Additional Comments Summary Response to Additional Comments

RESPONSE SUMMARY 

REVISED DRAFT ORDER OF APPROVAL NO. 10052 

Comment Period – September 13 – October 28, 2010 

Additional Comments Received on Revised Draft Order of Approval 10052 

Because the changes made to the Order of Approval conditions were substantial, and because of 

public interest, a second request for public comment was published by the Puget Sound Clean 

Air Agency on September 13, 2010. Legal notices were published in the Seattle Times, The 

Daily Journal of Commerce, the Voice of the Valley, Issaquah Press, and in the Maple Valley, 

Issaquah & Covington Reporter. A public meeting to receive oral comments took place at the 

Maple Hills Elementary multi-purpose room on 7:00PM on Tuesday, October 19, 2010. Written 

and oral comments were received from 80 commenters during the comment period, including 

Cedar Grove Composting, Inc. The comments (shown below) have been reviewed and 

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

Jo Newland 

Commenter 

(Written 09/25/2010) 

Comment Synopsis 

I live in North Everett and am dealing with the horrid stench of the 

Cedar Grove composting facility in North Everett. Nothing has been 

done about the odor which is sent into our air in North Everett, 

Marsyville and the surrounding areas. Including the requirement that 

odor cannot be above a set level outside of their facility property would 

be a first step and open the discussion of including such language in any 

future permit requirement for the north Everett facility. I believe that a 

level 2 is still too high for the surrounding areas; be it Maple Valley or 

Marysville, Everett or surrounding areas. 

I am sorry; My name is Jo Newland and as I stated, I do live in North 

Everett. Thank you. 

James Moffat 

(Written 09/26/2010) 

William E. Ward 

(Written 09/28/2010) 

It should be made imperative that NO level 2 Be detectible outside the 

plant boundaries OF ANY waste recycling plant. 

If that means they have to totally enclose the cite, SO BE IT! 

Thank you 

James Moffat, Marysville, WA 

We are 25 year residents of 4 lakes community and are very frustrated 

with the odor condition that has been caused by Cedar Grove 

Composting (CGC). It has become worse and I don’t believe we 

should have to live with the conditions cause by them. It is the 

PSCAA’s responsibility to protect us from neighbors like CGC that 

Violate others right to clean air, property value, and enjoyment of life at 

home or in their yard. Based on the comments by CGC I believe they 

don’t see it as a problem and see us as just complainers, yet they have 

not bought homes by their facility. Bottom line I don’t care how much




Commenter 


they spend on fixing this problem. I care the problem is fixed! 

There needs to be language on what happens if they don’t comply. 

What happens if “air contaminant emissions from Cedar Grove results 

in Level 2 or greater odors beyond the facility property boundaries?” 

Are they forced to cease operations that day? Cease that month? Fix it 

in a Year? Please specify the penalty If they don’t comply with the 

requirements of the permit. In that penalty I do not believe fines are 

adequate for them. If the fines still enable them to be profitable, then we 

have to continue to live with it while they still profit. They must cease 

operations. 

And how is it determined if they are compliant? 

Paul Nave 

(Written 09/28/2010) 

I wish to make a public comment in regards to this facility. Although 

the purpose of the facility is to recycle biodegradable materials is a 

desirable outcome, the methods currently in use can cause obnoxious 

odors prevalent throughout the local surrounding community depending 

in conditions at the time. 

As a resident located approximately 1.5 miles from the facility, I would 

say 70% of the time it un noticeable, but the other 30% can be very 

unpleasant. 

There have been occasions when the "sour" smell has been bad enough 

to warrant either going inside or leaving the area to avoid have 

happened. If the proposed construction is meant to better contain and 

filter out these odors, then I am for it. If this construction is to increase 

production and not help eliminate the odors, then I am against it. 

I understand this facility was in the area before a lot of the current 

homes were, but the fact remains now that there are more residential 

properties nearby and there now has to be consideration made for those 

families. 

Jeremy R. Klein 

(Written 10/06/2010) 

My family and I are residents of Maple Hills in unincorporated King 

County. I was recently made aware that there is a new comment period 

regarding Cedar Grove. I would like to echo the comments of others 

regarding the odors and emissions from the site: 

 

 

 

Odors from the facility are a persistent nuisance 

Odors are an embarrassment to during guest visits 

Facility impacts have a negative impact on property values




Commenter 

 

 

 


Emissions from the facility are negatively impacting my families 

health (in particular when we go for walks or jog the 

neighborhood) 

Odors have become worse in the last 2 years 

Cedar Grove has no credibility in the community and cannot 

police themselves 

I feel that the county should limit the operational level of Cedar Grove 

until they can perform. The impact on our community is severe. To 

think it has gone this long without being properly addressed is 

ridiculous. 

Starr M. Tavenner 

(Written 10/16/2000) 

Dick Fackenthall 

(Written 10/16/2000) 

Lisa Huntley 

(Written 10/17/2000) 

I live within five miles of Cedar Grove Compost. The bad odors have 

once again become a frequent nuance and health hazard. I would like to 

go on record as requesting strong, stringent requirements for complete 

elimination of odors, stringent compliance, and demand for a third 

party objective assessment and identification of all the pollutants that 

Cedar Grove emits prior to renewal of their air permit. 

Cedar Grove Compost’s air permit should only be renewed following 

identification of all the chemical emissions it makes, and the permit 

should be strengthened to prohibit an odors, and ability to close them 

down if they emit odors. 

Hello- I will not be able to attend the meeting Tuesday, October 19th 

but wanted to share my observations. 

I live quite near the scvhool, at: 

15541 207th PL SE 

I moved in to this address in March of 2003. 

I have smelled compost many, many times over the years. In the last 

year or two it has been a more sickening smell, likely because they have 

started adding food scraps. 

I agree with the three additional draft revisions, but in particular #3: 

"New condition specifying that air contaminant emissions from Cedar 

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

property boundaries" 

What is the enforcement mechanism? Clearly they cannot meet this 

standard now, so what exactly is going to change? 

Or- if they do move forward with the application/project and then we 

(neighbors) detect odor and complain- what happens? Do they ever get 

shut down? Or do we just have to keep complaining forever?




Commenter 


Thanks for the opportunity for comment. 

I feel a little awkward commenting since I work at the landfill (I have 

worked there since 1999). I smell compost at the landfill, too. I am 

certain it is not garbage- I only smell that when I drive right up into the 

working area and roll the window down- and even then sometimes the 

compost is the main odor. 

Steve and Wendi 

Hitchings 

(Written 10/18/2000) 

My family and I live directly above High Valley and I have lived here 

for around 24 years. We actually have a view of the Cedar Hills landfill, 

which by the way looks much better now than it did 20 years ago. 

Yesterday I received a “stop the stink” mailer in my paper box left by a 

Starr Tavenner, who is apparently a resident of High Valley below us. 

My wife and I have rarely noticed any kind of odor from Cedar Grovelike 

maybe once every couple of years or so. It is simply not an issue 

with us. The weather generally comes out of the southwest or north up 

here, and consequently does not blow anything from Cedar Grove this 

way unless there is a rare wind out of the southeast. I could see how 

those lying northeasterly or sometimes southerly of the facility might be 

more affected, but I can’t see how High Valley residents could be 

impacted much. 

This seems over-sensitive to us and the fact that Cedar Grove is 

composting seems like a positive thing for the environment. I don’t 

think High Valley residents are affected much- but then-maybe we’re 

under-sensitive! 

Kara/Shawn 

Mulqueeney 

(Written 10/18/2010) 

Unfortunately we can't attend the meeting this coming Tuesday so here 

are some comments regarding the proposed permit for Cedar Grove 

Compost: 

1)We applaud the notion of continuous monitoring of the filtering 

system but didn't find when that automation will be in place. 

2) Inspection of the filters increasing is also a grand notion if they will 

not only be inspected but replaced/repaired, is there a timeline to stay 

on top of maintenance? 

3)A condition stating that emissions shall not exceed a level 2 or greater 

is also fantastic, but what are the consequences if they do get exceeded, 

a written warning, or actual penalty? 

As we have commented previously on the increasing odor emission it




Commenter 


would be nice if there were some facts issued by PSCAA or another 

agency regarding any health issues that may be arising due to 

emissions. It would be great PR and would be welcome knowledge to 

help alleviate some of the "fears" that residents are now commenting 

on. 

The statement regarding meteorological data and that residents may be 

wrong about what they are smelling was an absolute insult...we're sure 

we know what compost smells like and we're sure we smell it for an 

extended period of time. Yes by the time a "tracker" comes to our 

"approximate" location it may be on the other side of the hill, but don't 

tell us that we aren't smelling compost and that we're not considering 

which way the wind is blowing, I don't believe you're in our front yard 

explaining to our children and their friends that hopefully the smell will 

dissipate in time for them to enjoy playing outside when the sun is 

shining...the fact that 30 residents are taking the time to complain, that's 

another issue. 

We certainly like the fact that there is a compost facility that services 

King County and that it is a vital part of protecting the Puget Sound but 

clearly the odors that are associated with the facility need to have better 

processing measures put in place so that all of us can co-exist and enjoy 

the area that we like to entertain at, enjoy the outdoor "fresh air smell" 

and just plain get outside and not be nauseated. 

cnevi 

(Written 10/19/2010) 

I appreciate the efforts of the clean Air Agency at the meeting at Maple 

Hills Elementary on Oct. 19. However, I walked out of the meeting 

within the first half hour. The speaker could not be heard because he 

did not use a microphone, and at least while I was in attendance the 

people giving comments could not be heard for the same reason, despite 

attempts to set up a microphone. As a result of the lack of 

communication, it seemed that although the meeting was held to receive 

input regarding the odor from Cedar Hills, most of those in attendance 

wanted to hear how the odor problem is going to be solved. 

My input is that the summary of the comments from the previous 

hearing, the summary that begins with Odors are a persistent nuisance 

and ends No credibility for Cedar Grove, is a fairly accurate summary 

of the problem. I will add that "nuisance" is not a strong enough 

description of the discomfort and inconvenience of the odor. At times it 

is nauseating. 

The third of the "proposed additional revisions" may be the solution to




Commenter 

Michelle Clark 

(Written 10/19/2010) 


the odor problem. If the odor can be contained on the Cedar Hills 

property, the people in adjoining neighborhoods should be 

satisfied. However, there is still the credibility problem, and until the 

odor actually does disappear, you can expect the concern, and hostility, 

expressed at the meeting to continue and even grow stronger. 

I am writing to you about Cedar Grove and the awful smell I notice 

from it whenever I enter the Maple Hills neighborhood. I grew up in 

this neighborhood and had to live with the smell for several 

years. Now, whenever I return to visit my family there (about every 

other week), I am reminded not of all the great memories, but instead, 

of how happy I am to live far away from that awful smell. 

Charles Landback 

(Oral Comments October 

19, 2010) 

Stacy Morford 


19, 2010) 

Darroll Westover 


19, 2010) 

Jan Pelroy 


19, 2010) 

Dick & Diane Beaudry 


19, 2010) 

Please reject the proposed order 10052 and shut this place down. I 

appreciate that composting is a good thing, but this company needs to 

find ways to manage its mess better and not degrade quality of life of 

the men, women and children who live and attend school in the area. 

(October 19 Oral Comments Paraphrased) – Since last lawsuit there 

have been 9000 complaints. They had an opportunity to get it right. No 

more. Their system should be patterned after LRI’s. 

(October 19 Oral Comments Paraphrased) – Neighbor for 41 years. 

