City of San Diego
Metropolitan Wastewater Department
4918 North Harbor Drive, #201
San Diego, CA 92106

August 28, 1997

The Metropolitan Wastewater Department has a policy to beneficially recycle municipal biosolids (generated from sewage solids). Biosolids are safe and provide organic carbon and nitrogen to amend soils used in agriculture. including forestry. Although not directly in the "Area of Analysis" we offer the following comments with respect to the "Rangeland Health Standards and Guidelines for California and Northwestern Nevada Draft ElS, dated May, 1997".

Specific Comments:

1. Section 2.2 Water Quality- Best Management Practices

The use of biosolids compost as a soil amendment can be useful in areas of re-vegetation projects to reduce non-point source pollution or to control noxious weeds.

2. Section 3.2.3 Range Improvements and Section 3.3.2 Vegetation

Biosolids In the form of dewatered cake or as biosolids compost can provide a soil amendment to assist in restoring perennial grasslands. The primary benefit is that organic matter is added to the soil structure and nutrients are in a slow-release organic form which limits the potential for nitrate pollution of ground water.

General Comments:

1. In 1990, the US Department of Interior was a member of an Interagency Task Force convened to develop a policy regarding the beneficial use of municipal sewage sludge (biosolids) on federal lands. A copy of the July 2,1992 Federal Register is attached describing the policy.

As you will note:

The weight of scientific evidence supports the presumption that beneficial use of sludge that is permitted by EPA or the States and is of such quality to ensure compliance with the permit does not present a significant risk to the environment when appropriately applied to land".

2. Overall, it may be in the best interests of the BLM and the grazing permittees, to supplement the volume of forage via biosolids application and graze the same number of cows on fewer acres. This would release lands for other (and perhaps) higher uses without any negative economic impact on the cattle grazing interests.

Thank you for the opportunity to provide these comments.

Sincerely,

Larry Wasserman
Environmental Monitoring and Technical Service Division

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