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NEUMILLER ST BEARDSLEE A PROFESSIONAL CORPORATION•ATTORNEYS&COUNSELORS ESTABLISHED 1903 22968-19159 131IOOKE K. BIRKIE STOCKTONOFFICE: 509 W.WEBER AVE. STOCKTON,CA September 27 , 1995 SEP 95203-3166 (209)948-8200 (209)948-4910 FAX MAILRNG ADDRESS. Mr. John Caffrey, Chair 7-0 CWP P.O.Box 20 State Water Resources Control Board Le. DC. STOCKTON,CA Post Office Box 100 gLr= 95201-302D Sacramento, California 95812-0100 MODESTO (209)577-8200 Re: External Program Review Recommendations (209)577-4910 FAx Dear Mr. Caffrey: T work with Jeanne M. Zolezzi of Neumiller & Beardslee who has been in communication with you on various issues regarding: "Implementation of the External Program Review Recommendations, " dated July 5, 1995. She has asked that T share with you the frustration I have experienced on behalf of a client with a recommendation of the External Program Review Committee which your sa _ states has already been solved. My experience illustrates quite the contrary. On September 1, 1995, I attempted to use a "completed" administrative process identified as one of the Groundwater Protection Task Force Recommendations for a client in order to avoid the expense of a formal appeal. Specifically, EPR No. GWP 4 .2d addressed whether the present division of responsibilities was appropriate and whether the process for appealing local oversite programs to the state was adequate. Specifically, this EPR Recommendation states: That the Regional Boards set up an informal information and dispute resolution process at the state level to provide Responsible Party quick and easy access to a knowledgeable third party and an opportunity to question the actions of the LOPs. If the Responsible party is not satisfied with the results, then the appeal together with the Regional Water Board's recommendations for resolution should be submitted to the State Water Board- for final decision. The action was identified as complete with the following comments: 43369-1