Bring in an Expert Before Minimum Criteria Are Finalized
by Trisha Kunst · resident living less than one mile from the proposed expansion border · delivered September 2, 2026
This is the comment I delivered in person to the Washtenaw County Board of Commissioners, the body that gives final approval to the county's Materials Management Plan, at its regular meeting on September 2, 2026.
To: Washtenaw County Board of Commissioners (the County Approval Agency for the Materials Management Plan)
From: Trisha Kunst, resident less than 1 mile from the proposed expansion border
Re: The documented elevated-temperature record at Arbor Hills, and retaining an independent expert to help set the minimum siting criteria
Delivered: September 2, 2026, regular Board of Commissioners meeting (spoken, three minutes)
My name is Trisha Kunst. I live less than a mile from the expansion boundary at Arbor Hills Landfill. I want what every family wants: a home I don't have to worry about.
On August 19, I gave your Materials Management Planning Committee contact information, with his permission, for Todd Thalhamer, a nationally recognized expert in landfill smoldering events. He reviewed Arbor Hills' elevated-temperature history compiled from EGLE filings and agreed to be contacted.
The MMPC Committee discussed hiring experts after an expansion application is filed. But the siting criteria are being written now. As of this afternoon, Todd confirmed that no one from the county had contacted him.
In April 2019, an EGLE inspector titled his Arbor Hills visit an "Elevated Temperature Landfill Event" inspection. I am not claiming a confirmed fire. The history deserves expert interpretation.
In March 2025, one wellhead reached 177 degrees. At that reading, methane was approximately 8 percent and oxygen approximately 7 percent. Carbon monoxide reached 150 parts per million during that reporting period. EPA identifies elevated temperature, depressed methane, and increased carbon monoxide among the common indicators of an elevated-temperature landfill.
That well has an EGLE-approved Higher Operating Value allowing up to 180 degrees through May 1, 2028. Because 177 degrees was within that approved value, it was not recorded as a temperature exceedance. Mr. Thalhamer recommends no Higher Operating Value above 160 degrees without a corrective-action plan.
The most recent report, covering January through June 2026, recorded 26 wellfield locations that reached at least 131 degrees, including three that reached at least 145. The hottest readings declined, but elevated temperatures remained. That is improvement, not resolution. The source records and visualizations are at ArborHillsMonitor.org.
I am not asking the county merely to make a phone call. Before this plan is finalized, retain a qualified, independent elevated-temperature expert. Obtain that expert's written recommendations for minimum siting criteria for any new or expanded landfill, and put those protections into the plan before approving it.
You need not decide what the criteria should be. Get us an expert to help establish them before allowing expansion. Thank you.
Trisha Kunst Resident less than 1 mile from the proposed expansion border arbor-hills@trishakunst.com
Every figure in this comment traces to a primary regulatory record. The underlying wellfield data, EGLE filings, and the interactive visualizations behind these numbers are published at Arbor Hills Monitor.
This is advocacy, prepared by a resident. It reproduces a comment delivered in the Washtenaw County public record. Every figure traces to a primary regulatory record or a named source. Read the evidence brief behind these requests, the fuller written comment submitted to the county on August 19, or write the county commissioners yourself.
My name is Trisha Kunst. I live less than a mile from the expansion boundary at Arbor Hills Landfill. I want what every family wants: a home I don't have to worry about.
On August 19, I gave your Materials Management Planning Committee contact information, with his permission, for Todd Thalhamer, a nationally recognized expert in landfill smoldering events. He reviewed Arbor Hills' elevated-temperature history compiled from EGLE filings and agreed to be contacted.
The MMPC Committee discussed hiring experts after an expansion application is filed. But the siting criteria are being written now. As of this afternoon, Todd confirmed that no one from the county had contacted him.
In April 2019, an EGLE inspector titled his Arbor Hills visit an "Elevated Temperature Landfill Event" inspection. I am not claiming a confirmed fire. The history deserves expert interpretation.
In March 2025, one wellhead reached 177 degrees. At that reading, methane was approximately 8 percent and oxygen approximately 7 percent. Carbon monoxide reached 150 parts per million during that reporting period. EPA identifies elevated temperature, depressed methane, and increased carbon monoxide among the common indicators of an elevated-temperature landfill.
That well has an EGLE-approved Higher Operating Value allowing up to 180 degrees through May 1, 2028. Because 177 degrees was within that approved value, it was not recorded as a temperature exceedance. Mr. Thalhamer recommends no Higher Operating Value above 160 degrees without a corrective-action plan.
The most recent report, covering January through June 2026, recorded 26 wellfield locations that reached at least 131 degrees, including three that reached at least 145. The hottest readings declined, but elevated temperatures remained. That is improvement, not resolution. The source records and visualizations are at ArborHillsMonitor.org.
I am not asking the county merely to make a phone call. Before this plan is finalized, retain a qualified, independent elevated-temperature expert. Obtain that expert's written recommendations for minimum siting criteria for any new or expanded landfill, and put those protections into the plan before approving it.
You need not decide what the criteria should be. Get us an expert to help establish them before allowing expansion. Thank you.
Trisha Kunst
Resident less than 1 mile from the proposed expansion border
arbor-hills@trishakunst.com
Every figure in this comment traces to a primary regulatory record. The underlying wellfield data, EGLE filings, and the interactive visualizations behind these numbers are published at Arbor Hills Monitor.