 tons moving above The Dalles. Assuming an average of 

5,000 tons per barge load, there are approximately 10,000 barge trips per year on the Columbia. If 

100 additional barge trips per year are added, the anticipated increase in barge traffic 

(approximately 100 trips per year) would represent approximately 1 percent of all barge traffic on 

the Columbia. This represents a minimal increase in barge traffic on the Columbia River. 

Household chemical waste comprises only 0.3% of Hawaiian solid municipal waste (R.M. 

Towhill Corp., 1999). Before baling, this waste will be sorted to eliminate yard waste, 

recyclables, and hazardous chemical waste. Although there is a possibility that some household 

chemical waste could make its way into a bale, an accident would have to occur for a bale to fall 

into the water. The bale would also have to break open. The rate of barge accidents is low, as 

will be discussed later in this BA. Because the potential quantity of household chemical wastes 

being present in the bales is very low, combined with the low probability of a bale-rupturing 

barge accident, it is very unlikely that there would be an effect on water quality in the mainstem 

Columbia River. Therefore, the potential impacts on water quality are not considered further. 

Another direct effect of the proposed action could be a decrease in water quality from fuel or oil 

leaks from the tug. A catastrophic spill of fuel or oil is extremely unlikely and would be 

considered under an emergency consultation with the Services. However, routine leakage of 

small amounts of fuel or oil in the Columbia River is considered in this assessment. Effects of 

the fuel could directly poison fish species in the Columbia River or indirectly affect them by 
 

17

poisoning invertebrate or prey species. Oil and petroleum products vary considerably in their 

toxicity, and the sensitivity of fish to petroleum varies among species. The sublethal effects of 

oil on fish include changes in heart and respiratory rates, gill hyperplasia, enlarged liver, reduced 

growth, fin erosion, impaired endocrine system, and a variety of biochemical, blood, and cellular 

changes, and behavioral responses (from page B-32: Biological Opinion, May 9, 2003, U.S. Fish 

and Wildlife Service, Montana Ecological Services Field Office). 

A risk assessment discussing these effects are included in the assessment for Columbia River fish 

in section II of this document. This assessment has indicated that the risk to species in the 

Columbia River as a result of fuel or oil leaks would be extremely small. 

Transportation by Rail and Truck: Flat-bed semi-tractor trailer trucks or other truck types 

may be used to transport baled GRG from barge offloading sites to landfills. In certain cases, 

rail cars will be used to transport baled GRG to landfills. Both of these transportation options 

would increase truck or rail traffic in Washington, Oregon, or Idaho, depending on the 

destination landfill. 

For example, at the Columbia Ridge Landfill in Oregon, 600 to 750 trucks per month are 

currently received. A proposed option of unloading barges near Boardman, OR and transporting 

baled GRG by truck to the Columbia Ridge Landfill would add 125 to 200 additional trucks per 

month to that landfill. The Columbia Ridge Landfill currently receives approximately 5 unit 

trains per week with each train containing 60 to 65 railcars (1,200 to 1,400 railcars and 60,000 to 

80,000 tons per month). A proposal to unload barges in the Portland, Oregon area and transport 

GRG by rail to Columbia Ridge Landfill, would add an additional 100 to 150 additional railcars 

each month to the incoming rail traffic at that landfill. 

As of 2001, there were 2,387 route miles of railroad in Oregon (ODT, 2001) (figure 4). 

Currently, the Union Pacific’s east-west line in Oregon that runs along the south bank of the 

Columbia River and the I-84 corridor into Idaho is proposed for transport of GRG from Portland 

to a landfill in Gilliam County, Oregon. 
 

18

Figure 4. Freight railroads in Oregon (ODT, 2001). 

Idaho is served by two Class I Railroads (carriers having revenues in excess of $250 million 

annually), the Burlington Northern and the Union Pacific. In addition, service is provided by six 

regional or local railroads. Together, they comprise a 1,940-mile state rail system (ITD, 1996) 

(figure 5). 
 

19

Figure 5. Railroads in Idaho (ITD, 1996). 

Washington State is served by two Class I railroads, two regional railroads, and 16 active short 

lines and switching railroads (WSTC, 2006) (figure 6). In total, there are 3,628 miles of rails 

operated in the state (WSTC, 2006). 
 

20

Figure 6. Washington State Rail System (WSDOT, 2007). 

Potential Effects From Rail and Truck Transportation: Increased rail and truck traffic as 

GRG bales are transported from unloading sites on the Columbia River to landfills will occur. 

This traffic increase could increase the likelihood that certain listed species could be struck by 

trucks or trains. Collisions between wildlife and vehicles result in the loss of wildlife, vehicle 

damage, and, occasionally, human injuries or fatalities. Between 1986 and 2005 in Yoho 

National Park in Canada, park staff have recorded over 500 wildlife-vehicle collisions involving 

large animals. Most victims of highway strikes are large ungulates (deer, elk, and moose), but 

wolves, coyotes and black bears are also commonly hit. The impact of highway strikes on small 

mammal, bird, and amphibian populations is unknown, as these collisions are rarely reported. 

The following quoted information is from: The relationship between rare carnivores and 

highways, an update for year 2000. Bill Ruediger, Endangered Species Program Leader, USDA 

Forest Service, Northern Region, Missoula, Montana 

“Carnivores are particularly susceptible to highway mortality because of their large home ranges, 

low biological productivity and the enormous sized areas required to sustain populations and 

individuals. Due to the long life spans (over 30 years for grizzly bear), carnivores can continue 

existing as individuals-without persisting as populations. As mentioned previously, human 
 

21

caused mortality has been a contributing factor for many species. 

Examples of direct mortality on wolves are numerous. In Banff National Park during 1996, there 

were 11 wolf mortalities caused by collisions with cars, trucks and trains. This was the 

equivalent of the entire known wolf reproduction for the park and surrounding area. When 

wolves recolonized NW Montana, two alpha male wolves were killed on I-90 (Bangs, personal 

communication). The reintroduced wolves as of 2000 are doing well in both Yellowstone 

National Park and Central Idaho. Vehicle collisions with wolves have become a regular 

occurrence for these populations. In Weaver's (personal communication) wolf study in Jasper 

National Park and Paquet's in Banff National Park, highway and railroad mortality averaged 1-2 

per pack per year. 

Grizzly bear are rarely killed on highways. However, documented fatal collisions have occurred 

on Highways 93 and 2 in Montana and the Trans-Canada Highway before fencing was 

employed. The rare occurrences of grizzly mortality are likely due to their general avoidance of 

highways and their low population numbers and densities.” 

“Lynx highway mortalities have recently been observed in Colorado, where 10% of the known 

mortality of a reintroduced population has been vehicle collisions. Clevenger has also seen lynx 

carcasses on the Trans-Canada Highway. Sixteen of 83 lynx translocated lynx were killed on 

highways in New York (Brocke et al. 1991).” 

“Information from Florida on black bear road kills suggests that while vehicle use of highways 

in the study area increased by 100% (to 24,000 vehicle trips per day), black bear road kills went 

from less than five to over 90 in the same period (Gilbert & Wooding, 1996).” 

Grizzly bears have been struck and killed by trains; trains between West and East Glacier, 

Montana killed 13 grizzly bears during the period 1992-2002 (Waller et al. 2005). Railways are 

another source of human-induced wildlife mortality in Yoho National Park. The Canada Pacific 

(CP) rail line through Yoho was opened in 1885; today approximately 35 trains travel through 

the park each day. Since 1986, over 55 animals have been reported killed on the CP rail line, 

including 25 elk, 11 black bears and 6 wolves. In Banff National Park in Canada, significant 

amounts of spilled grain have been observed between the rails over the past several years from 

6,000 CP hopper cars suspected of leaking grain between the prairies and west coast terminals. 

Grizzly bears, black bears, wolves, coyotes, elk and deer have been struck and killed as they 

forage for grain or use the right-of-way for easy passage. 

Estimate of Rail Traffic Increase: Using an estimate of 500,000 tons of GRG from Hawaii per 

year, a bale weight of 1.7 tons, and a transport weight of 112 tons per railcar (based on 

information submitted by Idaho Waste Systems), a total of about 4,465 railcars would be added 

to rail transport per year, assuming that all of the GRG is transported by railcar to landfills. In 

Oregon alone, 63.5 million tons of cargo were transported by rail to, from, within, and through 

the state in 1999 (Oregon Rail Plan, 2001). This would translate into 566,965 railcars per year. 

Based on this figure, transport of GRG by rail would result in a less than 1 percent increase in 

number of railcars per year in Oregon. In 1998, 85 million tons of freight were moved by rail to, 

from, and within Washington (USDOT, 2002a). This translates to 758,929 railcars. Based on 

this figure, transport of GRG by rail would also result in a less than 1 percent increase in number 
 

22

of railcars per year in Washington. For Idaho, 18 million tons of freight were moved by rail to, 

from, and within the state (USDOT, 2002b). This translates into 160,715 railcars. Based on this 

figure, transport of GRG by rail would result in a 3 percent increase in number of railcars per 

year in Idaho. These estimates of rail increase are very conservative and assume that all of the 

GRG from Hawaii would be transported by rail, a scenerio that is unlikely. 

Estimate of Truck Traffic Increase: Using an estimate of 500,000 tons of GRG from Hawaii 

per year, a bale weight of 1.7 tons, and a transport weight of 34 tons per truck (based on 

information submitted by applicants in WA), a total of 14,706 trips would be added to truck 

transport per year, assuming that all of the GRG is transported by truck to landfills. In 1998, 220 

million tons of freight were transported by highway in Oregon (USDOT, 2002c) (approximately 

6,470,588 truckloads), 307 million tons in Washington (USDOT, 2002a) (approximately 

9,029,411 truckloads), and 95 million tons in Idaho (USDOT, 2002b) (approximately 2,794,117 

truckloads). This results in a 0.2, 0.1, and 0.5 percent increase of truck/highway freight traffic in 

Oregon, Washington, and Idaho, respectively. These estimates of truck traffic increase are very 

conservative and assume that all of the GRG from Hawaii would be transported by truck, a 

scenerio that is unlikely. 

Potenial Effects from Barge, Train, Truck, and Bale Transferring Accidents: Short of 

capsizing (which would be considered a catastrophic event and would be cause to initiate 

emergency consultation with NMFS and/or FWS), there is little risk of environmental impact 

from the transport of baled GRG from Hawaii to the mainland United States. Places where there 

is potential for impact to occur are wherever bales are moved from one staging area or mode of 

transportation to another. The transfer points include: (1) the staging area in Hawaii where baled 

GRG is moved, handled, and loaded onto barges, (2) the staging area where bales are transloaded 

from the barges and loaded onto railcars or trucks; and (3) the final destination where bales are 

unloaded from rail cars or trucks and placed into the landfill. 

At each of the bale transfer points identified above, there is a small potential for dropping a bale 

into the water or compromising the integrity of one or more bales of GRG that could result in 

spillage of the contents on the ground or into the water. Information provided by one of the 

applicants indicates that when bales were dropped from heights ranging from 7.5 feet to 12 feet, 

the bales did not rupture, but remained intact. Rather than bales rupturing, it is more likely that 

equipment operators who are handling bales could accidentally puncture bales. Even though 

puncturing may occur, material compressed to the extent the baled GRG will be (estimated at 

1000 kilograms per cubic meter) is likely to be resistant to movement of material out of the bale. 

 In addition, the likelihood of pest species escaping, while not zero, is very low because of the 

low likelihood of host material being present and of pests surviving the compression and 

packaging process and any anoxic conditions experienced until the time of the puncture. Even if 

material did exit the bale upon puncture, in most cases the spilled GRG would be quickly 

retrieved and the bale patched or repackaged according to the requirements of the compliance 

agreement. If this were to happen over water, it would be more difficult to retrieve the spilled 

GRG. 

Physical risks that must be considered in such a situation include a physical disruption of the 

environment caused by the broken bales and the physical retrieval of their strewn contents. 
 

23

Physical removal of GRG that has been spilled on land will be relatively easy to retrieve. Most, 

if not all, of the land that will be used during the transfer of bales will be commercial or 

industrial in nature and not suitable habitat for wildlife. Therefore any cleanup activities are 

unlikely to have an environmental effect. GRG that is spilled into waterways will be more 

difficult to retrieve, and some may not be retrievable, resulting in an incremental but permanent 

degradation of the natural aquatic environment. Since hazardous wastes are not permitted in the 

bales, any negative impacts will be restricted to physical ones and no chemical pollution is likely 

to result from the GRG itself. 

Bales of GRG could potentially fall from the barge, either in the ocean or in the Columbia River. 

Bales of GRG will sink to the bottom because of their significant relative density. Bales may 

remain intact or could break open, depending on conditions. U.S. Army Corps of Engineers 

(2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles. Of those, only 4 

of the 167 accidents on the Columbia River involved freight barges (Marine Safety Offices, 

2006). The mean fraction of accidents that might cause bales to rupture was 0.11, estimated 

from the number of accidents involving hazardous materials which resulted in spills from 1990 

to 1997 (see appendix C for APHIS risk assessment). However, applicants must submit spill 

response plans should bales fall into the water. 

The APHIS risk assessments (appendices D-F) analyzed the potential for bale-rupturing accidents 

based on specific proposals submitted by applicants. Although none of the risk assessments 

analyzed the transport of 500,000 tons of GRG, they demonstrate the low probability of balerupturing accidents for barge, truck, and rail transport. This information is summarized in the 

below. 

• The APHIS risk assessment for Washington State (see appendix D) estimated the annual 

likelihood of a bale-rupturing accident was 0.03 percent for trucks and 0.37 percent for 

barges. Mean years to the first bale-rupturing accident for trucks was estimated at 3,333, 

and that for barges was 130 (USDA, APHIS, 2006). APHIS found a 95 percent chance that 

the first truck accident would occur only after 171 years, or after 7 years for barge 

transport. The risk of catastrophic rupture of bales while in transport by truck or barge to 

Roosevelt landfill is very low (USDA, APHIS, 2006). These risk figures were based on the 

proposed transport of 300,000 tons of GRG per year. 

• The APHIS risk assessment for Gilliam County, Oregon (see appendix E) estimated that 

for the proposal to offload the baled GRG at the Port of Arlington and truck it to Columbia 

Ridge Landfill, the risk of a bale-rupturing accident for trucks was 0.045 percent and for 

barges was 0.41 percent. Mean years to the first bale-rupturing accident for trucks was 

2,222, and that for barges was 246. For the alternate route where GRG is off-loaded near 

Ranier, Oregon and is transported by rail to the Columbia Ridge Landfill, the risk of any 

bale-rupturing accident by train was 0.002 percent, while that for barges was 0.77 percent. 

Mean years to the first bale-rupturing accident for trains was 50,000 and for barges, was 

130. There wa a 95 percent chance that the first train accident would occur only after 921 

years, or after 554 years for barge transport. These risk figures were based on the proposed 

transport of 120,000 tons of GRG per year. For both options, the risk of catastrophic 

rupture of bales is low, less than 1 percent. 
 

24

• The APHIS risk assessment for Elmore County, Idaho (see appendix F) estimated that for a 

proposal to barge bales 60 miles up the Columbia River and off-load them onto railcars at 

Rainier, OR, the mean annual probability of a bale-rupturing accident by barge was 0.07 

percent, and for trains 0.26 percent. Mean years to the first bale-rupturing barge accident 

was 645 years, with only a 5 percent chance of happening within 34 years. Mean years to 

the first bale-rupturing rail accident was estimated to be 1,429 years, with only a 5 percent 

chance of that accident happening within 74 years. These probabilities are based on a 

figure of 360,000 tons transported annually. 

Potential Effects from Interrelated Actions: An interrelated action of the proposed action is 

that barges that transport bales of GRG from Hawaii to the mainland will come from the 

mainland to Hawaii loaded with materials that are not regulated by APHIS. This could include 

construction materials or any other product that is transported to Hawaii via barge, and rather 

than these barges returning to the mainland empty, bales of GRG will be transported to the 

mainland. APHIS has no knowledge of what these materials are because they are unregulated by 

this agency. Barges transporting materials from the mainland will depart to Hawaii regardless of 

whether APHIS approves the movement of GRG bales. It is difficult to predict the effects of 

these interrelated, yet unknown actions. 

Potential Effects from Interdependent Actions: There are no known interdependent actions 

that will result from approval or implementation of this proposal. 

Potential Cumulative Effects: Private and state activities, including barging and transport of 

materials in the Columbia River, movement of freight by truck or rail, and disposal of MSW in 

landfills occur on a regular basis throughout Oregon, Idaho, and Washington. APHIS does not 

anticipate any cumulative effects as a result of the proposed action because the increase in barge, 

rail, and truck transport as a result of this action is not significant. In addition, because the 

likelihood of bale rupturing accidents via barging, rail transport, and trucking is low, increased 

pollution/trash in the Columbia River or plant pest release is not expected as a result of this 

action (USDA, APHIS, 2006, 2007 (see appendices C-F)).

In Hawaii, there are many shipping and boating activities that occur. Some of these include: 

Hawaii Superferry is a privately owned inter-island ferry system, that utilizes a 350 foot-long, 

four-story high-speed catamaran to carry passengers, vehicles and freight between Oahu, Maui 

and Kauai. These ships will carry upwards of 850 passengers and 280 vehicles each. They will 

cruise at speeds of up to 45 mph, greatly endangering humpback whales and all marine life in 

their path. Currently, service to Maui has been suspended until December 1, 2007. An 

environmental assessment is in preparation by the State of Hawaii to consider the potential for 

increased traffic around ports, the potential spread of invasive species, and collisions with 

humpback whales, among other things. The state legislature passed a measure that was signed 

by the governor on November 6, 2007 that allows the ferry to operate conditionally while an 

environmental assessment is conducted. 
 

25

Cruises between the United States mainland and Hawaii are growing in popularity each year. 

Norwegian/NCL America offers the most Hawaii cruises. Other cruise lines with Hawaii 

itineraries include Carnival, Celebrity, Holland America, Princess, and Royal Caribbean. These 

ships offer weekly itineraries visiting ports on the major Hawaiian Islands: Oahu (Honolulu 

port), Maui (Kahului or Lahaina), Kauai (Lihue), and the Big Island (Hilo and Kailua-Kona). In 

the first 9 months of 2007, there were 52 cruise ship arrivals in Hawaii compared to 45 in the 

same period in 2006(Wienert, 2007). 

According to a Department of Transportation Freight Management and Operations report, 14 

million tons of freight was shipped to, from, and within Hawaii by water in 1998 (USDOT, 

2002d). The report predicts 20 million tons for 2010 and 24 million tons by 2020 (USDOT, 

2002d). See figure 7 for a Department of Transportation map of domestic water flows to Hawaii, 

and table 1 for the top 5 commodities shipped to, from and within Hawaii. 

Figure 7. Domestic Water Flows To, From, and Within Hawaii by Water: 1998 (tons) (USDOT, 

2002d) 
 

26

Table 1. Top Five Commodities Shipped To, From, and Within Hawaii (USDOT, 2002d) 

Tons 

(millions) 

Value 

Commodity (billions $) 

1998 2020 

Commodity 

1998 2020 

Crude Petroleum/Natural Gas 12 15 Transportation Equipment 11 21 

Nonmetallic Minerals 7 9 Electrical Equipment 7 37 

Waste/Scrap Materials 4 9 Machinery 7 39 

Petroleum/Coal Products 3 6 Mail/Contract Traffic [a] 5 25 

Farm Products 3 3 Crude Petroleum/Natural Gas 1 2 

a

 U.S. mail or other small packages. 

There is increased potential for collisions with listed marine species and other protected marine 

mammals from increased vessel traffic in Pacific waters. All forms of marine vessel traffic 

appear to be on the increase whether from increased visitors or freight to and from the islands. 

However, the proposed action will not contribute to cumulative impacts on these species because 

there will be no increase in the number of tugs and barges coming to Hawaii or returning to the 

mainland as a result of this proposed action. Barges will come to Hawaii bringing construction 

materials and other cargo not regulated by APHIS. APHIS has no authority over the number of 

tugs and barges that travel to and from Hawaii. Rather than returning empty to the mainland, 

barges will carry baled GRG from Hawaii. It is not financially feasible for waste haulers to send 

barges to Hawaii solely for the purpose of hauling baled GRG. 

References 

Brocke, R.H., K.A. Gustafson and L.B. Fox. 1991. Restoration of Large Predators: Potentials 

and Problems. In: Decker, D.J., M.E. Krasny, G.R. Groff, C.R. Smith and D.W. Gross. Editors: 

Challenges in the Conservation of Biological Resources - A Practitioners Guide. 

Gilbert, T., and J. Wooding. 1996. An Overview of black bear roadkills in Florida 1976-1995. 

In: Evink, G.L.; Garrett, P.; Ziegler, D.; and J. Berry (Eds.) Trends In Addressing 

Transportation Related Wildlife Mortality. Proceedings of the TransportationRelated Wildlife 

Mortality Seminar. 

Wienert, M. 2007. In Hawaii, $9.2 Billion in Visitor Spending Realized Year-to-Date. Hawaii 

Reporter, October 25, 2007. http://www.hawaiireporter.com/story.aspx?5df8dad9-1c91-4796-

9342-08299dfa6ef3 last accessed November 20, 2007. 

Idaho Transportation Department, Transportation Planning Division (ITD). 1996. Idaho State 

Rail Plan. http://itd.idaho.gov/planning/railfreight/railplan/raildown.html last accessed

September 27, 2007. 

Office of Solid Waste Management. 2006. Report to the twenty-fourth legislature, State of 
 

27

Hawaii, Department of Health, December, 2006. 6 pp. 

Oregon Department of Transportation (ODT). 2001. Oregon Rail Plan. 

http://www.oregon.gov/ODOT/RAIL/docs/railplan01.pdf last accessed September 26, 2007. 

OSWM−see Office of Solid Waste Management 

R.M. Towhill Corp., 1999. Oahu Municipal Refuse Disposal Alternatives Study, Waste 

Composition Study. Honolulu, HI. 36 pp. 

U.S. Army Corps of Engineers. 2002. Waterborne Commerce of the United States: Calendar 

Year 2000, Part 5. Corps of Engineers, United States Army, Washington, D.C. 2002. 140 pp. 

U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar 

Year 2001, Part 5. Corps of Engineers, United States Army, Washington, D.C. 2002. 98 pp. 

U.S. Army Corps of Engineers. 2006. Waterborne Commerce of the United States: Calendar 

Year 2004, Part 4 – Waterways and Harbors Pacific Coast, Alaska and Hawaii Corps of 

Engineers, United States Army, Washington, D.C. 2002. 197 pp. 

U.S. Department of Transportation, Federal Highway Administration. 2002a. Freight 

Transportation Profile−Washington Freight Analysis Framework. FHWA-OP-03-046, EDL 

13734. 2 pp. 

U.S. Department of Transportation, Federal Highway Administration. 2002b. Freight 

Transportation Profile−Idaho Freight Analysis Framework. FHWA-OP-03-042, EDL 13730. 2 

pp. 

U.S. Department of Transportation, Federal Highway Administration. 2002c. State Profile – 

Oregon: 1998, 2010, 2020 6 pp. 

http://ops.fhwa.dot.gov/freight/freight_analysis/state_info/oregon/profile_or.htm last accessed

September 20, 2007. 

U.S. Department of Transportation, Federal Highway Administration. 2002d. State Profile – 

Hawaii: 1998, 2010, 2020 6 pp. 

http://ops.fhwa.dot.gv/freight/freight_analysis/state_info/hawaii/profile_hi.htm last accessed

November 20, 2007. 

United States Department of Agriculture, Animal and Plant Health Inspection Service. 2006. 

The Risk of Introduction of Pests to the Continental United States via Plastic-Baled Municipal 

Solid Waste from Hawaii, 41 p. 

United States Department of Agriculture, Animal and Plant Health Inspection Service. 2006. 

The Risk of Introduction of Pests to Washington State via Plastic-Baled Municipal Solid Waste 

from Hawaii, 8 p. 

Waller, J.S., C. Serveen, and D.A. Patterson. 2005. Probabilistic measure of road lethality. 
 

28

John Muir Institute of the Environment, Road Ecology Center, University of California, Davis. 

http://repositories.cdlib.org/jmie/roadeco/Waller2005a last accessed August 28, 2007. 

 

Washington State Transportation Commission (WSTC). 2006. State Rail Capacity and State 

Needs Study. Task 1.1.A – Washington State’s Freight Rail System. Technical Memorandum. 

http://www.wstc.wa.gov/Rail/TM1_1_A_WashStateFreightRailsys.pdf last accessed September 

26, 2007. 

Washington State Department of Transportation (WSDOT). 2007. Washington State Rail 

System Map. 

http://www.wsdot.wa.gov/freight/Rail%20System%20Map%20%20Update%20Aug2007.pdf 

last accessed September 26, 2007. 

II. Listed Species and Program Assessments 

Section 7 of the Endangered Species Act (ESA) and its implementing regulations require Federal 

agencies to ensure that their actions are not likely to jeopardize the continued existence of 

endangered or threatened species or result in the destruction or adverse modification of critical 

habitat. This BA considers the effects of transportation by barge, truck, and train, and landfilling 

of baled Hawaiian GRG on listed species and designated critical habitat in Oregon, Idaho, and 

Washington, and on species occurring in the Pacific Ocean where barges would cross from 

Hawaii to the Columbia River. 

APHIS has determined that the proposed action will have no effect on the species or their 

designated critical habitat listed in tables 2-5, including plants, birds, aquatic species, and 

butterflies. 

APHIS is requesting concurrence with its determination that, with the implementation of certain 

protection measures (in some cases), the proposed action may affect, but is not likely to 

adversely affect, the humpback whale, blue whale, fin whale, sei whale, sperm whale, Southern 

Resident killer whale (and designated critical habitat), green sea turtle, hawksbill sea turtle (and 

designated critical habitat), olive ridley sea turtle, leatherback sea turtle (and designated critical 

habitat), loggerhead sea turtle, steller sea-lion (and designated critical habitat), and the Hawaiian 

monk seal (and designated critical habitat) during the barging of baled GRG from Hawaii to the 

continental United States. 

In the unlikely event that a barge accident were to occur and GRG bales were to fall into the 

Columbia River, or that oil/fuel would leak from tugs into the river, APHIS requests concurrence 

with its determination that this may affect, but is not likely to adversely affect salmon, steelhead, 

and bull trout in the Columbia River. The proposed action may affect, but is not likely to 

adversely affect the designated critical habitat of these fish. 

APHIS is requesting concurrence with its determination that the increased transport of GRG via 

train or truck, potentially increasing mortality from strikes, may affect, but is not likely to 
 

29

adversely affect the Columbian white-tailed deer, Canada lynx, grizzly bear, northern Idaho 

ground squirrel, woodland caribou, gray wolf, and the pygmy rabbit (Columbian Basin DPS). 

Measures necessary to protect listed species as a result of this and/or future consultations with 

NMFS and FWS (i.e., steller sea-lion, whales, Hawaiian monk seal, etc.) will be included in all 

compliance agreements between APHIS and the applicants. 

In the occurrence of a catastrophic event, such as the capsizing of a barge loaded with bales of 

Hawaiian GRG or an oil spill, APHIS will initiate emergency consultation with the Services. 

Spills and capsizing would be an unpredictable event (temporally/geographically) and therefore, 

not possible to assess at this time. 

PPQ will provide to FWS an annual report for three years (first report should be submitted a year 

from when GRG shipments from Hawaii commence, and then at he same time for the next 2 

years) concerning compliance agreement activities, a summary of any incidents documented on 

the bale manifests, and any PPQ quarantine-significant pest found in association with the 

movement of baled garbage from Hawaii. If within those three years no PPQ quarantinesignificant pests are found in association with the movement of baled garbage then PPQ will no 

longer send annual reports. After the three year reporting period, a report will only be issued by 

PPQ to the FWS and NMFS if formally requested. PPQ will notify FWS and NMFS within 3 

business days of any known release of any unwanted organisms. 

Listed Marine Species That Could be Affected by Transport of GRG From 

Hawaii to the Columbia River. 

Hawaiian Monk Seal, Monachus schauinslandi 

Status: The Hawaiian monk seal was listed as endangered on November 23, 1976 (FWS and 

NMFS, 1976). Critical habitat was designated on March 23, 1999 (USDOC, NMFS, 1999). A 

revised recovery plan for the Hawaiian monk seal was completed in August, 2007 (NMFS, 

2007). 

Pertinent Species Information: Hawaiian monk seals have limbs that are relatively short; 

forelimbs are somewhat flipper-like; hind limbs have fully webbed digits and cannot be turned 

forward or used effectively for terrestrial locomotion. Pup pelage is woolly and black. Juvenile 

pelage is silvery gray above and creamy white below, changing to dull brownish above and 

yellowish below. Adults are silvery gray to brownish above, whitish or silvery gray or yellowish 

below. Adult males average around 214 cm in total length and 170 kg; adult females may grow 

a little larger than this and attain much greater mass (e.g., 270 kg) when pregnant. Pup mass is 

16-18 kg at birth. (From NatureServe, 2007) 

Hawaiian monk seals are found throughout the northwestern Hawaiian Islands (NWHI) 

including the population’s six main reproductive sites in the NWHI: Kure Atoll, Midway 

Islands, Pearl and Hermes Reef, Lisianski Island, Laysan Island, and French Frigate Shoals 

(NMFS, 2007). Smaller breeding sub-populations occur on Necker Island and Nihoa Island, and 

monk seals have been observed at Gardner Pinnacles and Maro Reef. Monk seals are now found 
 

30

throughout the main Hawaiian Islands, where births have been documented on most of the major 

islands (NMFS, 2007). 

The Hawaiian monk seal is in a decline and only approximately 1,200 seals remain (NMFS, 

2007). 

Threats to this species include low survival of juveniles and sub-adults due to starvation, 

entanglement of seals in marine debris, predation by Galapagos sharks, human interactions in the 

main Hawaiian Islands, including recreational fishery interactions, mother-pup disturbance on 

popular beaches, and exposure to disease, seal-haul-out and pupping beaches are being lost to 

erosion (NMFS, 2007). 

Assessment: Honolulu Harbor, around Barber’s Point (west Mamala Bay) and the Port of Hilo 

in Hilo Harbor, Hawaii are currently proposed harbors for loading baled GRG. It is possible that 

Hawaiian monk seals may be present within the harbors used by barges transporting baled MSW. 

Hawaiian monk seals have been sighted in the harbors of Maui and Kauai and some of these 

harbors are known to have resident seals. For example, in Maalaea Harbor, Maui, a resident 

monk seal is known to swim almost daily throughout the harbor. That particular individual is 

tagged and monitored. There is no discussion of Hawaiian monk seals and harbor occurrences in 

the recovery plan. 

Although there is no published evidence that Hawaiian monk seals have been struck by vessels, 

one seal was found in 1986 with a broken jaw and presumed propeller cuts on his ventrum 

(NMFS, 2007). Another seal was found off Kona with an injured back and broken vertebrae and 

may have been due to a vessel strike (NMFS, 2007). As occurrences of Hawaiian monk seals 

and vessel traffic both increase in the Main Hawaiian Islands, the chance of collision is likely to 

increase. 

The potential for collisions between the tug/barge and Hawaiian monk seals is very low due to 

the slow tow speed (6-9 knots). In addition, implementation of the proposed action will not 

result in an increase in vessel traffic because the barges used for transport of baled GRG would 

be coming to Hawaii and returning to the mainland regardless of APHIS approval of GRG 

transport. The barges would carry GRG bales rather than returning to the mainland empty. 

However, the following protection measures will be implemented and included in compliance 

agreements: Vessel operators will be on the lookout for Hawaiian monk seals when transiting to 

and leaving harbor waters. In the event that a seal is in the harbor, the vessel must be prepared to 

stand down until the seal leaves on its own volition. Should a vessel collision occur with a 

Hawaiian monk seal, immediately contact the National Oceanic and Atmospheric Administration 

(NOAA) Fisheries hotline at 1-888-256-9840. This incident should be reported to APHIS. 

APHIS will initiate formal consultation with NMFS. 

With the implementation of these measures, APHIS has determined that the proposed action may 

affect, but is not likely to adversely affect the Hawaiian monk seal. 

References: 

National Marine Fisheries Services (NMFS). 2007. Recovery Plan for the Hawaiian Monk Seal 
 

31

(Monachus schauinslandii). Second Revision. National Marine Fisheries Service, Silver Spring, 

MD. 165 pp. 

U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Services (NMFS). 1976. 

Hawaiian Monk Seal Final Regulations. Federal Register, Vol. 41, p.51611-51612, November 

23, 1976. 

United States Department of Commerce. 1999. National Marine Fisheries Service. Endangered 

and Threatened Species; regulations Consolidation. Federal Register, Vol. 64, p. 14052-14077, 

March 23, 1999. 

Steller Sea Lion, Eumetopias jubatus 

Status: The steller sea lion was emergency listed as endangered west of 1440 west longitude 

(USDOI, FWS, 1990a). It was emergency listed as threatened in locations other than west of 

1440 west longitude on April 5, 1990 (USDOI, FWS, 1990b). Critical habitat has been 

designated for this species. 

Pertinent Species Information: (From National Marine Mammal Laboratory 

http://nmml.afsc.noaa.gov/AlaskaEcosystems/sslhome/StellerDescription.html last accessed

June 7, 2006). 

The steller sea lion is the largest member of the Otariid (eared seal) family. Males may be up to 

325 cm (10-11 ft) in length and can weigh up to 1,100 kg (2,400 lb). Females are smaller than 

males, 240-290 cm (7.5-9.5 ft) in length and up to 350 kg (770 lb) in mass. Males and females 

are light buff to reddish brown and slightly darker on the chest and abdomen; naked parts of the 

skin are black. Wet animals usually appear darker than dry ones. Pups are about 1 m (3.3 ft) in 

length and 16-23 kg (35-50 lb) at birth and grow to about 30-40 kg (65-90 lb) after 6-10 weeks. 

Pups are dark brown to black until 4 to 6 months old when they molt to a lighter brown. By the 

end of their second year, pups have taken on the same pelage color as adults. 

Bulls become mature between 3 and 8 years of age, but typically are not massive enough to hold 

territory successfully until 9 or 10 years old. Females reproduce for the first time at 4 to 6 years 

of age, bearing at most a single pup each year. Pups are born from late May through early July, 

with peak numbers of births during the second or third week of June. Females stay with their 

pups for about 9 days before beginning a regular routine of foraging trips to sea. Females mate 

11 to 14 days after giving birth. Implantation takes place in late September or early October, 

after a 3-4 month delay. Weaning is not sharply defined as it is for most other pinniped species, 

but probably takes place gradually during the winter and spring prior to the following breeding 

season. It is not uncommon to observe 1- or 2-year-old sea lions suckling from an adult female. 

Steller sea lions are distributed across the North Pacific Ocean rim from northern Hokkaido, 

Japan, through the Kuril Islands, Okhotsk Sea, and Commander Islands in Russia, the Aleutian 

Islands, central Bering Sea, and southern coast of Alaska, and south to the Channel Islands off 

California. During the May-to-July breeding season, steller sea lions congregate at more that 40 

rookeries, where adult males defend territories, pups are born, and mating takes place. Nonreproductive animals congregate to rest at more than 200 haul-out sites where little or no 

breeding takes place. Sea lions continue to gather at both rookeries and haul-out sites outside of 

the breeding season. 
 

32

The world population of Steller sea lions includes two stocks divided at 144° W longitude (Cape 

Suckling, just east of Prince William Sound, Alaska). The stock differentiation is based 

primarily on differences in mitochondrial DNA, but also on differing population trends in the 

two regions. 

Steller sea lions are opportunistic predators, feeding primarily on a wide variety of fishes and 

cephalopods. Prey varies geographically and seasonally. Some of the more important prey 

species in Alaska include walleye pollock (Theragra chalcogramma), Atka mackerel 

(Pleurogrammus monopterygius), Pacific herring (Clupea harengus), Capelin (Mallotus 

villosus), Pacific sand lance (Ammodytes hexapterus), Pacific cod (Gadus macrocephalus), and 

salmon (Oncorhynchus spp.). Steller sea lions have been known to prey on harbor seal, fur seal, 

ringed seal, and possibly sea otter pups, but this would represent only a supplemental component 

to the diet. 

In Oregon, numbers have remained relatively stable since 1981 at about 2,000-3,000 animals. In 

California, numbers have declined, especially in the southern portion of range. Breeding 

colonies occur in Oregon and British Columbia but not in Washington (nonbreeding occurrences 

only). Breeding rookeries extend from the central Kuril Islands and the Okhotsk Sea in the west 

to Ano Nuevo Island and San Miguel Island, California, in the east, though the latter rookery is 

nearly or actually defunct; none have been seen on the Channel Islands since 1984. (From 

NatureServe, 2006). 

Factors suggested as potential causes for the declines of steller sea-lions in Alaska and Russia 

include reduced food availability, possibly resulting from competition with commercial fisheries, 

incidental take and intentional kills during commercial fish harvests, subsistence take, 

entanglement in marine debris, disease, pollution, and harassment. Steller sea-lions are also 

sensitive to intrusion at rookeries and haul-out sites. (From NatureServe, 2006). 

Assessment: The proposed action would have no effect on steller sea-lion prey. Ship strikes are 

not reported as a threat to the steller sea-lion and the slow movement of the barges (6-9 knots) 

would make a strike unlikely. 

Marine debris and pollution will be prevented by the measures included in the compliance 

agreements with waste management companies, including the frequent inspection of bales for 

breaks, training of waste management personnel in proper handling procedures, and labeling and 

identification of all bales. 

To avoid distubance of rookeries and collisions with steller sea-lions, APHIS will implement the 

following protection measures: 

Vessel operators will maintain a sharp lookout for Steller sea lions and other collision hazards. 

Operators are advised to post at least one person dedicated to lookout for sea lions on route to 

the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 
 

33C

Contact APHIS and NOAA's Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS. 

No barge will approach within three nautical miles of the Steller sea lion rookeries in Oregon 

(Rogue Reef: Pyramid Rock and Orford Reef: Long Brown Rock and Seal Rock) and California 

(Ano Nuevo Island, Southeast Farallon Island, Sugarloaf Island, and Cape Mendocino). 

With the implementation of these protection measures, APHIS has determined that the proposed 

barging of garbage from Hawaii to the mainland United States may affect, but is not likely to 

adversely affect the steller sea lion or its designated critical habitat. 

References:

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 12, 2006 ). 

United States Department of the Interior, 1990a. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; emergency listing of the steller sea lion. Federal Register, Vol. 

55, p.13488, April 10, 1990. 

United States Department of the Interior, 1990b. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; Listing of steller sea lions as threatened under Endangered 

Species act with Protective Regulations. Vol. 55, p. 12645-12662, April 5, 1990. 

Whales 

Humpback Whale, Megaptera novaeangliae 

Status: The humpback whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 

1970). 

Pertinent Species Information: The humpback whale is a mostly black or gray baleen whale 

with very long (up to one-third of body length) flippers that often are white or partly white. In 

front of the paired nostrils, the head is flat and covered with knobs. The rear edge of flippers and 

flukes is scalloped. The dorsal fin is variable, but often has a hump or step along the front edge. 

 The throat has about 14-35 longitudinal grooves. The baleen generally is all black, up to 70 cm 

long. The females reach 16 meters and males reach 15 meters. Its blow is bushy and V-shaped. 

It often raises its flukes high when starting a dive. (From NatureServe, 2006). 

It occurs in pelagic and coastal waters, sometimes frequenting inshore areas such as bays. It 

winters largely in tropical/subtropical waters near islands or coasts, and summers in temperate 

and subpolar waters. (From Nature Serve, 2006) 

It is primarily dependent upon schooling fishes and krill (essentially krill only in the Southern 

Hemisphere). It feeds singly or in groups. It feeds mainly in high latitudes, though stranded 

individuals in Virginia and Georgia had eaten sciaenid fishes. It may feed at the surface or while 

submerged. It employs various foraging methods, including cooperative feeding on prey 
 

34

enclosed in "nets" of exhaled air bubbles. (From NatureServe, 2006). 

The humpback whale was depleted by past overharvesting. Currently, it is vulnerable to marine 

pollution, disturbance by boat traffic, and entanglement in fishing gear. (From NatureServe, 

2006) 

According to scientists, the shallow, warm waters surrounding the main Hawaiian Islands 

constitute one of the world's most important habitats for the endangered humpback whale. 

Nearly two-thirds of the entire North Pacific population of humpback whales migrates to Hawaii 

each winter. Here, they engage in breeding, calving and nursing activities critical to the survival 

of their species. Most North Pacific humpback whales begin their annual migrations from the 

Gulf of Alaska in early fall. They move to three primary locations in the southern latitudes of 

the North Pacific. One group will travel to the coast of Baja in Mexico. Another will migrate to 

a group of islands south east of Japan. But the largest population (over 60%) will find 

themselves in the Hawaiian Islands, a distance of nearly 3500 miles from their feeding grounds 

in Alaska. This migration takes the humpback approximately 4 to 8 weeks to complete. The 

majority of the humpbacks that travel to Hawaii end up in the waters off of Maui. It is a "trickle 

migration with the juveniles usually arriving first, followed by the adult males, adult females, 

then the pregnant females. (From http://www.whalewatchmaui.com/migration.html Last 

accessed June 5, 2006.) 

The Hawaiian Islands Humpback Whale National Marine Sanctuary is comprised of five 

separate areas abutting six of the major islands of the State of Hawai`i. The five areas of the 

sanctuary cover relatively shallow offshore areas built up from the sea floor by the development 

of the Hawaiian Islands chain. (Sources. Hawaii topography: USGS DEM, Ocean bathymetry: 

ETOPO5, Humpback Whale NMS boundary: NOAA). From 

http://hawaiihumpbackwhale.noaa.gov/maps/maps.html Last accessed June 5, 2006. 

Assessment: Adverse impacts to the humpback whale could come from accidental whale/vessel 

collisions, displacement due to traffic or noise from vessel traffic, or from ingestion of or 

entanglement in marine debris. Direct collision or displacement conflicts are at a minimum due 

to the consistent and relatively slow speeds of barge traffic. (From 

http://www.earthtrust.org/wlcurric/whales.html Last accessed June 5, 2006.) 

Noise or visual disturbance will not likely occur since marine mammals have demonstrated little 

behavioral reaction to slow-moving vessels, according to surveys conducted (NMFS, 2006). The 

baled garbage will be inspected at multiple points in the transport process to ensure that bales are 

intact and garbage will not be released. 

The potential for collisions between the tug/barge and the humpback whale is very low due to 

the slow tow speed (6-9 knots). However, because the Hawaiian Islands are such an important 

habitat for the humpback whale, the following protection measures will be implemented: 

Within 200 nautical miles of the Hawaiian Islands, barges will not approach or cause an object to 

approach within 100 yards of any whale species. 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel

operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 
 

35

Operators are advised to post at least one person dedicated to lookout for whales from November 

through May, the peak period for humpback whales in Hawaiian waters. 

Tugs and barges will not travel above a speed of 12 knots. 

 

The barges will use appropriate VHF radio protocol or other means to alert other vessels of 

whales that may be in their path. 

Vessel operators will move out of the way of approaching whales. 

If possible, vessel operators will attend educational workshops held in Hawaii and sponsored by 

the State of Hawaii or NOAA Fisheries on whale etiquette. 

Vessel operators will call the NOAA Hotline if involved in a collision: (888) 256-9840 or hail 

the U.S. Coast Guard on VHF channel 16. This incident would also be reported to APHIS and 

NOAA’s Pacific Islands Regional Office. APHIS will re-initiate consultation with NMFS. 

With the implementation of these measures, APHIS has determined that the proposed action may 

affect, but is not likely to adversely affect the humpback whale. 

References: 

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes 

of marine mammals incidental to specified activities; movement of barges through the Beaufort 

Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, 

p34064, June 13, 2006. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

Blue Whale, Balaenoptera musculus 

Status: The blue whale was listed as endangered on June 7, 1970 (USDOI, FWS, 1970). 

Pertinent Species Information: The blue whale is a very large (the largest living animal) 

baleen whale; its body is mottled bluish gray. Its head is flat in front of the paired nostrils, broad 

and nearly U-shaped in dorsal view, with a single median ridge that extends forward from the 

raised area in front of the nostrils (the ridge does not quite reach the tip of snout). The dorsal fin, 

located in the last quarter of the back, is very small. The throat has 55-68 longitudinal grooves. 

Its belly may appear yellowish due to diatom accumulations. Its flippers are long and slim and 

its baleen is black. The potential maximum length of the blue whale is over 30 meters, with the 

largest females averaging slightly longer than the largest males. (From NatureServe, 2006). 

The blue whale mates May-September in the Northern Hemisphere. Gestation is reported as 11 
 

36

or 12 months. Adult females bear one calf every 2-3 years. Young are weaned in about 8 

months. Females reach sexual maturity in about 10 years. The maximum lifespan is uncertain; 

it is reportedly only about 20 years or up to 80-90 years. It is usually solitary or in pairs or 

threes, but may congregate in good feeding areas. It eats primarily krill. Feeding occurs 

primarily in high latitude waters. (From NatureServe, 2006). 

The blue whale occurs throughout the world's oceans. There are three major breeding groups: 

North Pacific, North Atlantic, and Antarctic; there is perhaps a separate breeding population in 

the Indian Ocean. It is seen with some regularity in deep coastal canyons off central and 

southern California, far inside the Gulf of St. Lawrence, and in the Denmark Strait. For all 

practical purposes the Northern Hemisphere and Southern Hemisphere stocks do not mix. (From 

Nature Serve, 2006) 

Most migrate to high latitude feeding areas for summer and return to lower latitude breeding 

areas for winter. For example, those that summer off Alaska winter off southern California and 

Baja California. There may be a basically resident or short distance migratory population off 

California and Baja California. Of individuals tagged off southern California, where apparently 

they were feeding or foraging, one moved to waters off northern California and four moved 

southward to Baja California, two passing Cabo San Lucas and one of these moving an 

additional 3000 km to near the Costa Rican Dome (an upwelling feature), which may be a 

calving/breeding area. Data on vocalizations support the idea that blue whales off North 

America and in the eastern tropical Pacific represent a single stock. Hydrophone recordings 

suggest possible winter and late summer migrations off Oahu (Hawaii). (From NatureServe, 

2006). 

The distribution of the blue whale in the western North Atlantic generally extends from the 

Arctic to at least mid-latitude waters. Blue whales are most frequently sighted in the waters off 

eastern Canada, with the majority of recent records from the Gulf of St. Lawrence. The blue 

whale is considered only an occasional visitor in the United States. Records have suggested an 

occurrence of this species south to Florida and the Gulf of Mexico, although the actual southern 

limit of the species’ range is unknown. (From 

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ). 

The Eastern North Pacific Stock feeds in California waters in summer/fall (from June to 

November) and migrates south to productive areas off Mexico and as far south at the Costa Rica 

Dome in winter/spring. Blue whales are occasionally seen or heard off Oregon, but sightings are 

rare. (From http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ). 

Blue whales are extremely rare in Hawaii. It is believed that the Hawaiian stock feeds off the 

Aleutian Islands in summer and winters in offshore waters north of the Hawaiian Islands. There 

is little published evidence of blue whale sightings in Hawaii, and most evidence comes from 

acoustic recordings made off Oahu and Midway Islands. The recordings made off Oahu showed 

bimodal peaks throughout the year, suggesting that the animals were migrating into the area in 

summer and winter. (From 

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ). 

Historically, the blue whale was over-harvested. Today the species may be negatively affected 
 

37

by food-chain alterations resulting from commercial fishing/whaling. There is concern among 

some biologists that underwater sound waves, such as those to be transmitted as part of the 

Acoustic Thermometry of Ocean Climate project, may detrimentally impact marine mammals; 

all agree that more information is needed on the impact of noise on marine mammals. 

(NatureServe, 2006). 

Blue whales are at least occasionally injured or killed by ship collisions. Several blue whales 

have been photographed in California with large gashes in their dorsal surface that appear to be 

from ship strikes. It is estimated that between 9-25% of the whales in the Gulf of St. Lawrence 

have injuries or scars attributed to contact with ships. The St. Lawrence Seaway has heavy ship 

traffic during the time of year when blue whales are relatively abundant there. (From 

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/blue_whale.doc ). 

 

Assessment: This species may be harassed by the noise generated by the tug boats, by physical 

disturbance from visual or other cues, and collisions with the tug/barge. The potential for 

collisions between the tug/barge and the blue whale is very low due to the slow tow speed (6-9 

knots). Noise or visual disturbance will not likely occur since marine mammals have 

demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted 

(NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to 

ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined 

that the proposed action may affect, but is not likely to adversely affect the blue whale. 

However, APHIS will implement the following protection measures: 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel

operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 

Operators are advised to post at least one person dedicated to lookout for whales while on route 

to the mouth of the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS.

References: 

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 7, 2006 ). 

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes 

of marine mammals incidental to specified activities; movement of barges through the Beaufort 

Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, 

p34064, June 13, 2006. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 
 

38

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

Fin Whale, Balaenoptera physalus 

Status: The fin whale was listed as endangered on June 2, 1970 (USDOI, FWS, 1970). 

Pertinent Species Information: The fin whale is a large dark gray to brownish black baleen 

whale. It has a narrow V-shaped rostrum with a prominent median ridge. The dorsal fin is 

angled strongly rearward, and is located about one-third the body length forward from the fluke 

notch. The throat has numerous longitudinal grooves. Many individuals have a whitish chevron 

on each side of the back above the flippers. The right lower lip and right front baleen are 

whitish. The left lower lip is dark and the remainder of baleen is streaked with yellowish white 

and bluish gray. The flippers are fairly long and narrow. The baleen is up to 72 cm long. It 

grows to about 26.8 meters, with females reaching larger sizes than males. It mates in winter. 

Gestation lasts 11-12 months. Adult females bear 1 young every 2-3 years. Young are weaned 

at 6-8 months. It is sexually mature at a minimum age of about 5-6 years in the western Atlantic. 

 The life span may be 40-100 years. (From NatureServe, 2006) 

In the North Pacific, the fin whale eats fishes, krill, calanoid copepods, and squid. In the North 

Atlantic, its primary foods are fishes (e.g., capelin, herring, sand launce), krill, and calanoid 

copepods. In the Southern ocean, its main diet is krill. In the Gulf of California, it eats 

euphausiids in winter and spring. Newly weaned young eat crustaceans. Fine fringing on the 

baleen of young facilitates capture of copepods. (From NatureServe, 2006) 

The fin whale is widespread in the Atlantic, Pacific, Indian, and Southern oceans. Populations 

were greatly reduced by historical commercial whaling; approximately 102,000-122,000 remain 

from pre-exploitation levels of over 450,000. It is threatened by general deterioration of the 

marine ecosystem. Most populations apparently have increased little if at all since commercial 

harvest was ended in the 1970s. The population off the coast of the eastern United States may be 

increasing. However, a ten-year survey (published in 1989) of prime Antarctic waters yielded 

far fewer numbers than expected, raising concern. (From NatureServe, 2006) 

The fin whale occurs worldwide in temperate and polar waters in several distinct breeding 

stocks. In the western North Atlantic, it summers north to arctic Canada and Greenland, and 

winters south to Gulf of Mexico and Caribbean region. In the eastern North Pacific, it summers 

north to the Chukchi Sea, and winters north to California (From NatureServe, 2006) 

Populations of fin whales in all oceans were greatly reduced by historical commercial whaling. 

They are also threatened by heavy metal pollution from dumped waste in the Mediterranean. 

Human exploitation of euphausiids in the southern ocean is a potential threat. (From 

NatureServe, 2006) 

Assessment: This species may be harassed by the noise generated by the tug boats, by physical 

disturbance from visual or other cues, and collisions with the tug/barge. The potential for 

collisions between the tug/barge and the fin whale is very low due to the slow tow speed (6-9 
 

39

knots). Noise or visual disturbance will not likely occur since marine mammals have 

demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted 

(NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to 

ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined 

that the proposed action may affect, but is not likely to adversely affect the fin whale. 

However, APHIS will implement the following protection measures: 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel

operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 

Operators are advised to post at least one person dedicated to lookout for whales while on route 

to the mouth of the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS. 

References: 

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 7, 2006 ). 

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes 

of marine mammals incidental to specified activities; movement of barges through the Beaufort 

Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, 

p34064, June 13, 2006. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

Sei Whale, Balaenoptera borealis

Status: The sei whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 1970). 

Pertinent Species Information: The sei whale is a large dark gray baleen whale often with 

ovoid grayish-white scars. The front edge of its prominent dorsal fin is angled upward more than 

40 degrees from the back. The tip of the snout is turned slightly downward. There are many 

longitudinal grooves on throat. The flippers are pointed and relatively small. The tail fluke is 

relatively small. The baleen is uniformly ash-black with fine white fringes. The sei whale grows 

to 18.6 meters in the northern hemisphere and 21 meters in the southern hemisphere, with 
 

40

females reaching the largest sizes (largest males average a couple meters shorter than the largest 

females). (From NatureServe, 2006) 

A single calf is born usually in winter after a gestation period of about 11-12 months. The young 

nurse for about 5-9 months. The calving interval for individual adult females is 2-3 years. They 

are sexually mature at an average age of 6-10 years. They usually travel in groups of 2-5, but 

may concentrate in larger numbers on feeding grounds. The sei whale eats copepods, 

euphausiids, squid, and various small schooling fishes. It may skim feed on copepods at the 

surface or gulp feed on krill and small fishes (From NatureServe, 2006) 

The sei whale occurs worldwide, but its distribution and movements during much of year are 

poorly known. It is found from the Coast of Mexico to the Gulf of Alaska in the eastern North 

Pacific. It is found in the Bering Sea to Japan and Korea in the western North Pacific. It is 

found in the Gulf of Mexico to Davis Strait (especially off eastern Canada) in the western North 

Atlantic. It occurs from Norway to Spain and northwestern Africa in the eastern North Atlantic. 

 In the Southern Hemisphere, it occurs from the Antarctic Ocean to the coasts of Brazil, Chile, 

South Africa, and Australia. (From NatureServe, 2006) 

The total population of sei whales is estimated at less than 51,000: about 14,000 in the Northern 

Hemisphere (mainly in the North Pacific), 37,000 or less in the Southern Hemisphere. A survey 

of Antarctic waters in the summer of 1989 found only 1,500 in an area where perhaps 10,000 

were expected. The North Atlantic population numbers a few thousand. Populations in all 

oceans have been depleted by overexploitation. (From NatureServe, 2006) 

Twelve aerial surveys were made within 25 nautical miles of the main Hawaiian Islands in 1993-

98 (Mobley et al., 1998) but no sightings of sei whales were made. A 2002 shipboard linetransect survey of the entire Hawaiian Islands Exclusive Economic Zone resulted in a 

summer/fall abundance estimate of 77 sei whales (Barlow, 2003). No data are available on the 

current population trend. Although whales can get tangled in longline fishing gear, between 

1994 and 2002, no interactions with sei whales were observed in the Hawaii-based longline 

fishery. (From National Marine Fisheries Service Stock Assessment Report for Hawaiian Stock 

of Sei Whale http://www.nmfs.noaa.gov/pr/pdfs/sars/po04seiwhalehawaii.pdf last accessed June 

8, 2006). 

