Report 2020-107 All Recommendation Responses

Report 2020-107: California Department of Toxic Substances Control: The State's Poor Management of the Exide Cleanup Project Has Left Californians at Continued Risk of Lead Poisoning (Release Date: October 2020)

Recommendation #1 To: Toxic Substances Control, Department of

To ensure that it minimizes the exposure of children and other at-risk individuals to lead contamination, DTSC should immediately solicit a contractor to clean the 31 remaining childcare centers, parks, and schools. It should use the TCRA process to expedite this cleanup if necessary.

1-Year Agency Response

The Audit Report identified 31 childcare facilities, parks, and schools as remaining to be cleaned. These included three parks, two schools, two publicly owned childcare centers, and 24 daycare facilities operating out of residential properties. In response to the audit findings, DTSC executed a contract with National Engineering and Consulting Group Inc. on 10/28/2020 to implement Time Critical Removal Actions at the three parks, two schools, and two publicly owned childcare centers.

DTSC has completed field work at these 31 properties as described below:

Parks (3): Field work was completed at the area in front of Bell City Hall and the area in front of Bell Library on 12/11/2020, and Benito Juarez Park on 1/19/2021.

Schools (2): Field work was completed at the St. Rose of Lima School on 1/21/2021, and at the

Cristo Viene Christian School on 3/29/2021.

Childcare centers (2): Field work was completed at the Maywood Child Development Center on 1/6/2021, and Garcia Park Head Start on 3/4/2021.

Daycare Facilities (24): Field work was completed at all 24 residential daycare facilities as of 5/10/2021.

Since the Audit report, we have implemented a procedure to request a list of all daycare facilities operating in the PIA from the California Department of Social Services Community Care Licensing Division on a semiannual basis. During the most recent request from this agency, DTSC identified 31 additional daycare facilities within the cleanup area. All the newly identified daycare facilities have been evaluated, and those that have a representative soil lead concentration above 80 ppm have been prioritized for cleanup. The status of the 31 additional daycare centers is below:

26 have completed clean up.

4 do not require cleanup.

1 requires cleanup and has been prioritized.

The status of the remaining daycare facilities prioritized for cleanup is updated weekly on DTSC's website (https://dtsc.ca.gov/exide-audit/).

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

DTSC executed a contract with National Engineering and Consulting Group Inc. (NEC) on October 28, 2020 to implement Time Critical Removal Actions (TCRA) at three parks, two schools, and two publicly owned childcare centers. In addition, DTSC directed NEC to prioritize the 24 residential daycare facilities for cleanup under their existing cleanup contract. DTSC has completed field work at these 31 properties as described below:

-Parks (3 identified in the audit): Field work was completed at the area in front of Bell City Hall and the area in front of Bell Library on December 11, 2020, and Benito Juarez Park on January 19, 2021.

-Schools (2 identified in the audit): Field work was completed at the St. Rose of Lima School on January 21, 2021, and at the Cristo Viene Christian School on March 29, 2021.

-Childcare centers (2 identified in the audit): Field work was completed at the Maywood Child Development Center on January 6, 2021, and Garcia Park Head Start on March 4, 2021.

-Daycare Facilities (24 identified in the audit): Field work was completed at 22 of the 24 residential daycare facilities, and the remaining two facilities are scheduled to be cleaned up by May 5, 2021.

Since the Audit report, we have implemented a procedure to request a list of all daycare facilities operating in the PIA from the California Department of Social Services Community Care Licensing Division on a semiannual basis. During the most recent request from this agency, DTSC identified 31 new additional daycare facilities within the cleanup area. The status of the 31 additional daycare centers is below:

-16 have completed clean up.

-3 do not require cleanup.

-12 require cleanup, and have been prioritized.

The status of the remaining daycare facilities prioritized for cleanup is updated weekly on DTSC's website (https://dtsc.ca.gov/exide-audit/).

California State Auditor's Assessment of 6-Month Status: Partially Implemented

We assess this recommendation as partially implemented, pending the completion of the cleanup activities.

