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Legislative Analyst's OfficeAnalysis of the 2001-02 Budget Bill |
The State Water Resources Control Board (SWRCB), in conjunction with nine semi-autonomous regional boards, regulates water quality in the state. The regional boards—which are funded by the state board and are under the state board's oversight—implement water quality programs in accordance with policies, plans, and standards developed by the state board.
The board carries out its water quality responsibilities by (1) establishing wastewater discharge policies and standards; (2) implementing programs to ensure that the waters of the state are not contaminated by underground or aboveground tanks; and (3) administering state and federal loans and grants to local governments for the construction of wastewater treatment, water reclamation, and storm drainage facilities. Waste discharge permits are issued and enforced mainly by the regional boards, although the state board issues some permits and initiates enforcement action when deemed necessary.
The state board also administers water rights in the state. It does this by issuing and reviewing permits and licenses to applicants who wish to take water from the state's streams, rivers, and lakes.
The budget proposes expenditures of $872.9 million from various funds for support of SWRCB in 2001-02. This amount is a net increase of $41.6 million, or about 5 percent, over estimated current-year expenditures. Major budget proposals include (1) $100 million for the Clean Beaches Initiative, (2) an increase of $8.1 million to control stormwater runoff, (3) $3.2 million to improve information management, and (4) $3 million for research and monitoring to improve Lake Tahoe water quality. In addition, the budget proposes $9.6 million to continue, and augment, a one-time increase in the current year to reduce backlogs in permit updates and increase inspections. Finally, the budget proposes a reduction of $52.6 million for local projects funded from Propositions 13 and 204 bond funds.
The Total Maximum Daily Load (TMDL) program implements a federal requirement to address pollution in the state's most seriously impaired water bodies. The state lags in developing TMDLs (plans that allocate responsibility for reducing pollution), has no long-term work plan, and is spending ten times the national average to develop each plan. The slow pace of developing TMDLs delays water quality improvements and may result in a loss of both federal funds and state control over aspects of water quality regulation.
We have identified a number of efficiencies and improvements that can be made in the TMDL program. We also recommend that the State Water Resources Control Board develop a long-term plan for the program in order that funding requirements can be evaluated.
What Are TMDLs? Federal law enacted in 1972 requires states to periodically compile lists of water bodies that, in spite of controls on point sources of pollution, are failing to meet water quality standards. Point sources of pollution are those sources that discharge waste directly into water bodies (such as rivers, lakes, and streams), and include wastewater treatment plants and factory pipes. In contrast, nonpoint source pollution is created when water picks up contaminants from pesticide use, mining, logging, and other sources and deposits them in water bodies.
States are required to develop plans—called Total Maximum Daily Loads (TMDLs)—to meet water quality standards in the impaired water bodies that have been listed. A TMDL is developed for each pollutant contributing to the impairment of a listed water body. The development of a TMDL involves the following steps:
When a listed water body later meets water quality standards, it is "de-listed." Neither state nor federal law specifies a time schedule for the development or implementation of TMDLs or for when listed water bodies should become de-listed. Only three of the 18 impaired water bodies on the state's initial list from 1976 have been de-listed.
State Versus Federal Role. The state is primarily responsible for compiling the list of impaired water bodies and developing TMDLs. This is carried out by the nine regional water quality control boards, operating under SWRCB's oversight. The regions' lists and TMDLs are both submitted to SWRCB for its review and approval.
A number of other state agencies assist in the development of TMDLs, depending on the sources of pollution and beneficial uses of a particular water body. For example, the Department of Pesticide Regulation (DPR) would be involved if pesticides were the pollutants of concern, and the California Department of Forestry and Fire Protection (CDFFP) would comment on a TMDL if timber harvesting was contributing to the impairment of a water body. The Department of Fish and Game would be involved if fish and wildlife were beneficial uses of water that were impacted in an impaired water body.
The list of impaired water bodies and TMDLs are submitted to the U.S. Environmental Protection Agency (U.S. EPA) for its review and approval. If U.S. EPA rejects a particular TMDL, it must establish the TMDL itself. In some cases, the development of TMDLs is carried out under a federal court settlement. These TMDLs may be developed by U.S. EPA or delegated by U.S. EPA to the state to develop.
