Below is the response letter from the FDEP regarding all of the complaints and concerns that were submitted to them throughout the years as well as primarily the concerns from the FDEP public meeting that was held in August of 2025. This letter was sent out on Dec. 22, 2025 along with the FDEP's decision to issue the intent to approve Indianhead Biomass' permit renewal.

The Florida Department of Environmental Protection (DEP) thanks you for your comments and/or attendance at the public meeting held on Aug. 7, 2025. As a part of the application process, a public meeting was held to obtain comments regarding the domestic wastewater permit renewal application for Indianhead Biomass, LLC for the continued operation of its biosolid management facility in St. Johns County.

All permit applications are carefully evaluated under Florida law to ensure that all aspects of the operation are protective of the environment and human health.

Additionally, public input is an important and valued part of all DEP decision making and permitting activities. The Department has reviewed all public comments and considered them prior to taking final agency action on the draft domestic wastewater permit renewal.

Comments on Odors

The Department received numerous comments regarding the presence of odors in the neighborhoods surrounding the Indianhead Biomass (IHB) facility. These comments requested that the Department consider not renewing the domestic wastewater permit and some commenters expressed concerns about health impacts and quality of life due to presence of odors in the area.

DEP Response:

The Department recognizes that citizens living in the neighborhoods adjacent to the CR-214 area stated they are being impacted by odors emanating from the operations at the IHB facility. To address these concerns, the Department has proposed an odor control study as a permit condition. The study must be designed and overseen by a licensed Professional Engineer and will identify potential odor sources, evaluate existing odor control systems and recommend improvements to reduce odor emissions.

Based on the findings, the study will provide recommendations for any necessary operational changes or system upgrades to minimize potential odor impacts on nearby communities and the environment.

Additionally, new permit conditions were added to the proposed domestic wastewater permit outlining composting and facility management requirements. These permit conditions are targeted to further reduce or eliminate odors.

Of note is a requirement that within 180 days, no compost piles, including the curing piles shall be processed and stored to exceed 12 feet in height. This provides reasonable assurance under Rule 62-620 F.A.C. that these piles will not become compacted, which allows anaerobic conditions to develop and can lead to objectionable odors. The

facility will also be required to reduce the volume of the curing piles and mature, stable compost by 50% of the volume noted on Dec. 15, 2025.

Additionally, the facility will be required to screen incoming biosolids and will not accept abnormally malodorous biosolids that could contribute to off-site odors. After accepting material, the facility must mix accepted biosolids with vegetative material within four (4) hours of delivery. It is important to note that no unincorporated biosolids are permitted to be stored on-site.

Finally, the Modified Static Aerobic Pile (MSAP) composting methodology, which is authorized for use in accordance with Rule 62-640.880 Florida Administrative Code and the U.S. Environmental Protection Agency’s Code of Federal Regulations Part 503, assists with odor reduction. The proposed permit incorporates more stringent specifications for the composting material under the MSAP method, requiring that material in the windrows be left undisturbed for a minimum duration of 30 days.

Comments on Groundwater Monitoring

The Department received several comments regarding concerns for both surface water runoff and groundwater contamination. Some commenters noted visual concerns of a foam in the creek along Morgans Treasure Road, while other commenters have requested groundwater monitoring.

DEP Response:

The biosolids composting area is constructed on top of a clay liner with a 2-foot-thick working layer of wood chip material to absorb leachate and prevent impacts to groundwater. In response to these comments, the Department is requiring the facility to provide a report signed, sealed and dated by a Florida registered professional engineer verifying the continued integrity of the clay liner.

Additionally, the composting area is surrounded by a berm of adequate height to contain stormwater and manage runoff within the processing area. In response to concerns associated with surface water runoff, Department staff have conducted desktop reviews and site visits to assess surface water flows. At this time, there is no evidence suggesting the berms are not functioning as intended.

Department staff have also conducted investigations in response to concerns of discoloration or foam along the creek of Morgans Treasure Road. While Department staff did not observe the presence of foam during their investigations, the area was determined to be a drainage system from the wetland to the west of Morgan’s Cove. Any observations of foam are most likely due to a natural process.

Comments on Facility Operations

The Department received several comments suggesting various changes to the facility’s operations including placing limits on the hours in which deliveries are received and limits on the quantity of biosolids the facility can receive. Some commenters also suggested enclosing the composting zone (Zone B).

DEP Response:

DEP appreciates these comments and in response has incorporated a permit condition which limits the hours of operation for the biosolids receiving and operation to those specified in St. Johns County’s Special Use Authorization.

While additional operational suggestions for the facility were received, these comments are not applicable to the language in the permit as they are not regulatory conditions that DEP can impose upon the facility in a domestic

wastewater permit.

Comments on Compliance History

The Department received numerous comments regarding concerns related to a history of noncompliance and requested more oversight of the Indianhead Biomass facility through inspections. Some commenters requested that the Department consider not renewing the domestic wastewater permit due the facility being out of compliance.

DEP Response:

While the Department recognizes that some citizens claim the Indianhead Biomass facility is out of compliance, it is important to note that the facility currently is considered in compliance.

DEP issued the facility a Consent Order in October 2024 outlining corrective actions. Those actions were completed, and the facility returned to compliance in January 2025.

Since then, DEP has continued monitoring the site and, as of Dec. 3, 2025, has conducted 32 visits to assess odors and on-site operations. These most recent inspections have not resulted in any new violations.

The Department will continue its oversight of the facility. Announced facility inspections will occur at least every three years, while more frequent unannounced inspections can be completed in response to complaints or potential compliance concerns identified through Department review of submitted reports.

Comments on Local Requirements

The Department received comments regarding the location of the facility near residential neighborhoods and transparency in the signage depicting the nature of the operations of the facility.

DEP Response:

While DEP appreciates these comments, they are not applicable to the language in the permit as zoning decisions and siting approvals are done through local municipalities, and DEP has no authority to restrict or modify those local (city/county) zoning decisions.

The facility currently meets all state required setbacks outlined in Rule 62-650.700 Florida Administrative Code.

DEP is committed to protecting all Floridians, our state's natural resources and ensuring that the state's environmental laws are followed. DEP would not issue any permit that is not protective of Florida's environment and does not meet all requirements of Florida law. Once again, thank you for your participation in this process.