Dear Mr. Lockwood,
Thank you very much for your recent letter regarding compliance with County guidlines pertaining to solid waste storage and removal. (Case #SW 05-107)
In accordance with your suggestions, I have carefully reviewed a number of the applicable county statutes and ordinances. Also, in order to address your concerns in the most comprehensive manner possible, I have consulted with officials in several state offices, including the Department of Motor Vehicles, and with representatives of the US Environmental Protection Agency, the Department of Homeland Security, the Department Of Transportation, and the US Customs service, among others.
As you explained, the alleged violations on your property are not exactly what they might appear to a casual or uninformed observer. Specifically:
A. According to the State Department of Motor Vehicles and the US Department of Transportation, a motor vehicle is defined as "a vehicle with a motor." Since your truck does not currently qualify as such, you are quite correct in your assertion that the orginal complaint was improper. However, in its current state, the truck may qualify, according to EPA definitions, as a "solid materials retention site." This qualification typically applies to any collection of "metals, plastics, textiles, or any combination thereof, exceeding a gross mass of 100 Kg, and stored in proximity to residential or commercial buildings, public gathering areas, or industrial sites which lack the licenses appropriate for such storage." Since you've made it clear that you understand both the letter and the intent of the applicable codes and regulations, I've assured the local office of the EPA that you will be sending copies of your licences, quality control manuals for solid matter storage and disposal, and also the appropriate certifications and credentials for your firm's safety and environmental affairs officers, at your earliest convenience. For your reference, the EPA case number is 05-122C-90096. The case file will be considered unresolved, pending investigation, until your documents have been received.
You should also be aware that the local fire department will recieve a copy of all entries to the EPA file. Given the tone of your letter, however, I'm sure that your fire-fighting equipment, training of personnel, and emergency preparedness plans, are all in good order, and have been properly registered and approved in advance. As soon as the local fire officials have verified your registrations and certificates, they'll be able to perform the legally mandated on-site inspections.
Also, just to be as helpful as I can, I would respectfully suggest that you contact your accountant or tax advisor, to discuss the possibility that the repairs you're making to the truck might affect its value as an item of taxable personal property, its status as a depreciable piece of industrial equipment, or both.
The repairs to the truck, of course, fall under the jurisdiction of the State Department of Licenses and Inspections, which, if I understand their guidlines correctly, requires that repairs exceeding certain levels of cost, complexity, or duration, be performed only by a licenced automotive technician. Since the removal and replacement of an engine seems clearly to be a very major repair, I've asked an acquaintance at L&I to look up your license, and to confirm that it's current and in good standing. That way, it won't be necessary for them to open a case file or investigate a violation that I'm sure you'd never be guilty of.
The only other matter concerning the truck will be for the regional office of the EPA to verify, probably with an on-site inspection that won't take more than two or three days, that you've followed all applicable rules and guidelines for collection, storage, and/or disposal of potentially hazzardous materials produced by your disassembly of the truck, and your removal of its motor. The materials in question will include, but not be limited to: motor oil, transmission fluid, refrigerants from the air conditioning system if the truck is so equipped, anti-freeze or other ethanol-based coolant additives, nonbiodegradable plastic and rubber parts, any solvents or chemicals used for cleaning the parts of the truck or engine, cloth or paper products which may have been used in conjunction with the solvents or cleaners, and any rainwater which may have come into contact with, mixed with, or disolved, any of the above, and which was not collected in approved catch-basins designed and licensed for that purpose and operated according to EPA guidelines.
I'm sure, based on your letter to me, that you routinely take all necessary precautions. The EPA inspectors, when they arrive at your facility, will very likely be able to save you a great deal of time and effort if you simply present to them all the applicable permits, receipts for fees, and certifications from disposal contractors that you might employ.
B. Unlike your truck, the tires might actually be a problem. If you'll please refer to page 14 of this letter...
Or you could just clean up your damned yard, Mr. Lockwood. You really, REALLY don't want to piss me off right before the holidays.
Sincerely, J. M. Trejo