California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: January 20, 2005

Response to Resolution 2005-01

February 15, 2005

Mr. Bill Prinz
Chair, EAC
Solid Waste Local Enforcement Agency
Development Services Department
1010 Second Ave Ste 600 MS 606L
San Diego, CA 92101-4998

Subject: Enforcement Advisory Council Resolution 2005-01; Policy Recommendations Concerning the Draft Regulations--Training Certification for Landfill Managers and Inspectors

Dear Mr. Prinz:

Thank you for providing me with Enforcement Advisory Council (EAC) Resolution 2005-01, which was passed at the January 20, 2005 EAC meeting. It is my understanding that the comments and recommendations in EAC Resolution 2005-01 are the result of input gathered by EAC representatives from Local Enforcement Agencies (LEAs) throughout the state during the fall 2004 LEA Round Tables.

This EAC resolution addresses the draft informal regulatory text that would require mandatory training and certification for landfill managers and inspectors, which has been circulated by California Integrated Waste Management Board (CIWMB) staff as directed by the Board at its September 2003 meeting, and broader policy issues related to LEA and operator training. The resolution specifies that the EAC does not support the draft regulations.

The resolution further identifies EAC support for additional specific training through the CIWMB’s LEA training program and recommends that the CIWMB consider expanding its current training and certification program to incorporate training such as enforcement at compost, construction and demolition, and transfer/processing facilities.

In responding, let me indicate that at an upcoming Permitting and Enforcement Committee meeting, tentatively the one scheduled for April 11, 2005, staff will agendize a discussion item that requests direction on the status of the draft regulations and on the CIWMB’s role in training LEAs, operators and inspectors.

This item will be based on activities and stakeholder comments over the last 1.5 years on these issues. As you know, with the success of the then-ongoing four-year pilot project on a California-specific curriculum for the Manager of Landfill Operations Certification class in partnership with the Solid Waste Association of North America (SWANA), in September 2003 the Board directed CIWMB staff to develop draft regulations that would make landfill training and certification mandatory for landfill managers and inspectors and to hold workshops on the draft regulations. At the workshops, which were held in spring 2004, LEAs provided significant input about many of the concerns expressed in the EAC Resolution. As a result, staff developed a draft matrix of alternative options, which ranged from mandatory training and certification, to training with no certification, to the option of not changing the status quo. Staff originally planned to present this information at the November 2004 Permitting and Enforcement Committee meeting. Prior to that, however, SWANA hosted a meeting in October 2004 to discuss the draft matrix of options. At that meeting, the more general issues of overall training needs were discussed by a range of stakeholders. Board staff then followed up with a November 2004 workshop to obtain further input on the broad issue of what the Board’s role should be regarding LEA and facility operator training. At the April 2005 Permitting and Enforcement Committee meeting, staff will summarize input from the workshops and subsequent meetings, and request direction from the Board on the draft regulations and on the CIWMB’s role in training LEAs, operators and inspectors. As part of this, staff will explore other training efforts such as that of the University of Florida’s TREEO program.

CIWMB staff share the EAC’s interest in exploring developing further training on compost, transfer/processing, construction & demolition facilities and other non-traditional waste handling facilities. In response to LEA requests, the Training Program is offering training sessions this spring on the permit process with emphasis on compliance with the California Environmental Quality Act and on holding public hearings. The annual LEA Conference will offer training sessions on unique enforcement challenges, and following the conference staff will provide training on enforcement of State Minimum Standards. Additionally, the CIWMB remains committed in its effort to provide joint training between regulatory agencies, for example through its involvement in CalEPA’s Basic Inspector Academy and CalEPA’s annual Enforcement Symposium.

In closing, we recognize that the Board’s LEA training program success is linked with the EAC/LEA and CIWMB partnership effort. We will continue to work with EAC to meet the training needs of LEAs, CIWMB staff, and other stakeholders. We will continue to make training as cost-effective as possible for LEAs to attend, not least by making training available in various locations throughout the state in order to maintain reduced costs for LEAs participation.

We will apprise the EAC once the Board provides direction to staff on training LEAs, operators and inspectors.


Original signed by

Howard Levenson, Ph.D.
Deputy Director
Permitting and Enforcement Division

Attachment: EAC Resolution 2005-01

cc: Enforcement Advisory Council Members
      Ken Stuart, Chair, CCDEH Solid Waste Policy Committee
      Rosario Marin, Chair, CIWMB
      Linda Moulton-Patterson, Member CIWMB
      Rosalie Mulé, Member, CIWMB
      Michael Paparian, Member, CIWMB
      Cheryl Peace, Member, CIWMB
      Carl Washington, Member, CIWMB
      Mark Leary, Executive Director, CIWMB
      Julie Nauman, Chief Deputy Director, CIWMB

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Last updated: February 17, 2005
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