California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting

CIWMB Response to Resolution of Enforcement Advisory Council

October 10, 2003

Mr. Greg Pirie, Chair, EAC
Solid Waste Local Enforcement Agency
Office of County Administrator
1195 3rd St. Room 310
Napa, California 94559

Subject: EAC Resolution 2003-04, Five Year Permit Review Process

Dear Mr. Pirie:

Thank you for sending Enforcement Advisory Council (EAC) Resolution 2003-04, dated August 19, 2003, which was passed at the June 19, 2003 EAC meeting.

The resolution requests that the five-year permit review process be evaluated by a work group of LEA and CIWMB staff. The resolution states that a critical component of the evaluation should be a determination of which changes to the permit are informational in nature and would not require a permit revision and/or the Board to concur on the permit revision. The resolution also requests that the LEA and CIWMB Partnership Working Group evaluate the five-year review procedures as part of their permitting process review.

The CIWMB is dedicated to streamlining the permitting process while maintaining the necessary level of regulatory oversight associated with solid waste handling and disposal activities. The CIWMB adopted regulations in 1994 implementing a tiered regulatory permit structure and followed with numerous permit process changes to provide flexibility and a streamlined approach. Given that the purpose of the permit review is to document any changes in design and operation, the CIWMB is willing to evaluate conditions surrounding minor informational changes to the permit and the feasibility of a process that allows minor changes to get approved without requiring a full permit revision.

CIWMB Partnership with LEAs is part of the efforts to accomplish Goal 4 of the CIWMB s Strategic Plan which is to: Manage and mitigate the impacts of solid waste on public health and safety and the environment and promote integrated and consistent permitting, inspection, and enforcement efforts.

The Partnership workgroup met in August 2003 to begin resolution of issues relating to permitting, enforcement and inspection, and regulations. Although permitting was identified as the issue of second highest concern to LEAs (regulations was the top priority), the five-year permit review process was not identified as a top permitting issue for discussion at the August workgroup meeting, yet it could be addressed in future meetings.

Additionally, I believe that the staff that participated in the permit workgroup are highly experienced and knowledgeable and would be the best group to evaluate the five-year permit review process. Further, because of the expertise of the Partnership workgroup, it may be most valuable for the Partnership effort to undertake the drafting of regulations to define significant change to comply with AB 1497 if it is chaptered into law.

Again, CIWMB is strongly committed to the success of the Partnership work group and resolving issues to improve the regulatory efforts of the CIWMB and LEAs to continually improve the environment and enhance public health and safety.

Thank you for the opportunity to address the issues outlined in EAC Resolution 2003-04. Should you have any questions, please contact me at (916) 341-6311.


original signed by

Howard Levenson, PhD,
Deputy Director
Permitting and Enforcement Division

Attachments: EAC Resolution 2003-04

cc: EAC Members
      Mr. Dan Avera, Chair, CCDEH Solid Waste Policy Committee
      Linda Moulton Patterson, Board Chair, CIWMB
      Jose Medina, Board Member, CIWMB
      Steve Jones, Board Member, CIWMB
      Michael Paparian, Board Member, CIWMB
      Cheryl Peace, Board Member, CIWMB
      Carl Washington, Board Member, CIWMB
      Julie Nauman, Chief Deputy Director, CIWMB

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Last updated: February 09, 2005
Enforcement Advisory Council (EAC)
Leta Forland: (916) 341-6395