1

AP HIS Responses to Comments on Docket Number A PHIS -2006 - 0172, Site Specific Environmental A ssessment 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 an d 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 require s 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 pre sent 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 W ashington. 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 tho se 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 C ontainers Could I ncrease the R isk of P est I ntroductions2

Some commenter

s 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 pest s . APHIS PPQ will sample and inspect containers and bales to ensure they are p est 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 re sponsible for providing a pest free environment associated with the staging of baled MS W in Honolulu and routinely inspect ing and treat ing 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 equipmen t , 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, i f 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 in tern 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 )

. T he purpose of the 75 - day threshold for intern m e nt was to prevent degradation o f the wrapped bales due to excessive sunlight expos ure . 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 da ys would be required to rewrap those bales.3

Several commenters expressed concerns that bales are punctured, torn and otherwise not in compliance (

comment numbers 18 - 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 b ales 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. On e 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) . I t i s 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 MS W 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 f ruit fly Bactrocera cucurbitae , are unlikely to be attracted to properly baled MS W 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 conduct ing pest inspections and treatment as necessary. Issues regarding the potential for other inse cts 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 Hono lulu 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 cre ated 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 MS W in containers will be subjected to little buffetin g and remain untouched until it reaches4

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, 3 7- 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 Roose velt 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 damage d when they are being loaded and unloaded during the shipping proces s. (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 H awaii and the unloading on mainland. If there is a failure to comply with the Compliance Agreement, appropriate5

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 non compliance (comment numbers 42 - 11, 44 - 1). Impacts associated wi th 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 addres sed 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 associate d 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% a gricultural 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 Wa imanalo Gulch Landfill had dropped by almost half, to 3.4 percent (Beck, 2007). Furthermore, beginning in 2007, the City and County of Honolulu have i mplemented a Green W aste 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 re sidential 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 lo w likelihood of catastrophic bale rupture6

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, p er the compliance agreement, bales may not contain g reater 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 ac tion 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 additi on 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 con sidered 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 H WS 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 4 2 - 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 condi tions, 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.7

O th ers (ODEQ , 2008 and N WE DC , 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 Wa shington 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 a n e stimated 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 i ndividual 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 t he 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

). Wecharacterized 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 Haw aii. The likelihood of freezing temperatures annually

— especially in Eastern W ashington

— 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 consideri ng host availability and potential for multiple generations as well as weather, only the coastal areas of Wa shington state posed any risk for introduction, and the ratings given were either 1 or 2 out of 10 possible. By comparison, the highest rated counti es 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 W ashington). 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 handling8

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, 2006 a ). 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 numerou s countries around the world (e.g., Cross W rap, 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 assessm ent 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 recogn ized 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 wit h the transport of baled MSW in containers, APHIS believes that potential pest introduction risks are negligible. G. Storage of baled MS W 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 of9

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 p eer- 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 Alternat ive is misleading (comment number 42 - 8). The statement in the No Action Alternative is correct. Under the No Action Alternative, baled MSW may b e shipped directly to Roosevelt under the terms of the 2006 Compliance Agreement already issued to petitioners. However, when APHIS evaluate d the impacts of shipment of MSW to Roosevelt in its previous Environmental Assessment ( USDA APHIS , 2006) it assum ed 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 HW S Some commente rs 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 H W S 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 impact s associated with the proposed action and any alternatives.

III. Support for the Program A. Requests for expeditious review/ expedition is the solution to environmental concerns10

Several commenter

s 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 Americ ans. APHIS reviewed a previously proposed action (APHIS, 2006), by the petitioner , ( Hawaiian Wa st e Systems, LLC ) and provided a Compliance Agreement to allow for the movement of MS W. The p etitioner, however, has since modified it s proposal to include diffe rent methods of shipping the MS W , 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 HW S 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 W ash ington. 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 o n 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 commenter

s expressed a concern that the current EA reviews informatio n 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 preparatio n of an additional environmental assessment. C. Action will address over- burdened landfills

. Several commenter

s cited that the proposed action will address issues related to Hawaii’ s “over -burdened” landfills. (comment numbers 22, 28, 29, 36, 39). In acco rdance 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.11

D. Containers offer greater level of protection

. Several commenter

s 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 ( CP H ST , 2009b) confirms this conclusion. E. Oversi gh t is adequate One commenter noted that proposed safeguards adequately protect Oregon and Washington State against pest establishmen t

. (comment number s 41 - 2, 38 - 4

). Comment noted. F. Project will create jobs, both in Hawaii and Wash ington. Several commenter

s 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, transport ation and land filling of baled MSW from Hawaii. W e 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 landfil l 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 Landfil l, having observed the company as a responsible environmental steward (comment numbers 32, 41 - 1). Comment noted. H. Company is t rustworthy 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).12

