Recommend Class I W/ CE Requirement

In the past many composting operations were started at landfill facilities since waste was already going to that location; under this old model the Class II license was best to run both operations. However compost operations are becoming more common and independent of landfills meaning the operators do not need to know the landfill world rules and regulations. In addition it should be noted that these licensure requirements are only applied to those operations permitted under the solid waste regulations and do not cover many biosolids composting operations. Biosolids composting operations are regulated separately (different DEQ Division) than the wood waste and food waste composting operations permitted under solid waste regulations.In addition it appears that DEQ is working toward additional permitting exemptions to help encourage composting as a sustainable form of waste management.

Considering these factors I would recommend that composting operations permitted under the solid waste regulations require a Class I license and carry a CE requirement for continuing education specifically associated with the area of practice. By requiring the Class I license you are helping the composting community which does not need to know landfill regulations but also will allow for Class II operators to continue working to develop composting methods and operations under their existing license class.