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I wish to express my opposition to HB2517. Just because VA Tech or any other institution of higher learning wants to study the land application of biosolids/sludge, that should not relieve that institution from providing the same notice requirements to its neighbors that commercial appliers and private farmers are obligated to provide. I urge an unfavorable report on HB2517. Thank you, Glen Besa

I am David Sligh, Conservation Director at Wild Virginia. I would like to thank Del. Bulova for his efforts on HB2050 and for accepting and responding to some concerns from the conservation community. We believe the substitute offered today is significantly improved over the version first introduced and we are grateful for those changes. We do have some continuing concerns, as follows: 1) We believe that basing compliance with permit limits on a running annual average of monitoring results, as included in 1.B., can allow harmful levels to be discharged and affect the water supply and that the variability in discharges should weigh against this condition; 2) The addition of an exception to municipal solid waste facilities under 1.D. is unwise, given that landfill leachate is a known and often significant source of PFAS in discharges and would be a serious threat to water supplies; 3) The allowance for cessation of monitoring after four consecutive samples below method detection levels, as allowed under 1.A. may allow dangerous levels of PFAS to be released. The variability in discharges can be quite significant due to variations in industrial processes an other factors and ongoing monitoring is important. Wild Virginia opposes HB2517 from Delegate Runion and asks the subcommittee to reject it. The bill's exemption for sludge land application on land owned and operated by institutions of higher education would be unfair to the public and could create threats to state waters and residents around these sites. Current regulations require public notice and opportunity to comment and these are necessary to let people know what is happening in their communities and have the chance to influence the decisions about these activities. Sludge that is land applied contains many pollutants, including in most if not all cases PFAS, and the normal regulatory process and permit conditions must be used for these sites as they are for all others in the state. Educational institutions have the capacity to meet the regulations and should be required to abide by them.

HB2517 These comments specifically refer to this proposed language of the bill in this paragraphy: "S. The permitting requirements of this article shall not apply to any land application of sewage sludge when such land is owned and operated by an institution of higher education in the Commonwealth. As used in this subsection, "institution of higher education" means a public institution or private institution of higher education, as those terms are defined in § 23.1-100." Supposedly, the point of this bill is to help make sure universities can land-apply biosolids (sewage sludge) for research, but it is actually an industry-backed document that will result in silencing the public, reducing access to important data, and increasing the potential for chemical contamination of Virginia land and water. The industry and academia are understandably worried right now about public opposition to the land application of biosolids (sewage sludge), given that the public is becoming increasingly aware of how full of toxic chemicals biosolids are, and in particular, PFAS chemicals. This language is so wide-ranging as to allow a university to spread sludge across its entire campus without any notice given or opportunity for input from any stakeholders. That may seem a far-fetched scenario, but the law would allow it, nonetheless. Perhaps the language of this bill was intentionally written as over-broad, so that it could subsequently be amended and narrowed to focus on research. Then its supporters could say it was "fixed" and therefore, ready to be passed. Dear Legislators, please do not fall for this ruse. This idea of exemption for anyone or any institution takes us in exactly the wrong direction. We need firmer state and local controls over sources of pollution -- including sewage sludge -- not looser ones, because federal regulators are dissolving and abdicating all their responsibilities, even as we speak. Now that we know there are PFAS in nearly every sample of sewage sludge taken, we need more public awareness and input on biosolids permits, not less. This bill would cut the public out of the process altogether. I urge you to please kill it.