Owner for 15 years. Same Story, still the same odors as from the 

lawsuit. Do something – like enforcement. 

(October 19 Oral Comments Paraphrased) – Lives 3 miles across SR 18. 

Raises trees and vegetables. Gets no response from complaints. The 

odor is a problem for his farm store. He is embarrassed and can’t sell 

his product. 

(October 19 Oral Comments Paraphrased) – Lives in 4 Lakes. The 

odors are obscene, and they should not have to live with this. Cedar 

Grove told her that if they got the same tipping rate as in Pierce County 

they could do something like in Pierce County. Meanwhile Seattle is 

looking for a rate decrease. What is wrong with the Agency? Do 

complaints go away after a Civil Penalty? Shut Cedar Grove down. 

(October 19 Oral Comments Paraphrased) – Lives in Cedar Grove 

Estates. Cedar Grove is blaming Cedar Hills Landfill. He believes there 

is a lack of communication and wants to know if there is any 

coordination between Cedar Grove, Cedar Hills, and the Agency to get 

rid of the dirty diaper smell. All he gets is excuses from the Agencies. 

He may join the Snohomish County group against Cedar Grove.




Commenter 

David Prochaska 


19, 2010) 

Liz Marshall 


19, 2010) 

Anna Rothenberg 


19, 2010) 

Patti Flanik 


19, 2010) 

Sean Kronberg 


19, 2010) 

Tara Bingham 


19, 2010) 

David I. Hardin 


19, 2010) 


(October 19 Oral Comments Paraphrased) – Has lived in 4 Lakes since 

1977 and was part of the last lawsuit. Then both Cedar Grove and the 

Cedar Hills Landfill was sued because both were giving off odors and 

because the difference between both sources odors could not be sorted 

out. The proposed permit is OK. If there are continued odors shut them 

down, don’t just fine them. 

(October 19 Oral Comments Paraphrased) – A Maple Hills resident for 

16 years. They were part of the lawsuit, and the standards since have 

never been met. How can the Agency help? RCW 70.94.097 says the 

Agency can collect additional funds to do additional studies. You guys 

are closed on Saturday and Sunday. We need the Agency there nights 

and weekends. What happens after Cedar Grove gets a “Level 2” 

NOV? Who do we go to after the Clean Air Agency to get help? 

(October 19 Oral Comments Paraphrased) – Disappointed with the 

Agency response. There were 275 complaints in the last two months. 

What will be the punitive damages? $200K Fine? What is the 

complaint/ enforcement follow-up? 

(October 19 Oral Comments Paraphrased) – Works at Maple Hill 

Elementary School. Feels frustrated because she calls every week to the 

Health Dept., and the Clean Air Agency. She is a 20 year resident and 

was part of the last lawsuit. Where are the complaints going, and what 

are the outcomes? 

(October 19 Oral Comments Paraphrased) – Will submit written 

comments. Appreciated the community presence at the public hearing. 

What is going to happen when a “level 2” odor violation occurs? 

(October 19 Oral Comments Paraphrased) – Has lived in 4 Lakes for 7 

years. She is a realtor who has lost two sales due to the odor. Odor 

drives the typical home price down $100,000 less than the asking price. 

Referred to her past comments. She has identified the smell as being the 

same as when compost is delivered to her house. Stated that the 

compost is of poor quality, and that it burns plants. She has health 

concerns and is a lymphoma survivor. She suffers from nausea and 

headaches. Was not impressed with the changes in the permit 

conditions. Feels that the new provisions do not have enough teeth. 

Evaluations on the biofilters once a quarter are not enough. The Agency 

should shut them down. 

(October 19 Oral Comments Paraphrased) – Has lived by Maple Hill 

Park since 1991. He was part of the last lawsuit. He gets odors from 

both Cedar Grove Compost and Cedar Hills Landfill. His spouse suffers 

from an increase in sinus infections. Odors from Cedar Grove have 

increased since Seattle’s yard waste has included food waste. He has




Commenter 


children aged 5, 6, 7 and 8 years old. The five year old is adopted. That 

one says “it smells like drugs are here”. Guests can still smell the odor 

though even when he can’t. The Clean Air Agency needs to put more 

staff on the problem, since the facility now operates nights and 

weekends. He can’t sign a complaint if no inspector is available to take 

a statement. Odors go into the school. What is the health impact? 

Portia McGuire 


19, 2010) 

Deborah Jacobson 


19, 2010) 

Jeremy Brown 


19, 2010) 

(October 19 Oral Comments Paraphrased) – Has lived in Lake Francis 

since 1969. Is sick of living with the smell. It used to be the dump that 

smelled. Now it’s not the Dump. Received the post card from Cedar 

Grove asking residents to call them. Feels that was a diversion to avoid 

complaints going to the Clean Air Agency. Control the stench or shut it 

down. 

(October 19 Oral Comments Paraphrased) – Has lived in the area since 

1977, and at first she did not smell them. Since the settlement they were 

better for a couple of months. Then it got worse. She knows the 

difference between Cedar Grove and Cedar Hill Landfill odors. She 

works at Maple Hill Elementary, and she gets comments from the 

students on the odors. Sometimes in the morning the odors are worse 

inside the building than outside. She has asthma and she worries 

because it gets worse when the compost odor is in the air. Are all 

complaints registered or deemed “valid”? Does the Agency sort the 

complaints/comments? Checkups should be unannounced. She almost 

got fired for making too many complaints to her administration at 

school. 

(October 19 Oral Comments Paraphrased) – Moved to Maple Hills 7 

years ago. Has two daughters age three. He teaches Environmental 

Science at Newport High School. No one told him about the odor when 

he was buying the house. Now, he can’t sell it. Why is it ok to 

contaminate the air with odor? The smell hurts us. Science can’t prove 

it is safe to breathe this air. Why does the public have to prove there is a 

problem? He cannot celebrate holidays outdoors or enjoy the pool. Most 

homes in the area do not need or have air conditioning. Yet, his house 

cannot be cooled down the usual way by opening windows, or the odor 

gets into the house. For this reason he can’t sleep on warm nights 

because of Cedar Grove odors. Odors are impacting his quality of life 

and his economics. Fines can’t hurt Cedar Grove. Meanwhile, odors are 

still increasing, the Clean Air Agency is ineffective at solving the 

problem, and Cedar Grove’s excuses are unacceptable. One company’s 

profits are being allowed to overpower community life. If it’s not Cedar 

Grove, let them prove it by shutting it down. Europe is doing 

composting right, in buildings. Don’t permit Cedar Grove if they can’t 

do it right. Level two odors are unacceptable. This is not Mexico. The




Commenter 


family wants a normal existence. They want their rights upheld. 

Chris Burleigh 


19, 2010) 

Rob Ashby 


19, 2010) 

Hugh McKechnic 


19, 2010) 

Starr Tavenner 


19, 2010) 

Alicia Cottom 


19, 2010) 

Laurie Dunivant 

Larsen 


19, 2010) 

(October 19 Oral Comments Paraphrased) – Has lived in Maple Hills 

for 10 years, and found out about the odor one week after buying. He 

hears machinery all night long, and 24/7. It’s a high pitch whine. His 

wife uses earplugs. He cannot open windows. 

(October 19 Oral Comments Paraphrased) – President of the Maple 

Hills Community Association. In their monthly meetings odors from 

Cedar Grove are a common topic. The Agency should look at Health 

and Safety issues. Why maintain these services? Cedar Grove and the 

Cedar Hills Landfill should close their sites. 

(October 19 Oral Comments Paraphrased) – Cedar Grove has to comply 

with the law and the settlement. The Clean Air Agency needs to 

enforce. If the Agency can’t do it then call Dave Reichert. 

(October 19 Oral Comments Paraphrased) – Is concerned about the 

health impacts from Cedar Grove, and would like the Clean Air Agency 

to get involved in that evaluation. There is no monitoring data with 

details. The permit should be held up until health studies are completed. 

The study should be done by a third party, not paid for by Cedar Grove 

nor by the Clean Air Agency. Fines may not be effective, $1K is not 

enough, and it’s just a cost of doing business. Increase the fines. 

Develop a public record available so people can look up complaints and 

outcomes. Some people say they can’t get through to the complaint line. 

(October 19 Oral Comments Paraphrased) – Age 19. Never got used to 

the smell. Parents can’t move. Can’t open windows, or the odors get 

in, and sleeps on the couch in the summer. Friends who visit complain 

about the smell. It impacts her summer activities. Wants to volunteer to 

stop the smell. She wants to have kids someday. She is definitely 

moving. 

(October 19 Oral Comments Paraphrased) – Appreciates the community 

involvement and restraint. She has health concerns. Her eyes and 

asthma has been a problem since moving here. 20 years of testing is 

needed. The laws in place are constantly violated. Fines don’t address 

community needs. Penalties don’t change Cedar Grove’s behavior. 

There is a facility in Puyallup that can do the job. Move waste contracts 

there. Seattle waste is in our backyard. She may join any class action 

suit. Cedar Grove won’t do the right thing unless the Clean Air Agency 

or someone else pushes. Take more firm action to resolve it.




Commenter 

Clint Willaford 


19, 2010) 

Kevin Bruce 


19, 2010) 

Patrick Daly 


19, 2010) 


(October 19 Oral Comments Paraphrased) – The smell must go away. 

Cedar Grove and the Clean Air Agency are both ineffective. Shut them 

down. 

(October 19 Oral Comments Paraphrased) – Lives in 4 Lakes. Cedar 

Groves breaks their word over and over. The last two years were the 

worst. Look for a continuous monitoring option. Do it before approving 

a permit. Otherwise reject it. 

(October 19 Oral Comments Paraphrased) – For 25 years Cedar Grove 

has held him hostage. Tired of the impacts, which are getting worse. 

We need Dic Gribbon back out here. He has had enough. 

Catherine Avila 


19, 2010) 

Sharon Schimke 


19, 2010) 

Paul Beuter 


19, 2010) 

Rick Tieman 


19, 2010) 

(October 19 Oral Comments Paraphrased) – Lives in Mirror Mont. 

Moved there for her health. She has asthma. She did not experience the 

smell for two years, but the addition of food waste at Cedar Grove 

Compost changed that. Now she can’t open windows, but needs to for 

her asthma. Can’t work outside. She has trouble sleeping and 

headaches. It is not possible for her to host an office party at her house. 

She can’t sell her house because of both the economy and the odors. 

Now her health is deteriorating. Jerry Bartlett tried to tell her the odor 

was not from compost, their odor expert confirmed it. Her husband did 

APCO work in California. He looked at the complaints. He can’t 

believe they are still open. Make the fines hurt. She is interested in a 

potential lawsuit. And is open for contact for that purpose. Also 

interested in a Joint Appeal of Taxes due to depreciation. 

(October 19 Oral Comments Paraphrased) – Has lived in Maple Hills 

since 1968. In 1991 the odors came. For 4-1/2 years now she has had 

cancer. She worries about the effects of Cedar Grove on her health, as 

it’s not possible to have such sustained odor without health effects. She 

is glad to know she isn’t the only complainant. She appreciates the 

public involvement 

(October 19 Oral Comments Paraphrased) – Calls for a show of hands 

of who would like to see CG shutdown. 

(October 19 Oral Comments Paraphrased) – Is a 22 year resident. 

Don’t trust manual tests. They need to be automatic. The end product is 

not mentioned, and is not monitored. The finished product still produces 

odors, and the emissions need to be controlled.




