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11 <br />FRED\SOLID\FCWD.LET <br />Don Koepp, Director <br />Environmental Health Division <br />Ventura, CA 93009 <br />IT T-7101 <br />San Joaquin County Public Health Services Environmental Health Division (EHD) was <br />designated as the certed Local Enforcement Agency (LEA) for San Joaquin County <br />on July 31, 1992. <br />EHD feels that the California Integrated Waste Management Board (CIWMB) <br />enforcement division staff has violated the intent of AB 939 by initiating enforcement <br />action within the jurisdiction of a certified LEA. The specific enforcement action is <br />listing the French Camp Landfill on the inventory of non -complying facilities. <br />According to statute the responsibility of the LEA, within its jurisdiction and <br />consistent with its certification, is to enforce the state minimum standards for solil <br />waste handling and disposal (PRC 43209). The responsibility of the CIWMB staff iz <br />to insure that the LEA fulfills its responsibilities (PRC 43215). <br />EHD would like the Enforcement Advisory Committee to determine whether the <br />CIWMB has exceeded its statutory authority by initiating enforcement actions within <br />the jurisdiction of a certified LEA without first demonstrating that the enforcement <br />agency is not fulfilling its responsibilities. <br />CC Gary Stephany CCDEH <br />Ralph Chandler CIWMB <br />