California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: January 25, 2007

Response to Resolution 2007-02

December 18, 2007

Mr. Trey Strickland
Chair, Enforcement Advisory Council
Solid Waste Local Enforcement Agency (LEA)
Mendocino County Public Health Department
Division of Environmental Health
501 Low Gap Rd Rm 1326
Ukiah, CA 95482

Subject: Request for the CIWMB to clarify issues regarding the revised Permit Application Form (E-1-77) and Instructions for Completing the Application for Solid Waste Facility Permit/Waste Discharge Requirements (EAC Resolution 2007-02)

Dear Mr. Strickland:

This letter is in response to Enforcement Advisory Council (EAC) Resolution 2007-02, dated October 15, 2007, and passed at the January 25, 2007 EAC meeting.

This EAC resolution requested actions to clarify the issues regarding the permit application form (Excel | PDF) by assisting LEAs to determine consistent permitted maximum capacity, providing the rationale for adding the beneficial reuse tonnage to the peak daily tonnage, conducting a workshop to fully discuss the history, intent, and final permit application, and revising the permit application form (regulatory change) to address the quandary concerning the application form showing that the peak daily tonnage may have increased when there has been no waste flow change at the facility.

Before taking one or more of the suggested actions outlined in the resolution, I suggest that a workgroup be formed that would include LEAs and Board staff. The resolution describes the key issues and will be a good starting point for the group. The workgroup would be tasked with sorting through the details of the issues and developing specific recommendations to address the problems they identify. To this end I have asked Mary Madison-Johnson and additional staff to join with the LEAs you select to form the workgroup. The forth coming LEA Roundtables could be a forum for soliciting LEAs to participate. Please provide Mary with the names of the LEAs that will participate in the workgroup and she will facilitate getting the effort started. She can be reached at (916) 341-6329. I would ask that the workgroup not be tasked with implementing any of the recommendations but would be asked to provide their assessment and recommendations to the EAC and me for further action.


Original signed by

Ted Rauh, Program Director
Waste Compliance & Mitigation Program

Attachment: EAC Resolution 2007-02


Enforcement Advisory Council Members
Ray Ruminski, Chair, CCDEH Solid Waste Policy Committee
Margo Reid Brown, Chair, CIWMB
Wes Chesbro, Member, CIWMB
Jeffrey Danzinger, Member, CIWMB
Rosalie Mulé, Member, CIWMB
Cheryl Peace, Member, CIWMB
Gary Petersen, Member, CIWMB
Julie Nauman, Chief Deputy Director, CIWMB

EAC Archive

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Last updated: December 28, 2007
Enforcement Advisory Council (EAC)
Leta Forland: (916) 341-6395