Only 2 confirmed sightings of sei whales and 5 possible sightings were made in California, 

Oregon, and Washington waters during extensive ship and aerial surveys in 1991-93, 1996, and 

2001 (Hill and Barlow, 1992; Carretta and Forney, 1993; Mangels and Gerrodette, 1994; Von 

Saunder and Barlow, 1999; Barlow, 2003). Green et al. (1992) did not report any sightings of 

sei whales in aerial surveys of Oregon and Washington. The abundance estimate for California, 

Oregon, and Washington waters out to 300 nautical miles is 56 sei whales (Barlow, 2003). 

(From National Marine Fisheries Service Stock Assessment Report for Eastern North Pacific 

Stock of Sei Whale http://www.nmfs.noaa.gov/pr/pdfs/sars/po2003seiwhale_en.pdf last 

accessed June 8, 2006). 

Assessment: Sei whales are very rare within the proposed action area. However, this species 

may be harassed by the noise generated by the tug boats, by physical disturbance from visual or 
 

41

other cues, and collisions with the tug/barge. The potential for collisions between the tug/barge 

and the sei whale is very low due to the slow tow speed (6-9 knots). Noise or visual disturbance 

will not likely occur since marine mammals have demonstrated little behavioral reaction to slowmoving vessels, according to surveys conducted (NMFS, 2006). The baled garbage will be 

inspected at multiple points in the transport process to ensure that bales are intact and garbage 

will not be released. Therefore, APHIS has determined that the proposed action may affect, but 

is not likely to adversely affect the sei whale. 

However, APHIS will implement the following protection measures: 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel

operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 

Operators are advised to post at least one person dedicated to lookout for whales while on route 

to the mouth of the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS. 

References: 

Barlow, J. 2003. Cetacean abundance in Hawaiian waters during summer/fall 2002. Admin. 

Rep. LJ-03-13. Southwest Fisheries Science Center, National Marine Fisheries Service, 8604 

La Jolla Shores Drive, La Jolla, CA 92038. 

Caretta, J.V. and K.A. Forney. 1993. Report on two aerial surveys for marine mammals in 

California coastal waters utilizing a NOAA DeHavilland Twin Otter Aircraft: March 9-April 7, 

1991 and February 8-April 6, 1992. U.S. Department of Commerce. NOAA Technical Memo. 

NMFS-SWFSC-185. 77 pp. 

Green, G.A., J.J. Brueggeman, R.A. Grotefendt, C.E. Bowlby, M.L. Bonnell, K.C. Balcomb, III. 

 1992. Cetacean distribution and abundance off Oregon and Washington, 1989-1990. Chapter 1 

In: J.J. Brueggeman (ed.). Oregon and Washington rine Mammal and Seabird Surveys. 

Minerals Management Service Contract Report 14-12-0001-30426. 

Hill, P.S. and J. Barlow. 1992. Report of a marine mammal survey of the California coast 

aboard the research vessel McARTHUR July 28-November 5, 1991. U.S. Department of 

Commerce. NOAA Technical Memo. NMFS-SWFSC-169. 103 pp. 

Mangels, K.F. and T. Gerrodette. Report of cetacean sightings during a marine mammal survey 

in the eastern Pacific Ocean and the Gulf of California aboard NOAA ships McArthur and 

David Starr Jordan July 28-November 6, 1993. U.S. Department of Commerce. NOAA 

Technical Memo. NMFS-SWFSC-221. 88 pp. 
 

42

Mobley Jr., J.R., S.S. Spitz, K.A. Forney, R.A. Grotefendt, and P.H. Forestall. 2000. 

Distribution and abundance of odontocete species in Hawaiian waters: preliminary results of 

1993-98 aerial surveys. Admin. Rep. LJ-00-14C. Southwest Fisheries Science Center, National 

Marine Fisheries Service, P.O. Box 271, La Jolla, CA 92038. 26 pp. 

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 8, 2006 ). 

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes 

of marine mammals incidental to specified activities; movement of barges through the Beaufort 

Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, 

p34064, June 13, 2006. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

Von Saunder A., and J. Barlow. 1999. A report of the Oregon, California and Washington Linetransect Experiment (ORCAWALE) conducted in west coast waters during summer/fall 1996. 

U.S. Department of Commerce. NOAA Technical Memo. NMFS-SWFSC-264. 40 pp. 

Sperm Whale, Physeter catodon (=macrocephalus) 

Status: The sperm whale was first listed as endangered on June 2, 1970 (USDOI, FWS, 1970). 

Pertinent Species Information: The sperm whale is found throughout the world's oceans; adult 

females and young generally stay between 40 degrees N and 40 degrees S latitude. Nonbreeding 

males range into high latitude waters. Northern and southern hemisphere populations apparently 

are reproductively isolated from each other. It is pelagic, and prefers deep water, but is 

sometimes found around islands or in shallow shelf waters (e.g., 40-70 meters). (From 

NatureServe, 2006) 

Sperm whale gestation lasts 14-15 months. Births occur May-September in the Northern 

Hemisphere and November-March in the Southern Hemisphere. A single young is produced 

every 3-6 years. Young are weaned in about 1.5-3.5 years, though young may continue to nurse 

for several years. Females sexually mature at 7-11 years; pregnancy rate gradually declines after 

age 14. Males may not breed until about 25 years old. Sperm whales may live up to at least 60-

70 years. (From NatureServe, 2006) 

The sperm whale eats primarily large squids, and sometimes also octopus and various fishes. It 

dives deeply when foraging; some dives over 1800 meters have been recorded, but most are less 

than 500 meters. It apparently feeds throughout the year. (From NatureServe, 2006) 

The basic social unit of the sperm whale is a mixed school of adult females plus their calves and 

juveniles (usually about 20-40 individuals). As males grow older they leave this group and form 

bachelor schools (of variable sizes up to about 50 individuals). The largest males tend to be 

solitary. (From NatureServe, 2006) 
 

43

The Hawaiian Islands marked the center of a major nineteenth century whaling ground for sperm 

whales. Since 1936, at least five strandings have been reported from Oahu, Kauai and Kure 

Atoll. Sperm whales have also been sighted around several of the Northwestern Hawaiian 

Islands, off the main island of Hawaii, in the Kauai Channel and in the Alenuihaha Channel 

between Maui and the island of Hawaii. In addition, the sounds of sperm whales have been 

recorded throughout the year off Oahu. (From National Marine Fisheries Service Stock 

Assessment Report for Hawaiian Stock of Sperm Whale 

http://72.14.203.104/search?q=cache:r7VnMELgVVEJ:www.nmfs.noaa.gov/pr/PR2/Stock_Asse

ssment_Program/Cetaceans/Sperm_Whale_(Hawaii)/POD00spermwhale_hawaii.pdf+sperm+wh

ale+hawaii&hl=en&gl=us&ct=clnk&cd=1 last accessed June 9, 2006). 

The best estimate for sperm whales occurring in U.S. waters of Hawaii is 66. This abundance 

underestimates the total number of sperm whales off Hawaii because areas around the Northwest 

Hawaiian Islands and beyond 25 nautical miles from the main islands were not surveyed when 

compiling this estimate. (From NOAA Fisheries, Office of Protected Resources, 

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/spermwhales.htm last accessed June 

12, 2006.) 

The most recent abundance estimate of the California-Oregon-Washington Stock for the period 

between 1996 and 2001 is 1,233 sperm whales. Sperm whale abundance appears to have been 

rather variable off California between 1979/1980 and 1996, but does not show any obvious 

trends. (From NOAA Fisheries, Office of Protected Resources, 

http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/spermwhales.htm last accessed June 

12, 2006.) 

Historically, the sperm whale was hunted for spermaceti, ambergris, and oil. It is no longer 

threatened by direct catching, but entanglement in fishing gear may cause mortality in some 

areas. It is potentially threatened by ocean pollution and ingestion of plastics. (From 

NatureServe, 2006) 

Assessment: This species may be harassed by the noise generated by the tug boats, by physical 

disturbance from visual or other cues, and collisions with the tug/barge. The potential for 

collisions between the tug/barge and the sperm whale is very low due to the slow tow speed (6-9 

knots). Noise or visual disturbance will not likely occur since marine mammals have 

demonstrated little behavioral reaction to slow-moving vessels, according to surveys conducted 

(NMFS, 2006). The baled garbage will be inspected at multiple points in the transport process to 

ensure that bales are intact and garbage will not be released. Therefore, APHIS has determined 

that the proposed action may affect, but is not likely to adversely affect the sperm whale. 

However, APHIS will implement the following protection measures: 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. Vessel

operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 

Operators are advised to post at least one person dedicated to lookout for whales while on route 
 

44

to the mouth of the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 

Vessel operators will contact APHIS and NOAA’s Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS. 

References: 

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 9, 2006 ). 

United States Department of Commerce. 2006. National Marine Fisheries Service. Small takes 

of marine mammals incidental to specified activities; movement of barges through the Beaufort 

Sea between West Dock and Cape Simpson or Point Lonely, Alaska. Federal Register, Vol. 71, 

p34064, June 13, 2006. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

Killer Whale, Southern Resident Distinct Population Segment, Orcinus orca 

Status: The southern resident killer whale was listed as endangered on November 18, 2005 

(DOC, NOAA, 2005). Critical habitat was designated on November 29, 2006 (DOC, NOAA, 

2006). 

Pertinent Species Information: Killer whales are members of the family Delphinidae, which 

includes approximately 20 genera of marine dolphins. They are the world’s largest dolphin. 

Killer whales are black dorsally and white ventrally, with a conspicuous white oval patch located 

slightly above and behind the eye. A highly variable gray or white saddle is usually present 

behind the dorsal fin. Sexual dimorphism occurs in body size, flipper size, and height of the 

dorsal fin (DOC, NOAA, 2005). 

Killer whales occur in all oceans, but it is most common in coastal waters and at higher latitudes, 

with fewer sightings from tropical regions (NMFS, 2005). In the North Pacific, killer whales 

occur in waters off Alaska, including the Aleutian Islands and Bering Sea, and range southward 

along the North American coast and continental slope (NMFS, 2005). Killer whales occur 

broadly in the world’s other oceans, with the exception of the Arctic Ocean (NMFS, 2005). 

They are highly social animals that occur primarily in pods of up to 50 animals. Vocal 

communication is an essential element of the species’ complex social structure. They produce 

numerous types of vocalizations that are useful in navigation, communication and foraging. 

There are three categories of sounds: echolocation clicks, tonal whistles and pulsed calls. Killer 

whales hear sounds through the lower jaw and other portions of the head, which transmit the 

sound signals to receptors in the middle and inner ears. 
 

45

Killer whales swim at speeds of 5-10 kilometers per hour, but can attain speeds of 40 kilometers 

per hour. While in the inshore waters of southern British Columbia and Washington, the 

southern residents spend 95% of their time underwater, nearly all of which is between the 

surface and a depth of 30 meters. As top-level predators, they feed on a variety of organisms 

ranging from fish to squid to other marine mammal species. Cooperative hunting, food sharing, 

and innovative learning are notable foraging traits in killer whales. (From NMFS, 2005) 

Three distinct forms of killer whales, termed as residents, transients, and offshores, are 

recognized in the northeastern Pacific Ocean. There is considerable overlap in their ranges, but 

the populations display significant genetic differences due to a lack of interchange of member 

animals. The southern resident population consists of three pods that reside for part of the year 

in the inland waterways of Washington State and British Columbia (Strait of Georgia, Strait of 

San Juan de Fuca, and Puget Sound), mainly during the late spring, summer and fall. Pods have 

visited coastal sites of Washington and Vancouver Island and are known to travel as far south as 

central California and as far north as the Queen Charlotte Islands. Winter and early spring 

movements and distribution are largely unknown for the population. Although there is 

considerable overlap between the ranges of northern and southern residents, pods from the two 

populations have not been observed to intermix. (From NMFS, 2005) 

Threats to the killer whale include reduced prey availability, environmental contaminants, vessel 

effects and sound, oil spills, disease, and chronic effects from multiple stressors (NMFS, 2005) 

Assessment: This species may be harassed by the noise generated by the tug boats, by physical 

disturbance from visual or other cues, and collisions with the tug/barge. The potential for 

collisions between the tug/barge and the southern resident killer whale is very low due to the 

slow tow speed (6-9 knots). Vessel strikes are rare, but do occur and can result in injury, such as 

in the collision of a southern resident whale with a vessel in the San Juan Islands in July 2005 

(NMFS, 2005). 

The National Oceanic and Atmospheric administration (NOAA) has little information about the 

effects of vessel activity on killer whales (DOC, NOAA, 2006). Whale watching vessels are of 

particular concern. Vessel traffic may have contributed to the decline of the Southern Resident 

killer whale population through collisions (rare), chemicals such as unburned fuel and exhaust, 

masking echolocation signals, and disruption of feeding activity resulting in increased energy 

expenditure and reduced energy acquisition (Bain et al., 2006). However, NOAA is uncertain 

about the extent to which these effects interfere with the survival and recovery of the Southern 

Residents but studies have linked vessels with short-term behavioral changes in these animals 

(DOC, NOAA, 2006). Although there can be occurrence of these whales as far south as central 

California, the area where the barges will travel is south of the spring, summer, and fall range of 

the Southern Resident. Thus, there is a low likelihood that barges will interact with Southern 

Resident killer whales. Therefore, APHIS has determined that the proposed action is not likely 

to adversely affect the southern resident killer whale. In addition, the proposed action will not 

adversely modify proposed critical habitat since the mouth of the Columbia River is south of this 

area and barges will not enter the area where the habitat has been designated. 

However, APHIS will implement the following protection measures: 

Vessel operators will maintain a sharp lookout for whales and other collision hazards. 
 

46

Vessel operators will also look ahead for “blows” (puffs or mists), dorsal fins, tails, etc. 

Operators are advised to post at least one person dedicated to lookout for killer whales on route 

to the Columbia River. 

Tugs and barges will not travel above a speed of 12 knots. 

Contact APHIS and NOAA’s Northwest Regional Office if involved in a 

collision: (206) 526-6733. APHIS will re-initiate consultation with NMFS. 

References: 

Bain, D.E., J.C. Smith, R. Williams, and D. Lusseau. 2006. Effects of vessels on behavior of 

southern resident killer whales (Orcinus sp.). NMFS Contract Report No. AB133F03SE0959 

and AB133F04CN0040. 61 pp. 

Department of Commerce, National Oceanic and Atmospheric Administration. 2005. 

Endangered and threatened wildlife and plants; Endangered status for Southern Resident killer 

whales. Vol. 70, p. 69903-69912, November 18, 2005. 

Department of Commerce, National Oceanic and Atmospheric Administration. 2006. 

Endangered and threatened species; Designation of critical habitat for the Southern Resident 

killer whale. Vol. 71, p. 69054-69070, November 29, 2006. 

National Marine Fisheries Service. 2005. Proposed Conservation Plan for Southern Resident 

Killer Whales (Orcinus orca). National Marine Fisheries Service, Northwest Region, Seattle 

Washington. 183 pp. 

Sea turtles 

The following five sea turtles are all marine organisms, except when nesting on beaches. The 

potential impacts due to program activities are the same for all five species. For this reason, the 

assessment for the green sea turtle, the hawksbill sea turtle, the Olive Ridley sea turtle, the 

leatherback sea turtle, and the loggerhead sea turtle has been combined and follows the species 

accounts of the five sea turtles. 

Green Sea Turtle, Chelonia mydas 

Status: The green sea turtle was listed as endangered on July 28, 1978, (USDOI, FWS, 1978). 

Pertinent Species Information: The green sea turtle has a brown carapace, often with radiating 

mottled or wavy dark markings or large dark brown blotches. There are 4 costal plates on each 

side of carapace. There is one pair of prefrontal plates between the eyes. Its limbs are flattened 

flippers. The young are black to dark brown above, mainly white below, with a middorsal keel 

and two plastral keels. They are 4-6 cm at hatching. The adult carapace length usually is 90-122 

centimeters (cm) (to 153 cm) and mass is 113-204 kilograms (kg) (to 295+ kg). (From 

NatureServe, 2006). 

Green sea turtles spend most of their lives feeding on sea grasses and algae along the Continental 
 

47

Shelf. They migrate long distances and return to the same beaches at intervals of 2 to 4 years to 

nest. Nesting beaches need to be relatively undisturbed by humans and predators, and they must 

have stable temperatures and moisture for the incubation period. 

Turtles in the northern Gulf of California overwinter in a dormant condition. In Hawaii, green 

sea turtles may bask on beaches mid-morning to mid-afternoon, especially after period of rainy 

weather (NatureServe, 2006). 

The green sea turtle lays 1-8 clutches, averaging about 90-140 eggs, at about two-week intervals, 

usually every 2-4 years. It nests generally at night. It nests March-October in Caribbean-Gulf of 

Mexico region, with peak May-June. In Florida, it nests in May-September. It nests AprilOctober, with a peak between mid-June and early August, in Hawaii. Eggs hatch usually in 1.5-

3 months. Hatchlings emerge between early July and late December (peak mid-August to early 

October) in Hawaii. Females mature probably at an average age of 27 years in Florida, but 

growth rates and hence age of maturity may vary greatly throughout the range (slower growth in 

Australia, Hawaii, and Galapagos than in Florida and West Indies region). (From NatureServe, 

2006) 

The threats to the green sea turtle include development of beaches, hunting for their meat, 

poaching of the eggs, and drowning as a result of being caught in shrimp nets. The State of 

Florida is working to preserve the nesting areas, and the National Marine Fisheries Service has 

regulations (50 CFR Part 227) requiring the use of turtle excluder devices (TED's) on larger 

shrimp boats in both the Atlantic and the Gulf of Mexico (World Wildlife Fund, 1990). 

Hawksbill Sea Turtle, Eretmochelys imbricata 

Status: The hawksbill sea turtle was listed as endangered on June 2, 1970 (USDOI, FWS, 

1970). Critical habitat has been designated in Puerto Rico (50 CFR 17.95(c) and 226.71). 

Pertinent Species Information: The hawksbill is one of the smaller of the sea turtles. Mature 

turtles grow to a length of 2 feet and weigh 100 pounds. The name “hawksbill” is derived from 

the turtle’s prominent hooked beak. 

The hawksbill sea turtle is primarily carnivorous feeding on jellyfish, sponges, and other 

sedentary organisms near coral reefs. The species does not migrate and occupies a small range. 

In tropical waters, the turtle breeds year-round, and the species tends to nest alone. The female 

will scoop out a nest in an isolated, undisturbed, sandy beach area and deposit about 160 eggs, 

which incubate in about 50 days. 

Global protection needs include: A ban on international commercial trade of shells, protection of 

nesting beaches and adjacent land and waters from human disturbance, and a requirement of 

year-round use of turtle excluder devices (NatureServe, 2006). 

Currently found throughout the world in tropical seas, the hawksbill sea turtle represents two 

distinct subspecies in the Atlantic and Indo-Pacific. No population estimates exist. The 

hawksbill is pelagic and spends most of its time in the open ocean (World Wildlife Fund, 1990). 

 The hawksbill is virtually unknown along coastal waters of the U.S. Pacific continental coast 

(NMFS and USFWS, 1998). 
 

48

In Hawaii, there are numerous protected areas for the hawksbill turtle throughout the islands. 

Kure Atoll at the northwest end of the chain is a wildlife refuge and potentially important to 

nesting and foraging sea turtles. The northwest atolls and islands between Pearl and Hermes to 

the northwest and Kaula to the southeast are part of the Hawaiian National Wildlife Refuge 

complex. The state of Hawaii administers a system of state parks and Marine Life Conservation 

Districts throughout the main islands, and one coastal natural preserve on Maui. The Hawaii 

Volcanoes National Park includes coastal areas on the southeast coasts of Hawaii and Maui 

islands. Honaunau and Pu’u Kohola are also national parks with coastal areas along the coast of 

Hawaii Island. All of these areas afford protection for foraging and nesting sea turtles in Hawaii. 

(From NMFS and USFWS, 1998). 

Olive Ridley Sea Turtle, Lepidochelys oliveacea

Status: The olive ridley sea turtle was listed as endangered in the breeding colony populations 

on Pacific coast of Mexico and threatened wherever found other than where listed as endangered 

on July 28, 1978, (USDOI, FWS, 1978). 

Pertinent Species Information: (From NOAA Fisheries, National Marine Fisheries Service, 

Office of Protected Resources, Olive ridley turtle species account. < 

http://www.nmfs.noaa.gov/prot_res/species/turtles/olive.html> last accessed June 6, 2006.) 

The olive ridley is a small, hard-shelled marine turtle, one of the two species of the genus 

Lepidochelys, and a member of the family Cheloniidae. The species may be identified by the 

uniquely high and variable numbers of vertebral and costal scutes. Although some individuals 

have only five pairs of costals (the number shown by almost all individuals of the congener 

Lepidochelys kempii), in nearly all cases some division of costal scutes occurs, so that as many 

as six to nine pairs may be present. They are primarily carnivorous, eating jellyfish, shellfish, 

and other marine animals. Algae may also be an important dietary component. 

The most dramatic aspect of the life history of the olive ridley is the habit of forming great 

nesting aggregations, generally known as “arribadas.” Although not every adult olive ridley 

participates in these arribadas, the vast majority of them do. Formerly these nesting 

concentrations occurred at several beaches along the Pacific coast of Mexico, including Piedra 

del Tlacoyunque, Bahia Chacahua, and El Playon de Mismaloya, but in recent years the Mexican 

arribadas have been largely restricted to La Escobilla, although smaller nesting concentrations 

have been reported from Morro Ayuta. In Costa Rica, a major nesting aggregation is found at 

Ostional, on the Nicoya Peninsula, and smaller arribadas occur at Nancite, in the Santa Rosa 

National Park. Smaller arribadas also occur in Nicaragua at La Flor and Chacocente and at 

several localities in Panama. In the Indian Ocean, four arribada sites have been reported in the 

Indian State of Orissa, the most important being Gahirmatha Beach. In the Atlantic, only small 

arribadas, numbering at most a few hundred animals per night, have been reported from a single 

locality. 

Individual olive ridleys may nest one, two or three times per season, typically producing 100-110 

eggs on each occasion. The internesting interval is variable, but for most localities it is 

approximately 14 days for solitary nesters and 28 days for arribada nesters. The genus is also 

unique in that ridleys of both species commonly, and probably typically, nest each year, without 

intervening non-breeding seasons as shown by dermochelyids and other cheloniids. The ridleys 
 

49

nesting in an arribada could not be sustained by the productivity of immediately adjacent marine 

ecosystems, and the species is indeed migratory. Recent investigations show that olive ridleys 

reside in oceanic habitats of the eastern Pacific Ocean during the non-reproductive portion of its 

life cycle. 

Despite its abundance, there are surprisingly few data relating to the feeding habits of the olive 

ridley. However, those reports that do exist suggest that the diet in the western Atlantic and 

eastern Pacific includes crabs, shrimp, rock lobsters, jellyfish, and tunicates. In some parts of the 

world, it has been reported that the principal food is algae. 

The range of the olive ridley is essentially tropical. In the eastern Pacific nesting takes place 

from southern Sonora, Mexico, south at least to Colombia. Non-nesting individuals occasionally 

are found in waters of the southwestern United States. They occur abundantly in Pacific 

Colombia and Ecuador, but only in small numbers in Peru and Chile. 

The olive ridley has been recorded occasionally from Galapagos waters, but it is essentially very 

rare throughout the islands of the Pacific, and indeed even in the western Pacific it is scarce 

everywhere, although widespread low-density nesting occurs. In the Indian Ocean it only 

achieves abundance in eastern India and Sri Lanka, although minor nesting occurs alongside the 

green turtles at Hawke's Bay, Pakistan, and some nesting also occurs in New Britain, 

Mozambique, Madagascar, peninsular Malaysia, and various other localities. 

Washington State has only a single olive ridley record, a turtle that was found dead in Grays 

Harbor County. Oregon has two records. They are rarely found in waters north of southern 

California. (Richardson, 1997) In Hawaii, olive ridley turtles are rarely seen; nesting has only 

been recorded once, on Maui in 1985. 

In the Atlantic Ocean, the olive ridley occurs widely, but probably not in great abundance, in 

waters of West Africa, from about Mauritania southward at least to the Congo. In the western 

Atlantic, nesting formerly occurred abundantly in eastern Surinam, as well as in western French 

Guiana and northwestern Guyana. Non-nesting individuals occur regularly as far west as Isla 

Margarita and Trinidad, but they rarely penetrate any further into the Caribbean than this. The 

species occurs in Brazil, and nests in the states of Bahia and Sergipe, but it seems to be rare. 

Because of the continued existence of several large arribadas, it is probable that the olive ridley 

is, in terms of absolute numbers of adult individuals in existence, the most abundant sea turtle 

species in the world. Nevertheless, there is evidence of downward trends at several arribada 

beaches. The various populations are under considerable stress, and the concentration of such a 

large proportion of the reproductive animals into a few arribadas may be a liability, not only in 

that such aggregation facilitates industrial-scale exploitation, as it has in Mexico as well as on 

the feeding grounds in Ecuador, but also because arribadas do not seem to be an efficient method 

of guaranteeing maximum reproductive efficiency. Indeed, at the relatively undisturbed arribada 

beach of Nancite, within Santa Rosa National Park, Costa Rica, it has been estimated that only 

about 5% of eggs laid actually produce hatchlings. 

The number of ridleys nesting during an arribada is difficult to count, although methodologies to 

estimate arribada size have been developed that are useful if nesting is well supervised by 
 

50

competent biologists. On the other hand, estimates by laymen of numbers of turtles in a given 

arribada are probably so inaccurate as to be useless. Because nesting in successive years is 

commonplace for olive ridleys, and may well be the norm for the species, the erratic nesting 

population trend lines often shown by loggerhead or green turtle populations, that very rarely 

nest in successive years, are not shown by olive ridley populations. It is thus much easier and 

more justified to draw conclusions about overall ridley population trends from a few years of 

comprehensive nest counts than it is for those species with multi-year nesting cycles. 

Threats include: pesticides, heavy metals and PCB's, oil spills, consumption of marine debris 

such as plastic bags, plastic and styrofoam pieces, tar balls, balloons and raw plastic pellets, and 

in areas where recreational boating and ship traffic is intense, propeller and collision injuries are 

not uncommon. 

Leatherback Sea Turtle, Dermochelys coriacea 

Status: The leatherback sea turtle was listed as endangered on June 2, 1970 (USDOI, FWS, 

1970). Critical habitat has been designated in the Virgin Islands (50 CFR 17.95(c) and 226.71). 

Pertinent Species Information: The leatherback sea turtle is the largest sea turtle in the world 

and is known to migrate great distances. It spends most of its adult life in the open ocean, 

entering shallow waters only at breeding time. It eats twice its body weight of jellyfish each day 

with supplements of soft-bodied creatures. The turtles grow as large as nine feet (2.7 meters) 

long, six feet (1.8 meters) wide and weigh over 1,000 pounds (454 kilograms). Leatherback 

turtles are covered in a namesake rubbery shell and can dive 4,922 feet (1,500 meters) deep in 

search of soft-bodied prey like jellyfish. 

Leatherback turtles roam tropical and sub-tropical waters of the Pacific, Atlantic, and Indian 

Oceans. They are found as far north as the British Isles to as far south as Australia. 

The United States nesting beaches include barrier islands in south central Florida from Vero 

Beach to Boca Raton. The other nesting area is on St. Croix in the U.S. Virgin Islands. Nesting 

begins in March and continues until July. The females come ashore at night and lay about 35 

eggs. The eggs incubate approximately 60 days before hatching. 

Leatherbacks are commonly seen by fishermen in Hawaiian offshore waters, generally beyond 

the 100-fathom curve but within sight of land. Sightings often take place off the north coast of 

Oahu and the Kona coast of Hawaii. North of the Hawaiian Islands, a high seas aggregation of 

leatherbacks is known to occur at 35°-45°N, 175°-180°W. 

The major threat is egg collecting. It is jeopardized to some extent by destruction/degradation of 

nesting habitat. In Malaysia, a major decline was attributed primarily to mortalities associated 

with high seas fisheries and to a long history of egg exploitation. Mortality associated with the 

swordfish gillnet fisheries in Peru and Chile represents the single largest source of mortality for 

East Pacific leatherbacks. Many eggs are lost to beach erosion in some areas; short-term erosion 

and accretion cycles along a nesting beach in the Virgin Islands resulted in an annual loss of 40-

60% of the nests, though nest relocations recently have reduced this loss. Nesting females are 

slaughtered in some areas (e.g., Guyana, Trinidad, Colombia, Pacific coast of Mexico). Ingestion 

of plastics could be an important mortality factor. Collisions with boats and entanglement in 

fishing gear (especially offshore driftnets) result in some mortality, as does the ingestion of 

plastic refuse in the ocean. Pollution of ocean waters may pose problems. Beach development 
 

51

and illumination may make beaches unsuitable for successful reproduction. Other threats include 

beach erosion, beach armoring, beach nourishment, artificial lighting, beach cleaning, increased 

human presence, recreational beach equipment, exotic dune and beach vegetation, nest loss to 

abiotic factors, predation, and poaching. (From NatureServe, 2006). 

Loggerhead Sea Turtle, Caretta caretta 

Status: The loggerhead sea turtle was listed as threatened on July 28, 1978 (USDOI, FWS, 

1978). 

Pertinent Species Information: The loggerhead sea turtle is a reddish-brown sea turtle with a 

relatively large head. It has 5 or more costals (pleurals) on each side of the carapace. Three 

(usually) or 4 large poreless scutes are found on the bridge between shells. Its limbs are 

flattened flippers. The tail of adult males (extends past tips of back-stretched hind flippers) is 

much longer than that of adult females (barely reaches rear edge of carapace). The young are 

brown or reddish-brown dorsally and have 3 dorsal keels and 2 plastral keels. The adult 

carapace length is usually 70-125 centimeters (cm) (to 122+ cm), mass 70-180 kilograms (kg) 

(to 227+ kg). The hatchling shell length is 4-5 cm, with a mass of about 20 grams. (From 

NatureServe, 2006) 

It is carnivorous and has strong jaws to crush heavy-shelled mollusks and crustaceans. From 

May to August adult females lay an average of two clutches of eggs at 13-day intervals. Each 

clutch size is approximately 120 eggs. The eggs incubate for 2 months, with the hatchlings 

emerging, usually at night, and making their way to the ocean. The females require well-drained 

dunes, clean sand, and grassy vegetation for nesting. 

In the central North Pacific, loggerheads travel westward and move seasonally north and south, 

primarily through the region 28-40 N latitude (J. Polovina, personal communication) (Oahu 

latitude is 21.433 N). Few loggerheads are found in Hawaii. Most nesting occurs in Japan. 

Juveniles are rarely seen in Hawaii, and generally north of 22 degrees latitude 

(http://www.hawaii.gov/dlnr/dar/pubs/sawcs/mr_loggerhead.pdf last accessed June 14, 2006). 

The factors affecting the decline of the loggerhead sea turtle are habitat destruction, predation, 

and drowning from being caught in shrimp nets. The States of North Carolina, South Carolina, 

Georgia, and Florida are taking steps to prevent beach destruction and predation, and the 

Atlantic and Gulf shrimpers are using TED's (50 CFR Part 227) to prevent drowning (World 

Wildlife Fund, 1990). 

Assessment for Sea Turtles: Sea turtles occur within the proposed action area and may be 

harassed by the noise generated by the tug boats, by physical disturbance from visual or other 

cues, by marine debris entanglement or ingestion, and collisions with the tug/barge. The 

potential for collisions between the tug/barge and these turtles are very low due to the slow tow 

speed (6-9 knots). The baled garbage will be inspected at multiple points in the transport process 

to ensure that bales are intact and garbage will not be released. The proposed action will have no 

effect on beach habitat or nesting activities of these turtles. 

Although the potential for collision of barges with sea turtles is low due to the slow vessel speed, 

APHIS will implement the following protection measure: 
 

52

Vessels will operate at low speeds and have observers look out for sea turtles in Hawaii to avoid 

direct encounters with them. 

Should vessel collisions with sea turtles occur, this incident will be reported to 

APHIS and NOAA’s Pacific Islands Regional Office at 808-983-5730. APHIS will re-initiate 

consultation with NMFS. 

With the implementation of these measures, APHIS has determined that the proposed 

action may affect, but is not likely to adversely affect the green sea turtle, the hawksbill sea 

turtle, the olive ridley sea turtle, the leatherback sea turtle, or the loggerhead sea turtle. 

Designated critical habitat of the hawksbill and leatherback sea turtles does not occur in the 

program area. 

References: 

NatureServe. 2006. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.7. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: June 6, 2006 ). 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and USFWS). 

1998. Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle (Eretmochelys 

imbricate). National Marine Fisheries Service, Silver Spring, MD. 

Richardson, S. 1997. Washington State Status Report fro the Olive Ridley Sea Turtle. 

Washington Department of Fish and Wildlife, Olympia. 14 pp. 

United States Department of the Interior, 1970. Fish and Wildlife Service, Bureau of Sport 

Fisheries and Wildlife, Conservation of endangered species and other fish or wildlife, United 

States list of endangered native fish and wildlife. Federal Register, Vol. 35, p. 8491, June 2, 

1970. 

United States Department of the Interior, 1978. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; listing and protecting loggerhead sea turtles as "threatened 

species" and populations of green sea and olive sea turtles as threatened or endangered. Rules 

issued by the Department of Commerce, National Marine Fisheries Service, and Department of 

the Interior, Fish and Wildlife Service. Federal Register, Vol. 43, p. 32808, July 28, 1978. 

World Wildlife Fund, 1990. The Official World Wildlife Fund Guide to Endangered Species of 

North America. Vols. 1, 2, & 3. Walton Beacham. Washington, DC, 1647 pp. 

Fish Species That Occur in the Columbia River That Could be Affected by 

Transport of GRG by Barge 

The potential impacts due to program activities are the same for all listed fish species that occur 

in the Columbia River. For this reason, the assessment for these fish have been combined and it 

follows the species accounts. 
 

53

Chinook Salmon Life History and Description: Chinook salmon belong to the family 

Salmonidae and are one of eight species of Pacific salmonids in the genus Oncorhynchus. 

Chinook salmon are easily the largest of any salmon, with adults often exceeding 40 pounds; 

individuals over 120 pounds have been reported. Chinook salmon are very similar to coho 

salmon in appearance while at sea (blue-green back with silver flanks), except for their large 

size, small black spots on both lobes of the tail, and black pigment along the base of the teeth. 

Chinook salmon are anadromous and semelparous. 

Adult female chinook will prepare a spawning bed, called a redd, in a stream area with suitable 

gravel composition, water depth and velocity. The adult female chinook may deposit eggs in 4 

to 5 nesting pockets within a single redd. After laying eggs in a redd, adult chinook will guard 

the redd from 4 to 25 days before dying. Eggs are deposited at a time to ensure that young 

salmon fry emerge during the following spring when the river or estuary productivity is 

sufficient for juvenile survival and growth. Juvenile chinook may spend from 3 months to 2 

years in freshwater after emergence and before migrating to estuarine areas as smolts, and then 

into the ocean to feed and mature. 

Juveniles feed on plankton, then later eat insects and small fish. Coastwide, chinook salmon 

remain at sea for 1 to 6 years (more commonly 2 to 4 years), with the exception of a small 

proportion of yearling males (called jack salmon) which mature in freshwater or return after 2 or 

3 months in salt water. Adults do not feed during the freshwater spawning migration. 

Lower Columbia River Chinook Salmon, Oncorhynchus tshawytscha

Status: The lower Columbia River ESU chinook salmon was listed as a threatened species on 

March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 (65 FR 

7764). 

Pertinent Species Information: Critical habitat for this ESU is designated to include all river 

reaches accessible to listed chinook salmon in Columbia River tributaries between the Grays and 

White Salmon Rivers in Washington and the Willamette and Hood Rivers in Oregon, inclusive. 

Excluded are tribal lands and areas above specific dams or above long-standing, naturally 

impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The 

following counties lie partially or wholly within these basins (or contain migration habitat for the 

species): Oregon - Clackamas, Clatsop, Columbia, Hood River, Marion, Multnomah, Wasco, 

and Washington; Washington - Clark, Cowlitz, Klickitat, Lewis, Pierce, Pacific, Skamania, 

Wahkiakum, and Yakima.

Factors contributing to the decline of chinook salmon in this ESU include hatchery introgression, 

habitat blockages, logging, eruption of Mount Saint Helens, hydropower development, 

predation, and harvest. 
Upper Columbia River Spring-run Chinook Salmon, Oncorhynchus tshawytscha

54

Status: The Upper Columbia River spring-run chinook salmon was listed as an endangered 

species on March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 

(65 FR 7764). 

Pertinent Species Information: This ESU includes stream-type chinook salmon spawning 

above Rock Island Dam - that is, those in the Wenatchee, Entiat, and Methow Rivers, as well as 

the Columbia River and estuary. Designated habitat includes all river reaches accessible to 

chinook salmon in Columbia River tributaries upstream of the Rock Island Dam and downstream 

of Chief Joseph Dam in Washington, excluding the Okanogan River. Counties in Washington 

include Chelan, Douglas, Okanogan, Grant, Kittitas, Benton, Franklin, Yakima, Klickitat, Walla 

Walla, Skamania, Clark, Cowlitz, and Wahkiakum. In Oregon, critical habitat is found in the 

counties of Gilliam, Morrow, Sherman, Umatilla, Hood River, Wasco, Multnomah, Clatsop, and 

Columbia. 

Factors contributing to the decline of the Upper Columbia River spring-run chinook salmon 

include Columbia River hydroelectric development which has resulted in a major disruption of 

migration corridors and affected flow regimes and estuarine habitat. Some populations in this 

ESU must migrate through nine mainstem dams. Access to a substantial portion of historical 

habitat was blocked by Chief Joseph and Grand Coulee Dams. There are local habitat problems 

related to irrigation diversions and hydroelectric development, as well as degraded riparian and 

instream habitat from urbanization and livestock grazing. 

Upper Willamette River Chinook Salmon, Oncorhynchus tshawytscha

Status: The Upper Willamette River spring-run chinook salmon was listed as a threatened 

species on March 24, 1999 (64 FR 14308). Critical habitat was designated on February 16, 2000 

(65 FR 7764). 

Pertinent Species Information: Major river basins known to support this ESU include the 

Willamette, Milalla, North Santiam, and McKenzie Rivers, as well as the Columbia River and 

estuary. The Upper Willamette River ESU is located in portions of Clark, Cowlitz, Wahkiakum, 

and Pacific, Washington and Clatsop, Columbia, Douglas, Lane, Benton, Lincoln, Linn, Polk, 

Clackamas, Marion, Washington, Yamhill, Tillamook, and Multnomah counties in Oregon. This 

ESU includes naturally spawned spring-run chinook salmon populations below Cottage Grove, 

Dorena, Fern Ridge, Blue River, Big Cliff, and Green Peter Dams. 

Although it is unlikely that this species occurs within the action area, it may occur in the 

Columbia River estuary and is thus being included in this analysis of effects. 

Key factors affecting chinook in this ESU include habitat blockages, hatchery introgression, 

urbanization, logging, hydropower development, and harvest. 

Snake River Fall Chinook Salmon, Oncorhynchus tshawytscha

Status: The Snake River fall Chinook salmon was listed as a threatened species on April 22, 

1992 (57 FR 14653). This status was reclassified to endangered by an emergency interim rule on 
 

55

August 18, 1994 (59 FR 42529). Critical habitat for the Snake River fall Chinook salmon was 

designated on December 28, 1993 (58 FR 68543). 

Pertinent Species Information: From the Pacific Ocean, Snake River fall salmon enter the 

Columbia River and travel upstream about 324 miles (520 kilometers) to the Snake River. The 

majority of spawning is in the mainstream Snake River, from the upper extent of Lower Granite 

Dam pool to Hells Canyon Dam. Spawning also occurs in the lower reaches of the Imnaha, 

Grande Ronde, Clearwater, and Tucannon Rivers. 

Snake River fall Chinook salmon have declined to low numbers of fish that are thinly spread 

over a large and complex river system. Hydropower development, water withdrawal and 

diversions, water storage, harvest, inadequate regulatory mechanisms, and artificial propagation 

are factors contributing to the decline, and represent a continued threat to the Snake River fall 

Chinook salmon. 

Snake River Spring/Summer Chinook Salmon, Oncorhychus tahawytscha

Status: The Snake River spring/summer Chinook salmon was listed as a threatened species on 

April 22, 1992 (57 FR 14653). This status was reclassified to endangered by an emergency 

interim rule on August 18, 1994 (59 FR 14653). Critical habitat for the Snake River 

spring/summer Chinook salmon was designated on December 28, 1993 (58 FR 68543). 

Pertinent Species Information: From the Pacific Ocean, Snake River Spring/summer Chinook 

salmon enter the Columbia River and travel upstream about 324 miles (520 kilometers) to the 

Snake River. The Snake River contains five principle subbasins that currently produce spring 

and/or summer-run Chinook. Three of the five subbasins, the Clearwater, Grande Ronde, and 

Salmon Rivers, are large, complex systems: the others, the Tucannon and Imnaha Rivers, are 

small systems in which the majority of salmon production is in the mainstream rivers. The 

Asotin, Granite, and Sheep Creeks are small streams that enter the Snake River and provide 

small spawning and rearing areas. 

Snake River spring/summer Chinook salmon declined to low numbers thinly spread over a large 

and complex river system. Hydropower development, water withdrawal and diversions, water 

storage, harvest, inadequate regulatory mechanisms, and artificial propagation are factors 

contributing to their decline and represent a continued threat to the Snake River spring/summer 

Chinook salmon’s existence. 

Columbia River Chum Salmon, Oncorhynchus keta

Status: The Columbia River chum salmon was listed as a threatened species on March 25, 1999 

(64 FR 14508). Critical habitat was designated on February 16, 2000 (65 FR 7764). 

Pertinent Species Information: Chum salmon belong to the family Salmonidae and are one of 

eight species of Pacific salmonids in the genus Oncorhynchus. Chum salmon are anadromous, 

semelparous, and spawn primarily in fresh water. They have the widest natural geographic and 

spawning distribution of any Pacific salmonid, primarily because its range extends farther along 
 

56

the shores of the Arctic Ocean than that of the other salmonids. Juvenile chum salmon are 

distinguished by parr marks of relatively regular height that are smaller than the vertical diameter 

of the eye, and that are faint or absent below the lateral. Adult chum salmon have greenish to 

dusky mottling on the sides, with males exhibiting distinctive reddish-purple vertical barring. 

Adult chum in Washington range in size from 17 to 38 inches, with an average weight of 9 to 11 

pounds. Chum salmon spawn in the lowermost reaches of rivers and streams, typically within 

100 km of the ocean. 

This ESU includes all naturally spawned populations of chum salmon in the Columbia River and 

its tributaries in Washington and Oregon. Critical habitat for the Columbia River chum salmon 

is designated to include all river reaches accessible to listed chum salmon (including estuarine 

areas and tributaries) in the Columbia River downstream from Bonneville Dam, excluding 

Oregon tributaries upstream of Milton Creek at river km 144 near the town of St. Helens. Also 

included are adjacent riparian zones. The following counties lie partially or wholly within these 

basins (or contain migration habitat for the species): Oregon - Clatsop, Columbia, Multnomah, 

and Washington; Washington - Clark, Cowlitz, Lewis, Pacific, Skamania, and Wahkiakum. 

The decline of the Columbia River chum salmon is due to habitat loss and overfishing. Habitat 

loss is due to channel excavations, dewatering, channelization, flood control, major water 

diversions, poor forestry practices, and bulkheading of nearshore marine habitats. 

Snake River Sockeye Salmon, Oncorhynchus nerka

Status: The Snake River sockeye salmon was listed as an endangered species on November 20, 

1991 (56 FR 58619). Critical habitat was designated for the Snake River sockeye salmon on 

December 28, 1993 (58 FR 68543). 

Pertinent Species Information: The Snake River sockeye salmon is a member of the trout 

family (Salmonidae). These Pacific salmon are anadromous, spending their adult life in the 

ocean and traveling into freshwater to spawn and complete their early life histories. Redfish 

Lake in Custer County, Idaho supports the only remaining run of Snake River sockeye salmon. 

Adult Snake River sockeye salmon usually enter Redfish Lake in August, and spawning occurs 

near shoreline shoals in October. Eggs hatch in the spring, and the juveniles remain in Redfish 

lake for normally 2 years before migrating to the ocean. Migrants leave Redfish Lake from late 

April through May. Smolts migrate almost 900 miles through the Salmon, Snake, and Columbia 

Rivers to the ocean where they usually spend 2 years. Adults return to Redfish Lake in the 

fourth or fifth year of life, and begin their migration in June and July. 

Hydropower development, water withdrawal and diversions, water storage, harvest, predation, 

and inadequate regulatory mechanisms are factors contributing to the Snake River sockeye 

salmon’s decline and represent a continued threat to the Snake River sockeye salmon’s 

existence. 

Steelhead Life History and Description: Steelhead exhibit one of the most complex life 

histories of any salmonid species. Steelhead may exhibit anadromy or freshwater residency. 
 

57

Resident forms are usually referred to as rainbow trout, while anadromous life forms are termed 

steelhead. Like all trout, the steelhead are positively separated from the various salmon species 

by having eight to twelve rays in the anal fin. Steelhead are separated from brook trout, lake 

trout, and Dolly Varden by the complete absence of teeth at the base of the tongue. Coloration on 

the back is basically blue-green shading to olive with black, regularly spaced spots. The black 

spots also cover both lobes of the tail. Steelhead from the ocean are much more silver than 

resident rainbow trout. Spawning steelhead develop a distinct pink to red strip-like coloration 

that blends along the side, both above and below the lateral line. 

Juvenile steelhead trout are identical to rainbow trout until the period prior to their ocean 

migrations. Prior to migrating to the sea, juvenile steelhead become very silvery and resemble 

miniature adults. They are called smolt during this life phase. Steelhead typically migrate to 

marine waters after spending two years in freshwater. They then reside in marine waters for two 

to three years prior to returning to their natal stream to spawn. Within the range of west coast 

steelhead, spawning migrations occur throughout the year, with seasonal peaks of activity. 

Summer steelhead enter fresh water up to a year prior to spawning. Depending on water 

temperature, steelhead eggs may incubate in redds for one and one half to four months before 

hatching as alevins. The alevins remain within the redds, living on the rich nutrients contained 

in the yolk sac. In 3 to 4 weeks they emerge as fry and feed on small insects and drifting 

plankton. They then develop into parr (about 3 inches in length) feeding primarily on aquatic 

and flying insects, although small fish become an increasingly important part of their diet as they 

grow. Juveniles rear in freshwater from one to four years, then migrate to the ocean as smolts.

Upper Columbia River Steelhead, Oncorhynchus mykiss

Status: The Upper Columbia River steelhead was listed as an endangered species on August 18, 

1997 (62 FR 43974). Critical habitat was designated on February 16, 2000 (65 FR 7764). 

Pertinent Species Information: Critical habitat is designated to include all river reaches 

accessible to listed steelhead in Columbia River tributaries upstream of the Yakima River, 

Washington, and downstream of Chief Joseph Dam. Excluded are tribal lands and areas above 

specific dams or above long-standing, naturally impassable barriers (i.e., natural waterfalls in 

existence for at least several hundred years). The following counties lie partially or wholly 

within these basins (or contain migration habitat for the species): Oregon - Clatsop, Columbia, 

Gilliam, Hood River, Morrow, Multnomah, Sherman, Umatilla, and Wasco; Washington - 

Benton, Chelan, Clark, Cowlitz, Douglas, Franklin, Grant, Kittitas, Klickitat, Okanogan, Pacific, 

Skamania, Wahkiakum, Walla Walla, and Yakima. 

Habitat degradation, juvenile and adult mortality in the hydrosystem, and unfavorable 

environmental conditions in both marine and freshwater habitats have contributed to the declines 

of this ESU and represent risk factors for the future. Harvest in lower river fisheries and genetic 

homogenization from composite broodstock collection are other factors that may contribute 

significant risk to the Upper Columbia River steelhead. 
 

Snake River Basin Steelhead, Oncorhynchus mykiss 

58

Status: The Snake River Basin steelhead was listed as a threatened species on August 18, 1997 

(62 FR 43974). Critical habitat was designated on February 16, 2000 (65 FR 7764). 

Pertinent Species Information: Critical habitat is designated to include all river reaches 

accessible to listed steelhead in the Snake River and its tributaries in Idaho, Oregon, and 

Washington. Excluded are tribal lands and areas above specific dams identified or above longstanding, naturally impassable barriers (i.e., Napias Creek Falls and other natural waterfalls in 

existence for at least several hundred years). The following counties lie partially or wholly 

within these basins (or contain migration habitat for the species): Idaho - Adams, Blaine, Boise, 

Clearwater, Custer, Idaho, Latah, Lemhi, Lewis, Nez Perce, and Valley; Oregon - Baker, 

Clatsop, Columbia, Hood River, Morrow, Multnomah, Sherman, Umatilla, Union, Wallowa, and 

Wasco; Washington - Asotin, Benton, Clark, Columbia, Cowlitz, Franklin, Garfield, Klickitat, 

Skamania, Wahkiakum, Walla Walla, and Whitman. 

Widespread habitat blockage from hydrosystem management, potentially deleterious genetic 

effects from straying, and introgression from hatchery fish have contributed to the decline of 

Snake River Basin steelhead. 

Lower Columbia River Steelhead, Oncorhynchus mykiss

Status: The Lower Columbia River steelhead was listed as a threatened species on March 19, 

1998 (63 FR 13347). Critical habitat was designated on February 16, 2000 (65 FR 7764). 

Pertinent Species Information: Critical habitat is designated to include all river reaches 

accessible to listed steelhead in Columbia River tributaries between the Cowlitz and Wind 

Rivers in Washington and the Willamette and Hood Rivers in Oregon, inclusive. Excluded are 

tribal lands and areas above Bull Run Dam 2 and Merwin Dam or above long-standing, naturally 

impassable barriers (i.e., natural waterfalls in existence for at least several hundred years). The 

following counties lie partially or wholly within these basins (or contain migration habitat for the 

species): Oregon - Clackamas, Clatsop, Columbia, Hood River, Marion, Multnomah, and 

Washington; Washington - Clark, Cowlitz, Lewis, Pacific, Skamania, and Wahkiakum. 

Habitat loss, hatchery steelhead introgression, and harvest are major contributors to the decline 

of Lower Columbia River steelhead. 

Middle Columbia River Steelhead, Oncorhynchus mykiss

Status: The Middle Columbia River steelhead was listed as a threatened species on March 25, 

1999 (64 FR 14517). Critical habitat was designated on February 16, 2000 (65 FR 7764). 

Pertinent Species Information: Critical habitat is designated to include all river reaches 

accessible to listed steelhead in Columbia River tributaries (except the Snake River) between 

Mosier Creek in Oregon and the Yakima River in Washington (inclusive). Excluded are tribal 

lands and areas above specific dams (Condit Dam and Pelton Dam) or above longstanding, 

naturally impassable barriers (i.e., natural waterfalls in existence for at least several hundred 

years). The following counties lie partially or wholly within these basins (or contain migration 
 

59

habitat for the species): Oregon -Clatsop, Columbia, Crook, Gilliam, Grant, Harney, Hood River, 

Jefferson, Morrow, Multnomah, Sherman, Umatilla, Union, Wallowa, Wasco, and Wheeler; 

Washington - Benton, Clark, Columbia, Cowlitz, Franklin, Kittitas, Klickitat, Pacific, Skamania, 

Wahkiakum, Walla Walla, and Yakima. 

The recent and dramatic increase in the percentage of hatchery fish in natural escapement in the 

Deschutes River Basin is a significant risk to natural steelhead in this ESU. 

Bull Trout, Salvelinus confluentus 

Status: The bull trout was listed as a threatened species on June 12, 1998 (USDOI, FWS, 1998). 

 Critical habitat was designated on September 26, 2005 but does not occur within the mainstem 

of the Columbia River (USDOI, FWS, 20045. 

Pertinent Species Information: Bull trout, members of the family Salmonidae, are native to 

the Pacific Northwest and western Canada. Juvenile bull trout have a slender body form and 

exhibit the small scalation typical of char. The back and upper sides are typically olive-green to 

brown with a white to dusky underside. The dorsal surface and sides are marked with faint pink 

spots. They lack the worm-like vermiculations and reddish fins commonly seen on brook trout 

(Salvelinus fontinalis). Spawning bull trout, especially males, turn bright red on the ventral 

surface with a dark olive-brown back and black markings on the head and jaw. The spots 

become a more vivid orange-red and the pectoral, pelvic, and anal fins are red-black with a white 

leading edge. The males develop a pronounced hook on the lower jaw. Bull trout have an 

obvious notch on the end of the nose above the tip of the lower jaw. 

In the United States, bull trout occur in rivers and tributaries throughout the Columbia Basin in 

Montana, Idaho, Washington, Oregon, and Nevada, as well as the Klamath Basin in Oregon, and 

several cross-boundary drainages in extreme southeast Alaska. 

Bull trout populations are known to exhibit four distinct life history forms: resident, fluvial, 

adfluvial, and anadromous. Resident bull trout spend their entire life cycle in the same (or 

nearby) streams in which they were hatched. Fluvial and adfluvial populations spawn in 

tributary streams where the young rear from 1 to 4 years before migrating to either a lake 

(adfluvial) or a river (fluvial) where they grow to maturity. Anadromous bull trout spawn in 

tributary streams, with major growth and maturation occurring in the ocean. Bull trout spawn in 

the fall, primarily in September or October when water temperatures drop below 9 oC (48 oF). 

Juvenile bull trout feed primarily on aquatic insects. Adults are opportunistic and largely 

nondiscriminating fish predators. Adult bull trout, like the young, are strongly associated with 

the bottom, preferring deep pools in cold water rivers, as well as lakes and reservoirs. 

Bull trout in other Columbia River tributaries (e.g. Hood and Wenatchie Rivers) are known to 

migrate downstream to the mainstem of the Columbia River (FWS, 2002). The extent to which 

the Lower Columbia River Recovery Unit uses the mainstem of the Columbia River is unknown 

(FWS, 2002). Adult bull trout do appear to use the mainstem Columbia River for foraging, 
 

60

overwintering and as a migratory corridor and it contains core habitat requirements considered 

important for bull trout recovery (FWS, 2002). 

The decline of the bull trout is primarily due to habitat degradation and fragmentation, blockage 

of migratory corridors, poor water quality, past fisheries management practices, and the 

introduction of nonnative species. 

The following bull trout core areas occur and feed into the mainstem Columbia River between 

the mouth of the Columbia River and Klickitat County, where barging of bales of GRG from 

Hawaii will occur: Klickitat, John Day River, Upper Willamette, Lower Deschutes, Hood River, 

and Lewis. Only the migratory stage of bull trout from these core areas would be exposed to 

program activities because only the migratory stage would be present in the mainstem. Little is 

known about the presence of each individual bull trout subpopulation in the mainstem. 

Therefore, this assessment will assume that migratory adults from any subpopulation may be 

present in the mainstem. Freshwater feeding, migration, and overwintering habitats outside core 

areas, including the Columbia River, are difficult to evaluate due to the nature of this habitat and 

the limited information on its relationship to core areas. Bull trout from multiple core areas may 

use the Columbia River, making it extremely difficult to evaluate the overall effect to individual 

core areas. It is recognized that the Columbia River is an important component of the overall 

habitat network for migratory bull trout to complete their life history. 

The following narratives have been provided by the U.S. Fish and Wildlife Service to describe 

the baseline condition of the bull trout core areas considered in this risk assessment: 

Lewis Core Area 

The eruption of Mt. St. Helens affected water quality in the Muddy River and Pine Creek. 

