Report 2019-127 Recommendation 12 Responses

Report 2019-127: San Diego County Air Pollution Control District: It Has Used Vehicle Registration Fees to Subsidize Its Permitting Process, Reducing the Amount of Funds Available to Address Air Pollution (Release Date: July 2020)

Recommendation #12 To: San Diego County Air Pollution Control District

To ensure that it effectively manages its complaint investigation process and provides accurate information to the public regarding the complaints it receives, the San Diego Air District should, by June 2021, establish a process for validating the accuracy of the data it previously entered into its database.

Annual Follow-Up Agency Response From September 2023

The Compliance Manual of Policies and Procedures, Policy 2.3, was revised in August 2020 to incorporate all recommendations and to further document all roles and processes related to air quality complaints. Additionally, the system of record has been revised to update the historical complaint records by including the complaint response dates and complaint investigation outcome. This revision was based on the inspection reports, which at that time were MS Word documents posted on the system of record and did not have searchable fields. There are still 2 complaint records (APCD2023-CMP-0369 and APCD2022-CMP-0207) that do not have investigation dates as these complaints were submitted via the District's mobile app anonymously. Based on the information submitted for those anonymous complaints, the District determined they were outside its jurisdiction, but without contact information, the District was unable to provide a response. The District also updated its complaint inspection report to utilize an electronic form, making complaint data readily available and enabling reports to QA/QC the data. To further increase transparency and accountability, the District published a complaint dataset at https://www.sdapcd.org/content/sdapcd/compliance/Complaint-Info-Dataset.html. To view the dataset, please click https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fwww.sdapcd.org%2Fcontent%2Fdam%2Fsdapcd%2Fdocuments%2Fcompliance%2Fair-quality-complaint-list%2FComplaint-Report.xlsx&wdOrigin=BROWSELINK

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The Air District provided a policies and procedures manual that demonstrates it has created a process for reviewing new complaint data entered into its system; however, it still has not addressed the errors in the data it previously entered into its database. A review of the full dataset that it provided to us reveals multiple complaints with the same complaint number and numerous complaints with a response date prior to the date received--the same issues we described in our July 2020 report.

Annual Follow-Up Agency Response From October 2022

As previously reported, the Compliance Manual of Policies and Procedures, Policy 2.3, Complaint Investigation Procedures, was revised in August 2020 to incorporate all recommendations and to ensure all roles and processes are clear. Additionally, historical complaint records have been updated and corrected and the system of record report has been enhanced to provide additional tools to validate data accuracy related to the Air Quality Complaint Program.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The Air District did not provide evidence to substantiate that it updated and corrected the data previously entered into its database, nor did it provide a description of the process it used to validate the accuracy of the data it previously entered into its database. Further, the Air District's creation of a requirement to review newly entered complaint data for accuracy does not address the data entered before the requirement's creation.

Annual Follow-Up Agency Response From October 2021

A process is currently in place to validate the accuracy of data that is entered in the database. In addition, an updated version of the District Air Quality Complaint App is currently being integrated with the Complaint Business Process Reengineering (BPR) to include mapping functions, improved features, and reporting capabilities. These functionalities will further enhance the process for validating accuracy of data. The BPR is expected to be completed by November 2021.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Air District's response does not address the recommendation because it is not related to the accuracy of the data it previously entered into its database.

1-Year Agency Response

The Compliance Manual of Policies and Procedures, Policy 2.3, Complaint Investigation Procedures, (attached) was revised in August to incorporate all recommendations. Additionally, this BPR is critical to enhance the reporting tools and implement systematic controls to maintain the quality of our complaint program.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The Air District's response does not address the recommendation. Although the Air District added a requirement in its Compliance Manual to review newly entered complaint data for accuracy, the Compliance Manual does not address data entered prior to the requirement's creation.

6-Month Agency Response

The Compliance Manual of Policies and Procedures, Policy 2.3, Complaint Investigation Procedures, (attached) was revised in August to incorporate all recommendations. Additionally, the BPR will be critical to enhance the reporting tools and implement systematic controls to maintain the quality of our complaint program.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Although the Air District has added a requirement in its Compliance Manual to review newly entered complaint data for accuracy, the Air District's response does not address data entered prior to the requirement's creation.

60-Day Agency Response

The Compliance Manual of Policies and Procedures, Policy 2.3, Complaint Investigation Procedures, (attached) was revised in August to incorporate all recommendations. Additionally, the BPR will be critical to enhance the reporting tools and implement systematic controls to maintain the quality of our complaint program.

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

The San Diego Air District revised its Complaint Investigations Procedures manual to address the accuracy of data entered into the system; however, the District did not address how it intends to validate the accuracy of the system's existing data.

All Recommendations in 2019-127

Agency responses received are posted verbatim.