60-Day Agency Response

Audit report identified 31 childcare centers, parks, and schools as remaining to be cleaned. These included three parks, two schools, two publicly owned childcare centers and 24 daycares operating out of residential properties. In response to the audit findings, DTSC executed a contract with National Engineering and Consulting Group Inc. on 10/28/2020, to implement Time Critical Removal Actions at the three parks, two schools, and two publicly owned childcare centers.

In addition, DTSC directed NEC to prioritize the 24 residential daycares for cleanup under their existing cleanup contract. To facilitate their cleanup, DTSC increased our outreach efforts by deploying our consultants to work concurrently with DTSC outreach staff. DTSC anticipates completing field work at these 31 properties by the end of March 2021, as described below:

-Parks (3 identified in the audit): Field work was completed on two parks, one in front of Bell City Hall and the other in front of Bell Library as of 12/11/2020. Field work began on 12/18/2020, at the Benito Juarez Park and is anticipated to be completed on 12/30/2020.

-Schools (2 identified in the audit): Field work began on December 9, 2020, at the St. Rose of Lima School and is anticipated to be completed on 12/30/2020. Outreach continues for the Cristo Viene Christian School although the operator has withdrawn their school operation license and the school is locked with no activities onsite. As of 12/18/2020, DTSC has not been able to acquire an access agreement for this property.

-Childcare centers (2 identified in the audit): Field work began at the Maywood Child Development Center on 12/19/2020 and is anticipated to be completed on 12/30/2020. Garcia Park Head Start has requested DTSC to start field activities in early January 2021.

-Daycares (24 identified in the audit): As of 12/18/2020, following is the status of the 24 residential daycares identified in the audit report:

Response continued in recommendation #2

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

To support its assessment that it had fully implemented this recommendation, DTSC posted its new contract to implement time critical removal actions for seven publicly owned properties on its website and provided an update on the status of the remaining publicly owned properties, showing that it has made progress in cleaning these properties.

We assess this recommendation as partially implemented, pending the completion of the cleanup activities.

Recommendation #2 To: Toxic Substances Control, Department of

To ensure its ability to clean as many lead-contaminated properties as possible in a timely manner, DTSC should immediately begin soliciting an additional contractor to clean properties within the cleanup site. It should include performance standards for the pace of cleanup in its existing and future cleanup contracts.

1-Year Agency Response

DTSC has deployed public participation specialists and contractors' staff to conduct additional outreach to secure additional access agreements and increase the number of properties needing cleanup to get to our initial goal of 3,200 properties. DTSC amended the existing cleanup contract in December 2020 to add 450 properties, and the work is nearing completion. Using our existing contractor allows DTSC to maximize efficiencies while effectively managing costs.

DTSC has also continued to steadily increase the number of cleanup crews. NEC has employed 25 cleanup crews every week in the field since September 14, 2020, even with COVID-19 Stay-at-Home orders, unprecedented wildfires, and increases in COVID-19 cases in Southern California. Two more crews were added in mid-March 2021, two crews were added in April 2021, and one more crew was added on June 1, 2021, bringing the total number of crews to 30 that have been since actively cleaning up and restoring residential properties.

On July 12, 2021, the Governor approved Senate Bill (SB) 158. SB 158 added $31.4 million as a General Fund loan to reach the goal of cleaning 3,200 properties. With this funding, DTSC executed a new cleanup contract with NEC in early July 2021 to clean up an additional 400 properties to reach the goal of cleaning 3,200 properties. A copy of the contract can be found on DTSC's Exide Contracts page here: https://dtsc.ca.gov/wp-content/uploads/sites/31/2021/09/21-T4934-Exhibits_Revised_06.29.21_Clean.pdf. The contract contains performance standards for the pace of cleanup and crews in the field in Exhibit A, Section13, Task 1 Performance Standards, starting on page 18. The Contractor must clean up an average of 18 properties per week and maintain a minimum of 20 crews in the field at all times, except under certain circumstances. Additional performance standards relating to the Letters of Completion are found in Exhibit A, Section 13, Task 4 Performance Standards, starting on page 21.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

DTSC remains committed and focused on the expeditious cleanup of as many lead-contaminated properties as possible with the already appropriated funds. DTSC has deployed our consultants to conduct additional outreach to increase the number of properties signed up for cleanup to get to our initial goal of 3,200 properties. DTSC has amended the existing cleanup contract to add 450 properties. Using our existing contractor allows DTSC to maximize efficiencies while effectively managing costs. The contract amendment includes performance standards requiring a minimum number of crews to be provided by the contractor.