Commenter 

David Sheridan 


19, 2010) 

Michelle & Aaron 

Holmlund 


19, 2010) 

Rebecca Schwenk 


19, 2010) 

Spencer Sawyer 


19, 2010) 

Kathy Young 


19, 2010) 

David I. Harden 


19, 2010) 

Scott Duncan 


19, 2010) 


(October 19 Oral Comments Paraphrased) – Told neighbors to go to the 

website. Told them to comment. If Cedar Grove could have been a 

good neighbor that would have been fine. Now, feels like they should 

be shut down. (Business Case vs Community Life). It’s a quality of life 

issue with unknown health impacts. Got the smell this morning. The 

last two years have been the worse. Property values are down. We 

should be able to fix this, using air monitoring equipment paid for by 

Cedar Grove. 

(October 19 Oral Comments Paraphrased) - Is a 17 year resident who 

lives near Maple Hills Elementary. The odors make her sick, with 

medical impacts. It affects her animals. When they come in from 

outside they stink. She feels embarrassed. Some of her neighbors are 

not aware of the comment period. She was not aware of the meeting till 

almost too late. Where was it advertised? There is confusion about who 

to call about complaints. She does not want to be surprised by clean Air 

Agency actions. She wants on the mailing list. 

(October 19 Oral Comments Paraphrased) – If it is true that fines get to 

be reinvested into Cedar Grove, how does that change behavior? Send 

the fines to the community. 

(October 19 Oral Comments Paraphrased) – Is getting a building permit 

for a home on 192 nd Street. Cedar Grove is King County’s pet. King 

County and Seattle run everything. He gets nothing for his taxes. He is 

calling Dave Reichert and Reagan Dunn. 

(October 19 Oral Comments Paraphrased) - Lives South of Cedar 

Grove, and has been there since 1968. They did not use to be a problem 

for her. It now smells most days. When you buy their compost it reeks 

for about a week. The facility has gotten too big and food waste should 

no longer be allowed there. 

(October 19 Oral Comments Paraphrased) – Cedar Grove is contesting 

Clean Air Agency penalties. Does that affect their permit? The permit 

should not be approved as long as these odors persist. The odors are 

smelled by visitors. Its been worse these last two years. 

(October 19 Oral Comments Paraphrased) – A resident of Maple Hills 

for 1-1/2 years, the odor was a surprise. He is concerned about property 

values, and not being able to open windows or enjoy the outdoors. He 

supports additional online monitoring and reporting. Does not believe 

3 rd party biofilter testing is effective. Weather data and odor experience 

do not match, especially when the winds are 3 mph or less. Fines are 

ineffective. Have the pollutants been tested? (pesticides?) Does not




Commenter 


believe the permit conditions will be affective. 

Another summer of waiting is too long. Use sanctions to reduce 

production. Suggests production should be cut in 5-10% increments 

until the problem is fixed. 

Dick Beaudry 

(Written 10/20/2010) 

It was great meeting with you all on the 19 th . We would like to obtain a 

summary of all complaints and comments regarding the permitting 

proposals and citizen concerns regard health issues raised before and at 

the October 19 th meeting. These should be in hard-copy and electronic 

formats for easy downloading. I was (as I am sure you were) impressed 

at the turnout and comments at the latest meeting. The issues raised go 

beyond just the revised permitting to include property values, effects on 

real estate taxes, health, quality of life, etc. Any other documentation 

you feel might be in aid of our investigations will be gratefully 

received. 

Kurt – it was unfortunate that you were not at the October 19 th 

meeting. It was well attended by a large regional group who were 

unanimous for a shutdown of the composting operation. Only Dianne 

and I and Wayne Hill (who lives in Arrondale’s prior residence) were 

there that I could see. There was no real discussion with the Puget 

Sound Clean Air Agency, just recording of comments from many in the 

audience, which comments were uniformly negative regarding the 

stench and dangers feared as a result of pollution, etc. Of course it was 

pointed out that this hearing was about re-permitting or consolidating 

prior permits while the advertised sign for the meeting was “Tired of the 

smell “….etc. It was wonderful to see the activism of the various 

communities and the universal resolve of those attending to do whatever 

is necessary to get rid of the problem, shutting down the facility if 

necessary. The prior class action lawsuit was discussed and members 

of the class expressed great dissatisfaction with ongoing production of 

noxious odors despite legal action. Participants indicated that any fines 

imposed on CG were simply viewed as a “cost of doing business” with 

no real effect on the problem, nor remedial action or additional fines, 

which problem- all agreed - seems to be increasing, with negative 

effects on our quality of life and property values. 

I am going to check in with the people up north in Snohomish County to 

determine if they would like to cooperate with our group in forcing a 

shut-down of this noxious neighbor. It would be good if we could get 

information on the number, type and response and resolution of the 

ever-increasing complaints. One really got the impression that the




Commenter 


bureaucrats running the meeting were simply “going through the 

motions” and they gave no indication regarding what action alternatives 

would be proposed. We should gain access to all complaints, 

investigations, outcomes, if necessary through the Freedom of 

Information route. 

Many complained they had not been aware of the prior meeting and 

thus had no idea regarding what was the original draft Order of 

Approval for Notice of construction ….. was nor what the “revised 

draft” was. Legal gobbledygook (for instance, what are “Level 2 

odors”, “third party biofilter evaluations”, etc.) from this lawyers’ 

perspective! One got the feeling that the PSCAA put this meeting in a 

remote location thinking very few (like last time, apparently) would 

attend, but they were wrong. There were certainly enough people 

(some with thirty years or so residency in the area) to get serious 

attention. KING 5 NEWS should have been alerted , or some other 

local station, to cover and perhaps to investigate the issues. 

Just trying to plow through the Draft Notice is worse than trying to read 

an insurance policy – no definitions of terms used, no footnotes 

regarding prior actions, permitting applications, etc. 

I think we should engage with the attorneys who are doing the Cedar 

Grove case up north, because the administrative BS is so deep it 

resembles CD Compost! I am going to contact the attorneys in Snoho 

to see if we could join forces! 

Bob Liebling, Architect 

(Written 10/20/2010) 

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 

wish to notify you of my comments concerning the permit you are 

considering for Cedar Grove Composting. I attended the public 

comments hearing held last night at Maple Hills Elementary and was 

quite dismayed at the testimony that I heard from the residents of at 

least 5 neighborhoods near Cedar Grove Compost, on the continual 

deteriorating quality of life we’re experiencing due to the odors emitted 

from CGC. 

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

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. At times, we can’t even go into our own yards, because




Commenter 


the smell is so pungent. There was testimony last night from a realtor 

who tried to sell a home in 4-Lakes last year, and the reduced property 

value we’re experiencing due to the odor problem from CGC. I’ve 

noticed my allergies getting worse over the last two years, and last night 

several other people described similar health problems they’ve 

experienced with the odors, in addition to the children at Maple Hills 

Elementary school. 

There is a composting facility in Puyallup, LRI, that we visited and they 

don’t emit odors like CGC, so we know that there is a process that can 

be achieved for the composting that is superior to the processing at 

CGC. CGC must be forced to revise their processing techniques 

immediately, so they won’t continue creating the noxious odors, or they 

should cease doing business in our area. The penalties that have been 

applied to them don’t seem to be much of a deterrent for them, since 

they continue to violate the regulations that have been imposed upon 

them and the odors are increasing every year. 

I realize there must be a balance between the refuse needs of our society 

at large and 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 growing residential area. If they 

can’t act as such, they should leave or turn over their business to 

someone who can act more responsively to our concerns. We don’t 

understand why King County doesn’t seem to care as much about air 

pollution as it does about water pollution when it comes to health issues 

and quality of life. 

Jodi Baird 

(Written 10/20/2010) 

As a home owner of 10 years in the effected cloud of stench in the 

Maple Hills Area, I do hope that you will consider my comments. I 

agree with the comments and concerns raise last night at the meeting at 

Maple Hills though I was not present. My understanding is that a level 2 

odor is defined as “one that is distinct and definite, and any unpleasant 

characteristics are recognizable as coming from the source in 

question.” This odor presents itself worse in the fall mornings, it seems 

to be worse at hours when any overlooking agency is not on duty like 

the weekends. I do understand that I also live near the garbage dump, 

but they are two distinct smells. I have only smelled the dump less that 

20 times or days in the 10 years I have lived here. Cedar Grove on the 

other hand, smells as I have had to describe to visiting friends "funking 

bark." The number of days I smelled it over the last 10 years would 

number in the years of smelly days.




Jim Roper 

Commenter 

(Written 10/20/2010) 


It is crazy to me that we live in a time that we do and we are having to 

live in conditions that are pre-20th century. I agree with composting, I 

do it myself, but I never like to smell it myself and have simply found 

ways to eliminate smell by the spreading it thinner. It has always been 

and should always be a way of life to "do unto others as you would do 

to yourself." Would Cedar Grove employees like to live in the smell, I 

think not. The odor thus is not insignificant in any way and should not 

be considered so in the SEPA review. Strong requirements need to be 

held to so no one will have to live in stink! 

My name is Jim Roper and I live @ 16209 205 th Pl SE Renton, Wa 

98059. My wife Holly, my son’s Cooper and Brett, and I have lived in 

the Maple Station community for 6 years. We purchased our dream 

home in June, 2004 and have suffered from the intense smell of Cedar 

Grove Composting for most of that time. When it is hot, humid, foggy, 

cold, or rainy we smell Cedar Grove Compost. Friends and family have 

suffered the smell on visits. We have become prisoners in our home 

from the intense stench of Cedar Grove Compost. 

In 2009, on a level 2 violation day, Maple Hills Elementary gave me the 

phone number for the Puget Sound Clean Air hotline. I made numerous 

phone calls and was contacted one time for my input on the situation. 

The person from the department informed me that they receive many 

complaints from concerned neighbors in regards to Cedar Grove 

Composting consistent violations. Why can they continue to violate my 

air quality with no consequence? Children from Maple Hills 

Elementary suffer every day at recess. On strong odor days you can 

smell it inside the building! It is ridiculous that Cedar Grove continues 

to violate the community with little to no consequence. Obviously the 

fines and mandates King County has placed on Cedar Grove has had 

little effect on their daily business practices. I am tired of Cedar Grove 

Composting affecting my quality of life and the quality of life of my 

family, neighbors, students, and friends. 

I attended the public meeting held at Maple Hills Elementary on 

October 19, 2010 and it was shocking to say the least. Your revised 

draft for Cedar Grove is a complete insult to this community. Your 

proposed requirements for Cedar Grove to obtain approval on No. 

10052 are laughable. It is time for King County to do the right thing for 

the taxpaying home owners. Does Cedar Grove Composting have the 

right to affect the quality of life for thousands of King County tax 

payers? By definition any smell is an infraction, why can they continue 

to stink for years with a slap on the hand? It’s time for Puget Sound 

Clean Air to do their job and not renew Cedar Grove Composting their




Commenter 

Joe Bostjancic 

(Written 10/20/2010) 

Cami Carris 

(Written 10/20/2010) 

Shelly Anton 

(Written 10/20/2010) 

Amy & Chris Ash 

(Written 10/21/2010) 


permit and shut the operation down!!! They will continue to violate my 

rights and the rights of thousands until their doors are closed. Steve 

Van Slyke and the compliance department have failed the people and it 

is time for action not meaningless words. 