Comment noted. I. Miscellaneous Comments 1. T oo many existing regulations of garbage in W ashington State One commenter addressed a concern o ver 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 numb er 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 W ashington) could include in their MSW . A key feature of our analysis of this proposed actio n was ensuring that adequate space existed at the disposal site to contain the volume of baled MSW from Hawaii that will be shipped. To this end, APHIS has considered the lifespan and capacity of Roosevelt Regional Landfill, and has incorporated an approxim ate 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 increas e 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 evalua te 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 W ashington 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 oblig ated to facilitate trade under appropriate safeguarding conditions.13

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 numbe r 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 a ction. 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 ou r 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. W e are also required to evaluate the potential for enviro nmental impacts associated with all of our actions. 5. Media reports mischaracterized H WS operations One commenter noted that photos and media reports that cited the proposed action mischaracterized non - compliant bales as compliant bales, identifying them a s 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. Literature Cited Baldasano, J.M., S. Gass o, and C. Perez. 2003. Environmental performance review and cost analysis of MS W landfilling by baling - wrapping technology versus conventional system. Wa ste Management 23:795

– 806 Boedeker. 2010. Polyethylene Specifications. http://www.boedeker.com/polye_p. htm (Archived at PERAL) CPHST. 2006a. The Risk of Introduction of Pests to the Continental United States via Plastic Baled Municipal Solid Waste from Hawaii. United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protect ion and Quarantine, Center for Plant Health Science and Technology (CPHST). Raleigh, NC. 45 pp.14

CPHST. 2006b. The Risk of Introduction of Pests to W ashington State via Plastic - Baled Municipal Solid W aste from Hawaii. United States Department of Agriculture , Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Center for Plant Health Science and Technology (CPHST). Raleigh, NC. 8 pp. CPHST. 2007. Identification of Areas Susceptible to the Establishment of Fifty- three Bactrocera spp. (Diptera: Tephrididae: Dacinae) in the United States. United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Center for Plant Health Science and Technology (CPHST). Raleigh, NC. 42 pp. CPHST. 2 009. The Risk of Introduction of Pests to W ashington State via Plastic - Baled Municipal Solid W aste in Shipping Containers from Hawaii. Proposal: Hawaiian W aste Systems. United States Department of Agriculture, Animal and Plant Health Inspection Service, Pl ant Protection and Quarantine, Center for Plant Health Science and Technology (CPHST). Raleigh, NC. 6 pp. CrossW rap, 2010. Benefits of Cross Wrap wrapped bales. Cross W rap Oy Ltd., Finland. htt p://www.crosswrap.com/www/index.php?page=waste (Archived at PERAL) Crosswrap. 2010. References. Cross W rap Oy Ltd., Finland. http://www.crosswrap.com/www/index.php?page=waste_references (Archived at PERAL) DES. 2010. Curbside Recycling Islandwide Expansio n. Honolulu City Government, Department of Environmental Services (DES), Honolulu, HI. http://www.opala.org/solid_waste/curbside.htm#your_refuse (Archived at PERAL) IPPC. 2009. In ternational Standards For Phytosanitary Measures, 1 to 29 (2009 edition). Food 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. Oregon Department of Environmental Quality, 2008. http://www.deq.state.or.us/aq/factsheets/08aq002_gorge.pdf Last accessed on April 16, 2010 Paillat, J. - M. , and F. Gaillard. 2001. Air- tightness of Wrapped Bales and Resistance of Polythene Stretch Film under Tropical and Temperate Conditions. J ournal of Agric ultural Engineering Res earch 79 (1):15 - 22 PolyChem. 2010. Products: Plastic Strapping: Machine Grade Pol yester. Polychem Corporation, Mentor, OH. http://www.polychem.com/StrappingSubcat.asp?Catid=1&Subcatid=6

. (Archived at PERAL) Port of Tacoma. 2009. Port of Tacoma Container Volume s 2006 - 2009. Port of Tacoma, Tacoma, W A. http://www.portoftacoma.com/File.ashx?cid=4048 Robles - Martinez, F., and R. Gourdon. 2000. Long - term behaviour of baled household waste. Bioresource Technology 72:125 - 130. R.W . Beck. 2007. 2006 W aste Characterization Study: City and County of Honolulu. R.W . Beck Inc., Seattle, W A. 58 pp.15

Transload America. 2010. Our Services and Capabilities. TransLoad America Inc., NJ, USA. http://www.transloadamerica.com/su b.php?p_id=3 (Archived at PERAL) United States Department of Agriculture, Animal and Plant Health Ins pection Service, 2006. Mo vement of Plastic Baled W aste from Honolulu, Hawaii to Roosevelt Regional Landfill, Wa shington, Environmental Asse ssment, Decembe r 2006. 79 pp

.