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APHIS Responses to Comments on Docket Number APHIS-2006-0172, Site 

Specific Environmental Assessment for Hawaiian Waste System’s Proposal to 

Transport Municipal Solid Waste from Hawaii to the Roosevelt Regional Landfill 

(December 2009) 

I. General Comments on the Site Specific Environmental Analysis 

A. Unreasonable delay in processing petition

Multiple commenters suggested that too much time and analysis has already occurred 

(comment numbers 17-1, 20-1, 24-1, 26-1, 29-1, 39-1, 47-1, 48-1, 50-1, 52-1, 30-1, 22-

1).

The National Environmental Policy Act, or NEPA, was signed into law in 1970 as a 

landmark in national policy which sought to encourage good stewardship of the human 

environment through accountability and transparency in decision-making. This law 

requires federal agencies to cooperate with federal, state, and local governments, and 

other concerned public and private organizations and citizens, in a concerted effort to 

foster and promote the health of social, economic, and environmental requirements of 

present and future generations of Americans. APHIS is therefore obligated to fully 

evaluate the full range of environmental consequences of this action and to seek input 

from the public on our assessment. The current EA reviews a modified proposal 

submitted by the petitioners in November 2009, for movement of a maximum of 

150,000 tons of containerized baled MSW from Hawaii via barge to three potential port 

locations in Oregon and Washington. APHIS has worked in close cooperation with the 

petitioner to revise the petition and to ensure this new site specific assessment 

considers relevant environmental impacts associated with the revised petition and is 

consistent with the Regional Environmental Assessment (USDA APHIS, 2008). (see 

response to comment III(a) in this document). 

B. Error in Map of Train Routes

Several commenters noted the transportation routes in the EA are not valid (comment 

numbers 42-12, 45-1, 18-7, 18-8).

APHIS utilized maps of transportation routes provided by the petitioners and is aware 

those maps do not reflect functional transportation routes. APHIS has obtained the 

correct maps from the rail lines. The correct routes do not alter the impacts considered 

in the EA. Corrected maps are included in the Final EA. 

II. Specific Comments on the Site Specific Environmental Analysis

A. Use of Containers Could Increase the Risk of Pest Introductions
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Some commenters were concerned that the shipping containers represented a perfect 

environment for hitchhiking pests (comment numbers 27-1, 27-3, 31-1, 31-3, 37-10, 37-

5, 37-8, 40-1, 40-2, 40-4).

Pursuant to the Compliance Agreement, the petitioner must certify all containers used 

for shipment of MSW are free of regulated pests. APHIS PPQ will sample and inspect 

containers and bales to ensure they are pest free. The likelihood of a quarantine and/or 

regulated pest being introduced to the continental U.S. as a result of the analyzed 

movement of baled MSW from Hawaii is mitigated by the increased sampling and 

inspection associated with this action. Not all pests are quarantine pests. A quarantine 

pest is a pest of potential economic importance to the area endangered thereby and not 

yet present there, or present but not widely distributed and being officially controlled

(IPPC 2009). The petitioner is responsible for providing a pest free environment 

associated with the staging of baled MSW in Honolulu and routinely inspecting and 

treating the area for pests if necessary. 

B. Integrity of Bales

Two commenters expressed concerns that APHIS failed to account for risks of pest 

introductions associated with cleaning containers (comment numbers 44-4, 27-2).

MSW will only be removed from the containers once they reach the Roosevelt Regional 

Landfill. Removal of bales will be done utilizing specialized equipment, e.g., padded 

forklifts, to prevent bale tears, punctures and/or ruptures. Only bales that meet the 

requirements for shipment will be transported in containers, e.g. airtight, tear, puncture 

and rupture free. However, if a bale is compromised during the off loading process it is 

unlikely that any regulated pests would survive and escape the compromised bales. In 

the event of a tear, puncture or rupture of a bale in a container at the landfill, cleaning 

will be done at the landfill utilizing the existing waste water treatment facilities. The 

potential for pest introductions associated with ruptured bales at the landfill is mitigated 

by the deploying required emergency spill response plans as described in the 

compliance agreements and the requirement to intern bales within 24 hours of off 

loading.

