Examination of monthly and annual monitoring reports for four major facilities reveals that exceedances of permit conditions are occurring and that some of these exceedances present risks to receiving waters. Clearly, this Regional Board's enforcement program offers no deterrence to polluters. The Regional Board must act quickly once violations are discovered. When enforcement does occur, the Regional Board must improve existing penalty practices. Penalties must be sufficient to deter violations of the law.
Mandatory penalties are appropriate under certain circumstances.
The Regional Board must begin immediate implementation of its 1997 Priority Plan. The Regional Board must improve its filing and reporting system to ensure that the general public has a true appreciation for the types of violations and enforcement actions that have occurred. Regional Board staff must improve methods of informing the Board of potential enforcement opportunities in all areas. All penalty actions should be subject to public comment and Board approval. The state should support the California Storm Water Enforcement Act of 1988.