RESPONSE SUMMARY - Puget Sound Clean Air Agency

RESPONSE SUMMARY 

ORIGINAL DRAFT ORDER OF APPROVAL NO. 10052 

Comment Period – April 29 - June 15, 2010 

Comments Received on Draft Order of Approval 10052 

The Puget Sound Clean Air Agency published a request for public comment on April 29, 2010 in 

the Seattle Times, The Daily Journal of Commerce and in the Maple Valley & Covington 

Reporter. A public meeting to receive oral comments took place at the Maple Hills Elementary 

multi-purpose room on June 3, 2010 between 6:30 and 8:30 PM. Written and oral comments 

were received from 38 commenters, including a response to the Oral Comments given in writing 

to the Agency from Cedar Grove Composting, Inc. Specific responses to some technical 

comments received from the Seattle-King County Dept. of Health (Bill Lasby) are included in 

the table below next to the comment. The remainder of the comments (shown below) have been 

reviewed and responses prepared in a summary fashion at the end of these comments. 

Commenter 

Seattle-King County 

Dept of Health – Bill 

Lasby, Supervisor Solid 

Waste & Vector 

Nuisance Program 

(Written, June 15) 

Clean Air Agency 

Response 







Comment Synopsis 

Page 2: B.6. is INCORRECT and needs to be changed. Co-mingled 

yardwaste and residential foodwaste is ONLY allowed in Building 7 

and under GORE. I have never approved them to put POST-consumer 

foodwaste into the Zones 1-6 system. Only pre-consumer foodwaste 

(from grocery stores) are allowed in those zones. 

This comment is directed at a summary statement highlighting a request 

made by Cedar Grove in their application materials rather than a 

conclusion reached by this Agency. We appreciate the Department of 

Health’s comment and therefore we look forward to seeing that level of 

clarity added to their permit for Cedar Grove, which is currently 

pending issuance. Our response to this request was to provide 

clarifying language in our document. However, we cannot change or 

modify the Department of Health’s permit through this action and the 

permit renewal that is pending from the Department can clarify this 

confusion for Cedar Grove. No changes made based on this comment. 

Page 4: H.3. Although we have a regulation that discusses nuisance 

odors beyond the property boundaries, the source of the odor needs to 

be located. If the odor is coming from their finished product, it is no 

longer considered a solid waste and is not under the solid waste 

regulation under our jurisdiction. Even if the finished pile had gone 

anaerobic for staying stagnant for too long being saturated with rain, it 

was ruled in court when Snohomish Co. was involved that because the 

finished pile was a product, it no longer was under the purview of the 

solid waste regulations. 

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Commenter 

Comment Synopsis 

#16. is INCORRECT and needs to be changed. It states that secondary 

zones can accept compost for second phase treatment from primary 

Zones 1-7. Zone 7 has post-consumer foodwaste commingled with yard 

waste and should ONLY go into Gore for treatment. This statement 

needs to say, "...only from Zones 1-6. 

NOTE: On page 5 of NOC Worksheet, I.1.b. states that no postconsumer 

foodwaste would be in the primary or secondary zones, which 

is accurate and contradicts what is stated in the Order of Approval on 

page 4. 

Clean Air Agency This Agency appreciates the clarification by the Department of Health 

Response regarding their interpretation of Ecology’s rule regarding odors from 

composting operations. The worksheet identified it as a solid waste rule 

and not enforceable under the statutory authorities provided to this 

Agency. The Agency disagrees with the additional comments regarding 

post-consumer foowaste and the Zone 7 operations. The Agency 

believes that its records indicate post-consumer food waste has been 

approved in Zone 7 and that it would include use of the secondary zones 

to complete that composting for Zone 7 materials. The comment 

regarding the comments on pages 4 and 5 is referring to a historical 

summary of permit actions taken by this Agency over the life of this 

facility. The permit history reflects changes in the site development and 

operation and cannot be taken out of context. No changes made based 

on these comments. 







Page 6: 4.c.(1)ii, seems to imply that loss of electricity is only 

associated with a storm event. Consider inserting umbrella wording to 

cover other scenarios 

(e.g. "and for periods when electricity is lost after a storm event or other 

circumstance causing a power outage"). 

Clean Air Agency 

Response 

This comment refers to condition language derived from a previous 

SEPA review and determination which reflects mitigation terms which 

were previously approved. This proposed Order of Approval was 

published on the conclusion that the previous SEPA determinations 

were adequate for this proposed action and that a new SEPA 

determination was not being made at this time. Thus, editing previously 

approved SEPA mitigation language would necessitate a new SEPA 

review, which is not proposed at this time. No changes made based on 

these comments. 

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Page 8: The item 7 text contains two occurrences of upper case letters 

“IS”. Do these represent a typographic errors? In the last sentence of 

#7., the word "this" is missing after the last comma. In the first sentence 

of #9., the word "by" is missing after the word, "required". 

Clean Air Agency These observations were typographical errors and have been fixed. 

Response Additionally, the original proposed Condition No. 9 had a reference to 

the “Settlement Agreement”, which has been changed to the “Order”. 

Changes made based on these comments. 

See Summary Response at the End of this Document for the rest these 

Comments (starts on p. 22) 

Cedar Grove 

Composting, Inc 

Comments on Public 

Notice for Draft Order of 

Approval No. 10052 


Cedar Grove’s Commitment to Maple Valley: 

· Cedar Grove has spent at least $1 million in upgrades each year 

during the past 10 years at the Maple Valley facility. In one 

year, the company spent $5 million on upgrades. 

· Cedar Grove employs a full time odor specialist working in 

downwind locations from our facility, tracking and observing 

not only the Cedar Grove facility’s odor but odors from other 

sources. 

· Over the last two years, Cedar Grove developed and expanded 

upon an odor investigation protocol that allows us to thoroughly 

research information surrounding an odor complaint. Using three 

computer-controlled weather stations, we are able to match 

meteorological data with the time of complaint and location of the 

complaint to help us identify odor sources. With this real time 

information we have concluded that up to 75% of the complaints can 

not be substantiated due to meteorological conditions making the 

complaint impossible. While it is possible that people are smelling 

something, it cannot be attributed to our composting activity. Secondly, 

when odors are encountered, they are for a brief period of time and 

clearly are not inundating the neighborhood for hours on end and day 

after day as some resident have claimed. Most complaints come from 

less than 30 residents and many will not even consider the fact that the 

wind is blowing in the wrong direction for Cedar Grove to be the 

source. They have already made up their mind that what they are 

smelling comes from Cedar Grove and they do not want to 

acknowledge the possibility that they may be wrong. 

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· There are eight other odor sources in the immediate area of the 

Cedar Grove facility, including King County’s Cedar Hills 

landfill, which is located right next door. 

· Notwithstanding some of the comments made at the public 

hearing, multiple studies have demonstrated that odors from 

composting operations are not injurious to public health or to 

Cedar Grove’s own employees. 

· Cedar Grove utilizes state of the art composting technology 

that has been determined to be Best Available Control 

Technology by PSCAA. Assertions that other composting 

facilities use higher end technology and therefore do not have 

odor complaints are misguided. Cedar Grove utilizes in many 

cases the exact same technology, but faces additional challenges 

when compared with other operators, e.g., lower population 

densities, much lower tonnage being processed, smaller foot 

print, lack of finished compost storage on site, and wind 

directions that blow to agricultural areas instead of housing 

areas. These are just a few of the differences between our 

facility and other composters. 

