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Harprit S. Mattu [EH] <br />From: Matthew Cotton <matt@mattcotton.com> <br />Sent: Tuesday, December 6, 2016 1:05 PM <br />To: Robert McClellon [EH] <br />Cc: Sam Monaco; Jed Phelps; Harprit S. Mattu [EH]; Michael Kith [EH]; Lorraine Paskett <br />Subject: Re: Harvest Power Lathrop OIMP <br />Robert - <br />I think I understand your concerns. However, having an odor trigger in the CUP is a very unusual <br />approach. As I understand it, the Planning Department implements the CUP. How would the Planning <br />Department verify whether or not Harvest was having odor complaints? <br />The way I see it (based on 25 years of permitting and developing composting facilities in CA) the LEA already <br />has significant ability to shut the site down in the event of a serious odor event. LEA staff will be visiting the <br />site monthly and verifying whether or not the site is implementing its OIMP and whether or not the OIMP is <br />adequate. If it is not adequate, staff can assign an "Area of Concern" or a "Violation" to the monthly inspection <br />report. As you know, there is a potentially escalating process once a Violation is received, that can result in a <br />Notice and Order or other action. We all hope it never comes to that. But I don't want to create overlapping <br />and potentially conflicting areas of authority over the composting facility. The existing OIMP process works <br />pretty well. <br />I am available most of the rest of the week to discuss. Wednesday or Friday is best, but let me know when you <br />might be available. <br />4 <br />COTTON <br />Integrated Waste <br />Management Consulting, LLC <br />19375 Lake City Road <br />Nevada City, CA 95959 <br />530.265.4560 (office) <br />530.305.2060 (cell) <br />matta,mattcotton.com <br />f- tR�'`' <br />www.mattcotton.com � , � � � ��� � , <br />K� �a <br />