I completely support the comments of those who are either out rightly opposed to sludge applications or who urge extreme caution. I especially agree with Dave Gibson and Diane Parker, both are right on point.

Instead spending limited resources discussing setbacks, fee schedules, etc. maybe those resources should be used to find viable alternative uses like converting it to energy.  Or a testing protocol that goes far beyond what EPA has done. The agricultural community and citizens of the Commonwealth have a right to know what hazards they are being exposed to be it airborne pathogens, plant uptake or polluted waterways.

USEPA and its 503 Rule has a very dark cloud hanging over it, the same cloud hung over VDH. I hope DEQ will not be darkened by this same cloud.

I think you do the DEQ a disservice when your document states that sludge is commonly referred as biosolids, that may be the case at DEQ and in the sludge industry but the common term amongst concerned citizens is sludge. Repeatedly doing so gives the appearance that DEQ has lost its objectivity.