The TMDL Requirements Largely Ignored from 1972 to the Early 1990s. The requirement for TMDLs was largely ignored by federal and state water quality agencies until the early 1990s. Until then, water quality regulation had been focused on controlling point sources of pollution through state and federal permitting programs. Although water quality had been improving, over 40 percent of assessed water bodies nationwide remained too polluted for fishing or swimming. It became apparent that the remaining water pollution problems—largely associated with nonpoint source pollution—required different solutions. The activation of the TMDL program in the 1990s, in part instigated by lawsuits against the federal government to enforce the TMDL requirements, provides a planning framework to address these problems.
Current State List of Impaired Water Bodies. The most recent list of impaired water bodies in the state (1998) lists 509 impaired water bodies for which 1,471 TMDLs have to be developed. (The next list will be submitted to U.S. EPA in 2002.) As shown in Figure 1, there are impaired water bodies in every region of the state, with the largest number of impaired water bodies located in the Los Angeles region.
Figure 2 shows the breakdown of TMDLs to be developed based on pollutant. As shown, metals and pesticides are the leading contributors to impaired water bodies.
Expenditures for TMDL Development. Prior to 1997-98, no state or federal funds were targeted for TMDL development. Federal funds totaling $800,000 for TMDLs were first made available in 1997-98 (currently $3 million), and the first state funding was made available in 1999-00 ($5.1 million). As shown in Figure 3, expenditures for TMDL development in 2000-01 are estimated to total $13.5 million. A majority of these expenditures are from the General Fund, with the balance from federal funds and a tax on the sale of pesticides.
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Figure 3 |
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TMDL Development Expenditures a |
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(In Millions) |
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1997-98 |
1998-99 |
1999-00 |
2000-01 |
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State Water Resources Control Board |
$0.8 |
$1.5 |
$6.4 |
$11.9 |
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Department of Pesticide Regulation |
— |
— |
1.2 |
1.6 |
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Totals |
$0.8 |
$1.5 |
$7.6 |
$13.5 |
a All funding sources. Does not include expenditures to develop mitigation measures or to implement TMDLs that have been developed. |
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Recent Legislative Direction. In recent years, the Legislature has expressed interest in the state's TMDL program on a number of occasions. For example, Chapter 495, Statutes of 1999 (AB 982, Ducheny) requires SWRCB to form a public advisory group (PAG) to evaluate the structure and effectiveness of the state's TMDL program. In preparing this analysis, we reviewed the advisory group's draft recommendations. The board has notified the Legislature that its first report to the Legislature on the TMDL program, due on November 30, 2000, will be submitted early in 2001.
In addition, the 1999-00 Budget Act requires SWRCB to report to the Legislature by November 30, 2000 on various TMDL matters, including the process and criteria used to develop TMDLs and prioritize work, work products to date, and the activities undertaken to involve the public in TMDL development and implementation. The board has notified the Legislature that this report will also be submitted early in 2001.
We find that no matter what measure is used, the state lags in the development of Total Maximum Daily Loads (TMDLs). This causes delays in meeting water quality objectives and could result in a loss of federal funding and of state control over its water quality program. We recommend the enactment of legislation to require the State Water Resources Control Board to adopt in regulation a time schedule for completing all TMDLs required by the 1998 list of impaired water bodies. This time schedule should be based on the long-term work plan that we also recommend be developed.
As mentioned above, based on the 1998 list of impaired water bodies, there are currently 1,471 TMDLs to be developed. (Future water quality monitoring may result in additional water bodies being added to the list.) According to SWRCB, although it is possible to consolidate multiple listings by "bundling" TMDLs, at least 500 TMDLs will still have to be completed.
Board Is Not on Track to Complete TMDLs. At present, only eight TMDLs have been completed and adopted into basin plans. While neither state nor federal law specifies a time schedule for completing TMDLs, there are various measures that can be used to evaluate whether the state is "on track" in completing them. These measures include primarily commitments made to the Legislature and U.S. EPA, as well as court settlements, regarding the pace of TMDL development. Our review finds that no matter which measure is used, the board is lagging in its development of TMDLs. We discuss in sections which follow the reasons for this. In addition to insufficient resources, these reasons include a cumbersome approval process and inadequate policy direction from the state board to the regional boards to provide for efficient and consistent TMDL development.