Cedar Grove 






· This permit calls for many of the items that the neighbors have 

been requesting. 

o 

o 

o 

o 

o 

o 

Indoor receiving 

Indoor grinding 

Reduced dust from new screening operation 

Third party review of our operations (biofilters) 

Specific and detail inspections on a daily basis 

Quick corrections to deficiencies noted 

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Cedar Grove 






Cedar Grove 






Cedar Grove’s Commitment to the Region: 

· Cedar Grove’s Maple Valley facility serves over one million 

people in King County. 

· Five thousand customers each year buy Cedar Grove Compost 

to spread on their yards and gardens. 

· Cedar Grove’s mission is to create quality compost for 

consumers, businesses and municipalities. We also see ourselves 

as recycling educators in the Puget Sound region. 

· Cedar Grove takes yard debris and unwanted food scraps, turns 

them into a beneficial soil amendment and puts them back into 

local yards, gardens and parks. 

· Since our founding in 1989, Cedar Grove has led the way in 

bringing yard waste and food waste composting to the 

Northwest. 

· Cedar Grove is pioneering a sustainable model for recycling in 

the U.S., facilitating commercial zero waste initiatives, creating 

green jobs, keeping organic waste out of the landfill and offering 

quality compost to residents and businesses. 

· Composting is a key part of protecting our Puget Sound 

environment. Thanks to the efforts of residents and businesses in 

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Puget Sound, Cedar Grove has kept 4 million tons of food and 

yard waste out of the landfill since our founding in 1989. 

· Composting those 4 million tons of organics has prevented 3.72 

million metric tons of greenhouse gas emissions from entering 

the environment. Those emissions are the equivalent of 

removing about 67,000 cars from the road a year. 

Petition to the Puget 

Sound Clean Air 

Agency 

65 Petitioners 

(Received June 3, See 

Appendix 13) 

Linda Rasmussen 

Project Coordinator 

YWCA Passage Point 


The undersigned Respectfully, but resolutely request the Agency to take 

all necessary actions to cause the Cedar Grove Composting Company to 

cease emitting odors, utilizing the statutory power granted them by 

Washington State law. Up to and including obtaining an injunction for 

them to cease all operations until the problem has been solved. We 

make this request to defend the health of our families, to safeguard the 

value of our homes and to protect our right to the use and enjoyment of 

our property. 

The YWCA Seattle|King |Snohomish is providing comment on the draft 

Order of Approval No. 10052 regarding Cedar Grove Compost 

operations in Maple Valley Washington. 

Our agency is participating in the reuse of the facilities formerly used as 

the Cedar Hills Alcohol Treatment Center located on the eastern end of 

the King County Solid Waste Landfill. We anticipate opening 46 units 

of transitional supportive housing for low income households at that 

location beginning in June 2011. 

We are providing comment because we understand that Cedar Grove 

operations in the area emit strong odors that are described as causing 

nausea and making it impossible to have windows open or to spend time 

out of doors. While we have not had this experience; we are concerned 

and want to comment that we hope Puget Sound Clean Air Agency will 

take this opportunity to compel Cedar Grove Compost to make the 

necessary changes in their operations to prevent, reduce and eliminate 

extremely unpleasant odors to the surrounding area. 

Based on data about the health circumstances of low income and 

homeless persons as well as our own direct experience as a provider of 

services to this population; the YWCA is concerned that adults and 

children with poor health will be exposed to odors that may limit their 

ability to live in comfort in our housing at Cedar Hills. We are also 

concerned that our YWCA staff might be exposed to these odors on a 

long term basis, causing staff turnover due to an unpleasant work 

environment. 

The YWCA supports environmentally supportive enterprise, such as 

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composting and recycling. However, we believe that such endeavors 

should not be at the expense of the enjoyment of the environment. Our 

staff has heard that there are commercial composting operations in other 

locations in Washington that do not emit the odors that are typical of the 

Cedar Grove Compost operations. 

Howard and Diane 

Sheridan 

(Written, May 2) 

Cedar Grove Compost on Cedar Grove Road in Maple Valley, 

Washington, has been a very horrific experience for us and our 

neighborhood. 

On clear days, especially if they are warm, the stench coming from 

Cedar Grove Compost is unbearable. You cannot go outside and enjoy 

your yard, sit on the back deck, or even open the windows to the 

house because of the stench/odor. Not only is the smell putrid, it is 

nauseating and burns the eyes, the sinuses, the throat and lungs. This 

CANNOT be healthy. It is a terrible shame that we have to hide 

indoors. 

Not only does this affect our lifestyle and our health, it also affects our 

home values. Who would want to live in our neighborhood? 

Clearly, Cedar Grove Compost has failed to meet clean air standards 

and the permit should be denied. 

Bob and Sue Liebling 


I am a resident of the 4-lakes community on Cedar Grove Rd., about a 

mile and a half from the Cedar Grove Composting (CGC) facility and I 

understand that you are about to issue a renewal permit to them for their 

operations. For several years, my neighbors and myself have 

experienced the air quality around us deteriorating as CGC has 

continued to operate. I must strongly emphasize the need to better 

regulate and enforce the provisions of their permit to eliminate the 

noxious odors they create. This is not only a nuisance but is 

detrimentally affecting our property values and quality of life. 

The new permit should address the following issues: 

1. The operation and odors emanating from their processing. 

2. Define strict engineering standards that must be adhered to, or a 

violation is incurred. 

3. Define when CGC is responsible for a violation, and what happens 

when one occurs. 

4. Increase your enforcement roll to protect the air quality of our 

neighborhood. 

5. Limit the amount of "wet garbage" that can be processed, until a new 

and better process can be installed. 

In the last 3 years I have noticed an increase in the frequency of the 

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odors. Prior to that period, it was only in the summer months that we 

experienced the odors and now it's during the whole year. I think there 

is a direct correlation between the increased frequency of the odors and 

their processing of "wet garbage", and you must address this problem in 

the new permit. I realize you must balance the refuse needs of our 

society at large with the impacts from its processing. We appreciate 

their business necessity and the work they do, but they must act as 

good neighbors since they are located in a residential area. I want to 

request that you require CGC to install better processing procedures, 

like at the LRI Landfill in Pierce County that some of us toured last 

week, as their current operations aren't adequate. 

Heidi Kerr 


Jo Esta and Chauncey 

Deschenes 


Tara Bingham 


I am extremely concerned about Cedar Grove Compost. I am aware 

that they need to renew their permit. As a property owner paying 

exorbitant real estate taxes I feel I should have some rights as to the air I 

breathe on said property. I strongly believe that the permit should 

address the odor issue. Try to imagine what it is like to want to enjoy a 

quiet evening on your deck only to be driven inside by a putrid odor. 

You will also need to close all doors and windows. I have felt 

frustration in the past after calling to report a stench only to be told that 

an official has to be here and smell it at the time of occurrence. This is a 

heartbreak for me and I would appreciate your utmost concern on this 

matter. 

I am an 85 year old woman with asthma and COPD. On the many and 

frequent days that Cedar Grove composting company emits strong 

odors, I have difficulty breathing. I have relied upon my neighbors, to 

bring this to the attention of the agency, but both they and I are 

frustrated that the problem does not seem to be improving, despite 

numerous promises from both the agency and Cedar Grove. 