Riparian vegetation was destroyed and mud flows and ash deposits have contributed high levels 

of fine sediments to Pine Creek, Muddy River, and the Lewis River above Swift Creek 

Reservoir. Stream temperatures above 16 degrees Celsius (61 degrees Fahrenheit) have also 

been measured in Pine Creek although the most current data collected did not exceed 14.3 

degrees Celsius. While the exact cause of these elevated stream temperatures are not well 

understood, it is suspected that channel widening from high levels of timber harvest, and the 

1980 mudflows and the loss of riparian vegetation from the Mt. St. Helens eruption, have all 

contributed to elevated stream temperatures in Pine Creek. Merwin Dam (located on te Lewis 

River), Yale Dam, and Swift Number 1 and 2 Powerhouses on the Lewis River prevent upstream 

migration of bull trout and other resident fish. Lack of passage at these hydroelectric facilities 

within the Lower Columbia River Unit has fragmented bull trout populations and prevented 

migration into the lower Lewis and Columbia Rivers. Forest management practices in the Lewis 

River basin have combined to alter flow regimes, riparian conditions and instream habitat. Flood 

events in the 1970’s sent large pulses of sediment into Rush Creek increasing the average 

channel width 38 percent. The stream has adjusted to these sediment pulses over time by 

channel narrowing and down cutting. 

Key reference: Bull trout draft recovery plan, Chapter 20 (FWS, 2002). 
 

61

Klickitat Core Area 

Water quality is poor in the lower Klickitat (i.e., the area below the confluence with the Little 

Klickitat), with several tributaries listed as a 303(d) impaired waterway. Parameters that do not 

meet state water quality in portions of the Little Klickitat, Snyder Canyon, and Swale Creek 

include temperature, instream flow, fish passage barriers, and fish habitat. Sediment and various 

chemical contaminants have also been detected in the lower Klickitat, but did not exceed water 

quality standards. It is important to note that the Service has not completed consultation on 

water quality standards in terms of potential effects to listed species. In any case, sediment 

yields in the middle and upper Klickitat are elevated by a legacy of logging, road-building, and 

grazing impacts. In addition, high natural rates of sediment are associated with extensive glacial 

outwash from Big Muddy Creek. 

Habitat access is limited in the Klickitat through physical, temperature, and instream flow 

obstructions. Numerous existing and abandoned roads, especially in the lower Klickitat, limit 

fish access to tributaries and side channel habitat directly or by poor culvert design or placement. 

 Passage is impaired or precluded depending on flow, species, and life history form at Lyle Falls, 

the Klickitat Hatchery, and Castile Falls. While some of these areas appear to allow at least 

some passage during certain flow conditions, others prevent passage across a range of flows. 

Development in the lower Klickitat for agriculture and a long history of logging and grazing in 

the middle and upper Klickitat has resulted in an extensively degraded system. As described 

above, access to off-channel habitat is reduced, and temperatures and flow conditions may be 

inadequate to support fish. Elevated sediment yields have increased embeddedness and filled 

pools in some locations. A long history of agriculture and logging has simplified habitat 

conditions, and all but eliminated refugia. 

Development for agriculture, including loss of wetlands, intensive logging, and an extensive 

road network has substantially modified the hydrology of the Klickitat. This has resulted in 

pronounced changes in the timing and magnitude of peak flows, storage and recharge capacity. 

In addition, low flows appear to occur earlier, last longer, and consist of less total streamflow 

than similarly-sized watersheds.. 

The road network throughout the core area is extensive, approximating 8 miles/mile2

 across all 

FMO habitats. In particular, roads in the West Fork Klickitat local population involve 39 stream 

crossings. Riparian areas have been highly managed or have removed most riparian vegetation 

in the development and conversion to agriculture in the lower Klickitat. Similarly, logging, 

road-building, and grazing have substantially impacted all aspects of riparian areas in the middle 

and upper Klickitat. Human perturbations of the Klickitat have also impacted the natural 

disturbance regime, nearly eliminating frequent, low-intensity fires and altering all hydrological 

processes. 

(key reference: 2004 Klickitat Subbasin Plan) 
Upper Willamette Core Area 

62

The Upper Willamette Core Area is comprised of three local populations, McKenzie River, 

South Fork McKenzie, and Trailbridge Reservoir. Population estimates indicate less than 300 

adult bull trout survive in this core area. Annual redd counts have decreased gradually over the 

last five years (2000-2004) in the mainstem McKenzie River local population, from a high of 92 

redds in 2000, to 61 redds in 2003. Over the same time frame, redd counts have remained stable 

for the South Fork McKenzie River local population (annual average of 29), and increased in the 

Trail Bridge local population from two redds in 2000 to 25 redds in 2004. ODFW has been 

annually reintroducing bull trout fry into historic, unoccupied habitat in the Middle Fork 

Willamette River. No reproduction has been noted, but adult bull trout were captured in Hills 

Creek Reservoir in 2003 and 2004, and several age classes of bull trout were collected in and 

below the bull trout release sites. While there is some limited connectivity within and among 

local populations in this core area, there are some significant fish passage barriers posed by large 

dams. Habitat and population baseline conditions for the bull trout in the Willamette Basin are 

degraded, based on current condition, elevated risk from stochastic events, and the low 

probability of recolonization through dispersal due to the distance to other bull trout core areas in 

the lower Columbia River. 

Hood River Core Area 

The Hood River Core Area is comprised of two local populations, Clear Branch and Hood River. 

Accurate adult abundance estimates for the Hood River Core Area are not available; however, 

300 or less bull trout are believed to occur in the core area. Trap count and snorkel count data 

support this belief: Snorkel surveys conducted at Clear Branch above the dam found a total of 51 

to 200 bull trout annually between 1996 and 2003, while surveys below the dam found a total of 

0 to 3 bull trout annually between 1996 and 2003. Some migratory forms occur in the core area, 

and are believed to overwinter in the lower Hood River and Bonneville Pool of the Columbia 

River. The two local populations are isolated by an impassable dam. Bull trout are consistently 

found in the Hood River, the Middle Fork Hood River, and the Clear Branch of Hood River. 

Bull trout distribution in the East and West Forks of Hood River are based on isolated, 

infrequent sightings. Historical distribution is believed to approximate current distribution based 

on existing knowledge. Habitat baseline conditions are degraded in the Hood River Core Area, 

with numerous water diversions impacting connectivity. The Forest Service has undertaken 

numerous habitat restoration activities in the Clear Branch local population area.

Lower Deschutes Core Area 

The Lower Deschutes Core Area includes all current and historic bull trout habitat in the 

Deschutes River and tributaries from Big Falls downstream to the confluence of the Deschutes 

with the Columbia River. It contains five local populations: Shitike Creek, Warm Springs River, 

Whitewater River, Jefferson/Candle/Abbot river complex, and Canyon/Jack/Heising/mainstem 

Metolius river complex. Spawning, rearing, foraging, migrating, and overwintering habitats are 

present in the core area. Redd count data collected between 1998 and 2004 found that bull trout 
 

63

spawner numbers had generally increased in two of the three Metolius River basin local 

populations (Jefferson/Candle/Abbot river complex and Canyon/Jack/Heising/mainstem 

Metolius river complexes combined redd counts increased from 180 in 1998 to 1,045 in 2004), 

remained stable in the Metolius basin’s Whitewater River (data from the Whitewater River are 

limited, but suggest that the population there is about 30 adults), and remained stable in the 

lower Deschutes River’s Shitike Creek and Warm Springs River populations (Shitike Creek 

remained steady between 1998 and 2004: 117 redds were counted in 1998, and counts have 

averaged 137 redds (110 adults) in the last five years. In the Warm Springs River 101 redds 

were counted in 1998, and redd counts averaged 89 redds (71 adults) in the last five years). 

In late summer of 2003, the 91,902 acre B&B fire burned through large areas of the Metolius 

River basin. It burned areas of the Jefferson/Candle/Abbot river complex and 

Canyon/Jack/Heising/mainstem Metolius river complex, but did not affect the Whitewater River 

population. Habitat conditions in the two burned local populations are at elevated risk from 

increased sediment delivery, with resultant changes including sedimentation of spawning areas, 

loss of juvenile rearing habitat, increases in peak flows, and increases in stream temperature. 

Little data exists as to the current use of the mainstem Columbia River by bull trout in this 

recovery unit. 

John Day River Core Area

The Middle Fork John Day Core Area consists of three local populations: Granite Boulder 

Creek, Big Creek, and Clear Creek. Total numbers of bull trout, consisting of primarily juvenile 

and subadult fish, were estimated in 1999 to be 1,950 individuals in Big Creek, 640 individuals 

in Clear Creek, and 368 individuals in Granite Boulder Creek. Resident bull trout are the 

predominant life history form in the core area, and occupy tributary habitats, but some migratory 

bull trout have been collected in the Middle Fork John Day River and on spawning locations 

within tributaries. Sedimentation within this core area is a severe problem. Catastrophic fires 

burned through the core area in recent years causing erosion and high sediment yields. These 

effects combine with sedimentation from mining, the removal of streamside vegetation by 

livestock, and already existing habitat fragmentation to make the path to bull trout recovery 

difficult. 

The North Fork John Day River Core Area consists of seven local populations: Upper North 

Fork John Day River, Upper Granite Creek, Boulder Creek, Clear/Lightning creeks above ditch, 

Clear Creek below ditch, Desolation Creek, and South Fork Desolation Creek above the falls. 

Resident and migratory forms are found in the core area. Overall population trend for the North 

Fork John Day Core Area is upward. Habitat fragmentation, connectivity and water quality 

issues still occur. The threats associated with mining still exist, but have been reduced through 

improved administration and cooperation between the Forest Service and local miners. The 

presence of brook trout throughout the core area, including the high mountain lakes, continues to 

be a serious threat to bull trout. 

The John Day River Core Area consists of two local populations: Upper John Day River and 

Indian Creek. Spawning surveys in 1999 and 2000 of bull trout habitat in tributary streams to 

the mainstem John Day River showed few fish spawning in the local population, with most 

occupied streams having less than 20 redds. Redd surveys in 1990 estimated that the upper 
 

64

mainstem, and Call and Rail creeks may have more than 300 total spawning adults. Some new, 

small populations of resident bull trout have been discovered in smaller Core Area streams. 

Migratory bull trout commonly occur from the John Day River headwaters to the City of John 

Day, with at least seasonal use as far down as the town of Spray, below the John Day and North 

Fork John Day rivers’ confluence. Indian Creek is seasonally blocked by a diversion that 

dewaters the lower reaches and creates a migration barrier. The overall trend for bull trout in this 

core area is upward. Water quality issues, passage problems and competition from brook trout 

all continue to be major problems. 

Anadromous fish access to the John Day River basin is constrained by passage through the 3 

mainstem Columbia River dams. Bull trout use of the Columbia River in the vicinity of these 

dams is not well documented. 

Bull Trout Matrix 

The following table (table 2) is a summary of the documentation of the environmental baseline 

and effects of proposed actions on relevant indicators, provided in the document “A Framework 

to Assist in Making Endangered Species Act Determinations of Effect for Individual or Grouped 

Actions at the Bull Trout Subpopulations Scale”, prepared by the U.S. Fish and Wildlife Service. 

 Although the checklist for documentation includes many indicators, including habitat access, 

habitat elements, channel conditions and dynamics, flow/hydrology, and watershed conditions, 

APHIS considered only subpopulation characteristics and water quality because these were the 

relevant factors to the proposed action. Subpopulation characteristics included subpopulation 

size, growth and survival, life history diversity and isolation, and persistence and genetic 

integrity of the subpopulation. Water quality included temperature, sediment, chemical 

contamination, and nutrients. “H” indicates subpopulations functioning at an unacceptable risk, 

“M” indicates subpopulations functioning at risk, and “L” indicates subpopulations functioning 

appropriately. 
 

65

Table 2. Summary of the documentation of the environmental baseline and effects of proposed 

actions on relevant indicators. 

ore Area 

Local Population/Potential 

Local Population 

Subpopulation 

characteristics 

Water 

Quality 

Risk 

Rating 

Klickitat West Fork Klickitat River H H H 

upper North Fork John Day 

River L L L 

upper Granite Creek L L L 

Boulder Creek L L L 

Clear/Lightning Creek L L L 

Clear Creek below Pete Mann 

ditch L L L 

Desolation Creek L L L 

South Fork Desolation Creek L L L 

Clear Creek (in Middle Fork) M H H 

Granite Boulder Creek M H H 

Big Creek M H H 

upper John Day River L M M 

John Day River 

Indian Creek L M M 

McKenzie River M L M 

South Fork McKenzie M L M Upper 

Willamette 

Trail Bridge M L M 

Shitike Creek M L M 

Warm Springs River M L M 

Whitewater River M L M 

Jefferson/Candle/Abbot River M M M 

Lower 

Deschutes 

Canyon/Jack/Heising/ 

mainstem Metiolus river M M M 

Clear Branch M L M Hood River 

Hood River M L M 

Rush and Pine Creek H L M Lewis 

Cougar Creek H L M 

Subpopulations of bull trout considered most at risk based on subpopulation characteristics and 

water quality were West Fork Klickitat River in the Klickitat Core Area, and Clear Creek, 

Granite Boulder Creek, and Big Creek in the John Day River Core Area. 

Assessment for all listed fish in the Columbia River area: 

No disinfectants or detergents are required to be used to clean up spills of GRG that might occur, 

thus none of these chemicals will enter the Columbia River. Barge traffic on the Columbia River 

has been estimated to increase by approximately 100 trips per year (1%) as a result of this 

proposed action but this minimal increase would have no significant effect on any of these fish 
 

66

species. There is no evidence that barges in the Columbia River adversely affect listed species 

(other than the modifications made to the river to accommodate barges). Chance of pest escape 

from bales is very low and plant pest escape and establishment would not affect these fish. No 

animal pests are found in Hawaii that are not already found the continental United States. 

However, if an accident were to occur and bales of GRG were to fall into the Columbia River, 

debris might have an adverse effect on listed fish. Although the Columbia River mainstem is 

primarily a migration route for salmon and steelhead rather than a spawning area, some ESUs 

have been found to spawn in the Columbia River mainstem. There is a possibility that if a bale 

fell from the barge and broke open in the river that GRG could drift into spawning areas. 

It is unlikely that a bale would fall from the barge in the mainstem since bales will be well 

secured on the barge and the chance of a barge accident is very low. U.S. Army Corps of 

Engineers (2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles. Of 

those, only 4 of the 167 accidents on the Columbia River involved freight barges (Marine Safety 

Offices, 2006). Although loss of a bale in the river as a result of a barge accident is unlikely, 

both applicants have prepared emergency response plans to retrieve bales and loose GRG from 

the river. All efforts will be made to retrieve lost bales. 

The most likely location where bales could be lost is at the transloading points on the Columbia 

River where bales are unloaded from the barges. Bales could possibly be dropped into the River 

as they are being unloaded from the barge. Fish spawning areas are not likely to occur at the 

transloading points because the water would be too deep at the transloading point to 

accommodate redds. Hazardous materials are prohibited from inclusion in the bales; thus, bale 

contents would not be toxic to fish. As stated previously, applicants must have emergency 

response plans in place should bales fall into the water and all efforts will be made to retrieve 

GRG. These plans will be included as appendices to the compliance agreements. Thus, bales 

falling into the Columbia River as a result of a barge accident or being dropped during 

transloading are not likely to adversely affect listed fish in the Columbia River or designated 

critical habitat. If an entire barge were to capsize in the Columbia River, an emergency 

consultation with the Services would be initiated. Capsizing would be an unpredictable event 

(temporally/geographically) and therefore, not possible to assess at this time. 

Other than accidental spills, the only effect of barging GRG on bull trout, steelhead or salmon 

would be water quality if a gas or fuel spill from the barge were to occur. A catastrophic spill of 

fuel or oil is extremely unlikely and would be considered under an emergency consultation with 

the Services. However, routine leakage of small amounts of fuel or oil in the Columbia River is 

considered in this assessment. Effects of the fuel could directly poison bull trout or indirectly 

affect bull trout by poisoning invertebrate or prey species. Oil and petroleum products vary 

considerably in their toxicity, and the sensitivity of fish to petroleum varies among species. The 

sublethal effects of oil on fish include changes in heart and respiratory rates, gill hyperplasia, 

enlarged liver, reduced growth, fin erosion, impaired endocrine system, and a variety of 

biochemical, blood, and cellular changes, and behavioral responses (from page B-32: Biological 

Opinion, May 9, 2003, U.S. Fish and Wildlife Service, Montana Ecological Services Field 

Office). 
 

67

Analysis of impacts of a gas/fuel spill: 

Duration: Any effect from a gas/fuel spill from a barge is expected to be a short term event 

whose effects are relaxed almost immediately because of the small size of spills and the rapid 

evaporation of the most toxic fractions of the fuel. 

Disturbance Frequency: For this assessment, APHIS is expecting only two barges hauling GRG 

from Hawaii per week. The barge companies do not expect to leak fuel or oil from their tugs. 

However, for this assessment, APHIS is using a conservative estimate that 0.01% of the fuel 

would be lost through normal operations during the trip up the river for a total of 0.01 gal/hr. 

Disturbance Intensity: One company submitted information indicating that 13,500 gallons of 

fuel will be used to travel from the mouth of the river to Klickitat County (253 miles) over a five 

day period resulting in the consumption of 112.5 ga of fuel/hr over the five day trip. Based on 

comments from the companies regarding the lack of leaks from the operation of their tugs and 

the economics APHIS assumed that 0.01% of the fuel would be lost through normal operations 

during the trip up the river for a total of 0.01 gal/hr. Converting this to L/hr results in a value of 

0.042 L/hr. 

APHIS used flow data from McNary Dam which is at river mile 292. There are three other dams 

below McNary, creating uncertainty when trying to determine concentrations of fuel in the water 

downstream. APHIS used the Army Corps of Engineer’s lowest discharge rate below the dam 

(30,000 cfs or 224,415 ga/hr) and the average (191,000 cfs or 1,428,775 ga/hr ) to estimate the 

volume of water that is moving down the Columbia River near the location of the landfill. 

Minimum water discharge from McNary Dam = 30,000 cfs or 224,415 ga/hr or 849,503.19 L/hr) 

Average yearly discharge from McNary Dam = 191,000 cfs or 1,428,775 ga/hr or 5,408,503.6 

L/hr) 

To relate these numbers to a toxicity value APHIS converted the 0.042 L/hr discharge rate to 

mg/L/hr using the average density of diesel fuel (0.827 mg/L). Making all the conversions from 

ga to liter result in: 

 

0.042 L/hr * 0.827 g/mL (density of diesel fuel) = 34,734 mg/L/h of diesel fuel from the tug. 

34,734 mg/L/hr // 849,503.19 L/h = 0.04 mg/L/hr (concentration) 

34,734 mg/L/hr // 5,408,503.6 L/h = 0.006 mg/L/hr (concentration) 

When compared to the 48-hour Daphnia EC50 value of 1.43 mg/L the above values fall well 

below the toxicity value. Information from the EPA OW Gold Book Standard states that oil 

toxicity is highly dependent on the type and grade of fuel so no standards are stated. EPA 

recommends using a 0.01 factor of the lowest resident species EC/LC50 value which in this case 

(0.0143) would approximate the calculated exposure concentrations at a minimum discharge 

from the dam but would be an order of magnitude below potential levels at the average yearly 
 

68

discharge. However the above calculations are extremely conservative and reflect the use of 

available data using very simple assumptions. 

Assumptions: 

1. The amount of loss from the tug is considered a conservative estimate of loss over the 

period of the trip up the Columbia River. The companies have stated that no fuel is lost during 

normal operations of their tugs; however APHIS recognizes that a sheen could appear during 

normal operations of the tug. Estimates were based on economic considerations for an 

acceptable loss of fuel and were considered to occur during the entire five day trip. 

2. The calculation of cfs is based solely on discharge rates from the outflow of the McNary 

Dam and does not consider the volume of water already below the dam. Water discharging from 

the dam into a large volume of water will substantially increase the volume available for 

dilution. 

3. The calculations assume that the entire length of the Columbia River has the same flow 

rate. Three dams are located downstream of the McNary Dam, as well as numerous tributaries 

that drain into the Columbia River and create a volume at the mouth that is one to two orders of 

magnitude greater than the flow from McNary Dam. The added input from the additional 

drainages would be expected to dilute any possible oil sheening orders of magnitude below the 

above calculated values. 

4. The above calculations assume that the diesel fuel will be uniformly mixed within the 

water column which will not be the case since diesel fuel has an average density (0.827 mg/mL) 

which is less than water from the Columbia River. The lighter diesel fuel will remain at the 

surface of the water column where the more toxic components will be lost through evaporation 

and other biotic and abiotic pathways. 

5. The comparison of toxicity values expressed as (mg/L) to a rate expressed as (mg/L/hr) 

creates uncertainty in calculating risk. For reasons discussed above the concentration per hour 

calculated for this exercise would never been seen in the Columbia River. Making a comparison 

to toxicity values expressed over 48 to 96 hr is overly conservative and does not represent actual 

exposure scenarios. 

Conclusion from oil/fuel spill risk assessment:

APHIS has determined that because toxicity to listed fish from the routine leakage of fuel or oil 

in the Columbia River is not expected, the proposed barging of GRG in the Columbia River may 

affect, but is not likely to adversely affect any listed fish, including salmon, steelhead, and 

subpopulations of bull trout, including those considered most at risk due to subpopulation 

characteristics and low water quality within the core area. Direct toxicity to fish or indirect 

effects from toxicity to prey species are unlikely based on the small amount of fuel to which 

these species could be exposed to in a large body of water. In addition, barge traffic on the 

Columbia River has been estimated to increase only 1 percent (100 barges per year) as a result of 

this proposed action but this minimal increase would have no significant effect on salmon, 

steelhead, or bull trout. There is no evidence that barges in the Columbia River adversely affect 
 

69

listed species (other than the modifications made to the river to accommodate barges). For these 

reasons, the proposed action may affect, but is not likely to adversely affect listed salmon, 

steelhead, and bull trout in the Columbia River. The proposed action is also not likely to 

adversely affect designated critical habitat of these species. 

Potential Risk of Copper Exposure from Barges Containing Hawaiian Garbage to Salmonids

As a means to assess the risk of copper leaching from anti-hull fouling paints used on barges 

currently using the Columbia River and potentially carrying baled GRG from Hawaii, a 

conservative exposure estimate was calculated to compare to effect thresholds for salmonids. 

Several published articles have documented copper-related impacts to the olfaction response of 

salmonids that could result in sublethal adverse effects. A recent overview of these effects 

resulted in the establishment of proposed benchmark concentrations that provide threshold 

concentrations above which dissolved copper concentrations could be expected to impact 

olfaction and behavior (Hecht et al., 2007). Biologically relevant benchmark concentrations to 

unexposed salmonids were calculated to range from 0.59 to 2.1 μg/L. This range was used as 

the effects endpoint for this assessment since it is the most sensitive compared to other endpoints 

that have been documented in other studies. 

Exposure concentrations were derived based on multiple conservative assumptions to provide a 

copper concentration that could be compared to the benchmark values previously discussed. To 

calculate an exposure concentration, the literature was reviewed to determine potential leaching 

rates of copper from ships when an anti-hull fouling paint was used. As expected, leaching rates 

are variable depending on several factors, such as the type of copper-containing paint that is 

used, when it was applied, and other environmental factors that can affect leaching rates. 

Hattum et al. (2002) in a review of leaching rates used to develop an environmental fate model, 

documented copper leaching rates ranging from 1 to 101 μg Cu/ cm2

/day with a proposed default 

rate of 50 μg Cu/ cm2/day. This value is on the upper end of another study conducted in the 

United States in-situ and in the laboratory which documented initial laboratory leaching rates of 

25 to 65 μg Cu/ cm2/day and then declining to 8 to 22 μg Cu/ cm2/day within two months. 

Variability in the rates was attributed to the different types of copper coatings used in the studies. 

 In-situ leaching rates were much less with rates ranging from 3.8 to 8.2 μg Cu/ cm2/day (Valkirs 

et al. 2003). The rate used in this assessment was 50 μg Cu/ cm2

/day. 

Barges that potentially could be moving baled GRG can range in size from 80 to 100 feet in 

width and 400 to 450 feet in length. To maximize the amount of leaching, the barge with the 

largest surface area was used in the calculation which after converting to meters, results in a total 

surface area of 4,179 square meters. This value was used as a means to determine potential 

copper loading in a day to surrounding waters in a port. As another means of maximizing copper 

concentrations, the volume of water was assumed to be small relative to the area of the barge. 

For this calculation, the water body was assumed to be 200 m by 800 m and 25 m deep, resulting 

in a total volume of 400 M L. The surface area was based on taking a value approximately five 

to six times the size of the barge that would allow a tug to move around in the enclosed port. In 

reality, the volume of water is going to be much greater and will also be influenced by water 

flow from the river as well as potential tidal influences. In this example the volume of water is 

assumed to be a closed system with no contribution of flow or tide that would dilute copper 
 

70

concentrations further. Based on this 400 M L volume and the total load of copper from a barge 

4,179 sq meters discharging 50 μg Cu/ cm2

/day of copper, the estimated copper concentration 

would be 0.52 μg/L. This value is below the threshold range of 0.59 and 2.0 μg/L which 

suggests the risk of copper to salmonids is low. The exposure value should not be interpreted as 

actual copper levels that could result from current barge use in ports along the Columbia River. 

The exposure value is extremely conservative since it assumes a relatively high rate of leaching 

would occur uniformly across the entire surface area of the largest possible barge that could be 

used. Also, as discussed above, the leaching is occurring into a comparatively small water body 

than would occur at an actual port without any flow. Significantly more dilution would be 

expected in ports and rivers where flowing water and tidal fluctuations would dilute copper 

concentrations. In addition, the calculated exposure concentration in this assessment assumes 

that 100% of the copper is bioavailable and in the dissolved phase which would not be the case 

in natural waters that would contain suspended solids, organic carbon, acid volatile sulfides as 

well as having other water quality parameters that would affect the concentration of dissolved 

copper (Comber et al. 2002). 

Based on this assessment, APHIS has determined that anti-hull fouling treatments may affect, 

but are not likely to adversely affect listed salmonids in the Columbia River. In addition, use of 

such treatments may prevent invasive species from being carried into the Columbia River. 

References:

Comber, S.D.W., G.Franklin, M.J. Gardner, C.D. Watts, A,B.A. Boxall and J. Howcraft. 2002. 

Partitioning of marine antifoulants in the marine environment. Science of the Total Env. 

286:61-71. 

Hecht, S.A., D.H. Baldwin, C.A. Mebane, T. Hawkes, S.J. Gross and N.L. Scholz. 2007 An 

overview of sensory effects on juvenile salmonids exposed to dissolved copper: Applying a 

benchmark concentration approach to evaluate sublethal neurobehavioral toxicity. U.S. Dept. 

Commer., NOAA Tech. Memo. NMFS-NWFSC-83, 39 pp. 

United Stated Department of the Interior. 1998. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; determination of threatened status for the Klamath River and 

Columbia River distinct population segments of bull trout. Federal Register, Vol. 63, p. 31674, 

June 10, 1974. 

United Stated Department of the Interior. 2005. Fish and Wildlife Service. Endangered and 

Threatened Wildlife Plants; Designation of Critical Habitat for the Bull Trout; Final Rule. 

Federal Register, Vol. 70, p. 56211-56260, September 26, 2005. 

U.S. Fish and Wildlife Service, 2002. Chapter 20, Lower Columbia Recovery Unit, Washington. 

89. p. In: U.S. Fish and Wildlife Service. Bull Trout (Salvelinus confluentus) Draft Recovery 

Plan. Portland, Oregon. 

Valkirs, A.O., P.F. Seligman, E. Haslbeck, J.S. Caso. 2003. Measurement of copper release 

rates from antifouling paint under laboratory and in situ conditions: implications for loading 
 

71

estimation to marine water bodies. Marine Pollution Bulletin. 46: 763-779. 

van Hatttum, B., A.C. Baart and J.G. boon. 2002. Computer model to generate predicted 

environmental concentrations (PECs) for antifouling products in the marine environment. 2nd

edition accompanying the release of Mam-Pec version 1.4. Report Number E-02-04/Z 3117. 73 

pp. 

Listed Species That Could be Struck by Trucks or Trains Transporting GRG 

From the Barge Off-load Site to the Designated Landfill 

The assessments for listed species that could be struck by trucks or trains have been combined 

and it follows the species accounts. 

Columbian White-tailed Deer, Columbia River DPS, Odocoileus virginianus leucurus

Status: The Columbia River DPS of the Columbian white-tailed deer was listed as endangered 

on March 11, 1967 (USDOI, FWS, 1967). 

Pertinent Species Information: The Columbian white-tailed deer is one of 38 recognized 

subspecies of virginianus, a species with a continuous geographic distirbution that extends from 

southern Canada to South America. There are 2 distinct population segments (DPS) of the 

Columbia white-tailed deer. The Columbia River DPS is located along the lower Columbia 

River. The Douglas County DPS, also known as the Roseburg population, located 320 km south, 

has been delisted because of recovery. 

The Columbian white-tailed deer was formerly locally common in the bottomlands and prairie 

woodlands of the lower Columbia, Willamette, and Umpqua river basins in Oregon and southern 

Washington. It has been reduced to two distinct populations (NatureServe, 2007). The 

Columbia River DPS occurs on both banks of the river in Clatsop and Columbia counties, 

Oregon, and Wahkiakum and Cowlitz counties, Washington (NatureServe, 2007). Most of these 

occur along the lower Columbia River in Oregon and Washington from Wallace Island (RM 50) 

downstream to Karlson Island (RM 32). 

It prefers wet prairie and lightly wooded bottomlands or "tidelands" along streams and rivers; 

woodlands are particularly attractive when interspersed with grasslands and pastures. Along the 

Columbia River, Sitka spruce, dogwood, cottonwood, red alder, and willow dominate the 

vegetation; in inland habitats, and along the Umpqua River, the tree community consists of 

Oregon white oak, madrone, California black oak, and Douglas-fir, with a shrubby ground cover 

of poison oak and wild rose (NatureServe, 2007). 

Reasons for decline include habitat degradation, automobile collisions, poaching, entanglement 

in barbed wire fences, competition with livestock, flooding, disease and parasites, black-tailed 

deer competition and hybridizationand Roosevelt elk competition (FWS, 1983). 

References: 
 

72

NatureServe. 2007. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 6.2. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: August 14, 2007 ). 

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal 

Register, Vol. 32, p. 4001, March 11, 1967. 

U.S. Fish and Wildlife Service (FWS). 1983. Revised Columbian White-tailed Deer Recovery 

Plan. U.S. Fish and Wildlife Service, Portland, OR, 75 pp. 

Canada Lynx, Lynx canadensis 

Status: The Canada lynx was listed as a threatened species on March 24, 2000 (USDOI, FWS, 

2000). Cirtical habitat was designated on November 9, 2006 (USDOI, FWS, 2006). 

Pertinent Species Information: The Canada lynx is a medium-sized cat, similar to the bobcat 

but with longer legs and very large, well-furred paws -- adaptations to the deep winter snows 

typical throughout its range. It also has unique long tufts of hair on the ears and a short, blacktipped tail. Adult males average 22 pounds in weight and 33.5 inches in length while females 

are somewhat smaller. 

From NatureServe, 2004: In the contiguous United States, the Canada lynx is considered 

historically resident in 16 states represented by five ecologically distinct regions: Cascade Range 

(Washington, Oregon), northern Rocky Mountains (northeastern Washington, southeastern 

Oregon, Idaho, Montana, western Wyoming, northern Utah), southern Rocky Mountains 

(southeastern Wyoming, Colorado), northern Great Lakes (Minnesota, Wisconsin, Michigan ), 

and northern New England (Maine, New Hampshire, Vermont, New York, Pennsylvania, 

Massachusetts). Resident populations currently exist only in Maine, Montana, Washington, and 

possibly Minnesota. The lynx is considered extant but is no longer sustaining self-supporting 

populations in Wisconsin, Michigan, Oregon, Idaho, Wyoming, Utah, and Colorado. It may be 

extirpated from New Hampshire, Vermont, New York, Pennsylvania, and Massachussets 

(USDOI, FWS, 1998). In Canada, the lynx is still widespread and relatively abundant in most of 

historic range. 

Lynx are highly dependent on snowshoe hare, but when hare populations drop they also prey on 

other small mammals and birds. This change in diet causes sudden drops in the productivity of 

adult females and survival of young. Prey scarcity suppresses breeding and may result in 

mortality of nearly all young (Brand and Keith, 1979). 

In the western United States, lynx live in subalpine coniferous forests of northern latitudes. The 

U.S. Forest Service et al. (1993) listed three primary habitat components for lynx in the Pacific 

Northwest: (1) foraging habitat (15-35-year-old lodgepole pine) to support snowshoe hare and 

provide hunting cover, (2) denning sites (patches of >200-year-old spruce and fir, generally less 

than 5 acres, and (3) dispersal/travel cover (variable in vegetation composition and structure). 

Early successional forest stages provide habitat for the lynx's primary prey, the snowshoe hare. 
 

73

The home range of a lynx can be 5 to 94 square miles and they are capable of moving long 

distances in search of food. 

Canada lynx avoid openings such as clearcuts and grasslands because snowshoe hares also are 

unlikely to use such areas, and because these areas lack the cover necessary for both species. 

Forest management practices that result in the loss of diverse age structure, fragmentation, 

roading, urbanization, agriculture, recreational developments, and unnatural fire frequencies 

have altered suitable habitat in many areas. As a result, many states may have insufficient habitat 

quality and/or quantity to sustain lynx or their prey. Human access into habitat has increased 

dramatically over the last few decades contributing to direct and indirect mortality and 

displacement from suitable habitat. Although legal take is highly restricted, existing regulatory 

mechanisms may be inadequate to protect small, remnant populations or to conserve habitat. 

Competition with bobcats and coyotes may be a concern in some areas (NatureServe, 2004). 

References:

Brand, C. J., and L. B. Keith. 1979. Lynx demography during a snowshoe hare decline in 

Alberta. J. Wildl. Manage. 43:827-849. 

NatureServe. 2004. NatureServe Explorer: An online encyclopedia of life [web application]. 

Version 4.0. NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. 

(Accessed: September 14, 2004 ). 

United States Department of the Interior. 1998. Endangered and Threatened Wildlife and Plants: 

 Proposal To List the Contiguous United States Distinct Population Segment of the Canada 

Lynx; Proposed Rule. Federal Register, Vol. 63, p. 36993, July 8, 1998. 

United States Department of the Interior. 2000. Endangered and Threatened Wildlife and Plants: 

 Determination of Threatened Status for the Contiguous U.S. Population Segment of the Canada 

Lynx and Related Rule. Federal Register, Vol. 58, p. 16085, March 24, 2000. 

United States Department of the Interior. 2006. Endangered and Threatened Wildlife and 

Plants; Designation of Critical Habitat for the Contiguous United States Distinct Population 

Segment of the Canada Lynx; Final Rule. Federal Register, Vol. 71, p. 66007-66061, November 

9, 2006. 

U.S. Forest Service, et al. 1993. Draft supplemental environmental impact statement on 

management of habitat for late-successional and old-growth forest related species within the 

range of the northern spotted owl. Published separately is Appendix A: Forest Ecosystem 

Management Assessment Team. 1993. Forest ecosystem management: an ecological, economic, 

and social assessment (FEMAT Report). 
 

74

Grizzly (Brown) Bear, Ursus arctos horribilis 

Status: The grizzly bear was listed as a threatened species on March 11, 1967 (USDOI, FWS, 

1967). On November 17, 2000, the grizzly bear was designated as a non-essential, experimental 

population in the United States in portions of ID and MT (USDOI, FWS, 2000). 

Pertinent Species Information: Grizzly bears are generally larger than black bears and can be 

distinguished by longer curved claws, humped shoulders, and a face that appears to be concave. 

A wide range of coloration from light brown to nearly black is common. Guard hairs are often 

paled at the tips, hence the name “grizzly.” Spring shedding, new growth, nutrition and climate 

all affect coloration (FWS, 1993). 

An occasional male may exceed 1,000 pounds but the average weight is closer to 500 - 600 

pounds. Females are generally smaller. Adults stand 3-1/2 to 4-1/2 feet at the hump when on all 

fours, and they may rear up on their hind legs to over eight feet (FWS, 1993). 

The muscle structure in grizzly bears is developed for massive strength, quickness, and running 

speeds up to 25 miles per hour. Movement includes the normal position on all fours and an 

upright position on the hind legs which improves the opportunity to see and smell (FWS, 1993). 

Grizzlies are omnivorous and consume carrion, rodents, fish, grasses, roots, berries, fruits and 

leaves at varying times of the year. The bears are typically carnivorous during the pregrowing 

season. As summer progresses and into the fall they began to feed on vegetable matter. They 

are opportunistic feeders and will prey or scavenge almost any available food (FWS, 1993). 

Optimum habitat includes extensive timbered areas adjacent to grassland/herbland, shrubland, or 

other open feeding sites. Forest cover is very important to grizzly bears fro use as beds (FWS, 

1993). In the fall, grizzly bears excavate dens for winter hibernation. Dens are in isolated areas 

that will be covered with a thick blanket of snow to prevent escape of body-warmed air (FWS, 

1993). 

Breeding occurs in late May or early June and delayed implantation occurs at about the time that 

the females enter dens in late October through November. One or two cubs are born in January 

or February and remain with the mother for about 2.5 years. Due to the length of time it takes to 

wean the cubs, females only breed every second or third year. 

Grizzly bears are normally solitary and shy animals which require large amounts of isolated 

acreage in which to wander. The occurrence of the bear in North America has been only where 

spacious habitat insulated it from excessive human-related mortality. Populations in the 48 

contiguous States have survived primarily due to the preservation of suitable habitat, as required 

by the Wilderness Act of 1964. 

In the conterminous 48 States, only six areas are known to contain either self-perpetuating or 

remnant populations. Only 1,000 to 1,100 grizzly bears remain in a few isolated populations in 

Montana, Wyoming, Idaho, and Washington (USDOI, FWS, 2000). 

Reasons for decline of the grizzly bear include human-caused mortality and loss of habitat 

(USDOI, FWS, 2000). 
 

75

References: 

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal 

Register, Vol. 32, p. 4001, March 11, 1967. 

United States Department of the Interior. 2000. Endangered and Threatened Wildlife and Plants: 

Establishment of a Nonessential Experimental Population of Grizzly Bears in the Bitterroot Area 

of Idaho and Montana. Federal Register, Vol. 65, p. 69623, November 17, 2000. 

U.S. Fish and Wildlife Service. 1993. Grizzly bear recovery plan. Missoula, MT. 181 pp. 

Northern Idaho Ground Squirrel, Spermophilus brunneus brunneus 

Status: The Northern Idaho ground squirrel was listed as a threatened species on April 5, 2000 

(USDOI, FWS, 2000). 

Pertinent Species Information: The Northern Idaho ground squirrel is a relatively small 

member of the genus Spermophilus with males typically measuring 9.25 inches -- slightly longer 

than the average female. 

The Northern Idaho ground squirrel emerges in late March or early April, remains active above 

ground until late July or early August, and spends the rest of the year in hibernation underground 

(Yensen and Sherman, 1997). Seasonal torpor (a state of sluggishness or inactivity) generally 

occurs in early to mid-July for males and females, and late July to early August for juveniles. 

Northern Idaho ground squirrels consume the roots, bulbs, leaf stems, and flower heads of 45 to 

50 plant species during spring and summer (Dyni and Yensen, 1996). Seeds of forbs, lupines, 

and composites are important, while roots, bulbs, leaf stems, and flower heads are a minor 

component of their diet (FWS, 2003). To store energy for winter, the ground squirrel must 

consume large amounts of seed from Poa species (bluegrass) and other grasses (Dyni and 

Yensen, 1996). 

 

The Northern Idaho ground squirrel often digs burrows under logs, rocks, or other objects. Dry 

vegetation sites with shallow soil horizons above basalt bedrock are preferred. Nesting burrows 

are found in well-drained soils greater than 3 feet deep (Yensen et al., 1991), in areas not 

covered with trees or used by Columbian ground squirrels. 

The Northern Idaho ground squirrels is known to occur in dry, rocky meadows associated with 

deeper, well-drained soil surrounded by coniferous forests of ponderosa pine and/or Douglas-fir 

at elevations of 3,000 to 5,400 feet in Adams and Valley Counties of western Idaho (FWS, 

2003). 

In the spring of 2002, the northern Idaho ground squirrel population was estimated to be 450 to 

500 animals (FWS, 2003). It is primarily threatened by habitat loss due to forest encroachment 

into meadow habitats (FWS, 2003). The subspecies is also threatened by competition from the 
 

76

larger Columbian ground squirrel, land use changes, recreational shooting, poisoning, genetic 

drift, genetic isolation, and naturally occurring events (FWS, 2003). 

References:

Dyni, E. and E. Yensen. 1996. Dietary similarity in sympatric Idaho and Columbian ground 

squirrels (Spermophilus brunneus and Spermophilus columbianus). Northwest Science. 70:99–

108. 

United States Department of the Interior. 2000. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; Determination of Threatened Status for the Northern Idaho 

Ground Squirrel. Federal Register, Vol. 65, p. 17786, April 5, 2000. 

U.S. Fish and Wildlife Service. 2003. Recovery Plan for the Northern Idaho Ground Squirrel 

(Spermophilus brunneus brunneus). Portland, Oregon, 68 p. 

Yensen, E., M.P. Luscher, and S. Boyden. 1991. Structure of burrows used by the Idaho ground 

squirrel, Spermophilus brunneus. Northwest Science. 65:93–100. 

Yensen, E. and P.W. Sherman. 1997. Spermophilus brunneus. Mammalian Species. 560: 1–5. 

Woodland Caribou, Rangifer tarandus caribou 

Status: The woodland caribou was listed as an endangered species on January 14, 1983 

(USDOI, FWS, 1983). 

Pertinent Species Information: The woodland caribou is a brown hoofed mammal with large 

mossy antlers, and a hanging neck mane. Adult bulls weigh up to 270 kg but average about 180 

kg. Cows average 115 kg. Both males and females grow antlers but cows' are shorter and have 

fewer points. 

Most remain in forested habitats year-round. They migrate 80 km or more between their 

forested foothills winter range and alpine summer range. The woodland caribou's habitat 

consists of forested mountain regions and it prefers dense stands of fir and spruce. The 

woodland caribou's major food sources are arboreal lichens and they depend on them for up to 

six months of the year (FWS, 1993). They also eat huckleberry leaves, boxwood, and smooth 

woodrush during the spring and summer (FWS, 1993). 

Caribou mate in early to mid-October. Calves are born by early June. Pregnant females move to 

typical spring habitat in April or May, then move back onto snow-covered areas often at higher 

elevations to calve (FWS, 1993). This behavior may function to avoid predators, thus increasing 

calf survival (Servheen and Lyon, 1989). A cow first calves at 3 years of age and will usually 

have one calf per year. 

Historically, this species once populated most of the northern portion of the United States, 

ranging from New England to Washington. The only surviving populations in the United States 

are found in the Selkirk Mountain ecosystem of Idaho and Washington. All other populations 

within the lower 48 states have been extirpated. 
 

77

Threats to the woodland caribou include logging, coal mining, and oil and gas exploration which 

have greatly reduced the woodland caribou's habitat. When large areas of old-growth coniferous 

forests are logged, moose, deer and elk populations increase. As their prey become more 

plentiful, more wolves move in. Woodland caribou are most vulnerable to wolves so they suffer 

the greatest losses. 

References:

Servheen, G. and J. Lyon. 1989. Habitat use by woodland caribou in the Selkirk Mountains. J. 

Wildlife Management. 53:230–237. 

United States Department of the Interior. 1983. Endangered and Threatened Wildlife and Plants: 

 Emergency Determination of Endangered Status for the Population of Woodland Caribou Found 

in Washington, Idaho, and Southern British Columbia. Federal Register, Vol. 48, p. 1726, 

January 14, 1983. 

U.S. Fish and Wildlife Service. 1993. Recovery Plan for Woodland Caribou in the Selkirk 

Mountains. Portland, OR. 71 pp. 

Gray Wolf, Canis lupus

Status: The gray wolf has been designated as threatened in the western distinct population 

segment (CA, ID, MT, NV, OR, WA, WY, UT north of U.S. Highway 50, and CO north of 

Interstate Highway 70, except where listed as an experimental population). 

Designation of a Northern Rocky Mountain Gray Wolf Distinct Population Segment (Montana, 

Wyoming, Idaho, eastern Washington, eastern Oregon, and north central Utah) has been 

proposed and this population has been proposed for delisting (USDOI, FWS, 2007). 

Critical habitat was designated for this species on March 9, 1978 (USDOI, FWS, 1978) but does 

not occur in the program area. 

Pertinent Species Information: The gray wolf is a member of the Canidae family and 

resembles a large dog, but differs in having relatively longer legs, larger feet, and narrower 

chest. Wolves also have tails that are straight rather than curved upward posteriorly like those of 

dogs. Total length is about 51 to 71 inches, and weight is above 44 to 176 pounds for males. 

Wolves live in groups or packs, consisting generally of two to eight members (FWS, 1992). 

Packs are primarily family groups, consisting of a breeding pair, their pups from the current year, 

offspring from the previous year, an occasionally, an unrelated wolf. Packs defend a territory of 

20 to 214 square miles. 

Wolves gain sexual maturity in their second year, but often do not breed until the third. It is 

believed that wolves mate for life. The mating season may be any time between January and 

April depending upon locale. The gestation period is 63 days with an average of four to six pups 

(range of 1 to 11). Dens are usually in a sheltered place in a hole, rock crevice, or hollow log. 
 

78

Unlike most mammals, wolves do not construct or make use of shelters, except for dens used to 

give birth and rear young for about 2 months. Seasonal activity can be categorized into limited 

wanderings during the rest of the year (40 miles or more a day). Wolves prey on large mammals 

primarily--white-tailed and mule deer, caribou, moose, Dall sheep, bighorn sheep, and beaver. 

Only rarely are rodents and birds consumed. Wolves spend almost all of their waking time 

eating or hunting in packs, usually fewer than eight members. 

Gray wolves do not seem particular about habitat. They originally occurred in arctic tundra, 

taiga, plains or steppes, savannahs, and hardwood, softwood, and mixed forests (Chapman and 

Feldhamer, 1982). 

Reasons for decline include negative attitudes towards wolves by humans, leading to poisoning, 

trapping, shooting, and State and Federal bounties resulted in extirpation of this species from 

more than 95 percent of its range in the 48 coterminous states to scattered populations in 

northern Minnesota and the northern Rocky Mountains. 

References:

Chapman, J. A. and Feldhamer, G. [eds.]. 1982. Wild mammals of North America. Baltimore, 

MD: The Johns Hopkins University Press. 1147 p. 

United States Department of the Interior. 1967. Endangered Species List - 1967. Federal 

Register, Vol. 32, p. 4001, March 11, 1967. 

United States Department of the Interior. 1978. Endangered and Threatened Wildlife and Plants; 

Reclassification of the Gray Wolf in the United States and Mexico, With Determination of 

Critical Habitat in Michigan and Minnesota. Federal Register, Vol. 43, p. 9607, March 9, 1978. 

U.S. Fish and Wildlife Service. 1992. Recovery Plan for the Eastern Timber Wolf. Twin Cities, 

MN. 73 pp. 

United States Department of the Interior. 2003. Endangered and Threatened Wildlife and Plants; 

Final Rule To Reclassify and Remove the Gray Wolf From the List of Endangered and 

Threatened Wildlife in Portions of the Conterminous United States; Establishment of Two 

Special Regulations for Threatened Gray Wolves. Federal Register, Vol. 68, p. 15803, April 1, 

2003. 

United States Department of the Interior. 2007. Endangered and Threatened Wildlife and Plants; 

Designating the Northern Rocky Mountain Population of Gray Wolf as a Distinct Population 

Segment and Removing This Distinct Population Segment From the Federal List of Endangered 

and Threatened Wildlife; Proposed Rule. Federal Register, Vol. 72, p.6105-6139, February 8, 

2007 
 

79

Pygmy Rabbit (Columbian Basin Distinct Population Unit), Brachylagus idahoensis

Status: The pygmy rabbit (Columbian Basin Distinct Population Unit) was listed as an 

endangered species on November 30, 2001 (USDOI, FWS, 2001). 

Pertinent Species Information: The smallest rabbit species in North America, the pygmy 

rabbit measures 9.2-11.6 inches (23.5-29.5 cm) in length, weighs a slight 0.88-1.02 lbs (398-462 

g). The pygmy rabbit is typically colored brown/slate gray with short, white-margined, ears and 

a small tail. 

The breeding season of pygmy rabbits lasts from March through May in Idaho; in Utah, it lasts 

from February through March (Chapman and Feldhamer, 1982). The gestation period of pygmy 

rabbits is unknown. An average of six young are born perlitter and a maximum of three litters 

are produced per year (Green and Flinders, 1980).

Big sagebrush is the primary food source, but grasses and forbs are eaten in mid- to late summer 

(Green and Flinders, 1980; Lyman, 1991). Pygmy rabbits may be active at any time of day; 

however, they are generally most active at dusk and dawn. They usually rest near or inside their 

burrows during midday (Green and Flinders, 1980). Pygmy rabbits are generally limited to areas 

on deep soils with tall, dense sagebrush which they use for cover and food (Flath, 1994; Green 

and Flinders, 1980). Individual sagebrush plants in areas inhabited by pygmy rabbits are often 6 

feet or more in height (Flath, 1994). Extensive, well-used runways interlace the sage thickets 

and provide travel and escape routes (Green and Flinders, 1980). 

The pygmy rabbit is the only native leporid that digs burrows. Juveniles use burrows more than 

other age groups. Early reproductive activities of adults may be concentrated at burrows (Green 

and Flinders, 1980). Burrows are usually located on slopes at the base of sagebrush plants, and 

face north to east. Tunnels widen below the surface, forming chambers, and extend to a 

maximum depth of about 3.3 feet. 

A distinct population segment of the pygmy rabbit is found only in one area of Washington, 

Sagebrush Flat, and is nearly extinct. It has declined greatly in eastern Washington, from six 

colonies to probably just one, and from at least 150 individuals to fewer than 30 in the last 

decade (USDOI, FWS, 2001, 2003). Recently the Washington Department of Fish and Wildlife 

has initiated a captive-breeding program with hopes of revitalizing the population. Originally 

planning on crossbreeding with Idaho pygmies, the idea was scrapped in favor of preserving the 

Washington sub-species when it was found the two are genetically different (Pacific Diversity 

Institute, 2004). 

The loss of habitat is probably the most significant factor contributing to pygmy rabbit 

population declines. 

References:

Chapman, J. A. and Feldhamer, G. [eds.]. 1982. Wild mammals of North America. Baltimore, 

MD: The Johns Hopkins University Press. 1147 p. 
 

80

 

Flath, D. 1994. Bunnies by the bunch. Montana Outdoors. 25(3):8-13. 

Green, J. S. and J. T. Flinders. 1980. BRACHYLAGUS IDAHOENSIS. Mammalian Species. 

125:1-4. 

Lyman, R. L. 1991. Late Quaternary biogeography of the pygmy rabbit (BRACHYLAGUS 

IDAHOENSIS) in eastern Washington. J. Mamm. 72:110-117. 

Pacific Biodiversity Institute, Endangered Species Information Network. Pygmy Rabbit. 

<www.pacificbio.org/ESIN/Mammals/PygmyRabbit/pygmyrabbit.html> last accessed 

September 8, 2004. 

United States Department of the Interior. 2001. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants. Emergency Rule To List the Columbia Basin Distinct Population 

Segment of the Pygmy Rabbit (Brachylagus idahoensis) as Endangered. Federal Register, Vol. 

66, p. 59749, November 30, 2001. 

United States Department of the Interior. 2003. Fish and Wildlife Service. Endangered and 

threatened wildlife and plants; final rule to list the Columbia Basin Distinct Population Segment 

of the Pygmy Rabbit (Brachylagus idahoensis) as endangered. Federal Register, Vol. 68, p. 

10409, March 5, 2003. 

Program Assessment for Species that Could be Struck by Trucks or Trains: APHIS has 

determined that transport of GRG from Hawaii via rail or truck may affect, but is not likely to 

adversely affect the Columbian white-tailed deer (Columbia River DPS), Canada lynx, grizzly 

bear, northern Idaho ground squirrel,woodland caribou, gray wolf, and pygmy rabbit (Columbian 

Basin Distinct Population Unit) for the following reasons: 

• Only currently established routes will be used. No new railways or roads will be 

constructed. 

• No spillage of garbage is likely –the chance of an accident is low, and bales are tied 

down to the trucks and/or railcars. If a spill were to occur, very low amounts of 

greenwaste (< 3 percent) are in the bales and will not attract bears or other animals to 

forage and be struck by trains or trucks. 

• There will be only a slight increase in rail or truck traffic as a result of the proposed 

action. Rail traffic is expected to increase by only less than 1 percent in Oregon and 

Washington, and by 3 percent in Idaho. These estimates of rail increase are very 

conservative and assume that all of the GRG from Hawaii would be transported by rail, a 

scenerio that is unlikely. Truck/highway transport of freight would increase by only 0.2, 

0.1, and 0.5 percent in Oregon, Washington, and Idaho, respectively. Again, this assumes 

that all GRG would be transported by truck to landfills. 
 

Discussion of Remaining Species and Designated Critical Habitat That Occur

81

in Washington, Oregon, and Idaho. 

If plant pests from Hawaii were to escape and establish in the environments of Washington, 

Oregon, and Idaho, some of these might attack federally-listed plants. However, APHIS has 

determined that there will be no effect on the following plant species (table 3) or designated 

critical habitat of the Wenatchee Mountains checkermallow because of the negligible risk of pest 

escape and establishment of Hawaiian plant pests in Washington, Oregon, and Idaho, as 

described previously in this document and determined in the APHIS risk assessments (see 

appendices C-F). 

Table 3. Listed Plants in Idaho, Oregon, and Washington. 

Common Name Scientific Name State of 

Occurrence 

Listing 

Status 

Critical 

Habitat? 

Applegate’s milk-vetch Astragalus applegatei OR E No 

Bradshaw’s desert parsley Lomatium bradshawii WA, OR E No 

Cook’s lomatium Lomatium cookii OR E No 

Gentner’s fritillary Fritillaria gentneri OR E No 

Golden paintbrush Castilleja levisecta WA T No 

Kincaid’s lupine Lupinus sulphureus ssp. 

kincaidii 

WA, OR T No 

Large-flowered woolly 

meadowfoam 

Limnanthes floccosa ssp. 

grandiflora 

OR E No 

MacFarlane’s four-o’clock Mirabilis macfarlanei ID, OR T No 

Nelson’s checkermallow Sidalcea nelsoniana WA, OR T No 

Rough popcornflower Plagiobothrys hirtus OR E No 

Showy stickseed Hackelia venusta WA E No 

Spalding’s catchfly Silene spaldingii ID, WA, OR T No 

Ute ladies’tresses Spiranthes diluvialis ID, WA T No 

Water howellia Howellia aquatilis ID, WA, OR T No 

Wenatchee Mountains 

checkermallow 

Sidalcea oregana var. 

calva 

WA E Yes 

Western lily Lillium occidentale OR E No 

Willamette daisy Erigeron decumbens var. 

decumbens 

OR E No 

Certain birds have been discussed previously in this BA because of the possibility of being 

struck by trucks or trains carrying baled GRG. However, APHIS has determined that the 

proposed action will have no effect on the following birds (table 4) or the critical habitat of the 

marbled murrelet because they would not occur in areas where they could be struck by trucks or 

trains carrying GRG. 
Table 4. Listed Birds in Washington, Oregon, and Idaho not mentioned previously in this document. 

