I am in favor of the creation of a separate class of operating permit that distinguishes compost facility operators from traditional landfill operators. After some dialog with area compost facility managers many said that while the licensing process was rigorous it lacked much pertinent subject matter as it relates to compost facility operation. If Virginia wants to support & encourage composting here in the Commonwealth, we should move towards having a separate, clearly defined, well informed class of compost facility operators. It would require a new licensing protocol and license testing subject matter. If more people are going to compost in the future, I believe that this is the best course so that the relevant environmental issues are regulated properly & in a highly informed manner. Thank you.

I recently took the Class1 and Class 2 License Courses.  A very small percentage is about Compost Facilities.  I am in favor of a compost facility only needing a Class 1 license.

In favor of additional licensing specific for compost facility operators and to include various types of composting operations.

It seems that environmental safety would be compromised by having a person familiar only with Composting or a Landfill to be eligible to operate the other  just because that person holds a license.  I would prefer the two licenses be separate. 

As a holder of Class 2 Waste Management Facility Operator License, I can say that a license more specific to compost facilities would be more appropriate for my staff and would likely increase the number of license holders at our company. I fully support a separate license class for compost facilities.

Composting, especially for food waste, is becoming a "new frontier" in recycling and processes such as anaerobic digestion are being looked at much more seriously.  These involve completely different technologies and knowledge sets than landfilling.  Composting operations should require its own specific requirements licensing standards..

 Under current DPOR regulation, a Class 2 WMFO license is required of both landfill operators, and facilities that compost municipal solid waste.  Landfills and compost facilities are quite distinct operations.  This grouping places a burden on operators of both facilities, especially the compost facility operators, to be trained and tested on information that is not relevant to the operation and management of their respective facilities. 

 Also under current DPOR regulation, compost facility operators fall under two different license classes:  A WMFO Class 1 license is required for operators of a composting facility receiving yard waste, and a WMFO Class 2 license is required of operators of facilities that compost municipal solid waste.   Since all compost facilities have similar permitting, siting, and operational requirements, regardless of the type of material composted, the same class operator license should be required of all compost facilities. 

 Two possible options for resolving the current problems with the compost facility license requirements are: 
                1 - Require a Class 1 license for all compost facility operators, or
                2 - Create a fifth license class that covers all compost facility operators.
             

As the Board considers the scope of practice allowed under each license class, I recommend including all composting facilities in the definition of a Class I license for the following reasons:

 ·         1) The Class 1 basic training course and examination are sufficient to meet the minimum competency requirements needed to operate a composting facility, and to meet the intent of the statute requiring a WMFO license.  Therefore, creation of a 5^th license class for operators of composting facilities is unnecessary. 

·         2) Compost facility operators should be subject to equivalent basic training and testing requirements as other solid waste management facilities that hold similar-type Department of Environmental Quality (DEQ) solid waste management facility permits and are subject to similar requirements under DEQ regulations 9VAC20-81-300 et seq.  (In addition to composting facilities, these include primarily transfer stations and material recovery facilities.)

·        3)  Specific additional knowledge pertaining to compost facility operations can be obtained through the Continuing Education requirements of the WMFO license, as is done by other WMFO licensees.

·        4)  The subject matter of a Class 1 license exam applies generally to operators of all facilities subject to Virginia Solid Waste Management Regulations (VSWMR) Part IV (9VAC20-81-300 et seq), which includes all categories of compost facilities.

·         5) The WMFO license exam, which recently underwent a review, could be readily modified by placing all compost-related questions into the Class 1 exam question bank. 

·        6)  Avoids the potential dilemma of how to “grandfather” those operators of compost facilities who already have either a Class 1 or Class 2 license, if a new license class were to be created.

·         7) Reduces unnecessary regulatory and financial burden on composting facilities, which in many cases are small businesses. 

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.   

I believe there should be two separate licenses for composting.  One for organic composting and another for biosolids composting.  They are two different composting methods.