Several commenters expressed concerns that the 75-day threshold for internment had 

been violated (comment numbers 18-6, 42-10, 42-9).

The purpose of the 75-day threshold for internment was to prevent degradation of the 

wrapped bales due to excessive sunlight exposure. The containers, when used, remove 

the bales from exposure to sunlight, thus reducing the degradation process of the bales. 

A company which cannot move bales exposed to sunlight for greater than 75 days 

would be required to rewrap those bales.
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Several commenters expressed concerns that bales are punctured, torn and otherwise 

not in compliance (comment numbers18-4, 21-1, 31-2, 35-2, 42-5, 42-9, 44-5, 45-3 ).

Only intact wrapped bales will be allowed for shipment to the mainland. The bales 

depicted in the media are not compliant and are not available for shipment until they are 

made compliant with the terms of the compliance agreement. All torn bales are 

required to be re-wrapped prior to shipment. 

One commenter suggested that the material used for strapping the bales could 

compromise bale integrity (comment numbers 37-8). 

The banding is made to specification to help retain bale shape and resist accidental 

rupture (e.g., Baldasano et al., 2003). It is stiffer and less flexible (i.e., less stretchy) 

than the adhesive-backed plastic wrapping (e.g., PolyChem, 2010). It is not likely to fail 

or be affected by temperatures in the containers.

Several commenters expressed concerns that bales are attracting flies, rodents and 

birds (comment number 44-6). 

APHIS is aware of the issues regarding an increase in flies associated with the storage 

of baled MSW in Honolulu, HI, however, flies observed near the containerized MSW are 

not regulated pests and therefore not subject to APHIS regulation. Regulated and/or 

quarantined pests, such as the exotic fruit fly Bactrocera cucurbitae, are unlikely to be 

attracted to properly baled MSW due to a lack of access to fruit fly host material. In 

addition, the restriction of the waste stream allowed by this action, MSW may not 

contain more than 3 percent yard or agricultural waste, further mitigates the potential for 

fruit flies or other regulated and/or quarantined pests to be attracted to the waste 

handling facility. The petitioners are responsible for maintaining a pest free 

environment associated with the processing, staging and storage of baled MSW and 

shall routinely conducting pest inspections and treatment as necessary. Issues 

regarding the potential for other insects or mollusks to attach to the bales will be 

monitored closely by APHIS PPQ staff in Honolulu and the certification of bales ready 

for shipment through our sampling and inspection program. Other pests, birds and 

rodents, associated with the port in Honolulu are common in industrial areas and are not 

subject to APHIS regulation. 

Several commenters expressed concern that the baling technology will not kill pests

(comment numbers 18-3, 44-5, 35-2, 37-6). 

Once adequately wrapped anoxic conditions are created within the bales which will kill 

potential insect pests and perhaps some pathogens. Any bale that is punctured, torn or 

otherwise compromised will have to be re-wrapped prior to movement. Baled MSW in 

containers will be subjected to little buffeting and remain untouched until it reaches 
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Roosevelt Regional Landfill. Potential for ruptures during off loading is minimized by the 

use of specialized equipment, e.g., padded forklifts and grabbers. Seeds and other 

pathogens not killed by the anoxia will not have an opportunity to establish as baled 

MSW is required to be interned at the Landfill within 24 hours of arrival. 

Several commenters expressed concern that consequences of bale ruptures were not 

adequately addressed (comment numbers 18-4, 31-4, 37-2, 37-4, 42-1, 37-8).

The likelihood of bale ruptures is minimized by the use of specialized equipment for 

handling the bales and sampling and inspection by PPQ staff. The compliance 

agreement specifies the handling and clean-up of any ejected waste in the unlikely 

event of a tear or rupture. Upon arrival in the continental U.S., any bale which is 

punctured ruptured or torn may be patched or rewrapped, depending on the size of the 

puncture, rupture or tear. Off loading bales will only be done at Roosevelt Regional 

Landfill where containers will be opened and their contents moved to the working face 

of the landfill and interned within 24 hours of arrival. The potential for pest 

establishment, assuming any plant pests or disease survive within properly wrapped 

bales, is further mitigated by the requirement of internment within 24 hours of arrival. 

