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Welcome to our resource center of USCC stances to assist in advocating for similar compost-friendly policies in your jurisdiction.
Greenhouse Gases and the Role of Composting: A Primer for Producers
The goal of this factsheet is to provide composters with some basic definitions relating to Global Climate Change, help them understand composting’s role, and offer some direction for additional resources.
Persistent Herbicide Fight
USCC Position Statement on Persistent Herbicides
The US Composting Council calls on chemical manufacturers to withdraw herbicides known to persist in soil and compost with phytotoxic plant effects and to take responsibility for the damage these persistent herbicides cause, and on the US EPA and state agencies to take immediate and decisive action to prevent further environmental and financial damage.
PFAS (PolyFluoroAlkyl Substances)
A letter co-signed by USCC and developed and sent by NEBRA to the Alaska Department of Environmental Conservation in response to new regulations concerning PFAs. The main purpose of the letter is to illustrate how this proposed regulation will impact organics recycling based on a flawed model. The letter contains numerous examples developed by NEBRA to help illustrate the key points (below):
Comment Letter to US House Ag Subcommittee on Farm Bill
Support the USCC position to keep funding for food scrap diversion pilots in the 2018 Farm Bill.
USCC Position of Regulating VOC Emissions from Composting
The types and volumes of VOCs emitted from properly operated commercial composting facilities are naturally occurring (biogenic) and do not pose significant risk to the formation of ground level ozone.
Model Compost Rule Template Version 1.1
In 2011, the USCC initiated a public-private partnership to develop a model compost rule template (MCRT). The template includes a three-tiered permit structure, with design and operating requirements based on materials composted and technology employed. The foundation of the tiers is the feedstock categories, which are based on the materials’ potential risks to human health and the environment. The template also includes siting and testing requirements based on quantity and types of feedstocks processed. The MCRT is anticipated to be a “living document” that will be periodically reviewed and updated as knowledge and experience in compost manufacturing and regulating continue to mature.
We welcome comments and suggestions. The Legislative and Environmental Affairs Committee of the USCC will periodically review the comments and update the Model Rules as appropriate.
Please provide your comments or suggestions on the Model Compost Rule Template here
USCC Comments of the Food Safety Modernization Act’s proposed composting regulations
For compost manufacturers whose product is destined for use on food crops with a potential for compost to be on the final product and whose composts include manures or food scraps, we recommend a two-tier approach. A stricter level of testing to allow no application-to-harvest restrictions and a standard level that includes the USDA-recommended 45-day separation between application and crop harvest.
Letter in Opposition to EPA Renewable Fuel Standard Rule Revision
The USCC opposes US EPA’s proposal to expand the renewable fuel pathways for landfill biogas-to-electricity to qualify as a renewable fuel.
More info on the proposed standards can be found at http://www.epa.gov/otaq/fuels/renewablefuels/regulations.htm
U.S. Composting Council (USCC) Position Statement: 2012 Farm Bill
The USCC seeks to explain the nature and role of compost within the framework of the Farm Bill, offer its own positive experiences and provide specific suggestions for the more effective promotion of compost to the benefit of rural, suburban and urban economies and communities in the U.S.
The following statement supports the inclusion, recognition and promotion of compost manufacturing and compost use within the 2012 Farm Bill.
Policy--State and Local
Letter to New Jersey Senator Bob Smith Regarding S2515-Recycled Content Requirements (June 2020)
A bill in New Jersey, S2515 submitted by Sen.Bob Smith, requires 10% recycled content for all trash bags, including compostable bags, and 35% recycled content/recycling requirements for “rigid plastic containers, andis similar to California’s RPPC law. Due to the fact that there is neglible recovery of compostable resins currently, the Legislative and Environmental Affairs Committee and USCC agreed that requiring recycled content in compostables is an impossible task. USCC submitted a letter (see the letter here) requesting that compostables be exempted from the requirements of the bill. The New Jersey Composting Council submitted similar comments.
Letter to NYC Council Supporting Restoration of Funding for Community/Decentralized Composting Sites in NYC. (May 2020)
NYC's compost program grew from distributed sites run by non-governmental organizations and built support for the DSNY's government program, for which funding was cut due to the pandemic. Proposals to cut funding for these cost-effective community sites will set back NYC organics diversion and USCC is opposed to closing these.
Letter to CalRecycle Regarding SB1335-State Procurement of Compostables (May 2020)
USCC supports specific relationships between compostable products suppliers and compost manufacturers regarding compostability of products purchased by state agencies to guarantee their compostability.
Letter to St. Lucie County Florida objecting to restrictive zoning ordinance
St. Lucie County has proposed a zoning ordinance for commercial composting that is so restrictive that it will essentially prohibit any commercial composting facilities from being built. USCC submitted this letter in support of the Organics Recycling Committee of Recycle Florida Today.
USCC Comments of Proposed Changes to CA Compost Regs
As the national organization representing a wide range of composters we focused our comments on a few areas that have a potential for setting precedents that may be copied by other states.
USCC Comments on Draft Nutrient Management Regulations in Massachusetts
The US Composting Council reviewed draft regulations put forth by the Massachusetts Department of Agricultural Resources titled “Plant Nutrient Application Requirements for Agricultural Land and Land Not Used for Agricultural Purposes.” Comments touched on a number of areas starting with definitions for terms such as ‘biosolids,’ ‘compost,’ and ‘fertilizer.’ Council staff will continue to follow the progress of these draft regulations and encourage conditions that are based on scientific best management practices and improve markets for compost products.