DTSC has also continued to steadily increase the number of cleanup crews. NEC has employed 25 cleanup crews every week in the field since September 14, 2020, even with COVID-19 Stay-at-Home orders, unprecedented wildfires, and recent increases in COVID-19 cases in Southern California. Two more crews were added in mid-March 2021, bringing the total number of crews to 29.

The Governor's proposed 2021-22 Budget includes $31.4 million as a General Fund loan to reach the goal of cleaning 3,200 properties. If this funding is approved by the Legislature, DTSC anticipates finalizing a new cleanup contract in early July 2021. DTSC will add language regarding the pace of cleanups to that contract.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Although the department indicated it amended its contract to require its contractor to maintain a specific number of cleanup crews, the amended contracted did not include a pace of cleanup standard, which we recommended. Further, we cannot assess DTSC's statement about its anticipated new contract, which it does not anticipate finalizing until July 2021.

60-Day Agency Response

Rec. #1 Response Continued

14 daycares field work has been completed,

1 daycare field work is in progress and is anticipated to be completed by 1/2/2021

2 daycares are on the cleanup schedule and anticipated to be completed by end of January 2021

4 daycares with property owners' negotiating a cleanup start date in spring 2021, and

3 daycares with property owners who have declined cleanup due to various reasons.

Since the Audit report we have implemented a procedure to request a list of all daycares in the area undergoing cleanup activities from the California Department of Social Services Community Care Licensing Division on a semiannual basis. During the most recent request from these agencies, DTSC identified 31 additional daycares within the cleanup area. All the newly identified daycares have been evaluated and those that have a representative soil lead concentration above 80 ppm have been prioritized for cleanup. Please see status of the 31 additional daycares below:

-9 were already cleaned up

-2 do not require cleanup

-17 requiring cleanup have been prioritized

-3 have not provided DTSC access for initial sampling

The status for all daycares prioritized for cleanup is updated weekly on DTSC's website - https://dtsc.ca.gov/Exide-audit/

Recommendation #2 Response

DTSC remains committed and focused on the expeditious cleanup of as many lead-contaminated properties as possible with the already appropriated funds. In response to the audit finding, DTSC has deployed our consultants to conduct additional outreach to increase the number of properties signed up for cleanup to get to our initial goal of up to 3,200 properties. DTSC has amended the existing cleanup contract for 450 properties. Using our existing contractor allows DTSC to maximize efficiencies while effectively managing costs. Contract amendment in progress includes performance standards requiring a minimum number of crews to be provided by the contractor.

Response continued in rec. #3

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

To support its response, DTSC provided us a link to its website which showed that it amended its existing contract to clean an additional 450 properties which fulfills the portion of our recommendation to increase its cleanup capacity. However, although the department indicated it amended its contract to require its contractor to maintain a specific number of cleanup crews, the amended contracted did not include a pace of cleanup standard, which we recommended.

Recommendation #3 To: Toxic Substances Control, Department of

To ensure that the public and policy makers have the information they need to make informed decisions, DTSC should, by no later than April 2021, identify and publicize a date by which it expects to complete cleanup for all properties that meet or exceed the standard for lead contamination of 80 ppm identified in DTSC's cleanup plan. It should post this information on its website and, at least every six months, publish an update that indicates whether it is on track to meet that expected completion date based on its rate of progress.

