Should Havering County Spread Biosolids on Farm Fields?

Resolution: Havering County should permit treated biosolids from the Pennfield plant to be spread on farm fields in the county.

Havering County is fictional. Its Pennfield Water Reclamation Plant treats wastewater for about 40,000 people. Treatment separates the water from the solids. The water is cleaned and released to a creek. The solids are held in a heated tank where microbes break them down, a step called digestion, and the digested material is then dried into a crumbly product called biosolids.

Those biosolids have to go somewhere. Right now the county trucks them to a landfill two counties away. Farmers in the Pennfield valley have asked the county to let them spread the material on cropland instead, because it carries nitrogen and phosphorus that crops use. A fictional county estimate puts the landfill cost at $92 per ton, and land application would cost the county almost nothing.

Neighbors of those fields have objected. Their main concern is a family of long-lasting compounds called PFAS, which show up in many household products and end up at wastewater plants. Treatment plants were not built to remove them.

Roles. The affirmative team argues for the permit and must submit a written monitoring plan with its opening case. The negative team argues against the permit and must name what the county should do with the solids instead. Three students serve as the county board panel and ask one question of each team. One student keeps time and records which evidence each team cites.

Format. Round one is a four-minute opening case per team. Round two is three minutes of board questions per team. Round three is a three-minute rebuttal per team, and the negative team speaks last. The board panel then reads the monitoring plan aloud and votes.

Every point names its source. Points labeled fictional belong to this scenario only and must not be presented as documented fact.

Case for the permit

1. The solids exist whether or not they are used. Secondary treatment standards require monthly-average effluent BOD and TSS of 30 mg/L or less and at least 85 percent removal of each, while raw domestic sewage BOD typically runs about 100 to 300 mg/L. Much of what is removed from the water leaves the plant as solids. Source: EPA secondary treatment regulation.
2. The nutrients are real and useful. Nitrogen and phosphorus in biosolids are the same nutrients farmers buy in bags, so land application returns them to soil instead of burying them. Source: standard agronomic practice described in this kit.
3. Digestion has already reduced the material. The microbes in the digester consume much of the organic matter, cut the volume, and produce methane the plant burns for heat and power. Source: standard treatment plant practice described in this kit.
4. Landfilling costs money that ratepayers pay. A fictional county estimate puts hauling and disposal at $92 per ton, and the fields sit within ten miles of the plant. This is a figure from this scenario, not a documented statistic.
5. A fictional Pennfield valley farmer testified that fertilizer costs have been her largest single expense for three seasons, and that free biosolids would let her keep two fields in production. This is testimony from this scenario, not a documented statistic.
6. Rules can be written tighter rather than dropped. A permit can set application rates, buffer distances from wells and streams, and required soil tests, so the county can allow the practice under conditions rather than choosing all or nothing. Source: the permit structure described in this kit.

Case against the permit

1. PFAS do not break down easily. The limit for PFOA and PFOS in drinking water is 4.0 parts per trillion each, and water systems must comply by April 2029. In May 2026 EPA proposed letting eligible systems apply for a two-year exemption, to April 2031, without changing the limits; that proposal was not final as of September 2026, so the rules governing these compounds are still in motion. Source: EPA PFAS National Primary Drinking Water Regulation.
2. The county cannot yet see what it would be permitting. A fictional Havering County health board memo states that the county has no laboratory contract for testing PFAS in soil, so it would be approving a practice it has no way to monitor. This is testimony from this scenario, not a documented statistic.
3. Nutrients become pollution when there are too many. Phosphorus that washes off a field feeds algae in the creek, and when that algae dies, the decay drives dissolved oxygen down. Most fish need dissolved oxygen above 5 mg/L. Source: standard water quality benchmark from EPA and USGS.
4. Spreading is hard to undo. Solids placed in a lined landfill cell stay in one known place, while material spread across many fields cannot be collected again if a future rule bans it. Source: the disposal comparison described in this kit.
5. Neighbors bear the odor and the uncertainty. A fictional petition signed by residents along Pennfield Road asks the board to require a half-mile buffer from homes, which would remove most of the nearby fields from the program. This is testimony from this scenario, not a documented statistic.
6. Waiting has a low cost. The county already has a working landfill contract, so delaying the decision by two years while the rules settle does not leave the plant with nowhere to send its solids. Source: the disposal arrangement described in this kit.