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Common Name Scientific Name State of 

Occurrence 

Listing Status Critical 

Habitat? 

Brown pelican Pelecanus 

occidentalis 

WA, OR E No 

Eskimo curlew Numenius borealis ID, OR E (likely 

extinct) 

No 

Marbled murrelet Brachyramphus 

marmoratus 

WA, OR T Yes 

Northern spotted owl Strix occidentalis 

caurina 

WA, OR T Yes 

Short-tailed albatross Phoebastria albatrus WA E No 

Fish species occurring in the mainstem Columbia River have been discussed previously in this 

document as potentially being affected by decreased water quality from oil/fuel spillage or GRG 

bales dropped and broken in the Columbia River at the barge unloading point. However, APHIS 

has determined that there will be no effect on the following aquatic species or their critical 

habitat (table 5) because they do not occur in the mainstem Columbia River where GRG bales 

would be barged. 
 

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Table 5 Listed aquatic species in Washington, Oregon, and Idaho but not occurring in the 

Columbia River. 

Common Name Scientific Name State of 

Occurrence 

Listing Status Critical 

Habitat? 

Banbury Springs limpet Lanx sp. ID E No 

Bliss Rapids snail Taylorconcha 

serpenticola 

ID T No 

Borax Lake chub Gila boraxobius OR E Yes 

Bruneau hot springsnail Pyrgulopsis 

bruneauensis 

ID E No 

Foskett speckled dace Rhinichthys osculus 

ssp. 

OR T No 

Hood Canal summer-run 

chum salmon 

Oncorhynchus keta WA T Yes 

Hutton tui chub Gila bicolor ssp. OR T No 

Lahontan cutthroat trout Oncorhynchus clarki 

henshawi 

OR T No 

Lost River sucker Delistes luxatus OR E No 

Oregon coast Coho 

salmon 

Oncorhynchus kisutch OR T Yes 

Oregon chub Oregonichthys 

crameri 

OR E No 

Ozette Lake sockeye 

salmon 

Oncorhynchus nerka WA T Yes 

Puget Sound chinook 

salmon 

Oncorhynchus 

tshawytscha 

WA T Yes 

Shortnose sucker Chamistes brevirostris OR E No 

Snake River physa snail Physa natricina ID E No 

Utah valvata snail Valvata utahensis ID E No 

Vernal pool fairy shrimp Branchinecta lynchi OR T Yes 

Warner sucker Catostomus 

warnerensis 

OR T Yes 

White sturgeon, Kootenai 

River system 

Acipenser 

transmontanus 

ID E Yes 

APHIS has determined that there would be no direct effects on the listed butterflies from the 

proposed action (table 6). In addition there would be no indirect effects caused by plant pests 

escaping and establishing in the environment to attack host plants of these species. Therefore 

APHIS has determined that the proposed action would have no effect on the Oregon silverspot 

and Fender’s blue butterflies or the critical habitat of the Oregon silverspot. 
 

84

Table 6. Listed butterfly species occurring in Washington and Oregon (none are listed in 

Idaho). 

Common Name Scientific Name State of 

Occurrence 

Listing Status Critical 

Habitat? 

Fender’s blue butterfly Icaricia icarioides 

fenderi 

OR E No 

Oregon silverspot 

butterfly 

Speyeria zerene 

hippolyta 

WA, OR T Yes 
 

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Appendix A. Compliance Agreements 

1. Example Compliance Agreement for Movement of GRG Bales From 

Hawaii 

UNITED STATES DEPARTMENT OF AGRICULTURE 

ANIMAL AND PLANT HEALTH INSPECTION SERVICE 

PLANT PROTECTION AND QUARANTINE 

COMPLIANCE AGREEMENT

According to the Paperwork Reduction Act of 1995, no persons are required to 

respond to a collection of information unless it displays a valid OMB control 

number. The valid OMB control number for this information collection is 0579-

0054. The time required to complete this information collection is estimated to 

average 1.25 hours per response, including the time for reviewing instructions, 

searching existing data sources, gathering and maintaining the data needed, 

and completing and reviewing the collection of information.

1. NAME AND ADDRESS OF PERSON OR FIRM 

Hawaiian Waste Systems, LLC 

91-165 Kalaeloa Boulevard 

Kapolei, HI 96810

2. LOCATION 

 Kapolei, HI 

3. REGULATED ARTICLE(S) 

 Garbage and Regulated (domestic) Garbage from Honolulu, Hawaii

4. APPLICABLE FEDERAL QUARANTINE(S) OR REGULATIONS 

7 CFR 330.400, 7 CFR 318.13, 7 CFR 318.47, 7 CFR 318.30, 7 CFR 318.60, 9 CFR 94.5 , 

5. PORTS OF COVERAGE: 

Honolulu, Hawaii Areas (Covered by) USDA OFFICES IN: Honolulu. 

 

6. I/We agree to the following: 

General

This Compliance Agreement (CA) on Garbage and Regulated (domestic) Garbage Handling 

Procedures authorizes Hawaii Waste Systems, LLC (HWS) and its authorized representatives to 

handle and transport Garbage and Regulated (domestic) Garbage from Honolulu, Hawaii to the 

Roosevelt Regional Landfill, Washington, in accordance with the provisions of the applicable 

Federal Quarantines and the Administrator’s approval and under the following conditions approved 

by the United States Department of Agriculture, Animal Plant Health Inspection Service, Plant 

Protection and Quarantine (USDA, APHIS, PPQ). Specifically, this Compliance Agreement applies 

to the baling, wrapping, and handling of Garbage and Regulated (domestic) Garbage from the city 

and county of Honolulu, Hawaii. The bales are to be free of all agricultural waste and wrapped 

according to APHIS regulations. The bales are to be transported from Honolulu by barge to 

Roosevelt, Washington, and then buried without breaking and spreading waste in accordance with 

the regulations for solid waste disposal and all applicable Federal, State, and Local ordinances. All 

Foreign Garbage, not of Hawaii origin, is specifically prohibited from movement under this 

compliance agreement. 

DEFINITIONS 

Terms found in the agreement shall refer to the following: 
 

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Agricultural waste - Byproducts generated by the rearing of animals and the production 

and harvest of crops or trees. Animal waste, a large component of agricultural waste, 

includes (e.g.) feed waste, bedding and litter, and feedlot and paddock runoff from 

livestock, dairy, and other animal-related agricultural and farming practices. 

Bale means the confined unit of Garbage and Regulated (domestic) Garbage that has 

been approved for transport and burial. Bales are formed meeting all APHIS 

requirements in 7CFR330. 

Barge means the conveyance via ocean and the Columbia River on which the baled 

Garbage and Regulated (domestic) Garbage will be carried. 

Collections of agricultural waste and yard waste refers to bulk collections/pick-up of 

waste which is made up of primarily agricultural waste and yard waste. All collections of 

agricultural and yard waste shall not be accepted.

Commingling means the mixing of any regulated and non-regulated materials (including 

incinerated ash) within the bales, at any staging or transport area. 

Company Name – Hawaiian Waste Systems, LLC; (HWS)

Compression refers to the process in which the waste articles are crushed under high 

pressure, expelling air from, and compacting waste articles into a high density bale. 

Foreign garbage means all materials, associated with fruits, vegetables, meats or animal 

products, that have been removed (in Hawaii) from any means of conveyance originating 

from a port outside the continental United States (including Alaska) or Canada, which 

has not been treated in accordance with 7 CFR part 330 for foreign pests and animal 

diseases. The disposal method described in this compliance agreement has not been 

evaluated for the risk of animal diseases. 

Garbage is defined as urban (commercial and residential) solid waste from 

municipalities on any Hawaiian island. 

HWS refers to Hawaiian Waste Systems, LLC, 91-165 Kalaeloa Boulevard, Kapolei, 

HI 96707. It is the location of the HWS Transfer Station operated by HWS 

Inspector A properly identified employee of the USDA or other person authorized by 

the USDA to enforce the provisions of the Plant Protection Act and related legislation, 

quarantines, and regulations. 

Offloading means to move bales from the means of conveyance to its final destination 

spot; the bales will not be placed on any other means of conveyance. 

Patch is made of impermeable film made of low density polyethylene, of at least 16 

micrometers thickness, that is coated on one side with a non-hardening mastic/adhesive. 
 

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The patch must be sufficient to establish an airtight seal. 

Plant pest means any living stage of any insects, mites, nematodes, slugs, snails, 

protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or 

reproductive parts thereof, viruses, noxious weeds, or any organisms similar to or allied 

with any of the foregoing, or any infectious substances which can directly or indirectly 

injure or cause disease or damage in any plants or parts thereof, or any processed, 

manufactured, or other products of plants. 

PPQ Hawaii means the local office of the United States Department of Agriculture, 

Animal Plant Health Inspection Service, Plant Protection and Quarantine (USDA, 

APHIS, PPQ), Port of Honolulu located at 3375 Koapaka Street, Honolulu, HI 96819, 

phone number, (808) 861-8446 and fax, (808) 861-8450. 

PPQ Washington means an office of the USDA, APHIS, PPQ in Washington State; 

located at 222 N. Habana Street, Spokane, WA 99202, phone number, (509)353-2950 and 

fax, (509)353-2637. 

Puncture - any hole which is found in the plastic of the bale which goes through all four 

layers of the wrapping. 

Regulated Garbage refers to waste articles generated in Hawaii that are restricted from 

movement to the continental U.S. under various quarantine regulations established to 

prevent the spread of plant pests (including insects, disease, and weeds) into areas where 

the pests are not prevalent. 

Roosevelt Regional Landfill refers to the landfill site located at 500 Roosevelt Grade 

Road, Roosevelt, Washington. 

Rupture refers to a rupture or tear in the wrapping film where an observer or inspector is 

able to see Garbage and Regulated (domestic) Garbage that is no longer covered by film. 

Shredding refers to the process used to reduce bulky articles into scraps. 

Soil means the loose surface material of the earth in which plants grow, in most cases 

consisting of disintegrated rock with an admixture of organic material and soluble salts. 

Staging Area refers to the defined area where bales with apparent air tight seals are held 

and monitored to ensure air tight integrity. The Staging Area is located at Barber’s Point, 

Pier 5 at Barber’s Point Deep Water Harbor located in Campbell Industrial Park, Kapolei, 

HI. Barber’s Point shall be the site of the secondary Wrapping Area, the Storage Area, 

the Transport Area and the barge loading site (unless APHIS-approved alternative site is 

designated). Attached hereto is a site map illustration the location of Barber’s Point and 

the operational sites as described herein. 

Tear - any rupture found in the plastic of the bales which goes through all four layers of 
 

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wrapping. 

Transloading means the movement of regulated articles from one means of conveyance 

to any other means of conveyance. 

Transport Area refers to the location where bales approved for movement onto the 

barge are positioned for loading. The transport area is located at Barber’s Point, Pier 5 at 

Barber’s Point Deep Water Harbor located in Campbell Industrial Park, Kapolei, HI. 

Washington compliance agreement refers to the agreement between PPQ Washington 

and Hawaiian Waste Systems, LLC, 1011 SW Klickitat Way #C-109, Seattle, WA 

98134.

Wrapping - The wrapping material shall be an impermeable film made of low density 

polyethylene, of at least 16 micrometers thickness, that is coated on one side with a nonhardening mastic/adhesive. Bales are mechanically wrapped to achieve an air tight seals. 

Wrapping Area refers to the station where the bale wrapping machinery is located. The 

wrapping equipment should be located at each point where bales are handled. The two 

wrapping areas identified for this compliance agreement are: The initial wrapping area 

shall be located at HWS Transfer Station at 91-165 Kalaeloa Blvd., Kapolei, Oahu; and a 

wrapping area will be located at Barber’s Point, Pier 5 at Barber’s Point Deep Water 

Harbor located in Campbell Industrial Park, Kapolei, HI. The HWS Transfer Station is 

located approximately [2.5] miles from the Barber’s Point Pier facility. Attached hereto 

is a map showing the relative locations of the two facilities and the proposed trucking 

route. 

Yard waste – Solid waste composed predominantly of grass clippings, leaves, twigs, 

branches, and other garden refuse. 

Collection of Garbage and Regulated (domestic) Garbage for transport

Garbage and Regulated (domestic) Garbage collected by refuse trucks shall be delivered to the 

HWS facility at HWS Transfer Station at 91-165 Kalaeloa Blvd., Kapolei, HI 96707. Trucks of 

agricultural waste and yard waste shall not be accepted. Waste materials, containers, and bins 

associated with Foreign Garbage are strictly prohibited and shall not be accepted. The ground 

surface of the all areas for handling the Garbage and Regulated (domestic) Garbage should be 

level, solid, and impervious surface of asphalt or cement. 

The risk assessments for the movement of Garbage and Regulated (Domestic) Garbage were 

conducted based on the specific details provided by HWS. These details included the exclusion 

of incinerator ash and the removal of all hazardous and liquid waste prior to baling. HWS will 

notify PPQ if the company plans change to include such materials so that the proper risk 

assessments can be conducted. 

Preparation and Baling of Garbage and Regulated (domestic) Garbage for transport 
 

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The following is a description of the Garbage and Regulated (domestic) Garbage waste handling 

and processing steps: 

The waste transfer station will receive only household and commercial waste acceptable for 

disposal at Roosevelt Regional Landfill. Collection trucks will deliver waste picked up from 

existing collection routes. After waste is tipped onto the tipping floor it will be inspected for 

unacceptable waste including yard waste, (other than incidental amounts not to exceed 3% of the 

total waste stream pursuant to 7 CFR Part 330), agricultural waste, industrial waste, infectious 

waste, loads predominantly of construction and demolition waste and regulated hazardous waste. 

 Any segregated unacceptable waste will be separated for further processing. Loads consisting 

predominately of construction and demolition (C&D) waste will be transferred to a C&D 

handling facility. Other waste will be drummed or otherwise contained and arrangements made 

for its proper transportation and disposal. Notwithstanding the foregoing, it is acknowledged 

and agreed that follow-up inspection of the route that was the source of the unacceptable waste 

will be conducted to try to locate the source and correct the waste handling process that allowed 

unacceptable waste to be collected. 

Each load of waste received at the facility will be weighed and the date, time, company, driver 

name, truck number (i.e., company fleet number), weight (loaded), weight (empty), and origin of 

load, will be recorded. Records will be kept for a minimum of three years. 

Step-by-step waste receiving and processing description is as follows: 

1. Waste is delivered by collection truck to the HWS Transfer Station. The truck is 

weighed and then proceeds to the baling facility where it tips its waste onto the tipping 

floor. The collection truck is weighed again as it exits the site and continues on its 

collection routes. A weigh ticket is generated and kept on file. 

2. A loader operator inspects the waste and segregates any non-household or noncommercial waste. Household and commercial waste is pushed onto the in-feed 

conveyor by the loader. Segregated waste is set aside and handled separately as 

described previously.

3. Garbage and Regulated (domestic) Garbage moves along the conveyor to the intake feed 

of the baler. The baler operator introduces waste into the baler where it is compressed 

using a compactor that produces bale densities of approximately 1000 kg per cubic meter 

for the most waste materials. The same force compaction will be used regardless of the 

material in the processing line. Companies will provide documentation of the equipment 

used and compactor specifications. The baler operator monitors the baler operation and 

replaces baling wire or strapping and makes other adjustments as needed. 

4. The compacted bale moves from the baler via conveyor belt to the plastic wrapper. The 

plastic wrapper automatically wraps the bale with a minimum of 4 layers of prestretched, mastic-backed polyethylene plastic, of at least 16 micrometers thickness, and 

extrudes it onto a roller conveyor. The baler operator or loader operator will inspect each 

bale for integrity of the plastic wrap. Any bale with unsatisfactory wrapping will be resent through the wrapper. 

5. The wrapped bale moves down the roller conveyor and is removed by a loader with a 

special attachment that picks up the bale by squeezing it between two hydraulically 
 

90

operated smooth faced arms, or another piece of equipment designed to handle the bales 

without tearing or damaging them in any way. The smooth faced arms prevent damage to 

the plastic wrap. 

6. The loader moves the bale onto the bale storage area - which has a solid, impervious 

(concrete or asphalt) surface that is kept free of soil or other contaminants -- or directly 

onto a flat bed truck, if one is available. The loader then returns to pick up another bale 

from the roller conveyor. 

7. Bales that are placed onto the bale storage area will be loaded onto flat bed trucks as they 

become available. 

8. Flat bed trucks will haul the bale to Barber’s Point where they will be unloaded and 

stacked in the Staging Area. The same type of loader attachment (or equivalent 

equipment) will be used for unloading to prevent damage to the plastic wrap. The loader 

operator will inspect each bale for damage to the plastic wrap. If damage is found it will 

be returned to a wrapping area for rewrapping. 

9. Bales cannot be loaded onto the barge until they have been staged for at least five days. 

After five days, the bales are considered ready for transport and the area will be 

designated the Transport Area. HWS will maintain a clear separation between those 

bales ready for transport and those bales in the staging process. 

10. Bales at the Barbers Point Harbor facility will be stored until a barge is ready to be 

loaded. Barge loading will occur approximately monthly. When a barge is ready for 

loading, the bales in the Transport Area will be transferred onto the barge, again using 

squeeze-arm hydraulic equipment or other comparable, appropriate lifting equipment to 

prevent damage to the plastic wrap. The loading supervisor will inspect each bale once 

the bale is loaded onto the barge. Any damaged bale will be returned to the Transfer 

Station for rewrapping and restaging or be rewrapped and restaged on site at Barber’s 

Point. 

11. When the barge is fully loaded it will proceed to its destination at the Roosevelt Regional 

Landfill in Washington State. 

 

The compression settings on the baler shall be 1,000 kg per per cubic meter or more. 

Records indicating the size and weight of each bale shall be maintained. 

Garbage and Regulated (domestic) Garbage which has fallen apart from an unwrapped 

compressed bale, or has been otherwise improperly compressed, shall be set aside for a 

subsequent compression cycle. 

The unwrapped, compressed bales shall be bound with plastic or metal clamps, netting, or 

strapping devices to retain its shape. 

Compressed bales that do not hold together shall be rejected and set aside for a subsequent 

compression cycle. Records of re-compressed bales shall be maintained by HWS and available 

for monitoring by PPQ. 

Each compressed bale will be wrapped by HWS using a process approved by USDA, APHIS. 
 

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The wrapping process will follow the compliance agreement guidelines as outlined below: 

The compressed bale shall be physically isolated by an air tight barrier. The air tight 

barrier shall be built with multiple layers of highly tensile, impermeable film (made of 

low density polyethylene wrap, of at least 16 micrometers thickness, coated on one side 

with a non-hardening mastic/adhesive), covering all surfaces of the bale, and completely 

isolating the internal contents. 

To ensure a strong air tight barrier, a minimum four layers of wrap shall be used to 

isolate each bale. 

Machinery that repeatedly achieves the criteria required shall be used. 

Machinery used for wrapping shall be programmed to dispense a standard amount (length) of 

polyethylene wrap, in each wrap cycle. The length of the wrap programmed into each cycle, 

shall be in excess of the amount needed to provide four layers of wrap around a bale of 

maximum handling size and meet the wrapping specifications as listed in the definitions of this 

compliance agreement. 

HWS will examine each wrapped bale to ensure the air tight integrity and proper wrapping. Any 

bales that are punctured, ruptured, or torn will be re-wrapped by HWS. 

HWS will ensure that all wrapped bales will not contact surfaces contaminated by Garbage and 

Regulated (domestic) Garbage or soil. Any bales which come in contact with contaminated 

surfaces will be either re-wrapped or cleaned, and removed of any outside debris. 

Maintaining records of bales produced

HWS must maintain a log which records bale identification, date of baling, inspections done, any 

remedial measures (e.g., patches, rewrapping). A manifest for each bale produced shall be 

maintained by HWS for statistical and tracking purposes. Information recorded shall include: 

Bale identification number 

Date wrapped 

Weight of bale 

Size of bale 

Records of ruptures, punctures or tears to include the date, name of inspecting 

personnel, action taken and names of personnel completing action 

Dates of entry into the staging, transport, and barge controlled areas and the name 

of personnel responsible for inspecting and authorizing movement of the bale into 
 

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those areas 

Barge information (name and voyage #) 

Date of departure (Honolulu) 

Date of arrival (Washington) 

Inspection reports of the condition of the bale upon arrival its arrival at the 

Roosevelt Regional Landfill in WA and any subsequent patching or re-wrapping 

required. 

The records must be maintained and be available upon request by USDA-APHIS-PPQ. To 

ensure compliance, PPQ officers will be permitted access to the firm’s premises and relevant 

records without prior appointment. Records will be kept for a minimum of 3 years from the date 

the bale is shipped to the continental U.S. 

Marking and Identification of Bales

The bales must be permanently marked with the words “REGULATED GARBAGE,” printed in 

a contrasting color to the wrap. The size of the letters shall be 3 inches in height and easily 

visible and legible. 

Manifest and tracking identification numbers required on each bale include the Bale 

Identification Number, the Date Wrapped, and the Date Placed in Staging Area. These marking 

must be in a contrasting color to both the wrap and the words “REGULATED GARBAGE.” 

Markings on all bales must be viewable without moving the bales or climbing on top bales by 

the USDA APHIS PPQ inspector and/or designated cooperators. If markings are not viewable as 

stated above, a HWS operator will need to move the bales for viewing. 

Movement to the Designated Staging Area

Bales approved for movement to the staging area shall be trucked by HWS or its authorized 

representative to the designated Staging Area. 

Bales shall be moved using machinery best designed for holding, lifting and supporting its load 

with minimum or no breakage. 

Bales shall be inspected upon placement onto the truck. Trained HWS personnel shall ensure 

that punctured, ruptured, or torn bales and bales that are externally contaminated by garbage or 

soil are not forwarded. 
 

93

Bales that are punctured, ruptured, or torn while being loaded onto the truck shall be removed 

from the truck and re-wrapped. The date of re-wrapping shall be indicated in the bale manifest 

as specified under “Marking and Identification of Bales.” 

Bales that have been rewrapped shall be returned to the staging area for a minimum of 5 days. 

The date of placement in the Staging Area shall be indicated on the bale manifest. 

Staging Area Operation Requirements

A wrapping machine which meets all approved wrapping technology shall be located at the 

HWS Transfer Station within [2.5] miles of Barber’s Point. If wrapping machinery is located at 

the Staging area, HWS will ensure that the wrapping machinery located at the Staging Area shall 

be programmed to dispense a standard amount (length) of polyethylene wrap in each cycle. The 

length of the wrap programmed into each cycle shall be in excess of the amount needed to 

provide four layers of wrap around a bale of maximum handling size. 

HWS will ensure that the Staging Area be kept clean and free of loose garbage and soil. The 

Staging Area shall be clearly marked and physically separated from the Transport Area. 

Operational procedures pertinent to the Staging and Transport areas shall be posted in a location 

visible to all HWS personnel and authorized representatives. 

HWS shall develop and enforce plans for pest exclusion and eradication programs to control 

pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, 

mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu, 

Hawaii. 

Movement into the Staging Area

Bales with air tight integrity shall be forwarded to the staging area. The date of placement into 

the staging area shall be indicated in the bale manifest. 

The bales shall be off loaded from the truck using machinery best designed for holding, lifting 

and supporting its load with minimum or no breakage. 

Bales shall be inspected for punctures, ruptures and tears and external contaminants (i.e. 

garbage, soil or mollusks). Records of dates and identification of the personnel responsible for 

the inspection shall be indicated in the bale manifest. 

Bales shall be grouped together by their projected lapse date in the staging area. Physical 

separations shall be used to differentiate these groups and signage indicating such separation 

shall be posted in a position visible to all personnel. 

Bales shall be retained in the staging area for a minimum of 5 days. 

Bales that have been punctured, ruptured, or torn enroute to the (staging area) site shall be 
 

94

marked with colored tape and set aside for re-wrapping and returned to a wrapping area. The 

date of re-wrapping shall be indicated in the bale manifest and on the outside of the bale as 

indicated in the “Marking and Identification” section of this agreement. 

Bales that have been rewrapped shall be returned to the staging area for a minimum of 5 days. 

The date of placement in the Staging Area shall be indicated on the bale manifest. 

After the minimum 5 day hold, bales shall be inspected for punctures, ruptures and tears and 

external contaminants. Date and identification of personnel responsible for inspection shall be 

indicated in the bale manifest. 

Transport Area Operation Requirements 

HSW will ensure that the Transport Area be kept clean and free of loose Garbage and Regulated 

(domestic) Garbage and soil. The Transport Area shall be clearly marked and physically 

separated from the Staging Area. Operational procedures pertinent to the Staging and Transport 

areas shall be posted in a location visible to all HWS personnel and authorized representatives. 

HSW shall develop and enforce plans for pest exclusion and eradication programs to control 

pests that may be attracted to the bales in the staging and loading area (i.e. rodents, birds, 

mollusks, etc.) These plans shall be submitted for approval by USDA, APHIS, PPQ in Honolulu, 

Hawaii. 

Movement into the Transport Area

Bales with air tight integrity are allowed movement to the designated transport area. Date and 

identification of personnel responsible for authorization of the movement shall be indicated in 

the bale manifest. 

Any movement of bales shall be forwarded with machinery best designed for holding, lifting and 

supporting its load with minimum or no breakage. 

Bales moved to the transport area, shall be inspected for punctures, ruptures, and tears upon 

placement. Date of placement in the transport area and the identification of the personnel 

responsible for the inspection shall be indicated in the bale manifest. 

HWS will manage the placement of bales, such that the handling of bales will be minimized. 

HWS will track bales placement and date, such that all bales completing the 5-day staging 

requirement prior to a scheduled barge loading are maintained in a readily identified area. These 

bales shall be separated from bales that will not meet the 5-day staging requirement by the 

scheduled barge loading date. In this manner, the bales are not physically moved from the 

Staging Area to the Transport Area, but rather the bales achieving the minimum 5-day staging 

criteria are then designated to be within the Transport Area. The date of designation and the 

person authorizing the designation shall be indicated in the bale manifest 

For example, if the barge is scheduled for loading beginning on August 1st, then only those bales 
 

95

staged on or before July 26th will be eligible for loading. HWS will maintain physically separate 

areas for those bales stacked on or before July 26th from those stacked on July 27th or after. The 

bales in the area stacked on or before July 26th will have transitioned into the Transport Area and 

are eligible for loading onto the barge. The bales stacked on July 27th or after will be eligible for 

loading onto the next barge arriving in approximately one month. 

Bales found punctured, ruptured, or torn shall be immediately marked with colored tape and 

removed from the transport area for rewrapping. 

Bales with contaminants on the outside of the bale (e.g. soil, debris, pests, etc) shall be 

immediately cleaned or removed from the transport area. 

Re-wrapped bales shall be moved back into the staging area for a minimum 5 day holding 

period. The date of re-wrapping and placement into the Staging area shall be indicated in the 

bale manifest and on the outside of the bale as indicated in the “Marking and Identification” 

section of this agreement. 

Bales held for more than 75 days shall be re-wrapped. The date of re-wrapping and placement 

into the Staging area shall be indicated in the bale manifest and on the outside of the bale as 

indicated in the “Markings and Identification” section of this agreement. 

Bales in the transport area which have met the requirements for the transport to the mainland are 

authorized for movement onto the barge and shall be forwarded by machinery best designed for 

holding, lifting and supporting its load with minimum or no breakage. 

The bales must be permanently marked as specified in the “Markings and Identification” section 

on this agreement. 

Markings on all bales must be viewable without moving the bales or climbing on top bales by 

the USDA APHIS PPQ inspector and/or designated cooperators. If markings are not viewable as 

stated above, a HWS operator will need to move the bales for viewing. 

Movement onto the Barge 

HWS personnel or their authorized representative shall conduct a full inspection of each bale 

upon placement onto the barge. Bales shall be inspected for any punctures, ruptures, or tears and 

external contaminants (i.e. soil, garbage, mollusks) upon placement onto the barge. The date and 

identification of the personnel responsible for the inspection and authorization for forward 

movement shall be indicated in the bale manifest. 

Barge information (Name and Voyage no.) and Date of departure from Honolulu shall be 

indicated on the bale manifest. 

Any bale found punctured, ruptured, or torn before the barge leaves the port shall be 

immediately marked with colored tape and removed from the barge for re-wrapping. Rewrapped bales shall be moved back into the staging area for a minimum 5 day holding period. 
 

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The date of re-wrapping and placement into the Staging area shall be indicated in the bale 

manifest and on the outside of the bale as indicated in the “Marking and Identification” section 

of this agreement. 

Any other material (regulated or non-regulated, such as non-rolling equipment, empty 

containers, and non-regulated recyclables) placed on the same barge as the bales of Garbage and 

Regulated (domestic) Garbage must be secured to the barge in such a manner that they will not 

move or come in contact with the wrapped bales. Any other material placed on the same barge 

must be separated from the bales of Garbage and Regulated (domestic) Garbage approved for 

movement under this compliance agreement and must be easily distinguishable from the bales of 

Garbage and Regulated (domestic) Garbage approved for movement under this compliance 

agreement. 

CLEANUP PROCEDURES FOR GARBAGE AND REGULATED (DOMESTIC) 

GARBAGE SPILLS AND EQUIPMENT 

HWS must provide personnel and appropriate measures to control the Garbage and Regulated 

(domestic) Garbage in the event of a spill or other emergency. HWS will follow the clean-up 

protocols specified for spills as outlined in Appendix 1 of this compliance agreement. Any 

changes to these protocols must be reviewed and approved by USDA, APHIS, PPQ, and all 

appropriate Federal, State and Local regulations. 

A contingency plan should be in place to handle any spills or breakage during any part of the 

voyage, transloading, offloading, and/or transportation of the bales. All company employees, 

designees, drivers, and handlers of the baled Garbage and Regulated (domestic) Garbage shall be 

informed of the contingency plan. 

APPENDIX 1 clean up protocols will be followed. APPENDIX 1 is attached to this 

document. 

If spillage occurs during transport, USDA, APHIS, PPQ must be notified immediately. See list 

of contact numbers provided below: 

Contact Numbers

Compliance Officer Honolulu, HI 808-861-8446 

Supervisory Compliance Officer Honolulu, HI 808-861-8465 

For after hour, seven days a week 

Operations Desk Honolulu, HI 808-861-8490 

PPQ CLEARANCE IN HONOLULU

USDA, APHIS, PPQ in Honolulu, Hawaii shall be notified by facsimile 48 hours in advance of 
 

97

the departure date for each shipment of baled Garbage and Regulated (domestic) Garbage

destined to Washington. The notification shall include: 

Barge name and Voyage no. 

Date of departure from Honolulu 

First U.S. mainland port of entry 

Estimated date of arrival at the first U.S. mainland port of entry 

Name and phone number of the contact personnel responsible for the shipment. 

A list of the identification numbers for all bales included in the shipment. 

HWS personnel are responsible for notifying PPQ by facsimile 48 hours in advance of the barge 

departure. PPQ may schedule or conduct a compliance inspection prior to departure of the 

barge. 

Movement of the bales of Garbage and Regulated (domestic) Garbage is authorized only to the 

state of Washington through the Roosevelt Seaport. The tug/barge shall not be diverted to any 

other seaport. 

Bales must remain on the same barge from the port of Honolulu to the authorized port. 

Transloading to any other barge or means of conveyance prior to arrival at the authorized U.S. 

mainland port of entry is prohibited. 

Before leaving Hawaii, all bales must be well secured on the barge and within the railing to 

prevent falling during the voyage. 

TRAINING

HWS shall present a training program to employees before they are permitted to handle and 

transport or supervise the handling and transport of Garbage and Regulated (domestic) Garbage. 

This training program should be at least one (1) hour in duration. Previously trained employees 

shall be provided review training annually. A record of employees and their training dates shall 

be maintained and available for PPQ review. 

The training package must be approved by the local PPQ officer in charge, and may include both 

formal classroom training and on-the-job training. It must contain the following topics: 

Procedures for maintaining control of Garbage and Regulated (domestic) Garbage 

Define “Garbage” and “Regulated (domestic) Garbage” and “Foreign Garbage” 
 

98

Explain the regulation and its purpose. 

Explain the compliance agreement and its purpose. 

Include film, slides, or other training aids on Hawaiian soil, plant diseases and 

pests 

Specifically outline, by demonstration, illustration, or picture, proper regulated 

garbage handling procedures and transport 

Explain the manifesting process 

Be presented in English and other appropriate languages.

Procedures for reporting and data; procedures and reporting results of inspection of bales 

Procedures for cleaning and disinfecting contaminated equipment and areas. 

Records of training administered to employees shall be made available to PPQ personnel upon 

request. 

RECORDS AND MONITORING (INSPECTIONS)

HWS must maintain a log which records all information as specified in the “Maintaining records 

of bales produced” section of this compliance agreement. This includes bale identification, date 

of baling, inspections completed and any remedial measures performed (e.g., patches, 

rewrapping). 

These records must be kept for a minimum of 3 years from the date that the bale was shipped to 

the continental U.S. 

To ensure compliance, USDA, APHIS, PPQ personnel shall be allowed to monitor operations 

during normal business hours without prior notification. HWS shall ensure a safe location is 

available for the inspector to conduct all aspects of the inspection. Safe viewing areas will be 

established as approved by PPQ Hawaii. This may be a stanchioned area near, but not directly in 

the path of the barge loading operators. The handling equipment shall allow tilting of the bale or 

offer some other method of inspection for the bottom of the bale without requiring the PPQ 

inspector to stand underneath or within the drop line of a machine-held bale. 

Inspectors shall be allowed to safely view any unwrapped bales at the time of inspection. 

The compression process and the scale station and readouts shall be visible to the inspector from 

a safe location. 

The wrapping procedure and wrapping readouts showing calibration shall be visible to the 

inspector from a safe location. 

Records of all bales shall be maintained and made available to inspectors during business hours. 

ENVIRONMENTAL PROTECTION AND OTHER REGULATORY AGENCIES
 

99

By signing this agreement, the signer certifies that his/her facility has met or will meet the 

requirements of all applicable environmental and any other applicable regulatory authorities in 

addition to the Garbage and Regulated (domestic) Garbage handling regulated by the Animal 

and Plant Health Inspection Service. 

ENDANGERED SPECIES ACT COMPLIANCE

For the barging of Garbage and Regulated (domestic) Garbage bales from Honolulu, Hawaii to 

the continental United States (mouth of the Columbia River), the following protection measures 

will be adhered to for the Steller sea-lion and Humpback whale. This is required for compliance 

with the Endangered Species Act: 

Steller sea-lion 

No barge will approach within 3 nautical miles of the steller sea lion rookeries in Oregon (Rogue 

Reef: Pyramid Rock and Orford Reef: Long Brown Rock and Seal Rock) and California (Ano 

Nuevo l., Southeast Farallon 1., Sugarloaf l. and Cape Mendocino). 

Humpback whale 

Within 200 nautical miles of the Hawaiian Islands, the barge will not approach or cause an 

object to approach within 100 yards of any humpback whale and the speed of the vessel will not 

exceed 13 knots. 

NOTIFICATION

PPQ shall be notified within 7 days of any change in business status, business operations, 

telephone number, business address, management, ownership or business dissolution. 

COMPLIANCE

This compliance agreement is only valid in conjunction with a valid Washington compliance 

agreement issued to HWS, for handling Garbage and Regulated (domestic) Garbage from Hawaii 

destined to the Roosevelt Regional Landfill. 

This compliance agreement is nontransferable. If the person identified in section 7 of PPQ Form 

519 leaves their present employer, HWS or position, then he/she must notify the local PPQ office 

immediately. This agreement will then be terminated. 

If Garbage and Regulated (domestic) Garbage is handled by other personnel within the HWS, 

those persons must be under the permittee’s supervision and must be aware of and able to adhere 

to all stipulations in this agreement. 

This compliance agreement may be amended as necessary by USDA, APHIS, PPQ. HWS will 

be notified of all amendments. 
 

100

NOTE: “Any person who knowingly violates the Plant Protection Act (PPA) (7 U.S.C. §§ 7701 

et. Seq.) And/or the Animal Health Protection Act (AHPA) (7 U.S.C. §§ 8301 et. Seq.) may be 

criminally prosecuted and found guilty of a misdemeanor which can result in penalties, and one 

year prison term, or both. Additionally, any person violating the PPA and/or the AHPA may be 

assessed civil penalties of up to $250,000 per violation or twice the gross gain or gross loss for 

any violation that results in the person deriving pecuniary gain or causing pecuniary loss to 

another, whichever is greater.” 

WITHDRAWAL OF COMPLIANCE AGREEMENT

This compliance agreement may be canceled, by a PPQ Officer orally or in writing, if such 

officer determines that the holder thereof has not complied with any of the conditions stated in 

this compliance agreement. If the cancellation is oral, the cancellation and the reasons for the 

cancellation will be confirmed in writing as promptly as circumstances allow. Any person whose 

compliance agreement has been canceled may appeal the decision in writing to USDA- APHISPPQ within ten (10) days after receiving the written notification of the withdrawal. The appeal 

must be directed to the State Plant Health Director of Hawaii. The appeal must state all of the 

facts and reasons upon which the person relies to show that the compliance agreement was 

wrongfully canceled. USDA-APHIS-PPQ shall grant or deny the appeal, in writing, stating the 

reasons for such decision, as promptly as circumstances allow. If there is a conflict as to any 

material fact, a hearing shall be held to resolve such conflict. Rules of practice concerning such a 

hearing will be adopted by USDA-APHIS-PPQ. 

Agreement

By signing this agreement, the primary holder of Hawaiian Waste Systems, LLC agrees to 

maintain the scope and intention of this compliance agreement. The signature further certifies 

that the listed business has met or will meet the requirements of all other applicable 

environmental authorities prior to the processing of any USDA regulated garbage. 

This agreement may be immediately canceled or revoked for noncompliance. 

I have read and understand the conditions of this compliance agreement. 

 

 

6.Signature 

 

7. Title 8. Date Signed 

The affixing of the signatures below will validate this agreement, which shall remain in effect until 

canceled, but may be revised as necessary or revoked for noncompliance. 

10. Date of Agreement 11. Agreement Number 

PPQ OFFICIAL (Name and Title) ADDRESS 
 

101

 

Signature 

PPQ FORM 519 

(FEB 2002) 

 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

102

APPENDIX 1 - Spill Response Plan for Hawaiian Waste Systems, LLC 

 

 HWS Emergency Response Planning

HWS shall, either directly or through its contracted service providers, at all times have emergency 

response procedures in place at all times while shipment of baled, wrapped Hawaiian waste is 

occurring. 

HWS has contracted with Brusco Tug and Barge (Brusco) for the transport of baled and wrapped 

MSW from Oahu to the Roosevelt Intermodal Facility. As a marine carrier with over 35 years of 

tug and barge experience throughout the West coast and Hawaii, Brusco has longstanding internal 

response plans in place and in addition, Brusco is and shall remain under contract with MSRC 

Corporation and the Cowlitz County Clean Sweep. A copy of the MSRC contract is attached. 

HWS has contracted with Regional Disposal Company (RDC, a wholly owned subsidiary of Allied 

Waste, Inc.) for the handling, transportation and disposal of the bales, such contract commencing 

at the Roosevelt Intermodal and includes acceptance of the bales on RDC trucks, transport of the 

bales to the Landfill, offloading of the bales at the Landfill and disposal of the bales at the 

Landfill. RDC, with over fifteen years of operational experience and over 30 million tons 

disposed of to date, has long standing emergency response plans (ERPs) in place. A copy of the 

standard form RDC ERP, amended to address the specifics of baled Hawaiian waste handling, is 

attached. 

In brief, spills will be addressed as follows: 

• On Oahu: If a bale ruptures or there is a spill in transit to the barge facility or in loading, 

such bale and any loose waste shall be loaded into a roll-off container and returned to the 

Campbell park baling/wrapping facility for re-processing. Any affected spillage site shall 

be cleaned so as to restore the affected site to its pre-spill state. 

• In marine transit: If a bale is dislodged from the barge, Brusco shall report such incident 

as promptly as practicable and using either Brusco equipment (available for mobilization 

from its Longview facilities) or contracted equipment shall locate and retrieve such bale as 

practicable using a crane or other appropriate equipment. If a bale is ruptured as a result of 

being dislodged from the barge or being recovered, 6-mil hazardous waste bags will be 

available on the barge, which will be used to contain the ruptured bale in a manner similar 

to the “burrito” style burst bale protocol as described in the Compliance Agreement. The 

sealed bag will be delivered to the Roosevelt dock for offloading, transport to and disposal 

in the Landfill. 

• In Klickitat County: Any bales that significantly rupture or are ‘spilled’ during offloading shall be handled in accordance with the burst bale protocol provided for in the 

Compliance Agreement. In transit from the Roosevelt Intermodal to the Landfill, any spill 

shall be handled in accordance with RDC’s existing spill protocols – which entail a prompt 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

103

response, clean up of the affected area, and burial of the spilled material in the Landfill. 

Such spill response is laid out in greater detail in the attached RDC ERP. 

WASTE SPILL PROTOCOL ON LAND

REGIONAL DISPOSAL COMPANY 

(RDC) 

EMERGENCY RESPONSE PLAN (ERP) 

TRANSPORT OF BALED AND WRAPPED 

HAWAIIAN MUNICIPAL SOLID WASTE 

FROM THE ROOSEVELT DOCK 

TO ROOSEVELT LANDFILL 

Prepared by 

Regional Disposal Company (RDC) 

June 2006 
104

Table of Contents

1.0 INTRODUCTION AND PURPOSE .......................................Error! Bookmark not defined.

1.1 Emergency Response Team (ERTeam) Scope.....................Error! Bookmark not defined.

1.2 Objective...............................................................................Error! Bookmark not defined.

2.0 EMERGENCY RESPONSE PROCEDURES AND NOTIFICATION SCHEDULEError! Bookmark not de

2.1 ERTeam Duties And Responsibilities ..................................Error! Bookmark not defined.

2.1.1 ERCoordinator ...............................................................Error! Bookmark not defined.

2.1.2 ERLeader........................................................................Error! Bookmark not defined.

2.1.3 ERTeam Members..........................................................Error! Bookmark not defined.

2.2 Emergency Response Notification .......................................Error! Bookmark not defined.

2.3 Emergency Response Plan....................................................Error! Bookmark not defined.

2.3.1 Criteria and Circumstances for Implementing ERP.......Error! Bookmark not defined.

2.3.2 Types of Emergencies and Actions Required ................Error! Bookmark not defined.

2.3.3 Response to All Other Emergencies ..............................Error! Bookmark not defined.

2.4 Transportation Procedures....................................................Error! Bookmark not defined.

2.5 Public Relations....................................................................Error! Bookmark not defined.

2.6 Post-Emergency Critique......................................................Error! Bookmark not defined.

3.0 Appendices 

 3.1 Call Report 

 3.2 Emergency Response Report 

 3.3 Broken Bale Remediation and Cleanup Protocol 

 3.4 Emergency Response Directory 

 3.5 Required Equipment Inventory 

 3.6 Emergency Response Team (ERTeam) Contacts 

 

List of Tables

Table 1 Emergency Response 

FOR 24-HOUR EMERGENCY RESPONSE CALL 

Primary Number: (800) 275-5641

or 

Secondary Number: (206) 332-7700 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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2/11/2008 105

1.0 INTRODUCTION AND PURPOSE 

The purpose of the Emergency Response Plan (ERP) is to outline emergency response procedures 

and establish a notification schedule for responding to emergencies involving the handling, 

transport, and disposal of Baled and Wrapped Municipal Solid Waste from Hawaii (“Hawaiian 

Waste”) by the Regional Disposal Company (RDC). The primary facilities for handling, transport, 

and disposal of waste include the dock facility at the Roosevelt Intermodal (“Dock”) and the 

Roosevelt Regional Landfill. RDC will transport the waste from the Dock to the Roosevelt Regional 

Landfill.

1.1 Emergency Response Team (ERTeam) Scope 

The RDC Emergency Response Team (the ERTeam) will respond to any emergency involving 

Hawaiian Waste from Hawaii, once offloaded from marine-based equipment, during its transport to 

and disposal at the Roosevelt Regional Landfill. 

1.2 Objective 

RDC will maintain a team of emergency response personnel, under the direction of an Emergency 

Response Coordinator (the ERCoordinator) and Emergency Response Leader (ERLeader), trained 

and equipped to respond to any emergency involving Hawaiian Waste en route from the Dock to the 

Roosevelt Regional Landfill. 

2.0 EMERGENCY RESPONSE PROCEDURES AND 

NOTIFICATION SCHEDULE 

This section discusses the following: ERTeam duties and responsibilities; emergency response 

notification procedures; the Emergency Response Plan (ERP); transportation procedures; public 

relations; and post-emergency procedures.

2.1 ERTeam Duties And Responsibilities 

The ERTeam includes an ERCoordinator, ERLeader, and ERTeam Members. In an emergency, the 

ERCoordinator will be located at the Roosevelt Regional Landfill site office, and the ERLeader will 

assemble the ERTeam Members and accompany them to the scene of the emergency, if an off-site 

response is necessary. Duties and responsibilities of the ERCoordinator, ERLeader and ERTeam 
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 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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2/11/2008 106

Members are described in this section. 

2.1.1 ERCoordinator 

Preparedness 

• Maintain written, detailed, up-to-date emergency response procedures 

• Be experienced and knowledgeable in emergency response procedures, and on-call and 

available on a 24-hour basis 

• Be thoroughly acquainted with the properties and general characteristics of RDC's primary 

transport and disposal system for Hawaiian Waste 

• Maintain list of locations and contacts for outside resources 

• Keep record of training received by each ERTeam Member 

• Be prepared to respond to questions from the news media about emergency situations, if 

necessary 

• Serve as ERLeader, if necessary 

Response 

• Coordinate response planning with ERLeader 

• Arrange transportation for ERTeam to scene of emergency 

• Communicate with caller to give additional advice and notify that ERTeam is responding 

• Contact regulatory agencies, as necessary 

• Maintain frequent communication with ERTeam at scene 

• Arrange for additional personnel and supplies at the scene, if necessary 

• Update RDC contacts regularly on status of emergency 

• Arrange for relief ERTeam Members, as needed 

2.1.2 ERLeader 

Preparedness 

• Maintain emergency equipment in operable condition at all times 

• Ensure availability of sufficient number of ERTeam Members 

• Be experienced and knowledgeable in emergency response procedures, and on-call and 

available on a 24-hour basis 

• Participate in exercises at least annually to demonstrate emergency preparedness 

• Evaluate and update equipment at least yearly 

• Serve as ERCoordinator, if necessary 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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Response 

• Coordinate assembly of ERTeam Members and equipment 

• Maintain contact with person or official in charge at scene 

• Consult and work under the direction of the person in charge at scene 

• Direct ERTeam in on-site activities 

• Communicate frequently with ERCoordinator for advice and, if necessary, assistance in 

obtaining additional equipment 

• Monitor the health and safety of ERTeam Members 

• Ensure equipment is cleaned and stored after emergency 

• Complete post-emergency critique and Emergency Response Report 

2.1.3 ERTeam Members 

Preparedness 

• Train and practice on emergency response equipment 

• Serve as ERLeader, if necessary 

Response 

• Work under direction of ERLeader at scene 

• Work in a safe, efficient manner 

• Ask for help from ERLeader, if necessary 

2.2 Emergency Response Notification 

Because RDC’s handling of Hawaiian Waste will commence after offloading from marine-based 

equipment, such handling will occur almost exclusively on RDC-controlled property. The exception 

to this will be transportation on Roosevelt Grade Road and the crossing of WA SR14. The ERTeam 

will likely receive notification of an emergency from RDC personnel, but may receive notification of 

an emergency, generally by telephone, from several sources including outside customers or facilities, 

government agencies, or other interested parties. The person receiving the call (the Contact), who 

may or may not be a member of the ERTeam, will get as much information as possible from the 

caller, using the Call Report (contained in Appendix 3.1) to record the information. The Contact 

will transfer the information to the ERCoordinator, or ERTeam Member on-call (see Figure 1), 

which will initiate the ERTeam Emergency Response Plan (ERP). 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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2.3 Emergency Response Plan 

Upon receiving a call from the Contact regarding an emergency call received, the ERCoordinator 

will determine the type of response that is necessary. 

2.3.1 Criteria and Circumstances for Implementing ERP 

Based on an immediate initial assessment, the ERCoordinator will use his or her best judgment to 

determine when to initiate the ERP. An emergency poses a threat requiring implementation of the 

ERP if the emergency has the potential to: 

• Expose Hawaiian Waste to the environment and thus quarantine risk through a tear or 

rupture to a waste bale 

• Threaten human health or the environment from fire and/or explosion, or exposure to 

Municipal Solid Waste or contaminated water 

• Contaminate surface water or ground water 

• Result in significant soil contamination 

• Result in impacts to fisheries resources or 

• Disrupt commonly-used transportation routes 

If any of these criteria are satisfied, the ERCoordinator will implement the ERP immediately. 

Circumstances that have the potential to satisfy one more of the above criteria include: 

• Release of solids and/or liquids en route to the Roosevelt Regional Landfill 

• Release of liquids from the Roosevelt Regional Landfill 

• Fire and/or explosion en route or at the Roosevelt Regional Landfill 

• Release of gases en route or at the Roosevelt Regional Landfill 

• Vehicle accident en route or at the Roosevelt Regional Landfill 

Each circumstance is described briefly in Section 2.3.2. 

2.3.2 Types of Emergencies and Actions Required 

Table 1 identifies the types of emergencies that have the potential to occur and the nature of 

response that will be required. The table also identifies who will be responsible for initial response, 

who will be responsible for mobilizing for a response, and under what circumstances. Emergency 

situations rarely involve local agencies. 

Each type of emergency and the actions that will be required are described in this section. Section 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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2.3.3 describes specific procedures that will be followed in emergencies which will require either 

minor or full ERTeam response by RDC.

Table 1: EMERGENCY RESPONSE 

Emergency Situation Responsible for Response Type of Response 

 Initial 

Response 

Mobilization 

Responsibilit

y 

Minor 

ERTeam 

Response 

Full 

ERTeam 

Response 

Broken Bale - 

Release of Solids, 

Gases, and/or 

Liquids en Route to 

the Roosevelt 

Regional Landfill. 

RDC RDC Likely Possible 

Fire and/or 

Explosion en Route 

or at the Roosevelt 

Regional Landfill. 

RDC RDC Possible Likely 

Release of Gases en 

Route or at the 

Roosevelt Regional 

Landfill. 

RDC RDC Possible Likely 

 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

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Table 1: EMERGENCY RESPONSE, CONTINUED 

Emergency Situation Responsible for Response Type of Response 

 Initial 

Response 

Mobilization 

Responsibilit

y 

Minor 

ERTeam 

Response 

Full 

ERTeam 

Response 

Truck Accident en 

Route or at the 

Roosevelt Regional 

Landfill. 

RDC RDC Possible Unlikely 

Problem With a 

Truck or Chassis 

During Short Haul.

RDC RDC Possible Unlikely 

Broken Bale and Potential Release of Solids and/or Liquids en Route to the Roosevelt Regional 

Landfill 

In the event of a broken bale and the potential release of solids and/or liquids en route to the 

Roosevelt Regional Landfill, RDC will be responsible for the initial response which includes 

determination of the actual response necessary. Response procedures are described in Section 2.3.3 

of this ERP. 

If solids and/or liquids are released along the transportation route, RDC will be responsible for 

response.
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 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

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Fire and/or Explosion En Route or at the Roosevelt Regional Landfill 

In the event of fire and/or explosion en route to the Roosevelt Regional Landfill, RDC will be 

responsible for the initial response and will determine the response necessary. Response procedures 

are described in Section 2.3.3 of this ERP. 

Release of Gases En Route or at the Roosevelt Regional Landfill 

The release of gases en route is extremely unlikely. Methane gas generation is highly unlikely due 

to the baling, wrapping and handling protocols associated with the Hawaiian Waste prior to its 

delivery to the Dock. If an ERTeam response is required, the procedures described in Section 2.3.3 

of this ERP will be followed, as appropriate. 

Truck Accident En Route or at the Roosevelt Regional Landfill 

In the event of a truck accident en route or at the Roosevelt Regional Landfill, RDC will be 

responsible for any required response. The ERCoordinator will be notified as soon as possible by 

the truck driver. The ERCoordinator will notify the Washington State Patrol and Washington State 

Department of Transportation, as appropriate, to describe the nature, location, date and time of the 

accident, and other pertinent information. If the accident involves a release of Hawaiian Waste, 

response procedures described in Section 2.3.3 of this ERP will be followed. 

2.3.3 Response to All Other Emergencies 

Emergencies either will require minor response to the scene of the emergency, or full ERTeam 

response to the scene (see Table 1 in Section 2.3.2). It is anticipated that most emergencies will 

require minor ERTeam response. Procedures that will be followed for each type of emergency are 

discussed in this section. 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

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Emergencies Requiring Response to the Scene 

If a response to the scene of the emergency is necessary, the ERCoordinator will determine, to the 

extent possible, the type of response required. Emergencies either will require minor response, 

involving one or two ERTeam members, or full ERTeam response. In either case, the ERLeader 

first will determine how many ERTeam Members will respond. The ERLeader will notify the 

ERTeam Members chosen to respond and brief them on the situation. 

At the same time, the ERCoordinator, located at RDC's Roosevelt office, will: 

• Contact the caller and advise the caller on response measures to take while the ERTeam is 

traveling to the scene 

• Gather as much information as possible from the caller to determine personnel and 

equipment needed for the response 

• Contact the ERLeader to discuss the type of response necessary and the transportation mode 

to be used 

• Arrange for necessary transportation 

• Contact, if necessary, government agencies and officials at the scene to notify them of the 

ERTeam's location and approximate time of arrival 

• If the response involves air transport, arrange for land transport when the ERTeam arrives. 

Upon arriving at the scene, the ERLeader will: 

• Contact the individual in charge, or take charge if he or she is the only response person on 

site 

• Thoroughly evaluate the situation 

• Consult with officials at the scene 

• Determine what action will be taken 

• Communicate the information to the ERCoordinator, who will then decide if additional 

resources are necessary. 

If the incident involves a broken bale and/or release of Hawaiian Waste, upon arriving at the scene, 

the ERLeader, will: 

• Identify the character, source, amount, and extent of the release 

• Assess the direct, indirect, or immediate impacts to human health and the environment that 

may result 

• Direct the ERTeam in containing the release 

• Initiate remedial action and cleanup (See Appendix 3.3 for Broken Bale Remediation 

protocol) 

• Arrange for reloading of the waste 

• Document the release (i.e., with photographs), and complete the Emergency Response 

Report (see Appendix 3.5). 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

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Follow-up Actions for All Emergencies Requiring ERTeam Response

After the initial evaluation, the ERLeader will contact the ERCoordinator with updated information 

on the situation, and request additional personnel or equipment, if necessary. The ERLeader and 

ERCoordinator will maintain periodic communications throughout the incident until the emergency 

has been resolved. 

The ERTeam will remain at the scene until released by the person in charge. The ERCoordinator 

will arrange travel for the ERTeam's return to base. The ERCoordinator will contact appropriate 

government agencies and other interested parties to advise them that the emergency is over. 

Refer to Section 2.6 of this ERP for a description of the required post-emergency critique. 

2.4 Transportation Procedures 

If an ERTeam response to the scene of the emergency is necessary, transportation will be required. 