(see response to Comment II. A) One commenter indicated that bales could be further 

damaged when they are being loaded and unloaded during the shipping process. 

(comment number 37-3).

Movement of torn or punctured bales is not authorized. All bales that are broken, torn 

or punctured during handling must be re-wrapped prior to shipment to the mainland. 

Bales will not be handled once deposited in containers until they are off-loaded at the 

working face of the landfill where the petitioners are required to use specialized 

equipment, such as “grabber”-type lifts, to load and unload bales. Bales are easily and 

safely handled with this specialized equipment (e.g., CrossWrap, 2010). In the event a 

bale is torn or ruptured during the off-loading process the petitioners are required by the 

compliance agreement to have an emergency cleanup plan to minimize further threat of 

introduction of pests and pathogens. 

C. Compliance Issues

One commenter expressed doubt that APHIS would be able to detect bales that are 

punctured, torn or otherwise non-compliant (comment number 42-5).

The compliance agreement requires the company to inspect each bale prior to loading 

into the containers. APHIS PPQ officers work closely with the company and heavily 

monitor the start of the program. This includes the loading in Hawaii and the unloading 

on mainland. If there is a failure to comply with the Compliance Agreement, appropriate 
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measures will be taken to address the compliance issues. PPQ will also sample and 

inspect bales in containers.

Several commenters allege APHIS failed to assess impacts associated with noncompliance (comment numbers 42-11, 44-1).

Impacts associated with non-compliance are not contemplated because APHIS 

assumes the petitioner will meet the terms of the Compliance Agreement, lest their 

Compliance Agreement be cancelled. APHIS PPQ will work with the petitioners to 

ensure that compliance issues are addressed appropriately. 

One commenter suggested the stockpiles of MSW violate the Compliance Agreement 

(comment numbers 42-10).

The storage of baled MSW in Honolulu is not subject to APHIS’s regulatory authority. 

There are no regulated pest risks associated with this storage of bales. The shipment of 

baled MSW must comply with all mitigation measures to ensure pests will not be 

introduced as a result of the action.

One commenter expressed doubt that APHIS could ensure baled MSW would contain 

less than 3% agricultural wastes (comment numbers 42-4).

The estimate of up to 3 percent yard waste in the waste stream was a conservative one, 

based on a 1998 waste composition study and the company removing only half of the 

maximal likely amount of yard waste (CPHST, 2006a). By 2006, an updated waste 

composition study indicated the proportion of yard waste going into Waimanalo Gulch 

Landfill had dropped by almost half, to 3.4 percent (Beck, 2007). Furthermore, 

beginning in 2007, the City and County of Honolulu have implemented a Green Waste 

recycling program, in which yard waste is placed in separate bins and collected by 

dedicated trucks (DES, 2010). This will likely further reduce that percentage. Moreover, 

the company has implemented a training program dedicated to employee exclusion of 

green waste, and PPQ compliance officers report the amount of green waste in the 

waste stream at the baling facility meets the goal of “incidental amounts.” 

Commercial refuse going into the waste stream is much less likely than residential area 

refuse to harbor plant pests of concern to the mainland, because it contains much less 

green waste (Beck, 2007).

Even if one assumes that both the waste stream and, therefore, the bales on average 

have 3 percent yard waste, the extremely low likelihood of catastrophic bale rupture 
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means that in smaller accidents (tears and punctures), less than a five percent chance 

exists that exposed municipal solid waste would be green waste. The amount of 

escaping material will be further limited by bale density, binding materials, and the selfsealing ability of the Low Density Polyethylene LDPE (CPHST, 2006a).

Lastly, per the compliance agreement, bales may not contain greater than 3% green 

waste which will be monitored by PPQ staff. As such, APHIS is confident bales will not 

contain greater than 3% agricultural waste. 