I have lived in Briarwood (Renton) since 1971 and know the odors well 

that come from the compost facility. We, my wife and I have toured 

both the compost facility and the land fill. I cannot believe we have 

lived with this odor problem so long. You have banned one of the most 

enjoyable odors you can have. Burning leaves in the fall and yet you 

allow this facility to ruin our daily lives and cast doubt on our home 

evaluations. Leaves have never done that. I sure hope you can control 

the odors or shut down this facility. Fines are well and good but they 

just don't seem to stop the problem. A frequent caller to the odor line. 

My husband and I are writing to you to express our frustration with the 

offensive odor coming from Cedar Grove Composting, Inc. Some 

morning it's enough to make one's stomach turn. We all hoped this 

problem would improve, but instead the opposite has happened. Cedar 

Grove does not seemed a bit concerned with the current rules and 

appears to consider the fines they do pay to be simply a part of the cost 

of running their business. 

My husband and I are in full support of any new guidelines, conditions 

or requirements which would improve our quality of life concerning the 

offensive odor we experience on a regular basis from Cedar Grove 

Composting. 

I went for a walk today in my neighborhood at 2:15pm today and there 

was a very sour smell in the air from Cedar Grove Composting. 

I am very concerned about these smells and the potential toxins in the 

air, which could be dangerous to my family and neighbors. 

I attended the meeting last night and agree with the consensus, that 

Cedar Grove Compost does need to be shut down because the smells are 

getting worse. My husband and I have lived in this area for 20+ years 

and it is definitely continued to get much worse, esp. in the last 2 years. 

Please help keep our community safe. 

We are a Maple Hills resident and we are emailing to officially 

complain of the Cedar Grove odor. The odor is a Level 2 odor with 

distinct and definite unpleasant characteristics. The odor occurs daily at 

various times of the day. The odor affects my family, my children and 

guests in our home plus it affects our quality of life. The odor is 

extremely offensive and often times it has made us gag and cover our




Commenter 


mouths & noses. We are unable to open our windows at times 

throughout the day as the odor circulates within our home causing 

uncomfortable sleepless, restless nights which overall affects our 

productivity during the day. 

Aside from legal action, what are our options? I am copying the local 

news to gain visibility into this issue. Our neighborhood has met 

multiple times to discuss this issue and recently met at a formal 

gathering to log our complaints. We also call frequently to complain, 

however, there hasn’t been a change. 

From the meeting: “The main concerns people shared last night were 

the lack of firm measurements as to what a Level 2 odor is, the current 

fines are easily absorbed by Cedar Grove as a cost of doing business, 

health concerns about air quality are not addressed, this has been going 

on 19 years and home values have decreased because of it (economy 

aside), the agency is closed on weekends and at night when the smell is 

worst, lack of response by PSCAA, people are embarrassed to have 

friends over and often change plans because of the odor, cannot have 

windows open on hot summer days.” 

Feel free to stop by our neighborhood any day of the week, especially 

when our children are going to school and playing at recess to smell the 

foul & nauseating odor. Or, swing by at night time to experience the 

awful smell again…it occurs every day of the week. I am unable to 

take a brisk walk during the day as the smell is frequent, offensive and 

unpredictable. 

Truly, I am very surprised that your agency hasn’t taken further action 

to fix this problem as you are putting an entire communities health and 

well-being at risk. I would be appalled if you approved their order of 

approval to continue composting that affects the health of the public. 

From the order of approval…My question to you is, how is this possible? 

The Agency has completed a review of NOC application No. 10052 

and made a preliminary determination that draft Order of 

Approval No. 10052 meets all requirements of Agency Regulations 

I, II, and III and qualifies for approval. Additionally, since the 

proposed order does not include production increases or 

modifications to the operations, the Agency is relying on the State 

Environmental Protection Agency (SEPA) decision record for the 

site previously established. This conclusion is consistent with WAC




Commenter 


197-11-600 and Agency Regulation I, Section 2.02. 

Cedar Grove is a commercial composting operation that releases 

volatile compounds and other pollutants with the potential to cause 

odor. 

According to the EPA website, http://www.epa.gov/oecaagct/lcaa.html. 

“The objective of the Clean Air Act is to protect human health, welfare, 

and the environment by maintaining and improving the quality of the air 

through the development of standards.” 

Shann and Allan Blake 

(Written 10/21/2010) 

My husband and I have lived in our home here in High Valley for 43 

years. This neighborhood always represented a quiet, rural setting, far 

removed from traffic, air pollution and urban sprawl. We have raised 

two daughters here who still come "home" from time to time for family 

visits. Clean, fresh-smelling air was always a constant when they were 

growing up. We used to open our doors and windows in the 

summer, knowing clean, fresh-smelling air would be there to greet us. 

Unfortunately, that is not the case these days. Often now, when we step 

outside, a vile stench permeates the air forcing us to make 

sure our doors and windows are closed so this repulsive odor cannot 

filter inside. We have called and left messages with the local agency in 

the past. Once, in fact, the person who answered the phone, besides 

acknowledging the problem, alluded to health implications these odors 

could be creating. We have been told we are among hundreds 

who echo our same concerns. 

Given the gravity of this situation, why has nothing been done to correct 

the problem? We implore you to address this issue immediately! 

Richard Nieman 

(Written 10/21/2010) 

I was at the meeting at maple hills school last night. I just want to say 

that the smell is so bad at I can not go out side at times. Their are very 

few days that we don't have the smell. It will last for about 2 hrs when it 

shows. I am just saying what everyone else has said. One other thing 

that is a big problem is that they have been running that grinder all hrs 

of the night and it will wake you up from a sound sleep. They say they 

have not had many complaints , that is no true. We have called you 

people, king county landfill , and cedar grove compost. .Everyone just 

looks the other way.You say that is not your problem. Well I will tell 

you this if you don't get this compost under control there will be a 

lawsuit. It is about time that King County and Cedar Grove stop 

holding hands.




Commenter 

Bill and Rondi 

(Written 10/21/2010) 


I would like to state my concerns regarding the draft order of Approval 

No. 10052 as it relates to our family. We have lived at our current 

residence for 8 years and have smelled the putrid odor from Cedar 

Grove Composting the entire time. Before purchasing our house we 

were concerned about the smell and were told by our builder that it was 

the dump which would be closed within 10 years. It is not the dump we 

smell but the unmistakable odor of decomposing material from Cedar 

Grove Composting. For example, this morning I heard the grinders 

start to work and within 20 minutes the terrible odor had permeating our 

neighborhood. My son was in the garage getting his shoes on for school 

while holding his nose it smelled so bad. 

Health concerns are not addressed in any measurable form. Three 

people in our family have asthma and we would like to know what 

toxins or other matter the polluted air contains. There needs to be a way 

to measure the pollutants we are forced to breath day and night – not 

just verifying there is an unpleasant odor. 

The fines are not substantial enough to cause Cedar Grove Composting 

to make any changes that would improve the odor its operation puts 

off. They must be held accountable for the odor and required to 

eliminate it whether they can afford it or not. Perhaps the solution is to 

build a covered structure over the smelly piles and have a filtration 

system in place to eliminate any odors being released into the outside 

air. We should not have to live like this because they have a lobbyist in 

Olympia. 

The food waste the past two years has made the odors even worse. 

Checking the air quality quarterly is not nearly often enough when we 

smell it every day. We have made countless phone calls complaining 

about the odor and asking someone from your agency to respond but 

have not had anyone come out so that we could turn in our complaint 

paperwork. Also, there needs to be a public record of the number of 

complaint calls received AND what is being done about it. 

This should not be allowed to continue. The technology is available to 

fix the problem and we should not have to pay the price with our time, 

health and lifestyle.




Commenter 

Terry Deschenes 

(Written 10/22/2010) 


I attended last Tuesday’s meeting and felt more than a little sympathy 

for the roasting that PSCAA came in for. I would have been right with 

them if I hadn’t attended the first meeting and seen the changes to the 

permit that PSCAA had incorporated. I was tempted to speak up for you 

folks, but didn’t want to play the role of raw meat in front of that 

hungry crowd. If nothing else, the meeting served to show the anger in 

the community and their resolve to solve the problem. 

What I see in the three new items to be included in the permit is terrific! 

You have provided PSCAA with the tools necessary to solve the odor 

problem. That assumes that PSCAA has the will to utilize those new 

tools. What is most clear is that these new requirements will move our 

complaints from “nuisance odor infraction” to “permit violations”. 

There was one comment made at the meeting that I felt deserved serious 

consideration: Cedar Grove Composting should be required to provide 

scientific information as to what is contained in the odors. Not sure if 

this is a PSCAA issue or King County Health, but having that 

information would provide everyone with badly needed data to base 

decisions on. 

In summary, I enthusiastically endorse the new changes in the permit. 

Sincerely, 

Terry Deschenes 

President, Four Lakes Landowners 

16419 239 th Ave SE 

Issaquah, WA 98027 

The following thoughts are NOT PART of my public comment, but 

rather some suggestions for handling this issue in the community. 

1. I know you are attempting to communicate with all of us, but it is 

failing miserably as evidenced by the testimony at the hearing. I have 

been complaining for years now, but only recently became aware that 

what we were asking PSCAA to enforce came under the nuisance odor 

regulations! We need to hear more details about what your authority is 

and what you can and cannot do. You have an avid audience here! 

2. Be cautious about making promises. The community has endured 

a long history of promises which have not produced results. If it is 

necessary to ask for time to accomplish something, I recommend there 

be defined results with a date they will be achieved.




Julie Arena 

Commenter 

(Written 10/23/2010) 

Debra Hawkins 

(Written 10/25/2010) 


I am a resident of the community which lives near the Cedar Grove 

Compost facility. My family has lived in our home since 1987. My 

parents also lived here in a home which they built in 1967. For many 

years we had to deal with the problems of the King County 

Landfill. Since things have improved with that over the years, which 

took a class action lawsuit and lots of other actions; we feel we have 

had to put up with enough foul smelling air. However, since the 

compost company moved in things have been getting worse again. I 

have phoned many times and left messages with the clean air 

agency and have also e-mailed. This company has touted itself as 

being a "green" company on the radio this past summer. I always 

laughed when I heard the ad on the radio. When comptemplating the 

future act of selling our home, I have realized that it probably won't 

happen as long as this smell persists around us. Showing a home could 

result in a quick disaster when whiffing the outside air on a beautiful 

sunlit day. I know this compost dump will affect the price of our homes 

when we do put them on the market (if we will ever be able to)... 

I plan to get more invovled in this problem in our neighborhod. 

Families have to put up with this and also a beautiful neighborhood 

elementary school where children look forward to their daily recess 

time and then have to inhale that foul odor. Talk about a "green" 

company....oh yes, lets just call it rude and inhumane to subject small 

children to such a place. If you have any questions of me please feel 

free to call me or contact me by e-mail at anytime. 

I was at the meeting October 19 th but did not have a chance to comment 

due to the high number of people wanting to speak. The biggest 

concern I have regarding Cedar Grove Compost is that they seem to not 

want to comply within the parameters set for them. Obviously fining 

them is not working and I believe that your organization is being too 

lenient on them. It was brought up MANY times at the meeting that 

people want action taken either by stiffer fines or a complete closure of 

Cedar Grove Compost. 

It seems pretty simple to me…..follow the rules or go away. We don’t 

want to smell that horrible smell any more. 

