California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: June 6, 2006

Resolution 2006-03

June 7, 2006

Howard Levenson, Deputy Director
Permitting and Enforcement Division
California Integrated Waste Management Board
1001 I Street
Sacramento, CA 95812-4025

Subject: Enforcement Advisory Council Resolution 2006-03; Comments on Proposed Regulations Concerning Title 27, Subchapter 4, Article 6, Gas Monitoring and Control at Active and Closed Disposal Sites

Dear Mr. Levenson:

The Enforcement Advisory Council (EAC) met on June 6, 2006, and passed the above resolution. The resolution requests that the California Integrated Waste Management Board (CIWMB) consider the enclosed comments to the proposed regulatory changes for gas monitoring and control at active and closed disposal sites in Title 27 of the California Code of Regulations (CCR).

It is our understanding that the scope of these proposed regulations is to align the landfill gas monitoring and control regulations for active disposal sites with the more detailed regulations for closed disposal sites.

While we understand the narrow scope of these proposed regulations and support revisions to the regulations upon incorporating our suggested changes, we also want to bring your attention back to resolution 2005-03. The EAC still believes that there are significant issues with landfill gas monitoring and control that would require substantial changes to the regulations for both active and closed disposal sites.

We request that CIWMB bring together the technical advisory group of stakeholders formed in 2003 or form a new group of stakeholders to revisit the regulations one more time to explore the need to make additional changes in order to protect public health, safety and the environment.

Should you have any question please do not hesitate to contact me at (619) 533-3696 or by e-mail at wprinz@sandiego.gov.

Sincerely,

Original signed by

William E. Prinz, Chair
Enforcement Advisory Council

Enclosures:

  1. Proposed Revisions to Title 27, Chapter 3, Article 6: Gas Monitoring and Control at Active and Closed Disposal Sites
  2. Resolution 2005-03: Recommendations Concerning Title 27, Subchapter 4, Article 6, Gas Monitoring and Control at Active and Closed Disposal Sites

cc: EAC Members
      Ben Gale, Chair, CCDEH Solid Waste Policy Committee

EAC Archive

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Last updated: July 24, 2006
Enforcement Advisory Council (EAC) http://www.calrecycle.ca.gov/LEA/EACouncil/
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