For example, in budget proposals submitted to the Legislature, the board anticipated completing 18 to 20 TMDLs in 1999-00 with resources of about $6.9 million. In fact, the board completed only three. While the SWRCB's budget for TMDLs is based on work plans of the nine regional boards, the regional boards have generally failed to meet the work plan commitments. The board is also lagging in completing TMDLs according to schedules found in its annual grant commitments to U.S. EPA. At the current pace, it is highly unlikely that the board will complete all TMDLs within the U.S. EPA time frame that TMDLs be completed by 2011 for all water bodies on the 1998 list.
Finally, court settlements dictate a schedule for the development of about 700 TMDLs. The board also appears to be lagging in completing TMDLs subject to these schedules. For example, U.S. EPA has had to step in to develop some TMDLs itself, rather than the state, to ensure compliance with these time schedules.
Consequences of Lagging Behind. Our review finds that there are a number of potential consequences if the state does not pick up the pace of TMDL development. These include:
Recommend Enactment of Legislation Setting Time Schedule. According to U.S. EPA, other states are doing a much better job than California in meeting their TMDL development commitments. This is the case even though California's TMDL workload challenges are not out of line with those found in other states. In fact, California ranks thirteenth nationwide in terms of the number of TMDLs to be developed. (Illinois ranks first with 2,865 TMDLs to be developed.) In addition, other states are developing TMDLs that are as complex as ones being developed in California.
Specifically, U.S. EPA has expressed concern that there is a lack of urgency at many of the regional boards to develop TMDLs, and that the annual work plan commitments are not viewed by the boards as "firm" commitments.
Some state legislatures, including Montana's, have exerted control over the TMDL process in their states by requiring that a schedule for TMDL development be set in statute or regulation. In order to make SWRCB more accountable for achieving specified results, we recommend that the Legislature enact similar legislation. This legislation should require SWRCB to establish, in regulation, a time schedule for completing all TMDLs from the 1998 list of impaired water bodies.
We discuss opportunities for improvements and the need for a long-term work plan in the sections that follow.
We find that a number of improvements can be implemented to make the Total Maximum Daily Load (TMDL) program more effective and timely, and reduce costs. We recommend the enactment of legislation to (1) require greater policy direction from the State Water Resources Control Board to the regional water quality control boards and (2) streamline the TMDL approval process. We also recommend the adoption of budget bill language earmarking funds to streamline the boards' contracting process. Finally, we recommend the adoption of supplemental report language to require (1) an evaluation of the effectiveness of certain interagency agreements and (2) a status report on the board's implementation of organizational improvements.
Our review finds that a number of operational improvements can be made to make the program more effective and efficient. Some of these improvements should increase the pace of TMDL development and reduce costs. As discussed later, the state's average costs to develop a TMDL are substantially higher than other states' costs.
Provide Expanded Policy Direction. We find that the TMDL process would be significantly improved if the criteria to be used by the regional boards in making various TMDL-related decisions were more clearly articulated by SWRCB. Based on discussions with the regulated community, there is a general perception that regional board decisions are being made arbitrarily. If this perception is not addressed, further delays and costs in TMDL development are likely because TMDL decisions are more likely to be challenged in court.
While some policy guidance from SWRCB currently exists, including broad criteria regarding the listing of impaired water bodies, we think that SWRCB should expand its policy guidance. Specifically, we think that SWRCB policy should address:
In order to ensure greater direction to the regional boards, we recommend the enactment of legislation requiring SWRCB to adopt policies that address the issues discussed above. The Florida Legislature enacted similar legislation in 1999, requiring that state's water quality agency to adopt rules establishing methodologies for making various TMDL determinations.
Streamline TMDL Approval Process. According to a U.S. EPA report on the state's TMDL program, California has a cumbersome and lengthy TMDL approval process. This helps to explain why the state is taking on average three years to develop a TMDL, while other states are taking significantly less time at substantially lower costs.
Specifically, U.S. EPA's program review found that, unlike other states, the state's TMDL adoption process involves the review and approval of several agencies. These agencies include the regional board, the state board, the Office of Administrative Law, and U.S. EPA. These agencies are involved because state law requires that a regulation (a "basin plan amendment") be adopted to implement a TMDL. Both U.S. EPA and PAG have questioned the added benefit from SWRCB's review of all TMDLs. The inclusion of SWRCB review appears to add many months to the time to complete TMDLs, as well as additional costs.