The type of transportation used will be determined by the ERCoordinator, based on several factors: 

• Urgency of response 

• Distance to scene 

• Available access to scene 

• Amount of equipment needed 

• Number of team members required to respond, and 

• Weather conditions. 

If immediate response is necessary, the fastest mode of transportation to the scene will be used. If 

air transportation is used, arrangements will be made for travel to the scene from the nearest airfield. 

 The ERCoordinator will make travel arrangements. 

If the response is less urgent, or is to provide backup or to relieve another ERTeam Member at the 

scene, then ground transportation will be used. 

2.5 Public Relations 

Calls from the news media will be directed to the ERCoordinator identified in Appendix 3.2 of the 

ERP. If the ERCoordinator is not available, calls will be directed to the person designated by the 

ERCoordinator as the appropriate media contact. If an ERTeam Member is approached at the scene 

by a reporter or photographer, the team member will direct the inquiry to the ERLeader. 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 

2/11/2008 114

Upon arrival at the scene, the ERLeader will: 

• Check with the person in charge and notify him or her that the ERTeam will to keep all 

appropriate people up-to-date on the status of the emergency 

• Offer to have appropriate questions from the news media directed to the ERLeader 

• Be prepared to answer questions about the ERTeam and its activities 

• Keep an informal log of reporters and camera crews with whom the ERLeader has 

interacted, including their affiliations, telephone numbers, and information 

communicated. 

In talking to the news media, the ERLeader will: 

• Be available to respond to questions in the early morning and early afternoon, the most 

likely times when reporters on deadline will be seeking information 

• Brief the news media at least once every 30 minutes on the status of the emergency and, 

even when new information is not available, be accessible to answer questions that may 

arise 

• Treat television and newspaper representatives equally 

• Be brief and factual in responses, never speculate on probable causes, and explain the facts 

simply, so the reporter will not have to check back later 

• Know the facts (an inaccurate or misleading answer can be more detrimental than no 

answer); if a response is not available, indicate when a response is expected 

• Be courteous and responsive, maintain a level, factual tone of voice, and do not get agitated 

• Never speak "off the record" 

• Never use the words "no comment," use the response: "I don't have enough information to 

answer that question" or "I really don't think I can talk about that." 

• Never attempt to assign a dollar estimate to damage that has occurred 

• Never release names of injured people; tell reporters the hospital where the injured people 

have been taken, if appropriate 

• Never comment on the competency or performance of another person responding to the 

emergency. 

• Never attempt to physically restrain a member of the news media (i.e., at a barricade); notify 

local law enforcement personnel, who will respond appropriately. 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

Final Emergency Response Plan (ERP) 

2/11/2008 115

2.6 Post-Emergency Critique 

Upon return to base, the ERLeader will supervise the cleaning and storage of equipment. The 

ERLeader will conduct a critique of the incident with all ERTeam Members. The ERLeader will 

complete an Emergency Response Report (see Appendix 3.5) and provide a copy to the 

ERCoordinator, RDC management and other responsible agents upon request. 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

116

3.0 APPENDIX

3.1 CALL REPORT 

RDC EMERGENCY 

CALL REPORT 

Date Call Report No. 

Time (on/off) Call Taken By 

EMERGENCY DISPATCH AGENCY 

EMERGENCY NAME 

CALLER

 ORGANIZATION 

CALL BACK LOCATION 

 (City, County, State) 

CALL BACK TELEPHONE

PROBLEM 

(Include Type of Emergency) 

 

 Time 

 Details/Injuries 

 

IMMEDIATE 

ENVIRONMENTAL 

CONCERNS 

ACTION ALREADY TAKEN

 Police and/or Fire Called? 

 Railroad and/or RDC Called? 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

117

 ERCoordinator Called? 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

118

LOCATION OF EMERGENCY

 (City, County - if other than caller location) 

 Hwy No./Distance-Direction From 

 Weather/Temperature 

 Populated/Open Area 

 Terrain (flat/hilly/etc.) 

 Nearest Airfield 

 Directions to Scene 

 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

119

3.2 EMERGENCY RESPONSE REPORT

 (Attach Additional Pages as Necessary) 

Date: Emergency Response Report No.: 

Time: Completed By: 

Location & Phone Number Where Report may be Located: ( ) 

Type and Location of Incident: 

 Date: Time: 

Remediation Completed: Date: Time: 

Response Taken: Date: Time: 

Number of ERTeam Members Reporting to Scene: 

Names of all Team Members Responding: 

Possible Impacts to Human Health or the Environment: 

Description of Actions Taken: 

Extent of Injuries, if any: 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

120

If Release of Solid Waste is Involved: 

 Disposition of Recovered Material: 

 

 

 

 Identification of Material: 

 Quantity: 

Appearance of Site after Cleanup (include before and after photos): 

Equipment & Supplies Used: 

Signature Title: 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

121

3.3 Broken Bale Remediation and Cleanup Protocol

Substantially Damaged/Broken Bale Remediation Protocol 

Bales that incur only minor ruptures will be repaired by resealing the opening with 

appropriate adhesive and plastic liner/sheeting. 

In the event that a bale is substantially ruptured during RDC transport to the Landfill, the 

following mitigation measures will be immediately enacted: 

1) The ruptured bale and its contents will be isolated. 

2) A cleanup crew will scoop up the contents and any remnants of the broken bale 

and place it in waiting super-sacks – polypropylene bags lined on the interior with 

a minimum 6-mil plastic liner. The 6-mil plastic liner will be wrapped/folded 

over the waste and sealed with duct, thus creating a “burrito” wrapped waste bale. 

The sealed waste bale will then be secured inside the super sack to allow lifting 

the recovered waste to and from transportation equipment. This “burrito” 

wrapping of waste has been used effectively, under Washington State Department 

of Ecology supervision, to manage “contained-in” regulated remediation waste 

delivered to Roosevelt Landfill. 

3) Once the super sack is secured it will be placed on a flatbed trailer for transport to 

the active face of the Landfill where it will be lifted from the trailer and placed in 

the waste pile for subsequent coverage by other waste or soil cover. The “burrito” 

bag will be lifted and placed rather than tipped to ensure that it is not ruptured 

during tipping. 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

122

3.4 EMERGENCY RESPONSE DIRECTORY

Emergency Response Team (ERTeam) Contacts 

 

Regional Disposal Company

ERCoordinator Matt Henry (Landfill) 

 (800) 275-5641 (Roosevelt Office) 

 (509) 727-1488 (Mobile) 

 

ERLeader Dan Wedgwood 

 (800) 275-5641 (Office) 

 (541) 288-7027 (Mobile) 

ERLeader (Backup) Dave Gunderson 

 (800) 275-5641 (Office) 

 (509) 366-2646 (Mobile) 

ERTeam Member Jim Wright 

 (800) 275-5641 (Office) 

 

EMERGENCY RESPONSE DIRECTORY 

For 24-Hour Emergency Response Call 

Primary Number: (800) 275-5641 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

123

Agencies And Locations Where ERP Is Available 

The agencies and locations listed below will receive copies of the AOP: 

• RDC's Corporate Headquarters 

54 S Dawson St. 

Seattle, WA 98134 

(206)332-7700 

• Hawaiian Waste Systems, LLC 

 1011 SW Klickitat Way, #C-109 

 Seattle, WA 98134 

 (206)292-2929 

• Klickitat County Public Works 

205 S. Columbus, Room 103 

Goldendale, Washington 98620 

(509) 773-4616 

• Roosevelt Regional Landfill Main Office 

P.O. Box 204 

1800 Roosevelt Grade Road 

Roosevelt, Washington 99356 

(509) 374-5641 or 

(800) 275-5641 

• State of Washington Department of Ecology 

Central Regional Office 

15 Yakima Way, Suite 200 

Yakima, WA 98902 

509-575-2490 

3.5 EQUIPMENT INVENTORY

REQUIRED EQUIPMENT INVENTORY 
 United States Department of Agriculture 

 Animal and Plant Health Inspection Service 

 Plant Protection and Quarantine 

COMPLIANCE AGREEMENT

124

RDC maintains several vehicles and pieces of equipment on site at the Roosevelt Regional 

Landfill for responding to accidents or emergencies in the Roosevelt area, including the 

following: 

•

• tow vehicles 

• water storage trucks equipped with a fire hose. 

RDC will use these vehicles to assumes responsibility for first response for landfill-related 

accidents or emergencies in the Roosevelt area. 

Table 3.5.1A contains a list and brief description of required emergency equipment, its 

function, and location at the Roosevelt Regional Landfill. 
 

125

Table 3.5.1A Emergency Equipment (RDC) 

Material/Equipment Function Location 

Telephone For routine and emergency 

communication. 

Administration Building 

Emergency Vehicle To provide transport of injured 

people. 

On site 

Tow Vehicle To move disable trucks. On site 

Diesel-powered generator To provide power for essential 

equipment. 

Maintenance Building 

First Aid Kits To treat minor injuries. Administrative Building, 

Shop, Selected Vehicles 

Safety Locker To store emergency 

equipment. 

Maintenance Building 

Two-way Radios For routine and emergency 

communication. 

Administrative Building, 

assigned to operations 

personnel 

Portable and fixed cellular 

phones 

For routine and emergency 

communication. 

Administrative Building, 

assigned to operations 

personnel 

Dump Truck To transfer solid waste to 

landfill. 

On site 

Wheelloader To load spilled solid waste. On site 

Equipment Manufacturer/Model Number

Dozer Caterpillar/D10R WDA 1 

Dozer Caterpillar/D9L WDA 1 

Dozer Caterpillar/D6H WDA 1 

Grader Caterpillar/14G and 140G 1 

Compactor Various Models 1 

Wheelloader Caterpillar/980 and 966B 1 

Excavator Caterepillar 235 and 320 1 

Backhoe Caterpillar/466 1 

Fuel Truck 1 

Service Truck 1 

Dump Truck 1 
 

126

WASTE SPILL PROTOCOL ON WATER
 

127
 

128
 

129
 

130
 

131
 

132
 

133
 

134
 

135

2. Example Compliance Agreement for Handling 

Hawaiian GRG in the Continental United States. 

UNITED STATES DEPARTMENT OF AGRICULTURE 

ANIMAL AND PLANT HEALTH INSPECTION SERVICE 

PLANT PROTECTION AND QUARANTINE 

COMPLIANCE AGREEMENT

According to the Paperwork Reduction Act of 1995, no persons are 

required to respond to a collection of information unless it displays a 

valid OMB control number. The valid OMB control number for this 

information collection is 0579-0054. The time required to complete this 

information collection is estimated to average 1.25 hours per response, 

including the time for reviewing instructions, searching existing data 

sources, gathering and maintaining the data needed, and completing 

and reviewing the collection of information.

1. NAME AND ADDRESS OF PERSON OR FIRM

Hawaiian Waste Systems, LLC 1011 SW 

Klickitat Way, #C-109 

Seattle, WA 98134 

2. LOCATION 

 

 

3. REGULATED ARTICLE(S) 

 Garbage and Regulated (domestic) Garbage from the State of Hawaii  

4. APPLICABLE FEDERAL QUARANTINE(S) OR REGULATIONS 

7 CFR 330.400, 7 CFR 318.13, 7 CFR 318.47, 7 CFR 318.30, 7 CFR 318.60, 9 CFR 94.5 ,

5. PORTS OF COVERAGE: 

WASHINGTON STATE AREAS (Covered by) USDA OFFICES IN: Spokane, 

Seattle, Ellensburg 

6. I/We agree to the following: 

General

This Compliance Agreement (CA) that regulates the handling and transport of Garbage 

and Regulated (domestic) Garbage of Hawaiian origin only authorizes Hawaiian Waste 

Systems, LLC and its authorized representatives to handle and transport Garbage and 

Regulated (domestic) Garbage from the State of Hawaii to the Roosevelt Regional 

Landfill, Washington, in accordance with the provisions of the applicable Federal 

Quarantines and the Administrator’s approval and under the following conditions 

approved by the United States Department of Agriculture, Animal Plant Health 

Inspection Service, Plant Protection and Quarantine (USDA, APHIS, PPQ). Specifically, 

this Compliance Agreement applies to the handling and disposal of Garbage and 

Regulated (domestic) Garbage from the State of Hawaii, baled in adhesive backed plastic 

film barriers made of low density polyethylene (LDPE). The bales are to be transported 

from the State of Hawaii by barge to Roosevelt, Washington, by truck to the Roosevelt 

Regional Landfill in Klickitat County, and then buried without breaking and spreading 

waste and in accordance with the regulations for solid waste disposal and all applicable 

Federal, State, and Local ordinances. All Foreign Garbage, not of Hawaii origin, is 

specifically prohibited from movement under this compliance agreement. 

DEFINITIONS 
 

136

Terms found in the agreement shall refer to the following: 

Agricultural waste Byproducts generated by the rearing of animals and the 

production and harvest of crops or trees. Animal waste, a large component of 

agricultural waste, includes (e.g.) feed waste, bedding and litter, and feedlot and 

paddock runoff from livestock, dairy, and other animal-related agricultural and 

farming practices. 

Bale means the confined unit of Garbage and Regulated (domestic) Garbage that 

has been approved for transport and burial. Bales are formed meeting all APHIS 

requirements in 7CFR330. 

Barge means the conveyance via ocean and Columbia River on which the 

Garbage and Regulated (domestic) Garbage will be carried. 

 

Collections of agricultural waste and yard waste refers to bulk 

collections/pick-up of waste which is made up of primarily agricultural waste and 

yard waste. All collections of agricultural and yard waste shall not be accepted.

Commingling means the mixing of any regulated and non-regulated materials 

(including incinerated ash) within the bales, at any staging or transport area. 

Company Name – Hawaiian Waste Systems, LLC; (HWS)

Compression refers to the process in which the waste articles are crushed under 

high pressure, expelling air from, and compacting waste articles into a high 

density bale. 

Foreign Garbage means all materials, associated with fruits, vegetables, meats or 

animal products, that have been removed (in Hawaii) from any means of 

conveyance originating from a port outside the continental United States 

(including Alaska) or Canada, which has not been treated in accordance with 7 

CFR part 330 for foreign pests and animal diseases. The disposal method 

described in this compliance agreement has not been evaluated for the risk of 

animal diseases. 

Garbage is defined as urban (commercial and residential) solid waste from 

municipalities on any Hawaiian island. 

Inspector A properly identified employee of the USDA or other person 

authorized by the USDA to enforce the provisions of the Plant Protection Act and 

related legislation, quarantines, and regulations. 

Offloading means to move bales from the means of conveyance to its final 

destination spot; the bales will not be placed on any other means of conveyance. 
 

137

Patch is made of impermeable film made of low density polyethylene, of at least 

16 micrometers thickness, that is coated on one side with a non-hardening 

mastic/adhesive. The patch must be sufficient to establish an airtight seal. 

Plant pest means any living stage of any insects, mites, nematodes, slugs, snails, 

protozoa, or other invertebrate animals, bacteria, fungi, other parasitic plants or 

reproductive parts thereof, viruses, noxious weeds, or any organisms similar to or 

allied with any of the foregoing, or any infectious substances which can directly 

or indirectly injure or cause disease or damage in any plants or parts thereof, or 

any processed, manufactured, or other products of plants. 

PPQ Hawaii means the local office of the United States Department of 

Agriculture, Animal Plant Health Inspection Service, Plant Protection and 

Quarantine (USDA, APHIS, PPQ), Port of Honolulu located at 3375 Koapaka 

Street, Honolulu, HI 96819, phone number, (808) 861-8446 and fax, (808) 861-

8450. 

PPQ Washington means an office of the USDA, APHIS, PPQ in Washington 

State; located at 222 N. Havana Street, Spokane, WA 99202, phone number, 

(509)353-2950 and fax, (509)353-2637. 

Puncture - any hole which is found in the plastic of the bale which goes through 

all four layers of the wrapping. 

Regulated (domestic) Garbage refers to articles generated in Hawaii that are 

restricted from movement to the continental U.S. under various quarantine 

regulations established to prevent the spread of plant pests (including insects, 

disease, and weeds) into areas where the pests are not prevalent. 

Rewrapping means the entire bale is rewrapped again using the exact same 

material and same amount of materials as in the initial wrap of bales. The original 

wrap will not be removed from the bale.

Roosevelt Regional Landfill refers to the landfill site located at 500 Roosevelt 

Grade Road, Roosevelt, Washington. 

Rupture refers to a rupture or tear in the wrapping film where an observer or 

inspector is able to see Garbage and Regulated (domestic) Garbage that is no 

longer covered by film. 

Shredding refers to the process used to reduce bulky articles into scraps.

Soil means the loose surface material of the earth in which plants grow, in most 

cases consisting of disintegrated rock with an admixture of organic material and 

soluble salts. 
 

138

Staging Area refers to the solid flat impervious surface of asphalt or cement 

located at Roosevelt, WA where the bales will be staged pending transport to final 

destination. Wrapping machine will be located at this location. 

Tear means any rupture found in the plastic of the bales which goes through all 

four layers of wrapping. 

Transloading means the movement of Garbage and Regulated (domestic) 

Garbage from one means of conveyance to any other means of conveyance. 

Transport Area refers to the location where bales approved for movement onto 

the barge are positioned for loading. The transport area is located pier side of Pier 

5 at Kalaeloa Barbers Point Harbor. 

Washington compliance agreement refers to the agreement between PPQ 

Washington and Hawaiian Waste Systems, LLC, 1011 SW Klickitat Way #C-109, 

Seattle, WA 98134.

Wrapping The wrapping material shall be an impermeable film made of low 

density polyethylene, of at least 16 micrometers thickness, that is coated on one 

side with a non-hardening mastic/adhesive. Bales are mechanically wrapped to 

achieve an air tight seal. 

Wrapping Area refers to the station where the bale wrapping machinery is 

located. The wrapping equipment will be located at the baling facility in Hawaii 

and the staging area at the Port of Roosevelt. 

Yard waste – Solid waste composed predominantly of grass clippings, leaves, 

twigs, branches, and other garden refuse. 

 

Garbage and Regulated (domestic) Garbage Handling Procedures

The risk assessments for the movement of Garbage and Regulated (Domestic) Garbage 

were conducted based on the specific details provided by HWS. These details include 

the exclusion of incinerator ash and the removal of all hazardous and liquid waste prior to 

baling. HWS will notify PPQ if the company plans change to include such materials so 

that the proper risk assessments can be conducted. 
 

139

Garbage and Regulated (domestic) Garbage arriving by transport barge in Washington 

State from State of Hawaii will be categorized as Garbage and Regulated (domestic) 

Garbage. All Garbage and Regulated (domestic) Garbage arriving in Washington State 

will be baled using technology specified in 7 CFR 330.400, to create wrapped bales 

weighing approximately 1.5 to 4 tons. All waste bales shall be structurally sound and 

wrapped with a minimum of four layers of low density impermeable plastic film to 

provide an airtight and leak-proof enclosure. This will be demonstrated by conformance 

to applicable Hawaii Compliance Agreements. The Garbage and Regulated (domestic) 

Garbage will be continually maintained in securely closed and leak-proof bales which 

have been properly sealed in Hawaii, and will be disposed of in an approved manner at 

the Roosevelt Regional Landfill in Washington State. Every necessary precaution must 

be taken to reduce risk of opening or damage to the bale in Washington where the 

garbage is a quarantine article. 

Upon arrival in Washington State the bales of Garbage and Regulated (domestic) 

Garbage will be routed directly to the Port of Roosevelt and inspected by a HWS 

supervisor to verify that the wrapping of the bales is intact. The condition of bales will be 

noted on the manifest for each numbered bale. The Garbage and Regulated (domestic) 

Garbage will be kept completely segregated at all times from all other kinds of waste and 

non-regulated garbage during packaging and staging to eliminate commingling of 

materials. Any other material (regulated or non-regulated, such as non-rolling 

equipment, empty containers, and non-regulated recyclables) placed on the same barge as 

the bales of Garbage and Regulated (domestic) Garbage must be secured to the barge in 

such a manner that they will not move or come in contact with the wrapped bales. Any 

other material placed on the same barge much be separated from the bales of Garbage 

and Regulated (domestic) Garbage approved for movement under this compliance 

agreement and must be easily distinguishable from the bales of Garbage and Regulated 

(domestic) Garbage approved for movement under this compliance agreement. 

Equipment used during transloading operations will be appropriately blunted to minimize 

the potential for punctures, ruptures, or tears. A HWS supervisor will be present during 

all trans-loading and ensure proper handling equipment is used. 

Each bale will be inspected and marked with a manifest and tracking identification 

number. The inspection of the wrapping of the bale will be noted on the bale manifest 

prior to allowing the bale to progress to the next protocol step. 
 

140

Any time a puncture, rupture, or tear is detected, the bale will be visibly marked and 

moved to a designated area for subsequent patching or rewrapping. Punctures, ruptures, 

and tears which are 6 inches or smaller, will be covered with an adhesive patch which 

will extend at least 6 inches beyond the limits of the tear or puncture. Punctures, ruptures, 

and tears which are more than 6 inches, will be covered with a patch and then rewrapped. Any bales that have been repaired shall be prioritized for immediate transport 

to the landfill. The bale manifest will note any patch, any re-wrapping, and delivery to 

the landfill. If a bale is broken open, appropriate clean up procedures will be 

implemented per the clean up protocols of this compliance agreement. 

A wrapping machine will be located at the Port of Roosevelt which is currently the only 

transfer, staging and handling point approved for transloading. HWS will establish 

protocols for ensuring wrapped bales are properly inspected throughout the handling and 

loading processes. These protocols will be written, and available to USDA APHIS 

and/or its designated cooperators and HWS supervisors. 

The protocol must include at least one point in the process where the wrapping around 

the bale is completely and thoroughly inspected from every angle for punctures or tears. 

HWS will have a supervisor present at the transloading from barge to truck at the Port of 

Roosevelt, WA docks and must be able to safely view this inspection in action. A record 

on the bale manifest will show by initials or some other accountable way that a thorough 

inspection was performed and that no punctures or tears were found. 

Imperfectly sealed bales will be visibly marked and sent to the staging area for 

rewrapping. Movement and rewrapping of bales will be recorded on the bale manifest. 

Bale identification numbers of bales requiring rewrapping prior to departure from Hawaii 

will also be available for review. 

Bales will be re-inspected for punctures, ruptures, and tears any time the bales are moved 

or an incident occurs that would increase risk of puncturing, rupturing or tearing the 

bales. 

The Staging and Transport Area

This is a new process for handling Garbage and Regulated (domestic) Garbage from 

Hawaii. The integrity of the bales at the Hawaii port is important to review and maintain 

throughout the entire baling and transportation process. All punctures, ruptures, and tears 

will be documented and reported regularly. All spills will be documented on the bale 

manifest and reported immediately to the HWS Supervisor for proper cleaning in 

accordance with Appendix 1 of this compliance agreement. All spills will be reported to 

PPQ immediately. 

Garbage and Regulated (domestic) Garbage handling procedures pertinent to the 

transport and staging areas will be conspicuously posted. The procedures must be in 

English and other appropriate languages. 
 

141

The staging and transport area shall be kept clean and free of loose garbage and soil. The 

areas will be controlled for birds, rodents, mollusks, and any other pests that may be 

attracted to the bales. 

Very little biodegradation or production of gases occurs in the properly compressed and 

wrapped bales. Therefore, wrapped bales which exude unusual odors, or bulges could 

indicate improper processing and will immediately be completely rewrapped. The bale 

identity and the company’s supervisor inquiry will be noted for tracking results. Rewrapped bales will be prioritized for movement to the landfill. 

After inspection at the first port of call at Roosevelt, Washington the Garbage and 

Regulated (domestic) Garbage will be trucked to the Roosevelt Regional Landfill. 

The designated landfill, Roosevelt Regional Landfill meets the criteria of a modern 

facility that meets regulations and EPA guidelines for design and operations. HWS will 

immediately notify Honolulu and Washington PPQ if the landfill fails to meet these 

standards and will discontinue transport of Garbage and Regulated (domestic) Garbage 

until authorized by PPQ.

USDA, APHIS, or its designated cooperators in Washington shall be notified by 

facsimile 48 hours in advance (during normal business hours -Monday-Friday, 0730-

1600 hours) of each Garbage and Regulated (domestic) Garbage shipment arrival at the 

mouth of the Columbia River. This notification may be followed up with alternate means 

of communication (i.e. phone, email) at the discretion of HWS. 

The notification shall include: 

Barge name and Voyage no. 

Date of departure from the State of Hawaii 

First Port of Entry to continental U.S. 

Estimated date and time of arrival at the first port of entry to Continental U.S. 

Name and phone number of the contact personnel responsible for the shipment. 

A list of the identification numbers for the bales in the shipment. 

USDA APHIS or its designated cooperators will be notified by facsimile 48 hours prior 

to the trans-loading of the Garbage and Regulated (domestic) Garbage from the staging 

area to road trailers (during normal business hours -Monday-Friday, 0730-1600 hours). 

This notification may be followed up with alternate means of communication (i.e. phone, 

e-mail) at the discretion of HWS. The company must have a supervisor on site at all 
 

142

times to monitor the loading and securing of the bales on the trailers before transport to 

the Roosevelt Regional Landfill. 

Garbage and Regulated (domestic) Garbage staged at the Port of Roosevelt will be 

cleared from the staging area prior to the arrival of a second barge but in no way shall the 

total of 75 days from the date of wrapping be exceeded. Once the bales are transported 

from the staging area to the landfill they must be buried in lined landfill cells under a 

minimum of 6 inches of soil in the Roosevelt Regional Landfill within 24 hours of arrival 

as required by EPA guidelines. The landfilled bales must be completely buried under a 

minimum of 7 feet of material in the Roosevelt Regional Landfill within 75 days of being 

staged in Hawaii. 

A HWS supervisor will be present during all handling and transport of Garbage and 

Regulated (domestic) Garbage. The company operates under this compliance agreement 

and operations will be monitored by USDA APHIS and/or its designated cooperator. 

The vehicle transporting the bales of Garbage and Regulated (domestic) Garbage from 

the Roosevelt, WA docks must take a direct and expeditious route to the Roosevelt 

Regional landfill where burial will take place. Drivers must report any spills or breakage 

immediately to the HWS Supervisor for proper cleaning. The spill or breakage must be 

cleaned immediately according to Appendix 1 of this compliance agreement. All spills 

or breakages must be documented on bale manifest and reported to PPQ immediately. 

HWS will arrange and ensure the transport of Garbage and Regulated (domestic) 

Garbage directly to the Roosevelt Regional landfill by the transportation method and 

route approved under the APHIS-PPQ Washington State Compliance Agreement. 

Routing will be shown on the shipping manifests for the barge, and will be available for 

review. 

The routing of Garbage and Regulated (domestic) Garbage from Hawaii is to be directly 

to the Roosevelt, WA dock. Hawaii PPQ will approve the routing which shows the 

designated Port of Entry. No other stops are approved while enroute to the Roosevelt, 

WA dock. 

Transloading of the Garbage and Regulated (domestic) Garbage from barge to barge is 

prohibited. Transloading of the Garbage and Regulated (domestic) Garbage from barge 

to over-the-road carriers/trailers will be restricted to the designated staging area at the 

Port of Roosevelt dock and inter-modal facility. 

HWS will use only the Roosevelt Regional Landfill as described under the APHIS-PPQ 

Washington State office Compliance Agreement. Any deviation from this designated 

landfill must be authorized through a different Compliance Agreement approved by 

USDA-APHIS-PPQ. 

HWS is responsible for all Garbage and Regulated (domestic) Garbage it transports and 

will not allow its unauthorized removal, diversion, or use. 
 

143

Should HWS subcontract transport, handling, storage, or final destination of Garbage and 

Regulated (domestic) Garbage to another firm then that firm must also be a USDA 

approved company and under compliance with USDA, APHIS, PPQ. PPQ in Hawaii and 

Washington will be notified in advance if another firm is to be used. Substitution and 

approval is NOT automatic. Movement of Garbage and Regulated (domestic) Garbage 

may be temporarily or indefinitely delayed depending on the outcome of the approval 

process. 

Bales which are punctured, ruptured, or torn and require rewrapping must be visibly 

marked for easy observation. The marked bales will be moved to the designated staging 

area for bales requiring rewrapping. The staging area will clearly separate bales for 

rewrapping from other bales. 

Garbage and Regulated (domestic) Garbage must be processed under the described 

conditions and securely lodged on the barge prior to departure from Hawaii. To avoid 

accidental shipment of bales marked for rewrapping, bales for rewrapping must be 

immediately removed and separated from the bales for immediate transport. This separate 

area will be clearly designated for both the garbage handlers and the inspector. 

Marking and Identification of Bales

The bales must be permanently marked with the words “REGULATED GARBAGE,”

printed in a contrasting color to the wrap. The size of the letters shall be 3 inches in 

height and easily visible and legible. 

Manifest and tracking identification numbers required on each bale include the Bale 

Identification Number, the Date Wrapped, and the Date Placed in Staging Area. These 

markings must be in a contrasting color to both the wrap and the words “REGULATED 

GARBAGE.” Markings on all bales must be viewable without moving the bales or 

climbing on top bales by the USDA APHIS PPQ inspector and/or designated cooperators. 

 If markings are not viewable as stated above, a HWS operator will need to move the 

bales for viewing. 
 

144

Transport, staging and handling areas

Wrapped bales are clean and shall be handled so that they stay free of soil and attractant 

debris. No “grounding” or staging of the bales on Washington soil will be allowed. All 

staging will be conducted on a level, solid and impervious surface of asphalt or cement. 

All necessary safety precautions and anticipated precautions will be discussed with 

Washington PPQ prior to set up of the equipment. 

Any bale dropped or torn during the transport process must be immediately patched or 

removed and rewrapped. 

Bales will not be lifted higher than 3 meters except by recorded incident/explanation. 

All Garbage and Regulated (domestic) Garbage must be protected from birds, rodents, 

and mollusks during staging and transport. 

The bales of Garbage and Regulated (domestic) Garbage will be isolated from close 

proximity to exposed fresh fruits, plants, or other activities which may attract hitchhiking 

plant pest. Barriers will be erected if this occurs due to unusual and unavoidable 

circumstances if the operations cannot be moved. 

CLEANUP PROCEDURES FOR GARBAGE AND REGULATED (DOMESTIC) 

GARBAGE SPILLS AND EQUIPMENT 

HWS must provide personnel and appropriate measures to control the Garbage and 

Regulated (domestic) Garbage in the event of a spill or other emergency. HWS will 

follow the clean-up protocols specified for spills as outlined in Appendix 1 of this 

compliance agreement. Any changes to these protocols must be reviewed and approved 

by USDA, APHIS, PPQ, and all appropriate Federal, State and Local regulations. 

In the event of a spill or leak the trailer must be cleaned at the disposal site by using a 

method approved for use at the site. The barge transport must also be inspected for spills 

that may have occurred during transit. 

A contingency plan should be in place to handle any spills or breakage during any part of 

the voyage, transloading, offloading, and/or transportation of the bales. All company 

employees, designees, drivers, and handlers of the baled Garbage and Regulated 

(domestic) Garbage shall be informed of the contingency plan. 

Waste Spill Protocol for the breakage of bales on land
 

145

In the event that a bale is ruptured during offloading, the following mitigation measures 

will be immediately enacted: 

4) The ruptured bale and its contents will be isolated . 

5) A cleanup crew will scoop up the contents and any remnants of the broken bale 

and place it in waiting super-sacks – polypropylene bags with spread straps for 

machine lifting --lined on the interior with a 6-mil plastic liner. 

6) Once loaded, the plastic liner inside the super-sack will be folded over the 

material and sealed with duct tape, thus creating a “burrito” wrapped waste bale. 

The sealed waste bale will then be secured inside the super sack to allow lifting 

the recovered waste to and from transportation equipment. 

4) The super-sacks will be lifted with a forklift or similar equipment and placed on a 

flatbed trailer or similar transportation equipment for transport to the active face 

of the Landfill. 

Upon reaching the active face of the Landfill the super sacks containing “burrito” bags 

will be lifted and placed in the waste pile for subsequent coverage by other waste or soil 

cover. 

APPENDIX 1 clean up protocols will be follow, attached to this document. 

If spillage occurs during transport, USDA, APHIS, PPQ must be notified immediately. 

See list of contact numbers provided below: 

Contact Numbers

The contact phone and fax numbers for the USDA offices are as follows: 

USDA OFFICE CONTACT PHONE FAX 

 

Spokane, WA George Bruno or Steve Miller (509) 353-2950 (509) 353-

2637 

Ellensburg, WA Jordan Krug (509) 925-1188 (509) 925-

4678 

Seattle, WA Barbara Chambers, SPHD (206) 592-9057 (206) 592-

9043 
 

146

TRAINING

HWS shall present a training program to employees before they are permitted to handle 

and transport or supervise the handling and transport of Garbage and Regulated 

(domestic) Garbage. This training program should be at least one (1) hour in duration. 

Previously trained employees shall be provided review training annually. A record of 

employees and their training dates shall be maintained and available for PPQ review. 

The training package must be approved by the local PPQ officer in charge, and may 

include both formal classroom training and on-the-job training. It must contain the 

following topics: 

Procedures for maintaining control of Garbage and Regulated (domestic) 

Garbage 

Define “Garbage” and “Regulated (domestic) Garbage” and “Foreign 

Garbage” 

Explain the regulation and its purpose. 

Explain the compliance agreement and its purpose. 

Include film, slides, or other training aids on Hawaiian soil, plant diseases 

and pests 

Specifically outline, by demonstration, illustration, or picture, proper 

regulated garbage handling procedures and transport. 

Explain the manifesting process. 

Be presented in English and other appropriate languages. 

Procedures for reporting and data; procedures and reporting results of inspection 

of bales 

Procedures for cleaning affected equipment and areas. 

Records of training administered to employees shall be made available to PPQ personnel 

upon request. 
 

147

RECORDS AND MONITORING (INSPECTIONS)

HWS must maintain a log which records bale identification, date of baling, inspections 

done, any remedial measures (e.g., patches, rewrapping), and must document any spills 

or other mitigation actions taken. 

HWS must maintain records to indicate the date, weight, container number, and seal 

number when each load is destroyed. The records must be maintained and be available 

upon request by USDA-APHIS-PPQ. 

HWS must maintain a log which records the date, time, number, type and weight of the 

containers of Garbage and Regulated (domestic) Garbage transported and disposed of, 

and the name of the vehicle’s driver. This log will be made available to PPQ upon 

request. These records must be kept for a minimum of 3 years from the end of the month 

that the movement was made. 

To ensure compliance, PPQ officers will be permitted access to the firm’s premises and 

relevant records without prior appointment. 

ENVIRONMENTAL PROTECTION AND OTHER REGULATORY AGENCIES

By signing this agreement, the signer certifies that his/her facility has met or will meet 

the requirements of all applicable environmental and any other applicable regulatory 

authorities in addition to the Garbage and Regulated (domestic) Garbage handling 

procedures specified by the Animal and Plant Health Inspection Service. 

NOTIFICATION

PPQ shall be notified within 7 days of any change in business status, business operations, 

telephone number, business address, management, ownership or business dissolution. 

COMPLIANCE

This compliance agreement is nontransferable. If the person identified in section 7 as the 

signer of PPQ Form 519 leaves their present employer, company or position, then he/she 

must notify the local PPQ office immediately. This agreement will then be terminated.

If Garbage and Regulated (domestic) Garbage is to be handled by other personnel within 

the company, those persons must be under the permittee’s supervision and must be aware 

of and able to adhere to all stipulations in this agreement. 

This compliance agreement may be amended as necessary by USDA, APHIS, PPQ. HWS 

will be notified of all amendments. 

 NOTE: “Any person who knowingly violates the Plant Protection Act (PPA) (7 U.S.C. 

§§ 7701 et. Seq.) And/or the Animal Health Protection Act (AHPA) (7 U.S.C. §§ 8301 

et. Seq.) may be criminally prosecuted and found guilty of a misdemeanor which can 

result in penalties, and one year prison term, or both. Additionally, any person violating 
 

148

the PPA and/or the AHPA may be assessed civil penalties of up to $250,000 per 

violation or twice the gross gain or gross loss for any violation that results in the person 

deriving pecuniary gain or causing pecuniary loss to another, whichever is greater.” 

WITHDRAWAL OF COMPLIANCE AGREEMENT

This compliance agreement may be canceled, by a PPQ Officer orally or in writing, if 

such officer determines that the holder thereof has not complied with any of the 

conditions stated in this compliance agreement. If the cancellation is oral, the 

cancellation and the reasons for the cancellation will be confirmed in writing as promptly 

as circumstances allow. Any person whose compliance agreement has been canceled may 

appeal the decision in writing to USDA- APHIS- PPQ within ten (10) days after 

receiving the written notification of the withdrawal. The appeal must be directed to the 

State Plant Health Director of Washington. The appeal must state all of the facts and 

reasons upon which the person relies to show that the compliance agreement was 

wrongfully canceled. USDA-APHIS-PPQ shall grant or deny the appeal, in writing, 

stating the reasons for such decision, as promptly as circumstances allow. If there is a 

conflict as to any material fact, a hearing shall be held to resolve such conflict. Rules of 

practice concerning such a hearing will be adopted by USDA-APHIS-PPQ. 

 Agreement

By signing this agreement, the primary holder of Hawaiian Waste Systems, LLC agrees 

to maintain the scope and intention of this compliance agreement. The signature further 

certifies that the listed business has met or will meet the requirements of all other 

applicable environmental authorities prior to the processing of any USDA, APHIS, PPQ 

Garbage and Regulated (domestic) Garbage. 

This agreement may be immediately canceled or revoked for noncompliance. 

I have read and understand the conditions of this compliance agreement. 

 

 

6.Signature 

 

7. Title 8. Date Signed 

The affixing of the signatures below will validate this agreement, which shall remain in effect until 

canceled, but may be revised as necessary or revoked for noncompliance. 

10. Date of Agreement 11. Agreement Number 

PPQ OFFICIAL (Name and Title) 

 

Signature 

ADDRESS 

STATE AGENCY OFFICIAL (Name and Title) ADDRESS 
 

149

 

Signature 

PPQ FORM 519 

(FEB 2002) 

 
 

150

Appendix B. Marine Mammal Protection Act 

The Marine Mammal Protection Act (MMPA) prohibits, with certain exceptions, the take 

of marine mammals in U.S. waters and by U.S. citizens on the high seas, and the 

importation of marine mammals and marine mammal products into the U.S. All marine 

mammals are protected under the MMPA. 

Hawaii’s Marine Mammals: 

(From http://www.konawhalewatch.com/main_file.php/general/27/ last accessed June 

13, 2006) 

Baird’s Beaked Whale 

(Berardius bairdii) family: Ziphiidae 

Blainville’s Beaked Whale 

(Mesoplodon densirostris) family: Ziphiidae 

Bryde’s Whale 

(Balaenoptera edeni) family: Balaenopteridae 

Cuvier’s Beaked Whale 

(Ziphius cavirostris) family: Ziphiidae 

Dwarf Sperm Whale 

(Kogia simus) family: Physeteridae 

False Killer Whale 

(Pseudorca crassidens) family: Delphinidae 

Fin Whale 

(Balaenoptera physalus) family: Balaenopteridae 

Humpback Whale 

(Megaptera novaeangliae) family: Balaenopteridae 

Killer Whale 

(Orcinus orca) family: Delphinidae 

Melon-headed Whale 

(Peponocephala electra) family: Delphinidae 

Minke Whale 

(Balaenoptera acutorostrata) family: Balaenopteridae 
 

151

Northern Right Whale 

(Eubalaena glcialis) family: Balaenidae 

Pacific Bottlenose Dolphin 

(Tursiops gilli) family: Delphinidae 

Pygmy Killer Whale 

(Feresa attenuata) family: Delphinidae 

Pygmy Sperm Whale 

(Kogia breviceps) family: Physeteridae 

Risso’s Dolphin 

(Grampus griseus) family: Delphinidae 

Rough-toothed Dolphin 

(Steno bredanensis) family: Delphinidae 

Short-finned Pilot Whale 

(Globicephala macrorhynchus) family: Delphinidae 

Sperm Whale 

(Physeter macrocephalus) family: Physeteridae 

Spinner Dolphin 

(Stenella longirostris) family: Delphinidae 

Spotted Dolphin 

(Stenella attenuata) family: Delphinidae 

Striped Dolphin 

(Stenella coeruleoalba) suborder: Odonticeti family: Delphinidae 

Hawaiian Monk Seal (From: http://www.earthtrust.org/wlcurric/seals.html last 

accessed June 13, 2006)

(Monachus schauinslandi) family: Phocidae 
 

152

Washington’s Marine Mammals 

(From 

http://www.washington.edu/burkemuseum/collections/mammalogy/mamwash/mamwash.

html#cetacea last accessed June 13, 2006) 

Northern Right Whale, 

(Eubalaena glacialis) family: Balaenidae 

 

Minke Whale 

(Balaenoptera acutorostrata) family: Balaenopteridae 

Sei Whale 

(Balaenoptera borealis) family: Balaenopteridae 

Blue Whale 

(Balaenoptera musculus) family: Balaenopteridae 

Fin Whale 

(Balaenoptera physalus) family: Balaenopteridae 

Humpback Whale 

(Megaptera novaeangliae) family: Balaenopteridae 

Gray Whale 

(Eschrictius robustus) family: Eschrichtidae 

Short-Beaked Saddleback Dolphin 

(Delphinus delphis) family: Delphinidae 

Short-finned Pilot Whale 

(Globicephala macrorhynchus) family: Delphinidae 

Risso’s Dolphin 

(Grampus griseus) family: Delphinidae 

 

Pacific White-sided Dolphin 

(Lagenorhynchus obliquidens) family: Delphinidae 

 

Northern Right-Whale Dolphin 

(Lissodelphis borealis) family: Delphinidae 

Killer Whale 

(Orcinus orca) family: Delphinidae 

False Killer Whale 
 

153

(Pseudorca crassidens) family: Delphinidae 

Striped Dolphin 

(Stenella coeruleoalba) family: Delphinidae 

Rough-toothed Dolphin 

(Steno bredanensis) family: Delphinidae 

Bottle-nosed Dolphin 

(Tursiops truncates) family: Delphinidae 

 

Pygmy Sperm Whale 

(Kogia breviceps) family: Kogiidae 

Dwarf Sperm Whale 

(Kogia sima) family: Kogiidae 

Harbor Porpoise 

(Phocoena phocoena) family: Phocoenidae 

Dall's Porpoise 

(Phocoenoides dalli) family: Phocoenidae 

 

Sperm Whale 

(Physeter macrocephalus) family: Physeteridae 

Baird's Beaked Whale 

(Berardius bairdii) family: Ziphiidae 

Hubbs Beaked Whale 

(Mesoplodon carlhubbsi) family: Ziphiidae 

Pacific Beaked Whale 

(Mesoplodon stejnegeri) family: Ziphiidae 

Cuvier's Beaked Whale 

(Ziphius cavirostris) family: Ziphiidae 

Sea Otter 

(Enhydra lutris) family: Mustelidae 

Northern Fur Seal 

(Callorhinus ursinus) family: Otariidae 

Steller Sea Lion 

(Eumetopias jubatus) family: Otariidae 
 

154

 

California Sea Lion 

(Zalophus californianus) family: Otariidae 

Northern Elephant Seal 

(Mirounga angustirostris) family: Phocidae 

 

Harbor Seal 

(Phoca vitulina) family: Phocidae 

Oregon’s Marine Mammals 

(From http://www.mammalsociety.org/statelists/ormammals.html last accessed June 13, 

2006) 

Black Right Whale, 

(Eubalaena glacialis) family: Balaenidae 

 

Minke Whale 

(Balaenoptera acutorostrata) family: Balaenopteridae 

Sei Whale 

(Balaenoptera borealis) family: Balaenopteridae 

Blue Whale 

(Balaenoptera musculus) family: Balaenopteridae 

Fin Whale 

(Balaenoptera physalus) family: Balaenopteridae 

Humpback Whale 

(Megaptera novaeangliae) family: Balaenopteridae 

Gray Whale 

(Eschrictius robustus) family: Eschrichtidae 

Sperm Whale 

(Physeter macrocephalus) family: Physeteridae 

Pygmy Sperm Whale 

(Kogia breviceps) family: Kogiidae 

Baird's Beaked Whale 

(Berardius bairdii) family: Ziphiidae 
 

155

Pacific Beaked Whale 

(Mesoplodon stejnegeri) family: Ziphiidae 

Cuvier's Beaked Whale 

(Ziphius cavirostris) family: Ziphiidae 

Pacific Striped Dolphin 

(Lagenorhynchus obliquidens) family: Delphinidae 

Dall Porpoise 

(Phocoenoides dalli) family: Delphinidae 

Harbor Porpoise 

(Phocoena phocoena) family: Delphinidae 

Pilot Whale, 

(Globicephala macrorhynchus) family: Delphinidae 

Killer Whale 

(Orcinus orca) family: Delphinidae 

Rough-toothed Porpoise 

(Steno bredanensis) family: Delphinidae 

Northern Right Whale Dolphin 

(Lissodelphis borealis) family: Delphinidae 

False Killer Whale 

(Pseudorca crassidens) family: Delphinidae 

Risso's Dolphin 

(Grampus griseus) family: Delphinidae 

Northern Fur Seal 

(Callorhinus ursinus) family: Otariidae 

Steller Sea Lion 

(Eumetopias jubatus) family: Otariidae 

California Sea Lion 

(Zalophus californianus) family: Otariidae 

Northern Elephant Seal 

(Mirounga angustirostris) family: Phocidae 

Harbor Seal 
 

156

(Phoca vitulina) family: Phocidae 

Sea Otter 

(Enhydra lutris) family: Mustelidae 

California’s Marine Mammals (within program action area) 

(From http://www.dfg.ca.gov/Mrd/mambk_a.pdf last accessed June 13, 2006) 

Northern Right Whale, 

(Eubalaena glacialis) family: Balaenidae 

Minke Whale 

(Balaenoptera acutorostrata) family: Balaenopteridae 

Sei Whale 

(Balaenoptera borealis) family: Balaenopteridae 

Blue Whale 

(Balaenoptera musculus) family: Balaenopteridae 

Fin Whale 

(Balaenoptera physalus) family: Balaenopteridae 

Humpback Whale 

(Megaptera novaeangliae) family: Balaenopteridae 

Gray Whale 

(Eschrictius robustus) family: Eschrichtidae 

Short-Beaked Saddleback Dolphin 

(Delphinus delphis) family: Delphinidae 

 

Short-finned Pilot Whale 

(Globicephala macrorhynchus) family: Delphinidae 

Risso’s Dolphin 

(Grampus griseus) family: Delphinidae 

Pacific White-sided Dolphin 

(Lagenorhynchus obliquidens) family: Delphinidae 

Northern Right-Whale Dolphin 

(Lissodelphis borealis) family: Delphinidae 
 

157

Killer Whale 

(Orcinus orca) family: Delphinidae 

Harbor Porpoise 

(Phocoena phocoena) family: Phocoenidae 

Dall's Porpoise 

(Phocoenoides dalli) family: Phocoenidae 

False Killer Whale 

(Pseudorca crassidens) family: Delphinidae 

Striped Dolphin 

(Stenella coeruleoalba) family: Delphinidae 

Rough-toothed Dolphin 

(Steno bredanensis) family: Delphinidae 

Bottle-nosed Dolphin 

(Tursiops truncates) family: Delphinidae 

Pygmy Sperm Whale 

(Kogia breviceps) family: Kogiidae 

Dwarf Sperm Whale 

(Kogia sima) family: Kogiidae 

Sperm Whale 

(Physeter macrocephalus) family: Physeteridae 

Baird's Beaked Whale 

(Berardius bairdii) family: Ziphiidae 

Hubbs Beaked Whale 

(Mesoplodon carlhubbsi) family: Ziphiidae 

Cuvier's Beaked Whale 

(Ziphius cavirostris) family: Ziphiidae 

Northern Fur Seal 

(Callorhinus ursinus) family: Otariidae 

Steller Sea Lion 

(Eumetopias jubatus) family: Otariidae 
 

158

California Sea Lion 

(Zalophus californianus) family: Otariidae 

Northern Elephant Seal 

(Mirounga angustirostris) family: Phocidae 

Harbor Seal 

(Phoca vitulina) family: Phocidae 

Sea Otter 

(Enhydra lutris) family: Mustelidae 

Assessment: 

These species could be harassed by the operation of towing vessels during barge 

movement. The physical presence of tugs and barges could lead to disturbance of marine 

mammals by visual or other cues. Marine debris could be generated if integrity of bales 

is not maintained. 

The potential for collisions between the tug/barge and marine mammals is very low due 

to the slow tow speed (6-9 knots). Noise or visual disturbance will not likely occur since 

marine mammals have demonstrated little behavioral reaction to slow-moving vessels, 

according to surveys conducted (NMFS, 2006). The baled garbage will be inspected at 

multiple points in the transport process to ensure that bales are intact and garbage will not 

be released. Therefore, implementation of the proposed action is expected to be 

protective of marine mammals within the action area. 

Reference: 

United States Department of Commerce. 2006. National Marine Fisheries Service. 

Small takes of marine mammals incidental to specified activities; movement of barges 

through the Beaufort Sea between West Dock and Cape Simpson or Point Lonely, 

Alaska. Federal Register, Vol. 71, p34064, June 13, 2006. 
 

159

Appendix C. Risk of Introduction of Pests to the Continental United 

States via Municipal Solid Waste from Hawaii. 
United States 

Department of 

Agriculture 

Animal and Plant 

Health Inspection 

Service 

March 2006 

Updated August 2006 

The Risk of Introduction of Pests to the 

Continental United States via Plastic-Baled 

Municipal Solid Waste from Hawaii 

Executive Summary 

Companies have proposed transporting large volumes of Hawaiian 

municipal solid waste (MSW) in airtight bales to landfills in the 

continental United States. The bales are created by shredding, 

compressing, and wrapping MSW in adhesive-backed, plastic film 

barriers. Airtight enclosure from creation to burial would mitigate plant 

pest risks, but this technology is still relatively new. Moreover, federal 

regulations prohibit garbage from Hawaii from entering the continental 

United States. Thus, the Center for Plant Health Science and Technology 

(CPHST) was asked to assess the risks of plant pest establishment via this 

pathway. Specifically, we assessed the soundness of baling technology 

and the safety of the general pathway, considering here those processes 

likely to apply to all company proposals. We also did a generic 

quantitative analysis of the likelihood of bale-rupturing accidents via the 

different conveyances: trucks, trains, and barges. Some proposal-specific 

parameters, such as the locations of landfills on the mainland and the types 

of transport to be used, will be evaluated separately for each particular 

proposal to identify any exceptionally significant risk factors. 

Published, independent scientific testing of the baling technology 

confirmed manufacturers’ specifications and indicated that it is likely to 

mitigate the risk from all types of plant pests. In particular, insects, 

mollusks, and some pathogens are unlikely to survive in the bales because 

of compression, anoxia, and the absence of hosts. Other procedures, such 

as bale construction, monitoring during transport, and burial in regulated 

landfills, should adequately protect against escapes from within bales via 

accidental ruptures and punctures during handling and transport. 

Compliance with general procedures, such as diversion of yard and 

agricultural waste, and proper staging and prompt shipment of bales, is 

also important. The accident rate analysis indicated a very low likelihood 

of bale-rupturing accidents for all conveyances. If these procedures are 

followed, transporting municipal solid waste from Hawaiian cities in bales 

poses an insignificant risk of plant pest introduction. In addition, we 

recommend that the pathway be monitored to ensure that pathway 

processes and compliance do not differ significantly from proposals 

evaluated here.
PRA for Baled Hawaiian Solid Waste 161

Table of Contents 

Executive Summary.................................................................................................................................. 1

I. Introduction ........................................................................................................................................... 3

II. Definitions............................................................................................................................................. 3

III. Detailed overview ............................................................................................................................... 4

IV. Validity of the baling technology....................................................................................................... 5

V. Potential plant pests............................................................................................................................. 6

VI. Pest risk mitigations ........................................................................................................................... 7

Mitigations from the baling technology.................................................................................................. 7 

Mitigation from pathway procedures...................................................................................................... 7 

VII. Risk of bale-rupturing accidents ..................................................................................................... 9

Model development and parameterization.............................................................................................. 9 

Results and discussion .......................................................................................................................... 10 

VIII. Qualitative risk assessment........................................................................................................... 11

IX. Conclusions ....................................................................................................................................... 12

Contact..................................................................................................................................................... 13

References................................................................................................................................................ 13

Appendices............................................................................................................................................... 12

Appendix A. Lists of selected Hawaiian pests, including insects, pathogens, and pest plants of 

quarantine significance to the continental United States. The lists focus on plant pests but also include 

other categories of pests, such as human health pests. ......................................................................... 12 

Appendix B. Modeling the likelihood of bale-rupturing accidents during transport of baled municipal 

solid waste (MSW) by truck, rail, or barge........................................................................................... 37 
PRA for Baled Hawaiian Solid Waste 162

I. Introduction 

Companies have proposed transporting up to 300,000 tons (lbs) of baled municipal solid waste (MSW) 

per year from Hawaii to landfills in the continental United States. Bales will be created by compressing 

and wrapping MSW in adhesive-backed, plastic film barriers made of low density polyethylene (LDPE), 

creating airtight packages. Bales would be transported by barge to the mainland and then perhaps by 

other means to landfills, and ultimately buried intact, in accordance with regulations for solid waste 

disposal (40CFR§258; EPA (1993)). Garbage from Hawaii is not enterable under current federal 

regulations for plant pests (7CFR§330.400). Therefore, an assessment of the risks of plant pest 

introduction via baled Hawaiian MSW to the continental United States is needed. At the request of the 

State of Hawaii, this assessment was done by the Center for Plant Health Science and Technology 

(CPHST), part of the Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of 

Agriculture (USDA). 

The objective of this report is to evaluate whether the baling technology will effectively mitigate 

potential plant pest risks associated with MSW from Hawaii. The assessment focuses upon the planned 

use of the baling technology, because airtight enclosure from creation to burial would mitigate the risks 

of establishment by any plant pests (Appendix A). We address the following three questions: 

1) Does the baling technology provide a strong, airtight barrier? 

2) How likely are bale-rupturing accidents for barges, trucks, and trains during transport? 

3) How likely are punctures? and 

4) Will general pathway procedures reduce pest incidence in the bales and the chances of escape in 

the event of accidental ruptures or punctures? 

In addition, we give qualitative risk ratings for different pest types based on the likelihood of 

introduction. Only those pathway processes likely to be common to all company proposals to transport 

baled Hawaiian waste were considered. Separate assessments for particular company proposals will 

address factors such as the destination landfill, type of transportation to be used on the mainland, and 

pest species that may pose particular threats. 

II. Definitions 

Garbage is defined as urban (commercial and residential) solid waste from municipalities on any 

Hawaiian island, such as Honolulu on Oahu, and Hilo on Hawaii. Based on company proposals to move 

baled waste (not shown), this analysis assumed that yard and agricultural waste will be excluded from 

the waste stream. Therefore, the volume of any such waste accidentally entering the pathway should be 

minimal. If it was found that yard and agricultural waste was not typically excluded, a revised 

assessment might be necessary. 

A spill is defined as the escape of waste material from a bale and contact with the surrounding 

environment, e.g. ground, truck, tractor, barge, or other terrestrial features. 

