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We also believe that the ADC regulations do not prohibit minimal amounts of food waste contamination in ADC. Therefore, we contend that our permit controls the levels of contamination in our ADC and our permit specifically allows up to 5% contaminants (SWFP Condition 17.t) in green material used for ADC. A more detailed discussion of this issue follows and includes a proposal to "minimize" contaminants in the green materials used for ADC. Prior to the adoption of the ADC regulations, Title 27, Section 20690 (a) (3) (A) included the phrase: "Processed green material shall be green material as defined in Title 14, California Code of Regulations, §17852(u) with the exclusion of manure..."However, the final version of the ADC regulations deleted"...shall be green material as defined in Title 14, California Code of Regulations, §17852(u) with the exclusion of manure". Thus eliminating a possible cross -reference to the composting regulations. The composting regulations contained in Title 14, Chapter 3.1 include a definition of green material in section 17852. (a)(21) That in part requires less than 1% contamination and specifically excludes mixed solid waste from the definition. However, Section 17852 is preceded by restrictive language stating " (a) For the purposes of this Chapter:" meaning that the definitions contained in Section 17852 are applicable only to the composting regulations and cannot be applied to ADC regulation since those regulations are contained in a different Chapter and in a different Title of the CCR's. Now,the ADC Regulations contained in Title 27,include a definition of"processed green material" (Section 20690 (a) (3) (A)). That definition does not include either the 1% restriction on contamination nor does it include the very restrictive prohibition on mixed solid waste. That definition states that: "... processed green material means any plant material that is either separated at the point of generation, or separated at a centralized facility that employs methods to minimize contamination." The definition even states that green material includes but is not just limited to "...yard waste, wood waste, paper products and natural fiber products." Thus, leaving the door open for other materials. Some materials are specifically excluded from the definition of"green material", such as " ... treated wood waste, mixed demolition or mixed construction debris, manure and plant waste from the food processing industry". The City of Stockton's curbside program does not include any of those excluded materials! Therefore, it would seem that the ADC regulations contain no specific limitation on some food materials in green waste destined for ADC, as long as the resulting processed material meets the grain size specifications and performance standards specified in the regulations. In fact the curbside greenwaste collected in the City of Stockton is separated at the point of generation and in addition, it is sorted at the .site to remove contaminants and is processed through a grinder prior to applying to the working face. Finally, our SWFP Condition 17.t specifically authorizes the use of shredded green material for ADC as long as a dozer is used for spreading and compacting and the green material contains no more than 5% contamination. The City of Stockton curbside greenwaste program meets both of those requirements.