small regenerative, sustainable farm - tree biomass

greetings, :)

We are a small 50 acres, regenerative, sustainable farm (umrit farm) in Hillsborough, NJ. Our farm is off Millstone river, interestingly flowing from south to north. Our farm is land of https://en.wikipedia.org/wiki/Lenape. We have been farming on this land for 10 years now. The sandy clay loam soils are very depleted.  In order to be successful at being sustainable, regenerative, ecological, to improve the soil fertility we chose to utilize tree biomass (leaves, wood chips, wood logs) in various ways, rather than import compost, so as to have diverse microbial life in soil and know what is going into our soils.

- wood chips as mulch
- logs on hedges to grow mushrooms and serve as habitat for insects
- logs to make lumber for farm use
- logs to build hügelkultur beds, in ground and above ground

We practiced no-till for 8 years, as years went by, the soil compacted further. We did find good structure development. Whenever there is moisture in soil, small life in soil can mobilize and build up soil structure to allow water to percolate through, rather than flooding off.

One of our above ground hügel beds is 7 years old and is the most productive, balanced soil at the farm (attached is a soil test report that shows difference between different soils at the farm). Within 2 years of completing it, the soils came to balance without any supplements and are now growing 3 times bigger plants compared to grown in other soils at the farm.

We have about 4 acres of soil under wood chips as mulch and these soils are also productive. Sorghum in wood chips mulched soils, grows to 14 feet tall, compared to non-mulched soil, which is about 5-6 feet tall. The soils under wood chips mulch don't have compaction issue. The bacterial and fungal life is in good balance, promoting plant growth and good vegetable harvest.

The tree biomass is also important to retain moisture in soil and warding off fluctuations in temperatures. It also shields microbial life from solarization.

We have realized many benefits that many of you have experienced and discussed for a good long time. We are fortunate to be able to afford sustainable, regenerative practices.

We have been unable to assure the state agriculture development committee (SADC) and county agriculture development committee (SCADB) that our practices are not new, had been in practice for millenniums, all across the world, and are good for us to grow food as well as for the environment and ecology. The governing agencies have cited that our practices are not well known, established, prevalent and hence we are in violation, as tree biomass is considered to be waste in the state, hence it is dumping.

We have been asked to revert and remediate the areas of our practice. It is a set back to our efforts, of years observing that purer, natural methods and least impactive importation and supplementation, allowing us to grow very good foods as well as enrich the soil with organic matter and carbon, spurring many things soils should have like glomalin, amino acids, soil stable carbon and most importantly carbon sequestration.

Please suggest measures and resources to bring about mediation so as we don't lose out the progress we have made and enable the governing bodies to recognize the practices to be viable agriculture practices as prevalent practice of using urea, pesticides, herbicides, plastic mulching and imports are. Growing foods, no matter the practices, is a demanding and many a times unnoticeable act. Every farmer works very hard to grow foods, no matter the nature of practice. We happen to be fortunate to understand and utilize close to natural methods.

Please find will and resources, allowing us to gain your help. The farm website has good bit of information and we should be able to furnish further, within our reach.

Hey Yash, I probably don't have any useful knowledge to pass along, but I'm curious what your interactions with Somerset County have been like so far? I've found that county officials are usually willing to help you figure out a way to make things work when you approach them as a collaborator rather than an enemy, so I hope you've taken that route.

I know for zoning purposes, you can petition the county for a variance. And I know here in Minnesota, if you want to e.g. dispose of human waste in an irregular manner, you can get permission from the county/state if you can convince the sanitation folks that you know what you're doing. What are your similar options? You should assume they have good reasons for the policies, but you also have good reasons for your own actions and want to find some way the county can understand what you're doing so they can help you figure out how to make it legal.

(Honestly, I'm only responding because 25 years ago I lived 10 miles from where you're farming -- just up on Sourland Mountain, so this is a small-world moment for me.)

I do hope that you can work something out with them!

Wow, that sounds like a great farm!

When dealing with the government, it helps to answer the three keys before taking action.

1. What did we hear them say?
2. What did they actually say?
3. What is their goal they want to achieve?

Not being there first hand, it's difficult to know for certain what applies in your situation.  The following is based on your description.

1. What did we hear them say?
- you must return to 20th century agriculture and reduce yield while increasing expense.

This is the hardest key to examine because what we hear them say is what we base our actions on.  It's amplified by our prey instincts and emotion.  We feel attacked because authority demands. But if we can see this and put it to one side for a moment, it helps us see what the other two keys might be.  

2. What did they actually say?
- "hence it is dumping"

This is what you mentioned above.   So let's run with this and pretend it's what they said.

Remember how key 1 can be influenced by emotions and history - so can key 2.  The government person is a real human who has a history of frustration and abuse.  Sure, it's their job, but also, it influences how they communicate.  Like any person in authority, they are used to not being listened to.  