Other important terms are defined as follows (Merriam-Webster, 2004): 

Anoxia: hypoxia especially of such severity as to result in permanent damage 

Anoxic: greatly deficient in oxygen 

Hypoxia: a deficiency of oxygen in organisms/bodily tissues 
PRA for Baled Hawaiian Solid Waste 163

Anaerobic means living, active, occurring, or existing in the absence of free oxygen. Thus, the term 

anaerobic is only correctly applied to organisms, not non-living things like bales, or the conditions 

within them. 

III. Detailed overview 

Some details will be specific to each company proposal, such as the landfill site and means of transport 

within the continental U.S., but general characteristics related to the pathway include the following: 

1) The material to be transported is municipal solid waste 

2) Agricultural and yard waste will be diverted to other transfer stations and waste streams, and actively 

removed at some processing centers; only incidental amounts of yard waste are likely to enter the 

waste baling process 

3) A baling system will be used to create high-density bales (ca. 1000 pounds per cubic yard) wrapped 

with at least four layers of adhesive-backed plastic 

4) The shape and weight of the bales depends on the technology used but rectangular bales with weights 

from 2 to 12 tons might be expected 

5) Bales will be stored, or ‘staged,’ for a short time—e.g., five days (Pacific Rim Environmental 

Resources, 2004)—before transport to allow bales to become anoxic 

6) Manifested bales will be moved on barges to the mainland, a trip of about 12 to 18 days 

7) Bales will eventually be unloaded and moved by truck or by rail to a landfill 

8) In procedures likely to be specified in compliance agreements, companies will monitor bales to detect 

ruptures and punctures during transport, with particular regard for handling operations (loading and 

unloading) 

9) Landfilled bales will be covered with at least six inches of soil within 24 hours (EPA, 1993) 

10) Landfilled bales will ultimately be covered by at least seven feet of material if placed on the top 

(final) waste layer, but many more feet if placed closer to the bottom layer 

Other important points include the following: 

▪ Hazardous and liquid wastes will be diverted or removed before shredding and baling 

▪ Waste and bales will not contact soil after collection or wrapping (i.e., stored on asphalt, concrete, etc) 

▪ Imperfectly sealed bales found during staging in Hawaii will be rewrapped and re-staged 

▪ Fewer ruptures of bales seem likely to occur with tractors that have grabbing rather than forked lift 

arms (Figure 1) 

▪ Companies will deal appropriately with punctures and small ruptures detected after shipment 

▪ Companies will handle larger ruptures by collecting spilled waste, storing all waste in sealed 

containers, and rewrapping and re-staging waste 

▪ Spills will be cleaned up and disinfected according to USDA guidelines for spills of international 

garbage (PPQ, 2004) 

▪ All ruptures and punctures will be documented and reported regularly to PPQ and State officials 

▪ Destination landfills will be modern facilities that meet all regulations for design and operation (e.g., 

EPA, 1993) 

Finally, we presumed here that after creation, bales will only be moved once into staging, and then once 

again onto barges bound for the mainland. (Of course, bales will once again be handled on the 

mainland.) Additional handling in Hawaii, for instance to transport bales from other islands to a central 

location for staging and barge loading, would increase the risk of punctures and ruptures. 
PRA for Baled Hawaiian Solid Waste 164

Figure 1. Example tractor with ‘grabbing’ lift arms for handling bales. 

IV. Validity of the baling technology 

Although sizes and shapes of bales depend on the exact technology used, bale creation processes and 

specifications are similar across different manufacturers (e.g., DEKRA (1996), Roll Press Pack 

International, Ltd. (2004), RPP America (2004), and Cross Wrap (2004)). Information from 

manufacturers (e.g., DEKRA, 1996) was corroborated by independent research (see below). During the 

baling process waste material is shredded if necessary, compressed to a high density, wrapped with 

bands or netting to maintain shape (Fig. 2), and then wrapped with adhesive-coated LDPE. At least four 

layers of plastic are used, forming a strong, airtight barrier (Appendix A). Bale shape depends on the 

process, with cylinders created in “roll-press” systems and rectangles created in ramming systems (e.g., 

Baldasano et al., 2003). Roll-press systems tend to result in bales with less trapped air (Sieger and 

Kewitz, 1997). The degree of compression is typically greater with rectangular bales, and more liquid is 

pressed out as well. Bale densities are expected to be in the range of 800 to 1100 kg/m3

 (ca. 1300 to 

1800 lbs/yd3

) (Baldasano et al., 2003). 

The bales become anoxic within a few days after wrapping (Paillat and Gaillard, 2001; Robles-Martinez 

and Gourdon, 1999). The O2 concentration of normal air is 21 percent (21 kPa), but concentrations in 

bales were near 2 percent (ca. 2 kPa). Because of that and other factors, very little biodegradation or 

production of gases occurs. 

The wrapping is strong as well as airtight. According to Baldasano et al. (2003), the LDPE “...has a 

high, although not total, degree of resistance to perforation and tearing.” Pre-stretching helps maintain 

bale shape, increases adhesion, and helps prevent ruptures. Bales weighing less than 1000 kg did not 

rupture when dropped from a height of 3 m (DEKRA, 1996). A user in Utah reported that bales larger 

than 1000 kg rupture when dropped 3.1 to 7.6 m (10 to 25 ft) onto the vertical sides of railroad cars 

(pers. comm., Barry Edwards, North Pointe Waste Transfer Station, Lindon, UT). USDA will not allow 

Hawaiian baled MSW to be handled that way. Pointed or sharp objects within the bales might perforate 
PRA for Baled Hawaiian Solid Waste 165

the plastic (Baldasano et al., 2003) but we found no indication that this has commonly occurred, and 

compression would reduce that possibility. 

Under normal storage conditions, the bales typically remain airtight for many months (Robles-Martinez 

and Gourdon, 2000). LDPE film degrades over time when exposed to sunlight. The plastic film used in 

this baling process is expected to remain effective for at least 100 days (Paillat and Gaillard, 2001) and 

possibly for up to 12 months (Baldasano et al., 2003) in direct sunlight. The combined storage and 

transit time from Hawaii to the mainland is unlikely to exceed 100 days (see below). 

The adhesive-backing provides the plastic film with a self-sealing capability: small ruptures (size 

unspecified) tend to become airtight again (Paillat and Gaillard, 2001). That, and the density of the 

waste itself, should help mitigate the chance of material escaping through punctures and small ruptures 

but cannot be relied upon exclusively. The plastic or metal netting used in some baling technologies to 

maintain shape would also limit the chance of waste and plant pests escaping through ruptures but the 

rectangular bale system apparently uses straps rather than netting. 

Overall, the waste baling technologies using adhesive-backed plastics seem very sound, creating strong, 

airtight bales that can be safely handled, stored, and transported. 

©2006 PAALGroup. Used by permission 

Figure 2. A representative high-density bale of compacted solid waste, 

ready to be wrapped in adhesive-backed plastic. 

V. Potential plant pests 

Specific pests are not discussed here because the species of interest will depend upon the destination, 

and because the baling technology will be universally effective against all types of pests if bales remain 

airtight. Lists of selected Hawaiian insects, pathogens, and pest plants of quarantine concern for the 
PRA for Baled Hawaiian Solid Waste 166

contiguous 48 states are given in Appendix A. Those lists include both plant pests and other pests that 

pose human health risks (e.g., cockroaches). 

VI. Pest risk mitigations 

Mitigations considered here either result from the baling technology itself or features of the proposed 

pathway, including the waste type, and how bales are staged, handled, transported, and buried. 

Mitigations from the baling technology 

Bales that remain airtight from creation until burial completely mitigate the risk from all plant pests 

because the pests and pest propagules cannot escape. That mitigation is universal, i.e. it does not depend 

on pest type or taxonomy, and probably applies equally to both current and future pests that establish in 

Hawaii. Because of the possibility of accidental ruptures or punctures, however, we also consider pest 

mortality and the effects of other pathway factors. 

Given that achieved bale densities should be about 1000 kg/m3

, compaction would likely kill most 

insects, regardless of stage (see Montgomery and Manning, 2004). This would therefore greatly reduce 

the possibility of boring-type insects chewing through the plastic wrapping, which, moreover, would 

only be possible if those insects ended up on the outermost surface of the compacted waste. In addition, 

compaction ensures no whole fruit will enter bales. Compaction may also neutralize some weed seeds 

and nematodes, but at a greatly reduced rate than for other organism types. Shredding will have some 

mitigative effects if done, but that would depend on the technology used and the pest organism type. 

Anoxia would kill any insects and insect propagules or mollusks that remain viable in the bales, 

probably within a few days (Hinton, 1981; Hoback and Stanley, 2001; Montgomery and Manning, 2004; 

Navarro and Donahaye, 2005; Robinson, 2006; Woods and Hill, 2004). This idea has been used for 

centuries for pest-free food storage (e.g., De Lima, 1990). Concentrations of less than 3 percent O2

provide control, while concentrations of less than 1 percent provide rapid control (Navarro and 

Donahaye, 2005). Adults and eggs of insects are probably most sensitive to hypoxia (Hoback and 

Stanley, 2001). Insect and mollusk mortality is important because, of the pest organisms considered 

here, only those actively disperse. 

Anoxia by itself would not kill most weed seeds (Paillat and Gaillard, 2001). Some pathogens would be 

killed by persistent anoxia, such as some bacteria and nematodes, but many others could be unaffected 

(L.M. Ferguson, 2005, CPHST, pers. commun.,). 

Mitigation from pathway procedures 

Waste stream. For MSW in the United States, paper is the single largest component at 35 percent, on 

average, while inorganic components (e.g., plastic, glass) make up an additional 32 percent (EPA, 

2005). Food waste and yard trimming each make up 12 percent, and wood makes up 6 percent of the 

waste stream. Exclusion of yard and agricultural waste from the baling waste stream in Hawaii should 

reduce the number of potential pests and pest propagules in this pathway to very low levels. Green 

recycling operations in urban areas (e.g., Refuse Division, 2006) that separate the collection and 

processing of yard and agricultural waste from general MSW may also help reduce the chance of waste 
PRA for Baled Hawaiian Solid Waste 167

contamination. Regulated plant pests or pest propagules are likely to only be present in an extremely 

small proportion of any baled yard waste. 

On Oahu, the MSW most likely to be diverted to baling and transport is raw MSW going to Waimanalo 

Gulch landfill, which has a mean of 6.0 percent yard waste (± 3.4 percent) (R. M. Towill Corporation, 

1999). Likewise, MSW on Hawaii has a mean percentage of yard waste of 5.4 percent (M. Dworsky, 

County of Hawaii, 2006, pers. commun. to D. Alontaga). By comparison, the yard waste fraction in 

residential MSW on Oahu—which is very unlikely to enter the baling process—is almost 30 percent (R. 

M. Towill Corporation, 1999). Companies plan to further screen and remove visible yard waste in 

transfer stations or on bale processing lines. If those procedures were 50 percent effective, they would 

reduce the fraction of yard waste in baled Hawaiian MSW from 6 percent to 3 percent or less. Screening 

and exclusion is likely to be made more effective because most yard waste in MSW will be clumped 

(e.g., bags of grass clippings or leaves). As the proportion of yard waste decreases, removal will become 

increasingly difficult. Given the mitigations from baling and other pathway factors, we think these 

incidental amounts probably still represent a Low risk of plant pest introduction. 

Staging. The minimum staging plus transport time is about 15 days, which is more than enough time for 

the bales to become anoxic. The maximum staging plus trip time is unknown. We recommend a waiting 

period before transport of less than 75 days to avoid nearing the 100-day period for the earliest possible 

degradation by sunlight. 

During staging, bales might become contaminated with hitchhiking plant pests, and mollusks in 

particular (Robinson, 2006). For example, plastic-wrapped pallets of stone and tiles from Italy that are 

left in fields before shipping have often become contaminated with snails and slugs (USDA-APHISPPQ, 2005). The requirement that bales not contact soil should reduce the risk of contamination. Still, 

we strongly recommend that the two following precautions also be taken: 1) that bales be staged or 

stored as far from vegetation and pavement borders as possible, and 2) that bales be certified as snailand slug-free before shipment (details to be specified in compliance agreements). 

Handling. Ruptures and punctures of bales are most likely to occur during loading and unloading; 

moving accidents will probably be rare. These rates are as yet unknown. Punctures seem very unlikely to 

occur if tractors have grabbing lift arms rather than forks. Bales may rupture if dropped from heights of 

3 m or more; that depends upon bale weight and shape and other factors. Using tractors like that in Fig. 

1 will greatly reduce the risk of drops from significant heights—because bales are clamped during 

movement rather than balanced on forks—even if bales are occasionally stacked 3 m high or more, such 

as might happen during staging. 

Monitoring. Companies will likely be required to monitor bales for two things: 1) punctures and 

ruptures, and 2) the presence of hitchhiking snail and slug pests before bales depart for the mainland 

(above). If bales are to be certified mollusk-free, responsible parties will need to be specified in 

compliance agreements. Ruptures are likely to be detected, since they will probably result from drops, 

and we expect any dropped bales to be inspected carefully at the time. Punctures are less likely to be 

detected but are much less likely to occur if grabbing-type lift arms are used, and are most likely to selfseal (see above). All compliance will be monitored by PPQ and/or State personnel. 

Transport on the mainland. See Section (VII) below. 
PRA for Baled Hawaiian Solid Waste 168

Clean up. Bale density, binding materials, and the self-sealing ability of the LDPE should all limit the 

amount of escaping material. Most weed seeds and plant pathogens will have little or no ability to 

disperse after a spill. One exception may be spores which are small enough for wind-dispersal. 

Pathogens dispersing to a susceptible host, or invasive plant seeds dispersing to a suitable site for growth 

are highly unlikely, assuming clean-up procedures are followed scrupulously. Thorough cleaning should 

capture nearly all waste material, and proper use of approved disinfectants (PPQ, 2004) will likely 

control any escaped pathogens.

Landfilling. Because of monitoring, bale-handling technologies, and the low number of times bales will 

be handled, only airtight bales are likely to enter the landfill. If the handling equipment used in the 

landfills is similar to that used previously, ruptures during placement will be unlikely. Covering with a 

6-inch barrier of soil or other material (see 40CFR§258.21) within 24 hours will further mitigate the 

possibility of dispersal of plant pests or propagules, by both natural and vector-caused means. Baled 

waste is unlikely to be attractive to vectors because of its composition, appearance, and the lack of 

odorous biodegradation (above). Most proposals specify that bales will be landfilled separately from 

other waste (“monofilled”); this means bales will not be subjected to compacting of regular, loose MSW 

by tractors. Ultimately, landfilled bales will be covered with from seven to dozens of feet of materials 

(see 40 CFR §258.60), depending upon the layer in which they are placed. In addition, the final cover 

has water-impermeable layers (EPA, 1993). 

VII. Risk of bale-rupturing accidents 

Model development and parameterization 

We estimated the annual accident rates for trucks, trains, and barges, and years to the first bale-rupturing 

accident for each, in a probabilistic model (Appendix B). We did this for generic but realistic travel 

distances of 25 miles by truck, 500 miles by rail, and 140 miles by barge on the Columbia River. From 

the number of 3.3-ton bales required to transport 300,000 tons of MSW, and the number of bales per 

truck (25 ton capacity, 7 bales per truck on average), barge (10,000 ton capacity, ca. 2,900 bales per 

barge), and train (ca. 2900 bales), we calculated the annual number of trips required, total vehicle miles 

traveled (VMT), and, for barges, annual ton-miles (the product of tons and distance transported). 

Importantly, not every accident would rupture bales. For trucks, for example, fender-benders would not 

represent a risk for bale ruptures, while rollovers would. Thus we assumed that only bales ejected from 

the conveyance would be likely to rupture. 

Truck. The mean national accident rate for trucks was 1.96 per million VMT (2000 to 2004) (Analysis 

Division, 2006; Federal Motor Carrier Safety Administration, 2004). The fraction of those relevant to 

the transportation of baled MSW—accidents to flat bed trailers moving intrastate—was about 1.5 

percent . The fraction of accidents that released some cargo was 0.325 for flatbed trucks (1991 to 2000: 

Craft, 2004). 

Train. For the period from 1996 to 2005, the mean accident rate for trains was 3.94 per million VMT 

(all rail modes: Office of Safety Analysis, 2006). The fraction of those accidents relevant to baled MSW 

was the product of the proportion that occurred on main lines (i.e., greater speed), about 0.55, and the 

proportion of those that occurred to freight trains, about 0.47 (e.g., Federal Railroad Administration, 

2005b). Finally, data from the same source on the proportions of accidents in which hazardous materials 
PRA for Baled Hawaiian Solid Waste 169

were released for 2000 to 2004 indicated that the mean likelihood for a cargo spill (i.e., bale rupture) 

was 0.039 (3.9 percent). 

Barge. The average haul distance for the Columbia River of 140 miles was estimated directly from 

freight transport data (e.g., U.S. Army Corps of Engineers, 2003): that distance approximated the 

average known distances that bales will likely be moved by transport companies. For the most recent 

available data, the number of accidents on the Columbia River was 80 in 2000 and 87 in 2001 (Marine 

Safety Offices, 2006). Accounting for the amount of freight moved (U.S. Army Corps of Engineers, 

2002, 2003) gave a mean accident rate for barges of 28.3 per billion ton-miles [a ton-mile is the product 

of the mass and distance moved]. Of those, only 4 of the 167 accidents (2.4 percent) on the Columbia 

River involved freight barges (Marine Safety Offices, 2006). The mean fraction of accidents that might 

cause bales to rupture was 0.11, estimated from the number accidents involving hazardous materials 

which resulted in releases (spills) from 1990 to 1997 (Office of Hazardous Materials Safety, 1999). 

Results and discussion 

Using the above parameter estimates in a probabilistic model (@Risk version 4.5.4 - Professional 

Edition, Palisade Corporation, Ithaca, NY), we estimated that the annual likelihood of a bale-rupturing 

accident was 0.0035 for trucks, 0.0007 for trains, and 0.0029 for barges. The corresponding mean time 

to first bale-rupturing accident was 285 yr for trucks, 344 yr for barges, and more than 1,400 yr for trains 

(Fig. 3). We found a 95 percent chance that the first bale-rupturing accident would occur only after 15 yr 

for trucks, after 18 yr for barges, and after 74 yr for trains. 

Reductions in trip distance below 25 miles for trucks, 500 miles for trains, or 140 miles for barges would 

decrease the likelihood of bale-rupturing accidents. For example, the distance from the off-loading point 

to the landfill in Roosevelt, WA, is only 8 miles, meaning the risk of a truck accident for that particular 

pathway would likely be about two-thirds less. Similarly, accident rates would be proportionate to the 

total amount of MSW transported, so accident rates would be somewhat less at the start of operations 

until the capacity increased. Typically, proposals to move baled MSW from Hawaii use only two of the 

three conveyance types. 
PRA for Baled Hawaiian Solid Waste 170

0

0.2

0.4

0.6

0.8

1

0 1000 2000 3000 4000

 Years to first bale-rupturing accident (no.)

 Cumulative probability

Trucks

Trains

Barges

Figure 3. Model results for years to first bale-rupturing via three types of 

conveyances. Arrows indicate mean values of the output distributions. 

VIII. Qualitative risk assessment 

The baling technology is sound and should ensure that MSW is shipped only in strong, airtight bales. 

Compaction and the use of the baling technology may not kill seeds of invasive plants or some types of 

plant pathogens but makes their escape extremely unlikely. It especially mitigates against insect pests 

because of anoxia-induced mortality within a few days. Pathogens and seeds of invasive plants cannot 

actively disperse and except for significant ruptures would have little chance of escaping and coming 

into contact with acceptable hosts or suitable growth sites. Because of the structure of the bales, only 

catastrophic ruptures—which should always be detected—might facilitate significant dispersal of pests 

or pest propagules. The handling procedures, strength of the plastic wrapping and strapping materials, 

and the probable small accident rate for final transport to the landfill (above) reduce the likelihood of 

ruptures. Other procedures, such as patching or re-wrapping bales, cleanup and disinfection, and 

restaging bales will provide further mitigation. 

We qualitatively assessed the likelihood of introduction for general pest classes of insects, pathogens, 

and pest plants (invasive plants and weeds). We followed the PPQ guidelines for conducting pathwayinitiated risk assessments (PPQ, 2000), and modified them where appropriate. Some subelements were 

removed because they did not apply to this pathway, and totals were revised accordingly. Only the 

general pest classes of insects, mollusks, pathogens, and pest plants (invasive plants and weeds) were 

scored, because the baling technology is so broadly effective, and the very small likelihood of 

introduction for any particular pest. For each subelement a score of either none = 0, low = 1, moderate = 

2, or high = 3, was given. Values of zero are not usually possible but were reasonable here because of 
PRA for Baled Hawaiian Solid Waste 171

the potential effectiveness of the technology. Cumulative risk rating intervals were Low = 0 to 6, 

Moderate = 7 to 9, and High = 10 to 12 (after PPQ, 2000). 

The likelihood of introduction of plant pests inside bales of MSW was least for insects and mollusks 

(score = 1; Table 1), as expected due to mortality from anoxia. Cumulative ratings for pathogens and 

pest plants were greater because of the increased likelihood of survival inside the bales, but were still 

Low overall. Even if we assumed a moderate rate for accidental ruptures of bales, so that the likelihoods 

of pests dispersing and coming in contact with a suitable host or site were equal to 1, the overall risk 

estimates would still be Low (total = 6, for pathogens and weeds). 

Lastly, we did not include hitchhiking mollusks in Table 1, because as contaminating pests they would 

not reside in the bales, but under the same scoring they would rate High risk (1 + 3 + 3 + 3 = 10). This 

highlights the need to properly stage bales and certify them as being mollusk-free before shipment (see 

above). 

Table 1. Qualitative risk ratings for the likelihood of introduction into the continental United States for 

three pest types via Hawaiian municipal solid waste in airtight bales. Hitchhiking pests were not 

considered here (see text). 

Pests Risk subelements 

 1 2 3 4 

 Annual quantity 

imported 

Survive baling 

and shipment 

Moved to 

suitable habitat

Contact suitable 

host or site 

Cumulative 

risk ratings

Insects 1a 0 0 0 1 

Mollusks 1 0 0 0 1 

Pathogens 1 2 2 0 5 

Pest plants 1 2 2 0 5 

a

 The total amount of baled municipal solid waste may be high, but the proportion of waste that might 

harbor plant pests is low. 

IX. Conclusions 

Transporting urban solid waste from Hawaiian cities to the continental United States in airtight bales 

poses a Low risk of pest introduction. That is because the baling technology mitigates the risk from all 

types of plant pests, and the other pathway procedures should adequately protect against accidental 

ruptures and punctures in bales during the handling and transport process and subsequent escapes of 

pests and pest propagules. We also recommend proper staging of bales and certifying them as molluskfree to mitigate against contaminating pests. So long as those processes and the procedures proposed by 

the companies—including diversion of yard and agricultural waste, prompt shipment, monitoring and 

inspection of bales, and thorough clean up of any ruptures that do occur—are followed, establishment of 

Hawaiian plant pests via this pathway is highly unlikely. We recommend that this new pathway be 

monitored for some time to ensure that pathway procedures match those described here from proposals. 
PRA for Baled Hawaiian Solid Waste 172

Lastly, only the plant pest risk associated with the pathway was addressed here. Although we concluded 

that the overall pest risk was Low, complete approval by USDA for the pathway or particular procedures 

should not be inferred. The pathway, in whole or in part, may still be subject to denial or modification 

based upon other constraints (pest or non-pest related), such as logistics, available resources, or other 

Federal regulations. 

Contact 

Barney P. Caton, Ph.D., Ecologist and Pest Risk Analyst 

CPHST, Plant Epidemiology and Risk Analysis Laboratory (PERAL) 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

919-855-7504; 919-855-7595 (fax) 

barney.p.caton@aphis.usda.gov 

Authors: Barney P. Caton, Lisa M. Ferguson, and Betsy Randall-Schadel (PERAL, CPHST) 

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Sieger, E., and H.J. Kewitz. 1997. Application of baling technology for temporary storage of household 

waste. Proceedings of the Sixth International Landfill Symposium, Vol. 1, Cagliari, Sardinia, Italy. 

p. 457-462. 

U.S. Army Corps of Engineers. 2002. Waterborne Commerce of the United States: Calendar Year 2000, 

Part 5. Corps of Engineers, United States Army, Washington, D.C. 2002. 140 pp. 

U.S. Army Corps of Engineers. 2003. Waterborne Commerce of the United States: Calendar Year 2001, 

Part 5. Corps of Engineers, United States Army, Washington, D.C. 2003. 98 pp. 

USDA-APHIS-PPQ. 2005. Pest interception network (PIN309) [Online]. Plant Protection and 

Quarantine, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, 

Washington, D.C. 

Vose, D. 2000. Risk Analysis: A quantitative guide. 2nd ed. John Wiley & Sons, Ltd., New York. 418 

pp. 

Woods, H.A., and R.I. Hill. 2004. Temperature-dependent oxygen limitation in insect eggs. The Journal 

of Experimental Biology 207:2267-2276. 
PRA for Baled Hawaiian Solid Waste 175

Appendices Appendix A. Lists of selected Hawaiian pests, including insects, pathogens, and pest plants of quara

the continental United States. The lists focus on plant pests but also include other categories of pest

health pests. Table A1. Selected exotic or quarantine-significant plant pests from Hawaii for the 48 contiguous states in the Unitenot a complete list of all quarantine-significant pests from Hawaii and should not be regarded as such. 

Pest Geographic Distribution1 References 

INSECTA ACARI Tetranychidae Oligonychus biharensis (Hirst) HI Bolland, et al., 1998; CABIOligonychus mangiferus (Rahman & Sapra) HI Bolland et al., 1998 BLATTODEA Blaberidae Diploptera punctata (Eschscholtz) HI Anon., 2005; Evans, 2004; Blattellidae Blattella lituricollis (Walker) HI Anon., 2005; Evans, 2004; Blattidae Neostylopyga rhombifolia (Stoll) HI Anon., 2005; Evans, 2004; Platyzosteria soror (Brunner) HI Anon., 2005; Evans, 2004; Polyphagidae Euthyrrhapha pacifica (Coquebert) HI Anon., 2005; Evans, 2004; COLEOPTERA Anthribidae Exillis lepidus Jordan HI Swezy, 1950 Bostrichidae Sinoxylon conigerum Gerstaeker HI CABI, 2004; Nishida, 2002 
PRA for Baled Hawaiian Solid Waste 176

Pest Geographic Distribution1 References 

Cerambycidae Ceresium unicolor (F.) HI Nishida, 2002 Coptops aedificator (F.) HI Bridwell, 1920 Lagocheirus sp. HI, US Nishida, 2002; USDA-APHOopsis nutator (F.) HI Swezy, 1950 Sybra alternans (Wiedemann) HI Nishida, 2002; UH-CTAHR 

USDA-APHIS-PPQ, 2005 

Chrysomelidae Metriona circumdata (Herbst) HI CABI, 2001; HI-DoA, 2002 Octotoma scabripennis Guerin-Meneville HI CABI, 2003; Nishida, 2002 Cucujidae Parandrita aenea (Sharp) (= Laemophlaeus minutus[Oliv.])

HI Nishida, 2002 

Curculionidae Elytroteinus subtruncatus (Fairmaire) HI UH-CTAHR and HI-DoA, 

PPQ, 2002 

Euscepes postfasciatus (Fairmaire) HI, CA HI-DoA, 2002; O’Brien and Dryophthorus distinguendus Perkins HI Swezy, 1950 Orchidophilus aterrimus (Waterhouse) HI Tenbrink and Hara, 1994a Orchidophilus perigrinator (Buchanan) HI Tenbrink and Hara, 1994b Oxydema fusiforme Wollaston HI Swezy, 1950 Nitidulidae Carpophilus oculatus Murray HI Ewing and Cline, 2005; Gil

2002 

Epuraea munda (Sharp) HI Ewing and Cline, 2005 Epuraea ocularis Fairmaire (= Haptoncus ocularis 

[Fairmaire])

HI Chûjô and Lee, 1994; Ewin

Nishida, 2002 

Haptoncus ocularis (Fairmaire) HI Gillogly, 1962; Nishida, 20
PRA for Baled Hawaiian Solid Waste 177

Pest Geographic Distribution1 References 

Phenolia attenuata (Reitter) HI Ewing and Cline, 2005 Phenolia limbata (F.) HI Ewing and Cline, 2005 Platypodidae Platypus cupulatus Chapuis HI Wood and Bright, 1992 Scarabaeidae Adoretus sinicus Burmeister HI CABI, 2004; Nishida, 2002

2005 

Protaetia fusca (Herbst) HI CABI, 2004; Nishida, 2002

2005 

Scolytidae Coccotrypes sp. HI USDA-APHIS-PPQ, 2005 Ericryphalus henshawi Hopkins HI Swezy, 1949 Ericryphalus sylvicola (Perkins) HI Swezy, 1950 Ericryphalus trypanoides Beeson HI Van Zwaluwenburg, 1956 Euwallacea fornicatus (Eichhoff) HI CABI 2004; Hill 1994; Nish

and HI-DoA, 2005; Wood a

Hypothenemus ruficeps Perkins HI Swezy, 1941 Xyleborus fornicatus Eichhoff HI Swezy, 1950 Xyleborus perforans (Wollaston) HI CABI, 2004 Xylosandrus morigerus (Blandford) HI CABI, 2004; Wood and BriDIPTERA Agromyzidae Liriomyza huidobrensis (Blanchard) HI, CA CABI, 2004; Nishida, 2002

2005 

Melanagromyza splendida Frick HI Frick, 1953 Ophiomyia phaseoli Tryon HI CABI, 2003; Hill, 1994; Ni

Steyskal, 1986 
PRA for Baled Hawaiian Solid Waste 178

Pest Geographic Distribution1 References 

Lauxaniidae Homoneura hawaiiensis (Grimshaw) HI Hardy and Delfinado, 1980 Lonchaeidae Lamprolonchaea metatarsata (Kertész) HI Hardy and Delfinado, 1980 Muscidae Atherigona hendersoni Malloch HI Hardy, 1981 Otitidae Euxesta annonae (F.) HI, FL Steyskal, 1969; Stone et al.Euxesta wettsteini Hendel HI Hardy and Delfinado, 1980 Phoridae Puliciphora lucifera Dahl HI Hardy, 1964 Sciaridae Bradysia spatitergum (Hardy) (= Sciara spatitergum Hardy)

HI Hardy, 1960; Nishida, 2002 

Scatopsciara nigrita Hardy HI Hardy, 1960 Stratiomyidae Cephalochrysa maxima (Bezzi) (= Cephlochrysa [sic] 

hovas [Bigot])

HI Hardy, 1960; Nishida, 2002 

Exaireta (= Noexaireta) spinigera (Wiedemann) HI Hardy, 1960; Nishida, 2002 Syrphidae Syritta oceanica Macquart HI Hardy, 1964 Syritta orientalis Macquart HI Hardy, 1964 Tephritidae Bactrocera cucurbitae (Coquillett) HI CABI, 2003; Nishida, 2002

2005; White and Elson-Har

Bactrocera dorsalis (Hendel) HI CABI, 2004 Bactrocera latifrons (Hendel) HI CABI, 2004 Ceratitis capitata (Wiedemann) HI CABI, 2003; Liquido et al., 
PRA for Baled Hawaiian Solid Waste 179

Pest Geographic Distribution1 References 

Tipulidae Limonia perkinsi (Grimshaw) HI Hardy, 1960 HEMIPTERA Aleyrodidae Aleurocanthus woglumi Ashby HI, FL CABI 2004; Hill 1994; HI-D

2002; USDA-APHIS-PPQ, 

Aleurothrixus antidesmae Takahashi HI Nishida, 2002; UH-CTAHR Aleurotulus anthuricola Nakahara HI Nishida, 2002; UH-CTAHR Orchamoplatus mammaeferus (Quaintance & Baker) HI Nakahara, 1982 Parabemisia myricae (Kuwana) HI, CA, FL Nishida, 2002; USDA-APHTrialeurodes vaporariorum (Westwood) HI, FL UH-CTAHR and HI-DoA, Aphididae Melanaphis sacchari (Zehnter) HI, FL CABI, 2001; Zimmerman, Sitobion (= Macrosiphum) luteum (Buckton) HI, FL Johnson, 2006; Tenbrink anToxoptera citricida (Kirkaldy) HI, FL CABI 2004; Nishida, 2002; 

2005 

Cicadellidae Gyponana germari (Stal) HI Nishida, 2002; USDA-APHCoccidae Coccus capparidis (Green) HI Nishida, 2002; USDA-APHCoccus viridis (Green) HI, FL Ben-Dov et al., 2005; WoodVinsonia stellifera (Westwood) HI, AL, FL, GA Ben-Dov et al., 2005; CABCoreidae Physomerus grossipes (F.) HI HI-DoA, 2002 Delphacidae Aloha ipomoeae Kirkaldy HI Giffard, 1917 Nesosydne ipomoeicola Kirkaldy HI Fullaway, 1943 
PRA for Baled Hawaiian Solid Waste 180

Pest Geographic Distribution1 References 

Derbidae Lamenia caliginea (Stål) HI Kessing and Mau, 1992 Diaspididae Andaspis punicae (Laing) HI Nishida, 2002; USDA-APHLepidosaphes laterochitinosa Green (= L. spinulosaBeardsley)

HI Beardsley, 1966, 1975; Ben

Nishida, 2002 

Parlatoria ziziphi (Lucas) HI, MS CABI, 2003; USDA-APHISPseudaulacaspis subcorticalis (Green) HI Ben-Dov et al., 2005 Flatidae Siphanta acuta (Walker) HI Nishida, 2002; UH-CTAHR Lygaeidae Graptostethus manillensis (Stal) HI Sakimura, 1944 Miridae Halticus tibialis Reuter HI CABI, 2001; HI-DoA, 2002 Hyalopeplus pellucidus (Stal) HI HI-DoA 2005; UH-CTAHR Pseudococcidae Maconellicoccus hirsutus (Green) HI, CA, FL CABI, 2003; USDA-APHISNipaecoccus viridis (Newstead) HI Ben-Dov et al., 2005; CABParacoccus marginatus Williams & Granara de Willink

HI, FL CABI 2004; USDA-APHIS

Pseudococcus cryptus Hempel (= P. citriculus Green) HI Ben-Dov, 1994; USDA-APPseudococcus dendrobiorum Williams HI UH-CTAHR and HI-DoA, Puto barberi (Cockerell) HI Nishida, 2002; USDA-APHPsyllidae Blastopsylla occidentalis Taylor HI Nishida, 2002; USDA-APHHYMENOPTERA Formicidae Camponotus variegatus (F. Smith) HI Anon., 2006; Nishida, 2002 
PRA for Baled Hawaiian Solid Waste 181

Pest Geographic Distribution1 References 

Pheidole megacephala (F.) HI Williams, 1931 ISOPTERA Rhinotermitidae Reticulitermes speratus (Kolbe) HI Nishida, 2002; USDA-APHTermitidae Nasutitermes cornigera (Motschulsky) HI Nishida, 2002; USDA-APHLEPIDOPTERA Crambidae Omphisa anastomosalis (Guenee) HI HI-DoA, 2002 Udea despecta (Butler) HI Zimmerman, 1958 Geometridae Anacamptodes fragilaria (Grossbeck) HI, CA HI-DoA, 2002 Lycaenidae Lampides boeticus Linnaeus HI CABI, 2003; Hill, 1994; Ni

APHIS-PPQ, 2005; Zhang 

Lyonetiidae Bedellia orchilella Walsingham (= B. somnulentella) HI HI-DoA, 2002 Noctuidae Achaea janata L. HI CABI, 2004; Hill, 1994; Ni

al, 2003; USDA-APHIS-PP

Athetis thoracica (Moore) HI Zimmerman, 1958 Chrysodeixis erioosoma (Doubleday) HI Swezy, 1944 Eudocima fullonia (Clerck) HI CABI, 2004 Spodoptera litura (Fabricius) HI CABI, 2003; Hill, 1994; Ni

2003; USDA-APHIS-PPQ, 

Spodoptera mauritia subsp. acronyctoides Guenée HI CABI, 2003; Hill, 1994; Ni

2003; USDA-APHIS-PPQ, 

Stictoptera cucullioides (Guenée) HI Zhang, 1994 
PRA for Baled Hawaiian Solid Waste 182

Pest Geographic Distribution1 References 

Pieridae Colias sp. HI Nishida, 2002; USDA-APHPyralidae Cryptoblabes gnidiella (Milliere) HI CABI, 2004; Nishida, 2002Hellula undalis (F.) HI Zimmerman, 1978 Maruca vitrata Fabricius HI CABI, 2003; Hill, 1994; Ni

al, 2003; USDA-APHIS-PP

Tineidae Opogona purpuriella Swezy HI Zimmerman, 1978 Tortricidae Cryptophlebia illepida (Butler) HI Zimmerman, 1978 Cryptophlebia ombrodelta (Lower) HI CABI, 2004; Robinson et a

1978 

Epiphyas postvittana (Walker) HI Ebeling 1959; HI-DoA, 200

CTAHR and HI-DoA, 20052005; Zhang, 1994 

ORTHOPTERA Gryllotalpidae Gryllotalpa africana Palisot de Beauvois HI CABI, 2004 Pyrgomorphidae Atractomorpha sinensis Bolivar HI Holdaway, 1944 Tettigoniidae Conocephalus saltator (Saussure) HI Mau, 1977 Elimaea punctifera (Walker) HI UH-CTAHR and HI-DoA, Xiphidiopsis lita Hebard HI Nishida, 2002; USDA-APHPSOCOPTERA Ectopsocidae Ectopsocus fullawayi Enderlein HI Zimmerman, 1948 
PRA for Baled Hawaiian Solid Waste 183

Pest Geographic Distribution1 References THYSANOPTERA Thripidae Chaetanaphothrips signipennis (Bagnall) HI Wood, 2000 Dichromothrips corbetti (Priesner) HI Nishida, 2002; UH-CTAHR Frankliniella schultzei (Trybom) HI, FL CABI, 2004 Helionothrips errans (Williams) HI Nishida, 2002; UH-CTAHR Scirtothrips dorsalis Hood HI CABI, 2003 Thrips palmi Karny HI, FL CABI, 2004; Wood, 2000 CHROMISTA Albugo sp. (Oomycetes: Peronosporales) HI Farr et al., 2006 Aphanomyces sp. (Oomycetes: Saprolegniales) HI Farr et al., 2006 Phytophthora katsurae Ko & Chang (Oomycetes: Pythiales)

HI Farr et al., 2006 

Phytophthora meadii McRae (Oomycetes: Pythiales) HI Farr et al., 2006 Phytophthora tropicalis Aragaki & J.Y. Uchida (Oomycetes: Pythiales)

HI Farr et al., 2006 

FUNGI Farr et al., 2006 Acremonium recifei (Leão & Lôbo) W. Gams (Ascomycetes: Hypocreales)

HI Farr et al., 2006 

Acrodictys fimicola Ellis & Gunnell (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Allomyces arbusculus Butler (Chytridiomycetes: Blastocladiales)

HI Farr et al., 2006 

Alternaria aragakii Simmons (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Amazonia spp. (Ascomycetes: Meliolales) HI Farr et al., 2006 Anungitea fragilis Sutton (Ascomycetes: Incertae sedis) HI Farr et al., 2006 
PRA for Baled Hawaiian Solid Waste 184

Pest Geographic Distribution1 References Aschersonia marginata Ellis & Everh. (Ascomycetes: Hypocreales)

HI Farr et al., 2006 

Ascochyta spp. (Ascomycetes: Incertae sedis) HI Farr et al., 2006 Aspergillus spp. (Ascomycetes: Eurotiales) HI Farr et al., 2006 Asteridiella spp. (Ascomycetes: Meliolales) HI Farr et al., 2006 Asteromella lantanae Petr. (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Atichia solaridiscoidea Meeker (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Bactridium flavum Kunze (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Beauveria sp. (Ascomycetes: Hypocreales) HI Farr et al., 2006 Beltraniella portoricensis (Stevens) Piroz. & Patil (Ascomycetes: Xylariales)

HI Farr et al., 2006 

Bipolaris spp. (Ascomycetes: Pleosporales) HI Farr et al., 2006 Botryodiplodia sp. (Ascomycetes: Incertae sedis) HI Farr et al., 2006 Botryosphaeria parva Pennycook & Samuels (Ascomycetes: Dothideales)

HI Farr et al., 2006 

Botrytis spp. (Ascomycetes: Helotiales) HI Farr et al., 2006 Calonectria insularis Schoch & Crous (Ascomycetes: Hypocreales)

HI Farr et al., 2006 

Calonectria pauciramosa Schoch & Crous (Ascomycetes: Hypocreales)

HI, FL Farr et al., 2006 

Cercospora aciculina Chupp (Ascomycota: Mycosphaerellales)

HI Farr et al., 2006 

Ceuthospora latitans (Fr.:Fr.) Höhn. (Ascomycetes: Helotiales)

HI, AK Farr et al., 2006 

Chaetophoma sp. (Ascomycetes: Incertae sedis) HI Farr et al., 2006 Cladosporium spp. (Ascomycota: Mycosphaerellales) HI Farr et al., 2006 
PRA for Baled Hawaiian Solid Waste 185

Pest Geographic Distribution1 References Clypeoseptoria rockii Stevens & Young (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Colletotrichum artocarpi Delacr. (Ascomycetes: Phyllachorales)

HI Farr et al., 2006; Raabe et a

Colletotrichum dianellae Stevens & Young (Ascomycetes: Phyllachorales)

HI Farr et al., 2006 

Coniothyrium nitidae Crous & Denman (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Cordana musae (Zimmerm.) Höhn. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Cryptosporiopsis eucalypti Sankaran & B. Sutton (Ascomycetes: Helotiales)

HI Farr et al., 2006 

Curvularia spp. (Ascomycetes: Pleosporales) HI Farr et al., 2006 Cylindrocarpon spp. (Ascomycetes: Hypocreales) HI Farr et al., 2006 Cylindrocladium spp. (Ascomycetes: Hypocreales) HI Farr et al., 2006; Killgore, 2

HI-DoA, 2005 

Cylindrosporium sp. (Ascomycetes: Helotiales) HI Farr et al., 2006 Cytospora sp. (Ascomycetes: Diaporthales) HI Farr et al., 2006 Dinemasporium sp. (Ascomycetes: Incertae sedis) HI Farr et al., 2006 Diplodia shearii Petr. (Ascomycetes: Dothideales) HI Farr et al., 2006 Discosia spp. (Ascomycetes: Incertae sedis) HI CSREES, 2004 Dothiorella opuntiae Siemaszko ex Petr. (Ascomycetes: Dothideales)

HI Farr et al., 2006 

Elsinoë batatas Viégas & Jenkins (Ascomycota: Myriangiales)

HI CABI, 2001; Raabe et al., 1

Enthallopycnidium gouldiae Stevens (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Eriosporella calami (Niessl) Höhn. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 
PRA for Baled Hawaiian Solid Waste 186

Pest Geographic Distribution1 References Exserohilum spp. (Ascomycetes: Pleosporales) HI Farr et al., 2006 Flavodon cervinogilvum (Jungh.) Corner (Basidiomycetes: Polyporales)

HI CSREES. 2004; Farr et al., 

2002 

Fomitopsis nivosa (Berk.) Gilb. & Ryvarden (Basidiomycetes: Polyporales)

HI, FL, SC Farr et al., 2006; Gilbertson

Fusarium spp. (Ascomycetes: Hypocreales) HI Farr et al., 2006 Fusicoccum canavaliae Lyon (Ascomycetes: Dothideales)

HI Farr et al., 2006 

Gampsonema exile (Tassi) Nag Raj (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Gloeocoryneum hawaiiense Sutton & Hodges (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Gloeosporium spp. (Ascomycetes: Helotiales) HI UH-CTAHR and HI-DoA, Harknessia gunnerae Stevens & Young (Ascomycetes: Diaporthales)

HI Farr et al., 2006 

Lasmenia sp. (Ascomycetes: Incertae sedis) HI Farr et al., 2006 Leptothyrium gleicheniae Stevens & Young (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Libertella kokiae Petr. (Ascomycetes: Xylariales) HI Farr et al., 2006 Marssonina sp. (Ascomycetes: Helotiales) HI Farr et al., 2006 Melanconium sp. (Ascomycetes: Diaporthales) HI Farr et al., 2006 Microporus flabelliformis (Klotzsch) Pat. (Basidiomycetes: Polyporales)

HI Farr et al., 2006 

Mycoacia kurilensis Parmasto (Basidiomycetes: Polyporales)

HI Farr et al., 2006; Gilbertson

Mycosphaerella artocarpi Stevens & Young (Ascomycetes: Mycosphaerellales)

HI Farr et al., 2006; Raabe et a

Mycotribulus mirabilis Nag Raj & Kendr. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 
PRA for Baled Hawaiian Solid Waste 187

Pest Geographic Distribution1 References Neonectria rugulosa (Pat. & Gaillard) Mantiri & Samuels [= Nectria rugulosa Pat. & Gaillard] (Ascomycetes: Hypocreales)

HI Farr et al., 2006 

Penicillium sp. (Ascomycetes: Eurotiales) HI CABI, 2001; Raabe et al., 1Pestalotia sp. (Ascomycetes: Xylariales) HI Phanerochaete australis Jülich (Basidiomycetes: Polyporales)

HI Farr et al., 2006; Gilbertson 

Phellinus grenadensis (Murrill) Ryvarden (Basidomycetes: Hymenochaetales)

HI, LA Farr et al., 2006 

Phlebia acanthocystis Gilb. & Nakasone (Basidiomycetes: Polyporales)

HI Farr et al., 2006; Gilbertson

Phoma agapanthi (Thüm.) Sacc. (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Phoma caricae-papapae (Tarr) Punith. (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Phomopsis caricae-papayae Petr. & Cif. (Ascomycetes: Diaporthales)

HI Farr et al., 2006 

Phyllosticta acicola Bissett & Palm (Ascomycetes: Dothideales)

HI Farr et al., 2006 

Pleurophomopsis eucalypti Petr. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Pyrenochaeta sp. (Ascomycetes: Pleosporales) HI Farr et al., 2006 Ramularia ipomoea Stevens (Ascomycetes: Mycosphaerellales)

HI Farr et al., 2006 

Rhabdospora pittospori Stevens & Young (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Rhizoctonia spp. (Basidiomycetes: Polyporales) HI Farr et al., 2006; Killgore, 2Rhizopus sp. (Zygomycetes: Mucorales) HI Raabe et al., 1981 
PRA for Baled Hawaiian Solid Waste 188

Pest Geographic Distribution1 References Robillarda rhizophorae Kohlm. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Septogloeum arachidis Racib. (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

Septoria canavaliae Lyon (Ascomycetes: Mycosphaerellales)

HI Farr et al., 2006 

Septoriella rockiana (Petr.) Nag Raj (Ascomycetes: Dothideales)

HI Farr et al., 2006 

Sphaceloma sp. (Ascomycetes: Myriangiales) HI Farr et al., 2006 Sphaeropsis tumefaciens Hedges (Ascomycetes: Incertae sedis)

HI, FL CABI, 2004; Farr et al., 200

Sporonema sp. (Ascomycetes: Helotiales) HI Farr et al., 2006 Stagonospora erythrinae Stevens & Young (Ascomycetes: Pleosporales)

HI Farr et al., 2006 

Uredo artocarpi Berk. & Broome (Urediniomycetes: Urediniales)

HI Gardner, 1991 

Verticillium sp. (Ascomycetes:Hypocreales) HI Farr et al., 2006 Waydora typica (Rodway) B. Sutton (Ascomycetes: Incertae sedis)

HI Farr et al., 2006 

MOLLUSCA Achatinidae Achatina fulica Bowdich HI, FL Cowie, 1997, 2002b; RobinAmpullaridae Pila ampullaceae (Linne) HI Robinson, 2006 Pila conica (Wood) HI Cowie, 1997, 2002a; RobinPila sp. HI Cowie, 2002b; Robinson, 2Pomaceae canaliculata (Lamarck) HI, CA, TX, FL Cowie, 1997, 2002b; Robin
PRA for Baled Hawaiian Solid Waste 189

Pest Geographic Distribution1 References Helicarionidae Parmarion cf. martensi (Simroth) [Tentative] HI Cowie, 1997, 2002b; RobinHelicidae Cornu aspersum (Müller) [= Cryptomphalus aspersus(Müller); Helix aspersa Müller]

HI, CA2, OR2, LA, PA2, NC2, NJ2, SC2, UT, WA 

Cowie, 1997, 2002b; Robin

Philomycidae Meghiamtium straitum (Hasselt) HI Cowie, 2002a; Robinson, 2Subulinidae Beckianum beckianum (Pfeiffer) HI Robinson, 2006 Paropeas achatinaceum (Pfeiffer) HI Cowie, 1997; Robinson, 20Veronicellidae Laevicaulis alte (Ferussac) HI Cowie, 1997, 2002b; RobinVeronicella cubensis (Pfeiffer) HI (Tentative), AS, PR Cowie, 1997, 2002b; RobinNEMATODA Anguinidae Ditylenchus dipsaci (Kühn) Filipjev HI, US CABI, 2001 Aphelenchidae Aphelenchoides sp. HI USDA-ARS, 2005 Seinura filicaudata Christie HI Handoo et al., 1998; USDABelonolaimidae Tylopharynx annulatus (Cassidy) Golden HI USDA-ARS, 2005 Criconematidae Criconemoides palmatum (Siddiqi & Southey) HI USDA-ARS, 2005 Heteroderidae Meloidogyne konaensis Eisenback HI Zhang and Schmitt, 1994 Mononchidae Monochus sp. HI USDA-ARS, 2005 
PRA for Baled Hawaiian Solid Waste 190

Pest Geographic Distribution1 References Panagrolaimidae Panagrolaimus sp. HI USDA-ARS, 2005 Pratylenchidae Hirschmanniella diversa Sher HI USDA-ARS, 2005 Rhabditidae Rhabditus sp. HI USDA-ARS, 2005 

1 Distribution: AK = Alaska, AL = Alabama, AS = American Samoa, CA = California, FL = Florida, GA = Georgia, 

Louisiana, MS = Mississippi, NJ = New Jersey, NC = North Carolina, OR= Oregon, PA = Pennsylvania, PR = PCarolina, TX = Texas, UT= Utah, and WA = Washington 

2 These states have quarantines and or eradication programs in place Table A2. Selected pest plants (i.e., weeds, invasive plants) in Hawaii that are quarantine-significant for the contigu

United States. NOTE: This is not a complete list of all quarantine-significant plant pests from Hawaii and should not 

pest plant references include USDA NRCS, 2006. 

Family Pest plant Geographic distribution1 Noxious weed list2 

 HI Fed Other1 Acanthaceae Asystasia gangetica (L.) T. 

Anders.

HI, FL 

Agavaceae Furcraea foetida (L.) Haw. HI, FL Amaranthaceae Alternanthera sessilis (L.) R. Br. 

ex DC.

HI, FL, GA, LA, TX 9 AL, AR, CA, FL, M

MN, NC, OR, SC, 

Anacardiaceae Schinus terebinthifolius Raddi HI, CA, FL, PR, TX FL, TX Araliaceae Schefflera actinophylla (Endl.) 

H.A.T. Harms 

HI, FL, PR 

Asteraceae Ageratina adenophora (Spreng.) 

King & H.E. Robins.

HI, CA 9 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Elephantopus mollis Kunth HI, PR 9Montanoa hibiscifolia (Benth.) Standl.

HI 9
PRA for Baled Hawaiian Solid Waste 191

Family Pest plant Geographic distribution1 Noxious weed list2  HI Fed Other1 Asteraceae Senecio madagascariensis Poir. HI 9

Tridax procumbens L. HI, FL, PR 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Basellaceae Anredera cordifolia (Ten.) 

Steenis 

HI, CA, DC, FL, LA, PR, TX 9

Bignoniaceae Spathodea campanulata Beauv. HI, FL, PR Boraginaceae Cordia glabra L. HI, PR Cactaceae Cereus hildmannianus K. 

Schum. 

HI, PR 9

Harrisia martinii (Labouret) Britt. 

HI 9

Casuarinaceae Casuarina equisetifolia L. HI, FL, PR FL Cecropiaceae Cecropia obtusifolia Bertol. HI Commelinaceae Commelina benghalensis L. HI, CA, FL, GA, LA 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Convolvulaceae Ipomoea aquatica Forssk. HI, CA, FL 9 AL, AZ, AR, CA, 

NC, OR, SC, TX, V

Cucurbitaceae Coccinia grandis (L.) Voigt HI, FL 9Fabaceae Caesalpinia decapetala (Roth) 

Alston

HI, PR 

Prosopis juliflora (Sw.) DC. HI 9Prosopis pallida (Humb. & Bonpl. ex Willd.) Kunth

HI, PR 9 AL, CA, MA, MN

NC, OR, SC, VT 

Pueraria phaseoloides (Roxb.) Benth.

HI, PR 9

Spartium junceum L. HI, CA, OR, WA 9 OR, WA Ulex europaeus L. HI, CA, MA, NY, OR, PA, 

VA, WA, WV 

9 CA, OR, WA 
PRA for Baled Hawaiian Solid Waste 192

Family Pest plant Geographic distribution1 Noxious weed list2  HI Fed Other1 Lamiaceae Hyptis pectinata (L.) Poit. HI, FL, PR 9

Hyptis suaveolens (L.) Poit. HI, PR 9

Malvaceae Malachra alceifolia Jacq. HI, FL, PR 9

Urena lobata L. HI, FL, LA, PR 9

Marattiaceae Angiopteris evecta (J.R. Forst.) 

Hoffmann

HI 

Melastomataceae Clidemia hirta (L.) D. Don HI, PR 9 

Medinilla venosa (Blume) Blume 

HI 

Melastoma candidum D. Don HI 9Melastoma malabathricum L. HI 9Miconia calvescens DC. HI 9Oxyspora paniculata (D. Don) DC.

HI 

Tibouchina herbacea (DC.) Cogn. 

HI 9

Tibouchina longifolia (Vahl) Baill. ex Cogn. 

HI 9

Tibouchina urvilleana (DC.) 

Cogn. 

HI, PR 9

Mimosaceae Acacia mearnsii Willd. HI, CA 9Myricaceae Morella faya (Ait.) Wilbur HI 9Myrsinaceae Ardisia elliptica Thunb. HI, FL 9Myrtaceae Melaleuca quinquenervia (Cav.) 

Blake

HI, FL, LA, PR 9 AL, CA, FL, MA, 

OR, SC, TX, VT 

Rhodomyrtus tomentosus (Ait.) Hassk.

HI, FL 9 FL 
PRA for Baled Hawaiian Solid Waste 193

Family Pest plant Geographic distribution1 Noxious weed list2  HI Fed Other1 Oleaceae Fraxinus uhdei (Wenzig) 

Lingelsh.

HI, PR 

Papaveraceae Bocconia frutescens L. HI, PR 9Passifloraceae Passiflora bicornis P. Mill. HI 9Pinaceae Pinus caribaea Morelet HI, PR Piperaceae Piper aduncum L. HI, FL, PR 9Pittosporaceae Pittosporum undulatum Vent. HI, CA 9Poaceae Cenchrus echinatus L. HI, AL, AZ, CA, DC, FL, GA, 

LA, MS, NC, NM, SC, TX 

 AZ, CA 

Chrysopogon aciculatus (Retz.) Trin.

