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San <br />unty <br />Joaquin r ■ <br />r Department <br />600 East Main Street <br />Stockton,California95202-3029 <br />Nicholas Jacobs, Attorney <br />Somach, Simmons & Dunn <br />500 Capital Mall Ste 1000 <br />Sacramento, CA 95814 <br />Website: www.sjgov.org/ehd <br />Phone: (209) 468-3420 <br />Fax: (209) 464-0138 <br />December 8, 2011 <br />Subject: Forward Landfill Solid Waste Facility Permit Revision <br />Dear Mr. Jacobs, <br />DIRECTOR <br />Donna Heran, REHS <br />PROGRAM COORbINATORS <br />Robert McClellon, RENS <br />Jeff Canuesco, REHS, RDI <br />Kasey Foley, REHS <br />Linda Turkatte, REIAS <br />The Environmental Health Department (EHD) has received your letter dated November 18, <br />2011. The EHD has the following responses to you questions: <br />I . Has the LEA determined that the proposed SWFP revision conforuts with <br />relevant statutes and regulations governing the Landfill, as required by Public Resources <br />Code section 44004? Does this include compliance with the terms and conditions of all other <br />permits and authorizations from other regulatory entities that control the Landfill? <br />The permit revision does not conflict with Title 27 California Code of Regulations (CCR), Title <br />14 CCR, Public Resources Code (PRC) and the local land -use approvals. In July 1997, AB 1220 <br />became affective. The PRC states that the LEA may consider other permits when writing the <br />terns and conditions of the Solid Waste Facility Permit (SWFP), but there is no requirement for <br />the LEA to consider other permits. The EHD is not aware of existing compliance issues <br />concerning the facility as it pertains to other permits the facility currently hold. <br />AB 1220 removed overlap that had existed that required Solid Waste Facilities Permit (SWFP) to <br />act as an umbrella permit (meaning that it had to consider all other permits and requirements as <br />part of the SWFP). Please see the lank below and the excerpt. <br />http://www.cah-ec cly a.ca.gov/Laws/Rulemakin /Archive/1997/AB1220/f"sorwrd.doc <br />"The Solid Waste Disposal Regulatory Reform Act (AB 1220) shapes the development of <br />regulations as follows: <br />1) maintain a clear and concise division of authority and responsibility to remove all areas of <br />overlap, duplication and conflict between the CIWMB and SWRCB in the regulation of solid <br />waste disposal sites, without reducing current state minimum standards for environmental <br />protection..." <br />Page 1 of 5 <br />December 2, 2011 <br />