Chapter 3.1
Development Patterns and Infill

• ALL
• Remove Code Barriers
• Create Incentives
• Fill Regulatory Gaps

Composting in Agricultural, Residential, and Commercial Districts

INTRODUCTION

Composting is gaining prevalence as a way to minimize waste, reduce landfill emissions, support local food systems, help build community resilience, and create a marketable product out of materials that were once thought of as nothing more than burdensome municipal wastes. It is more important now than ever for both residents and policy makers to have a resource to guide them in tailoring a workable composting system that fits their community. The United States Composting Council and Sustainable Development Code collaborated on this policy brief to serve as a starting point for local governments seeking to establish new zoning categories to address composting, as well as to provide a broad view of state regulations and other potential code considerations to expand organics collection in communities. With examples from communities who have already enacted provisions to spur composting efforts, this brief has something to offer for both rural and urban communities alike. Importantly, similar to most local regulations, local composting regulations are subject to state law. Any community interested in local composting regulations should double check their local home rule or enabling legislation to make sure any proposed regulation complies with state law.

This brief describes local ordinances that allow composting in agricultural, commercial and residential zones. In addition, it identifies ordinances that permit commercial composting in association with organic waste collection services. The Association of American Plant Food Control Officials (AAPFCO) and United States Composting Council define compost as “the product manufactured through the controlled aerobic [involving the use of oxygen], biological decomposition of biodegradable materials. The product has undergone mesophilic [relatively moderate] and thermophilic [relatively hot] temperatures, which significantly reduces the viability of pathogens and weed seeds, and stabilizes the carbon such that it is beneficial to plant growth.”[1] Compost is typically used as a soil amendment, but may also contribute nutrients to plants.[2] Recognizing that there are benefits to allowing composting, discussed in more detail below in the Effects section, some local governments are permitting composting in certain districts. Such composting regulations are commonly found in the solid waste portion of local codes.[3] Composting regulations across local governments vary in that some subject varying types of composting operations to a permit process,[4] while others allow composting as a by-right or accessory use,[5] and still others employ a combination of the two approaches.[6]

Ordinances that allow composting typically authorize only certain feedstocks,[7] which are defined as organic wastes used as inputs for composting.[8]  Often, local regulations set the size of composting operations (usually measured in cubic yards or tons allowed to be on-site over a given period of time)[9] or the percentage of the property that may be dedicated to composting.[10] In addition, some local regulations control the type and form of permissible composting activities. Some jurisdictions allow for higher windrows at sites that can support bigger operations, such as farm fields.[11] Local ordinances vary in their definitions, but a standardized version describes windrows as “forming organic waste into rows of long piles” that are “[aerated] periodically by either manually or mechanically turning the piles.”[12] Other places might allow vermicomposting, where red worms are placed within feedstocks to assist in the composting process.[13]

Communities may have provisions that regulate “small site” composting, or similar categories that are larger than residential backyard composting yet have less of an impact than commercial operations, such as those that take place at community gardens or urban farms.[14] Small site operations allow for a larger amount of compost materials to be on-site relative to backyard ordinances, and allow feedstocks to be collected from both on- and off-site sources.[15] Provisions governing community garden composting may restrict feedstocks to yard waste only, or allow for other materials to be introduced such as food scraps (though these might face additional regulatory measures).[16] Community garden composting may allow for the reception of materials generated off-site.[17] Operators at urban farms may have to receive a local permit before commencing composting activities.[18] Ordinances covering composting at urban farms might allow for the use of both organic and livestock wastes as feedstocks, though local governments often put strict conditions on how food scraps and manure are handled in order to avoid sites becoming a nuisance to the public.[19] Jurisdictions that allow urban farm composting have the option of allowing finished compost to be sold and used off-site in their regulations.[20]

Backyard composting is typically limited to compost bins (mostly enclosed structures with small vents or openings for aeration) and compost piles (stacks of open-air feedstocks that have strict size limitations).[21] In many cases, regulations require a compost pile or bin to be sited in a side yard or back yard.[22] Local governments with these requirements should anticipate questions concerning compliance on uniquely situated properties, such as corner lots.[23] Regulations addressing backyard composting and the options described above can be drafted to permit multiple residents to combine feedstocks and compost as a joint operation.[25]

