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Here you’ll find a collection of letters sent by USCC, our committees/chapters and others in the past five years on a variety of issues to several levels of local, state and federal regulators.

These letters can provide good language for local public policy issues you are working on in your own city, town, county or state.

Please use the Report Your Advocacy Efforts form to let us know what you did---we have more power when we can tell regulators what our industry is working on!

FEDERAL

Comments on the Food Safety Modernization Act’s proposed composting regulations (2013)

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.

https://uscc.site-ym.com/resource/resmgr/images/USCC-comments-on-FSMA-FINAL.pdf

 

Opposition to EPA’s Renewable Fuel Standard Rule Revision (2013)

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

https://uscc.site-ym.com/resource/resmgr/images/Comments-against-EPA-RFS-rul.pdf

 

STATE AND LOCAL

Letter to Alaska DEQ

The US Composting Council has signed on in support of a letter written by the North East Biosolids and Residuals Association (NEBRA) and North West Biosolids opposing draft amendments to Alaska's Oil and  Hazardous Substances Pollution Control regulations. The amendments concern cleanup of Polyfluoroalkyl Substances.

https://compostingcouncil.org/advocacy-resource-materials/?category=all&category=pfas

 Howard County, MD in support of a county-level on-farm composting bill. (2017)
https://drive.google.com/file/d/1P_2Tcy0mRuna5pX8HFI15JFell7gU1nZ/view?usp=sharing

Statement to Maryland General Assembly supporting Compostable Labelling legislation (2017)

HB 1349 required products being sold in the state labelled as compostable to meet BPI standards, and used USCC model legislation designed by the Compostable Products Task Force.

https://drive.google.com/file/d/15pS6412gynqGJurS-5fFpv2Xh4AsfIB1/view?usp=sharing

Letter to St. Lucie County Florida objecting to restrictive zoning ordinance (good example for opposition to overly restrictive zoning proposals) (2017)

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.

https://uscc.site-ym.com/resource/resmgr/images/USCC-letter-to-St-Lucie-re-o.pdf

Letter in support of Rhode Island’s Food Scrap/Organics Residuals Diversion law (2014)\

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.

https://drive.google.com/file/d/15F-pH4va3t5sptGR1N1WIDqw8chSIBuR/view?usp=sharing

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.

  • Physical Contamination Limits in Compost:  One of the guiding principles of the USCC is that product quality can only be defined in relation to its intended use. So it should be the purchasers and users of the products—the marketplace—that should set the product quality standards beyond minimum health and safety standards
  • Food Scraps to Dairy Loophole: We are opposed to allowing dairies to take off-farm food scraps for digestion under a simple “notification” tier.
  • Regulating Direct Land Application: We support increased regulation of this practice to protect not only markets for compost but even more so for reducing the threat of spreading imported pests

https://uscc.site-ym.com/resource/resmgr/images/USCC-comments-of-CA-Title-14.pdf