If Caltrans believes that responding to the monitoring requirements and enforcement actions related to the certification program is too costly, it should begin to gather and track these costs using its accounting system. Once it has tracked these costs for a period of time, Caltrans should analyze whether these monitoring and enforcement activities are, in fact, too costly and work with the state and regional water boards to resolve how these costs might be better contained.
Caltrans Divisions of Environmental Analysis and Project Management have made modifications to the WSG to capture compliance and enforcement costs. The Project Resource and Schedule Management System has been revised to include the new tracking codes. The Division of Project Management will be providing direction to District project management personnel on how to incorporate the new tracking codes into existing and new project workplans. Tracking of compliance and enforcement support costs will begin on July 1, 2014.
Corrective action pending; full implementation will occur on July 1, 2014.
After July 1, 2014, Caltrans provided the instructions it sent to staff to begin using the new tracking codes. Further, according to Caltrans' Chief of the Division of Environmental Analysis, Caltrans intends to regularly check in and see what the trends are and analyze the data for potential corrective measures, which could certainly include working with the regulatory agencies to address problems.
Caltrans Divisions of Environmental Analysis and Project Management have worked together to modify the time-tracking system for capturing support costs for enforcement actions and environmental permitting. The first step, which was to determine a method within Caltrans' time-tracking system to capture the support costs of all environmental permitting, has been completed. The next step, which is currently being performed, will include making modifications to the time-tracking system to separate out compliance and enforcement costs, and will require coordination with the Workplan Standards Guide (WSG) committee. The WSG committee will coordinate implementation of all changes to the statewide system. The target date for accomplishing the modifications to the time-tracking system, and providing direction concerning new tracking practices, continues to be June 2014.
The first committee meeting (established by the Environmental Management Board with a cross section of statewide environmental managers) was held on May 21, 2013. Discussion focused on existing enforcement tracking, methods to capture all enforcement information, and various processes to capture support and capital costs. A follow-up meeting was held on June 20, 2013, where the group recognized that further investigation was needed to determine the most efficient way to coordinate with other functions and to capture the desired information. The first step will be to determine a method within Caltrans' time-charging system to capture the support costs of all environmental permitting (which will include 401 costs) from project identification through construction, along with support costs incurred for responses to enforcement actions. The next step will include making modifications to the charging system to separate out compliance and enforcement costs. Once the system has been modified, staff will be provided direction to separate out these costs. The target date for accomplishing the modifications to the tracking system and providing direction to staff for new charging practices is June 2014. Tracking will commence in Fiscal Year 2014/15.
Agency responses received are posted verbatim.