In its draft recommendations, PAG has recommended that statute be amended to eliminate the requirement for automatic SWRCB review and approval of all regional board-approved TMDLS, provided a right of appeal from the regional board action to SWRCB is maintained. We think that this recommendation has merit, provided regional board development of TMDLs is thorough and adequate. Improved policy direction from SWRCB, as recommended above, should ensure this. Therefore, we recommend that the Legislature enact legislation to streamline the TMDL approval process as recommended by PAG. The recommended streamlining maintains safeguards by continuing to provide for SWRCB review of regional board decisions when these decisions are challenged.
Streamline Contracting Procedures. Our review finds that much of TMDL-related work, such as data modeling and monitoring data collection, can be contracted out. However, we find that SWRCB and the regional boards have a cumbersome contracting process. Generally, the boards create a new contract each time a contract is entered into. In contrast, other states such as Arizona rely much more on "master contracts" for their TMDL work. This streamlining measure has facilitated the use of contracts, and has helped these states complete their TMDL work on a more timely basis and at a lower cost. A master contract would allow the boards to rely largely on a predeveloped standard contract when they enter into new TMDL contractual relationships, rather than have the boards develop a new contract each time.
In order to realize the efficiencies from master contracts, we recommend that the Legislature direct SWRCB to establish a master contract for TMDL contract needs. According to SWRCB, it would require about one personnel-year to develop a master contract. We therefore recommend that the Legislature adopt the following budget bill language:
Item 3940-001-0001. Of the funds appropriated by this item, up to $100,000 is to be expended by the board to develop a master contract for its Total Maximum Daily Load (TMDL) program.
Evaluate Coordination Efforts. In order to coordinate overlapping regulatory responsibilities, SWRCB has entered into interagency agreements (referred to as a management agency agreement [MAA]) with CDFFP and DPR. While these MAAs are not exclusively focused on TMDLs, the effectiveness of the TMDL program depends on the lead management agencies effectively exercising their responsibilities under the agreements. The DPR will be the lead management agency for pesticide-related water quality issues. Similarly, CDFFP will be the lead in handling forestry-related water quality issues (to be handled under the Forest Practices Rules).
Based on discussions with staff, U.S. EPA has expressed concern about the level of effort of the lead management agencies under these agreements in addressing water quality issues. For example, concern has been expressed that Forest Practice Rules are not being amended on a timely basis to implement TMDLs in the North Coast region. Accordingly, we think that SWRCB should review its MAAs with DPR and CDFFP regularly to determine whether the agreements are working as intended. The SWRCB should revise these agreements if its evaluation finds that they are not serving to protect water quality. Therefore, we recommend that the Legislature adopt the following supplemental report language:
It is the intent of the Legislature that the State Water Resources Control Board regularly evaluate the effectiveness of its Management Agency Agreements (MAAs) with the Department of Pesticide Regulation and the California Department of Forestry and Fire Protection in addressing pesticide-related and forestry-related water quality issues, respectively, in the context of the state's Total Maximum Daily Load (TMDL) program. The board shall submit a report with its initial evaluation of these MAAs to the Legislature by January 1, 2002.
Make Organizational Improvements. Finally, PAG has made a number of recommendations for organizational changes in order for the state and regional boards to improve the program's accountability and efficiency. For example, SWRCB could establish "strike forces"of staff who are technical experts on some of the leading TMDL pollutants (such as metals and sedimentation). These strike forces could rotate among regional boards to assist with TMDL development.
To ensure that these organizational improvements are made, we recommend that the Legislature adopt the following supplemental report language:
The State Water Resources Control Board shall report to the Legislature by January 1, 2002 on the status of implementing organizational improvements to the Total Maximum Daily Load program recommended by the public advisory group formed pursuant to Chapter 495, Statutes of 1999 (AB 982, Ducheny).
We recommend the enactment of legislation requiring the board to develop a ten-year work plan for Total Maximum Daily Load development, including an analysis of funding requirements.
In the previous sections, we have identified improvements that can be made to the TMDL program without additional resources. In this section, we have identified other improvements, specifically for ambient water quality monitoring and for staff training, that should be addressed if TMDLs are to be developed in a timely manner. Such improvements are likely to require additional funds. However, as discussed below, the lack of a long-term work plan for the TMDL program means that total long-term funding requirements for the TMDL program are not known.
