Garden Grove Sanitary District v. County of Orange

Opinion

SONENSHINE, J.

In 1972, the Legislature enacted the Solid Waste Management and Resource Recovery Act (Act). (Gov. Code, § 66700 et seq.) Due to population increases and technological advances in packaging, it declared the state’s increased volume of solid waste was creating a threat to public health and the environment. (§ 66701.)

The Act required the county and board of supervisors to draft a Master Solid Waste Management Plan (SWMP) to “accomplish both of the following: [t] (1) Identify and reserve sites for the establishment or expansion of solid waste facilities [1] (2) Ensure that…