California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: March 7, 2006

Response to Resolution 2006-02

May 3, 2006

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: Response to EAC Resolution 2006-02-Providing Comments and Recommendations on the Proposed Permit Implementation Regulations During the Formal 60-Day Review Period

Dear Mr. Prinz:

This letter is in response to Enforcement Advisory Council (EAC) Resolution 2006-02, dated April 19, 2006 which was passed at the March 7, 2006 EAC meeting.

The EAC resolution requests that the California Integrated Waste Management Board consider the comments of the EAC as part of the formal rulemaking on the proposed Permit Implementation Regulations. Specifically, the EAC mentions strong support for the Decision Tree model for determining significant change.

Further, the EAC indicates a position of no support for the three lists provided in the proposed regulations (Alternative 1 Minor Change List, Alternative 2 Optional Minor Change List or Alternative 3 Significant Change List), primarily for the reason that no list can be “all-inclusive” and address the limitless variety of circumstances that could constitute changes at solid waste facilities and require LEA discretion. Finally, the EAC states that the proposed regulations should continue to maintain local control and discretionary actions as central to the permit process.

As you know, the CIWMB staff cannot necessarily endorse one set of comments over another during the formal rulemaking period; however, please know that your comments will be considered during staff analysis of comments received during this timeframe. We do expect further revisions to the proposed regulations followed by another comment period.

Should you have any questions, please contact me at (916) 341-6311 or Mark de Bie at (916)


Original signed by

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

Attachment: EAC Resolution 2006-02

cc: Enforcement Advisory Council Members
      Ben Gale, Chair, CCDEH Solid Waste Policy Committee
      Margo Reid Brown, Chair, CIWMB
      Rosalie Mulé, Member, CIWMB
      Cheryl Peace, Member, CIWMB
      Gary Petersen, Member, CIWMB
      Pat Wiggins, Member, CIWMB
      Jeffrey Danzinger, Member, CIWMB
      Julie Nauman, Chief Deputy Director, CIWMB

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Last updated: September 27, 2006
Enforcement Advisory Council (EAC)
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