I implore you to take any action necessary to eliminate the odor 

problem. The agency is the single hope that we have, short of 

shouldering a law suit on our own. Please, please take the steps 

necessary. 

I would like to add my voice to the growing concern over the stench of 

Cedar Grove Composting Company, which is located a short distance 

from my home in the Four Lakes community in Issaquah Washington. 

We bought our house in 2003 and proceeded to spend a great deal of 

energy, sweat and about $100,000 to renovate it. Part of our renovation 

included an updated deck and concrete patio on the east and north sides 

of the house. Yes, we were aware that there was an “odor issue”, but at 

that time on even the worst days it wasn’t bad enough to interrupt our 

lives. Over the past three years though, that has definitely changed. 

We like to entertain, so we thought that we’d be enjoying our outdoor 

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eating areas with our friends and neighbors on sunny days. However 

that has not always been possible. The effect of the smell from Cedar 

Grove Composting is not something easily described, but I will try to 

illuminate you. 

Imagine if you will, the nauseatingly sour odor of rotting garbage, 

vegetation, and probably dead animals, floating by and assaulting your 

nose and making your eyes water while trying to enjoy, say – a $50 

salmon filet that has been carefully grilled on our your BBQ. First your 

nose wrinkles, then your face makes a rather nasty grimace, and finally 

you have lost your appetite. Then you look up and see that all your 

guests have the same look on their face. Your event is cut short or 

everyone moves back into the house. This is what we experience when 

the cloud of stench is blown our way, and unfortunately it’s happening 

more and more. Also, we have my 83 year old mother living here in 

our mother in law apartment. On days when the odor is its worst, which 

is almost always when the sun is out, she is unable to sit on her deck 

because the odor bothers her breathing. 

In theory, in the State of Washington and probably elsewhere, a 

landowner’s rights extend to the upper limits of the sky. In practice this 

is not exactly true since congress created the Civil Commerce act of 

1926 and the Civil Aeronautics Act of 1938. Since then landowners still 

have exclusive right to use the lower reaches of airspace over their 

property, as long as it doesn’t interfere with normal air traffic. On the 

other hand, sometimes air traffic interferes with the normal use of their 

land, and in that case, we are able to sue for damages. 

I believe its clear that Cedar Grove Composting is interfering with the 

normal use of our land and lower air space. If your agency allows 

Cedar Grove to continue with its ineffective odor management methods, 

a law suit is exactly what will have to happen to stop the infringement 

upon our rights as land owners and I can certainly see that the Puget 

Sound Clean Air Agency may also be liable. 

Now is your chance to really make a difference and prevent this issue 

from growing into a bigger and more costly problem for all involved. 

The way I see it, Cedar Grove Compost should not be allowed a new 

permit unless 1. They are required to pay all fines incurred up to this 

point. 2. They immediately and regularly invest in better technology 

that will effectively contain their nuisance odors. 3. They are more 

effectively regulated by your agency and the King County Health 

Department, being continuously reprimanded and fined until they stop 

polluting the air. 4. They keep their nasty piles of debris covered – 

period. 

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Your attention to this letter and those like it are greatly appreciated. We 

are standing up for our rights as tax paying landowners. Please take 

note and stop the permitting process unless appropriate conditions are 

met, and if those conditions are not met, shut them down. 

Michael A. Jaeger 


Joy D. Garner and 

Family 


Joseph and Nancy 

Bostjancic 


I am writing to address concerns regarding air pollution caused by the 

above mentioned facility. My nan1e is Michael Jaeger and I reside just 

off of Cedar Grove Road at 24201 SE 1 64th Street, Issaquah 

Washington. My family and I have lived at that address since October 

2000. Although there is a mechanism for reporting the odor caused by 

this facility, the reporting process appears to have had little impact on 

the frequency and severity of the pollution. Over the last 10 years, the 

odor violations have continued on a regular basis. I understand Cedar 

Grove Compositing is applying for a new permit to operate and this is 

to request the permit be denied or severely restricted. Frankly, I'm tired 

of my family being exposed to this pollution and not being able to walk 

out of our home, or open a window, without smelling the foul stench 

created by this facility. It is unclear who is responsible for these 

violations, but it's obvious the Puget Sound Clean Air Agency (PSCAA) 

has failed to establish strict enough engineering standards or 

enforce whatever standards, if any, are currently in place. PSCAA is 

responsible for protecting the air quality and the folks that live in this 

area would appreciate it if the agency would vigorously pursue that 

mandate. 

We approve of recycling and composting and anything done for the 

good of our environment, but I am writing this letter to you to let you 

know about the offensive odors coming out of Cedar Grove Composting 

in Maple Valley, WA. We live at 4 Creeks which is just off SE May 

Valley Rd and Issaquah-Hobart Road. Many days for years now we 

have had to endure the odors, just when the weather turns nice & you 

want to spend time outdoors… out comes the stink a& ruins the day. 

It’s especially embarrassing when we have guests, not to mention the 

potential health problems that could occur fro breathing this foul air. 

We enjoy living in Issaquah and we were here long before Cedar Grove 

Composting moved in and we would be so thankful to have this 

problem resolved. 

In addition to my verbal comments made at Maple Hills Elementary 

School on June 3, 2010, please know that I am against Cedar Grove 

Compost processing food waste on its Maple Valley site as the odor 

situation has not improved. Please read and re-instate my attached 

letters of Sept. 21, 1997 to PSCA and Feb. 25, 1998 (CC to PSCA) that 

are still applicable. The air quality in the Issaquah Hobart Valley has 

improved little since these letters were delivered to PSCA. LRI of 

Puyallup operates an enclosed odor free facility. Harvest Power of 

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Richmond, B.C. uses in-vessel composting to capture odors and gas to 

produce electrical energy with guarantees of "no odors." Other 

industries that have emissions to the atmosphere must comply with the 

Clean Air RCW and laws of the national EP A. Why is Cedar Grove 

allowed to continue with unlawful activity that is 17 times more 

detrimental to destruction of the ozone layer than carbon dioxide? 

Food waste generators can purchase Hot Rot "In Vessel" compo sting 

equipment, install the equipment on their site and sell product locally. 

Thus, reducing transfer costs and carbon emissions as it can be 

processed and utilized locally. Again, Cedar Grove Compost is not 

capable of policing itself. Therefore, Cedar Grove needs to comply or 

cease operations until a facility can be established that is truly 

sustainable and does not impact the use of neighboring properties for 

approved non-offensive intended uses. 

Helen Scott 


Kara Mulqueeney 


We were part of the Class Action Lawsuit Settlement in 1999 with 

Cedar Grove Compost. The odor problem etc. has gotten better since 

that time, but we still smell Cedar Grove at our home several times a 

week. I have called Sandra Hector, Cedar Grove Composting's Odor 

Control Specialist. She has come out to our house. There was one time 

she blamed the odor on Cedar Hills Landfill, saying it was a garbage 

smell. When Cedar Grove is now accepting food waste, how can they 

decide whose garbage smell belongs to which place? Drive along 

Cedar Grove Rd. and you can certainly tell it is coming from the 

compost facility. I have picked up the smell as far South as Maple 

Valley. I don't feel Cedar Grove Compost is holding up their side of the 

lawsuit that was made back in 1999. It is hard to work in one's yard or 

go outside, when the smell is so bad. I hate to see my grandchildren go 

to Maple Hills Elementary School, where the smell also exists many 

days of the week. This air quality needs to have something done about 

it and now. 

