Enforcement Program Plan Toolbox

Yes, updates to the EPP must be submitted annually.  Per 14 CCR 18081(e)(4), “The components of the EPP shall be reviewed and amended by the LEA annually or more frequently as determined by CalRecycle to reflect any changes.”

Not all components need to be submitted every year. Please see the guide below to determine what items the LEA is required to provide to CalRecycle during the Annual Update:

Items that must be updated:

• Facility & Vehicle Tally 18077 (a)(6)
  • Needed to prepare the Time Task Analysis (TTA).
  • Should match the SWIS database (SWIS) and the Designation Information Package (DIP).
• Time-Task Analysis 18077 (a)(7)
  • If no change, resubmit with the current fiscal year indicated.
• Budget 18077 (a)(9)
  • If no change, resubmit with the current fiscal year indicated.

Items that may be updated:

• EPP Goals & Objectives 18077 (a)(3)
  • Update as needed.
• Local Solid Waste Ordinances 18077(a)(5)
  • Update if any local ordinances or regulations change.
• Staff Technical Expertise 18077(a)(8)
  • Document any LEA program staffing changes or changes in the TTA that would alter the number of staff needed to perform LEA duties and responsibilities.
• Staff Training Procedures 18077(a)(10)
  • Update as needed.
• Permitting, Closure/Postclosure Manual 18077(a)(11)
  • Permitting manual updates are unnecessary if referring to CalRecycle Permit Toolbox.
  • Closure/Postclosure Manual requires review to ensure manual is up-to-date with changes in statute or regulations.
• Inspection, Investigation, Compliance, Assurance, Enforcement & Hearing Panel Utilization Manual 18077 (a)(12)
  • Requires review to ensure manual is up-to-date with changes in statute or regulations.
• Disposal Site ID, Assessment & Corrective Action Procedure Manual 18077(a)(13)
  • No update necessary if referring to CalRecycle Closed, Illegal and Abandoned Tools.
• Form 1000, LEA Designation 18077(a)(2) & DIP 18051(a)
  • Reflect current LEA information.
  • New information may be submitted in a letter format.
  • A new Form 1000 with a local governing body signature is only required if the designated LEA or its jurisdiction of authority has changed.
• Organizational Chart Documentation LEA Separation 18077(a)(2) & DIP 18051(d)
  • Ensure and document clear separation of LEA from any public agencies or departments which own/operate sites in that jurisdiction under the local governing body.
• Organizational Chart of Designated Agency 18077(a)(2) & DIP 18051(e)
  • Update to reflect staffing changes, etc.
• Hearing Panel Member/Officer 18077(a)(2) & DIP 18051(f)
  • Check to make sure Hearing Panel/Officer member status is current. Must be updated prior to expiration.
• Waste Facilities & Disposal Site Enumeration 18077(a)(2) & DIP 18051(h)
  • Update when facilities are added or removed.
  • Update owner/operator contact information as needed.
• Collection Operation & Handling Enumeration 18077(a)(2) & DIP 18051(i)
  • Update as needed.

Items that are unlikely to be updated:

• Certification Request Letter 18077(a)(1)
  • Update if LEA is changing the types of certification to include new solid waste facilities for which the LEA has no certification.
• Cover Letter (with DIP submittal) 18077(a)(2) & DIP 18051(b)
  • Not required to be updated.
• Enabling Resolutions 18077(a)(2) & DIP 18051(c)
  • Update when there is a newly incorporated city/cities within the jurisdiction that may affect the majority requirement for certification.
• Enabling Ordinances or Resolutions for Jurisdictional Authority 18077(a)(4)
  • Update when there is a newly incorporated city/cities within the jurisdiction that may affect the majority requirement for certification.
• Tabulation of Municipal Resolutions 18077(a)(2)  & DIP 18051(g)
  • Update when there is a newly incorporated city/cities within the jurisdiction that may affect the majority requirement for certification.