CLFP Testifies Regarding Proposed New Land Application Regulations

On December 10, CLFP staff participated in a hearing conducted in Sacramento by the California Department of Resources Recycling and Recovery (CalRecycle) regarding proposed new regulations for food processing land application sites. The proposed regulations would classify food processing solid byproducts as "wastes" and facilities or farms that stockpile or store these materials as "waste handling facilities" under the jurisdiction of CalRecycle. The net effect of this change would be to add a new layer of regulations that would discourage land application across the state.

CalRecycle became involved in this issue due to several incidents in recent years where waste haulers from the Los Angeles area spread large amounts of residential green waste mixed with trash onto farm land in Kern and Ventura counties. These incidents caused serious local nuisances that warranted attention, but they had no connection to the legitimate land application operations conducted by food processors and farmers. However, based on these cases CalRecyle decided to expand their oversight beyond landfills and composters to agricultural operations.

CLFP stressed that CalRecyle has not provided any information to indicate that permitted land application sites are causing any problems in terms of environmental degradation, odor nuisance, or insect vector. In both written comments and the oral presentation at the hearing, CLFP staff stressed that using food processing byproducts as a soil amendment or animal feed is a beneficial reuse of the material, and that these activities are already regulated by other agencies.

CLFP is hopeful it is making some headway in terms of increasing CalRecycle’s understanding of the value of land application, and that the proposed regulations may cause more confusion than environmental benefit. CLFP’s goal is to obtain an exemption from the CalRecycle regulations for food processing byproduct land application sites, and staff will work with other industry organizations to achieve that goal. If you have any questions about this issue contact Trudi Hughes in the CLFP office.

Article written by Rob Neenan, CLFP President & CEO