We have tolerated odors from Cedar Grove Composting Company for 

too long. Complaints seem to fall on deaf ears, our children complain 

and sometimes won't play outside due to the smell and our poor 

elementary school gets hit hard with an odor that's just plain disgusting 

some days. While other company's seem to be able to control their odor 

emission and have few public complaints, Cedar Grove has yet to 

resolve the issue. Which brings up the current concern for the new 

permit; it doesn't appear to change the process by which they will 

control the odor, and the permit doesn't define who holds responsibility 

when there is a violation of odor, or show enforcement penalties or 

provisions. 

Page 11 of 27

Debra Hawkins 





I live off Cedar Grove Road and on many occasion smell the horrible 

odor of Cedar Grove Compost. There have been days that the odor is so 

bad that I have to close any windows that are open and spend the day in 

the house. When I go to my daughters school I realize that we don’t 

have it that bad…..the smell at Maple Hills Elementary is horrible. My 

daughter has complained on many occasion that the smell was so bad 

that she didn’t want to go out for recess. Kids need time outside to 

blow off steam and I think it is terrible that she doesn’t feel comfortable 

to do that on some days. I am concerned about the permit: Please hold 

Cedar Grove Compost more accountable for the odors that leave their 

facility. The range of the smell that leaves their facility is huge and I 

don’t see the problem lessening. 

David Bluhm 


We moved into the above address in July of 2005 and were told, with 

documented support, that a prior settlement had been reached between 

the local residents and the Cedar Grove Composting site over poor air 

quality. And more importantly, that the issues directly related to the air 

quality had been addressed through improved process management at 

the composting site. 

While we are not able to compare our air quality to that which was prior 

to the settlement, we receive a constant and predictable odor from the 

site. We have reported these odors consistently over the last 5 years 

through both phone and written communications to the PSCAA. Any 

warm day, even without any significant wind, brings a strong, pungent 

odor from the site. 

We have no issue with the current land use. We even welcome the 

presence of a composting site in our area but the odors can and should 

be addressed as previously determined by the PSCAA and defined by 

the settlement agreement. The overall community’s air quality, the 

liability of Cedar Grove Composting as well as the liability of the 

PSCAA are all in question in this matter. 

What must be fixed? 

1. The odors must be abated and the overall air quality improved 

2. Responsibility for non-action or ongoing failure must be 

assigned. 

3. Penalties must be established. 

At this point, we hold the agency, as much as Cedar Grove Composting 

as responsible. 

Page 12 of 27

Ken Naito 





I smell the Cedar Grove compost odor on a regular basis. It is a foul 

and disgusting odor and it ruins the experience at my house. Often I 

will walk outside my house to enjoy nature on my 2.5 acres only to 

have my happiness diminished by compost odor. Sometimes I get in 

my car and leave because I can’t deal with it. 

I think Cedar Grove Compost should fix this problem. 

Paul F. Beuter 


Scott Duncan 


Debby Duncan 


Jeff Larson 

(In writing, June 14) 

Four Lakes 

Landowners 

Association - Terry 

Deschenes 

(In writing, Received at 

the public hearing June 

3) 

Please do the right thing and do not renew the Cedar Grove Compost 

permits. The negative impact that they have imposed on the people of 

King County has gone on for too long. The time is now for the 

opportunity to stop the stench that this organization releases on the 

surrounding communities. Please do not renew their permits. 

I would like to express concern about the compost odor. We moved into 

Maple Hills last year and were quite disappointed from that first day on. 

The smell of the composting material is quite strong at times and causes 

my nose and sinuses to feel restricted and irritated. 

I live in the Maple Hills neighborhood, and have been for over a year. 

Many times I can smell the odor from Cedar Grove, and I must say that 

it is obnoxious and somewhat intolerable. I love being outdoors, and 

sometimes I just don't want to be when this smells. Please stop the 

odors. 

I would like to voice my concern about the smells that emanate from the 

Cedar Grove facility. I live in the Maple Hills subdivision and some 

days the smell is so strong that we curtail our outdoor activities. 

Unfortunately, I was unaware of the smell when I purchased my home 

but now have no choice but to live with the consequences. I hope your 

organization is working to prevent the on going issue and that part of 

the current open permit review process addresses it. 

1. Since 1988, Cedar Grove Composting has had 7,725 complaints, 

virtually all for odor. 

2. In the past year, May 2009 to May 2010, there have been 7,725 odor 

complaints, with 80 coming in last month. 

3. The proposed permit does not define who has responsibility when 

there is a violation. Is Cedar Grove Composting allowed to emit odors 

so long as they have complied with the operating plan and engineering 

requirements specified in the NOC? 

4. What happens when there is a violation? The people in our 

community have been making complaints since Cedar Grove began 

operations. For all we can tell, we are simply whistling in the wind. 

There is no feedback loop in the PSCAA process that tells us what is 

being done. 

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5. PSCCA is clearly spending a great deal of time and money on 

reviewing the engineering of Cedar Groves' permit request. From can be 

seen, the Agency has been diligent in doing that. Where are the same 

efforts at the enforcement side of things? When inspections are made, 

there are clearly numerous and serious violations. Why aren't they being 

inspected more often? 

6. If a tree falls in a forest, is there a sound? This old riddle has a new 

counterpart in our community: If you can smell the stench of Cedar 

Grove, does it really smell if there is no PSCAA inspector smelling it as 

well? The fact is that a great deal of the odor problems come after hours 

and on the weekends. (I personally suspect that is because they have not 

moved all of the material in the tipping area inside, but I have no 

firsthand knowledge.) PSCAA is getting the reports, but there is no one 

there to bring their tightly calibrated olfactory organ out to tell us "yep, 

it stinks! 

7. This is having serious impacts on the value of our homes. I have 

firsthand knowledge of an individual in our neighborhood had two real 

estate deals fall through. The information he received from the real 

estate agent was that it was a result of the odor problems experienced in 

our neighborhood. He had to sell at a substantial ($100 K) reduction to 

sell the property. Bad times for selling a house, you bet, but clearly the 

odors are having a harsh impact. 

8. The odor is so overwhelming at times that it is impossible to be 

outside. Clearly we are being denied the right and freedom to enjoy our 

own property. 

9. Many of the parents in our community have reported the elementary 

school frequently has to keep the kids inside because of the smell. 

10. This issue has already been resolved in a class action law suit, filed 

by residents of the area, with Cedar Grove having to pay an enormous 

amount of money. Part of that settlement was that Cedar Grove would 

make the necessary changes to eliminate the odors within three years. 

That deadline has long since passed and by the number of complaints 

being filed, Cedar Grove has failed miserably to meet their 

commitments. 11. The agency has told us Cedar Grove was making 

changes last year and that by the end of a very smelly summer, the 

odors would be eliminated. It did not happen. 

12. It's obvious to me and to the overwhelming majority of the Four 

Lakes community that Cedar Grove Composting's failure to meet the 

requirements of the law suit, their lack of compliance with their own 

operating plan, and their cavalier response to numerous complaints, 

Page 14 of 27




means their word should not be trusted. We believe it would be 

appropriate that they post a bond against odor complaints, which the 

Agency would have access to anytime a citation/penalty is issued. 