HI 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Cortaderia jubata (Lem.) Stapf HI, CA, OR Cymbopogon refractus (R. Br.) A. Camus 

HI 9

Digitaria abyssinica (Hochst. ex A. Rich.) Stapf

HI 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Paspalum scrobiculatum L. HI, AL, GA, MD, NJ, TX 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Pennisetum macrourum Trin. HI, CA, TX 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Saccharum spontaneum L. HI, PR 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Themeda villosa (Poir.) A. Camus

HI 9

Polygonaceae Emex spinosa (L.) Campd. HI, CA, FL, MA, TX 9 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Pontederiaceae Monochoria vaginalis (Burm. f.) 

K. Presl ex Kunth

HI, CA 9 AL, CA, FL, MA, 

OR, SC, VT 
PRA for Baled Hawaiian Solid Waste 194

Family Pest plant Geographic distribution1 Noxious weed list2  HI Fed Other1 Proteaceae Grevillea banksii R. Br. HI 9Rhizophoraceae Bruguiera sexangula (Lour.) 

Poir. 

HI 

Rosaceae Rubus ellipticus Sm. var. 

obcordatus Focke

HI 9

Rubus niveus Thunb. HI, FL 9Rubus sieboldii Blume HI 9

Rubiaceae Cinchona pubescens Vahl HI Solanaceae Solanum robustum Wendl. HI 

Solanum torvum Sw. HI, AL, FL, MD, PR 9 AL, CA, FL, MA, 

MN, NC, OR, SC, 

Sterculiaceae Melochia umbellata (Houtt.) 

Stapf

HI 

Tiliaceae Heliocarpus popayanensis

Kunth

HI 

Triumfetta rhomboidea Jacq. HI, FL, PR 9Triumfetta semitriloba Jacq. HI, FL, GA, PR 9

Ulmaceae Trema orientale (L.) Blume HI Verbenaceae Clerodendrum japonicum

(Thunb.) Sweet

HI, MD 

Zingiberaceae Hedychium gardnerianum

Shepard ex Ker-Gawl.

HI 9

1 Distribution: AL = Alabama, AR = Arkansas, AZ = Arizona, CA = California, DC = District of Columbia, FL = Florida, GA = 

= Louisiana, MD = Maryland, MA = Massachusetts, MN = Minnesota, MS = Mississippi, NC= North Carolina, NJ = New 

Mexico, NY = New York, OR= Oregon, PA = Pennsylvania, PR = Puerto Rico, SC = South Carolina, TX = Texas, VA = V

WA = Washington, and West Virginia. 

2 9 = Listed 
PRA for Baled Hawaiian Solid Waste 195

Contact 

Barney P. Caton 

barney.p.caton@aphis.usda.gov 

(919) 855-7504; (919) 855-7595 (fax) 

Authors 

Barney P. Caton, Thomas W. Culliney, Lisa M. Ferguson, Andrea V. Lemay, and Betsy RandallSchadel 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology (CPHST) 

Plant Protection and Quarantine, Animal and Plant Health Inspection Service 

U. S. Department of Agriculture 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

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PRA for Baled Hawaiian Solid Waste 200

Appendix B. Modeling the likelihood of bale-rupturing accidents during transport of 

baled municipal solid waste (MSW) by truck, rail, or barge. 

I. Introduction 

Here we describe the approaches used to estimate the likelihoods of bale-rupturing accidents to occur 

while moving baled MSW to landfills on the mainland United States by either truck, rail, or barge. We 

did this here for generic but realistic travel distances of 25 truck miles, 500 rail miles, and 140 barge 

miles. 

II. Models And Methods 

A. Standard simulation settings and functions 

All probabilistic analyses and simulations were performed using @Risk ver. 4.5.2 Professional (Palisade 

Corporation, 31 Decker Road, Newfield, NY 14867). Simulation settings were as follows unless 

otherwise specified: number of iterations = 20,000; sampling type = Latin Hypercube; and random seed 

= 101. Equations below are shown in their general form; actual equations used in @Risk can be found 

in the formulae section in Fig. 1. 

Two equations were used most often for probabilistic predictions. Most nodes, or pathway processes, in 

the model were binomial, meaning that n independent identical trials were conducted, each with the 

same probability of success, p, as follows (e.g., Vose, 2000): 

S = binomial(n, p) [1] 

where S is the number of successes observed. Both n and p vary by iteration but are ‘constant’ across 

the n trials in a single iteration. 

The value of p was often determined from a beta distribution, which estimates the probability of success 

from the observed number of successes, s, and the number of trials, n, as follows: 

p = beta(s + 1, (n − s) + 1) [2] 

For example, for the probability of an accident happening to a freight barge (below), n = total number of 

accidents and s = number of accidents for freight barges. More generally, Eqn. (2) is the probability of 

success during the next (+1) time period or event, given the number of successes and trials already 

observed. 

B. Numbers and distances of trips 

This depended upon the annual amount of baled MSW transported, average bale mass, and the balecarrying capacity of each type of conveyance. We estimated the total annual amount of baled MSW as 

300,000 tons (PRER, 2004) with ten percent variability. The resulting distribution was uniform from 

270,000 to 300,000 tons annually. In addition, the best estimate we have for the annual number of 

oceanic barge trips to transport that amount is about 36 trips. We estimated the number of trips required 

as a uniform distribution between 32 and 36. The number of tons of baled MSW per trip was simply the 

total amount divided by the number of trips. 
PRA for Baled Hawaiian Solid Waste 201

From company information, bale mass was estimated as a uniform distribution between 3.2 and 3.35 

(lb.) tons (6,400 to 6,700 pounds), which is about 2900 to 3000 kg. 

The annual number of bales transported was the total mass of baled MSW divided by the mass per bale, 

and rounded up to the nearest whole number. The mean number of bales per barge trip was the total 

number of bales divided by the number of barge trips, again rounded up to the nearest integer. The 

number of bales per train trip was assumed to be the number per barge, since the capacity of a 100-car 

train exceeded that necessary to move all the bales on a single barge. The carrying capacity of a flatbed 

trailer truck is about 22.7 metric tons, which gave 7 bales per truck on average. 

The total number of trips was calculated as the annual number of bales divided by the carrying capacity 

for each conveyance, and rounded up. The total number of vehicle miles traveled (VMT) was the 

product of the trip distance and the number of trips. For barges, the number of ton-miles was calculated 

as the product of total tons and the average trip distance. 

C. Total numbers of accidents 

In this case, as conveyance move over the total trip distance a constant probability of an accident 

occurring exists: this describes a Poisson process. In a Poisson process the two parameters are λ, the 

probability of an event (accident) occurring, and d, the amount of exposure. Here d is the distance 

traveled; in other situations time, t, is often the measure of exposure. The number of events, s, occurring 

within d is the following (Vose, 2000): 

s = Poisson(λd) [3] 

As the exposure level d or the rate λ increase, so does s. 

The national accident rates for trucks and trains are based on VMT, while that for barges is based on 

ton-miles. For trucks the estimated mean rate was 1.96 accidents per million VMT, based on data for 

numbers of fatal, non-fatal, and property damage-only accidents (Federal Motor Carrier Safety 

Administration, 2004) and total VMT (Analysis Division, 2006) for the years 2000 to 2004. We 

specified the rate as a pert distribution with the above mean, and minimum and maximum values equal 

to the lower and upper 99 percent confidence intervals over the five years of data (Fig. B1). 

For trains, we estimated the national accident rate from ten years of data, 1996 to 2005 (Office of Safety 

Analysis, 2006). The overall mean was 3.94 accidents per million VMT, for all companies and all modes 

(e.g., yards and main lines). The distribution based on the 99 percent confidence limits of the mean was 

a pert with minimum = 3.665, and maximum = 4.215 (Fig. B2). Ninety percent of the sampled values 

were between 3.77 and 4.11. 

For barges the accident rate was calculated from recent statistics for accidents on the Columbia River. In 

2000, 80 accidents were reported, and 87 were reported in 2001 (U.S. Army Corps of Engineers, 2002, 

2003). The corresponding values for annual ton-miles (billions) of freight moved were 2.9 in 2000 and 

3.0 in 2001, giving annual accident rates of 27.6 accidents per billion ton-mile in 2000, and 29.0 in 

2001. In the model we used the mean rate of 28.3 accidents per billion ton-miles. 
PRA for Baled Hawaiian Solid Waste 202

0

0.5

1

1.5

2

2.5

3

3.5

1.6 1.7 1.8 1.9 2 2.1 2.2 2.3

 Truck accident rate (no. per million VMT)

 Probability density

Fig. B1. The distribution for the truck accident rate, number per million vehicle miles traveled (VMT), 

based on data from 2000 to 2004. Lines indicate the 5th and 95th percentiles, so 90 percent of the 

sampled values will fall in between the lines. 

0

0.5

1

1.5

2

2.5

3

3.5

3.6 3.7 3.8 3.9 4 4.1 4.2 4.3

 Accident rate for rail (no. per million VMT)

 Probability density

Fig. B2. The distribution for the truck accident rate, in number per million vehicle miles traveled 

(VMT), based on data from 1996 to 2005. Lines indicate the 5th and 95th percentiles, so 90 percent of 

the sampled values will fall in between the lines. 
PRA for Baled Hawaiian Solid Waste 203

D. Numbers of relevant accidents 

Not every accident, however, is relevant to transportation of baled Hawaiian MSW. For trucks in 

particular, we needed to estimate the number of intrastate accidents to flat-bed trucks, because trips to 

landfills will not involve interstate travel, and because trucks such as cargo vans will not be used to 

transport bales. In all cases, the number of relevant accidents was a binomial process with N = total 

accidents and p = the likelihood of an accident being relevant. 

For trucks, we estimated the likelihood of a relevant accident as the product of the likelihood of 

accidents during intrastate travel, and the proportion of accidents occurring to body types that could 

carry bales (e.g., flatbed trailer vs. cargo van). Both of these were done specifically for data from the 

states of Idaho, Oregon, and Washington, because rates there may differ from nationwide statistics. The 

probability of an accident during intrastate travel in those states was a beta distribution with s = 996 and 

n = 6,703 (Federal Motor Carrier Safety Administration, 2004), which had a mean value of 0.15, and 90 

percent of sampled values were between 0.142 and 0.156. The probability of an accident occurring to a 

bale-carrying truck body type was also a beta, with s = 361 and n = 3,483, based on data for fatal, 

injurious, and tow-away accidents (Analysis Division, 2006). That distribution had a mean value of 

0.10, and 90 percent of the sampled values were between 0.096 and 0.113. 

For trains, we were interested in accidents to freight trains on main lines, since about two-thirds of all 

rail accidents occur in and around rail yards (Office of Safety Analysis, 2006), which are likely to be 

lower speed accidents in which bales would not rupture. First we estimated the likelihood that an 

accident occurred to a freight train based on data for 2000 to 2004 (Federal Railroad Administration, 

2001, 2003, 2004, 2005a, b). Overall, 8,251 accidents out of 17,588 were to freight trains. From 99 

percent confidence intervals for the annual means, this gave a pert distribution with mean = 0.47, 

minimum = 0.417, and maximum = 0.523. Ninety percent of the sampled values were between 0.437 

and 0.503. Similarly, the likelihood of an accident being on a main line was based on data in which 

4,524 of the 8,251 freight train accidents occurred on main lines. This data gave a pert distribution with 

mean = 0.55, minimum = 0.52, and maximum = 0.58, with 90 percent of sampled values between 0.53 

and 0.57. The overall probability of an accident being relevant was the product of the two probabilities 

for freight and main line accidents. 

For barges, we were only interested in accidents to freight barges. Very few accidents on the Columbia 

River in 2000 and 2001 (the most recent data) involved freight barges (U.S. Army Corps of Engineers, 

2002, 2003). We estimated the likelihood that an accident was to a freight barge as a beta with s = 4 and 

n = 167, which had a mean value of 0.03, and 90 percent of sampled values were between 0.012 and 

0.054. 

The probability that a relevant accident would occur annually (prel) was estimated, for each conveyance 

type, by calculating the number of iterations in which at least one occurred. 

E. Numbers of bale-rupturing accidents 

Just as not every truck, train or barge accident will involve transport of baled MSW, not every accident 

involving baled MSW will result in ruptures of bales. For example, a “fender bender” can be counted as 

an accident but is highly unlikely to result in ejection and rupture of cargo. Accordingly, the number of 
PRA for Baled Hawaiian Solid Waste 204

potential bale-rupturing accidents was a binomial process with N = the number of relevant accidents and 

p = the probability that an accident is of a type that could rupture bales. 

For trucks, the number of accidents that could results in bale ruptures was determined from data from 

1991 to 2000 on flatbed trucks carrying hazardous cargo (Craft, 2004). Out of 5,208 total crashes (= n), 

1,690 (= s) resulted in cargo spills. This beta distribution gave a mean of 0.325, and 90 percent of the 

sampled values were between 0.314 and 0.335 (Fig. B3). 

For trains, we found total accidents and the number of accidents likely to cause bale ruptures from 2000 

to 2004 data on releases of hazardous materials relative to the total number of accidents involving 

hazardous materials (Federal Railroad Administration, 2001, 2003, 2004, 2005a, b). The data directly 

estimated the proportion of rail accidents in which spills occur, and since hazardous materials are 

packaged and handled similarly to baled MSW, using these numbers seemed very appropriate. Overall, 

releases occurred in only 154 of 3,961 accidents involving hazardous materials. Using 99 percent 

confidence limits for the annual mean, we specified the distribution as a pert with mean = 0.039, a 

minimum value of 0.028, and a maximum value of 0.051, where 90 percent of the sampled values were 

between 0.032 and 0.046. 

For barges, we based our estimate of the likelihood of bale-rupturing on the number of releases of 

material in accidents involving transport of hazardous material. As with trains, this data seemed most 

relevant to the quantity being estimated, and did not require assumptions about accident types based on 

speed or other proxies for release risk. The most recent available data was for 1990 to 1997 (Office of 

Hazardous Materials Safety, 1999). Over that period, 6 of 63 accidents involving hazardous materials 

resulted in releases. A beta distribution with s = 6 and n = 63 gave a mean of 0.11, and 90 percent of 

sampled values were between 0.053 and 0.177 (Fig. B4). 

The probability that a bale-rupturing accident would occur annually (prupt) was estimated, for each 

conveyance type, by calculating the number of iterations in which at least one occurred. 

Contact/Author 

Barney P. Caton 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology (CPHST) 

Plant Protection and Quarantine, Animal and Plant Health Inspection Service 

U. S. Department of Agriculture 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

barney.p.caton@aphis.usda.gov 

(919) 855-7504; (919) 855-7595 (fax) 
 

205

Appendix D. Risk of Introduction of Pests to Washington State via 

Municipal Solid Waste from Hawaii. 
United States 

Department of 

Agriculture 

Animal and Plant 

Health Inspection 

Service 

April 2005 

Updated, September 

2006 

The Risk of Introduction of Pests to Washington 

State via Plastic-Baled Municipal Solid Waste 

from Hawaii 

Executive Summary 

Companies have proposed transporting large volumes of municipal solid 

waste (MSW) in airtight bales from Hawaii to landfills in the continental 

United States. In a previous general pest risk assessment, CPHST found that 

the risk of introduction of pests from Hawaii via this pathway was 

insignificant. Here we focus on a proposal to transport baled MSW to a 

landfill in Klickitat County, Washington State. We assessed whether any 

exceptional risks associated with this particular proposal would justify a 

different recommendation than was made for the general pathway. 

Two companies propose to move baled MSW by barge up the Columbia 

River, unload it in Roosevelt, WA, and move it eight miles by truck to the 

Roosevelt Regional Landfill. The landfill is a modern facility complying with 

relevant federal regulations. The transportation methods involved are low risk, 

and the local environment and climate do not pose exceptional risks. In 

particular, the climate in Klickitat County is much drier and colder than that in 

most large cities in Hawaii, which should greatly reduce the compatibility of 

some Hawaiian pests. None of the relevant Federal or State quarantine plant 

pests, which included insects, diseases, and pest plants (i.e., weeds, invasive 

plants), seemed to pose an exceptional threat of surviving, escaping and 

establishing via this pathway. 

In conclusion, this proposal closely followed the procedures outlined in the 

general pest risk assessment, and no factors justified a different 

recommendation. Thus, transportation of baled MSW from Hawaii to 

Klickitat County, Washington, poses an insignificant risk of pest 

establishment. We recommend that the pathway be monitored to ensure that 

procedures and compliance do not differ significantly from what was 

described here and in the general pest risk assessment.
PRA for Baled Solid Waste to WA 207

Introduction 

The Center for Plant Health Science and Technology (CPHST) completed, at the request of the State of 

Hawaii, a pest risk assessment of the likelihood of introduction of pests into the continental United 

States via the transport of plastic-baled municipal solid waste (MSW) from Hawaii (CPHST, 2006). The 

garbage will be baled by compressing it and wrapping it in adhesive-backed, plastic film barriers made 

of low density polyethylene (LDPE), creating airtight packages. Bales would be transported by barge to 

a receiving facility on the mainland and buried intact in landfills in accordance with regulations for solid 

waste disposal (40CFR§258; EPA (1993)). Each company would transport perhaps 300,000 tons of 

MSW per year. A pest risk assessment was required because garbage from Hawaii cannot enter the 

continental U.S. under current federal regulations for plant pests (7CFR§330.400). The assessment dealt 

with parts of the pathway expected to be valid for any company proposing to transport the baled waste. 

In the pest risk assessment, CPHST concluded that if the proposed procedures were followed, 

transportation of baled Hawaiian MSW posed an insignificant risk of pest establishment (CPHST, 

2006). Some reasons for that were that exclusion of most yard and agricultural waste from the pathway 

would greatly reduce the presence of potential plant pests or propagules in the bales; insects, mollusks, 

and some pathogens and weed seeds are unlikely to survive compaction and transport in the bales; and 

other pathway procedures (e.g. proper staging, mollusk-free certification, monitoring during transport) 

would adequately protect against introductions of pests. A qualitative risk analysis indicated that the 

cumulative risk ratings for the introduction of insects, mollusks, pathogens, and pest plants in baled 

MSW were each Low. 

Pacific Rim Environmental Resources, Inc. (PRER) (Luneke, 2004; PRER, 2004) and Hawaii Waste 

Systems, LLC (HWS) (HWS, 2006), have proposed moving baled MSW from Hawaii to a landfill in 

Washington State. Bales will be transported by barge to Roosevelt, Washington, and by truck to the 

Roosevelt Regional Landfill in Klickitat County. The objective of this assessment is to evaluate the 

proposals to assess whether any exceptional risk factors warrant a recommendation other than the Low 

risk ratings given previously. The procedures for transporting baled MSW in the documents closely 

followed the general procedures evaluated in CPHST (2006). Specific items considered here include the 

destination landfill, the Federal and State quarantine pests of concern, the type(s) of transportation used 

to move bales after reaching the mainland, and any other notable factors in the proposals. Refer to 

CPHST (2006) for definitions of key terms. 

Review of proposal

The details of the proposals are, for PRER, in PRER (2004) and Luneke (2004), and, for HWS, in HWS 

(2006). As mentioned above, the general procedures closely follow those used in the general assessment 

(CPHST, 2006). Some important details include the following: 

1) The baling system used will create rectangular bales weighing about 3 metric tons (pers. comm., 

Luneke, PRER Inc.), or between 2 and 4 pound tons (HWS, 2006); in both cases bale density will 

be about 1000 kg per cubic meter 

2) Bales will move on barges up the Columbia River directly to Roosevelt, WA, a distance from the 

ocean of about 253 miles 

3) Bales will be unloaded and moved eight miles by truck to the landfill 
PRA for Baled Solid Waste to WA 208

In addition, the companies specified their intention to do the following: 

▪ Not allow waste to contact soil after collection; 

▪ Rewrap and re-stage imperfectly sealed bales found during staging in Hawaii; 

▪ Use tractors with “grabbing-type” lift arms or well-padded tines to handle rectangular bales; 

▪ Monitor bales for ruptures and punctures, and track bales in an electronic manifesting system; and 

▪ Place baling machines at handling sites to seal ruptured bales when necessary, or move ruptured bales 

in re-sealed liners and bags designed for safe transport of hazardous waste. 

Destination landfill 

Roosevelt Regional Landfill (see http://www.rabanco.com/disposal.htm), in Klickitat County near the 

town of Roosevelt (Fig. 1), is a modern facility that meets regulations and EPA guidelines for design 

and operation (e.g., EPA, 1993). We have no reason to expect improper landfilling of bales at this site, 

and therefore the mitigation likely to come from landfilling seems valid (CPHST, 2006). 

Transportation of bales 

As discussed above, bales will be barged up the Columbia River to Roosevelt, offloaded onto trucks, 

and driven about 4 miles to the landfill. Roosevelt Regional Landfill has only had one significant truck 

accident in eight years of transporting loads from the dock to the landfill in Washington (pers. comm., 

D. Luneke, PRER). Both of those means of transport are low risk for potential bale-rupturing accidents 

(CPHST, 2006). Adapting the generic quantitative risk analysis for bale-rupturing accidents to transport 

of bales to Roosevelt Regional Landfill required an increase in barge miles from 140 to 253, and a 

decrease in truck miles from 25 to 4. When these changes were made, the risk of any bale-rupturing 

accident for trucks was reduced from 0.0035 to 0.0003, while that for barges increased from 0.0029 to 

0.0037. Mean years to the first bale-rupturing accident for trucks was 3333, and that for barges was 130. 

We found a 95 percent chance that the first truck accident would occur only after 171 years, or after 7 

years for barge transport. The risk of catastrophic rupture of bales while they are being transported by 

truck or barge to Roosevelt Regional Landfill is therefore very low. 

Local environment: geography and climate 

Although the likelihood of pests or pest propagules escaping from bales is extremely low, for 

completeness we briefly discuss here the environment through which bales will be transported and into 

which bales will be deposited. Five general habitat types exist in Klickitat County: 1) dry coniferous 

forest, 2) dry grassland, 3) sagebrush desert, 4) farmland (dry > irrigated), and 5) riparian (Hoyle 

Consulting Services, 2002). The area around the town of Roosevelt and extending up to the landfill is 

largely made up of two habitat types, orchards (rainfed) and dry cropland (Hoyle Consulting Services, 

2002: Appendix 1, Figure A-1). The great majority of crop area is devoted to forage and wheat (National 

Agricultural Statistics Service, 2004a). Smaller areas have fruits and nuts, and row crop vegetables. 

As indicated above, a key feature of Klickitat County is the dryness of the area, which differs from many 

Hawaiian cities. Annual precipitation near Roosevelt Regional Landfill is about 6 to 9 inches (Rabanco, 

2004); Klickitat County is in the rain shadow of the Cascade Mountains (Department of Assessment and 

GIS, 2003). The average daily minimum temperature in the county is 24° F, and the average daily 

maximum is 80° F (Department of Assessment and GIS, 2003). In addition, average annual snowfall is 

about 10 inches. Below-freezing temperatures and snowfall would both mitigate against the 

establishment of tropical and subtropical Hawaiian pests. 
PRA for Baled Solid Waste to WA 209

Potential plant pests 

Quarantine plant pests for Washington State include pathogens, insects, and pest plants (Laboratory 

Services Division, 1999; PRER, 2004: Exhibit 2). We expect an extremely low incidence of these pests 

in typical MSW (CPHST, 2006). Washington also has no quarantines for terrestrial mollusks, which 

pose no exceptional risks here (see CPHST, 2006). 

No quarantine insects for Washington are present in Hawaii (Montgomery and Manning, 2004) but 

some insects in Hawaii are Federal quarantine pests (CPHST, 2006). We do not discuss insects further 

since they are unlikely to survive in the bales. 

Bacterial, fungal, and viral diseases of plants under Federal or Washington State quarantine are present 

in Hawaii (APS-APHIS Virus Working Group, 2003; University of Hawaii and Hawaii Department of 

Agriculture, 2004) and could be transported (Table 1). For various reasons, these organisms are very 

unlikely to establish in Washington State via this pathway (Table 2), and, as above, no exceptional 

factors in the proposal appear to make pathogens more likely to establish in this case than in the 

previous assessment (CPHST, 2006). 

Twenty quarantine pest plants for Washington are present in Hawaii (Table 3, and Luneke (2004)). All 

of those species are present in Washington, although perhaps under ongoing control or eradication 

(USDA NRCS, 2004). They seem more likely to disperse to new areas from within the state than via 

baled MSW from Hawaii. Other quarantine significant pest plants are also present in Hawaii (CPHST, 

2006), but no exceptional factors in the proposal increased the risk associated with pest plants here 

relative to the previous assessment. 

Figure 1. Map1

 of Roosevelt Regional Landfill and surrounding locations. 

The distance from West Roosevelt to the landfill is about 4 miles. 

1 From Klickitat County Solid Waste, 2001 (http://www.klickitatcounty.org/SolidWaste/ContentROne.asp? 

fContentIdSelected=1742226046&fCategoryIdSelected=1677677085)
PRA for Baled Solid Waste to WA 210

Table 1. Quarantine diseases for Washington State present in Hawaii. 

Genus and species (if applicable) Common name Host (in HI) Type 

Bean common mosaic potyvirus Bean common mosaic virus Beans Virus 

Colletotrichum lindemuthianum Bean anthracnose Beans Fungus 

C. truncatum Lentil anthracnose Alfalfa Fungus 

Clavibacter michiganensis spp. sepedonicus1 Bacterial ring rot Potato, eggplant Bacteria

Erwinia carotovora subsp. atroseptica1

 Soft rot Potato Bacteria

Potato leaf roll polerovirus1 Potato leaf roll virus Potato Virus 

Potato Y potyvirus (N strain) Potato virus Y (necrotic) Potato Virus 

Pseudomonas syringae pv. phaseolicola Halo blight Beans Bacteria

P. syringae pv. syringae Brown spot disease Beans Bacteria

Sclerotium cepivorum Onion white rot Onions Fungus 

Verticillium albo-atrum Verticillium wilt Potato, tomato Fungus 

Xanthomonas albilineans2 Sugarcane leaf scald Sugarcane Bacteria

X. campestris pv. phaseoli Common bean blight Beans Bacteria

X. phaseoli var. fuscans Fuscous blight Beans Bacteria

X. vasculorum2 Sugarcane bacterial blight Sugarcane Bacteria

1

 Washington State has a general quarantine for seed potato diseases, and a specific quarantine for Potato virus Y 

(Laboratory Services Division, 1999) 

2

 Federal quarantine 

Table 2. Rationales for pathogens being Low risk for establishment in Washington State via baled waste 

from Hawaii. 

Pathogen Rationale for Low risk rating 

Bean common mosaic 

potyvirus

▪ Seed-borne and aphid-vectored: infected seeds unlikely to be present 

and aphids highly unlikely to survive 

Clavibacter michiganensis 

spp. sepedonicus 

Pseudomonas spp. 

Xanthomonas spp. 

▪ These bacterial pathogens need oxygen and are unlikely to survive in 

the bales 

Colletotrichum 

lindemuthianum 

C. truncatum

▪ Primarily seed-borne, therefore presence in the bale and dispersal after 

escape are unlikely 

▪ Dormant agents may need oxygen for survival 

Erwinia carotovora subsp. 

atroseptica

▪ Short-term survival outside of a suitable host (e.g., in soil) 

▪ Low survival in dry conditions, so Klickitat County may be a poor 

habitat 

Potato virus Y potyvirus 

Potato leaf roll polerovirus 

▪ Aphid-vectored or spread by propagative host material, both of which 

are highly unlikely to survive in the bales 

Sclerotium cepivorum ▪ Germination induced by chemicals exuded by Allium sp. roots 

▪ Low likelihood of contact with host because Klickitat County has few 

acres of onion (National Agricultural Statistics Service, 2004b) 

Verticillium albo-atrum ▪ Establishing anoxic soil conditions, i.e. flooding, is a commonly used 

cultural practice for control of Verticillium wilt, so it is unlikely to 

survive in the bale 
PRA for Baled Solid Waste to WA 211

Table 3. Quarantine Hawaiian pest plants present (“9”), from three sources, and presence (+) in 

Washington State (WA). Synonyms were not listed. 

Genus species Common name1

 Presence in HI (by source2) WA

 PLANTS Bishop Manual 

1 Carduus pycnocephalus Italian plumeless thistle 9 9 9 + 

2 Centaurea biebersteinii spotted knapweed 9 9 9 + 

3 C. melitensis Maltese star-thistle 9 9 9 + 

4 Cirsium vulgare bull thistle 9 9 + 

5 Convolvulus arvensis field bindweed 9 9 9 + 

6 Cyperus esculentus chufa flatsedge 9 9 9 + 

7 Cytisus scoparius scotchbroom 9 9 9 + 

8 Egeria densa Brazilian waterweed 9 9 9 + 

9 Hypericum perforatum common St. Johnswort 9 9 9 + 

10 Leucanthemum vulgare oxeye daisy 9 9 9 + 

11 Myriophyllum aquaticum parrotfeather watermilfoil 9 9 9 + 

12 Picris hieracioides hawkweed oxtongue 9 9 9 + 

13 Solanum elaeagnifolium silverleaf nightshade 9 9 9 + 

14 S. rostratum3 buffalobur nightshade 9 9 + 

15 Soliva sessilis field burrweed 9 + 

16 Sorghum halepense Johnsongrass 9 9 9 + 

17 Spartium junceum Spanish broom 9 9 9 + 

18 Tanacetum vulgare common tansy 9 9 + 

19 Tribulus terrestris puncturevine 9 9 9 + 

20 Ulex europaeus common gorse 9 9 9 + 

1

 According to PLANTS 

2

 Databases: PLANTS (USDA NRCS, 2004), Bishop (Bishop Museum, 2004), Manual (Wagner et al., 1999); 

latter two after PRER (2004) 

3

 Eradicated from Hawaii in 1977 

Conclusions

We found no exceptional risks related to the two proposals that justified a conclusion different from that 

given in the previous assessment (CPHST, 2006). A few mitigating factors seemed particularly 

noteworthy: 

• The climate in Klickitat County is very different from that found in most Hawaiian cities; 

• Hawaiian pest plant species of concern are already present in Washington State; and 

• The risks from relevant diseases and pathogens seem likely to be effectively mitigated by the baling 

technology and other factors. 

Overall, transportation of urban MSW from Hawaii to Roosevelt Regional Landfill in Washington State 

by PRER or HWS in airtight bales poses an insignificant risk of pest establishment. 

Last, we note that only the pest risk associated with the proposals by PRER and HWS to move baled 

MSW from Hawaii to Washington State were addressed here. Complete approval of the proposal 

(pathway) or particular procedures should not be inferred. The pathway and proposal in question may 

still be subject to denial or modification, in whole or in part, based upon other constraints (pest or nonpest related), such as available resources or other Federal regulations. 
PRA for Baled Solid Waste to WA 212

References 

APS-APHIS Virus Working Group. 2003. Widely Prevalent Virus List by State [Online]. Animal and 

Plant Health Inspection Service (APHIS), U.S. Department of Agriculture; and The Plant Virology 

Committee, American Phytopathological Society (APS), Riverdale, MD, and St. Paul, MN (verified 

May 19, 2004). 

Bishop Museum. 2004. Bishop Museum--Hawaiian Flowering Plant Checklist [Online]. The State 

Museum of Natural and Cultural History, Honolulu, Hawaii. 

http://www.bishopmuseum.org/research/natsci/botany/botdbhome.html (verified June 1). 

CPHST. 2006. The Risk of Introduction of Pests to the Continental United States via Plastic-Baled 

Municipal Solid Waste from Hawaii. Center for Plant Health Science and Technology (CPHST), 

Plant Protection and Quarantine, USDA-APHIS, Raleigh, NC. August 2006. 45 pp. 

Department of Assessment and GIS. 2003. 2003 Population and Economic Handbook: Klickitat County 

[Online]. Clark County Department of Assessment and GIS, Clark County, Vancouver, Washington. 

http://gis.clark.wa.gov/applications/gishome/publications/popecon_docs/27-klecon.pdf (posted 

January 2003; verified March 24, 2005). 

EPA. 1993. Safer Disposal For Solid Waste: The Federal Regulations for Landfills, EPA/530 SW-91 

092,. Environmental Protection Agency (EPA), Washington, DC. 18 pp. 

Hoyle Consulting Services. 2002. 2000 Klickitat County Comprehensive Solid Waste Management Plan 

Update Including The Moderate Risk Hazardous Waste Management Plan Update. Prepared for 

Klickitat County Solid Waste Department, Goldendale, Washington. February 2002. 117 + 

Appendices pp. 

HWS. 2006. HWS-APHIS Resource Compendium. Hawaii Waste Systems, LLC, Seattle, Washington. 

March 28, 2006. 172 pp. 

Laboratory Services Division. 1999. Washington: Summaries of Exterior Quarantines. Department of 

Agriculture, State of Washington, Olympia, WA. August, 1999. 21 pp. 

Luneke, D. 2004. [Correspondence about the] Compliance Agreement for Honolulu Solid Waste 

Transportation. Pacific Rim Environmental Resources, Inc., Goldendale, Washington. April 20, 

2004. 6 pp. 

Montgomery, S.L., and A. Manning. 2004. (Exhibit 5) Memorandum: Multiple mortality factors for 

stowaway pests in sealed solid waste bales, an analysis for PRER, LLC. Honolulu Solid Waste 

Export Project: Waste Handling and Management Operations Protocol. Pacific Rim Environmental 

Resources, Inc., Goldendale, WA. p. 3. 

National Agricultural Statistics Service. 2004a. 2002 Census of Agriculture County Profile: Klickitat, 

Washington [Online]. Washington Agricultural Statistics Service, National Agricultural Statistics 

Service, U.S. Department of Agriculture, Olympia, Washington. 

http://www.nass.usda.gov/census/census02/profiles/wa/cp53039.PDF (verified March 24, 2005). 

National Agricultural Statistics Service. 2004b. 2002 Census of Agriculture -- County Data [Online]. 

National Agricultural Statistics Service, U.S. Department of Agriculture, Washington, D.C. 

http://www.nass.usda.gov/census/census02/volume1/wa/index2.htm (verified March 24, 2005). 

PRER. 2004. Honolulu Solid Waste Export Project: Waste Handling and Management Operations 

Protocol. Pacific Rim Environmental Resources, Inc. (PRER), Goldendale, WA. February, 2004. 

115 pp. 

Rabanco. 2004. Roosevelt Regional Landfill [Online]. Rabanco,, Seattle Washington. 

http://www.rabanco.com/regional_landfill/default.aspx (verified March 24, 2005). 
PRA for Baled Solid Waste to WA 213

University of Hawaii and Hawaii Department of Agriculture. 2004. Crop Knowledge Master [Online]. 

University of Hawaii, College of Tropical Agriculture and Human Resources (UH-CTAHR), and 

Hawaii Department of Agriculture (HDA), Manoa, HI (verified May 19, 2004). 

USDA NRCS. 2004. The PLANTS Database, Version 3.5 [Online]. National Plant Data Center, 

National Resources Conservation Service (NRCS), U.S. Department of Agriculture (USDA), Baton 

Rouge, LA. http://plants.usda.gov (verified June 1). 

Wagner, W.L., D.R. Herbst, and S.H. Sohmer. 1999. Manual of the Flowering Plants of Hawai'i. Rev. 

ed. University of Hawaii Press, Bishop Museum Press, Honolulu, HI. 1919 pp. 

Authors 

Barney P. Caton, Ecologist/Pest Risk Analyst Lisa M. Ferguson, Plant Pathologist 

barney.p.caton@aphis.usda.gov lisa.m.ferguson@aphis.usda.gov 

(919) 855-7504; (919) 855-7595 (fax) (919) 855-7515 

Center for Plant Health Science and Technology 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 
 

214

Appendix E. Risk of Introduction of Pests to Oregon via GRG from 

Hawaii.
 Version 1, September 25, 2007 

United States 

Department of 

Agriculture 

Animal and Plant 

Health Inspection 

Service 

September 2007 

The Risk of Introducing Pests to Gilliam 

County, Oregon via Hawaiian Plastic-Baled 

Municipal Solid Waste 

Agency Contact: Barney P. Caton 

Authors: Betsy Randall-Schadel and Barney P. Caton 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology 

Plant Protection and Quarantine 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606
Hawaiian baled MSW to OR 216

Executive Summary 

Proposals to move waste 

to mainland landfills in 

airtight bales 

This assessment focuses 

on proposed transport to 

a landfill in Oregon 

Description of transport 

means and route 

Low risk conveyances 

Unsuitable climate 

Few relevant quarantine 

pests 

Risk rating different than 

Low Risk not justified 

Companies are proposing to transport large volumes of 

municipal solid waste (MSW) in airtight bales from Hawaii to 

landfills in the continental United States. In a previous general 

pest risk assessment, CPHST found that the risk of introduction 

of pests from Hawaii via this pathway was insignificant. Here we 

assess a proposal by Waste Management Disposal Services of 

Oregon, Inc., to transport baled MSW to the Columbia Ridge 

Solid Waste Landfill in Gilliam County, Oregon. Our objective is 

to determine if the proposal entails any exceptional risks, due to 

different procedures or the specific transport route or location of 

the landfill that would justify a different recommendation than 

was made for the general pathway. 

The company proposes to barge the baled MSW to one of two 

ports in Oregon: the primary location is Arlington (Gilliam 

Count); the alternative location is Rainier (Columbia County). 

Bales will be transported to the landfill by truck from Arlington 

and by rail from Rainer. All transportation methods are low risk. 

The local environments and climates for the two ports and the 

Gilliam Country landfill do not pose exceptional risks. The 

climate in Gilliam County is drier and much colder than that in 

most Hawaiian cities and should mitigate the risk from tropical 

and sub-tropical pests. The landfill is a modern facility that 

complies with relevant federal regulations. The environment of 

Columbia County is milder that Gilliam County. None of the 

relevant Federal or State quarantine plant pests, which include 

insects, mollusks, pathogens and invasive plants, was found to 

present an exceptional threat of surviving, escaping and 

establishing via this pathway. 

This proposal largely followed the procedures outlined in the 

general pest risk assessment, and we found no factors that 

justified a pest risk rating other than Low risk. Transportation of 

baled Hawaiian MSW to Gilliam County, Oregon poses an 

insignificant risk of pest establishment. We recommend that the 

pathway be monitored to ensure that procedures and compliance 

do not differ significantly from what was described here and in 

the general pest risk assessment. 
Hawaiian baled MSW to OR 217

Introduction 

Assess risk of plasticbaled waste from Hawaii 

General pest risk 

assessment had Low risk 

ratings for plant pests. 

Waste Management 

proposed shipping 

baled MSW from Hawaii 

to a landfill in Gilliam 

County, Oregon 

The Center for Plant Health Science and Technology (CPHST), 

at the request of Hawaii, conducted a general pest risk 

assessment to analyze the likelihood of introduction of pests into 

the continental United States via the transport of plastic-baled 

municipal solid waste (MSW) from Hawaii (CPHST, 2006). The 

MSW would be shredded, compressed, and wrapped in adhesivebacked, plastic film barriers made of low density polyethylene 

(LDPE), creating airtight packages. Bales would be transported 

by barge to a receiving facility on the mainland, moved by rail or 

truck to the landfills, and then buried intact in accordance with 

regulations for solid waste disposal (40CFR§258; EPA (1993)), 

with each company transporting perhaps 300,000 tons of MSW 

per year. A pest risk assessment was required because garbage 

from Hawaii cannot enter the continental United States under 

current federal regulations for plant pests (7CFR§330.400). The 

assessment dealt only with parts of the pathway expected to be 

valid for any company proposing to transport the baled waste. 

In the general pest risk assessment, CPHST (2006) concluded 

that, if the planned procedures were followed, transportation of 

baled Hawaiian MSW posed an insignificant risk of pest 

establishment. Reasons included exclusion of most yard and 

agricultural waste from the pathway to greatly reduce the 

presence of potential plant pests or propagules in the bales; 

inability of insects, mollusks, and most pathogens to survive in 

the bales; and establishment of pathway procedures (e.g. 

monitoring during transport) to protect against escapes via 

accidental ruptures and punctures during handling and transport. 

A qualitative risk analysis indicated that the cumulative risk 

ratings for the introduction of insects, mollusks, pathogens, and 

weeds were each Low. 

Waste Management Disposal Services of Oregon, Inc. (Waste 

Management or WMDSO) has proposed moving baled MSW 

from Hawaii to the Columbia Ridge Solid Waste Landfill (CRL) 

in Gilliam County, Oregon. Bales will be transported by barge to 

either Rainier or Arlington, Oregon, and then by truck or rail to 

the landfill. The objective of this assessment is to assess whether 

any exceptional risk factors in the proposal warrant a 

recommendation other than the Low risk rating given in the 

general pest risk assessment (CPHST, 2006). Although a baling 

technology provider has not been decided upon by WMDSO, the 

procedures proposed by Waste Management (2005) for 

transporting baled MSW will closely follow the procedures 
Hawaiian baled MSW to OR 218

evaluated by CPHST (2006). Specific items considered here 

include the destination landfill, the Federal and State quarantine 

pests of concern, the type(s) of transportation used to move bales 

after reaching the mainland, and any other notable factors in the 

proposal. 

Definitions of key terms 

Definition of ‘garbage’ 

Definition of a ‘spill’ 

Other definitions 

Garbage is defined as urban (commercial and residential) solid 

waste from Hawaiian municipalities. Based on company 

proposals to move baled MSW (not shown), this analysis 

assumes that yard and agricultural waste will be actively 

excluded from the waste stream. 

A spill is defined as the escape of waste material from a bale and 

contact with the ground, truck, tractor, barge, or other terrestrial 

feature. 

Other important terms are defined as follows Merriam-Webster 

(2004): 

Anaerobic: Living, active, occurring, or existing in the absence 

of free oxygen. The term only correctly applies to 

organisms, not non-living things like bales or the 

conditions within them 

Anoxia: Hypoxia especially of such severity as to result in 

permanent damage 

Anoxic: Greatly deficient in oxygen 

Hypoxia: A deficiency of oxygen reaching the tissues of the 

body 

Basic Proposal 

Eight important details 

Agricultural and yard 

waste separated 

Bale specifications 

Bale staging conditions 

Following are some important details from the proposal by 

Waste Management (2005). 

1) Agricultural and yard waste will be separated, or diverted to 

other disposal sites, so that it does not enter the pathway. 

2) The waste compression and baling system used will create 

rectangular bales weighing 2 to 3 tons, with a density of about 

1600 to 2000 pounds per cubic yard (approx. 950 to 1200 

kg/m3

). Densities should be about 1000 kg/m3 (CPHST, 2006). 

3) WMDSO did not specifically state that bales would not be 

allowed to contact soil or other moist surfaces and to be 

distanced from vegetation, but they mentioned that bales would 

be kept in quarantine. New processing facilities built in 
Hawaiian baled MSW to OR 219

Shipping 120,000 tons 

annually 

Two transportation 

route options 

Barge then truck 

Barge then rail 

Tracking bales 

Monitor bales for damage 

Transport in industrial 

bags if repair is not 

possible 

Proposed bagging spills 

differs from previous 

proposals, but 

rewrapping restaging will 

be required in Hawaii. 

Hawaii, as well as unloading stations on the mainland, need to 

accommodate this requirement. 

4) Estimated shipping an annual maximum of 120,000 tons 

(Willmann, 2007). 

5) Bales will be moved up the Columbia River by barge, and 

then to the landfill by one of the following routes (Fig. 1): 

a) 210 miles up river to the Port of Arlington, Oregon (Gilliam 

County), then approx. 10 miles on truck and flatbed trailer to 

the landfill; or 

b) 52 nautical miles to a facility at Rainier, OR, near Portland, 

then approximately 130 miles by rail flatcar to the landfill. 

6) Track bales using an electronic manifesting system. 

7) Monitor bales for ruptures and punctures, and patch ruptured 

bales when and where found. 

8) If patching is not possible, MSW proposed that bale will be 

contained and transported to the landfill in one or more 

industrial-grade bags (Super Sack®, B.A.G. Corp., Dallas, 

TX), with MSW inside 6-ml LPE liners. Liners will be handclosed to create an airtight package (Willmann, 2005). The 

bales will need to be re-wrapped and re-staged if damage 

occurs in Hawaii. If the bale damaged is beyond patching and 

in route to Oregon or in Oregon, the bag protocol can be used. 

Though probably slightly inferior to re-baling, in terms of 

compression and forced evacuation of air, it offers the 

advantage of quickly collecting and sealing the MSW with less 

handling than if the MSW were put through the baling process 

again. As with bales (CPHST, 2006), the packages would be 

re-staged for several days before transport re-starts. If the 

clean-up, disinfection, and bag sealing procedures described in 

the Waste Management proposal (2005) are followed, we think 

the pest risk mitigation will be equally effective. 

Destination landfill 

Columbia Ridge Recycling 

and Landfill meets EPA 

guidelines 

The CRL (www.wmnorthwest.com/landfill/landfillcities/ 

columbia.html) in Gilliam County, near the town of Arlington 

(Fig. 2), is modern and meets regulations and EPA guidelines 

for design and operation, e.g. EPA (1993). We expect proper 

landfilling of bales at this site, and therefore the mitigation 

likely to come from landfilling seems valid (CPHST, 2006). 
Hawaiian baled MSW to OR 220

Figure 1. Map showing the transport route by barge (light blue), and either 

rail (yellow) or truck (green) for baled MSW to the Columbia Ridge 

Landfill in Oregon. 

Figure 2. Map of Columbia Ridge Landfill and surrounding locations. 

Transportation of bales 

Quantitative risk for 

transportation modes and 

routes 

As discussed above, bales will be barged up the Columbia River, 

and then moved either onto trucks or onto railcars (Willmann, 

2007). The generic quantitative risk analysis for bale-rupturing 
Hawaiian baled MSW to OR 221

Tandem tows decrease 

number of trips 

accidents to transport of bales (CPHST, 2006) and modified 

(CPHST, 2007), Appendix A) was further adapted for the two 

routes proposed by Waste Management to the CRL. The 

proposed use of tandem tows (two barges towed inline) 

decreased the number of trips by half. The impact of accident 

rate on the tandem towing of barges was not examined. The two 

proposed routes and associated risks follow.

Main route option

Barge then truck 

Mean years to first balerupturing accident was 

2,222 for trucks and 

246 for barges 

Low Risk route overall 

Unloading at the Willow Creek Barge Facility, Port of Arlington 

and trucking to the CRL requires an increase from 140 barge 

miles in the generic model to 210 miles, and a decrease in truck 

miles from 25 to 10. 

The risk of any bale-rupturing accident for trucks was 0.00045, 

while that for barges was 0.0041. Mean years to the first balerupturing accident for trucks was 2,222, and that for barges was 

246. We found a 95 percent chance that the first truck accident 

would occur only after 5444 years, or after 1391years for barge 

transport. The risk of catastrophic rupture of bales while they are 

being transported by truck or barge to CRL is therefore Low. 

Alternate route option 

Barge then rail 

Mean years to first balerupturing accident was 

2222 for trucks and 

 247 for barges 

Unloading in Rainier, Oregon, and transporting by rail to CRL 

reduces rail miles in the model from 500 to 180, and barge 

distance from 140 to 52 nautical miles. 

The risk of any bale-rupturing accident by train was 0.00002, 

while that for barges was 0.0077. Mean years to the first balerupturing accident for trains was 50,000.4, and for barges was 

130. We found a 95 percent chance that the first train accident 

would occur only after 921 years, or after 554 years for barge 

transport. The risk of catastrophic rupture of bales while they are 

being transported by truck or barge to CRL is therefore Low. 

Local environment and climate comparison to Hawaii

Climate in Hawaii The tropical climate in Hawaii is characterized by relatively 

uniform day lengths and temperatures (Western Regional 

Climate Center, 2007). Annual climatic averages for Honolulu 

(Oahu) are maximum temperature = 84.0 °F, minimum 

temperature = 70.2 °F, and total precipitation = 20.7 inches (52.6 

cm), while the same averages for Hilo (Hawaii) are maximum 

temperature = 81.2 °F, minimum temperature = 66.3 °F, and total 

precipitation = 128.2 inches (3.25 m) (Western Regional Climate 

Center, 2007). 
Hawaiian baled MSW to OR 222

Gilliam County lies in rain 

shadow 

Climate is arid and cold in 

comparison to Hawaii 

Local agriculture: Wheat 

predominate crop in the 

area 

Climate of Rainier based 

on Longview, WA, 

Annual precipitation at 

Rainier is similar to that 

of Hawaii 

Gilliam County lies in the eastern rain shadow of the coastal 

Cascade Mountains (Department of Assessment and GIS, 2003). 

Mean annual precipitation is only about 15 inches (38 cm), and 

most falls during the winter (Taylor et al., 2005). The mean 

(annual) daily maximum temperature in the county is 58.7 °F, 

and the mean daily minimum is 35.7 °F. That is about 20 °F less 

than the mean maximum temperatures in Hawaii, and about 30 

°F less than the mean minimum temperatures. In addition, mean 

annual snowfall in the central part of Gilliam County is about 18 

inches (45.7 cm; equal to approximately 4.6 cm of rainfall). 

Thus, Gilliam County is drier and much colder than most 

municipalities in Hawaii. Most of the transport route (Fig. 1) is 

also in the rain shadow of the coastal range, and therefore would 

also be significantly drier and colder. 

Gilliam County is in the main wheat-producing area of Oregon. 

Most acreage in the county is devoted to wheat, followed by 

forage and barley (National Agricultural Statistics Service, 

2004). Apples, grapes and other irrigated crops are found in the 

northern part of the county. 

Rainier is in Columbia County, OR. We used weather 

information for Longview, WA, which is directly across the 

Columbia River from Rainier. Rainier and Longview have 

climates which are more moist and mild than that of Arlington 

(Western Regional Climate Center, 2007). The annual climatic 

averages for Longview range from an average maximum 

temperature of 61.7 °F to an average minimum temperature of 

41.8 °F (Western Regional Climate Center, 2007). The total 

annual precipitation averages 46.3 inches (18.2 cm), with an 

annual average snowfall of 4.9 inches (1.9 cm) (Western 

Regional Climate Center, 2007). 

Though much colder than Hawaii, annual precipitation in Rainier 

is between the averages recorded for Honolulu and Hilo. Thus, 

compared to Arlington, the Rainier area poses a greater pest 

establishment risk. The proximity of Rainier to several protected 

wetlands and wildlife refuges also increases the potential 

environmental risk from hitchhikers from this route (EPA, 2007). 

Potential plant pests

We expect a low 

incidence of pests in 

baled MSW 

Quarantine plant pests from Hawaii include pathogens, mollusks, 

insects, and invasive plants (CPHST, 2006). We expect an 

extremely low incidence of these pests in Hawaiian municipal 
Hawaiian baled MSW to OR 223

solid waste (CPHST, 2006). In addition to federal quarantines, 

Oregon has state plant pest quarantines in Gilliam County for 

apple maggot (603-052-0121), small broomrape (603-052-1025) 

and noxious weeds (603-052-1200). 

Insects 

Insects are highly 

unlikely to survive in 

bales

Of the insect pests of concern to the Oregon nursery industry, 

two, Popillia japonica (Japanese beetle) and Homalodisca 

coagulata (Say) (glassy winged sharpshooter), are present in 

Hawaii (Table 1). Some insects in Hawaii are Federal quarantine 

pests (Table 2). We do not discuss insects further since they are 

highly unlikely to survive in the bales (CPHST, 2006).

Invasive plants 

Definition of category A 

noxious plant 

Four category A noxious 

weeds present in Hawaii 

Aquatic weed, Hydrilla 

Two other noxious weeds 

produce seed with low 

viability 

In Oregon, Category “A” noxious plant species are defined as 

“Weeds of known economic importance which occur in the state 

in small enough infestations to make eradication or containment 

possible; or which are not known to occur, but their presence in 

neighboring states makes future occurrence in Oregon seem 

imminent” (Oregon Department of Agriculture, 2005). Only four 

of these Category “A” species are present in Hawaii, according 

to USDA NRCS (2004), Imada et al. (2007), Bishop Museum 

(2004), and Wagner et al. (1999). Those species are Cyperus 

rotundus L. (purple nutsedge), Hydrilla verticillata (hydrilla), 

Pueraria lobata (Willd.) Ohwi (kudzu), and Solanum 

elaeagnifolium Cav. (silverleaf nightshade). 

Hydrilla, an aquatic species, may present a risk to the Rainer, 

Oregon, area, but the arid conditions in Gilliam County would 

greatly mitigate the risk. Furthermore, hydrilla relies greatly on 

reproduction from leaf fragments (Kay and Hoyle, 2007), which 

would not be possible via this pathway because plant material 

would not survive in the bales. 

Weed seed viability may be unaffected by bale conditions in 

general, but the seeds are highly unlikely to escape and contact a 

suitable growth environment. In addition, the kudzu (Susko et 

al., 2001) and Cyperus rotundus (Justice and Whitehead, 1946) 

seeds only have about 10 percent viability. The vegetative nutlets 

of C. rotundus are produced in the soil, and therefore, are much 

less likely than seeds to be present in MSW. As in the PRA for 

Washington state (CPHST, 2005), the risk from invasive plants 

in baled MSW is Low. 
Hawaiian baled MSW to OR 224

Mollusks 

Mollusks present concern 

as hitchhikers 

Suitability of climate 

C. aspersum already 

present in California

Proper staging and 

certification mitigates risk 

from mollusks

Federal quarantine phytophagous snails occur in Hawaii 

(Robinson, 2006; Table 3) and may be a risk to hitchhike on 

bales. Mollusks have been detected in pre-departure and 

permitted cargo from Hawaii headed by air to the continental 

United States (AQAS, 2007), but not in maritime shipments, for 

which less inspection data is available. Smith and Fowler (2003) 

rated the risk for movement of A. fulica by cargo and empty 

containers as Low, partly because the large size of the snail 

facilitates detection. Contact of bales with moist substrates 

(Robinson, 2006), such as soil or mulch, increases the likelihood 

that mollusks can become established. 

The climate in Oregon is suitable for at least one species, 

Achatina fulica (Smith and Fowler, 2003). We do not know if the 

climate is suitable for other species such as C. aspersum, but that 

species has been a problem pest in California for many years 

(Grafton-Cardwell et al., 2005). Dispersal from there probably 

poses a greater risk. 

Staging bales on impermeable surfaces away from vegetation 

sources, and certification of bales by the company as molluskfree (CPHST, 2006; Robinson, 2006) should make them Low 

Risk. 

Plant pathogens 

Some quarantine plant 

pathogens present in 

Hawaii 

Some bacterial, fungal, and viral diseases of plants under Federal 

or Oregon quarantine are present in Hawaii and the pathogens 

could be transported (Tables 4 and 5). Oregon has a general pest 

quarantine against grapes (Vitis spp.) (excluding table grapes, V. 

labrusca), but we found no pathogens of grapes in Hawaii. For 

various reasons, the plant pathogens listed in Tables 4 and 5 are 

very unlikely to establish in Oregon via this pathway (Table 6). 
Hawaiian baled MSW to OR 225

Table 1. List of insect species of quarantine concern to the Oregon nursery industry (Oregon 

Department of Agriculture, 2006) with recorded presence in Hawaii (HDOA, 2004; Nishida 

(ed.), 2002). 

Scientific Name Common Name Present in HI? 

Conotrachelus nenuphar Plum Curculio No 

Homalodisca coagulata Glassy Winged Sharpshooter Yes 

Ostrinia nubilalis European Corn Borer No 

Oulema melanopus Cereal Leaf Beetle No 

Popillia japonica Japanese Beetle Yes 

Rhagoletis mendax Blueberry Maggot No 

Rhyacionia buoliana European Pine Shoot Moth No 

Tomicus piniperda Pine Shoot Beetle No 

Yponomeuta malinellus Apple Ermine Moth No 

Table 2. Selected Federal quarantined insects present in Hawaii relevant to Oregon ecosystems. 

