values
sequence | metadata
dict |
|---|---|
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] | {
"pdf_file": "7DHC66NNE4RHBN7MNVPKSCN6E2GFRS2Z.pdf",
"text": "August 4, 2010: Weekly Washington Update\nAugust 04, 2010\nThis past week, we received good news about jobs in our area, and I voted on important\nlegislation supporting our military and veterans.\n \nOn Thursday, the Air Force announced that Langley Air Force Base (LAFB) will receive six\nadditional F-22s resulting in over 100 additional jobs at the base. I have worked closely with the\nAir Force on this issue for over two years, and have spoken to Air Force Secretary Michael\nDonley on a number of occasions regarding Langley and its strong position for growth\nopportunities. It’s great news for Langley, and a strong boost in jobs for our area. \n \nTwo key pieces of legislation for our troops and veterans passed the House last week with my\nsupport. The Supplemental Appropriations Act of 2010 , to cover combat operations, U.S.\ndisaster assistance, Haiti relief and reconstruction, and benefits for Vietnam veterans, finally\npassed on Tuesday. In June, the House voted on an $81 billion version of the bill, which\ncontained $33 billion for the Department of Defense to conduct ongoing war operations, and\nalso billions in unrelated domestic spending. It’s unfortunate that for weeks, this particular bill\nsupporting our brave men and women in uniform was delayed because of political attempts to\nadd on unrelated domestic spending measures. Our troops deserve our unwavering support. It\nwas essential that the House pass this legislation to support our men and women and uniform,\nand I’m glad we were able to complete the bill to give our troops the funding they need to\naccomplish their critical missions to keep our nation safe.\n \nThe annual spending measure supporting military construction and veterans’ affairs also passed\nthe House with overwhelming support. Here at home, America’s First District has a rich heritage\nof military service and dedication to the defense of our nation, and one of the top priorities in my\nwork as your representative is to support our active military men and women, veterans, and\ntheir families. This measure goes well beyond simply funding war efforts by providing resources\nhere at home to support our heroes with the benefits they have earned and deserve. This bill\nprovides the support and structure to maintain adequate housing, and support veterans’\neducation, health care and other services. Overall, this legislation provides funding for military\nconstruction projects and improvements. It also provides for the planning and design of a variety\nof military facilities including operations, training, barracks, and medical care. Additionally, it\nfunds Department of Veterans Affairs programs, including compensation for veterans and\nsurvivors, pension payments for disabled veterans, widows and children, housing credits,\ntraining and tuition assistance, and veterans’ medical care and treatment. Another critical\nelement of funding in this bill provides for the GI Education Benefits program and for Arlington\nNational Cemetery.\n \n 1 / 2 August 4, 2010: Weekly Washington Update\nAugust 04, 2010\nAs August begins, I am excited at the opportunities this month will allow for me to speak with\nyou directly. I look forward to the many events, town halls, and meetings with many of you and I\nhope we have a chance to meet as we travel around America’s First District. For frequent\nupdates of my work, be sure to follow me on Twitter and Facebook . \n \nCongressman Rob Wittman represents the First District of Virginia. He serves on the Natural\nResources Committee and the Armed Services Committee where he is the Ranking Member of\nthe Oversight and Investigations Subcommittee.\n \n 2 / 2"
} |
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"pdf_file": "HSZJLPQSI6NJU2NBWZWZY2CHBUKDXG2M.pdf",
"text": "From: STEPHEN L WRIGHT [steveanddian@sbcglobal.net] \nSent: Saturday, March 06, 2010 9:07 AM \nTo: lthomason@wheatland.ca.gov \nSubject: Fw: Wheatland Heritage Oaks \nLisa, \nPlease attach this email too. Thanks. \nSteve \n \n--- On Fri, 3/5/10, swright@wheatland.ca.gov <swright@wheatland.ca.gov> wrote: \n \nFrom: swright@wheatland.ca.gov <swright@wheatland.ca.gov> \nSubject: Fw: Wheatland Heritage Oaks \nTo: steveanddian@sbcglobal.net \nDate: Friday, March 5, 2010, 4:52 PM \n \nSent via BlackBerry by AT&T \nFrom: \"Kevin\" <kevin@builtbypremier.com> \nDate: Fri, 5 Mar 2010 16:32:46 -0800 \nTo: 'Steve Wright'<swright@wheatland.ca.gov>; 'Tim \nRaney'<timraney@raneymanagement.com> \nCc: <hs@janascorp.com>; 'Jenny Taylor'<jtaylor@raneymanagement.com> \nSubject: FW: Wheatland Heritage Oaks \n \nSteve and Tim, \n \nPlease see email below from US Bank in regards to Herit age Oaks. Thank you. \n \nKevin Yttrup \nPremier Homes Properties Inc. \n(916) 789-9715 Ext.106 \n(916) 871-3028 Cell \n \nFrom: bruce.oneill@usbank.com [mailto:bruce.oneill@usban k.com] \nSent: Friday, March 05, 2010 3:40 PM \nTo: Kevin Yttrup \nSubject: Wheatland Heritage Oaks \n Page 1 of 2\n3/8/2010 file://\\\\server -1\\Public\\LJT\\Staff Reports\\2010\\CC -Agenda -03 -09 -10\\City Council Staff Re ... \nKevin, \n \nI received your voiceamil. This email confirms our support of your effort to postpone the hearing to \nterminate the development agreement. \n \nThanks, \nBruce \n \nBruce O'Neill, VP \nUS Bank \nSF-CA-SFMZ \n415-399-8069 \n415-882-7722, fax \n101 California St. , Ste130 \nSan Francisco , CA 94111 \nU.S. BANCORP made the following annotations \n--------------------------------------------------- ------------------ \nElectronic Privacy Notice. This e-mail, and any attachment s, contains information that is, or may be, \ncovered by electronic communications privacy laws, and is also co nfidential and proprietary in nature. If \nyou are not the intended recipient, please be advised th at you are legally prohibited from retaining, using, \ncopying, distributing, or otherwise disclosing this informa tion in any manner. Instead, please reply to the \nsender that you have received this communication in error, and then immediately delete it. Thank you in \nadvance for your cooperation. \n \n--------------------------------------------------- ------------------ Page 2 of 2\n3/8/2010 file://\\\\server -1\\Public\\LJT\\Staff Reports\\2010\\CC -Agenda -03 -09 -10\\City Council Staff Re ... "
} |
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"pdf_file": "CYINDTQC52PLSE235SEE2FHV4OVS5UHQ.pdf",
"text": "783 Federal Reserve System § 263.81 \nunder this subpart unless the Board or-\nders that subpart A of this part applies. \n(2) The informal hearing shall be re-\ncorded and a transcript shall be fur-nished to the institution-affiliated party upon request and after the pay-ment of the cost thereof. Witnesses need not be sworn, unless specifically requested by a party or the presiding officers. The presiding officers may ask questions of any witness. \n(3) The presiding officers may order \nthe record to be kept open for a reason-able period following the hearing (nor-mally five business days), during which time additional submissions to the record may be made. Thereafter, the record shall be closed. \n(d) Authority of presiding officers. In \nthe course of or in connection with any proceeding under this subpart, the Board or the presiding officers are au-thorized to administer oaths and affir-mations, to take or cause to be taken depositions, to issue, quash or modify subpoenas and subpoenas duces tecum, and, for the enforcement thereof, to apply to an appropriate United States district court. All action relating to depositions and subpoenas shall be in accordance with the rules provided in §§263.34 and 263.53. \n(e) Recommendation of presiding offi-\ncers. The presiding officers shall make \na recommendation to the Board con-cerning the notice or order of suspen-sion, removal, or prohibition within 20 calendar days following the close of the record on the hearing. \n§ 263.74 Decision of the Board. \n(a) Within 60 days following the close \nof the record on the hearing, or receipt of written submissions where a hearing has been waived, the Board shall notify the institution-affiliated party whether the notice of suspension or prohibition will be continued, terminated, or oth-erwise modified, or whether the order of removal or prohibition will be re-scinded or otherwise modified. The no-tification shall contain a statement of the basis for any adverse decision by the Board. In the case of a decision fa-vorable to the institution-affiliated party, the Board shall take prompt ac-tion to rescind or otherwise modify the order of suspension, removal or prohi-bition. (b) In deciding the question of sus-\npension, removal, or prohibition under this subpart, the Board shall not rule on the question of the guilt or inno-cence of the individual with respect to the crime with which the individual has been charged. \nSubpart E—Procedures for \nIssuance and Enforcement of Directives to Maintain Ade-quate Capital \n§ 263.80 Purpose and scope. \nThis subpart establishes procedures \nunder which the Board may issue a di-rective or take other action to require a state member bank or a bank holding company to achieve and maintain ade-quate capital. \n§ 263.81 Definitions. \n(a) Bank holding company means any \ncompany that controls a bank as de-fined in section 2 of the BHC Act, 12 U.S.C. 1841, and in the Board’s Regula-tion Y (12 CFR 225.2(b)) or any direct or indirect subsidiary thereof other than a bank subsidiary as defined in section 2(c) of the BHC Act, 12 U.S.C. 1841(c), and in the Board’s Regulation Y (12 CFR 225.2(a)). \n(b) Capital Adequacy Guidelines means \nthose guidelines for bank holding com-panies and state member banks con-tained in appendices A and D to the Board’s Regulation Y (12 CFR part 225), and in Appendix A to the Board’s Regu-lation H (12 CFR part 208), or any suc-ceeding capital guidelines promulgated by the Board. \n(c) Directive means a final order \nissued by the Board pursuant to ILSA (12 U.S.C. 3907(b)(2)) requiring a state member bank or bank holding company to increase capital to or maintain cap-ital at the minimum level set forth in the Board’s Capital Adequacy Guide-lines or as otherwise established under procedures described in §263.85 of this subpart. \n(d) State member bank means any \nstate-chartered bank that is a member of the Federal Reserve System. \nVerDate Aug<04>2004 12:33 Feb 22, 2005 Jkt 205037 PO 00000 Frm 00783 Fmt 8010 Sfmt 8010 Y:\\SGML\\205037T.XXX 205037T"
} |
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"pdf_file": "L3KZFZMAQFEW4RY6D5IJJXCRWUVUBLRJ.pdf",
"text": "Action Plan: After the Downgrade\nTo the Constituents of Florida Congressional District 22,\n \nAs we are all aware, Standard and Poor's (S&P) recently downgraded the credit rating of the\nUnited States. This marks the first time in our nation's history that our credit rating has been\ndowngraded.\n \nFor months, the rating agencies have warned that without significant changes to the fiscal\ndirection of our country, a downgrade of our debt was likely. Yesterday's downgrade affects the\n\"full faith and credit of the United States.\" It also affects America's stature as a beacon of\nfreedom and liberty for the world and it could damage our ability to provide for our future\ndefense and security.\n \nIn short, it materially hurts the futures of our children and grandchildren. Like you, I am deeply\ntroubled by the direction the country is headed—this is why I decided in 2009 to run for\nCongress.\n \nAs a Member of the Republican Freshman class, we were elected to change the culture of our\nnation's capital. Washington has spent too much, borrowed too much, and created an\natmosphere hostile to families and job creators.\n \nYour votes last November for this large, committed Freshman class provided a dramatic change\nin leadership for the House of Representatives. Under new leadership, the \"Peoples' House\"\nhas acted aggressively to change a broken political system in Washington. We have passed\nnumerous pieces of legislation to cut spending, create jobs, provide for more American energy,\nrepeal the President's Patient Affordable Care and Protection Act, and ease crushing regulatory\nburdens. The downgrading of our debt is a wakeup call that we need to continue to act quickly\nand more aggressively.\n \nThe House broke for the August recess on August 1st after passing the Budget Control Act.\nUnfortunately, S&P did not believe this legislation reduced our projected deficits enough and\nthey elected to downgrade our credit rating.\n 1 / 5 Action Plan: After the Downgrade\n \nIt is important to note, however, that the House had previously passed landmark pieces of\nlegislation, which would have prevented this downgrade – The Path to Prosperity Budget, and\nthe Cut, Cap and Balance Act. Both of these pieces of legislation provided realistic paths to stop\nrunaway Washington spending. Unfortunately, however, the Senate killed both pieces of\nlegislation.\n \nWorse yet, the Senate, under the leadership of Harry Reid, continued to squander precious\ntaxpayer dollars on broken Washington programs, evidenced by the FAA shutdown over the\npast week, which happened because Senator Reid and some of his colleagues wanted to\nmaintain wasteful spending for airline passengers at airports near their homes.\n \nUnder his leadership, the Senate has not passed a budget for over TWO years. Like you, I\ncontinue to say: Enough is Enough!\n \nWhat should we do now? At this point, the House of Representatives is not in a position to act\nunilaterally. We have already passed good legislation, which has died in the United States\nSenate.\n \nNonetheless, there are a few options we could act upon under the following circumstances: (1)\nif the House is to be called back into session, (2) if the Senate will agree to come back into\nsession and get serious about fixing our broken system, and (3) if the President will heed the\nwishes of the American people to fix our broken government.\n \nFor example, we must pursue the following actions:\n \n1. The House and Senate could amend the Budget Control Act passed on August 1 to increase\nthe cuts from $2.4 trillion to over $4 trillion\n \n2. The Senate could adopt the House (Ryan) Budget\n 2 / 5 Action Plan: After the Downgrade\n \n3. The Senate could adopt the House passed Cut, Cap and Balance Act\n \n4. Both Houses could act quickly to enact reforms to address the massive amounts of waste\nidentified in a recent GAO report, thus saving billions of taxpayer dollars\n \n5. The Senate could adopt all of the House passed energy bills putting Americans back to work\nproducing safe, clean, and efficient American energy from both conventional and alternative\nsources (and helping provide billions of dollars in additional federal revenues to help balance\nour budget)\n \n6. The Senate could pass all of the House passed legislation to reform our regulatory system\nand remove the crushing regulatory overreach of unelected and unaccountable Washington\nbureaucrats\n \n7. We could adopt the tax reforms included in the House (Ryan) Budget to simplify our tax code,\nremove loopholes, lower tax rates, improve competitiveness for American job creators, and\ndevelop a fairer, flatter tax system for all Americans\n \n8. We could adopt the House designed reforms to Medicare and Medicaid to fix these programs\nbefore they go insolvent and bankrupt America in the process, and/or\n \n9. We can immediately begin to sell excess federal property and raise billions of dollars in\nfederal revenues\n \nIn addition, we need to reform our broken budget process which relies on inaccurate economic\nforecasting models, \"baseline\" budgeting, and provisions that allow one or more houses of\nCongress to ignore their responsibility to create annual budgets. We should also implement\nzero-based budgets, just like American families and job creators use.\n \n 3 / 5 Action Plan: After the Downgrade\nI humbly request you contact Senate Majority Leader Harry Reid and President Obama and\ndemand they take action on the issues I have outlined.\n \nI am standing ready, willing, and committed to finishing the work Americans sent my Freshman\ncolleagues and me to the nation's capital to do. If this involves calling the United States\nCongress back into session now to do this, I am ready to go back to the Capitol, continue to roll\nup my sleeves, and take care of our problems.\n \nWhile I cannot speak for the Leadership of the House or for my other House colleagues, I\nbelieve they stand ready to do this as well -- if the Senate and the President are ready to do so.\n \nIf you are like me, in light of the downgrade to our debt, you believe some or all of these actions\nshould be taken immediately. You have had enough, I have had enough, and our fellow\nAmericans have had enough!\n \nEnough reckless Washington spending. Enough piling on debt. Enough empty promises.\n \nIt is time we stop the President's blank-check spending and take the necessary steps to force\nWashington to act responsibly and live within its means. If we fail to do so soon, to paraphrase\nRonald Reagan, we will sentence our children and grandchildren into a thousand years of\ndarkness.\n \nWe must make fundamental changes to our federal government so we can save the American\nDream for our children and grandchildren. If we succeed, we can restore America to the vision\nRonald Reagan believed in when he talked about \"a shining city on a hill.\"\n \nSteadfast and Loyal,\n \nCongressman Allen B. West\n 4 / 5 Action Plan: After the Downgrade\n \n 5 / 5"
} |
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"pdf_file": "23JCEIKVL65X2RGSARNY2VOUNXBTJ5AS.pdf",
"text": "Direct observations of N 2O5reactivity on ambient aerosol particles\nTimothy H. Bertram,1,2Joel A. Thornton,1Theran P. Riedel,3Ann M. Middlebrook,4\nRoya Bahreini,4,5Timothy S. Bates,6Patricia K. Quinn,6and Derek J. Coffman6\nReceived 28 July 2009; accepted 10 September 2009; published 8 October 2009.\n[1]N 2O5reactivity has been measured directly for the first\ntime on ambient aerosol particles using an entrained aerosol\nflow reactor coupled to a custom-built chemical ionization\nmass spectrometer at two urban locations during summer.\nThe observed N 2O5reactivity is a strong function of both\nrelative humidity (RH) and particle chemical composition.\nWe show that particulate organic mass loadings, together\nwith ambient relative humidity, play a leading role in\ndetermining the reaction rate of N 2O5with particles. Our\nobserved reactivity values are both more variable and, at\ntimes, as much as a factor of ten lower than currently\nimplemented large-scale model parameterizations would\npredict. Such discrepancies have likely consequences for\npredictions of NO xavailability and ozone production,\nand the sensitivity of these quantities to aerosol particle\nloadings. Citation: Bertram, T. H., J. A. Thornton, T. P. Riedel,\nA. M. Middlebrook, R. Bahreini, T. S. Bates, P. K. Quinn, and\nD. J. Coffman (2009), Direct observations of N 2O5reactivity on\nambient aerosol particles, Geophys. Res. Lett. ,36, L19803,\ndoi:10.1029/2009GL040248.\n1. Introduction\n[2] The production of tropospheric ozone (O 3), a criteria\nair pollutant and potent greenhouse gas, is a complex\nfunction of nitrogen oxides (NO x=N O+N O 2), volatile\norganic compounds (VOC), sunlight, and trace oxidants\nsuch as the hydroxyl radical (OH). O 3production is non-\nlinearly dependent on NO xabundance and thus accurate\ndescription of the processes that remove NO xradicals is\ncritical for predicting the down-wind influence of anthro-\npogenic emissions on tropospheric O 3. Global modeling\nstudies suggest that nocturnal processes involving the\nreactions of the nitrate radical (NO 3) and N 2O5account\nfor 50% of the globally averaged annual net NO xremoval\n[Dentener and Crutzen , 1993]. However, the impact of\nnocturnal NO xremoval processes on the tropospheric O 3\nbudget continues to be limited by uncertainty in the reaction\nrate of N 2O5with aerosol particles.\n[3] The influence of N 2O5on the removal of atmospheric\nNO xradicals is determined by the product of the probabilitythat N 2O5will react on a particle given a collision, g(N2O5),\nand the total gas-particle collision frequency primarily set\nby the available particle surface area concentration (S a).\nUntil recently, direct measurements of g(N2O5) have been\nrestricted to the laboratory, where simplified model particle\ntypes are probed to ascertain functional dependences. These\nstudies have shown that N 2O5removal by particles and the\nresulting products are strongly dependent on: i) liquid water\ncontent (H 2O(l)) [ Thornton et al. , 2003], ii) particle nitrate\n(NO 3/C0), which inhibits N 2O5hydrolysis [ Wahner et al. ,\n1998], iii) the presence of additional nucleophiles in water\nstressed particles [ Behnke et al. , 1997], iv) organic coatings\nthat have been theorized to either suppress N 2O5accom-\nmodation or decrease water av ailability at the surface\n[McNeill et al. , 2006; Folkers et al. , 2003], and v) particle\nacidity [ Mozurkewich and Calvert , 1988]. These effects\nlead to measured g(N2O5) that span three orders of magni-\ntude (1 /C210/C04<g< 0.1) depending on the chemical and\nphysical properties of the particles employed. Consistent\nwith this large potential variability, recent analyses of NO 3\nand N 2O5field measurements have inferred that g(N2O5)\ncan range from 1 /C210/C03to 0.017 and is likely dependent\non particle chemical composition [ Brown et al. , 2006].\n[4] In the context of atmospheric particle composition,\nthe importance of the above dependences, either individu-\nally or as a whole, remains entirely unclear. Combining our\ndirect measurements of g(N2O5) on ambient particles with\nco-located observations of particle chemical composition\nand particle S a, gas phase precursors, and meteorological\nparameters, allows such evaluations and the elucidation of\nfactors that most likely control g(N2O5) on ambient particles.\n2. Experimental Design\n[5] The pseudo-first order rate coefficient for N 2O5loss\nto aerosol particles (k het) was measured directly using an\nentrained aerosol flow reactor coupled to a chemical ioni-\nzation mass spectrometer (CIMS) [ Kercher et al. , 2009].\nThe experimental technique is described in detail elsewhere\n[Bertram et al. , 2009]. Observations of g(N2O5) were made\nat two urban sampling locations during the summer of 2008.\nBetween July 3rd and 21st, observations were made from a\n10 m tower adjacent to the NOAA Earth System Research\nLaboratory in Boulder, CO. Particle size distributions (65 nm\nto 1mm) were measured by an ultra-high sensitivity aerosol\nspectrometer and particle composition measured by an\nAerodyne compact time-of-flight aerosol mass spectrometer\n[DeCarlo et al. , 2006; Drewnick et al. , 2005]. Coincident\nmeasurements of gas-phase precursors (e.g., O 3and NO)\nand basic meteorological parameters were also made during\nthe sampling period. Between August 6th and 16th, obser-\nvations were made from a 5 m sampling mast extending\nabove an instrument sea container located at the NOAAGEOPHYSICAL RESEARCH LETTERS, VOL. 36, L19803, doi:10.1029/2009GL040248, 2009\nClickHere\nforFullArticle\n1Department of Atmospheric Sciences, University of Washington,\nSeattle, Washington, USA.\n2Now at Department of Chemistry, University of California, San Diego,\nLa Jolla, California, USA.\n3Department of Chemistry, University of Washington, Seattle,\nWashington, USA.\n4Earth System Research Laboratory, NOAA, Boulder, Colorado, USA.\n5CIRES, University of Colorado, Boulder, Colorado, USA.\n6Pacific Marine Environmental Laboratory, NOAA, Seattle, Washington,\nUSA.\nCopyright 2009 by the American Geophysical Union.\n0094-8276/09/2009GL040248$05.00\nL19803 1o f5 Pacific Marine Environmental Laboratory, 10 km NE of\ndowntown Seattle, WA. Particle size distributions (10 nm to\n10mm) were measured with two differential mobility\nparticle sizing instruments and aerodynamic particle sizer.\nSub-micron particle composition was measured by an\nAerodyne quadrupole aerosol mass spectrometer [ Jayne et\nal., 2000].\n[6] We interpret these results using a newly developed\nparameterization of g(N2O5)[Bertram and Thornton , 2009]\nthat is driven by observations of particle composition and\nRH, and calculations of H 2O(l) as determined by the aerosol\ninorganics model (AIM Model II) [ Carslaw et al. , 1995].\nThis approach permits us to directly assess the dependence\nof the observed g(N2O5) on the factors outlined in section 1.\n3. Observed Dependence of g(N2O5) on Particle\nChemical Composition\n[7] In Boulder, the ambient RH was low (30 ± 15%),\nparticle loadings were rather uniform (mean S a= 108 ± 35,total mass = 5.3 ± 1.5 mgm/C03), and particles contained high\norganic mass fractions (mean organic/sulfate mass ratio =\n6.1 ± 3.9). The median g(N2O5) observed in Boulder was\n0.003 (interquartile range of 0.9–1.2 /C210/C03). In contrast,\nin Seattle, the ambient RH was higher (74 ± 13%), particle\nloadings were enhanced and more variable (mean S a= 190 ±\n115, total mass = 7.2 ± 4.1 mgm/C03), but particles had similar\nbulk particle chemical composition as in Boulder (mean\norganic/sulfate = 7.1 ± 4.8). The median g(N2O5) observed\nin Seattle was 0.009 (interquartile range of 0.26–2.9 /C2\n10/C02), a factor of three larger than measured in Boulder.\n[8] These differences in the median g(N2O5) are grossly\nconsistent with the difference in RH between the two\nlocations leading to lower H 2O(l) in Boulder relative to\nSeattle. But, RH alone is not sufficient for describing either\nthe observed variability in, or the level of suppression of\ng(N2O5) relative to that expected on aqueous solution\nparticles. For example, the strongly decreasing trend of\ng(N2O5) with the increasing mass ratio of particulate\norganic matter (POM) to sulfate (SO 42/C0) observed in the\nSeattle data, and the lack of such a correlation in the\nBoulder data (Figure 1a), provide insights into the particle\ncharacteristics that exert control over g(N2O5). In what\nfollows, we investigate the dependence of g(N2O5)o n\nPOM, making the reasonable assumption that the aerosol\nparticles are largely internal mixtures [ Murphy et al. , 2006]\n(see auxiliary material).1\n[9] In the absence of POM, g(N2O5) should be controlled\nby the RH-dependent liquid water content and the molarity\nof nucleophiles such as NO 3/C0and chloride (Cl/C0)[Bertram\nand Thornton , 2009; Griffiths et al. , 2009; Wahner et al. ,\n1998; Behnke et al. , 1997]. In both locations studied, when\nPOM/SO 42/C0was lowest, the non-refractory particle compo-\nsition was mainly ammonium sulfate (AS) with trace NO 3/C0\nand Cl/C0(Figure S1), and our observations of g(N2O5) are in\ngood agreement with both laboratory measurements and the\nparameterization of Bertram and Thornton [2009]. Probing\nthe response of g(N2O5) to an increasing mass fraction of\nPOM, in both Boulder and Seattle, permits us to assess the\npotential affects of POM on g(N2O5). POM has been\nsuggested to influence g(N2O5)via: i) altering H 2O(l),\nwhich has been shown to influence g(N2O5) either through\na direct H 2O(l) limitation [ Thornton et al. , 2003] or by\nchanging particle [H 2O(l)]/[NO 3/C0][Mentel et al. , 1999], and/\nor ii) the formation of organic coatings on aqueous cores\nthat inhibit the accommodation or reaction of N 2O5[Badger\net al. , 2006; McNeill et al. , 2006; Folkers et al. , 2003].\n[10] The small g(N2O5) values and lack of correlation\nwith POM observed in Boulder indicates that the particles\nsampled were either solid (independent of POM mass\nfraction) or that increases in POM did not lead to the\nassociated increase in H 2O(l) required to enhance g(N2O5).\nInterestingly, our observed g(N2O5) values are consistent\nwith that predicted by the Bertram and Thornton [2009]\nparameterization regardless of the AS phase state. Labora-\ntory measurements of g(N2O5) are <0.005 on crystalline AS\n[Mozurkewich and Calvert , 1988], similar to the median of\n0.003 observed in Boulder. If AS crystallization was\ninhibited by the available POM [ Parsons et al. , 2004] and\nwe treat POM as hygroscopic (i.e. malonic acid like),\nFigure 1. (a) Observed dependence of g(N2O5) on the\nmass ratio of POM to SO 42/C0for measurements made in\nSeattle (black) and Boulder (gray). (b) Calculated depen-\ndence of the molar ratio of H 2O(l) to NO 3/C0on the mass ratio\nof POM to SO 42/C0for measurements made in Seattle,\nassuming that POM does (circles) and does not (squares)\ncontribute to H 2O(l) uptake. Data points are equal\npopulation binned medians, where the bar corresponds to\nthe interquartile range of the calculations. The shaded\nregion (in panel b) represents values of [H 2O(l)]/[NO 3/C0]\nwhere laboratory measurements predict suppression in\ng(N2O5) due to the NO 3/C0effect.\n1Auxiliary materials are available in the HTML. doi:10.1029/\n2009GL040248.L19803 BERTRAM ET AL.: DIRECT OBSERVATIONS OF N 2O5REACTIVITY L19803\n2o f5 calculations made using the Bertram and Thornton [2009]\nparameterization show that at the low RH sampled,\n[H2O(l)]/[NO 3/C0] is low enough to significantly suppress\ng(N2O5) to <0.005 across the entire range of POM/SO 42/C0\nobserved in Boulder. Co-located measurements of g(N2O5)\nand particle phase state [ Martin et al. , 2008] will clearly\nallow such distinctions to be made in the future.\n[11] The behavior of g(N2O5) observed in Seattle, at\nhigher RH, more clearly illu strates the importance of\nunderstanding POM in order to assess the factors control-\nlingg(N2O5). The dependence of g(N2O5) on POM/SO 42/C0\nwas observed during a stagnation episode in which most of\nthe POM mass growth was likely due to SOA formation as\nindicated by the fraction of POM that is measured to be\nhighly oxidized (see Figure S4). In light of the above\nexpectations, the decreasing g(N2O5) with increasing\nPOM/SO 42/C0can be hypothesized to be a result of: i) a\nrelative decrease in the particulate water mass fraction,\nfollowing increased partitioning of organics that are less\nhygroscopic than AS (i.e. DH2O(l)/DPOM /C240), leading to\nboth an increased nitrate effect [ Wahner et al. , 1998] and a\npossible H 2O(l) limitation [ Thornton et al. , 2003], and/or\nii) an increasing role of organic coatings that limit either\nN2O5surface accommodation or N 2O5accessibility to\nH2O(l).\n[12] To examine these suppositions, we first calculate\n[H2O(l)] and [H 2O(l)]/[NO 3/C0] using AIM for the two\nextremes of POM hygroscopicity: i) POM does not con-\ntribute to H 2O(l) uptake, and ii) POM is highly hygroscopic,\ncontributing significantly to H 2O(l) (POM treated as\nmalonic acid) (Figure 1b). In both cases [H 2O(l)] is suffi-\nciently high (>20M), so as not to suppress g(N2O5) directly.\nThe molar ratio of H 2O(l) to NO 3/C0remains nearly constant\nwhen POM is allowed to contribute to H 2O(l), but decreases\nwith increasing POM/SO 4/C02when POM is prohibited from\ncontributing to H 2O(l). To determine whether the calculated\nchanges in [H 2O(l)]/[NO 3/C0] are sufficient for describing the\nobserved changes in g(N2O5), we use the parameterization\nforg(N2O5) described by Bertram and Thornton [2009].[13] Figure 2 depicts the parameterization-observation\ncomparison for both cases as a function of the molar ratio\nof H 2O(l) to NO 3/C0. The strong parameterization-observation\nagreement, shown in panel A, lends support to the conclu-\nsion that POM sampled in Seattle did not contribute\nsignificantly to H 2O(l). Such a notion would be generally\nconsistent with the findings of Mochida et al. [2008] and\nQuinn et al. [2005], where ambient observations revealed\ndecreases in RH-dependent particle growth factors or scat-\ntering efficiency in the presence of large organic mass\nfractions. Based on our observations alone, we cannot rule\nout the possibility that organic coatings may act to offset the\neffects of hygroscopic organics (Figure 2b). Nonetheless, it\nis clear that the presence and chemical properties of POM\nplay a decisive role in setting g(N2O5) in the troposphere.\nFurther measurements of g(N2O5) downwind of source\nregions, where POM is likely more oxidized [ Zhang et\nal., 2007], and more hygroscopic [ Kondo et al. , 2007], and/\nor alongside co-located observations of particle hygroscopic\ngrowth will be strong tests of this hypothesis and the\napplicability of these first results to regional and global\nmodels.\n4. Implications for NO xProcessing Rates\n[14] Quantifying the absolute magnitude of g(N2O5) and\nultimately the loss rate of N 2O5to particles is necessary for\nreliable model representations of NO x, OH, O 3, and particle\nabundances and the couplings between them. The sensitiv-\nity of the NO xbudget to g(N2O5) is a strong function of the\nNO 3and N 2O5production rates, S a, temperature, and NO 3\nreactivity. To assess the importance of g(N2O5) we examine\nthe fraction of NO xpresent at sunset, [NO x]sunset, that is lost\nat night as a function of g(N2O5).\nFlost¼NO x½/C138Sunset/C0NO x½/C138Sunrise\nNO x½/C138SunsetE1\nFigure 2. Comparison of parameterized [ Bertram and Thornton , 2009] and observed g(N2O5) as a function of the molar\nratio of H 2O(l) to NO 3/C0assuming (a) that POM does not contribute to H 2O(l) uptake and (b) that POM contributes to H 2O(l)\nuptake. Data points are separated into equal population bins, where the bar and whiskers correspond to the median to mean\nrange and the interquartile range of the observations, respectively. The parameterized g(N2O5), derived from the observed\nparticle chemical composition and RH, is shown with black solid lines and the shaded region represents the propagated\nuncertainty in its determination. The dashed black line depicts g(N2O5) as parameterized for regions where direct\nmeasurements of g(N2O5) were not available.L19803 BERTRAM ET AL.: DIRECT OBSERVATIONS OF N 2O5REACTIVITY L19803\n3o f5 The dependence of F lostong(N2O5) and NO 3reactivity, as\ncalculated using a time-dependent chemical box model (see\nSI) for characteristic summer and winter conditions, is\nshown in Figure 3. We chose conditions (e.g., temperature\nand NO 3reactivity) in order to bracket the range of possible\nsensitivities to g(N2O5). In our summer calculations, F lostis\nprimarily limited by the NO 3production rate and nearly\nindependent of g(N2O5) due to assuming high loadings of\nbiogenic volatile organic compounds (BVOC), which\nincrease NO 3reactivity, and warmer temperatures, which\nshift the N 2O5-NO 3equilibrium in favor of NO 3. The result\nis that at high NO 3reactivity the nocturnal loss of NO xis\nindependent of g(N2O5). During winter, BVOC emissions\nare significantly smaller, and lower temperatures shift the\nN2O5-NO 3equilibrium in favor of N 2O5. As a result, F lostis\nfar more sensitive to g(N2O5) during winter than in summer.\nThese calculations illustrate the acute sensitivity of the NO x\nbudget to changes in g(N2O5) between 1 /C210/C04and 0.1\nand imply that the NO xlifetime is strongly dependent on\nNO 3reactivity at low g(N2O5).\n[15] In addition to accurate predictions of the total\nnocturnal NO xloss, models must also correctly attribute\nthat loss between the N 2O5and NO 3channels to achieve a\nrealistic sensitivity of the NO xbudget to changes in VOC,\ntemperature, and particle loadings. Our modeling shows this\nbranching is sensitive to g(N2O5) for the majority of likely\nconditions. The reaction products for the two channels have\ndifferent effects on oxidant concentrations and particle mass\nloadings: the products of NO 3homogeneous reactions canlead to the formation of secondary organic aerosol [ Ng et\nal., 2008] and the heterogeneous reaction of N 2O5can lead\nto halogen activation [ Finlayson-Pitts et al. , 1989] or\nincreased particulate nitrate mass [ Riemer et al. , 2003].\n[16] When compared to predictions of g(N2O5) made\nusing two currently implemented large-scale model param-\neterizations [ Davis et al. , 2008; Evans and Jacob , 2005],\nour directly observed reac tivity values are both more\nvariable and as much as a factor of ten lower, consistent\nwith reactivity values inferred from aircraft observations of\nNO 3and N 2O5[Brown et al. , 2009]. If our observations\ndescribed herein are representative of other urban/suburban\nlocations, then incorporating the observed g(N2O5) into\ncurrent models would likely lead to increases in predicted\nO3and OH, and an increased sensitivity of NO xloss to both\nNO 3reactivity and particle loadings.\n5. Conclusions\n[17] We present an analysis of the first direct measure-\nments of g(N2O5) on ambient aerosol particles. At the limit\nof low POM, our observations confirm RH as a primary\ncontrol and particulate nitrate as a secondary control in\nregulating g(N2O5). Observations at high RH illustrate a\nstrong dependence of g(N2O5) on particle POM/SO 42/C0. Our\nrecent parameterization [ Bertram and Thornton , 2009] can\nadequately capture the trend and variability in the observed\ng(N2O5) if we make the assumption that the increasing\nPOM mass fractions do not contribute significantly to\nadditional particulate water uptake at the same RH. In such\na case, the nitrate effect is sufficient to explain our results. If\nPOM does contribute to H 2O(l) uptake, then our results\nsuggest an additional means of suppressing g(N2O5) that is\ncorrelated with oxidized POM such as organic coatings.\nRegardless, these results clearly indicate that regional and\nglobal modeling efforts need to consider the effects of\nparticulate organic loadings and hygroscopicity in parame-\nterizing the rate of nocturnal NO xlossviaN2O5reactions\non particles.\n[18]Acknowledgments. This work was funded in large part by a\ngrant from the Office of Earth Science (NIP/03-0000-0025) at the National\nAeronautics and Space Administration. THB gratefully acknowledges the\nNOAA Climate and Global Change Fellowship Program for financial\nsupport. We thank Brian Lerner (NOAA ESRL) for meteorological data\nand Charles Brock (NOAA ESRL) for particle data during NORAA-\nBoulder, Steve Brown (NOAA ESRL) for helpful discussions and Drew\nHamilton (NOAA PMEL) for assistance in the set-up for the Seattle\nobservations.\nReferences\nBadger, C. L., et al. (2006), Reactive uptake of N 2O5by aerosol particles\ncontaining mixtures of humic acid and ammonium sulfate, J. Phys. Chem.\nA,110(21), 6986–6994, doi:10.1021/jp0562678.\nBehnke, W., C. George, V. Scheer, and C. Zetzsch (1997), Production and\ndecay of ClNO 2, from the reaction of gaseous N 2O5with NaCl solution:\nBulk and aerosol experiments, J. Geophys. Res. ,102(D3), 3795–3804,\ndoi:10.1029/96JD03057.\nBertram, T. H., and J. A. Thornton (2009), Toward a general parameteriza-\ntion of N 2O5reactivity on aqueous particles: the competing effects of\nparticle liquid water, nitrate and chloride, Atmos. Chem. Phys. Discuss. ,\n9, 15,181–15,214.\nBertram, T. H., et al. (2009), An experimental technique for the direct\nmeasurement of N 2O5reactivity on ambient particles, Atmos. Meas.\nTech. ,2, 231–242.\nBrown, S. S., et al. (2006), Variability in nocturnal nitrogen oxide proces-\nsing and its role in regional air quality, Science ,311(5757), 67 – 70,\ndoi:10.1126/science.1120120.\nFigure 3. (a) Fraction of available NO x([NO x]sunset) lost\nduring a 12-hr night as a function of g(N2O5) for low NO 3\nreactivity (T = 278 /C176K and NO 3reactivity = 0.01 min/C01,\ngray squares) and high NO 3reactivity (T = 298 /C176K and NO 3\nreactivity = 0.1 min/C01, black circles) conditions. Values were\ncalculated using a time-dependent chemical box model, with\nthe following initial conditions: [O 3] = 50 ppbv, [NO 2]=\n5 ppbv, and S a= 200 mm2cm/C03. (b) Fraction of total nocturnal\nNO xlossviaN2O5for summer and winter conditions.L19803 BERTRAM ET AL.: DIRECT OBSERVATIONS OF N 2O5REACTIVITY L19803\n4o f5 Brown, S. S., et al. (2009), Reactive uptake coefficients for N 2O5deter-\nmined from aircraft measurements during the Second Texas Air Quality\nStudy: Comparison to current model parameterizations, J. Geophys. Res. ,\n114, D00F10, doi:10.1029/2008JD011679.\nCarslaw, K. S., et al. (1995), A thermodynamic model of the system HCl-\nHNO 3-H2SO4-H2O, including solubilities of HBr, from less than 200 to\n328 K, J. Phys. Chem. ,99(29), 11,557–11,574, doi:10.1021/\nj100029a039.\nDavis, J. M., et al. (2008), Parameterization of N 2O5reaction probabilities\non the surface of particles containing ammonium, sulfate, and nitrate,\nAtmos. Chem. Phys. ,8, 5295–5311.\nDeCarlo, P. F., et al. (2006), Field-deployable, high-resolution, time-of-\nflight aerosol mass spectrometer, Anal. Chem. ,78(24), 8281–8289,\ndoi:10.1021/ac061249n.\nDentener, F. J., and P. J. Crutzen (1993), Reaction of N 2O5on tropospheric\naerosols: Impact on the global distributions of NO x,O 3, and OH,\nJ. Geophys. Res. ,98(D4), 7149–7163, doi:10.1029/92JD02979.\nDrewnick, F., et al. (2005), A new time-of-flight aerosol mass spectrometer\n(TOF-AMS)—Instrument description and first field deployment, Aerosp.\nSci. Technol. ,39(7), 637–658, doi:10.1080/02786820500182040.\nEvans, M. J., and D. J. Jacob (2005), Impact of new laboratory studies of\nN2O5hydrolysis on global model budgets of tropospheric nitrogen\noxides, ozone, and OH, Geophys. Res. Lett. ,32, L09813, doi:10.1029/\n2005GL022469.\nFinlayson-Pitts, B. J., et al. (1989), Formation of chemically active chlorine\ncompounds by reactions of atmospheric NaCl particles with gaseous\nN2O5and ClONO 2,Nature ,337(6204), 241–244, doi:10.1038/\n337241a0.\nFolkers, M., T. F. Mentel, and A. Wahner (2003), Influence of an organic\ncoating on the reactivity of aqueous aerosols probed by the heterogeneous\nhydrolysis of N 2O5,Geophys. Res. Lett. ,30(12), 1644, doi:10.1029/\n2003GL017168.\nGriffiths, P. T., et al. (2009), Reactive uptake of N 2O5by aerosols contain-\ning dicarboxylic acids. Effect of particle phase, composition, and nitrate\ncontent, J. Phys. Chem. A ,113(17), 5082–5090, doi:10.1021/jp8096814.\nJayne, J. T., et al. (2000), Development of an aerosol mass spectrometer for\nsize and composition analysis of submicron particles, Aerosp. Sci. Tech-\nnol.,33(1–2), 49–70.\nKercher, J. P., et al. (2009), Chlorine activation by N 2O5: In situ detection\nof ClNO 2and N 2O5by chemical ionization mass spectrometry, Atmos.\nMeas. Tech. ,2, 193–204.\nKondo, Y., Y. Miyazaki, N. Takegawa, T. Miyakawa, R. J. Weber, J. L.\nJimenez, Q. Zhang, and D. R. Worsnop (2007), Oxygenated and water-\nsoluble organic aerosols in Tokyo, J. Geophys. Res. ,112, D01203,\ndoi:10.1029/2006JD007056.\nMartin, S. T., T. Rosenoern, Q. Chen, and D. R. Collins (2008), Phase\nchanges of ambient particles in the Southern Great Plains of Oklahoma,\nGeophys. Res. Lett. ,35, L22801, doi:10.1029/2008GL035650.\nMcNeill, V. F., et al. (2006), The effect of varying levels of surfactant on the\nreactive uptake of N 2O5to aqueous aerosol, Atmos. Chem. Phys. ,6,\n1635–1644.Mentel, T. F., et al. (1999), Nitrate effect in the heterogeneous hydrolysis of\ndinitrogen pentoxide on aqueous aerosols, Phys. Chem. Chem. Phys. ,\n1(24), 5451–5457.\nMochida, M., T. Miyakawa, N. Takegawa, Y. Morino, K. Kawamura, and\nY. Kondo (2008), Significant alteration in the hygroscopic properties of\nurban aerosol particles by the secondary formation of organics, Geophys.\nRes. Lett. ,35, L02804, doi:10.1029/2007GL031310.\nMozurkewich, M., and J. G. Calvert (1988), Reaction probability of N 2O5\non aqueous aerosols, J. Geophys. Res. ,93(D12), 15,889–15,896,\ndoi:10.1029/JD093iD12p15889.\nMurphy, D. M., D. J. Cziczo, K. D. Froyd, P. K. Hudson, B. M. Matthew,\nA. M. Middlebrook, R. E. Peltier, A. Sullivan, D. S. Thomson, and R. J.\nWeber (2006), Single-particle mass spectrometry of tropospheric aerosol\nparticles, J. Geophys. Res. ,111, D23S32, doi:10.1029/2006JD007340.\nNg, N. L., et al. (2008), Secondary organic aerosol (SOA) formation from\nreaction of isoprene with nitrate radicals (NO 3),Atmos. Chem. Phys. ,8,\n4117–4140.\nParsons, M. T., J. Mak, S. R. Lipetz, and A. K. Bertram (2004), Deliques-\ncence of malonic, succinic, glutaric, and adipic acid particles, J. Geophys.\nRes.,109, D06212, doi:10.1029/2003JD004075.\nQuinn, P. K., et al. (2005), Impact of particulate organic matter on the\nrelative humidity dependence of light scattering: A simplified parameter-\nization, Geophys. Res. Lett. ,32, L22809, doi:10.1029/2005GL024322.\nRiemer, N., H. Vogel, B. Vogel, B. Schell, I. Ackermann, C. Kessler, and\nH. Hass (2003), Impact of the heterogeneous hydrolysis of N 2O5on\nchemistry and nitrate aerosol formation in the lower troposphere under\nphotosmog conditions, J. Geophys. Res. ,108(D4), 4144, doi:10.1029/\n2002JD002436.\nThornton, J. A., et al. (2003), N 2O5hydrolysis on sub-micron organic\naerosols: the effect of relative humidity, particle phase, and particle size,\nPhys. Chem. Chem. Phys. ,5(20), 4593–4603.\nWahner, A., et al. (1998), Heterogeneous reaction of N 2O5on sodium nitrate\naerosol, J. Geophys. Res. ,103(D23), 31,103–31,112, doi:10.1029/\n1998JD100022.\nZhang, Q., et al. (2007), Ubiquity and dominance of oxygenated species in\norganic aerosols in anthropogenically-influenced Northern Hemisphere\nmidlatitudes, Geophys. Res. Lett. ,34, L13801, doi:10.1029/\n2007GL029979.\n/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0/C0\nR. Bahreini and A. M. Middlebrook, Earth System Research Laboratory,\nNOAA, Boulder, CO 80305, USA.\nT. S. Bates, D. J. Coffman, and P. K. Quinn, Pacific Marine\nEnvironmental Laboratory, NOAA, Seattle, WA 98115, USA.\nT. H. Bertram, Department of Chemistry, University of California, San\nDiego, La Jolla, CA 92093, USA.\nT. P. Riedel, Department of Chemistry, University of Washington, Seattle,\nWA 98195, USA.\nJ. A. Thornton, Department of Atmospheric Sciences, University of\nWashington, Seattle, WA 98195, USA. (thornton@atmos.washington.edu)L19803 BERTRAM ET AL.: DIRECT OBSERVATIONS OF N 2O5REACTIVITY L19803\n5o f5"
} |
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"pdf_file": "BO22JMPQ7C2FRODUK35FIODAQMDOCY6B.pdf",
"text": "U.S. Department of Homeland Security \nU.S. Citizenship and Immigration Services \nOffice ofAdministrative Appeals MS 2090 \nidentitjring data deleted to \nprevent cleari): 1.rnwarranted \ninvasion of personal pnvacj \nPUBLlC COPY \nU. S. Citizenship \nand Immigration \n1 \nFILE: Office: HOUSTON Date: \nMSC-05-208-11780 JAN 1 4 2010 \nIN RE: Applicant: \nAPPLICATION: \n Application for Status as a Temporary Resident pursuant to Section 245A of the \nImmigration and Nationality Act, as amended, 8 U.S.C. 5 1255a \nON BEHALF OF APPLICANT: \nINSTRUCTIONS: \nThis is the decision of the Administrative Appeals Office in your case. If your appeal was dismissed or \nrejected, all documents have been returned to the National Benefits Center. You no longer have a case \npending before this office, and you are not entitled to file a motion to reopen or reconsider your case. If your \nappeal was sustained or remanded for further action, you will be contacted. \nPerry Rhew \nChief, Administrative Appeals Office Page 2 \nDISCUSSION: The application for temporary resident status pursuant to the terms of the settlement \nagreements reached in Catholic Social Services, Inc., et al., v. Ridge, et al., CIV. NO. S-86-1343- \nLKK (E.D. Cal) January 23, 2004, and Felicity Mary Newman, et al., v. United States Immigration \nand Citizenship Services, et al., CIV. NO. 87-4757-WDK (C.D. Cal) February 17, 2004 \n(CSS/Newman Settlement Agreements), was denied by the Director, Houston. The decision is now \nbefore the Administrative Appeals Office (AAO) on appeal. The appeal will be dismissed. \nThe applicant submitted a Form 1-687, ,4pplication for Status as a Temporary Resident under Section \n245A of the Immigration and Nationality Act (Act), and a Form 1-687 Supplement, CSS/Newman Class \nMembership Worksheet. The director denied the application, finding that the applicant had not \nestablished by a preponderance of the evidence that he had continuously resided in the United States \nin an unlawful status for the duration of the requisite period. \nOn appeal, the applicant, through counsel, asserts that he has established his unlawful residence for \nthe requisite time period. \nAn applicant for temporary resident status must establish entry into the United States before January 1, \n1982, and continuous residence in the United States in an unlawfkl status since such date and through \nthe date the application is filed. Section 245A(a)(2) of the Act, 8 U.S.C. 5 1255a(a)(2). The applicant \nmust also establish that he or she has been continuously physically present in the United States since \nNovember 6, 1986. Section 245A(a)(3) of the Act, 8 U.S.C. 5 1255a(a)(3). The regulations clarify \nthat the applicant must have been physically present in the United States from November 6, 1986 \nuntil the date of filing the application. 8 C.F.R. 9 245a.2(b). \nFor purposes of establishing residence and physical presence under the CSS/Newman Settlement \nAgreements, the term \"until the date of filing\" in 8 C.F.R. 5 245a.2(b) means until the date the \napplicant attempted to file a completed Form 1-687 application and fee or was caused not to timely \nfile during the original legalization application period of May 5, 1987 to May 4, 1988. CSS \nSettlement Agreement paragraph 11 at page 6; Newman Settlement Agreement paragraph 11 at page \n10. \nThe applicant has the burden of proving by a preponderance of the evidence that he or she has resided in \nthe United States for the requisite periods, is admissible to the United States under the provisions of \nsection 245A of the Act, and is otherwise eligible for adjustment of status. The inference to be drawn \nfrom the documentation provided shall depend on the extent of the documentation, its credibility and \namenability to verification. 8 C.F.R. 5 245a.2(d)(5). \nAlthough the regulation at 8 C.F.R. 5 245a.2(d)(3) provides an illustrative list of contemporaneous \ndocuments that an applicant may submit in support of his or her claim of continuous residence in the \nUnited States in an unlawful status since prior to January 1, 1982, the submission of any other \nrelevant document is permitted pursuant to 8 C.F.R. $245a.2(d)(3)(vi)(L). To meet his or her \nburden of proof, an applicant must provide evidence of eligibility apart from the applicant's own \ntestimony, and the sufficiency of all evidence produced by the applicant will be judged according to \nits probative value and credibility. 8 C.F.R. 5 245a.2(d)(6). The \"preponderance of the evidence\" standard requires that the evidence demonstrate that the \napplicant's claim is \"probably true,\" where the determination of \"truth\" is made based on the factual \ncircumstances of each individual case. Matter of E-M-, 20 I&N Dec. 77, 79-80 (Comm. 1989). In \nevaluating the evidence, Matter of E--44- also stated that \"[tlruth is to be determined not by the \nquantity of evidence alone but by its quality.\" Id. Thus, in adjudicating the application pursuant to \nthe preponderance of the evidence standard, the director must examine each piece of evidence for \nrelevance, probative value, and credibility, both individually and within the context of the totality of \nthe evidence, to determine whether the fact to be proven is probably true. See 8 C.F.R. 5 \n245a.2(d)(6). The weight to be given any affidavit depends on the totality of the circumstances, and \na number of factors must be considered. More weight will be given to an affidavit in which the \naffiant indicates personal knowledge of the applicant's whereabouts during the time period in \nquestion rather than a fill-in-the-blank affidavit that provides generic information. The regulations \nprovide specific guidance on the sufficiency of documentation when proving residence through \nevidence of past employment or attestations by churches or other organizations. 8 C.F.R. $5 \n245a.2(d)(3)(i) and (v). \nEven if the director has some doubt as to the truth, if the applicant submits relevant, probative, and \ncredible evidence that leads the director to believe that the claim is \"probably true\" or \"more likely \nthan not,\" the applicant or petitioner has satisfied the standard of proof. See US. v. Cardozo- \nFonseca, 480 U.S. 421 (1987) (defining \"more likely than not\" as a greater than 50 percent \nprobability of something occurring). If the director can articulate a material doubt, it is appropriate \nfor the director to either request additional evidence or, if that doubt leads the director to believe that \nthe claim is probably not true, deny the application or petition. \nThe issue in this proceeding is whether the applicant (1) entered the United States before January 1, \n1982 and (2) has continuously resided in the United States in an unlawfbl status for the requisite period \nof time. The documentation that the applicant submits in support of his claim to have arrived in the \nUnited States before January 1982 and lived in continuous unlawful status during the requisite \nperiod consists of affidavits. Some of the evidence submitted indicates that the applicant resided in \nthe United States after May 4, 1988; however, because evidence of residence after May 4, 1988 is \nnot probative of residence during the requisite time period, it shall not be discussed. \nstatements that the affiants have known the applicant for years and that attest to the applicant being \nphysically present in the United States during all or part of the required period. These affiants fail, \nhowever, to establish the applicant's continuous unlawful residence in the United States for the \nduration of the requisite period. As stated previously, the evidence must be evaluated not by the \nquantity of evidence alone but by its quality; an applicant must provide evidence of eligibility apart \nfrom his or her own testimony; and the sufficiency of all evidence produced by the applicant will be \njudged according to its probative value and credibility. \nNone of the witness statements provide concrete information, specific to the applicant and generated \nby the asserted associations with him, which would reflect and corroborate the extent of those \nassociations and demonstrate that they were a sufficient basis for reliable knowledge about the applicant's residence during the time addressed in the affidavits. To be considered probative and \ncredible, witness affidavits must do more than simply state that an affiant knows an applicant and \nthat the applicant has lived in the United States for a specific time period. Their content must \ninclude sufficient detail from a claimed relationship to indicate that the relationship probably did \nexist and that the witness does, by virtue of that relationship, have knowledge of the facts alleged. \nUpon review, the AAO finds that, individually and together, the witness statements do not indicate \nthat their assertions are probably true. Therefore, they have little probative value. \nThe remaining evidence in the record is comprised of the applicant's statements and application \nforms, in which he claims to have entered the United States in 1979. The AAO notes that the record \nof proceeding contains inconsistent information regarding when the applicant first arrived in the \nUnited States. In her February 27, 2008 notice of intent to deny (NOID), the director stated that \nduring his June 1, 2006 interview, the applicant stated that he first entered the United States in April \n1982, and in 1984 he was sent to Mexico by an immigration officer, and re-entered the United States \nin 1986. It is incumbent upon the applicant to resolve any inconsistencies in the record by \nindependent objective evidence. Any attempt to explain or reconcile such inconsistencies will not \nsuffice unless the petitioner submits competent objective evidence pointing to where the truth lies. \nDoubt cast on any aspect of the applicant's proof may lead to a reevaluation of the reliability and \nsufficiency of the remaining evidence offered in support of the application. See Matter of Ho, 19 \nI&N Dec. 582, 591-92 (BIA 1988). The applicant has not submitted any additional evidence in \nsupport of his claim that he was physically present or had continuous residence in the United States \nduring the entire requisite period or that he entered the United States in 1979. \nOn appeal, counsel asserts that the director did not consider the applicant's response to the director's \nNOID. The applicant's response to the director's NOID consists of assertion by the applicant, \nthrough counseli that he entered the United States prior to January 1, 1982 and an affidavit from his \nbrother stating that the applicant lived with him in Texas from 1979 to 1986. The \napplicant's response to the director's NOID does address the director's concerns regarding his \ninconsistent statements during the interview. As stated previously, doubt cast on any aspect of the \napplicant's proof may lead to a reevaluation of the reliability and sufficiency of the remaining \nevidence offered in support of the application. See Matter of Ho, supra. Upon a de novo review of \nall of the evidence in the record, the AAO agrees with the director that the evidence submitted by the \napplicant has not established that he is eligible for the benefit sought. \nTherefore, based upon the foregoing, the applicant has failed to establish by a preponderance of the \nevidence that he entered the United States before January 1, 1982 and continuously resided in an \nunlawful status in the United States for the requisite period as required under both 8 C.F.R. \n5 245a.2(d)(5) and Matter of E- M--, supra. The applicant is, therefore, ineligible for temporary \nresident status under section 245A of the Act on this basis. \nORDER: \n The appeal is dismissed. This decision constitutes a final notice of ineligibility. "
} |
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] | {
"pdf_file": "GGYFXPMKQD267PXVZ3L2TK46IIHHSV7V.pdf",
"text": "Table 90. Selected personal and property crimes, 2008:\nPercent distribution of victimizations resulting in loss of time\nfrom work, by race of victims, type of crime, and number of days lost\nNot known\nNumber of Less than 1-5 6-10 11 days or not\nRace and type of crime victimizations Total 1 day days days or more available\nWhite only\nAll personal crimesa268,580 100 % 19.9 53.5 15.1 9.2 * 2.3 *\nCrimes of violence 262,200 100 % 17.9 54.8 15.5 9.4 * 2.3 *\nAll property crimes 897,150 100 % 35.4 48.4 9.6 4.6 2.0 *\nHousehold burglary 220,200 100 % 36.1 42.8 9.4 * 11.7 * 0.0 *\nMotor vehicle theft 90,510 100 % 31.3 * 57.3 5.5 * 2.3 * 3.5 *\nTheft 586,450 100 % 35.8 49.1 10.4 2.3 * 2.5 *\nBlack only\nAll personal crimesa62,870 100 % 6.7 * 59.8 * 8.6 * 16.2 * 8.7 *\nCrimes of violence 62,870 100 % 6.7 * 59.8 * 8.6 * 16.2 * 8.7 *\n \n All property crimes 171,320 100 % 17.9 * 59.5 9.9 * 8.3 * 4.3 *\n Household burglary 54,840 100 % 5.1 * 62.5 * 19.5 * 12.9 * 0.0 *\n Motor vehicle theft 28,750 * 100 %* 9.2 * 80.8 * 0.0 * 0.0 * 9.9 *\n Theft 87,740 100 % 28.8 * 50.6 7.2 * 8.2 * 5.1 *\nNote: Detail may not add to total shown because of rounding.\nExcludes data on persons with races other than white only or black only.*Estimate is based on 10 or fewer sample cases.\naIncludes data on rape, sexual assault, robbery, assault, and purse snatching/pocket picking, not shown separately.\nCriminal Victimization in the United States, 2008 — Statistical Tables May 2011Criminal Victimization in the United States, 2008 — Statistical Tables May 2011"
} |
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] | {
"pdf_file": "GXN6NIJAPDVKETP2WCAL523Z6OESGKDD.pdf",
"text": " \n2007 CENSUS OF AGRICULTURE - COUNTY DATA SOUTH CAROLINA 351 \nUSDA, National Agricultural Statistics Service Table 17. All Goats - Inventory and Number Sold: 2007 and 2002 \n[For meaning of abbreviations and symbols, see introductory text] \nInventory Sold Geographic area \nFarms Number Farms Number \nSTATE TOTAL \n \nSouth Carolina .............................................2007 \n 2002 \n \nCOUNTIES, 2007 \n \nAbbeville ............................................................... \nAiken .................................................................... Allendale .............................................................. \nAnderson .............................................................. \nBamberg ............................................................... \nBarnwell ............................................................... \nBeaufort ................................................................ \nBerkeley ............................................................... \nCalhoun ................................................................ \nCharleston ............................................................ \n \nCherokee .............................................................. \nChester ................................................................. \nChesterfield .......................................................... \nClarendon ............................................................. \nColleton ................................................................ \nDarlington ............................................................. \nDillon .................................................................... \nDorchester ............................................................ \nEdgefield .............................................................. \nFairfield ................................................................ \n \nFlorence ............................................................... \nGeorgetown .......................................................... \nGreenville ............................................................. \nGreenwood ........................................................... \nHampton ............................................................... \nHorry .................................................................... \nJasper .................................................................. \nKershaw ............................................................... \nLancaster ............................................................. \nLaurens ................................................................ \n \nLee ....................................................................... \nLexington .............................................................. \nMcCormick ........................................................... \nMarion .................................................................. \nMarlboro ............................................................... \nNewberry .............................................................. \nOconee ................................................................. \nOrangeburg .......................................................... \nPickens ................................................................. \nRichland ............................................................... \n \nSaluda .................................................................. \nSpartanburg ......................................................... \nSumter .................................................................. \nUnion .................................................................... \nWilliamsbu rg ......................................................... \nYork ...................................................................... \n \n2,949 \n2,143 \n \n \n \n71 \n146 \n7 \n238 \n23 \n38 \n11 \n40 \n33 \n41 \n \n54 \n37 \n79 \n31 \n42 \n44 \n23 \n46 \n45 \n15 \n \n62 \n17 \n175 \n102 \n24 \n82 \n9 \n66 \n67 \n72 \n \n27 \n163 \n12 25 \n7 \n124 \n95 \n83 \n123 \n53 \n \n72 \n155 \n60 \n32 \n35 \n143 \n \n43,589 \n41,192 \n \n \n \n1,541 \n2,571 \n116 \n3,649 \n359 \n811 \n195 \n517 \n392 \n689 \n \n695 \n403 \n1,324 \n337 \n385 \n482 \n677 \n607 \n478 \n188 \n \n1,016 \n220 \n1,960 \n1,381 \n387 \n1,732 \n62 \n883 \n862 \n1,285 \n \n565 \n2,384 \n105 \n607 \n122 \n1,672 \n1,328 \n1,771 \n1,457 \n545 \n \n1,031 \n1,990 \n983 \n495 \n392 \n1,938 \n \n1,189 \n898 \n \n \n \n47 \n64 \n6 \n88 \n9 \n18 \n8 \n22 \n15 \n11 \n \n19 \n10 \n37 \n12 \n16 \n13 \n13 \n15 \n21 \n5 \n \n23 \n9 \n54 \n36 \n11 \n24 \n4 \n27 \n24 \n27 \n \n11 \n69 \n2 \n14 \n3 \n61 \n47 \n29 \n48 \n15 \n \n38 \n54 \n35 \n11 \n12 \n52 \n \n14,777 \n16,762 \n \n \n \n730 \n1,040 \n50 \n1,478 \n67 \n311 \n123 \n368 \n193 \n220 \n \n195 \n86 \n400 \n134 \n129 \n157 \n266 \n123 \n160 \n50 \n \n200 \n53 \n481 \n428 \n89 \n407 \n267 \n395 \n219 \n280 \n \n77 \n800 \n(D)\n273 \n(D)\n892 \n328 \n447 \n557 \n224 \n \n389 \n625 \n249 \n65 \n124 \n569"
} |
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"pdf_file": "6S4BF3BBWSDF2EUWMDVBVAAUUCVOCTVP.pdf",
"text": "LIBRARY sec ne '«S.:e A\"\"\"'NI• \n~ \nIssue 83-4 EXCHANOE COMMISSION .... ~.January 6, 1983 \nADMINISTRATIVE PROCEEDINGS \nINITIAL DECISION FINDS PAINE WEBBER WILFULLY AIDED AND ABETTED \nWILFUL VIOLATION OF TENDER OFFER PROVISIONS \nAdministrative Law Judge David J. Markun has filed an initial decision finding that \nPaine Webber Jackson & Curtis, Incorporated, a broker-dealer registered with the \nCommission, wilfully aided and abetted a wilful violation of the tender offer re-\nquirements of Section l4(d) of the Securities Exchange Act of 1934, 15 U.S.C. \n178n(d), in purchasing for a client on the Pacific Stock Exchange, in June 1980,\n9.9% of the outstanding common stock of Diamond International Corporation in a \nsingle transaction involving some 256 sellers. The client concededly did not \ncomply with the tender offer requirements of Section l4(d) and Commission rules \nthereunder. A tender offer under Section l4(d) by another offeror was pending at \nthe time of the June 1980 acquisition of 9.9% of the Diamond common stock by\nRespondent's client. \nThe decision further found that two associated persons of the Respondent, wholly-\nowned broker-dealer subsidiaries Blyth Eastman Paine Webber and Paine Webber \nMitchell Hutchins also wilfully aided and abetted the primary violation, thus \nestablishing an additional basis for imposition of a sanction against the Respon-\ndent. \nOn the basis of several factors, Judge Markun concluded that the finding by the \nCommission of wilful aiding and abetting violations would adequately satisfy the \npublic interest without imposition of a sanction upon the Respondent. \nThe decision is subject to review by the commission on its own motion or on petition\nof a party. \n1M. 'BCEEDI1I8S \nRELTRON CORP. ENJOINED \nThe Commission announced that on January 5 the U.s. District Court for the \nDistrict of Columbia entered a Final Judgment of Permanent Injunction against \nReltron Corp. of Rochester, New York, restraining it from failing to file timely\nperi06ic ~eports and ordering it to comply with certain undertakings. Reltron,\nconsenting to the entry of the Court's judgment, admitted that it had filed \nreports in an untimely manner on 13 separate occasions and failed to file six \nNotifications of Late Filing required to have been filed in connection with its \nlate periodic reports. The Commission's complaint was filed on November 9, 1982. \nReltron has agreed to adopt certain procedures to assure timely filing of reports\nrequired to be filed under the Securities Exchange Act of 1934. (SEC v. Reltron \nCorp., U.S.D.C. D.C., Civil Action No. 82-3191). (LR-9856) \nINVESTMENT COMPANY ACT RELEASES \nNATIONWIDE INVESTING FOUNDATION \nA notice has been issued giving interested persons until January 31 to request a \nhearing on an application filed by Nationwide Investing Foundation and Heritage\nSecurities, Inc. (Applicants), for an order: (1) pursuant to Section ll(a) of the \nInvestment Company Act of 1940 approving certain proposed exchanges: (2) pursuant \nto Section 6(c) of the Act exempting Applicants from the provisions of Section \n22(d) of the Act in connection with those exchanges: and (3) pursuant to Section \n6(c) of the Act granting a conditional exemption from the provisions of Rules \n2a-4 and 22c-l under the Act to the extent necessary to allow the price per share \nof one of Nationwide's classes of shares, Nationwide U.S. Government Money Market \nFund, to be calculated to the nearest one cent on a share value of one dollar. \n(Rel. IC-12945 -Jan. 4) LIQUIDITY FUND FOR THRIFTS, INC. \nA notice has been issued giving !nteres-ted pers9rts:until January 31 to re9ues~.t-a \nhearing on an application by L~quidity Fund ~or ~~ifts, Inc., for an 'order, pur-\nsuant to Section 6(c) of the Investment Company Act of 1940, exempting it froJJi~the \nprovisions of Section 2(a) (41) of the Act and Rules 2a-4 and 22c-l thereunder to \nthe extent necessary to permit it to compute the net asset value per share of its \nShort-Term Portfolio using the amortized cost method of valuing portfolio securi-\nties. (ReL, IC-12946 -Jan. 4) \nLISTING, DELISTING AND UNLISTED TRADING ACTIONS \nUNLISTED TRADING SOUGHT \nA notice has been issued giving interested persons until January 25 to comment on \nthe applications of the Midwest Stock Exchange, Inc. for unlisted trading privileges \nin three issues which are listed and registered on one or more other national securi-\nties exchanges and are reported in the consolidated transaction reporting system.\n(Rel. 34-l939B) \nUNLISTED TRADING GRANTED \nOrders have been issued granting the applications of the following stock exchanges\nfor unlisted trading privileges in issues which are listed and registered on one\nor more other national securities exchanges and are reported in the consolidiated\ntransaction reporting system: Philadelphia Stock Exchange, Ihc. -five issues.\n(Rel. 34-19399); and the Midwest Stock Exchange, Inc. -,seven issues.\n(Rel. 34-19400)\nSELF ·REGULATORY ORGANIZATIONS \nNOTICE OF PROPOSED RULE CHANGES \nThe following stock exchanges have filed proposed rule changes pursuant to Rule \n19b-4: The New York Stock Exchange, Inc. (SR-NYSE-B2-22) to provide for minimum \nmargin on uncovered short positions in options on a broad based stock index. \n(ReI. 34-19396); and The American Stock Exchange, Inc. (SR-Amex-B2-20) to provide\nfor minimum margin on uncovered short positions 1n stock index options. _\n(Rel. 34-19397) \nPublication of the proposals are expected to be made in the Federal Register during \nthe week of January 10. \nAPPROVAL OF PROPOSED RULE CHANGES \nThe Commission has approved proposed rule changes filed under Rule 19b-4 by the \nfollowing: The Municipal Securities Rulemaking Board (SR-MSRB-B2-13) to amend \nMSRB Rule G-12(e) (v) to permIt delIvery of tax exempt notes in denominations smaller \nthan those specified in an inter-dealer trade confirmation if the notes delivered \ncan be aggregated to constitute the denominations specified. (Rel. 34-19390); \nThe New York Stock Exchange, Inc. (SR-NYSE-82-2l) involving the size of orders \neligible for routIng In the NYSE's Designated Order Turnaround (DOT) System, the \nActive Stock Feature of the DOT System and the design of the mark-sense cards \nused by specialists in reporting executions of DOT orders. (Rel. 34-19392); and \nThe Midwest Stock Exchange, Inc. (SR-MSE-B2-7) to amend MSE's Constitution to.add \ntwo additional public governors to MSE's Board of Governors and to allow one public\ngovernor to be a former officer of the Exchange who is not a broker or·dea~er. \n(Re!. 34-19402) \nNEWS DIGEST, January 6, 1983 2 MISCELLANEOUS \nORDERS GRANTING APPLICATION PURSUANT TO SECTION l2(h) \nOrders have been issued granting the application of the following companies, \npursuant to Section l2(h) of the Securities Exchange Act of 1934, for an exemption\nfrom the specified requirements of the following sections of the Exchange Act: \nCommonwealth Dealers Life Insurance Company -reporting requirements of Section \n15(d). (ReI. 34-19393): and Rochester Community Baseball, Inc. -registration,\nreporting proxy soliciting, and others provisIons of Section l2(g), 13, 14 and 16. \n(ReI. 34-19394) \nSECURITIES ACT REGISTRATIONS \nThe following registration statements have been filed with the SEC pursuant to the \nSecurities Act of 1933. The information noted below has been taken from the cover \npage and the facing ~heet of the prospectus and registration statement and will \nappear as follows: Form, Name, address and phone number (if available) of the \nissuer of the security: Title and the number or face amount of the securities being\noffered: Name of the managing underwriter (if applicable): Whether the offering is \na rights offering: File number and date filed: Assign~d Branch: if the registration \nstatement is a New Issue: and [S] denoting SHELF REGISTRATION pursuant to Rule 415. \n(S-18) BLUE GRASS BREEDERS, INC., 2825 East Long Court, Littleton, CO 80121 (303)\n694-1370 -24,000,000 common shares. Underwriter: Rocky Mountain Securities &\nInvestments, Inc., 909 17th St., Suite 200, Denv~r, CO 80202 (303) 623-6700.\nThe company will acquire, breed and sell thoroughbred horses. (File 2-8l022-D -\nDec. 21, 1982) (Br. 3 -New Issue)\n(S-18) MICROCOMM CORPORATION, 1407 East Cliff Rd., Burnsville, MN 55337 (612) 894-7790 \n-600,000 shares of common stock. Underwriter: Summit Investment Corporation,\nSuite 412, Butler Square Bldg., 100 North 6th St., Minneapolis, MN 55403. The com-\npany designs, manufactures and sells setback thermostats. (File 2-8l045-C -\nDec. 23, 1982) (Br. 8 -New Issue) \n(S-18) OLYMPIC NORTHERN AIRLINES, INC., Suite 115, Terminal Bldg., Boeing Field, \nSeattle, WA 98108 (206) 762-8010 -714,000 shares of Class A common stock. The \ncompany plans to provide high frequency scheduled airline service. (File 2-8l055-S \n-Dec. 23, 1982) (Br. 3 -New Issue) \n(S-18) UNITED BANCORP, 605 S. E. Kane St., Roseburg, OR 97470 (503) 440-2660 -\n$1,950,000 of Series A/Series B floating rate, convertible subordinated debentures,\ndue December 15, 1992. Underwriter: Somers, Grove & Co., Inc., 707 S. W. Washing-\nton St., Portland, OR 97205. (File 2-8l060-S -Dec. 23, 1982) (Br. 1 -New Issue) \n(S-18) H-S ROYALTY, LTD., 507 Philtower Bldg., Tulsa, OK 74103 (918) 583-0178 -80,000\nunits of limited partnership interests. (File 2-8ll08-FW -Dec. 29, 1982) (Br. 10 \n-New Issue) \n(S-18) FAMILY SHOWTIME THEATRES, INC., 61 Broadway, New York, NY 10006 -500,000 units. \nUnderwriter: Muller and Company, Inc., III Broadway, New York, NY 10006 (212)\n766-3200. The company has undertaken to open ten ·Chuck E. Cheeze's Pizza Time \nTheatre\" family-oriented restaurant and entertainment centers in various cities in \nthe State of New York. (File 2-8lll2-N¥ -Dec. 29, 1982) (Br. 4 -New Issue) \n(S-18) SPORTS PROMOTIONS OF TULSA, INC., 100 Civic Center, Tulsa, OK 74103 (918)\n582-8283 -180,000 shares of common stock. Underwriter: S. W. Devanney & Company,\nInc., 10200 East Girard Ave., suite l50-C, Denver, CO 80237. The company was\nincorporated to maintain, operate and control a professional ice hockey team.\n(File 2-81178 -Jan. 4) (Br. 4 -New Issue) \n(S-3) WHIRLPOOL CORPORATION, Benton Harbor, MI 49022 (616) 926-5000 -1,497,508\nshares of common stock. Underwriters: Goldman, Sachs & Co. and Dean Witter Rey-\nnolds Inc. The company and its consolidated subsidiaries manufacture major house-\nhold appliances. (File 2-81182 -Jan. 5) (Br. 10) [S] \nNEWS DIGEST, January 6, 1983 3 (S-6's) ~.II\\.SSACHUSETTS EXEMPT UNIT TRUST, DISCOUNT SERIES 2; MASSACHUSETTS TAX TAX \nEXEMP~ :iNIT TRUST, SERIES 56, 60 State St., Boston, MA 02109 -13,000 and 7,000\nunits, respectively. Depositor: Moseley, Hallgarten, Estabrook & Weeden Inc. \n(File 2-81183; 2-81184 -Jan. 5) (Br. 16 -New Issues) \n(S-6) THE FIRST TRUST OF INSURED MUNICIPAL BONDS, SERIES 96, 300 West Washington St.,\nChicago, IL 60606 -an indefinite number of units. Depositor: Clayton Brown &\nAssociates, Inc. (File 2-81185 -Jan. 5) (Br. 18 -New Issue)\n(S-3) ANALOGIC CORPORAT~ON, Audubon Rd., Wakefield, MA 01880 (6l7) 246-0300 -650,000\nshares of common stock. Underwriters: Shearson/American Express Inc., Donaldson, \nLufkin & Jenrette Securities Corporation and Merrill Lynch White Weld Capital Mar ... \nkets Group. The comD~ny is engaged in the design, manufacture and marketing of \nadvanced, precision data conversion and computer-based signal processing instru-\nments and equipment. (File 2-81186 -Jan. 5) (Br. 8) \n(N-l) THE AMERICAN BOARD OF TP.ADE Go\\~RNMENT FUND, INC., 9 South William St., New York, \nNY 10004 (212) 943-0100 -an indefinite number of securities. (File 2-81187 -\n,'an. 3) (Br. IR -~J.. w I~sue) \n(S-14) CAMBRIDGE BANCO~P, 1336 Massachu~ptts Ave., Cambridge, MA 02138 (617) 876-5500 -\n150,000 shares of common stock. (File 2-81188 -Jan. 3) (Br. 2 -New Issue) \n(S-6) NATIONAL MUNICIPAl. TRUST, SPECIAL TRUSTS, SEVENTH MULTI-STATE SERIES, One New\nYork Plaza, New York, NY 10004 -13,000 units. Depositor: Thomson McKinnon\nSecurities Inc. (File 2-81190 -Jan. 5) (Br. 18 -New Issue)\n(S-14) HEALTHDYNE,INC., 2253 Northwest Pkwy., Marietta, GA 30067 (404) 955-9555 -\n1,443,912 shares of common stock. (File 2-81191 -Jan. 5) (Br. 8)\n(S-3) J~MES RIVER CORPORATION, Tredeqar St., Richmond, VA 23217 (804) 644-5411 -\n1,612,500 shares of common stock: Underwriters: Kidder, Peabody & Co. Incorporated,\nWheat, First Securities, Inc. and Scott & Stringfellow, Inc. The company is \nengaoed in the development, manufacture and marketing of paper and paperboard, \nconverted paper products, woodpu1p and coated film. (File 2-81192 -Jan. 5)\n(Br. 8) [5] \n(5-15) JOHNSON & JOHNSON, 501 Goerqe St., New Brunswick, NJ 08903 (201) 524-0400 -\n365,521 shares of common stock. (File 2-8111)4 -Jan. 5) (Br. 8)\n(S-l) GEOVEST ENE~GY INCOME FUND LTD. 1983-1, 1983-2, 1983-3, 19R3-4, 1983-5, 1983-6, \n6090 Central Avenue, St., Petersburg, FL 33707 -25,000 vnits of preformation \nlimited partnership interests ($1,000 per unit). (File 2-81195 -Jan. 5) (Br. 4 -\nNpw Issue) \n(5-6) MUNICIPAL INVESTM~NT TRUST FUND, FIRST MASSACHUSETTS SERIES, One Liberty Plaza,\n165 Broadway, New York, NY 10080 -an indefinite number of units of beneficial\ninterest. Depositor~: Mprril1 Lynch, Pierce, Fenner & Smith Incorporated,\nOne Liberty Plaza, ]1;5 Broadway, New York, NY 10080, Dean Witter Reynolds Inc.,\nPrudential-Bache Securities Inc. and Shearson/American Express Inc. (File\n2-81196 -Jan. 5) (Br. 17 -New Issue)\nREGISTRATIONS EFFECTIVE \nDec. 30: GIT Cash Trust, 2-78159; GIT Tax-Free Trust, 2-77986; Lorimar, 2-80804.\nJan. 3: Astrosystems, Inc., 2-87096; Austex 1983 Drilling Program, 2-78340;\nCass Commercial Corporation, 2-80070; Centennial Development Fund III, 2-79829;\nDaily Money Fund, 2-77909; Dresher, Inc., 2-80124; Optical Coating Laboratory,\nInc., 2-81070; Pacific Gas and Electric Company, 2-80829; Public Storage Proper\n-\nties IX, Ltd., 2-79B57; Teradyne, Inc., 2-81072; Tosco Corporation, 2-80996.\nJim. 4: ~nixter Bros., Inc., 2-81007; Carmel Bancorporation, 2-80730; Common\n-\nwealth Financial Futures Fund, 2-79900; First Peoria Corp., 2-80363; Peoples\nRestaurants, Inc., 2-~0922; Repub1icBank Corporation, 2-80914.\nJan. 5: Allied Bancshares, Inc., 2-81041; Armatron International, Inc., 2..80950;\nFarmland Industries, Inc., 2-80509; Worldwide Energy Corporation, 2-79630.\nNEWS DIGEST, January 6, 1983 4 ACQUISITIONS OF SECURITIES \nCompanies and individuals must report to the Commission within ten days on Schedule \nl3D if after the acquisition of equity securities of a public company their benefi-\ncial interest therein exceeds five percent. Persons eligible to use the short form \n(Schedule 13G) may in lieu of filing a Schedule 13D file a Schedule l3G within 45 \ndays after the end of the calendar year in which the person became subject to Sec-\ntion l3(d) (1). Companies and individuals making a tender offer must have on file \nat the time the tender offer commences a Schedule l4D-1. \nBelow is a list of recent filings of Schedules l3D and l4D, which includes the \nfollowing information: Column 1 -the company purcha~ed (top), and the name of thp.\npurchaser; Column 2 -the type of security purchased; Column 3 -the type of form \nfiled: Column 4 -the date the transaction occurred; Column 5 -the current n\\~ber \nof shares (in ODD's) owned (top) and the current percent owned; Column 6 -the \nCUSIP number (top) and the prior percent o~ed: and Column i-the status of tp~\nfiling, i.e., new, update, or revision. \nEVENT SHRS(OOO)/ CUSIP/ FILING \nFORM DATE %OWNED PRIn~% ST~TUS \nAMERICAN METALS SVC INC COM 115 0274871 I)\nSTEPHENS:ON MERCHANT BI( 13D 5.7 0.0 NEW\nCADO SYS CORP COM 361 12760410\nALPINE ASSOC 8., ECKERT VICTORIA 7.3 0.0 NEW\nCHEMINEER INC COM 207 16381810\nINTERPACE CORP 13D 17.9 0.0 ~c~\nCINDYS INC COM 710 1723991 (I \nSOUTHSIDE MGMT ET AL 13I1 33.9 31.4 UPDATE \nCOGENIC ENERGY SYS INC COM 1,3:38 1923'00110\nNISSLEY MARREN 1.•1 1:::D 12/ 1/82 21.2 22.3 UPDATE \nCOLONIAl BANCORP INC COM 707 19549910\nFSC CORP 13D 12/17\"'82 33.3 0.0 NEW\nCOUNTY TOMER CORP COM 87 22258810 \nMORR ISSEY ~IOSEPH JR 13D 12····22/82 5.2 4.7 UPDRTE \nFEDERAL RLTY INVT TR S:H BEN UlT 46331:37472 (I \nSIAM LTD 13D 11.8 9.8 UPDATE \nF INANC IAL NE't.IS: COM 31790210 NETt.IORK INC 738 \nMERRILL LYNCH CO/MLPF&S 1 :;:D 15.7 0.0 NEW \nGUL F RES &, CHEM CORP COM 2,464 40249610 \nZOPRES:S COMMERCIAL S A ET AL 13D 27.5 25.1 UPDATE \nNACHMAN CORP COM 811 62958110\nLEGGETT &, PLATT INC 13D 84.3 0.0 NEW\nN'1TIONAL CONTROLS INC COM 287 63556110\nP.AMSAY CORP 13D 23.6 0.0 NEW\nNATIONAL ENERGY CAPITFIL COP.P COM 248 63580010\nNELSON P.ICHARD H 1:3D 11.9 0.0 NEW\nNATIONAL ENEPGY CAPITAL CORP COM 268 635:::0010\nNISSLEY WAPREN W 13D 11/23.... 12.8 0.0 NEW\n 82 \nNATIONAL ENERGY' CAPITAL CORP COM 550 63580010\nSHLENSI(Y' PAUL D 13D 26.4 0.0 NEW\nNAT IONAL ENERGY' CAP ITAL COP.P COM 103 63580010\nWARNER DONALD 13D 5.0 0.0 NEW\nNUMBER 1 TV INC COM 63 67052310 \nSILVA KENNETH 8., DnpOTHEA 13D 6.2 0.0 NEW \nNEWS DIGEST, January 6, 1983 5 ACQUISITION REPORTS CONT. \nP.EPCO INC COM 243 75990910 \nWEBCOP. ELECTPONICS INC 13D 20.0 0.0 /'lEW \nSCOPE INC COM 243 80914610 \nPACE PANDOLPI-I is· POO~E\"Y PATR ICK 20.0 0.0 /'lEW \nS·UBUPBAN PPOPANE GAS COPP COM 744 86447310 \nDR ACQUISITION/NATl DISTILLERS 14.2 0.0 /'lEW \nTPC COMMUNICATIONS INC COM 60 87261510 \n1.,10DrllANrl CAP ITAL CO 13D 6.3 0.0 /'lEW -.-----\nRECENT 8K FILINGS \nForm 8-K is used by companies to file current reports on the following events: \nItem 1. Changes in Control of Registrant.\nItem 2. Acquisition or Disposition of Assets.\nItem 3. Bankruptcy or Receivership.\nItem 4. Changes in Registrant's Certifying Accountant.\nItem 5. Other Materially Important Events.\nItem 6. Resignations of Registrant's Directors.\nItem 7. Financial Statements and Exhibits.\nThe companies listed below have filed 8-K reports for the date indicated and/or amend· \nments to 8-K reports previously filed, responding to the item(s) of the form specifie\nCopies of the reports may be purchased from the Commission's Public Reference Section \n(in ordering, please give the date of the report). An invoice will be included with \nthe requested material when mailed. \nCOMPANY ITErotS Nil. DATE \nACADEMY C~PUTING CORP 4 12114/82\nADVANCE ~OSS CORP 2.1 12/29/82 \nUR R.ORIDA SYSTEM INC 2.5.6 09130182 \nAlGERAN INC 2.1 12115/82\nALPHA PETROLEUM E.PLORATION CORP 4 12129/82\nAMERICAN BEVERAGE CORP INYI 5 11105/82 \nAMERICAN BllTRITE INC 1.2 12/16/82\nAMERICAN CENTURY CORP 5.7 ·10/29/82 AMEND \nAMERIC.H EQUITY INVESTMENT TRUST 2.7 12111/82\nAMERICAN PROPERTY INVESTORS VIII 2.1 12115/82\nANI MATEO ELECTRONICS INC 4.5.6.7 12109/82\nANRET INC 1 12109/82 \nARAPAHO PETROLEUM INC 5 12116/82\nARGOSY ENERGY INC 1 05/04/82\nAR~ANSAS POWER r. LIGHT CO 5 12117182 \nART RA GROUP INC 5.7 12129/82\nAT&E CO~P 4 12103/82\nAZTEC RESOURCES CORP 5 12116182 \n~AlCOR EOUITY PROPERTIES .11 2.7 12115/82\nBA'4CORP OF \"'ISSISSIPPI INC 2.7 07101/82\nBANGOR HY{)Q.OELECTRIC CO 5 12121/82\nB.lNI( S OF IO W4 INC 5.7 12115182 \nBASIC AMERICAN CORP 2.7 12101/82\n81L TRITE CORP 1.7 12116182 \n~OETTCHER WESTERN PROPERTIES FUND 1981-8 2.7 12117/82\nROETTCHER WESTERN PROPERTIES II LTO 2.7 12117/A2\nBREEZE CORPORATIONS INC 1.2.7 12115/82\n~~USH WELLMAN INC 2.5.7 12/17182\nRTK INDUSTRIES INC 5· 12127182 \nCABLE TV FUND IO-~ 2.7 11/26/82 AMEND \nCALLON DRILLING FUND 1~81 7 11/19182 '''END\nCALLON DRILLING FUND 1~82-A 7 11/19/82 AMEND \nCALLON INSTITUTIONAL ROYALTY IN~STORS I 7 ll/19/82\nCALMA~K REAL ESTATE FUND LTD 2.1 12/02182\nCARE CORP 2.1 12115/82 \nNEWS DIGEST, January 6, 1983 6 7 RECENT 8K FILINGS CONT. \nCASINO ANTIOUES LTD 1.7\t 12115/82\n12122/82 C~TRAl MNCORP INC \nCENTRAL ~IHE POWER CO\n 11130/82\n11130/82 CENTRALHAINE. POWER CO\nAM END\n6\n5\n5\n7\n7\n2 CENTURY PRQ1»ERT1ES EOUITY fUND 73 \n~OPERTtfS EOUITY 11/05/82\n11130182 CENTURY\n PARTNERSHIP\n AMEND\n 72 \nAMEND\n CENTURY PROPERTIES FUND XVII\n 06/29/82\nC .. SE ..AIllHATTAN CORP 4.7\t 12128182 \nCIMARRON CORP 5 12115/82\nCOLORADO SOLAR CORP 4.7 10/25/82\nCONNECTICUT GENERAL REALTY INVESTORS LTD 2.7 12108182 \nCON~UEST EXPLOUTION CO\n 5 12120/82\nCONSOLIOATEO CAPITAL PROPERTIES IV\n 2.7 12114/8211/22/82\nCONSOliDATED RESOURCES HEALTH CARE FUND 5 \nCONTINENTAL MORTGAGE INVESTORS 5.7 12117182 \nCOOK VS STEAK PUBS INC 5.7 12117/82\nDAI_Y WORLD GENETICS LTD PARTNERSHIP lq8 5 12123/82\nDAU LAW CO 3.7 12114/82\nDUNES HOTELS & CASI NOS INC 2.7 12120/82\nDyeD\" INdUStRIES INC 2.7 11109/82\nEL PASO CO 12120/82\n09/271925\n5\n7 \n6 ELECTRO AUDIO DYNAMICS- INC\nENCORE INDUSTRIES INC\n 12128/82\n12117182 ENERGY CAPITAl DEVelOPMENT CORP \nfNERSY CONVERSION DEVICES INC 5.7 12113/82\nENERGY CONVERSION DEVICES INC 5.7 12113/82\nENER\"ARK OIL LTD 1.2.5 12103/82\n£NERSERV PRODUCTS INC 2.7 12110/82\nENERSERVPRODUCTS INC 5.7 12128/82\n12117182 I=OU IPMENf CD-OF AMERICA 4\n2 \n5 ERB LUMBER co IMII 12103/82\nFlUT BANCOR'P Of N H INt 12114/82\nLOAN ASSOCIATIOIII 5.7 12117182 FIRST COLONY SAVINGS\n£\nFIRST FAR~EST CORP 5 12113/82\nFIRST GENERAL RESOURCES CO 5.7 12116182\nFIR ST MIDWEST CORPIUT 1 2.7 12110/82\nFIRST WICHITA 8lNCSHARES INC 5.7 12109182\nFLARE INC\n 5 \nFLORIDA NATIONAL BANKS Of FLOPIDA INC 5.7 12121/82\n12115/82\nFRANKUN elECTRIC CO INC \nGAYNOR & CO INC 5\n5 \nGENERAL BUILDERS CORP\t 4.7 12123/82 \n12123/82\n11/30/82\nAMEND\n GENERAL PORTLAND INC\nGEO INTERNATIONAL CORP INEWI\n12115182 7\n5 10111/82\n10/18/82 AMEND I;Q..DENCORRAl..RESTAURANT JOINT VENTURES \nH&H Oil TOOL CO INC 1 \n5.7 12108/82\nHANFORD SIL VER INC \nHARVEY GROUP INC\nI-OSPITAL TRUST CORP\nHYPERION INC\nILLINOIS BELL TelEPHONE CO \nINTERCONTINENTAL DIA~OND CORP\n2\n2\n5\n1\n5\n2 12110/82\n08/05/82 AMEND \n12128182 \n12120/82\n12117182 \n12120/82\n12121182 \n12108/82\n12118182 INTERNA TlONAL ROYAL TV & OIL CO\t 4 \n!NTRAWEST FINANCIAL CORP\nINVESTEX INC\n5\n3 \nJM8 INCOME PROPERTIES LTD 1973 2.1\t 12111182 \nKENILWORTH SYSTEMS CORP\n 5\n7\n2 12116/82\n12127182 1(ERR ..CGEE CORP \nKETCHUM s CO INC 12113/82\n12116182 OLE TECHNOlOGY CORP\t 4.7 \nLEADER \nUASCO DEVELOPMENT \nCORP IOlD COIlP 4.7 \n5.7 12110/82\n12123182 \nLEUCADIA NATIONAL CORP 5.7 12115/82 \nNEWS DIGEST, January 6, 1983 RECENT 8K FILINGS CONT.\nLINCOLN PLAZA RESOURces INC 5.1 12/22182\n12121/82\n12113182LOUISIANA POWER & LIGHT to ILAI \nMAINE YANKEE ATOMIC POWER CO\n~CCORMICK COMMODITY FUND I\n5\n5\n5\n5 12109182 \n12/09182 ~CDRMICK COMMODITY FUND II\n5.1\n 12103/82\n06/03/82 AMEND \n11126182 I4CDOWEll ENTERPRI SE S INt \n~~EIL PACIfiC INVESTORS FUND 1912 \nMERRILL LYNCH MBS INC\n31 \n5.1 11/15182\n12117/82~ID AMERICA INDUSTRIES INC\n5\n5\n5 MIDDLE SOUTH UTILITIES INC\n~ISSOURI EDISON CO\nIIIONTANA POWER CO INTI 12113182 \n12/28182\n12/01182 IV 5.1\n MUlTI BENEFIT REALTY FUND \n5.1 12/15/82\n12/13/82NATIONAL CENTRAL FINANCIAL CORP\n1 NATI~AL MOBILE CONCRETE CORP\nNATIONAL PROPERTY IN~ESTORS 5 2.1 12113/82\nNE~ PlAN REALTY TRUST 5.1 12/15182\nNEW YORK TI MES CO 1 12/15/82 AMEND \nPARAGON 1979 DRILLING PROGRA~ LTD <\\.1 12/17/82\nPARAGON 80-1 LTD <\\.1 12111182 \n<\\.1 \n512/11/8212/01/82 PARAGON 80-2 LTO \nPIERCE S S co INC \nINC 2.1 12/10/82\n12/23/82PIONEER STANDARD ELECTRONICS\nPRO SCAN INC\n 5 \n5.1 12/2V82PSA INC\n1.2.1\n 12/15/82\n12/06/82REFINEMET INTERNATIONAL CO\n4 REFLECTONE INC\n5.1\n 12/23/8212/16182\n12/10/82REL lANCE GROUP HOLDINGS INC \nSABA OIL & GAS CORP\n 5 \nSIERRA REAL ESTATE EOUITY TR~ST 2.1\n11/23/82 5\n5\n5 SIGMA ALDRICH CORP\nSLATER ELECTRIC INC\n 12/13/82\n12/2V82 SOUTHERN co \nSPII4GROUP INC 5.1 12/09182\nTEU4ICOLD CORP 1.2.7 12/14/82\nTEXAS ENERGIES INC 5.7 12111182 \n12/16/82 5 ToeON INC \n5.1\n 12/09182\n2.1 12115/82TOSCO CORP\nTRANSTECHNOLOGY CDRP\nUNIT 1982 BOIL & GAS PROGRA~ 5.1 12/10/82\n12/10/82\nm.1 TED EDUCATORS INC 4.7 07131/82 \nUNITED STATES MUTlML REAL ESTATE INVESTM 5.1 5 UNITED CnMPANIES FINANCIAL CORP \n12/15182\n12/08/82 UNIVERSAL BANtORP \nWAlKER COlOR INC 5\n5 12103/82\n12/08182 5.1\n WARNER CO\"\"UNICATIONS INC\n11124182 WASHINGTON MUTUAL SAYINGS BANK SERIES A\nWEST BAY FINANCIAL CORP ICAI \nWORLDWIDE ENERGY CORP \nXEROX CORP 7\n2\n5\n5 12/20/82 \n12121/82 \n12/11182\n12120/82 ZEllO CORP 5.1 \nZIMMER CORP\n 5 12/13182 \nNEWS DIGEST, January 6, 1983 8 "