13. I, and two- other Four Lakes community members had the 

opportunity to tour the LRI facility in Puyallup. The PSCAA also is 

responsible for monitoring their composting efforts as well, so I'll skip 

all the details of what we saw. The inescapable truth is that composting 

can be done effectively and without being the terrible neighbor that 

Cedar Grove has proven to be. They have had one (1!) complaint since 

2008. There is a new medical clinic less than a block away and a 

housing development on a hill above the site and probably two blocks 

away, both built after the composting site was. They produce a very 

high quality product in 35 days, accept material from any resident of 

Pierce County - for free and operate at a profit. The point being that the 

technology exists to accomplish these results and has for some time. 

14. If the Cedar Grove Composting's technology is capable of achieving 

the same results of LRI's operation, then clearly it is the management 

and operating plan that are at fault. Their history makes plain that they 

will not comply unless forced to do so. Financial penalties have been 

levied without any apparent change in their behavior. The Agency 

needs to escalate their enforcement efforts. 

15. I don't believe that the people in the area are looking to see Cedar 

Grove Composting permanently closed. We recognize the need for such 

a facility and support stated ecological goals. However, we feel that the 

people of Seattle and King County should pay whatever fees are 

necessary to see that it is a good neighbor to those of us living here. 

Clearly Pierce County has proven it can be done at a profit. 

16. I believe that the people of our community have proven to be 

extraordinarily patient with seeing this problem resolved. First waiting 

for the three years after the class action suit, then waiting for promised 

improvements, and now waiting for this hearing. I believe that patience 

is exhausted. Certainly mine is and I intend to pursue this issue, 

encouraging as many people as possible to join me, until the problem 

has been resolved to our satisfaction. 

17. It seems tp me that this is the time and place where the problem can 

be addressed in a rational manner if all parties will deal in good faith. If 

not, then hard lines and hard positions will be taken and while I believe 

we will achieve what we need, it is by far the harder path for all 

concerned. 

18. My final thought is, by law, we are entitled to clean air. Leaving all 

Page 15 of 27




the above issues aside, it is the job of PSCAA to enforce this. It seems 

to me that the goal, stink-free air, has gotten lost in issues of process. 

PSCAA is the only recourse that is open to us, other than the courts. We 

desperately need PSCAA to enforce the law. 

(June 3 Oral Comments Paraphrased) - Since 1988 PSCleanAir received 

(Oral Comments June 3) 7725 Complaints, 80 in the previous month. As much enforcement 

effort as permitting effort needed. Cedar Grove failed to meet 

commitments from lawsuit settlement. Have CG post a bond against 

Chuck Arnold 

(Oral Comments June 3) 

odor complaints. Patience is exhausted. 

(June 3 Oral Comments Paraphrased) - Was unaware of the smell when 

he purchased his home but now has no choice but to live with the 

consequences. Curtails outdoor activities when smell is so strong. 

David and Brandi 

Sheridan 

(Written May 16) 

My wife and I have lived in rural Maple Valley, since early 2002, and 

we love the area. It was not until sometime early in 2009, that the 

stench from Cedar Grove Compost became so strong, that we began to 

make repeated phone calls and e-mails to your organization (PSCAA), 

to complain of the situation. Nina Birnbaum at PSCAA can verify some 

of the times we have called, and e-mailed. We began to keep a log of 

the 

times that the odor was unbearable. During one period from July 15, 

2009 through August 30th, 2009, we had 18 entries over about 15 of the 

days, and we were out of town for about 10 days during the period. 

We live several miles south of the Cedar Grove Compost facility, and 

know that hundreds of our neighbors must also be affected by the 

noxious odor. A lot of the times, the stench is stronger in the evenings, 

and on the weekends, when no one from PSCAA is around to verify the 

complaints. 

We feel that the self monitoring by Cedar Grove Compost is not 

acceptable, as we would not have this continued problem. 

A lot of our neighbors are moving, and have moved away due to this 

problem. As the smell only seems to be getting worse, the last year or 

two, we feel as though the efforts put in place so far to minimize the 

stench have been highly ineffective. As such, we strongly urge PSCAA, 

not to grant Cedar Grove Compost any permit to continue operating. 

In summary, we feel that it is unacceptable for Cedar Grove Compost to 

continue it's operations, when so many people are affected. 

There are health concerns to ourselves and our pets and livestock, not to 

mention decreased property values. We are not able to plan 

any outdoor events at our house, as we are ashamed and embarrassed by 

the stench. Some people say that we should have been aware 

of the smell when we located to the area, but we contend that the smell 

is getting worse and traveling further, as it has only begun to affect 

Page 16 of 27




(Oral Comments June 3) us in the last 2 years. 

(June 3 Oral Comments Paraphrased) - Neighbors are moving or have 

moved away. Self monitoring is an issue. Do not grant any permit to 

continue operating. Is there monitoring equipment available? In the last 

two years the stench has reached their house, (2 to 3 miles away), so 

they began to make repeated phone calls and e-mails to complain. 

Strongest during evenings and weekends. Smells like rotting food. 

Jan Pelroy 



Richard Reininger Jr. 

(Written June 16) 

I live in Four Lakes, and am tired of the lack of enforcement at the 

Cedar Grove Composting Company. Neither my Family nor I should 

have to live with the embarrassing odors that Cedar Grove and the 

Puget Sound Clean Air Agency are unable to control. Complaints-seem 

to only mitigate the problems until the next set of clear weather days 

appear. I stopped calling in complaints when I was told by one of 

your employees that as soon as a fine is paid the record of the complaint 

goes away and their record is expunged. We should not have to live 

under these conditions, it is unhealthy. I know they installed fans that 

were to help the problem, but all I think it has done was to diffuse the 

problem over a larger area. It's time to pull their permit. It is clear they 

have had ample time to correct their deficiencies and have been unable, 

or unwilling to do so. Clearly it is time for your agency to do what you 

are mandated for, and that is to protect the public from polluted Air. 

Promises from Cedar Grove Composting are not acceptable anymore. 

Please understand what it is like to live under this type of situation for 

several years without any relief. 

(June 3 Oral Comments Paraphrased) - Tired of the lack of 

enforcement. PSCAA has failed the public. The odors are embarrassing. 

Pull their permit. 

In addition to my verbal comments made at Maple Hills Elementary 

School on June 3, 2010, please know that I am against Cedar Grove 

Compost processing food waste on its Maple Valley site as the odor 

situation has not improved. Please read and re-instate my attached 

letters of Sept. 21, 1997 to PSCA and Feb. 25, 1998 (CC to PSCA) that 

are still applicable. The air quality in the Issaquah Hobart Valley has 

improved little since these letters were delivered to PSCA. LRI of 

Puyallup operates an enclosed odor free facility. Harvest Power of 

Richmond, B.C. uses in-vessel composting to capture odors and gas to 

produce electrical energy with guarantees of "no odors." Other 

industries that have emissions to the atmosphere must comply with the 

Clean Air RCW and laws of the national EPA. Why is Cedar Grove 

allowed to continue with unlawful activity that is 17 times more 

detrimental to destruction of the ozone layer than carbon dioxide? 

Food waste generators can purchase Hot Rot "In Vessel" compo sting 

equipment, install the equipment on their site and sell product locally. 

