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Mr. Ed Padilla <br />June 26, 1990 <br />Page 2 <br />Under these standards, there does not appear to be a <br />basis for revoking or refusing to renew the permit at issue here. <br />Even assuming that there were such a basis (an assumption we do <br />not adopt), we believe that the procedural requirements for <br />revoking or refusing to renew a permit have not been satisfied. <br />However, out of an abundance of caution, we request that this <br />letter be considered a request for reconsideration of the actions <br />set forth in your agency's letter of June 18, 1990, and also a <br />notice of appeal from any actions set forth in that letter. We <br />do not intend by this request to invoke the formal procedures for <br />reviewing and reconsidering these actions if we are able to <br />resolve these issues through an informal process within your <br />agency. We do, however, reserve our client's right to pursue the <br />formal reconsideration and appeals process if a _rdatually <br />satisfactory resolution is not reached. Our hope is to work <br />productively with your agency and avoid any unnecessary conflict, <br />but it is our obligation to represent our client's interests and <br />work within the required rules and procedures. <br />We welcome your thoughts on this matter, and are <br />interested in discussing these issues with you further. We hope <br />that you will agree with our analysis, that the permit will be <br />renewed, and that we can amicably proceed with your review of the <br />engineering issues pertaining to the landfill. In furtherance of <br />that cooperative approach, and as we discussed with you at the <br />February, 1990 meeting regarding the landfill, reports are being <br />prepared for submission to your agency and to the Regional Water <br />Quality Control Board on the schedule set by the Water Board. We <br />hope to submit those reports within the next 30 days. We will be <br />happy to work with you and your agency to provide any information <br />you may need and to meet any requirements necessary to protect <br />public health and safety. <br />soon.If you have any questions, please do not hesitate to <br />call me at (213) 689-7629. 1 look forward to speaking with you <br />Sincerely, <br />cc: Jack Hecht, Cove Contractors <br />