California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting

Regulation Development Issue Statement from Enforcement Advisory Council Meeting—January 30, 2003

The highest priority, general subject identified in the LEA Solid Waste Program Issues Survey was regulation development. The outline consolidates the concerns that LEAs raised about the current regulatory process.

What specific Issues were raised by LEAs pertaining to the development of regulation packages?

  1. Industry and state politics have driven recent CIWMB regulatory efforts rather than scientifically based concerns about public health, safety and the environment.
    1. LEAs are required to be enforcers of the “level playing field” rather than addressing legitimate public health, safety and environmental concerns.
    2. Statewide “solutions” to address urban issues have no practical application in rural areas.
    3. Regulations are not based on sound, scientific principles.
    4. The concerns of LEAs, as the regulatory arms of the CIWMB, should be given higher priority in determining which regulatory packages need to be developed and which direction the regulations should take.
    5. Regulation being developed without its “regulatory partner” (LEA) who must implement the regulations.
    6. Regulations generally not clear and unambiguous, and have to be clearly enforceable and verified by legal.
  2. Too many regulatory packages are being introduced within a short period of time.
    1. LEA’s are not able to wade through, digest and comment on regulatory packages within the prescribed timeframes.
    2. Regulations are hastily developed and not well thought out, resulting in confusing, complicated proposals that fail to satisfy stakeholders or address real issues.
    3. Regulation being developed without its “regulatory partner” (LEA) who must implement the regulations.
    4. Regulations generally not clear and unambiguous.
    5. Does not appear to considering LEA input.

EAC Archive

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Last updated: February 9, 2005
Enforcement Advisory Council (EAC) http://www.calrecycle.ca.gov/LEA/EACouncil/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395