Page 17 of 27




Thus, reducing transfer costs and carbon emissions as it can be 

processed and utilized locally. Again, Cedar Grove Compost is not 

capable of policing itself. Therefore, Cedar Grove needs to 

comply or cease operations until a facility can be established that is 

truly sustainable and does not impact the use of neighboring properties 

for approved non-offensive intended uses. 

(Oral Comments June 3) (June 3 Oral Comments Paraphrased) - Lives 3 miles away. Against 

Food Waste Composting as the odor situation has not improved. 

Previous letters attached. CG can't police itself. Harvest Power has an in 

vessel system. LRI is totally enclosed. Harvest Power guarantees "no 

odors". Or each food waste generator should be asked to "hot rot" onsite. 

Leo Fennegar 


Tom Carpenter 


Wayne Bingham 


Sean Kronberg 


Evan Lurton 


Pamela Tucker 


Kevin and Becky Scott 


(June 3 Oral Comments Paraphrased) - Require better technology and 

put in a condition to eliminate the odor within 12 to 18 months. Clean 

up or shut up. 

(June 3 Oral Comments Paraphrased) - Would have liked a good 

neighbor but for CG it is too late. Is CG willing to invest to fix this? 

(Past President of the 4 Creeks Association) 

(June 3 Oral Comments Paraphrased) - Can't believe that the complaints 

do not change things. Downsize CG until the odor is under control. 

Penalties now are just a cost of doing business. 

(June 3 Oral Comments Paraphrased) - Resident since 2004. Using 

Ecology rules Health Dept limits odors at the fenceline. Agency and 

Health Dept should cooperate. What can be added to the permit to 

improve performance? Why are some areas allowed to skip weekly yard 

waste pickup? 

(June 3 Oral Comments Paraphrased) - Resident for 24 years. Dump 

got its act together. How come with $ in and $ out they are so short 

staffed? Health Concerns because of Allergies. 

(June 3 Oral Comments Paraphrased) - Nothing has gotten better. Needs 

to be able to open windows in the summer. Concerned about impacts at 

the school. 

(June 3 Oral Comments Paraphrased) - The landfill returns his calls, 

Cedar Grove does not. Cedar grove did not live up to terms of the 

lawsuit settlement. Smell has been worse the last two years. 

Page 18 of 27

Sharon Schimke 






Fred Malmassari 


I would like to see that there will be strong regulations regarding the 

food and other recycled wastes. I would like to see strong penalties for 

any odors emitting from Cedar Grove Compost. The only ones 

benefiting from the odors from Cedar Grove Compost are the owners of 

the company. I hate what they have done to my community. We have 

lived here for 43 years, and when they bought the old pig farm/ airport, 

that was the end of our life style. I personally believe that if they cannot 

put an end to the odor they should be put out of business. They do not 

care what they have done to us, and I don't care about their desire to 

keep their business going. King County needs to enforce all of the codes 

that Cedar Grove Compost is failing to comply with or close them 

down. King County needs to pass additional laws about eliminating 

odors if the laws on the books are not strong enough. Who has the 

power to close down. Cedar Grove Compost for not eliminating the 

odors? Who has the power to close them down for not paying the fines 

that I have heard that they owe? How much do they owe? I have heard 

$20,000. Is that true? I would like to think that if I owed a fine to King 

County they would condemn my house and sell it for the amount owed. 

(June 3 Oral Comments Paraphrased) - 43 year resident. Was part of the 

lawsuit. Believes odors were cause of her throat cancer. Only Cedar 

Grove benefiting from the odors. End Odor or put out of business. What 

are the penalties now due, $400K? Who collects or shuts them down? 

Odors get into car even with windows closed. Can smell odors at 

Safeway and Issaquah Highlands. Odor Regulations are not strong 

enough. 

(June 3 Oral Comments Paraphrased) - Complaints received by the 

Agency do not reflect actual odor impact as many either don't call or 

have given up. Odors are bad "all the time". 

Dawn Peschek 


(June 3 Oral Comments Paraphrased) - Lives 3 blocks from the school 

and has a six and eight year olds attending. What is in the air? Worried 

about health effects. Her home visitors ask about the odor. At swim 

meets visitors ask about the odor. Smell is so bad you can "taste it" 

inside the school. When the odor is really bad the kids are kept in the 

school. Odors are getting worse, especially in the last two years. Close 

the place down. 

Tom Pfeiffer 


David C. Prochazka, PE 


(June 3 Oral Comments Paraphrased) - Has lived two blocks from the 

school since 1999. Likes the neighborhood, except for Cedar Grove. Its 

getting progressively worse. Odors will wake you up at night even with 

all the doors and windows closed in the winter. Worse at night and early 

Morning. Shut it Down. 

May 16 Letter - I have a great concern over the stench of Cedar 

Grove Composting Company, which is located a short distance from my 

home in the Four Lakes community in Issaquah Washington. I have 

lived in this house for 33 years and have experienced the condition of 

Page 19 of 27




the air grow worse with time. I was a primary plaintiff in the class 

action law suit against Cedar Grove and Cedar Hills. As part of the 

settlement of that suit the defendants had 3 years to fix the problems (it 

has been well over 3 years). For a while things seemed to be okay (I 

travel a lot so am not here all the time) but in the last year or so the stink 

has got much worse. I understand the Cedar Grove is taking in more 

than they can process, started taking in animal scraps and are not 

covering their stuff. This may explain at least part of the problem. The 

stink has reduced my enjoyment of my home and property value (I 

never would have bought this house if I knew I had to deal with this). I 

was here before Cedar Grove. I am an engineer and have the job of 

explaining our "engineering solutions" to problems to our customers. 

Although the customers listen politely, they make it clear that they 

don't care about "engineering solutions". They want performance 

guarantees with big financial penalties if the performance is not met and 

they will not buy our product if things are not fixed. In other words, if 

we don't get things fixed right, they are going to effectively shut us 

down. That is what I want for Cedar Grove. Cedar Grove has had the 

money to expand and take in new products. The have chosen not to 

spend money to fix the stink problems because they can make .more 

profit by not fixing it. The only way that I think they will fix the 

problem is when it becomes uneconomical not to. They are in business 

to make money and they have shown that they don't care about the 

community around them. Now is the chance to really make a difference 

and prevent this issue from growing into a bigger and more costly 

problem for all involved. The way I see it, Cedar Grove Compost 

should not be allowed a new permit unless: 

1. There are performance guarantees that will shut them down if they 

fail. They should not be allowed to operate if they create a stink. 

2. They are required to have adequate insurance to cover the decreased 

property values of the community, payable to the homeowners. In the 

class action suit, we settled for what was available from the insurance 

which was much less than our losses. At that time, our settlement 

allowed Cedar Grove to continue to operate. Cedar Grove presented 

“engineering solutions" which we thought would solve the problem. 

Clearly either Cedar Grove either did not implement the “solutions" 

or they did not work. 


(June 3 Oral Comments Paraphrased) - Resident 33 years. Plaintiff in 

class action lawsuit. Is the VP for the 4 Lakes Association. CG did not 

fix problems within 3 years as promised. CG is taking in more than they 

can process. Condition of air grows worse with time. Wants 

performance guarantees in our permit with big financial penalties. 

Require they insure surrounding property values. (Recommendations 

Page 20 of 27




for new permit conditions submitted.) Shut down the plant between the 

problem and the correction, and prevent material movement. 


