By JEFF LITTLEJOHN
For decades, biosolids policy rested on a practical bargain. Wastewater utilities needed somewhere to put the residual material left after treatment. Farmers needed affordable nutrients. Land application offered both sides a workable answer.
That bargain is now under stress.
Florida is part of a broader policy shift toward tighter controls on biosolids, particularly the land application of sewage sludge. Historically, the debate focused on nutrients and pathogens. Increasingly, national concern is shifting beyond those familiar issues toward per- and polyfluoroalkyl substances (PFAS), a persistent class of chemicals that wastewater treatment systems were not designed to destroy.
That distinction matters. Florida’s traditional biosolids debate has largely centered on nutrients, especially nitrogen and phosphorus loading in sensitive watersheds. That is still a valid concern. But PFAS changes the policy discussion because it is not managed through ordinary agronomic rate calculations. A field may be able to use nitrogen or phosphorus. That does not mean it can safely assimilate industrial chemicals.
The Florida Legislature appears to be drawing a clearer connection between these two issues. During the 2026 session, lawmakers advanced measures that would tighten management of Class AA biosolids, including limits on land application above agronomic rates, expanded recordkeeping requirements, and direction to the University of Florida’s Institute of Food and Agricultural Sciences to publish recommended land application rates beginning in 2027 (HB 1245).
In parallel, the Legislature approved a requirement for certain public wastewater utilities to conduct quarterly PFAS sampling of biosolids and treated effluent, although those results would remain informational for now and could not serve as the basis for enforcement until federal standards are adopted (HB 1019). Both measures have been enrolled and, if approved by the Governor, would represent a measured step toward improving oversight without resolving the underlying disposal challenge.
That is a careful legislative approach. It improves oversight without pretending that Florida already has the answers. But it also reveals the gap. Agronomic rates can help manage nutrients. Sampling can identify PFAS presence. Neither, by itself, solves the disposal problem.
The practical consequence is that biosolids are moving from a beneficial reuse issue to a residuals management issue. That sounds like a small wording change. It is not. Once land application becomes less available, utilities must rely more heavily on landfilling, incineration, advanced treatment, gasification or other technologies.
Those options are not free. Landfilling biosolids creates a dual problem. It consumes limited disposal capacity in a state where permitting new landfills is increasingly difficult, and it concentrates PFAS within the landfill system itself. Over time, those compounds accumulate in landfill leachate, which must be managed. In practice, that leachate is often sent back to wastewater treatment facilities, reintroducing PFAS into systems that are not designed to remove them.
The alternative — deep well injection of leachate — remains technically viable but politically and publicly contentious. Incineration presents its own challenges, including air permitting and questions about residual emissions. Advanced treatment technologies may offer a path forward, but they require capital, energy, siting and operational confidence. The underlying issue remains the same. The waste does not disappear because the law becomes more ambitious.
This is where Florida should be careful. A policy that simply restricts land application without building reliable alternatives may improve one environmental pathway while creating another set of operational problems. The better approach is to define the risk clearly, measure it consistently, and create a transition path that utilities, farmers, regulators and ratepayers can actually implement.
Florida’s next phase of biosolids policy should answer four practical questions. What contaminants are present, and at what levels? Where have biosolids been applied historically? Which treatment technologies can reliably reduce or destroy PFAS and other contaminants? And how will the cost of new management options be allocated?
The direction of travel is clear. Biosolids land application will face tighter scrutiny. Class AA treatment will become more important. PFAS sampling will likely move from informational data collection toward regulatory decision-making. The unresolved question is whether Florida builds a durable management system before the existing one becomes politically and practically unavailable.
Jeff Littlejohn is Senior Policy Advisor at Adams and Reese