Annual Follow-Up Agency Response From October 2023

On 7/12/2021, the Governor signed Senate Bill (SB) 158, a budget trailer bill that added $291 million to the residential cleanup project, to clean an additional 2740 residential properties by September 2025. With the addition of this new funding, DTSC has cleaned up 4979 properties as of 10/20/2023, and expects to complete cleanup of a total of 5940 properties by March 2025. DTSC has made the projected cleanup schedule publicly available via addition of a section to the Residential Cleanup website (https://dtsc.ca.gov/residential-cleanup/) that includes a timeline of cleanup activities with the newly approved funding to clean 5940 properties. On July 1, 2022, the CalEPA sent a letter to the U.S. EPA requesting to list the former Exide Technologies Inc. facility in Vernon, California and areas impacted by the former facility's operations under the Comprehensive Environmental Response, Compensation and Liability Act (Superfund) for cleanup. A copy of DTSC's letter to the U.S. EPA can be found on DTSC's website (https://dtsc.ca.gov/wp-content/uploads/sites/31/2022/07/CalEPA-letter-to-US-EPA-on-Listing-Exide-7.1.22.pdf). The U.S. EPA has begun the Site Assessment and Prelisting process for the Exide Facility and surrounding residential area. DTSC anticipates a response to the NPL request in October 2025. U.S. EPA's listing of the former Exide facility on the National Priority List (NPL) would provide additional critical resources needed to complete the cleanup of the remaining properties. If the Exide project is added to the NPL list, DTSC will provide an updated cleanup timeline. On 6/27/2023, Governor Newsom signed SB 101, a budget bill that added $67.3 million to the residential cleanup project, to clean up the residential parkways within Exide Preliminary Investigation area. Cleanup of the parkways is anticipated to begin late 2023. Overall, 6425 parkways exceed the residential cleanup goal for lead and/or other metals, and thus qualify for cleanup.

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

DTSC identified a date it expects to clean the 5,940 properties that it has the funding to clean. However, DTSC did not identify a date it expects to clean all properties that meet or exceed the standard for lead contamination of 80 ppm identified in its cleanup plan, which is what we recommended.

Annual Follow-Up Agency Response From November 2022

On July 12, 2021, the Governor signed Senate Bill (SB) 158, a budget trailer bill that added $291 million to the residential cleanup project, to clean an additional 2,740 residential properties by September 2025. With the addition of this new funding, DTSC has cleaned up 4,218 properties as of October 21, 2022, and expects to complete cleanup of a total of 5,940 properties by March 2025.

DTSC has made the projected cleanup schedule publicly available via addition of a section to the Residential Cleanup website (https://dtsc.ca.gov/residential-cleanup/) that includes a timeline of cleanup activities with the newly approved funding to clean 5,940 properties. This timeline is updated monthly and when new residential cleanup funding is made available.

On July 1, 2022, the California Environmental Protection Agency sent a letter to the United States Environmental Protection Agency (U.S. EPA) requesting to list the former Exide Technologies Inc. facility in Vernon, California and areas impacted by the former facility's operations under the Comprehensive Environmental Response, Compensation and Liability Act (Superfund) for cleanup. A copy of DTSC's letter to the U.S. EPA can be found on DTSC's website (https://dtsc.ca.gov/wp-content/uploads/sites/31/2022/07/CalEPA-letter-to-US-EPA-on-Listing-Exide-7.1.22.pdf).

U.S. EPA's listing of the former Exide facility on the National Priority List (NPL) will provide additional critical resources needed to complete the cleanup of the remaining properties. If the Exide project is added to the NPL list, DTSC will provide an updated cleanup timeline.

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

In its response, DTSC indicated that it expects to clean the 5,940 properties that it has the funding to clean by March 2025. However, DTSC did not identify a date by which it expects to clean all properties that meet or exceed the standard for lead contamination of 80 ppm identified in its cleanup plan, which is what we recommended.

1-Year Agency Response

SB-158 added $291 million to the residential cleanup project to clean an additional 2,740 residential properties by September 2025. With this new funding, DTSC expects it will be able to complete cleanup of a total of 5,940 properties by September 2025.

DTSC has made the projected cleanup schedule publicly available via addition of a section to the Residential Cleanup website (https://dtsc.ca.gov/residential-cleanup/) that includes a timeline of cleanup activities with the newly approved funding to clean 5,940 properties. This timeline will be updated monthly and/or when new residential cleanup funding is made available.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

DTSC identified a date it expects to clean the 5,940 properties that it has the funding to clean. However, DTSC did not identify a date it expects to clean all properties that meet or exceed the standard for lead contamination of 80 ppm identified in its cleanup plan, which is what we recommended.