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"pdf_file": "NHYKVCJIDJXBIL5EMS743GR74TJUOWAT.pdf",
"text": "Seasonal Outlook into early 2012 Klaus Wolter University of Colorado, CIRES & NOAA-ESRL PSD 1, Climate Analysis Branch klaus.wolter@noaa.gov • La Niña has indeed returned from its summer vacation • What does that mean for us? • Expectations for next two weeks • CPC forecasts from October ‘11 through March ‘12 • Experimental Seasonal Forecast Guidance (ditto) • Executive Summary CO WATF, 22 September 2011 Denver \n Current state of El Niño/Southern Oscillation (ENSO) phenomenon (bottom), compared to three months ago (top): La Niña has made a modest comeback last month. This includes enhanced trade winds near the dateline, and below-normal SST in central tropical Pacific, especially just west of 120W. \nNiño 3.4 Here we go again, La Niña is coming back for an encore performance, just like in 2008, 1999, 1974, 1971, 1955, 1950,… \n ECMWF forecast from May 2011(left): Correct anticipation of warm-up through June, but missed the reappearance of La Niña conditions after that; A not-yet published paper that has evaluated every model over the last decade has confirmed that ECMWF is the ‘gold standard’ in this business. The most recent forecast (right) shows moderate La Niña conditions this winter, with no chance of El Niño or even ENSO-neutral before February 2012. \n ENSO forecasts from 15 dynamical & 8 statistical forecast models in June 2011 (left): Transition to ENSO-neutral by early summer (√), then wide open outcome for rest of 2011; On average, dynamical models a bit warmer than statistical models, insignificant differences overall. The most recent forecast collection (right) shows a shift towards La Niña, although only half of the models reach the ‘magic’ -0.5C threshold; meanwhile, the latest available PDO-value (July) remains negative, having proven itself yet again to be consistent with the return of La Niña... \n Compared to the typical outcome of La Niña fall seasons (top left), Oct-Dec 2010 (bottom left) ended up with the same preference for wet conditions in western CO, while drought conditions were more severe in SE CO than is typical for La Niña. Autumn 2011 may end up drier than in 2010 for much of our state (top right). This is based on the same set of double-dip Las Niñas as presented last October. 1st vs 2nd Yr La Niña composites for October-December \n Compared to the typical outcome of La Niña winter seasons (top left), Jan-Mar ‘11 (bottom left) ended up close to (dry) expectations (this does not monitor mountains snowpack), especially in SE CO. The upcoming winter season shows no signal (top right), which may be our ‘opening’ for a possible rebound after a dry fall. This is based on same set of double-dip Las Niñas as before. 1st vs 2nd Yr La Niña composites for January-March \n What can we expect in the next five days? \nExpected precipitation amounts for the next five days, according to Hydrological Prediction Center (NOAA-HPC) –sure looks dry for the weekend… \n What can we expect next week and beyond? \nEuropean model shows mid-continent ridging 8-10 days out from last night – keeping us dry and mild, while the American model is further along in replacing the ridge with westerly flow. \n What can we expect in the next two weeks? \nPrecipitation chances for 4-6, 6-10, and 8-14 days from today show poor chances for precipitation early next week (top); close to ‘normal’ for next weekend (top right), and back to drier than ‘normal’ by “Week 2” (right). Temperatures are expected to rise above normal over the weekend and staying mild beyond that, delaying the onset of winter snowpack conditions. \n Climate Prediction Center ‘Analog’ Forecasts \nAccording to yesterday’s soil-moisture analog forecast, wet anomalies are favored in northernmost CO along with cooler-than-average temperatures, while drought conditions remain anchored towards the Four Corners and northern TX. Typical skill at this lead-time (right) is quite high over northeast CO where there is a tilt towards wet conditions. Source: http://www.cpc.ncep.noaa.gov/soilmst/cas.shtml \n Climate Prediction Center ‘Analog’ Forecasts \nAccording to yesterday’s soil-moisture analog forecast, dry conditions threaten eastern CO in late winter, while our mountains may look forward to a near-normal winter. Typical skill at this long lead-time (right) is high to our south, maintaining drought conditions from eastern NM and most of TX up into SE CO. Source: http://www.cpc.ncep.noaa.gov/soilmst/cas.shtml \n Climate Prediction Center Forecasts \nCPC’s Oct-Dec (left) temperature forecast expects a warm fall (La Niña+trend), especially in already dry eastern CO. Their precipitation forecast (right) keeps it dry for all of us, again, consistent with La Niña-based expectations, and some composites that I made for 2nd year La Niña conditions. Source: http://www.cpc.ncep.noaa.gov/products/predictions/ \n Climate Prediction Center Forecasts \nCPC’s Jan-Mar ‘12 (left) temperature forecast expects Colorado to straddle warm anomalies to the south and cold anomalies to the north. A similar picture transpires for precipitation (wet to the north, dry to the south), again, consistent with La Niña-based expectations (and my composite). Source: http://www.cpc.ncep.noaa.gov/products/predictions/ \n Statistical Forecast for April-June 2011 \nFebruary’s (top left), March’s (top middle), and April’s (top right) forecasts for April-June 2011 were fairly confident that southern CO would see below-normal moisture. The northwestern third of our state had slightly increased chances of being wetter-than-average. Most of southern CO ended up dry, and northwest CO wet (right). On the other hand, the northeast corner of our state was wetter than expected, ditto for the Four Corners region. IOW, the February forecast panned out better than later updates (also for New Mexico)! \n Statistical Forecast for July-September 2011 \nThe April forecast for July-September 2011 (left) was optimistic for northwestern CO, and undecided for the rest of the state. The June forecast (top right) was significantly drier, including my 1st dry summer forecast for the eastern plains in more than one decade. As of yesterday (right), dry conditions have indeed prevailed in much of eastern CO, especially in the Arkansas Valley which was already under drought conditions. Early July wetness (plus a couple of storms this month) have kept us (FR) wetter than expected. \n Statistical Forecast for Oct-Dec 2011 \nMy new forecast for October-December 2011 (left) is leaning towards dry conditions over southern and eastern CO, leaving the West slope and mountains under climatological odds. Verification statistics over the last decade (right) show skill over the dry northeastern plains of CO, but not to the west. \n Statistical Forecast for January-March 2012 \nMy new forecast for January-March 2012 (left) is leaning towards dry conditions over southeastern CO, again leaving the mountains under climatological odds, and the far western valleys and Four-Corners’ region with a slight tilt towards a dry late winter. Verification statistics over the last decade (right) show skill for much of the domain, except the higher elevations of CO. Last year (no forecast issued), my forecast for JFM’11 would have been dry for eastern CO, and at least near-normal for the mountains. \n Executive Summary (22 September 2011) – klaus.wolter@noaa.gov 1. La Niña appears to be making a come-back, confirming my long-lead statements from last October. It probably will end up weaker than last winter, but that is less important for impacts than in the El Niño case. 2. The last three months did not see much of a flooding season (√), a late run-off season (no excessive dust √), and a less severe fire season than feared. All in all, Colorado did very well last Water Year, with (near-)record snowpack conditions coming off in the most benign manner possible. 3. Along the Front Range, the monsoon season was wetter-than-expected, with a particularly wet start in July, but severe dryness in August. Those rains of early July may have involved recycled moisture from our record-snowpack, IMHO. The next two weeks will see a return of dry/mild conditions, with no prospects for snow (or rain) before September is over. 4. My forecast for the next six months is not optimistic, especially for southeastern Colorado. Thanks to La Niña, the mountains have a good chance of getting close to normal snowfall in mid-winter (to be firmed up in next two months). A repeat of last year’s record-breaking snows is unlikely. 5. Bottomline (Double-Dip La Niña): In our state, 2nd year La Niña winter half-years are often drier than in the previous year. There is little evidence that would support a contrary (wet) viewpoint. This statement does not factor in ‘rogue atmospheric river events’ (like last December) that are currently not predictable at the seasonal time-scale. "
} |
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] | {
"pdf_file": "QCZLJRXUA3KIQPMRQ4LSGYCNVTIK6PG4.pdf",
"text": "STATEMENT OF INTENT Wisconsin Department of Transportation \n \nMV2489 10/2000 \n \nPerson Making Statement Vehicle Year Make \nAddress Vehicle Identification Number \n \n \n Any person who knowingly makes a false statement in an application for a certificate of \ntitle may be fined not more than $5,000 or imprisoned not more than 7 years and 6 \nmonths or both s.342.06(2) Wis. Stats. \n \n \n ____ My name appears in error on the title of the vehicle described. I did not \npurchase the vehicle and have no interest in it. \n \n \n ____ As seller, I signed/printed my name in the purchaser area of the title by \nmistake. I do not wish to be a co -owner of the vehicle. \n \n \n ____ As seller, I signed/printed my name in the lien area of the title by mistake. \nI do not wish to be a lienholder of the vehicle. \n \n \n ____ As seller, I printed the wrong name in the purchaser area. The vehicle \nwas actually sold to:________________________________________. \n \n \n ____ Other (describe in detail): \n \n \n \n(Signature of Person Certifying) (Date) \n \nThe Wisconsin Depar tment of Transportation complies with the Americans with Disabilities Act. "
} |
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"pdf_file": "P6HR4OCK2XESQDYBJJZZKFXDENQUEURI.pdf",
"text": " \nJOINDER BY COUNTY OF MONO TO WALKER RIVER IRRIGATI ON DISTRICT’S MOTION (DOC # 743 ) \nPage 1 \n 1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31 \n MARSHALL S. RUDOPLH, SBN 150073 \nMono County Counsel \nSTACEY SIMON, SBN 203987 \nAssistant County Counsel \nssimon@mono.ca.gov \nP.O. Box 2415 \nMammoth Lakes, CA 93546 \nTel: (760) 924 -1700 \nFax: (760) 924 -1701 \n \nAttorneys for Defendant , COUNTY OF MONO \n \n \n \nUNITED ST ATES DISTRICT COURT \nDISTRICT OF NEVADA \nUNITED STATES OF AMERICA , \n Plaintiff , \nTHE WALKER RIVER PAIUTE TRIBE, \n Plaintiff -Intervenor, \n v. \nWALKER RIVER IRRIGATION \nDISTRICT , a corporatio n, et al., \n Defendants . \n \nMINERAL COUNTY , \n Proposed Plaintiff -Intervenor , \n v. \nWALKER RIVER IRRIGATION \nDISTRICT , et al., \n Proposed Defendants . IN EQUI TY NO. C -125-RCJ \nSUBFILE No. C -125-C \n3:73-CV-OOI2 8-RCJ-WGC \n \nJOINDER BY COUNTY OF MONO \nTO WALKER RIVER IRRIGATION \nDISTRICT’ S MOTION TO VACATE \nSCHEDULE RELATED TO \nMOTIONS REGARDING BASIC \nTHRSHOLD JURISDICTIONAL \nISSUES, OR, IN THE \nALTERNATIVE, MOTION FOR \nSTATUS CONFER ENCE \n \n \n \n \n \n \n Case 3:73-cv-00128-RCJ-WGC Document 1 Filed 03/12/14 Page 1 of 2 \nJOINDER BY COUNTY OF MONO TO WALKER RIVER IRRIGATI ON DISTRICT’S MOTION (DOC # 743 ) \nPage 2 \n 1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31 \n Defendant County of Mono, by and through its counsel, Stacey Simon, Mono County \nAssistant County Counsel, hereby join s in the Walker River Irrigation District’s Motion to \nVacate Schedule Related to Motions Regarding Basic Threshold Jurisdict ional Issues, or, in the \nAlternative, Motion for Status Conference. \n \nDATED this 11th day of March, 2014 \n \n \n MONO COUNTY COUNSEL \n \n /s/ \n \n Stacey Simon, Assistant County Counsel \n Office of the Mono County Counsel \n 452 Old Mammoth Road, Third Floor \n P.O. Box 2415 \n Mammoth Lakes, CA 93546 \n PH (760)924 -1700 \n ssimon@mono.ca.gov \n \n Attorneys for Defendants Case 3:73-cv-00128-RCJ-WGC Document 1 Filed 03/12/14 Page 2 of 2"
} |
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"pdf_file": "KUHZYBRS6BEYSNUBQ3WGCKIFFDWLBVLM.pdf",
"text": " \n \n \n \nAugust 8, 2011 \n Dear Tribal Leader: \n We are pleased to announce the release of the congressionally-mandated Long Term Plan \nto Build and Enhance Tribal Justice Systems (Tri bal Justice Plan), which responds to sections \n211, 241, and 244 of the Tribal Law and Order Act. The U.S. Departments of Justice (DOJ) and \nInterior (DOI) were asked by Congress to develo p long-term plans to ad dress incarceration in \nIndian Country and alternatives to incarceration. We have furthe r enhanced the plan to include \noffender reentry. We appreciate and thank all those who commented on and helped to finalize \nthe Tribal Justice Plan. \n The Tribal Justice Plan is attached a nd may be accessed at the following web sites: \n• Bureau of Justice Assistance’s Tribal Law and Order Act: Implementation\n \n \n• National Congress of American Indians’ Tribal Law and Orde r Resource Center \nFollowing our public outreach to Indian Country on the draft Tribal Justice Plan, Indian \ntribes, advocates, and contractors submitted 40 comments, sharing their concerns and \nrecommendations. Each of these comments was discussed by DOJ and DOI staff, and most \nrecommendations were included in the final Tribal Justice Plan. \nDOJ and DOI will continue to work on the impl ementation of the Tribal Justice Plan with \ntribal leadership, tribal justice practitioners, and community residents. More information on \nimplementation meetings with federal and tribal representatives will be released later this \nsummer. For updates, please visit the Tribal Law and Order Act: Implementation page at \nwww.bja.gov/grant/tloa.html . \n \nSincerely, \nA. Elizabeth Griffith Carla Flanagan \nCo-Chair, DOJ-DOI Corrections Workgroup Co-Chair, DOJ-DOI Corrections Workgroup \nAssociate Deputy Director A ssociate Director of Corrections \nBureau of Justice Assistance Bureau of Indian Affairs U.S. Department of Justice U.S. Department of Interior \n \n"
} |
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"pdf_file": "X2T7N7IH7E45XFYXNJH5Q3AYJU4BEC57.pdf",
"text": "Date of Approval Letter: June 2, 2006 \nFREEDOM OF INFORMATION SUMMARY \nSUPPLEMENTAL NEW ANIMAL DRUG APPLICATION \n \n \n \nNADA 140-338 \nNAXCEL Sterile Powder \n(ceftiofur sodium) \n \n \nTo establish a 4-day pre-slaughter withdrawal period for cattle \n \n \nSponsored by: \nPharmacia & Upjohn Co., \na Division of Pfizer, Inc. \n \n \n \n \n \n \n \n1. GENERAL INFORMATION: \na. File Number: NADA 140-338 \nb. Sponsor: Pharmacia & Upjohn Co. \na Division of Pfizer, Inc. \n235 East 42d St. New York, NY 10017 \nDrug Labeler Code: 000009 \nc. Established Name: Ceftiofur sodium \nd. Proprietary Name: NAXCEL Sterile Powder \ne. Dosage Form: Sterile powder for reconstitution to injectable \nsolution \nf. How Supplied: 1 and 4 g glass vial \ng. How Dispensed: Rx \nh. Amount of Active Ingredients: 50 mg ceftiofur equivalents (CE) per mL of \nreconstituted solution \ni. Route of Administration: Intramuscular (IM) or subcutaneous (SC) injection \nj. Species/Class: Cattle; may be used in lactating dairy cattle \nk. Recommended Dosage: 0.5 to 1.0 mg ceftiofur per pound of body weight \n(1-2 mL reconstituted sterile solution per 100 lb body weight). Treatment should be repeated at 24-hour intervals for a total of three consecutive days. Additional treatments may be given on days four and five for animals which do not show a satisfactory response (not recovered) after the initial three treatments. \nl. Pharmacological Category: Antimicrobial \nm. Indications: NAXCEL Sterile Powder is indicated for treatment \nof bovine respiratory disease (shipping fever, pneumonia) associated with Mannheimia haemolytica , Pasteurella multocida, and \nHistophilus somni . NAXCEL Sterile Powder is \nalso indicated for treatment of acute bovine interdigital necrobacillosis (foot rot, pododermatitis) associated with Fusobacterium \nnecrophorum and Bacteroides melaninogenicus . \n \nn. Effect of Supplement: To establish a 4-day pre-slaughter withdrawal \nperiod for cattle \n \n2. EFFECTIVENESS: \n \nCVM did not require effectiveness studies for this supplemental approval. The FOI \nSummaries for the original approval of NAXCEL Sterile Powder (NADA 140-338) dated \nJanuary 25, 1988, and the supplemental approvals of NADA 140-338 dated April 5, 1990; August 24, 1995; and May 29, 2001, contain summaries of studies that demonstrate effectiveness of the drug for cattle. \n \n3. TARGET ANIMAL SAFETY: \n \nCVM did not require target animal safety studies for this supplemental approval. The FOI Summaries for the original approva l of NAXCEL Sterile Powder (NADA 140-338) \ndated January 25, 1988, and the supplemental approvals of NADA 140-338 dated April 5, 1990, and May 29, 2001, contain summaries of target animal safety studies for cattle. \n \n4. HUMAN FOOD SAFETY: \n \nA. Toxicology \nThe toxicity testing of ceftiofur is summarized in the FOI Summary for the original approval of NAXCEL Sterile Powder (NADA 140-338) dated January 25, 1988, and in the FOI Summary dated April 1996, for the original approval of EXCENEL RTU (ceftiofur hydrochloride) Sterile Suspension (NADA 140-890) for use in swine. \nTolerances for cattle are summarized in the FOI Summary for NAXCEL XT (now EXCEDE) Sterile Suspension (NADA 141-209) dated September 5, 2003. \nSafe concentrations are established for cattle as follows: \nMuscle: 4.4 ppm \nLiver: 13.2 ppm \nKidney: 26.4 ppm \nFat: 26.4 ppm \nInjection site: 166 ppm \nMilk: 0.320 ppm \nB. Residue Chemistry \nThe total residue depletion and metabolism in the target species and comparative metabolism in the toxicological species for ceftiofur are summarized in the FOI Summaries under NADA 140-338 and NADA 140-890. The following pivotal study was conducted to confirm applicable withdrawal periods in cattle. \n \n1. Study \n“Decline of ceftiofur and desfuroylceftiofu r-related metabolites in bovine tissues \nafter intramuscular administration of ceftiofur sodium (NAXCEL Sterile Powder) \nto cattle at a rate of 2.2 mg ceftiofur equivalents/kg body weight for five consecutive days”. Study Number: 2000-0427. June 2001. \nPrincipal Investigators: D.A. Merritt and M.J. Prough, Pfizer Animal Health, Kalamazoo, MI \nAnimal Species: Bovine \nBreed: Mixed breed \nNumber of Animals/Sex: 38; 18 male and 18 female (plus 1 male and 1 female control animals) \nWeights of Animals: 200 to 297 kg \nHealth Status: Clinically healthy \nRoute of Administration: Intramuscular (IM) injection \nDose Rate: 2.2 mg ceftiofur equivalents (CE)/kg body weight (actual dose 2.25 ± 0.03 mg CE/kg BW) \nDuration of Dosing: one injection daily for five consecutive days \nMarker Residue Depletion Data: Samples of kidney, liver, injection site, muscle, and fat were assayed for desfuroylceftiofur-related residue by the HPLC-DCA assay. The results of the assays are provided in Table 1. The limit of detection (LOD) of the assay was 0.05 ppm and the limit of quantification (LOQ) was 0.10 ppm. \nTable 1. Mean Concentration of Ceftiof ur and Desfuroylceftiofur-Related Residues \n(as DCA) in Bovine Tissues from Animals Receiving Five Doses of NAXCEL Sterile \nPowder (2.2 mg CE/kg BW) \nMean ± S.D., ppm \nTissue 3 hours 24 hours 48 hours 72 hours 96 hours 121 \nhours \nKidney 5.29 ± 0.79 1.00 ± 0.18 0.35 ± 0.08 0.20 ± 0.07 0.12 ± 0.02 < LOQ \nInjection \nsite 33 ± 18 0.94 ± 0.85 0.25 ± 0.07 0.15 ± 0.06 0.21 ± 0.13 < LOQ \nLiver 1.60 ± 0.25 0.19 ± 0.06 0.44 ± 0.13 < LOQ < LOQ < LOQ \nMuscle 0.36 ± 0.04 < LOQ < LOD < LOD <LOD NA \nFat 0.31 ± 0.15 < LOQ < LOD NA NA NA \nNA = not assayed \nBy 3 hours after the last dose, all injection sites contained less than 95 ppm DCA. \n2. Target Tissue and Marker Residue \n \nThe target tissue for residue monitoring is kidney. The marker residue in edible \ntissues, including milk, is the sum of ceftiofur and desfuroylceftiofur-related metabolites, measured by HPLC as the stable derivative desfuroylceftiofur acetamide (DCA). \n3. Tolerances \nCattle tolerances are: 0.4 ppm DCA in kidney, 2 ppm DCA in liver, 1 ppm DCA in muscle, and 0.1 ppm DCA in milk. For research purposes, a value of 95 ppm DCA has been established for making decisions regarding the safety of the injection site. \n4. Withdrawal Period \nThe kidney data were analyzed with a statistical method which determines the statistical tolerance limit for the 99\nth percentile of the population with \n95% confidence as outlined in FDA’s Guideline for Establishing a Withdrawal \nPeriod . The tolerance limit falls below the kidney tolerance of 0.4 ppm at 93 hours \nafter the last dose. The data support the assignment of a 96-hour (4-day) pre-slaughter withdrawal period for the IM treatment. \nBased on a comparison of residue data for the SC route of administration (FOI Summary for NADA 140-338 dated May 29, 2001) vs. that for the IM route, FDA also established a 4-day pre-slaughter withdrawal period for the SC treatment. \n5. Milk Discard \nThe milk tolerance has not changed. Consequently, no milk out data were required and the no discard can be maintained. \nC. Microbial Food Safety \nFDA concluded the impact of the proposed supplemental application on microbial food safety was not of a magnitude that required a hazard characterization or a full microbial food safety assessment. \nD. Analytical Methods for Residues \n \nThe regulatory method for determination of DCA in swine kidney and muscle, and bovine kidney, muscle, and milk is the HPLC-DCA assay which successfully completed a sponsor-monitored multi-laboratory method trial. The method is on file with the Center for Veterinary Medicine, Food and Drug Administration, 7500 Standish Place, Rockville, MD 20855. \n5. USER SAFETY: \nStudies to evaluate the safety of ceftiofur to users are discussed in detail in the original FOI Summary for NAXCEL Sterile Powder (NADA 140-338) dated January 25, 1988. \n \nHuman Warnings are provided on the product labeling as follows: \nNot for human use. Keep out of reach of children. \nPenicillins and cephalosporins can cause allergic reactions in sensitized individuals. \nTopical exposures to such antimicrobials, including ceftiofur, may elicit mild to severe allergic reactions in some individuals. Repeated or prolonged exposure may lead to sensitization. Avoid direct contact of the product with the skin, eyes, mouth and clothing. \nPersons with a known hypersensitivity to penicillin or cephalosporins should avoid exposure to this product. \nIn case of accidental eye exposure, flush with water for 15 minutes. In case of accidental skin exposure, wash with soap and water. Remove contaminated clothing. \nIf allergic reaction occurs (e.g., skin rash, hives, difficult breathing), seek medical attention. \n \nThe material safety data sheet contains more detailed occupational safety information. To obtain a material safety data sheet (MSDS) please call 1-800-733-5500. To report any adverse event please call 1-800-366-5288. \n \n6. AGENCY CONCLUSIONS: \nThe data submitted in support of this NADA satisfy the requirements of section 512 of the Federal Food, Drug, and Cosmetic Act and 21 CFR Part 514 of the implementing regulations. The data demonstrate that NAXCEL Sterile Powder, when administered according to the label directions, is safe and effective for the treatment of bovine respiratory disease (shipping fever, pneumonia) associated with Mannheimia \nhaemolytica , Pasteurella multocida, and Histophilus somni ; and for the treatment of \nacute bovine interdigital necrobacillosis (foot rot, pododermatitis) associated with Fusobacterium necrophorum and Bacteroides melaninogenicus . \nLabeling restricts this drug to use by or on the order of a licensed veterinarian. This \ndecision was based on the following factors: (a ) adequate directions cannot be written to \nenable lay persons to appropriately diagnose and subsequently use this product to treat bovine respiratory disease or foot rot, and (b) restricting this drug to use by or on the order of a licensed veterinarian should help prevent indiscriminate use which could result in violative tissue residues. \nIn accordance with 21 CFR 514.106(b)(2) this is a Category II change which did not \nrequire a reevaluation of safety and effectiveness data in the parent application. \nThis approval does not qualify for marketing exclusivity under section 512(c)(2)(F)(iii) of the Federal Food, Drug, and Cosmetic Act. \nNo patent information was submitted with this application. \n \n7. ATTACHMENTS: \nFacsimile labeling is attached as indicated below. \nA. NAXCEL Sterile Powder - 1 g vial and shipper carton label \nB. NAXCEL Sterile Powder - 4 g vial and shipper carton label \nC. NAXCEL Sterile Powder - package insert \n \n "
} |
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] | {
"pdf_file": "UA55FQO7YFJPF45VIJCGELKJ6KPWTIFY.pdf",
"text": "525 Environmental Protection Agency § 86.136–90 \nshall not be used to make this adjust-\nment. Dynamometers using automatic control of preselectable power settings may be set anytime prior to the begin-ning of the emissions test. \n(h) The driving distance, as measured \nby counting the number of dynamom-eter roll or shaft revolutions, shall be determined for the transient cold start, stabilized cold start, and transient hot start phases of the test. The revolu-tions shall be measured on the same roll or shaft used for measuring the ve-hicle’s speed. \n(i) Four-wheel drive and all-wheel \ndrive vehicles may be tested either in a four-wheel drive or a two-wheel drive mode of operation. In order to test in the two-wheel drive mode, four-wheel drive and all-wheel drive vehicles may have one set of drive wheels dis-engaged; four-wheel and all-wheel drive vehicles which can be shifted to a two- wheel mode by the driver may be test-ed in a two-wheel drive mode of oper-ation. \n[54 FR 14529, Apr. 11, 1989, as amended at 70 \nFR 72927, Dec. 8, 2005] \n§ 86.135–94 Dynamometer procedure. \nSection 86.135–94 includes text that \nspecifies requirements that differ from §86.135–90. Where a paragraph in §86.135–90 is identical and applicable to §86.135–94, this may be indicated by \nspecifying the corresponding paragraph and the statement ‘‘[Reserved]. For guidance see §86.135–90.’’ Where a cor-responding paragraph of §86.135–90 is not applicable, this is indicated by the statement ‘‘[Reserved].’’ \n(a) Overview. The dynamometer run \nconsists of two tests, a ‘‘cold’’ start test, after a minimum 12-hour and a maximum 36-hour soak according to the provisions of §§86.132 and 86.133, and a ‘‘hot’’ start test following the ‘‘cold’’ start by 10 minutes. Engine startup (with all accessories turned off), oper-ation over the UDDS and engine shut-down make a complete cold start test. Engine startup and operation over the first 505 seconds of the driving schedule complete the hot start test. The ex-haust emissions are diluted with ambi-ent air in the dilution tunnel as shown in Figure B94–5 and Figure B94–6. A di-lution tunnel is not required for test-ing vehicles waived from the require-ment to measure particulates. Six par-\nticulate samples are collected on fil-ters for weighing; the first sample plus backup is collected during the first 505 seconds of the cold start test; the sec-ond sample plus backup is collected during the remainder of the cold start test (including shutdown); the third sample plus backup is collected during the hot start test. Continuous propor-tional samples of gaseous emissions are collected for analysis during each test phase. For gasoline-fueled, natural gas- fueled and liquefied petroleum gas- fueled Otto-cycle vehicles, the com-posite samples collected in bags are analyzed for THC, CO, CO\n2, CH 4and \nNO X. For petroleum-fueled diesel-cycle \nvehicles (optional for natural gas- fueled, liquefied petroleum gas-fueled and methanol-fueled diesel-cycle vehi-\ncles), THC is sampled and analyzed continuously according to the provi-sions of §86.110. Parallel samples of the dilution air are similarly analyzed for THC, CO, CO\n2, CH 4and NO X. For nat-\nural gas-fueled, liquefied petroleum gas-fueled and methanol-fueled vehi-cles, bag samples are collected and analyzed for THC (if not sampled con-tinuously), CO, CO\n2, CH 4and NO X. For \nmethanol-fueled vehicles, methanol and formaldehyde samples are taken for both exhaust emissions and dilution air (a single dilution air formaldehyde sample, covering the total test period may be collected). Parallel bag samples of dilution air are analyzed for THC, CO, CO\n2, CH 4and NO X. Methanol and \nformaldehyde samples may be omitted for 1990 through 1994 model years when a FID calibrated on methanol is used. \n(b)–(i) [Reserved]. For guidance see \n§86.135–90. \n[56 FR 25775, June 5, 1991, as amended at 59 \nFR 48510, Sept. 21, 1994] \n§ 86.136–90 Engine starting and re-\nstarting. \n(a) Otto-cycle vehicles. Paragraph (a) \nof this section applies to Otto-cycle ve-hicles. \n(1) The engine shall be started ac-\ncording to the manufacturer’s rec-ommended starting procedures in the owner’s manual. The initial 20-second idle period shall begin when the engine starts. \nVerDate Aug<31>2005 08:05 Aug 07, 2008 Jkt 214159 PO 00000 Frm 00535 Fmt 8010 Sfmt 8010 Y:\\SGML\\214159.XXX 214159dwashington3 on PRODPC61 with CFR 526 40 CFR Ch. I (7–1–08 Edition) § 86.137–90 \n(2) Choke operation: (i) Vehicles \nequipped with automatic chokes shall be operated according to the manufac-turer’s operating instructions in the owner’s manual, including choke set-ting and ‘‘kick-down’’ from cold fast idle. \n(ii) Vehicles equipped with manual \nchokes shall be operated according to the manufacturer’s operating instruc-tions in the owner’s manual. \n(3) The transmission shall be placed \nin gear 15 seconds after the engine is started. If necessary, braking may be employed to keep the drive wheels from turning. \n(4) The operator may use the choke, \naccelerator pedal, etc., where necessary to keep the engine running. \n(5) If the manufacturer’s operating \ninstructions in the owner’s manual do not specify a warm engine starting pro-cedure, the engine (automatic and manual-choke engines) shall be started by depressing the accelerator pedal about half way and cranking the en-gine until it starts. \n(b) Diesel vehicles. The engine shall be \nstarted according to the manufacturers recommended starting procedures in the owners manual. The initial 20-sec-ond idle period shall begin when the en-gine starts. The transmission shall be placed in gear 15 seconds after the en-gine is started. If necessary, braking may be employed to keep the drive wheels from turning. \n(c) If the vehicle does not start after \nthe manufacturer’s recommended cranking time (or 10 continuous sec-onds in the absence of a manufacturer’s recommendation), cranking shall cease for the period recommended by the manufacturer (or 10 seconds in the ab-sence of a manufacturer’s rec-ommendation). This may be repeated for up to three start attempts. If the vehicle does not start after three at-tempts, the reason for failure to start shall be determined. The gas flow measuring device on the constant vol-ume sampler (usually a revolution counter) or CFV (and the hydrocarbon integrator and particulate sampling system when testing petroleum-fueled diesel vehicles and the particulate sampling system when testing meth-anol-fueled diesel vehicles, see §86.137) shall be turned off and the sampler se-lector valves, including the methanol \nsampler, placed in the ‘‘standby’’ posi-tion during this diagnostic period. In addition, either the CVS should be turned off, or the exhaust tube discon-nected from the tailpipe during the di-agnostic period. If failure to start is an \noperational error, the vehicle shall be rescheduled for testing from a cold start. \n(d) If the engine ‘‘false starts’’ the \noperator shall repeat the recommended starting procedure (such as resetting the choke, etc.). \n(e) Stalling. (1) If the engine stalls \nduring an idle period, the engine shall be restarted immediately and the test continued. If the engine cannot be started soon enough to allow the vehi-cle to follow the next acceleration as prescribed, the driving schedule indi-cator shall be stopped. When the vehi-cle restarts, the driving schedule indi-cator shall be reactivated. \n(2) If the engine stalls during some \noperating mode other than idle, the driving schedule indicator shall be stopped, the vehicle shall then be re-started and accelerated to the speed re-quired at that point in the driving schedule and the test continued. Dur-ing acceleration to this point, shifting shall be performed in accordance with §86.128. \n(3) If the vehicle will not restart \nwithin one minute, the test shall be voided, the vehicle removed from the dynamometer, corrective action taken, and the vehicle rescheduled for test. The reason for the malfunction (if de-termined) and the corrective action taken shall be reported to the Adminis-trator. \n[54 FR 14530, Apr. 11, 1989, as amended at 58 \nFR 16042, Mar. 24, 1993; 59 FR 48510, Sept. 21, 1994] \n§ 86.137–90 Dynamometer test run, gas-\neous and particulate emissions. \n(a) General —(1) Gasoline-fueled and \nmethanol-fueled Otto-cycle vehicles. The \nvehicle shall be allowed to stand with the engine turned off for a period of not less than 12 hours or more than 36 hours before the cold start exhaust emission test. The cold start exhaust test shall follow the diurnal breathing loss test by not more than one hour. The vehicle shall be stored prior to the \nVerDate Aug<31>2005 08:05 Aug 07, 2008 Jkt 214159 PO 00000 Frm 00536 Fmt 8010 Sfmt 8010 Y:\\SGML\\214159.XXX 214159dwashington3 on PRODPC61 with CFR"
} |
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] | {
"pdf_file": "VMAVPNCX4546X5JYE5USJNJDWXJKFQOL.pdf",
"text": "George Washington\n\"I wish from my soul that the legislature of this State could see a policy of a gradual Abolition of\nSlavery.\" (letter to Lawrence Lewis, August 4, 1797)\n \n---\n \nGeorge Washington was the Commander-in-Chief of the Continental Army and the first\nPresident of the United States of America.\n \n 1 / 1"
} |
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] | {
"pdf_file": "TQSAKC5ZXKO27EPBJ7HLTN2K3CW5L4MR.pdf",
"text": "Hinchey Announces $3.6 Million in Economic Recovery Funding For Local Housing Authorities\nTuesday, 24 March 2009 19:00\nWashington, DC - Congressman Maurice Hinchey (D-NY) today announced that the\nBinghamton, Ithaca, Kingston, Newburgh, Poughkeepsie, Monticello, and Woodridge Housing\nAuthorities will receive a total of $1.65 million in federal funds from the recently-approved\neconomic recovery bill. The funds, which Hinchey voted for, will be used to pay for a variety of\npublic housing projects that have been delayed due to a lack of funding. The Kingston Housing\nAuthority will receive $281,757 from the economic recovery package; the Housing Authority of\nNewburgh will receive $224,341; the Binghamton Housing Authority will receive $1,308,424; the\nIthaca Housing Authority will receive $649,230; the Poughkeepsie Housing Authority will receive\n$869,736; the Monticello Housing Authority will receive $193,712; and the Woodridge Housing\nAuthority will receive $81,855.\n \n\"These federal funds will help make improvements to local public housing units that have been\nneeded for some time, but have lacked the necessary federal funding,\" Hinchey said. \"This\neconomic recovery funding nearly doubles the amount of federal support given to local housing\nauthorities on an annual basis. These improvements and modernizations will help improve the\nlives of the residents and the quality of public housing abroad.\"\n \nAllocated through an established formula, this funding will allow local housing agencies to\naddress long-standing improvement needs to public housing units. It will also help to create jobs\nin the area and increase energy efficiency within public housing units. HUD's Capital Fund\nProgram provides annual funding to public housing authorities to develop, finance, and\nmodernize the public housing in their communities. This funding can also be used to make\nlarge-scale improvements such as new roofs; and for the replacement of plumbing and\nelectrical systems to more energy efficient standards.\n \nIn addition to the funds announced today, the U.S. Department of Housing and Urban\nDevelopment (HUD) will soon make an additional $1 billion available nationwide through a\ncompetitive grant process.\n \n 1 / 1"
} |
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] | {
"pdf_file": "HWWJCHPYGVP2VEQLTYB3Q2EQABOTUJ3U.pdf",
"text": "Weekly Metrics: April 7 - 13, 2013 \n \nMission \n(Launch \nDate) Instrument Category Data \nCenter RQMTS \n(GB) Requirements * \nMultiplier \n Actual \n(GB) Footnote \n HIRDLS L0 Ingest \nL1 Prod \nL2-3 Prod \nArchive Distribution \n End Users GES DISC \nSIPS \nSIPS \nGES DISC GES DISC \n5 \n \n \n \n1x Baseline \n \n 5 \n0 \n51 \n55 \n \n15 \nA \nA \n \n \nAura \n(7/04) MLS L0 Ingest \nL1 Prod \nL2-3 Prod \nArchive Distribution \n End Users GES DISC \nSIPS \nSIPS \nGES DISC GES DISC \n \n26 \n1 \n \n1x Baseline \n1x Baseline \n 7 \n41 \n8 \n56 \n \n27 \nL \nL \nL \n \nL \n OMI L0 Ingest \nL1 Prod L2-3 Prod \nArchive \nDistribution End Users GES DISC \nSIPS SIPS \nGES DISC \nGES DISC \n152 209 \n \n \n1x Baseline 1x Baseline \n 41 \n46 55 \n143 \n \n1,199 \nA A \n \n \n TES L0 Ingest \nL1 Prod \nL2-3 Prod Archive \nDistribution \n End Users ASDC \nSIPS \nSIPS \nASDC \nASDC 231 \n210 \n4 \n245 \n \n214 1x Baseline \n1x Baseline \n1x Baseline 1x Baseline \n \n1x Baseline 2 \n1 \n0.3 \n3 \n \n50 Q \nQ \nQ Q \n \nE \nSORCE \n(1/03) TIM/SIM/ \nSOLSTICE/ \nXPS L0 Ingest \nArchive GES DISC \nGES DISC 0.9 \n0.9 1x Baseline \n1x Baseline 0.8 \n0.8 B \n \nICESat \n(1/03) GLAS L0 Ingest \nL1 Prod \nL2-3 Prod \nArchive Distribution \n End Users NSIDC \nSIPS \nSIPS \nNSIDC NSIDC 41 \n115 \n43 \n199 \n \n161 1x Baseline \n1x Baseline \n1x Baseline \n \nVarious 0 \n3,295 \n0 \n3,295 \n \n720 F \nF, R \nF \nF, R \n \nE \n \nAqua \n(5/02) AIRS/ \nAMSU/ HSB L0 Ingest \nL1 Prod L2 - 3 Prod \nArchive \nDistribution \n \n End users GES DISC GES DISC GES DISC \nGES DISC \nGES DISC \n 183 \n99 \n2,071 \n2,259 \n \n5,743 \nL L \nL \n \nL \n AMSR-E L0 Ingest \nL1 Ingest \nL2-L3 Prod Archive \nDistribution \n End Users NSIDC \nNSIDC \nGHRC \nNSIDC \nNSIDC \n 10 \n28 \n77 \n114 \n 1x Baseline \nVarious \n3.045x Baseline \nBaseline \n \n 7 \n0 \n0 7 \n \n1,022 S, T \nD, S \nS S \n \nP \n CERES Archive \nDistribution \n Testing/QA End Users ASDC \nASDC 496 \n \n1,421 \n109 Various \n \nIT Requirements \n1.015x Baseline 1,115 \n \n0 \n42 J \n \n \n MODIS L0 Ingest \nL1 Prod \nL2-L4 Prod Archive MODAPS \nMODAPS \nMODAPS \nLP DAAC 518 \n \n \n7,034 1x Baseline \n \n \nVarious (L2-L4) 482 \n1,178 \n1,089 \n418 \nL \nI, L \nH \n Distribution \n Testing/QA \n End User Distribution \n End User \nDistribution \nEnd User \nDistribution \n End User NSIDC \nMODAPS \nLP DAAC \n \n \nNSIDC \n \nMODAPS \n \nOBPG 53 \n \n23 \n2,345 \n \n284 Various (L2-L3) \nVarious (L0-L4) \n \nIT Requirements \n1.015x Baseline \n \n 6 \n2,218 \n \n0 \n10,002 \n \n19 \n \n35,016 \n \n7,825 H \nG, L \n \n \nE, M \n \nE \n \nE, L \n \nU \nMEOTEOR \n3M \n(12/01) SAGE III Archive \nDistribution \n End Users ASDC \nASDC 0.9 \n \n0.02 Various \n \n1.015x Baseline 0 \n \n41 \n \n \nACRIMSAT \n(12/99) ACRIM 3 Archive ASDC 1 1x Baseline 0 B \n \n \n \n ASTER L1A Ingest \nL1B Ingest \nL1 Archive L2-L3 Prod \nArchive \nDistribution Production \n End Users LP DAAC \nLP DAAC \nLP DAAC LP DAAC \nLP DAAC \nLP DAAC \n 680 \n271 \n271 \n0 \n2,173 \n \n1,221 1x Baseline \n1.015x Baseline \n1.015x Baseline \nOn Demand \nVarious \n \n1.015x Baseline 156 \n22 \n178 \n0 \n179 \n \n1,433 \n2,748 J \nC, J \nC \n \nC \n \n \n CERES Archive \nDistribution Testing/QA \n End Users ASDC \nASDC 357 \n \n1,421 \n119 Various \n \nIT Requirements \n1.015x Baseline 1,693 \n \n0 \n847 J \n \nO \n MISR L0 Ingest \nL1 Prod L2-L3 Prod \nArchive \nDistribution \n End Users ASDC \nASDC ASDC \nASDC \nASDC 249 \n3,359 \n285 \n3,894 \n \n1,215 1x Baseline \nVarious \n3.045x Baseline \nVarious \n \n1.015x Baseline 254 \n1,113 \n152 \n1,520 \n \n110 \n \n \n \nE \nTerra \n(12/99) MODIS L0 Ingest \nL1 Prod L2-L4 Prod \nArchive \n \nDistribution \n Testing/QA End User \nDistribution \n End User \nDistribution \nEnd User \nDistribution \n End User MODAPS \nMODAPS MODAPS \nLP DAAC \nNSIDC \nMODAPS \nLP DAAC \n \nNSIDC \n \nMODAPS \n \nOBPG 518 \n \n7,034 \n853 \n \n \n23 \n2,345 \n \n284 1x Baseline \n \nVarious (L2-L4) \nVarious (L2-L3) Various (L0-L4) \n \nIT Requirements \n1.015x Baseline \n \n1.015x Baseline 483 \n1,212 \n764 \n485 \n6 \n1,861 \n \n0 \n17,825 \n \n88 \n \n24,162 \n \n2,833 \n K, L \nI, L \nH \nH \nG, L \n \n \nE, M \n \nE \n \nE, L \n \nU \n MOPITT L0 Ingest \nL1 Prod \nL2-L3 Prod \nArchive \nDistribution End Users ASDC \nSIPS \nSIPS \nASDC \nASDC 2 \n2 \n2 \n6 \n \n1 1x Baseline \nVarious \n3.045x Baseline \nVarious \n \n1.015x Baseline 2 \n1 \n8 \n10 \n \n2,092 \n \n \n \n \nE \n PR L0 Archive \nL1 Prod \nL2 - 4 Prod Archive GES DISC \nTSDIS \nTSDIS \nGES DISC \nRQMTS \nNot \nAvailable N/A \nN/A \nN/A N/A 3 \n14 \n5 \n22 \n \n Distribution \n End Users GES DISC \n \n1,554 \n \nTRMM \n(8/97) TMI L0 Archive \nL1 Prod \nL2 - 4 Prod \nArchive Distribution \n End Users GES DISC \nTSDIS \nTSDIS \nGES DISC GES DISC \n \nRQMTS \nNot \nAvailable \n N/A \nN/A \nN/A \nN/A 1 \n2 \n6 \n9 \n \n2,418 \n \n \n \n \n VIRS L0 Archive \nL1 Prod L2 - 4 Prod \nArchive \nDistribution \n End Users GES DISC \nTSDIS TSDIS \nGES DISC \nGES DISC \n \nRQMTS \nNot \nAvailable \n N/A \nN/A N/A \nN/A 4 \n21 \n1 \n26 \n \n377 \n \n \n \n \n \nNotes: \nA. Volume reported here represents what has been archived at DAAC. SIPS production volume could be different \nB. This instrument data are not transf erred to DAAC on a daily basis. \nC. Volumes of ASTER L1A and L1B products are a function of production at ERSDAC in Japan. L1A and L1B \nvolumes include the expedited data sets generated at LP DAAC. ASTER L2 products are produced on demand, and \nthe actual volumes may be significantly different from requirements. In June 2003, LPDAAC started to generate \nL1B products from L1A ingested. The total archive volume includes L1B products generated at LP DAAC. \nD. L1 data are produced in Japan. \nE. Distribution requirements represent the delivered capacity fo r distribution. Because dist ribution is based on user \norders, the actual distribution volumes may be significantly different from the available capacity. \nF. Fell to Earth on August 30, 2010. \nG. Includes all products archived at MODAPS. \nH. Archival of MODIS L2+ products are dependent on MODAPS processing schedule. Values reported here represent \nwhat have been archived at DAACs. MODAPS production volume could be different. \nI. Actual volume does not incl ude the MODIS ocean color products proces sed at SeaDAS (SeaWIFS Data Analysis \nSystem). \nJ. No information is available \nK. May include reprocessed products \nL. Does not include the Near Real-time (NRT) products \nM. Includes the distribution through MODIS Reprojection Tool Web (MRTWeb) interface \nN. All data products except L0 are being held for calibration validation. \nO. Represents the total amount of the CERES products distributed through LaRC ANGe and Orders. \nP. Includes the distribution through NSIDC Search Light. \nQ. Started limited science operation on April 25, 2012. \nR. Includes reprocessed data. \nS. Started experiencing anomaly on October 4, 2011. \nT. Operating in a 2-RPM mode for cross-calibration with AMSR-2 (no science data generated) \nU. Includes Sea Surface Temperature (SST) and ocean color pr oducts from MODIS \n \n* Baseline requirements refer to the May 20 03 EOSDIS technical baseline. The QA requ irements for distribution are the Level 2 \nrequirements based on inputs from instrument teams (ITs). The requirements multipliers are ramp-up factors to account for forwa rd \nprocessing and reprocessing. They varies, de pending on processing level and launch date . Ramp-up factors used in this table are : \n \nProcessing Level 1st year after launch 2nd year Launch+2 or more year \n L 0 1 1 1 \n L 1 A 1 2 3 \n L1B 1.015 2x1.015 3x1.015 \n L2-4 0.5*1.015 1.5*1.015 3*1.015 \nPlease note that browse data volumes for L1B-L4 products are assumed to be 1.5% of product volumes. "
} |
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"pdf_file": "T6UERWTWNYUVPT45YBOFTBSDVEH7SR2E.pdf",
"text": "IN THE UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF DELAWARE\nUNITED STATES OF AMERICA, :\n:\nPlaintiff, :\n:\nv. : Criminal Action No. 90-110-JJF\n:\n:Civil Action No. 01-442-JJF\nTHOMAS FLAHERTY, :\n:\nDefendant. :\n____________________________________\nColm F. Connolly, Esquire, United States Attorney, Richard G.\nAndrews, Esquire, Assistant United States Attorney of the UNITEDSTATES DEPARTMENT OF JUSTICE, Wilmington, Delaware.Attorney for Plaintiff. \nThomas Flaherty, Pro Se Defendant.\n_______________________________________\nMEMORANDUM OPINION\nJune 21, 2002\nWilmington, Delaware 2Farnan, District Judge.\nPending before the Court is a Motion To Renew Motion Under\n28 U.S.C. § 2255 And For Leave To Amend Motion Under 28 U.S.C. §2255 (D.I. 200) filed by Defendant, Thomas E. Flaherty. For thereasons set forth below, the Court will grant Defendant’s MotionTo Renew his Section 2255 Motion (D.I. 200), grant Defendant’sMotion For Leave To Amend his Section 2255 Motion (D.I. 200) anddeny Defendant’s Amended Section 2255 Motion (D.I. 189, 200).\nBACKGROUND\nOn November 15, 1990, Defendant was indicted on various drug\ncharges. Following a jury trial, Defendant was convicted of twocharges, conspiracy to distribute cocaine in violation of 21U.S.C. § 846 and distribution of cocaine in violation of 21U.S.C. §§ 841(a)(1), (b)(1)(C) and 18 U.S.C. § 2. On November15, 1991, Defendant was sentenced to 360 months imprisonment torun concurrently on the two charges. In sentencing Defendant,the Court concluded that Defendant was a “career offender”pursuant to Section 4B1.1 of the United States SentencingGuidelines (the “Guidelines”). The Court based its determinationupon Defendant’s previous convictions for a crime of violence anda controlled substance offense.\nOn April 14, 1997, Defendant filed a Section 2255 Motion. \n(D.I. 189). By his Motion, Defendant sought to collaterallyattack a state court conviction that had been used to enhance his 1Defendant filed a Motion For Expansion Of Time (D.I.\n205) to file a Reply Brief. However, Section 2255 and the RulesGoverning Section 2255 Proceedings do not contemplate the filing\n3federal sentence under Section 4B1.1 of the Guidelines. In his\nMotion, Defendant indicated that he had a state court collateralchallenge pending and that he filed his Section 2255 motion topreserve his right to seek Section 2255 relief if he wassuccessful in his state court proceedings. \nThereafter, the Court ordered Defendant to advise the Court\nof the status of his motion for state post-conviction relief.(D.I. 193). Defendant filed a letter in response to the Courtindicating that the motion was denied without a hearing, but anappeal was filed. Defendant represented that, as of November1998, his appeal was still pending in the state court system. \nAlthough several months transpired, the Court received no\nfurther updates on the progress of Defendant’s appeal. As aresult, the Court denied Defendant’s pending Section 2255 Motionwith leave to renew upon the disposition of Defendant’s statecourt action. (D.I. 198). Shortly thereafter, Defendant filedthe instant Motion renewing his Section 2255 Motion and seekingto amend the Motion to add a claim under Apprendi v. New Jersey\n,\n530 U.S. 466 (2000).\nThe Government has filed a response to Defendant’s Renewed\nSection 2255 Motion and his Motion For Leave To Amend. (D.I.204).\n1 Accordingly, the instant Motion is ripe for the Court’s of a traverse by the movant in response to the Government’s\nanswer, except in special circumstances. In this case, the Courtfinds that the issues are straightforward and capable ofresolution on the record currently before the Court. As such,the Court concludes that a traverse by Defendant is notwarranted, and therefore, Defendant’s Motion For Expansion OfTime will be denied. See\n e.g. United States v. Sanchez , 2002 WL\n465297 (E.D. Pa. Mar. 21, 2002) (denying defendant’s request forleave to file a traverse where issues were straightforward andcapable of being resolved on the record before the court).\n4review.\nDISCUSSION\nI. Defendant’s Motion To Amend His Section 2255 Motion To\nInclude An Apprendi\n Claim\nIn renewing his previously filed Section 2255 Motion,\nDefendant seeks to amend his Motion to include a claim that hissentence was invalid under Apprendi v. New Jersey\n, 530 U.S. 466\n(2000).\nIn determining whether Defendant should be permitted to\namend his original Section 2255 Motion to add an Apprendi claim,\nthe Court must consider Rule 15 of the Federal Rules of CivilProcedure. Riley v. Taylor\n, 62 F.3d 86, 89 (3d Cir. 1995). Rule\n15(a) provides that a party may amend his pleading once as amatter of course any time before a responsive pleading is filed. When amendment as a matter of course is not permitted, a partymay amend his pleadings by obtaining leave of court, which shouldbe freely given.\nRelying on United States v. Duffus\n, 174 F.3d 333, 337-338\n(3d Cir.), cert. denied , 528 U.S. 866 (1999), the Government 5opposes Defendant’s Motion To Amend on the ground that his\namendment does not relate back to his original claims, but addsan entirely new claim. However, the Duffus\n decision relied on\nthat portion of Rule 15 requiring leave of court to amend. Inthis case, however, it appears to the Court that Defendant soughtto add his Apprendi\n claim prior to the time that the Government\nfiled its responsive pleading. As such, Defendant was permittedto amend his petition as a matter of course to advance anApprendi\n claim. Accordingly, the Court will grant Defendant’s\nMotion For Leave To Amend his Section 2255 Motion.\nII. Defendant’s Amended Section 2255 Motion\nA. Defendant’s Apprendi Claim\nBy his renewed Section 2255 Motion, Defendant contends that\nhis sentence is invalid under Apprendi v. New Jersey , 530 U.S.\n466 (2000). Specifically, Defendant contends that he wasconvicted of two drug counts that did not specify the amount ofcocaine and that he was sentenced to a term of imprisonment thatexceeded the statutory maximum in violation of Apprendi\n.\nIn Apprendi , the United States Supreme Court held that\n“[o]ther than the fact of a prior conviction, any fact thatincreases the penalty for a crime beyond the prescribed statutorymaximum must be submitted to a jury, and proved beyond areasonable doubt.” Id.\n at 490. The Court of Appeals for the\nThird Circuit has recently concluded that Apprendi does not apply 6retroactively to cases on collateral review. In re Turner , 267\nF.3d 225, 231 (3d Cir. 2001) (joining majority view that Apprendi\nis not retroactive); United States v. Robinson , 2001 WL 840231\n(D. Del. Jul. 20, 2001) (Farnan, J.) (collecting cases). Accordingly, the Court concludes that Defendant is not entitledto relief on his Apprendi\n claim. \nIn the alternative, however, even if the Supreme Court were\nto subsequently make Apprendi retroactive to cases on collateral\nreview, the Court would conclude, as a substantive matter, thatDefendant has failed to establish a claim for a violation ofApprendi\n. In this case, Defendant was convicted of two drug\ncounts that did not specify the quantity of drugs. As such, themandatory minimum provisions of Section 21 U.S.C. § 841(b)(1)were not invoked. Rather, Defendant was sentenced in accordancewith 21 U.S.C. § 841(b)(1)(C) and 21 U.S.C. § 851, because he hada prior drug conviction. Pursuant to 21 U.S.C. § 841(b)(1)(C),Defendant was subject to a maximum period of incarceration of 30years imprisonment on each count. In this case, Defendant wassentenced to thirty years imprisonment to run concurrently onboth of his convictions. Because Defendant’s sentence did notexceed the statutory maximum penalty that he was subject to as aresult of his prior conviction, the Court concludes thatDefendant cannot establish a violation of Apprendi\n. United\nStates v. Pressler , 256 F.3d 144, 159 (3d Cir. 2001); United 7States v. Butch , 256 F.3d 171, 180 (3d Cir. 2001) (requiring\nunder first prong of Apprendi inquiry that defendant’s sentence\nexceed the “prescribed statutory maximum”); see also United\nStates v. Combs , 267 F.3d 1167, 1180-1181 (10th Cir. 2001)\n(“Apprendi does not require us to reverse where a sentence is\nequal to the statutory maximum.”). Accordingly, the Court willdismiss Defendant’s claim that his sentence violated Apprendi\n.\nB. Defendant’s Claim That He Was Sentenced Based On A \nConstitutionally Invalid Prior Conviction\nIn renewing his Section 2255 Motion, Defendant also requests\nthe Court to adjudicate the claim he initially advanced, i.e.that his sentence was enhanced by a prior state court convictionin Massachusetts that is constitutionally invalid. (D.I. 189).In his renewed Motion and attached affidavit, Defendant does notexpand on this claim other than to inform the court of thedisposition of his collateral attack. Specifically, Defendantstates that he was unsuccessful in pursuing his collateral attackin the Massachusetts appellate court. As for his appeal to theMassachusetts Supreme Court, Defendant contends that his appealwas rejected because it was not properly formatted and hiscounsel did not submit a corrected application. (D.I. 200,Flaherty Aff. at ¶¶ 1-4).\nThe United States Supreme Court has held that a defendant\ncannot collaterally attack a previous state court conviction usedto enhance a federal sentence through a federal Section 2255 2Defendant has not informed the Court of the grounds\nupon which he challenged his prior state court conviction ineither his original Section 2255 Motion or his renewed Motion,but Defendant has acknowledged that he “has no valid grounds tobase his section 2255 motion unless\n he receives a favorable\ndecision in the state court either modifying or vacating thestate conviction used to enhance his federal sentence.” (D.I.189 at 6) (emphasis in original). Accordingly, the Court doesnot believe that the Gideon\n exception applies in this case. \nFurther, because Defendant has not provided the Court with anyinformation about his state court conviction, the Court does notbelieve Defendant is trying to use the instant Section 2255Motion to substantively attack that conviction.\n8proceeding. Daniels v. United States\n, 532 U.S. 374, 382-383\n(2001). This rule applies to all federal constitutionalchallenges to the state court conviction, except for a challengethat the conviction was obtained in violation of the SixthAmendment right to court-appointed counsel established in Gideon\nv. Wainwright , 372 U.S. 335 (1963). Id. at 382. (“A defendant\nmay challenge a prior conviction as the product of a Gideon\nviolation, in a 2255 motion, but generally only if he raised thatclaim at his federal sentencing proceeding.”).\n2\nTo challenge a state court conviction used to enhance a\nfederal sentence, the defendant must pursue the remediesavailable for that conviction, i.e. direct appeal, post-conviction proceedings under state law and habeas corpus reliefpursuant to 28 U.S.C. § 2254. Id.\n at 381. If the defendant is\nsuccessful in such a challenge, the defendant may then apply toreopen his federal sentence. Id.\n at 381-382. However, if the\nprior conviction is no longer open for direct or collateral 9attack because the defendant failed to pursue his remedies or was\nunsuccessful in pursing them, then the conviction ispresumptively valid and may be used to enhance the defendant’sfederal sentence. Id.\nBased on Defendant’s affidavit, it appears that he was\nunsuccessful in challenging the state court conviction used toenhance his federal sentence in the Massachusetts state courts. Should Defendant be successful at some point in the future inchallenging that conviction through Section 2254 proceedings orrenewed state court proceedings, he can petition the Court toreopen his federal sentence. At this point, however, Defendanthas not established that the state court conviction used toenhance his federal sentence was invalid. Accordingly, the Courtwill dismiss Defendant’s claim to the extent that it challengesthe state court conviction used to enhance his federal sentence.\nCONCLUSION\nFor the reasons discussed, the Court will grant Defendant’s\nMotion To Renew his Section 2255 Motion, grant Defendant’s MotionFor Leave To Amend and deny Defendant’s Amended Section 2255Motion (D.I. 189, 200).\nAn appropriate Order will be entered. IN THE UNITED STATES DISTRICT COURT \nFOR THE DISTRICT OF DELAWARE\nUNITED STATES OF AMERICA, :\n:\nPlaintiff, :\n:\nv. : Criminal Action No. 90-110-JJF\n:\n:Civil Action No. 01-442-JJF\nTHOMAS FLAHERTY, :\n:\nDefendant. :\nO R D E R\nAt Wilmington, this 21st day of June 2002, for the reasons\nset forth in the Memorandum Opinion issued this date,\nIT IS HEREBY ORDERED that:1. Defendant’s Motion To Renew Motion Under 28 U.S.C. §\n2255 (D.I. 200) is GRANTED.\n2. Defendant’s Motion For Leave To Amend Motion Under 28\nU.S.C. § 2255 (D.I. 200) is GRANTED.\n3. Defendant’s Amended Motion To Vacate Sentence Under 28\nU.S.C. § 2255 (D.I. 189, 200) is DENIED.\n4. Because the Court finds that Defendant has not made “a\nsubstantial showing of the denial of a constitutional right”under 28 U.S.C. § 2253(c)(2), a certificate of appealability isDENIED.\n JOSEPH J. FARNAN, JR.\nUNITED STATES DISTRICT JUDGE"
} |
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] | {
"pdf_file": "GZ62LWSF6OMAXHC5VDCOYD53D7GSE2HO.pdf",
"text": "Draft \nBay Area to Central Valley HST Program EIR/EIS Appendix 2D \nPacheco Pass \n \n \n U.S. Department \nof Transportation Federal Railroad Administration Pacheco Pass\nPlan & Profiles\nPage 2-D-32\n \n \n"
} |
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] | {
"pdf_file": "5LJK3WBGEWURVXHBKF7FQP32FD7C7FQO.pdf",
"text": "Political Action Committee\nSTATEMENT OF ORGANIZATION\n(Utah Code Section 20A-11-801)\nInformation about the PAC\nUtah Broadcasters PACName of PAC Also known as\n1600 South Main St Salt Lake City UT84115Street Address Suite/Apartment/PO Box City StateZip\n? ?Name of PAC Primary Officer Title\n? ?Telephone Number Email Occupation\n? ? UT?Street Address Suite/Apartment/PO Box City StateZip\n? ?Name of PAC Primary Officer Title\n? ?Telephone Number Email Occupation\n? ? UT?Street Address Suite/Apartment/PO Box City StateZipInformation about the Primary Officers\n1\n2\nInformation about Chief Financial Officer or Treasurer\nName of the PAC Chief Financial Officer or Treasurer Title\n? ? UT?Street Address Suite/Apartment/PO Box City StateZip\nTelephone Number Email Occupation\nBusiness Address Suite/Apartment/PO Box City StateZip Information about all other Officers\nName of additional PAC Officer Occupation\nStreet Address Suite/Apartment/PO Box City StateZip"
} |
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] | {
"pdf_file": "SYBT26QCMSRHEOFZDZM4TZ5CCJ6T34MF.pdf",
