Oʻahu, Hawaiʻi — Feedstock Assessment

Oʻahu’s ~880 TPD of available manufacturing feedstock flows to a facility with a binding March 2, 2028 closure order and no contracted alternative destination — creating a procurement-critical condition with a 23-month action window.

§0 — What This Means

• Hard deadline, no backstop. The Waimānalo Gulch Sanitary Landfill (WGSL) — Oʻahu’s only MSW landfill — is legally required to cease all operations by March 2, 2028 under the Hawaiʻi Land Use Commission Decision & Order (November 1, 2019; SUP SP09-4031). The City identified Makaiwa Hills (adjacent to WGSL) as the only viable replacement in December 2024, but that expansion requires contested Act 73 amendments, a full environmental impact statement, and construction — a process requiring a minimum of 4–6 years from authorization. The off-island shipping pathway costs ~$99/ton and is volume-limited and market-sensitive. Oʻahu has no confirmed contractual backstop for the 255,000 TPY of MSW and ash currently flowing to WGSL.
• H-POWER is not the solution. The Reworld™ Honolulu facility (H-POWER) processes ~544,000 TPY of MSW at Campbell Industrial Park and is at contractual and physical capacity. H-POWER ash — approximately 165,000 TPY — requires landfill disposal at WGSL. When WGSL closes, ash disposition is an independent unresolved problem alongside MSW disposition.
• ~880 TPD of ACM-addressable manufacturing feedstock is immediately available. The system generates approximately 1.2 million TPY of MSW. Approximately 321,000 TPY (880 TPD) is uncontracted and WGSL-bound — carrying no exclusive third-party processing agreement. An additional 17,000 TPY of contaminated recyclables flows to WGSL with no separate contract. Together these constitute the Phase Initial opportunity at zero contract barrier.
• ACM engagement must be authorized by mid-2026. Phase Initial COD of Q1 2028 requires T0 (ACM engagement authorization) no later than mid-2026. Every quarter of delay compresses commissioning time and increases the probability that Oʻahu faces an uncovered feedstock disposition gap at the March 2028 regulatory closure date.
• Multi-phase ACM deployment is supported by the full feedstock system. Phase Initial at 200 TPD is fully supportable from IMMEDIATE streams. Phase Medium at 400 TPD and Phase Expanded at 800 TPD draw CONDITIONAL streams — H-POWER ash, C&D fluff, biosolids — eliminating dependence on any landfill by Phase Expanded.

§1 — Feedstock Profile

§1.2 — Feedstock Volume Table

§1.3 — Primary ACM Feedstocks

Two streams carry IMMEDIATE classification — no third-party contract barrier and available for Phase Initial CSA delivery:

• WGSL-bound MSW residual (~880 TPD): The uncontracted remainder after H-POWER and recycling diversion flows to WGSL under no exclusive third-party processing agreement. The City & County’s WGSL tipping contract with Waste Management of Hawaii covers disposal operations — not exclusive processing rights over the feedstock itself. ACM can receive this volume at a new on-island facility without contract novation.
• Contaminated recyclables (~47 TPD): Approximately 17,158 TPY of recyclable material is misplaced in gray bins and sent to H-POWER or WGSL. These carry no separate contract; they are currently a cost center. ACM processes all material types without pre-sorting — no contamination concept applies.

Phase Initial at 200 TPD draws entirely from these IMMEDIATE streams. No third-party contract renegotiation is required for Phase Initial deployment.

§2 — Logistics and Infrastructure

Oʻahu’s solid waste collection system serves over 200,000 residential accounts through seven collection yards, three major transfer stations (Keehi, Kapaa, Kawailoa), seven residential convenience centers (including Waipahu), and enclosed delivery vehicle fleets operating island-wide. The island’s geography concentrates feedstock flows toward the west — both H-POWER and WGSL are at Campbell Industrial Park / Kapolei. All three transfer stations aggregate volume and route to these western facilities via H-1, H-2, and H-3 corridors.

Driving distances to Campbell Industrial Park zone from key transfer nodes: Keehi (central Honolulu) ~16 miles via H-1; Kapaa (Windward) ~25 miles via H-3 or Pali Hwy; Kawailoa (North Shore) ~22 miles via H-2. Waipahu Convenience Center is ~4 miles from the Campbell Industrial Park zone. This convergence makes the Campbell Industrial Park zone the natural ACM facility location for Phase Initial — minimal route modification required.

The enclosed delivery vehicle fleet currently servicing H-POWER is fully compatible with ACM intake requirements. Sealed, compacted feedstock loads meet ACM intake specifications without modification. No new collection infrastructure is required for Phase Initial.

§3 — Cost Structure

§3.1 — Current System Cost Table

§3.2 — Operator Names (Verified)

Reworld™ Honolulu (formerly Covanta Honolulu Resource Recovery Venture) — operator of the H-POWER Waste-to-Energy facility at 91-174 Hanua St, Kapolei, HI 96707. Reworld™ is the current operating name following the 2023 Covanta rebranding. Operates under a long-term power purchase agreement with Hawaiian Electric (HECO). reworld.com · +1 800-950-8749.