Local governments usually incorporate state operational permitting requirements to ensure the facility’s operation complies with best practices to mitigate odor and other issues. Some local governments may require piles to have enclosures on one or more sides and may also list the approved materials for construction of the enclosure.[26]

While many composting ordinances are found in suburban and rural areas, densely populated urban areas are also permitting composting where practical or allowing for curbside compost pickup.[27] New York City, for example, allows micro-haulers (individuals who can transport organic waste on bicycles)[28] to pick up organic waste for transport to a processing facility.[29] More aggressive approaches, such as the City of San Francisco, require residents and businesses to separate compostable feedstocks from other solid wastes.[30] In addition, San Francisco provides collection bins to make compost available for curbside pickup, where it is then hauled to a commercial processing facility in partnership with the City.[31]

Local governments are also exploring ways to increase commercial composting. Commercial composting facilities are usually subject to state permitting regulations[32] and site plan approval that may require owners or operators to detail the position of fixed equipment that will be used, the placement of structures, and where feedstocks will be located.[33] Commercial facilities often face stricter regulations regarding nuisance activities; for example, because large compost operations can create a large amount of dust,[34] odors, or attract vectors (e.g. insects and rodents), some communities institute remedial measures such as requiring that dust does not blow onto neighboring properties.[35] Commercial composting regulations can also require the implementation of strategies to prevent stormwater from running onto the compost location from adjacent areas, alongside a plan to prevent runoff when water accumulates on the site.[36] In addition, ordinances can require large facilities to be screened from public view and to comply with strict setback regulations.[37] Several regulations require adherence to best management practices, such as site monitoring and frequent temperature checks to certify that safety precautions are met.[38] Local governments have also incorporated regulations that address noise levels from composting and grinding activities when facilities are sited close to residential areas.[39]

Finally, local governments should be conscious of odor and rodent or insect infestation concerns that have been raised in the context of composting. Such concerns can deter communities from maximizing on the benefits of composting and from adopting measures that enable composting within their jurisdiction.[40] However, trained and certified operators using proper technology and management practices can provide the positive result of finished compost while minimizing or eliminating the nuisance of odors and pests.[41]

EFFECTS

More than 40 million tons of food waste and eight million tons of yard waste are discarded into landfills annually in the United States.[42] These materials account for approximately 28 percent of the country’s total waste deposits.[43] In 2017, communities on average spent $51.82 per ton on disposal costs of solid waste.[44] Composting reduces the amount of organic wastes that end up in landfills[45] and creates an economic opportunity out of materials that would otherwise remain a financial burden.[46] Moreover, municipal composting operations can contribute to economic development in the form of local jobs in processing plants and  marketable products by way of finished compost.[47]

Recycling organic waste can also have a positive impact on the environment. Organic waste in landfills emits methane as it breaks down.[48] Landfills rank as the United States’ third largest source of methane emissions.[49] Methane is a key contributor to ground-level ozone (a.k.a. smog) as it binds with nitrogen oxide when the chemicals are present in the air and exposed to sunlight.[50] In addition, methane is a highly reactive greenhouse gas, many times more potent and destructive to the atmosphere than carbon dioxide.[51] Composting helps to alleviate problems associated with methane emissions by exposing organic wastes to oxygen, changing its decomposition process and thereby reducing emissions. In contrast, landfills cause waste to undergo anaerobic (zero oxygen) decomposition, which creates methane as a byproduct when organic materials decay.[52]

Agricultural operations can benefit from ordinances that allow the use of finished compost on site. Compost use promotes microorganisms that are critical to good soil health.[53] Healthy microorganisms, in turn, improve plant life by providing a better growing medium and helping fight vegetative diseases.[54] Compost-amended soil also confers improvements to water infiltration rates, water retention, and nutrient availability for vegetation.[55] Landowners may save on costs by not having to purchase additional fertilizers.[56] Avoiding commercial fertilizer may also reduce the negative environmental impacts associated with its use, such as nutrient runoff.[57] Research indicates that that crops grown in composted soils produce at higher yields.[58] Also, adding compost to degraded soils improves soil health and the productivity of crops grown within.[59] Some communities have combined composting ordinances with community garden ordinances as community gardens may also benefit from composting[60] (for our brief on permitting community gardens in numerous districts see Community Gardens on Private Property as a By-Right or Permitted Use).