"text": "FINAL \nFunctional Equivalent Document \nWater Quality Control Policy for Developing \nCalifornia's Clean Water Act Section 303(d) List \nSEPTEMBER 2004 \nDIVISION OF WATER QUALITY \nSTATE WATER RESOT JR CES CONTR OT .BOARD STATE WATER RESOURCES \nCONTROL BOARD \nPo mnn. . -. . - - \nSacramenlo, CA 95812-0100 \nTo request copies of the draH Final FED \nand proposed Policy please call \n(916) 341-5566. \nDocuments are also available at: \nhttp:/W.swrcb.ca.gov STATE WATER RESOURCES CONTROL BOARD \nDIVISION OF WATER QUALlTY \nFINAL FUNCTIONAL EQUIVALENT DOCUMENT \nWATER QUALITY CONTROL POLICY FOR DEVELOPING \nCALIFORNIA'S CLEAN WATER ACT SECTION 303(d) LIST \nFINAL \nSEPTEMBER 2004 This page intentionally left blank. PREFACE \nSection 303(d) of the federal Clean Water Act (CWA) and accompanying \nfederal regulations require states to regularly identify water bodies that \ncannot achieve applicable water quality standards after technology-based \ncontrols have been implemented. In complying, California has developed \nsuccessive lists of \"impaired\" water bodies biennially since 1976. After \n1996, public attention increasingly focused on an important consequence \nof \"section 303(d) listing\" -the development and implementation of Total \nMaximum Daily Loads (TMDLs). Simultaneously, public demand for \nregional consistency and transparency in the section 303(d) listing process \nintensified. \nIn response, the California Water Code (CWC) was modified to require \nthe State Water Resources Control Board (SWRCB) to prepare guidelines \nfor listing or delisting water bodies on the section 303(d) list (CWC \nsection 13191.3(a)). SWRCB regulations (Title 23 of the California Code \nof Regulations [CCR] section 3777(a)) independently require that an \nenvironmental review, equivalent to a CEQA document, accompany a \nPolicy proposed for SWRCB adoption. Such a \"functionally equivalent \ndocument\" (FED) must contain (a) a brief description of, (b) reasonable \nalternatives to, and (c) mitigation measures for the proposed activity. \nThis document is the final FED supporting a Policy for development of \nand revisions to a list of water quality limited segments, otherwise known \nas a section 303(d) list of water quality limited segments. This final FED \nexplores various alternatives, provides options and recommendations, and \nevaluates the environmental impacts of these guidelines. \nThe proposed \"Water Quality Control Policy for Developing California's \nCWA Section 303(d) List\" (Policy) is intended to provide SWRCB and \nRWQCB staff with recommended procedures for evaluating information \nsolicited in support of listing or delisting candidate water bodies for the \nsection 303(d) list. The Policy does develop new or revise existing \nwater quality standards (i.e., beneficial uses, water quality objectives, or \nthe State's Non-degradation Policy). The Policy does address scheduling \nof listed water bodies for eventual development and implementation of \nTMDLs. \nThe SWRCB held public hearings on January 28,2004 and February 5, \n2004 to hear public comment on the draft FED and Policy. SWRCB \nreceived testimony and written comments from 126 individuals or \norganizations. SWRCB staff responded to all comments received and the \ndraft FED and Policy have been revised in response. TABLE OF CONTENTS \nTABLE OF CONTENTS ............................................................................................................................................ \n i \nLIST OF TABLES ..................................................................................................................................................... \n iv \nLIST OF FIGURES .................................................................................................................................................... v \n..LIST OF ABBREVIATIONS .................................................................................................................................. va \nINTRODUCTION .................................................................................................................................................... ..1 \nPURPOSE 2 ................................................................................................................................................................ \nCEQA COMPLIANCE 2 ........................................................................................................................................... \nBACKGROUND 3 .......................................................................................................................................................... \nDeveloping the Scope of the Policy ............................................................................................................... 4 \nConsensus Recommendations of the PAC .................................................................................................... .....\n5 \nSCOPE OF FED ......................................................................................................... 5\n .................................... \nSTATEMENT OF GOAL S....................................................................................................................................... 5 \nACTION .................................................................................................................................................\n PROPOSED 6 \nENVIRONMENTAL SETTING ................................................................................................. .............................. 7 \nNORTH COAST REGION (REGION 1)...................................................................................................................... 7 \nSANFRANCISCO REGION (REGION 2) ............................................................................................................ .......\n16 \nCENTRAL REGION (REGION 18\n COAST 3) ................................................................................................................ \nLOS ANGELES REGION (REGION 4).................................................................................................................... .21 \nCENTRAL VALLEY REGION (REGION 5) ....................................................................................................... ..........\n23 \nLAHONTAN REGION (REGION 6) 27 \nCOLORADO RIVER BASIN REGION (REGION 7) .................................................................................................. ..31 \n......................... ..... SANTA ANA REGION (REGION 8) ................................................................................. ........\n34 \nSANDIEGO REGION (REGION 9) .................................................................................................................... ......\n35 \nISSUE ANALYSIS .................................................................................................................................................... 39 \nISSUE 1: SCOPE OF THE LISTING/~ELISTING POLICY ..................................................................................... .....40 \nISSUE 2: STRUCTURE OFTHE SECTION 303(~) LIST ....................................................................................... ..43 \nISSUE 3: WEIGHT OF EVIDENCE AND DELISTING FOR LISTING ............... ...................................................... 54\n : \nISSUE 4: LISTING WITH SINGLE LINE OFEVIDENCE OR DELISTING ............................................................... ...\n58 \nIssue 4A: Interpreting Numeric Water Quality Objectives and Criteria ...................................................... 59 \nIssue 48: Interpreting Numeric Marine Bacterial Water Quality Standards ............................................... 63 \n. . Issue 4C: Interpreting Numeric Freshwater Bacterial Water Quality Standards ......................................... 73 \nIssue 40: Interpreting Narrative Water Quality Ob~ectrves .......................... ... 75\n .......................................... \nIssue 4E: Interpreting Aquatic Life Tissue Data ......................................................... ............................ ...\n81 \nIssue 4F: Interpreting Data on Trash Impacts to Water Bodies ................................................................ 88 \nIssue 417: Interpreting Nutrient Data ............................ ..:.................................................................. ......92 \nIssue 4H: Impacts of Invasive Species on Water Quality 97 \nISSUE 5: OR DELISTING LINES OF EVIDENCE ............................................................ 81\n L~ST~NG WITH MULTIPLE \nIssue 5A: Interpreting Heahh Advisories ................................................................................................ .103 \nIssue 5B: Interpreting Data Related to Nuisance ..................................... ........................................ ....\n109 \nIssue 5C: Interpreting Toxicity Data .................................................................................................. .......\n113 \nIssue 5D: Interpreting Sedimentation Data ............................................................................................ ..127 \nIssue 5E: Interpreting Temperature Wafer Quality Objectives ............................................................ 132 \nIssue 5F: Interpreting Data Related to Adverse Biological Response ...................................................... 136 \n. . \n11 Issue 5G: Degradation of Biological Populations or Communities .......................................................... I39 \nIssue 5H: Trends in Water Qualify ..............................................................................................................\n IS0 \nISSUE 6: STATISTICALEVALUA~ON WATER QUALITY 154 OF NUMERIC DATA................................................. \nIssue 6A: Selection of Hypotheses to Test ............................................................................................... ....158 \nIssue 68: Choice of Statistical Tests for the Evaluation of Water Qualify Data .......................................... I64 \nIssue 6C: Critical Rate of Exceedances of Water Qualify Standards ......................................................... ..183 \nIssue 60: Selection of Statistical Confidence and Power Levels ........................................................... 195 \nIssue 6E: Minimum Sample Size ........................................................................................................ .........\n209 \nIssue 6F: Quantitation of Chemical Measurements .................................................................................. .214 \nISSUE 7: POLICY IMPLEMENTATI ..............................................................................................................ON .\n218 \nIssue 7A: Review of the Existing Section 303(d) List .......................................................................... ........219 \nIssue 7B: Defining Existing Readily Available Data and Information ................................................... 222 \nIssue 7C: Process for Soliciting Data and Information and Approval of the List ....................................... 224 \nIssue 70: Documentation of Data and Information .............................................................................. 229 \nIssue 7E: Data Qualify Requirements .................................................................................................... ..232 \nIssue 7F: Spatial and Temporal Representation .................................................................................. .......\n236 \nIssue 7G: Data Age Requirement ......................................................................................................... ....239 \nIssue 7H: Determining Water Body Segmentation ............................................................................... .......\n242 \nIssue 71: Natural Sources of Pollutants ............................................................................................ .........\n245 \nISSUE 8: RANKING SCHEDU PRIORITY AND TMDL COMPLETION LE\n............................................................. 247 \nENVIRONMENTAL EFFECTS OF THE PROPOSED POLICY ................................................................... .250 \nBASELIN E............................................................................................................................................... .............\n250 \nPOTENTIALLY ADVERSE EFFECTS ..................................................................... 251 SIGNIFICANT ENVIRONMENTAL \nIssue I: Scope of the LisringDelisting Policy ........................................................................................... ....\n251 \nIssue 2: Structure of Section 303(d) List ................................. ............................................................... .......\n252 \nIssue 3: Weight of Evidence for Listing and Delisting .............................................................................. .....\n253 \nIssue 4: Listing or Delisting with a Single Line of Evidence ....................................................................... ...\n254 \nIssue 5: Listing or Delisting with Multiple Lines of Evidence ....................................................................... 260 \nIssue 6: Statistical Evaluation of Numeric Water Quality Data .................................................................... 264 \nIssue 7: Policy Implementation ................................................................. 266\n .................................................. \nIssue 8: Priority Ranking and TMDL Completion Schedule ....................................................................... 269 \nGROWH-INDUCING\n IMPACTS .......................................................................................................................... .270 \nCUMULATIVE AND LONG-TERM IMPACTS ............. ....................................................................................... ...\n271 \nENVIRONMENTAL CHECKLIST ..................................................................................................................... 273 \nGLOSSARY ........................................................................................................................................................... .283 \nREFERENCES ..................................................................................................................................................... ..289 \nAPPENDIX A: Draft Water Quality Control Policy ......................................................................................... A-1 \nAPPENDIX B: Responses to Comments ............................................................................................................... B-1 \n LIST OF TABLES \nTABLE 1: \tTOTAL WATER BODIES BY REGION. WATER BODY TYPE AND \nESTIMATED ON THE 2002 SECTION LIST................................................. 8 SIZE APPECTED 303(~) \nTABLE 2: GUIDELINES FOR THE INTERPRETATION OF NARRATIVE AVAILABLE \nWATER QUALITY OBECTWES ....................................................................................................\n 78 \nTABLE 3: \t WILDLIFE FOR EVALUATION OF PROTECTION CRITERIA \nBIOACCUMULATION MONITORING DATA ................................................................................ 84 \nTABLE 4: \t SCREENING VALUES FOR THE PROTECTION HEALTH OF HUMAN \nFROM THE CONSUM~ON AND SHELLFISH ...................... ....................................... 86 OF FISH \t .. \nTABLE 7: \t MARINE TESTS WATER TOXICITY ........................................................................................ 116 \nTABLE \t FRESHWATER SEDIMENT AND POREWATER ORGANISMS ................................\n 9: WHOLE TEST 118 \nTABLE 10: FOR MARINE AND SEDIMENT- CHRONICTESTS SEDIMENTPORE WATER ..............................................................................................................\n WATER INTERFACE 118 \nTABLE 11: TE PROCEDURES FOR EFFLUENT AND AMBIENT WATER. SEDIMENT \nEULTRIATE. PORE WATER. AND LEACHATES ........................................................................ 121 \nTABLE 12: SEDIMENT QUALITY GUIDELINES ESTUARINE. FOR MARINE. \nAND FRESHWATER ............................. 122 SEDIMENTS ................................................................. \nTABLE 13: COMPARISON TESTS OF STATISTICAL AND QUANTITATIVE \nAVAILABLE 303(D) ANALYSES ....................................................................... FOR SECTION 165 \nTABLE 14: BY USEPA ........................................................ CRITICALEXCEEDANCERATES PROPOSED \t 184 \nTABLE 16: \t ESTIMATED FOR TOXICANTS COSTS OF SAMPLING AND ANALYSIS USING \n20 PERCENT AND USING \n ALPHA AND BETA FOR LISTING DECISIONS \n10PERCENT \t .............................................................................\n FOR DELISTING DECISIONS 202 \nTABLE 17: COSTS OF SAMPLING AND ANALYSIS FOR CONVENTIONAL ESTIMATED \nPOLLUTANTS USING 20 PERCENT ALPHA AND BETA........................................................ 204 \nTABLE 18: \t USEPA GUIDANCE OF MEASUREMENTS ON INTERPRETATION \nBELOW DETECTION 216 ............................................................................................................... \n LIST OF FIGURES \nFIGURE 1: \tNORTH COAST BASIN..........................................................................................\n REGION HYDROLOGIC \t 15 \nFIGURE 2: \tSANFRANC~SCO .............................................................................. 17\n BAY REGION HYDROLOG~C BASIN \nFIGURE 3: \t HYDROLOGIC ..................................................................................... 20\n CENTRAL COASTREGION GASIN \nFIGURE 4: \tLOS ANGELES REGION HYDROLOGIC ....................................................\n BASIN.............................. .. \t 22 \nFIGURE 5: VALLEY \t REGION HYDROLOG~C .................\n CENTRAL REGION. SACRAMENTO BASIN ......................... 24 \nFIGURE CENTRAL HYDROLOGIC ........................................................ 25\n 6: VALLEY REGION. SANJOAQU~N BASIN \nFIGURE 7: \t REGION. TULARE BASIN......................................................... 26\n CENTRALVALLEY LAKE HYDROLOGIC \nFIGURE 9: REGION. SOUTH LAHOWTAN HYDROLOGIC ............................................................ 29\n LAHONTAN \t BASIN \nFIGURE 11: SANTA HYDROLOGIC ............................................................................................. 36\n ANAREGION BASIN \nFIGURE 12: SAN DIEGO REGION HYDROLOGIC ............................................................................................ 37\n BASIN \nFIGURE 13: NUTRIENT LISTING OPTIONS FLOW CHART ........................................................................................... 96 \nFIGURE 15: TYPE I ERROR \t (WITH 10% AND 20% RATES FOR EXACTBINOMIALTEST \nTYPEI ERROR FREQUENCY) AND THE \n RATES AND 10%EXCEEDANCE \nUSEPA RAW SCORE IvlETHOD .................................... ................................................................... 173 \nFIGURE 16: TYPEII \t (WITH 10% AND 20% ERROR RATES FOR EXACTBINOMIALTEST \nTYPE 1ERROR AND THE \n RATES AND 10% EXCEEDANCEFREQUENCY) \nUSEPA RAW SCORE METHOD .............................................................................................................. 174 \nFIGURE 17: PROBABILITLES OF REJECTING (SOLID LINE) AND NOT REJECTING \n(DASHED LINE) THE STANDARD NULL HYPOTHESIS HO: R < RI = 0.1 \nWHEN USING THE BINOMIALMODEL .................................................................................................... 177 \nFIGURE 18: \t PROBABILITIES OF REJECTING (SOLID LINE) AND NOT REJECTING \n(DASHED LINE) THE REVERSE NULL HYPOTHESIS HG: R > RI = 0.1 \nWHEN USING THE BINOMIALMODEL ............................................................................................... 178 \nFIGURE \t 06 EFFECT SIZE (a=P) ........................... 180\n 19: VISUALREPRESENTATION \t ............................................. \nFIGURE 20: \t STATISTICAL DECISION-MAKING RATES FOREXCEEDANCE ERROR \nFREQUENCIES USED IN THE DRAFT SWRCB POLICY (DECEMBER .......................... 2. 2003 VERSION) 198 \nFIGURE 21: \t BALANCED ERROR RATES ASSOCIATED WITH THE SAMPLING PLAN FOR \nRI = 3 PERCENT AND R2 = 18 PERCENT WITH EFFECT SIZE = 15 PERCENT ....................................... 205 \n FIGURE ERROR RATES ASSOCIATED WITH THE SAMPLING PLAN FOR 22: \tBALANCED \nRl = 10 PERCENT AND R2 = 25 PERCENT WITH EFFECT SIZE = 15 PERCENT. ........................................ 206 \nFIGURE OF DECEMBER 23: \tCOMPARISON 2003 VERSION OF LISTING POLICY VERSUS \nBALANCED ERROR SAMPLING NOTATION OR DELIST(R~, ................. 207 PLANS. USED IS LIST(R~, R~) R~). \nFIGURE \t 211 24: \t LISTING WITH TWO EXCEEDANCES ........................................................................................................ \nFIGURE COMPARISON \t WATERS 25: \tGRAPHICAL OF THE NUMBER OFDECIS~ONS TO PLACE \nON THESECTION 303(D) LIST ............................................................................................................... 212 \nFIGURE 26: INTERPRETING DATA WHEN MEASUREMENTS ARE LESS THAN OR EQUAL TO \nTHE QUANTITATION (QL) AND THE WATER QUALITY OBJECTIVE IS \n LIMIT \nGREATERTHAN THE QL....................................................................................................................... 215 \nFIGURE 27: \t INTERPRETING DATA WHEN MEASUREMENTS ARE LESS THAN OR EQUAL TO THE QL AND THE WATER \nQUALITY OBJECTIVE IS LESS THAN THE QL....................................................................................... 216 LIST OF ABBREVIATIONS \nAB Assembly Bill \nAGR Agriculture water supply beneficial use category \na Type I error rate (alpha) \nAP A Administrative Procedure Act \nASTM American Society of Testing Materials \nP Type 11error rate (beta) \nBCF bioconcentration factor \nBMI benthic macroinvertebrates index \nBMP best management practice \nBOD bioIogical oxygen demand \nBPJ best professional judgment \nBPTCP Bay Protection and Toxic Cleanup Program \nBWQW Beach Water Quality Workgroup \n\"C degrees Celsius \nOF degrees Fahrenheit \nCalEPA California Environmental Protection Agency \nCALM Consolidated Assessment and Listing Methodology \nCAMLnet California Aquatic Bioassessment Laboratory Network \nCCR California Code of Regulations \nCEQA California Environmental Quality Act \nCFR Code of Federal Regulations \nCOD chemical oxygen demand \nCOMM Commercial and recreational fisheries beneficial use category \nCSBP California Stream Bioassessment Procedures \nCTR California Toxic Rule \nCWA Clean Water Act \nC WC California Water Code \nDDT dichlorodiphenyltrichloroethane \nDEP Department of Environmental Protection \nDEQ Department of Environmental Quality \nDFG California Department of Fish and Game \nDHS California Department of Health Services \nDO dissolved oxygen \nDOC dissolved organic carbon \ndw dry weight \nEDL Elevated Data Level \nEIR Environmental Impact Report \nEMAP Environmental Monitoring and Assessment Program \nEqp equilibrium partitioning \nERL Effects Range-Low \nERM Effects Range-Median \nFED Functional Equivalent Document \nGIs Geographic Information System \nHa alternate hypothesis \nvii IBI \nIND \nIRIS \nk \nkdelist \nklist \nMCL \nmg/kg \nmg/L \nmm \nMSD MTRL \nMUN \nMWAT \nN \nNAS \nNAV \nNAWQA \nng/kg\nNMFS NOAA \nNPDES \nNPS NSSP \nNTU \nOC \nOC \nOEHHA \nONRW \nP \nPA,H \nPCB PEC \nPEL \npH\nPHG \nPOW \nPP \nQA \nQC \nQAPP \nQL null hypothesis \nIncomplete beta function \nindex of biological integrity \nIndustrial process supply beneficial use category \nIntegrated Risk Information System \nnumber of exceedances in a sample \nmaximum number of exceedances to remove a water \nbodylpollhtant combination from the list \nminimum number of exceedances to list \nmaximum contaminant level \nmilligrams per kilogram (parts per million) \nmilligrams per liter (parts per million) \nmillimeter \nminimum significant difference \nMaximum Tissue Residue Level \nMunicipal beneficial use category \nmaximum weekly average temperature \nsample size \nNational Academy of Sciences \nNavigational beneficial use category \nNational Water Quality Assessment Program \nnanograms per kilogram \nNational Marine Fishery Service \nNational Oceanic and Atmospheric Administration \nNational Pollutant Discharge Elimination System \nnonpoint source \nNational Shellfish Sanitation Program \nnephelometric turbidity unit \norganic carbon \noperating characteristics curve \nOffice of Environmental Health Hazard Assessment \noutstanding national resource water \nProbability \nEstimate of the true proportion of samples \nPublic Advisory Group \nPolynuclear Aromatic Hydrocarbon \npolychlorinated biphenyl \nProbable Effects Concentration \nProbable Effects Level \nHydrogen ion concentration \nPublic Health Goal \nHydropower generation beneficial use category \nPrecautionary Principle \nquality assurance \nquality control \nquality assurance project plan \nquantitatioa limit \nviii r \nREC \nREMAP \nRIVPACS \nRMP \nRTAG \nRWQCB \nSB SCCWRP \nSFEI \nSMWP \nSNARL \nSNARLS \nSQG \nSTRTAG \nSWAMP SWMP \nSWRCB \nTDS TEL TIE TKP TMDL \nTOC \nTSD \nTSS \nUSC \nUSEPA \nUSFDA \nUSFS \nUSGS v* \nWDR \nWQ \nWQC \nWQO \nWW exceedance rate \nRecreational beneficial use category \nRegional Environmental Monitoring and Assessment Program \nRiver Invertebrate Prediction and Classification Scheme \nregional monitoring program \nRegional Technical Advisory Group \nRegional Water Quality Control Board \nSenate Bill \nSouthern California Coastal Water Research Project \nSan Francisco Estuary Institute \nState Mussel Watch Program \nSierra Nevada Aquatic Research Laboratory \nsuggested no-adverse-response levels \nsediment quality guideline \nState Regional Technical Advisory Group \nSurface Water Ambient Monitoring Program \nStorm Water Management Plan \nState Water Resources Control Board \nTotal Dissolved Solids \nThreshold Effects Level \nToxicity Identification Evaluation \nTotal Kjeldahl phosphorus \nTotal Maximum Daily Load \nTotal Organic Carbon \nTechnical Support Document \nTotal Suspended Solids \nmicrograms per liter (parts per billion) \nUnited States Code \nU.S. Environmental Protection Agency \nU.S. Food and Drug Administration \nU.S. Forest Service \nU.S. Geological Survey \nsediment evaluation tool \nwaste discharge requirement \nwater quality \nWater Quality Criteria \nWater Quality Objective \nwet weight This page intentionally left blank. FINAL FUNCTIONAL EQUIVALENT DOCUMENT: \nWATER QUALITY CONTROL POLICY \nFOR DEVELOPING CALlFORNIA'S \nCLEAN WATER ACT SECTION 303(d) LIST \nINTRODUCTION \nSection 303(d)(l) of the federal Clean Water Act (CWA) requires states to \nidentify waters that do not meet applicable water quality standards with \ntechnology-based controls alone and prioritize such waters for the \npurposes of developing Total Maximum Daily Loads (TMDLs) (40 Code \nof Federal Regulations (CFR) 130.7@)). Water quality limited segments \nare defined as \"any segment [of a water body] where it is known that \nwater quality does not meet applicable water quality standards, andlor is \nnot expected to meet applicable water quality standards, even after \napplication of technology-based effluent limitations required by [CWA] \nsections 301(b) or 306.. .\" (40 CFR 130.2u)). The states are required to \nassemble and evaluate all existing and readily available water quality- \nrelated data and information to develop the list (40 CFR 130.7(b)(5)) and \nto provide documentation to list or not to list a state's waters (40 CFR \n130.7(b)(6)). \nSection 13191.3(a) of the California Water Code (CWC) requires the State \nWater Resources Control Board (SWRCB), on or before July 1,2003, to \nprepare guidelines to be used by the SWRCB and the RWQCBs (Regional \nWater Quality Control Boards) in listing, delisting, developing, and \nimplementing TMDLs pursuant to section 303(d) of the federal CWA \n(33 United States Code [USC] section 1313(d)). In addition, the 2001 \nBudget Act Supplemental Report required the use of a \"weight of \nevidence\" approach in developing the Policy for listing and delisting \nwaters and to include criteria that ensure the data and information used are \naccurate and verifiable. \nCWC section 13191.3(b) also requires the SWRCB to consider the \nconsensus recommendations on the guidelines adopted by the Public \nAdvisory Group (PAG). California kssembly ~ili(~~) 982 PAG was \nestablished in 2000 to assist in the evaluation of the SWRCB's water \nquality programs structure and effectiveness as it relates to the \nimplementation of section 303(d) of the CWA (33 USC section 1313 (d)) \nand applicable federal regulation. The PAG has of twelve members from \nthe regulated community and twelve members from the environmental \ncommunity. Each member has an alternate representative. Purpose \nThe purpose of this Functional Equivalent Document (FED) is to present \nalternatives and SWRCB staff recommendations for the development of a \nWater Quality Control Policy to guide the RWQCBs in the development \nof the CWA section 303 (d) list. The FED also assesses the potential \nadverse environmental impacts of the recommended Policy. \nCEQA Compliance \nThe SWRCB must comply with the requirements of the California \nEnvironmental Quality Act (CEQA) and the Administrative Procedure Act \n(APA) when adopting a plan, policy or guideline. CEQA provides that a \nprogram of a State regulatory agency is exempt from the requirements of \npreparing Environmental Impact Reports (EIRs), Negative Declarations, \nand Initial Studies if certain conditions are met. The process the SWRCB \nis using to develop the Policy has received certification from the \nResources Agency to be \"functionally equivalent\" to the CEQA process \n(Title 14 CCR section 15251(g)). Therefore, this FED fulfills the \nrequirements of CEQA for preparation of an environmental document. \nAs part of a certified regulatory program, the proposed Policy is exempt \nfrom Chapter 3 of CEQA that requires state agencies to prepare EIRs and \nNegative Declarations (Resources Code section 21080.5). Agencies \nqualifying for this exemption must comply with CEQA's goals and \npolicies, evaluate environmental impacts, consider cumulative impacts, \nconsult with other agencies with jurisdiction, provide public notice and \nallow public review, respond to comments on the draft environmental \ndocument, adopt ~~~~-findin~s, and provide for monitoring of mitigation \nmeasures. SWRCB regulations (CCR Title 23, Chapter 27, section 3777) -\nrequire that a document under its certified regulatory programs \nmust include: \n1. \ta brief description of the proposed activity; \n2. \treasonable alternatives to the proposed activity; and \n3. \tmitigation measures to minimize any significant adverse \nenvironmental impacts of the proposed activity. \nA certified regulatory program is exempt from the requirement to prepare \nan EIR or Negative Declaration but must comply with other CEQA \nrequirements. The SWRCB will, therefore, prepare the FED following \nCEQA guidelines. The environmental impacts that may occur as a result \nof the Policy are summarized in an Environmental Checklist and analyzed \nin the Environmental Effects section of the FED. Background \nThe listing of water bodies pursuant to CWA section 303(d) has evolved \nover time. The first section 303(d) list was assembled in 1976. This \ninitial list identified less than 20 water bodies in the section 305(b) report \nas \"Water Quality Limited Segments\". The \"Water Quality Limited \nSegments\" list remained virtually the same until 1988, when the number \nof water quality limited segments increased to 75 water bodies. In 1990, \nthe list grew to approximately 250 water quality limited segments due in \npart to an increase in water quality assessment activity resulting from \namendment of the CWA. CWA section 304 required lists of impaired \nwaters and sources to be submitted to U.S. Environmental Protection \nAgency (USEPA) as a \"one time\" effort. The list included waters (1) not \nachieving numeric water quality standards for priority pollutants after \nimplementation of technology-based controls, (2) not meeting the \nfishablelswimmable goals of the Act, and (3) not meeting applicable \nstandards after technology-based controls were met due primarily to point \nsource discharge of toxic pollutants. \nIn 1997, the SWRCB and RWQCB staff prepared informal guidance for \nthe water quality assessment update. That guidance outlined procedures \nfor the RWQCBs assessment process. The assessment methodology \nrecommended: (1) reevaluation of the listed water bodies on the 1996 \nsection 303(d) list, (2) reviewing new monitoring information, \n(3) consistent procedures for the information soliciting process, and \n(4) measures to increase public participation. The RWQCBs staff used \nthese guidelines to establish public noticing procedures, list or delist water \nbodies, and prioritize and schedule TMDLs. \nIn 1998, 509 water bodies were listed with 1,471 water bodylpollutant \ncombinations. This 1998 section 303(d) list served as the basis for the \n2002 list. The State and USEPA-approved 2002 section 303(d) list has a \ntotal of 685 water quality limited segments and 1,883 segment-pollutant \ncombinations (SWRCB, 2003a; USEPA, 2003d). \nDuring the development of the section 303(d) list in 2002, the RWQCBs \nassembled and evaluated all new available water quality data and \ninformation and provided recommendations for each water body-pollutant \ncombination. The RWQCBs prepared staff reports, fact sheets, and \nsummaries of the additions, deletions and changes to the 1998< \nsection 303(d) list in order to create the 2002 list. The SWRCB staff \nreviewed the RWQCBs staff recommendations and either concurred or \nidentified the reasons for not concurring with the RWQCB \nrecommendations. \nIn preparing the 2002 section 303(d) list, the SWRCB set Priorities and \nSchedules for Completing TMDLs as required by federal law for listed \n3 water bodies to help guide TMDL planning (40 CFR 130.7@)(4)). Federal \nregulations also require the state to identify waters targeted for TMDL \ndevelopment in the next two years. \nIn addition to the section 303(d) list the following related lists were \ncompiled in 2002: \nTMDL Completed List. This list included water bodies where a number \nof TMDLs have been completed to show progress in developing TMDLs. \nThe TMDLs Completed List contained those water quality limited \nsegments that already had TMDLs with approved implementation plans. \nEnforceable Programs List. This list included water bodies where an \nalternate regulatory program was already in place to address the water \nquality problem. Regulatory programs included the Consolidated Toxic \nHot Spots Cleanup Plan and enforcement of existing permits or other \nlegally required authorities. The programs and requirements were \nspecifically applicable to the identified water quality problem. \nMonitoring List. Many water bodies identified had minimal, \ncontradictorv, or anecdotal information that suggested standards were not \nmet but the available data or information was zdequate to draw a \nconclusion. In many cases, the data or information were not of adequate \nquality andlor quantity to support a listing. In these cases, a finding was \nmade that more information must be collected to resolve whether water \nquality objectives and beneficial uses were attained. Waters on this list \nwere considered high priority for monitoring before the completion of the \nnext section 303(d) list. \nThe TMDLs Completed List, the Enforceable Programs List, and the \nMonitoring List were not considered part of the section 303(d) list. \nHowever, these lists including the section 303(d) list were submitted to the \nUSEPA. \nDeveloping the Scope of the Policy \nCWC section 13191.3(b) requires SWRCB to consider the consensus \nrecommendations of the PAC. In developing the proposed Policy, \nSWRCB staff consulted with the PAC and other groups several times. Six \nscoping meetings were held between December 2001 and January 2002 \nwith members from the environmental and regulated caucuses. Based on \nthe feedback received at these meetings, SWRCB staff developed a \nconcept paper discussing important policy issues. This concept paper was \ndiscussed at the PAC's February 2002, April 2002, July 2002, and \nOctober 2002 meetings (AB 982 PAC, 2002). A pre-draft version of the \nPolicy was reviewed by the PAC during its July 2003 meeting (AB 982 \nPAC, 2003). At each step in this review the PAC caucuses provided verbal and written comments (e.g., Johns, 2002,2003; Sheehan, 2002, \n2003), but only in February 2002 did the PAG provided consensus \nrecommendations. \nConsensus Recommendations of the PAG \nIn February 2002, the AB 982 PAG developed the following consensus \nrecommendations: \n+ \tThe listing process should be transparent. \n+ \tThe public participation process should be transparent; in addition it \nshould be (a) specific and (b) well advertised with active outreach to \ndiverse geographic areas and those with environmental justice \nconcerns. \n+ \tTo the greatest extent possible, there should be a consistent \nstandsized set of toois and principles used across the Regions to \nevaluate data. Additionally, site-specific information should be taken \ninto consideration. \nScope of FED \nThe FED has been developed with consideration of existing state statute, \nregulations, and policies; the current approaches of the SWRCB and the \nRWQCBs; approaches used by other states; USEPA guidance; and the \nconsensus recommendations of the PAG. \nThe FED contains six major sections: Introduction, Environmental Setting, \nIssue Analysis, Environmental Effects of the Proposed Policy, \nEnvironmental Checklist, and References. The Proposed Policy in \nincluded in Appendix A and the responses to all comments received \nbefore the close of the hearing record on February 18,2004 and comments \nreceived before or at the September 8,2004 workshop are included in \nAppendix B. Comments discussed at the September SWRCB workshop \nwere focused on a draft final version of the FED (SWRCB, 2004b). \nStatement of Goals \nThe SWRCB's goals for this Policy are to provide: \n+ \tconsistent and transparent approaches for the identification of water \nquality limited segments using a standardized set of tools and \nprinciples to be used by the RWQCBs to evaluate data; \n+ \tscientifically defensible approaches to address the identification and \nlisting of water bodies on the section 303(d) list; and \n+ \ta transparent public participation process. Proposed Action \nThe proposed action is SWRCB adoption of the proposed Policy outlined \nabove and as presented in Appendix A. ENVIRONMENTAL SETTING \nCalifornia encompasses a variety of environmental conditions ranging \nfrom the Sierra Nevada to deserts (with a huge variation in between these \ntwo extremes) to the Pacific Ocean. \nFor water quality management, section 13200 of the Porter-Cologne Water \nQuality Control Act (Porter-Cologne) divides the State into nine different \nhydrologic regions. Brief descriptions of the Regions and the water \nbodies, including water bodies on the 2002 section 303(d) list (Table 1) \nare presented below. The information descriptive of the Regions provided \nin this section comes from the Basin Plans. \nNorth Coast Region (Region I) \nThe North Coast Region comprises all regional basins, including Lower \nKlamath Lake and Lost River Basins, draining into the Pacific Ocean from \nthe California-Oregon state line southern boundary and includes the \nwatershed of the Estero de San Antonio and Stemple Creek in Marin and \nSonoma Counties (Figure 1). Two natural drainage basins, the Klamath \nRiver Basin and the North Coastal Basin divide the Region. The Region \ncovers all of Del Norte, Humboldt, Trinity, and Mendocino Counties, \nmajor portions of Siskiyou and Sonoma Counties, and small portions of \nGlenn, Lake, and Marin Counties. It encompasses a total area of \napproximately 19,390 square miles, including 340 miles of coastline and \nremote wilderness areas, as well as urbanized and agricultural areas. \nBeginning at the Smith River in northern Del Norte County and heading \nsouth to the Estero de San Antonio in northern Marin County, the Region \nencompasses a large number of major river estuaries. Other north coast \nstreams and rivers with significant estuaries include the Klamath River, \nRedwood Creek, Little River, Mad River, Eel River, Noyo River, Navarro \nRiver, Elk Creek, Gualala River, Russian River and Salmon Creek (this \ncreek mouth also forms a lagoon). Northern Humboldt County coastal \nlagoons include Big Lagoon and Stone Lagoon. The two largest enclosed \nbays in the North Coast Region are Humboldt Bay and Arcata Bay (both \nin Humboldt County). Another enclosed bay, Bodega Bay, is located in \nSonoma County near the southern border of the Region. \nListings on the 2002 section 303(d) list for the North Coast Region \nincluded seven water bodies affecting an estimated 49,374 acres (bays, \nestuaries, lakes, and wetlands) and 48 water bodies affecting 20,493 miles \nof rivers and shoreline. The major pollutants affecting these water bodies \nincluded nutrients, metals, pathogens, sediment, and temperature among \nothers (SWRCB, 2003a). \n7 TABLE1: TOTALWATERBODIES BY REGION,WATERBODYTYPEAND EST~MATED \nSlzE AFFECTED ON THE 2002 SECTION 303(~)LIST \nRegion Water Body Type Pollutant Category Pollutant Total Estimated Size -\nCategory Totals* Affected \n1 Bays and Harbors Other Organics 1 16,075 Acres \n1 Estuaries Nutrients 1 199 Acres \n1 Estuaries Sediment 2 247 Acres \n1 LakeslReservoirs MetalsIMetalloids 3 6,054 Acres \n1 LakeslReservoirs Miscellaneous** 1 26,998 Acres \n1 RiversIStreams Miscellaneous** 36 17,148 Miles \n1 RiversIStreams Nutrients 12 5,849 Miles \n1 RiverslStreams Pathogens 2 282 Miles \n1 RiversIStreams Sediment 37 14,647 Miles \nBays and Harbors 279,415.73 Acres \nBays and Harbors 270,870.73 Acres \nBays and Harbors Nutrients 8,545 Acres \nBays and Harbors Other Organics 270,870.73 Acres \nBays and Harbors Pathogens 10,984 Acres \nBays and Harbors Pesticides 270,870.73 Acres \nBays and Harbors Sediment 8,545 Acres \nCoastal Shoreline Pathogens 3.1 Miles \nEstuaries MetalsIMetalloids 47,472.5 Acres \nEstuaries Miscellaneous** 47,393 Acres \nEstuaries Nutrients 54.5 Acres \nEstuaries Other lnorganics 54.5 Acres \n~stuaries . ' Other Organics 47,518.5 Acres \nEstuaries Pathogens 169 Acres \nEstuaries Pesticides 48,642.5 Acres \nLakeslReservoirs MetalslMetalloids 1,289 Acres \nLakes/Reservoirs Miscellaneous** 299 Acres \n2 LakeslReservoirs Nutrients 2 441 Acres \n2 LakeslReservoirs Trash 1 142 Acres \n2 RiverslStreams MetalsIMetalloids 5 50.3 Miles \n2 RiverslStreams Nutrients 6 151.1 Miles \n2 RiverslStreams Pathogens 9 159.4 Miles \n2 Rivers/Streams Pesticides 37 523.3 Miles \n2 RiversIStreams Sediment 9 202.6 Miles \n2 Wetlands, Tidal MetalsIMetalloids 1 66,339 Acres \n2 Wetlands, Tidal Nutrients 1 66,339 Acres \n8 2 Region Water Body Type \nWetlands, Tidal \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nCoastal Shoreline \nCoastal Shoreline \nCoastal Shoreline \nEstuaries \nEstuaries \nEstuaries \nEstuaries \nEstuaries \nEstuaries \nEstuaries \nLakesIReservoirs \nLakesIReservoirs \nLakesIReservoirs \nRiversIStreams \nRiverslStreams \nRivers/Streams \nRiverslStreams \nRivers/Streams \nRiversIStreams \nRiverslStreams \nRiverslStreams RiverslStreams \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nCoastal Shoreline \nCoastal Shoreline \nCoastal Shoreline \nEstuaries Pollutant Category \nSalinity \nMetalslMetalloids \nPathogens \nPesticides \nSediment \nToxicity \nMetalsNetalloids \nPathogens \nPesticides \nMetalsNetalloids \nNutrients \nOther Organics \nPathogens \nPesticides \nSalinity Sediment \nMetalslMetalloids \nNutrients \nPathogens \nMetalslMetalloids \nMiscellaneous** \nNutrients \nOther Organics \nPathogens \nPesticides Salinity \nSediment \nToxicity \nMetalslMetalloids \nMiscellaneous** \nOther Organics \nPathogens \nPesticides \nToxicity \nTrash \nOther Organics \nPathogens \nPesticides \nMetaldMetalloids Pollutant \nCategory Totals* \n1 Total Estimated Size \nAffected \n66,339 Acres \n1,998 Acres \n2,001 Acres \n79 Acres \n2,001 Acres \n76 Acres \n12 Miles \n7.23 Miles \n12 Miles \n196 Acres \n552.2 Acres \n384 Acres \n2,371.2 Acres \n2.397 Acres \n30 Acres \n2,678.2 Acres \n6,362 Acres \n79 Acres \n23 Acres \n102.9 Miles \n16 Miles \n31 1 Miles \n17 Miles \n520.82 Miles \n136.6 Miles \n215 Miles \n438.6 Miles \n8.6 Miles \n6,673 Acres \n148,148 Acres \n154,421 Acres \n849 Acres \n154,421 Acres \n154,248 Acres \n146,645 Acres \n32.77 Miles \n62.83 Miles \n33.78 Miles \n605 Acres Region Water Body Type \n4 Estuaries \n4 Estuaries \n4 Estuaries \n4 Estuaries \n4 Estuaries \n4 Estuaries \n4 Estuaries \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIS treams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nRiversIStreams \nWetlands, Tidal \nWetlands, Tidal \nWetlands, Tidal \nWetlands, Tidal \nWetlands, Tidal \nWetlands; Tidal \nWetlands. Tidal \n4 Wetlands, Tidal \n4 Wetlands, Tidal Pollutant Category Pollutant Total Estimated Size \nCategory Totals* Affected \nMiscellaneous** 15 Acres \nNutrients 359 Acres \nOther Organics 605 Acres \nPathogens 64 Acres \nPesticides 654 Acres \nSediment 344 Acres \nToxicity 344 Acres \nHydromodification 121 Acres \nMetalsMetalloids 696.8 Acres \nMiscellaneous** 255 Acres \nNuisance 243.8 Acres \nNutrients 949.1 Acres \nOther Organics 321 Acres \nPathogens 20 Acres \nPesticides 429 Acres \nSalinity 15 Acres \nToxicity 20 Acres \nTrash 235.6 Acres \nHydromodification 48.43 Miles \nMetalsMetalloids 236.09 Miles \nMiscellaneous** 194.4 Miles \nNuisance 99.9 Miles \nNutrients 393.19 Miles \nOther Inorganics 124.2 Miles \nOther Organics 58.2 Miles \nPathogens 350.69 Miles \nPesticides 124.6 Miles \nSalinity 236.3 Miles \nSediment 101 Miles \nToxicity 122.3 Miles \nTrash 104.7 Miles \nHydromodification 289 Acres \nMetalsMetalloids 44 Acres \nMiscellaneous** 289 Acres \nNutrients 3 1 Acres \nOther Organics 13 Acres \nPathogens 31 Acres \nPesticides 44 Acres \nToxicity 1 13 Acres \nTrash 1 289 Acres Region Water Body Type Pollutant Category Pollutant Total Estimated Size \nCategory Totals* -- Affected \n5 Estuaries MetalsMetalloids 3 43,991 Acres \n5 Estuaries Nutrients 1 952 Acres \n5 Estuaries Pesticides 3 43,991 Acres \n5 Estuaries Salinity 1 22,904 Acres \n5 Estuaries Toxicity 3 43,991 Acres \n5 Lakes/Reservoirs MetalslMetalloids 14 87,196 Acres \n5 LakesJReservoirs Nutrients 1 40,070 Acres \n5 LakesReservoirs Pathogens 1 98 Acres \n5 RiverslStreams MetalslMetalloids 38 636.75 Miles \n5 RiverslStreams Miscellaneous** 2 127.3 Miles \n5 RiverslStreams Nutrients 12 199.43 Miles \n5 RiversIStreams Other Organics 3 18.8 Miles \n5 RiverdStreams Pathogens 15 8 1.93 Miles \n5 RiversIStreams Pesticides 35 647.3 Miles \n5 RiverslStreams Salinity 9 218 Miles \n5 RiverslStreams Sediment 3 28.8 Miles \n5 RiverslStreams Toxicity 18 630 Miles \n5 Wetlands, Freshwater MetalsMetalloids 1 3,045 Acres \n5 Wetlands, Freshwater Salinity 1 7,962 Acres \nLakesReservoirs MetalslMetalloids 2,687 Acres \nLakesReservoirs Nutrients 113,832 Acres \nLakesReservoirs Other Organics 819 Acres \nLakesReservoirs Sediment 88,937 Acres \nRiverslStreams Hydromodification 30.8 Miles \nRiversIStreams Metalsh4etalloids 83.31 Miles \nRiverdStreams Miscellaneous** 218.1 Miles \nRiverslStreams Nutrients 92.58 Miles \nRiverdStreams Other Inorganics 4 Miles \nRiversIStreams Other Organics 3.8 Miles \nRiversIStreams Pathogens 104.98 Miles \nRiverslStreams Salinity 29 Miles \nRiverslStreams Sediment 220 Miles \nRiversIStreams Toxicity 58 Miles \nSaline Lakes Hydromodification 665 Acres \nSaline Lakes MetalsMetalloids 58,421 Acres \nSaline Lakes Salinity 58,421 Acres \nWetlands, Freshwater MetalsMetalloids 62,590 Acres \nWetlands, Freshwater Nutrients 1 Acre \nWetlands, Freshwater Salinity 1 Acre Region \n7 \n7 \n7 \n7 \n7 \n7 \n7 \n7 \n7 \n7 Water Body Type \nRiverslStreams \nRiversIStreams \nRiversIStreams \nRivers/Streams \nRiversIStreams \nRiversIStreams \nRiverslStreams \nSaline Lakes \nSaline Lakes \nSaline Lakes \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nCoastal Shoreline \nCoastal Shoreline \nEstuaries Estuaries \nLakesReservoirs \nLakesIReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nLakesReservoirs \nRiverslStreams \nRiverslStreams \nRiverslStreams \nRiverslStreams RiverslStreams \nRiversIStreams \nRiverslStreams \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nBays and Harbors \nCoastal Shoreline Pollutant Category \nMetalsh4etalloids \nNutrients \nOther Organics \nPathogens \nPesticides \nSediment \nTrash \nMetalsMetalloids \nNutrients \nSalinity \nMetalsMetalloids \nOther Organics \nPathogens \nPesticides \nMetalsMetalloids \nPathogens \nMetalsMetalloids \nPesticides \n~etalsllhetalloids \nMiscellaneous** \nNutrients \nPathogens \nSediment \nToxicity \nMetals/Metalloids \nNutrients \nPathogens \nPesticides \nSalinity Sediment \nToxicity \nMetalsh4etalloids \nMiscellaneous** \nNutrients \nOther Organics \nPathogens \nPesticides \nToxicity \nPatboaens Pollutant \nCategory Totals* \n* \n1 \n1 \n2 \n3 \n2 \n1 \n1 \n1 \n1 Total Estimated Size \nAffected \n1,279 Miles \n66 Miles \n66 Miles \n76.4 Miles \n1,345 Miles \n1,288 Miles \n66 Miles \n233,340 Acres \n233,340 Acres \n233,340 Acres \n1,390 Acres \n1,390 Acres \n221 Acres \n1,390 Acres \n2.6 Miles \n6.33 Miles \n653 Acres \n653 Acres \n2,865 Acres \n2,865 Acres \n5,839 Acres \n547.2 Acres \n5,296 Acres \n2,431 Acres \n11.8 Miles \n19.1 Miles \n156.59 Miles \n7.8 Miles \n20.8 Miles \n6.3 Miles \n6.3 Miles \n2240 Acres \n206.8 Acres \n2032 Acres \n60.5 Acres \n2,160.9 Acres \n5.5 Acres \n206.8 Acres \n23.86 Miles Region Water Body Type Pollutant Category Pollutant Total Estimated Size \nCategorv Totals* -- Affected \n9 Estuaries Metals/Metalloids 1 1319 Acres \n9 Estuaries Nutrients 6 2,155.2 Acres \n9 Estuaries Pathogens 7 2,108.59 Acres \n9 Estuaries Pesticides 1 1,319 Acres \n9 Estuaries Sediment 4 1,243.8 Acres \n9 Estuaries Trash 1 1,319 Acres \n9 LakeslReservoirs Nuisance 2 1,665 Acres \n9 LakeslReservoirs Nutrients 2 1,137 Acres \n9 LakeslReservoirs Salinity 1 1,104 Acres \n9 RiversIStreams MetalslMetalloids 3 13.6 Miles \n9 RiverslStreams Miscellaneous** 1 6.4 Miles \n9 RiverslStreams Nutrients 9 75.12 Miles \n9 RiversIStrearns Other Inorganics 1 1.2 Miles \n9 RiversIStreams Other Organics 1 5.8 Miles \n9 RiversIStreams Pathogens 8 54.9 Miles \n9 RiverslStreams Pesticides 2 7 Miles \n9 RiverslStreams Salinity 8 49.01 Miles \n9 RiverslStreams Sediment 2 2.12 Miles \n9 RiverslStrearns Toxicity 2 25.6 Miles \n9 RiversIStreams Trash 1 5.8 Miles \n* The pollutant category totals are derived from counting the number of pollutant-water segment combinations for \nthe pollutant category. For a more detailed listing of water bodylpollutant combinations, please refer to SWRCB \n(2003a).\n** Miscellaneous pollutants include abnormal fish histology, pH, pH(high), temperature, habitat alterations, noxious \naquatic plants, exotic species, exotic vegetation, fish consumption advisory, shellfish harvesting advisory, \nbenthic community effects, and fish kills (SWRCB, 2003a). - - Distinct temperature zones characterize the North Coast Region. Along \nthe coast, the climate is moderate and foggy with limited temperature \nvariation. Inland, however, seasonal temperature ranges in excess of \n100°F (Fahrenheit) have been recorded. Precipitation is greater than for \nany other part of California, and damaging floods are a fairly frequent \nhazard. Particularly devastating floods occurred in the North Coast area in \nDecember 1955, December 1964, and February 1986. Ample \nprecipitation in combination with the mild climate found over most of the \nNorth Coast Region has provided a wealth of fish, wildlife, and scenic \nresources. The mountainous nature of the Region, with its dense \nconiferous forests interspersed with grassy or chaparral covered slopes, \nprovides shelter and food for deer, elk, bear, mountain lion, fur bearers, \nand many upland bird and mammal species. The numerous streams and \nrivers of the Region contain anadromous fish, and the reservoirs, although \nfew in number, support both cold water and warm water fish. \nTidelands and marshes are extremely important to many species of \nwaterfowl and shore birds. both for feeding and nesting. Cultivated land \nand pasturelands also provide supplemental food for many birds, including \nsmall pheasant populations. Tideland areas along the north coast provide \nimportant habitat for marine invertebrates and nursery areas for forage \nfish, game fish, and crustaceans. Offshore coastal rocks are used by many \nspecies of seabirds as nesting areas. \nMajor components of the economy are tourism and recreation, logging and \ntimber milling, aggregate mining, commercial and sport fisheries, sheep, \nbeef and dairy production, and vineyards and wineries. In all, the North \nCoast Region offers a beautiful natural environment with opportunities for \nscientific study and research, recreation, sport and commerce. \nApproximately two percent of California's total population resides in the \nNorth Coast Region. The largest urban centers are Eureka in Humboldt \nCounty, and Santa Rosa in Sonoma County. North Coast Reglon (I) \nNORTH COAST HYDROLOGIC BASIN PLANNING ARU (NC) \n0 10 20 30 -\nMILES \nBase map prepared by the Division of Water Rtghts. Graphics\nSBNC~S Unll \nFIGURE1:NORTH REGION BASIN COAST HYDROLOGIC \n15 San Francisco Region (Region 2) \nThe San Francisco Bay Region comprises San Francisco Bay, Suisun Bay \nbeginning at the Sacramento River, and San Joaquin River westerly, from \na line which passes between Collinsville and Montezuma Island \n(Figure 2). The Region's boundary follows the borders common to \nSacramento and Solano counties and Sacramento and Contra Costa \ncounties west of the Markely Canyon watershed in Contra Costa County. \nAll basins west of the boundary, described above, and all basins draining \ninto the Pacific Ocean between the southern boundary of the North Coast \nRegion and the southern boundary of the watershed of Pescadero Creek in \nSan Mateo and Santa Cruz counties are included in the Region. \nThe Region comprises most of the San Francisco Estuary to the mouth of \nthe Sacramento-San Joaquin Delta. The San Francisco Estuary conveys \nthe waters of the Sacramento and San Joaquin Rivers to the Pacific Ocean. \nLocated on the central coast of California, the Bay system functions as the \nonly drainage outlet for waters of the Central Valley. It also marks a \nnatural topographic separation between the northern and southern coastal \nmountain ranges. The Region's waterways, wetlands, and bays form the \ncenterpiece of the fourth largest metropolitan area in the United States, \nincluding all or major portions of Alameda, Contra Costa, Marin, Napa, \nSan Francisco, San Mateo, Santa Clara, Solano, and Sonoma counties. \nThe San Francisco Bay RWQCB has jurisdiction over the part of the San \nFrancisco Estuary, which includes all of the San Francisco Bay segments \nextending east to the Delta (Winter Island near Pittsburg). The San \nFrancisco Estuary sustains a highly dynamic and complex environment. \nWithin each section of the Bay system lie deepwater areas that are \nadjacent to large expanses of very shallow water. Salinity levels range \nfrom hypersaline to fresh water and water temperature varies widely. The \nBay system's deepwater channels, tidelands, marshlands, fresh water \nstreams and rivers provide a wide variety of habitats within the Region. \nCoastal embayments including Tomales Bay and Bolinas Lagoon are also \nlocated in this Region. The Central Valley RWQCB has jurisdiction over \nthe Delta and rivers extending further eastward. \nThe Sacramento and San Joaquin Rivers enter the Bay system through the \nDelta at the eastern end of Suisun Bay and contribute almost all of the \nfresh water inflow into the Bay. Many smaller rivers and streams also \nconvey fresh water to the Bay system. The rate and timing of these fresh \nwater flows are among the most important factors influencing physical, \nchemical and biological conditions in the Estuary. Flows in the region are \nhighly seasonal, with more than 90 percent of the annual runoff occurring \nduring the winter rainy season between November and April. San Francisco Bay Region (2) \nSAN FRANCISCO SAY HYorioLoalc BASIN PLANNING AREA (SR \n0 10 20 30 \nMILES \nBase map prepared by the Olvision of Water R~ghts. Graphics\nServices Unit The San Francisco Estuary is made up of many different types of aquatic \nhabitats that support a great diversity of organisms. Suisun Marsh in \nSuisun Bay is the largest brackish-water marsh in the United States. San \nPablo Bay is a shallow embayment strongly influenced by runoff from the \nSacramento and San Joaquin Rivers. \nThe Central Bay is the portion of the Bay most influenced by oceanic \nconditions. The South Bay, with less freshwater inflow than the other \nportions of the Bay, acts more like a tidal lagoon. Together these areas \nsustain rich communities of aquatic life and serve as important wintering \nsites for migrating waterfowl and spawning areas for anadromous fish. \nThe 2002 section 303(d) list for the San Francisco Region included 25 \nwater bodies affecting an estimated 396,296 acres (bays, estuaries, lakes, \nand wetlands) and 54 water bodies affecting 724 miles of rivers and \nshoreline. The major pollutants affecting these water bodies included \nnutrients, metals, pathogens, pesticides, and sediment among others \n(SWRCB, 2003a). \nCentral Coast Region (Region 3) \nThe Central Coast Region comprises all basins (including Carrizo Plain in \nSan Luis Obispo and Kern Counties) draining into the Pacific Ocean from \nthe southern boundary of the Pescadero Creek watershed in San Mateo \nand Santa Cruz Counties; to the southeastern boundary of the Rincon \nCreek watershed, located in western Ventura County (Figure 3). The \nRegion extends over a 300-mile long by 40-mile wide section of the \nState's central coast. Its geographic area encompasses all of Santa CNZ, \nSan Benito, Monterey, San Luis Obispo, and Santa Barbara Counties as \nwell as the southern one-third of Santa Clara County, and small portions \nof San Mateo, Kern, and Ventura Counties. Included in the region are \nurban areas such as the Monterey Peninsula and the Santa Barbara coastal \nplain; prime agricultural lands such as the Salinas, Santa Maria, and \nLompoc Valleys; National Forest lands; extremely wet areas such as the \nSanta Cruz mountains; and arid areas such as the Carrizo Plain. \nWater bodies in the Central Coast Region are varied. Enclosed bays and \nharbors in the Region include Morro Bay, Elkhorn Slough, Tembladero \nSlough, Santa Cruz Harbor, Moss Landing Harbor, San Luis Harbor, and \nSanta Barbara Harbor. Several small estuaries also characterize the \nRegion, including the Santa Maria River Estuary, San Lorenzo River \nEstuary, Big Sur River Estuary, and many others. Major rivers, streams, \nand lakes include San Lorenzo River, Santa Cruz River, San Benito River, \nPajaro River, Salinas River, Santa Maria River, Cuyarna River, Estrella River and Santa Ynez River, San Antonio Reservoir, Nacimiento \nReservoir, Twitchel Reservoir, and Cuchuma Reservoir. \nThe economic and cultural activities in the basin have been primarily \nagrarian. Livestock grazing persists, but has been combined with hay \ncultivation in the valleys. Irrigation, with pumped local groundwater, is \nvery significant in intermountain valleys throughout the basin. Mild \nwinters result in long growing seasons and continuous cultivation of many \nvegetable crops in parts of the basin. \nWhile agriculture and related food processing activities are major \nindustries in the Region, oil production, tourism, and manufacturing \ncontribute heavily to its economy. The northern part of the Region has \nexperienced a significant influx of electronic manufacturing; while \noffshore oil exploration and production have heavily influenced the \nsouthern part. Total population of the Region is estimated at 1.22 million \npeople. \nWater quality problems frequently encountered in the Central Coastal \nRegion include excessive salinity or hardness of local groundwaters. \nIncreasing nitrate concentration is a growing problem in a number of \nareas, in both groundwater and surface water. Surface waters suffer from \nbacterial contamination, nutrient enrichment, and siltation in a number of \nwatersheds. Pesticides are a concern in agricultural areas and associated \ndownstream water bodies. \nListings on the 2002 section 303(d) list for the Central Coast Region \nincluded 16 water bodies affecting an estimated 11,366 acres (bays, \nestuaries, lakes, and wetlands) and 77 water bodies affecting 842 miles of \nrivers and shoreline. The major pollutants affecting these water bodies \nincluded nutrients, metals, pathogens, pesticides, and sediment among \nothers (SWRCB, 2003a). Central Coast Region (3) \nCENTRALCOAST HYDROLOGIC BASIN PLANNlNGAREA(CC) \n1 \n0 10 20 30 \n-\nMILES \nBase map prepared by the Division of Water Rights, Graphics\nServices Unit Los Angeles Region (Region 4) \nThe Los Angeles Region comprises all basins draining into the Pacific \nOcean between the southeastern boundary of the watershed of Rincon \nCreek, located in western Ventura County, and a line which coincides with \nthe southeastern boundary of Los Angeles County, from the Pacific Ocean \nto San Antonio Peak, and follows the divide, between the San Gabriel \nRiver and Lytle Creek drainages to the divide between Sheep Creek and \nSan Gabriel River drainages (Figure 4). \nThe Region encompasses all coastal drainages flowing into the Pacific \nOcean between Rincon Point (on the coast of western Ventura County) \nand the eastern Los Angeles County line, as well as the drainages of five \ncoastal islands (Anacapa, San Nicolas, Santa Barbara, Santa Catalina and \nSan Clemente). In addition, the Region includes all coastal waters within \nthree miles of the continental and island coastlines Two large deepwater \nharbors (Los Angeles and Long Beach Harbors) and one smaller \ndeepwater harbor (Port Hueneme) are contained in the Region. There are \nsmall craft marinas within the harbors, as well as tank farms, naval \nfacilities, fish processing plants, boatyards, and container terminals. \nSeveral small-craft marinas also exist along the coast (Marina del Rev, \nKing Harbor, Ventura Harbor); these contin boatyards, other small -\nbusinesses and dense residential development. \nSeveral large, primarily concrete-lined rivers (Los Angeles River, San \nGabriel River) lead to unlined tidal prisms which are influenced by marine \nwaters. Salinity may be greatly reduced following rains since these rivers \ndrain large urban areas composed of mostly impermeable surfaces. Some \nof these tidal prisms receive a considerable amount of freshwater \nthroughout the year from publicly owned treatment works discharging \ntertiary-treated effluent. Lagoons are located at the mouths of other rivers \ndraining relatively undeveloped areas (Mugu Lagoon, Malibu Lagoon, \nVentura River Estuary, and Santa Clara River Estuary). There are also a \nfew isolated coastal brackish water bodies receiving runoff from \nagricultural or residential areas. \nSanta Monica Bay, which includes the Palos Verdes Shelf, dominates a \nlarge portion of the open coastal water bodies in the Region. The Region's \ncoastal water bodies also include the areas along the shoreline of Ventura \nCounty and the waters surrounding the five offshore islands in the region. Los Angeles Region (4) \nLOSANGELES HVDROLWIC BASIN PLANNINGARU (LA) \nBase map prepared by the D~vislan dWater Rights. Graphics \nSewicss Unit \nFIGURE4: LOS ANGELES HYDROLOGICREGION BASIN Waters on the 2002 section 303(d) list for the Los Angeles Region \nincluded 38 water bodies affecting an estimated 156,921 acres (bays, \nestuaries, lakes, and wetlands) and 142 water bodies affecting 802 miles of \nrivers and shoreline. The major pollutants affecting these water bodies \nincluded nutrients, metals, pathogens, pesticides, and sediment among \nothers (SWRCB, 2003a). \nCentral Valley Region (Region 5) \nThe Central Valley Region includes approximately 40 percent of the land \nin California stretching from the Oregon border to the Kern County1 Los \nAngeles county line. The Region is divided into three basins. For \nplanning purposes, the Sacramento River Basin and the San Joaquin River \nbasin are covered under one Basin Plan and the Tulare Lake Basin is \ncovered under a separate distinct one. \nThe Sacramento River Basin covers 27,210 square miles and includes the \nentire area drained by the Sacramento River (Figure 5). The principal \nstreams are the Sacramento River and its larger tributaries: the Pitt, \nFeather, Yuba, Bear, and American Rivers to the East; and Cottonwood, \nStony, Cache, and Putah Creek to the west. Major reservoirs and lakes \ninclude Shasta, Oroville, Folsom, Clear Lake, and Lake Berryessa. \nThe San Joaquin River Basin covers 15,880 square miles and includes the \nentire area drained by the San Joaquin River (Figure 6). Principal streams \nin the basin are the San Joaquin River and its larger tributaries: the \nConsumnes, Mokelumne, Calaveras, Stanislaus, Tuolumne, Merced, \nChowchilla, and Fresno Rivers. Major reservoirs and lakes include \nPardee, New Hogan, Millerton, McClure, Don Pedro, and New Melones. \nThe Tulare Lake Basin covers approximately 16,406 square miles and \ncomprises the drainage area of the San Joaquin Valley south of the San \nJoaquin River (Figure 7). The planning boundary between the San \nJoaquin River Basin and the Tulare Lake Basin is defined by the northern \nboundary of Little Pinoche Creek basin eastward along the channel of the \nSan Joaquin River to Millerton Lake in the Sierra Nevada foothills, and \nthen along the southern boundary of the San Joaquin River drainage basin. \nMain rivers within the basin include the King, Kaweah, Tule, and Kern \nRivers, which drains the west face of the Sierra Nevada Mountains. \nImported surface water supplies enter the basin through the San Luis \nDrain- California Aqueduct System, Friant- Kern Channel and the Delta \nMendota Canal. Central Valley Reglon (5) \nSACRAMENTO HYDROLOGIC BASIN PLANNING AREA (88) \nBase map prepared by the D~v~sion of Waler Righls, Graphics \nServices Unlt \nFIGURE5: CENTRAL VALLEY SACRAMENTO HYDROLOGIC REGION, REGION BASLN \n24 Central Valley Region (5) \nSAN JOAOUIN HYDROLOGIC BASIN PLANNING AREA (SJ) \n0 10 20 30 -\nMILES \nBase map prepared by the Division of Water Rights. Graphics\nServices Unit \nFIGURE6: CENTRAL VALLEYREGION,SAN JOAQUIN HYDROLOGIC BASIN \n25 Central Valley Region (5) \nTULARE LAKE HYDROLOGIC BASIN PLANNING AREA (TL) \n0 10 20 30 \nMILES \nBase map prepared by the D~vislonof Water R~ghts, Graphics \nSerwces Unlt \nFIGURE 7: CENTRAL VALLEYREGION, LAKE HYDROLOGIC TULARE BASIN \n26 The two northern most basins are bound by the crests of the Sierra Nevada \non the east and the Coast Range and Klamath Mountains on the west. \nThey extend about 400 miles from the California-Oregon border \nsouthward to the headwaters of the San Joaquin River. These two river \nbasins cover about one fourth of the total area of the State and over 30 \npercent of the State's irrigable land. The Sacramento and San Joaquin \nRivers furnish roughly 50 percent of the State's water supply. Surface \nwater from the two drainage basins meet and form the Delta, which \nultimately drains into the San Francisco Bay. \nThe Delta is a maze of river channels and diked islands covering roughly \n1,150 square miles, including 78 square miles of water area. Two major \nwater projects located in the South Delta, the Federal Central Valley \nProject and the State Water Project, deliver water from the Delta to \nSouthern California, the San Joaquin Valley, Tulare Lake Basin, the San \nFrancisco Bay Area, as well as within the Delta boundaries. The legal \nboundary of the Delta is described in CWC section 12220. \nThe 2002 section 303(d) list for the Central Valley Region included 20 \nwater bodies affecting an estimated 142,292 acres (bays, estuaries, lakes, \nand wetlands) and 83 water bodies affecting 1344 miles of rivers. The \nmajor pollutants affecting these water bodies included nutrients, metals, \npathogens, and pesticides among others (SWRCB, 2003a). \nLahontan Region (Region 6) \nThe Lahontan Region has historically been divided into North and South \nLahontan Basins at the boundary between the Mono Lake and East Walker \nRiver watersheds (Figure 8 and 9). It is about 570 miles long and has a \ntotal area of 33,131 square miles. The Lahontan Region includes the \nhighest (Mount Whitney) and lowest (Death Valley) points in the \ncontiguous United States. The topography of the remainder of the Region \nis diverse. The Region includes the eastern slopes of the Warner, Sierra \nNevada, San Bernardino, Tehachapi and San Gabriel Mountains, and all or \npart of other ranges including the White, Providence, and Granite \nMountains. Topographic depressions include the Madeline Plains, \nSurprise, Honey Lake, Bridgeport, Owens, Antelope, and Victor Valleys. \nThe Region is generally in a rain shadow; however, annual precipitation \namounts can be high (up to 70 inches) at higher elevations. Most \nprecipitation in the mountainous areas falls as snow. Desert areas receive \nrelatively little annual precipitation (less than 2 inches in some locations) \nbut this can be concentrated and lead to flash flooding. Temperature \nextremes recorded in the Lahontan Region range from -45'F at Boca \n(Truckee River watershed) to 134'F in Death Valley. The varied \ntopography, soils, and microclimates of the Lahontan Region support a Lahontan Region (6) \nNORTH LAHONTAN HYDROLOGIC BASIN PLANNING AREA(NL) Lahontan Region (6) \nSOUTH LAHONTAN HYDROLOQIC BASIN PLANNING AREA (SL) \nBase map prepued by the Divisim dWater Rights. Graphics \nSeMce~Unit \nFIGURE 9: LAHONTAN REGION,SOUTH HYDROLOGIC LAHONTAN BASIN corresponding variety of plant and animal communities. Vegetation ranges \nfrom sagebrush and creosote bush scrub in the desert areas to pinyon- \njuniper and mixed conifer forest at higher elevations. Subalpine and \nalpine communities occur on the highest peaks. Wetland and riparian plant \ncommunities, including marshes, meadows, \"sphagnum\" bogs, riparian \ndeciduous forest, and desert washes, are particularly important for \nwildlife, given the general scarcity of water in the Region. \nThe Lahontan Region is rich in cultural resources (archaeological and \nhistoric sites), ranging from remnants of Native American irrigation \nsystems to Comstock mining era ghost towns, such as Bodie, and 1920s \nresort homes at Lake Tahoe and Death Valley (Scotty's Castle). \nMuch of the Lahontan Region is in public ownership, with land use \ncontrolled by agencies, such as the U.S. Forest Service (USFS), National \nPark Service, Bureau of Land Management, various branches of the \nmilitary, the California State Department of Parks and Recreation, and the \nCity of Los Angeles Department of Water and Power. While the \npermanent resident population (about 500,000 in 1990) of the Region is \nlow, most of it is concentrated in high density communities in the South \nLahontan Basin. In addition, millions of visitors use the Lahontan Region \nfor recreation each year. Rapid population growth has occurred in the \nVictor and Antelope Valleys and within commuting distance of Reno, \nNevada. Principal communities of the North Lahontan Basin include \nSusanville, Truckee, Tahoe City, South Lake Tahoe, Markleeville, and \nBridgeport. The South Lahontan Basin includes the communities of \nMammoth Lakes, Bishop, Ridgecrest, Mojave, Adelanto, Palmdale, \nLancaster, Victorville, and Barstow. Recreational and scenic attractions of \nthe Lahontan Region include Eagle Lake, Lake Tahoe, Mono Lake, \nMammoth Lakes, Death Valley, and portions of many wilderness areas. \nSegments of the East Fork Carson and West Walker Rivers are included in \nthe State Wild and Scenic River system. Both developed (e.g., camping, \nskiing, day use) and undeveloped (e.g., hiking, fishing) recreation are \nimportant components of the Region's economy. In addition to tourism, \nother major sectors of the economy are resource extraction (mining, \nenergy production, and silviculture), agriculture (mostly livestock \ngrazing), and defense-related activities. There is relatively little \nmanufacturing industry in the Region, in comparison to major urban areas \nof the state. Economically valuable minerals, including gold, silver, \ncopper, sulfur, tungsten, borax, and rare earth metals have been or are \nbeing mined at various locations within the Lahontan Region. \nThe Lahontan Region includes over 700 lakes, 3,170 miles of streams and \n1,58 1 square miles of groundwater basins. There are twelve major \nwatersheds (called \"hydrologic units\" under the Department of Water Resources' mapping system) in the North Lahontan Basin. Among these \nare the Eagle Lake, Susan Rivermoney Lake, Truckee, Carson, and \nWalker River watersheds. The South Lahontan Basin includes three major \nsurface water systems (the Mono Lake, Owens River, and Mojave River \nwatersheds) and a number of separate closed groundwater basins. Water \nquality problems in the Lahontan Region are largely related to nonpoint \nsources (including erosion from construction, timber harvesting, and \nlivestock grazing), storm water, acid drainage from inactive mines, and \nindividual wastewater disposal systems. \nListings on the 2002 section 303(d) list for the Lahontan Region included \n16 water bodies affecting an estimated 239,309 acres (lakes and wetlands) \nand 54 water bodies affecting 699 miles of rivers and shoreline. The major \npollutants affecting these water bodies included nutrients, metals, \npathogens, and pesticides among others (SWRCB, 2003a). \nColorado River Basin Region (Region 7) \nThe Colorado River Basin Region covers approximately 13 million acres \n(20,000 square miles) in the southeastern portion of California (Figure 10). \nIt includes all of Imperial County and portions of San Bernardino, \nRiverside, and San Diego Counties. It shares a boundary for 40 miles on \nthe northeast with the State of Nevada, on the north by the New York, \nProvidence, Granite, Old Dad, Bristol, Rodman, and Ord Mountain \nranges, on the west by the San Bernardino, San Jacinto, and Laguna \nMountain ranges, on the south by the Republic of Mexico, and on the east \nby the Colorado River and State of Arizona. Geographically the Region \nrepresents only a small portion of the total Colorado River drainage area \nwhich includes portions of Arizona, Nevada, Utah, Wyoming, Colorado, \nNew Mexico, and Mexico. A significant geographical feature of the \nRegion is the Salton Trough, which contains the Salton Sea and the \nCoachella and Imperial Valleys. The two valleys are separated by the \nSalton Sea, which covers the lowest area of the depression. The trough is a \ngeologic structural extension of the Gulf of California. \nMuch of the agricultural economy and industry of the Region is located in \nthe Salton Trough. There are also industries associated with agriculture, \nsuch as sugar refining as well as increasing development of geothermal \nindustries. In the future, agriculture is expected to experience little growth \nin the Salton Trough, but there will likely be increased development of \nother industries (such as construction, manufacturing, and services). The \npresent Salton Sea, located on the site of a prehistoric lake, was formed \nbetween 1905 and 1907 by overflow of the Colorado River. The Salton \nSea serves as a drainage reservoir for irrigation return water and storm Colorado River Basin Region (7) \nCOLORADO RIVER HYDROLWIC BASlN PLANNING AREA (CR) \n0 10 20 30 \nMILES \nBase mep prepand by the Division of Water Rights. Graphics \nServices Unl \nFIGURE10:COLORADO BASIN RIVER REGION HYDROLOGIC water from the Coachella Valley, Imperial Valley, and Borrego Valley, \nand also receives drainage water from the Mexicali Valley in Mexico. The \nSalton Sea is California's largest inland body of water and provides a very \nimportant wildlife habitat and sportfishery. Development along \nCalifornia's 230 mile reach of the Colorado River, which flows along the \neastern boundary of the Region, include agricultural areas in Palo Verde \nValley and Bard Valley, urban centers at Needles, Blythe, and \nWinterhaven, several transcontinental gas compressor stations, and \nnumerous small recreational communities. Some mining operations are \nlocated in the surrounding mountains. Also the Fort Mojave, Chemehuevi, \nColorado River, and Yuma Indian Reservations are located along the \nRiver. \nWaters on the 2002 section 303(d) list for the Colorado River Basin \nRegion included one water body affecting an estimated 233,340 acres \n(lakes and wetlands) and five water bodies affecting 1,421 miles of rivers. \nThe major pollutants affecting these water bodies included nutrients, \nmetals, pathogens, pesticides, and sediments among others (SWRCB, \n2003a). \nThe Region has the driest climate in California. The winters are mild and \nsummers are hot. Temperatures range from below freezing to over 120°F. \nIn the Colorado River valleys and the Salton Trough, frost is a rare \noccurrence and crops are grown year round. Snow falls in the Region's \nhigher elevations, with mean seasonal precipitation ranging from 30 to 40 \ninches in the upper San Jacinto and San Bernardino Mountains. The lower \nelevations receive relatively little rainfall. An average four inches of \nprecipitation occurs along the Colorado River, with much of this coming \nfrom late summer thunderstorms moving north from Mexico. Typical \nmean seasonal precipitation in the desert valleys is 3.6 inches at Indio and \n3.2 inches at El Centro. Precipitation over the entire area occurs mostly \nfrom November through ~~ril, and August through September, but its- \ndistribution and intensity are often sporadic. Local thunderstorms may \ncontribute all the average seasonal precipitation at one time, or only a \ntrace of precipitation may be recorded at any locale for the entire season. \nThe Region provides habitat for a variety of native and introduced species \nof wildlife. Increased human population and its associated development \nhave adversely affected the habitat for some species, while enhancing it \nfor others. Large areas within the Region are inhabited by animals tolerant \nof arid conditions, including small rodents, coyotes, foxes, birds, and a \nvariety of reptiles. Along the Colorado River and in the higher elevations \nof the San Bernardino and San Jacinto Mountains where water is more \nabundant, deer, bighorn sheep, and a diversity of small animals exist. - - Practically all of the fishes inhabiting the Region are introduced species. \nThe most abundant species in the Colorado River and irrigation canals \ninclude largemouth bass, smallmouth bass, flathead and channel catfish, \nyellow bullhead, bluegill, redear sunfish, black crappie, carp, striped bass, \nthreadfin shad, red shiner, and, in the colder water above Lake Havasu, \nrainbow trout. Grass carp have been introduced into sections of the All \nAmerican Canal system for aquatic weed control. Fish inhabiting \nagricultural drains in the Region generally include mosquito fish, mollies, \nred shiners, carp, and tilapia, although locally significant populations of \ncatfish, bass, and sunfish occur in some drains. A considerable \nsportfishery exists in the Salton Sea, with orangemouth corvina, gulf \ncroaker, satgo, and tilapia predominating. The Salton Sea National \nWildlife ~efu~e and state waterfowl management areas are located in or \nnear the Salton Sea. The refuge sumorts large numbers of waterfowl in \naddition to other types of birds. Ldcited along the Colorado River are the \nHavasu, Cibola and Imperial National Wildlife Refuges. The Region \nprovides habitat for certain endangeredlthreatened species of wildlife \nincluding desert pupfish, razorback sucker, Yuma clapper rail, black rail, \nleast Bell's vireo, yellow billed cuckoo, desert tortoise, and peninsular \nbighorn sheep. \nSanta Ana Region (Region 8) \nThe Santa Ana Region comprises all basins draining into the Pacific \nOcean between the southern boundary of the Los Angeles Region and the \ndrainage divide between Muddy and Moro Canyons, from the ocean to the \nsummit of San Joaquin Hills; along the divide between lands draining into \nNewport Bay and Laguna Canyon to Niguel Road; along Niguel Road and \nLos Aliso Avenue to the divide between Newport Bay and Aliso Creek \ndrainages; and along the divide and the southeastern boundary of the Santa \nAna River drainage to the divide between Baldwin Lake and Mojave \nDesert drainages; to the divide between the Pacific Ocean and Mojave \nDesert drainages (Figure 11). The Santa Ana Region is the smallest of the \nnine regions in the state (2.800 sauare miles) and is located in southern . . \n~alifoGia, roughly between Los ngeles and San Diego. Although small \ngeographically, the region's four-plus million residents (1993 estimate) \nmake it one of the most de~lsely populated regions. The climate of the \nSanta Ana Region is classified as Mediterranean: generally dry in the \nsummer with mild, wet winters. The average annual rainfall in the region \nis about fifteen inches, most of it occurring between November and \nMarch. The enclosed bays in the Region include Newport Bay, Bolsa Bay \n(including Bolsa Chica Marsh), and Anaheim Bay. Principal Rivers \ninclude Santa Ana, San Jacinto and San Diego. Lakes and reservoirs \ninclude Big Bear, Hemet, Mathews, Canyon Lake, Lake Elsinore, \nSantiago Reservoir, and Perris Reservoir. The section 2002 303(d) list for the Santa Ana Region included nine water \nbodies affecting an estimated 7,886 acres (bays, estuaries, lakes, and \nwetlands) and 24 water bodies affecting 191 miles of rivers and shoreline. \nThe major pollutants affecting these water bodies included nutrients, \nmetals, pathogens, pesticides, and sediments among others (SWRCB \n2003a). \nSan Diego Region (Region 9) \nThe San Diego Region comprises all basins draining into the Pacific \nOcean between the southern boundary of the Santa Ana Region and the \nCalifornia-Mexico boundary (Figure 12). The San Diego Region is \nlocated along the coast of the Pacific Ocean from the Mexican border to \nnorth of Laguna Beach. The Region is rectangular in shape and extends \napproximately 80 miles along the coastline and 40 miles east to the crest \nof the mountains. The Region includes portions of San Diego, Orange, \nand Riverside Counties. The population of the Region is heavily \nconcentrated along the coastal strip. Six deepwater sewage outfalls and \none across the beach discharge from the new border plant at the Tijuana \nRiver empty into the ocean. Two harbors, Mission Bay and San Diego \nBay, support major recreational and commercial boat traffic. Coastal \nlagoons are found along the San Diego County coast at the mouths of \ncreeks and rivers. \nThe 2002 section 303(d) list for the San Diego Region included 26 water \nbodies affecting an estimated 6,907 acres (bays, estuaries, lakes, and \nwetlands) and 40 water bodies affecting 148 miles of rivers and shoreline. \nThe major pollutants affecting these water bodies included nutrients, \nmetals, pathogens, pesticides, and sediments among others (SWRCB, \n2003a). \nWeather patterns are Mediterranean in nature with an average rainfall of \napproximately ten inches per year occurring along the coast. Almost all \nthe rainfall occurs during wet cool winters. The Pacific Ocean generally \nhas cool water temperatures due to upwelling. This nutrient-rich water \nsupports coastal beds of giant kelp. The cities of San Diego, National \nCity, Chula Vista, Coronado, and Imperial Beach surround San Diego Bay \nin the southern portion of the Region. \nSan Diego Bay is long and narrow, 15 miles in length and approximately \none mile across. A deep-water harbor, San Diego Bay has experienced \nwaste discharge from former sewage outfalls, industries, and urban runoff. \nUp to 9,000 vessels may be moored there. San Diego Bay also hosts four \nmajor U.S. Navy bases with approximately 80 surface ships and \nsubmarines. Coastal waters include bays, harbors, estuaries, beaches, and \nopen ocean. Santa Ana Region (8) \nSANTA ANA HYDROLOGIC BASIN PUNNINGAREA (SA) \n0 10 20 M \nMILES \nBase map prepared by the Division of Water Rights. Graphics \nSeNices Unit \nFIGURE11: SANTA HYDROLOGIC ANA REGION BASIN San Diego Region (9) \nSAN DIEGO HYDROLOGIC BASIN PLANNING AREA (SO) \n0 10 20 30 \nMILES \nBase map prepared by the Division of Water Rights. Graphics\nServlces Unit \nFIGURE12: SAN DIEGO HYDROLOGICREGION BASIN \n37 Deep draft commercial harbors include San Diego Bay and \nOceanside Harbor and shallower harbors include Mission Bay and \nDana Point Harbor. Tijuana Estuary, Sweetwater Marsh, San \nDiego River Flood Control Channel, Kendal-Frost Wildlife \nReserve, San Dieguito River Estuary, San Elijo Lagoon, Batiquitos \nLagoon, Agua Hedionda Lagoon, Buena Vista Lagoon, San Luis \nRey Estuary, and Santa Margarita River Estuary are the important \nestuaries of the Region. \nThere are thirteen principal stream systems in the Region \noriginating in the western highlands and flowing to the Pacific \nOcean. From north to south these are Aliso Creek, San Juan \nCreek, San Mateo Creek, San Onofre Creek, Santa Margarita \nRiver, San Luis Ray River, San Marcos Creek, Escondido Creek, \nSan Dieguito River, San Diego River, Sweetwater River, Otay \nRiver, and the Tijuana River. Most of these streams are \ninterrupted in character having both perennial and ephemeral \ncomponents due to the rainfall pattern in the region. Surface water \nimpoundments capture flow from almost all the major streams. ISSUE ANALYSIS \nThe staff analysis of each issue addressed during the development of the \nPolicy is formatted consistently to provide the SWRCB with a summary of \nthe topic or issue as well as alternatives for their action. All comments \nreceived and the responses are presented in Appendix B. Many of the \nissue analyses were revised in response to the comments received. \nEach issue analysis contains the following sections: \nIssue: A brief question framing the issue or topic. \nIssue Description: A description of the issue or topic plus (if appropriate) any additional \nbackground information, list of limitations and assumptions, descriptions \nof related programs or other information. \nBaseline: A description of how the SWRCB or RWQCBs addressed the issue or \ntopic during the development of the 2002 section 303(d) list and, if \nnecessary, prior to 2002. \nAlternatives: For each issue or topic, at least two alternatives are provided for SWRCB \nconsideration. \nRecommendation: In this section, a suggestion is made for which alternative (or combination \nof alternatives) should be adopted by the SWRCB. The reader is also \nreferred to the section(s) of the proposed Policy relevant to the issue. Issue 1: \t Scope of the Listing/Delisting Policy \nIssue: \t What factors should be addressed by the ListingIDelisting Policy? \nIssue Description: \t To develop guidance on listing and delisting factors, the SWRCB held \nscoping meetings for the Policy with members of the AB 982 PAG as well \nas other constituencies interested in the development of this Policy. Some \nof these constituencies urged the SWRCB to consider revision of \nbeneficial uses before any listing decisions were made. Comments have \nalso been received suggesting that the Policy be limited to creation of the \nsection 303(d) list since other programs focus on standards revision \n(e.g., triennial review of the Basin Plans). Additionally, during \ndevelovment of the 2002 section 303(d) list. several comments addressed ,, \nthe appropriateness or applicability of many of the water quality standards \nand beneficial use designations (SWRCB, 2003a). \nCWC section 13191.3(a) requires the SWRCB to develop guidelines for \nlisting and delisting of waters on the section 303(d) list. The development \nof a section 303(d) list relies on the interpretation of existing water quality \nstandards. \nBaseline: \t SWRCB is required to submit to USEPA a new section 303(d) list every \ntwo years. In 2002, SWRCB did not modify any water quality standards \nduring the development of the section 303(d) list. \nAlternatives: 1. Incornorate guidance on listinddelisting factors only. CWA \nsection 303(d) requires the state to create a list of waters that do not \ncurrently meet existing water quality standards and where TMDLs are still \nrequired. This alternative is focused narrowly on developing guidance for \ncompletion of the section 303(d) list. \nFocusing the Policy on the listingldelisting factors for the section 303(d) \nlist provide the following advantages: (1) deadlines are more likely to be \nmet for completion of the section 303(d) list; (2) the established triennial \nreview process for the Basin Plans and Statewide Plans would not have to \nconform to the 2-year time frame for development of the section 303(d) \nlist; and (3) the process would be manageable with existing staff \nresources. \nThe major disadvantage to this approach is that existing standards may not \nrepresent actual water body conditions and the problem identified during \nthe listing process may no longer represent a real water quality problem. \nAnother disadvantage is that, if not narrowly focused, the potential to \nbroadly apply the Policy requirements is greater. For example, the Policy \n40 could potentially be used to determine compliance with permit limitations \nor translate narrative objectives for the regulation of point sources. To \navoid these problems and others, the Policy should clearly state that it is \nnot to be used to: (1) develop or revise water quality objectives or \nbeneficial uses (2) determine compliance with waste discharge \nrequirements (WDRs) or National Pollutant Discharge Elimination System \n(NPDES) requirements, or (3) interpret narrative water quality standards \nfor the purposes of regulating point sources. The purpose of the Policy \nshould be clearly articulated. \nOf the two alternatives considered, this is the preferred alternative because \na standardized approach for developing California's section 303(d) list \nwould be established that focuses only on development of the list. \n2. Incornorate guidance on beneficial use designationlde-designation and \nwater aualitv standards revision or development, as well as guidance on \nintemretation of water quality standards. A National Academy of \nSciences (NAS) committee (2001) has recommended that beneficial uses \nand water quality standards be reviewed as a first step in developing the \nsection 303(d) list. The NAS committee wrote: \n\"States should develop appropriate use designations for water bodies in \nadvance of assessment and refine these use designations prior to TMDL \ndevelopment.