Local Enforcement Agency (LEA) Central
2007 Financial Assurances Contracted Study

Task 1 and 5 Comments: California State Association of Counties

The following e-mailed comments were received from the California State Association of Counties (CSAC) for the first phase of the study, Tasks 1 and 5 Work Plans. Task 1 finalizes a detailed work plan for Tasks 2 through 4 indicating the steps that will be taken in completing each task. Task 5 finalizes a detailed work plan for Task 6 indicating the steps that will be taken in completing the task.

Comments

Thank you for the opportunity to review and comment on the Draft Work Plan on behalf of CSAC. The comments are based upon review by the CSAC Solid Waste Management Committee.

The Draft Work Plan is very comprehensive and appears to cover the goals of the study very well. Our specific comments are as follows:

Will some of the work tasks be worked on concurrently?

Would it be possible for the AB 2296 Consulting Group to receive a time line, which will provide us with this information, so that we can be prepared to respond in a timely manner with our comments on the deliverables?

Will the AB 2296 Consulting Group have the opportunity to review the various "white papers"?

As it relates to Task 3: Developing a Model for a State Wide Pooled Fund which would be based, per the RFP, on receiving contributions only from active landfills, we support ICF's Consulting Services (contractor) recommendation to identify the advantages and disadvantages of this concept.

Task 3, Step 4 under the section on Estimate Occurrence, Timing and Amount of CA Expenditures. There is a reference to a "bounding concept that most, if not all landfillss will require CA eventually." What is the basis for this concept, is there factual data to support it?

Task 4: Commercial Insurance Product, ICF notes that the RFP stated that product development should be based on the concept " that the product must be purchased by "all landfill operators". Is it correct to assume that "all landfill operators" comprises only active sites? Regardless, we support ICF's suggestion to look at both mandatory and optional models.

Task 6: Risk Screening Methodology: Development of this methodology for assessing a individual landfill's risk based on identified key factors and the weighting of those factors is an area of keen interest to jurisdictions/operators, as each landfill can have it's own unique set of circumstances which may contribute to a lower or higher overall risk. Therefore, CSAC recommends added emphasis on providing the AB 2296 Consulting Group adequate opportunity for review and comment on Task 6, Steps 2-5.

Again thank you for the opportunity to comment.

Susan R. Klassen, Deputy Director
Department of Transportation and Public Works
2300 County Center Drive, Suite B100
Santa Rosa, CA 95403
Phone: (707) 565-2231
Fax: (707)565-2620
E-mail: sklassen@sonoma-county.org

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Last updated: April 18, 2008