Landfill Gas Monitoring Plan Parallel Review Process

The parallel review process is optional but encouraged. It is designed to provide Local Enforcement Agencies (LEA) with technical support during their review and approval of Landfill Gas Program Plans. CalRecycle will continue to review Plans approved by LEAs in support of its concurrence responsibility. The parallel process is intended to work similarly to the review of draft documents by LEAs and CalRecycle for permit application packages.

Currently, regulations do not specify a timeline for LEA review. Once the revised regulations are approved, LEAs will have 60 days to complete the review of the submitted plans. Requests to CalRecycle for parallel review should allow adequate time for review and response to the LEA consistent with a 60-day deadline.

The suggested parallel review process:

  • The operator submits a Plan to the LEA. At the time of submission, the operator may request a CalRecycle parallel review. The LEA may accept or reject the operator’s request or make its own request for a parallel review.
    • The operator should not submit a plan directly to the CalRecycle.
    • Plans received by the LEA will undergo a completeness review before a copy is forwarded to the CalRecycle.
    • The operator can provide multiple copies of the Plan to the LEA to help reduce delays.
  • If the LEA’s initial review finds that the plan does not have all the elements required by the regulations, it should provide specific guidance to the operator on what additional information is needed to complete any missing element(s).
    • LEAs are encouraged to use the “Plan Element Guidance Checklist” when conducting reviews for the required elements.
    • A plan should not be sent to CalRecycle for parallel review until the LEA is satisfied that all the elements are included.
  • LEAs can request assistance from CalRecycle, if necessary, to review the required elements.
    • CalRecycle staff will utilize the “Plan Element Guidance Checklist” when assisting an LEA in an initial review.
    • CalRecycle will provide LEAs with written comments on plan element requirements, with a cc to the operator.
  • Once the LEA is satisfied that all the elements are present in the plan, the LEA can forward the plan to the jurisdictional point of contact to begin the parallel review.
  • The plan can be sent to the CalRecycle electronically and/or via US mail. The transmittal should clearly indicate that the LEA is asking for a parallel review and indicate a reasonable date when the LEA would like to receive CalRecycle comments.
  • CalRecycle will review the submitted plan to ensure all the elements are present.
    • If the plans are found not to include the elements required in the regulations, the LEA will receive written comments indicating what elements are missing.
    • When the plan has all the elements, it must be resubmitted.
  • Technical staff will review the plans within the requested LEA timelines, if possible. Technical staff will be in close contact with LEAs throughout the review process. 
  • CalRecycle will send a cover letter and a full set of comments on the plan back to the LEA with a cc to the operator.
  • If the LEA denies the operator’s plan or requires additional information be provided by the operator, it is suggested that the LEA incorporate CalRecycle comments, as the LEA deems appropriate, in its formal response to the operator.
  • If the plan undergoes multiple revisions before LEA plan approval, CalRecycle can also review these revisions at the same time. The same procedure would be followed when requesting a parallel review of a revised plan.
  • Upon LEA approval of a plan, it should be sent to the point of contact for the jurisdiction with a request that CalRecycle concur with the LEA’s approval. This initiates CalRecycle’s formal concurrence process.
  • CalRecycle has 60 days to act on LEA’s request by either concurring with the approval of the plan, by not concurring on the approval of the plan, or by requesting additional information before deciding on whether to concur or not to concur.
    • For Plans that have gone through a parallel review, CalRecycle’s review should consist of verifying that the approved plan reflects the version reviewed by staff, addressing any comments made by CalRecycle and consistency with regulatory requirements. 

Plan Element Guidance Checklist

Landfill Name:


LEA Staff:

Date Received:

Prior to forwarding a Plan to CalRecycle with a request for a parallel review, the LEA should review the Plan to determine if all of the required Plan elements are included in the submittal. This checklist is designed to aid LEAs in making a determination and is similar to one utilized by CalRecycle to assist them in their review.

If alternatives to the prescriptive standards are being requested, documentation must be included that supports the request.

Are the following included and/or described in the Plan?

  • Designed by a registered engineer or certified engineering geologist (signed and stamped) [20923(a)(1)]
  • Wells identified that are around the outside of the waste footprint (not in the waste) [20925(a)(1)]
  • Wells identified (at or near the permitted boundary or an alternative) [20925 (a)(2)]
  • Spacing of wells (1,000 feet of each other or an alternative) [20925 (b)(1)]
  • Information provided to support alternative location or spacing request
  • All well depths indicated (drilled to level at least equal to the deepest level of waste or an alternative) [20925 (c)(1)]
  • Depth of shallow probes indicated (5 to 10 feet from the surface or an alternative) [20925 (c)(1)(A)]
  • Depth of intermediate probes indicated (at or within 5 feet of half the depth of the waste, [if waste depth is less than 30 feet only need a shallow and deep probes] or an alternative) [20925 (c)(1)(B)]
  • Depth of deep probes indicated (at or with 5 feet of the deepest waste level or an alternative) [20925 (c)(1)(C)]
  • All probes are above low seasonal water table or an alternative [20925 (c)(1)(E)]
  • Information provided to support an alternative to well or probe depth requested [20925 (c)(2)]