\" \n\"CWA goals of fishable and swimmable waters are too broad to be \noperational as statements of designated uses. Thus, there should be \ngreater stratification of designated uses at the state level (such as \nprimary and secondary contact recreation). The appropriate designated \nuse may not be the use that would be realized in the water's \npredisturbed condition. Sufficient science and examples exist for all \nstates to inject this level of detail into their water quality standards.\" \nThe purpose of the section 303(d) list is to provide information about \nwater bodies relative to existing standards. Preparation of the list does not \nrequire states to reexamine whether those standards are appropriate. \nThere are disadvantages of taking an approach that combines the section \n303(d) process with standards review and revision. Any attempt to revise \nwater quality standards before or during the listing process would almost \ncertainly prevent timely fulfillment of section 303(d)-required tasks. The \nprocess for revising beneficial uses or water quality objectives is lengthy \nand it would be unlikely that the SWRCB and RWQCBs would be able to \ncomplete these revisions within the mandated 3-year time frame. The process for examining and assessing water quality standards is distinct \nand by necessity separate from the section 303(d) listing process. Federal \nlaw requires the states to review water quality standards \"at least once \nevery three years\" (40 CFR 131.20). During a triennial review, the: \n\"State shall .. . hold public hearings for the purpose of reviewing \napplicable water quality standards, and, as appropriate, modifying or \nadopting standards. Any water body segment with water quality \nstandards that do not include the uses specified in section 101(a)(2) of \nthe Act shall be re-examined every three years to determine if any new \ninformation has become available.\" \nThe often lengthy and labor-intensive process to review and change water \nquality standards is best handled through the established Basin Plan \nTriennial Review process. \nThe advantage of combining the triennial review process and the \ndevelopment of the section 303(d) list is that the SWRCB would be more \nlikely to identify real water quality problems. \nRecommendation: Alternative 1. See Policy section 1. Issue 2: Structure of the Section 303(d) List \nIssue: Should the State integrate the federal CWA requirements for assessing \nwater quality? What structure should be used? \nIssue Description: USEPA has issued guidance (USEPA, 2003b) that recommends states \nintegrate the report requirements of sections 303(d) and 305(b). \nSection 305(b) of the CWA requires that states and other jurisdictions \nreceiving CWA grant funding submit a water quality report to USEPA \nevery two years that evaluates the quality of the state's waters. The \nsection 305@) report contains summary information about water quality \nconditions in rivers, lakes, estuaries, bays, harbors, wetlands, and coastal \nwaters. \nThe SWRCB and RWQCBs prepare both the section 303(d) list and the \nsection 305(b) report. A key portion of the listing process is deciding how \nto address water bodies and sites identified as not meeting water quality \nstandards. \nBaseline: In 2002, the SWRCB submitted four lists to the USEPA: \nSection 303(d) List of Water Quality Limited Segments. Waters on this \nlist did not meet water quality standards due to pollutants. It is required \nthat USEPA approve this list. \nEnforceable Program List. Water quality standards were not met but the \nproblem is being addressed by another enforceable program. \nTMDL Completed List. Water quality standards were not met; a TMDL \nand implementation plan has been approved for the water body-pollutant \ncombination. \nMonitoring List. Insufficient data and information were available to \nplace the water body on the section 303(d) list. \nIn the past, California has developed the section 303(d) list independently \nof the CWA section 305(b) Report. After the section 303(d) list is \ndeveloped it is typically incorporated into the section 305(b) report. Alternatives: 1. \tDevelo~an all-inclusive list of impaired waters. This list would become \nthe section 303(d) list. The State could develop a list of impaired waters \nthat includes all waters that may not meet water quality standards without \nregard to whether the problem is best resolved by the implementation of a \nTMDL (i.e., due to a pollutant). The appropriate management action \nwould then be determined in an analysis separate from, and subsequent to, \nthe determination of whether standards are being met. \nThis alternative would provide consistency in the assessment approaches \nused by all RWQCBs while allowing the flexibility necessary to address \nregional differences and site-specific concerns. The maintenance of a \nsingle \"Impaired Waters List\" and database would allow the state to \nrespond to potential changes in USEPA regulations for section 303(d) \nimplementation. Future federal regulations could require state submission \nof a subset of this list of impaired waters. Should federal regulations \nchange in this regard, the structure of California's impaired waters list \nwould be easily amenable to sorting the waters to accommodate any such \nrequirements. \nCreating an \"impaired waters\" list goes beyond the requirements of state \nlaw in developing the listing and delisting Policy. CWC \nsection 13191.3(a) (Senate Bill [SB] 469) requires the SWRCB to prepare \nguidelines for the listing and delisting of waters and developing and \nimplementing the TMDL program and TMDLs pursuant to section 303(d) \nof the federal CWA. Since all waters that do not meet water quality \nstandards would be placed on the section 303(d) list, the identified \nproblems would extend beyond the scope of the TMDL program. \nThis alternative is very similar to the structure of the section 303(d) list as \nadopted in 1998. The 1998 list included all waters that were identified as \nnot meeting water quality standards. The expectation was that the \nRWQCBs would develop TMDLs for all waters on the 1998 section \n303(d) list. Many of the water bodies listed were not amenable to TMDL \ndevelopment for a variety of reasons including standards exceedance was \nnot due to a pollutant, additional research and monitoring was needed to \nidentify pollutants causing adverse conditions, etc. \n2. Place all waters that do not meet water aualitv standards on the \nsection 303(d) list and, for those waters with inadequate monitoring, data, \nuse a watch list or vreliminarv list. A committee of the NAS (2001) \nrecommended that before waters are placed on the section 303(d) list, all \nwaters should go through an initial screening assessment. This preliminary \nassessment would involve comparing available, and often limited, data on \nwater quality conditions with the existing applicable water quality \nstandards. If, based on this initial assessment, the water body is considered \nto exceed standards, it is advanced to a \"preliminary\" list for further consideration. The NAS committee recommended that placement on the \npreliminary list should be relatively easy, the consequences of which \nwould include additional investigation to determine the nature and reality \nof a suspected problem. The term \"preliminary\" indicates that water \nbodies on this list may later be placed on the section 303(d) list for action. \nSuch a preliminary list has been employed in some states (e.g., Florida). \nThose water bodies placed on the preliminary list would be the focus of \nadditional monitoring and assessment of new data and information. This \nadditional assessment would lead to a better understanding of the impacts \nto beneficial uses and water quality standards exceedances. If, as a result \nof the more complete assessment, there were sufficient evidence to \nindicate that water quality standards are indeed exceeded, the water \nsegment on the preliminary list would be moved to the section 303(d) list. \nThe NAS Committee has stated that this process would improve the \naccuracy of the listing process. Placement of a water body on the \npreliminary list serves as an indication to stakeholders that action should \nbe taken soon to achieve water quality standards and avoid the costs \nassociated with TMDL development. However, because of the \nconsequences of movement to the section 303(d) list, there may be an \nincentive to keep waters on the preliminary list indefinitely. This incentive \ncan be eliminated by requiring that a water body be automatically placed \non the section 303(d) list at the end of the next rotating basin monitoring \ncycle if additional analyses have not been undertaken. Such a requirement \nmay also provide an incentive for point and nonpoint pollutant sources to \ncontribute to the monitoring program in order to avoid the consequences \nof placement on the section 303(d) list. \n3. Use the Integrated Water Oualitv Re~ort Guidance to develou the section \n303(d) list and integrate it with the section 3051b) reDort. In 2003, \nUSEPA issued guidance on the integration of the CWA section 305(b) \nrequirements with the section 303(d) list (USEPA, 2003b). This guidance \nimplemented many of the recommendations of the NAS (2001). Instead \nof providing a single \"preliminary list,\" USEPA recommended the use of \nmultiple lists depending on the type of water quality problem, availability \nof data and information, and actions that are being implemented in water \nbodies. Implementation of the USEPA guidance <2003b) would require \nthe development of five major lists or categories of waters as follows: \nCategory 1: Attaining the water quality standard and no use is \nthreatened. Water bodies would be listed in this category if there are \ndata and information that meet the requirements of the state's \nassessment and listing methodology and support a determination that \nthe water quality standard is attained and no use is threatened. \nRWQCBs would consider scheduling these water bodies for future monitoring to determine if the water quality standard continues to be \nattained. \nCategory 2: Attaining some of the designated uses; no use is \nthreatened; and insufficient or no data and information is available \nto determine if the remaining uses are attained or threatened. \nWater bodies would be listed in this category if there were data and \ninformation which meet the requirements of the state's assessment and \nlisting methodology to support a determination that some, but not all, \nuses are attained and none are threatened. Attainment status of the \nremaining uses is unknown because there is insufficient or no data or \ninformation. Monitoring would be scheduled for these water bodies to \ndetermine if the previously attained uses remain in attainment, and to \ndetermine the attainment status of those uses for which data and \ninformation was previously insufficient to make a determination. \nCategory 3: Insufficient or no data and information to determine if \nany designated use is attained. Water bodies would be listed in this \ncategory when the data or information to support an attainment \ndetermination for any use is not available, consistent with the \nrequirements of the state's assessment and listing methodology. To \nassess the attainment status of these water bodies, the state should \nobtain supplementary data and information, or schedule monitoring as \nneeded. \nCategory 4: Impaired or threatened for one or more designated \nuses but does not require the development of a TMDL. \nCategory 4A: TMDL has been completed. Water bodies would be \nlisted in this subcategory once all TMDL(s) have been developed and \napproved by USEPA that, when implemented, are expected to result in \nfull attainment of the standard. Where more than one pollutant is \nassociated with the impairment of a water body, the water body will \nremain in Category 5 until all TMDLs for each pollutant have been \ncompleted and approved by USEPA. Monitoring would be scheduled \nfor these water bodies to verify that the water quality standard is met \nwhen the water quality management actions needed to achieve all \nTMDLs are implemented. \nCategory 4B: Other pollution control requirements are reasonably \nexpected to result in the attainment of the water quality standard \nin the near future. Consistent with 40 CFR 130.7(b)(i), (ii), and (iii), \nwater bodies would be listed in this subcategory when other pollution \ncontrol requirements required by local, state, or federal authority are \nstringent enough to implement any water quality standard applicable to \nsuch waters. USEPA expects these requirements to be specifically applicable to the particular water quality problem. Monitoring would be \nscheduled for these water bodies to verify that the water quality \nstandard is attained as expected. \nCategory 4C: Impairment is not caused by a pollutant. Water \nbodies would be listed in this subcategory if a pollutant does not cause \nthe impairment. RWQCBs would consider scheduling these water \nbodies for monitoring to confirm that there continues to be no \npollutant-caused impairment and to support water quality management \nactions necessary to address the cause(s) of the impairment. \nCategory 5: The water quality standard is not attained. The water \nbody is impaired or threatened for one or more designated uses by a \npollutant(s), and requires a TMDL. This category constitutes the \nsection 303(d) list of waters impaired or threatened by a pollutant(s) for \nwhich one or more TMDL(s) are needed. A water body would be listed \nin this category if it is determined, in accordance with the state's \nassessment and listing methodology, that a pollutant has caused, is \nsuspected of causing, or is projected to cause an impairment. When \nmore than one pollutant is associated with the impairment of a single \nwater body, the water body will remain in Category 5 until TMDLs for \nall pollutants have been completed and approved by USEPA. \nFor water bodies listed in this category, RWQCBs would provide . \nmonitoring schedules that describe when data and information will be \ncollected to support TMDL establishment and determine if the standard \nis attained. USEPA recommends that while the state is monitoring the \nwater body for a specific pollutant to develop a TMDL, it also monitor \nthe watershed to assess the attainment status of other uses. \n4. Integrate section 303(d) and section 305(b) re~ortinz reauirements but \nmodifv the use of the guidance to clearlv state the consequence of listing \nand the conditions that would trigger listing in each category. Building on \nthe USEPA Integrated Report Guidance (2003b), California's list structure \ncould: (1) describe the purpose of the category or list; (2) organize the lists \nto distinguish waters that meet standards from those that do not; (3) state \nthe consequence of being placed in a category or list; (4) state the \nconditions that would trigger listing in a category; and (5) modify the \nUSEPA guidance to integrate with California's TMDL Program. This \napproach was recommended in the July 2003 version of the proposed \nPolicy that was presented to the AB 982 PAG. \nUnder this alternative, the SWRCB, in coordination with the RWQCBs, \nwould develop an integrated water quality report that would present the \ncondition of all the State's waters. The water quality of each water body \nwould be assessed in the integrated report by comparison of measurements \n47 to applicable water quality standards. After the assessment, waters would \nbe placed in the appropriate category. The categories of waters \nrecommended for the California Integrated Water Quality Report \ncorrespond to the categories recommended by USEPA in the Integrated \nReport Guidance (2003b) as follows: \nCategories \nUSEPA Guidance California Integrated Report \nCategory 1 Standards Fully Attained List \nCategory 2 Standards Partially Attained List \nCategory 3 Planning List and Monitoring List \nCategory 4A TMDLs Completed List \nCategory 4B Enforceable Program List \nCategory 4C Pollution List \nCategory 5 Section 303(d) List of Water Quality \nLimited Segments \nIn order to comply with CWA sections 303(d) and 305(b), the integrated \nreport would be divided into two sections. The first section would assess \nwhether water quality standards are being met. This would be \naccomplished by determining whether there is sufficient data and \ninformation to conclude that water quality standards are being attained. \nThe planning list would contain waters where some data and information \nare available but the data and information are insufficient to conclude that \nwater quality standards are not attained. Waters not meeting standards \nwould be placed on the section 303(d) list unless: (1) a TMDL has been \ncompleted, (2) other pollution control measures are in place, or \n(3) documented impacts are not caused by a pollutant. Several states have \nused a planning list or preliminary list as recommended by NAS (2001). \nThe second section addresses several CWA section 305(b) requirements. \nThis section would contain the standards fully attained list, standards \npartially attained list, and the monitoring list. Waters on the standards \nfully attained list attain all standards. The standards partially attained list \nwould include waters for which one or more standards are attained and \ndata and information related to other standards are insufficient to \ndetermine attainment. Waters would be placed on a \"monitoring list\" if \ndata or information were not available to determine if water quality \nstandards are met. \nImplementation of this alternative would require the development of eight \nlists or categories of waters as follows: \nWaters that do not meet or potentially do not meet water quality standards \nPlanning List. Waters would be placed on this list if some data and \ninformation are available but are insufficient to determine whether water quality standards are attained. Water segments would be listed in this \ncategory when the data or information to support an attainment \ndetermination for any water quality standard is only partially available, \nconsistent with the requirements of the State assessment and listing \nmethodology. \nThe planning list would contain only a portion of the waters described in \nCategory 3 of the USEPA guidance (2003b). Waters placed in this \ncategory exceed applicable water quality objectives infrequently, have too \nfew samples to confidently assess that standards are exceeded, or lines of \nevidence contradict one another. \nWhile the planning list would help focus the site-specific monitoring \nactivities of the SWRCB and RWQCBs, it is possible that this list could be \nused to avoid listing waters on the section 303(d) list. To mitigate this \npotential problem, the planning list should have specific decision rules that \nrequire known but lower confidence for listing and require that monitoring \nis completed. \nWaters on the planning list would be scheduled for monitoring to \ndetermine if water quality standards or beneficial uses are not attained. \nThe waters on the planning list would also have high priority for \nmonitoring before the next section 303(d) list is completed. Thus, the \nplanning list would be used as the rationale to obtain the needed \nmonitoring. Because of limited state funds available for ambient \nmonitoring, a commitment from the SWRCB and RWQCBs to seek \nfunding for monitoring from interested parties either on a voluntary basis \nor through existing regulatory mechanisms would be needed (e.g., using \nthe authorities granted in CWC sections 13267 and 13225). As a last \nresort, the SWRCB and RWQCBs could use state funds identified for this \npurpose. State funds that could be used for this purpose include Surface \nWater Ambient Monitoring Program (SWAMP) funding (e.g., to complete \nsite-specific monitoring to identify water quality problems) and TMDL \nprogram funding (e.g., to identify pollutants responsible for observed \ntoxicity). \nSection 303(d) List of Water Quality Limited Segments. Waters would \nbe placed on this list if a water quality standard is not attained, the \nnonattainment is due to a pollutant or pollutants, and remediation of the \nstandards attainment problem requires a TMDL. \nThis category would constitute the section 303(d) list of water quality \nlimited segments for which one or more TMDL(s) are needed. A water \nsegment would be listed in this category if it were determined, in \naccordance with the State assessment and listing methodology that a pollutant has caused or is suspected of causing non-attainment of \nstandards. \nThis definition was used in the development of the 2002 section 303(d) list \nand narrows the scope of waters that need TMDLs to waters where the \nwater quality problem is due to a pollutant or pollutants. As TMDLs are \ncompleted for the identified waters, the water segment-pollutant \ncombination would be removed from this list. However, where more than \none pollutant is associated with standards non-attainment for a single \nwater segment, the water segment would remain on the section 303(d) list \nuntil TMDLs for all pollutants have been completed, are approved by \nUSEPA, and an implementation plan is adopted. \nWater Quality Standards are not met but the development of a TMDL is not \nrequired \nTMDLs Completed List. Water segments would be placed in this \nsubcategory once a TMDL has been developed and approved by USEPA \nand, when implemented, are expected to result in full attainment of the \nstandard. Where more than one pollutant is associated with the listed \nwater body, the water body would remain on the section 303(d) list until \nall TMDLs for each pollutant have been completed and approved by \nUSEPA. This category or list shows progress in the completion of TMDLs \neven though standards are not met. \nTo track implementation of TMDL(s), monitoring would be scheduled for \nthese water segments to verify that the water quality standard is met once \nthe water quality management actions are implemented. \nEnforceable Program List. Water segments would be placed in this \ncategory if pollution control requirements, other than TMDLs, were \nreasonably expected to result in the attainment of the water quality \nstandard in the near future. Water segments would be listed in this \nsubcategory when other pollution control requirements required by local, \nstate, or federal authority are stringent enough to implement water quality \nstandsds applicable to such waters. Criteria would be developed to ensure \nthat there is a high probability the existing program will address the \nidentified water quality problem so that this category could not be used to \navoid placement of waters on the section 303(d) list. Waters on this list \nwould be scheduled for monitoring as part of the enforceable program to \nverify that the water quality standard is attained as expected. \nPollution List. This category provides an approach for acknowledging \nwater quality problems that are not due to pollutants. Water segments \nwould be listed in this subcategory if beneficial uses are impacted but a \npollutant does not cause the impact. The problems identified on this list \nwould be those described as pollution (i.e., the man-made or man-induced alteration of the chemical, physical, biological and radiological integrity of \nwater (33 USC section 1362)) and would include invasive species, as well \nas, habitat, channel, or flow modifications that cause nonattainment of \nwater quality standards. \nHabitat, channel, or flow modification may affect water quality standards \nattainment under two sets of circumstances: (1) situations where these \nthree factors cause direct impairment of beneficial uses; and (2) where \nthey influence one or more water quality parameters (e.g., temperature or \nsediment) leading to impairment of beneficial uses. \nThe waters on this list would be scheduled for monitoring to confirm that \nthere continues to be no pollutant-caused impairment and to support water \nquality management actions. \nWaters that meet water quality standards or no data available \nStandards Fully Attained List. Water bodies placed in this category \nattain all water quality standards. Water segments would be listed in this \ncategory if available data and information demonstrate standards are met \nand support a determination that all water quality standards are attained. \nWaters on this list may be scheduled for periodic monitoring to confirm \nthat the waters are still clean. \nStandards Partially Attained List. Waters placed in this category attain \nsome water quality standards. Data and information are insufficient to \ndetermine if the remaining water quality standards are attained. Waters \nwould be listed in this category if data and information support a \ndetermination that some, but not all, standards are attained. Attainment \nstatus of the remaining standards would be unknown because data or \ninformation is insufficient. Monitoring would be scheduled for these \nwaters to determine if the previously attained standards remain in \nattainment, and to determine the attainment status of those water quality \nstandards for which data and information was previously insufficient to \nmake a determination. \nMonitoring List. Waters would be placed on this list if data and \ninformation were not available to determine if water quality standards are \nattained. This concept is similar to the planning list. This list would be \ndeveloped in stages because the number of waters with no information \ncould be quite large. To be manageable, the development of this list \nwould be completed on the same schedule as the rotating basin monitoring \nconducted by SWAMP. \n5. Narrow the focus of the Policy to section 303(d) list only. The SWRCB \ncould focus the Policy on the development of a narrowly defined \nsection 303(d) list. The list would include only those waters that do not meet water quality standards and a TMDL is needed to resolve the \npollutant problem and those waters that do not meet standards but \n(1) other programs address water quality impacts or (2) a TMDL has been \ncompleted and an implementation plan has been approved. The \nsection 303(d) list would, therefore, have two distinct categories of water \nquality limited segments: (1) waters still requiring a TMDL, and \n(2) waters where the water quality limited segment is being addressed. \nGeneral guidelines for the placement of the categories described above \ncould be provided to assure that these categories are used consistently. \nFor example, waters could be placed in the water quality limited segments \nstill needing TMDLs category if the conditions are met for placement in \nthe water quality limited segments category (section 3.1). Conversely, if \na TMDL has been completed, the water could be placed in the second \ncategory if standards are not met and: (1) a TMDL has been approved by \nUSEPA for the pollutant-water segment combination, and (2) an \nimplementation plan has been approved for the TMDL. \nWaters could also be put in the second category if water quality standards \nare not met and there is an existing regulatory program or programs being \nimplemented to address the identified problem. General guidelines for \nincluding a water segment in this category could includea determination \nthat: \n+ \tA regulatory program has been adopted and is being implemented by \nanother state, regional, local, or federal agency, and the program will \ncorrect the impairment. \n+ \tSufficient mechanisms exist to provide reasonable assurances that the \nprogram will address the impairment in a reasonable period of time. \n+ \tSufficient mechanisms to enforce the program exist or the RWQCB \notherwise has sufficient confidence that the program will be \nimplemented. \n+ \tWater quality standards attainment can be demonstrated through an \nexisting monitoring program or a future monitoring program with \nreasonable assurance of implementation. \n+ \tThe program contains conditions that require trackable progress, and \nsuch progress is tracked. \n+ \tFor alternative programs intended to control non-point source \ncontributions to an impairment, such programs comport with the \nrequirements of the Policy for Implementation and Enforcement of the \nNonpoint Source Pollution Control Program, including, but not limited \nto, the Key Elements of an NPS Pollution Control Implementation \nProgram (SWRCB, 2004a). Recommendation: By using this alternative the scope of the Policy is limited to the \nsection 303(d) list but this does not prevent SWRCB from using USEPA \nguidance (2003b) in developing the CWA section 305(b) report. For \nexample, the SWRCB could accomplish the integration of these reporting \nrequirements through the CWA section 106 work plan. A disadvantage of \nnot linking the section 303(d) and 305(b) reporting requirements is that \nany needed monitoring to identify waters not meeting standards would not \nbe mandated in statewide Policy. \nThis alternative is the preferred alternative because narrowly focusing the \nlisting process on the section 303(d) list complies with the requirements of \nstate law in developing the listing and delisting Policy. Waters that do not \nmeet water quality standards related to pollutants or toxicity would be \nplaced on the section 303(d) list. The additional category identifying water \nquality limited segments currently being addressed either through other \nprograms or approved TMDLs would help the RWQCBs and SWRCB \nfocus attention on waters where TMDLs are still required. \nAlternative 5. See Policy section 2. Issue 3: \t Weight of Evidence for Listing and Delisting \nIssue: \t What factors should comprise California's weight-of-evidence approach? \nWhat should the relationship among the various factors be? \nIssue Description: \t The 2001 Budget Act Supplemental Report required the use of a \"weight \nof evidence\" approach in developing the Policy for listing and delisting \nwaters and to include criteria that ensure the data and information used are \naccurate and verifiable. \nThe expression \"weight of evidence\" describes whether the evidence in \nfavor or against some hypothesis is more or less strong (Good, 1985). In \ngeneral, components of the weight-of-evidence consist of the strength or \npersuasiveness of each measurement endpoint and concurrence among \nvarious endpoints. Confidence in the measurement endpoints can vary \ndepending on the type or quality of the data and information available or \nthe manner in which the data and information is used to determine \nimpairment. \nScientists have used a variety of definitions for \"weight of evidence.\" A \nscientific conclusion based on the weight of evidence is often assembled \nfrom multiple sets of data and information or lines of evidence. Lines of \nevidence can be chemical measurements, biological measurements \n(bioassessment), and concentrations of chemicals in aquatic life tissue. \nBaseline: \t In 2002, SWRCB used a weight-of-evidence approach to evaluate \nRWQCB recommendations. Ten factors were used to assess the quality of \nthe measurement endpoints: (1) extent to which data quality requirements \nare met; (2) linkage between measurement endpoints and beneficial use or \nstandard; (3) correlation of stressor to response; (4) utility of measurement \nfor judging if standards or uses are not attained; (5) water body specific .--\ninformation; (6)sensitivity of the measurement endpoint for detecting a \nresponse; (7) spatial representativeness; (8) temporal representativeness; \n(9) quantitativeness; and (10) use of standard methods. Each water body- \npollutant combination was evaluated case-by-case. \nAlternatives: 1. Provide general description of the weight-of-evidence awroach. The \nPolicy would, under this alternative, require a weight of evidence \napproach to confirm that the available data and information favors or does \nnot favor placing waters on, or removing waters from, the section 303(d) \nlist. In applying the weight-of-evidence approach to listing decisions, the \nPolicy would provide guidance on data and information preprocessing, \ndata and information processing; and data assessment (i.e., combining \nestimates of standards exceedance). The weight of evidence approach would be a narrative process where \nindividual lines of evidence are evaluated separately and combined using \nthe professional judgment of the RWQCBs and SWRCB. The lines of \nevidence would be combined to make a stronger inference about water \nquality .standards attainment. Lines of evidence are typically data or \ninformation that pertain to an important aspect of a water body. Using this \napproach the SWRCB and RWQCBs would use their judgment to weigh \nthe lines of evidence to determine the attainment of standards based on the \navailable data. This general approach was used by the SWRCB in \ndeveloping the 2002 section 303(d) list (SWRCB, 2003a). \nUsing this approach, a single line of evidence, under certain \ncircumstances, could be sujjicient by itselfto demonstrate water quality \nstandards attainment. In other situations and with many data types, \nmultiple lines of evidence would be needed to determine if standards are \nattained. \nThis approach would follow a two-step process to accommodate the \nvariety of data that may be encountered. The first step is screening the \navailable data and information for comparison with numeric water quality \nobjectives that would be sujjicient by themselves to demonstrate standards \nattainment. The second step would be to consider the available data and \ninformation using a variety of listing factors that require multiple lines of \nevidence for listing. The listing factors that require multiple lines of \nevidence include: (1) Human Health, (2) Toxicity, (3) Nuisance Condition, \n(4) Adverse Biological Response, (5) Degradation of Biological \nPopulations or Communities, and (6)Trends in Water Quality. \nIt is possible that RWQCBs may have justification for listing or delisting a \nwater body but, under the Policy listing factors, action would not be taken. \nIn some instances, the available lines of evidence may conflict making it \ndifficult or impossible to determine if water quality standards are attained. \nWhile most lines of evidence are addressed by the assessment and listing \nmethodology, there may be circumstances when, due to additional or \nconflicting lines of evidence, RWQCBs may still feel compelled to place \nwater bodies on the section 303(d) list. The Policy could approach this \ncircumstance by specifying the factors to evaluate data and information, \nbut also allow the use of additional lines of evidence, alternate data \nanalysis procedures, and alternate exceedance frequencies depending on \nsite-specific factors. However, an approach of this sort may exclude some \ndata and information that still could support a listing or delisting decision. \nUnder these circumstances, RWQCBs should be allowed to recommend a \nlisting, delisting, or maintenance of a listing based on a situation-specific \nweight of evidence (i.e., where there is information showing standards are attained or not attained). If this approach were used, RWQCBs would be \nafforded significant discretion in determining the basis for listing or \ndelisting. To make sure the decision is transparent RWQCBs should be \nrequired to justify its recommendation by: \nt Providing any data or information supporting the listing; \nt Describing in fact sheets how the data or information affords a \nsubstantid basis in fact from which listing can reasonably be inferred; \nt Demonstrating that the weight of evidence of the data and information \nindicate that the water quality standard is not attained; and \nt Demonstrating that the approach used is scientifically defensible and \nreproducible. \nSWRCB would consider the basis for the situation-specific analysis in the \ncourse of the approval of the section 303(d) list. \nThe disadvantage of a situation-specific weight of evidence listing and \ndelisting factor is that listings could be decided inconsistently. The \nadvantage is that the decision rules used for these cases would be \ntransparent. \nThis alternative has been identified as the preferred alternative because the \nPolicy would establish decision rules for assessing compliance with water \nquality standards and allow flexibility to interpret multiple lines of \nevidence as dictated by circumstances present in the water body. \n2. Provide svecific descrivtion of the weight of evidence avvroach. Under \nthis alternative, the weight-of-evidence approach would be a numerical \nprocess where individual lines of evidence are evaluated separately and \nthen combined by converting the data to a single format and comparing \nthe line of evidence mathematically. Statistical weight of evidence \napproaches have been proposed (e.g., Smith et al., 2002; Bettinger et al., \n1995)but have not been widely used for placement of waters on the \nsection 303(d) list. \nSmith et al. (2002) presented a quantitative approach that provides a way \nto combine multiple lines of evidence in a calculation of a weight-of- \nevidence. A single number can then summarize the weight-of-evidence. \nIn this example, the method uses statistical theory and odds ratios to \ncombine the measures of risk from different lines of evidence. By \ncollapsing many lines of evidence into one metric, this approach has the \npotential to lose information when the data are summarized. In addition, \nall types of data and information may not be amenable to such a \nquantitative approach. The Massachusetts Weight-of Evidence Workgroup (Bettinger et al., \n1995) defined weight-of evidence as the process by which measurement \nendpoint(s) are related to an assessment endpoint to evaluate if there is a \nsignificant risk of harm to the environment. This quantitative approach \nincludes methods for: (1) weighting the individual measurement endpoints \nby evaluating how well they score against a set of ten attributes; \n(2) determining whether harm or lack of harm is indicated and the \nmagnitude of response, and; (3) graphically displaying the measurement \nendpoints in a matrix so the concurrence can be examined. This approach \nuses quantitative methodology in order to make the assessment process \nmore transparent and objective. \n3. Use best professional judgment (BPJ) of each RWOCB to determine \nweight-of-evidence in all circumstances. Under this alternative, each \nRWQCB would use its own approach and make its own judgments of the \nmethodology to use. This approach would allow RWQCBs to use a case- \nby-case assessment of which lines of evidence to use, alternate data \nanalysis procedures, and exceedance frequencies depending on site- \nspecific factors. \nWhile this approach would provide the maximum amount of flexibility for \nthe RWQCBs, it is possible that the lists generated would be very \ninconsistent from region to region. \nRecommendation: Alternative 1. See Policy sections 1, 3,3.11,4, and 4.11. Issue 4: Listing or Delisting with Single Line of Evidence \nA variety of numeric or narrative water quality objectives and beneficial \nuses can be used by themselves to assess whether water quality standards \nare attained. Using this approach, a single line of evidence, under certain \ncircumstances, is strong enough to make a conclusion about water quality \nstandards attainment. Approaches for assessing these lines of evidence that \ncould be used by themselves include: \nA. Numeric water quality objectives, criteria, or other applicable \nstandards; \nB. Marine bacterial standards; \nC. Freshwater bacterial standards; \nD. Narrative water quality objectives; \nE. Tissue data; \nF. Trash; \nG. Nutrients; and \nH. Invasive species. \nThese categories are discussed separately in Issues 4A through 4H. \n Issue 4A: \t Interpreting Numeric Water Quality Objectives and Criteria \nIssue: \t How are exceedances of a water quality objective or criterion evaluated? \nIssue Description: \t Water quality objectives or federally promulgated water quality criteria \nrepresent water quality levels that are not to be exceeded, or exceeded \nonly infrequently, in order to protect the designated beneficial uses of state \nwaters. Water quality objectives and the beneficial uses form two \ncomponents of water quality standards; the third component is \nimplementation of an antidegradation policy. \nWater quality objectives or criteria can be either numeric or narrative. In \ngeneral, numeric water quality objectives and criteria may quantitatively \naddress magnitude, frequency andlor duration of exposure to toxic \nchemicals or conditions. The chemical concentration addresses the \nmagnitude component of the objective (i.e., how much of a pollutant is \nallowable). Water quality objectives are the limit or level of a constituent \nor characteristic that is established for the reasonable protection of a \nbeneficial use of the water or the prevention of a nuisance in a specific \narea [CWC section 13050(h)l. Water quality objectives are generally \nestablished as maximum levels or concentrations of a pollutant, but may \nbe set as a minimum level for certain water quality parameters such as \ndissolved oxygen, or as a range for other parameters, such as pH. \nHowever, many water quality objectives are expressed as averages, \nmedians, or as a percentage of samples that exceed a numeric value. \nUSEPA has promulgated numeric criteria for toxic pollutants that \nsupplement existing state water quality standards. Regional water quality \ncontrol plans (Basin Plans) contain designated beneficial uses, water \nquality objectives, and an implementation program to achieve these \nobjectives. Applicable statewide plans and policies include, but are not \nlimited to, the State Policy for Implementation of Toxics Standards in \nInland Surface Waters, Enclosed Bays, and Estuaries; California Ocean \nPlan, the Thermal Plan, and State Water Resources Control Board \nResolution 68-16. USEPA's criteria for toxic pollutants are found in the \nCalifornia Toxics Rule (CTR). Applicable standards are also promulgated \nby the California Department of Health Services (DHS). \nPrior to conducting list assessments, RWQCBs should consider a number \nof factors. It should be determined if there is a sufficient number of \nsamples and whether those samples are spatially and temporally \nrepresentative of the water quality in the water segment. Additionally, the \nduration (i.e., averaging period) of concentrations expressed in the water \nquality objective or criterion should be addressed. Samples should, then be compared to the water quality objective to determine if an exceedance has \noccurred. \nBaseline: \t During the 2002 section 303(d) listing process, data were evaluated on a \ncase-by-case basis. RWQCB staff used the magnitude and duration \nexpressed in the water quality objectives to assess the State's waters in the \nBasin Plans. Data evaluation was usually expressed as the number of \nsamples exceeding the standard or guideline out of a total number of \nsamples. When appropriate, the magnitude of the measurements was also \nconsidered. \nAlternatives: 1. Evaluate numeric data using only the magnitude portion of numeric water \nquality obiectives or criteria. Under this alternative, data would be \ncompared to the magnitude component of water quality objectives only. \nDuration and frequency stated in the water quality objective would not be \nconsidered. This alternative would treat all water quality objectives as if \nthe duration was expressed as an instantaneous maximum. The advantage \nof this approach is that the analysis is simple and data do not need to be \nassessed before statistical analysis. The major disadvantage is that the \nduration and frequency components of the water quality objectives are \nignored and the water quality objectives are not interpreted as presented in \nthe Basin Plans, statewide plans, or federal regulation. \n2. Evaluate numeric data in terms expressed in the numeric water quality \nobjective or criterion. The evaluation of numeric data should bc consistent \nwith the expression of the numeric water quality objectives or water \nquality criteria. If the water quality objectives or criteria state a specific \naveraging period andlor mathematical conversion, the data should be \nconverted in a consistent manner prior to conducting list assessments. \nSufficient data are frequently not available to assess compliance during the \nstated averaging period. In these cases, the available data should be used \nto represent the averaging period. For example, if the water quality \nstandard is based on a four-day average and the RWQCB has only one \nsample for the four consecutive day period, that data should be used to \nrepresent the four-day average. \nUnder this alternative, to the extent possible, RWQCBs would use the \nmeasure that corresponds directly with the duration, magnitude, and \nfrequency portions of the water quality objective or criterion to represent \nthe data set. Some examples follow: \nA. \tSeveral measures of central tendency are associated with a number of \nwater quality standards, objectives, or criteria. Basin plans, statewide \nplans, and federal regulation contain standards with a variety of \naveraging periods, such as: t Annual average \nt Four-day average \nt 24-hour average \nt One-hour average \nt Median \nt Geometric mean \nB. Several water quality objectives are based on the maximum value, \nminimum value, or worst case value of the data set. Basin Plans, \nstatewide plans, and federal regulation contain water quality standards, \nobjectives, or criteria focused on maximum values such as: \nt Acute water quality criteria \nt \"Not to be exceeded\" maximum or minimum water quality \nobjectives \nC. \tSome water quality objectives have built in exceedance frequencies. \nThese types of water quality objectives include standards based on \npercentile of samples exceeded as stated in the water quality objective \nor criterion. \nD. Many standards or objectives do not have stated averaging periods. \nFor data that are not temporally independent (e.g., when multiple \nsamples are collected at a single location on the same day), the \nmeasurements should be combined and represented by asingle \nresultant value before the determination is made whether the standard \nis met. For these values, it is necessary to consider averaging the data, \nif it is likely that samples are not temporally independent. For \nexample, samples collected at the same location less than seven days \napart should be considered as one sample, with the median value used \nto represent the sampling period. A 7-day averaging period has been \nused by many states to avoid problems with temporal independence of \nsamples (Arizona Department of Environmental Quality (DEQ), 2000. \nFlorida Department of Environmental Protection (DEP), 2002). \nOnce raw data have undergone the necessary mathematical conversions to \nrepresent magnitude, frequency, and duration it is ready to be compared \nagainst water quality objectives or criteria to determine whether water . \t. \nquality standards are attained. Recommendation: The disadvantage of this alternative is that when data are limited, \nassumptions about the duration and frequency portions of the water quality \nobjective will have to be made unless it is determined that only large \nextensive data sets will be used to assess standards attainment. The \nadvantage of this alternative is that the form and expression of the water \nquality objective is used in section 303(d) list assessments; therefore, staff \nhas identified this alternative as the preferred alternative. \nAlternative 2. See Policy sections 6.1.5.6 and 6.1.5.7. Issue 4B: \t Interpreting Numeric Marine Bacterial Water Quality Standards \nIssue: \t How should numeric marine bacterial water quality standards be \ninterpreted? \nIssue Description: \t Water quality standards for beaches are contained in the California Ocean \nPlan and have been promulgated by DHS (pursuant to AB 411 [Title 17, \nCCR]). The Ocean Plan standards are implemented through NPDES \npermits. Local public health agencies implement the AB 411 standards \nand, if exceeded, beaches are posted. Postings indicate impaired water \nquality and the loss of a beneficial use. \nEnvironmental health agencies may also permanently post a beach at \nstorm drain outlets because the ocean water at the discharge (based on \nwater quality monitoring) exceed bacterial standards or as a precautionary \nmeasure. The latter action may not be based on water quality monitoring \ndata. \nBaseline: \t Before 2002, RWQCBs used a variety of approaches for evaluating \nmarine beach water quality data, postings, and closure information. The \ngeneral approach for developing recommendations for the 2002 \nsection 303(d) list related to bacterial standards exceedances, beach \npostings, and beach closures included: \n+ \trecommendations based on the frequency of water quality standards \nexceedances; \n+ \tthe consideration of frequency of water quality standard exceedances \nand additional, site-specific information, when appropriate; and \n+ \tplacement of a beach on the section 303(d) list when there was no \nother means to address the problem. \nIdeally, the frequency threshold for listing was the number of water \nquality standard exceedances in a relatively unimpaired watershed. Since \nsite-specific background data were not available, 10 percent of the total \ndays exceeding standards per year was used as the threshold for listing. \nThis value is based on studies of natural background conditions observed \non some southern California beaches. If sample collection was consistent \nover the sampling period, the number of samples exceeding standards was \nequivalent to the number of days exceeding the standard per year. \nPermanent postings were counted as exceedances when they were based \non site-specific water quality data. \"Precautionary\" postings were not \ncounted as exceeding water quality standards. The number of postings (the posting of warning signs on the beach by the \nlocal environmental health agency) or the total number of days posted was \nnot used in the assessment. \"Rain Advisories\" were considered in the \nsame manner as precautionary postings. Site-specific data collected \nduring storm events was used for listing determinations. \nAlternatives: 1. Interpret water aualitv standards case-bv-case. Under this alternative, \nRWQCBs would be given significant latitude in deciding what constituted \na standards exceedance. For each circumstance, RWQCBs would decide \nwhich waters to list, after considering the available data and information \nfor the site. The Policy would not provide guidance on data and \ninformation to use, standards exceedance frequency, estimated area \naffected, number of postings or closures that would trigger a listing, which \nstandards to apply, or other factors. This alternative was used for \nsection 303(d) listing decisions before 2002. \nThis alternative would foster inconsistent interpretation of standards, \nposting, and closure data and information because each RWQCB would \ndevelop its own set of decision rules. Conceivably, this alternative would \nallow listing of beaches with little information available as well as listing \nof sites that are well studied. Broad interpretation of standards could lead \nto large portions of California's coastline, including enclosed bays and \nestuaries, to be placed on the section 303(d) list. A very broad \ninterpretation would make it difficult for the SWRCB and RWQCBs in \nplanning for the development of TMDLs and focus efforts where \nregulatory response is needed most. \n2. Establish consistent process and decision rules to trigeer listing. Under \nthis alternative, the SWRCB and RWQCBs would assess compliance with \neach water quality standard using data and information generated by \nRWQCB regulatory activities and various local agencies. The data and \ninformation would come from the monitoring and regulatory activities of \nthe local environmental health agencies, monitoring activities \ndemonstrating compliance with NPDES permits, and special studies \nconducted by RWQCBs and recognized private and public institutions. \nDuring 2002, the Beach Water Quality Workgroup (BWQW) endorsed \nrecommendations of their Monitoring and Reporting Subcommittee \nregarding criteria to support listing sites on the section 303(d) list \n(BWQW, 2003). The BWQW is a group of state agencies, environmental \nhealth agencies, environmental organizations, the regulated community, \nand other institutions focused on the improvement of water quality at \nbeaches throughout California. The Monitoring and Reporting \nSubcommittee consists of representatives from the SWRCB, RWQCBs, \nlocal environmental health agencies, regulated dischargers and Heal the \nBay. Recommendations of the Monitoring and Reporting Subcommittee of the \nBWQW \nA. Listing should be based on the frequency of water quality standards \nexceedances. The frequency of exceedances of water quality objectives \nestablished by the SWRCB in the Ocean Plan, and the exceedances of \nstandards established by DHS (Title 17 CCR) should determine when an \nocean water bodvlbeach segment is listed. This reuresents the most \" \nappropriate means of measuring the failure to meet water quality \nobjectives and the loss of a recreational (REC-1) designated beneficial \nuse. \nNumerous studies indicate that bacterial levels vary considerably over \nshort periods of time and distances. The magnitude of bacterial levels \nusually vary by source, the concentration of the source contaminate, and \nthe volume of discharge. The magnitude of bacteria does not justify the \nuse of bacterial levels for section 303(d) listing since they measure neither \nloss of beneficial use nor a failure to attain water quality objectives. \nMonitoring frequencies, with the exception of daily monitoring, employed \nby environmental health agencies and many dischargers do not accurately \nreflect the duration of the failure to meet the established standards. \nConsequently, only the frequency of exceedances should be used. \nSWRCB and DHS (AB 41 1, Statutes of 1997) have respectively \nestablished water quality objectives and bacterial standards for marine \nbeaches. When these bacterial standards are exceeded, the local health \nofficerlenvironmenta1 health agency must warn the public that standards \nhave been exceeded by posting warning signs on the beach where the \nstandard exceedances have occurred. The posting of warning signs on the \nbeach constitutes a failure to meet water quality objectiveslstandards and \nthe loss of REC-1 beneficial use for that water body. \nRoutine bacteriological monitoring of ocean water is conducted in \naccordance with the requirements of AB 411 and various NPDES permits \nissued by RWQCB. AB 41 1 monitoring is conducted by local \nenvironmental health agencies. The latter monitoring is conducted by \nagencies discharging sewage effluent into the ocean waters. The data \ncollected in these monitoring programs should be used to identify beaches \nwhere water quality does not meet state bacteriological standards for \nmarine beaches. \nImplementation: RWQCB staff may use the frequency of \"postiags\" by \nthe local environmental health agency as the \"first screen\" to determine if \na water body should be listed. When beaches are rarely or never posted \nand when they are frequently posted, the RWQCB may be able to make \nthe appropriate determination without reviewing the bacteriological data. \nThis data must clearly be indicative of the water quality at the monitoring station in question. The number of postings and the total number of days a \nbeach is posted should not be considered alone since postings may not \naccurately reflect the frequency that the water body does not meet the \nhealth standards or water quality objectives. An analysis of the \nbacteriological data should be conducted when posting data reported to the \nSWRCB by local agencies does not provide a clear method for making a \nlisting decision. \nA beach should be listed when there is no enforcement action available to \naddress the water quality impairment, and the most appropriate means to \naddress the water quality impairment is a TMDL. Generally, the number \nof beach closures should notbe considered in the listing criteria since the \ncauses of beach closures can usually be addressed by RWQCB \nenforcement actions. If site-specific conditions warrant their use, e.g., \nbeach closures caused by high indicator bacterial densities with an \nunknown source, RWQCB staff may use this data. Other site-specific \ninformation should be considered when appropriate. For example, BMPs \nmay have been instituted to address impairment and a TMDL may no \nlonger be required to address the problem. \nB. \tThe threshold frequency for listing should be the number of water \nquality standard exceedances in a watershed that is minimally \nimpacted by human activities. At least portions of total and fecal \ncoliform and enterococcus bacteria are naturally occurring in the \nenvironment, and their presence does not necessarily indicate fecal \npollution from human and domestic animals. As a result, the receiving \nwater from natural runoff in creeks and streams may contain significant \nlevels of coliform and enterococcus bacteria causing the water body to \nexceed the bacterial standards. \nTo adequately compensate for natural occuning indicator bacteria, each \nRWQCB should establish a \"reference\" beach in their region where \npossible. The reference beach is one where adequate ba~teriological data \nhas been collected and is available from a minimally impacted water body, \ni.e., one that is not impacted or only minimally altered by human activity. \nThe frequency of exceedances at this site becomes the threshold for \ndetermining a bacteriological impaired water body. This requires the \nidentification of watersheds within defined regions that have not been \nenvironmentally altered by human activity where possible. \nIf data is not available from a minimally impacted water body, USEPA \nrecommends that the threshold for exceedances should be 10percent of \nthe total samples collected. If water quality monitoring at any given site is \nonly conducted during the AB 411 period (April 1 through October 31), \nthe threshold frequency for exceedances at that site should be set at \n4 percent of the total samples (Noble et al., 1999). Implementation: RWQCBs should identify, where possible, a minimally \nimpacted water body within that region and collect bacteriological data to \ndetermine what is the appropriate threshold to use for the frequency \ncriteria. Lacking a reference beach, the RWQCB must select and use the \nmost appropriate threshold frequency. This will generally be either \n10percent or 4 percent of the samples as the exceedance threshold. \nSignificant rainfall may occur during the AB 411period, however. When \nthis occurs, RWQCBs should consider excluding the wet-weather data \nfrom the data set if the 4 percent threshold is used since the use of \n4 percent is based on dry-weather monitoring. \nC. \tListing should be based on a valid data set. RWQCBs should have \nconfidence that the bacteriological data set is adequate and unbiased \nfor listing purposes. In most instances, the data set for a given location \nshould be derived from routine monitoring by either a discharger or the \nlocal environmental health agency. \nImplementation: RWQCB staff must ascertain the validity of their data \nset. There may be instances where the number of samples collected may \nbe inadequate for determining the impairment of a water body or, when \ndoubts exist, determining that it is unimpaired. Every effort should be \nmade to collect a sufficient amount of data before this determination is \nmade. This may involve special studies or increased monitoring. \nD. \tListing should be based on the frequency of water quality standards \nexceeding the threshold number in multiple years. The entire \nbacteriological data set for the time period between listings for any given \nsite should be used to determine impairment and the need to implement a \nTMDL. The CWA calls for listings to be conducted every two years, but \nthe period has been lengthened to three-year intervals.' Using multiple \nyears of data is more likely to ensure the listing is representative of the \nactual water quality at the beach since an unusually wet or dry year should \nnot unduly affect the data set. \nImplementation: The entire data set between listing periods should be \nused to determine if the frequency threshold has been exceeded, unless \nthere is a reason to consider the data on a yearly basis. A suitable reason \nfor considering less than the entire data set may be the implementation of \na BMP. If only one year in the period exceeds the threshold, professional \njudgment should be exercised in determining if the water body in question \nshould be listed. \n' Some members of the Monitoring and Reporting Subcommittee believe that the minimum amount of data used for \nlisting purposes should encompass a minimum of three years. - - E. \tPermanent postings should be counted as exceedances when they are \nbased on site-specific water quality data. \"Precautionary\" postings \nshould not count as water quality exceedances. Local environmental health \nagencies may permanently \"post\" beach areas adjacent to storm drains \nand creek discharges with warning signs. These postings are long term \nand are based on the experience of the local agency and the accumulation \nof sufficient data to show that the ocean water in the area is often impaired \nwhen there is a discharge. This type of posting is a \"permanent posting\". \nThere are other instances when warning signs are posted because the local \nhealth agency believes that the receiving water will be impaired by the \ndischarge even though there is little or no confirmation monitoring to \nvalidate this belief. These are referred to as \"precautionary postings\". \nAs discussed under Recommendation A, beach listings for impairment due \nto elevated levels of bacteria should be based on water quality data. Since \npermanent postings are typically based on monitoring results, these \npostings should be counted as exceedances of water quality parameters \nand used in the listing process. \nA permanent posting therefore constitutes water quality impairment and \nmust be listed. Precautionary postings not supported by water quality data \nshould not be considered in the listing process even though both types of \npostings result in a loss of beneficial use in the area of the posting. \nImplementation: RWQCB staff must obtain posting information from \neach local environmental health jurisdiction to differentiate permanent \npostings from precautionary postings. A revised data collection and \nprocessing system to be employed by the SWRCB may allow this \ninformation to be posted on their web site. \nF. \t\"Rain Advisories\" should be considered in the same manner as \nprecautionary postings. \"Rain advisories\" are issued by local health \njurisdictions when rainfall is imminent or after rainfall has begun. These \nadvisories are precautionary in nature and are not issued on the basis of \nmonitoring data. These advisories are usually issued in lieu of posting the \nbeach during the non-AB 41 1 periods. During the AB 411 period, routine \nmonitoring is required, and if the AB 41 1 standards are exceeded the \nbeach must be posted. Consequently, monitoring data is usable to the \ndegree that it is appropriate during rainfall. \nAB 41 1 and its regulations do not authorize the use of \"rain advisories\". \nThey are an activity that local health jurisdictions generally conducted \nbefore the passage of AB 41 1 and the practice has been continued. No \nprotocols have been established for the issuance of these advisories. Most routine bacteriological monitoring by both dischargers and \nenvironmental health agencies continues as scheduled during wet-weather \nperiods. If an agency suspends monitoring during rainfall or within \n72 hours of rainfall, the involved monitoring stations are, in effect, \nmonitored only during dry-weather since bacterial levels usually revert to \nbackground levels 72 hours following rainfall. Consequently, the \nfrequency threshold for listing should be reduced to 4 percent of the \nsamples collected. \nImplementation: No implementation issues exist since the \nrecommendation essentially says to ignore these advisories. \nG. Establish monitoring stations at defined distances from storm drain \ndischarges in order to enhance data consistency. Monitoring locations \nhave been established in NPDES permits by RWQCBs and the local \nhealth agency establishes monitoring locations for its AB 411regulatory \nactivities. AB 411 and its regulations do not prescribe the location of \nmonitoring stations in relation to storm drain discharges. As a result, no \nconsistency exists between the agencies conducting monitoring activities \nrelative to the distances samples are collected from storm drain discharges. \nThe BWQW has recommended that the distance of a monitoring station \nfrom a storm drain discharge be set at 25 yards, but it is unknown how \nmany health agencies or RWQCBs are following this recommendation. \nImplementation: Neither RWQCBs nor DHS have the authority to \nestablish a consistent location for monitoring stations from storm drain \ndischarges. RWQCBs set the monitoring locations for NPDES compliance \nbut they have no authority over health iurisdictions' monitoring locations. \nDHS may have the statutory authority to determine monitorin~locations, \nbut, if so, it did not exercise this authority in the regulations. TMDL \ncompliance monitoring may further complicate any action regarding this \nrecommendation. \nH. \tDifferences in the results of laboratory analyses utilizing different \nlaboratory methods are insignificant. Currently, most health agencies \nuse a defined substrate methodology for the laboratory analyses of their \ncollected samples. Because USEPA has not approved this method, \ndischargers are either using membrane filter or multiple tube fermentation \nmethodologies for sample analysis. Bight '98 studies (Noble et al., 1999) \nand correlation studies conducted by local public health laboratories and \napproved by DHS demonstrated that there was no significant difference in \nthe results each method produced. \nImplementation: No implementation issues exist, I. \tIn the absence of site-specific data, the length of beach to be listed \nshould be 50 yards on each side of the storm drain discharge. The \nMonitoring and Reporting Subcommittee has recommended that \nmonitoring stations be located 25 yards from the source of the impairment, \ne.g., storm drain discharge. When the bacterial standard(s) are exceeded, \nsigns are routinely posted at 25 yards on each side of the source of the \nimpairment. They can be seen for a distance of approximately 25 yards. \nConsequently, the loss of beneficial use is approximately 50 yards on each \nside of the source of impairment. \nIn order to assess the area of beach impacted by the storm drain discharge, \n\"adaptive\" sampling may be employed by some agencies when a \nmonitoring station frequently exceeds bacterial standards. In these cases, \nsigns are posted at a greater distance from the source discharge point. \nThese distances are reported to SWRCB and are in the database. \nIn some cases, two monitoring stations may be linked by hydrological \nconditions. It may also be demonstrated, in the future, that the amount of \nflow and its from the discharge point can significantly increase the \namount of beach affected by the discharge. In both cases, the entire area -\naffected should be listed. \nImplementation: The distance recommended is for guidance purposes \nonly. The establishment of a TMDL, when appropriate, should address \nthe problem regardless of the distance cited in the listing. \nSWRCB Staff Response to the BWQW Recommendations \nA. \tListing should be based on the frequency of water quality standards \nexceedances. Frequency of water quality standard exceedances should be \nused to determine compliance with California Ocean Plan and AB 411 \nstandards. It is recommended that a beach be placed on the section 303(d) \nlist when there is no other way to address the problem. For example, \nbeach closures will not be listed if the closure is due solely to a pipe \nbreakage because the most efficient way to address this problem would be \nthrough some form of enforcement action. Site-specific data and \ninformation shall be used to determine if a TMDL is the most appropriate \napproach to address the problem. RWQCBs shall be asked to assemble \ninformation regarding the implementation of other enforceable efforts to \naddress the identified problem. \nB. \tThe threshold frequency for listing should be the number of water \nquality standard exceedances in a watershed that is minimally \nimpacted by human activities. The threshold frequency for listing should \nbe the number of water quality standard exceedances in a watershed that is \nminimally impacted by human activities. RWQCBs shall be asked to identify one or more reference beaches in a relatively unimpaired \nwatershed to account for any naturally occurring indicator bacteria. \nIn the absence of site-specific background data or other site-specific study, \n10 percent of the total samples collected will be used as the threshold for \nlisting. If water quality monitoring is conducted only during April 1 \nthrough October 31, four percent of the total samples shall be used as the \nthreshold for listing. \nC. \tListing should be based on a valid data set. The confidence in the data \nset used to make listing decisions shall be temporally and spatially \nrepresentative of the conditions at the beaches. \nD. \tListing should be based on the frequency of water quality standards \nexceeding the threshold number in multiple years. The entire data set \nbetween listing periods (i.e., multiple years) shall be used to assess \nstandards exceedance. Shorter time frames are allowable if management \nactions have been implemented that improve water quality. In these cases, \nonly data and information collected after the management action \nimplementation shall be used in the assessment. \nE. Permanent postings should be counted as exceedances when they are \nbased on site-specific water quality data. Permanent postings based on \nsite-specific water quality data shall be counted as exceedances and placed \non the section 303(d) list. Precautionary postings shall not be counted as \nwater quality standards exceedances. \nF. \t\"Rain Advisories\" should be considered in the same manner as \nprecautionary postings. Site-specific data collected during storm events \nshall be used for listing determinations. If data collection by local \nagencies is halted during rainfall or within 72 hours of rainfall, the \nmonitoring shall be considered dry weather monitoring and the four- \npercent exceedance frequency shall be used. \nG. \tEstablish monitoring stations at defined distances from storm drain \ndischarges in order to enhance data consistency. Data from all \nmonitoring stations shall be used in the assessments supporting the section \n303(d) list. In reporting the spatial characteristics of the sample location, \nRWQCBs report the sample location distance from storm drains or other \ndischarge points. \nH. \tDifferences in the results of laboratory analyses utilizing different \nlaboratory methods are insignificant. The RWQCBs shall aggregate \ndata from all methods and analyze as one data set. I. The length of beach to be listed shall be 50 yards on each side of the \nstorm drain discharge. The distance recommended is for guidance \npurposes only. The establishment of a TMDL, when appropriate, should \naddress the problem regardless of the distance cited in the listing. If site \nspecific data are available, RWQCBs should be allowed to determine the \nlength of beach to list on a case-by-case basis, the length of beach to be \nlisted on each side of the discharge point, or the sampling location. No \nspecific guidance should be provided that limits the RWQCBs discretion \nto establish the area affected. \nThis alternative has been identified as the preferred alternative because it \nprovides for consistent interpretation of the applicable standards, by \nstandardizing, to the extent possible, the approach for interpreting marine \nbeach water quality data and information. \nRecommendation: Alternative 2. See Policy sections 3,3.3, and 4.3. Issue 4C: Interpreting Numeric Freshwater Bacterial Water Quality Standards \nIssue: How should numeric freshwater bacterial water quality standards be \ninterpreted? \nIssue Description: Several counties have ordinances containing bacterial standards that can \ntrigger freshwater beach swimming warnings, postings, or closures (DHS, \n2001). As with marine waters, postings are indicative of impaired water \nquality and the number of postings measure loss of a beneficial use. \nThe RWQCBs have not previously implemented a consistent approach for \nevaluating freshwater beach water quality data, postings, and closure \ninformation. \nBaseline: During the 2002 listing process, RWQCBs developed recommendations \nfor freshwater bacterial water quality objectives on a case-by-case basis. \nFor freshwater bodies, each RWQCB compared monitoring data to Basin \nPlan water quality objectives. No specific approach or guidelines were \nmandated. Frequency of standards exceedance was used to assess \nnonattainment. Typically, RWQCBs used an exceedance frequency of \n10 percent. \nAlternatives: 1. Intemret freshwater bacterial standards on a case-by-case basis. \nUnder this alternative, RWQCBs would be given significant latitude in \ndeciding what constitutes a standards exceedance. For each situation, \nRWQCBs would decide which waters to list after considering the \navailable data and information for the site. The Policy would not provide \nguidance on what data and information to use, standards exceedance \nfrequency, estimated area affected, number of postings or closures that \nwould trigger a listing, which standards to apply, or other factors. This \nalternative has been used for all freshwater bacterial standards \nsection 303(d) listing decisions. \nThis alternative would allow a region-specific interpretation of standards, \nposting, and closure data and information because each RWQCB would \ncontinue to develop its own set of decision rules. Conceivably, this \nalternative would allow listing of freshwater bodies with little information \navailable as well as sites that are well studied. This alternative would \nallow for a broad interpretation of standards and place of large portions of \nCalifornia's lakes, rivers, streams, and canals on the section 303(d) list. A \nbroad interpretation would not help the SWRCB and RWQCBs in \ncorrecting problems through the development of TMDLs. Additionally, it \nwould be difficult to focus efforts where regulatory response is needed \nmost. \n2. \tEstablish consistent orocess and decision rules to trianer listinn based on \nthe BWOW recommendations. Under this alternative, SWRCB and RWQCBs would assess compliance with each water quality standard \nusing the data and information generated by the regulatory activities of the \nRWQCBs and various local agencies. Data and information would come \nfrom the monitoring and regulatory activities of the local environmental \nhealth agencies, monitoring activities conducted to demonstrate \ncompliance with NPDES permits, and special studies that may be \nconducted by RWQCBs or recognized private and public institutions. \nThese changes would be compared to applicable water quality standards in \nregional water quality control plans (basin plans) or bacterial standards \ncontained in CCR. \nAlthough specifically focused on marine water quality, the BWQW \nrecommendations could be used as the foundation for developing listing \nrecommendations for freshwaters. The advantage of using these \nrecommendations is that the State would use a consistent approach for \naddressing bacterial standards in fresh and saltwater. A possible \ndisadvantage is that some of the BWQW recommendations are focused \nonly on marine waters, such as the 4 percent exceedance frequency that \nwas developed using measurements of bacteria in marine waters. \nHowever, there is nothing in the record and staff has no reason to believe \nthat background fecal coliform or other fecal-related bacterial contaminant \ndensities should be different in fresh waters (Petrailia, personal \ncommunication). Listings could be limited to locations where there is a \nhigh likelihood of human fecal contamination and where there is \nsubstantial water contact by people. \nAnother disadvantage is that the monitoring of freshwater lakes, rivers, \nstreams and canals may not occur as frequently as monitoring on marine \nbeaches. This problem could be addressed by providing limited guidance \non the characteristics of an acceptable data set. For freshwaters, the data \nshould be sufficient to assess compliance with applicable water quality \nstandards. Data collected less frequently than weekly should be used with \ncaution and monitoring collected during wet and dry conditions should be \nidentified. \nMonthly data or a limited, non-routine data set (e.g., sampling frequency \nis less than once per month) can be used when coupled with an \nunderstanding of the watershed, including potential sources of the \nbacteria, and bacterial fate and transport processes. \nThis alternative is the preferred alternative because it provides for the \nconsistent interpretation of the applicable standard and standardizes, to the \nextent possible, the interpretation of freshwater bacterial water quality data \nand information. \nRecommendation: Alternative 2. See Policy sections 3.1,3.3, and 4.3. \n74 Issue 40: \t Interpreting Narrative Water Quality Objectives \nIssue: \t How should SWRCB and RWQCBs interpret narrative water quality \nstandards? \nIssue Description: \t Water quality standards often contain narrative water quality objectives to \ndescribe a requirement or a prohibition for a constituent or parameter that, \nif not exceeded, will provide reasonable protection for beneficial uses of \nthe specified water body. The SWRCB and RWQCBs have used a variety \nof guidelines or scientifically derived values to interpret narrative water \nquality objectives. \nFederal regulation explicitly states that narrative water quality standards \nshould be assessed in developing the section 303(d) list. Narrative water \nquality standards are subject to substantial subjectivity in interpretation \nand typically take the form: No toxics shall be discharged in toxic \namounts. For example, the San Diego RWQCBs Basin Plan toxicity \nobjective states that \"all waters shall be maintained free of toxic \nsubstances in concentrations that are toxic to, or that produce detrimental \nphysiological responses in human, plant, animal or aquatic life.