I would like to commend this committee for its work on this highly controversial subject.  I, unlike most of the people commenting, have gone over the entire text regarding the Amendment of Regulations Pertaining to Biosolids (200+ pages)

First, I would like to make an observation regarding the previous 22 comments made.  People seem to be mostly concerned with sludge/biosolids entering the water via groundwater or through runoff into rivers and streams.  They are worried about illnesses resulting from toxic substances in these biosolids.  It is also apparent that there is a lack of trust concerning E.P.A. and D.E.Q.'s past actions in this area and people believe big business, local connections, and outside interference will permit practices that would otherwise be prohibited.  One third of the comments were from people that were concerned and frustrated, but clearly did not have the time or knowledge to write any substantial feedback.  One individual is obviously adamant about their concerns but does not provide any constructive advice or objectivity regarding the true problems and solutions of Wastewater Treatment Plant sludge disposal, (myths not withstanding).  

Mr. Kent Cuthbertson mirrors my opinion best in stating; "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 petroleum, the source of fertilizer, is soaring; properly stabilized and professionally applied biomass is an excellent solution." 

The lack of knowledge by people concerned about toxins, diseases, and lack of oversight and monitoring procedures is astounding.  No one has pointed out the importance of differentiating the terms "sludge" and "biosolids".  It is quite significant as untreated "sludge" is very rarely if ever applied directly to land. Biosolids, which are of a particular class of treated sludge, are in fact commonly applied to land.  As Mr. Cuthbertson has so accurately referred to in his comments: properly stabilized and professionally applied biosolids present no potential harm to waterways or humans by way of pathogens or metals contained within them.

I will readily admit that I do not like the idea of Class B biosolids being applied to lands when they could be converted to Class A biosolids with very little additional effort and expense.  What I do object to is when Class B biosolids are being dumped into a landfill at considerable expense and harm to the environment while wasting a potentially valuable resource for our land.

I do believe and agree with previous comments that this committee needs to be more proactive in researching and encouraging solutions pertaining to recycling of biosolids.  Not one person made mention of an innovative, affordable, and environmentally sound method called vermicomposting or vermistabilization of sludge.  It makes no sense at all to me to put any class of biosolid onto soils without inoculating that soil with earthworms first.   

The vermistabilization process requires 3 classes of earthworms, (Redworms, gardenworms, and nightcrawlers) a piece of land, and a device to apply the biosolids in a continuous layering method that is controlled and monitored for effective operation.  The worms eat the microbes generated from the biosolids, and eliminate any odors and pathogens while producing castings that serve as a rich organic humic substance that replaces and replenishes the nutrients in soils that are otherwise lost to soil erosion from fires, floods, and poor agricultural practices.  Numerous benefits occur from these castings including: providing soils with excellent aeration, porosity, structure, drainage, and moisture holding capacity; a lower pH then the applied sludge due to CO2 and organic acids from microbial metabolism; timed release of nutrients N, P, K through the breakdown of a mucus membrane surrounding the castings which produces  more soluble minerals that can be more readily absorbed by plant roots increasing plant growth up to 20% and root mass 150%;  a reduction in harmful bacteria and diseases in crops by the production of a huge increase in benevolent disease suppressing microbes that crowd out harmful diseases, pests and pathogens by as much as 72% due to an aerobic environment that is created; a nutrient rich organic fertilizer that provides up to 7x K, 5x N, and 1.5 x Ca than in surrounding topsoil; a more neutral pH that will not burn plants, a reduction of carbon emissions into the air; a reduction in the potential for harmful inorganic chemicals leaching into water systems; less possibility for soil erosion, increased crop yields and overall income to farmers; less labor costs and disruption of soil from tilling practices;  and best of all – the converted biosolid meets Part 503 Class A PFRP requirements.  The process is flexible to be used in conjunction with other methods, can be done indoors or outdoors, and is able to be managed and monitored without the exorbitant capital costs and energy usage that is common with thermophillic methods.  This successful technology is being used in many other countries such as England, Canada, India, Mexico, Australia, Philippines, and others.

The National Academy of Sciences (NAS) has proposed a study to review the science behind the federal government's laws on applying biosolids to land.   The $531,000, 18-month project would review new information on biosolids land application (vermistabilization?) and evaluate EPA's methods of determining risk from chemicals and pathogens in biosolids. All aspects of the Part 503 risk assessment will be examined, including the identification of pollutants, exposure pathways, default assumptions, and others.  (What a great opportunity to explore vermistabilization as an alternative method to meeting Part 503 requirements.) 

Better scientific tools are available now to help EPA gather needed data and monitor land-application practices. Science does not remain static, nor should our efforts to protect public health and the environment.  Thomas A. Burke, Ph.D.

http://www.epa.gov/waterscience/biosolids/nas/complete.pdf

Biosolids frequently asked questions website listed above.