D. Cumulative Impacts

Several commenters suggested the assessment of cumulative effects was inadequate 

and failed to account for the incremental impacts of the action on the localities affected 

(comment numbers 42-6, 45-2, 44-7).

The cumulative impacts analysis conducted for the EA considered the impacts of the 

incremental addition of the numbers of trucks, trains and barges associated with the 

action on a statewide basis. The addition of 20 trucks per day for 14 days of a month 

was considered insignificant when compared to the local traffic patterns in each of the 

respective port areas. APHIS evaluated traffic statistics for each of the port areas and 

determined the addition of truck traffic associated with this action will not result in 

cumulative impacts to air quality or existing traffic problems in Portland, OR. Similarly, 

the addition of 6 round trip unit trains were considered and 1 barge trip per month were 

also considered insignificant when compared to daily, weekly and monthly traffic for 

these means of conveyance. This portion of the draft EA was written in accordance 

with plans which were submitted by HWS at the time of the document's publication, but 

features a port location no longer under consideration by the company.

E. Air quality

Several commenters stated the EA failed to consider impacts associated with the action 

on air quality within the port municipalities and the Columbia River Gorge (comment 

numbers 42-7, 44-8). 

APHIS evaluated the contribution of additional air quality pollutants, hydrocarbons, 

carbon monoxide and nitrous oxide associated with each mode of transport considered 

in the proposed action and compared it to the baseline existing conditions, e.g., truck, 

rail and barge traffic, in the action area and determined that the proposed action will not 

result in significant contributions individually or in aggregate to air quality in the local 

municipalities and the Columbia River Gorge. 
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Others (ODEQ, 2008 and NWEDC, 2008) have inferred that the majority of air quality 

problems in the Columbia Gorge and the large metropolitan areas of the Pacific 

Northwest are primarily associated with pollution from industries to the East of the 

Gorge and by local daily commuter traffic. The addition of 20 additional trucks for a 

maximum of 14 days per month on local, state and interstate highways in Oregon and 

Washington are not likely to decrease air quality in any of the municipalities associated 

with the ports considered in this action or the Columbia River Gorge. Further, the 

addition of one rail unit (1 train containing 110 railcars) is also not likely to contribute 

significantly to a decrease in air quality in the region. Lastly, the addition of an 

estimated maximum of 13 barges annually entering the Columbia River and landing at 

the ports considered in this action also will not significantly affect air quality in the local 

municipalities or the Columbia River Gorge. Based on this assessment of the individual 

and aggregate contributions of pollutants associated with each means of conveyance, 

APHIS has determined there will be no significant contribution of air pollutants 

individually or cumulatively because these increases are de minimis compared to the 

existing traffic volumes for each means of conveyance considered. 

F. Risk Analysis

One commenter stated the pest risk analysis was fundamentally flawed because it failed 

to consider the potential impacts of consequences of introduction of non-native species 

and relied too heavily on weather and/or weather extremes (comment numbers 42-1, 

42-2, 18-5, 44-3).

We characterized the climatic conditions in the relevant areas using averages, but the 

responders are incorrect: extreme temperature conditions are the primary reason for the 

low risk in the region for establishment of of pests from Hawaii. Two excellent examples 

are exotic fruit flies in Hawaii, Bactrocera cucurbitae and B. dorsalis, which are perhaps 

the most serious potential pest threats from Hawaii. The likelihood of freezing 

temperatures annually—especially in Eastern Washington—mean that these fruit flies 

are highly unlikely to ever permanently establish in these areas. In a recent risk 

assessment on Bactrocera spp. (CPHST, 2007), and considering host availability and 

potential for multiple generations as well as weather, only the coastal areas of 

Washington state posed any risk for introduction, and the ratings given were either 1 or 

2 out of 10 possible. By comparison, the highest rated counties in the United States are 

some in Florida which received ratings of 9 out of 10. Other likely pests from Hawaii 

would be similarly restricted by extremes in cold temperatures, as well as low rainfall (in 

Eastern Washington).