Rick Simpkinson 

(Written 10/25/2010) 

I’m am writing you to comment on the Cedar Grove Composting 

Application No. 10052. 

http://www.pscleanair.org/announce/permits/openpermits.aspx 

As a resident of SE 158 th St., Issaquah, WA 98027, I have to tell you




Commenter 


how disappointed I am in the Puget Sound Clean Air Agency (PSCAA) 

in not sufficiently protecting the air quality of my neighborhood. The 

stench coming from Cedar Grove Composting is terrible and 

ongoing. Sometimes it is so bad that we can’t stand to be outside and 

have to stay indoors with all the doors and windows closed tightly. The 

best way that I can describe the smell is “warm vomit”. Yes, it is that 

gross! When the smell occurs, it often lasts for the entire day and 

sometimes for several days on end. The regularity and intensity of the 

smell has grown each year that we’ve lived in this neighborhood (since 

Winter 2006). Clearly, whatever measures have been taken during this 

time by PSCAA to enforce regulations or by Cedar Grove Composting 

to comply with regulations has been grossly insufficient. 

I only recently learned of the PSCAA and how to submit a complaint 

and wish to reflect that while there is not a specific record over the past 

years from me for my property, this does not mean that there were not 

incidents of violation of air quality standards. Instead it is 

representative of the difficulty in obtaining information about the 

correct agencies and parties to complain to about this specific issue. 

I 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 permanently and 

absolutely solved. I 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. 

Further, the track record PS Clean Air in regards to this facility and 

enforcement of clean air standards is disappointing. What good is 

having penalties for violation of clean air standards when all you do is 

suspend the majority of the penalty? I appreciate the balance required 

to allow compliance with regulations, but suspending penalties does not 

make them much of a deterrent. While there is a long list of measures 

identified by PSCAA for Cedar Grove Composting to take to address 

the problems, those are clearly insufficient. The Agency’s actions todate 

have been insufficient in protecting the air quality of my 

neighborhood. It would seem as though the only viable course of action 

at this point is to require that Cedar Grove Composting cease the receipt 

of new materials, clean up existing materials, and shut down the facility.




Commenter 

Dave Prochazka P.E. 

(Written 10/26/2010) 


I am very encouraged by the subject draft. I especially liked the: 

“New condition specifying that air contaminant emissions from Cedar 

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

property boundaries”. 

I think this gives the Puget Sound Clean Air Agency the tools to do 

meaningful enforcement. I am convinced that CGC will not correct the 

odor problems unless it becomes uneconomical not to correct them. If 

the fines are small there needs to be enough of them to make it 

worthwhile for CGC to correct the problem. If not, we are all wasting 

our time. 

In the public meeting, I said that I didn’t care about the fines and 

wanted CGC shut down if they cannot correct the odor problem. What I 

meant by that is the fines and/or possible law suit awards are not 

important to me, I just want to odor stopped. As far as I am concerned, 

the good in the fines are if they make CGC hurt so much that they 

correct the problem. Please enforce the new requirements. 

Linda Villa 

(Written 10/26/2010) 

I wish to express my extreme concern over the negative effects of living 

in Maple Hills while Cedar Grove Compost continues to pollute our air 

to the point that it diminishes the life my family and I lead here. I have 

lived in my home for 41 years and plan to die here. For the past 19 

years, a monster has moved into the area and changed my life for the 

worse. When a person can't sit out on their patio and enjoy the quiet of 

the morning with a cup of coffee, can't have company over on weekends 

or evenings for an outside gathering, has to explain to outsiders what 

that terrible smell is, has to endure the stench along with the kids when 

volunteering at the neighborhood elementary school, can't open a 

window in the morning or evening to enjoy some fresh air, something is 

terribly wrong. We have been given the run-around for too many years 

by the county and Cedar Grove Compost. We pay our taxes just like 

everyone else, but we have to endure life in an odor-filled hell so that a 

company can make money. This is wrong!!!!!!!!!!!!!! I engaged in a 

lawsuit years ago against the dump and the compost company. We won 

this suit and promises were made to correct the air quality here. Those 

promises have not been met and I am very willing to engage once again 

in this war to clean our air. 

Please pay attention to our pleas and don't ignore us any longer. Our 

patience is gone, absolutely gone.




Commenter 

Evan Lurton 

(Written 10/26/2010) 

Samuel Taylor 

(Received US Post 

10/26/2010) 


I have a strong feeling that the adage, “where there’s smoke, there’s 

fire” also applies to the situation at the Cedar Grove Compost facility. 

In this instance, I strongly believe that where there is CGC odor, there 

are also inordinately large concentrations of mold and fungi allergens. 

These organisms, which thrive in decaying vegetation, can give people 

headaches, malaise, and flu-like symptoms. Of course, this process 

occurs naturally all around; however, CGC’s operation without doubt 

greatly concentrates the occurrence of these molds and fungi, and since 

the operation is mostly uncovered, probably sends large quantities aloft 

with the air currents. The odor, as bad as it can be sometimes, is likely 

the “red flag”, to those allergic to molds that they are in for another 

allergic reaction. It is no surprise to me that after a lifetime of being 

allergy-free, and having lived here 12 years prior to CGC’s arrival, I 

developed allergies to mold in the late 90’s. Coincidentally, right about 

when CGC’s operations (and odor) really started ramping up. My 

allergies have been particularly bad this year, and so has the odor. 

History has shown that a variety of seemingly innocuous substances 

have ultimately proven to be quite detrimental to public health (e.g. 

asbestos, lead). I think it would be very prudent for the Puget Sound 

Clean Air Agency and the King County Department of Health to 

consider the possibility that operations such as CGC’s may need to be 

scrutinized much more thoroughly to ensure public health. Potentially, 

much of their outdoor and exposed operation needs to be contained in 

negative pressure facilities. 

After the public meeting held last Thursday evening October 20th and 

looking at the information posted on your web site, I have the following 

comments about your order of approval for Cedar Grove Composting. 

Has there ever been an allowance in a previous order of approval by 

your agency that give Cedar Grove permission to process food waste in 

any of the primary compost pads? What reasoning is behind this 

changed language especially because of the increase in foul odor/stink 

to our neighborhoods from Cedar Grove Composting? How would a 

reportable deviation under this order result in a fine being issued by 

your agency? Where in the order, agency rule or state law does it say a 

reportable deviation will result in a fine? 

In number 8, will any biofiltration clause that is to be watched and 

recorded establish circumstances which can’t be violated? If so, what 

would be the fine be to Cedar Grove in the order? If no, why? 

In number 15, what would be fine to Cedar Grove in the order if they 

did not meet your agencies requirement to change an earlier OK'd test 

procedure? In the approval, Cedar Grove has test procedures which 

must be OK'd by your agency. Some test procedures give your agency




Commenter 

Susan, Brian, Connor, 

and Griffin Cherry 

(Written 10/26/2010) 


the right to make Cedar Grove change their test procedures after being 

OK'd by you, but others don’t. How come all approved test procedures 

OK'd by your agency don’t have a clause that makes Cedar Grove 

change a test process upon demand by your agency? Again, for test 

procedures that must have an OK from your Agency, what is the fine to 

Cedar Grove if they do not to change your agencies accepted test and 

monitoring procedures? 

I am emailing to voice my complaint about the odors from Cedar 

Grove Composting and request on behalf of my family that King 

County does not issue a permit to this company until they can run their 

compost operation odor free. We have lived in the Maple Hills 

neighborhood since 1995 and were part of the class-action lawsuit 

against Cedar Grove and the Cedar Hills Landfill. My understanding of 

the lawsuit was that the odors would stop and they have not. Since the 

settlement, the odors have persisted resulting in an impact on our daily 

lives. Examples of those impacts included, burning eyes, coughing, 

nausea, inability to use our backyard during peak odor times, and not 

being able to open our windows for fresh air because the air is so rank 

with odors. 

I also work at Maple Hills Elementary and the odors impact our 

students too. The smell gets into our ventilation system and it makes it 

very unpleasant to breathe and teach. I cannot take a full breath of air 

without coughing when the odors are present. The children get off of 

the buses in the morning holding their noses. It is particularly bad in the 

morning on clear days. 

I attended the public meeting at Maple Hills Elementary on October 19, 

2010 and over and over again the same complaint persisted. I am 

concerned that fines from the county have done nothing to hold Cedar 

Grove Composting Inc accountable for polluting the air. I would also 

like to know how much revenue these fines have generated for King 

County or the State of Washington. We have watched our property 

values decline because of this business yet Cedar Grove Compost Inc 

seems to be thriving. 

I am also very concerned with the long-term impact these odors may 

have on our health and the health of the children in our neighborhood. It 

is not surprising that I have developed migraine headaches since 1995. I 

did not have these headaches prior to moving here and they have 

become worse over the years. I now average about 3-4 migraines per 

month. I believe that there could be an environmental cause to these 

headaches because of the odors.




Commenter 


Cedar Grove Composting Inc. needs to stop polluting our air. There 

needs to be a record of what pollutants we are being exposed to and in 

what quantities. Just because it is air doesn’t mean that it can’t be 

measured. 

If a permit is issued, Cedar Grove Composting Inc must be held 

accountable if conditions are broken. They should be made to operate 

odor free or be shut down. 

Frecia Kelly 

(Written 10/26/2010) 

I moved to the house I'm in now 25 years ago. I was robustly healthy 

with no limitations. Now I have developed asthma, and it has really 

been bad for the last 2 years. I finally had skin tests done to determine 

what is setting it off. I am highly allergic to mold. I have dealt with the 

mold in my house, and even run two air purifiers daily. I firmly believe 

that Cedar Grove Composting is putting a significant amount of mold 

into the air in the surrounding neighborhoods, including this one. 

I want proof of what the composting facility is disseminating into the air 

and I want someone besides Cedar Grove Composting to collect the 

samples and run the tests. The noise from that facility is also ruining our 

quiet way of life. 

I will be waiting to hear from you. 

Jesse Pishue 

(Written 10/27/2010) 

These are my comments in regards to Cedar Grove Compost to be 

recorded. We have worked incredibly hard to be able to purchase a 

home for our family which includes myself, my husband, my 6 year old 

daughter and our dog. We purchased our home in Maple Hills, located 

in Renton, around 6 months ago. When originally touring the home, we 

smelled what we thought to be a very large load of fresh beauty bark 

that had been recently delivered to a neighbor. The smell was incredibly 

overwhelming. We were not informed of Cedar Grove Compost which 

apparently backs up to our neighborhood. After we purchased our 

home, I went to the elementary school (Maple Hills) to register my 

daughter. The smell was so bad that my daughter pulled her shirt over 

her nose because the smell was making her sick. I asked the office what 

that horrible smell was and they informed me that it is Cedar Grove 

Compost. This was devastating news as I now understood that this was 

not going away any time soon. On average, it smells atleast 2 times a 

day for around an hour or two at a time at our home. During the hot 

summer, I would open my windows to air out my house just to wake up 

in the middle of the night to close the windows because my entire house 

would smell so incredibly bad that I could not sleep. During a few




Alex Pishue 

Commenter 

(Written 10/27/2010) 


attempts at having company over for bonfires, we ended up moving into 

the house because the smell became so offensive. That is very sad and 

embarassing for ourselves and our company. When I leave my home 

early in the morning, the smell is very strong. It seems that the smell is 

the worst in the evenings and mornings. My husband drops my daughter 

off in the mornings to the before and after school care at Maple Hills 

where it is an almost daily occurence that it smells so bad it makes my 

daughter gag and it is a topic of conversation in the classroom daily. 