Scientific name (Order: Family) Common name Reference1

Adoretus sinicus (Coleoptera: Scarabaeidae) Chinese rose beetle 7 CFR§318.13

Adoretus sp. – 7 CFR§318.60

Bactrocera cucurbitae (Diptera: Tephritidae) melon fly 7 CFR§318.13

Bactrocera dorsalis (Diptera: Tephritidae) Oriental fruit fly 7 CFR§318.13

Cactoblastis cactorum (Lepidoptera: Pyralidae) cactus borer 7 CFR§318.13

Ceratitis capitata (Diptera: Tephritidae) Mediterranean fruit fly 7 CFR§318.13

Coccus viridis (Hemiptera: Coccidae) green scale 7 CFR§318.13

Chilo suppressalis (Lepidoptera: Crambidae) Asiatic rice borer 7 CFR§318.13

Eriophyes gossypii (Acarina: Eriophyidae) cotton blister mite 7 CFR§318.47

Euscepes postfasciatus (Coleoptera: Curculionidae) sweet potato scarabee 7 CFR§318.30

Lampides boeticus (Lepidoptera: Lycaenidae) bean butterfly 7 CFR§318.13

Maruca testulalis (Lepidoptera: Pyralidae) bean pod borer 7 CFR§318.13

Omphisa anastomosalis (Lepidoptera: Pyralidae) sweet potato stem borer 7 CFR§318.30

Pectinophora gossypiella (Lepidoptera: Gelechiidae) pink bollworm 7 CFR§318.47

Phyllophaga spp. (Coleoptera: Scarabaeidae) white grubs 7 CFR§318.60

Phytalus sp. (Coleoptera: Scarabaeidae) white grubs 7 CFR§318.60

Sternochetus mangiferae (Coleoptera: Curculionidae)

 synonym: Cryptorhynchus mangiferae

mango seed weevil 7 CFR§318.13

1

 CFR = Code of Federal Regulations 
Hawaiian baled MSW to OR 226

Table 3. Federal quarantined and regulated mollusks present in Hawaii that are relevant to 

Oregon ecosystems. 

Scientific name (Type: Family) Common name Reference 

Achatina fulica Bowdich 

 (Mollusca:Achatinidae) 

giant African land snail Cowie (1977; 2002b); 

Robinson, (2006) 

Cornu aspersum (Müller) 

(Mollusca:Helicidae) 

[Syn. Cryptomphalus aspersus

(Müller); Helix aspersa Müller]

brown garden snail Cowie (1977; 2002b); 

Robinson (2006) 

Laevicaulis alte (Férussac) 

 (Mollusca:Veronicellidae) 

tropical leatherleaf – thrives in 

arid biotopes 

Cowie (1977; 2002b) 

Meghimatium striatum (Hasselt) 

 (Mollusca:Philomycidae)

a terrestial snail Cowie (2002a); 

Robinson (2006) 

Parmarion cf. martensi (Simroth) 

[tentative identification] 

 (Mollusca:Helicarionidae) 

a semi-slug; Carrier of the 

human parasitic nematode, 

Angiostrongylus cantonensis

Robinson (2006) 

Paropeas achatinaceum (Pfeiffer) 

 (Mollusca:Sublinidae) 

a snail Robinson (2006) 

Pila ampullacea (Linné) 

 (Mollusca:Ampullaridae) 

“apple snail” Robinson (2006) 

Pila conica (Wood) 

 (Mollusca:Ampullaridae) 

“apple snail” Robinson (2006) 

Pila sp. 

 (Mollusca:Ampullaridae)

“apple snail” Robinson (2006) 

Pomacea canaliculata (Lamarck) 1 

 (Mollusca:Ampullaridae) 

channelled apple snail Cowie (1977; 2002b); 

Robinson (2006) 

Veroncella cubensis (Pfeiffer) 

 (Mollusca:Veronicellidae)

two striped slug or Cuban slug Cowie (1977; 2002b); 

Robinson (2006) 

1 Three other species occur in Hawaii, but this is the worst pest in that genus. 
Hawaiian baled MSW to OR 227

Table 4. Federal quarantined and regulated pathogens and nematodes present in Hawaii that are 

relevant to Oregon ecosystems. 

Scientific name (Type: Family or 

Order)1 

Common name Reference 

Meloidogyne konaensis 

(Nematoda: Meloidogynidae)

root-knot nematode Zhang and Schmitt, 

(1994) 

Xanthomonas albilineans (Ashby) 

Dowson 

 (Bacterium: Xanthomonadales 

sugarcane leaf scald USDA-APHIS-PPQ, 

(2003) 

X. axonopodis pv vasculorum (Cobb 

1894) Vauterin, Hoste, Kersters & 

Swings Synonym: X. vasculorum 

 (Bacterium: Xanthomonadales) 

sugarcane gumming disease USDA-APHIS-PPQ, 

(2003) 

1

Family is listed for nematodes; Order is listed for bacteria. 

Table 5. Plant pathogens and parasitic nematodes of concern in Oregon (Division of Plant 

Industries, 2005), and present in Hawaii (CABI, 2005; Raabe et al., 1981; University of Hawaii 

and Hawaii Department of Agriculture, 2004; USDA-APHIS-PPQ, 2003). 

Scientific name Common name 

Bean common mosaic virus (strain US-6)2,4 bean common mosaic virus 

Colletotrichum truncatum4 lentil anthracnose 

Colletotrichum lindemuthianum1,3,4 bean anthracnose

Curtobacterium flaccumfaciens pv flaccumfaciens2,3,4 bacterial wilt of beans

Ditylenchus dipsaci (onion race)5 onion stem and bulb nematode 

Fusarium graminearum2,5 wheat scab 

Phakopsora pachyrhizi4 soybean rust 

Phytophthora infestans5 potato late blight 

Pseudomonas savastanoi pv phaseolicola2,3,4

 synonym: P. syringae pv phaseolicola

halo blight of beans 

Pseudomonas syringae pv syringae2,3,5 bacterial brown spot of beans 

Sclerotium cepivorum2,3,5 onion white rot 

Xanthomonas axonopodis pv phaseoli 3,4

 synonym: X. campestris pv phaseoli 

common blight of beans 

1

 Reported present in Hawaii (CABI, 2005) and under control in Malheur County by Oregon 

Department of Agriculture ((2007) (Oregon Revised Statutes (ORS) 570.405 to 570.435). 

2

 Reported present in Oregon by CABI (2005). Bean diseases are under control in Malheur 

County by Oregon Department of Agriculture (2007) (ORS 570.405 to 570.435). 

3

 Pests of moderate to high concern. 

4

 Not known to occur or not detected in Oregon. 

5

 Limited distribution or newly established. 
Hawaiian baled MSW to OR 228

Table 6. Rationales for pathogens being low risk for introduction and establishment in Oregon 

via baled solid waste from Hawaii. 

Common/scientific name Rationale for low risk rating 

bacterial brown spot of beans 

bacterial wilt of beans 

common blight of beans 

halo blight of beans 

sugarcane gumming disease 

sugarcane leaf scald 

▪ Aerobic bacteria need oxygen (Wener, 2005) and are 

unlikely to survive in bales 

bean anthracnose 

lentil anthracnose 

▪ Primarily seedborne (CABI, 2005), so unlikely to be present 

in the bale or to disperse after escape 

▪ Dormant agents may require oxygen 

bean common mosaic virus 

(strain US-6) 

▪ Seedborne and aphid-vectored (CABI, 2005); aphids cannot 

survive and infected seeds are unlikely to be present 

▪ Only multiplies in living cells ((Agrios, 2005)) and suitable 

host plants would either not enter or survive in the bales 

onion stem and bulb nematode ▪ Needs oxygen for survival 

▪ Seedborne (CABI, 2005), so unlikely to be present or to 

disperse after escape 

▪ Most stages need host material for survival (CABI, 2005) 

▪ Fourth stage juveniles survive for years without a host, but 

populations decline rapidly (CABI, 2005) and are not likely 

to survive other bale conditions (e.g., compression, anoxia) 

onion white rot ▪ Fungus is unlikely to survive anoxic conditions in the bale 

▪ Dormant sclerotia germinate only in the presence in soil of 

specific root exudates from Allium spp. (CABI, 2005) 

potato late blight ▪ Dormant agents may need oxygen for survival 

▪ Except for oospores, a living host or crop debris is required 

for survival (CABI, 2005), which are unlikely to be present 

or to survive in the bales 

▪ The asexual stage only occurs in contact with living host 

material (Agrios, 2005; CABI, 2005), which is unlikely to 

be present in the pathway 

root-knot nematode ▪ Dormant agents may need oxygen for survival 

▪ Cool temperatures are expected to kill eggs (Schmitt, 2002) 

▪ Nematode has limited tolerance to changes in temperature 

(prefers 75±10 °F), so climatic conditions in Oregon would 

probably prevent long-term establishment (Schmitt, 2002) 

▪ Dispersal is primarily via roots and tubers, or by field 

equipment (Agrios, 2005), which are both unlikely to occur 

soybean rust ▪ Obligate parasite can only survive on live plant material, 

which would not survive in the bales 

wheat scab ▪ Seedborne; requires host material for survival (CABI, 2005), 

which is very unlikely to be present 

▪ Needs oxygen for survival 
Hawaiian baled MSW to OR 229

Conclusions

We found no exceptional 

pest risks 

Three notable mitigating 

factors 

Overall Low Risk of pest 

establishment 

Both routes with 

conveyances were Low 

risk for bale-rupturing 

accidents 

This assessment only 

dealt with pest risks 

The pathway may be 

disallowed for other 

reasons 

We found no significant exceptional pest risks related to the 

WMDSO proposal to take baled MSW to the CRL that justified a 

conclusion different from that given in CPHST (2006). 

A few mitigating factors seemed particularly noteworthy: 

• The climate in Gilliam County is very different from that of 

Hawaii; 

• Very few relevant invasive plant species in Oregon are 

present in Hawaii; and 

• The risks from relevant diseases and pathogens seem likely 

to be effectively mitigated by the bale technology and other 

factors. 

Overall, transportation of urban solid waste from Hawaii to the 

CRL in Oregon by WMDSO in plastic-wrapped, airtight bales 

poses a Low risk of pest establishment. Perhaps the greatest pest 

risk is from hitchhikers, so we strongly recommend that bales be 

certified mollusk-free by the company (subject to audit by USDA 

APHIS). 

The two routes proposed, barge plus truck or barge plus rail, 

were both Low risk for accidents. However, in the alternate route 

the unloading site of Rainier, Oregon, has a milder climate and 

represents an increased possibility of establishment by 

hitchhiking mollusks and other pests. 

Last, we only addressed the pest risk associated with the proposal 

by WMDSO to move baled MSW from Hawaii to Oregon. 

Complete approval of the proposal (pathway) or particular 

procedures should not be inferred. The pathway and proposal in 

question may still be subject to denial or modification, in whole 

or in part, based upon other constraints (pest or non-pest related), 

such as available resources or other State or Federal regulations. 
Hawaiian baled MSW to OR 230

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Activity Systems, United States Department of Agriculture Animal and Plant Health 

Inspection Service, Plant Protection and Quarantine. Last accessed April 19, 2007, 

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Museum of Natural and Cultural History. Last accessed June 1, 

http://www.bishopmuseum.org/research/natsci/botany/botdbhome.html. 

CABI. 2005. Crop Protection Compendium. CAB International (CABI), Wallingford, UK. 

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the Hawaiian Islands. Bishop Museum Press, Honolulu, HI. 66 pp. 

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Contacts 

Center for Plant Health Science and Technology 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

919-855-7595 (fax) 

Barney P. Caton, Ph.D. 

Ecologist/Pest Risk Analyst 

barney.p.caton@aphis.usda.gov 

919-855-7504 

 

Betsy Randall-Schadel, Ph.D. 

Plant Pathologist/Risk Analyst 

betsy.randall-schadel@aphis.usda.gov 

919-855-7544 
 

233

Appendix F. Risk of Introduction of Pests to Idaho via GRG from 

Hawaii.
United States 

Department of 

Agriculture 

Animal and Plant 

Health Inspection 

Service 

September 2007 

The Risk of Introducing Pests to Elmore 

County, Idaho, via Plastic-Baled Municipal 

Solid Waste from Hawaii 

Agency Contact: Barney P. Caton 

Authors: Barney P. Caton, Andrea Lemay, and Betsy 

Randall-Schadel 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology 

Plant Protection and Quarantine 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 235

Executive Summary 

Proposals to move waste to 

mainland landfills in airtight 

bales 

This assessment is for 

proposed transport to 

Idaho 

Description of transport 

means and route 

Unsuitable climate 

No exceptional factors 

favoring pest establishment 

Risk rating different than 

Low Risk not justified 

Companies are proposing to transport large volumes of Hawaiian 

municipal solid waste (MSW) in airtight bales to landfills in the 

continental United States. In a previous general pest risk assessment, 

CPHST found that the risk of introducing pests from Hawaii via this 

pathway was insignificant. The following is an assessment of a 

proposal by Idaho Waste Systems, Inc. to transport baled MSW to the 

Simco Road Regional Landfill in Elmore County, Idaho. The landfill 

is a modern facility that complies with all relevant federal 

regulations. Our objective was to determine if the proposal entails 

any exceptional risks, due to different procedures or the specific 

transport route or location of the landfill, that would justify a different 

recommendation than was made for the general pathway. 

This proposal closely follows the procedures for waste processing, 

bale creation, monitoring, and transport outlined in the general pest 

risk assessment. The company proposes to barge the baled MSW to 

the mainland for unloading at Rainier, Oregon. Bales will be 

transported directly to the landfill by rail. The transportation methods 

to be used are low risk for accidents that might rupture bales. 

In addition, the climate in Elmore County is much drier and colder 

than that in Oahu, which will mitigate against many possible 

introductions of subtropical Hawaiian pests. 

We found 44 Federal or State quarantine plant pests relevant to this 

pathway. These included 19 insects, 16 pathogens and nematodes, 

two mollusks, and nine invasive plants. None of them posed an 

exceptional threat—i.e., factors enabling special means of escaping or 

dispersing, or an enhanced likelihood of establishment—of 

introduction and establishment via this pathway. 

In conclusion, we found no factors that justified a different pest risk 

finding than the Low Risk rating given in the general risk 

assessment. The transportation of baled MSW from Hawaii to Elmore 

County, Idaho, poses an insignificant risk of pest establishment. 

We recommend that the pathway be monitored to ensure that 

procedures and compliance do not differ significantly from what was 

described in this document and in the general pest risk assessment. 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 236

Introduction

General pest risk 

assessment done in 2005 

High-density, airtight bales 

Previous finding was 

insignificant pest risk 

Factors contributing to low 

risk for the pathway 

Low Risk ratings given to 

pest introductions 

New proposal for Idaho 

Objective is to find 

exceptional risk factors 

Site-specific factors 

considered 

A general pest risk assessment was done by the Center for Plant 

Health Science and Technology (CPHST) at the request of Hawaii to 

assess the likelihood of introduction of pests into the continental 

United States via the transport of Hawaiian plastic-baled municipal 

solid waste (MSW) (CPHST, 2005a). In the baling process MSW is 

compressed and wrapped in adhesive-backed, plastic film barriers 

made of low density polyethylene (LDPE), creating airtight packages. 

Bales are then transported by barge to a receiving facility on the 

mainland, taken to landfills by rail or truck, and buried (intact) in 

accordance with solid waste disposal regulations (40CFR§258; EPA 

(1993). The assessment dealt with parts of the pathway applicable to 

all companies proposing to transport baled MSW. A pest risk 

assessment was necessary because garbage from Hawaii cannot enter 

the continental U.S. under current federal regulations for plant pests 

(7CFR§330.400). 

CPHST concluded that, if the general procedures described were 

followed, the transportation of baled MSW from Hawaii posed an 

insignificant risk of pest introduction and establishment (CPHST, 

2005a) for the following reasons: 

● the exclusion of most yard and agricultural waste from the pathway 

would reduce the presence of potential plant pests or propagules in 

the bales 

● insects and some pathogens are unlikely to survive in the bales 

● other pathway procedures (e.g., monitoring during transport) would 

adequately protect against escapes via accidental ruptures and 

punctures during handling and transport 

Qualitative risk analysis indicated that the cumulative risk ratings for 

the introduction of insects, pathogens, and weeds were Low. 

Idaho Waste Systems, Inc. has proposed moving baled MSW from 

Hawaii to the Simco Road Regional Landfill in Elmore County, 

Idaho. Bales will be transported by barge to Rainier, Oregon, and 

then by rail to the landfill. The objective of this assessment is to 

evaluate the proposal by Idaho Waste Systems to determine if any 

exceptional risk factors exist to warrant a risk rating greater than 

Low. Although a specific baling technology provider has not been 

designated by Idaho Waste Systems, the proposed procedures for 

baling and transporting the MSW (Idaho Waste Systems, 2005) 

closely follow those evaluated by CPHST (2005a). Specific items 

considered include the destination landfill, Federal and State 

quarantine pests of concern, the type(s) of transportation used to 

move bales after reaching the mainland, and other notable factors in 

the proposal. 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 237

Definitions of key terms 

Definition of ‘garbage’ 

Definition of ‘spill’ 

Other definitions 

Garbage is defined (CPHST, 2005a) as urban (commercial and 

residential) solid waste from municipalities in Hawaii (e.g., Honolulu, 

Hilo). Based on proposals to move baled waste, we assumed in this 

analysis that the company will actively exclude yard and agricultural 

waste from the waste stream. 

A spill is defined as the escape of waste material from a bale, and 

contact with the ground, truck, tractor, barge, or other terrestrial 

features. 

Other important terms are defined as follows (Merriam-Webster, 

2004): 

Anoxia: Hypoxia especially of such severity as to result in permanent 

damage 

Anoxic: Greatly deficient in oxygen 

Hypoxia: A deficiency of oxygen reaching the tissues of the body 

Anaerobic: Living, active, occurring, or existing in the absence of 

free oxygen. The term applies to living organisms, not those 

that are non-living, like bales, or the conditions within them 

Proposal review 

Eleven important details 

from the proposal 

Diversion of some waste 

Volume will increase in 

time 

Baling system details 

Staging and storage 

Transportation route 

Idaho Waste Systems (2005) indicated the following important details 

in their proposal: 

1) Agricultural and yard waste will be diverted to other disposal sites 

or separated from conveyors belts as it enters processing so that 

yard waste does not enter the pathway: the goal will be to achieve 

3 percent or less yard waste entering the waste stream 

2) The company plans to start transporting about 5,000 tons of baled 

MSW monthly, or 60,000 tons annually, but to increase that over 

time to the full barge capacity available, which would mean 

30,000 tons monthly, or 360,000 tons annually (Gauthier, 2006) 

3) The waste compression and baling system (Macpresse solid waste 

baler, model MAC 112; Idaho Waste Systems, 2005) will create 

rectangular bales weighing about 1.7 tons, with densities from 

about 1,000 to 1,500 lbs to per cubic yard (approx. 640 to 880 

kg/m3

) (Harris, 2005). Total thrust produced is equal to 440,000 

pounds, or 235 psi, which 

4) Any imperfectly sealed bales found during staging in Hawaii will 

be rewrapped and re-staged. 

5) Any stored bales will be kept on hard, impervious surfaces, at least 

100 ft from any vegetation or agricultural product 

6) Bales will be moved to the mainland and up the Columbia River 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 238

Direct loading onto railcars 

Manifesting system 

Company inspections 

Bale repairs 

Bales monofilled at the 

landfill 

Use of vapor meters could 

be an improvement 

Restaging repaired bales is 

not necessary 

Bales palletized from 

Hawaii to Oregon 

Forklifts may reduce the 

drop rate but increase the 

likelihood of punctures 

by barge to a facility near Rainier, Oregon (Columbia County) 

(Fig. 1), unloaded, and then moved to the landfill by rail, a 

distance of 550 miles (distance estimated as Longview, WA, to 

Simco, ID) (Union Pacific Railroad Corp., 2006) 

7) The company plans to move bales from the barge directly onto rail 

cars, to reduce handling 

8) Bales will be tracked with an electronic (“chain-of-custody”) 

manifesting system 

9) Bales will be inspected by the company for ruptures and punctures 

at each handling point. An organic vapor analyzer/meter will be 

used to detect waste decomposition gases that would escape if a 

puncture or rupture allowed oxygen to re-enter the bale 

10) Broken or ruptured bales will be patched or repaired when and 

where found. Bales will be repaired if ruptures are 6 inches long 

or less; otherwise they will be rewrapped at a mainland baling 

facility 

11) Bales will be segregated, or “monofilled,” in the landfill to allow 

careful handling and to avoid waste compacting operations used 

for daily deliveries of regular MSW 

In regard to item (5), we could not fully evaluate the effectiveness of 

the organic vapor meter; however, if it is sufficiently sensitive and 

properly used it could improve visual detection of small breaches. 

Also note that for item (10) above, restaging is not necessary since 

the initial staging in Hawaii would have met the requirement. At this 

point, getting the bale to the landfill quickly is proper. 

The company will handle the bales on pallets in Hawaii and while 

barging them to the mainland. The pallets are the type used for 

newsprint, wooden, with features (e.g., rounded edges, sanded 

planks) designed to avoid snagging or tearing (Gauthier, 2007). One 

pallet has the capacity for four bales, which will minimize the number 

of handling operations required, but expose four bales to a single 

accident. Furthermore, the use of standard forks will expose bales to 

accidental punctures and rips. If necessary, the company will strap the 

bales together or to the pallets. Palletized bales probably will be 

handled using lift trucks with standard forks, or cranes, which 

increases the likelihood for bale punctures. After off-loading in 

Oregon, bales will be separated from the pallets and handled using lift 

trucks with clamp-type arms. 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 239

Destination landfill 

Proposed landfill 

Alternate landfill 

Simco Road Regional Landfill (http://www.idahowaste.com/ 

simco.html) is in Elmore County, about 30 miles southeast of Boise. 

It is a modern facility that meets regulations and EPA guidelines for 

design and operation (e.g., EPA, 1993). We have no reason to believe 

that bales will not be properly landfilled at this site; therefore, the 

mitigation likely to come from landfilling (CPHST, 2005a) is valid. 

Rail travel to Idaho from the west may sometimes close during the 

winter . In that case, the company has proposed to deliver the bales to 

the Columbia Ridge Solid Waste Landfill in Gilliam County, Oregon 

(http://www.wmnorthwest.com/landfill/landfillcities/ columbia.html), 

near the town of Arlington. As above, it is a modern facility meeting 

all regulations and EPA guidelines. The environment of the alternate 

landfill poses no exceptional pest risks (CPHST, 2007). 

Transportation of bales 

Bales moved 60 miles by 

barge 

1,429 years to the first 

bale-rupturing barge 

accident 

550 miles by rail to Idaho 

385 years to the first balerupturing rail accident 

Only 180 rail miles to 

alternate landfill site 

Bales will be barged 60 miles up the Columbia River, and off-loaded 

onto railcars at Rainier, OR. Based on data on the number of freight 

barge accidents from 2000 to 2005, and estimates of the mean 

number of miles freight was moved, the mean barge accident rate was 

0.000575 per mile (Appendix A). The mean annual probability of a 

bale-rupturing barge accident was 0.0007 (0.07 percent). This gave a 

mean of 1,429 years to the first bale-rupturing accident, with only a 5 

percent chance of happening within 74 years. 

The trip by rail to the landfill is 550 miles. Like barges, rail transport 

has a very low accident rate: the mean rate from 1996 to 2006 was 

3.92 accidents per million rail miles (Appendix A). From that rate 

and other parameters, the annual probability of a bale-rupturing train 

accident was 0.0005 at the beginning of service, and 0.0026 (0.26 

percent) after the anticipated increase in volume. Accordingly, the 

estimated means for years to the first bale-rupturing accident were 

2000 years at the beginning, and 385 years after the increase. In 

addition, even in the latter case, there is only a 5 percent chance of 

that accident happening within 20 years. 

If transported by rail to the Columbia Ridge Landfill from Rainier, 

the barge miles would not change, while rail distance would decrease 

to 180 miles. We assumed this would only affect trips 25 percent of 

the time (3 mos. out of 12). Given this, the risk of any bale-rupturing 

rail accident was 0.035 percent under the starting MSW amounts, and 

0.235 percent for future amounts. Mean years to the first balerupturing accident for trains was 2,857 at start, and 426 in the future. 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 240

426 years to the first balerupturing rail accident We found a 95 percent chance that the first train accident would 

occur only after 147 years at start, and after 22 years with the 

increased amounts. Using the landfill in Oregon would decrease the 

risk somewhat, because fewer rail miles would be traveled. 

 

Local environment

Elmore County is very arid 

Major crops are livestock 

and pasture/forage 

Northern Elmore County is mountainous, while the southern 

portion—where the landfill is located—slopes down to the Snake 

River. The area is “a relatively parched environment” (Schlosser, 

2004) that supports drought-tolerant sagebrush and grasses (Fig. 2). 

Elmore County is primarily a livestock and pasture/forage area 

(National Agricultural Statistics Service, 2002). Other crops grown 

include sugar beets, potatoes, wheat, and fresh market vegetables. 

Climate

Hawaii: Mild climate, no 

freezing 

Idaho is much drier and 

much colder 

Short growing season 

Transport route mostly has 

climate like SW Idaho 

Hawaii’s tropical climate is characterized by relatively uniform day 

lengths and temperatures (National Weather Service, 1983). Annual 

climatic averages for Honolulu (Island of Oahu) are maximum 

temperature = 88.0 oF, minimum temperature = 74.4 oF, and total 

precipitation = 20.75′′ (Western Regional Climate Center, 2005a). 

Elmore County is significantly drier and colder than Oahu. Mean 

annual precipitation is only about 10′′, most of which falls as snow 

from November to February (Western Regional Climate Center, 

2005b). Mean daily minimum temperature in the county is 36.7 °F, 

and the mean daily maximum is 64.8 °F. Mountain Home, near the 

landfill, has about 150 days a year in which the temperature drops 

below freezing, 32 deg F. The growing season is only about 135 days. 

Most of the transport route (Fig. 1) is also in the rain shadow of the 

coastal range, and would be significantly drier than Oahu, and colder 

as well. 

Potential plant pests 

Very low pest incidence in 

MSW 

Quarantine plant pests for Idaho include insects, pathogens, mollusks, 

and invasive plants. We expect an extremely low incidence of these 

pests in typical MSW. 

Insects 

Only species of concern are 

federal quarantine insects 

No insects of concern for Idaho (http://www.agri.state.id.us/ 

Categories/PlantsInsects/RegulatedAndInvasiveInsects/ 

Insectpestwatchlist.php) are present in Hawaii except for federally 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 241

quarantined pests (Table 1). Insects are Low Risk because they 

cannot survive inside the bales (CPHST, 2005a); we do not discuss 

them further here. 

Pathogens 

Risk from both federal and 

state quarantine pests 

Bacterial, fungal, nematode and viral diseases of plants under Federal 

or Idaho quarantine are present in Hawaii and can be transported 

(Tables 2 and 3). For various reasons, these organisms are unlikely to 

establish in Idaho via this pathway (Table 4). 

Invasive plants 

Many Idaho noxious weeds 

are already present and 

widespread 

Three relevant noxious 

weeds are present in HI 

Risk mitigating factors 

include aquatic habit and 

unsuitable means of 

reproduction 

The state list of noxious weed species for Idaho includes species that 

are often already widespread (Division of Plant Industries, 2007a). 

Consequently, few of the listed species have limited distributions and 

would be a concern. Nine noxious weed species categorized as ‘Early 

Detection-Rapid Response’ represent the most risk (Table 5). Only 

three are reported as present or cultivated in Hawaii: Egeria densa

(Brazilian elodea), Eichhornia crassipes (water hyacinth), and 

Hydrilla verticillata (hydrilla) (Bishop Museum, 2002; Imada et al., 

2007). All three species are aquatic, and the arid conditions in 

southwest Idaho would greatly mitigate the risk from all three species. 

Furthermore, two of them—elodea and hydrilla—rely greatly on 

reproduction from leaf fragments (Kay and Hoyle, 2007a, 2007b), 

which would not be possible via this pathway because plant material 

would not survive in the bales. As in the PRA for Washington state 

(CPHST, 2005b), the risk from invasive plants in baled MSW is Low. 

Mollusks 

No risk in baled MSW, but 

potential risk as hitchhikers 

Pallets increase the 

likelihood of hitchhikers 

Four of six Idaho-regulated 

species are not present in 

Hawaii 

Risk mitigating factors 

Generally, mollusks in baled MSW pose no risk because they would 

be killed by either compression or hypoxia. They may pose risks as 

hitchhikers on the outside of bales, however (CPHST, 2006; 

Robinson, 2006). Unfortunately, in this proposal the planned use of 

pallets to transport the bales increases the likelihood that hitchhiking 

mollusks could follow the pathway. Pallets provide better cover and 

will be more difficult to inspect than the plain surfaces of the bales. 

The regulated list of mollusks for Idaho has six species (Division of 

Plant Industries, 2007b). Four are not present in Hawaii, but the 

others—Achatina fulica (giant African snail), and Cornu aspersum

(brown garden snail) (Bishop Museum, 2004b)—are among several 

Federal quarantine phytophagous snails that occur in Hawaii 

(Robinson, 2006) and might hitchhike on bale exteriors (Table 6). 

Smith and Fowler (2003) rated the risk for movement of A. fulica, by 

cargo and empty containers as low, partly because its large size 

would facilitate detection. Moreover, except for the off-loading point 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 242

Unsuitable climate for giant 

African snails in Idaho 

C. aspersum already 

present in nearby California 

Inspection and proper 

staging should 

reduce the risk 

in Oregon, weather-based mapping indicated that Idaho and eastern 

Oregon are not suitable for A. fulica establishment (Smith and 

Fowler, 2003). We do not know if the climate is suitable for other 

species such as C. aspersum, but that species has been a problem pest 

in California for many years (Grafton-Cardwell et al., 2005). 

Dispersal from there probably poses a greater risk. 

If bales are inspected and certified to be mollusk-free, and if they do 

not contact moist substrates, such as soil or mulch, before departure 

from Hawaii, the pathway should be low risk (Robinson, 2006). We 

strongly recommend that this inspection and certification be required 

and implemented. Likewise, the staging area for bales in Hawaii 

should always be on an impervious surface, and should be 

appropriately distant from vegetation to reduce the likelihood of 

snails being present (CPHST, 2006). 

Figure 1. Map showing barge (light blue) and rail (yellow) transport route for 

baled MSW to the Simco Road Regional Landfill in Idaho. 

Figure 2. Sagebrush-dominated plant community typical of Southwest Idaho 

©BLM
Vers

PRA for Hawaiian Baled MSW to ID 243Table 1. Federally quarantined insects present in Hawaii and potentially relevant to Idaho ecosystems. 

Scientific name (Order: Family) Common name Reference1

Aceria litchi (Acarina: Eriophyidae)  synonym: Eriophyes litchi

litchi rust mite, litchi gall mite Chia et al. (1997), USDA

Adoretus sinicus (Coleoptera: Scarabaeidae) Chinese rose beetle 7 CFR§318.13 Adoretus sp. – 7 CFR§318.60 Bactrocera cucurbitae (Diptera: Tephritidae) melon fly 7 CFR§318.13 Bactrocera dorsalis (Diptera: Tephritidae) Oriental fruit fly 7 CFR§318.13 Cactoblastis cactorum (Lepidoptera: Pyralidae) cactus borer 7 CFR§318.13 Ceratitis capitata (Diptera: Tephritidae) Mediterranean fruit fly 7 CFR§318.13 Coccus viridis (Hemiptera: Coccidae) green scale 7 CFR§318.13 Chilo suppressalis (Lepidoptera: Crambidae) Asiatic rice borer 7 CFR§318.13 Eriophyes gossypii (Acarina: Eriophyidae) cotton blister mite 7 CFR§318.47 Euscepes postfasciatus (Coleoptera: Curculionidae) sweet potato scarabee 7 CFR§318.30 Lampides boeticus (Lepidoptera: Lycaenidae) bean butterfly 7 CFR§318.13 Maconellicoccus hirsutus2 (Hemiptera: Pseudococcidae) pink hibiscus mealybug CABI (2005), USDA-APMaruca testulalis (Lepidoptera: Pyralidae) bean pod borer 7 CFR§318.13 Omphisa anastomosalis (Lepidoptera: Pyralidae) sweet potato stem borer 7 CFR§318.30 Pectinophora gossypiella (Lepidoptera: Gelechiidae) pink bollworm 7 CFR§318.47 Phyllophaga spp. white grubs 7 CFR§318.60 Phytalus sp. white grubs 7 CFR§318.60 Sternochetus mangiferae (Coleoptera: Curculionidae)  synonym: Cryptorhynchus mangiferae

mango seed weevil 7 CFR§318.13 

1 CFR = Code of Federal Regulations 2 This pest is established in California, Florida and Hawaii and is under biological control (Meyerdirk, 2004), but not official control. (Of

active enforcement of mandatory phytosanitary regulations and the application of mandatory phytosanitary procedures with the objective 

of quarantine pests” (IPPC, 2001).) Thus, it does not fit the IPPC definition of a quarantine pest: “A pest of potential economic importancthereby and not yet present there, or present but not widely distributed and being officially controlled” (IPPC, 2001). 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 244

Table 2. Federally quarantined pathogens in Hawaii that are relevant to Idaho ecosystems. 

Scientific name (Order: Family) Common name Reference 

Meloidogyne konaensis (Nematoda: 

Meloidogynidae)

root-knot nematode Zhang and Schmitt (1994)

Phakopsora pachyrhizi (Uredinales: 

Phakopsoraceae)

soybean rust USDA-APHIS-PPQ, 

2003; USDA-APHISPPQ, 2005 

Xanthomonas albilineans

(Xanthomonadales: Xanthomonadaceae) 

sugarcane leaf scald USDA-APHIS-PPQ, 2003

X. axonopodis pv vasculorum 

(Xanthomonadales: Xanthomonadaceae) 

Synonym: X. vasculorum 

sugarcane gumming 

disease 

USDA-APHIS-PPQ, 2003

Table 3. Plant pathogens and parasitic nematodes of concern in Idaho (Division of Plant 

Industries, 2005), and that are present in Hawaii (CABI, 2005; Raabe et al., 1981; University of 

Hawaii and Hawaii Department of Agriculture, 2004; USDA-APHIS-PPQ, 2003).

Category Scientific name Common name 

Not known to occur or not detected in the state 

 Bean common mosaic virus1 (strain US-6) bean common mosaic virus 

Colletotrichum truncatum lentil anthracnose 

Colletotrichum lindemuthianum1 bean anthracnose

Curtobacterium flaccumfaciens pv flaccumfaciens1 bacterial wilt of beans

Phakopsora pachyrhizi soybean rust 

Pseudomonas savastanoi pv phaseolicola1

 synonym: P. syringae pv phaseolicola

halo blight of beans 

Xanthomonas axonopodis pv phaseoli 

 synonym: X. campestris pv phaseoli 

common blight of beans 

Limited distribution or newly established 

Ditylenchus dipsaci (onion race) onion stem and bulb nematode

Fusarium graminearum wheat scab 

Phytophthora infestans potato late blight 

Pseudomonas syringae pv syringae bacterial brown spot of beans 

Sclerotium cepivorum2 onion white rot 1

 Reported as present in Idaho (CABI, 2005). 

2

 Pests of moderate to high concern. 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 245

Table 4. Rationales for pathogens being Low Risk for introduction and establishment in Idaho via 

baled solid waste from Hawaii.

Common/scientific name Rationale for Low Risk rating 

▪ bacterial brown spot of beans 

▪ bacterial wilt of beans 

▪ common blight of beans 

▪ halo blight of beans 

▪ sugarcane gumming disease 

▪ sugarcane leaf scald 

▪ Aerobic bacteria need oxygen and are unlikely to survive in 

bales 

▪ Free bacteria have lower survival rates, i.e., when not in 

contact with suitable host material (Agrios, 2005) 

▪ bean anthracnose 

▪ lentil anthracnose 

▪ Primarily seedborne (CABI, 2005), so it is unlikely to be 

present in the bale or to disperse after escape 

▪ Dormant agents may require oxygen 

▪ bean common mosaic virus 

(strain US-6) 

▪ Seedborne and aphid-vectored (CABI, 2005); aphids cannot 

survive and infected seeds are unlikely to be present 

▪ Only multiplies in living cells (Agrios, 1997) and suitable 

host plants; would not enter or survive in the bales 

▪ onion stem and bulb 

nematode 

▪ Needs oxygen for survival 

▪ Seedborne (CABI, 2005), so it is unlikely to be present or to 

disperse after escape 

▪ Most stages need host material for survival (CABI, 2005) 

▪ Fourth stage juveniles survive for years without a host, but 

populations decline rapidly (CABI, 2005) and are not likely 

to survive other bale conditions (e.g., compression, anoxia) 

▪ onion white rot ▪ Fungus is unlikely to survive anoxic conditions in the bale 

▪ Dormant sclerotia germinate only in soil in the presence of 

specific root exudates from Allium spp. (CABI, 2005) 

▪ potato late blight ▪ Dormant agents may need oxygen for survival 

▪ Except for oospores, a living host or crop debris is required 

for survival (CABI, 2005), which are unlikely to be present 

or to survive in the bales 

▪ The asexual stage only occurs with contact to living host 

material (Agrios, 2005; CABI, 2005), which is unlikely to 

be present in the pathway 

▪ root-knot nematode ▪ Dormant agents may need oxygen for survival 

▪ Cool temperatures are expected to kill eggs (Schmitt, 2002) 

▪ The nematode has limited tolerance to temperature change 

(prefers 75±10 °F), so climatic conditions in Idaho would 

probably prevent long-term establishment (Schmitt, 2002) 

▪ Dispersal is primarily via roots and tubers, or by field 

equipment (Agrios, 2005), which are both unlikely to occur 

▪ wheat scab ▪ Seedborne; requires host material for survival (CABI, 2005), 

which is both unlikely to be present and to survive 

▪ Needs oxygen for survival 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 246

Table 5. Idaho noxious weeds classified as ‘Early Detection-Rapid Response’, with scientific and 

common names and reported presence or cultivation in Hawaii. 

Scientific Name Common Name Present 1 Cultivated 2 

Centaurea squarrosa squarrose knapweed No No 

Eichhornia crassipes water hyacinth Yes Yes 

Egeria densa Brazilian elodea Yes Yes 

Heracleum mantegazzianum giant hogweed No No 

Hieracium glomeratum yellow devil hawkweed No No 

Hieracium piloselloides tall hawkweed No No 

Hydrilla verticillata hydrilla No Yes 

Impatiens glandulifera policeman's helmet No No 

Zygophyllum fabago Syrian beancaper No No 

1

 Bishop Museum (2004a) 

2

 Imada et al. (2007) 

Table 6. Federal quarantined and regulated mollusks present in Hawaii that may be relevant to 

Idaho ecosystems. 

Scientific name (Type: Family) Common name Reference 

Achatina fulica Bowdich (Mollusca: 

Achatinidae) 

giant African land snail Cowie (1977; 2002b); 

Robinson (2006) 

Cornu aspersum (Müller) (Mollusca: 

Helicidae) 

[Syns. Cryptomphalus aspersus (Müller);

Helix aspersa Müller]

brown garden snail Cowie (1977; 2002b); 

Robinson (2006) 

Laevicaulis alte (Férussac) (Mollusca: 

Veronicellidae) 

tropical leatherleaf Cowie (1977; 2002b) 

Meghimatium striatum van Hasselt 

(Phylomicidae)

a terrestial snail Cowie (2002a); 

Robinson (2006) 

Parmarion cf. martensi (Simroth) 

[identification tentative] 

a semi-slug 1 Robinson (2006) 

Paropeas achatinaceum (Pfeiffer) a snail Robinson (2006) 

Pila ampullacea (Linné) “apple snail” Robinson (2006) 

Pila conica (Wood) “apple snail” Robinson (2006) 

Pomacea canaliculata (Lamarck) 2 channelled apple snail Cowie (1977; 2002b); 

Robinson (2006) 

Veroncella cubensis (Pfeiffer) (Mollusca: 

Veronicellidae) 

two striped slug or Cuban 

slug 

Cowie (1977; 2002b); 

Robinson (2006) 

1

 Carrier of human parasitic nematode, Angiostrongylus cantonensis

2

 This is the worst of four Pomacea species in HI 
Version 1, September 26, 2007 

PRA for Hawaiian Baled MSW to ID 247

Conclusions 

No exceptional risks found 

for Idaho proposal 

Three notable mitigation 

factors 

Overall conclusion is an 

insignificant risk of plant 

pest establishment 

This assessment only dealt 

with pest risks 

The pathway may be 

disallowed for other 

reasons 

We found no exceptional risks related to the Idaho Waste Systems 

proposal that justified a finding different from that given in the earlier 

document by CPHST (2005a). Three risk mitigating factors seemed 

particularly noteworthy: 

• The climate in Elmore County is very different from that of Oahu; 

• Very few invasive plant species of concern in Idaho are present in 

Hawaii 

• The risks from potentially invasive diseases and pathogens are likely 

to be mitigated by the bale technology, climate, and other factors 

Overall, Idaho Waste Systems transporting MSW from Hawaii to 

Simco Road Regional Landfill in plastic-wrapped, airtight bales poses 

an insignificant risk of plant pest establishment. 

Finally, we note that we have only addressed the plant pest risks 

associated with the proposal by Idaho Waste Systems to move baled 

MSW from Hawaii to Idaho. Complete approval of the proposal 

(pathway) or particular procedures should not be inferred. The 

pathway and proposal in question may still be subject to denial or 

modification, in whole or in part, based upon other issues or 

constraints (pest or non-pest related), such as available resources or 

other State or Federal regulations. 

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Contacts 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

 

Barney P. Caton, Ph.D., Ecologist/Pest Risk Analyst 

barney.p.caton@aphis.usda.gov 

919-855-7504 

919-855-7595 (fax) 

Betsy Randall-Schadel, Ph.D., Plant Pathologist/Risk Analyst 

betsy.randall-schadel@aphis.usda.gov 

919-855-7544 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 251

Appendix A. Updating the models for the likelihood of bale-rupturing accidents during 

transport of baled municipal solid waste (MSW) by truck, rail, or barge. 

I. Introduction 

This appendix describes 

updates and changes to 

the previous model version 

Only relevant sections 

included here 

Also report effects on 

previous model results 

In 2006, we released a description of the models used to estimate the 

likelihoods of bale-rupturing accidents occurring during transport of 

baled MSW to landfills on the U.S. mainland by either truck, rail, or 

barge. Since then, more data on accident rates has become available, 

and we have changed the way barge accidents are predicted, so we 

discuss below the changes and updates to the accident models. 

Only the relevant sections are included below. For full model details 

and descriptions, see Appendix B in CPHST (2006a). 

For completeness, though, we have also included the effects these 

changes would have on the results of previous models, for the generic 

situation (CPHST, 2006a) and for the Washington state PRA (CPHST, 

2006b). 

II. Updated accident-related distributions 

A. Barges 

1. Total accidents 

Barge accident rates were 

in ton-miles before 

Changed to a rate based 

on miles, not ton-miles 

“Average haul” statistic 

provided necessary 

conversion factor 

Mean annual barge miles 

on the Columbia was 

110,000 miles 

The first change made was in the way we calculated the barge accident 

rate. That rate used to be based on ton-miles, because that is how 

waterborne freight is commonly reported (e.g., U.S. Army Corps of 

Engineers, 2003). In contrast, the accident rates for trucks and trains 

are based on vehicle miles traveled (VMT). That had the unfortunate 

effect, however, of increasing risk if the tonnage transported increased, 

even if total distance traveled was unchanged. Therefore, we changed 

the barge accident rate to match the others, calculating it in terms of 

miles rather than ton-miles. 

 To do this, we needed to estimate annual miles traveled from annual 

ton-miles. We converted ton-miles to miles using the national “average 

haul”, or the mean number of miles a ton of freight travels by water. 

For internal (inland) barge traffic, this value has been relatively 

constant over the years at about 465 miles per ton (U.S. Army Corps 

of Engineers, 2006b). Using these values, and total annual ton-miles 

for the Columbia River system (U.S. Army Corps of Engineers, 

2006a), we calculated mean annual miles traveled, which was about 

110,000 miles. 

The accident rate was calculated from statistics for 2000 to 2005 for 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 252

Fewer accidents in 2003 

and 2005 than other years 

Model rate was a triangular 

distribution 

numbers of accidents on the Columbia River (U.S. Coast Guard, 

2007). The previous estimate was based on just two years of data, 

2000 and 2001. The number of accidents per year was often about 80 

to 85, in years 2000, 2001, 2002, and 2004. But in 2003 it was only 29, 

and in 2005 it was 36. The accident rate was annual accidents divided 

by miles, and these values ranged from 0.00028 in 2003, up to 0.00088 

in 2002. The mean value was 0.00061. We estimated the model rate as 

a triangular distribution (Fig. A1) with most likely value = mean value, 

and the minimum and maximum values from the 99 percent 

confidence limits around the mean. Ninety percent of the sampled 

values from the distribution were between 0.00032 and 0.00090. 

2. Relevant accidents 

Data unchanged Accident reporting to the level of type of vessel has apparently stopped 

since the last work was done, and so it was not possible to include 

more information. Even in the previous PRA we only had data on this 

from 2000 and 2001. 

3. Bale-rupturing accidents 

Updated release rate 

No change from previous 

estimate 

We updated the estimate of the proportion of barges in serious 

hazardous waste accidents (1990-1997 data) with data from 1998 to 

2006 (Hazardous Materials Information System, 2007a, 2007b). The 

updated data had 6 serious incidents out of 216 total incidents (2.8 

percent). When combined with the previous data, the new beta 

distribution had a mean of 0.046, and 90 percent of sampled values 

were between 0.028 and 0.069 (Fig. A2). The updated mean value was 

about half of the previous mean. 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 253

Fig. A1. The distribution for the barge accident rate, number per miles traveled, based on data from 

2000 to 2005. Lines are the 5th and 95th percentiles, so 90 percent of samples fall between the lines. 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

0.0002 0.0003 0.0004 0.0005 0.0006 0.0007 0.0008 0.0009 0.001

 Probability of a barge accident

Probability density function

Fig. A2. The distribution for the likelihood of a barge accident causing bale rupture, based on data from 

1990 to 2006. Lines are the 5th and 95th percentiles. 

0

5

10

15

20

25

30

35

0 0.015 0.03 0.045 0.06 0.075 0.09

Likelihood of bale-rupturing accident

 Probability density function
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 254

B. Trucks 

1. Total accidents 

Updated estimate with 

2005 data 

We updated the data to include 2005 accidents. The new mean rate 

was 1.89 accidents per million VMT, a decrease from the previous 

mean of 1.96. The pert distribution had minimum = 1.56, and 

maximum = 2.23, with 90 percent of sampled values between 1.68 and 

2.10 (Fig. A3). 

2. Relevant accidents 

Overall probability is based 

on two likelihoods 

Likelihood of an accident to 

an intrastate truck 

Likelihood of an accident to 

a flat-bed truck 

The likelihood of an accident being relevant is the product of two 

likelihoods: 1) the probability of an accident during intrastate travel, 

and 2) the probability of an accident occurring to a flat bed truck. 

Before, the distribution for the likelihood of an accident to an intrastate 

truck was based on data from 2003 to 2004 only. We updated that data 

here to include 2002 to 2005 data (Federal Motor Carrier Safety 

Administration, 2007). The likelihood was estimated as the proportion 

of accidents to intrastate trucks, which had a mean of 0.148, with 99 

percent confidence limits of 0.124 to 0.172 (Fig. A4). Ninety percent 

of the sampled values were between 0.133 and 0.163. 

Before, the likelihood of an accident being for a flat bed truck was 

based only on 2004 data. Here we specified the distribution based on 

2002 to 2005 data (Federal Motor Carrier Safety Administration, 

2007). The mean proportion of accidents to flat bed trucks was 0.178, 

with 99 percent confidence limits of 0.152 to 0.204 (Fig. A5). In the 

model distribution 90 percent of the sampled values were between 

0.162 and 0.194. 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 255

Figure A3. The distribution for the truck accident rate, number per million miles traveled, based on data 

from 2000 to 2005. Lines are the 5th and 95th percentiles. 

0

0.5

1

1.5

2

2.5

3

1.5 1.6 1.7 1.8 1.9 2 2.1 2.2 2.3

Truck accident rate (no. per million miles)

 Probability density function

Figure A4. The distribution for the likelihood of an accident being for intrastate transport, based on data 

from 2002 to 2005. Lines are the 5th and 95th percentiles. 

0

10

20

30

40

0.12 0.13 0.14 0.15 0.16 0.17 0.18

 Proportion of intrastate truck accidents

Probability density function
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 25

Figure A5. The distribution for the likelihood of an accident being for a flat-bed truck, based on data 

from 2002 to 2005. Lines are the 5th and 95th percentiles. 

0

10

20

30

40

0.15 0.16 0.17 0.18 0.19 0.2 0.21

 Proportion of accidents to flat bed trucks

 Probability density function

C. Trains 

1. Total accidents 

Updated accident rate by 

including 2005 data 

Very little change from 

previous estimate 

For trains, we estimated the national accident rate from ten years of 

data, 1996 to 2005 (Office of Safety Analysis, 2006b). The overall 

mean was 3.92 accidents per million VMT, for all companies and all 

modes (e.g., yards and main lines). The distribution based on the 99 

percent confidence limits of the mean was a pert with minimum = 

3.645, and maximum = 4.186 (Fig. A6). Ninety percent of the sampled 

values were between 3.75 and 4.08. Compared to the previous 

estimate, the values and distribution changed only very slightly. 

2. Relevant accidents 

Updated main line freight 

accident numbers 

Number of freight train 

accidents 

We updated the numbers of accidents to freight trains on main lines. 

The overall probability of an accident being relevant was the product 

of the two probabilities for freight and main line accidents. 

Using data from 2000 to 2005, 9,893 out of 21,485 accidents were to 

freight trains (Office of Safety Analysis, 2001, 2003, 2004, 2005a, 

2005b, 2006a). We summarized this with 99 percent confidence 

intervals for the annual proportion, which gave a pert distribution with 

mean = 0.462, minimum = 0.412, and maximum = 0.512 (Fig. A7). 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 257

Number of main line 

accidents 

Little change from previous 

estimates 

Ninety percent of the sampled values were between 0.431 and 0.493. 

Out of the 9,893 freight accidents, 5,488 were main line accidents. 

This data gave a pert distribution with mean = 0.555, minimum = 

0.522, and maximum = 0.588 (Fig. A8). Ninety percent of the sampled 

values were between 0.534 and 0.576. 

Compared to the previous values (data only through 2004), the mean 

proportion of freight accidents declined only slightly, from 0.47 to 

0.462, and the mean proportion of main line freight accidents was 

basically unchanged: 0.55 then and 0.555 now. 

3. Bale-rupturing accidents 

Updated release rate 

No change from previous 

estimate 

We updated the estimate of the proportion of trains in accidents 

releasing hazardous materials with data from 2005 and 2006 (Office of 

Safety Analysis, 2006a, 2007). The new mean proportion of accidents 

releasing waste was 0.039. The pert minimum was 0.031 and the 

maximum was 0.048, with 90 percent of sampled values between 

0.034 and 0.045 (Fig. A9). These values were almost unchanged from 

the previous parameters. 

Figure A6. The distribution for the train accident rate, number per million miles traveled, based on data 

from 1996 to 2005. Lines are the 5th and 95th percentiles. 

0

0.5

1

1.5

2

2.5

3

3.5

3.6 3.7 3.8 3.9 4 4.1 4.2

Train accident rate (no. per million miles)

 Probability density function
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 258

Figure A7. The distribution for the likelihood of a train accident being for a freight train, based on data 

from 2000 to 2005. Lines are the 5th and 95th percentiles. 

0

4

8

12

16

20

0.41 0.43 0.45 0.47 0.49 0.51

 Proportion of freight train:all other train accidents

 Probability density function

Figure A8. The distribution for the likelihood of a train accident being for a main line freight train, 

based on data from 2000 to 2005. Lines are the 5th and 95th percentiles. 

0

5

10

15

20

25

30

0.52 0.53 0.54 0.55 0.56 0.57 0.58 0.59

 Proportion of main line:other freight accidents

 Probability density function
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 259

Figure A9. The distribution for the likelihood of a train accident releasing hazardous materials, based on 

data from 2005 and 2006. Lines are the 5th and 95th percentiles. 

0

0.2

0.4

0.6

0.8

1

1.2

30 32 34 36 38 40 42 44 46 48

Proportion of accidents releasing hazmat (thousandths)

Probability density function

II. Updated results from previous models 

A. Generic model 

Updated estimates not 

greatly different 

Barge transport was 

riskiest of the three 

conveyances 

Estimates of risk declined for train transport and increased for 

transport by barge or truck (Table 1). Still, the differences were not 

particularly great. For example, the annual probability of a balerupturing accident for barge transport more than doubled, but the mean 

years to first occurrence was still 308 years. Likewise, the mean 

number of years to the first bale-rupturing accident for truck transport 

decreased to 161 years. The same response variable for train transport 

increased by about 400 years, to 1818 years. The riskiest conveyance 

in the generic situation, therefore, was still by barge, which had a 95 

percent chance that the first bale-rupturing accident would not happen 

for at least 7 years. 

B. Washington state model 

Risk of truck transport 

increased four-fold 

Risk estimates increased by a factor of four for truck transport in the 

Washington state model, with the mean annual probability of a balerupturing accident changing to 0.0011 from 0.0003 (Table 2). Despite 

this, the annual probability was still very low: mean years to the first 
Appendix Version 1, August 2007 

PRA for Hawaiian Baled MSW to Idaho 260

Only a 5 percent chance of 

happening within 49 years 

Risk during barge transport 

also increased 

occurrence was 952 years. In this case, there was only a 5 percent 

chance of that happening within 49 years. 

The annual probability of a bale-rupturing accident during barge 

transport increased from 0.0037 to 0.0065 (+76 percent). Still, mean 

years to first occurrence was still 155, with a 5 percent chance of 

happening within 4 years. 

Table 1. Comparison of results from the previous generic accident model with results from the updated 

model. 

Response variable Truck Train Barge 

 Updated Previous Updated Previous Updated Previous

p(any bale-rupturing accident) 0.0062 0.0035 0.0006 0.0007 0.0033 0.0029

 

Years to 1st bale-rupturing accident 161 285 1818 1429 308 344

5th percentiles 9 15 94 74 16 18

Table 2. Comparison of results from the previous accident model for transport to Washington state with 

results from the updated model. 

Response variable Truck Barge 

 Updated Previous Updated Previous

p(any bale-rupturing accident) 0.0011 0.0003 0.0065 0.0037

 

Years to 1st bale-rupturing accident 952 3333 155 130

5th percentiles 49 171 8 7

Contact/Author 

Barney P. Caton 

Plant Epidemiology and Risk Analysis Laboratory 

Center for Plant Health Science and Technology (CPHST 

Plant Protection and Quarantine, Animal and Plant Health Inspection Service 

U. S. Department of Agriculture 

1730 Varsity Drive, Suite 300 

Raleigh, NC 27606 

barney.p.caton@aphis.usda.gov 

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PRA for Hawaiian Baled MSW to Idaho 262261

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