Finally, the contention that the region would be exposed to a “high rate of exposure to 

non-native species,” is very likely incorrect. Tears and punctures while handling 
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individual bales are probably the types of accident most likely to occur. These types of 

accidents have limited, if any, ejected waste material due to the low speeds and limited 

force used while handling the bales. Catastrophic ruptures, due to accidents such as 

truck collisions or train derailments, are much less likely. Compared to the generic risk 

assessment the probability of a rail accident dropped by almost half in the current 

proposal because of the reduced distance being travelled, (CPHST, 2009). Now we 

estimate only a five percent chance of a rail accident occurring in the first 129 years of 

transport.

Several commenters expressed concerns the proposed risk mitigations were insufficient 

to kill pests (comment numbers 18-3, 44-1).

Bales that are punctured, torn or in any way not sealed are not in compliance with the 

regulations or the compliance agreement and are not suitable for shipment. Bales must 

be airtight to be shipped. APHIS will inspect bales for shipment and randomly select 

loaded containers to ensure that bales ready for shipment are compliant. The anoxic 

environment within the bales has been deemed sufficient to kill plant pests (CPHST, 

2006a). 

Further, the baling technology applied here has been proven in research tests (e.g., 

Baldasano et al., 2003; Paillat and Gaillard, 2001; see CPHST, 2006a), and it continues 

to be used successfully in numerous countries around the world (e.g., Cross Wrap, 

2010), including the United States (e.g., Transload America, 2010). USDA plans to 

monitor and verify compliance once transport starts, to verify the system works.

Several commenters said the pest risk assessment underestimates risks of introducing 

non-native species (comment numbers 18-4, 44-1, 31-5, 40-3). 

APHIS has evaluated the potential pests and pathways and determined that the 

proposed mitigation measures will prevent the introduction of species recognized by 

APHIS as plant pests (CPHST, 2006b). Inspections at the point of departure in 

Honolulu and the port of entry on the mainland U.S will further reduce the likelihood of 

pests introductions. Given the assessment of plant health risks associated with the 

transport of baled MSW in containers, APHIS believes that potential pest introduction 

risks are negligible. 

G. Storage of baled MSW not contemplated

Several commenters argue APHIS failed to consider impacts of the storage of baled 

garbage in Honolulu (comment numbers 21-3, 35-3).

The storage of baled MSW in Honolulu is not subject to APHIS’s regulatory authority. 

There are no regulated pest risks associated with this storage of bales. The shipment of 
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baled MSW must comply with all mitigation measures to ensure pests will not be 

introduced as a result of the action. 

Several commenters noted that odors and pests are prevalent on stored MSW. 

(comment numbers 18-1, 18-2, 18-3, 21-1, 21-2, 25-1, 25-2, 35-1, 44-5). 

Because of the nature of the operation, a municipal solid waste processing center is 

highly likely to have bird, rodent, and fly issues, despite the best efforts at daily clean 

up. Given that environment, the recent experience in Hawaii is not sufficient evidence to 

discount the industrial and peer-reviewed research which has consistently indicated that

intact bales are not attractive to potential vectors (e.g., Robles-Martinez and Gourdon, 

2000). 

H. Inadequate analysis of the No Action Alternative 

One commenter stated that the No Action Alternative is misleading (comment number 

42-8).

The statement in the No Action Alternative is correct. Under the No Action Alternative, 

baled MSW may be shipped directly to Roosevelt under the terms of the 2006 

Compliance Agreement already issued to petitioners. However, when APHIS evaluated

the impacts of shipment of MSW to Roosevelt in its previous Environmental 

Assessment (USDA APHIS, 2006) it assumed all necessary infrastructure was in place. 

It is the lack of the existence of this infrastructure that warrants this new evaluation. 

I. Financial integrity of HWS

Some commenters expressed concern that HWS may be financially incapable of 

meeting its obligations to the state of Washington and the citizens of Hawaii (comment 

numbers 37-1, 43).

The ability of HWS to meet its contractual obligations with the government of Honolulu 

and other private citizens is a contractual matter between those parties, but it is not 

relevant to this assessment, which was intended to evaluate the potential for 

environmental impacts associated with the proposed action and any alternatives.

