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to know the background ofthe decision. Ifthere is no ordinance,it apparently is not <br /> enforceable. <br /> We feel that ifthis requirement isnot revoked,that it is discrimination against testing <br /> companies by disallowingthemto continue to perform work that they have been suc- <br /> cessfully,professionally,and repeatedly doing for manymany years. <br /> IfSan Joaquin County Environmental Healthputs themselves in the position that they are <br /> more experienced and knowledgeable in leak detection than those ofus that have been <br /> doing this full time for,oftentimes,over a decade,it implies that we are imcompetent <br /> to perform our normal duties. It especially seems an unreasonable requirement now <br /> that your agency wantsto be on site during thetesting and,therefore,changing ofthese <br /> leak detectors. Since you are alreadythere,there is no reasonfor an exhorbitant permit <br /> fee of$261 for 'tank retrofit and plan review'. It only takes a few minutes to change out <br /> a leak detector and your inspector would be right there to make sure it was done to your <br /> standards. I called fourteen other Environmental Healthagencies we work with,and not <br /> one ofthem has a huge fee like this. Only one other agency had any fee at all,(it is$60), <br /> but it is actually a fee they charge for the annual inspection and not for a permit. In fact, <br /> nobody that I talked to required every site to even have leak detectors. Ina lot of <br /> instancesthey are superfluous,and simply cause problems and expense. Manyjurisdic- <br /> tions agreed that ifthe site had all the bells and hoops,that they could(and should)be <br /> removed. However,they are not making$261 for every bad one,so their opinion <br /> would differ from San Joaquin County! Under these new circumstances,I am sure your <br /> office will see that this fee now becomes anunnecessary charge to impose onthese site <br /> owners. Allthe testing that is nowrequired and the immense expense to keep these sites <br /> in compliance for EnvironmentalHeahh,Air Quality,Weightsand Measurements,etc.,is <br /> a total nightmare for these poor site owners. There is no reasonto pad the bill. <br /> The way things are now in your county,the costs for a bad leak detector goes as fol- <br /> lows: <br /> Tester comes in and tests,..finds faulty leak detector. They pull off. <br /> Site Owner has to find someone else that can screw in a large bolt(leak detec- <br /> tor). <br /> New screwer has to file your permit <br /> Set up date and come in to screw. Screw. Pull off. <br /> Site Owner has to call tester to come back in with test equipment to retest the <br /> newly screwed Most'contractors'do not carry test equipment. <br /> All this could easily cost the poor site owner as high as$400-$500(not including the <br /> cost ofthe leak detector). We would have charged$25 to install and retest at the time <br /> ofinitial test and the site would have been complete. This does not come out inthe <br /> wash!! Isn't the whole point to just have the sites in compliance?Does it reallyrequire <br /> that you make them as miserable as possible? <br /> Page 2 <br />