Soils amended with compost help to protect watershed quality.[61] Composted soils can reduce nutrient runoff from stormwater and reduce the potency of nitrogen and phosphorous that enter water systems.[62] Greater infiltration rates reduce the speed and volume at which stormwater enters traditional gray infrastructure or fresh water sources.[63] During the infiltration process, pollutants such as “heavy metals, pesticides, herbicides and other contaminants” bind with the compost, decreasing leachate and reducing their uptake into plants.[64] One study found that a thin layer of compost spread over a 10-acre development could reduce treatment costs by $181,428 annually when compared to a site with impervious surfaces.[65]

EXAMPLES

Cleveland, OH

Composting facilities are allowed in Cleveland’s General Industry Districts.[66] All facilities must be located at least 500 feet from adjacent residential zones.[67] The facility must be screened by a seven-foot wall or fence that may not be closer to the street than the setback line.[68] The wall or fence may have one opening up to twenty feet wide or two openings of that size if the barrier is more than 200 feet long.[69] Walls and fences must be well constructed and maintained in good order.[70] Feedstocks may not be stacked higher than eight feet above the height of the fence or wall.[71] Composting operations may also be performed as an accessory use on sites where the principal use is agricultural.[72]

Operating under this framework is the Rust Belt Riders composting service, a United States Composting Council Member founded to divert organic waste from landfills and create compost to support local agriculture.[73] Rust Belt Riders offers a residential pick-up service for source-sorted organic waste.[74] Residents can also drop off their compostable materials at Rust Belt Rider sites.[75] Rust Belt Riders can also arrange pick-up services for commercial establishments.[76]

To view the provisions, see Cleveland, OH, City of Cleveland, Ohio Code of Ordinances Pt. III(B) Tit VII Ch. 337 § 337.25 (2010); Cleveland, OH, City of Cleveland, Ohio Code of Ordinances Pt. III(B) Tit VII Ch. 345 § 345.04 (2018).

Altoona, WI

Altoona’s Code provisions provide for both backyard and small site composting.[77] Small compost sites are limited to less than 50 cubic yards.[78] They may receive feedstocks “from multiple households, multifamily dwellings, commercial properties, or institutions.”[79]A small compost site must be located at least six feet from property lines and principal buildings.[80] With the exception of a dwelling on which the site is located, small compost sites may not be within twenty feet of any residency.[81] Back yard compost sites may not exceed 125 cubic feet and must generate feedstock and use all finished compost on-site.[82] Bins on backyard sites are limited to five feet in height, and must be separated from property lines and principal buildings by at least four feet.[83]

The Code requires all composting to take place in free standing bins, excepting yard waste that does not contain fruit, which may be set in a compost pile.[84] All composting sites must be maintained so as not to attract or harbor rodents and pests, or emit odors.[85] Piles and bins must be situated so they are not at any time in standing water, and must be kept in a manner to prevent storm water from infiltrating and running off of the materials.[86] Bins and piles must be sited at least 25 feet away from waterbodies, wetlands, or areas within a 100 year flood plain.[87] Acceptable feedstocks include “raw vegetables and food scraps, yard waste, egg shells, unwaxed recyclable paper, [and] commercial compost additives.”[88]

To view the provisions, see Altoona, WI, Altoona Municipal Code Ch. 8 § 8.34.20-8.34.040 (2018).

Chicago, IL

Chicago allows both gardening and urban farming operations to compost under separate regulations.[89] Urban farms may not begin composting without first obtaining a permit.[90] Acceptable feedstocks on urban farms are organic and livestock waste, although the permit may place reasonable limitations on the composting operation including limiting how much livestock waste may be used.[91] Composting activities may not exceed two percent of the site’s acreage.[92] Food used as feedstock must be integrated into the composting process the same day it is generated or received from off-site, and other organic wastes or livestock waste must be either integrated or covered and sealed in a well maintained “steel or rigid plastic container” on the same day it was generated or received from off-site.[93] Finished compost may be sold for off-site use but must meet the quality standards set by the Illinois Pollution Control Board.[94] Windrows, bins, and “anaerobic digestion composting technologies” may be used to compost feedstocks.[95]

