CMRA Executive Director William Turley met with representatives of the White House’s Office of Management and Budget (OMB) to discuss the ramifications of the then unreleased Non Hazardous Secondary Materials (NHSM) rule from the U.S. Environmental Protection Agency. Others involved in the meeting, which was requested and led by the CMRA, included Max Lee, Phd, Koogler Associates, Angela Morrison, Hopping Green & Sams, Kerry Kelly, WMI, and Chaz Miller, NSWMA.

The reason for the visit was that OMB was reviewing the entire suite of boiler rules, including the Boiler MACT, CISWI, and NHSM. It was an opportunity to again provide to the regulators the viewpoint of C&D recyclers on the rule’s negative effect on the use of C&D biomass wood as a fuel to replace traditional fuels.

Specifically, OMB was told that the wood is heavily processed and prepared, and a description and photos were provided showing how C&D biomass is created. That includes removing as many contaminants as possible. It was explained that this was done for two reason: some states require it, and that the end user, the boilers, needed to have that level of quality fuel in order to meet their permit requirements. Otherwise, the material would not be accepted and have to go to a landfill, a cost the recycling facility would not like to have. So there already is a thorough inspection and regulatory process the wood goes through, and the addition of the NHSM rule would only add more regulatory burden to an industry dominated by small and medium sized businesses.

OMB personnel asked specific questions about C&D biomass, which the group answered. But OMB is not allowed to provide any information on how they were thinking, and any changes would have shown up when the rule was later released.

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