2017-118 Audit Scope and Objectives
State and Regional Water Boards—Permitting
The audit by the California State Auditor will provide independently developed and verified
information related to storm water treatment and management and municipal separate storm
sewer system permits issued to three California regions by Regional Water Quality Control Boards
(Regional Water Boards), and will include, but not be limited to, the following:
- Review the laws, rules, and regulations significant to the audit objectives.
- Identify the roles and responsibilities of the State Water Resources Control Board (State Water
Board), Regional Water Boards, and any other relevant statewide entities involved in developing
policy and providing oversight regarding storm water runoff permitting. Determine whether
these entities' storm water permitting and compliance requirements are consistent with federal
law and regulations, including the Clean Water Act.
- Identify data and information used by the State Water Board, Regional Water Boards, and any
other entities to allocate storm water cleanup costs and establish storm water runoff permits,
permit requirements, and associated programs directed at local or regional jurisdictions. In
particular, explain the history and evolution of storm water runoff permits for the Regional
Water Board of Los Angeles.
- Since 2011, for the three Regional Water Boards responsible for storm water permitting for Los
Angeles County, the Central Valley, and the San Francisco Bay Area, do the following:
- Determine whether the three boards' storm water permitting and compliance requirements
are consistent with state and federal requirements. Identify any significant disparities and
determine why those disparities exist.
- Identify any significant differences in storm water permitting and compliance requirements
among the three boards and determine why such differences exist and, to the extent
possible, determine the impact any differences have on local jurisdictions and other parties.
- To the extent possible, determine whether those responsible for storm water pollution in
these three regions are also responsible for the associated costs of their pollution and the
storm water permits. If not, determine whether options exist for equitably redistributing
cleanup costs to those responsible. In particular, determine who has paid for storm water
pollution within the jurisdiction for the Regional Water Board of Los Angeles.
- For a selection of local and regional jurisdictions covered by the three boards, such as
municipalities and counties, identify the fiscal and other impacts jurisdictions have had or
will have in complying with storm water permits. Provide the jurisdictions' perspectives
about these impacts and, to the extent possible, assess their significance.
- For the selection of three or more of the local jurisdictions specified by the requester,
identify current and potential funding sources for programs that target storm water cleanup
and management, such as watershed management programs.
- As part of reviewing the storm water permitting processes and policies, identify any best
practices that could assist the State Water Board, Regional Water Boards, and permitted
- Review and assess any other issues that are significant to the audit.