(July 16, 2020) – In comments filed on July 6, NACWA continues its support of EPA maintaining the existing Comprehensive Procurement Guideline Designations (CPG) and Recovered Materials Advisory Notice (RMAN) recommendations for landscaping products, which includes compost made from recovered organic materials like biosolids.

NACWA has supported this designation since 2003 when biosolids were first proposed to be added under CPG V and the corresponding RMAN V. Under the Resource Conservation and Recovery Act (RCRA) Section 6002, EPA must follow established requirements for the procurement of products containing recovered materials. This effort leverages the purchasing power of the federal government and further encourages the ongoing support and market for the land application of biosolids.

In EPA’s recent request for input, the Agency sought feedback on the existing CPGs and their respective RMANs and whether the right items are designated. NACWA continues to support that biosolids are correctly designated and does not recommend EPA make any revisions at this time.

EPA itself has continued to affirm that the Clean Water Act statutory obligations and correlating federal regulations governing the management of biosolids ensure the protection of public health and the environment. EPA continues to support land application as a safe, viable and sustainably-sound biosolids management option. The designation of biosolids helps to support this ongoing practice. 

If members have questions, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.