Research Composting Operations Regulatory Process Challenges September 2007 Carolyn Hawkins, Humboldt County LEA 707-268-2224.

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Presentation transcript:

Research Composting Operations Regulatory Process Challenges September 2007 Carolyn Hawkins, Humboldt County LEA

Purpose: To help others anticipate and avoid some of the pitfalls the Humboldt County LEA has experienced with research compost operation proposals

Defined: “Research Composting Operation” means a composting operation, that is operated for the purpose of gathering research information on composting. CCR T14 Section 17852(a)(34)

Section (a) - (e) (a)< 5000 cy all materials at any one time shall comply with Notification requirements (b)In vessel may >5000 cy if EA authorizes (c)Requires the operator to provide a description of the research to be performed, research objectives, methodology/protocol to be employed, data to be gathered, analysis to be performed, how requirements will be met, and projected timeframe for completion of research. (d)EA reviews Notification every two years-- includes results and conclusions drawn from research (e)Mammalian specific regs……

Research compost operations in SWIS database, September 2007: Active:7 Closed: 2 Planned:1

Two Main Challenges: 1.Many proposals do not meet definition of a research compost operation 2.Lack of research results and conclusions for review

Humboldt County Number of proffered research compost proposals:10 Number of complete Notification packages: 2 Number that actually operated: 1 Number produced results and conclusions: 0

Is it authentic compost research? Market research Transportation feasibility research Urgent waste diversion Making an event more “green” An attempt to increase one’s Groovy Status in the community A way to avoid obtaining a Compostable Materials Handling Facility Permit

To avoid struggling with “faux research”: 1.Read carefully the few regulations dealing with research compost operations 2.Review them with the proposed operator 3.Rely on the proposed operator to demonstrate clearly that her/his project meets the definition of §17852(a)(34)

To avoid struggling with “faux research”: 4.Discuss the required report contents 5.Accept only a complete Notification package 5.Inquire about data collection and research progress during routine inspections 6.Send a reminder before the results and conclusions are due for review

Ending a Research project: Use Final Report to determine whether or not research is completed. Is operation in compliance with Notification requirements? Options: Close site Continue research for another two year period Find in default of Notification