Report 2017-118 Recommendation 11 Responses

Report 2017-118: State and Regional Water Boards: They Must Do More to Ensure That Local Jurisdictions' Costs to Reduce Storm Water Pollution Are Necessary and Appropriate (Release Date: March 2018)

Recommendation #11 To: Water Resources Control Board

The State Water Board should revise its trash policy to focus it on local jurisdictions that have water bodies that are harmed by trash, as identified by the polluted waters list. In addition, the State Water Board should review the polluted waters list at least biannually to identify any additional water bodies recently determined to be harmed by trash and impose its trash policy on the applicable jurisdictions.

1-Year Agency Response

The State Water Board must periodically review the requirements, such as the trash control requirements, established in its water quality control plans. Consistent with applicable law, the State Water Board will consider this audit recommendation during the Ocean Plan 2019 Triennial Review, which was initiated in August 2018. That said, the State Water Board adopted the trash control requirements following a comprehensive public process, considered competing policy considerations, and sees no reason to revise the trash control plans at this time.

  • Response Date: February 2019

California State Auditor's Assessment of 1-Year Status: Will Not Implement

As we state in our report, the State Water Board's trash policy requires certain local jurisdictions to address a pollutant that is of lesser concern than other pollutants. Therefore, we believe that this statewide policy is overly broad in its application and should be revised.


6-Month Agency Response

The State Water Board must periodically review the requirements, such as the trash control requirements, established in its water quality control plans. Consistent with applicable law, the State Water Board will consider this audit recommendation during the Ocean Plan 2019 Triennial Review, which was initiated in August 2018. That said, the State Water Board adopted the trash control requirements following a comprehensive, public process, considered competing policy considerations, and sees no reason to revise the trash control plans at this time.

  • Estimated Completion Date: To be determined
  • Response Date: August 2018

California State Auditor's Assessment of 6-Month Status: Pending

During its triennial review, the State Water Board should consider how its requirements affect all areas of California. As we note on page 29 of our report, communities in the Central Valley have documented that other pollutants are a greater source of concern in their jurisdiction than trash. By imposing statewide requirements for trash, the State Water Board has led certain local jurisdictions to spend resources to address a pollutant of lower concern than other pollutants within those jurisdictions. Further, our recommendation that the State Water Board consider the applicability of its trash policy biannually is consistent with the frequency with which it must review those waters in the State that are impaired by trash.


60-Day Agency Response

The State Water Board must periodically review the requirements, such as the trash control requirements, established in its water quality control plans. Consistent with applicable law, the State Water Board will consider this audit recommendation during its next triennial review, which will be initiated in mid-2018. That said, the State Water Board adopted the trash control requirements following a comprehensive, public process, considered competing policy considerations, and sees no reason to revise the trash control plans at this time.

  • Estimated Completion Date: To be determined
  • Response Date: April 2018

California State Auditor's Assessment of 60-Day Status: Pending

During its triennial review, the State Water Board should consider how its requirements affect all areas of California. As we note on page 29 of our report, communities in the Central Valley have documented that other pollutants are a greater source of concern in their jurisdiction than trash. By imposing state-wide requirements for trash, the State Water board has led certain local jurisdictions to expend resources to address a pollutant of lower concern than other pollutants within those jurisdictions. Further, our recommendation that the State Water Board consider the applicability of its trash policy biannually is consistent with the frequency with which it must review those waters in the State that are impaired by trash.


All Recommendations in 2017-118

Agency responses received are posted verbatim.