6-Month Agency Response

New appropriations of state funding for additional cleanups would be part of future budgetary discussions. DTSC's Exide Public website (https://dtsc.ca.gov/residential-cleanup/) is updated weekly, and includes all information related to the status of cleanup and contracts. Additionally, DTSC notes that the state is not legally responsible for lead contamination cleanup for these properties.

California State Auditor's Assessment of 6-Month Status: Pending

In its response to recommendation #3, DTSC does not directly address our recommendation that it identify and publicize a date that it expects to complete the cleanup, nor whether it will post this information on its website and update its progress every six months as we recommend. Further, DTSC includes in its response a statement that the State is not legally responsible for lead contamination cleanup for these properties. If DTSC included this statement to suggest that it is not responsible for completing the cleanup of these lead contaminated properties, it should notify the Legislature.

60-Day Agency Response

Recommendation #2 Response Continued

DTSC has also continued to steadily increase the number of cleanup crews. NEC has employed 25 cleanup crews every week in the field since September 14, 2020, even with Stay-at-Home orders due to COVID-19, unprecedented wildfires, and the most recent increases in the COVID-19 cases in Southern California. We are working within the Administration to identify additional funds DTSC needs to get to our initial goal of up to 3,200 properties.

Recommendation #3 Response

New appropriations of state funding for additional cleanups would be part of future budgetary discussions.

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

DTSC provided a lengthy response to recommendation #2, which it continued onto this page.

In its response to recommendation #3, DTSC does not directly address our recommendation that it identify and publicize a date that it expects to complete the cleanup, nor whether it will post this information on its website and update its progress every six months as we recommend.

Recommendation #4 To: Toxic Substances Control, Department of

To ensure that it has sufficient funding to clean up all lead-contaminated properties in the cleanup site, DTSC should do the following:

-Identify the full amount of funding it needs to complete the cleanup of the 3,200 most contaminated properties and the remaining 4,600 contaminated properties. It should submit a request for funding in time for spring 2021 budget discussions that includes a range of funding options that spans from funding for the full cleanup to funding for only a portion of the remaining contaminated properties.

-Immediately revise its cost estimation methods to encompass the factors that it now knows will affect its overall costs. If needed, it should contract for expertise in determining accurate and complete estimates of the remaining cleanup cost.

Annual Follow-Up Agency Response From October 2023

In January 2021, DTSC submitted a budget change proposal (BCP) to provide the resources needed to reach the goal of cleaning 3,200 of the most contaminated properties. In May 2021, DTSC put forth a second BCP to cleanup an additional 2,740 properties with a representative lead concentration above 200 ppm. The Legislature approved both requests and appropriated the resources in SB 158, for a total of $322.4 million to achieve cleanup of these qualified properties. This funding will reduce the universe of remaining properties requiring cleanup from 4,600 to approximately 1,900.

As described in the response to recommendation 3, DTSC is currently working with the U.S. EPA to add the Exide project to the NPL list. If approved, this would provide additional critical resources needed to complete the cleanup of the approximately 1,900 remaining properties.

Additionally, on June 27, 2023, Governor Newsom signed SB 101, a budget bill that added $67.3 million to the residential cleanup project, to clean up the residential parkways within Exide Preliminary Investigation area. Cleanup of the parkways is anticipated to begin late 2023. Overall, 6,425 parkways exceed the residential cleanup goal for lead and/or other metals, and thus qualify for cleanup.

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

DTSC had previously revised its cost estimation methodology, but then only used it to estimate the cost of cleaning an additional 2,740 properties. This remains only partially implemented until DTSC uses its revised methods to calculate the cost of cleaning all contaminated properties.

Annual Follow-Up Agency Response From November 2022

In January 2021, DTSC submitted a budget change proposal (BCP) to provide the resources needed to reach the goal of cleaning 3,200 of the most contaminated properties. In May 2021, DTSC put forth a second BCP to cleanup an additional 2,740 properties with a representative lead concentration above 200 ppm. The Legislature approved both requests and appropriated the resources in SB 158, for a total of $322.4 million to achieve cleanup of these qualified properties. This funding will reduce the universe of remaining properties requiring cleanup from 4,600 to approximately 1,900.

As described in the response to recommendation 3, DTSC is currently working with the U.S. EPA to add the Exide project to the NPL list. If approved, this would provide additional critical resources needed to complete the cleanup of the approximately 1,900 remaining properties.

