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u u FFTheUST operty for this SSCR was in the 10,000 block of Copperopolis Road, while the is near the 22,500 block- seven miles away. tes by property owner, which makes it virtuallyimpossible to determine USTs py to the subject property. In addition, this list was apparently last updated in 2001. A consultant would have to know every property owner within one-quarter mile of a property under examination to utilize this "resource." Because of this, I use the GeoTracker System maintained by the State Water Resources Control Board(See attached). This data base inventories all USTs and LUSTS on, or near a property under investigation. If it is found that GeoTracker has mapped a tank near the subject property, then further review of applicable documents are warranted. Additionally, Section 3.1 of the Checklist references an EHD records search "as an example" to discuss the methods used to research and investigate the potential or known above and belowground sources of contamination at the project site. It does not say that "an actual physical review of EHD data for contamination site listings should always be undertaken." Mr. Escotto goes on to say that "verbal discussions with EHD staff regarding such information, is not viewed as a sufficient method of data examination." Where on the SSCR Checklist does it say this? Verbal conversations with regulators regarding contaminated sites, etc. is always an acceptable means to acquire environmental data and information, by the simple fact that regulators and regulatory agencies "hold the keys" to this public information. This brings up another interesting point that needs to be discussed. Typically, environmental investigations are conducted for certain groups, such as lenders,property buyers, etc.,that may or may not have access to applicable information, or may want to hire a firm to do the research and/or attempt to shift liability. With the SSCR, it is the EHD, which already has most of the pertinent environmental information (or available access to it)who is requesting the information. In essence,the Development Title is requiring EHD to force a landowner to hire a consultant to investigate data to which the EHD already has access. For the past 15 years, I have thoroughly enjoyed working with you and your staff. We have accomplished several significant objectives that are quite noteworthy. However, I am finding trivial issues, as outlined above, to be very cumbersome and nonproductive for me, and as I'm sure you will agree, for your staff. I am therefore suggesting that a meeting between you, myself and Donna Heran be set to discuss and to stop this continual changing of the SSCR requirements so that they do not add an additional workload to your overworked and understaffed Unit, and do not cause me and other consultants unnecessary time to rebut insignificant issues. Thank you for your attention to this matter. Res fu llyy sub i ed, Don Che ey Attachments Page 3 of 3 �Ji Chesney Consulting