Waste Management of Hawaii — operator of WGSL under contract with the City & County. 92-460 Farrington Hwy, Kapolei, HI 96707. LUC Special Use Permit SP09-4031. wm.com · +1 808-668-2985.

PVT Land Company Ltd — operator of Oʻahu’s only C&D landfill at 87-2020 Farrington Hwy, Waianae, HI 96792. Accepts C&D debris only. +1 808-668-4561.

Hawaiian Earth Recycling — City organics/green waste composting programme under contract to 2045. Produces Menehune Magic compost. Not a solid waste landfill operator.

City & County of Honolulu, Department of Environmental Services (ENV) — system operator for transfer stations, convenience centers, and wastewater treatment plants. honolulu.gov/env.

§3.3 — Cost Trajectory

Mechanism 1 — Rate escalation. The H-POWER tipping fee is subject to contractual escalation linked to CPI and fuel cost adjustments. Historical escalation has averaged 2–3% per year. At 2.5% annual escalation, the $91/ton gate rate reaches approximately $126/ton by 2035 and $161/ton by 2045. The WGSL tipping rate is adjusted periodically by City Council under ROH Chapter 9 — recent adjustments have tracked inflation.

Mechanism 2 — Capital reinvestment pressure and new landfill cost. The Makaiwa Hills landfill expansion requires Act 73 amendment or waiver, EIS preparation, land acquisition (potentially through condemnation), and construction. Island landfill capital benchmarks are $150–$300M. This unquantified obligation will be financed through tip fees, creating upward rate pressure regardless of the Makaiwa Hills timeline. The City’s post-closure care liability for WGSL (GASB 18) is an additional unquantified future obligation that will require rate support.

Mechanism 3 — Absence of competitive alternatives. Oʻahu’s island geography eliminates the mainland competitive dynamics that discipline disposal rates. Off-island shipping ($99/ton, COVID period) is the only backstop alternative — not available at scale. Military lands (Waipio Peninsula, Iroquois Point, Bellows) have been excluded. Makaiwa Hills depends on contested legislation and a multi-year permitting process. This structural disposal monopoly will intensify cost pressure through 2028 and beyond.

§4 — Regulatory Baseline

Permit status — H-POWER: Reworld™ Honolulu operates under a long-term energy conversion and power purchase agreement at nameplate capacity. No capacity expansion is under review. The ash-to-aggregate pilot (City/Reworld™ contract) is a volumetric reduction pilot, not a capacity expansion. H-POWER cannot absorb displaced WGSL-bound feedstock.

Environmental compliance — WGSL: The facility has an EPA Clean Water Act enforcement history (settlement April 2019; $425K penalty). PFAS has been detected in landfill leachate at Hawaiʻi landfill sites consistent with national regulatory trends. Post-closure PFAS liability at WGSL is an unquantified exposure for the City, growing with each year of continued operation. ACM’s 1,200°C+ elemental dissociation process permanently destroys PFAS — eliminating this liability on diversion.

Act 73 (2020): State law restricting new landfill siting within half-mile buffers of residences, schools, and hospitals, and prohibiting conservation district siting. Makaiwa Hills requires Act 73 amendment or waiver — contested in 2024 and 2025 legislative sessions without resolution.

Policy alignment: Hawaiʻi State targets 70% solid waste diversion from landfill by 2030. ACM deployment at 200 TPD directly contributes to this target. The NAICS manufacturing classification (Sector 31–33) aligns with Hawaiʻi’s economic diversification goals and qualifies for state manufacturing tax abatement under HRS §237.

§5 — Feedstock Opportunity

§5.1 — System-Wide Addressable Volume Summary

§5.2 — Addressability Table

§5.3 — Phase Configuration Preview

§6 — Feedstock Infrastructure Map

Active, closing, and historical feedstock infrastructure on Oʻahu. All facility data sourced from Google Places, City & County ENV public records, Hawaiʻi DOH Office of Solid Waste Management, and EPA enforcement records.

Appendix A — Evidence Chain

Appendix B — Change Factors

Appendix C — Sources and References

• City & County of Honolulu, Dept. of Environmental Services — Rates and Data, Landfill Status, New Landfill Siting. honolulu.gov/env. Accessed May 2026.
• Hawaiʻi Land Use Commission — Decision and Order, Docket SP09-4031, November 1, 2019 (WGSL closure order).
• LUC 2024 Extension Decision — August 23, 2024.
• ENV Landfill Siting Status Report — April 2026. honolulu.gov/env.
• EPA — Clean Water Act enforcement press release, Waimānalo Gulch Landfill, April 29, 2019.
• Honolulu Civil Beat — “City Spared From Paying A Hefty Price For Lack Of Trash.” May 18, 2020.
• KHON2 — “How to Keep Waste from Our Landfills.” December 2025.
• Honolulu Star-Advertiser — Landfill siting coverage, 2023–2024.
• Hawaii Business Magazine — “The Economics of Recycling in Hawaii.”
• Google Places API — Facility locations and operator information. May 2026.
• Hawaiʻi DOH Office of Solid Waste Management — Annual Legislative Report, March 2024.

Appendix D — Authoritative Glossary