Regulation
Contents:
Urine Recycling
Compost toilets
Urine Recycling
We are working to identify regulatory barriers and create permitting pathways for nutrient cycling from human waste at the local, state and national levels.
Safety of Urine Fertilizer
The concentrations of heavy metals and pathogens in urine are very low, while its fertilizer value is quite high. These factors allow urine to be safely used as a powerful fertilizer with only minimal processing– as documented by the World Health Organization (WHO). Unfortunately, many jurisdictions do not yet recognize source separated urine as a material distinct from wastewater or sewage. New regulations are needed to set treatment and reuse standards specifically for source separated urine, in order to facilitate the recycling of urine into fertilizer.
The Environmental Protection Agency’s mission is to protect human health and the environment, and source separation of urine accomplishes this mission better than conventional wastewater management strategies. When urine is flushed into sewers, much of the nitrogen and phosphorus can flow straight through wastewater treatment systems and into our drinking water supplies, lakes, estuaries, and other sensitive aquatic ecosystems. Instead, directing these nutrients to agriculture as urine-derived fertilizer puts nutrients where they are needed and can reduce dependence on synthetic fertilizers.
State-by-state Development
Rich Earth worked with the Vermont Agency of Natural Resources Watershed Management Division to create unique regulatory pathways for permitting the collection, transport, treatment, and land application of urine as a fertilizer in Vermont. We are now working to support the creation of regulatory pathways in other states, using our permits as a model.
Some key milestones from our permitting journey include:
- 2012-13: Received IWMEA (permit for small-scale wastewater experiments)
- 2014: Received 10-year Solid Waste Management Facility permit (SW-266) to pasteurize and distribute urine
- 2013-18: Partnered with Best Septic of Westminster West to transport urine
- 2017: Revised SW-266 to include the Brattleboro Urine Depot
- 2018: Purchased truck; received VT and NH septic hauling permits
- 2020: Secured Innovative/Alternative permit pathway for plumbed installations and barrel urine storage
- 2020: Received approval for pilot installation of Wostman Eco-Flush toilet from VT Plumbing Board
- 2022: Revised SW-266 to include second urine depot and solids composting
National Reform
In addition to supporting regulatory pathways on a state-by-state basis, we are working in partnership with other organizations to promote comprehensive national-level regulatory reform.
Additionally, Rich Earth Institute is working to update code language and policy documents, such as the Uniform Plumbing Code (UPC), to include approved practices for urine recycling. To this end, in 2020 we launched the Golden Ribbon Committee in partnership with Nutrient Networks and Recode. Through this collaborative project, we will work to advance the regulation of urine reuse. Our project goal is to create rules and policies for a national urine reuse standard that can then be adopted into state and local site development and building codes.
In 2023, Mathew Lippincott and the Rich Earth Institute launched an Ecosan Permitting Group. This group convenes via bimonthly Zoom meetings to discuss US regulatory pathways for ecological sanitation, including focus on specific projects and strategies to address their permitting challenges. Fill out this form to join the group!
Compost Toilets
Compost toilets are very common throughout Vermont. However, though Vermonters can have compost toilets, there is currently no permit available for actually turning their solids into compost. While home gardening with urine fertilizer is fully allowed, gardening with humanure compost has no legal pathway.
Rich Earth participates in the volunteer Vermont Eco-San Working Group to support the creation of new allowances and best management practices for compost toilet management. We are advocating for the passage of H. 163, which would establish working group to navigate regulatory pathways and define best management practices, based on guidelines developed across the country to ensure health and safety.
The 2023 sponsors of this bill were: Rep. Mollie Burke, Rep. James Gregoire, and Rep. Lucy Boyden.
The Working Group includes: Chrissy Wade (Master Composter), Deb Neher (UVM, Plant & Soil Science), Joe Ducharme (Clivus), Tom Mosakowski (helped introduce bill H. 164), Sheri Young (DEC TAC), John Medose (VT State Parks), Julia Cavicchi (Rich Earth Institute), Composting Association of Vermont (CAV), and more.
Current allowable compost toilet management options are:
- Landfill: limited availability (only one landfill in Vermont); contributes to methane emissions & climate change
- Wastewater Treatment Plants: limited availability, may refuse to accept waste (*In 2022, Rich Earth received Vermont’s first permit to compost community-collected toilet solids at our Research Center as a solid waste management facility.)
- Shallow Burial: permit for burying solids; expensive to procure; lacks guidance for storage and management (especially during winter); many homeowners report unclear pathway to obtaining the permit, including reluctance from wastewater engineers to pursue this permitting pathway
Why are compost toilets important for Vermont?
PROTECTING WATER RESOURCES: Toilets are the largest single user of water in homes. Rather than wasting precious potable water, we can collect our waste with waterless toilets.
COMPLETING THE NUTRIENT CYCLE: Composting toilets reclaim our “waste” as a resource. When flushed, our waste causes nutrient pollution in local water bodies. When composted, our nutrients and organic matter can be returned to the soil.
BUILDING CLIMATE RESILIENCE: Vermont’s current wastewater systems are contributing to climate change. 55% of all Vermonters are on septic systems, the contents of which must be regularly pumped and hauled – sometimes over long distances to landfills, wastewater treatment plants, or incinerators. Wastewater treatment plants are highly energy intensive, vulnerable to the impacts of climate change (e.g flooding & combined sewer overflows). Compost toilets can offer a climate-friendly solution to managing our waste onsite. Smart growth (compact village settlement) is a key strategy for reducing habitat fragmentation & increasing access to local resources; this is particularly important as VT prepares to be a recipient state for climate migrants. A primary barrier in VT to this smart growth is the lack of space for wastewater infrastructure (check out ANR Secretary Julie Moore’s opinion piece on this). On-site waste management & use can be an affordable tool for enabling compact village settlement.
Developing Best Management Practices
Composting can be safe and effective way to to return nutrients from the toilet to the soil, protecting both human and environmental health. By collaborating with regulators and existing compost toilet users, we hope to support the creation of guidelines for compost toilet solids management.
Pathogen-kill can be achieved through following best management practices (either through monitored hot composting or time & storage). Published guidelines and regulatory pathways will enable safe at-home composting and support for new practitioners.
Through the VT Eco-San Working Group, we have already supported the creation of new best management practices for backcountry mouldering toilets in Vermont State Parks, which previously lacked guidelines. Through collaboration between Vermont Forest Parks and Recreation (VPFR) and Vermont Department of Environmental Conservation regulators, new guidelines were cerated to enable the management of solids on-site. This helps VPFR avoid risks associated with ‘packing out’ material, inducing spills/releases to surface waters or other sensitive areas, and additional handling of material by park staff.
Webinar
In this webinar, the VT Eco-San Working Group introduces our advocacy for composting toilet permitting pathways in Vermont. In this presentation, we cover the environmental and societal benefits of ecological sanitation for Vermont, the safety of humanure composting, and current regulatory options. We conclude by discussing how Vermonters can advocate for two bills in the Vermont House (H.163 and H.164), which would create new allowances and best management practices for humanure. Presenters include Chrissy Wade (Master Composter & working group leader), Deb Neher (UVM Plant & Soil Science Professor), Julia Cavicchi (Rich Earth Institute’s Education Director), and Tom Mosakowski (H. 164 advocate).