Funding for Ambient Water Quality Monitoring. The TMDL program requires comprehensive, up-to-date water quality monitoring data for several reasons. Such data allow the boards to set credible water quality standards, to determine whether water quality standards are being met, to allocate responsibility for reducing pollution among those contributing to the pollution problem, and ultimately to monitor the effectiveness of TMDL implementation. The credibility of TMDL decisions depends on these data.
Unfortunately, according to SWRCB, the state has not assessed 43 percent of the state's coastal waters, 56 percent of the state's lakes and reservoirs, and 93 percent of the state's rivers and stream miles.
This lack of monitoring data is a very substantial barrier to speeding up the pace of TMDL development. This is because according to U.S. EPA, it will likely take several years in some cases to obtain sufficient data to complete TMDLs for many of the state's water bodies.
For the current year, SWRCB expenditures for ambient surface water monitoring are about $7 million. Chapter 495 requires the board to report to the Legislature with a proposal for a comprehensive surface water quality monitoring program for the state. While the board expects to submit its report in early 2001, it has developed preliminary estimates of $50 million to $100 million annually to implement a comprehensive monitoring program.
Funding of Staff Training. The U.S. EPA's program review also found that existing regional board staff do not have the training or background to fully address a number of TMDL-related activities. These activities include modeling, data management, project management, and education/outreach. The review found that due to the lack of staff expertise, the regional boards sometimes developed TMDLs based on "overly simplistic approaches." The review also found that a lack of staff expertise resulted in major deficiencies in draft TMDLs that needed to be addressed to meet federal requirements.
Board Has Not Developed a Long-Term Work Plan. The SWRCB has not developed a comprehensive, long-term work plan for the TMDL program. Such a work plan is needed in order to evaluate how much work needs to be done each year to follow federal and state law and policy guidance, federal grant commitments, and court settlements. Without such a work plan, the program's total long-term funding needs, including for ambient water quality monitoring and staff training discussed above, are unknown.
State's Average Cost Per TMDL Far Exceeds Other States' Costs. Although a long-term work plan has not been developed, the board was able to provide a very rough estimate of its future annual costs over a 13-year period based on state and regional board cost experience to date. The board estimates these future annual costs at $32 million, of which $20 million is for staff and $12 million for contracts. (This does not include the costs of a comprehensive ambient water quality monitoring program to support the TMDL effort.) This represents almost a tripling of current-year expenditures. The board's estimate assumes 800 TMDLs could reasonably be completed over this time period, with an average completion time of three years. Therefore, the board's estimate assumes an average cost of about $500,000 to develop a TMDL.
Our review finds that the board's estimate of average costs to complete a TMDL far exceeds the cost experience in other states' TMDL programs. Specifically, SWRCB's average costs to develop a TMDL are more than ten times higher than the national average. Even when compared to states such as Virginia that also require TMDLs to include an implementation plan, SWRCB's average costs are still more than five times higher.
Board Should Prepare a Ten-Year TMDL Program Implementation Plan With Cost Estimates. As discussed above, without a long-term work plan for the TMDL program, the board is unable to provide a comprehensive estimate of the program's long-term funding requirements. Given the Legislature's concern about the state's lack of effectiveness and timeliness in meeting TMDL requirements, we think that the Legislature's oversight of the program would be improved if SWRCB developed a long-term plan for the program. Currently, the program is budgeted on a year-by-year basis, without knowing how far the expenditures will move the state to completing total TMDL workload over the long term.
The Virginia Legislature enacted legislation last year requiring the Virginia Department of Environmental Quality to submit a comprehensive ten-year plan for implementation of Virginia's TMDL program. The plan addresses the program's funding requirements, suggests ways to pay for the program, and provides a ten-year schedule for TMDL development. We recommend that the Legislature enact similar legislation, requiring SWRCB to develop a comprehensive long-term plan for implementing the state's TMDL program. We recommend that the plan cover the ten-year period from 2001-02 through 2010-11, to coincide with U.S. EPA guidance that all TMDLs from the 1998 list of impaired water bodies be complete by 2011.
Specifically, the plan should include:
With this type of work plan, SWRCB will be able to develop a schedule in regulation for initiating and completing work for each TMDL required to be developed from the 1998 list of impaired water bodies, as recommended previously.
The Clean Beaches Initiative lacks sufficient detail to justify approval. We recommend that funding for the initiative be deleted from the budget bill and, instead, be put in legislation. (Reduce Item 3940-001-0001 by $435,000 and 3940-101-0001 by $99,565,000.)
