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Mr. Herb Iwahiro July 14, 1989 Page 2 source recovery effort) and earthcover requirements ... ". See also page 27, where under the heading "South Littlejohn Creek" it is stated, "The estimated life of the disposal site proposed for the site north of Littlejohn Creek is 30 years based on the disposal rate of 500 tons per day". See also page 29, item #9 in the summary to the report which states, "Based on a refuse disposal site of 500 tons per day, it is estimated that the site has a total capacity of approximately 4.7 million tons of refuse, and a site life on the order of 30 years". On October 31, 1972, there was completed an environmen- tal impact statement which was done, as indicated in the transmittal letter "in accordance with the guidelines estab- lished by the San Joaquin County Planning Department". That EIS used the figure of 500 tons per day to calculate the number of vehicle trips which would be generated (see IV A5 where it is stated "Disposal rate anticipated at the site is 500 tons per day"). In short, the environmental impact statement used the Emcon Associates report informa- tion in determining the environmental impact and determined that with that 500 tons per day, the amount of traffic could be accommodated on the existing road. Your other concern, as I understand it, was a concern that the EIS had never been circulated to the State Clear- inghouse. As I indicated to you there was, to the best of my knowledge, no requirement that it be so circulated. I have researched this issue and have determined the follow- ing: First, the requirement to circulate to the State Clear- inghouse is contained in Title 14, CCR 15206. Leaving aside the discussion of effective dates below, you will see that pursuant to that section, it would not be required that the EIS be submitted to the State Clearinghouse. Assuming, however, that it was so required, you must under- stand that the EIS was done in October 1972. At that time, the law which established the requirements to circulate items to the State Clearinghouse was not in effect. Public Resources Code 521083, which directs the OPR to prepare guidelines, was not even effective until December 1972, and our information from Mr. Robert King, Senior Analyst of the Office of Planning and Research is that Section 15206 was not even enacted until 1976, effective 1977. In other words, there was no procedure or requirement existing to circulate the EIS at the time and therefore it could not have been circulated. The requirement to circulate items