Order of Approval for NC No. 10052 

Suggested addition per David C. Prochazka P.E. 

10-Jun-2010 

22. Regardless of the procedures outlined in this document, Cedar 

Grove shall have the sole responsibility to contain all odors 

form their processes. They shall do this to the extent that no 

odor emanating from Cedar Grove bothers the local residents. 

Local residents are defined as people that live within 6 miles of 

the Cedar Grove facility. If Cedar Grove fails to contain the 

odors, this permit will be immediately revoked, Cedar Grove 

will immediately be shut down and not be permitted receive or 

ship any material until the problem is corrected to the 

satisfaction of the Puget Sound Clean Air Agency and all the 

people that have filed complaints with Puget Sound Clean Air 

Agency. Failure to contain the odors will be determined by 5 

complaints filed by local residents with Puget Sound Clean Air 

Agency or by Agency’s own inspection. 

23. If this permit is revoked, Puget Sound Clean Air Agency will 

have the responsibility to notify Cedar Grove and if necessary 

obtain police enforcement to prevent material from being 

moved in or out of the Cedar Grove Facility. For this 

document, material is defined as raw material used to make 

compost and the compost product. 

Page 21 of 27




Summary Response to Public Comments Received (NOC 10052) 

April 29 – June 15, 2010 

The Agency has reviewed all the comments received in writing or offered orally at the public 

hearing. This review and the nature of the comments led to some recurring themes and messages 

which have been identified below. The Agency has used these themes to reply to the comments 

in a summary fashion. At the end of this summary, the conclusions and changes related to the 

originally proposed order of approval are identified. 

1. Odors from the facility are a persistent nuisance 

The Agency agrees with this general observation, even though not all of the complaints 

received by the Agency have been verified by personnel on the ground or traced to Cedar 

Grove. When Agency personnel are able to respond to a complaint of a nuisance odor 

that is “in progress”, it has sometimes been possible to verify the impact and determine 

that Cedar Grove is the source of the odor. Cedar Grove has indicated it is in compliance 

with all site specific order of approval conditions, settlement agreement conditions, and 

general Agency regulations when these complaints are received. That observation 

combined with the Agency experience in the field would suggest that compliance with 

those requirements alone may not be sufficient to prevent the odor nuisance experience in 

the community, especially in the last 2-3 years. 

2. Odors are an embarrassment to residents during guest visits 

The Agency understands this comment and believes it is an extension of the nuisance 

issue identified above. The comment supports the idea that observations about the odor 

may not be limited to just the most local residents with an awareness of Cedar Grove and 

their operations in Maple Valley. These comments also indicate how far odors can be 

transported in a recognizable fashion. 

3. Odors from the facility negatively impact school operations 

The general comment was that the odor impacts negatively affected the school operations 

and led to restrictions of activities (i.e. keeps children inside at recess). The Agency 

contacted staff at the Maple Hills Elementary School to determine the level of impacts 

that may have occurred at that school in relation to the nuisance odors covered by these 

comments. What we were able to determine is that the school has experienced the odors 

in a similar manner that the residents have identified. Sometimes, the complaints 

received by this Agency are from staff at the school. The experience related by the 

school is that the odors tend to be strongest in the morning, permeate throughout the 

school, and have tended to be most persistent (e.g. every day) in the spring. Parents and 

Page 22 of 27




students comment on it during arrival to school. The school does not have any records or 

recollection of recess or PE class restrictions where students were kept inside. 

4. Facility impacts have negative impact on property values 

The Agency is unable to directly address the concerns related to impacts on property 

values. We believe that this is an extension of the nuisance odor complaint comments. 

5. Emissions from facility are negatively impacting residents health 

The Agency does not presently have sufficient information to assess this issue or answer 

this question directly at this time. Information regarding specific emissions continues to 

be developed for composting operations, but historically, emissions from composting 

operations have been characterized as “odors” or “volatile organic compounds (VOCs). 

Emission information collected by Cedar Grove for this Agency has included VOCs and 

ammonia emissions. Discussions of composting related emissions as solely being a 

matter of “odor” or limited to odor impacts does not address the potential health related 

questions that can follow. It is understandable that when a community is experiencing 

elevated odor impacts, they have questions and concerns related to associated potential 

health impacts. 

There is some limited data collected as a survey for health impacts for compost facility 

workers (“Compost Air Emission Health Studies: Summary of the Literature”, Ellen Z. 

Harrison, Director, Cornell Waste Management Institute, July 2007). That document 

stated a conclusion that “composting facilities do not pose any unique endangerment to 

the health and welfare of the general public” and was based on the health studies 

available for workers at a composting facilities which showed no significant impacts for 

their health. However, the summary also went on to state that “Current data are not 

sufficient to resolve questions regarding the potential health impacts of siting a large 

yard waste composting facility in relatively close proximity to neighbors.”. Additional 

studies are currently underway in California to develop emission profile data for 

composting operations for some of the specific compounds that make up the generic 

category of VOCs. These studies, being funded by the California Department of 

Resources and Recycling and the Alameda County Waste Management Authority, are 

being completed by staff at the University of California – Davis with preliminary data 

possibly being available later this year. This speciated organic emission testing is 

intended to identify the mix of compounds that represent VOCs from composting 

operations and evaluate their ozone formation potential. 

In order to more effectively address the comment and questions related to health impacts 

from composting operation emissions, more detailed and site specific emission 

information is needed. Data collected from other sites and types of operations are not 

consistent nor directly transferable to the various processes and operational practices at 

this site. This Agency has the authority to require sources to test for emissions to 

determine compliance with standards, as specified in Regulation I, Section 3.05(b). In 

Page 23 of 27




order to supplement the incomplete emission data available for this site (both for odorous 

emissions and toxic air contaminants), the Agency intends to issue a Regulatory Order 

requiring Cedar Grove to collect and submit the emission information for specified 

operations and emission parameters. This order would likely be issued before the end of 

this calendar year, with the intention to have the specified emission data collected during 

the spring peak grass season in 2011. This emission information may be useful to 

determine potential compliance with Regulation I, Section 9.11 and would also support a 

health impact analysis as defined in Regulation III, Section 2.05 (Sources of Toxic Air 

Contaminants). The health impact analysis defined in Regulation III is based on an 

evaluation of predicted emission impacts offsite in comparison to the Acceptable Source 

Impact Levels (ASILs) identified in WAC 173-460. 

6. Complaint record does not accurately reflect the level of impacts 

The Agency agrees with this general comment, but recognizes that the complaint history 

is just one form of data and most of it is anecdotal. The comments with respect to this 

topic indicated that the level of impacts on the community are understated because some 

residents either don’t know who to call, choose not to call even though they experience 

the odor impact, or have given up filing complaints because they do not see that it is 

making a difference. Cedar Grove believes that the complaints are not indicative of what 

is really happening in the community and that there are other sources of odors in the 

vicinity. The Agency is unable to verify and complete a full investigation of every 

complaint received. However, when we are able to respond, our investigation process 

does allow the impact to be documented and the source of odors to be identified. 