Budget Proposal. The budget proposes $100 million in one-time funding from the General Fund for the Governor's Clean Beaches Initiative. Of this amount, $435,000 is for state staff to administer $99.6 million of grants to local agencies. The budget proposes to allocate the grant funding as follows:
We have several concerns with the budget proposal as discussed below. Specifically, we find that more information is needed to justify the proposed funding level and source of funding and that details are lacking on the selection criteria for the grants. In addition, it is not clear how the proposed program will work in conjunction with other programs that have similar objectives or are involved in similar activities.
No Basis for Proposed Funding Level. We recognize that there are major water quality problems to be addressed at the state's beaches. However, our review shows that the budget proposal does not contain information that details the extent of water quality problems at the state's beaches and the funding requirements necessary to improve beach water quality. In the absence of such information, it is not possible to determine if the proposed funding level is too much or too little to address beach water quality problems in the state.
Unclear How Proposal Relates to Existing Programs. The budget proposal also does not provide information regarding (1) the extent to which existing environmental programs address beach water quality problems and (2) how the budget proposal works in conjunction with these other programs.
For example, the budget proposes $30 million (bond funds)—separate from the Clean Beaches Initiative—for local projects to improve coastal water quality in 2001-02. That proposal would leave a reserve of about $50 million of bond funds for other projects to be spent in future years. Specifically, Proposition 13—the Safe Drinking Water, Clean Water, Watershed Protection, and Flood Protection Act (2000)—provides $90 million for a Coastal Nonpoint Source Control program to administer grants and loans for sewage system improvements, water quality monitoring, stormwater runoff reduction, and other local projects that protect the water quality and environment of coastal and near-shore waters. Given that there are bond funds remaining from Proposition 13 yet to be expended, there is little justification for the proposed amount from the General Fund for the Clean Beaches Initiative.
In addition to the bond program, there are other existing SWRCB programs that aim to improve coastal water quality. Specifically, under the stormwater regulatory program, regional boards issue permits to control stormwater runoff, conduct related inspections, and take enforcement actions. It is not clear how the budget proposal will work in conjunction with this regulatory program. For example, it is uncertain whether the grants under the Clean Beaches Initiative could act as an incentive for compliance with stormwater permit requirements.
Similarly, it is not clear how the wetlands acquisition and restoration activities under the proposal would be coordinated with the programs of a number of Resources Agency departments—in particular the Wildlife Conservation Board—that are involved with similar activities.
Grant Selection Criteria Not Defined; Funding Priorities Not Clear. The board has yet to develop criteria to award grants under this proposal. Even within the administration, there is some confusion about funding eligibility. For example, at a briefing on the budget proposal, administration representatives stated that funding would be limited to projects located in San Diego, Orange, Los Angeles, and Ventura Counties. However, according to the board, it is still performing analyses to determine where funding would be targeted. Without such information, the Legislature is unable to determine if the funds will be targeted to those beaches in most need of remediation.
Besides funding eligibility, other issues to be resolved include the maximum amount for any given grant and whether there should be a matching requirement for the grants. It is not clear from the proposal whether the board would adopt the same criteria to award grants as the Proposition 13 bond program discussed above. Proposition 13 also provides detailed criteria for the distribution of funds to improve coastal water quality, including the type of projects eligible for funding, the anticipated benefits from funded projects, maximum grant amounts, a tiered matching requirement based on the grant amount, and a cap on administrative costs. Proposition 13 also specifies a project evaluation requirement which requires grant recipients to monitor their project's impact on water quality and to report on the project's effectiveness in preventing or reducing pollution.
Board Is Only Now Developing Plan to Provide Basis for Budget Proposal. According to the board, it is currently developing a plan—the Clean Beaches Plan—that will serve as a "roadmap" for improving beach water quality over the next ten years. However, the board expects that this plan will not be completed until July 2001. Once this plan is available, the Legislature would be in a better position to evaluate whether a grants program is warranted, and what should be the appropriate funding level for such a program.
Recommend Deletion of Funding From Budget Bill. We think that funding the Clean Beaches Initiative is premature until the proposal is better defined as discussed above. Accordingly, we recommend the deletion of the $100 million from the budget bill. We further recommend that funding for the initiative instead be put in legislation which defines the program, and provides selection criteria for the allocation of grant funds and project evaluation requirements similar to Proposition 13's Coastal Nonpoint Source Control program.