III. Support for the Program

A. Requests for expeditious review/ expedition is the solution to environmental 

concerns
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Several commenters requested that APHIS’s review of the proposed action be 

completed quickly, as its final approval would allow solutions to several environmental 

concerns regarding baled MSW to move forward and take effect (comment numbers 

17, 20, 22, 24, 28, 29, 32, 36, 38-3, 39, 47, 48, 50, 52).

The National Environmental Policy Act, or NEPA, was signed into law in 1970 as a 

landmark in national policy which sought to encourage good stewardship of the human 

environment through accountability and transparency in decision-making. This law 

requires federal agencies to cooperate with federal, state, and local governments, and 

other concerned public and private organizations and citizens, in a concerted effort to 

foster and promote the health of social, economic, and environmental requirements of 

present and future generations of Americans. APHIS reviewed a previously proposed 

action (APHIS, 2006), by the petitioner, (Hawaiian Waste Systems, LLC) and provided 

a Compliance Agreement to allow for the movement of MSW. The petitioner, however,

has since modified its proposal to include different methods of shipping the MSW, and 

shipping to different locations on the mainland than previously analyzed. The preferred 

method of shipment covered by the current environmental assessment is unique in that 

it includes fully-enclosed shipping containers and is based on a revised petition from 

HWS submitted in November 2009. The current EA reviews the modified proposal for 

movement of a maximum of 150,000 tons of baled and containerized MSW from Hawaii 

via barge to three port locations in Oregon and Washington. Containerized baled MSW

from Hawaii will then be transported via truck or rail to Roosevelt Regional Landfill, 

APHIS is therefore obligated to evaluate the full range of environmental consequences 

of this action and to seek input from the public on our assessment. This obligation has 

resulted in the current EA (see response to comment I A in this document). 

B. The proposed action has already been reviewed and approved 

Several commenters expressed a concern that the current EA reviews information 

already analyzed in prior EAs, which addressed actions similar to the proposed action

(comment numbers 22, 29, 20, 30, 38-1). 

As stated above, APHIS has determined that modifications to the originally proposed 

shipping methods warranted the preparation of an additional environmental 

assessment.

C. Action will address over-burdened landfills. 

Several commenters cited that the proposed action will address issues related to 

Hawaii’s “over-burdened” landfills. (comment numbers 22, 28, 29, 36, 39).

In accordance with NEPA, APHIS is obligated to fully evaluate the full range of 

environmental consequences of the proposed action and to seek input from the public 

on our assessment. 
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D. Containers offer greater level of protection.

Several commenters stated that the use of shipping containers provided a greater level 

of protection against the establishment of regulated pests in Washington and Oregon. 

(comment numbers 38-1, 41-3).

APHIS’ own pest risk assessment of the proposed action (CPHST, 2009b) confirms this

conclusion.

E. Oversight is adequate 

One commenter noted that proposed safeguards adequately protect Oregon and 

Washington State against pest establishment. (comment numbers 41-2, 38-4).

Comment noted.

F. Project will create jobs, both in Hawaii and Washington.

Several commenters stated that the proposed action (and subsequent approval) 

would create jobs, in both Hawaii and the mainland (comment numbers 20, 22, 23, 

26, 30, 36).

APHIS agrees that there will be an economic benefit to companies involved in the 

processing, baling, transportation and land filling of baled MSW from Hawaii. We 

further acknowledge that shipment of baled MSW from Hawaii to the mainland will 

relieve the pressure on Honolulu to find an alternative to burial in the existing landfill 

until a new waste to fuel incinerator can be constructed.

G. Landfill great neighbor/provides invaluable environmental service

Comments were received from individuals expressing a personal endorsement of dayto-day operations at Roosevelt Regional Landfill, having observed the company as a 

responsible environmental steward (comment numbers 32, 41-1).

Comment noted.

H. Company is trustworthy

Comments were received from individuals expressing a personal endorsement of dayto-day operations of Hawaii Waste Systems in Honolulu, having observed the company 

as a responsible environmental steward (comment numbers 23, 26, 28).
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Comment noted.

