The proposed Amendment 9 to the VSWMR would prohibit locating a composting facility (except for those only composting vegetative waste and yard waste) less than 1,200 feet from any airport's air operations area.

The U.S. Department of Transportation, Federal Aviation Administration (FAA), in its Advisory Circular, "Hazardous Wildlife Attractants On or Near Airports" (#150/5200-33, 1997) notes the following setbacks for wildlife attractants (Sec. 1-3):

a. Airports serving piston-powered aircraft. A distance of 5,000 feet is recommended.

b. Airports serving turbine-powered aircraft. A distance of 10,000 feet is

recommended.

c. Approach or Departure airspace. A distance of 5 statute miles is recommended, if the

wildlife attractant may cause hazardous wildlife movement into or across the approach or departure airspace.

Sec. 3-4 of that same document states: "composting operations should not be located closer than the greater of the following distances: 1,200 feet from any aircraft movement area, loading ramp, or aircraft parking space; or the distance called for by airport design requirements."

The FAA notes that yard waste is "generally not considered a wildlife attractant", but I recommend you modify the proposed language at 9VAC20-81-320 to require Category I-IV composting facilities and composting facilities handling only vegetative and yard waste (and not other Category 1 feedstocks) not be located closer to airports than the recommended FAA Siting Criteria in Sec. 1-3 as noted above.