How California’s Tougher Regulations will Affect Composting

Meet Matt Cotton, the man behind Integrated Waste Management Consulting, who during his 25 years in the composting industry has become a go-to resource on everything from providing permitting assistance to new and expanded composting, anaerobic digestion, and chipping & grinding facilities, to providing hands-on odor mitigation at composting facilities, to conducting important statewide studies of the California organics industry.

Cotton has developed training programs for the U.S. Composting Council (USCC), the Solid Waste Association of North America and the California Resource Recovery Association. He’s also a lead instructor for the USCC's 40-hour Compost Operator Training Course.

Just last week, he led a workshop entitled “Composting Under Cover: Minimizing Odors, VOCs and Stormwater Impacts” for the USCC to help those who work in California’s organics recycling to understand and integrate the new regulations into their operation.

“The majority of what I do is related to permitting and permit compliance and that sort of thing for large commercial composting facilities of which there are 130+ in California,” says Cotton. “It’s a very robust market here in California and occasionally I get to go to exciting places like Australia or China.”

We caught up with Cotton before he left for a two-week trip to Beijing to get his insight into how the stiffening air and water regulations in the Golden State will affect the compost industry.

Waste360: Can you give us an overview of what is happening in California right now?

Matt Cotton: Sure. In many ways, it’s more of the same. I've often said permitting anything is challenging in California. We have a lot of people and a lot of land use conflicts, so permitting a composting site is somewhat of a challenge certainly. Some of this has to do with that and increasing regulations on air emissions from composting. But arguably more of it has to do with the very recent development in a new state-wide general order for composting facilities which really, by itself would be driving composting sites to seek a solution or technology that allows them to manage more material on a small space, which is what forced aeration composting can do. So we're hitting a couple of birds with one stone. Forced aeration has a better odor control and can help you comply with the DOC requirements but also help you manage more material on less space. It's not any one of those things, but all of those things, which I think is driving the technology in that direction, at least in some places in California.

Waste360: What is driving these new regulations?

Matt Cotton: We've had an amazing couple of years in California with a lot of very progressive pro-organics, pro-composting, pro-organics diversion landfill type legislation and part of this is the air boards and the state water board anticipating some significant growth in composting in California. So rather than treat every individual facility as its own entity, the state passed a general order as a new state-wide standard for all commercial composting facilities.

Waste360: What’s the biggest implication of this new statewide standard?

Matt Cotton: It basically classifies every facility as tier 1 or tier 2. Most new facilities will probably fall into tier 2 which requires basically a certain permeability requirement for the pad and the conveyances, and they set a higher permeability for the pond. The pond is now considered a waste-water pond whereas prior to this order, it was probably considered a storm-water pond and people complied with the storm-water reqs but this is greater requirements for management of water that hits the site. Any water that hits the composting site is basically going to be treated as wastewater and actually managed in a pond. It’s very consistent with what Washington State did years ago.

Waste360: What are some of the benefits of forced aeration?

Matt Cotton: The biggest thing is, and I should trademark this phrase, more stuff on less space. Why that's important is because if you've got to comply with this new general order then if you have to put down 10 acres of concrete with a windrow facility, you can only put down 6 acres of concrete with a forced aeration system so you’re going to spend a lot less money. That's the biggest thing, but it also helps you comply with the air emission regulations. There are multiple benefits: Better odor control; better emissions control; possibly lower labor costs. It’s not new, it’s just an application of the technology that's been around for a while and it's been evolving. Some of the system manufacturers are coming out of Washington State because they've been doing this for a little bit longer and have a lot more water to manage. A lot of it’s about managing less storm water.

Waste360: What are the drawbacks?

Matt Cotton: Probably cost is the biggest drawback. Really initial capital costs are the biggest challenge for it. Maybe a little part of it is unfamiliarity because there are thousands of windrow composting sites and it's not super challenging to operate. There is a fairly low barrier to entry with windrow composting. The barrier entry for an aerating site is a little higher. It's a little more sophisticated to operate.

Waste360: Composting is clearly a very dynamic, evolving industry. Anything else you’d like to add about the state of affairs in California?

Matt Cotton: California has always had fairly progressive legislation. We have a very progressive governor and he's in his second term, so we have this momentum for a lot of these issues. We've got problems, and we're proposing solutions. Forced aeration is a great solution to a lot of these challenges. We want to manage more of this stuff than we used to -- you know put in a hole and cover with dirt. Now we want to manage what we put underground. Now we want to manage what's on the surface. We want to take the value of those nutrients and materials and put them back on the soil for all the great benefits that compost brings.