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

As DTSC indicates, it revised its cost estimation methodology but then only used it to estimate the cost of cleaning an additional 2,740 properties. This recommendation remains only partially implemented until DTSC uses its revised methods to calculate the cost of cleaning all contaminated properties.

1-Year Agency Response

In January 2021, DTSC submitted a budget change proposal (BCP) to provide the resources needed to reach the goal of cleaning 3,200 properties. In May 2021, DTSC put forth a second BCP to cleanup an additional 2,740 properties with a representative lead concentration above 200 ppm. In response, the Legislature approved both requests and appropriated the resources in SB 158, for a total of $322.4 million to achieve cleanup of these qualified properties.

DTSC has used a revised cost estimation procedure to estimate the cost of cleaning up the remaining qualified properties within the PIA. This was reflected in the 2021 May Revision BCP that requested $291 million General Fund to clean up 2,740 additional properties. This revised cost estimation incorporates the following factors:

Inflation

Increased Labor rates

Sample storage

Performance and Payment Bonds

Project Management and Quality Assurance

Financial Audit

DTSC's cost estimation spread sheet will be provided via email along with the additional supporting documentation.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

As DTSC indicates, it revised its cost estimation methodology but then only used it to estimate the cost of cleaning an additional 2,740 properties. This remains only partially implemented until DTSC uses its revised methods to calculate the cost of cleaning all contaminated properties.

6-Month Agency Response

The Governor's Budget includes a Budget Change Proposal (BCP) for $31.4 million to complete cleanup of the 3,200 properties. We also intend to use a portion of Lead-Acid Battery Recycling Facility Investigation and Cleanup (LABRIC) cleanup funds to continue residential cleanups in the preliminary investigation area (PIA).

DTSC has used a revised cost estimation procedure to estimate the cost of cleaning up the remaining properties within the PIA that may require cleanup. This revised cost estimation incorporates the following factors:

-Inflation (3.5% annual)

-Increased Labor rates

-Sample storage

-Performance and Payment Bonds

-Project Management and Quality Assurance

-Financial Audit

California State Auditor's Assessment of 6-Month Status: Pending

In its response, DTSC did not indicate that it identified the full amount of funding to complete the cleanup of the remaining lead contaminated properties. Further, although it described its revised cost estimation procedure, it did not provide any documentation to support that it used this revised procedure to estimate its remaining cleanup costs. Without a new cost estimate, DTSC does not have an accurate and complete estimate of the remaining cleanup cost.

60-Day Agency Response

4.A Response: Not Fully Implemented

New appropriations of state funding for additional cleanups would be part of future budgetary discussions.

4.B Response: Fully Implemented as of 12/18/2020.

DTSC has revised our cost estimation methods to include the following:

Inflation

Project Labor Agreement wage increase

Sample storage

Performance and Payment Bonds

Project Management and Quality Assurance

Financial Audit

DTSC will use this revised methodology for cleanup cost going forward.

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

DTSC provided us its updated cost estimation methodology. However, it did not provide us any evidence that it has used this updated methodology to prepare a new cost estimate. Without a new cost estimate, DTSC does not have an accurate and complete estimate of the remaining cleanup cost.

Recommendation #5 To: Toxic Substances Control, Department of

To protect against the unsustainably high costs it has incurred thus far in the cleanup project, DTSC should structure its future cleanup contracts to at least partially incorporate fixed prices.

60-Day Agency Response

DTSC has amended the existing cleanup contract, which already contains fixed price elements as recommended in the audit findings, for 450 properties. DTSC will seek to incorporate fixed pricing where possible in all future cleanup contracts. Following are the fixed price elements in the current cleanup contract:

-Project management costs per property,

-Mobilization, permit application and fees per property,

-Pre-excavation confirmation sampling costs per property,

-Property-specific Design Plan per property,

-Vehicle and equipment cost per property,

-Field management costs per property,

-Air and dust monitoring cost per property, and

-Letters of completion cost per property.

Performance standards requiring a minimum number of crews to be provided by the contractor were added to the amendment.

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

All Recommendations in 2020-107

Agency responses received are posted verbatim.