The Code provides specific carveouts from the permit process for garden composting.[96] A “Tier I garden composting operation” is one that does not need a permit and only composts yard waste, which can be generated on- or off-site.[97] Tier I gardening sites may not engage in any commercial activities attendant to composting, accepting feedstock, or landscaping.[98] The size of Tier I gardening sites is limited to ten cubic yards of feedstock or finished compost, though the Commissioner of streets and Sanitation may grant a variance of up to 25 cubic yards.[99] A “Tier II gardening operation” is one that may compost yard waste and a limited amount of organic waste.[100] Organic waste on a Tier II site may not exceed ten percent of the total feedstock being actively composted at any one time.[101] All food scraps must be integrated into the composting operation the day it was generated or received from off-site, and any other organic waste must either be integrated or covered and sealed in a well maintained “steel or rigid plastic container” on the same day it was generated or received from off-site.[102] Operators at Tier II sites must keep and make available records for inspection in a form as set out by the City Commissioners.[103] All finished compost from these sites must be used on site, and the same restrictions on size and commercial activity apply to Tier II gardening operations as do to Tier I.[104]

Garden composting operations may not “[create] odor, litter, dust or noise nuisance, or attracts vectors or pests.”[105] Chicago may require additional measures for pest controls such as grinding feedstock, putting up netting or screens, or mandating the use of bins.[106] Composting operations may not be situated in such a manner that they sit atop standing water, and operators must ensure water does not run off feedstocks and create standing pools of water.[107] Feedstocks that are actively composting must be turned at regular periods as needed until the process is complete.[108]

To view the provisions, see Chicago, IL, Municipal Code of Chicago Tit. 7 Ch. 7-28 § 7-28-715 (2015); Chicago, IL, Tit. 11 Ch. 11-4 Art. XX § 11-4-2545 (2015); Chicago, IL, Tit. 11 Ch. 11-4 Art. XX § 11-4-2510 (2017).

Ferguson, MO

Owners and residents in Ferguson can apply for a permit to compost on their property.[109] A site plan must be submitted to the Director of Public Works before approval is granted.[110] The plan must note the site’s dimensions and the feedstocks to be used.[111] Ferguson issues permits for freestanding compost piles on lots ten acres or more; sites below this threshold must have containment walls or store compost materials in bins.[112] Piles on lots smaller than ten acres are limited to 125 cubic feet in size, while bins may be larger so long as a method of inspection is available.[113] The City permits a maximum of three bins on lots 5,000 square feet or smaller.[114] One bin may be added for each additional 10,000 square feet.[115] On properties greater than ten acres, compost piles are allowed to be stacked in windrows that occupy 800 cubic yards of space.[116] These sites may add an extra windrow or expand an existing windrow by 20 feet for each additional acre of land.[117]

Odor, pest, and rodent controls must be implemented so as not to cause a nuisance in the area.[118] The Code requires that operators balance the carbon and nitrogen levels in the feedstock to facilitate the best results and lowest level of odor possible.[119] Piles and bins must be located in side or rear yards, five feet away from the backyard boundary and 30 feet away from any neighboring “home, patio, pool, or similar structure.” Acceptable feedstocks listed in the Code are “leaves, paper, sawdust, straw, sod and grass clippings, aquatic weeds, coffee grounds, evergreen needles, pre-consumer organic food scraps, vegetative garden waste, untreated wood and chips, herbivore manure and commercial compost additives.”[120] “Vegetables, fruit and their remains, egg shells, fruit peels and rinds” need to be placed in compost piles so that they are buried in the center of the pile.[121] Finished compost products are meant for personal or on-site uses only, though producers may seek the City’s permission to sell and distribute if they desire.[122]

To view the provisions, see Ferguson, MO, Code of Ordinances Ch. 37 § 37-6 (2009).

Island County, WA

Island County has a comprehensive ordinance that is described here in detail. Island County composting provisions are designed to lessen the quantity of recycled material from entering landfills and to facilitate the beneficial use of compost.[123] Pursuant to the Code, large compost and grinding facilities must apply for a permit or be subject to conditional use requirements,[124] but exceptions are in place for less intensive operations.[125] The Code details the zones where permit-required and permit-exempt operations may be sited. Non-commercial home composting is allowed in all districts.[126] Home composting is performed by owners and tenants of single-family residences or multifamily residences consisting of “two to five families, such as a duplex or clustered dwellings.”[127] Ten cubic yards of bin composting is allowed in every district for food waste that is produced by a site.[128] Composting on agricultural land (ag-composting) performed according to a farm management plan is allowed in the R (Rural), RA (Rural Agriculture), and CA (Commercial Agriculture) zones.[129] Sites where feedstock is generated off site and then composted on site are allowed in the R, RA, and CA districts if the primary use of the property is agricultural.[130] Up to a total of 1,000 cubic yards of compost may be processed annually at these locations.[131] Enclosed operations that utilize vermicomposting are authorized as a by-right use for up to 10 cubic yards except in the Rural Residential Zone and on any parcel sized under two and a half acres.[132] In the R, RA, CA, and RF (Rural Forest) districts, composting facilities that require a permit are subject to conditional use review.[133]