Most of the time dealing with the government, I find most of the problem can be solved by showing the government guy that I think of him as a real human and I heard what he has to say (active listening is possibly the worlds most powerful superpower for getting what you want in life - and can be learned by anyone).

If we can find out what they mean by dumping and why it concerns them, then it's possible to solve that problem without destroying all your hard work.  


For that, we need to know what problem they are trying to solve.

I don't know if showing them it's a traditional or useful farming method is going to solve this.  Let's deep dive into what some possibilities are they are wanting to solve.


3. What is their goal they want to achieve?
- here we need to speculate

Based on personal expierence, here is (what turned out to be a long list) of why a government might be against bringing woodchips onto a location from another location.  

- Pest and illness quarantine.

One place I lived has their major income for the region in fruit production.  In that climate, at that time, moving wood chips with juniper from one location to another (even near by) was a really great way to harm the fruit tree harvest as it spread something I was too young to pay attention to what the actual thing was.

Here, we had trouble with chips from a local tree service that cuts down dead and dyeing trees - full of beetles.  Beetles that now are eating and killing our trees.  

Chips need to be heat treated (composted) before used to remove this risk.  Even if you aren't growing whatever XYZ they worry about, it might be vital to your local economy.

- money

Locally we have a family that charges $25-50 to dump a load of branches or chips off at his place.  Then he composts the mulch and sells it for a crazy-expensive price.  The family is making money twice on the same stuff and has to do very little other than turn the pile with a machine once or twice a year.

They also have family members in government.  And if people get chips for free then that family loses income.  Thus the dislike of dumping.

- my neighbour but one charged trucks $10 a load to dump at his place.  They loved it!  However, they weren't um... caring about the contamination of the stuff they dumped and it penetrated the ground water.  This could be a big concern for moving stuff onto a farm.  

- a different house, a different neighbour.  He got a lot of free chips and fill to help reshape his land.  Got in trouble for dumping under the bylaws.

About that time, we were getting a lot of chips and yard waste delivered to our farm, so our neghbour made a fuss and sent the government to visit us too.  

Now, we were getting the exact same stuff from the same people as our neighbour did earlier, but we were paying for the time and gas of the driver.  So we weren't dumping, we were buying a valuable commodity.  

If it was free or we were being paid for it, it would be dumping, like our neighbour got in trouble for.  But, in our case, the exact same thing was considered a purchase.  


Lots of possible reasons.  Probably about 200 more I missed.  

Start with evaluating which branch of the government is kicking up the fuss and see what law they are citing.  It's usually bylaws so give those another read (I assume everyone reads the bylaws when moving to a new home because these are icky to deal with).  Or ask them kindly to point you to the specific law and ask them for more details.  Most government people hate paperwork and are happy to educate rather than enforce.  

In a simple version what is it they did not like that you were doing?

I can imagine that this involved using human waste?

My first call would be to someone at Somerset Cty Rutgers cooperative extension service.
https://somerset.njaes.rutgers.edu/
my second call would be to one of the research/extension offices at Rutgers proper, maybe here https://ifnh.rutgers.edu/centers/agricultural-food-ecosystems/
or here https://ecocomplex.rutgers.edu/
plus there are all the experimental farms
https://sebs.rutgers.edu/research/centers-facilities

it sounds to me, if someone is saying you are in violation and need to remediate, either someone has it out for you (who is reporting a violation of what you do on your own farm?? that seems very strange), youve run afoul of someone, etc. A connection with links to legal resources will be useful.
Good luck.

Wow! Yash, better than 5% soil carbon, compared to 1% - you rock!  It sounds like you've got a great system going and ought to be emulated. I really hope that you can sort this out with the county officials.

As @Anne Miller, @r ransom, @Christopher Week reviewed, there is good bit more to it. Our farmland is Preserved Farmland (deed restricted to agricultural activities only). We value the tree biomass as a natural source to replenish the soils. We don't charge for delivery us the biomass, we spend our resources to get it organized and get it to work. Many a times we don't pay for receiving it.

SADC and SCADB do consider it to be dumping and hence it is not agricultural activity. We did get "Exempt from Recycling Certificate" from NJ DEP to utilize tree biomass for agricultural activities.

SADC and SCADB did make provision for us to practice a pilot program for them to be able to review it's viability. We couldn't practice the pilot program because we didn't have adequate resources to practice the pilot program

SADC did suggest for us to update conservation plan to mention the need for use of wood chips to used and once a conservation plan is completed we can utilize the wood chips as stated in the plan. There is a good likelihood, we will be able to use wood chips in some capacity once the technicality is met.

