Note: To download a copy of the original Word document,
right-click on the link below and choose "Save As..."
(Word Document, 64KB)
The Word document is write-protected.
When opening the document, choose "read-only" when prompted.

February 20, 2002

Dept. of Land Use and Transportation

Washington County

155 N. First Ave. #350

Hillsboro, OR 97124

Subject: Casefile # 01-535 — Nature's Needs Humus Facility

Friends of North Plains appreciates the opportunity to offer testimony regarding the Nature's Needs humus facility. Our testimony centers on five topics: benefit to the community, commercial viability, traffic, required road improvements, and odor complaints.

If our society is to learn how to exist without compromising the earth's future ability to provide for our needs, we must aggressively learn and practice organic and sustainable farming methods. Reprocessing food and wood waste reduces the load on our landfills. We must consider the long-term good of the greater community and the earth when passing judgement on such innovative activities. Indeed, part of North Plains' vision is "to become Oregon's first sustainable city". We believe that Nature's Needs is leading the way toward the City's realization of that portion of its vision.

The facility's products have received an approval listing from the Organic Materials Review Institute (OMRI, Eugene, OR). The facility performs regular, extensive laboratory testing to ensure their product is of high quality. These are not actions that would be taken by a landfill operator. Our members have purchased and used Nature's Needs' products, and the facility has a large and growing list of satisfied customers.

(continued on next page)

1. The facility is an agricultural operation, and odors are often a normal part of agricultural operations. Consider dairy, hog, and cattle farms, for example. Fertilizers, pesticides, and field burning are allowed operations that produce far more disagreeable (and more harmful) odors than those produced by the facility. North Plains is a small town completely surrounded by agricultural lands. While no one enjoys agricultural odors, those located close to an operating agricultural facility should be able to tolerate a certain amount of odor.
2. The facility has taken many steps to address this issue, including hiring odor consultants, being more selective about what types of waste are accepted, and more aggressively covering windrows after turning them. It is our understanding that the facility is making progress in addressing most complaints. We believe that the facility is making good faith efforts to address odor complaints and is trying to be a good community citizen.
3. We understand that odor complaints were filed before the facility even began to receive material for processing. If this is true, we believe it is extremely important that the County consider possible motivations for such complaints, and to consider subsequent complaints from the same sources with a healthy degree of skepticism.
4. It has proven extremely difficult to isolate or even prove that the objectionable odors are indeed coming from the facility. Given the elusive and inconsistent nature of the odor problems, we believe it is reasonable to consider other possible odor sources in the area. These include:
• The wetlands southwest of the facility. Water levels in this area constantly fluctuate with the amount of rainfall. As water recedes, it may displace odorous sub-surface gases, releasing them into the air. The standing (and often stagnant) water that is common during dry periods may contribute to perceived odors.

  The wetland is also a storm water discharge site for the City of North Plains. High runoff may bring other materials into the storm water waste stream, and hence into the wetland.

  Note that Valley Machine Service, the source of many odor complaints, is located just north and west of the wetland.

• Other nearby facilities. For example, we understand that the nearby Van Dyke Seed Company facility also processes waste materials, including fish waste. An unaffiliated entity just to the east of the facility is also stockpiling a very large amount of wood chips. This material is not being covered or managed in such a way as to minimize decomposition and its related odors.
• The Clean Water Services (USA) pumping station located just south of the facility.

We believe that the odor complaint process should be modified to emphasize problem solving and problem resolution rather than merely incident tracking. Since the odor source is so elusive, we would like to see the County promptly notify the facility when a complaint is received, so that a timely investigation may be conducted. This would facilitate efforts to correlate odor complaints with on-site as well as off-site activities and conditions.

As we've stated, we believe this facility is an asset to the farming community whose value will only increase in the future. It would be a mistake to revoke its permit solely because of odor complaints. If the County is uncomfortable granting a permanent operating permit due to this issue, we recommend that the temporary use permit be extended for another year, after putting in place an aggressive, solution-oriented problem reporting process.

Thank you for considering our comments.

____________________________________

Brian Beinlich, on behalf of the Friends of North Plains Steering Committee