I. Miscellaneous Comments

1. Too many existing regulations of garbage in Washington State

One commenter addressed a concern over the number of current restrictions regarding 

MSW, which regulates residential trash collection and what may or may not be 

collected. The commenter expressed a fear that the proposed action would result in an 

increase in these restrictions (comment number 16).

APHIS is unaware of anything in this proposed action that would lead to restrictions on 

what citizens residing in other localities (including the State of Washington) could 

include in their MSW. A key feature of our analysis of this proposed action was 

ensuring that adequate space existed at the disposal site to contain the volume of baled 

MSW from Hawaiithat will be shipped. To this end, APHIS has considered the lifespan 

and capacity of Roosevelt Regional Landfill, and has incorporated an approximate total 

of 150,000 tons of MSW imported from Hawaii in its analyses. Therefore, the proposed 

importation will result in a 6 percent increase in the annual tonnage of MSW sent to the 

landfill. APHIS believes that this amount represents a minimal increase to the annual 

intake for Roosevelt that will not significantly reduce the operating lifespan of the 

Roosevelt Regional Landfill or limit the types of items that could be put into that landfill.

2. Hawaii should recycle its waste

One commenter suggested a state-wide recycling program as an alternative to the 

proposed action (comment numbers 46). 

Although recycling represents one solution to Hawaii’s increasing waste disposal issue, 

the current EA does not evaluate all possible long-term solutions. The proposed action 

has been presented as a short-term solution to be performed on an interim basis, until 

adequate waste-to-energy facilities becomes available. The analysis of the proposed 

movement of waste from Hawaii to Washington State is a response to the quarantine 

which regulates shipments of goods between Hawaii and the mainland United States. 

APHIS-PPQ is obligated to consider requests for movement of articles with agricultural 

risk and to assess that risk. If this risk can be mitigated, APHIS is obligated to facilitate 

trade under appropriate safeguarding conditions. 
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3. Trial load should be shipped

One commenter suggested that a “trial load” should take place in order to test the 

efficacy of safeguards associated with the proposed action (comment number 37-7).

As with any new program that operates under a compliance agreement, APHIS will 

closely monitor activities throughout the launch period of the program to help ensure 

adherence to elements of the compliance agreement associated with the proposed 

action. 

4. Too much government oversight

One commenter expressed concern over the amount of oversight the USDA seeks over 

the proposed action (comment number 30). 

APHIS is carrying out its legally mandated oversight role on this action. The purpose of 

our oversight role in this case is to ensure that the movement of MSW from Hawaii to 

the mainland does not create an increased risk of agricultural pest introduction or 

establishment on the mainland. We are also required to evaluate the potential for 

environmental impacts associated with all of our actions.

5. Media reports mischaracterized HWS operations

One commenter noted that photos and media reports that cited the proposed action 

mischaracterized non-compliant bales as compliant bales, identifying them as ready for 

transport via shipping containers (comment number 38-2). 

The Commenter is correct. Ripped or otherwise damaged bales are non-compliant and 

will have to be re-wrapped before shipment to the mainland.

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Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Center for 

Plant Health Science and Technology (CPHST). Raleigh, NC. 45 pp.
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http://www.crosswrap.com/www/index.php?page=waste (Archived at PERAL)

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DES. 2010. Curbside Recycling Islandwide Expansion. Honolulu City Government, Department 

of Environmental Services (DES), Honolulu, HI. 

http://www.opala.org/solid_waste/curbside.htm#your_refuse (Archived at PERAL)

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and Agriculture Organization of the United Nations, Secretariat of the International Plant 

Protection Convention (IPPC), Rome, Italy. 434 pp.

https://www.ippc.int/index.php?id=13399&L=0

Northwest Environmental Defense Center, 2008. 

http://legacy.lclark.edu/org/nedc/objects/GorgeFactSheet.pdf Last accessed April 16, 

2010.

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http://www.deq.state.or.us/aq/factsheets/08aq002_gorge.pdf Last accessed on April 16, 

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