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-6- The most important condition of any potential new Permit should be that the entire Calaveras River project be rehabilitated in compliance with the full set of conditions set forth in the existing and prior Permits. No further consideration of future Permit privileges should occur until Stockton Sand and Gravel respects and complies with all of the existing Permit requirements. B. The County Must Develop an Effective Mechanism for Enforcing the Permit Thusfar, as described above, the County has been unsuccessful in gaining Mr. Merian ' s compliance with his eXisting Permit. If Mr. Merian were offered the privilege to further excavate in San Joaquin County, the County would have to adapt its enforcement rules, develop staff , and initiate procedures which would secure compliance with the Permit. The County' s responsibility in an excavation Permit is tremendous, and the County cannot afford to not actively enforce the Permit provision with Mr. Merian as operator. The following specific adaptations to the enforcement process would have to be made in order to protect the County and its residents: 1) Monthly inspections of all Stockton Sand and Gravel operations would be necessary to determine compliance with the Permit . 2) It would be necessary to develop a mechanism to assure that the County follows-up and that Mr. Merian rectifies all areas of non-compliance with the Permit 3 ) When a violation occurs , penalties and fines should be levied on the Permitee. 4) When any violation occurs, no excavation, processing or hauling activity should be allowed until the violation is remedied. 5) The cost of enforcement, including additional tr�A ned County staff if necessary, should be borne by the Permitee . 6) The Permit and conditions would have to be written with much more specificity. Generalizations make enforcement much more difficult. Very detailed descriptions of conditions will facilitate enforcement.