The County categorizes feedstock into four “Types.” Type 1 is set as the lowest risk and Type 4 the highest risk. The categories are based on potential issues arising from the feedstock, such as the harborage of pathogens, hazard level, and contamination potential.[134] Type 1, for example, includes yard, garden, and wood wastes, while Type 4 includes a variety of solid and industrial wastes, such as “industrial biological treatment sludges.”[135]

The County exempts a variety of composting uses from the permit process.[136] Exempted composting uses are still subject to the non-permitting regulations set forth in the Code.[137] For example, vermicomposting of feedstock Types 1-3 is allowed without a permit when the feedstocks are generated on site, the operation is enclosed, and feedstock quantities on site are less than 50 cubic yards.[138] In addition, up to 250 cubic yards of feedstock Types 1-2 (which may come from sources generated off site) may be composted on site without a permit; the 250 cubic yard limitation includes all material from beginning feedstocks to finished product.[139] Furthermore, up to ten cubic yards of composting bins may be used for food wastes produced on site so long as the bins are designed to keep pests away and prevent odor.[140]

Some categories of ag-composting are also exempt from the permit process.[141] There are no limitations on ag-composting when feedstocks are generated on site and the end product is used on site.[142] When an ag-composting operation uses feedstock generated from other locations and the composted material is intended for on-site use, up to 1,000 cubic yards of material spanning from raw feedstocks to finished compost may be stored on site.[143] When finished compost is intended for off-site distribution, composting may operate without a permit if it contains less than 1,000 cubic yards of compost material or if the site is operated pursuant to a farm management plan created in accordance with “a conservation district, a qualified engineer, or other agricultural professional.” The conservation district, engineer, or agricultural professional must confirm that the plan meets the conservation standards set forth in the Washington Field Office Technical Guide.[144]

All permit-exempt composting sites are still subject to inspection by the Departments of Health and Ecology.[145] Permit-exempt sites must not pose a health or environmental threat.[146] All reasonable methods must be used to protect water sources, such as appropriate setbacks from areas where runoff is likely to deposit harmful materials therein.[147] Odors, as well as animal and insect infestation, must be managed so as not to become a nuisance.[148] Operators of permit-exempted ag-composting sites and sites with more than 40 cubic yards of compost materials that intend to distribute finished compost off site must prepare an annual report to ensure that potentially harmful contaminants in the composted product are at acceptable levels.[149]

Composting facilities that do not fit into an exempted category must obtain a permit after submitting a comprehensive site plan detailing the location of feedstock and finished compost storage areas, processing areas, structures, fixed appurtenances, leachate mitigation devices, and others. In addition, composting facilities must submit design specifications for stormwater management, composting pads, and collection/conveyance systems that control leachate.[150] The Code outlines minimum requirements for composting pads, as well as curbs or grading to direct the flow of leachate.[151] Composting facilities that need a permit must also use methods that prevent stormwater from running onto the property.[152] Leachate must be diverted into a holding tank or retention pond that is designed and lined in accordance with the technical specifications listed in the Code.[153] The Code also requires that site designs “take into account porosity, nutrient balance, pile oxygen, pile moisture, pile temperature, and retention time of composting” before operations begin.[154]

Additionally, the Code regulates dust, odor, contaminants, and infestation by pests and rodents on permitted sites.[155] At all times during operating hours, a permitted site must be supervised and staffed, and access to the site must be restricted when closed.[156] When feedstock Types 2-4 are used, documentation is required to note that pathogen reduction actions have been performed, such as temperature monitoring, pile turning, and other technical specifications as required by the Code.[157] Operators are responsible for weekly inspections; sites using retention ponds for leachate must also have the pond’s liner inspected once every five years and must provide notice to the Health Department of such inspection.[158] The regulations require an annual report to be submitted to the Health and Ecology Departments.[159] An operational plan for the site must be created and be available for inspection by the Health Department.[160]