The fact that my daughter breaths this all day in her classroom because 

the smell gets caught up in the vents is very upsetting to me. My 

daughters soccer league had a game at the Maple Hills Park on a 

saturday morning when the smell was particularly bad and it was 

horrible to watch these small children playing sports and trying to catch 

their breath with such foul air which no one can seem to figure out if it 

is toxic or not. I can hear the machines beeping all night and early 

morning while they move compost. This is a horrible way to live and it 

is affecting so many people in such a horrible way. The fines are 

obviously not changing anything in favor of our neighborhoods. If this 

smell is making adults eyes burn and asthma act up, I don't want to 

think about what it is doing to all of the children who breath this air on a 

daily basis. 

This letter is in regards to Cedar Grove Compost and is to be recorded. I 

have worked very hard to purchase a home for my family only to find 

out the the value of our home which we recently purchased is worth 

even less with the knowledge of the offensive smell from Cedar Grove 

Compost. The smell that is coming through my house and neighborhood 

is unbearable. It is a crime that they are able to pollute the air in such a 

horrible way that it affects the surrounding neighborhoods so badly. I 

feel that Cedar Grove Compost should either be closed down or be able 

to run their business indoors as they do in Europe and other responsible, 

respectful areas. My family is being exposed to unknown toxins in the 

air. They need to get a handle on this situation before any permits are 

renewed or allowed. The responsibility should not lie with the families 

that are being subjected to this pollution. Where are our rights and 

protection? The children can't sleep in a tent in our yard because during 

the night the smell is so overwhelming. We are embarassed to have any 

type of get togethers because that is during the time of day that it smells 

the worst. The list goes on and on of how this affects our lives in a bad 

way. Please help us do something about it.




Commenter 

Mark Heinzen 

(Written 10/27/2010) 


My Name is Mark Heinzen and I live approximately .75 miles from the 

entrance of Mirrormont and 2.5 miles as a crow flies east from Cedar 

Grove Composting. 

I would like to thank you for accepting comments and concerns 

regarding the odor emanating from the location at the Cedar Grove 

Recycling Center. 

I attended the public hearing on October 19, 2010 at Maple Hill 

Elementary School and found it to be very eye opening and concerning 

on how the Cedar Grove Recycling Center, in particular how the 

Owner, is handling complaints regarding this odor issue. 

On several occasions I have called to complain of the strong odor and 

even requested a tour of the facility to help better understand the 

process on how Cedar Grove Recycling works. Although the 

conversations on the phone had been pleasant there was a sense that if I 

would just go away so would the problem with no action plan to resolve 

it. I figured I was wasting my time so I stopped calling I wonder now 

how many other people followed suit as well? 

On occasion I ride my bike to work and during my ride the odor can be 

pretty unbearable. The route that I take is Issaquah Hobart Rd SE, 152 

Ave., Cedar Grove Road to the Cedar River Trail and on to Renton. The 

valleys, wind currents, inversion layers and other such factors make it 

very unpredictable to which day would be better than others but one 

thing for sure is when I do approach the composting facility it is where 

the source of the smell is at. 

On 10/19/2010 and in all fairness to the citizens of the surrounding 

neighborhood and the freedoms and protections that governs us all with 

the great services that Cedar Grove Compost provides in compost that is 

purchased by citizens of the community some of who were present at 

the meeting. There was no negative statement against having a viable 

profitable company that supports the community in many different 

ways. 

The disagreement and frustration comes when a company has been told 

there is a problem by being the loosing party in a related law suit. To 

then continue to process compost in a similar method instead of 

changing to a proven alternative process that is used by several compost 

companies, including a local competitor that does not produce the 

offensive odors. 

The actions of Cedar Grove Compost in creating these odors off hours 

make it harder to identify and correct the problems of the processes of 

production and reporting. The timing of the post card postmarked




Commenter 


10/15/2010 was viewed as a tool to try to derail or soften the attitude of 

people in the community and prevent them from testifying against 

Cedar Grove to have them then say later “we really don’t see a 

problem.” Cedar Grove seems to be thumbing their nose in the direction 

of the complaints similar to what an adolescent would do to a parent 

that is trying to steer them in a more positive direction. 

Their actions are being felt and impacted very negatively at the root of 

our own being our children during the days at Maple Hills Elementary 

where my child attends. At a recent visit to Maple Hills Elementary 

walking from my car to the building the stench was so great it almost 

caused me to gag and nearly vomit. 

I understand that food scraps that have now been added to the recycling 

list maybe the source of the increased odors and should be managed out 

of the production process. To me the process that is employed is getting 

closer to that of a rendering operation than that of a compost operation. 

I know there is a landscaping company near Jones Rd and Hwy. 169 

and they don’t seem to have an odor problem. We all know where the 

source is emanating from. We as citizens of King County with the up 

coming election are all being asked to approve Charter Amendment 

No.1 which includes, an amendment to the preamble “To Preserve a 

Healthy Environment”. How is this preserving that to our community? 

I do additionally thank the more pro active folks of our community for 

posting the signs around alerting us of the meeting and applaud the 

gentleman that attended the meeting that is employed by Newport High 

School for giving such a very thoughtful and thorough testimony about 

the problem and solution as well as others who testified about this issue. 

I am very proud of the community that I live in and confident that if we 

remain steadfast the implementation of a corrective action will quickly 

follow. 

Catherine Avila 

(Written 10/27/2010) 

I spoke at the October 19th meeting about revisions to the Cedar Grove 

Composting permit, and I would like to add three points to the public 

record: 

Firstly, I am very happy about the condition that "air contaminant 

emissions from Cedar Grove shall not result in Level 2 odors or greater 

beyond the facility property boundaries." Am I correct in reading this 

as saying PSCAA will no longer be required to have me sign a 

complaint in order to impose a fine against Cedar Grove? I know on a 

number of occassions I had been kept up all night with the smell and




Commenter 


didn't have the time during the day to hang around waiting for someone 

from your agency to fill out a complaint form. I feel this 

provision would allow me to be heard when there is a problem without 

further disrupting my life. 

Cathy and Doug Brandt 

(Written 10/28/2010) 

Secondly, I would like to address the subjectivity of what constitutes a 

level 2 odor. Every citation PSCAA writes can be legally challenged by 

Cedar Grove Composting. This adds up to significant legal costs for 

PSCAA at the taxpayers expense. At the meeting, a couple people 

commented on whether PSCAA had the ability to take air quality 

measurements and to try to find out what it is that we are breathing. If 

this equipment exists, Cedar Grove should be required to front the costs 

for PSCAA to purchase and maintain the equipment as long as they 

continue to have a significant number of odor complaints. Certainly 

having a scientific basis for these odors would dramatically reduce any 

legal challenges. I read an interesting article about "field olfactometers" 

and was thinking this might be one thing that could be used. Here is a 

copy of that link 

http://www.jgpress.com/archives/_free/000435.html. The information I 

was interested in is under the heading "Quantifying Compost Odors." 

Lastly, I would like to emphasize the need for larger fines. Cedar 

Grove Composting has demonstrated that the current fine amounts are 

simply being absorbed as operating costs. At least a portion of this 

money should go to PSCAA to recoup the expenses the agency incurs 

while the composting facility repeatedly violates their operating 

requirements. 

My husband and I have lived on the top of Squak Mt. (between 

Issaquah and Renton) for 6 years. We are often disturbed by an strong 

odor that smells like manure, or what we now know to be rotting 

compost. We always wondered where the smell was coming from since 

it was so detectable and we knew there weren't any neighbors below us 

that had spread compost (we are the highest residence on this 

mountain). 

This odor occurred so frequently that we started to research the issue 

a while back. Unfortunately we didn't research everything when we 

bought this property, and were unaware that it was apparently 

condemned or devalued at one time due to the smell coming from the 

Cedar Grove Compost facility. We should note that we are completely 

natural/organic up here, and rarely purchase compost. We have our 

own tumbling composter which we fill only with dropped leaves and 

other debris from our native trees/plants (and all non-native




Commenter 

Alex Carter 

(Written 10/28/2010) 


weed/plant debris is removed from our property via our yard waste 

pickup service). 

We would like to go on record with our complaint about this 

odor. We are great supporters of composting, and occasionally 

enjoy the great Cedar Grove products ourselves. However, we feel that 

we should not be subjected to this odor when we are outside enjoying 

our 5 acres. We would like there to be a way to diminish this odor or 

prevent it from spreading out into the outlaying area. If this is not 

possible, we feel we should be somehow compensated for what we are 

being subjected to. 

Please make sure that this letter is including in the reviews for the 

'Air Permit' for Cedar Grove. Also, if you have any suggestions on how 

we can get this resolved, please let us know. 

I wanted to voice my concern with the others. I ask that the permit not 

be issued and that Cedar Grove Compost be shut down until they can 

resolve their issues, if that is within your abilities. If anyone would like 

to understand what we are experiencing, all they need to do is crawl 

inside their yard waste container on a nice hot summer day. Now to get 

the full understanding they not only have to live there but be paying a 

morgage to live there. They need to move now to an unpopulated area 

or shut down! Good idea, bad place for it! 

Rex & Lynne 

McCullough 

(Written 10/28/2010) 

Liz Marshall 

(Written 10/28/2010) 

We are longtime residents of Mirrormont, over 25 years. This year has 

been one of the worst years for the stench from the composting 

operation. I believe it is getting worse each year but have no idea 

why. We love the outdoors and spend considerable time on our decks 

but this year the stench has been bad enough to force us to move inside 

several times. I hope through the permitting process we can get some 

relief. 

I am writing about the public comment for the permit on Cedar Grove 

Compost Co . I attended the public meeting and asked a few question 

there that I have been assured will be answered . I have a few more that 

I will ask now. 

I hear that in Marysville some of the city employees were trained to be 

able to write violations. How can we have that happen for our area ? 

Since we are outside of the city limits can we have members of our 

community take this training and have the authority to write violations ? 

I am interested in this training if we are allowed to receive it. 

Are the SEPA forms that Cedar Grove fills out verified as being




Commenter 


accurate by anyone? What are the restrictions of the critical 

designations that are on the property tax records ? Same with the 

environmental notation on that record? What are the zoning on that 

property and what are the definitions in regards to that? What permits 

and licenses are needed for those activities? What licenses and permits 

have been issued to that property and what are they for ? What are the 

conditions of those licenses and permits ? Who is the issuing body of 

those permits and licenses and when do those permits and licenses 

expire ? Are there any violations of those permits and licenses that 

could results in a non renewal or suspension of operations? Are they 

allowed to operate without out a current license or permit ? And if so 

why ? Please address all of the statement of WAC 173-401-710 as far as 

compliance of the statute . Also please do the same WAC 173-401-810 

and WAC 173-401-400 especially clause 7 . Why did Cedar Grove 

property tax get reduced for the tax years 2007, and 2008? 

In regards to WA state EPA ID # WAD980511745 , what are the 

conditions of any and all findings and actions to be performed ? Are 

those conditions being met ? If not why ? Are any of the contaminants 

able to be air borne and is that being monitored ? 

Will this property be required to be monitored for the new EPA 

Greenhouse gas act ? If not why are they exempt ? 

What are the general definitions of what is compost ? Does the material 

that is now included in the yardwaste recycling change the monitoring 

requirements of a compost facility , and why ? Are there any safe 

guards to prevent any bacterial contamination to the public from the 

added material ? Are there any chemical or biological additives 

introduced during the composting ? What are the quantities of material 

processed at that facility . What are the yearly totals of material 

processed at that facility for the last 10 years . How much material are 

they allowed to process for those years ? How is the amount of material 

measured and is the equipment used calibrated ? What steps does this 

material go through to become compost and where do those steps take 

place at in the facility . What are their hours of operation ? Is there any 

times that they are not allowed to do any of the activities involved in 

that business ? Who are the current insurance companies for this 

property and businesses? 

