Looks like that was the intent to me. www.dec.ny.gov/docs/permits_ej_operations_pdf/finalTransferPolicy.pdf
"Edit: Perhaps the transfer is in limbo until they renew the Solid Waste 360 permit, which had to be done by 1/30/2019." That would be a lot easier for the transferee, I guess. A renewal/transfer has to be easier than a new permit would be. Sure would like to see that Transfer request.