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REGULATORY STRATEGY/
FACILITATION, PLANNING
AND PERMITTING

JJ&A offers an alternative to the usual “technology-centric” approach to projects. We view regulations as opportunities – different paths provide different pros and cons; we work with you to identify what is best for your project needs.

We are consistently able to deliver cost savings and expedite project schedules by focusing first on the regulations that define the framework for technical solutions. For example, instead of just permitting an activity, we first ask , “Under what conditions would the activity be exempt or excluded from a permit? Based on those conditions, is the project exempt or excluded? If not, are there project approach options to make it exempt?”

We have extensive experience with regulatory strategy development, agency facilitation, planning and permitting within the frameworks of:

  • CWA, California Water Code and regulations (CCR Titles 23, 27);
  • RCRA, California Hazardous Waste Control Law (Health and Safety Code; CCR Title 22);
  • CERCLA (including NCP compliance for cost recovery),
  • California State Superfund and Voluntary CleanUp Program (Health and Safety Code);
  • CEQA/NEPA; and,
  • California natural resource codes and regulations (CCR Title 14).
  • We believe regulatory strategies are key to a project’s success from the scoping stage through permitting and project execution.

Representative types of projects and examples of specific services include:

  • Developing/negotiating lead agency and preferred regulatory framework strategies for site cleanups
  • Developing/negotiating RCRA clean-closure, closure plans, and corrective action strategies
  • Order and Consent Agreement negotiations
  • Remedy selection documents and related public review and CEQA services
  • Hazardous (RCRA/Title 22) and Non-Hazardous (Title 27) waste management unit permitting, permit modifications, renewals and closures, with a specialty in engineered alternatives and clean closures
  • Project permitting strategy and development
  • Individual and general industrial NPDES permitting
  • Storm Water NPDES permitting
  • Notice of Violation (NOV) negotiation and resolution
  • Lake and Streambed alteration agreements (DFG Code 1600 et seq.)
  • CWA 404 permitting and CWA 401 water quality certifications
  • Local county permitting (e.g., grading)
  • CEQA/NEPA Environmental Reviews