\" To ensure \nthat the designated beneficial uses have been protected the toxicity \nobjective further states, \"compliance with this objective will be \ndetermined by use of indicator organisms, analyses of species diversity, \npopulation density, growth anomalies, bioassays of appropriate duration, \nor other appropriate methods as specified by the Regional Board\" \n(San Diego RWQCB, 1994). \nBaseline: \t In developing the 2002 section 303(d) list, the determination of standard \nor use attainment were based on the RWQCB and SWRCB interpretation \nof narrative water quality objectives. Compliance with narrative water \nquality objectives was considered on a case-by-case basis using all \nrelevant data submitted to the RWQCBs. Data were evaluated using \nrelevant and well-accepted standards, criteria, guidelines, or other \nobjective measures that interpret the sensitivity of a benchmark in \ndetermining standards or beneficial use attainment. Guidelines that were \nwell accepted and had high levels of certainty and applicability were used. \nEach of these evaluation guidelines had a strong scientific basis. Examples \nincluded: NAS tissue guidelines, U.S. Food and Drug Administration \n(USFDA) action levels, USEPA screening values, Maximum Contaminant \nLevels (MCLs); fish advisories; approaches used in the Bay Protection and \nToxic Cleanup Program (BPTCP); published temperature thresholds; \npublished sedimentation thresholds; Federal agency and other state \nsediment quality guidelines (SQGs); DHS bacterial standards; California \nDepartment of Fish and Game (DFG) guidelines, Maximum Tissue \nResidue Levels (MTRLs), etc. Evaluation guidelines with no scientific basis for judging standards or \nbeneficial use attainment were not used. Overall, in the 2002 \nsection 303(d) list, constituents that violated the narrative water quality \nobjective and were not supported with acceptable evaluation guidelines \nwere not listed or were recommended for placement on the monitoring list. \nThe exceptions were two listings that exceeded the water quality standard \nfor aquatic life. One was for sedimentation that was based on a 1998 DFG \nbioassessment report; and the second was a listing for nutrients, continued \nfrom the 1998 list that was a part of the Salton Sea TMDL. \nAlternatives: 1. Do not allow the use of anv guidelines for intemreting narrative water \naualitv standards. This alternative would provide the RWQCBs with the \ngreatest flexibility for interpreting narrative water quality standards and \ncan be advantageous when applied to regional and site-specific water body \nconditions. However, with nine RWQCBs, multiple interpretations of \nnarrative water quality standards could result and listing or delisting \ndecisions could be inconsistent. \nWhen the interpretation of a narrative water quality standard has pointed \nto a listing decision, the SWRCB and RWQCBs have used available \ndefensible guidelines to assess quantitatively the potential for standards to \nbe exceeded. This includes guidelines used as translators and draft \nguidelines that have a strong scientific basis. Specific evaluation values \nshould address the beneficial use, applicability of the evaluation value, \nprevious use of the criteria, as well as other factors. Draft guidance could \nbe used when no other criteria are available and the scientific foundation \nand application of the criteria are not in question. \nNarrative objectives have been interpreted in two ways-comparison to the \nstrictly narrative objective or interpretation using local, state, or federal \ncriteria or guidelines. An example of evaluation criteria based on State \nguidelines to protect a beneficial use is the Los Angeles RWQCBs use of \nDFG guidelines for macroinvertebrate and bioassessment, supporting the \nconclusion that sedimentation im~acts were detrimental to aauatic life in \nthe Calleguas Creek Watershed (Anderson et al., 1998). A &termination \nof exceedance of the narrative water quality objective was based on the \nuse of standard bioassessment methods and a 1998 bioassessment report. \nThe DFG guideline further provides guidance in sampling and defines \nwater quality objectives by statistical distribution when appropriate. \nThe Central Valley RWQCB's water quality objective for color-\"Water \nshall be free of discoloration that causes nuisance or adversely affects \nbeneficial usesn-is an example of a narrative water quality objective, \ncommon in many Basin Plans, that does not have a quantitative translator. \nNarrative water quality objectives devoid of a translator are subjective; \nsome rely primarily on BPJ. BPJ can be defined as the ability to draw conclusions and make interpretations based on experiments, \nmeasurements, literature, or other forms of information. BPJ is subjective \nand open to a variety of interpretations based on individual observations, \nknowledge, and experience. While BPJ differs among various personnel- \nthe applicable knowledge and experience of each individual will vary- \nconclusions using BPJ must be based on scientifically defensible data. \nNarrative water quality objectives do not quantify the water quality \nparameters necessary to clearly determine if beneficial uses are being \nprotected. Presence of a pollutant does not automatically translate into \nimpairment of a beneficial use. To be most useful, a narrative water \nquality objective should include a description of the process used to derive \na quantitative evaluation value to help interpret the narrative water quality \nobjective. Interpretive evaluation guidelines can identify the difference \nbetween the impaired and unimpaired state of the water body by using \nindicators as a quantitative measure of water quality and can be used to \nestablish relationships between pollutants and their impact on water \nquality. Examples of indicators are suspended sediment concentrations, \nnumbers of spawning fish, algal biomass, or total phosphorus \nconcentration. The selected target value must lead to achievement of water \nquality standards. \nThe use of a narrative water quality objective without a translator is often \nnot scientifically defensible because the interpretation of impairment \nbecomes subjective. The water quality objective is presumed to be \nprotective of beneficial uses. Without a quantifiable evaluation guideline, \nthe water quality standard is only a description of the desired level of \nwater quality; sufficient data to show cause for a listing is not provided. \n2. On a case-by-case basis, allow RWOCBs to establish the method and \napproach for intemreting narrative water aualitv standards. This \nalternative would provide flexibility for the RWQCBs and would address \nsite-specific concks. Various guidelines and criteria are available from \nstate and federal agencies, as well as other countries that the RWQCBs \ncould use to ensure attainment of water quality objectives. However, \nguideline selection on a case-by-case basis would lack statewide \nconsistency. USEPA (2002a) provides guidance on the organizational \nstructure for documenting assessment and listing methodology and also \nprovides information on the content of these methodologies. \nFor narrative water quality objectives, USEPA (2002a) states -\n\"Narrative criteria are adopted to supplement numeric criteria or if \nnumerical criteria cannot be determined. Narrative criteria are \ndescriptions of the conditions necessary for a water body to attain its \ndesignated use, whereas numeric criteria are values expressed as chemical concentrations, toxicity units, aquatic community index \nlevels, or other numbers deemed necessary to protect designated uses. \nA \"translator\" identifies a process, methodology, or guidance to -. -\nquantitatively interpret narrative criteria statements. Translators may \nconsist of biolorrical assessment methods (ex.. field measures of the ., \t . -\nbiological community), biological monitoring methods (e.g., laboratory \ntoxicity tests), models or formulae that use input of site-specific \ninformationldata, or other scientifically defensible methods. Translators \nare particularly useful for addressing water quality conditions that \nrequire a greater degree of sophistication to assess than can be typically \nexpressed by numerical criteria that apply broadly to all waters with a \ngiven use designation. Criteria must be based on sound scientific \nrationale and should contain sufficient parameters or constituents to \nprotect the designated use.\" \nFrom the above guidance, interpretation of narrative water quality \nobjectives without a translator would not be transparent or consistent and \nvery difficult to defend if the scientific rationale for the listing is not \npresented. A number of guidelines and criteria exist that can be used to \nhelp interpret narrative water quality objectives. For example, translators \nof narrative water quality objectives can be pulled from numerous sources. \nTable 2 lists some beneficial uses and the guidelines that have been used \nby the various RWQCBs to interpret narrative water quality objectives. \nUnder this alternative, the RWQCBs would be able to use any guidelines \nfor interpreting narrative water quality objectives. However, without \nspecific guidance to the RWQCBs in the interpretation of narrative water \nquality objectives, different endpoints could result leading to \ninconsistencies in interpretation of water quality standards. \nTABLE 2: AVAILABLE GUIDELINES FOR THE INTERPRETATION OF NARRATIVE WATER \nQUALITY OBJECTIVES \nBeneficial Use Evaluation Guidelines \nAquatic Life \t NAS tissue guidelines, BPTCP approaches to identify toxic hot spots, \npublished temperature thresholds; published sedimentation thresholds; \nFederal agency and other state SQGs, DFG guidelines, Sediment \nApparent Effects Thresholds from California and other states toxicity \nguidelines \nFish Consumption \t NAS tissue guidelines, USEPA screening values fish advisories, State \nAction levels; Fish and Shellfish Consumption Advisories; USEPA \nWater Quality Advisories \nShellfish Harvesting Shellfish harvesting bans . Beneficial Use Evaluation Guidelines \nDrinking Water \t DHS Primary MCLs, Secondary MCLs; USEPA Primary MCLs, \nSecondary MCLs; MCL goals; Office of Environmental Health Hazard \nAssessment (OEHHA) Public Health Goals pHGs); DHS Action Levels; \nDrinking Water Health Advisories; Water Quality Advisories; Suggested \nNo-Adverse-Response Levels (SNARLS): Prop 65 levels: California \nEnvironmental Protection Agency (CalEPA), USEPA and NAS drinking \nwater Cancer Risk \nTaste and Odor \t DHS Secondary MCLs, USEPA Secondary MCLs, State action levels \n(taste and odor-based), USEPA Drinking Water Contaminant Fact Sheets \nAgricultural Water Agricultural Water Quality Goals published by the Food and Agriculture \nsupply Organization of the United Nations \nAdapted from Marshak, 2000. \n3. Establish general guidance for the interpretation of narrative standards. \nState the types of interpretative guidelines that may be used. When . \nselecting interpretative evaluation guidelines to translate narrative water \nquality objectives, the most appropriate water quality limit would be \nselected to protect the applicable beneficial use within a water segment. \nThe examples of interpretative guidelines, presented in Table 2 could be \nused by the RWQCBs for interpreting narrative water quality objectives \nwhile still providing flexibility in dealing with site-specific circumstances. \nHowever, this list iH not inclusive and, by itself, doe; not achieve the \nstatewide consistency desired in a listing policy. \nWhen evaluating narrative water quality objectives or beneficial use \nprotection, RWQCBs and the SWRCB should identify interpretative \nevaluation guidelines that represent standards attainment or beneficial use \nprotection. The Policy should provide specific guidance on selection of \ninterpretative evaluation guidelines to the extent possible. Guidance on \nseleciion of evaluation for tissue and sediment quality is \npresented in Issues 4E and 5C, respectively. \nFor some parameters, however, evaluation guidelines may be required \noutside of those recommended by the Policy. In order to make sure the \nguidelines are selected transparently and are applicable to the \ncircumstance before the RWQCB, an alternate evaluation guideline could \nbe used if it can be demonstrated that the evaluation guideline is: \nt Applicable to the beneficial use \n+ Protective of the beneficial use + Linked to the pollutant under consideration \n+ Scientifically-based and peer reviewed \n4 Well described \nRWQCBs should assess the appropriateness of the guidelines for use in \nthe hydrographic unit and present justification for the alternate guideline -\nin thd water body fact sheet. \nStaff has chosen this alternative as the preferred alternative because it \nprovides RWQCBs the flexibility to identify the appropriate interpretative \nevaluation guideline that represents standards attainment or beneficial use \nprotection while the mechanism used to reach the listing decision is \ntransparent. \n4. Establish explicit guidance for specific parameters svecifving which \nguidelines should be used. List the guidelines in the Policy. The SWRCB \nand RWQCBs can strengthen the use of chemical, physical, and biological \ndata in the assessment of narrative water quality objectives and develop a \nscientifically defensible listing process by establishing explicit guidance \nfor the parameters that will be used to list a water quality impairment. A \nlisting based strictly on a narrative water quality objective without a \ntranslator is subjective and relies exclusively on case-by-case judgement \nto list a water body as impaired on the section 303(d) list. Therefore, to \nmake the mechanisms used to reach these judgements transparent, \nexceedances based on a narrative water quality objective must be suitable \nfor calculation and specific evaluation guidelines should be presented in \nthe Policy. \nUnder this alternative, RWQCBs would be required to use specific values \nand would not have the flexibility to compare data sets to measures that \nbest represent site-specific conditions. If specific guidelines were \nrequired, RWQCBs would not be able to incorporate the most recent \nversions of the available guidelines or the most recent research that may \nset values that are more protective of the designated beneficial use. \nRecommendation: Alternative 3. See Policy section 6.1.3. Issue 4E: \t Interpreting Aquatic Life Tissue Data \nIssue: \t How should chemical residue concentrations in tissue be interpreted? \nIssue Description: \t The presence of toxic substances in water bodies can be determined by \nanalyzing tissues from aquatic organisms. Concentrations of toxic \nsubstances in water are often too low or transitory to be reliably detected \nthrough the more traditional methods of water sample analysis. Also, \nmany toxic substances are not water soluble, but can be found associated \nwith sediment or organic matter. Aquatic organisms are sampled because \nthey bioaccumulate and bioconcentrate toxic substances to levels that may \nbe many hundreds of times the levels actually in the water. This \nconcentration factor facilitates detection of toxic pollutants. \nThe tissue pollutant levels of aquatic organisms, collected from a water \nbody, determine whether substances are bioaccumulating and detect \npotential impacts to aquatic life and on human health from the \nconsumption of fish and shellfish. Bioaccumulation reflects the uptake and \nretention of a chemical by an aquatic organism from all surrounding media \n(e.g., water, food, and sediment). Bioconcentration refers to the uptake and \nretention of a chemical by an aquatic organism from water only. Both \nbioaccumulation and bioconcentration can be viewed simply as the result \nof competing rates of chemical uptake and depuration (chemical loss) by \nan aquatic organism (USEPA 2000d). \nBioaccumulation is a measurable phenomenon, rather than an effect. \nMerely identifying the presence of a chemical substance in the tissues of \nan organism is not sufficient information to conclude that the chemical \nwill produce an adverse effect. All chemical substances have the potential \nto produce adverse effects (e.g., toxicity). The likelihood that a chemical \nsubstance, in the tissues of an organism, will produce an adverse effect is a \nfunction of the physical and chemical properties of the substance, the \nconcentration of the chemical in the tissues of the organism, and the length \nof time the organism is exposed to the compound. Environmental \npollutants vary widely in their potential to produce toxicity. Therefore, \npollutant-specific information must be used to determine the potential for \na bioaccumulated substance to produce adverse effects. \nTrace metals such as mercury and lead, and trace organic compounds such \nas DDT (dichlorodiphenyltrichloroethane), PCBs (polychlorinated \nbiphenyls) and PAHs (polynuclear aromatic hydrocarbons) are \nbioaccumulative substances commonly measured. Fish and shellfish \ntypically take in these substances at a greater rate than they can eliminate \nthem, causing the substance to accumulate in tissue over their lifetimes. \nConcentrations in aquatic organisms from highly bioaccumulative \nchemicals may pose unacceptable human health risks from fish and shellfish consumption and may also biomagnify in aquatic food webs, a \nprocess whereby chemical concentrations increase in aquatic organisms of \neach successive trophic level due to increasing dietary exposures (e.g., \nincreasing concentrations from algae, to zooplankton, to forage fish, to \npredatory fish) (USEPA 2000d). \nEvaluation of tissue chemical concentrations are based on screening \nvalues established by USEPA, NAS, and additional criteria used in the \nState Mussel Watch Program (SMWP) reports, such as elevated data \nlevels (EDLs) and MTRLs for the protection of human health and wildlife. \nData is collected to determine the prevalence of selected bioaccumulative \npollutants in fish and shellfish and to identify sources of these pollutants. \nIn addition, human health risks are estimated for those pollutants for \nwhich cancer potency factors andlor reference doses have been \nestablished. \nBaseline: \t In developing the 2002 section 303(d) list measures used to interpret \nchemical residue concentrations in tissue included MTRLs and public \nhealth guidelines. In addition to MTRLs, guidelines that were well \naccepted and had a strong scientific basis with high levels of certainty and \napplicability were used. Examples included: NAS tissue guidelines, \nUSFDA action levels, USEPA screening values, MCLs; and fish \nadvisories. The use of numeric evaluation values, focused on protection \nfrom consumption of aquatic species (e.g., MTRLs or USFDA values), \nwas sufficient by themselves to demonstrate standards attainment. The \nState did not set a minimum number of samples; however, at least two \nsamples were sufficient to determine attainment. \nAlternatives: 1. Do not use this factor. It has been suggested that analysis of fish and \nshellfish tissue concentrations is not needed to determine attainment of \nwater quality standards because scientifically defensible methods for \ndetermining standards attainment already exists through numeric ambient \nwater quality criteria. \nMeasurements for ambient water column concentrations of pollutants are a \nbasis for determining impairment. However, the lack of pollutants in the \nwater column does not always mean that designated uses are being \nprotected. Water body-specific factors sometimes cause pollutants, \nincluding pathogens, to accumulate in fish and shellfish tissue at higher \nlevels than predicted by the methodology used to derive numeric human \nhealth or aquatic life criteria. Examples of such factors include water \ntemperature, nutrient levels, food web structure, the concentration of \ndissolved organic carbon in ambient water, and accumulations in the \nsediment. Therefore, a water body can meet numeric ambient water \nquality criteria, but not attain designated uses because fish or shellfish tissue concentrations exceed levels that are protective of human health or \naquatic life. \nThe use of numeric evaluation values to interpret chemical residue \nconcentrations in tissue is an important indicator that designated uses are \nbeing attained. The use of tissue measurements adheres to USEPA's \nguidance to use all readily available data and information. \n2. Interpret bioaccumulation data on a case-by-case basis. This alternative \nprovides the RWQCBs with the most flexibility, as it would account for a \nvariety of site-specific conditions that could be encountered. However, \nthis could also lead to inconsistencies in assessment methodology. \nGuidance by USEPA (2003b) recommends that, when determining \nwhether a pollutant impairs a segment, listing methodologies should be \nconsistently applied and scientifically valid. The decision rules in the \nmethodology should provide the opportunity to see exactly how \nassessment decisions are made. \nThere are many measurements that can be used to interpret chemical \nresidue concentrations in tissue. Screening values developed by OEHHA \nand USEPA measure contaminant concentrations found in aquatic \norganisms for the protection of human health. The USFDA has also \nestablished maximum concentration levels for some toxic substances in \nhuman foods (USFDA, 1987) and NAS has established recommended \nmaximum concentrations of toxic substances in animals (NAS, 1972). The \nUSFDA levels are based on specific assumptions on the quantities of food \nconsumed by humans and the frequency of their consumption. The \nUSFDA limits are intended to protect humans from the chronic effects of \ntoxic substances consumed in commereial foodstuffs and include \neconomic considerations. The NAS limits were established not only to \nprotect organisms containing toxic compounds, but also to protect species \nthat consume these contaminated organisms. The NAS has set guidelines \nfor marine fish but not for marine shellfish. \nMTRLs and measurement endpoints from other State and federal agencies, \nother states, and other countries are also available for comparison. \nMTRLs were developed by SWRCB staff from the human health water \nquality objectives in the 1997 California Ocean Plan (SWRCB, 2001b) \nand from the CTR (40 CFR Part 131, May 18,2000). These objectives \nrepresent levels that protect human health from consumption of fish, \nshellfish, and water (freshwater only). MTRLs are used as alert levels or \nguidelines indicating water bodies with potential human health concerns. \nHowever, MTRLs are a calculated value derived by multiplying the \nhuman health water quality objectives by the bioconcentration factor \n(BCF) for each substance as recommended in the USEPA Draft \nAssessment and Control of Bioconcentratable Contaminants in Surface Waters (USEPA, 1991a). They are an assessment tool and are not \ncompliance or enforcement criteria. While mRLs have value as alert \nlevels, their use is questionable in assessing water bodies for placement on \nthe section 303(d) list. IviTRLs are not based on any site-specific \nconsiderations. As such MTRLs should not be used to evaluate fish or \nshellfish tissue data for listing decisions. \nTo ensure consistency in listing, specified numeric values should be used \nto trigger a listing. consistent values can be developed to provide limited \nflexibility to address site-specific situations encountered by the RWQCBs. \nwithout guidance, listings-could be based on screening values that &e not \nthe most protective of the designated beneficial use. \n3. Establish consistent value to trigger listing, Tissue concentrations are \ndifficult to evaluate in terms of impact on aquatic life; however measures \ndo exist to aid in the interpretation of chemicals bioaccumulated in fish or \nshellfish tissue. The NAS (1972) has evaluated tissue residues for several \nchemicals and has made recommendations that reflect scientific \nunderstanding of the relationship between aquatic organisms and their \nenvironment. Screening values (Table 3) represent levels that are \nprotective of aquatic life. \nScreening values developed by the OEHHA and the USEPA assume that \nhuman exposure to contaminants can result from edible aquatic species \nand are based on the general U.S. population's average consumption rate \nfor fish and shellfish. The criteria, therefore, represent concentrations in \nwater that protect against the consumption of aquatic organisms \ncontaining chemicals at levels greater than those predicted to result in \nsignificant human health problems. The current values are listed in \nTable 4. \nTABLE 3: WILDLIFE CRITERIA OF BIOACCUMULATION PROTECTION FOR EVALUATION \nMONITORING DATA \nContaminant NAS \nGuidelines* \nAldrin 100 Wag \nTotal DDT 1,000 Pag \nTotal PCBs 500 ~g/kg \nChlordane (total) 100 Pg/kg \nDieldrin 100 Pg/kg \nEndosulfan (total) \t 100 ~dkg \nEndrin \t 100 Pdkg \nLindane (gamma hexachloro-cyclohexane) 100 Pflg \nhexachloro-cyclohexane (total) \t 100 Pdkg \nHeptachlor \t 100 Ndkg \nHeptachlor epoxide \t 100 irglkg \nToxaphene \t 100 pglkg \n*NAS, 1972. \t pglkg = micrograms per kilogram \n(measurements based on wet tissue samples) \n The values from these two tables apply to muscle tissue (e.g., fillets) or \nedible flesh (e.g., whole mussels or clams) samples collected in all types \nof waters (marine, estuarine, fresh). \nIn the 2002 list, USFDA action levels were used as an evaluation value. \nHowever, USFDA action levels were established to address levels of \ncontamination in foods sold in interstate commerce. Thus, the \nmethodology used by USFDA in establishing tolerances is directed at \nhealth risks of contaminants in commercial fish and shellfish (for interstate \ncommerce) rather than in locally harvested fish and shellfish and were \nnever intended to be protective of local water bodies and recreational and \nsubsistence fisherman. USEPA has concluded that USFDA action levels \ndo not provide as great a level of protection for consumers of fish and \nshellfish caught and consumed than do human health criteria (USEPA, \n2003b). Listings based on USFDA action levels may not be the most \nprotective of beneficial uses and, therefore, should be accompanied by \nwater body-specific data showing nonattainment of beneficial uses. \nAdditional values may also be available from the SMWP. The SMWP has \nbeen evaluating bioaccumulation in mussels, fresh water clams, and oyster \ntissues since mid 1970 and use EDLs and MTRLs. EDLs provide a \ncomparative measure that ranks a given concentration of a particular \nsubstance with previous data collected by the SMWP. EDLs were \ndetermined by pooling all SMWP data from 1977 through 1997 by species \nand exposure, ranking the concentrations of each toxicant from highest to \nlowest concentration (including nondetects), calculating the cumulative \nfrequency of occurrence and percentile ranking for all concentrations, and \nidentifying and designating the concentrations of the toxic substance \nrepresenting the 85th percentile (EDL 85) and the 95th percentile (EDL \n95). EDLs are based on the relative ranking of each measurement, rather \nthan a percentage of the highest concentration obtained and reflect the \nbiases of the data upon which they have been based. EDLs do not assess \nadverse impacts, nor do they represent concentrations that may be \ndamaging to the mussels, clams, or to a human consuming these species. \nThey do not directly relate to MTRLs, FDA action levels, or NAS \nguidelines. Therefore, EDLs should not be used to evaluate shellfish or \nfish tissue data. \nThe use of consistent values aid in the interpretation of chemicals \nbioaccumulated in fish or shellfish tissue. Evaluation of tissue chemical \nconcentrations based on screening values established by the USEPA and \nNAS provide consistent interpretation of the levels of chemical residue \nconcentrations in tissue that impact beneficial uses. TABLE 4: \tSCREENING VALUES FOR THE PROTECTION OF HUMAN HEALTH FROM THE \nCONSUMPTION OF FISH AND SHELLFISH \nContaminant OEHHA Screening USEPA Screening \nValues* Values** \nArsenic I.O mgikg 1.2 mg/kg*** \nCadmium 3.0 mg/kg \nMercury 0.3 mgkg \nSelenium 2.0 mgikg \nTributyltin 1.2 mgkg \nTotal DDT 100 Pgikg \nTotal PCBs 20 Pgikg \nTotal PAHs 5.47 Pgkg \nChlordane (total) 30 ~gikg \nDieldrin 2.0 P@g \nEndosulfan (total) 20,000 Pg/kg \nEndrin 1,000 ~g/kg \nLindane (gamma 30 ~g/kg \nhexachloro-\ncyclohexane) \nHeptachlor epoxide 4.0 ~g/kg \nHexachlorobenzene 20 i*g/kg \nMirex 800 \nToxaphene 30 ~gikg \nDiazinon 300 ~gikg \nChlorpyr~fos l0,OOO P& \nDisulfoton 100 PA \nTerbufos 80 \nOxyfluorfen 546~gikg \nEthion 2,000 ~dkg \nDiox~n 0.3 ngikg \n*Brodberg and Pollock, 1999 mg/kg = milligrams per kilogram (parts per mill~on) \n**USEPA, 2000c ngikg =nanograms per kilogram \n***USEPA, 2000b (measurements based on wet tissue samples) \n4. \tProvide guidance to trigger listine. Various measures exist that can be \nused to interpret chemical residue concentrations in tissue. Tissue \npollutant levels of organisms can be compared to values established by \nOEHHA or USEPA for the protection of human health or NAS for the \nprotection of aquatic life to determine if beneficial uses have been \nimpaired. Measurement endpoints from other State and federal agencies \ncan also be used to translate appropriate narrative water quality objectives. \nAcceptable tissue concentrations can be measured either as muscle tissue \n(preferred) or whole body residues. Residues in liver tissue alone are not \nconsidered a suitable measure because livers are generally not targeted for \nconsumption. Composite samples may yield a cost-effective and perhaps more accurate estimate of tissue concentration because many tissue \nsamples are combined before chemical analysis. \nAnalyzing the tissue from one bottom-feeding fish species (a trophic level \nthree species) and one predator fish species (atrophic level four species) at \neach site can adequately assess differences in bioaccumulation of various \ncontaminants. Bottom-feeding species accumulate contaminant \nconcentrations by consuming benthic invertebrates and epibenthic \norganisms living in contaminated sediment. Predator species are good \nindicators of persistent pollutants that can biomagnify through several \ntrophic levels of the food web. \nThe discovery of specific contaminants during water quality or sediment \nstudies, or the identification of pollutant sources is one reason for \nconducting fish tissue analysis. Site-specific information (water or \nsediment data, data from municipal and industrial sources, or pesticide use \ndata) are critical factors in assessing the impact of a contaminant. \nAdditionally, tissue from appropriate target species permits comparison of \nfish, and shellfish contamination over a wide geographic area. \nThis is the preferred alternative because RWQCBs would have the \nflexibility to compare data sets to the most appropriate measure that can be \nused to interpret chemical residue concentrations in tissue. Screening \nvalues that could trigger a listing decision are described in Alternative 3. \nBy not requiring specific guidance, RWQCBs could incorporate the most \nrecent versions of the aforementioned documents or the most recent \nresearch that may set values that are more protective of the designated \nbeneficial use (as long as the evaluation guideline meet the criteria in \nsection 6.1.3of the Policy). \nRecommendation: Alternative 4. See Policy sections 3.5,4.5,and 6.1.3. Issue 4F: \t Interpreting Data on Trash Impacts to Water Bodies \nIssue: \t How should data on trash be interpreted? \nIssue Description: \t Trash or litter that accumulates in waterways may be offensive and cause a \nnuisance condition. Nuisance is defined in the CWC and in narrative water \nquality objectives in Basin Plans. Trash can be floating material, such as \nsolids that can cause nuisance or adversely affect beneficial uses. Table 5 \npresents some examples of types and sources of floatable debris as \nreported by USEPA. \nTABLE 5: TYPES AND SOURCES DEBRIS OF FLOATABLE \nSource Examples of Debris Released \nStorm Water Discharges \t Street litter (e.g., cigarette butts, filters, and filter elements), \nmedical items (i.e., syringes), resin pellets, food packaging, \nbeverage containers, and other material from storm drains, \nditches, or ~noff. \nCombined Sewer Overtlows \t Street litter, sewage-related items (condoms, tampons, and \napplicators), medical items (i.e., syringes), resin pellets, and \nother material from storm drains, ditches, or runoff. \nBeachgoers and Other Nonpoint \t Food packaging, beverage containers, cigarette butts, toys, \nSources (NPS) \t sewage, pieces of wood and siding from construction \nprojects, and trash (e.g., beverage containers, food \npackaging) left behind by workers in forestry, agriculture, \nconstruction, and mining. \nShips and Other Vessels \t Fishing equipment (e.g., nets, lures, lines, bait boxes, ropes, \nand rods), strapping bands, light sticks (used by recreational \ndivers and by fishermen to light up fishing lines), plastic \nsalt bags, galley wastes, household trash, plastic bags and \nsheeting, and beverage yokes (six pack rings for beverage \ncontainers). \nSolid Waste Disposal and Landfills \t Materials such as garbage and medical waste. \nOffshore Mineral and Oil and Gas Data recording tape, plastic drill pipe thread protectors, \nExploration hard hats, gloves, and 55-gallon drums. \nIndustrial Activities \t Plastic pellets and other materials \nIllegal Dumping or Littering Food packaging, beverage containers, cigarette butts, \nappliances, electronics, and ocean and street litter. \nAdapted from Woodley, 2002. Land-based sources of debris cause 80 percent of the marine debris found \non our beaches and waterways (USEPA, 2003~). Floatable debris on \nbeaches and in waterways is considered an aesthetic problem. \nSuspended or settleable materials must also be considered as defined in \nthe Basin Plans. Examples of these narrative water quality objectives are: \n\"waters shall not contain suspended or settleable materials in \nconcentrations that cause nuisance or adversely affect beneficial uses.\" \nUnlike floatables, settleable materials are not always noticeable. These \nmaterials include glass, cigarette butts, construction debris, batteries, and \ndiapers. Settleables can be a source of bacteria and toxic substances and \ncan also impact wildlife. \nMany types of data and information can be used to support a finding of \nnuisance but primarily non-numeric information has been used. Some \nnumeric data submitted comes from \"Clean-Up Days\". Organizations \nthroughout the state sponsor cleanup days, usually along the coast or \ncreeks typically for one day. These events result in trash and debris \ncollections from the beaches and waterways. \nBaseline: \t During the 2002 section 303(d) listing process, SWRCB and RWQCBs' \nreceived several submittals of non-numeric information and limited \namounts of data in support of trash listing decisions. In general, it could \nnot be determined if these submittals were temporally or spatially \nrepresentative of water body conditions. Currently, there are \n30 pollutantlwater body combinations that are listed due to trash impacts. \nAlternatives: 1. Use non-numeric information (such as photographs) to support listing \ndecisions. Under this alternative, water bodies would be listed if non- \nnumeric or qualitative information were available to show that water \nquality standards were not met. Non-numeric information would include \nvisual assessments. Visual assessment documents waterway and \nwatershed conditions and uses. These assessments require minimal \ntechnical equipment or training and rely primarily on an individual's \nsensory abilities and common sense. \nPhotographic monitoring, also referred to as \"photo documentation,\" \nprovides a permanent visual documentation of specific waterway andlor \nwatershed conditions. Visual assessments can be used to document \nconditions from the viewpoint of the individual observer, and are therefore \nusually qualitative or, at best, semi-quantitative. This type of assessment \ncan be used as a baseline for gross problem identification, or for tracking \ngross changes over time. Photographs are easy to understand but \ninterpretation between sites in a water body or between different locations \nis difficult to do in a consistent manner. Using photo documentation by itself, without any other supportive \ninformation, to list a water body for trash raises some,important issues. \nPhotographs alone are difficult to interpret spatially and temporally. In \naddition, photographs can be easily modified or altered to portray the \ndesired effect or the bias of the photographer. \nEven though photographs by themselves may be equivocal evidence that \nstandards are not met; they can be used to support listing decisions or \nindicate that additional monitoring is needed to better characterize trash \naccumulation. Photo documentation is most useful as a secondary line of \nevidence, used in conjunction with other lines of evidence. \n2. List trash using numeric data with non-numeric information in the \nassessments to support numeric data. This alternative would require that \nboth numeric and non-numeric data and information be used to support \nlisting decisions. Even though there are limitations in using non-numeric \ninformation such as photographs in the listing process, this information \ncould serve as an indication that additional monitoring needs to be \nperformed to better characterize the problem. \nThe types of numeric data that could be used include trash cleanup day \ndata or spatially and temporally representative measurements of trash in \nwaterways or at beaches. In order for these data to be interpreted, \nRWQCBs would need some numeric way of translating the narrative \nwater quality objectives for nuisance so the data can be clearly and \npredictably interpreted. At present, numeric evaluation guidelines are not \navailable to interpret trash data in terms of water quality objectives or \nbeneficial use attainment. An alternative to a trash evaluation guideline is \nto compare trash accumulation to reference conditions (i.e., waters \nscarcely impacted by trash accumulations). Waters would be placed on \nthe section 303(d) list if visual assessments and numeric water quality \nobjectives or evaluation guidelines show that trash is a water quality \nproblem. \nIt would be difficult for the RWQCBs to implement either of these \napproaches. \n3. Identify trash as a problem using numerical data and non-numeric \ninformation (as described in Alternative 2) but allow existing programs to \naddress anv identified water-related trash problem. This option would \nrequire placement of water bodies on the section 303(d) list, as described \nin Alternative 2, but would establish a specific mechanism to place waters \nin the Water Quality Limited Segments category where an existing \nprogram is addressing the water quality problem in lieu of a TMDL. \nTrash is typically thrown directly on beaches and into rivers and streams. \nSome trash enters waterways by blowing in from adjacent areas, but most trash enters these waterways via storm drains. Litter is intentionally or \naccidentally discarded in watersheds and, during major storms, flushed \nthrough the storm drains into the rivers and streams. \nIf trash is a nuisance in water bodies of the State and storm drains are the \nmajor source, then existing storm water permits could be used to reduce \nthe trash discharged via storm drains. \nTypically, storm water permits require the permittee to develop and \nimplement a Storm Water Management Plan (SWMP) that is intended to \nreduce pollutant discharged in storm water to the \"maximum extent \npracticable.\" The SWMP provides the framework for the development \nand implementation of specific program components, ranging from legal \nauthority and funding, to BMP programs. The storm water permits require \nthat standards are met, but the mechanism used to meet the standards is the \nuse of ever evolving and more effective BMPs, which can include \nstructural controls. All permit requirements are enforceable. \nWater bodies could be placed in the Water Quality Limited Segments \nBeing Addressed category if an existing program or programs are \naddressing the water quality problem for trash. General guidelines for \nincluding a water segment in this category could include a determination \nthat: \n+ \tA regulatory program has been adopted and is being implemented by \nanother state, regional, local, or federal agency, and the program will \ncorrect the impairment. \n+ \tSufficient mechanisms exist to provide reasonable assurances that the \nprogram will address the impairment in a reasonable period of time. \n+ \tSufficient mechanisms to enforce the program exist or the RWQCB \notherwise has sufficient confidence that the program will be \nimplemented. \nt \tWater quality standards attainment can be demonstrated through an \nexisting monitoring program or a future monitoring program with \nreasonable assurance of implementation. \n+ \tThe program contains conditions that require trackable progress, and \nsuch Dromess is tracked. . \t-\n+ \tFor alternative programs intended to control non-point source \ncontributions to an impairment, such programs comport with the . \t-\nrequirements of the policy for Implementation and Enforcement of the \nNonpoint Source Pollution Control Program, including, but not limited \nto, the Key Elements of an NPS Pollution Control Implementation \nProgram (SWRCB, 2004a). \nRecommendation: Alternative 3. See Policy sections 2.2,3.7,3.7.2, and 4.7.2. Issue 4G: Interpreting Nutrient Data \nIssue: How should nutrient data be interpreted? \nIssue Description: Nutrients, in appropriate amounts, are essential to the health and continued \nfunctioning of aquatic ecosystems. Excessive nutrients, however, can \nresult in undesirable growth of macrophytes or phytoplankton and \npotentially harmful algal blooms, leading to oxygen declines, imbalance of \naquatic species, public health risks, and a general decline of the aquatic \nresource. \nExcessive nutrient loading has been identified as one of the leading causes \nof water quality impairments of the nation's waters. Nitrogen and \nphosphorus are the primary causes of cultural eutrophication; the most \nrecognizable manifestation is algal blooms. Other chronic symptoms \ninclude low dissolved oxygen (DO), fish kills, murky water, and depletion \nof desirable flora and fauna. \nNarrative objectives for nutrients are not directly tied to a set pollutant \nconcentration below which beneficial uses are protected. Basin Plans, for \nthe most part, lack a set of numeric nutrient objectives. \nImpairments occur when biostimulatory substances promote aquatic \ngrowths in concentrations that cause nuisance or adversely affect \nbeneficial uses. \nBaseline: \t RWQCBs recommendations for nutrient listings for the 2000 \nsection 303(d) list included listings for DO, nitrates, ammonia and other \nnitrogen-related substances. The 2002 section 303(d) list also cited growth \nof noxious plants, algae, eutrophication, and increased turbidity (i.e., \ndecreased water clarity) as problems. \nAlternatives: 1. Use criteria from USEPA. Under this alternative, RWQCBs would use the \nUSEPA recommended parameters for nutrient assessment, which are total \nphosphorus, total nitrogen, chlorophyll-a, and some measure of water \nclarity (USEPA, 1998~). USEPA criteria establish nitrogen and \nphosphorus as the main causal agents of enrichment and chlorophyll-a and \nwater clarity as response variables. Criteria developed by USEPA uses an \necoregion approach, establish target regional nutrient ranges for \nphosphorus and nitrogen, and recognizes ambient \"natural\" background \nlevels of nutrients in each region. \nThis alternative is not preferable since the criteria are based on numerous \nassumptions that do not apply to the western U.S. Using USEPA \nreference-based values would result in the listing of a large number of \npotentially unirnpacted water bodies. In the development of their guidance, USEPA recognized that flexibility is important and encouraged \nstates to develop regional nutrient criteria. Therefore, in acknowledgement \nof the differences posed by the western U.S., the USEPA Region IX \nRegional Technical Advisory Group (RTAG) for developing nutrient \ncriteria has unanimously chosen to develop its own criteria. \n2. Wait for RTAG to complete its work before making any further nutrient \nlistings. In 2001, the SWRCB created the State Regional Technical \nAdvisory Group (STRTAG) to work with RTAG to develop nutrient \ncriteria for California and better coordinate the activities of the RWQCBs. \nThis alternative would provide the RWQCBs with consistent numeric \nendpoints upon which to base nutrient listings. However, this alternative \nwould also require waiting at least two years for RTAGISTRTAG nutrient \ncriteria to be developed and several more years before they are adopted \nand implemented. \n3. Provide guidance to trigger listing. To place a water body on the section \n303(d) list based on a narrative objective, it should be shown that a \nnuisance condition exists or that beneficial uses are being adversely \nimpacted. Nuisance or adverse impacts may be established by showing: \n(1) degradation of the aquatic community or its habitat; (2) complaints \nfrom the public; (3) presence of objectionable tastes or odors in drinking \nwater supplies; (4) presence of weeds that impede recreation or \nnavigation; or (5) low DO. \nOnce nuisance or an adverse impact is shown, it is necessary to \ndemonstrate the problem is caused by excessive nutrients. \nEstablishing the role of nutrients may be accomplished by: (1)using \ncomputer models; (2) reviewing relevant scientific literature; (3) making \ncomparisons with historical data for the area; (4) comparing monitoring \ndata with similar water bodies that are not impaired; or (5) any \nscientifically defensible method that demonstrates the observed nutrient \nconcentrations result in excessive aquatic growths. \nData requirements vary based on the rationale for listing and the \navailability of supporting information. If listing for nitrogen or \nphosphorus specifically, RWQCBs should consider whether the ratio of \nthese two nutrients provides an indication of which is the limiting agent. \nIndividual datum points should have an identifiable location, quality \nassurancelquality control (QNQC) procedures, sample collection methods \nand analytical methods. \nIn the absence of RTAGISTRTAG nutrient criteria, RWQCBs should use \nmodels, evaluation guidelines for excessive algae growth, unnatural foam, \nodor, and taste, scientific literature, data comparisons to historical values or to similar but unimpacted streams, Basin Plan objectives, or other \nscientifically defensible methods to demonstrate that nutrients are to \nblame for the observed impacts. Nutrient-related nuisance may also be \nplaced on the section 303(d) list when a significant nuisance condition \nexists when compared to reference conditions. \nRWQCBs should first determine the endpoints that are impacted and \nwhether the nutrient is causing or not causing biostimulation. Next the \nRWQCBs should determine the beneficial use that is impacted \n(Figure 13). RWQCBs should follow the guidance provided below when \nnutrient listing decisions are being made: \nListing for excessive nitrates \nCompare the nitrate data to water quality objectives intended to protect \ndrinking water quality or compare data to the MCL. If it is suspected that \nthe aquatic life use is impacted, compare the nitrate data to relevant \nguidelines available that meet the requirements of section 6.1.3 of the \nPolicy. If listing for nitrogen or phosphorus specifically, RWQCBs should \nconsider examining whether the ratio of these two nutrients provides an \nindication of which is determined to be the limiting agent. \nListing for violating ammonia objectives to protect aquatic life \nCompare the ammonia data to appropriate use-specific objectives and use \nthe approach described for other toxics. \nListing for violating DO objective \nCompare the DO data to appropriate use-specific objectives. Data should \nbe sufficient to document the extent and severity of the impairment as well \nas any temporal/seasonal trends. \nWhen continuous monitoring data are available, the seven-day average of \ndaily minimum measurements should be assessed. For depressed DO, if \nmeasurements taken over the day (diel) show low concentrations in the \nmorning and sufficient concentrations in the afternoon, then it should be \nassumed that nutrients are res~onsible for the observed DO concentrations \nif riparian cover, substrate composition or other pertinent factors can be \nruled out as controlling DO fluctuations. In the absence of die1 \nmeasurements, concurrently collected measurements of nutrient \nconcentration should be assessed as described in section 3.1 to applicable \nand appropriate water quality objectives or acceptable evaluation \nguidelines (section 6.1.3). If diel pattern is not seen, the impairment may \nbe the result of excessive biological oxygen demand (BOD) or chemical \noxygen demand (COD). \nWhen continuous monitoring data is not available, but data are available \nfrom at least seven days in any 30-day period, the average of the lowest measurement on seven consecutive days on which measurements were \ntaken should be assessed. \nThis is the preferred alternative because in the absence of \nRTAGISTRTAG nutrient criteria, the Policy provides general guidance in \nthe use of models and applicable evaluation guidelines. \nRecommendation: Alternative 3. See Policy sections 3.1,3.2,3.7.1,4.1,4.2, and 4.7.1. Determine what endpoints are being impacted \nNutrients are causing \nbiostimulation / \nNutrients are causing \nbiostimulatory effects that \nimpact drinking water, \naquatic life, recreation or \nDocument how algae or \naquatic weeds impact a \ngiven use. \nUse models, scientific literature, \ncomparing data to historical values, \ncomparing data to similar but \nunimpaired streams, Basin Plan \nobjectives or other scientifically \ndefensible methods to demonstrate \nthat nutrients are to blame for the \nobserved problem. Nutrients are toxic or low DO is not \ncaused by biostimulation \nNitrates, ammonia, low \nDO are impacting \ndrinking water or \naquatic life uses. \nDetermine \nappropriate levels for \nthe impacting \npollutant from Basin \nPlan objectives. \nFIGURE 13: NUTRIENT LISTING OPTIONS FLOW CHART Issue 4H: Impacts of lnvasive Species on WaterQuality \nIssue: How should invasive species impacts be addressed? \nIssue Description: Natural barriers, such as mountains, deserts, and oceans have historically \nacted to restrict the natural dispersion of different types of plants and \nanimals. Human activities, the advent of progressively more advanced \ntechnologies in worldwide transportation, and increased global trade have \nhelped reduce the effects of these natural barriers allowing nonindigenous \norganisms to become introduced into new habitats. Although many of \nthese introduced organisms have minimal or no effect on their new \nhabitats, some have caused enormous negative impacts on the \nenvironment and economy. \nHuman activities have helped to remove the effects of natural barriers \nthrough the: \n+ discharge of organisms from ships ballast water and ships surfaces; \n+ release of organisms from home aquariums; \n+ dumping of live bait containers and packing materials; \n+ discharge of organisms attached to recreational boats, shipping crates, \nor fishing gear; \n+ escape of organisms from shipments of live seafood, soil, or seed; \n+ transfer of aquaculture products or fish stocks; \n+ intentional introduction of organisms to establish new fisheries; \n+ propagation of landscape plantings or ornamental ponds; and \nintentional introduction of organisms to control other pests. \nAs a result of increasing introductions from many sources, nonindigenous \naquatic organisms can now be found in many coastal and inland waters \nacross the state, e.g., San Francisco Bay (Cohen, 1998; Cohen and \nCarlton, 1997; Veldhuizen, 2001). \nRecent studies indicate that the rate of such introductions are increasing \nexponentially, with more invasions being reported along the Pacific coast \nthan the Atlantic or Gulf coasts (Ruiz et al., 2000). It is likely that the rate \nof introductions will continue, as ships and port systems become larger as \nglobal commerce grows, and as investigators find new organisms from \nother sources. These invasive organisms can clog waterways, impair \nrecreational boating, threaten shellfish production, and interfere with \nirrigation operations and power generation. \nNonindigenous organisms present unique challenges; they are natural \nbiological entities that have been translocated from one ecosystem to \nanother, either by natural biogeographical processes or by human activities. The introductions of such species occur through point and \nnonpoint sources. The organisms vary widely, ranging from virus and \nbacteria unicellular organisms to vascular plants, clams, crabs and fish. \nEach type of organism can cause different problems. Nonindigenous \ninvasive organisms are capable of creating public health hazards, \ndisrupting trophic structures, and displacing native organisms by out- \ncompeting native species for resources and upsetting predator-prey \nrelationships. \nOnce introduced into a new habitat, invading organisms are virtually \nimpossible to eliminate. Nonindigenous species propagate to become \ninvasive causing permanent impacts that amplify over time. \nMany interested parties are attempting to prevent the introduction of \nnonindigenous species through public awareness, education, and the -\t -. \nimplementation of non-regulatory prevention practices. A number of \nfederal and state agencies are in the process of implementing laws \ndesigned to prevent and lor eradicate all or specific introduced species. \nA recent petition to USEPA requested that ballast water discharges be \nregulated under the NPDES program (USEPA, 1999b). However, USEPA \ndenied the petition (USEPA, 2003g). NPDES permits impose effluent \nlimits designed to remediate the discharge of pollutants to waters of the \nstate from point source discharges. The goal of developing and imposing \neffluent limits in NPDES permits is to allow the discharge of specific \nlevels of pollutants at specifically calculated concentrations so that \ndesignated beneficial uses of the receiving waters are still protected. The \nissued permits allow discrete loads of pollutants to be discharged into \nreceiving waters. \nAnother alternative has been to use invasive species.as a factor for \nsection 303(d) listing eventually leading to the development of TMDLs. \nBaseline: \t The San Francisco Bay RWQCB listed San Francisco Bay for exotic \nspecies on the 1998 section 303(d) list, which was ultimately approved by \nthe SWRCB. \nIn the 2002 section 303(d) listing process, the SWRCB did not list any \nnew water bodies proposed for listing under section 303(d) for invasive \nspecies. \nAlternatives: 1. List water bodies under CWA section 303(d) for invasive species that \nim~act water aualitv and develov TMDLs. At present, documented \npopulation explosions of many introduced invasive species have a \nsignificant impact on designated beneficial uses in many of our state's \nwaters. ~xamples include~di~ru~tion of commercial and recreational fisheries beneficial use (COMM), interfering with the delivery of \nagriculture water supply (AGR) and industrial process supply (IND), \nobstruction of waterways (navigational beneficial use, NAV), and \nobstruction of hydropower generation structures (POW).Invasive species \ncan also impact native aquatic habitats. \nIf the presence of invasive species were used as a listing factor, a TMDL \nwould need to be developed for the impacted water body. Although it \nmay be possible to list a water body for invasive species under \nsection 303(d), it may not be possible to develop a TMDL. Invasive \nspecies can affect beneficial uses by obstructing waterways, industrial and \nagricultural water conveyance structures, affecting water quality \nparameters such as DO, or causing human health hazards due to \npopulation explosions. However, most documented impacts to beneficial \nuses due to degraded water quality are usually not caused by invasive \nspecies. ~anyinvasive species prevent indigenous organisms from \nmaintaining a \"balanced indigenous population\" but this impact is not the \nresult of a water quality parameter being affected. obstruction-related \nimpacts require immediate response for which there are some controls \nalready in place, such as eradication and removal. Other impacts, require \ntime to naturally subside. The TMDL process would not be the most \neffective or appropriate way to address these specific impacts. \nThe section 303(d) listing and TMDL process comprises the next \nremediation step in reducing waste loads in water bodies that do not meet \nwater quality standards. TMDLs not only take into account the sum of \nindividual point source waste load allocations established through permits, \nbut also the load allocations for nonpoint sources, plus the natural \nbackground loads from tributaries or adjacent water segments. As with the \napplication of NPDES permits, TMDLs are remediation plans designed to \nfurther reduce pollutant loads in a more comprehensive fashion while still \nallowing discrete loads of pollutants to be discharged into receiving \nwaters. \nIt would be theoreticallv ~ossible to develo~ TMDLs based on either taxa -. \nor a specific-sized population for the discharge of nonindigenous species \ninto receiving waters. The International Maritime Organization and the \nU.S. Coast Guard are currently developing such standards for ballast water \n(Federal Register, 2002; Globalast, 2002). Initially, such loads would be \ndriven by current treatment technology, which would not necessarily \nprotect water bodies from invasive species impacts. There would be no \nassurance that any or all organisms discharged as part of the load \nallocation would not become invasive at some time in the future. The load \nallocations would need to be restrictive enough to impart confidence that \nthe organisms being discharged have a very low probability of survival. \nThe same assurances would also need to be extended for discharges or releases from other sources of introduction. This would include \ndischarges and releases from surfaces of boats or ships, aquariums, or \nauthorized and unauthorized releases of nonindigenous organisms. \nRegulation and control of these types of discharges would be very difficult \nto achieve. \nIt would, therefore, be impractical to regulate invasive species through \nload allocations that would allow for the discharge of nonindigenous \nspecies into the waters of the state without assurance that any organism \ndischarged would not become invasive. \n2. Do not list waters impacted bv invasive species on the section 303(d) list. \nInstead. place such identified waters on a subcateaorv list for impacts not \ncaused bv a ~ollutant. Water bodies impacted by invasive species could \nbe listed under a subcategory for impacts to beneficial uses not caused by \na pollutant (USEPA, 2003b). TMDL development would not be required \nfor these waters; the listing would support other appropriate water quality \nmanagement actions that would address the cause of the impact. Water \nbodies placed on this list would still be included as part of the water \nquality monitoring and assessment report submitted in compliance with \nCWA sections 305(b) and 303(d), creating the much-needed awareness \nregarding this increasingly important problem. \nAt present the SWRCB, must rely on USEPA to determine that \nnonindigenous species fall under the CWA definition of \"pollutant\". The \nCWA defines \"pollutant\" to include such things as dredge spoils, solid \nwaste, incinerator residue, sewage, garbage, sewage sludge, munitions, \nchemical waste, biological material, radioactive materials, heat, wrecked \nand discarded equipment, rock, sand, cellar dirt, and industrial, municipal \nand agricultural waste discharges. Some courts have found that biological \norganisms such as bacteria, dead and live fish, and plant materials are \npollutants. While some invasive organisms may be considered pollutants, \nUSEPA has not concluded that all aquatic invasive species are pollutants \n(USEPA, 2001a). At this time, USEPA believes that invasive species \nshould not be included within the definition of \"pollutant\", as defined by \nthe CWA, and, therefore, State's are under no obligation to develop \nTMDLs for waters impacted by nonindigenous species under \nsection 303(d) (USEPA, 1999~). \nA TMDL would not be the most appropriate tool to address invasive \nspecies because this program is designed to remediate water quality \nproblems by reducing load amounts from different sources into receiving \nwaters in an attempt to restore beneficial uses. If the intent were to \nprevent further introductions of nonindigenous species into waters of the \nstate, then allowing some predetermined load to be discharged would \nseem inappropriate. Current ballast water management law in effect prohibits the discharge of \nballast water unless the master in charge of the vessel employs one of \nseveral ballast water management practices. This includes exchanging \nballast water in mid-ocean, retaining ballast water, removing or killing \nnonindigenous organisms in the ballast water through the application of an \nalternate treatment technology, or discharging ballast water in an approved \nfacility. \nThe draft San Francisco Bay RWQCB TMDL (2000) reached essentially \nthe same conclusion and recommended a load of zero discharge of \nnonindigenous organisms into regional waters. \n3. Do not list waters imvacted bv invasive svecies on the section 303(d) list \nand delist already listed waters during subseauent listing cvcles. Since \ninvasive species are not pollutants (refer to Alternative 2 for discussion) \nand USEPA has found NPDES permits or TMDLs are not needed for \nthese types of problems, RWQCBs would not need to list waters for \ninvasive species. In 1999, USEPA did not disapprove the inclusion of San \nFrancisco Bay waters listed in the 1998 section 303(d) list for impacts \nassociated with invasive species (USEPA, 1999~). However, USEPA \nstated that neither the State nor USEPA had an obligation under current \nregulations to develop TMDLs for such waters because a pollutant was not \nimpacting such waters. \nUnder this alternative, exotic species listings currently on the \nsection 303(d) list would be removed during the next listing cycle. \nInvasive species impacts continue to be addressed through other \nregulatory and non-regulatory approaches, and other programs would \ncontinue to support the research necessary to effectively prevent and \neradicate invasive species in California's aquatic systems. Waters \nimpacted by invasive species could be acknowledged in fact sheets but no \njudgement would be made on their disposition with regard to \nsection 303(d) listing. However, this information would be useful in the \ndevelopment of the section 305(b) report. \nIn the 1998 section 303(d) listing process, nine water body segments were \nlisted for exotic species impacts. During the 2002 303(d) listing cycle, \nSWRCB did not adopt anyfurther additions to the list. current listings \nfocused on exotic species would be removed from the section 303(d) list. \nThis altemative is the preferred altemative because USEPA does not \nconsider invasive species to be a pollutant and it would be difficult or \nimpossible to develop TMDLs for invasive species. \nRecommendation: Alternative 3. Issue 5: Listing or Delisting with Multiple Lines of Evidence \nFor many data types, multiple lines of evidence are needed to determine if \nstandards are attained. Listing or delisting with multiple lines of evidence \nis based on the weight of evidence assembled from multiple sets of data \nand information, the strength or persuasiveness of each measurement \nendpoint, and concurrence among various endpoints. With the exception \nof toxicity, the listing factors that require multiple lines of evidence are: \nA. Health advisories; \nB. \tNuisance condition; \nC. \tToxicity (listings may be made with or without the pollutant \nidentified); \nD. Sedimentation (under certain circumstances); \nE. \tWater temperature (under certain circumstances); \nF. \tAdverse biological response; \nG. \tDegradation of biological populations or communities; and \nH. Trends in water quality. \nThese categories are discussed separately in Issues 5A through 5H. - - Issue 5A: \nIssue: \nIssue Description: \nInterpreting Health Advisories \nHow should health advisory information be interpreted? \nWhen water bodies contain fish with high levels of chemicals or metals, \nOEHHA issues health advisories. Health advisories advise against fish \nconsumption or provide guidelines for limiting consumption in particular \nareas. The guidelines usually specify how many meals of specific fish, if \nany, may safely be eaten per week or per month. Often the guidelines \nspecify lower eating limits for some population subgroups, such as \npregnant or nursing women or children, because of their higher sensitivity. \nSection 101(a)(2) of the CWA establishes as a national goal \"water quality \nwhich provides for the protection and propagation of fish, shellfish, and \nwildlife, and recreation in and on the water, wherever attainable.\" These \nare commonly referred to as the \"fishable/swimmable\" goals of the Act. \nUSEPA interprets \"fishable\" uses to include, at a minimum, designated \nuses providing for the protection of aquatic communities and human \nhealth related to consumption of fish and shellfish. In other words, \nUSEPA views \"fishable\" to mean, not only can fish and shellfish thrive in \na water body, but when caught can also be safely eaten by humans. \nFish consumption rates are a factor in the development of water quality \nstandards and are used to prevent human risk. In order to characterize \nhuman exposure to contaminated fish and shellfish, the population at-risk \nmust be identified, the consumable concentrations of contaminants in fish \nand shellfish tissues must be measured, and the types and quantities of fish \nand shellfish consumed must be determined. OEHHA health advisories \nare an important indicator that beneficial uses have been impacted and, \nbecause they are typically based on the water body of concern and \ndescribe actual consumption rates of fish andlor shellfish, are an \nappropriate indicator of potential health impacts. \nThe major types of advisories and bans issued to protect both the general \npublic and specific subgroups are: \nt No consumption advisories; \nt No consumption advisories targeted to sensitive subgroups; \nt Advisories recommending either the general population or sensitive -\nsubgroups restrict their c~nsumption of a specific species; and \nt Commercial fishing bans which prohibit the commercial harvest, sale \nand, by inference, consumption of the species identified in the ban. Fish advisories developed by OEHHA are published in the California \nSport Fishing Regulations and California Sport Fish Consumption \nAdvisories (OEHHA, 2001a). \nBaseline: \t In the past, water bodies with issued health advisories or shellfish bans \nwere automatically considered water quality limited segments and \nsubsequently listed on the section 303(d) list. The approach for \ndeveloping recommendations for the 2002 section 303(d) list related to \nhealth advisories required multiple lines of evidence to list or delist a \nwater body. Each of these lines of evidence generally needed the \npollutant(s) that caused or contributed to the adverse condition. \nAlternatives: 1. Use OEHHA advisories alone or as an indicator of beneficial use \nimpairment. Health advisories issued against the consumption of edible \nresident non-migratory organisms or shellfish harvesting bans by OEHHA \nare acknowledged as indicators that the beneficial use to protect human \nhealth is impaired. OEHHA's fish advisories are based on site-specific \nsamples from the water body in question. Additionally, supporting data, \nwhen available, is analyzed to assess the likelihood and degree of human \nexposure. These advisories are based on chemical specific values for \ntissue concentrations that are intended to protect human health. \nOEHHA is the agency responsible for evaluating potential public health \nrisks from chemical contamination of sport fish. Therefore, fish advisories \nissued by OEHHA provides scientifically credible evidence of an \nimpairment of the fishable beneficial use. However, advisories can be \nissued to be protective of subgroups or restrict consumption. Levels of fish \ntissue contamination may, therefore, be lower than the value set in the \nBasin Plan or statewide water quality objective. More than one criterion \nmay be necessary to determine impairment. Additionally, USEPA and \nlocal health agencies can issue advisories for fish, as well as for drinking \nwater and swimming impacts. Using only OEHHA advisories would \ndisregard valid advisories issued by these other agencies. Therefore, to be \nmost protective of the fishable beneficial uses, all lines of evidence should \nbe considered. \n2. Use all types of advisories. Fish or shellfish consumption advisories are \nsometimes issued by a local agency or a national health advisory can be \nissued by USEPA. Local advisories can be relied upon if the advisory is \nbased upon methodologies similar to OEHHA and data supporting the \nadvisory exists. To use a health advisory issued by an agency other than \nOEHHA, the advisory should demonstrate: \nt The advisory is based on fish or shellfish tissue data; \nt The chemical or biological contaminant is associated with sediment or \nwater in the segment; + \tThe data are collected from the specific water body in question; and \n+ \tThe risk assessment parameters (e.g., toxicity, risk level, exposure \nduration and consumption rate) of the advisory or classification are \ncumulatively equal to or less protective than those in the water quality \nstandards. \nThis applies to all pollutants that constitute potential risks to human \nhealth, regardless of the source of the pollutant. \nSome health advisories are based on exceedances of the USFDA action \nlevels. As discussed in Issue 4E, USEPA has concluded that USFDA \naction levels should not be the sole basis for a decision to list a water \nbody. Water bodies with a fish or shellfish consumption advisory based \non USFDA action levels should only be listed as impaired when site \nspecific data support nonattainment of the water quality criteria for human \nhealth. \nDHS and USEPA issue drinking water health advisories as well. Where \ndrinking water is a designated use, USEPA recommends the inclusion of \nthe drinking water exposure pathway for derivation of the ambient water \nquality criteria for human health. Water Quality Advisories contain \nhuman health related criteria that assume exposure through both drinking \nwater and consumption of contaminated fish and shellfish from the same \nwater. For waters that are sources of drinking water, exposure is assumed \nboth from drinking the water and consuming aquatic organisms (fish and \nshellfish) that live in the water. For waters that are not sources of drinking \nwater, exposure is assumed to be from the consumption of aquatic \norganisms only. Aquatic organisms are known to bioaccumulate certain \ntoxic pollutants in their tissues, so as to magnify human exposures. The \ncriteria also include threshold health protective criteria for non- \ncarcinogens. Incremental cancer risk estimates for carcinogens are \npresented at a variety of risk levels. Organoleptic (taste- and odor-based) \nlevels are also provided for some chemicals to protect human welfare. \nHealth Advisories are published by USEPA for short-term (1-day \nexposure or less or 10-day exposure or less), long-term (7-year exposure \nor less), and lifetime human exposures through drinking water. Health \nadvisories for non-carcinogens and for possible human carcinogens are \ncalculated for chemicals where sufficient toxicologic data exist. \nMTRLs are an assessment tool, developed by SWRCB that have been \nused to access concentrations of chemicals in fish. As discussed in \nIssue 4E, MTRLs should not be used to evaluate fish or shellfish tissue \ndata for listing decisions. Health advisories are issued based on real water quality or fish tissue data \nor they can be issued as a precautionary tool. If the advisory is based on \nwater quality data from a specific water body, the water quality limited \nsegment of the water body should be listed. If the advisory is based on \nregional water quality and the advisory is precautionary, the data may be \nused as evidence in support of a listing but should not be used as the sole \nbasis for a listing. \n3. Use advisories if associated with water measurements. The issuance of a \nhealth advisory provides sufficient evidence that some portion of a water \nbody is impaired due to a specific pollutant as described in Alternative 2. \nHowever, a health advisory for an entire water body issued as a public \nhealth precaution should not be used alone as basis for placement of a \nwater on the section 303(d) list because some areas covered by the \nadvisory may not reflect the contaminant problems identified in the \nadvisory. In evaluating water segments for the section 303(d) list, the \nassessment needs to evaluate the segment and determine if the \ncontaminant is associated with water concentrations or tissue burdens in \nthe segment. \nWhen using health advisories to list a water quality limited segment, it is \nimportant to consider if their use targets a population subgroup, \nrecommends restricting consumption, or is preventative. In these \ninstances, the level of contamination in fish tissue may be lower than the \nvalue set in the Basin Plan, statewide plan, or CTR. More than one \ncriterion may be necessary to determine if the water segment is impaired. \nAdditional indicators to assess attainment with fish and shellfish \nconsumption-based advisories include: \n+ \tChemical data -from fish tissue and water column; \n+ \tShellfish growing area classifications -developed by the National \nShellfish Sanitation Program (NSSP); and \n+ \tBacteria criteria -the use of fecal coliform as a water quality \nindicator. \nThere are several idvantages to combining the above data with health \nadvisories. Direct measurements of the levels of chemical pollutants in \nfish tissues can be used in support of health advisories for calculating \nhuman health screening values and determining fish consumption levels in \nthe contaminated segment. Additionally, levels of chemical pollutants in \nfish tissue tend to reflect an integration of the wide fluctuations that occur \nin chemical concentrations in the water column over time. Measurements \nof tissue data are also an indicator of the bioaccumulation processes that \noccur in fish and shellfish that can be concentrated at levels higher than \nthose present in the water column. Site-specific measurements of chemicals in the water column can provide \na link from the source of contamination to the health advisory. Water \ncolumn data are typically based on total concentrations of chemicals in the \nwater. For some chemicals that require relatively long periods of time \nbefore they are detected in fish and shellfish tissues, changes in water \ncolumn concentrations may occur on a more rapid time scale compared to \nthe corresponding changes in tissue concentrations. Therefore, chemical \nconcentrations found in tissue samples may have little resemblance to \nmeasurements based on water column concentrations which are averaged \nover a sufficient period of time. \nShellfish growing area classifications developed by NSSP uses water \ncolumn and tissue data (where available). NSSP classifications are not \nappropriate to consider when performing a beneficial use assessment but \nthey can provide supporting documentation. Measurements of fecal \ncolifom&e used ti dete&ne if water quality is safe for shellfish \nconsumption. \nIn some cases, it may not be appropriate to list a water body even though \nan advisory has been issued (e.g., where an advisory covers a large \ngeographic region, but the sampling data were limited to certain water \nbodies or where an advisory pertains to migratory or highly mobile \nspecies). Also, a water body need not be listed if more recent data or \ninformation indicates that designated beneficial uses are being attained \nand that the advisory is no longer representative of current conditions. \nThis alternative is the preferred alternative because this alternative \nprovides additional evidence that pollutants in the water segment \ncontribute to the conditions addressed in health advisories. The use of all \nthe lines of evidence listed above would support the use of a health \nadvisory by providing additional documentation that the chemical or \nbiological contaminant is associated with water or tissue in the segment. \n4. Use Advisories if associated with water or sediment measurements but do \nnot specify how to evaluate the measurements in the Policy. This \nalternative would provide the RWQCBs with more flexibility in \ndetermining how to evaluate water and sediment measurements in \nassociation with health advisories. However, without guidance to assist in \nevaluating measurements, interpretations could vary by region and \nevaluation guidelines could be used inappropriately. For example, .. . \nmeasurements of sediment concentrations can potentially provide a picture \nof the levels of environmental contamination for those contaminants that \nare metabolized by physiological processes in fish tissues. However, as a \nmethod of evaluation, direct toxicity testing of sediments provide a \nchemical-by-chemical specification of sediment concentrations that would be protective of benthic aquatic life but have not been used in association \nwith impacts on human health. \nUSEPA is implicit in it's guidance that for purposes of determining \nwhether a water body is impaired and should be included on the \nsection 303(d) list, the methodology and documentation should clearly \ndescribe the rationale for identifying potential violations of numeric and \nnarrative criteria. In its 2004 guidance, USEPA (2003b) stresses the need \nfor a consistent approach and thorough documentation of the scientific and \ntechnical rationale for listing impaired water bodies. \nRecommendation: Alternative 3. See Policy sections 3.4 and 4.4. Issue 5B: Interpreting Data Related to Nuisance \nIssue: How should data related to nuisance conditions (e.g., odor, foam, oil \nsheen, excessive algae, taste, and color) be interpreted? , \nIssue Description: As defined in CWC section 13050(m), nuisance is anything that is \ninjurious to health, indecent or offensive to the senses, or an obstruction to \nthe free use of property and interferes with the comfortable enjoyment of \nlife or property. The Basin Plans variously define nuisance as solids, \nliquids, foams, oils, taste, color, odor, floating material and scum in \nconcentrations that can cause nuisance or adversely affect beneficial uses. \nThe extent, to which beneficial uses are impacted, in many of the Basin \nPlans, relies on a narrative objective and is defined as \"concentrations that \nadversely affect beneficial uses.