Rich Earth urine project seeks long-term permit
BRATTLEBORO >> It has taken the state of Vermont a little while to figure out just how to issue a permit for the Rich Earth Institute.
Since 2011 Rich Earth Institute founders Abe Noe-Hays and Kim Nace have been conducting experiments in the treatment of human urine to create a fertilizer that can be used on crops.
The organization has never been in violation of state law, but Allison Lowry, an environmental analyst with the Waste Water Management Program at the Department of Environmental Conservation, said no one else has ever treated human urine on a large scale in Vermont and the business model did not really come under any of the department's existing permits.
"There was a challenge in giving them a permit because we didn't really know exactly how they fit into our rules," Lowry said. "Our rules are geared for what to do with sewage and sludge and what they are doing does not exactly look like that."
After working with the state for a year, and deciding to grow the institute after a series of successful experiments, Rich Earth Institute is now applying for a waste management facility certification.
The certification, which is the same permit large scale waste water management facilities must obtain, gives Rich Earth the authority to take its mobile pasteurization unit to other farms, and the permit is good for 10 years.
"They worked hard to try to figure out how to fit us in," Nace said. "They had to work within the existing statutes and they had to figure out how to accommodate the work we were doing within those rules."
The Rich Earth Institute has been collecting urine from over 170 volunteers, and the organization is the first legally authorized and publicly documented community-scale urine reuse project in the United States.
The group has received funding for three years from the USDA Sustainable Agriculture Research and Education Partnership grant program and Rich Earth has also been working with scientists from University of Michigan and University of Buffalo, which have both been supporting the group's work.
Up until now the Rich Earth Institute has been operating with a permit for insignificant waste management disposal, an approval process that is taken on a case-by-case basis when projects do not fit into standard permitting categories.
These permits are given out to large scale developers, for example, who might be burying tree stumps under authority of the Department of Environmental Conservation, which has found the practice to not adversely affect water quality.
That permit, Lowry said, gave the group authority to operate a mobile waste collection unit at the two farms that have agreed to work with the group on their experiments.
The new permit, she explained, will allow them to take their mobile units to other farms
"The initial permit was for a small scale operation and it allowed them to experiment," Lowry said. "With this permit they can expand the scope of their work."
In 2012 and 2013 the Rich Earth Institute conducted the first field trials in the United States using source-separated human urine as fertilizer. Their work has caught the attention of scientists and public water specialists around the country.
Noe-Hays will be presenting next month in Chicago at the Water Environmental Federation's Annual Technical Exhibition and Conference, or WEFTEC, which is the largest water quality meeting and conference in North America.
Lowry stressed that Rich Earth Institute was never in violation of state environmental law and the group has been in close contact with all of the appropriate state agencies all along.
"We've been very satisfied with their results," Lowry said. "We have not had any issues with their experiments and initial results, and based on what they've shown us the treatment process does seem to work."
And while the state has been able to figure out how Rich Earth could apply for a long term permit, it came with a cost. The organization had to issue public notices, contact abutters and jump through all of the regulatory hoops that any large scale waste water treatment plant developer would have to jump through. Nace said they spent more than $2,000 meeting those requirements.
Rich Earth has been in front of the regulatory issues and standard acceptance and practice in treating human urine from its start, and Noe-Hays said all of the lessons learned during the permitting process will only make it easier as more organizations, farmers and municipalities look to collect urine and come up with ways to keep it out of the waste stream and out it to use.
He even said state officials have acknowledged that rules regulating the process of handling and treating urine might be written into the rules the next time they are re-written.
"We've had to jump through many, many more hoops than seemed reasonable to anyone, but when the rules were written it was never foreseen that someone would be doing what we are doing," he said. "Now this is on their radar, and maybe it will be easier next time."
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