Local Enforcement Agency Correspondence

Rural Jurisdiction Meetings

Date: December 4, 1998

To: All Local Enforcement Agencies

Meetings were held with 20 "rural" LEA jurisdictions (as identified by the California State Association of Counties) during April and May, 1998, to ask rural LEAs about their specific needs, suggestions, ideas and obstacles to the management of solid waste. The intent of the meetings was to collect information to help set the framework and to give focus to the development of the LEA Support Services Rural Assistance Program.

The areas of need which were most often described by these rural LEAs fall primarily into the following categories: training, funding, permits simplification (i.e., paperwork and cost), reduced regulatory requirements for rural solid waste facilities and effective time management as it relates to mandates.

The information presented in this letter to all LEAs is the beginning of a process to address all the issues and needs identified by rural LEAs. As we continue to learn and as decisions are made on how best to address those needs, we will add to the information presented here and establish definitive strategies to resolve those needs which require further research and planning. The process is a dynamic one, and as some needs are addressed, others will arise. The success of these strategies will be determined by the LEA.

The following topic areas are addressed in the attachment. These are the areas for which staff have immediate information. They do not reflect any specific priority.

1. Title 27 Training

2. Illegal Dumping Publication

3. Available Grants – USEPA

4. USEPA Grant-Writing Tutorial

5. State of California Training Center - Grants Writing Classes

6. Computers - CIWMB Web Site - Information Management

7. Regulations – LEA Participation

8. LEA Roundtables

9. Field Shop - Equipment Loan

10. Tires - Financial Assistance

11. Computers - Hardware and Training

12. LEA Certification

13. LEA Grant Money

14. Inventory Process and Environmental Disasters

Sincerely,

Original signed by:

Julie Nauman
Acting Deputy Director
Permitting and Enforcement Division

Attachment

LEA Correspondence Home

Attachment

Rural LEA Needs - I

LEA topics of interest, issues, comments and questions are enumerated and bolded, followed by unbolded responses.

Title 27 training was completed in July, 1998. Specific aspects of Title 27 and other issues will be covered in future scheduled classes (i.e., Permits, Closure, etc.). Contact Mark de Bie of LEA Support Services at (916) 341-6331 for specific dates, subjects and requests or for any training needs that may be addressed through the Rural Assistance Program. The master training schedule can be found at: http://www.calrecycle.ca.gov/LEA/Training/Schedule.htm.

Calendars which include training dates over the next three months (along with other events) are at: http://www.calrecycle.ca.gov/LEA/Events/.

The following USEPA publication is now available: Illegal Dumping Prevention Guidebook (No. EPA905-B-97-001).

Following is the grants address for USEPA grants: http://www.epa.gov/ogd/grants/cfda.htm. At this address are found links to information about grant programs administered by the USEPA, grant programs for environmental education, Environmental Justice Grants, EPA Grant Writing Tutorial, etc.

For additional information on EPA programs listed in the Federal Domestic Assistance Catalog, small business funding sources, how to apply for an EPA grant, grant regulations and policies, grants and finance resources, check out the Western Regional Pollution Prevention Network at: http://www.westp2net.org. This site is an interactive information network of tools and information in EPA Region 9, which includes California. Information regarding EPA grants regulations and policies, how to apply for an EPA grant and grant programs listed in the Federal Domestic Assistance Catalog can be found at: http://www.westp2net.org/grants.htm. This catalog is a government-wide compendium of Federal programs, projects, services and activities which provide assistance or benefits to the American public. It contains financial and non-financial assistance programs administered by departments and establishments of the Federal government.

4.  EPA Grant-Writing Tutorial:

Download the interactive EPA Grant-Writing Tutorial software tool: http://www.epa.gov/grtlakes/seahome/grants.html. This interactive software walks the users through the grant writing process and helps them learn to write more competitive grants. The program includes:

• Detailed information and tips on writing a grant proposal;
• How to complete a grant application package;
• Program-specific sections on three EPA grant programs:
   
  1. Environmental Justice
  2. Environmental Justice through Pollution Prevention
  3. Environmental Education
      
• Examples of good, complete grant packages;
• References;
• A glossary of terms;
• Resources and contacts;
• A mock grant writing activity where the users are able to compare their results to a successful grant application.

5. State of California Training Center: (Now closed)

The State Training Center (STC) offers classes on grant writing. Classes are open to employees of California state, city, county, school districts and special district or quasi-government agencies. Classes are also available to federal employees. If you need help, call the STC at (916) 445-5121 or visit their web site at: http://www.dpa.ca.gov/stcosci/stoscimn.htm.

a. How to work with the CIWMB home page.

A demonstration of how to work within the CIWMB home page was given at the annual conference in August, 1998. Information Management Branch (IMB) staff suggest the best way to use the CIWMB web site is to explore all of its options.

b. Maintain updated information on CIWMB web sites.

The Public Affairs Office and the Information Management Branch are enhancing and reorganizing the CIWMB web site to include improved integration/linking of related information and ease of use.

c. Provide an index and/or table of contents, which will make it clear how to access information.

The Information Services Branch staff have developed a table of contents for LEA Central. Also, the CIWMB web site includes a site map which is similar to a table of contents and includes all sites which can be accessed through the CIWMB home page. The map can be accessed by clicking on "SITE MAP" located in the center on the CIWMB home page.

d. LEAs - Names, Addresses

The LEA Directory may be found after accessing the CIWMB home page and typing "LEA Directory" and clicking on the "SEARCH" mechanism. The LEA Directory web site address is: http://www.calrecycle.ca.gov/LEA/Directory/default.asp.