\" For example, the objective for color in \nthe North Coast RWQCB Basin Plan states \"Waters shall be free of \ncoloration that adversely affects beneficial uses\" (North Coast RWQCB, \n1994). The Los Angeles RWQCB Basin Plan has a similar narrative \nobjective for oil and grease. It states, \"waters shall not contain oils, \ngreases, waxes or other materials in concentrations that result in a visible \nfilm or coating on the surface of the water or on objects in the water that \ncause nuisance, or that otherwise adversely affect beneficial uses\" \n(Los Angeles RWQCB, 1995). \nThe SWRCB and RWQCBs have received information describing \nnuisance conditions in many waters of the State. This documentation, for \nthe most part, has been qualitative (e.g., photographs, accounts from \nindividuals, etc.). Some numeric data have been provided that describes \nnuisance conditions (e.g., measures of algae cover or water color). \nBaseline: In 2002, water segments were not recommended for placement on the \nsection 303(d) list for nuisance conditions related to assessments of color, \nodor, excessive algae, and scum. \nAlternatives: 1. Use onlv auantitative data in the evaluation of nuisance. The Basin Plans \nprovide narrative objectives for the various types of nuisance conditions. \nThese types of narrative objectives are subjeciive and difficult to interpret \nunless there is a numeric evaluation guideline available that represents a \nquantifiable level of beneficial use protection. \nSome Basin Plans have numeric objectives that protect waters from \nnuisance. An example is the San Diego RWQCB's Basin Plan objective \nfor color. The objective is: \"Waters shall be free of coloration that causes nuisance or adversely \naffects beneficial uses. The natural color of fish, shellfish, or other \nresources in inland surface waters, coastal lagoon, or bay and estuary \nshall not be impaired. Inland surface waters shall not contain color in \nconcentrations in excess of the numerical objectives described in Table \n3-2 (20 Color Units).\" \nWhen a numeric water quality objective or guideline is available for \nnuisance conditions, it provides a comparative value upon which numeric \ndata can be directly assessed to determine if water quality standards are \nmet. \nA benefit of listing, based on such numeric water quality objectives, is that \nit is less subjective and reproducible. With all other listing requirements \nsatisfied, such as data quality and quantity requirements, if the data shows \nan exceedance of the objective and is not attaining standards than the \ndetermination that the water segment is impacted is scientifically \ndefensible. \nIn many cases, nuisance conditions are symptoms of problems and are the \nmanifestation of the effects of pollutants. For example, excessive algae \ngrowth is typically caused by unnaturally high concentrations of nutrients. \nTherefore, a listing based on nutrient-related impairment may be more \nappropriate. Caution should be exercised in listing decisions related solely \nto nuisance conditions because many of these factors can also be natural \nconditions of water bodies (e.g. foam, algae growth, and odors). \n2. \tUse aualitative information to evaluate nuisance. Photographic \ninformation and other types of visual assessments are useful as supporting \ndocumentation of water quality problems but its value is debatable unless \naccompanied by quantitative data. \nVisual assessments require minimal technical equipment or training and \nrely primarily on the individual's sensory abilities and common sense to \ndocument water body conditions. There are two general approaches used \nto develop visual assessments. The first, a narrative approach, involves the \nuse of standardized forms to interpret visual (and other sensory) \nobservations into words or numeric descriptions. The second approach, \nphotographic monitoring also referred to as \"photo documentation,\" \nprovides a permanent visual documentation of specific waterway andlor \nwatershed conditions. \nThe RWQCBs have, in previous listing cycles, recommended water \nsegments for the list using qualitative information. For example, Calleguas \nCreek Watershed-Conejo CreekIReach 9B was recommended for listing \ndue to unnatural foam and scum during the development of the 2002 section 303(d) list. The recommendation was based on photographic \ndocumentation. The photographic evidence provided was for one \nphotograph (SWRCB, 2003a). The pollutant was not identified, the \npotential sources were unknown, and the only evidence provided to \ndocument impairment were photographic visual assessments. \nPhotographs and other qualitative infomation can be subject to multiple \ninterpretations. Used alone it is difficult to differentiate between natural \nand human-caused water quality problems. Qualitative information alone \n(even if it is subject to multiple interpretations and sampling bias) can be \nused to evaluate the potential for nuisance conditions and to plan for future \nmonitoring efforts. \n3. Use both Quantitative and qualitative data and information in the \nevaluation of nuisance. Qualitative information and quantitative data in \ncombination can provide a strong basis for placement of waters on the \nsection 303(d) list. Qualitative information can be used to evaluate the \npotential for nuisance conditions and to plan for future monitoring efforts. \nQualitative information should not be discouraged. When qualitative \ninformation is combined with quantitative data related to pollutants, such \nas excessive nutrients, multiple lines of evidence provide strong support \nfor placement on the section 303(d) list. \nWhen submitting photo documentation to support a listing, the submission \nshould describe events or conditions that indicate impairments of water \nquality that are outside the expected natural range of conditions. The \ndocumentation should also provide linkage between the measurement \nendpoint (e.g., a study that may have been performed for some other \npurpose) and the water quality standard of interest. Documentation should \ninclude the analysts' credentials and training, and be verifiable by the \nRWQCB or S WRCB. \nFor photo documentation to be most useful the date and location on a \ngeneral area map should be provided. If known IatitudeAongitude \ncoordinates should be provided or the location marked on an U.S. \nGeological Survey (USGS) 7.5-minute quad map. The documentation \nshould provide a thorough description of the photo(s) and describe \nconditions that are not represented by the photo in surrounding areas. For \nphoto documentation of impairment, linkage should be provided between \nphoto-represented conditions and conditions that indicate impairments of \nwater quality that are outside the expected natural range of conditions. The \nphotographer's rationale for the area photographed, the camera settings \nutilized, and scale should be provided. The organization submitting photos \nshould submit its entire photo set for a given condition in order to \ndocument spatialltemporal conditions for the time frame specified. Recommendation: For the section 303(d) list, the pollutant or pollutants that cause or \ncontribute to the observed impacts should be identified. To do this, the \nRWQCBs should rely on existing numeric water quality objectives \n(related to nutrients or other pollutants) or evaluation guidelines that \nrepresent an acceptable levelof beneficial use The guidelines \nshould satisfy the requirement of section 6.1.3of the Policy. It is also \ndefensible to compare water bodies conditions to reference conditions, if \nthey have been identified. \nThis alternative represents the preferred alternative because using \nestablished guidelines or comparisons to reference conditions for \nquantitative and qualitative data and information could lead to better \nassessments of nuisance conditions. \nAlternative 3. See Policy sections 3.7, 3.7.2,4.7,4.7.2, and 6.1.3. Issue 5C: \t Interpreting Toxicity Data \nIssue: \t How should toxicity data be interpreted? \nIssue Description: \t Toxicity is a direct measurement of the health of the water body. Toxicity \nmeasurements assess the response of aquatic organisms to pollutants by \ndirectly measuring the organism's exposure to a water or sediment sample. \nAssessing the response of a number of different organisms ensures a \ngreater opportunity to identify water quality problems. Toxicity \nmeasurements can assess the relationship of complex mixtures of \npollutants or individual substances and can evaluate acute or chronic \nexposures in test systems. \nToxicity tests are conducted in water or sediment for freshwater, estuarine, \nand marine environments. Several lines of evidence can be used to \nidentify toxic effects and several approaches are available to assess what \npollutant might have caused or contributed to the observed toxicity. \nBaseline: \t During the development of the 2002 section 303(d) list, toxicity testing \nwas used as a basis for listing as long as concurrently sampled chemical \ndata was available to show the chemical caused or contributed to the toxic \neffect. \nAlternatives: 1. \tProvide no guidance on methods or approaches for intemreting toxicity -data. Under this alternative, the RWQCBs would be given significant \nflexibility on the use of toxicity data for determining the attainment of \nwater quality standards. Guidance would not be established in the Policy \nfor evaluating toxicity information and data. The RWQCBs would be able \nto exercise BPJ in determining which waters would be placed on the \nsection 303(d) list. The disadvantage of this alternative is that it would \nallow potentially significant inconsistencies in listings for toxicity among \nthe various RWQCBs. \n2. \tUse toxicitv alone as a listing factor. Using this alternative, the RWQCBs \nwould be required to use well-established toxicity testing methods to make \nlisting determinations, as long as appropriate reference and control \nmeasures are included in the toxicity tests. \nOne disadvantage of this alternative is that it is very difficult to complete a \nTMDL on toxicity alone. In addition, there are no examples in California \nwhere a TMDL has been developed for toxicity in the absence of the \npollutant. When toxicity has been identified, the RWQCBs have, in a few \ncases, sponsored studies to identify the pollutant causing the toxicity \n(e.g., Foe et al., 1998). The performance of these types of studies may \ndelay development of TMDLs. To reduce the effect of this disadvantage, TMDLs should be scheduled to proceed even if the pollutants are not . \nidentified. Federal regulation allows for developing TMDLs for the \nidentified pollutants causing or expected to cause water quality standards \nviolations (40 CFR 130.7(b)((4)). The exception is toxicity. The \ndefinition of a TMDL (40 CFR 130.2(i)) allows for \"TMDLs to be \nexpressed in terms of either mass per time, toxicity or other appropriate \nmeasure.\" In order for TMDLs to be expressed in terms of toxicity, it is \nnecessary for TMDLs to be developed for toxicity. \nIn assessing toxicity data several considerations need to be addressed \nincluding: \n4 toxicity test methods; \n+ assessment of statistical significance of toxicity; and \n4 persistence of toxicity. \nToxicity Test Methods \nSeveral species have been used in acute and chronic toxicity testing for \nfresh and marine waters. Toxicity tests typically compare ambient water to \neither standard control waters or unpolluted receiving water (as specified \nin the testing manual) or sediments to a reference condition. \nCurrently, no single toxicity test can adequately characterize the toxicity \nthat pollutants may cause in water or sediment. For freshwaters, USEPA \n(1991f) recommends selection of toxicity tests, using species from \necologically diverse taxa and the screening of ambient water with three \nspecies (a fish, an invertebrate, and a plant) for chronic testing and two \nspecies (a fish and an invertebrate) for acute testing (Table 6).This \nrecommendation is based on differences in species sensitivity among \ngroups of organisms to different toxicants. \nSpecies Effect \t Reference \nFish-~.-~ \nFathead minnow, Survival; \t USEPA, 1993c' \nPimephales promelas Survival and growth \t USEPA, 2002d' \nUSEPA, 1994c\" \nUSEPA, 2002~\" \nASTM, 2002c \nRainbow trout, Larval survival USEPA, 1993c' \nOncorhynchus ntykiss USEPA, 2002d' . \nASTM, 2002c Species \t Effect Reference \nBrook Trout, Larval survival USEPA, 1993c' \nSalvelinius fontinalis USEPA, 2002d' \nASTM, 2002c \nBluegill Sunfish, Survival and growth ASTM, 2002c \nLepomis macrochinus (48 hours to 32 days) \nChannel Catfish, Survival and growth ASTM, 2002c \nZctalurus punctatus \nRotifer, \t Embryo survival ASTM, 2002e \nBrachionus calyciflorus \nInvertebrate \nWater flea (Invertebrate), Survival USEPA, 1993c' \nCeriodaphnia dubia USEPA, 2002d' \nSurvival and \t ASTM, 2002b \nreproduction \t USEPA, 1994~\" \nUSEPA, 2002~\" \nASTM, 2002b \nWater flea (Invertebrate), Survival USEPA, 1993c' \nDaohnia oulex and Daohnia USEPA. 2002d' \nmagna ASTM, 2002b \nWater flea (Invertebrate), Survival, growth and USEPA, 1994c** \nDaphnia mqna reproduction USEPA, 2002c\" \nASTM, 2002b \nRotifer, Embryo survival ASTM, 2002e \nBrachionus calyciflorus \nPlant \nGreen algae, Growth USEPA, 1994~\" \nRaphidocelis subcapitata USEPA, 2002c\" \n(=Selenastrum \ncapricornutum) \n*Acute test \n**Chronic test \nFor marine waters (Table 7), a variety of tests are included in the \nCalifornia Ocean Plan that address the responses from a range of \norganisms (SWRCB, 1996; SWRCB, 2001b). Species \nGiant Kelp, \nMacrocystis pyrgera \nRed abalone, \nHaliofis rufescens \nPacific Oyster, \nCrassostrea gigas; \nMussels, \nMyrilus spp. \nUrchin, \nSfrongylocenfrotus \npurpuratus; \naltemate species \n(S.franciscanus, \nS.droebachiensis, \nDendraster excentricus, \nL. pictus) \nSand dollar, \nDendraster excentricus \nUrchin, \nSrrongylocenfrotus \npurpuratus; \nalternate species \n(S.franciscanus, \nS.droebachiensis, \nDendraster excentricus, \nL. pictus) \nSand dollar, \nDendrasfer excentricus \nShrimp, \nHolmesimysis cosrata \nShrimp, \nAmericanmysis (Mysidopsis) \nbahia \nShrimp, \nNeomysid mercedis \nTopsmelt, \nAtherinops affinis Effect \nPercent germination; \ngerm tube length \nAbnormal shell \ndevelopment \nAbnormal shell \ndevelopment; \npercent survival \nPercent normal \ndevelopment \nPercent fertilization \nPercent survival; \ngrowth \nPercent survival; \nGrowth \nPercent survival \nLarval growth rate; \npercent survival Reference \nUSEPA, 1995\" \nSWRCB, 1996\" \nUSEPA, 1995\" \nSWRCB, 1996\" \nUSEPA, 1995\" \nSWRCB, 1996\" \nUSEPA, 1995\" \nSWRCB, 1996\" \nUSEPA, 1995\" \nSWRCB, 1996\" \nUSEPA, 1995\" \nSWRCB, 1996\" \nASTM, 2002h \nUSEPA, 1993~' \nUSEPA, 2002d' \nUSEPA, 1994b\" \nUSEPA, 2002e\" \nASTM, 2002h \nUS EPA, 1994b\" \nUSEPA, 2002e\" \nASTM, 2002h \nUSEPA, 1995\" \nSWRCB, 1996\" \nASTM, 2002a Species Effect Reference \nSilversides, Larval growth rate; USEPA, 1993c' \nMenidia beryllina percent survival USEPA, 2002d' \nUSEPA, 1994c\" \nUSEPA, 2002~\" \nUSEPA, 2002e\" \nASTM, 2002a \n*Acute test **Chronic test \nToxicity tests are also available for fresh and marine sediments (Tables 8, \n9, and 10). A variety of tests have been used throughout the state by a \nnumber of monitoring programs (e.g., SWAMP, SCCWRP (Southern \nCalifornia Coastal Water Research Project), SFEI (San Francisco Estuary \nInstitute), and BPTCP). These programs have used well-developed and \naccepted toxicity tests with amphipods, polychaete worms, and midges, \netc. Toxicity tests are available to test toxic effects on organisms of pore \nwater (i.e., the water between sediment particles) or the sediment-water \ninterface (the effect of chemicals released from the sediment to water). \nSpecies Effect Reference \nAmphipods: Acute survival USEPA, 1994a \nRhepoxynius abronius, ASTM, 2002g \nEohaustorius estuarius, \nLeptocheirus plumulosus, \nGrandidierella japonica, \nAmpelisca abdita \nPolychaete, Survival (10 day) ASTM, 2002f \nNereis (Neanthes) USEPA, 1998a \narenaceodentata Survival and Growth ASTM, 2002f \n(28 day) TABLE9: FRESHWATER WHOLE AND POREWATER SEDIMENT TEST ORGANISMS \nSpecies Effect Reference \nAmphipod, Survival and Growth (10 USEPA, 2000e \nHyalella azreca days) \nAmphipod, Survival, Growth, and USEPA, 2000e \nHyalella azteca Reproduction (28-42 \ndays) \nMidge, Survival and Growth (10 USEPA, 2000e \nChironomus tentans days) USEPA, 2000e \nSurvival and Growth \n(long-term) \nTABLE10: CHRONIC FOR MARINE POREWATER AND SEDIMENT- TESTS SEDIMENT \nWATERINTERFACE \nSpecies Effect Reference \nPorewater \nUrchin, Percent normal USEPA, 1995 \nStrongylocentrotuspurpuratus development SWRCB, 1996 \nUrchin, Percent fertilization USEPA, 1995 \nStrongylocentrotus SWRCB, 1996 \npurpuratus; \nalternate species \nS.franciscanus, \nS. droebachiensis, \nDendraster excentricus, \nL pictus, \nBivalve, Bay Mussel USEPA, 1995 \nMytilis galloprovincialis SWRCB, 1996 \nSediment-water Interface \nUrchin, Percent normal USEPA, 1995 \nStrongylocentrotuspurpuratus development SWRCB, 1996 \nBivalve, Bay Mussel, Abnormal shell USEPA, 1995 \nMyrilis galloprovincialis development; percent SWRCB, 1996 \nsurvival Many toxicity tests are used by a variety of monitoring programs \nthroughout the State. These methods should be encouraged for use in \nsection 303(d) listing decisions. Acceptable methods include those listed \nin water quality control plans or used by SWAMP (Puckett, 2002), \nSCCWRP (SCCWRP, 1998), USEPA Environmental and Assessment \nProgram (EMAP) (USEPA, 1997a; USEPA, 2001b; USEPA, 2003d), the \nRegional Monitoring Program (RMP) for SFEI (Lowe et al., 1999), and \nBPTCP (Stephenson et al., 1994). Other SWRCB and RWQCB-approved \nmethods should also be encouraged on a case-by-case basis. \nAssessing Significant Toxicity \nIn toxicity tests, the most common approach to assess endpoints is to \nstatistically compare the ambient water or sediment toxicity to a reference \ncondition. Other approaches have been used extensively and are also \nvalid. For example, comparison of ambient toxicity to reference \nconditions using a \"reference envelope\" or to a percentage of the \nminimum significant difference (MSD) have been used in water quality \nprotection programs such as the BPTCP (SWRCB, 1998). The reference \nenvelope is a statistical approach (Smith, 2002; Fairey et al., 1996) that \nallows a comparison of sites to reference sites. The approach considers all \nsources of field and laboratory variation. \nThe MSD compares differences between the control and ambient waters to \ndetermine whether the sample is toxic. Using this approach, the \nmagnitude of difference depends on the selected Type I error rate (e.g., \np<0.05; refer to Issue 6 for more complete description of Type I error), the \nlevel of between-replicate variation, and the number of replicates specific \nto the experiment. With the number of replicates and the error level held \nconstant, the MSD varies with the degree of between-replicate variation. \nThe \"detectable difference\" for a specific toxicity test protocol can be \ndetermined by the magnitude of difference detected by the protocol \n90 percent of the time (Schimmel et al., 1994; Thursby and Schlekat, \n1993) and is equivalent to setting the level of statistical power at 90 \npercent (refer to Issue 6 for definition of statistical power). This is \naccomplished by determining the MSD for each t-test conducted, ranking \nthem in ascending order, and identifying the 90\" percentile MSD; the \nMSD that is larger than or equal to 90 percent of the MSD values \ngenerated (Anderson et al., 1998). The MSD considers laboratory \nvariation only and is specific to each toxicity test protocol. \nAnother common method for assessing statistical significance in toxicity \ntests is by comparing reference or control conditions to ambient waters \nusing a statistical test like the \"t-test\". A \"t-test\" compares the differences \nbetween an ambient water sample and control. If the difference is large, \nrelative to the variance observed, then the difference is significant. In many cases, however, a low between-replicate variance causes a \ncomparison to be considered significant, even though the magnitude of \ntoxicity may not be biologically meaningful (Anderson et al., 1998). \nEach of these approaches have been used to decide if a water or sediment \nsample is toxic and could be used to support section 303(d) listing \ndecisions. \nPersistence of Toxicity \nAnother factor that should be considered when assessing toxicity is \npersistence in water or sediments. As with all kinds of measurements of \nenvironmental conditions, toxicity measurements are uncertain because of \nthe inherent difficulty in using sampling data to represent actual \nenvironmental conditions (USEPA, 2000b). In most cases, the smaller the \ndata set, the larger the statistical uncertainty. The uncertainty of these \ntoxicity test measurements is reduced when acute and chronic toxicity is \nmeasured on a number of samples. USEPA (Denton and Narvaez, 1996) \nhas recommended consideration of the following factors when selecting \nthe frequency of toxicity monitoring: \n+ environmental significance and the nature of the pollutant, \n+ cost of monitoring relative to the capabilities and benefits obtained, \n+ history of the health of the water body, \n+ water and sediment variability, \n+ the presence of legacy pollutants, and \n+ the number of samples required to make an assessment. \nToxicity testing is integrative of environmental conditions, depending on \nthe length of exposure to pollutants that may cause or contribute to the \ntoxic effect. While it is desirable to have a large number of samples for \ndecision making, findings of repeated occurrences of toxicity can be \ndetermined with relatively few samples. In one program, two samples was \nthe minimum number of samples needed to assess the persistence or \nrecurrence of toxicity (SWRCB, 1998). \n3. Use a weight of evidence approach to determine the pollutant(s) that may \ncause toxicitv. This alternative would require that toxicity be used as one \nline of evidence to place waters on the section 303(d) list (as described in \nAlternative 2). In general, pollutants need to be identified before a TMDL \ncan be developed for a water placed on the section 303(d) list (40 CFR \n130.7: USEPA, 2003b). Toxicity is not a pollutant, but is a manifestation \nof effects caused by pollutant concentrations. \nA second line of evidence to justify placement of waters on the \nsection 303(d) list would be concurrently collected chemical data. Chemical data would be interpreted using evaluation guidelines, \ntoxicological information, or studies that identify the pollutant causing the \ntoxicity. The advantage of this alternative is that if pollutants are \nassociated with the observed toxicity, RWQCBs will have a better chance \nof completing TMDLs. \nThere are several approaches available that can be used to assess if \npollutants in ambient water or sediment contribute to toxic or other effects. \nThese approaches include: \nt Toxicity Identification Evaluations; \nt Sediment Quality Guidelines; and \nt Statistical Correlation. \nToxicity Identification Evaluations (TIES) \nTIES are scientific studies used to determine the cause of toxicity or other \nbiological effect. To complete TIES, water or sediment is separated into \nvarious components to assess which portion causes the toxicity. Sediment, \nwater, and porewater samples can be manipulated to alter or render \nbiologically unavailable generic classes of chemicals (USEPA, 1991~). \nBecause sediments, water, and porewater posing potential risks are usually \ntoxic to aquatic organisms, portions or fractions of the water or sediment \nexhibiting toxicity can reveal the nature of the toxicant(s). Depending \nupon the response, toxicant(s) can be tentatively categorized as having \nchemical characteristics of non-polar organics, cationic metals, or \nconfounding factors, such as ammonia. TIE methods identify the toxicant \ngroup, the chemical causing the effect, and confirm the toxicant effects \n(Table 1 1). \nTABLE 11: TIE PROCEDURES FOR EFFLUENT AND AMBIENT WATER, SEDIMENT \nEULTRIATE, PORE WATER, AND LEACHATES \nTest Reference \nCharacterization Procedures USEPA, 1991c \nProcedures for samples exhibiting acute USEPA, 1993a \nand chronic toxicity \nConfirmation Procedures USEPA, 19931, \nCharacterization Procedures for Marine USEPA, 1996b \nSpecies \n Sediment Quality Guidelines (SQGs) \nWhen SQGs are used to determine the toxic effect of a sample, \nconcurrently collected measurements of chemical concentrations can be \nused to associate toxic effects with toxicity or other biological effects. \nSQGs are widely used, empirically derived guidelines that predict or \nassociate the chemical concentrations likely to be associated with the \nmeasurable biological response. \nSeveral evaluation guidelines are available that can be used to assess \nassociation between toxicity or other measures of effect and the pollutants \nthat may cause or contribute to the observed effects. \nThe predictability of toxicity, using the sediment values reported (Long et \nal., 1998), is reasonably good and is most useful if accompanied by data \nfrom biological analyses, toxicological analyses, and other interpretative \ntools. These measures are most predictive of toxicity if several values are \nexceeded. Since these values often are not good predictors of toxicity \nalone, SQGs that predict toxicity in 50 percent or more samples, should be \nused in making decisions to place a water body on the section 303(d) list. \nThe guidelines presented in Table 12 are the guidelines most predictive of \nbiological effects. \nTABLE12: SEDIMENT FOR MARINE, AND QUALITY GUIDELINES ESTUARINE, \nFRESHWATER SEDIMENTS \nMarine and Estuarine Sediment s Freshwater \nSediments \nChemical Effects Probable Other Probable Effect \nRange- Effects ~evel' Sediment concentration3 \n~edian' Quality \n~uideiines \nAntimony 25 uda dw \nArsenic 70 ug/g dw 33.0 mgkg dw \nCadmium 4.21 ug/g dw 4.98 mgkg dw \nChromium 370 ug/g dw 111 mg/kgdw \ncopper \nLead 270 ug/g dw \n112.18 ug/g dw 149 mg/kg dw \n128 mgikg dw \nMercury 2.1 udg4 1.06 mg/kg dw \nNickel 48.6 mglkg dw \nSilver 1.77 uglg dw \nZinc 410 ug/g dw 459 mglkg dw \nChlordane 17.6 ugkg dw \nTotal Chlordane 6 nglg5 dw \nDieldrin 8 ng/g dw 61.8 ugkg dw \nSum DDD 28.0 ugikg dw \nSum DDE 31.3 ugkg dw \nSum DDT 62.9 ugikg dw \nTotal DDTs 572 ugkg dw \nEndrin 0.76 ug/g oc6 207 ugkg dw \nLindane 0.37 ug/g oc8 4.99 ugkg dw Marine and Estuarine Sediments \t Freshwater \nChemical \nTotal PCBS \nAnthrazene \nFluorene \nNaphthalene \n2-methyl-\nnaphthalene \nPhenanthrene \nLow molecular weight \nPAHs \nBenz[a]anthrazene \nBenzo[a]pyrene \nChrysene \nDibenz[a,h]-\nanthrazene \nFluoranthene \nPyrene \nHigh molecular weight \nPAHs \nTotal PAHs \n'~ong et al., 1995. \n2MacDonald et al., 1996. \n'~ac~onald et al., 2000a. \ndw =Dry Weight Effects \nRange-\n~edian' \n260 ng/g dw \n9600 ng/g dw Sediments \nProbable Other Probable Effect \nEffects ~evel' Sediment concentration3 \nQuality \nGuidelines \n400 ndg' \t 676 ugkg dw \n845 ugikg dw \n536 ugkg dw \n561 ugkg dw \n201.28 nglg dw \n543.53 ng/g dw 1170 ugkg dw \n1442 nglg dw \n692.53 ng/g dw \t 1050 ugkg dw \n763.22 ng/g dw \t 1450 ugkg dw \n845.98 nglg dw \t 1290 ugkg dw \n2230 ugikg dw \n1397.4 ng/g dw 1520 ugkg dw \n1800 ug/g8 \t 22800 ugikg dw \n'PTI Environmental Services, 1991. 'MacDonald et al., 2000b. \n5Long and Morgan, 1990. '~aire~ et al., 2001 \nVSEPA, 1993d. oc = Organic Carbon \nThe SQGs in Table 12are based on empirical data compiled from \nnumerous field andlaboratory studies performed in North America. \nChemistry data and a variety of different types of biological data for \nnumerous taxa were derived from bioassays of field collected samples, \nlaboratory toxicity test of clean sediments spiked with specific toxicants, \nbenthic community analyses, or equilibrium-partitioning models. These \nguidelines are not intended as toxicity thresholds above which effects are \nalways expected. Rather, the use of these values is to determine the \nincidence of significant toxicity among samples that exceed the values. \nSQGs should be used with caution because they are not perfect predictors \nof toxicity and are most useful when accompanied by data from in situ \nbiological analyses, other toxicologic assays, and other interpretive tools, \nsuch as metals-to-aluminum ratios and other guidelines derived either \nfrom empirical approaches andlor cause-effects studies. \nThe following sections briefly describe several SQGs: Effects Range Median (ERM), Probable Effects Level (PEL) \nTwo related efforts provide approaches for evaluating the quality of \nmarine and estuarine sediments. They are the National Oceanic \nAtmospheric Administration (NOAA) guidelines (Long et al., 1995) and \nthe sediment weight-of-evidence guidelines developed for the Florida \nCoastal Management Program (MacDonald, 1992 and 1994). \nLong et al. (1995) assembled data from throughout the country that \ncorrelated chemical concentrations with effects. These data included \nspiked bioassay results and field data of matched biological effects and \nchemistry. The product of the analysis is the identification of two \nconcentrations for each substance evaluated. One level, the Effects \nRange-Low (ERL) was set at the 10\" percentile of the ranked data and \nrepresents the point below which adverse effects are not expected to occur. \nThe second level, the ERM, was set at the 50\" percentile and is interpreted \nas the point above which adverse effects are expected. A direct cause and \neffect linkage in the field data was not a requirement for inclusion in the \nanalysis. Therefore, adverse biological effects recorded from a site could \nbe attributed to both a high concentration of one substance and a low \nconcentration of another substance, if both substances were measured at a \nsite. Either one, both, or neither of the two substances of concern could \ncause the adverse effect in field data. \nThe State of Florida efforts (McDonald, 1994) revised and expanded the \nLong and Morgan (1990) data set and identified two levels of concern for \neach substance: the \"TEL or threshold effects level, and the PEL. Some \naspects of this work represent improvements in the original Long and \nMorgan analysis. First, the data was restricted to marine and estuarine \nsites, thereby removing the ambiguities associated with the inclusion of \nfreshwater sites. Second, a small portion of the original Long and Morgan \n(1990) database was excluded, while a considerable increase in the total \ndata was achieved due to inclusion of new information. \nThe development of TELs and PELS differ from the development of ERLs \nand ERMs in that data showing no effects were incorporated into the \nanalysis. In the weight-of-evidence approach recommended for the State \nof Florida, two databases were assembled: a \"no-effects\" database and an \n\"effects\" database. Taking the geometric mean of the 50\" percentile value \nin the effects database and the 85\" percentile value of the no-effects \ndatabase generated the PEL. Taking the geometric mean of the isth \npercentile value in the effects database and the 50\" percentile value of the \nno-effects database generated the TEL. By including the no effect data in \nthe analysis, a clearer picture of the chemical concentrations associated \nwith the three ranges of concern -no effects, possible effects, and \nprobable effects, can be established. Probable Effect Concentrations (PECs) \nFor freshwater sediment, another benchmark is available, the consensus \nbased PEC. PECs are based on empirical measurements that relate \npollutant concentration to harmful effects on sediment-dwelling organisms \nand are intended to be predictive of those effects. These values were \nderived from a large database with matching sediment chemistry and \ntoxicity information from field studies conducted throughout the United \nStates. The SQG, expressed on an organic carbon-normalized basis, were \nconverted to dry weight-normalized values at one percent organic carbon \n(MacDonald et al., 1994; MacDonald et al., 1996; USEPA, 1997d). PECs \nare intended to identify harmful effects on sediment-dwelling organisms \nfrom contaminant concentrations. \nEquilibrium Partitioning (EqP) \nEqP values are theoretical SQGs, derived from effect concentrations \nmeasured in water only exposures. In sediment exposures, the effect is \npredicted to occur when the same concentration occurs in the pore water \nof the sediment. The premise of the EqP SQG is that if chemical \nconcentrations in pore water are not at toxic levels, then the sediment will \nnot be toxic. EqPs were developed for non-ionic chemicals. This \napproach is based on the distribution of contaminant between sediment \nsolids and pore water, and is predictable based on their physical and \nchemical properties, assuming continuous equilibrium exchange between \nsediment and pore water. \nThe EqP approach is supported by the results of spiked-sediment toxicity \ntests, which indicate that positive correlation exists between the biological \neffects observed and the concentration of the contaminants measured in \npore water. The primary strength of this approach is that the \nbioavailability of a class of compounds is addressed. The SQG is \ncalculated by using the appropriate water quality criteria (i.e., final chronic \nvalue, or equivalent value; USEPA 1997d) in conjunction with the \nsediment-water partition coefficient for the specific contaminants. \nHowever, other effect concentrations can be used, such as an LC50 (lethal \nconcentration for fifty percent of the population) for a particular species. \nThe EqP predicts fifty percent mortality occurs at a pore water \nconcentration equal to the water only LCJo. \nCorrelations \nCorrelations between toxicity, or other effects, and chemical concentration \ncan be used to show the relationship between these factors. Correlation \nanalysis is most useful in assessing which chemicals, study-wide (or \nthroughout a specific data set), may contribute to toxicity or benthic \neffects (Fairey et al., 1996; Anderson et al., 1997). Correlations provide \nadditional evidence that the observed toxicity could be caused by \nsediment-based or water concentrations of chemicals. Simple rank Recommendation: correlation can be used to determine the co-occurrence of chemical \nconcentrations and toxicity or other effects. \nThe preferred alternative is a combination of alternative 2 and 3 because \nthe CWA allows the placement waters on the section 303(d) list for \ntoxicity alone; however, once the pollutant is identified, the pollutant \ncausing or contributing to the toxicity should be added to the \nsection 303(d) list as soon as possible (e.g., during the next listing cycle). \nAlternative 3 lists various approaches that can be used to identify the \npollutant. \nAlternative 2 and 3. See Policy section 3.6,4.6,and 6.1.3. Issue 5D: \t Interpreting Sedimentation Data \nIssue: \t How should impacts due to sedimentation be addressed? \nIssue Description: \t Increased sedimentation can cause nuisance or adverse effects to many \nbeneficial uses. Water quality objectives for sediment are typically \nnarrative and based on nuisance condition or an adverse effect to a \nbeneficial use from increased sediment loads over natural levels. \nSediment-related water quality objectives are also expressed as numeric \nobjectives based on turbidity. \nRWQCBs face a variety of challenges when determining whether a water \nbody is impacted by sediment. Data that characterize beneficial use \nimpairment due to excess sedimentation often do not lend themselves to \nconventional measures of data quality. Given the natural variability in \nsediment supply and transport capacity, representativeness of data is \ndifficult to establish. Determining cause and effect relationships for \nsediment-related impacts is challenging due to changes in sediment \nsupply, transport capacity, and channel configuration, which can all \nproduce similar effects in a water segment. \nFor most RWQCBs, determining the impacts of sediment has been based \non non-attainment of numeric water quality objectives and the threat to \ndesignated beneficial uses. Basin Plans contain applicable water quality \nobjectives for sediment, settleable material, and turbidity. Examples of \nBasin Plan water quality objectives for sediment, settleable material, and \nturbidity include: \n\"The suspended sediment load and suspended sediment discharge rate \nof surface waters shall not be altered in such a manner as to cause \nnuisance or adversely affect beneficial uses.\" (Lahontan RWQCB, \n1995) \n\"Water shall not contain substances in concentrations that result in \ndeposition of material that causes nuisance or adversely affect \nbeneficial uses.\" (North Coast RWQCB, 1994) \n\"Turbidity shall not be increased more than 20 percent above naturally \noccurring background levels. Allowable zones of dilution within which \nhigher percentages can be tolerated may be defined for specific \ndischarges upon the issuance of discharge permits or waiver thereof.\" \n(North Coast RWQCB, 1994) \nBaseline: \t Sediment or sedimentation listings for the 2002 section 303(d) list were \nbased primarily on exceedances of numeric objectives. Alternatives: 1. Interpret case-bv-case. Establish general guidelines to trigger listing. This \nalternative provides the RWQCBs with the most flexibility, as it would \naccount for-a variety of site-specific conditions that could be encountered. \nHowever, this could also lead to inconsistencies in assessments. USEPA \n(2003b) recommends that, to determine whether a pollutant impairs a \nsegment, decision rules in the listing methodology should provide the \nopportunity to see exactly how assessment decisions were made. \nThere are many measurements that can be used to interpret concentrations \nor loads of sediment in water or in the channel. For example, with respect \nto cold freshwater habitat, beneficial uses may be threatened due to \nconditions either in the water column (e.g., suspended sediment and/or \nturbidity) or on the streambed (settleable material), or both. Indicators of \nstreambed condition include channel morphology, such as riffle (pool \nratios, residual pool depth), the index V* (a measure of the sediment \nwhich has filled in pools), cross-section, and thalwag profiles. Substrate \nconditions, such as percent of fine sediment in the total bulk core sample, \nmedian particle size, and riffle embeddedness are also indicators of the \nstream bed condition. Beneficial use impairment can be assessed by \n, \tevaluating site specific suspended sediment concentrations, turbidity \nlevels, and/or substrate conditions and comparing the data to threshold \nlevels and/or critical aquatic life stage requirements. \nUnder this alternative, a water body would be listed if any one of the \nfollowing conditions were met: \n4 \tBeneficial use impairment caused by increased sediment loads. \nThis condition would require evidence that beneficial use impacts are \ncaused by increased sediment loads. Evidence of beneficial use \nimpacts could include documentation of adverse biological responses, \ndegradation of aquatic life populations or communities, or restrictions \non recreation, navigation, or other beneficial uses. Comparison to \nreference conditions within watersheds or ecoregions would be \nappropriate in order to establish these impacts, as would documented \ndeclines in aquatic populations and aquatic community diversity. \n4 \tEvidence that beneficial use impacts are caused by sediment \nshould describe the link between the documented impact and the \npresence of sediment in the water, or stored in the channel. This \nevidence could include documented occurrence of conditions that are \nrecognized as having the impacts observed. For example, the filling of \na stream's pools with fine sediment reduces rearing opportunities for \ncertain fish and, as a consequence, reduces their populations. Where \nno single condition is compelling, multiple lines of evidence could \nsupport the determination that an impact has occurred, or that the \nimpact is caused by sediment. \n4 \tNuisance caused by sediment loads (CWC section 13050). Nuisance conditions could be documented through visual \nassessment or other methods conducted in a manner consistent with \nQA practices for reducing error and subjectivity. \n+ \tExceedance of turbidity objective, where turbidity is caused by \nincreased suspended sediment loads. Water bodies would not be \nlisted for sediment based on turbidity unless it can be demonstrated \nthat the cause of increased turbidity is an increased delivery of \nsediment. For example, increased turbidities that are related to \nreservoir releases should not lead to a sediment listing. \nDeterminations that Basin Plan turbidity objectives are exceeded, due to \nincreased delivery of sediment, should be based on data collected from the \nwater body over a period of time that accounts for the variable nature of \nsediment delivery and transport. \nThis alternative is the preferred alternative because waters would be listed \nbased on sufficient credible data and information that indicate water \nquality standards for sediment are not met by comparison to acceptable \nevaluation guidelines, or that impacts to beneficial uses are caused by \nsediment. This alternative would result in no change to existing listings, \nand would help provide guidance if other sedimentation listings are \nproposed. At present there are 135 pollutant/water body combinations that \nare listed due to sediment impacts. \n2. Provide s~ecific guidance to interoret narrative obiectives. Under this \nalternative, all the requirements of Alternative 1would apply but the \nRWQCBs would also be required to compare data sets to selected \nevaluation guidelines in order to interpret sediment concentration or load \ndata. A disadvantage of this alternative is that these evaluation values may \nnot be applicable throughout the State. \nScientific understanding of linkage between sediment supply and specific \nimpacts to aquatic species in a given watershed is often poor because \nhabitat conditions in streams a; shaped not just by sediment load, but also \nby the interactions of stream flow and in-channel and streamside \nvegetation and obstructions. Literature related to suspended \nsedimenvturbidity and streambed condition thresholds or life stage \nrequirements and measurements that could possibly be used to interpret \nthese impacts are reviewed briefly below. \nIt is generally accepted that for fish, the severity of the effect of suspended \nsediment increases as a function of sediment concentration and duration of \nexposure. However, identification of a specific threshold causing \nimpairment is difficult. While research to date is suitable for assessing \neffects of discrete suspended sediment (or turbidity) events, it is unsuitable \nfor measuring the cumulative effect of multiple events over the course of a storm season. Fish experience reduced short term feeding rates and \nfeeding success when exposed to a suspended sediment concentration of \n20 mgL (milligrams per liter; parts per million) for three hours \n(Newcombe and Jensen, 1996). Additionally, juvenile and adult \nsalmonids have been shown to undergo major physiological stress and \nexperience long-term reduction in feeding rates and feeding success when \nexposed to suspended sediment concentrations exceeding 148 mg/L for a \nduration of six days (Bjornn and Reiser, 1991). Direct mortality of under \nyearling salmonids has been tied to suspended sediment concentrations of \n1,200 mgL, while concentrations in the 300 mgL range caused reduced \ngrowth and feeding (Meehan, 1991). Feeding and territorial behavior have \nbeen reported to be disrupted by short term exposures (2.5-4.5 days) to \nturbid water with up to 60 NTU (nephelometric turbidity units) (Bjornn \nand Reiser, 1991). Juvenile coho salmon avoid water with turbidities that \nexceeded 70 NTU (Bisson and Bilby, 1982). Additionally, turbidities in \nthe 25-50 NTU range (equivalent to 125-275 mgL of bentonite clay) \nreduced growth and caused more newly emerged salmonids to emigrate \nfrom laboratory streams than did clear water (Sigler et al., 1984). \nAs the percentage of fine sediment (percent fines) in a channel increases \nas a proportion of the total bulk core sample, the survival to emergence \ndecreases. The percent fines 20.85-mm (millimeter) is defined as the \npercentage of subsurface fine material in pool tail-outs 10.85 mm in \ndiameter. Identifying a specific percentage of fines that can comprise the \nbulk core sample and still ensure adequate embryo survival is not clearly \nestablished. Research conducted in unmanaged streams (streams without a \nhistory of land management activities) in Washington recommended the \nuse of 11 percent fines 10.85-mm as a target. Percent fines 10.85 mm \nranged from four percent in the Queen Charlotte Islands to 28 percent on \nthe Oregon Coast, with a median value for all the data of about 11 percent \n(Bjornn and Reiser, 1991). \nA three-year study was conducted in Northern California streams, \nincluding three streams classified as unmanaged (Bums, 1970). The values \nfor fines <0.85 mm ranged from 17 to 18 percent, 16 to 22 percent, and \n18 to 23 percent. The numeric target representative of properly \nfunctioning conditions for fines <0.85 mm used in several TMDLs for \nNorth Coast streams is 14 percent. Another evaluation tool, V*, is \nrepresentative of the in-channel supply of mobile bedload sediment (Lisle \nand Hilton, 1992). The usefulness of this parameter is further \ndemonstrated by comparing annual sediment yields of select streams with \ntheir average V* values. The comparison indicated that V* is well \ncorrelated to annual sediment yield and quickly responded to changes in \nsediment supply. For example, V* values in French Creek, a tributary to \nthe Scott River in the North Coast Region, decreased to approximately \none-third the initial value soon after an erosion control program focusing on roads was implemented. V* values for Elder Creek, an undisturbed \ntributary of the South Fork Eel River averaged only 0.09 (Lisle and Hilton, \n1999). A study of over sixty streams in Northern California found that \nmean V* values of 21 percent or less represented good stream conditions \n(Knopp, 1993). The difference in the V* values is indicative of the \nvariability inherent in V* measurements. \nRecommendation: \t Alternative 1. See Policy sections 3.1,3.2,3.7.2,3.8,3.9,4.1,4.2,4.7.2, \n4.8,and 4.9. Issue 5E: Interpreting Temperature Water Quality Objectives \nIssue: \t How should water temperature data be interpreted? \nIssue Description: \t \"Water temperature is a catalyst, a depressant, an activator, a restrictor, \na stimulator, a controller, a killer, one of the most important and most \ninfluential water quality characteristics to life in water.\"- The Federal \nWater Pollution Control Administration (USEPA, 1986). \nTemperature can adversely affect the beneficial uses of water. Beneficial \nuses that are related to temperature impacts include cold water fisheries; \nwarm water fisheries; wildlife habitat; and aquatic organisms migration, \nspawning, reproduction, and endangered species. \nAmbient water temperature is one of the most important factors affecting \nthe success of fish and other aquatic life. With regard to coho salmon and \nsteelhead trout, temperature influences growth and feeding rates; \nmetabolism; development of embryos and juveniles; timing of life history \nevents, such as upstream migration, spawning, freshwater rearing, and \nseaward migration; and food availability (North Coast RWQCB, 2000). \nElevated temperatures can cause stress and lethality. \nWater quality objectives for temperature are specified in Basin Plans and \nthe \"Water Quality Control Plan for Control of Temperature in the Coastal \nand Interstate Waters and Enclosed Bays of California\" (SWRCB,1975). \nGenerally, Basin Plans define temperature objectives in two parts: \n\"The natural receiving water temperature in (intrastate and/or inland \nsurface) waters shall not be altered unless it can be demonstrated to the \nRWQCB that such alteration in temperature does not adversely affect \nbeneficial uses.\" (North Coast RWQCB, 1994) \n\"At no time or place shall the temperature of any cold (and/or warm) \nfreshwater habitat be increased by more than 5'F (2.S°C) above natural \nreceiving water temperature.\" (North Coast RWQCB, 1994) \nIn most circumstances, natural receiving water temperature is not defined. \nThe Thermal Plan describes natural receiving water temperature as 'The \ntemperature of the receiving water at locations, depths, and times which \nrepresent conditions unaffected by any elevated temperature, waste \ndischarge, or irrigation return waters.\" \nThe major difficulty in assessing whether a water body is meeting water \nquality objectives requires making a determination of the natural receiving \nwater temperatures. Determining \"natural receiving water\" temperature is limited by the availability of historic temperature monitoring data that is \nconsidered representative of unaltered andlor natural conditions in a water \nbody. \nBaseline: \t In 2002, section 303(d) listings were proposed for several North Coast \nrivers. These recommendations were based on evaluation of the Maximum \nWeekly Average Temperature (MWAT) data ranges, as compared to \nevaluation values for impacts on anadromous fish species. In addition, the \ntemperature data were evaluated with respect to the current and historic \npresence of cold water fish. If a stream, which exhibits temperatures \nwithin the chronic reduced-growth MWAT ranges, and had a decreased \nsalmonid fishery compared with historic levels, then it was listed using \ninferred historical stream MWATs. At present there are 37 pollutant/water \nbody combinations that are listed due to temperature impacts. \nAlternatives: 1. List using the Basin Plans obiectiveb) for temperature as the sole basis for w. When data of sufficient quantity and quality are available, a \ncomparison of current and \"historic\" or \"natural\" receiving water \ntemperatures can be made to determine whether water quality objectives \nare being met. \nDetermination of \"natural receiving water\" temperatures is limited by the \navailability of natural background and ambient temperature monitoring \ndata for water bodies. ~ssessm~nt of natural receiving water temperatures \nis complicated by the fact that water temperature of streams vary \nsubstantially due to drainage area, stream size, geographical location, \nriparian vegetation, seasonal climatic conditions, elevation, and other \nfactors (Lewis et al., 2000). Consequently, there are no generally \navailable natural receiving water temperature data sets for stream \nsegments that can be used because these natural levels are so site-specific. \nWithout natural receiving water temperatures it is impossible to interpret \nthe Basin Plan and Thermal Plan water quality objectives. \n2. \tList water bodv segments for temverature using an alternative avvroach \nfocused on beneficial use impacts and likelv effects of elevated \ntemperature on sensitive species. \"The evolution of freshwater \ntemperature criteria has advanced from the search for a single 'magic \nnumber' to the generally accepted protocol for determining mean and \nmaximum numerical criteria based on the protection of appropriate \ndesirable or important fish species or both\" (Bmngs and Jones, 1977). \nWhen \"historic\" or \"natural\" temperature data are not available, \nalternative approaches could be employed to assess temperature impacts. \nThe approach presented in this alternative deals with comparing recent \ntemperature monitoring data for a specific water body to the temperature requirements of resident aquatic life. In many cases, fisheries, particularly \nsalmonids, represent the beneficial uses most sensitive to temperature. \nInformation on the current and historic condition and distribution of the \nsensitive beneficial uses (e.g., fishery resources) in the water body is \nnecessary, as well as recent temperature data on conditions experienced by \nthe most sensitive life stage of the aquatic life species. If temperature data \nis from the past (historic) when the beneficial use was fully supported are \nnot available, information about presencelabsence or abundance of \nsensitive aquatic life species can be used to infer past temperature \nconditions. Therefore, this approach assumes that a decrease in the \npopulation and distribution of sensitive aquatic life species when \ncompared to past levels is due, at least in part, to a change in temperature \nconditions. \nDetermination of life stage temperature requirements of sensitive aquatic \nlife species should be based on peer-reviewed literature. Similarly, \nevaluation of temperature data should be based on metrics reflective of the \ntemperature requirements for sensitive aquatic life species. For example, a \ncommon metric for assessing chronic (i.e. sub-lethal) effects on salmonids, \nis the MWAT, the mathematical mean of multiple, equally spaced, daily \ntemperatures over a 7-day consecutive period (Brungs and Jones, 1977). \nThe MWAT of a particular water body can be compared to MWAT \ngrowth requirements for salmonids. \nTo maintain growth of aquatic organisms at rates necessary for sustaining \nactively growing and reproducing populations, the MWAT, in the zone \nnormally inhabited by the species during the season, should not exceed the \noptimum temperature plus one-third of the range between the optimum \ntemperature and the upper incipient lethal temperature of the species. \nMWATs are derived from a range of studies that looked at sub-lethal and \nacute temperature thresholds, incorporating information from laboratory- \nbased research, field observations, and risk assessment approaches. \nCalculated MWAT metrics for growth range from 14.3OC to 18.0°C for \ncoho salmon, and 14.3\"C to 19.0°C for steelhead trout. This approach \nsuggests that upper thresholds for the MWAT of 14.8\"C for coho and \n17.0°C for steelhead will reduce growth 10 percent from the optimum. \nThresholds for the MWAT of 19.0°C for both coho and steelhead will \nreduce growth 20 percent from optimum (Sullivan et al., 2000). \nWhile these thresholds relate to reduced growth, temperatures at sub-lethal \nlevels also can effectively block migration, inhibit smoltification, and \ncreate disease problems (Elliot, 1981). Further, the stressful impacts of \nwater temperatures on salmonids are cumulative and correlate to the \nduration and severity of exposure. The longer the salmonid is exposed to thermal stress, the less chance it has for long-term survival (Ligon et al., \n1999). \nThe upper lethal limit for salmonids ranges from 27OC to 30°C (Jobling, \n1981). Acute threshold values, causing death or total elimination of \nsalmonids from a location, range from 21.0°C to 25.5OC for coho, and \n21.0°C to 26.0°C for steelhead (Sullivan et al., 2000). \nIn streams, however, temperature is not uniform in space or time. \nTherefore, a single exceedance of the temperature threshold does not \nnecessarily mean that temperature conditions are impairing salmonids, and \nwould not necessarily result in a determination of impairment. On the \nother hand, consistent exceedance of these thresholds in disperse \nmonitoring locations throughout a sub-basin and over two or more seasons \nlikely does mean that temperature conditions are impairing salmonids, and \ntherefore, could lead to a determination that water quality standards are \nexceeded. \nThis alternative is the preferred alternative because it provides a \nmechanism for addressing potential temperature problems in the absence \nof often-unavailable temperature background data. This alternative is \nbased on the assumption that aquatic life beneficial uses (e.g., cold and \nwarm water fisheries) are most sensitive to modifications to natural \ntemperature. Other beneficial uses that may also be affected by \ntemperature include recreation and aquaculture; other approaches for \nassessing temperature impairment may be more appropriate for these \nbeneficial uses. \nRecommendation: Alternative 2. See Policy sections 3.2.4.2, and 6.1.5.9. Issue SF: \t Interpreting Data Related to Adverse Biological Response \nIssue: \t How should data related to adverse biological response be interpreted? \nIssue Description: \t An organism's response to pollutants is typically assessed with toxicity. \ntests or by observation of changes in the biological population or \ncommunity. There are also studies that address the exposure and response \nof individual organisms to chemical stressors. For example, adverse \neffects may be assessed by visual means for necropsy or for \nmorphological deformities, defects, or other pathological changes in \nspecific tissues or organs. Lesions in these tissues are often correlated \nwith death, deformity, or poor general fitness (condition indices) of the \nanimal, and include cancerous or precancerous transformations in tissues \nsuch as the gills, liver, or reproductive organs, etc. Some abnormalities \ncan, however, appear in the early stages of development of more \ndamaging pathologies that may be reversible (these are indications of \nexposure rather than actual adverse effects). \nBaseline: \t In 2002, listings for adverse biological response were not recommended. \nHowever, in previous lists (prior to 2002), some waters were placed on the \nsection 303(d) list for abnormal fish histology. \nAlternatives: 1. RWOCBs should interuret adverse bioloeical response data on a case-bv- \ncase basis. Interpreting adverse biological response in an organism is a \nhighly complex process. Complexities involve patterns of exposure, \nseasonal effects,~bioavailability, age, gender, prior history of exposure and \nphysiologic conditioning of the host, and species residence in the water \nbodies in question. Under this alternative, general guidelines would be \noutlined in the Policy. \nGeneral guidance for adverse biological response would require the \ncomparison of endpoints to reference conditions, the identification of \npollutants suspected of causing or contributing to the adverse response, \nand the association of pollutants with an adverse response. Endpoints for \nthis factor would be stated in the Policy but no specific evaluation values \nwould be proposed. The endpoints would include fish kills, reduction in \ngrowth, reduction in reproductive capacity, abnormal development, \nhistopathological abnormalities, and other adverse conditions. Evidence \nthat pollutants or pollution are capable of causing or contributing to the \nadverse condition would be the same process as described in the toxicity \ntesting section (Issue 5C). The major factors identified include: \nGrowth Measures: Reductions in growth can be addressed using suitable \nbioassay through measurements of field populations. Recommendation: The major disadvantage of this alternative is RWQCB would be limited by \nthe approaches presented and would not be able to interpret the various \nkinds of data and information that may be submitted. These types of data \nare typically water body-specific; often are not collected using standard \nprocedures; are usually the result of research projects; and are not part of \nmajor ambient monitoring programs. The only advantage is the more \nspecific guidance could lead to greater consistency among RWQCBs. \nAlternative 1. See Policy sections 3.8 and 4.8. Issue 5G: \t Degradation of Biological Populations or Communities \nIssue: \t How should bioassessment information be used in determining whether a \nwater body is attaining water quality standards? \nIssue Description: \t The diversity and condition of biological communities reflect overall \necological integrity (i.e., chemical, physical, and biological integrity). \nTherefore, bioassessments are important for evaluating ecosystem health \nand providing crucial water quality planning information for managing \nmore complex water quality problems (Barbour and Hill, 2003). \nThe effects of different pollutants such as excess nutrients, toxic \nchemicals, increased temperature, and excessive sediment loading are \nintegrated by biological communities and provide an overall measure of \npollutant impact. The response of biological populations and communities \nto stresses of all degrees often occurs over time. Therefore, information \non disturbances within the community is not always evident with episodic \nwater chemical measurements or discrete toxicity tests. The purpose of \nassessing the biological condition of aquatic populations and communities \nis to determine how well a water body supports aquatic life. \nAquatic community structure (organisms that live in the water or \nsediments) can be used to assess whether sites with substantially similar \nphysical characteristics differ in terms of the species present and number \nof individuals of each species. These types of measures focus on the \npopulation or community level. The results can then be analyzed using \nvarious indices, ordination techniques, principal component analysis, or \nother techniques to identify potential causes of any differences detected. \nThe analysis of community composition provides not only direct \nassessment of impacts, but also an opportunity to identify indicator \nspecies, i.e., species that respond predictably or characteristically in the \npresence or absence of degraded conditions, such as those produced by a -\npolluted environment. ~ue to the numerous forces influencing the \ncomposition of a community or population, it is often difficult to \ndetermine whether pollution or pollutants are responsible for such \nchanges. \nBioassessment serves four primary functions or uses: \nt Screening or initial assessment of conditions; \nt Characterizing the magnitude of impairment; \nt Assisting in the diagnosis of causes to impairment; and \nt Monitoring of temporal trends to evaluate improvements or further \ndegradation. Baseline: \t In 2002, the section 303(d) list based listings on data types that considered \ndegradation of aquatic life populations or communities and required \nmultiple lines of evidence. Each of these multiple lines of evidence \ngenerally needed the pollutant(s) that caused or contributed to the adverse \ncondition. \nAlternatives: 1. Do not use bioassessment as a water aualitv indicator. This alternative \nwould fail to meet the state's responsibility under CWA to protect and \nrestore the biological integrity of the state's waters. chemical, physical, \nand biological integrity define the overall ecological integrity of a water \nbody. Biological integrity is a strong indicator of ecological integrity and \nserves as a useful measure of a water body's environmental status. \nBiological systems are more variable than the chemical and physical \nproperties that were the basis of the state's water quality regulations. \nThis alternative would also be contrary to USEPA's focus on the \ndevelopment of sound scientific approaches to determine the health of the \nnations aquatic ecosystems and the stressors most closely associated with \nthe impairment. In keeping with its responsibilities under CWA, USEPA \ninitiated, in the late 1980's, EMAP, a long-term research effort to enable \nstatus and trend assessments of aquatic ecosystems. EMAP addresses \nmonitoring the conditions of estuaries, streams, and lakes in selected -\ngeographic regions, as well as examining the surrounding landscapes in \nwhich these resources occur. This is the first stev in USEPA's overall \nstrategy for environmental protection and restoration and EMAP forms the \nbasis for the research needed to establish the condition of the nation's \nresources. \nTraditionally, RWQCBs have measured biological conditions indirectly, \nthrough the use of chemical-specific analysis and toxicity. These \nmeasures assess the suitability of a water to support a healthy community, \nbut do not assess the communities health itself. Assessment of the \nbiological community measures the resident aquatic community structure \nand function to determine biological and ecological integrity. \n2. Intemret case-bv-case. Assessing the biological condition of aquatic \ncommunities is an indication of how well a water body supports aquatic \nlife. This indicator is measured against a reference condition--the baseline \nagainst which human effects can be compared. Understanding reference \nconditions requires distinguishing and classifying ecological systems \nwithin and between regions. It also requires defining standards for each of \nthose systems, that is, quantitative benchmarks corresponding to \nconditions with little or no human influence (Karr and Chu, 1997). \nAs RWQCBs seek to develop bioassessment programs, the lack of \nbiocriteria for specific areas within each region leads to the interpretation of impairment on a case-by-case basis. Currently, the SWRCB and the \nRWQCBs have only recently begun to use bioassessment programs to \nassess ecological conditions and there is no one program that is currently \nfavored in the state. Five programs exist in California that have \nscientifically valid methods, similar purposes and scope, and could \nprovide the framework for the implementation of a statewide \nbioassessment approach. In lieu of development of a statewide program, \nthe RWQCBs should look to these programs for assistance: \nt \tCalifornia DFG Aquatic Bioassessment Laboratory -California \nStream Bioassessment Procedure (CSBP) -the most widely used in \nthe state, CSBP was developed for point-source assessments. CSBP \nhas collected nearly 9,000 samples at 2,500 sites. An adaptation has \nbeen developed for non-wadeable streams and ambient water quality \nmonitoring. \n+ \tLahontan RWQCB Biological Assessment Program -Sierra Nevada \nAquatic Research Laboratory (SNARL) Method -the Lahontan \nRWQCB has collected samples using SNARL protocols. Since 2000, \nthey have evaluated benthic macroinvertebrates, periphyton, and \nphysical attributes using SNARL, CSBP, and the River Invertebrate \nPrediction and ~lassification Scheme (RNPACS). \nt \tUSFS -Pacific Southwest Region Bioassessment Program -this \nprogram has established reference conditions by collecting \nmacroinvertebrates from a network of perennial and intermittent \nwadeable streams on Forest Service Lands throughout the state. \nt \tUSGS: National Water Quality Assessment (NAWQA) Program -this \nprogram describes the status of and trends in the quality of surface \nwater and groundwater to provide scientific understanding of natural \nand human-induced factors that assess water quality. NAWQA has \nassessed the Sacramento Basin, the San Joaquin-Tulare Basins and the \nSanta Ana Basin. \nt \tUSEPA Central Valley Regional Environmental Monitoring and \nAssessment Program (REMAP) -focuses on assessing the biological \nintegrity of agriculture-dominated water bodies throughout the Central \nValley. USEPA is also collecting bioassessment data in California as \npart of the EMAP Western Surface Water pilot study, a five-year \nresearch and monitoring project to assess the ecological condition of \nstreams and rivers throughout the Western U.S. \nWith the lack of a statewide bioassessment program, guidance on the use \nof bioassessment data for listing decisions becomes increasingly \nimportant. While this alternative would give the RWQCBs added \nflexibility to develop bioassessment programs, it lacks the consistency \nnecessary to ensure that listing decisions comply with this Policy and \nUSEPA guidance. 3. \tEstablish consistent value(s) to hipeer listing. The implementation of an \neffective bioassessment program requires the establishment of consistent \nvalues that trigger listings. However, while a standardized program is \nimportant for the listing process, biocriteria still needs to be appropriately \ntailored to the regional setting. \nOptions: \nA. \tUse professional judgement of qualified scientists to interpret \ndata. The development of biocriteria relies on the examination of raw \ndata in the field and in the laboratorv. The need for interoretation of . \ndata by qualified scientists is necessary but expert judgement alone is \nnot an acceptable substitute for scientifically valid data. 'Professional \njudgement can be incorporated into approaches using multivariate \ntechniques and the regional reference approach. The use of \nprofes&onal judgemeit to interpret data is most valuable once \nquantitative criteria for determining what constitutes exceptional, \ngood, fair, poor and very poor water body conditions has been \nestablished. At that point, professional judgement is but one of the \ncomponents used to tailor the biocriteria process to regional \nconditions. \nB. Express factors in terms of changes in numbers, species diversity, \nindices of community metrics, etc. Direct measurements of ambient \nbiological communities including plants, invertebrates, fish, and \nmicrobial life have been used by many states as indicators of the health \nof a water body. Data on the biological assemblages present in a water \nbody: \n4 \tProvide a functional definition of biological integrity, \n4 \tMinimize problems with interpreting the natural geographic and \ntemporal variability of data by aggregating within regions of \necological similarity, -\nt Use reference conditions for specific geographic areas, and \nt Combine several assemblage attributes to produce a single numeric \nmeasure of biological integrity. \nWater body measurements require an indicator species or community \nwhich possess particular requirements with regard to a known set of \nphysical or chemical variables, such that changes in presencelabsence, \nnumbers, morphology, physiology, or behavior of the species or \ncommunity indicate that the given physical or chemical valuables are \noutside its preferred limits. The ideal biological indicator should have \nthe following characteristics (Barbour et al., 1996): \n4 Taxonomic soundness and easy recognition, \nt Cosmopolitan distribution, \n + Numerical abundance, \n+ Low genetic and ecological variability, \n+ Relatively large body size, \n+ Limited mobility and relatively long life history, \n+ Well known ecological characteristics, and \n+ Suitable for use in laboratory studies. \nThere are indexes of biological conditions, which have been \nextensively developed for freshwater systems, and are effective for \nassessing ecological conditions in a variety of settings, with many \ntaxa, and in diverse geographic regions. They are objective, \nscientifically rigorous, and easy to communicate to non-technical \naudiences. \nOne system, the Index of Biological Integrity (IBI) is a synthesis of \ndiverse biological information, which numerically depicts associations \nbetween human influence and biological attributes. It is based on a \ncombination of tested biological attributes (metrics or indices) that are \nsensitive to changes in biological integrity caused by human activities. \nThe multi-metric (a compilation of metrics) approach compares what \nis found at a monitoring site to what is expected using a regional \nbaseline condition that reflect little or no human impact (Barbour et \nal., 1999). The IBI provides a cumulative site assessment as a single \nscore value and is the endpoint of a multi-metric analytical approach. \nAnother approach, RIVPACS uses empirical models that predict the \naquatic macroinvertebrate fauna expected to occur at a site in the \nabsence of environmental stress. RNPACS sampling strategy and end \nproduct are similar to the IBI approach. However, these approaches \nuse fish assemblages in assessing the quality of rivers and streams. In \nCalifomia, it is difficult to integrate metric values for fish into one IBI \nscore because aquatic systems are: inherently low in species richness \nespecially in trout streams; abundant in populations of introduced fish; \nand altered due to pressures from fish stocking and angling pressure. \nA promising approach for California is the use of a benthic \nmacroinvertebrates index (BMI) for water resource monitoring. \nBenthic macroinvertebrates are ubiquitous, relatively stationary and \ntheir large species diversity provides a range of responses to \nenvironmental pressures. Individual species reside in the aquatic \nenvironment from a period of a few months to several yearsand are \nsensitive, in vaiying degrees to temperature, DO, sedimentation, \nscouring, nutrient enrichment, and chemical and organic pollution. \nAquatic invertebrates also represent a significant food source for \naquatic and terrestrial animals. In addition to the advantages listed \nabove, the taxonomy of many groups and the response of many species are well known, and data analysis methods have been developed for \ncommunity level bioassessment. \nThe California Aquatic Bioassessment Laboratory Network \n(CAMLnet) has current information on the taxonomy of \nmacroinvertebrate taxa found in California streams and lakes \n(www.dfg.ca.gov/cabw/cabwhome.html).