USCC Supports and Comments on Rhode Island Food Residual Disposal Legislation
USCC submitted letters of support and comments to the State of Rhode Island General Assembly regarding H7033 (S2315) and H7482 (S2436), two bills that would require large generators of food residuals to recycle those residuals. This legislation mandates producers of food residuals to 1) source-separate food residuals from other solid waste for recycling; and 2) recycle or treat food residuals on-site or send their organic waste to a recycling facility.
Comment letter on Minnesota Rules Chapters 7001 and 7035
USCC support Minnesota’s leadership in the compost manufacturing industry, and suggest improvements to the proposed rules in the following areas:
Letter in Support of IA SF 306
The U.S. Composting Council is strongly in favor of SF-306 and the emphasis it puts on recovering, reusing, and recycling organics, particularly food scraps. This bill will not only reduce production of harmful methane gas at landfills in Iowa, it will also increase awareness of organics recycling in Iowa.
MA Press Release: Composting and Anaerobic Digestion Industry Poised to Expand in Massachusetts
A consortium of industry associations announced today its support for the ban on the disposing of organic materials as proposed by the Massachusetts Department of Environment Protection (Mass DEP) on July 10, noting that this compelling policy will help the Commonwealth to achieve significant environmental, economic and social goals. Called FOOD (Focus on Organics Diversion), the consortium formed by the American Biogas Council, the US Composting Council, and MassRecycle together represent dozens of companies and local agencies already playing significant roles in the growth of alternatives to the disposal of organic resources such as yard debris and food scraps.
Letter in Opposition of OR SB 462
USCC opposes SB 462’s 1500′ exclusion zone for composting facilities around schools on a property-line-to-property-line basis, and more more generally on reversing DEQ’s progressive performance-based permitting to prescriptive legislation.
Letter in support of CT RB 1116
The US Composting Council wholeheartedly supports Raised Bill 1116, An Act Concerning The Recycling Of Organic Materials By Certain Food Wholesalers, Manufacturers, Supermarkets And Conference Centers.
Support for CT SB 1081
Email to Composting Council Members and Allies that are in or do business in Connecticut:
Comment letter on CA Title 14 changes
We support the overall intent of the package of changes, and suggest improvements to:
Support letter for CA AB 323 (Chesbro)
AB 323 presented a package of policies that will drive the recycling of yard trimmings and food scraps, not only resulting in a reduction of pollution and greenhouse gases, but also creating jobs and supporting a
Preserving Landfill Bans
Yard Trimmings Ban Impacts and Support
Presentation By Dr. Stuart Buckner to the Recycling Organizations of North America on the positive impacts of banning yard trimmings
USCC Position: Keep Organics Out of Landfills!
This two-page summary explains why the US Composting Council is firmly opposed to landfilling yard trimmings, food residuals and other source-separated organics when viable alternatives are available.
Analysis of the Impact of a Yard Waste Ban On Landfill Quantities and Household Costs
Report from the Delaware Solid Waste Management Authority on the impact of yard trimming bans, which concludes that “states or counties with landfill bans receive significantly less yard waste [at their landfills] on a
Keeping Yard Debris out of Michigan Landfills
This is a great presentation developed by JD Lindeberg of Resource Recycling that debunks the claims made by the waste industry on the alleged benefits of repealing the ban on landfilling in Michigan. For a PDF version use the download link.
EPA Regions 4 and 5 Support Ban on Landfilling Yard Waste
Letters from two different EPA regions demonstrates that the US EPA supports the continuation of landfill bans for yard debris and sees them as essential to ensuring that these resources continue to find their way into reuse markets, such as composting.
Stop Trashing the Climate!
This report documents the link between climate change and unsustainable patterns of consumption and wasting, dispels myths about the climate benefits of landfill gas recovery and waste incineration, outlines policies needed to effect change, and offers a roadmap for how to significantly reduce greenhouse gas (GHG) emissions within a short period. Stop Trashing the Climate provides compelling evidence that preventing waste and expanding reuse, recycling, and composting programs — that is, aiming for zero waste — is one of the fastest, cheapest, and most effective strategies available for combating climate change. The report was authored by Brenda Platt, Institute for Local Self-Reliance, David Ciplet, Global Anti-Incinerator Alliance/Global Alliance for Incinerator Alternatives, and Kate M. Bailey and Eric Lombardi, Eco-Cycle. Click HERE to visit the Stop Trashing the Climate website.
Measuring the benefits of composting source separated organics in the Region of Niagara
The report prepared by CM Consulting for the Region of Niagara, Canada, provides the ‘true costs’ or ‘full cost accounting’ associated with the environmental and human health impacts of composting, landfill and energy from waste (EFW) for 47,178 tonnes of organic waste projected to be managed in the Region. The results show that in the case of the Region of Niagara, the ‘True Costs’ associated with managing organics are $(15.76) and $32.18 per tonne for composting leaf, yard and brush waste, and food waste respectively, $75.14 per tonne for landfill with gas flaring, 49.37 per tonne for landfill with gas recovery for electricity generation, and from $62.72 – $142.72 per tonne for EFW.
Florida Landfill Ban Preserved!
Though ultimately overridden, this documents the successful drive to have Gov. Crist veto the landfill ban repeal.
Biocycle Special Report
Biocycle puts the landfill energy myth to bed
The Argument Against Repeal of Michigan’s Landfill Ban on yard Trimmings
This paper for JD Lindeberg and Mike Csapo explain why MI 864 is bad for the economy and the environment. NOTE: This document is placed for the convenience of our members. The views and opinions expressed are those of the authors and do not necessarily represent the views of the USCC or our sponsors.