A ban on fields, a bill at the landfill

Portland Water District, Maine's largest wastewater utility, had not spread its sludge on farmland in more than a decade when the state banned the practice in 2022. Its cost to get rid of a wet ton of sludge still rose about 60% in five years. The ban closed an outlet for everyone else, and all of Maine's sludge went looking for the same few landfills.

The weekly brief that started this piece said utilities are being "forced out of land application into thermal destruction". I went to the utility's own documents to see what the move looks like from the inside. Portland Water District (PWD) posts its budgets, its consultants' studies, its trustee packets and a request for qualifications from June 2026. The path they show runs from land application elsewhere in the state, to a landfill squeeze, to digestion and drying. Thermal destruction has a reserved spot on the site plan.

I believe this is one of the clearer cases of a rule reaching a utility it was never written for. For anyone who sells into solids handling, the dates to watch at PWD are in 2027, and the facility is planned for 2031.

1. The ban, and the landfill it filled

Maine's law, LD 1911, was signed on April 20, 2022 and took effect on August 8, 2022 (P.L. 2021, chapter 641). It prohibits the land application of sludge and the sale of compost made with it, regardless of PFAS concentration. The state had already been restricting land application above PFAS thresholds since 2019.

The effect shows up in the state's own tonnage. According to a January 2024 report by Maine DEP and the Public Utilities Commission, in 2018 about 17,013 tons of municipal sludge were land applied, 25,701 tons were composted and 59,018 tons went to landfill. By 2022 landfill disposal had reached 86,932 tons, and 78,383 tons, about 90%, went to one site, the state-owned Juniper Ridge Landfill.

PWD was not part of the land-applied share. Its 2023 request for information says so plainly: "Given that PWD has not had land-applied solids in over a decade, it is these landfill impacts that are driving the need for the current planning study, as landfill options dwindled, and costs increased."

The second half of the squeeze came from a solid waste law. Wet sludge cake has to be mixed with bulky material, such as construction debris, to stay stable in a landfill. LD 1639, which took effect in early 2023, restricted out-of-state waste coming into Maine, and that waste was a main source of the bulking material. Less bulking material meant the landfills could take less sludge. The Legislature then allowed oversized bulky waste for this purpose on a temporary basis, and in June 2025 extended that allowance to July 1, 2027 (P.L. 2025, chapter 373).

2. What it did to one budget

PWD's annual budgets state the disposal rate they assume per wet ton, so the cost can be followed year by year.

The 2022 budget assumed $100 a wet ton, up from $90, and added: "It is expected that issues with per- and poly-fluoroalkyl substances (PFAS) will impact the price. In addition, the State of Maine has put in place a $10/wet ton regulatory fee to deal with issues regarding PFAS." The 2023 annual financial report shows the disposal expense rising from $2.41 million to $3.10 million "due to a price per unit increase of 28%, combined with a relatively flat change in units hauled." By 2025 the budget assumed $143.41 a wet ton. In May 2026 staff summed it up for the trustees: hauling costs about $3.2 million a year, and "costs have risen approximately 60% in the last five years."

There is a smaller cost inside the larger one. The hauling contract requires a minimum solids content. When the sludge is too wet, PWD pays to stabilize it, and from 2020 to 2025 that came to an estimated $405,000. When the screw press at its Westbrook plant failed in August 2025, PWD rented a centrifuge at about $40,000 a month.

3. What PWD is buying, in order

PWD hired Brown and Caldwell, which finished a biosolids master plan in April 2023 and ran a request for information that summer. Twenty-nine companies responded. The consultants' December 2023 advanced study put PWD's current cost at $131 a wet ton and laid out phases: digestion of primary sludge at the main plant first (about $24 million, called a "no regrets" project because it cuts the solids to be hauled by about 22%), then drying, onsite or at a regional site, and pyrolysis as a possible third phase.

By 2026 the plan had become one regional facility. At a workshop on April 13, 2026, trustees heard that it was sized at about 85 wet tons a day and that "landfill tipping fees in the Northeast are projected to increase substantially, potentially over 100% in the next decade." They also heard that pyrolysis and similar thermal destruction "would be considered potential future phases rather than part of the initial project." On May 26 the agenda carried $2 million for preliminary design. On June 9 PWD issued a request for qualifications.

