The Contra Costa Clean Water Program (CCCWP) is
characterized by an inability among the stakeholder organizations to reach
agreement regarding exactly what they are trying to accomplish, in what manner,
in what period of time, and the consequences of failing to do so. Stakeholders
include CCCWP management and Permittees, empowered regulatory bodies, and
interested activist community groups. They have different opinions and
perspectives of what is important, what should or should not be prioritized,
what is urgent, what quantifiable indicators should be used to gauge progress
and compliance and what is the real exposure for non-compliance. The result is
a stream of public communication and comment that is, at best, contradictory
and, at worst, misleading. As a starting point, there needs to be constructive
dialogue between each of the Permittees and the appropriate regulatory
authorities.
The failure of Proposition 218, the 2012 Community Clean
Water Initiative, to receive voter approval was a serious setback for the program.
The ballot initiative was intended to, at least partially and for a short
period of time, address the imbalance between the current and projected future
costs for planned clean water activities that far exceeded available funds. Now
the Permittees must determine alternative funding sources.
It is projected that by 2015, with no changes in the current
permit requirements, a funding gap of several million dollars will exist. This shortfall could significantly grow if
new permit requirements are incrementally more onerous than current
requirements, as expected. This funding gap, if not resolved, may result in an
inability to conduct critical activities needed to meet permit standards. It may also place some Permittees in a
condition of non-compliance, with consequent exposure to fines, other monetary
damages and enforcement actions.
As the challenge of finding additional funding is addressed,
it is an appropriate time for the Permittees to make an effort to better define
and understand their paths forward and develop more detailed plans, timelines,
and desired outcomes. These re-evaluations should, at least, include:
a) negotiation
of more realistic, better-defined compliance terms that take into account
differences in participant characteristics;
b) implementation
of more efficient and effective operating practices of the Contra Costa Clean
Water Program; and,
c) identification
of ways to make the impacted communities more aware of the importance of the
program and the challenges ahead.
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