NEBRA Continues Quest To Understand MA Nutrient Regulations
On December 5, 2015, the new Massachusetts plant nutrient management regulations went into effect for agriculture. The portions of the new regulation pertaining to turf grass had gone into effect in June, 2015.  Much of this year, NEBRA staff and members have been trying to learn from the agency responsible for the regulations – the Massachusetts Dept. of Agricultural Resources (MDAR) – to what extent the regulations apply to biosolids and other organic residuals and to what lands they apply. (See prior NEBRA News.)

On December 10th, several NEBRA members held productive discussions with MDAR staff at MDAR's offices in Boston. Key clarifications from that meeting include:

• Biosolids heat-dried fertilizers, such as those produced at Boston's MWRA/NEFCO facilities and by the Greater Lawrence Sanitary Treatment District, are definitely covered by the regulation. 
• All other biosolids and organic residuals - composts, digestates, etc. - are all definitely covered by the regulation.
• The regulations, which are driven by definitions and requirements in law, relies heavily on referrals to University of Massachusetts Amherst (UMass) Extension guidance.  That guidance does not provide much information on the nuances of testing and managing organic residuals.  As an example: A fact sheet on compost analysis, published in November, seems to lead to the conclusion that biosolids and manure composts (composts relatively high in P) will not be able to be used on organic or other farms that have extensively used compost in the past, because those farms will likely test high in soil total P. 
• The impacts of the regulations on biosolids and other residuals will depend, to a large extent, on what test methods for composts, biosolids, and other residuals products are included in UMass Extension guidance.  If water-extractable P is the standard, then biosolids heat-dried fertilizers may show less than the threshold 0.67% P, meaning they could be applied to turfgrass and other areas without the requirement of a soil test showing need for P.  Because they contain abundant iron, aluminum, and/or calcium, biosolids tend to have low levels of the environmentally-relevant water-soluble forms of P that cause surface water impacts. 
• The intent of the regulations is to apply to two types of land:  agricultural (as defined in MA laws and regulations) and non-agricultural turf.  Home gardens are not covered by the regulations.  NEBRA has demonstrated that the language in the regulations is confused about this, but MDAR made this clear on December 10th.

At the December 10th meeting, MDAR agreed to work with UMass Extension – along with NEBRA, Mass Farm Bureau Federation, and other stakeholders – to formulate guidance that clarifies how and where biosolids and other organic residuals products may be used under the new regulations.  For more information, contact the NEBRA office.