To the Editor, The administration’s legislation HB1443 and SB386) will require PFAS sludge testing for the first time and also require disclosure of testing results to landowners 14 days prior to land applications. This is good.

The legislation proposes a threshold of 50 ppb PFOA or PFOS measured as a 12-month average. This means that if the average value for samples collected over a 12 month period results in concentrations of PFOA or PFOS greater than 50 ppb, then the material in that state is prohibited from land application. It still leaves open the possibility that the material could be blended to achieve lower concentrations below the 50-ppb threshold. In any event, all available sampling data from Maryland and DC demonstrate conclusively that existing concentrations of PFOA and PFOS fall well below 50 ppb. What does this mean? The thresholds are unlikely to constrain the practice of land application of sludge… status quo.

Moreover, the numeric thresholds do not protect human health, the environment, or state waters. That’s the most important point. But this legislation is a good first step, a first try by our elected officials. Hopefully, they can build on it.

Testing = good Farmer disclosure = great Numeric limits = not likely to reduce the amount of sludge applied, nor will they protect public health or water quality HB1072 will modify DEQ regulations and allow those county’s that have Biosolids testing in their zoning Use Ordinance (like Northunberland, Lancaster, Westmoreland (NOT Richmond) to test. -Michael Lightfoot, Hague