\n It also describes the standard \nlevel of taxonomic effort that has been defined for bioassessment \nprojects using the CSBP. Specialized references are suggested for \nparticular taxa. \nC. Identify appropriate reference conditions within watersheds or \necoregion. Variation is fundamental to biological communities and \nmeasures of biotic integrity based on these communities vary \naccordingly. Most bioassessment techniques account for variation \nthrough the use of reference sites. Reference sites can be used to \ncharacterize the range of biotic conditions expected for minimally \ndisturbed sites. The conditions of aquatic life found at these sites help \nto detect both the cause and level of risk to biological integrity at \nsimilar sites in a region. Reference sites determine the overall base \ncondition for waters of a certain type within a region. In keeping with \nthe strategy of not degrading the resource, interim reference conditions \n-like the criteria they help define -are expected to be upgraded with \neach improvement to the water resource. Biological criteria should not \nbe based on data derived from degraded reference sites. \nIn order for a bioassessment program to be meaningful and defensible, \nthe RWQCBs should strive toward objective procedures for selecting \nreference sites. This could include theuse of Geographic Information \nSystems (GIs) to allow identification and selection of \"minimally- \nimpaired\" reference sites based on objective criteria. \nOne approach for selecting reference sites has been developed by DFG \nin collaboration with SNARL. The approach uses GIs to identify areas \nwithin the region that exhibit minimal impacts (target areas). Suitable \nstream reaches within these target areas are identified resulting in \nreference sites for the region of interest. The procedure consists of the \nfollowing five steps: \n1. \tDefine region of interest and classes of stream types to be \nevaluated, \n2. \tIdentify regions with major disturbances and quantify potential \nimpacts to different areas within the region using GIs techniques, \n3. \tUse GIs-based impact estimates to identify least-disturbed \ncandidate areas in the region, \n 4. \tUndertake field reconnaissance of candidate areas for selection of \nreference sites for sampling, and \n5. \tAssess local conditions quantitatively to confirm high quality \nenvironments. \nMost reference sites selected in bioassessment studies have been selected \nfor comparison to local conditions and have not been selected using \ncommon criteria that would allow comparison among projects. These \nstudies have relied almost exclusively on BPJ in the selection of reference \nsites. While there is legitimacy in this approach, BPJ is rarely quantified \nand is not repeatable. This complicates comparison with other projects. \nAdditionally, recent USEPA analyses indicates that reference sites chosen \nby BPJ often do not have significantly different biological signatures from \nsites chosen randomly. A standardized and objective approach to \nselecting reference sites would improve consistency and repeatability \nacross bioassessment studies. \n4. \tUse bioassessment data and information if associated with water and \nsediment measurements. Provide guidance on values for association \nassessment. Bioassessments are an effective tool for evaluating ecosystem \nhealth because biological assemblages (fish, macroinvertebrates, etc.) \nintegrate relevant chemical, physical, and biological factors in the \nenvironment. However, bioassessment by itself may not present enough \ninformation to determine attainment for a particular water body, \ndepending on its designated uses. ~el~in~bn bioassessment alone does \nnot allow for determination of associated causes and sources of \nimpairments necessary to determine attainment of a beneficial use. \nEvaluation of biological data begins with selection of a reference site. \nWide variability among natural surface waters prevents the establishment \nof a single reference site. Reference sites may be established using \nhistorical data, unimpaired habitat or empirical data. Reference site \nselection should take into account the level of human disturbance, stream \nsize, stream channel type, location, and historical records of resident biota, \nRWQCBs should clearly document how reference sites are selected and \nused. Specific guidelines for selecting reference sites are described in \nAlternative 3. Guidance is also available from USEPA on selecting \nreference sites. Using USEPA guidance (1990), RWQCBs can select site \nspecific, upstream downstream, near field-far field, regional, paired \nwatershed, or ecoregional reference sites. \nSite-specific reference conditions are used to evaluate impacts from point \ndischarges on waters with strong directional flow and require a \ncomparable habitat within the same watershed. This approach is difficult \nto establish when significant contamination from nonpoint sources exists, i extensive habitat modification has occurred, contamination comes from \nmultiple sites, or the impacted site is significantly different than the \nreference site. \nUpstream-downstream reference conditions are used in rivers and streams \nwhere habitat characteristics are similar above and below the point of \ndischarge. This approach may be cost effective when bioassessment of the \nupstream reference condition reflects the attainable condition of the \nimpacted site. However, assessment of several upstream sites may be \nneeded to describe the natural variability of the reference biota. \nNearfield-farfield reference conditions, effective for establishing \nreference sites in unique water bodies, measure habitat characteristics and \nthe gradient of impairment. This approach may provide an effective \nmethod to establish biological criteria for estuaries, large lakes, or \nwetlands. \nRegional reference conditions are based on the assumption that surface \nwaters integrate the character of the land they drain. Reference sites, \ntherefore, would incorporate ecological features, such as soil type, \nvegetation, land-surface form, climate and land use that directly or \nindirectly relate to water quality. \nPaired watershed reference conditions are established by identifying \nsimilar unimpaired water bodies that are comparable to the type and \nhabitat of impaired water. This method is usdd in the Rapid \nBioassessment Protocols (Barbour et al., 1999). \nEcoregional reference conditions identify water bodies of similar type in \nregions of ecological similarity. Reference sites should be as minimally \ndisturbed as possible, yet represent similar habitat type and be \nrepresentative of the region. \nOnce reference sites are selected, bioassessment data should be used in \nconjunction with water and sediment measurements, physical habitat data, \nand other water quality data to support conclusions about the status of the \nwater body. These methods should be used together to support an \nintegrated water quality assessment, each providing an independent \nevaluation of nonattainment of a designated use. Bioassessment, water and \nsediment assessments, and habitat data provide different and \ncomplementary types of information about the source and extent of \nimpairment. \nProperly developed sampling methods, combined with the use of metrics \nand reference conditions, provides a direct measure of the ecological \ncondition of a water body. The determination of impairment to beneficial uses relies on the strength of the biological survey, as well as on the \navailability of quantitative data-intensive physical and chemical \nmonitoring at all test sites and reference sites. This data is critical to the \nrefinement of bioassessment models because it allows for the \nidentification of physio-chemical factors that have the ability to influence \nnatural community variation. The interpretation and assessment of \ntoxicity measurements and sedimentation are discussed more thoroughly \nin Issues 5C and 5D respectively. \nRWQCBs should describe the habitat they are sampling and why it was \nchosen. Sampling considerations should include adherence to strict QC \nprocedures to provide consistency and avoid sampling error. RWQCBs \nshould also document the index period (time of year and duration) when it \nwill sample the condition of the biological community, or specify that it \nwould sample year-round. Index periods should be established for a \nparticular season, time of the day, or other window of opportunity when \nsignals are determined to be strong and reliable. Further, only results from \nsimilar index periods should be compared. \nBioassessment Guidelines \nTo accurately assess degradation of populations and communities, \nRWQCBs should identify water bodies and ecoregions of interest and \ncollect data from representative samples of water bodies in the target \npopulation (e.g., EMAP). \nRWQCBs should clearly document how the natural variability of its \nbiological data is determined. Classification of water bodies may be based \non water body type (e.g., rivers, streams, lakes, wetlands, estuaries), \nwatershed drainage size, ecological regions, elevation, temperature, and \nother physical features of the landscape andlor water body. \nRWQCBs should also document how reference sites are selected and used. \nA reference condition, an empirical model of expectations that may \ninclude knowledge of historical conditions, or a model extrapolated from \necological principles can be derived from reference sites. A reference site \nmay be natural, minimally impaired (somewhat natural), or best available \n(altered system). Actual sites that represent best attainable conditions of a \nwater body should be used. Where reference sites are not available \n(e.g., for large ecosystems such as rivers, estuaries, nearshore coastal \nareas, and in significantly altered systems such as urban centers and \ncropland areas), a disturbance gradient may be constructed to extrapolate \nto an appropriate reference condition (Karr and Chu, 1997). \nRWQCBs should verify the current conditions of candidate reference sites. \nA candidate site should be eliminated if conditions preclude its ability to \nserve as a reference for high-quality water. RWQCBs should document both the assemblages used as indicators and \nthe level of taxonomy used to assess them. Biological indicators can be \nseparated into four principal assemblages that are used for assessing water \nquality standards attainmentlimpairment decisions: benthic \nmacroinvertebrates, fish, algae, and aquatic macrophytes. \nBenthic macroinvertebrates -Macroinvertebrate community structure \ngenerally is a function of past conditions in the specific water body. \nGenus/species taxonomic identification provides the most representative \ninformation on ecological relationships and best resolution in sensitivity to \nimpairment. A representative of each taxon in the macroinvertebrate for \neach major basin, ecoregion, site class, or other appropriate study unit can \nserve as a basin record and reference for checking identification as well as \nproviding a data quality check. \nFish -Bioassessments using a fish assemblage requires that all fish species \n(and size classes), not just game fish, be collected. Fish are good \nindicators of long-term effects and broad habitat conditions because they \nare relatively long-lived, mobile and integrate various features of \nenvironmental quality, such as food and habitat availability (Simon and \nLyons, 1995). The objective of a fish assemblage is to collect a \nrepresentative sample of all species (except rare species) in the assemblage \nand provide a measure of the relative abundance of species in the \nassemblage. All fish should be identified to species level. \nPeriphyton orphytoplankton -Algae are primary producers and \nresponsive indicators of environmental change. The periphyton . . \nassemblage serves as a good biological indicator in streams and shallow \nareas because of its nahlrally high number of species and rapid response to \nexposure and recovery. Additionally, this assemblage integrates physical \nand chemical disturbances to a stream reach. Algae should be identified to \nthe species level in rivers and wadeable streams. Identifying diatom \ngenera in assemblages can provide valuable characterizations of biotic \nintegrity and environmental conditions. For assessing lakes, phytoplankton \nassemblages should be sampled and counted and cells should be identified \nto the order or genus level. \nAquatic macrophytes -Aquatic macrophytes include vascular plants \n(grasses and forbs) and may be emergent or submergent. Vascular aquatic \nmacrophytes are extensive primary producers and provide valuable habitat \nfor fish and waterfowl. Important in estuaries and wetlands, macrophytes \nare identified to species level or categorized as emergent, submergent, or \nfloating leaf for purposes of assessment. There are three basic macroinvertebrate habitat types commonly used to \nsample aquatic organisms. They are artificial substrate, multihabitat, and \nsingle habitat. The following considerations should be met when selecting \nwhich one to sample: (1) adherence to strict QC procedures to provide \nconsistency and avoid sampling error, (2) reliance in choosing a single \nhabitat type based on its availability and dominance as a productive \norganism habitat (e.g., cobble in streams, kelp beds in coastal areas, or \nmud in estuaries), (3) preference for a multihabitat approach in systems \nwith diverse habitat, and (4) use of artificial substrates, which leads to \nsampling habitat that is natural for the system@) under study (e.g., rock \nbaskets in cobble streams or lakes, or substrates to represent woody debris \nin streams). The RWQCBs should describe which habitat type it is \nsampling and why it was chosen. \nBioassessments are most useful when the sample is representative of the \nsite examined and the assemblage measured; the data are an accurate \nreflection of that sample; and the methods distinguish natural and \nmeasurement variability (i.e., \"noise\") from a true environmental effect \n(i.e., \"signal\"). \nThis alternative represents the preferred alternative because bioassessment \nof natural communities directly assesses the status of a water body relative \nto the primary goal of the CWA. General guidance is needed because of \nthe diversity of measurements and analyses needed to interpret \nbioassessment data. Association of bioassessment data with water or \nsediment concentrations of pollutants is necessary to show that the \npopulation or community changes observed are potentially caused by \npollutants. \nRecommendation: Alternative 4. See Policy sections 3.9,4.9, and 6.1.5.8. Issue 5H: Trends in Water Quality \nIssue: How should trends in water quality (Antidegradation Policy and \nthreatened waters) be used? \nIssue Description: Waters that currently meet standards but show a declining trend in water \nquality may not meet antidegradation requirements and could be \nconsidered for inclusion on the section 303(d) list. Antidegradation is a \nprimary component of water quality standards. \nState Antidegradation Policy calls for maintenance of water quality where \nit exceeds existing water quality standards unless degradation will provide \nmaximum benefit to the public, not unreasonably affect existinglpotential \nbeneficial uses, and not diminish quality below existing water quality \nobjectives. \nFederal regulation also calls for the identification of threatened waters as \npart of the section 303(d) listing process (40 CFR 130.2Q)). \nBaseline: In 2002, all section 303(d) listing proposals were based upon data and \ninformation that showed water quality objectives were exceeded. No data \nand information used showed trends in water quality that did not also \nindicate standards were exceeded. \nAlternatives: 1. Provide no guidance in the section 303(d) process on the use of the \nantidegradation component of standards or for threatened waters. Under \nthis alternative, RWQCBs would be given significant latitude in deciding \nwhat constitutes a violation of the antidegradation portion of water quality \nstandards or if threatened waters should be identified on the list. For each \ncircumstance, RWQCBs would decide which waters to list after \nconsidering the available data and information. The Policy would not \nprovide guidance on the analysis of data and information for the \nantidegradation portion of water quality standards or for threatened waters. \nEach RWQCB would address trends in water quality, threatened waters, \nand antidegradation in their own manner. This alternative was used for \nsection 303(d) listing decisions before 2002. \nThis alternative may foster inconsistent interpretation of antidegradation \nrequirements because each RWQCB would develop its own set of decision \nrules. Existing practices would continue and it is likely that many waters \nthat show declining trends in water quality would not be considered for the \nsection 303(d) list. \n2. Provide general euidance on trends in water aualitv. The goal of many \nmonitoring programs is to identify changes or declining trends in water \nquality over time. If trends in pollutant concentrations are declining to levels that may eventually not meet water quality objectives, it is possible \nthat the antidegradation provisions of water quality standards are not met \nor that water might be threatened. Consequently, numeric, pollutant- \nspecific water quality objectives need not be exceeded to satisfy this \nlisting factor. \nData and information to properly substantiate the decline of water quality \nrequires the application of unique trend analysis approaches to account for \nsuch factors as seasonal or weekly systematic variations, and auto- \ncorrelation in the data due to interventions or sampling procedural \nchanges. Such approaches currently exist and are accepted for \ndocumenting trends in water quality (USEPA, 2000a). Although there are \nsome trend data already available from some long-term monitoring \nprograms the data may be statistically difficult to analyze and interpret \nbecause of problems with the characteristics of the data mentioned above \n(Gilbert, 1987). The RWQCBs should take into consideration the \nfollowing factors in specifying statistical approaches used to evaluate the \ndeclining trend in water quality measurements: \nChanges in analytical procedures \nIf analytical procedures are changed during the implementation of along- \nterm monitoring program, changes in the trend may be due to these \nchanges alone and not due to the underlying factors that influence the \npollutant or condition data. These problems can be reduced through side- \nby-side comparisons of the methods (Gilbert, 1987). Changes in analytical \ndetection can also have a large effect on the trend. If detection limits are \nlowered and censored data are used in the trend analysis, this change could \ninduce an artificial downward trend (Smith and McCann, 2000). \nSeasonal changes \nMany water quality parameters change seasonally making it difficult to \nidentify trends. To characterize seasonal changes, data should be available \nfor several years and, depending on the circumstances, more than two \nseasons should be available. \nCorrelated data \nWhen analyzing trend data using statistical procedures, it is important that \nmeasurements be independent. In trend analysis, data collected at closely \nspaced sites or over relatively short periods of time can be positively \ncorrelated and not independent. \nBaseline conditions \nThe significance of trends is compared to a time or series of measurements \nearly in the monitoring effort to establish baseline conditions. If less \naccurate or precise data are used during the early stages of the monitoring effort, it may induce an artificial downward trend merely because of the \nanalytical methods used (Smith and McCann, 2000). \nSpecific guidance on trend analysis that applies to the variety of \ncircumstances encountered cannot be provided. General guidance for \nassessing trends in water quality include: \n1. \tUsing data collected for a minimum of three years [data covering \nseveral years are needed to address systematic variation such as \nseasonality (USEPA, 2000a)l; \n2. \tEstablishing specific baseline conditions; \n3. \tSpecifying statistical approaches used to evaluate the declining trend \nin water quality measurements; \n4. \tSpecifying the influence of seasonal effects, inter-annual effects, \nchanges in monitoring methods, changes in analysis of samples, and \nother factors deemed appropriate; \n5. \tDetermining the occurrence of adverse biological response, \ndegradation of biological populations and communities, or toxicity; \nand \n6. \tAssess whether the declining trend in water quality is expected to not \nmeet water quality standards by the next listing cycle. \nWaters should be placed on the section 303(d) list if the declining trend in \nwater quality is substantiated (steps 1 through 4 above) and impacts are \nobserved (step 5). It should also be acknowledged in the Policy \nintroduction that waters should be listed where water quality standards are \nnot expected to be met by the next listing cycle (currently two years). \nRelationship to Antidegradation Requirements \nFederal antidegradation policy applies to situations where existing water \nquality may be changed. These situations include: establishment or \nrevision of water quality objectives, changes in water quality objective \nimplementation procedures, permit and waste discharge requirement \ndecisions, some cleanup and abatement orders, remedial action plans, \nwaivers or exceptions from Plans, and water right decisions. Where the \nantidegradation policy applies, it does not absolutely prohibit changes in \nwater quality. The application of the policy depends on the conditions \nexisting in water bodies. The antidegradation policy (40 CFR 131.12) lays \nout a three-tiered approach for the protection of water quality. \n\"Tier I\" (40 CFR 131.12 (a)(l)) of antidegradation maintains and protects \nexisting uses and the water quality necessary to protect these uses. \n\"Tier II\" (section 131.12(a)(2)) protects the water quality in waters whose \nquality is better than that necessary to protect \"fishable/swimmable\" uses \nof the waterbody. Outstanding national resource waters (ONRWs) are provided a high level of protection under the antidegradation policy \n(\"Tier III\"). \nThe focus of the Listing Policy provisions related to trends is focused on \ndetermining compliance with Tier I or Tier 111. In general, States must \nassure protection of beneficial uses, including aquatic life. Reductions in \nwater quality (declining trends) should not be allowed if this change \nwould result in serious harm to any species found naturally in the water. \nWater quality must be maintained at levels that result in no mortality or \nsignificant growth or reproductive impact of resident species (Attwater, \n1987). If numeric water quality standards are met but there is a declining \ntrend (the prohibited change in water quality) and beneficial uses are \nimpacted, the antidegradation portion of standards is not met. \nTier I1 waters are not addressed under the Listing Policy because (1) no \naction or activity is being proposed that would require a finding that the \nlowered water quality is necessary to accommodate important economic or \nsocial development in the area in which the waters are located, \n(2) beneficial uses are not impacted, and (3) numeric water quality \nobjectives are achieved. \nThis alternative represents the preferred alternative because trends in \nwater quality should be used to assess compliance with the antidegradation \nportion of standards and to address threatened waters. General guidance \nshould be used because very specific guidance might not be applicable to \nthe wide range of trend data that may be encountered. \nRecommendation: Alternative 2. See Policy sections 1,3.10, and 4.10. Issue 6: \t Statistical Evaluation of Numeric Water Quality Data \nIssue: \t Should statistical procedures be used to evaluate numeric water quality \ninformation for section 303(d) listing and delisting decision-making? \nIssue Description: \t Decisions to list or delist a water body should be based on accurate, \nrepresentative, and verifiable information and on up-to-date conditions in \nthe water bodies in question. However, water quality conditions can \nrarely be known at all times and at all water body locations. If the \nsection 303(d) process is to be consistent, a methodology is needed to \nassess the validity of the water quality data. Information submitted to \nRWQCBs and SWRCB is often qualitative (i.e., verbal, anecdotal, \nphotographic, or otherwise non-numeric). When quantitative data is \nsubmitted (i.e., samples of water column chemistry, bacterial colony \ncounts, concentrations of pollutants in sediment, and chemical \nconcentration in fish tissue, etc.), it often needs to be appropriately \nsummarized and assessed to reach accurate listing decisions. \nTo help resolve these concerns, scientists commonly rely on careful \nsampling methodologies and statistical test procedures to help ensure that \ndecisions made, based on inferences from sampled data, are as error-free \nas possible. Proper statistical procedure is intended to help answer the \nquestion: Does a water quality sample accurately reflect actual conditions \nin the water body? \nStatistics helps raise confidence in decisions that are based on limited \ninformation. Statistical tools can assist in the handling and processing of \nnumeric information that might otherwise be confusing, or at times \ncontradictory, leading to clear, meaningful, and defensible conclusions \nabout actual conditions in the water body. \nSection 303(d) listing decisions can be made with or without reliance on \nstatistical assessments of sampled data. However, the lack of statistical \nassessment on numeric water quality data could affect the confidence in \nand reliability of section 303(d) listing decisions. \nRelationship between water quality standards and statistics \nConcern has been raised that statistical analysis of water quality data will \nresult in an inappropriate revision of existing water quality objectives or \ncriteria. This concern was addressed by USEPA in its Consolidated \nAssessment and Listing Methodology (CALM) guidance (USEPA, \n. 2002a). The following briefly describes the relationship between existing \nwater quality standards and statistical analysis of data to assess \ncompliance with standards. Water quality criteria and objectives apply to water segments in their \nentirety-to every portion of a water body. USEPA has described these \ntypes of criteria as \"ideal standards\" (USEPA, 2002a). Ideal standards \ninclude USEPA acute and chronic chemical criteria or criteria set as \nmaximum levels not to be exceeded. Ideal standards rarely address \nvariation or uncertainty; therefore assessment of attainment implies that \navailable monitoring data provides a perfect understanding of chemical \nconcentration throughout the population (i.e., at all points in the water \nsegment and at all times). \nWater quality monitoring programs are not capable of monitoring all \npoints in a water segment and at all times. Consequently, monitoring \nprograms collect samples in water segments to determine attainment with \nwater quality standards. Sampling water segments requires that scientists \nestimate the characteristics of water segments based on the characteristics \nobserved in the water samples. Unfortunately, sample characteristics are \nnot always identical to characteristics in the entire water body. \nAdditionally, sampling introduces inherent bias from the sampler. For \nthese reasons, sampling introduces variability, uncertainty, and the \npotential for error. \nStatistical analysis provides the means to produce a quantifiable level of \nconfidence that a water body achieves or does not achieve a water quality \nstandard. Statistical tests assess with known certainty whether ideal \nstandards are attained or not attained. With respect to the section 303(d) \nlist, the end product of statistical testing is the number of samples, \nrepresentative of the water body being sampled, that exceed the water \nquality standard out of all samples available. \nWater quality standards themselves are not changed by statistical analysis. \nStatistics test the validity of the sample and provides the numerical means \nto verify compliance based on imperfect and randomly variable sampling \ndata. Further, the use of statistics, as described in the proposed Policy, is \nto be used only for the purpose of developing the section 303(d) list. If \nstandards were changed by the use of statistical analysis then the standards \nwould be different for all purposes (i.e., development of effluent limits, \nenforcement, etc.). The use of statistics to assist in the development of the \nsection 303(d) list does not change the calculation of effluent limits \nderived from water quality objectives or criteria nor does section 303(d) \nstatistical analysis change the level of enforcement of water quality \nstandards. \nIf a State's listing methodology is inconsistent with existing water quality \nstandards, USEPA is compelled by CWA to disapprove the State- \nsubmitted section 303(d) list and make its own listing decision. A \nchallenge to one state's listing process based on statistical analysis has been found to neither formally nor in effect establish new or modified \nexisting water quality standards or policies generally affecting those water \nquality standards (Florida Public Interest Group et al. vs. USEPA et al., \n2003). \nBaseline: \t During prior section 303(d) listingdelisting activities, RWQCBs gathered \nand received numeric information but little or no statistical validation of \ndata was employed by any RWQCB in making recommendations to the \nSWRCB. \nAlternatives: 1. Do not reauire that information gathered or submitted in support of section \n303(d) listineldelisting activities be evaluated with statistical vrocedures. \nThis alternative provides the RWQCBs the greatest flexibility, possibly \nleading to listingdelisting recommendations lacking statistical or other \nverification. If statistics were used without guidance from the Policy, \nstatistical methodology could vary significantly from region-to-region. \nRWQCBs might choose to forego statistical analysis. \nThe advantage to this alternative is that it gives the RWQCBs the least \nregulatory constraints and would not increase the RWQCBs workload. \nRWQCB staff could rely on BPJ in reaching conclusions based on \nnumeric information. \nA disadvantage to this alternative is the chance that water bodies may be \nlisted or delisted erroneously increases. At the very least, it would be \nimpossible to predict listing decisions with a given dataset and to \nunderstand and quantify decision error. Inconsistencies in section 303(d) \nlist decision-making would continue among the RWQCBs, and SWRCB \nwould have difficulty justifying and defending final listingldelisting \ndecisions. \n2. Reauire that information gathered or submitted in support of \nsection 303(d) listinddelistine activities be evaluated with statistical \nprocedures. This alternative would require that the RWQCBs base \nsection 303(d) recommendations on valid statistical procedures for \nanalysis of numeric water quality data. An appropriate statistical \nprocedure would be presented in the Policy and proposed for use in \nsection 303(d) listing recommendations. Appropriate scientific/statistical \nmethodologies would be followed and guidelines recommended for \nestablishing hypotheses to be tested, sampling design, numeric analyses, \nand statistical testing. \nThis alternative is the preferred alternative because this alternative would \nincrease confidence in section 303(d) decision making, allow \nquantification in the level of assurance (i.e., that decisions are correct), \nincrease decision predictability, and follow standard scientific protocols for decision-making based on numeric information. The disadvantage of \nthis alternative is that it would require additional effort by RWQCB and \nSWRCB staff in evaluating information. \nRecommendation: Alternative 2. See Policy sections 3 and 4. \nThe following sub-issues 6A though 6E describe various considerations \nand provide recommendations necessarv to develop a consistent \nstaniardized set of tools and principles ihat can behsed across the Regions \nto evaluate numeric data. Each of the sub-issues assumes the \nrecommendation of this issue. Issue 6A: \t Selection of Hypotheses to Test \nIssue: \t Which preliminary hypothesis should be tested in order to determine \nwhether a water body should be placed on the section 303(d) list? What \nhypothesis should be tested to remove the water body from the list? \nIssue Description: \t Hypothesis testing evaluates individual hypotheses about the population \n(i.e.. water bodv or segment) and eliminates those that do not pass . . \t -\nstatistical muster, until one hypothesis appears to satisfy the ficts (based \non sampling data) and, therefore, can be rejected. In statistics and in \nscience in general, likely hypotheses are never proven; they are simply not \nrejected and stand until, possibly another hypothesis takes its place. \nHypothesis testing begins by selecting a null hypothesis (Ho). The null \nhypothesis assumes that the testable statement (based on sampling data) \nwill be \"no different\" from (or less than or equal to) some particular value \nor range of values. If the null hypothesis cannot be rejected based on \nstatistical tests performed on sample data, information about the \npopulation as a whole can be inferred with a certain degree of confidence. \nIf, on the other hand, the null hypothesis is rejected (i.e., found likely to be \nfalse), then an alternative or alternate hypothesis (Ha) must be considered. \nMore complete and technical descriptions of statistics and hypothesis \ntesting are presented in USEPA (2000a, 2000b) and CALM (USEPA, \n2002a). \nIn analyzing many experimental and field sampling situations, a number \nof null and alternative hypotheses may be possible. However, for \nsection 303(d) listing anddelisting, only two general premises need to be \nconsidered: \n1. The water body in question achieves water quality standards. \n2. The water body does achieve water quality standards. \nThe critical question for section 303(d) listing activities is which form of \nthe two hypotheses should be used as the null hypothesis? \nConsidering Errors in Hypothesis Testing \nThe choice of null hypothesis is important because the form of the initial \nassumption to be tested determines which of two types of statistical error \ncan be most easily controlled. One type of error takes place when a water \nMore precise forms of these two alternative hypotheses are: 0 <k, and f3> k, where 0 represents a (population) \npollutant parameter of concern (e.g., [dissolved copper]) and k is an applicable water quality criterion (for those \ncriteria that are upper boundaries). body is incorrectly listed (or delisted); the other, when a water is \nerroneously not listed (or not delisted). \nDecision error may occur when an incorrect conclusion is reached about \nthe total population (i.e., water body or segment) because the collected \nsample data, by chance, has been misleading or unreliable. For example, \nwhen sampled data for a particular water body is analyzed to determine if \nbeneficial uses are impaired, the assumption of the initial (null) hypothesis \nto be tested is: The water body &meeting water quality standards. If this \nhypothesis is indeed correct (i.e., the water body is not impacted) and the \nstatistical analysis leads to that conclusion, then a correct decision to not \nreject the null hypothesis will be made. Therefore, beneficial uses are not \nimpaired and the water body will not be recommended for placement on \nthe section 303(d) list. \nOn the other hand, the samples, by chance, can indicate a greater degree of \nimpairment in the particular samples than actually occurs across the water \nbody as a whole. In that case, the samples would not represent the hue \npopulation and, an erroneous conclusion would be made that the water \nsegment as a whole does not meet water quality standards. Following \nproper statistical procedures, the null hypothesis would be rejected and the \nwater would mistakenly be recommended for placement on the \nsection 303(d) list. This is an example of a Type Ierror, incorrectly \nrejecting a true null hypothesis (Figure 14). \nHowever, if the null hypothesis is false (i.e., the water & impacted) an \nerror can still be made if the non-representative sample data, by chance, \nsuggests that the water body is not polluted although as a whole it really \nis. This is called a Type I1 error (failing to reject an untrue null \nhypothesis). \nIn similar fashion, if the null hypothesis states the water body is \nmeeting water quality standards (i.e., it is assumed from the start to be \npolluted), unreliable data can again lead to either a Type I or Type I1 error \n(refer again to Figure 14). In those cases, the form of the starting premise \n(null hypothesis) is the opposite of what it was in the first example; \ntherefore, the precise forms of the Types I and I1 error will likewise be \nreversed. Reality \nDecision Hois True Hois False \nReject & Type 1 (false Correct \npositive) Error Decision \nDo not reject Ho \nCorrect Type 11(false \nDecision negative) Error \nImportance of the Form of the Null Hypothesis \nThe null hypothesis, H,, represents an assumption that has been put \nforward, either because it is believed to be true or because it is to be used \nas a basis for argument, but has not been proved. Once data have been \nanalyzed in an attempt to reject a null hypothesis, the null hypothesis is \nrejected only if the evidence against it is suffitiently strong. The \nalternative hypothesis, Ha,on the other hand, is a statement of what a \nstatistical hypothesis test is set up to establish. \nIf it is concluded that the null hypothesis cannot be rejected, it does not \nmean that the null hypothesis is true, it only suggests that there is not \nsufficient evidence against H, in favor of Ha. \nThe form of the null hypothesis is important for at least two reasons, \nrelating to the two types of error. The first reason is ability to limit, and \nhence control, Type I error. Most basic statistical tests o& allow direct \ncontrol (i.e., limitation) over Type I error rates. The form of the Type I \nerror depends directly on the form of the null hypothesis. \nStatistical tests are designed apriori to allow the maximum Type I error to \nbe directly chosen, and hence controlled. For example, if a Type I error \nrate is desired no more than 10 percent of the time (i.e., sampling data are \ncorrect 90 percent of the time), the statistical test calculations can be directly manipulated to achieve that goal (or at least approach it as \nmathematically close as a particular sample size will allow). \nType I1 error rates, on the other hand, cannot be so easily controlled within \nmost statistical tests. Type I1 errors are lowered (controlled) most \neffectively by increasing sample size, increasing the size of the effect, or \ndecreasing the overall rangeldistribution of sample values. Fortunately, \nwhen only two opposing hypotheses are being considered, Type I and \nType I1 errors change places depending on which hypothesis is chosen to \nbe the null hypothesis. \nBaseline: \t No hypothesis testing or choice of null hypothesis was performed by the \nRWQCBs on previous section 303(d)-related data. \nAlternatives: 1. The form of the null hypothesis is: the water segment meets water auality \nstandards. To place waters on the section 303(d) list, the form of the null \nhypothesis and alternate hypothesis would be: \nHo: The water segment meets water quality standards. \nHa: The water segment does meet water quality standards. \nTo remove waters from the section 303(d) list, the two hypotheses would \nbe reversed: \nHo: The water segment does not meet water quality standards. \nHa: The water segment does meet water quality standards. \nFor listing, if &is rejected then the evidence is considered to be \nsufficiently strong to say the water body does not meet water quality \nstandards. Only waters where it is demonstrated that standards are not met \nwould be placed on the section 303(d) list. For this alternative, a Type I \nerror would be to erroneously list a \"clean\" water body. A Type I1 error \nwould be to fail to list a water segment with a real water quality problem. \nThe water segments placed on the section 303(d) list would be those water \nbodies where there is sufficient information to reject the null hypothesis \nand accept the alternate hypothesis. \nWith most statistical tests, this form of null hypothesis would result in \ngreater control over the potential (Type I) error of inadvertently listing a \nwater segment that should not be listed because there is not a real water \nquality problem. With this form of null hypothesis, the error of failing to \nidentify and list a truly polluted water body is a Type I1 error. Direct \ncontrol of Type I1 error is difficult to achieve unless the amount of \nevidence is increased (i.e., more samples taken), Type I errors are \nincreased, the effect size (or critical exceedance rate) is increased, or \npollution levels are lowered (USEPA, 2002a). A disadvantage of this null \n hypothesis is that there may be reduced incentives to increase sample sizes \nbecause more data may indicate that water quality standards are not being \nmet and the water should be listed. \nTo mitigate which error should be controlled, statistical errors could be \nbalanced so the tests performed would control both types of statistical \nerror (Smith et al., 2001; Commenter 51). Taking a balanced error \napproach would protect against the error of incorrectly adding water \nbodies to the section 303(d) list and would protect against the unnecessary \nexpenditure of funds developing TMDLs when the water segment does not \nhave a water quality problem. At the same time, an error balancing \napproach would guard against missing real water quality problems that \nmight go undetected. \nWith an error balancing approach, direct control of Type I1 error would be \naddressed by taking into account the amount of evidence available and the \neffect size (USEPA, 2002a). If errors are balanced in this way, this \nalternative may increase incentives to increase sample sizes because the \ncollection of more data may increase the possibility that waters would be \nremoved from the list. \nThis alternative is the preferred alternative because it would give SWRCB \nand the RWQCBs the greatest control over the error of incorrectly adding \nwater bodies to the section 303(d) list and, therefore, helps protect against \nthe unnecessary expenditure of funds developing TMDLs when the water \nsegment does not have a water quality problem. \n2. The form of the null hvvothesis is: The water segment does not meet water \naualitv standards. To place waters on the section 303(d) list, the form of \nthe null and alternate hypothesis would be: \nHo: The water segment does not meet water quality standards. \nHa: The water segment meets water quality standards. \nTo remove waters from the section 303(d) list, the hypotheses would be: \nHo: The water segment does not meet water quality standards. \nHa: The water segment meets water quality standards. \nFor listing, if H, is rejected then the evidence is sufficiently strong to say \nthe water body meets water quality standards. The section 303(d) list \nwould include all the waters where Ho is not rejected. Using this form of \nthe null hypothesis, a Type I error would be failing to list a polluted water \nbody. A Type I1 error would be incorrectly listing a non-polluted water \nbody. Under this alternative, the RWQCBs and SWRCB would again have direct \ncontrol over Type I error; but in this case, Type I error would be the \nlikelihood of failing to list a water body that should be identified as \nimpacted. As a result, this alternative is conservative in the sense that the \nbaseline condition (the water body does not meet water quality standards) \nbecomes the de facto decision when there is insufficient evidence to refute \nit (USEPA, 2000b). Consequently, while waters that do not meet \nstandards would be placed on the section 303(d) list, the potential to place \nwaters on the list with inconclusive data would be great. If the null \nhypothesis is rejected, the accepted alternate hypothesis represents those \nwaters that meet water quality standards. \nThis alternative gives the SWRCB and the RWQCBs the greatest control \nover the error of incorrectly missing water segments that should be on the \nsection 303(d) list. Using this form of the null hypothesis controls the \nerror of not identifying real water quality problems that can have impacts \non aquatic life or human health. In addition, this alternative may \nencourage additional monitoring (USEPA, 2003b). \nA disadvantage of this alternative is that TMDLs would likely be required \nfor waters where they are not needed. However, if statistical errors are \nbalanced, as described in Alternative 1, these problems would be mitigated \nand the difference between Alternative 1 and this alternative would be \nreduced (Smith et al., 2001). \nRecommendation: Alternatives 1. See Policy sections 3 and 4. Issue 6B: Choice of Statistical Tests for the Evaluation of Water Quality Data \nIssue: Based on the need to use statistical analysis to help develop the \nsection 303(d) list and selection of an initial null hypothesis to anchor \nthose analyses, what statistical test(s) should be used to evaluate water \nquality sample data? \nIssue Description: A number of statistical tests can be used to evaluate water quality sample \ndata and assess compliance with water quality standards. All of these tests \nhave their strengths and weaknesses. For the purpose of assessment of \nstandards attainment a statistical test used to analyze water quality data \nshould have as many of the following desirable traits as possible: \nt \nt \nt \nt \nt \nt Accurate with relatively small sample sizes. \nEasy to calculate. \nEasy to understand and interpret. \nRelevant and applicable to data from different types of distributions. \nAccurately handles the characteristics of water quality data. In \nparticular, deals successfully with magnitude, frequency, and spatial \nand temporal variations in water quality values. \nApplicable to water quality objectives, water quality criteria, and the \narray of evaluation guidelines that may be available. \nDescriptions of statistical concepts that may assist in understanding \nstatistical analysis of data have been summarized by USEPA (2000a, \n2000b, and 2002a). \nBaseline: In previous section 303(d) listing processes, RWQCBs performed little or \nno statistical or quantitative analyses on water quality data. In the \ndevelopment of the 2002 section 303(d) list, most RWQCBs and SWRCB \nused the USEPA raw score approach. \nAlternatives: . Ten alternatives are presented in this issue paper. For convenience, brief \nsummaries of the statistical tests are presented in Table 13. The table \nincludes the statistical test, the test's major assumptions, major limitations, \nand reference. TABLE 13: COMPARISON AND QUANTITATIVE FOR OF STATISTICAL TESTS AVAILABLE \nSECTION 303(D) ANALYSES \nStatistical Test Assumptions \t Disadvantages Reference \n1. \tUSEPA \"Raw Random sampling High Type I error USEPA, 1997c \nScore\" Method Independent sampling \n2. \tOne Sample Random sample Greatly influenced by outliers USEPA, 2000a; \nStudent's t-test Independence of data values Difficulty using \"less-than\" USEPA, 2002a \nfor the Mean Data approximately normally data (i.e., values below the \ndistributed \t detection limit) \n3. \tWilcoxon Random sample Repeated data values produce USEPA, 2000a; \nSigned Rank Independence of data values misleading result USEPA, 2002a \n(One-Sample) Data symmetric continuous \nTest for the distribution \nMean \n4. \tThe Chen Test Random sample Difticulty using \"less-than\" USEPA, 2000a; \n(Modified One- Independence of data values values USEPA, 2002a \nSample t-test Data are from a skewed data \nfor the Mean) set \n5. \tOne-sample Random sample Difticult to use with small USEPA, 2000a \nProportion Test Independence of data values sample sizes \n6. \tPercent Lower Random sample Influenced by outliers Gibbons, 2001 \nConfidence Independence of data values Difficulty using \"less-than\" \nLimits Data approximately normally data \ndistributed or lognormally Not widely used \ndistributed \n7. \tExact Binomial Random sample Does not consider absolute USEPA, 2002a; \nTest (Fixed Independence of data values data magnitude Lin et al., 2000 \nSignificance Data is dichotomous (only two High Type I1 error (N<20) \nLevel) possible answers) Loss of information (raw \n~xceedance probability , values changed to nominal \nremains constant [\"yes\"/\"now] information) \nPopulation of samples is \ninfinite \n8. \tExact Binomial Same as for the Exact Does not consider absolute USEPA, 2002a; \nTest (Balanced Binomial Test (Fixed data magnitude Smith et al., \nAlpha and Beta Significance Level) Error rates can be balanced at 2002; Gibra, \nErrors)- any desired level 1973 \nAcceptance Loss of information (raw \nSampling by values changed to nominal \nAttributes [\"yes\"/\"nov] information) Statistical Test Assumptions \t Disadvantages Reference \n9. Bayesian Same as for Exact Binomial Prior information about likely Smith et al., \nVersion of Test violation rates required. 2001; Ye and \nBinomial Test; Same as for other parametric DifficulWcomplex calculations Smith, 2002 \nBayesian Test tests assuming the nonnal \nusing a normal distribution \ndistribution \n10. Exact \t Random sample Does not consider absolute USEPA, 2002a \nHypergeometric Independence of data values data magnitude \nTest Data is dichotomous Limited to use when samples \nExceedance probability are made from finite \nremains constant populations \nPopulation of samples is finite \n1. Use of the USEPA \"Raw Score\" Method. This procedure involves \nevaluation of data collected from a water segment for constituents of \nconcern and comparing results against applicable criteria. The test \nstatistic is the number of sample results that are greater than an applicable \ncriterion in some critical percentage of the samples (USEPA, 1997~). This \ncritical exceedance rate has traditionally been established based on \nUSEPA guidance [e.g., 10 percent exceedance rate for conventional \npollutants (USEPA, 1997~); <25 percent depending on the pollutant \n(SWRCB, 2003a)l. Under this procedure, if more than the critical \npercentage of samples exceeds the standard, the water body is deemed \nto meet water quality standards for that pollutant and the water body in \nquestion is placed or remains on the section 303(d) list. \nThis is a rigid and absolute test: gexceedance above the critical \nexceedance percentage is cause for listing, whether values come from a \nsmall or large sample. The approach also does not consider the absolute \nmagnitude of the measurements being assessed. Since sample sizes are \nrarely multiples of ten, actual sample ratios must be rounded off. \nThe disadvantages of this type of test is that the associated Type I error \nrate is high in comparison with certain other types of tests (e.g., the exact \nbinomial; see Issue 6D). As Figure 15 shows, with the cut-off exceedance \nrate set at ten percent, the Raw Score Approach results in no less than a \n20 percent Type I error rate (Smith et al., 2001). Usually the rates are \nmuch higher (e.g., to 60%) and these error rates are not reduced by larger \nsample sizes. If Type I error is of concern this test results in unacceptably \nhigh false positive error rates. \nThe advantages of this approach are that it is very simple to calculate and \nunderstand; the chance of making a Type I1 (false negative) error is significantly lower than for some other tests (Figure 16). The lower \nType I1 error is at the expense of high Type I error (listing when a problem \ndoes not exist). Using this test, it is less likely to fail to reject a false null \nhypothesis. \nThe Raw Score Approach does not explicitly manage error rates and it has \nbeen suggested that the approach be replaced with other statistical \napproaches (Smith et al., 2001). USEPA does not recommend this \napproach in the CALM Guidance (USEPA, 2002a) but does recommend \nits use in limited circumstances in guidance for developing the 2004 \nsection 303(d) list (USEPA, 2003b). \n2. One-Sample t-Test. Student's t-Test is a parametric test with'the primary \nassumptions being random, independent sampling and approximate \nnormality of the data (USEPA, 2000a). It is frequently used to compare \nmeans from two samples. However, a variation may be used to compare a \nmean from one sample to a set criterion. In this case, the mean (or \narithmetic \"average\") of sample values is compared to a regulatory \nthreshold value. If the sample mean were equal to or below the critical \nvalue, an action (e.g., listing) would not take place. If the mean were \nfound to be above the action level, the water body would be listed. \nSample data are used to calculate the sample mean and standard deviation. \nA \"t\" statistic is then calculated and compared to a tabular value for the \ncorrect sample size. The tabular results tell whether or not to reject the \nnull hypothesis (i.e., that as a whole the sample is significantly different- \nbelow or above-a critical value). \nThis test and its results are well understood and relatively easy to calculate \nand interpret. It is \"robust\" against moderate deviations from normality. \nAs for most statistical tests, larger sample sizes improve this test's \nreliability and like other tests related mathematically to the mean, \nvariance, and standard deviation, this test is sensitive to outlier values. \nBecause the mean is greatly influenced by outliers, this may not always be \na reliable statistic. All alternatives dealing with the mean have similar \ndisadvantages, related to limitations of dealing with a measure of central \ntendency. All measures of central tendency may not be informative of the \nrange and distribution of the sample. These estimators (sample statistics) \nare helpful primarily when the sample distribution is symmetrical and not \nsubject to significant outliers. \nAlso, the t-test does not deal reliably with sample values below the \ndetection limit. Although the test operates reasonably well with non- \nnormal data, as for all parametric tests the normality of the sample data \nshould be assessed. Confirming assumptions of this test would add \nanother step to the section 303(d) analytical process and require increased workloads for RWQCBs. Although recommended by USEPA, it is \nunknown if any state uses this statistical test in the section 303(d) listing \nand delisting processes. \n3. One-Sam~le Wilcoxon Simed Rank Test. Using this nonparametric test, \nraw data values are transformed into ranks and can be used to test \nhypotheses about the mean or median of a population (USEPA, 2000a, \n2002a). The sample data are not assumed to be from a normal distribution. \nTo use this test, sample data are assumed to have been collected randomly \nfrom a symmetric continuous population of values. A detailed explanation \nof the test and an example calculation using the method is presented by \nUSEPA (2000a, 2002a). Although recommended by USEPA, it is \nunknown if any state uses this statistical test in the section 303(d) listing \nand delisting processes. \nSymmetry is an important assumption, and should be satisfied for this test \nto work properly. If sample values do not give a symmetrical frequency \ndistribution, which may happen frequently with water quality data, then \nthis test may be inappropriate. The t-Test is more resistant to inaccuracies \ndue to deviations from its assumptions then is this nonparametric test. \nReliability of the test is reduced if there are ties in the results or if there are \nvalues below quantitation. \n4. Chen Test. This is a derivation of the t-Test designed to compare the \nsample mean against a critical value when data is \"skewed;\" i.e., most \nvalues are small but a few large outliers are contained in the sample \n(USEPA, 2000a). The null hypothesis should be that the sample mean is \nless than or equal to the critical value. The alternative hypothesis is then \nthat the sample mean is greater than the critical value. A detailed \nexplanation of the test and an example calculation using the method is \npresented by USEPA (2000a, 2002a). No state uses this statistical test in \nthe section 303(d) listing and delisting processes. \nThis test assumes a \"right-hand\" skewed sample distribution (with a long, \nright \"tail\") and randomly sampled values. Skewness can be calculated to \nconfirm that this test is applicable. \nIf sampled water quality data is skewed, this test is more reliable andlor \nappropriate than other tests of the sample mean discussed above. Under \nthe proper conditions, it is not particularly Type I or Type I1 error prone. \nConfirming ':skewnessw in non-obvious cases would require additional \ndata analysis. If the data is not skewed, then other tests are more \nappropriate. Similar to the t-Test, the Chen test has problems dealing with \nnon-detected sample findings. 5. One-samvle Provortion Test (Z-test). This test addresses proportions or \npercentiles above or below a critical value (USEPA, 2000a) and is used to \ntest either the hypothesis that the proportion of sample values is equal to \nor less than some critical proportion, or that it is greater than that critical \nvalue. A detailed explanation of the test and an example calculation using \nthe method is presented by USEPA (2000a. 2002a). It is unknown if any \nstate uses this statistical test in the section 303(d) listing and delisting \nprocesses. \nThe Z-test assumes randomly collected sample data. It is equivalent to the \nSign Test for the median when proportions are equal to 50 percent. This \ntest is valid for data from any underlying distribution. The only \nassumption is for random sampling. This test remains accurate even when \nnon-erroneous outliers are present. \nThe major disadvantage is that the test cannot be performed easily using \nsmall sample sizes. In order to perform this test easily, both sample size \ntimes the proportion of non-exceedances and sample size times the \nproportion of exceedances must be greater than or equal to five. For \nexample, if the critical exceedance rate is ten percent, sample size must be \ngreater than 50. For smaller sample populations, calculations are \ncomplex. \nIn general, calculations for this test are more complicated than the exact \nbinomial test. \n6. Percent Lower Confidence Limit on the Percentile of the Pollutant \nConcentration. A statistical approach has been proposed to identify waters \nthat do not meet standards using the percent lower confidence limit on an \nupper percentile of the pollutant concentration to determine if the water \nquality standard is exceeded (Gibbons, 2001). Calculations of confidence \nintervals allows creation, based on sample data, of an interval that either \ndoes or does not encompass some critical value (i.e., the pertinent water \nquality standard). The results allow workers to be confident that the true \n(water segment) exceedance probability falls in an interval calculated from \nthe sample data. From these results, investigators can determine whether \nto list or not list a water body. \nIf performed correctly, the results should be identical to those from \nhypothesis testing. Lower one-sided confidence limit testing is the same \nas testing the null hypothesis that a water body meets water quality \nstandards. The approach proposed by Gibbons (2001) could be used to \nderive normal, lognormal, and nonparametric lower confidence limits. As \nwith other tests, the tests are sensitive to distribution, independence, and \nrandomness assumptions. Advantages of the method include: (1) appropriate for a variety of \ndifferent concentration distributions (i.e., normal, lognormal, \nnonparametric), (2) directly incorporates the magnitude of the measured \nconcentrations in the test of the hypothesis that a percentage of the true \nconcentration distribution exceeds the standard, and (3) explicit statistical \npower characteristics that describe the probability of detecting a true \nexceedance, conditional on the number of samples, the concentration \ndistribution, and the magnitude of the exceedance. \nThis nonparametric approach is used by the State of Nebraska for listing \ndecisions and the parametric tests are used for setting priorities on water \nsegments (~ansas-~e~artment of Health and ~nvironient, 2002). \n7. \tExact Binomial Test (Fixed Significance Level). The Exact Binomial Test \nis intended to be used for analyzing dichotomous data, which is \nappropriate for assessing compliance with water quality standards \n(USEPA, 2002a; Lin et al., 2000; Smith et al., 2001). For binomial \nanalysis of data related to section 303(d) listings, raw numeric data must \nbe transformed into nominal (\"named\") information; specifically \"yes\" the \ndata point attains the water quality objective or criterion or \"no\" it does \nnot. A detailed explanation of the test and an example calculation using \nthe method is presented by USEPA (2000b, 2002a). \nProcedure for Listing with a Fixed Significance Level \nThe exact binomial test is based on a default assumption that the true, but \nunknown, exceedance rate, r, is less than or equal to the regulatory \nexceedance rate, rl. The tested one-sided hypotheses are the null \nhypothesis, H,: r <rl, versus the alternate hypothesis, Ha: r >rl. \nTo find the minimum number of measured exceedances to place waters on \nthe section 303(d) list (klist), let klist = 0 initially. Then calculate a (for a \ndiscussion of alpha and beta, see Issue 6D) from the probability (P) of the \ncumulative binomial distribution: \nN \na =P(k 2klist Ir,,N) = \nWhere ct is Type I error (probability of making false positive errors), \nk is the number of exceedances in a sample, \nklisr is minimum number of exceedances to list, and \nA' is the total number of samples. \nThe cumulative binomial distribution in Equation (1) can also be \ncalculated using the incomplete beta function (Abramowitz and Stegun, 1972)or the Excel@ function BINOMDIST() that returns the binomial \nprobabilities as follows: \na=~(r,,k1ist.N -klist +I) \n= BINOMDIST(N-klist, N, 1-rl, TRUE) \nThe incomplete beta (I) and Excel@ functions are provided (here and \nelsewhere in this issue paper) so these values may be confinned using \nreadily available programs. The incomplete beta and BINOMDISTO \nfunctions are used to calculate the cumulative binomial distribution. \nIf a is greater than the desired significance level then add one to klist and \nrepeat until a is less than or equal to the desired significance level. \nConsequently, klist is a function of three input values: N, rl, and the \nsignificance level. \nUnder the null hypothesis, the expected number (i.e., the average value) of \nexceedances is the product rlN. If observed exceedance k equals or \nexceeds klist, the null hypothesis is rejected. The logical outcome of \nrejecting the null hypothesis is that the water body is not meeting water \nquality standards and should be placed on the section 303(d) list. \nProcedure for Delisting with a Fixed Significance Level \nA \"reversed\" null hypothesis is used for delisting a water body. The \ndefault assumption is that the true, but unknown, exceedance rate, rl, is \ngreater than or equal to the regulatory exceedance rate, H,: r> rl, versus \nthe alternate hypothesis, Ha: r < rl. \nTo find the maximum number of measured exceedances to remove a water \nfrom the section 303(d) list (kdelist), let kdelist = 0initially. Then \ncalculate a from the probability of the cumulative binomial distribution: \na = P(k 2kdelist I r,, N) = x N! \n= BINOMDIST(kdelist, N, rl, TRUE) \nIf a is less than the desired significance level then add one to kdelist and \nrepeat until a is less than or equal to the desired significance level. The null hypothesis is rejected if k 5kdelist, and the water body is considered \nto meet water quality standards and removed from the section 303(d) list. \nNote that for delisting with small sample sizes, amay be larger than the \ndesired significance level even when kdelist = 0. The minimum sample \nsize required for delisting is equivalent to the sample size required for an \nupper one-sided non-parametric tolerance limit (Owen, 1962): \nIn practice, N is rounded up to the nearest integer. For example, using a \nnominal significance level of 0.1 and an exceedance rate of 0.1 the \nminimum sample size required is ln(O.l)/ln(l-0.1) =21.9. Rounded up, a \nminimum of 22 samples would be required for delisting. \nAnother Excel@ function CRITBINOM() can be used to calculate klist or \nkdelist if the significance level is fixed. This procedure is described more \nfully in the draft FED (SWRCB, 2003~). \nThis statistical procedure is relatively quick and easy, especially because it \nis readily available in EXCEL@ software programs. The binomial test \nprovides a relatively low chance of committing a Type I error (rejecting a \ntrue null hypothesis) (Figure 15). Since section 303(d) listing issues can \nbe boiled down to \"measurements do or do not meet water quality \nstandards\", the use of the binomial test, intended for dichotomous \ninformation, seems appropriate. Many states have used this test, including \nArizona (Arizona DEP, 2000). Florida (Florida DEP, 2002), Nebraska \n(Nebraska DEQ, 2001). Texas (TNRCC, 2002), and Washington \n(Washington Department of Ecology, 2002). \nThis test allows the user the flexibility of choosing (1) the critical \nexceedance rate, (2) the desired statistical \"confidence\" (Type I error rate), \nand (3) the minimum sample size allowed. The binomial test has been \ndescribed as a modest improvement beyond USEPA's raw score method \n(Shabman and Smith, 2000). \nIn binomial testing, specific and sometimes critical information concerned \nwith the absolute magnitude of sample values is not addressed in the test. \nThis could be addressed somewhat in establishing priority for TMDL \ndevelopment by interpreting measurement magnitude as a percentage 0 10 20 30 40 50 60 \nSample size \nFIGURE15: TYPE 1 ERROR BINOMIALTEST RATESFOR EXACT (WITH 10% AND 20% TYPE 1ERROR \nRATESAND 10% EXCEEDANCE AND THE USEPA RAW SCORE FREQUENCY) METHOD \nabove the standard. Another way to address magnitude is to use an \nalternative procedure for listing and delisting using a situation-specific \nweight of evidence approach. \nThe chance of making a Type I1 error (i.e., not rejecting a false null \nhypothesis) is greater using the binomial test than for some bther \nprocedures, especially with samples sizes less than 20 (Figure 16). In \nnonpararnetric statistical procedures in general, there is little control over \nType 11 error rates (USEPA, 2002a). Error rates using this fixed level of \nconfidence is analyzed further in Issue 6D, Alternative 2). 0 10 20 30 40 50 \nSample size \nFIGURE16: TYPE 11 ERROR BINOMIAL RATESFOR EXACT TEST (WITH 10% AND 20% \nTYPE I ERROR RATESAND 10% EXCEEDANCE FREQUENCY) AND THE USEPA RAW SCORE \nMETHOD \n8. Exact Binomial Test (Balanced Alpha and Beta Errors)-Acceptance \nSampling by Attributes. The exact binomial test as described in the \nprevious alternative, like most statistical hypothesis testing procedures, \nwill control the maximum arate at a value below the nominal significance \nlevel for most sample sizes. In contrast, the magnitude of P (beta) \ndepends on several factors, including a,the population variance, the effect \nsize, and sample size. Generally, a varies inversely with P,and control of \np is traditionally sought through the appropriate selection of sample size \n(Gibra, 1973) or through the use of a more powerful statistical test (Helsel \nand Hirsch, 2002). \nThis alternative looks at the possibility of balancing alpha and beta errors. \nOne way to balance errors is to use acceptance sampling by attributes: i.e., \nrandom samples are evaluated to be either above or below the applicable \nwater quality standard using the binomial test (Gibra 1973). A water body \nis listed if the number of exceedances kin N samples equals or exceeds a \ncritical value klist. Likewise, a water body is delisted if k< kdelist in a \nsample of N. This process is called a single acceptance sampling plan \nsince the decision is based on a single sample of size N (Gibra, 1973). Procedure for Listing \nFor listing water bodies, the probability of rejecting the null hypothesis is \ncalculated using the probability of the cumulative binomial distribution \nand selected values of r (i.e., alternate exceedance rates) within the \ninterval [0,1]: \nP(reject H,) =P(k 2klist Iklist, N) \n= BINOMDIST(N-klist, N, I-r, TRUE) \nThis probability equals a when the null hypothesis is true and power (1 -\nD) when the null hypothesis is false. Under the standard hypothesis, ais .- --\n;he probability of incorrectly listing a clean water body while Pis the \nprobability of incorrectly failing to list a contaminated water body. \nThe probability of not rejecting the standard null hypothesis is the \ncomplement of Equation (4): \nP(not reject H,) =1-P(reject H,)=P(k Iklist -11 klist, N) \nkii,,-1 \n= (k!(N\"!-k)!);(l-n'\"-\" \n=1 -klist,N -klist +1) ~(r, \n= BINOMDIST(k1ist-I,N,r, TRUE) \nThis probability equals the confidence coefficient (1-a) when the null \nhypothesis is true and P when the null hypothesis is false. \nUsing the example of N = 25, Figure 17 illustrates these probabilities as a \nfunction of alternate exceedance rates for the standard null hypothesis. \nThis graph simultaneously depicts alpha or power (via Equation 4) and \nconfidence or beta (via Equation 5). The Figure shows the theoretical \nprobability of rejecting the null hypothesis on the vertical axis versus r on \nthe horizontal axis is known as a power curve. The mathematical \ncomplement of a power curve is an operating characteristics (OC) curve. An OC curve is a power curve flipped along the horizontal axis by \nsubtracting the power curve probability from unity. \nProcedure for Delisting \nFor delisting water bodies, the probability of rejecting the reverse null \nhypothesis is calculated using the probability of the cumulative binomial \ndistribution and selected values of rwithin the interval [0,1]: \nP(reject H,) =P(k <kdelist 1 kdelist, N) \nk,f~IiS' N! Irk (l-r)(N-k) \n= & [k!(N -k)! \n=1-I(r,kdelist +1,N -kdelist) \n= BINOMDIST(kdelist, N, r, TRUE) \nAgain, this probability equals a when the null hypothesis is true and \npower (i.e., 1 -p) when the null hypothesis is false. However, under the \nreverse hypothesis the nature of the errors are reversed: ais now the \nprobability of incorrectly failing to list(de1isting) a water body that does \nnot meet standards while Pis the probability of incorrectly listing (not \ndelisting) a water body that does meet standards. \nThe probability of not rejecting the reverse null hypothesis is the \ncomplement of Equation 6: \nP(nor reject H, )=1-P(reject H,) =P(k 2kdelist +1Ikdelist,N) \n=I(r,kdelist+1,N -kdelist) \n= BINOMDIST(N-kdelist-1, N, 1-r, TRUE) \n N = 25,SigLev = 0.1, klist = 5 \nAlternate Exceedance Rate, r \nFIGURE17: PROBABILITIES OFREJECTING (SOLID LINE) AND NOT REJECTING (DASHED LINE) THE \nSTANDARD NULL HYPOTHESIS HO: R <RI = 0.1WHEN USING THE BINOMIAL MODEL. \nAlpha error is the solid line to the left of the vertical dashed line; power is the line to the right. Beta error is the solid \nline to the right of the vertical dashed line; confidence is the line to the left. This graph assumes a sample size of 25, \na significance level of 0.10, and klist = 5. \nThis probability is confidence (1-a)when the null hypothesis is true and P \nwhen the null hypothesis is false. \nAgain, using the example of N = 25, Figure 18illustrates these \nprobabilities as a function of alternate exceedance rates for the standard \nnull hypothesis. N=25,SigLev =0.1,kdelist =0 \n\"8 '>'-I\"\"[\"\",\"\" 8 \n-l' -0.9 \n'I -0.8-1 - I -\n-\n-\n-\n--\n-\n-\nI,,,,I,,,,I,,,, \n0.0 0.1 0.2 0.3 0.4 0.5 \nAlternate Exceedance Rate, r -power /alpha--beta I conf \n'FIGURE OF REJECTING (SOLID LINE) AND NOT REJECTING (DASHED LINE) THE 18:PROBABILITIES \nREVERSE NULL HYPOTHESIS HO:R >R1= 0.1 WHEN USING THE BINOMIAL MODEL. \nAlpha error is the solid line to the right of the vertical dashed line; power is the line to the left. Beta error is the \ndashed line to the left of the vertical dashed line; confidence is the line to the right. This graph assumes a sample \nsize of 25, a significance level of 0.10, and kdelist =0. \nBalancing Errors \nAlternatives to controlling only the a rate are possible (Lehmann, 1958). \nMapstone (1995) argued against adhering to a fixed and arbitrary a, \nadvocating instead for the consideration of economic, environmental, \nsocial, and political consequences of both a and P decision-making errors. \nIn the absence of further information, Mapstone recommended that \ndecision errors should be weighted equally, i.e., a =P. In addition, he \nrecommended that decision-makers define a level of impact essential to \ndetect -an effect size. Furthermore, Mapstone suggested that the effect \nsize is perhaps the most critical aspect of environmental impact decision- making and is a biological (or chemical, physical, aesthetic, economic, \netc.) decision, not simply a statistical decision. This issue is addressed in \nIssue 6C. \nThe effect size is variously called the gray region within the Data Quality \nObjectives (DQO) process (Millard and Neerchal, 2001) or the indzfjerent \nzone (Gibra, 1973) within the acceptance sampling process. For section \n303(d) listing and delisting, the effect size represents the range of true \nexceedance rates where the consequences of decision errors are relatively \nminor. \nUSEPA (2002a) applied the error balancing approach of Smith et al. \n(2001) to the section 303(d) listing process. To balance errors, klist and \nkdelist are determined in a manner different than described in the previous \nalternative (No. 7) (Saiz, 2004). \nBalanced Error Approach for Listing \nFigure 19 is a magnification of the lower portion of Figure 17. \nExamination of Figure 19 reveals that an alternate exceedance rate value \nr2 exists such that a = P. This can be envisioned as a horizontal line \npassing through the a curve and the P curve with vertical lines indicating \nrland rz. In fact, an infinite number of alternate exceedance rate pairs (rl, \nrz) exist that will balance aand P at varying levels for a given N and klist. \nAs the balanced error level decreases the effect size (rz -rl) increases since \nrl must decrease and rz must increase. Holding rl or rzconstant will affect \nthe magnitude of a and P and the degree to which these errors can be \nbalanced. \nThe approach taken by USEPA (2002a) for listing is to first define N, rl, \nand 1-2. Next, klist is determined iteratively as the value that minimizes the \nabsolute difference between a and P. The minimized quantity la -PI can \nbe expressed using Equation (6)for a and Equation (7) for P: \nla -PI = 1 I(r,,klist,~-klist+l) -[I-I(r,,klist,~-klist+l)]l \n(8) \nwhere rl< r2<I. An equivalent procedure is to first define N,rl, and the \neffect size (rz- rl). \nThis minimization calculation is analogous to the minimum squared \ndeviation technique used in statistical curve fitting of data. Errors will \nbalance perfectly when the minimized quantity is zero. However, because \nof the discrete nature of the binomial probability distribution only \napproximate balancing of a and P is possible, especially with smaller \nsample sizes. N = 25,SigLev = 0.1, klist = 5 \n0.10 .................... I........................................ \n0 09 .......................................................... \nI \nI ........................................................... \n.7-\n0.08 \n ..y....................................-\nI2. \n........................0.07-..\n.-.a I ..............................................................\nca 0.06 a- n \n................\n9 0.05 , I \n0- I I 7-\n...-\n ,...... .I \nI ........................................... .......... .\\ \n...;......................................... 