I would like to know on what grounds the lawsuit that was brought 

against them and the landfill ? What were the findings of the judge as to 

those grounds and the exact settlement terms ?




Mr. D. Lang 

Commenter 

(Written 10/28/2010) 


I think I will end this email here but I may write another one later today 

. I just want to say that I am not against Cedar Grove Composting 

operating in my area but I am totally against the smell that the facility 

makes. They are in denial that they even make an odor and until they 

recognize that they can and do generate an odor I do not think they will 

do anything to stop it from happening . I have lived in this area over 16 

years and it is intolerable again . I cannot believe that they are allowed 

to continue to be able to generate such a foul awful odor year after year 

without any thing happening as a result of all the violations that they 

have had . It seems like there must be some kind of secret pact with the 

county or state that allows them to violate this law so many times 

without a change in their operations. It is a terrible injustice to the 

people who live in that area . I will continue to pursue any actions I can 

to get that horrible smell to stop!! 

I want to register a complaint regarding Cedar Grove Compost. During 

the past year especially in the warmer weather the odor coming from 

Cedar Grove has become unbearable and has prevented us from going 

outside and enjoying our yard, our home. It has a distinct smell and I 

have visited the Cedar Grove Compost site a number of times to verify 

that it is the same odor. It seems to be getting progressively worse each 

year. The impact to our life has been huge, we continually have to 

move inside during family events and cancel if the odor is too bad. We 

decided this year to not have my Daughter’s birthday party at home due 

to odor issues. During the summer my young children want to play 

outside but the smell keeps them indoors, they complain about the smell 

and I am reluctant to have the children’s friends spend any time at our 

house for the same reason. When the season changes to Fall and 

Winter the odor is less frequent but we still do smell it. I am an 

advocate for recycling and glad to see that waste and food scraps are 

being used to produce products for sale and reduce landfill waste but the 

volume and type of waste in the past few years comes with a huge cost 

to the quality of life for us. It has become an impact to quality of life 

for us and has contributed to a stress full living situation for our family, 

especially not being able to use our beautiful home's outdoor space in 

the Spring and Summer months. We want Cedar Grove to be 

responsible and do the right thing, I am not sure if proper filtering 

enclosures need to be installed but if so, this should be 

required immediately, maybe food scraps need to go somewhere else 

less populated or they should not be allowed to do business in the area. 

I am concerned about the local schools in Maple Valley that my kids 

will attend with the odor impact being much closer to Cedar Grove. 

This is wrong to continually subject my family to an environment where




Commenter 


we don’t even know the health impacts. 

There are many other Mirrormont residents that feel strongly about this 

but most likely don’t know how or where to communicate their 

frustrations. 

Sherry Partridge 

(Written 10/28/2010) 

Jerry Bartlett 

(Written 10/28/2010) 

This area smells bad alot of the time, and because of that it will make it 

very hard to sell our house. People don't want to live in an area that 

smells like this. It can make you sick to your stomach. Our guests have 

compalined as well. 

Cedar Grove Composting, Inc. ("Cedar Grove") submits the following 

comments on the revised draft order of approval ("Draft Order") for Cedar 

Grove's notice of construction ("NOC") application no. 10052 for 

consideration by Puget Sound Clean Air Agency ("PSCAA"). This is the 

second comment period PSCAA has held on this NOC application. Cedar 

Grove's comments submitted during that first comment period remain 

relevant to the revised draft order and so are incorporated by reference in 

these comments. 

General Comments 

Cedar Grove committed, in a 2008 settlement agreement with PSCAA (the 

"2008 AOC"), to submit an NOC that would consolidate the conditions of 

various Approval Orders that have been issued over the years for the 

Maple Valley facility and incorporate conditions agreed to as part of the 

2008 AOC settlement. Cedar Grove initially proposed to incorporate some 

operational changes into the NOC, but withdrew that request when it 

became clear that it was complicating what should have been a fairly 

simple administrative exercise. As the NOC was intended to consolidate 

existing requirements, and not to evaluate any proposed changes to the 

facility, no public notice should have been required. Nevertheless, PSCAA 

opted to provide an opportunity for public comment, and held a public 

hearing in June. The resulting public comments generally did not relate to 

the proposed order. Instead, PSCAA received complaints about nuisance 

odors, and a number of comments expressing frustration that the proposed 

order did not contain new requirements. In retrospect, the reaction to the 

proposed order should not be surprising, since it was never intended to 

impose new requirements, but rather to consolidate existing requirements. 

All of the physical changes occurred under the 2008 AOC two years earlier 

i.e. installation of grinding building and expansion of the receiving 

building. PSCAA understandably wants to respond to the comments it 

received, even though this Draft Order is not the appropriate vehicle for 

doing so. As explained below, the proposed conditions are not justified,




Commenter 


and are unlikely to respond to the concerns PSCAA heard from the 

community. Cedar Grove remains willing to work with PSCAA, but urges 

the Agency to not proceed with unilateral changes to the permits for the 

Maple Valley facility. In 2008, Cedar Grove committed to PSCAA that it 

would make several changes to the Maple Valley facility to improve the 

capture of odors in several parts of the operation. Cedar Grove then 

proceeded to expand the size of the tipping building, and construct an 

adjacent building to house sorting and grinding operations. These buildings 

are equipped with ventilation systems that pull the air from these buildings 

into a collection system and routes the air through a biofilter, which breaks 

down potentially odorous gases before the air is emitted to the atmosphere. 

Cedar Grove also committed to perform regular smoke tests on the 

performance of the ventilation system. Cedar Grove also agreed, as part of 

the 2008 settlement, to contract for third party evaluations of the emission 

capture system serving the tipping building, the grinding building, and 

Zone 7, as well as biofilter operation, to be performed every six months. 

Those evaluations have been conducted every six months since then, and 

when issues have been identified in the evaluation reports Cedar Grove has 

made the necessary corrections. The proposed permit would increase the 

frequency of those third-party evaluations to quarterly. Nothing in the past 

reports suggests this increase in frequency is necessary. Cedar Grove has 

continued to look for ways to improve odor controls at the Maple Valley 

facility. Earlier this year, Cedar Grove conducted a pilot project placing 

tarps over finished compost piles at another facility. The tarps were 

originally designed for use on landfills, as an alternative to using 

dirt as interim cover on the working face of the landfill at the end of each 

day. In their landfill application, the tarps control odors and vector access 

to the waste in the working face. Air sampling conducted by CH2M Hill 

showed that, when the tarps were placed on finished compost piles, they 

reduced odors from the pile by approximately 50 percent. Cedar Grove has 

ordered more of the tarps, and plans to place them on the finished compost 

piles at Maple Valley. Based on our experience, this should help reduce the 

potential for odors from the finished compost. Cedar Grove identified the 

potential use of tarps on its own, without input from PSCAA, and is 

undertaking the step of covering the finished compost piles voluntarily, 

independently of any order or direction from PSCAA. After seeing the 

potential benefits from use of the tarps in Everett, Cedar Grove also 

considered other uses for them. The primary ASP zones at Maple Valley 

(zones 1-6) currently are not covered, since air is drawn through the piles 

to capture odorous gases and break them down in a biofilter. The fact these 

zones are uncovered has led to some concerns from the Health Department 

about vector control, since some residential yard waste collection now 

contains some residential food waste (in Cedar Grove's experience, the 

food waste is 5 percent or less of the volume of residential collections). 

Use of the tarps on these primary zones would resolve the Health




Commenter 


department's concern about the potential for vector access to the food waste 

component of the residential collections. Cedar Grove also believed that 

use of the tarps would incidentally reduce the potential for odors 

from the piles. Cedar Grove did not believe these zones to be significant 

odor sources. However, Cedar Grove learned that at least one PSCAA 

inspector was telling residents that "garbage" odors they were experiencing 

were attributable to Cedar Grove accepting food waste for composting. In 

fact, that inspector acknowledged earlier this week that he had never 

smelled a "garbage" odor offsite from Cedar Grove that he attributed to the 

compo sting facility. Nevertheless, there has continued to be public 

speculation that acceptance of food waste had increased odors from the 

Maple Valley facility. Cedar Grove told PSCAA management about the 

idea of using the tarps on Zones 1-6 earlier this year, and launched a pilot 

in June to see if the tarps would alter the composting process. The pilot 

showed that the covered piles remained aerobic and composted normally. 

Unfortunately, PSCAA's inspector took the position that this pilot violated 

Cedar Grove's permits for zones 1-6. Accordingly, Cedar Grove suspended 

the experiment in early July. In considering ways to respond to odor 

complaints during July and August of this year, Cedar Grove suggested 

that approval for use of the tarps on Zones 1-6 be included in this revised 

Draft Order. PSCAA informed Cedar Grove that this request had been 

made too late in the process, and would have to be addressed in a separate 

NOC. PSCAA's air engineer also requested more information about the 

effect of the tarps on performance of the existing negative aeration system 

serving Zones 1-6, and on the compo sting process. In order to demonstrate 

that the tarps would not adversely affect either the composting process or 

the negative aeration system, Cedar Grove initiated another pilot with use 

of the tarps in Zones 1-6. As part of the pilot, Cedar Grove had a third 

party contractor take air samples on top of piles that were covered and 

uncovered and ship those sampled to a lab for odor analysis. Also, 

responding to the concern about the impact of residential food waste on 

odors, Cedar Grove prepared a pile consisting only of yard waste and 

collected an air sample above that pile as well. This sampling showed that 

the pile containing a mix of yard and food waste actually produced 

about half as much odor as the yard waste pile. Part of the explanation 

appears to be a higher carbon content in the mixed waste pile, due for 

example to the paper based feedstocks (pizza boxes, etc.) that routinely 

accompany residential food waste. Incidentally, this sampling disproves 

the concern that the addition of a small food waste component in Zones 1-6 

has increased odors from the site. The sampling also showed, not 

surprisingly, that odors above the tarped pile were much lower; about half 

of the result above the mixed waste pile, and about a quarter of that of the 

yard waste pile. Pile temperatures and oxygen levels demonstrated that the 

covered pile remained aerobic and composted properly. Cedar Grove's 

contractor also compared static pressure and fan operations between a




Commenter 


covered and uncovered pile, and found them comparable and within 

normal operating ranges. Accordingly, use of the tarps on Zones 1-6 

appears to be a success. Unfortunately, PSCAA's inspector once again 

objected to their use, issuing an order to Cedar Grove on October 12 

to remove them from the piles immediately. Cedar Grove complied. Next 

week, Cedar Grove plans to submit a request to PSCAA for a 

determination that no NOC is required for use of the tarps, since they do 

not alter existing odor control equipment and do not increase emissions. 

The information described in these comments will accompany that 

application. Cedar Grove also is evaluating whether the tarps could be used 

on the secondary zones at Maple Valley. Differences in the aeration system 

serving that portion of the facility could make that difficult. Also, there has 

been no indication that the secondary zones are a significant source of off 

site odors. Still Cedar Grove intends to continue to evaluate this option, 

and will consider other opportunities to reduce the potential for odors from 

the Maple Valley site as they arise. 

