VBC Comments on Permits

Recently the Virginia Biosolids Council submitted comments for the public record on two biosolids permits being considered by the Virginia State Water Control Board.

During the promulgation of a biosolids permit with the State Water Control Board, when a community provides sufficient interest, there is an opportunity for the public to comment. Modern biosolids recycling and practices are formed by a solid foundation of scientific research and review.

However, there continues today and during some of the public discussions new ‘angles’ regarding biosolids. The Virginia Biosolids Council believes that continuing robust and necessary scientific analysis will eventually provide even better policy and practices.

Even though research around biosolids has existed for more than four decades, scientists continue assessing biosolids constituent risk today, as evidenced by the active work of the W3170, a multi-state workgroup composed of representatives of the U.S. EPA, the U.S. Department of Agriculture, universities, and municipal governments from across the U.S. that review research on the potential hazards and value of constituents in biosolids and other residuals. In fact, under the Clean Water Act, Section 405(d)(2)(C), the EPA is required to conduct a review of the 40 CFR Part 503 standards for biosolids not less than every two years for purposes of regulating new pollutants where sufficient data exist.

Biosolids will always bring with it some challenges; however it is imperative and critical that the use of strong science be the foundation for the beneficial use of biosolids. And to this point, despite the continuing dialogue expressing concern about the ‘state of the science’, the science supports the beneficial use of biosolids in agriculture and forestland. It is for this reason, and as a reminder to the State Water Control Board, that biosolids be encouraged, not discouraged, as a valuable recycled resource for farmers and tree farmers in Virginia.

Letters submitted to the State Water Control Board can be found here.