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Mr. Alan Biedermann October 11 , 1988 Page 3 The RODSI was simply submitted, at the request of the Health District, for the five year review. It is important because the CWMB is suggesting that an environmental review be conducted for three specific areas. As you know, an environmental review is required under the California Environmental Quality Act (CEQA) , only when there is a "project" having a potential for a significant adverse impact on the environment. (See California Adminis- trative Code ("CAC" ) , Title 14 , S§15002 and 15378) . A "project" does include the issuance, or modification of a permit, since that is a discretionary action of a governmental agency. (CAC, Title 14 , §15002 (i) and §15378 (a) (3) . However, where there is no issuance, modification or renewal, there is no project and therefore no requirement for environmentalre-view. There is no need for modification of the existing permit, unless there are substantial changes which have not been previously reviewed or analyzed. Thus, we feel that, while you may wish to rewrite portions of the permit for clarification, unless there is a significant, substantial change, no environmental review is necessary. In the CWMB letter, there were three specific points listed which CWMB indicated should be addressed in an envi- ronmental review. I wish to address these points. First, CWMB indicated 1. Increase in daily volume of waste received. The existing permit, dated October 3 , 1978 , states the site receives an average of 700 cubic yards of waste per day. The proposed permit stated the site receives 3 ,000 cubic yards of waste per day. We do not feel that this is a new or significant change which has not already been addressed. First, this is not an absolute limitation in the existing permit. The actual statement is under the heading "Findings" , and says, "This site is closed to the public, but receives an annual