ELR Citation: ELR 20041
No(s). 02-35751 (9th Cir. Jul 1, 2004)

The Ninth Circuit held that grass residue remaining after harvesting Kentucky bluegrass is not solid waste under RCRA and that the Act does not prohibit growers' general practice of open burning. The court rejected a citizens group's argument that open burning is the discarding of waste. The group f...