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Public Comment · Arbor Hills

Write Elevated-Temperature Protections Into the Siting Criteria

by Trisha Kunst · data scientist and resident living less than one mile from Arbor Hills · delivered September 9, 2026

This is the comment I delivered in person to the Washtenaw County Materials Management Planning Committee, the body writing the minimum siting criteria for the county's Materials Management Plan, at its meeting on September 9, 2026.

The protections I asked for
Proposed minimum siting protections →
The three elevated-temperature protections this comment asks the county to write into the Materials Management Plan's minimum siting criteria, in full.

To: Washtenaw County Materials Management Planning Committee

From: Trisha Kunst, data scientist and resident less than 1 mile from Arbor Hills

Re: Writing elevated-temperature protections into the minimum siting criteria for any new or expanded landfill

Delivered: September 9, 2026, Materials Management Planning Committee meeting (spoken, under two minutes)

Hi again. I'm Trisha Kunst. I am a data scientist who lives less than a mile from Arbor Hills. My request is simple: please write elevated-temperature protections into the minimum landfill siting criteria for the county's Materials Management Plan.

Arbor Hills gas wells have repeatedly crossed the federal temperature threshold requiring corrective action. Instead of lowering temperatures, the operator obtained approval, a "higher operating value," to run fourteen gas wells and two leachate sumps above the federal temperature line, one of them as hot as 180 degrees. The hottest wellhead reading, 177 degrees, was therefore not counted as an exceedance. All evidence is posted at arborhillsmonitor.org.

Why care that buried garbage is unusually hot? Heat is not the public-health outcome; it warns that conditions inside the landfill are changing.

EPA says these may not be conventional fires. Abnormal subsurface reactions can alter landfill gas, produce leachate and odors, and impair containment systems. Heat can signal reactions that produce more toxic chemicals.

The expert I referred you to, Todd, confirmed that no one had contacted him as of about ten minutes before this meeting started.

Please require continuous wellhead monitoring and public data; elevated-temperature and smolder-prevention plans; and corrective action beginning at NESHAP's ("NESS-hap") 145-degree operating line, escalating to public-health notification and emergency-response measures at higher temperatures.

Trisha Kunst
Data scientist, resident less than 1 mile from Arbor Hills
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 page reproduces the remarks as delivered from the podium. The wording about the higher-operating-value waivers was made more precise than the spoken comment for accuracy: sixteen waivers in all, covering fourteen gas wells and two leachate sumps, with ceilings from 150 to 180 degrees and one well approved as hot as 180.

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 three proposed protections in full, the evidence brief behind these requests, the September 2 comment to the Board of Commissioners, or write the county commissioners yourself.