The RFQ describes the purchase in detail:

1. A progressive design-build-operate contract, with the facility "owned by PWD and operated by a Design-Build Team".
2. Cake receiving, anaerobic digestion, dewatering and thermal drying, plus "PFAS destruction in landfill leachate".
3. An average of 85 wet tons a day, 75 of them from PWD's own plants and the rest from peer utilities.
4. A capital estimate of $140 million in 2024 dollars, with "no public funding has been secured thus far".
5. Space on the site reserved for thermal destruction, "should a thermal destruction solution be necessary in the future".

Qualifications were due on August 11, 2026. The first operations are scheduled for the second quarter of 2031.

4. The 2027 squeeze

Lay the dates side by side and the pressure point is obvious.

The temporary bulky waste allowance ends on July 1, 2027. PWD's current hauling contract, with Casella, was extended in December 2022 "through the end of 2027". A landfill capacity study for Maine DEP in February 2024 estimated that Juniper Ridge "currently has capacity to remain available through 2028" without an expansion. The regional facility is planned for 2031. On the record I have read, nothing yet covers the years in between.

That gap is where the near-term buying is. Better dewatering is already moving: in February 2026 the trustees added a dewatering project at Westbrook, with a design contract of $312,100, and in July they heard that replacing dewatering at the East End plant carries "an estimated $7 million cost for temporary dewatering". Every point of solids content taken out at the plant is tonnage PWD does not have to haul.

What the brief got wrong, and what holds

The brief said states are banning land application and that litigation against wastewater utilities is "expanding rapidly". EPA's own draft guidance of June 2026 counts two states with bans, Maine and Connecticut, and notes that about 93% of Connecticut's sludge was already incinerated. Michigan sets thresholds instead of a ban. The suits I could find are against a private sludge processor and against EPA. PWD itself is a plaintiff: in 2024 it sued 3M, DuPont and other manufacturers over the cost of PFAS in its wastewater, according to the Portland Press Herald.

What holds is the cost. A ban in one state moved a lot of tonnage into a small number of landfills, and every utility using those landfills paid for it, whether or not it ever land applied.

If you sell to utilities

1. Read the hauling contract dates in the annual financial report. PWD's audited statements give the contractor, the term and the estimated payments for the coming year.
2. Look for the near-term projects that reduce tonnage. At PWD those are dewatering upgrades at both plants, with design contracts already awarded.
3. Treat thermal destruction as a later phase. PWD reserves space for it and says it is not yet commercially reliable at this scale.

What I don't know yet

• Whether the trustees approved the $2 million for preliminary design on May 26. It was on the agenda; I have not seen the minutes.
• Who submitted qualifications in August, and whether there is a shortlist.
• Whether Juniper Ridge will be expanded, which would change the 2028 date.
• Which disposal rate PWD pays today. Brown and Caldwell uses $131 a wet ton "based on current contract", and PWD's budgets assume $139 to $143 with surcharges.

The next markers are the selection of a design-build team and the Legislature's next move on the bulky waste allowance before July 1, 2027.

At AquaIntel we read trustee packets, budgets, financial reports and procurement documents together and keep each decision with its date, so a vendor can see where a utility's real deadline sits before the request for proposals goes out.

Sources

• Portland Water District, Request for Information, Phase I Biosolids Processing Facility, 28 Jun 2023, retrieved 3 Nov 2026.
• Brown and Caldwell for Portland Water District, Advanced Study for Regional Biosolids Digestion, Drying, and Thermal Processing, 21 Dec 2023, retrieved 3 Nov 2026.
• Portland Water District, 2022 and 2025 budgets; Annual Comprehensive Financial Report 2023; Board of Trustees agenda package, 26 May 2026 (Order 26-011 and 2025 financial statements); Board agenda, 23 Feb 2026 (Order 26-003); workshop minutes, 9 Feb 2026 and 13 Apr 2026; business minutes, 27 Jul 2026; Request for Qualifications, Regional Biosolids Facility, 9 Jun 2026, on PWD's construction bids page. All retrieved 3 Nov 2026.
• Maine Revised Statutes, Title 38, section 1306; LD 1911 (130th Legislature) status; P.L. 2025, chapter 373 (LD 297, 132nd Legislature).
• Maine DEP and Maine PUC, "Analysis of Sludge and State-Owned Landfills as Public Utilities", Jan 2024.
• Brown and Caldwell for Maine DEP, Landfill Capacity Assessment technical memorandum, 26 Feb 2024.
• US EPA, Draft Guidance for Reducing Risk From PFOA and PFOS in Biosolids, Federal Register, 6 Jul 2026.
• Portland Press Herald, "Portland Water District joins lawsuit against forever chemical makers", 4 Jun 2024, retrieved 3 Nov 2026.