Specific Comments On Proposed Permit Conditions 

No Legal Basis for New Conditions. PSCAA has acknowledged that the 

NOC does not request any production increases, nor any modifications to 

Cedar Grove's operations beyond those previously reviewed and approved 

by PSCAA. The sole purpose of the NOC, which Cedar Grove agreed to 

submit as part of the 2008 settlement agreement between the parties, is to 

consolidate the conditions of previously issued PSCAA Orders of 

Approval and to incorporate requirements established in the 2008 

settlement agreement into a single Order of Approval. As Cedar Grove has 

neither established a new source nor modified a source in a manner that 

would increase air emissions, there is no legal basis under RCW 70.94.152 

or PSCAA Regulation I, Article 6 to impose either new plant-wide 

emission limits or new requirements on specific control devices. 

Continuous Monitoring of Biofilter Airflow. PSCAA has proposed 

requirements for the continuous monitoring of velocity pressure, static 

pressure, and temperature of the inlet gas stream to each biofilter. These 

parameters are not meaningful indicators of biofilter performance, nor is 

continuous monitoring warranted. Air pressure measurements will vary for 

the aerated static piles ("ASP") depending on how many piles are in use 

and activities on the ASP pads. While biofilters serving the grinding and 

tipping building will not see the same level of variation, their air pressure 

readings also are likely to vary over time. These variations, particularly on 

a short term basis, have no implications for biofilter performance. 

Similarly, PSCAA has not identified any correlation between instantaneous 

biofilter inlet gas temperatures and biofilter performance. At a minimum, 

PSCAA should not require continuous electronic monitoring, which may 

be difficult and expensive to install while producing data with little or no




Commenter 


value. Even if the frequency were reduced and manual sampling allowed, 

however, there is no reason to believe the results would correlate to 

biofilter performance. More importantly, PSCAA's inspectors have never 

concluded that the biofilters are a significant source of off site odors, nor 

has PSCAA ever indicated that they have reason to believe they are a 

significant odor source. In fact, during recent inspections, PSCAA 

personnel have focused on insignificant details such as whether a biofilter 

is 127 feet instead of 130 feet long, rather than on whether the biofilter was 

emitting odors. Frequency of Third Party Biofilter Evaluations. The 

apparent purpose of the third-party evaluation of biofilters is to track 

changes in their condition over time to assure that they continue to perform 

within their design parameters, and that biofilter media is maintained and 

replaced as its condition degrades. Semi-annual third-party inspections are 

sufficient to satisfy this objective. As noted above, PSCAA has no reason 

to believe the biofilters at Maple Valley are a significant source of 

offsite odors. This proposed permit condition would increase operating 

expenses while producing no meaningful change in the facility. 

Proposed Odor Limit. PSCAA has proposed a facility-wide emission limit 

that would prohibit occurrence of what the agency characterizes as a Level 

2 odor beyond the property boundaries. There is no legal basis for this 

proposed limit, and it should be removed from the Draft Order. 

PSCAA's Regulation I, Section 9.11(a) prohibits emissions which 

unreasonably interfere with enjoyment of life and property. Section 9.1 1 

(b) specifies how PSCAA is to apply this standard to odors. It provides that 

the control officer or a duly authorized representative must document three 

criteria: (1) a Level 2 odor on the scale specified in 9.1 1 (b); (2) the source 

of the odor; and (3) an affidavit from a person making a complaint that 

"demonstrates that they have experienced air contaminant emissions in 

sufficient quantities and of such characteristics and duration so as to 

unreasonably interfere with their enjoyment of life and property." 

PSCAA's proposed emission limit would remove a necessary component of 

Section 9 .11 (b): the existence of a complainant who will provide an 

affidavit demonstrating that they have experienced a nuisance odor from 

that source. It also could obviate the need to determine the source of the 

odors. As written it appears that a PSCAA inspector could claim a 

violation of this condition had occurred without ever stepping on the Cedar 

Grove site to confirm it is the source of an odor. Given the propensity of 

PSCAA inspectors to attribute all odors in the Maple Valley/Maple Hills 

area to Cedar Grove (including even "garbage" odors that could not be 

from the Cedar Grove facility), this no doubt would occur if this provision 

were retained in the Draft Order. 

Conclusion 

Cedar Grove continues to improve odor controls at its Maple Valley




Commenter 


facility. The new conditions proposed in the Draft Order are not legally 

sound. More importantly, they will not advance that effort. Cedar Grove 

therefore requests that the newly proposed conditions be removed and that 

the Approval Order be issued as originally proposed. 

Jerry Bartlett 

Chief Environmental and Sustainabilitv Officer 

Chuck & Judy 

Sampson 

(Written 10/14/2010, 

Received 10/31/2010) 

We live in the High Valley neighborhood above May Valley. We have 

never made a complaint about the odor that we have been told emanates 

from Cedar Grove. Some days it is quite strong and offensive that it is 

hard to believe that it comes from such a distance. I feel sorry for anyone 

who lives closer. We would appreciate anything your organization can do 

to encourage Cedar Grove to mitigate the odor.




Summary Response to Additional Public Comments Received (NOC 10052) 

September 13 – October 28, 2010 

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

hearing. These comments are considered a part of the overall public record for the proposed 

NOC order of approval. In many ways, the comments received during this public comment 

period were similar to the comments that were received during the previous comment period. 

The Agency grouped the comments into recurring themes, and replied to the comments in a 

summary fashion. 

1. Previous comment concerns are consistently raised 

The Agency identified nine general categories of comments during the original comment 

period (documented above) and the comments received during the latest comment period 

generally fall into those categories Those nine comment categories included: 

 

 

 

 

 

 

 

 

 

Odors from the facility are a persistent nuisance 

Odors are an embarrassment to residents during guest visits 

Odors from the facility negatively impact school operations 

Facility impacts have negative impact on property values 

Emissions from the facility are negatively impacting resident’s health 

Complaint record does not accurately reflect the level of impacts 

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

morning, & weekends. 

Limit the operational level of Cedar Grove until they can perform 

Cedar Grove has no credibility in community, cannot police themselves 

Many of the same points were made during the original comment period and hearing, 

although many of the comments received were from community members who had not 

previously commented. Some of the comments received during this comment period 

exhibited stronger opinions. For example, there was a stronger sentiment for action that 

would shut operations on the site down. There were also comments regarding qualified 

support for composting objectives tempered by the impacts to the residents. 

There were more specific comments received this time regarding Cedar Grove’s evening 

operations and their contribution to impacts in the neighborhood. There were some 

suggestions that these evening activities was being done to avoid scrutiny. The Agency 

has no information to support the notion the evening work was being done to avoid 

scrutiny.




2. General support and concerns with respect to the proposed order of 

approval conditions 

Comments received on the proposed revisions to the order of approval (in comparison to 

the original public comment proposal) were generally supportive, with some qualified 

reservations. Some commenters said that the revisions would be helpful to the 

community providing they are implemented and enforced. Others thought they would 

help, but expressed doubts that they would lead to enough emission performance 

improvements to resolve the impacts to the community. The Agency believes that the 

proposed revisions will support improved emission performance from Cedar Grove’s 

operations. 

3. Confusion regarding this permit process, other agency activity 

outside of permitting, and the roles/responsibilities/authority of the 

various agencies that regulate Cedar Grove’s operations 

The Agency acknowledges the confusion that surrounds the various regulatory roles and 

actions regarding Cedar Grove’s operations. Despite that confusion, the Agency must 

continue to implement its program in accordance with the laws and rules that govern the 

facility. The Agency anticipates scheduling follow-up workshop meetings in the near future 

within the affected community to discuss the programs and actions of this Agency and 

answer questions. 

4. General concern regarding the validity of technical work done by 

others and the independence that work will have 

Some commenters expressed a general concern about the validity of information collected or 

developed by the Agency, by Cedar Grove, or by contractors working for Cedar Grove. The 

Agency will be issuing a regulatory order which requires Cedar Grove to collect specified 

emission data through testing and will require the use of outside contractors who have the 

technical expertise and capacity to perform this work. That is a common practice for 

compliance testing requirements at other regulated sources. The key to collecting technically 

valid emission data starts with the original test order, the subsequent test planning, and 

observation and oversight of the testing work, and the complete documentation and review of 

the final report. The Agency will review and oversee the work specified in the regulatory 

order. 

One commenter said money for testing should be obtained through other sources rather than 

have Cedar Grove pay the testing contractor. The Agency disagrees with this comment. The 

need for this emission data is a result of Cedar Grove’s operations at this site and thus, Cedar 

Grove has an obligation to clearly identify the emissions from its facility. Others should not




be paying for this work for Cedar Grove and the Agency believes that its involvement 

throughout the testing program should ensure that quality and representative data is collected 

and documented. Other technical work completed by others on behalf of Cedar Grove to 

satisfy a compliance requirement is also consistent with past practices by other sources. 

Again, involvement and oversight by the Agency is an important component to ensure that 

work is done adequately. 

5. Observation that Maple Valley is bearing the brunt of impacts from 

choices made by other jurisdictions for solid waste management 

The Agency acknowledges this concern. This is an issue beyond the scope of this permit 

action. The siting and past approvals for composting at this location are a part of the 

historical record. The proposed order of approval is one component of a combination of 

several regulatory elements which apply to Cedar Grove. It has been the intention of this 

Agency to improve emission performance of Cedar Grove’s operations to relieve the 

community of the odor impacts. 

6. Desire that the emission testing order for Cedar Grove to complete 

have the testing done earlier than the anticipated schedule 

The Agency is issuing a regulatory order for emission testing in conjunction with the final 

action on this application. The comments saying the testing should be done earlier rather 

than in the spring and summer seasons originally identified by the Agency is not feasible. 

Testing earlier will also not obtain representative emission data for an operational period of 

potentially maximum emissions. From the logistical standpoint, the planning and 

organizational work necessary by Cedar Grove and its testing contractors will take several 

months to mobilize resources to ensure the appropriate sampling and analytical work is ready 

to go. From a representative emission perspective, the desirable emission testing period is 

the summer (e.g. June to August timeframe). This is when the maximum throughput is 

occurring at the site. It allows maximum production activity levels at each of the emission 

units/activities identified for the site. Peak grass season typically starts in April/May and will 

be moving through the various process steps onsite until August/September. Additionally, 

the previous comments indicated that odor emissions from the site were impacting 

individual’s health and this intention to order emission testing is partially driven by that 

interest. Since the testing period anticipated also coincides with the typically peak offsite 

impact periods, the Agency believes the representativeness and validity of this testing 

direction is sound.




7. The agency has exceeded its legal authority with the proposed order 

or approval revisions and should return the order to the originally 

proposed conditions 

The Agency disagrees with the comments of this nature and believes it has the authority to 

issue the order of approval that was proposed for comment on September 13, 2010. 

8. The revised approval conditions will not improve emission 

performance for the site and voluntary measures proposed/taken by 

Cedar Grove will be more effective 

The Agency would welcome and consider any voluntary measures that Cedar Grove would 

like to propose to improve emission performance and reduce the impacts of emissions offsite. 

Experience to date has demonstrated that voluntary measures alone have not resolved the 

impact concerns in the community. The proposed elements of the order of approval clarify 

the currently known operational and maintenance practices which support more effective 

emission management and identify the performance level that would define effective 

emission control. 

9. Agency Conclusions 

The Agency has reviewed all of the comments received and has decided to issue Order of 

Approval No. 10052 as proposed on September 13, 2010, without any additional 

revisions. 

In addition, the Agency is issuing 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. This Regulatory Order is being issued on the same day 

as Order of Approval No. 10052.

Additional Comments Summary Response to Additional Comments

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