7. Odors have gotten worse in the last 2 years, especially during night, 

early morning, & weekends 

The Agency agrees with these comments and believes that there are multiple contributing 

factors. Over the past five years, the amount of waste material separated for composting 

in the region continues to increase and Cedar Grove receives most of that material. The 

amount of food waste in the compostable waste stream has also increased. The market 

for selling finished compost fluctuates, but the recent economic conditions have slowed 

construction and the sale of compost, leading to more finished product being stored 

onsite. Another factor which can affect odorous emissions is the ability of the site staff to 

manage this increased quantity and diversity of materials in an efficient and effective 

manner. All of this can contribute to potential increases in odorous emissions. Cedar 

Grove’s comments support this conclusion. Cedar Grove believes their competitors get 

the benefit of “lower population densities, much lower tonnage being processed, smaller 

foot print, lack of finished compost storage on site, and wind directions that blow to 

agricultural areas instead of housing areas”. 

Another aspect of these comments was a concern that Cedar Grove was doing something 

in the evening or at night which may contribute to the odors the neighborhoods 

experienced at night or in the early morning. The Agency does not have reason to 

Page 24 of 27




believe that Cedar Grove processes material at night. Normal staffing is for regular 

working days to address the receipt of wastes and processing in coordination with those 

receipts. Some weekend day or early evening work may be completed to address 

immediate demands, but the site does not handle or process materials around the clock. 

The Agency believes that the night and early morning related observations may be 

attributable to periods of calm meteorological conditions in which emissions from the 

facility may not be rising or dispersing in a typical dispersion modeling assumption. This 

assumption is consistent with the recognition that complaints have been received in all 

directions around the facility and are not consistently affected by prevailing wind 

directions. 

8. Limit the operational level of Cedar Grove until they can perform 

Many of the comments suggested that Cedar Grove should be limited operationally until 

it can perform acceptably with respect to impacts on the community. These comments 

ranged from a desire for complete shutdown to an interest in Cedar Grove being fully 

successful with the composting policy direction while being a better neighbor. Cedar 

Grove has expressed the view that they “utilize state of the art composting technology 

that has been determined to be Best Available Control Technology by PSCAA”, and has 

challenges that other commercial composting facilities do not have to overcome. This 

view may suggest that there is nothing more Cedar Grove can do to minimize their 

impacts in the community and that a certain amount of Level 2 odors in the community 

are unavoidable. 

The Agency does not agree with Cedar Grove’s view and has not reached a conclusion 

that there is nothing more Cedar Grove could do to minimize its impacts. The fact that 

the known emission profile for composting operations nationally is continuing to develop 

at this time illustrates how past permit decisions are not a shield when the information 

those decisions were based on is changing. As an example, a recent study in California 

indicated that the VOC emissions from a grass recycling compost operation could double 

with the addition of food to the waste stream. Also, operational practices onsite can have 

a significant effect on the odor emission performance for the site and compliance with the 

permit conditions alone is not sufficient to control all odors. Additional provisions could 

be added to the Cedar Grove permit conditions, but the performance the public seeks is 

not just onsite. They want to see results in their community. 

The Agency has considered a range of limitations to be included in the permit and is 

proposing to add a permit condition which prohibits Level 2 odors (or greater) beyond the 

facility property boundaries. This condition is consistent with the Agency view that a 

source which can routinely produce Level 2 (or greater) odor impacts offsite is not 

meeting Reasonably Available Control Technology (RACT) as defined in Regulation I, 

Section 9.11. 

The Agency considered other alternative conditions. However, neither a limitation on 

short-term capacity waste rates nor a requirement to limit the quantity of finished product 

onsite would assure acceptable impacts. One commenter specifically stated that the 

Page 25 of 27




permit documents identified a series of “engineering solutions”, but did not approach an 

expectation of “performance” by Cedar Grove. The Agency agrees with this comment 

insofar as the permit does identify specific engineering provisions that are expected to 

address the odor generation/control measures onsite. With respect to the performance 

comment, the processes and configuration onsite do not support traditional emission 

performance standards for a stationary source with a limited number of exhaust stacks. 

The release of emissions onsite at Cedar Grove can range widely (biofilter surface 

releases, building fugitive emissions, and area wide sources (compost process piles, 

product screening, finished product, and water surfaces). 

9. Cedar Grove has no credibility in community, cannot police 

themselves 

The Agency acknowledges the frustration and views expressed by many commenters. 

The previously recognized Environmental Management System (EMS) adopted by Cedar 

Grove to address onsite operational practices and environmental compliance seemed to 

be helpful after original adoption. More recent inspection experience found that some 

aspects of that self directed operational management were ignored. Enforcement actions 

using the EMS documents as reference for operation and maintenance practices led to 

revisions of the EMS documents to remove some of those elements from the plan. The 

settlement agreement which triggered this permitting action was intended to make the 

onsite monitoring expectations more clear and trigger repairs in a timely fashion. The 

Agency believes that this has provided some benefits, although not all that were 

expected. The third party biofilter inspections have led to biofilter operational 

improvements. Also, the expansion of self monitoring has clarified items which the 

Agency was able to identify as important for odor control. Diligent operational practices 

by Cedar Grove and onsite inspections by Agency staff continue to be needed. 

The Agency is proposing to enhance some onsite monitoring and evaluation steps to 

supplement the self inspection aspects of this order. The proposed additional monitoring 

includes continuous monitoring for flow related parameters to each biofilter onsite. 

Continuous monitoring and recording of those specified parameters will provide a more 

consistent record of biofilter operational status and conditions than periodic, anecdotal 

observations. It may provide early indications of potential problems with the biofilters 

and support systems before the reach the point where odor control is compromised. It 

will also verify the operational status of the systems during evening and weekend periods 

when the site is normally unmanned. 

Another proposed change is to increase the frequency of the 3 rd party biofilter reviews to 

quarterly from semi-annually. The reports submitted by Cedar Grove from these 3 rd party 

reviews suggest that operational improvements have been recommended by the 3 rd party 

contractor and those recommendations have been implemented by Cedar Grove. Recent 

experience indicates that the status of the biofilter can degrade more quickly than the 

semi-annual review frequency and that the self inspections of the biofilters have not 

identified the same types of biofilter deficiencies that the 3 rd party reviewers have noted. 

Page 26 of 27




10. Agency Conclusions 

The Agency has reviewed all of the comments received and has decided to propose three 

permit modifications in response to those comments. The following changes are included 

in the proposed order of approval for this Notice of Construction application: 

 

 

 

Add a condition requiring continuous monitoring of the velocity pressure, static 

pressure, and temperature at the inlet to each biofilter onsite, beginning no later 

than 90 days following issuance of the final order. Prior to installing a continuous 

parameter monitoring system, the data would be collected and recorded manually 

[Proposed Condition No. 8]. 

Increase the frequency of the 3 rd party biofilter evaluations from semi-annually to 

quarterly [Proposed Condition No. 9]. 

Add a condition specifying that air contaminant emissions from Cedar Grove 

shall not result in Level 2 or greater odors beyond the facility property boundaries 

[Proposed Condition No. 10]. 

In addition, the Agency intends to issue a Regulatory Order pursuant to Regulation I, 

Section 3.05 to require Cedar Grove to collect specified emission data and report the 

results to the Agency. This emission data will be used to evaluate compliance with 

various regulatory requirements, including but not limited to, Regulation I, Section 7.03 

and Section 9.11, and Regulation III, Section 2.05. 

The additional proposed changes are sufficiently different to warrant a new public 

comment period and public hearing on this proposal. The new proposed conditions are 

identified below. 

Page 27 of 27

RESPONSE SUMMARY - Puget Sound Clean Air Agency

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