Why the industrial compost facility in East Boulder County should not be built

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Bulldozer putting biomass on pile for composting in industrial facility
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When it comes to Boulder County’s plan for an industrial composting facility: words matter. When elected officials make promises to voters that Open Space tax revenues will only be used to “perpetually” protect land with conservation easements, or to “forever” operate Open Space lands in compliance with strict and clear Open Space policies, nobody should ever have to worry those lands will be abused, developed, traded or industrialized for profit. Perpetual and forever, passive recreation and preservation are not ambiguous terms, nor should they ever be subject to future interpretation. 

Boulder County’s proposed development of a composting facility on protected Open Space lands is an ill-informed and dangerous land-use policy with the potential for long-term adverse consequences. It is nothing short of a betrayal of a sacred trust. When residents realize their restricted Open Space tax dollars are involved in a bait-and-switch scheme, where the County gives protected lands to other County departments so the County can apply to itself for permission to develop and commercially operate the land, it will undermine voter support for future Open Space ballot measures.

If we have learned anything in the last year of political strife it is that facts also matter, but we are not getting the facts about the compost facility as evidenced by the comments of the Community Editorial Board in the Feb. 13, 2021 edition of the Daily Camera — predictable but uninformed and not helpful. It is all too easy, and perhaps a bit disingenuous, to readily dismiss neighboring objections as yet another NIMBY attack. However, resistance to the project goes far beyond the neighbors. For example, the Erie Board of Trustees recently passed a resolution opposing the project. As the discussion below demonstrates, opposition to the County’s proposed facility is anything but NIMBY. 

One of the problems in general is the County’s extravagant allocation of resources. We all long to live in a more organically sustainable world — to achieve that, we must invest our scarce human and economic resources in strategies that have environmental leverage in areas such as clean water and land conservation and management. But to apply such resources to an unproven and risky adventure is reckless. 

When examined in full light, apart from all the project’s legal difficulties of the concept addressed in current lawsuits, the facts show that the proposed facility would not be what it is being made out to be, and the County should put our scarce resources toward more reliable strategies. The environmental cost/benefit and the economic cost/benefit tradeoffs are not being disclosed. 

The County’s management of our Open Space lands has historically been less than stellar. Witness the fields of Open Space completely congested with Canada thistle, Bull thistle and Russian thistle, all invasive species. Surely the founders of the Open Space program did not intend to create industrial thistle farms. We should focus our resources on better management of the land we already have.

Industrial compost

The concept of a centralized composting center for our organic wastes is attractive as a concept but, in reality, the facility does not pass muster by any measure. Do we really want to engage in such a risky undertaking? We should avoid unintended consequences while we still have the chance. 

First, it is important to understand what compost is and what it is not. There is no scientific definition of compost as we are using the term here. A colloquial definition of compost goes something like this: a mixture of organic matter such as from biological material that has decayed or has been digested by organisms, and which is then used to improve soil structure and provide nutrients. The practice of composting derives historically from centuries of agrarian cultures that took advantage of natural processes of decay in their environment. 

Beginning in the 1960s, the natural food movement co-opted the term organic as healthy and desirable, and that notion continues to this day. Though technically organic refers to being carbon-based, the word has become the watchword for everything sustainable such that we are willing to pay a premium for organic products, while often shunning anything that is not “organic,” that which is “unsustainable.” To be clear, compost is not necessarily organic as we typically use the term.

Second, all compost is not the same. The County’s web site states: “The facility will be a Class III Composting Facility that will accept vegetative waste (leaves, grass, branches, limbs and forest materials) and animal waste, manure, food scraps and food processing vegetative waste. Biosolids are being discussed and may be accepted in the future.” Compost from the County’s proposed facility will not be organic. Rather, it will be a manufactured product from an industrial facility using raw materials that may be toxic or infectious. In particular, per the County’s description, the process contemplates the use of so-called “biosolids,” which is merely a euphemism for treated sewage sludge. Would you add treated sewage biosolids to your compost pile and then put that compost on your vegetable garden? Not in my backyard garden. NIMBY-G.

These ingredients have serious health and economic implications. Nothing good comes from adding the highly concentrated waste solids from human waste treatment plants, and animal manure, into the composting process. This is certainly true when contemplating the application of the finished product to croplands producing food for human consumption.  We don’t need the compost produced by this facility.

Third, it is important to understand the environmental risks from such a facility. To see clearly what is at risk, the auras of organic and sustainability must be stripped from discussions of the County’s compost product. Many environmental risks associated with industrial compost have not been fully evaluated — anywhere. For example, in a scathing 2018 report, the EPA Office of Inspector General noted the agency could not properly regulate biosolids, even if it sincerely tried, because “it lacked the data or risk assessment tools needed to make a determination on the safety of 352 pollutants found in biosolids.” The EPA identified 352 pollutants in biosolids but cannot yet consider these pollutants for further regulation due to either a lack of data or risk assessment tools. Pollutants found in biosolids can even include pharmaceuticals, steroids and flame retardants.

Contamination is by far the biggest problem for municipal composting programs. Following are some of the contaminant risks the County’s proposed facility will create, risks the County has largely ignored or dismissed with vague, euphemistic assertions that the problems will be “managed” or “mitigated.” 

Airborne particulate risk. This is the subject of the most comprehensive analyses of many peer-reviewed and published scientific papers/studies which confirm risk to workers and those close by, but research methods have not yet been applied to understand fully — or to rule out — risk to communities downwind. With the local weather patterns and winds, Erie does not deserve to be the first large-scale test sample. Also, important to note, these studies are not analyzing facilities of comparable scale to that of the County, nor those using mixed feedstocks that include massive volumes of animal and human waste in addition to food waste, grass clippings and other yard waste (leaves, tree branches, etc.). 