The Code provides siting standards for facilities that are more complex compared to home and simple agricultural composting operations, which are exempt from the following standards.[161] Larger facilities must be sited on a lot of at least 10 acres (unless otherwise exempted),[162] screened from public view, and set back at least 150 feet from each property line.[163] Operations that have a water well on site must be located 200 feet away from the well; if there is a well on an adjacent property, the distance is increased to 500 feet.[164] A fence or vegetative buffer must be utilized to catch blowing material and to keep both noise and dust from affecting the surrounding area; new sites without an existing buffer may face greater setback requirements.[165] The County retains the right to shut down facilities unable to “control nuisances such as noise, odor, dust, or vectors.”[166]

To view the provisions, see Island County, WA, Code of Ordinances Tit. VIII §§ 8.08B.030, 8.08B.050, 8.08B.150, Tit. XVI, § 16.13.040(A)(2) Tit. XVII §§ 17.03.040, 17.03.180(X) (2019).

ADDITIONAL EXAMPLES

Hoboken, NJ, Code of the City of Hoboken Ch. 151 § 151-4(D) (authorizing the City to contract with a service to provide for compost pick-ups. Hoboken formed a contract with US Composting Council member Community Composting Company).

Frederick County, MD, Pt. I Ch. 1-19 Art. VIII Div. 4 § 1-19-8.408(A)(1-3) (allowing compost operations on sites that are five thousand square feet or greater and zoned for agricultural uses according to the following: operations five acres or less are allowed by-right, operations between five and ten acres require a site-plan approval, and those greater than ten acres must obtain a solid waste handling permit).

Ontario, CA, Development Code Ch. 5 Div. 5.03 § 5.03.415(F)(2) (permitting composting operations subject to the approval of a conditional use permit. Where appropriate, Ontario will require compost to be turned based on pile temperature, and not a predetermined schedule).

Knoxville, TN, Code of Ordinances App. B Art. 10 § 10.3(I) (2020) (limiting the size of compost bins and piles to five percent of the lot size and limiting their height to no more than six feet).

Akron, OH, Code of Ordinances Tit. 9, Ch. 94 § 94.34(D) (2012) (requiring compost piles to be layered with six to twelve inches of plant materials at the ground level, then a two to three inch layer of herbivore manure or vegetable material, followed by a “layer of nitrogen-based chemicals or fertilizers,” with a one to two inch covering of topsoil; maximum height is five feet).

Montgomery County, MD, Montgomery County Code Pt. II Ch. 48 § 48-17B(b)(1-9) (2017) (requiring a composting study that includes what changes could be made to the County Code, policy suggestions, best management practices, metric models that describe how to efficiently divert food waste, and any challenges that might be encountered plus ways to overcome those challenges).

New York, NY, The New York City Administrative Code Tit. 16 Ch. 3 Subsec. 2 § 16-306 (2019) (authorizing “private carters” (a.k.a. micro-haulers) to collect organic wastes for reuse).

Basalt, CO, Municipal Code Ch. 18 Art. II § 18-24(d)(2)(e) (2020) (allowing indoor composting systems to count toward a point total that must be satisfied before the Town will issue a building permit).

San Francisco, CA, San Francisco Environment Code Ch. 19 § 1903 (2009) (requiring compostable materials to be separated from other wastes and made available for later pick-up).

ADDITIONAL RESOURCES

U.S. Composting Council, www.compostingcouncil.org and its State Regulations & Model Permitting Ordinance: https://www.compostingcouncil.org/page/StateRegulations.

Association of American Plant Food Control Officials (AAPFCO), https://www.aapfco.org/

Brenda Platt, Nora Goldstein, and Craig Coker, State of Composting in the U.S., Institute for Local Self Reliance (2014), https://perma.cc/N2SK-WYPD.

Brenda Platt, James McSweeney, and Jean Davis, Growing Local Fertility: a Guide to Community Composting, Institute for Local Self Reliance (2014), https://perma.cc/DK22-HTBF.

Composting for Community Map, Institute for Local Self-Reliance, https://perma.cc/HUF8-R8N9 (last accessed Oct. 25, 2020).

Strategic Plan to Advance Composting, Compost Use, and Food Scraps Diversion in Montgomery County, Maryland, Montgomery County, Maryland Department of Environmental Protection Division of Solid Waste Services (Apr. 2018), https://perma.cc/Y8YW-4NB8.