The data on-line today reflects all updates made through the previous day. The list of names included in the directory is provided by each jurisdiction and is not a complete listing of all LEA staff.

e. Regulations - Titles 14 and 27

Title 14 is currently on-line and may be found on the CIWMB home page under the heading "Legislation and Regulations." The current address is: http://www.calrecycle.ca.gov/Laws/Regulations/.

Title 27 is available on-line in a Word 6.0/95 format. From the CIWMB home page, go to "Facilities/Operations," then "LEA Central," then "Statutes and Regulations," then "Title 27/AB 1220." The downloadable document is at the top of the page. The current address.

f. CIWMB Grant Information

There is an existing grants page at our web site. This information can be accessed from the CIWMB home page by clicking on "Waste Management Programs," and then "Financial Assistance Programs." The address is: http://www.calrecycle.ca.gov/grants/. Grants listed include: Enforcement Assistance Grants, Household Hazardous Waste Grants, Used Oil Grants, Waste Tire Grants, and Solid Waste Disposal and Site Cleanup Grants.

g. Agenda Items

An agenda item template that will allow easy posting of all agenda items to the CIWMB web site is being tested on the CIWMB Boardnet (CIWMB Intranet system). Based on the success of this pilot, the posting may, in the future, be presented on the CIWMB web site.

LEAs should have more involvement in writing regulations.

Over the past several years, working groups have helped craft regulation packages developed by the Permitting and Enforcement Division. Working groups are made up of

knowledgeable, potentially affected parties, and always include LEAs. Board staff are always looking for interested LEAs to participate in these groups. To find information on up-and-coming regulatory projects, LEAs can go to the CIWMB home page, then "Legislation and Regulations" and then "Proposed Regulations" or "Tiered Regulations". LEAs interested in being involved with regulation development should contact Permitting and Enforcement Division staff responsible for a proposed regulation package.

a. Include an educational component (slides, presentations, etc.)

Round tables are an LEA-directed forum to be utilized for their benefit. LEA Support Services facilitates the meetings by drawing up a draft agenda for each round table in each of the six regions. Approximately six weeks prior to the date of a round table, this draft agenda is distributed to the Enforcement Advisory Council (EAC) representative in each region. The EAC representatives make changes to the draft agenda and add comments as necessary. In this way, each region develops its own round table agenda to meet the needs of that region. The revised draft agenda is sent to LEA Support Services staff who distribute the agenda to each region. The distribution occurs approximately four weeks prior to the round table date. LEAs wishing to include a specific item or subject or a change in the format for the agenda in their region should contact the regional EAC representative.

b. Locations of round tables should be more spread out.

The location of the next round table meeting is generally decided at the preceding regional round table meeting by those LEAs in attendance. Alternate locations should be discussed at the round table meeting or by contacting the regional EAC representative.

Need use of digital combustible gas indicator (CGI), gas vapor probe and evacuation pump for gas monitoring wells.

Please see Advisory No. 30 for a description of the CIWMB equipment loan program. Currently, digital CGIs are not available for use by LEAs; however, LEAs may request that CIWMB Permitting and Inspection staff or Field Shop staff come out to the site with the needed equipment. urrently, there is a proposal to allocate funds for digital CGIs as part of the LEA loan program. All LEAs will be notified if and when these instruments become available for loan.

Provide financial assistance for conducting tire cleanup.

Funds are appropriated in the amount of $150,000 through the Local Government Waste Tire Cleanup Matching Grant Program. The notice of funds available for the fiscal year 1998-1999 are scheduled to be mailed out this month and will be awarded in May 1999. In-kind service may be provided in lieu of matching funds (e.g., labor, equipment, etc.).

Funds are appropriated in the amount of $500,000 through The Tire Enforcement Grant Program.

Computers and Internet access have been provided to those LEAs requesting assistance.

What is the minimum required of an LEA to maintain certification?

LEA certification requirements are specified in Title 14 beginning with Section 18070. Certification maintenance requirements are found in LEA Performance Standards beginning with 14 CCR Section 18080. See also PRC 43200. The intention to withdraw approval of designation may be carried out only by Board action.

The Enforcement Assistance Grant is a non-competitive grant and is distributed based on a pre-determined formula. When the existing formula was developed, it was weighted with a base amount to be sure that a grant sizeable enough to be useful to the smaller jurisdictions would be provided. This grant is designed to enhance the LEA’s program, not to pay for the program. The formula used for the grant awards to the rural jurisdictions is considered adequate for determining the amount of funds needed for travel, training, equipment, computers, consulting and supplies.

14. Inventory Process and Environmental Disasters:

As a result of heavy rains, flooding and other natural disasters leading to a state of emergency, Public Works was inundated with problems and unable to amend the RDSI. The operator (Public Works) received a Notice of Intent to list the disposal site on the Inventory for failure to update the RDSI. Is this consistent with enforcement policy for all jurisdictions?

Due to an oversight that occurred during the transfer of regulatory sections from Title 14 to Title 27, the RDSI was excluded from the "State Minimum Standards" definition. The process to include the RDSI (27 CCR 21600) into State Minimum Standards is in progress.

14 CCR 17210.2 Purpose and Limitations of an Emergency Waiver states that an emergency waiver may be issued only after a proclamation of a state of emergency or local emergency has been declared. The EA approves and issues the waiver; the waiver may apply to specified State Minimum Standards or a specific term or condition of the permit. All other State Minimum Standards, which are not the subject of the waiver, shall remain in effect. The EA may extend the period of the waiver to assist in the recovery from an emergency.

14 CCR 17210.1(f) "Emergency Waiver of Standards" lists those areas to which a waiver may apply. The RDSI is not listed as one of the areas allowed to be waived; therefore, the EA may not extend the timeline for submittal of the RDSI through the Emergency Waiver regulations

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