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1� 0 <br />S H UTE1 HALY <br />t--WEINBERGERLLP <br />396 HAYES STREET, SAN FRANCISCO, CA 94102 <br />T: 415 552-7272 F: 415 552-5816 <br />www.smwiaw.com <br />September 18, 2014 <br />Via Via Email <br />Robert McClellon <br />San Joaquin County Environmental Health <br />Department <br />1868 East Hazelton Avenue <br />Stockton, CA 95205 <br />rmcclellonksicehd.com <br />Re: Solid Waste Facility Permit No. 39 -AA -0020 <br />Dear Mr. McClellon: <br />LAUREL L. IMPETT, AICP <br />Urban Planner <br />impett@smwlaw.com <br />On behalf of Clean San Joaquin, we submit this letter in connection with the <br />County's proposed revision of the Solid Waste Facility Permit ("SWFP") for the Forward <br />Resource Recovery Facility. We have reviewed the Notice of Public Information <br />Meeting, Forward's application for a SWFP/ ante Discharge Requirements <br />("Application"), the draft Transfer Processing Report ("TPR") and the draft Report of <br />Composting Site Information ("RCSI"). This documentation raises a few important <br />issues that require clarification before Clean San Joaquin is able to arrive at a position <br />regarding the permit revision. <br />As an initial matter, Clean San Joaquin is dismayed by the Environmental Health <br />Department's ("EHD") public notification process relating to this matter. It required <br />numerous emails from Jeannie and Mike LaForge to understand the reasoning behind the <br />proposed permit revision and to obtain copies of the relevant documentation, including <br />the draft TPR and the draft RCSI. After learning that these were lengthy reports and that <br />the draft permit could be subject to revision by the applicant, the LaForges requested a <br />continuance of the public hearing. Apparently the decision to postpone the hearing was <br />up to Forward rather than EHD since EHD was close to its 60 -day public hearing <br />deadline. Had the County made the documentation available to the public much earlier in <br />the 60 -day period, Clean San Joaquin would not have been put in the position of <br />requesting this continuance. <br />