Schoharie County Submits Public Comment to DEC Biosolids Policy Urging Caution and Regulatory Oversight

SCHOHARIE - This week, Schoharie County submitted public comment on the NYS Department of Environmental Conservation (DEC) Draft DMM Program Policy 7a. The following statement was provided on January 10, 2026.

Schoharie County submits this comment to express concern with the DEC’s current approach to biosolids recycling and land application, particularly as it relates to agricultural lands. While the County recognizes the stated nutrient and soil amendment benefits of biosolids, substantial scientific evidence indicates that biosolids commonly contain per- and polyfluoroalkyl substances (PFAS) and heavy metals, including but not limited to cadmium, lead, mercury, and arsenic. Existing wastewater treatment and biosolids processing technologies do not reliably or fully remove these contaminants.

Peer-reviewed research[1] has demonstrated that PFAS and certain heavy metals are persistent, bioaccumulative, and mobile in agricultural systems. When biosolids are land-applied, these contaminants accumulate in soils, can be taken up by crops, and may migrate into surface and groundwater. Repeated applications increase contaminant loading over time, raising long-term risks to food safety, drinking water supplies, livestock health, and farm viability. 

Schoharie County’s agricultural economy depends on soil integrity, water quality, and consumer confidence in the safety of agricultural products - as do many counties across New York. The current regulatory framework governing biosolids does not adequately account for long-term persistence, or bioaccumulation of PFAS and heavy metals nor does it address how to adequately test and mitigate for these contaminants. In the absence of enforceable, health-based standards and comprehensive monitoring requirements for these contaminants, land application of biosolids cannot be considered sufficiently protective of environmental resources or agricultural systems. 

The County urges the DEC to reevaluate its biosolids policies using a precautionary, science-based approach. Specifically, biosolids should not be promoted or approved for agricultural land application unless PFAS and heavy metals can be effectively removed, or unless strict contaminant limits, transparent testing, and long-term monitoring are required and enforced.

Protecting agricultural soils is essential to the long-term economic and environmental sustainability of Schoharie County and New York State. Regulatory decisions regarding biosolids must reflect current scientific understanding and prioritize the protection of farmland, water resources, and public health.