Comment Log Display

Date:  December 10, 2008
TO:  California Air Resources Board
From:  Dennis Shuler, REHS
Title:  Environmental Affairs Manager
Company:  Gilton Solid Waste Management, Inc.

Subject:  

Dear Board Members

I wish to make the following comments for both our companies: 
Gilton Solid Waste Management, Inc. and Gilton Resource Recovery /
Transfer Facility, Inc.

•	We operate fully permitted solid waste collection, recycling,
waste transfer and composting businesses
•	We are one of 20 companies that was certified for early
compliance with the Solid Waste Collection Vehicle rule passed in
2003 so we know about the difficulties of implementation
•	Over the past five years we have been only marginally successful
in having the jurisdictions we serve recognize the costs of CARB
compliance issues in our contracts and rates adjustments
•	Despite the Board’s intentions and nice letters reminding public
officials to treat us fairly on these costs we still have a long
way to go on the rule passed five years ago
•	This proposed rule appears to be more of the same and based upon
our real-world experience we are doubtful that the people we work
for will or can embrace the new costs that CARB has planned for us
•	As residents of the communities we serve, we have made a
commitment to be team players to improve air quality, but we cannot
do this alone

Our requests regarding the proposed new rule include:

1.	That CARB adopt the DTCC proposal to make our compliance
schedule more achievable
2.	That CARB include vehicles used to haul recycled organic
materials, including compost, in its time extension that is
afforded to chemical fertilizer haulers.  It seems only fair to us
that our “clean green” product made from organic waste that is
diverted from landfilling be given the same extension as chemical
fertilizers.