We practiced hügelkultur (below ground), that is deemed to be detrimental. We have been to grow better crops in the below ground hügelkultur beds compared to rest of the field. SCADB considers this to be non-agricultural practice, since we are deed restricted, this is deemed as a violation of deed, hence we are required to undo the hügelkultur.

A list of exchanges, notices is linked

If hügelkultur was a standard agriculture practice, this wouldn't be a matter.

As suggested by @Tereza Okava we reached out to Rutgers Extension as well. They let us know that, "they don't have authority to decide whether or not our practices are acceptable".

Since 2017 we have shared our understanding and since 2019 we have shared studies and practices with SADC and SCADB. There is a good possibility what we think of as providing necessary information to make informed decision, may have fell short of their needs.

The violation notice states that buried woody material (what we define as hügelkultur and grow crops on it) is not an agricultural practice, hence the field needs to be restored to be in compliance.

it sounds like the initial problem is non compliance with a plan that said you wouldn't import waste. that is a legal issue and i would still hunt around for someplace like extension that provides legal aid to farmers.
A simple search yielded a number of state ag university resources on hugels-- I haven't read it all, i'm just compiling here.
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are there any fact sheets on hugelkultur from state extension offices that can be used to support agricultural plans?

Yes, several U.S. state cooperative extension offices have published fact sheets on hugelkultur, a permaculture technique using buried wood to create fertile raised garden beds, which can support sustainable agricultural plans like soil building and water retention.
Key Fact Sheets
• Oklahoma State University Extension's "Sustainable Landscapes: Creating a Hügelkultur for Gardening" (HLA-6501) details benefits like stormwater management and construction steps using woody debris.[1]
• Washington State University Extension's "Hugelkultur: What is it, and should it be used in home gardens?" (FS283E) evaluates its origins, building methods, and research on effectiveness for home and landscape use.[2][3]
• Kansas State University Horticulture and Natural Resources offers a fact sheet on permaculture hügelkultur, describing layered organic materials for natural raised beds.[4]
Relevance to Agriculture
These resources from land-grant university extensions emphasize practical applications, such as improved soil aeration, reduced irrigation needs, and decomposition-driven fertility, making them reliable for farm or garden planning in varied climates. Clemson University (South Carolina) and others reference them for extended growing seasons. Access PDFs via extension sites for full diagrams and case studies.[5][6]

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1. https://extension.okstate.edu/fact-sheets/print-publications/hla/sustainable-landscapes-creating-a-hugelkultur-for-gardening-with-stormwater-management-benefits-hla-6501.pdf
2. https://rex.libraries.wsu.edu/esploro/outputs/report/Hugelkultur-What-is-it-and-should/99900501546101842
3. https://pubs.extension.wsu.edu/product/hugelkultur-what-is-it-and-should-it-be-used-in-home-gardens/
4. https://hnr.k-state.edu/extension/horticulture-resource-center/horticulture-newsletter/documents/2024/march2024/Hugelkultur template.pdf
5. https://www.piercecountywa.gov/DocumentCenter/View/104847/Hugelkultur-Brochure
6. https://hgic.clemson.edu/hugelkultur-gardening/
7. https://projects.sare.org/project-reports/fne19-942/
8. https://doee.dc.gov/sites/default/files/dc/sites/doee/service_content/attachments/Hügelkulture.pdf
9. https://www.dcmga.com/wp-content/uploads/docs/garden-basics-plan/gb-hugelkultur.pdf
10. https://thesovereignhomestead.com/a-primer-on-hugelkultur/

Thank you, @Tereza Okava!

You are right to point that it is deemed as non-compliance. Our humble response is, for the past 10 years, much of our lives have been agriculture. We are not exploiting our opportunity of being stewards for any other gains, rather committed to as natural farming as possible. There seems to be difference in what SADC and SCADB considers to be agriculture and what we are practicing. Our practices are allowing us to grow better crops, have higher yields and improve soil stable carbon.

There are numerous small scale and large scale productions via hügelkultur, within continental United States of America, as you have listed them.

Among it Saint Peters University in NJ did study our practice of hügelkultur as well and a student published a thesis paper.

Many of the studies and articles you mentioned, we submitted to SADC and SCADB over a period of past 7 years.

Farm website has compiled list of consolidated studies and articles that have been shared as well.

As you indicated, we are falling short somewhere and if we can bridge the gap, not only us, but a larger community will be able to take advantage of it and be instrumental to better environment and ecology.

Please suggest measures and resources to bring about mediation

Perhaps an actual mediation? Mediation is a great structured opportunity to try and reach a constructive resolution for you. It sounds like all parties are wanting to do what is best for the land and ensure that it continues to be productive space. Even with a mediator, I would suggest reaching out to legal counsel to help you best navigate through this process to avoid further heachaches. Good intentions can be misunderstood and having someone to help "go through the process" is invaluable.

I wish you the best.