Volatile organic compounds (VOCs) emitted from composting. The only studies analyzing this component of emissions are from substantially smaller composting facilities and operations that primarily include only yard clippings. A report based on the study of such operations conducted by University of California Davis researchers nevertheless clearly identifies, among other VOCs, formaldehyde and benzene. 

Microplastics. This is a major and emerging environmental risk from the precise type of industrial-scale, mixed-stream composting being proposed by the County. Just as microplastics are being identified as a massive threat to global marine ecosystem health, researchers are realizing that microplastics created in composting similarly disperse into the soil and water around composting centers — and everywhere the compost is applied to the soil — and then bioaccumulates. Interestingly, Eco-Cycle provides a reasonable resource base on the topic. 

Soil/water contamination risk from human sewage sludge. This is another area of emerging science and understanding. In short, nothing good comes from adding the highly-concentrated waste solids from human waste treatment plants, and animal manure, into the composting process. This is certainly true when contemplating the application of the finished product to croplands producing food for human consumption.

Unintended consequences

The Rainbow Nursery land is not now nor has it ever been zoned industrial, and for good reason. It sits in a prime agricultural area and the conservation easement the County procured in 1994 reflects that intended use. It must remain so or else there will be unacceptable risks, and consequences that are foreseeable even if not intended. 

Unfortunately, the County has not seriously analyzed these risks such that the necessary mitigation strategies can even be identified. The County’s characterization of its management approach is aspirational at best. Most certainly this will not be a zero-emissions facility in any respect.  There are so many uncertainties in municipal composting some states have had to close their facilities. For example, in Delaware, the Willington Compost Facility had so many problems -it was forced to close less than five years after it began operations. 

The Willington facility was employing the very same “Advanced Gore” technology as the County proposes here and it is, as yet, an unproven technology for manufacturing marketable industrial compost. Between mid-2012 and its closure in fall 2014, the facility received hundreds of odor complaints, notices of violation from the state, and complaints about plastic and glass contamination in the compost. 

As a result, though recommendations were made in an attempt to mitigate the problems, the operations continued to suffer from contamination, and from odor problems reaching out into area neighborhoods and businesses, even though buffer areas were in place. On Oct. 20, 2014, the Delaware Department of Natural Resources and Environmental Control, in the face of permit violations, refused to renew the facility’s permit, thus shutting down operations. Good intentions are pavers for many useless roads. The County’s should not be one of those roads to nowhere except, perhaps, failure.

The City of Everest, Washington, learned its own hard lessons with its compost facility also using the very same Gore technology. There, objectionable odors traveled some 15 miles from the facility. That installation has been involved in years of litigation, a class-action involving more than 300 plaintiffs, which has resulted in millions of dollars in settlement. 

Also, as the City of Seattle discovered, controlling the quality of the compost when you can’t control the inputs is a challenge. Consumers who bought the compost from the City’s facility in the 1980s reported that it killed certain garden plants. The problem was traced to clopyralid, an herbicide. When Washington state banned the use of the herbicide on lawns, the composting program recovered. But municipal composting feedstock will nevertheless still include materials that have been treated with chemicals.

Market considerations

Marketability of industrial compost is a key component of the success of municipal composting, and composting only works as a form of recycling if the resulting product is marketable. It is telling that none of the County’s feasibility studies actually support the municipal compost project, and one study in 2014 actually concludes that the facility would not be economically feasible. You can find the studies on the County’s web site. An excerpt from an analysis of the County’s proposal by an industry expert illustrates the potential economic impact of the toxic substances. 

The operators should be aware of the risks involved with handling biosolids and the potential re-classification of this substance by the EPA as a toxic material, preventing its use in land application. “Though the government is reacting slowly or ignoring problems, companies like Whole Foods, Dole, Heinz and Del Monte won’t buy crops grown in biosolids, while Switzerland, the Netherlands and other countries have banned it.” (The Guardian, Oct. 2019).

One “benefit” of the facility promoted by the County is reduced emissions by limiting the waste transportation distances, but this concept ignores the fact that other jurisdictions would be sending their organic wastes to Boulder and that would negate any emissions benefit. Further, what happens if the local citizens become educated about the risks and unknowns about the County’s facility decline to use the County’s product? What then becomes of the product? Demand would largely be commercial and the manufactured compost will be transported to other, distant sites willing to accept such material in large trucks with additional emissions that the facility was intended to reduce. There’s that darn road of good intentions again.

County Commissioners

It is not inaccurate to name the proposed facility for what it is, to wit, an industrial factory that produces a manufactured, potentially toxic product, a factory without walls perhaps, but a factory nonetheless, and with all of the attendant impacts and consequences. 

We surely need forward-looking strategies to manage our waste problems and other environmental concerns, but the human and economic resources required to build and operate this facility would be better put to developing more and better creative management techniques for our precious public lands. Certainly, better organic waste management practices are necessary as we move further into this ever more complex world, but this factory is not one of them.

The Rainbow Nursery land was purchased with tax money earmarked for the County’s Open Space program. To now suddenly reverse course and construct an industrial plant on the Open Space property is a breach of the County’s sacred trust, and a breach of its fiduciary duty to its citizens.  

Aldous Huxley has been quoted as saying: “Facts don’t cease to exist because they are ignored.” If you truly care about the value of our Open Spaces, please urge our County Commissioners to get the facts, all the facts, before they decide to go forward with an unwarranted and ill-advised expenditure of our scarce resources. We deserve nothing less. We certainly don’t deserve to be betrayed 

Ken Robinson is a concerned citizen, who formerly practiced as an environmental engineer. He is currently a practicing attorney and has lived in Boulder for more than 40 years.

This opinion does not necessarily reflect the views of Boulder Weekly.