Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
State Water Control Board
 
chapter
Virginia Pollution Abatement (VPA) Permit Regulation [9 VAC 25 ‑ 32]
Action Amendment of Regulations Pertaining to Biosolids After Transfer from the Department of Health
Stage Proposed
Comment Period Ended on 4/29/2011
spacer
Previous Comment     Next Comment     Back to List of Comments
4/22/11  1:38 pm
Commenter: Kent Cuthbertson, Licensed CL III WWTP Operator and Farmer

Application of Biosolids
 

I work for Long and Associates Environmental Services, Inc. as a WWTP startup operator and as a troubleshooter for failing treatment plants, including VDOT rest areas. I farm and raise Texas Longhorns. I singlehandedly successfully performed the startup of the $9 M Warsaw Enhanced Nutrient Reduction plant in 2010. I know "sludge", good and bad. The application of biomass for farming is an emotional issue as evidenced by the comments, largely because most people are completely uninformed and have been conditioned to consider sludge as nuclear material. Properly stabilized sludge is a natural affordable and more controlled alternative to chemical fertilizers. Given that the price of pertoleum, the source of fertilizer, is soaring; properly stabilized and professionally applied biomass is an excellent solution. I apply biosolids on my land. I maintain a current Nutrient Management Plan as well as Application Records on my land. I submit that I know more about my land's health (pH, soil samples, weed applications) than most homeowners who buy several bags of Scott's and apply all of it foor good measure, more is always better. How many homeowners keep records of their applications? The answer is none and most of the excess fertilizers and insecticides they apply runs off with the rain into the nearest receiving stream, fish kill anyone? Let's face it, the current regulations for applying biomass work. They do not need fixing. If you want to control environmental degradation, look at applying the same standards to suburbia and the homeowner that are applied to the farmer. 

CommentID: 17532