1 \nI \\ ...I .................................................. \n ._ \nI \\ -alpha\nIt\"'I\"4'I\" 'I' ;2, , --beta 0.0 0.1 0.2 0.3 0.4 0.5 \nAlternate Exceedance Rate, r \nFIGURE 19: VISUAL REPRESENTATION SIZE (a OFEFFECT = P) \nLowering the balanced error level (vertical lines) increases the effect size (horizontal lines). Three possible \nexceedance rate pair (r,,r2) realizations are shown. This graph assumes a sample size of 25, a significance level of \n0.10, and klist = 5. \nBalanced Error Approach for Delisting \nFor delisting, the USEPA (2002a) approach is to again define N, r,,and rz, \nbut this time rz is a value less than rl. kdelist is determined as the k value \nthat minimizes the absolute difference between a and P. The minimized \nquantity (a-PJcan be expressed using Equation (4) for a and Equation (5) \nfor p: \nla -PI = 1 [I-I(r,.kdelist +1,N -Melist)] -1(r2,Melist +1,N-Me1ist)l \n(9)\nwhere r2 < rl <I. \nThe balanced error approach, is useful because it considers both types of \ndecision-making errors, a and P, rather than only a when analyzing data. Another objective is to maintain these balanced error rates at or below an \nacceptable magnitude. A pre-defined maximum acceptable error for both \naand fi will allow the determination of acceptable sample sizes to use for \nlisting and delisting. This issue is addressed in Issue 6D. \nAs discussed in Alternative 7, specific and sometimes critical information \nconcerned with the absolute magnitude of sample values is not addressed \nin the binomial test. This could be addressed b; allowing a situation- \nspecific weight of evidence approach if the magnitude of measurement \nneeds to be considered. \nAt present, no other state uses this approach for listing or delisting. \nThis alternative is the preferred alternative because the exact binomial test \nis intended to be used for dichotomous data, which is appropriate for \nassessing compliance with water quality standards; by balancing errors, \nthe economic, environmental, social, and political consequences of \nand p decision-making errors are more adequately considered. \n9. Bavesian Procedures for Parametric or Nonparametric Statistical Tests. \nThis procedure is more sophisticated than the previously discussed tests. \nIn the Exact Binomial Test, for example, the chance of exceeding the \nwater quality standard is treated as fixed and the data are regarded as \nrandom. The Bayesian procedure treats the probability of exceeding a \nstandard as a random variable with an associated distribution (Smith et al., \n2001). For section 303(d) listing purposes, some form of prior \ninformation about the water body and its levels of pollutants would be \nrequired in order to choose the initial form of the distribution, called the \nprior distribution. Once new data are obtained, the prior distribution is \nupdated, and the available information is used to compute a resulting \ndistribution of likely standard exceedances (Ye and Smith, 2002). \nThe Bayesian Procedure may require relatively sophisticated analysis and \nstatistical understanding to calculate the test statistics manually. \nThis procedure may work well for small sample sizes. It provides \nflexibility when previous information about the situation being studied is \navailable. Using the parametric test, this model takes magnitude into \naccount and controls much more than, for example, the USEPA raw score \nand exact binomial procedures. Type I and Type I1 error rates are \nintermediate between those for binomial (lowest for Type I; highest for \nType 11) and USEPA raw score (highest for Type I; lowest for Type 11) \nprocedures for samples sizes to 50 (Ye and Smith, 2002). Likewise, if \nmore than one data point is significantly above an objective, with the \nremaining data well below the objective, the water body may still be \nrecommended for listing by the Bayesian procedure. cx This procedure has not been used for listing decisions. Apparently, no \nother states have yet adopted this procedure. One problem is that prior \ninformation is required that may not be available. In some instances it \nmay require data from a normally distributed population. \n10. Hvverrreometric Test. The hypergeometric test is equivalent to the \nbinomial test except that samples are assumed to be from a finite \npopulation and samples are not replaced (Sokal and Rohlf, 1995). Like the \nexact binomial test, this statistical model is also appropriate for binary \nresults (e.g., either \"yes\" or \"no\"). This test has been suggested for use in \ncomparing sample data to standards if standards are assessed on the \nexceedant day basis, like the USEPA acute and chronic criteria (USEPA, \n2002a). It is unknown if any state uses this statistical test in the section \n303(d) listing and delisting processes. \nAssumptions of the exact hypergeometric test, as for the exact binomial \ntest, are that the sample data are binary (only two outcomes possible), the \nchance of an exceedance remains constant, and sampling is independent \nand random. \nThis procedure is most appropriate for sampling with replacement from a \npopulation of finite size but if a small number of samples are taken from \nlarge populations, these populations can be considered essentially infinite \n(Sokal and Rohlf, 1995). As is almost always the case, water quality data \nare sampled from a continuous, infinite population of values (from a lake, \nriver segment, etc.). As the sample size increases, the hypergeometric \nmodel approximates the binomial model (Sokal and Rohlf, 1995). As a \nresult, for the most part, the exact binomial test appears to be more \nappropriate for evaluating water quality sample data. \nRecommendation: Alternative 8. See Policy sections 3,4, and 6.1.5.8. \nGiven the range of data sets that will be reviewed and the types of data \nthat have been reviewed in previous section 303(d) list processes, \nacceptance sampling by attributes (the exact binomial test and error \nbalancing) should be used as the base analysis of data. \nThe use of acceptance sampling by attributes is assumed in the selection of \ncritical exceedance rate (Issue 6C),confidence and power levels (Issue \n6D), and minimum sample size (Issue 6E). Issue 6C: \t Critical Rates of Exceedance of Water Quality Standards \nIssue: \t What is the \"critical rate of exceedance\" of a water quality standard in \neach sample that would trigger the listing of a water body on the \nsection 303(d) list? \nIssue Description: \t In establishing a statistical approach for assessing if water quality \nstandards are exceeded it is important to establish the level or levels of \nstandards exceedance that are acceptable or unacceptable. This critical \nexceedance rate (r) is the estimate of the actual proportion of samples that \nexceed an applicable water quality criterion (\"the proportion of \nexceedances\"). This variable may range from zero (0 percent), i.e., any \nexceedance is justification for listing the water body, to one (100 percent). \nRates from less than 1 percent to as high as 25 percent are discussed in \nTable 14. \nAn r value can also be used as an indication of the persuasiveness of the \nnumber of exceedances in a sample population. If the number of \nexceedances is greater than r, it increases confidence that the water quality \nstandard is exceeded and that the exceedance is not due to uncontrolled \nsampling or analytical errors. Since errors vary from one sample to \nanother, the critical exceedance rate is only an indirect representation of \nthat uncertainty. \nAccording to USEPA (2002a). sources of uncertainty include: (1) natural \nvariation in the population; (2) temporal and spatial variability; \n(3) measurement error; and (4)laboratory (analytical) error. With these \nsources of uncertainty possible, a critical exceedance rate of greater than \nzero is indicated. If a critical exceedance rate cannot be chosen, it is \nvirtually impossible to use any statistical approach. \nImplicit in selecting r is also the selection of a meaningful effect size. \nMapstone (1995) recommended that decision-makers define a level of \nimpact essential to detect -an effect size. Furthermore, Mapstone \nsuggested that the effect size is perhaps the most critical aspect of \nenvironmental impact decision-making and is a biological (or chemical, \nphysical, aesthetic, economic, etc.) decision, not simply a statistical \ndecision. For section 303(d) listing and delisting, the effect size represents \nthe range of true exceedance rates where the consequences of decision \nerrors are considered relatively minor. \nBaseline: \t Previously, RWQCBs used r to judge when a water body was not meeting \nwater quality standards. However, this process was implemented without \nthe use of statistical analysis. Instead, RWQCBs used r values from 10 to \nas high as 95 percent. This resulted in region-to-region inconsistencies in \nthe listing of water bodies. TABLE14: CRITICAL RATESPROPOSED EXCEEDANCE BY USEPA \nCritical Exceedance Source Notes \nRate \n<I-in-3 years - USEPA, 1997c fully supports beneficial uses \nfor acute criteria \n0.09% USEPA, 2002a using hypergeometric distribution \n(1 out of 1,095) equivalent to a 1-in-3 year exceedance \nfrequency \nfor acute criteria \n0.36% USEPA, 2002a using hypergeometric distribution \n(1 out of 274) equivalent to a 1-in-3 year exceedance \nfrequency (4-day averages) \nfor chronic criteria \n>1-in-3 years USEPA, 1997c partially supports beneficial uses \nto <lo% for acute criteria \n5% (plus a 15% effect size) USEPA, 2002a for toxicant criteria, equivalent to a 1-in-3 \nyear exceedance frequency \nUSEPA, 1997c; for bacteria criteria \nUSEPA, 2002a \nUSEPA, 1997c; fully suppor*i beneficial uses \nUSEPA, 2002a for conventional pollutants \nUSEPA, 2003 for chronic criteria \nfor acute criteria (if justified) \nfor conventional pollutants (if justified) \nusing either binomial or \"raw score\" tests \nUSEPA, 1997c for acute criteria \nno support of beneficial uses \nmeasurement error should be accounted for \n>lo% (plus a 15% effect USEPA, 2002a for conventional pollutants \nsize) \n>lo% to <25% USEPA, 1997c partially supports beneficial uses \nUSEPA, 2002a for conventional pollutants \n>25% USEPA, 1997c; for conventional pollutants \nUSEPA, 2002a does support beneficial uses Alternatives: 1. Provide no guidance on the choice of critical exceedance rate to the \nRWOCBs. Under this alternative, the RWQCBs would continue to use \nvarious r values in their analyses of sample data to develop the section \n303(d) list. Values would vary region-by-region, and could even vary \ndecision-by-decision within a single region. \nThe possibility of uncertainty affecting analyses of sampled information \nvaries widely. This alternative provides the maximum level of flexibility \nto RWQCBs for matching r with likely levels of statistical uncertainty. \nUnder this alternative, r may not always match a perceived or anticipated \noverall level of possible error in gathering, analyzing, and reporting \nsample data. Region-by-region listing or delisting inconsistencies would \nnot be addressed under this alternative. \n2. Test water aualitv sample data against a single r of 25 uercent. Under this \nalternative, a 25 percent value would be used in statistical analysis of \nsample data. Therefore, a ratio of exceedances close to 25 percent or more \nwould have to be observed in samples to conclude the water body was \nfailing to meet water quality standards. USEPA has used the 25 percent \ncritical exceedance rate for conventional pollutants (Table 14) as an \nindication that beneficial uses are not supported (USEPA, 1997~). \nHigh exceedance rates would most likely be observed in cases where very \nlarge errors in collection and analysis of data are possible or very large \nnatural variability is found. Unfortunately, exact knowledge of sample \nand laboratory error is rarely known on an individual sample basis. \nMany states use this exceedance rate to determine if water bodies are not \nsupporting beneficial uses for conventional pollutants (Table 15). \n3. Use a single r of 15 Dercent. Under this alternative, it would be assumed \nthat the variability and error associated with sampling and analysis of data \nwould sum to a sample exceedance rate of 15 percent. Therefore, at least \n15 percent of samples observed would exceed the applicable criterion \nbeforeconsidering whether the water body is not meeting standards and \nshould be listed. USEPA (2002a) has recommended a 15 percent effect \nsize when analyzing chemical data. At least one state uses 15 percent in \nanalyzing data for section 303(d) purposes (Table 15). TABLE 15: CRITICAL RATES PREVIOUSLY EXCEEDANCE USED BY SEVERAL STATES \nCritical Exceedance Rate \nUSEPA (1997b) guidance \n10%-bacteria \n4%-bacteria, marine beaches from \nApril 1 through October 31 \n25% or less depending on the \nconventional or toxic pollutant \n85\" percentile-chronic chemical \nstandards \n50\" percentile-iron \n15\" percentile-DO, pH \n10%-water quality criteria \n110/0--~onventional pollutants \n10%-Numeric and narrative water \nquality standards \n10%--chronic standards; bacteria; \nchloride; sulfate; parameters used to \nassess irrigation and livestock \nwatering, food procurement \n2 exceedances in 30-36 samples- \nacute standards \n0%-nitrate drinking water standard \n5O%-other drinking water \nparameters \n2 exceedances in 3 year period- \nToxicity-based standards \n-40%--Conventional pollutants -40%--Fecal coliform \n10% of measurements for acute and \nchronic standards; 25% exceedance \nof acute standards; 1-50% \nexceedance of chronic standards State \nAlabama \nCalifornia \nColorado \nFlorida \nGeorgia \nIdaho \nKansas \nMaryland \nMinnesota \nMontana \nReference \nAlabama Department of \nEnvironmental \nManagement, 2002 \nSWRCB, 2003a \nColorado Water Quality \nControl Division, 2001 \nFlorida Department of \nEnvironmental Protection, \n2002 \nGeorgia Environmental \nProtection Division, 1998; \nas quoted by Community \nWatershed Project \nIdaho Department of \nEnvironmental Quality, \n2003 \nKansas Department of \nHealth and Environment, \n2002 \nMaryland Department of \nthe Environment, 2003 \nMinnesota Pollution \nControl Agency, 2004 \nMontana Department of \nEnvironmental Quality, \n2002 Critical Exceedance Rate \n11% of measurements for . \nconventional pollutants; \n50% exceedance of standard \n>lo%-fecal coliform \n1 1%-water quality criteria \n>lo%-Agricultural water supply \nbeneficial use \n>lo%-bacteria, clarity, \nphosphorus, chlorophyll-a \n>10%4rinking water assessments \n1 1%-DO, pH \n10%-heavy metals, priority \npollutants, chlorine, ammonia \n25%-turbidity, total phosphoms, \ntotal nitrogen, chlorophyll-a \n10%-bacteria, DO, pH \nMinimum of 2 exceedances-toxics \n10%--conventional pollutants, \nmetals and organics (acute and \nchronic criteria \n25%-bacteria (single sample \ncriterion) \n1 lYo--conventional pollutants \n2 exceedances in 3-year period- \ntoxics \nNo more than one exceedance- \nDrinking water \nExceed only once or was not \nexceeded in < 10% of the samples if \nthe criterion was exceeded at least \ntwo times-aquatic life \nExceeded in >40% of the samples -\n-Chronic criteria \nMore than one violation --Acute \ncriteria \n2 or more exceedances in a 3-year \nperiod-toxics \n10% or exceeds geometric mean- \nbacteria \nOne 7-day average exceeds \nstandard-DO, temperature \n10%4issolved gas, pH, nitrogen, \nphosphorus, turbidity, hardness State \nNebraska \nNew York \nNorth Carolina \nOregon \nTexas \nVirginia \nUtah \nWashington Reference \nNebraska Department of \nEnvironmental Quality, \n2001 \nNew York State \nDepartment of \nEnvironmental \nConservation, 2002 \nSouth Carolina \nDepartment of Health and \nEnvironmental Control, \n2002 \nOregon Department of \nEnvironmental Quality, \n2003 Texas Natural Resource \nConservation Commission, \n2002 \nVirginia Department of \nEnvironmental Quality, \n2002 \nUtah Department of \nEnvironmental Quality, \n2004 \nWashington Department of \nEcology, 2002 4. Use a sin~le r of 10 oercent. Past USEPA guidance (USEPA, 1997c; \nUSEPA, 2002a) recommends making non-attainment decisions for \nconventional pollutants where more than 10 percent of samples exceed \napplicable water quality standards. This guidance provides a simple \"rule \nof thumb\" to evaluate data sets of limited size for assessment purposes, to \naccount for measurement error, and the potential that small data sets may \nnot be fully representative of receiving water conditions. \nThis r has traditionally been applied nationally (Table 15) in previous \nlisting cycles, most notably with the USEPA \"raw score\" methodology. \nOther states using a statistical approach (often the exact binomial test) use \nthe 10 percent critical value (e.g., Florida DEP, 2002). \n5. \tUse seoarate r values, as recommended in the CALM Guidance (USEPA, \n2002a). for toxic pollutants and another one for conventional oollutants in \norder to balance decision errors. The Policy would specify separate ranges \nof exceedance frequencies for toxic pollutants and conventional pollutants. \nIn order to avoid conflicting exceedance frequencies for listing and \ndelisting, the r values should be selected carefully. It is possible, and \nundesirable, to assign rl and rz values that would result in conflicting \ndecision rules for listing and delisting. Under such starting values, a set of \nobserved exceedances will exist that simultaneously result in a decision to \nlist under the standard null hypothesis and a decision to delist under the \nreverse null hypothesis for a given N. \nFor example, given N = 25 and for listing rl = 0.10 and rz = 0.25, but for \ndelisting rl = 0.40 and rz = 0.25. Using the balanced error approach leads \nto klist =5 or more exceedances and kdelist = 6 or less exceedances. A \nwater body listed with 5 or 6 exceedances in a sample of 25 could be \nsimultaneously listed and delisted. Generally, the balanced error approach \nshould result in a kdelist value that is at least one exceedance less than \nklisr. \nTo avoid this problem, the following relationship should be established: rl \n(listing) = rz (delisting) rz (listing) =rl (delisting). In this case, the rl \nand rz starting values results in the equality of the minimized error \nquantities. Equating these quantities means that kdelist will always be one \nless than klist. Thus, cx for listing becomes exactly equal to Pfor delisting \nand vise-versa. This reversal and equality of errors for listing and \ndelisting is desirable because conflicting decisions based on which null \nhypothesis is chosen (standard versus reversed) will then be eliminated. \nThe CALM Guidance (2002a) applied the error balancing approach (Smith et al., 2001) to the section 303(d) listing process noting that \nbalanced decision error rates are less affected by switching the null and \nalternative hypothesis. \nEstimating Critical Exceedance Frequencies and Effect Size \nWater quality standards exceedances can be influenced by natural \nvariability (including sample frame selection, sampling unit definition, and \nnumbers of samples), measurement error (including sample collection, \nsample handling, and analysis), and not due to a real violation of the \nstandard. Natural variability can be substantial but is rarely explicitly \nknown. Measurement error is more readily quantified when well-run \nmonitoring programs set limits on the amount of acceptable measurement \nerror. Typical allowable variation for the measurement of conventional \nparameters, metals, and organic chemicals range from 10 to 50 percent \n(e.g., Puckett, 2002; Stephenson et al., 1994), 40 percent for toxicity \nmeasurements (Stephenson et al., 1994), and up to three orders of \nmagnitude for bacteria measurements (Puckett, 2002). These types of \npotential measurement errors introduce doubt into the decision to list \nwaters. \nWhile it cannot be precisely known how much error is included in the \ndecision to list, the decision becomes unclear when the r values and effect \nsize approach acceptable measurement error. Consequently, with a small \nnumber of samples exceeding standards, at some point the decision to list \nbecomes \"too close to call.\" As the r value (the gray area where the \ndecision may be too close to call) decreases, fewer sample exceedances \nare required to place waters on the list. Conversely, for delisting, as r \ndecreases, the number of samples that show standards are met increases. \nThe r values should only be used in statistical analysis after an assessment \nis made of whether each measurement attains or does not attain water \nquality standards. The water quality standard's averaging period (if any) \nshould be addressed in this preliminary step of determining if a single \nsample measurement exceeds the water quality objective or criterion \n(Issue 4A). The r values and effect size should only be applied to \ndetermine the number of samples needed to place waters-on the section \n303(d) list. This value should never be used to assess if the standard is \nmet a percentage of the time because the r value assesses only the strength \nof the decision to list or delist based on the sample population (i.e., grab \nsamples) available. \nIt has been questioned whether a set r (say 10 percent) can be used to \ninterpret water quality objectives expressed as: \"the instantaneous \nconcentration of the pollutant shall not be greater than -pg/L, at any \ntime.\" These types of standards pose several challenges in assessing \nwaters to be placed on the section 303(d) list. It is reasonable to not treat every single sample as representing the true ambient condition of the \nwater segment because an individual sample is not a definitive assessment \nof whether the water segment is attaining applicable water quality \nstandards. It is necessary to account for natural or sampling variability in \nthe assessment because (1) error is introduced into the analysis of samples \nor (2) short-term or sporadic excursions of the water quality standard in \nsome samples does not reflect the best assessment of the true condition of \nthe water segment (USEPA, 2003e). \nIn general, aquatic organisms can tolerate higher concentrations of \npollutants for short periods than they can for complete life cycles \n(USEPA, 1991f). It is debatable whether short-term and sporadic \nexcursions from the water quality standard can occur without resulting in \nnonattainment of the water quality standard. At least one USEPA Region \nhas stated: \n\"[USIEPA's best information at this time is that the extent to which \nsuch a 'true' exceedance could occur without impairing designated uses \ndepends on the nature and toxicity of the pollutant and on the extent to \nwhich the pollutant is naturally variable in the environment without \nimpairing designated uses.\" (USEPA, 2003e) \nIn most Basin Plans, natural or controllable sources of pollution are \nrecognized as contributing to the variability of some pollutants in the \nState's waters. All major federal, State, and local monitoring programs in \nCalifornia recognize the variability inherent in sampling and analysis of \nsamples. Attainment assessments for \"not to be exceeded\" standards do \nnot recognize such variation and uncertainty. Consequently, perfect \nassessment of attainment for a \"not to be exceeded\" standard assumes a \nmonitoring effort that continually measures the water quality objective at \nall points in the water segment. No monitoring efforts measure all points \nat all times; actual monitoring involves sampling the water segment and \nestimating the characteristics of the entire water segment based on the \ncharacteristics of the sample. Therefore, water quality objectives set as \n\"not to be exceeded\" maxima should be subject to statistical analysis that \naccounts for variability. Statistical analysis does not allow for a single \nsample to determine if water quality standards are attained. \nIn these \"not to exceed\" cases, the r value is only used to quantify the \nstrength or persuasiveness of the data used to interpret this type of \nstandard. The r value should not be used to justify allowing the standard \nto be exceeded some percentage of the time,as this would be an \ninappropriate interpretation of the water quality objective. \nFor conventional pollutants (pH, temperature, dissolved oxygen, etc.), \nCALM Guidance (USEPA, 2002a; Table 4-3 in the reference) recommends a statistical guideline of acceptable exceedance frequency of \n10 percent (on average) and unacceptable exceedance frequency of 25 \nin any givensample. This approach includes a specification of \nmaximum effect size of 15 percent. Effect size is the maximum magnitude \nof exceedance frequency that would be tolerated. USEPA (1997~) \nrecommends listing for bacteria at a 10 percent exceedance frequency. \nIf this recommendation were used in listing decisions, waters with less \nthan 10 percent exceedance would not be listed while waters with \nexceedance frequency above 25 percent would always be placed on the \nsection 303(d) list. Waters that fall between these two values would \nsometimes be listed. As described by USEPA (2002a), the use of the exact \nbinomial test with a population exceedance rate of 25 percent (which \nincludes a 15 percent effect size) \"indicates severe problems and \nrepresents the minimum violation (rate) we would almost always want to \ndetect\" (Smith et al., 2001). This interpretation is consistent with CWA \nsection 305(b) guidance (USEPA, 1997c) and is in the low range for \nexpected measurement error. \nChronic water quality criteria (as presented in the CTR) are always \nexpressed as average concentrations over at least several days and are \nexpressed with exceedance frequencies over three-year periods on the \naverage. USEPA's chronic water quality criteria for toxics in freshwater \nenvironments are expressed as 4-day averages. On the other extreme, \nUSEPA's human health water quality criteria for carcinogens are \ncalculated based on a 70-year lifetime exposure period. As stated in the \nCTR, the allowable frequency of exceedance is one time in a three-year \nperiod on the average. \nFor toxics (including acute and chronic criteria for toxic pollutants, etc.), \nCALM Guidance (USEPA, 2002a; in table 4-3 of the reference) \nrecommends a statistical guideline of acceptable exceedance frequency of \n5 percent (on average) and unacceptable exceedance frequency of \n20 percent in any given sample. This approach again includes a maximum \neffect size of 15 percent. If this recommendation were used in listing \ndecisions, waters with less than 5 percent exceedance for these parameters \nwould not be listed while waters with exceedance frequency above \n20 percent would always be placed on the section 303(d) list. Waters that \nfall between these two values would sometimes be listed. This \ninterpretation is at the lower end of the allowable measurement error of \nmajor monitoring programs. \nAt present, no other state has implemented these specific exceedance \nfrequencies for placing waters on the section 303(d) list. 6. \t Use separate r values for conventional ~ollutants as recommended \nbv USEPA (2002a). Establish r values for toxicants at a level that is more \nconservative than the USEPA recommended values. As for alternative 5, \nthe Policy would specify separate ranges of exceedance frequencies for \ntoxicants and conventional pollutants. As described and justified in \nalternative 5, waters with less than 10 percent exceedance frequency \nwould not be listed while waters with exceedance frequency above \n25 percent would always be placed on the section 303(d) list (USEPA, \n2002a). \nFor toxicants (including acute and chronic criteria for toxic pollutants, \netc.), CALM Guidance (USEPA, 2002a; in table 4-3 of the reference) \nrecommends a statistical guideline of acceptable exceedance frequency of \n5 percent (on average) and unacceptable exceedance frequency of \n20 percent in any given sample. This approach again includes a maximum \neffect size of 15 percent. At the September 8,2004 SWRCB workshop, \ntestimony was received stating that these exceedance frequencies are not \nstringent enough to assure that problem waters would be placed on the \nsection 303(d) list. \nToxicants have significant potential to adversely affect aquatic life and \npotentially public health when present at levels above those defined in the \nwater quality standards. Therefore, to be most protective of water quality, \nlisting decisions for toxicants should be based on standards exceedances \nfor these substances at relatively low frequencies, even if on limited \noccasions, rather than on the more prolonged persistence required for \nother pollutants. Using a lower bound of 3 percent, for example, is well \nbelow the typical allowable variation for metals, organic chemicals, and \ntoxicity (see alternative 5). Using a 3 percent exceedance frequency is \nmore environmentally conservative and provides additional assurance \nwaters will be listed when measurement variation is moderate. \nIf this recommendation were used in listing decisions, waters with less \nthan 3 percent exceedance for these parameters would not be listed while \nwaters with exceedance frequency above 18percent would always be \nplaced on the section 303(d) list. Waters that fall between these two \nvalues would sometimes be listed. As described in alternative 5, this \ninterpretation is well below allowable measurement error of major \nmonitoring programs. \nThis alternative represents the preferred alternative because the range of \nvalues, in the absence of site-specific values, is pragmatic, balanced, fair, \nand within the limits of the water quality regulatory process. Based on the \nmonitoring efforts implemented in California (e.g., NPDES, SWAMP, \nUSEPA, etc.), the data sets available (SWRCB, 2003a), past practices of \nthe SWRCB and many RWQCBs, and the consequence of a section 303(d) listing; the 3 percent-18 percent and 10 percent-25 percent r values are \nreasonable in the absence of a site-specific values. \nAt present, no other state has implemented these specific dual exceedance \nfrequencies for placing waters on the section 303(d) list. \n7. Use a single r value of less than 5 percent. Under this alternative, the \ncritical maximum limit of exceedances seen in any sample would be less \nthan five percent. Several states use very low exceedance rates for toxic \nchemicals (Table 15). The justification for these low exceedance rates is \ndiscussed by USEPA (2002a) in the CALM guidance. Generally, very \nlow exceedance frequencies are justified by the requirement that USEPA \nacute and chronic water quality criteria only allow for a one-in-three year \nexceedance frequency. To work within this frequency, states typically \nassume there is no variability in sampling or analysis and, therefore, do \nnot use statistical analysis. \nTo distinguish very rare occurrences of standard exceedances with \nstatistical tests requires very large sample sizes because the exceedance \nfrequency is so small. USEPA has estimated that over 900 samples in a \nthree-year period are needed to assess if these standards are attained \n(USEPA, 2002a). The difficulty associated with the once-in-three-years \nassessments occurs because the standard as presented in the guidance \nallows only one extremely rare event (e.g., one exceedant day out of 1,095 \ndays for acute criteria or one exceedant period out of 274 four-day periods \nfor chronic criteria), but no more. With these types of critical exceedance \nfrequencies false negative (Type 11) error are very high unless sample size \nrequirements are increased. \nIf modestly-sized data sets are to be used to assess compliance with \nUSEPA acute and chronic criteria and variability of measurements are to \nbe considered in the assessments, then the attainment assessments become \nsimilar in practice to determinations of compliance with \"not to be \nexceeded standards discussed in Alternative 4. USEPA has \nacknowledged that a higher critical exceedance frequency can be used for \nacute and chronic criteria (USEPA, 2003b; USEPA, 2002a) and for \"not to \nexceed\" standards if justified. \nRecommendation: \t Alternative 6.See Policy sections 3 and4. The form of the testable \nhypotheses becomes: \n1. For Listing Toxics: \nH,: p 50.03 \nH,:p>0.18 \n2. For Delisting Toxics \nH,: pl0.18 \n Ha :p < 0.03 \n3. For Conventional Pollutants and Bacteria \nH,: p<0.10 \nHa :p >0.25 \n4. \tFor Delisting Conventional Pollutants and Bacteria \nH,: p 20.25 \nHa:p<O.10 \nWhere p is the estimate of the true proportion of samples that exceed the \nnumeric water quality standard. The proportion of samples exceeding the \nstandard is the number of samples exceeding divided by the total number \nof samples. Issue 6D: \nIssue: \nIssue Description: Selection of Statistical Confidence and Power Levels \nWhen a statistical test is used to evaluate numeric sample data, \nwhat minimum level of statistical confidence and power should be \nselected for section 303(d) list decision-making? \nStatistical hypothesis testing is primarily about choosing between \nlikely hypotheses that lead to better decision-making. A good deal \nof statistical theory is devoted to quantifying the reliability of such \ndecisions. An appropriate statistical test or value can be used to \nchoose the hypothesis that best fits the observed facts and to \nincrease confidence in the findings. Statistical confidence is the \nprobability of not committing a Type I error (listing when we \nshould not). The power of a hypothesis test is the probability of \nnot committing a Type I1 error (not listing when we should). \nFor the purposes of analyzing statistical confidence and power, the \nnull hypothesis is: water quality standards are met (as \nrecommended in Issue 6A). The alternative hypothesis is, then, \nwater quality standards are not met. Decisions on whether the \nwater body should be listed depend on which hypothesis, the null \nor alternative, is \"rejected at a certain level of confidence and \npower. \nIn statistics, the likelihood of making false-positive errors is \nassigned a shorthand symbol a. Alpha values range from zero (or \n0%) to one (or 100%) chance of making a Type I error. The \nconverse of alpha, the non-error rate, is defined as one minus alpha \n(or 1 -a),and ranges from a one (100%) to zero (0%) chance of -not making a Type I error. This non-error rate gives the \nconfidence in the test results. The greater the confidence in a \nstatistical test result (i.e., the lower the avalue), the more likely \nthat a Type I error (rejection of a true null hypothesis) will be \nmade. \nSimilarly, the likelihood of making false-negative errors is \nassigned a shorthand symbol P. Beta values range from zero (or \n0%) to one (or 100%) chance of making a Type I1 error. The \nconverse of beta, the non-error rate, is defined as one minus beta \n(or 1 -p), and ranges from a one (100%) to zero (0%) chance of -not making a Type I1 error. This non-error rate gives the power of \nthe test results. The greater the power in a statistical test (i.e., the \nlower the p value), the more likely that a Type I1 error (acceptance \nof a false null hypothesis) will be made. When other variables, Baseline: \nAlternatives: such as sample size and critical exceedance rate are held stable, \ndecreasing a increases P, and vice versa. \nConfidence levels have no direct bearing on Type I1 error, the error \nof failing to reject an untrue null hypothesis. A confidence of \n99 percent, for example, helps ensure that approximately 99 times \nout of 100 a true null hypothesis will not be judged falsely. \nHowever, setting such a high confidence level in test calculations \ndoes not prevent, and may actually promote, a higher error rate of \njudging a false null hypothesis to be true (Type I1 error). \nType I and Type I1 errors are both undesirable. However, a policy \nthat provides a moderately high degree of confidence can be \nadopted for both listing and delisting decisions. Further discussion \nof control of Type I1 error is addressed in the determination of \nrecommended form of the null hypothesis (Issue 6A), choice of the \nstatistical test (Issue 6B), critical exceedance rate (Issue 6C), and \nsample size (Issue 6E). \nPreviously, the RWQCBs and the SWRCB did not select or \ndetermine a level of statistical confidence in section 303(d) listing \ndecisions. \n1. Provide no guidance on the choice of statistical confidence or \npower to the RWOCBs. Under this alternative, RWQCBs would \nbe able to choose whatever confidence level (and Type I error rate) \nor power level (and Type I1 error rate) which seem appropriate. \nConfidence and power might vary from one decision to the next, or \nfrom region-to-region. \nThis alternative would grant the RWQCBs great flexibility in \nsection 303(d) list decision-making and would allow establishment \nof confidence levels depending on the circumstances of each \nlisting decision. However, to make decisions based on statistical \n'tests without bias, confidence and power levels should be \ndetermined before tests are ~erformed. \nAssuming that the RWQCBs use the same statistical procedure to \nanalyze sample data, this alternative could result in inconsistent \nlisting decisions (e.g., the same number of exceedances in two \nsamples of the same size could result in listing in one region and \nno listing in another region). \n2. Use any confidence level less than ninetv Dercent ke., 11-a1<= \n0.90). Under this alternative a confidence level of less than or \nequal to 90 percent would be used by RWQCBs and power (Type I1 error) would not be controlled. This less certain \nconfidence level (e.g., 75 to 90 percent) could be used for placing \nwaters on the section 303(d) list. Emerging and more subtle \nproblems (e.g., problems characterized by fewer exceedances) are \nmore likely to be identified with a lower confidence level \n(Williamson, 2001). However, the risk is an increase in Type I \nerrors, i.e., waters will be identified more frequently as exceeding \nstandards when in fact they may not be exceeding standards. \nAdditional monitoring or confirmation of the problem before a \nTMDL is developed would help identify and eliminate suth \nmistakes. The State of Florida uses an 80 Dercent confidence level \nfor placement of waters on its Planning List (i.e., those waters \nwhere additional monitoring is needed before the decision to place \nwaters on the section 303(d) list can be made). \nScientists and decision-makers normally look for a high degree of \nconfidence (i.e., a low a)in order to reject a null hypothesis. Any \nstatistical conclusion that has a confidence level of less than \n90 percent is considered not acceptable by most statisticians (Lin et \nal., 2000). Many states have selected 90 percent confidence for \nplacement and removal of waters from the section 303(d) list (e.g., \nArizona DEQ, 2000; Florida DEP, 2002; Texas, 2002; and \nWashington DEP 2002). \nAs used in the draft Listing Policy (SWRCB, 2003c), the binomial \ntest effectively controls a,but not P. Figure 20 shows maximal \nstatistical error rates associated with the draft Listing Policy for \nsample sizes up to 120. Type I error (a)is controlled at levels less \nthan or equal to 0.10 for all sample sizes shown. The P error rate, \nhowever, is consistently greater than 0.90. In addition, larger \nsample sizes do not appreciably lower maximal $ rates. Rates for \np of 0.2 or less are generally desirable but are not achieved using \nthis conventional hypothesis testing approach. \nThe top graph of Figure 20 emphasizes that when deciding not to \nlist a water body (i.e., accepting the null hypothesis of H,,: rs0.1) \nthere is a high probability (P >0.90) of \"missing\" a water body that \nshould, in fact, be listed. This decision error is greatest when the \ntrue alternate exceedance rate is very close to, but greater than, the \nhypothesized exceedance rate of r = 0.10. \nIn contrast, the lower graph of Figure 20 emphasizes that when \ndeciding to keep the water body on the section 303(d) list (i.e., \naccepting the null hypotheses of H,: r 20.1) there is a high \nprobability (P >0.90) of incorrectly failing to remove a water body \nfrom the section 303(d) list. Again, this decision error is greatest LIST WHEN Ho: R 50.10 IS REJECTED \n0.2 \n0.1 \tn ALPHA \n0.0 \t x BETA \n0 50 100 150 \nSample Size \nDELIST WHEN Ho: R > 0.10 IS RFJECTED \n0.1 \t0 ALPHA \n0.0 \t x BETA \n0 50 100 150 \nSample Size \nFIGURE DECISION-MAKING RATES FOR 20: STATISTICAL ERROR \nEXCEEDANCE USED IN THEDRAFT SWRCB POLICY FREQUENCIES \n(DECEMBER 2,2003 VERSION). when the true exceedance rate is very close to, but less than, the \nhypothesized exceedance rate of r = 0.10. \nThis alternative would allow section 303(d) decision making to \nproceed with greater than a one-in-ten chance of making a Type I \nerror. In scientific research, confidence levels of at least 90,95, or \neven 99 percent (i.e., a<0.10,0.05, or 0.01) are traditionally \ndesirable. Using this alternative, the probability of missing real \nwater quality problems is great. \n3. Balance confidence level at 80 Dercent (i.e., I1 -a1 = 0.80) and \npower at 0.80 he.. I1 -01 = 0.80). Use a higher degree of \nconfidence and Dower (90 ~ercent) when removing toxicants from theThe 80 percent confidence and 80 percent power levels \nare recommended under this alternative in order to balance the two \ntypes of errors (Types I and 11) when sample sizes are expected to \nbe relatively small (e.g., <30). A higher degree of certainty (i.e., \n90 percent confidence and power) would be required when \nconsidering removing a toxicant from the section 303(d) list. \nThe binomial test, like most statistical hypothesis testing \nprocedures, will control the maximum arate at a value below the \nnominal significance level for most sample sizes. In contrast, the \nmagnitude of P depends on several factors, including a,the \npopulation variance, the effect size, and sample size. Generally, a \nvaries inversely with P,and control of $ is traditionally sought \nthrough the appropriate selection of sample size (Gibra, 1973) or \nthrough the use of a more powerful statistical test (Helsel and \nHirsch, 2002). \nAlternatives to controlling only the arate are possible. Mapstone \n(1995) argued against adhering to a fixed and arbitrary a, \nadvocating instead for the consideration of economic, \nenvironmental, social, and political consequences of a and P \ndecision-making errors. In the absence of further information, \nMapstone recommended that decision errors should be weighted \nequally, i.e., a=P. \nIf errors are made in the section 303(d) process, they could be \ncostly. For example, if a TMDL is developed and implemented \nand the originally identified problem does not exist, the costs could \nrun into the millions of dollars to address a non-problem. \nConversely, if a real water quality problem is missed, the \nunidentified problem could have devastating impacts on beneficial \nuses of water unchecked by actions to control the problem. The \nloss of a beneficial use could also cost millions of dollars. Each of these errors may be avoided by assessing the water quality \nsituation more completely. In other words, if monitoring data were \navailable to better assess water quality conditions then Type I and \nType I1 errors could be minimized. The cost of minimizing these \nerrors is the cost of performing the monitoring. The costs for \nmonitoring many parameters addressed by the Listing Policy are \npresented in Tables 16 (toxicants) and 17 (conventional \npollutants). \nDepending on the parameter and the number of exceedances, \nmonitoring costs range from just over $2,700 to nearly $68,000 per \nsite to meet the minimum requirements for listing under the \nprovisions of the Policy. For removing toxicants from the \nsection 303(d) list the costs range from just under $38,000 to \nnearly $1 19,000. \nThe balanced error approach considers both types of decision- \nmaking errors, a and P, rather than only a. Another objective is to \nmaintain these balanced error rates at or below an acceptable \nmagnitude. Although USEPA (2002a) suggested that a moderate \nacceptable magnitude for balancing errors is 15 percent, the choice \nof values for a and p rates is a policy decision (Millard and \nNeerchal, 2001). Nevertheless, a pre-defined maximum acceptable \nerror for both a and P will allow the determination of acceptable \nsample sizes to use for listing and delisting. \nAppropriate sample sizes required to achieve the desired error rates \nare illustrated in Figures 21 and 22. If the effect size is 15 percent \nand both a and Prates at or below 0.20 then 16 samples for \ntoxicants (Figure 21) and 26 samples for conventional pollutants \n(Figure 22) are needed. For removing toxicants from the list, if \nboth a and P error rates at or below 0.10, then at least 28 samples \nare required. If the CALM Guidance-recommended balanced \nerrors of 0.15 are used, then 29 samples for toxics (assuming a \n5 percent and 20 percent exceedance frequency) and 33 samples \nfor conventional pollutants are needed. At the USEPA- \nrecommended a and P, monitoring costs would be approximately \n21 percent to 45 percent greater (Table 16). \nUse of the higher error rate (20 percent) is appropriate because the \nbasis for the listing will be reviewed and corroborated by \nsubsequent analyses performed in the course of developing the \nTMDL. In this situation, higher error rates are acceptable because \nthe listing only initiates the planning process that may lead to \nimplementation of more expensive management measures (Hahn and Meeker, 1991). Based on comments received at the \nSeptember 8,2004 SWRCB workshop, toxic pollutants can have \nlarge impacts on water quality and are of great public concern so it \nmay be desirable to require more certainty (e.g., a lower, more \nrestrictive error rate of 10 percent) when removing toxic pollutants \nfrom the section 303(d) list. This increased certainty however \ncomes at a greater cost for monitoring but the costs are balanced by \nthe assurance that when waters are removed from the list, a \nstatistically valid and larger sample would be available to support \nthe delisting. The cost of monitoring for toxicant delistings is \n43 percent to 93 percent greater than the costs of monitoring for \nplacement of the toxicant on the list (Table 16). Considering the \nenvironmental and social consequences as presented at the \nSeptember 8,2004 workshop, using this approach would reduce \nthe chances for removing pollutants from the list before standards \nare truly achieved. \nFigure 23 directly compares the selected balanced error sampling \nplans with the December 2003 Listing Policy (Alternative 2). \nBy using the balanced error approach both a and j3 decrease \nappreciably with increasing sample size (N). Lowered a and j3 \nrates using the balanced error approach contrast sharply with the \nhigher j3 error rates expected when using the traditional statistical \ntests such as the binomial test without balanced error rates. \nFor conventional pollutants (i.e., rl = 10 percent, rz = 25 percent), \nwith sample sizes under 60, the balanced error plans require fewer \nexceedances to list a water body and allow more exceedances \nwhen delisting a water body. When sample size is greater than 60, \na greater number of exceedances are needed to place a water on the \nsection 303(d) list. This greater number of allowable exceedances \nmay be an incentive for additional monitoring. The incentive for \nincrease toxicant monitoring is the need for increased certainty \nwhen toxicants are considered for delisting. \nThis alternative is the preferred alternative because the errors are \nsufficiently low to identify water quality problems while at the \nsame time balancing the potential costs of monitoring of \nconventional pollutants to identify real water quality problems. \nThis proposal is does not balance the costs of monitoring for \ntoxicants but, rather, requires that more information be used to \nsupport removal of these pollutants from the list. The error \nbalancing approach is an equitable way to decide whether a water \nbody should be listed or delisted. Listing when sample size is \nlower than 16 for toxicants or 26 for conventional pollutants is \ndiscussed in Issue 6E. TABLE16: ESTIMATED COSTSOF SAMPLING AND ANALYSIS USING20 PERCENT FOR TOXICANTS ALPHA AND \nBETA FOR LISTINGDECISIONS FOR DELISTING AND USING10 PERCENT DECISIONS \nListing Delisting \nSampleType Low Cost \nPer \nSample High \nCost per \nSample 2 samples \n(Low \nbnge) 16samples \n(Low range) 2 samples \n(H~gh Range) 16samples \n(H~ghRange) 28 samples \n(Low Range) 28 samples \n(High Range) \nWater Chemistry \nMetals w/WQ \nparameters $1,364 $2,026 $2,728 $21,824 $4,052 $32,416 $38,192 $56,728 \nOrganic wlWQ \nparameters $1,722 $2,371 $3,444 $27,552 $4,742 $37,936 $48,216 $66,388 \nTissue chemistry \nMetals w/WQ \nparameters $1,354 $2,609 $2,708 $21,664 $5,218 $41,744 $37,912 $73,052 \nOrganic wlWQ \nparameters $1,992 $2,990 $3,984 $31,872 $5,980 $47,840 $55,776 $83,720 \nSediment chemistry \nMetals w/WQ \nparameters $1,241 $1,795 $2,482 $19,856 $3,590 $28,720 $34,748 $50,260 \nOrganic wlWQ \nparameters $1,992 $2,990 $3,984 $31,872 $5,980 $47,840 $55,776 $83,720 \nToxicity Tests \nWafer \nSaltwater wlWQ \nparameters 1 species to $1,931 $3,904 $3,862 $30,896 $7,808 $62,464 $54,068 $109,312 \n3 species \nFreshwater wlWQ \nparameters 1 species to $2,130 $4,235 $4,260 $34,080 $8,470 $67,760 $59,640 $118,580 \n3 species Listing Delisting \nSample Type Low Cost High \nPer Cost per \nSample Sample 2 samples \n(Low \nR ~ 16 samples 2 samples \n(Low range) (High Range) \n~ ~ ~ ) 16 samples \n(High Range) 28 samples \n(Low Range) 28 samples \n(High Range) \ninterface \nSaltwater w/WQ \nparameters 1 species $2,096 $2,481 $4,192 $33,536 $4,962 $39,696 58,688 $69,468 \nSediment \nFreshwater w/WQ \nparameters, sediment \ngrain size 1 species, $2,388 $3,031 $4,776 $38,208 $6,062 $48,496 $66,864 $84,868 \nLow (Acute), High \n(Chronic) \nSaltwater WIWQ \nparameters and \nsediment grain size, 1 \nspecies, Low (survival $2,400 $4,088 $4,800 $38,400 $8,176 $65,408 $67,200 $1 14,464 \ntest), High (survival \nand growth test) \n1. WQ Parameters include: DO; pH; temperature; conductivity; turbidity \n2. Each sample type includes: sampling ranging from$788 (low) -$988 (high) per sample, chemical analysis or testing cost; water quality parameter and \nidentification of pollutant when stated. For all bacteria and virus measurements five replicate samples are included for each sample. \n3. Twenty percent of the cost for each sample type was added to cover the cost of data quality assurance. \n4. Estimated costs per sample were based on the November 2000 Report to Lz&slature (SWdCB, 2000b) and SWAMP costs (SWRCB, 2003b). \n5.Three samples are the absolute minimum number of samples needed to support a listing. TABLE 17:ESTIMATED OF SAMPLING FORCONVENTIONAL COSTS AND ANALYSIS \nPOLLUTANTS USING20 PERCENT AND BETA\n ALPHA \nLow High 5 samples 26 samples 5 samples 26 samples \nSample Type Cost per Cost per (Low Range) (Low range) (High Range) (High range) \nSample Sample \nConventional \nPollutants and \nNutrients \northo-Phosphate, nitrate \n+nitrite, chloride; \nsulfate; nitrate (sep- \narate); nitrite (separ- \nate); ammonia: total P; \nTKP; chorophyll-a; $1,636 $2,068 $8,180 $42,536 $10,340 $53,768 \nalkalmity; TSS; TDS; \nhardness; TOC; DOC; \nDO; pH, temperature; \nconductivity; turbidity \nTotaVFecal coliform \nbacteria $1,186 $1,918 $5,930 $30,836 $9,590 $49,868 \nEnterococcus bacteria $5,480 $28,496 $8,690 $45,188 \nCryptosporidum/ \nGiardia $1,306 $1,738 $6,530 $33,956 $8,690 $45,188 \nEnteric viruses $1,456 $1,918 $7,280 $31,538 $9,590 $49,868 \nColiform in shellfish $1,000 $1,276 $5,000 $26,000 $6,380 -$33,176 \n1. Costs for conventional pollutants alone could be less than reported because fewer exceedances are required. \n2. Each sample type includes: sampling ranging from $788 (low) -$988 (high) per sample, chemical analysis or \ntesting cost; water quality parameter and identification of pollutant when stated. For all bacteria and virus \nmeasurements five replicate samples are included for each sample. \n3. Twenty percent of the cost for each sample type was added to cover the cost of data quality assurance. \n4. Estimated costs Der sample were based on the November 2000 Repon to Legislature (SWRCB, 2000b) and -\nSWAMP costs (s~B, 2003b). \n5. Five samples are the absolute minimum number of samples needed to support a listing. List when H,: r 5 0.03 is rejected \no ALPHA \nx BETA \n0 \t 50 100 150 \nSample Size \nDelist when H,: r 2 0.18 is rejected \n0 ALPHA \nx BETA \nSample Size \nFIGURE21:BALANCED ERROR RATES ASSOCIATED WITH THE SAMPLING PLAN FOR R1= \n3 PERCENT AND Rz = 18 PERCENT WITH EFFECT 15 PERCENT. SIZE= LISTWHEN Ho: R 50.10IS REJECTED \n1 .o \n0.9 \n0.8 \nL 0.7 \ne\nG \t0.6\n-\n.-8 \t0.5 \n.w \nP U) 0.4 \n\"_m \n0.3 \n0.2 \n0.1 \t o ALPHA \n0.0 \t x BETA \n0 50 100 150 \nSample Size \nDELIST WHEN Ho: R 20.25 IS REJECTED \n1 .o \n0.9 \n0.8 \n0.7 \neG \t0.6\n--8 \t0.5.-\n--U) \t0.4m \n0.3 \n0.2 \n0.1 \t0 ALPHA \n0.0 \t x BETA \n0 50 100 150 \nSample Size \nFIGURE22: BALANCED ERROR RATES ASSOCIATED WlTH THE SAMPLING PLAN FOR Ri = \n10 PERCENT AND Rz = 25 PERCENT WlTH EFFECT = 15 PERCENT. SIZE Sample Size \nSample Size \nFIGURE23: COMPARISON 2003 VERSION POLICY VERSUS BALANCED OF DECEMBER OFLISTING \nERRORSAMPLING USED IS LIST(R~, R2). PLANS.NOTATION R2)OR DELIST(R~, - - 4. A confidence level greater than ninetv uercent (i.e.. I1 -a1 > 0.90r \nScientists and decision-makers normally look for a high degree of \nconfidence (i.e., a low a)in order to reject a null hypothesis. \nThis alternative decreases the likelihood of making a Type I error (e.g., to \n5%. 1%, etc.). Many scientific, medical, or social researchers demand \nthese levels of confidence for their investigations. \nUsing a larger value raises the statistical bar, making it harder for data to \nbe judged adequate. Because accurate water quality data are difficult to \ncollect in great numbers, these standards may be too high. Also, as \nconfidence is increased, power (1 -P;the rate of not making a Type I1 \nerror) increases (if sample size is held constant). All of the limitations \ndescribed in Alternative 2 when just Type I error is controlled applies to \nthis alternative. \nRecommendation: Alternative 3. See Policy sections 3 and 4. Issue 6E: \t Minimum Sample Size \nIssue: \t What minimum sample size is required for section 303(d) listing and \ndelisting? \nIssue Description: \t If critical exceedance rate, effect size, Type I error, Type I1 error, and \nvariance are held constant, the sample size has a large effect on expected \nerrors. Minimum sample size allowed is critical to decision-makers \nbecause this value is an effective way to help control errors associated \nwith making decisions based on sampled data. \nBaseline: \t RWQCBs used minimum sample sizes ranging from one to ten samples. \nAlternatives: 1. Provide no guidance in the choice of the sample size in the binomial \ndistribution model. This alternative would grant RWQCBs the greatest \nflexibility in making section 303(d) list recommendations. The RWQCBs \ncould choose to use the widest range of data sets submitted by public and \nagency sources. Information from resource-strapped data contributors \nwould not necessarily be excluded. \nHowever, region-by-region listing methodology inconsistencies would not \nbe addressed under this alternative. If very small sample sizes are used, \nerror rates even if balanced, could be very high (i.e., greater than \n20 percent). \n2. Set a minimum sample size to control error rates at a specified level. \nUSEPA guidance (2002a) identifies acceptable Type I1 error at 20 percent \nor less. Assuming a Type I error of 0.2 and a Type I1 error level of 0.2 \n(20 percent), the minimum sample size to place waters on the \nsection 303(d) list would be set at 21 for toxics and 26 for conventional \npollutants (Figures 21 and 22). Smaller sampling sizes could be used with \nthis Type I1 error but the critical exceedance rate would have to be \nincreased (USEPA, 2002a). For example, acceptable Type I1 error for a \nsample population of 10 requires a critical exceedance rate of at least \n40 percent. \nUsing a minimum sample size (such as 21 samples) would exclude \nnumerous data sets used in previous listing cycles and would not be \nconsistent with recent USEPA guidance (USEPA, 2003b). However, such \na relatively large sample size could result in the data taking on a nonnal \ndistribution. Investigators could then analyze the data with parametric \nstatistical tests that may offer advantages over the somewhat less powerful \nbinomial test. \n3. Require a minimum sample size of 20 for measurements of chemicals in \nwater and 10 for measurements of sediment, tissue, water toxicity, and bacteria. For delisting, use minimum sample size dictated by critical \nexceedance rate and confidence level used in the statistical test. Smaller \nsample sizes are more prone to yield erroneous decisions to list (USEPA, \n2003b). Even so, several states require the use of 10 or 20 samples to \nsupport listing decisions. Florida (Florida DEP, 2002), for example, \nrequires at least 20 samples before a water segment is considered for \nplacement on the section 303(d) list. Other states, such as Nebraska \n(2001) or Montana (2002) allows smaller sample sizes if the \nmeasurements.integrate biological response or chemical concentration. \nWhile smaller sample sizes have a higher potential for error, this may be \nacceptable because the measurements are either integrative of \nenvironmental effect or exposure (toxicity or sediments), or the potential \nis higher that the measurement (tissue or bacteria) is indicative of potential \nhuman health impact. \nSelection of a relatively small minimum sample size would allow \nRWQCBs to accept and use a larger number of data sets submitted for \nevaluation. Citizen monitoring groups and others with limited sampling \nbudgets could still contribute information to section 303(d) listing efforts. \n4. Do not reauire an absolute minimum number of samples. Use the number \nof samples that exceed water aualitv standards. Under this alternative, \nSWRCB would allow smaller sample sizes to be used if the frequency of \nsample exceedances is large, i.e., the number of exceedances is equal to or \ngreater than the minimum number of samples identified using the balanced \nerror approach with the exact binomial test (please refer to Issues 6A \nthrough 6D). \nOne of the balanced error sampling plans (listing using 3 percent and \n18 percent) requires 16 or more samples to keep both error types below , \n20 percent. Using this approach, two exceedances in 16 samples is the \nminimum exceedance needed to list a water body. IF a decision rule is \nestablished to list if two or more exceedances are observed for any sample \nsize less than 16, independent of the statistical sampling plan as \nrecommended in Issue 6D, the ct levels are always low and there is a small \nchance of incorrectly listing a clean water body (Figure 24). \nAt the September 8,2004 SWRCB workshop, comments were received \nstating that the use of small numbers of samples should be consistent with \nthe provisions of water quality standards. USEPA interprets the California \nToxics Rule (40 CFR 131.38(~)(2)(iii)) to mean that waters must be listed \nif there are two or more independent excursions of acute or chronic water \nquality standards within any 3 consecutive year time frame. Assuming two \nsamples are representative of the three year time frame on average and are ALPHA \nPOWER \nSample Size \nFIGURE WITH TWO EXCEEDANCES 24: LISTING \nrepresentative of the spatial characteristics identified for listing, then the \nPolicy should allow a toxicant to be placed on the section 303(d) list if \nthere are two exceedances in at least two samples. \nThe burden of proof is greater when using this rule, as compared to the \nbalanced statistical sampling plan (as discussed in the previous issue \npapers). With smaller sample sizes, a levels are always low and there is a \nsmall chance of incorrectly listing a clean water body. However, P errors \nare high with these smaller sample sizes and there is a large chance of \nfailing to list water bodies that are not meeting water quality standards. \nThe P errors comes from having small sample sizes that contain 0 or 1 \nexceedance, when we do not list with the decision rule (i.e., do not reject \nthe null of r 5 0.03). If listing occurs with two or more exceedances, a P \nerror cannot be committed because the null hypothesis is always rejected. \nTherefore, with two or more exceedances in sample sizes between two and \n16, inclusive, the only possible outcomes are a errors or a correct decision \n(i.e., power = 1-p). The correct decision rate depends on the alternative \nhypothesis proposed, in this case Ha:r > 0.18. For listing with two or more \nexceedances with N = 2 to 16, a errors are low, but power increases from \n<0.8 percent to 80 percent with increasing sample size. The same relationship holds for the balanced error approach using \n'10 percent and 25 percent. The decision rule would be to list if five or \nmore exceedances were observed in sample sizes between 5 and 25. \nUsing this approach, small sample populations are not excluded because \nthe frequency of the observed excursions are high enough to support \nreliable attainment determination as long as the samples are spatially and \ntemporally representative. \nIf these minimum sample sizes and minimum exceedance rates are used, it \nis likely that the number of decisions to list would be less than in 2002 \n(Figure 25). This alternative satisfies USEPA guidance (USEPA, 2003b) \nrequiring rigid sample sizes not be used and that small data sets be \nincluded in deciding to place waters on the section 303(d) list. \nRecommendation: Alternative 4. See Policy sections 3 and 4. \n(r = 3%-18% or 5%-20%) \nincludes DO, pH, temperature. \nbacterial measures, turbidity, \ntaste, and odor. \nWith Error With Error Without Error \nBalancing (3%- Balancing (5%- Balancing (10%) \n18%) 20%) \nI W Conventional Pollutants .Toxicants I \nFIGURE 25: GRAPHICAL COMPARISON OFDECISIONS WATERS ON THE OF THE NUMBER TO PLACE \nSECTION 303(D) LIST. \nFigure 25 was developed from the data and information analyzed during the development of the 2002 section 303(d) \nlist (SWRCB, 2003a). The figure was develop using the following assumptions: \n1. \tThe \"With Error Balancing (3%..18%)\" bar incorporates the recommendations presented in Issues 6B, 6C, 6D, \nand 6E. \n2. \tThe \"With Error Balancing (5%-20%)\" bar incorporates the recommendations presented in Issues 6B; 6C, \nAlternative 4; and 6E. Errors are balanced at 20 percent. 3. \tThe \"Without Error Balancing (10%)\" bar represents the recommended approach in the draft FED (SWRCB, \n2003c) and Issue 6D,Alternative 2. \n4. \tSometimes the same data set is compared to multiple evaluation guidelines. \nFigure 25 illustrates that 285 out of 334 listing decisions using acceptance sampling by attributes using the \nrecommended r values and error balancing would support decisions to list. This suggests a possible 14.7 percent \nreduction in numbers of decisions to list waters as compared to the 2002 listing process. Issue 6F: Quantitation of Chemical Measurements \nIssue: How should data measurements below the quantitation limit for the \nchemical measurement be interpreted? \nIssue Description: One of the most difficult problems in the analysis of water quality data is \nthe incorporation of measurements below analytical detection (nondetects) \ninto statistical analysis. Water quality data often include observed \nmeasurements that are below or less than the quantitation limit (QL) of the \nanalytical instruments. Measurements below the QL lies somewhere \nbetween zero and the detection limit. For some constituents, established \nwater quality objectives or criteria lies below the QL. \nBaseline: In 2002, the RWQCBs used several methods to evaluate nondetect data. \nAlternatives: 1. Provide no guidance for interpreting data below the OL. The RWQCB \nwould be given significant flexibility under this alternative. Guidelines \nwould establish in the Policy for interpreting data below the QL. \nHowever, one of the goals of the Policy is to establish consistent \nguidelines for interpreting data. If guidelines were not established, \ndifferent methods would likely be used statewide to analyze data that falls \nbelow the QL. \n2. Provide general guidance to interpret values below the OL. Under this \nalternative, the Policy would present general guidance on interpreting \nanalytical data that are below the QL. In order to obtain consistency \nstatewide, general guidelines should be established. \nThe following general guidelines could be used for interpreting data below \nthe QL. If the exact binomial test is used with data below detection, it is \nnot necessary to quantify the value. For detection levels below the water \nquality objective should always be judged as meeting water quality \nstandards and the nominal value used would not be affected by the \nmagnitude of the measurement. For measurements below quantitation and \nabove the water quality objective, it cannot be determined if standards are \nattained and therefore a fundamental assumption of the binomial test is \nviolated (i.e., there would be more than two outcomes). These \nmeasurements should not be evaluated using this test. The concepts for \nthis approach are presented in Figures 26 and 27. FIGURE 26: INTERPRETING DATA WHEN MEASUREMENTS ARE LESSTHAN OR \nEQUALTO THE QUANTITATION LIMIT(QL) AND THE WATER \nQUALITY OBJECTIVE IS GREATER THAN THE QL. \nIn Figure 26, XI, Xz and X3 should be interpreted in the following manner \n(consistent with Gibbons and Coleman, 2001). \nXI: This value should be used in the analysis if the measured value is \ngreater than the water quality objective and QL. If the data point is greater \nthan the QL, the data can be quantitatively analyzed with suitable \nprecision and accuracy. Additionally, if the data point is above the water \nquality objective, the water quality objective has been clearly exceeded. \nTherefore, the data point presents a valid assessment of the sample. \nXz :This value would meet the water quality objective if the measured \nvalueis below the water quality objective and above the QL; there is a \nhigher level of confidence that the measured valueis the true value. If the \ndata point lies above the QL, the data point is considered valid to use in \nassessments. However, since the value is below the water quality \nobjective, it is not exceeded and the standard is met. \nX3: This value would meet the water quality objective because the data are \nless than or equal to the QL and the water quality objective is greater than \nthe QL. FIGURE 27: INTERPRETING DATA WHEN MEASUREMENTS ARE LESS THAN OR \nEQUAL TO THE QL AND THE WATER QUALITY OBJECTIVE IS LESS \nTHAN THE QL. \nIn the circumstance presented in Figure 27, X should be interpreted in the \nfollowing manner (consistent with Gibbons and Coleman, 2001). When \nthe sample value is less than the QL but is greater than the water quality \nobjective, the results should not be used in the statistical analysis. If the \ndata value falls below the QL it is only an estimate of the true value. \nTherefore, it is unknown whether the estimated data value exceeded the \nwater quality objective. \nThis alternative is the preferred alternative because it provides a consistent \nmethod for the incorporation of measurements below analytical detection \n(nondetects) into statistical analysis. \n3. Use USEPA penera1 guidance to intemret non-detects. USEPA (1998d) \npresents some general guidelines to evaluate data that include values \nbelow the detection limit (Table 18). However, there is no general \nprocedure that is applicable in all cases. \nTABLE 18: USEPA GUIDANCE \t OF MEASUREMENTS ON INTERPRETATION \nBELOW DETECTION \nPercentage of \nNon-detects Statistical Analysis Methods \n< 15% \t Replace non-detects with detection limit divided by 2, \ndetection limit, or a very small number \n15% -50% \t Trimmed mean, Cohen's adjustment, Winsorized mean and \nstandard deviation. \n>50% -90% \t Use tests for proportions The suggested procedures depend on the amount of data below the \ndetection limit. For relatively small amounts of data below detection \nlimits, replacing the non-detects with a small number or half the detection \nlimit (DU2) and proceeding with the analysis may be satisfactory. For \nmoderate amounts of data below the detection limit, a more detailed \nadjustment (e.g., Cohen's adjustment, trimmed mean, Winsorized mean \nand standard deviation) is appropriate. \nCohen's method provides adjusted estimates of the sample mean and \nstandard deviation that accounts for data below the detection limit. The \nadjusted mean are based on the statistical technique of maximum \nlikelihood estimation of the mean and variance so that non detects that are \nbelow the detection limit but may not be zero are accounted for. \nTrimming discards the data in the tails of a data set, in order to develop an \nunbiased estimate of the population mean. For environmental data, \nnondetects usually occur in the left tail of the data, therefore, trimming can \nadjust the data set to account for nondetects when estimating a mean. \nWinsorizing replaces data in the tails of the data set with the next most \nextreme data value. In situations where relatively large amounts of data \nare below the detection limit, one needs only to consider whether the \nchemical was detected; the detection limit is subjective. The Test of \nProportions is suggested if more than 50 percent of the data are below the \ndetection limit but at least 10 percent of the observations are quantified. \nTherefore, if the parameter of interest is a mean, consider switching the \nparameter of interest to some percentile greater than the percent of data \nbelow the detection limit. \nThis alternative allows for flexibility in interpreting data below the QL. \nThis could lead to inconsistencies in dealing with nondetect data and also \npotential misinterpretation of the data and inappropriate decision making \nbecause many statistical tests are influenced greatly by the number of \nmeasurements below detection. \nRecommendation: Alternative 2. See Policy section 6.1.5.5. Issue 7: Policy Implementation \nIn order to implement the provisions of the California Listing Factors, \nCalifornia Delisting Factors, and statistical analysis, several issues must be \naddressed in order for the process to be transparent and the listing \napproach consistent. These factors include: \nA. Evaluation of existing listings \nB. Defining existing readily available data and information \nC. Soliciting data and information and approval of the list \nD. Documentation of data and information \nE. Data quality requirements \nF. Spatial and temporal representation \nG. Data age requirements \nH. Determining water body segmentation \nI. Natural sources of pollutants \nIssues related to these topics are presented in Issues 7A through 71. Issue 7A: Review of the Existing Section 303(d) List \nIssue: What steps should the SWRCB and RWQCBs take to implement the \nPolicy? \nIssue Description: The Policy will ultimately define the factors to place and remove waters \nfrom the section 303(d) list. There are more than 1,800 water segment and \npollutant combinations on the 2002 section 303(d) list that were included \nprior to the Policy's implementation. The State should review waters \ncurrently on the section 303(d) list for consistency with the Policy. \nHowever, the resources available to complete this task will limit the \nreview of all listings before the next section 303(d) list is due. \nBaseline: Since the inception of the California section 303(d) list, the SWRCB has \nused previous lists as the basis for the development of the biennial \nsection 303(d) list. The 2002 section 303(d) list was no exception. The \n1998 section 303(d) list formed the basis for the 2002 list submittal. \nThe SWRCB in 1998 and USEPA in 1999 approved the 1998 amendments \nto the list. At that time, the SWRCB and USEPA evaluated all the \nexisting and readily available water quality-related data and information to \nmake the listing decisions. For many of the listed water bodies, the \nSWRCB and RWQCBs did not receive new data or information. \nTherefore upon consideration of the 2002 list, the SWRCB had no new \nevidence with which to reexamine the 1998 section 303(d) list \nconclusions. In the absence of evidence that called the 1998 listing -\ndecisions into question, decisions based on the previous record, were \nincluded on the list. \nAlternatives: 1. Incornorate a reauirement to revise the existine section 303(d) list so it is \nconsistent with the ListindDelisting Policy. Under this alternative, the \nPolicy would be applied to all existing listings of water segment-pollutant \ncombinations on the 2002 section 303(d) list. If completed in one listing \ncycle, this alternative would be a monumental task. However, it is \nunlikely the SWRCB and RWQCBs would be able to complete this task \nwithin the next two years. There are not enough staff resources available \nto complete the extensive data and information review that would be \nrequired. To reduce the impact of a reevaluation, it would be necessary to \ndivide the re-analysis into several parts, completed over a number of \nlisting cycles. \nListings that have yet to be reassessed would be carried forward on to the \nnew section 303(d) list until all the reassessments are complete. After all \nwaters have been reassessed, the updated version of the list would be used as the basis for subsequent lists. Future reassessment of waters should \nonly be completed if new data and information become available. \nThis alternative would be staff resource intensive and could cause a delay \nin development of TMDLs. \n2. \tDo not require that the entire section 303(d) list be reviewed. Onlv change \nthe existing list if new data and information are available and indicate a \nchange is needed. This alternative represents the baseline process. The \nadvantage of this alternative is that the list could be reviewed within \nexisting resources with minimal impacts on staff. The major disadvantage \nis that inconsistencies with the Policy would remain on the section 303(d) \nlist until new information is available. Under this alternative, it cannot be \ndetermined when the State will completely reevaluate the section 303(d) \nlist because of uncertainties in developing new data and information. \nIn order to improve consistency in the re-evaluation of the section 303(d) \nlist, the Policy could include a process for interested parties to request the \nreassessment when new information or a new data evaluation is available. \nUsing the guidance provided in the Policy, an interested party would make \na request to the appropriate RWQCB to reassess a listing. The interested \nparty would describe the reason that the listing is inappropriate, provide \nevidence that the data and information for the original listing is \ninadequate, and provide the data and information necessary for the \nRWQCB to conduct the reassessment. \nThis alternative would have minimal impact on RWQCB staff resources. \n3. \tReevaluate existing listings on the section 303(d) list as resources allow \nwith no reauirement for new data and information. (Combination of \n~lternatives 1 and 2). Water segments and pollutants on the section \n303(d) list could be reevaluated, as resources allow, if the listing was \nbased on faulty data or if data and information indicates that the-waters \nwould not meet listing or delisting requirements of the Listing Policy. \nAn interested party would be able to request an existing listing be \nreassessed (whether new data are available or not) under the provisions of \nthe Policy. To reduce the workload involved in evaluating the existing \nlistings the request for reevaluation would include an assessment of all the \nreadily available and existing data and information. In requesting the \nreevaluation, the interested party would be required to describe the \nreason(s) the listing is inappropriate, state the reason the Policy would lead \nto a different outcome, and provide the data and information necessary to \nenable the RWQCB and SWRCB to conduct the review. The most recently completed section 303(d) list would form the basis for \nany subsequent lists. \nThe steps to complete a reevaluation would be: \n+ \tEvaluation of all readily available data and information to assess a \nwater segment. \n+ \tIn performing the reassessment the RWQCBs or SWRCB would use \nthe California Delisting Factors to assess each water segment-pollutant \ncombination. \nThis alternative is the preferred alternative because with the limited \nresources available, this alternative presents the most feasible means of \nreevaluating existing listings. \n4. \tDo not state in the Listina Policv when or if existing listinas are to be \nreevaluated. Under this alternative the Listing Policy would be silent on \nwhether existing listings would be reevaluated. The advantage of this \nalternative is that RWQCB and SWRCB may not be impacted by requests \nfor evaluation of previously listed waters. A disadvantage is that if the \nPolicy is silent on this point and makes no provision for reviewing \nhistorical listings, RWQCBs may or may not view it as obligated or \nauthorized to conduct such a review. This interpretation may lead to the \ncontinued development of TMDLs that may not be necessary. This last \npoint may be mitigated by requiring a full reevaluation of listings as the \nfirst step in TMDL development. \nRecommendation: Alternative 3. See Policy section 4. Issue 7B: Defining Existing Readily Available Data and Information \nIssue: How should the SWRCB define existing readily available data and \ninformation? \nIssue Description: Federal regulation requires the SWRCB and RWQCBs to assemble and \nconsider all existing readilv available data and information that will be \" \nuseful in determining whether water quality standards are being met (40 \nCFR 130.7). To date, each RWQCB has used its judgement in identifying \nwhich data and information to use in its listing process. \nThe RWQCBs and SWRCB in the process of evaluating whether water \nquality standards are being met have traditionally relied on data and \nreports documenting specific environmental characteristics pertaining to \nthe physical, chemicaiand biological conditions of each RWQCBS water \nbodies and watershed systems. The data and information reviewed has \nconsisted of subrnittalsas a result of the RWQCBs and SWRCB \nsolicitation, selected data possessed by the RWQCBs and the SWRCB, \nand other sources. \nBaseline: During the 2002 section 303(d) listing process, the RWQCB and SWRCB \nsolicited all data and information from state and federal agencies and from \nthe public to support updates of the section 303(d) list. \nAlternatives: 1. Onlv s~ecifv the possible sources of data and information; do not specify \nthe maior types of data. Sources of existing and readily available \ninformation could include all data and information from federal, state, \nregional and local agencies, institutions, environmental and volunteer \ngroups, private and public organizations, watershed groups, regulated \ndischargers, and private individuals. Data from SWAMP as well as other \nstatewide ambient monitoring programs implementing appropriate QAPPs \ncould also be used. \nThe advantage of this alternative is that the RWQCBs and SWRCB are not \nburdened with evaluating reports that may not yield any new or \nunassessed data and information. The disadvantage is there may be \ninconsistencies in the amounts and types of information used in the listing \nprocess. \n2. Specifv the tvpes of data and information that will be solicited by the SWRCB Under this alternative the RWQCBs would be \nrequired to seview a set number of data and information sources. These \nsources of readily available data and information could include all data \nand information, preferably on paper or in electronic form, and from all \navailable sources but at a minimum include: + The most recent CWA section 303(d) list; \n+ \tThe most recent CWA section 305(b) report; \n+ \tThe most recent drinking water source assessments; \n+ \tMunicipal Separate Storm Sewer System (MS4) monitoring reports; \n+ \tInformation on water quality problems in documents prepared to \nsatisfy Superfund and Resource Conservation and Recovery Act \nrequirements; \n+ \tData and information regarding fish and shellfish advisories, beach \npostings and closures, or other water quality-based restrictions; \n+ \tReports regarding fish kills, cancers, lesions or tumors; \n+ \tDilution calculations, trend analyses, or predictive models for \nassessing the physical, chemical, or biological condition of streams, \nrivers, lakes, reservoirs, estuaries, coastal lagoons, or the ocean. \n+ \tWater quality data and information from SWAMP or any other \nambient monitoring programs; \n+ \tData and information documenting water quality problems; and \n+ \tExisting and readily available water quality data and information \nreported by regional, local, state and federal agencies (including \ndischarger-monitoring reports); citizen monitoring groups; academic \ninstitutions; and the public. Federal agencies would be actively \nsolicited. These agencies could include: U.S. Department of \nAgriculture, NOAA, and U.S. Fish and Wildlife Service. \nThe disadvantage of this alternative is that RWQCBs and the SWRCB \nwould be required to review reports that may not yield any new or \nunassessed data and information. \nThis alternative represents the preferred alternative because \ninconsistencies or questions about the amounts and types of information \nused in the listing process would be reduced. \nRecommendation: Alternative 2. See Policy section 6.1.1. Issue 7C: \t Process for Soliciting Data and Information and Approval of the List \nIssue: \t How should the SWRCB and the RWQCBs solicit readily available data \nand information and approve the CWA section 303(d) list? \nIssue Description: \t Assembling all existing and readily available data and information is \ncentral in developing and revising the section 303(d) list. The RWQCBs \nhave access to a number of sources of data. However, many federal, state, \nand local agencies, as well as the interested public, may have data and \ninformation that could be useful in developing the section 303(d) list. In \nthe past, each listing cycle was initiated by the RWQCBs by soliciting \ninterested parties for any readily available data and information regarding \nthe water quality conditions in the surface waters of each region. This has \nbeen traditionally accomplished through public notices and local \nnewspaper ads and letters from the RWQCBs to interested parties. \nAfter existing data and information have been evaluated the approval \nprocess is initiated. Through a series of public hearings, each RWQCB \nassembles and approves a recommended section 303(d) list for submittal \nto the SWRCB. Subsequently, the SWRCB carries out a final review of \nthe candidate regional lists and assembles a statewide list for final \napproval and submittal to USEPA. The final approval of the statewide list \nis accomplished through several public hearings, workshops and a board \nmeeting where the final statewide CWA section 303(d) list is approved. \nBaseline: \t For the 1998 section 303(d) list, SWRCB and the RWQCBs staff prepared \nguidance for the water quality assessment update for reviewing new \nmonitoring information, soliciting information from state and federal \nagencies, and inviting the public to participate. RWQCBs' staff used the \nguidelines as the basis for the 1998 listing and delisting of water bodies, \nprioritizing and scheduling TMDLs, and public noticing procedures. \nThe development of the 2002 section 303(d) list was initiated by the \nRWQCBs request for readily available data and information in \nMarch 2001. After review of the data and information gathered. each \" \nRWQCB compiled their own list of water quality limited segment \nrecommendations for submittal to the SWRCB. Each RWQCB submitted \nstaff reports and lists to SWRCB, along with copies of public submittals, \ndata and information, and documents referenced in the submittal. All \ndocuments were made available in the administrative record for public \ncomment. \nIn May 2002, the SWRCB initiated a second data and information \nsolicitation. The SWRCB staff reviewed the RWQCBs recommendations \nand developed fact sheets for each proposal to add water bodies, delete \nwater bodies, andlor change the section 303(d) list. The 1998 section 303(d) list served as the basis for the 2002 section 303(d) list. \nListings from 1998 were not reviewed or evaluated, nor were fact sheets \ndeveloped unless new data was submitted. \nBeyond the general information solicitation, state and federal agencies \nsuch as DF~, DHS, the National Marine Fishery Service (NMFs), and \nUSGS were solicited for anv new information. The SWRCB held three \npublic hearings, a workshop, and Board meeting. \nAlternatives: 1. Only the RWOCBs should solicit readily available data and information \nand manaxe the avvroval process for section 303(d) listing \nrecommendations. The RWQCBs would initiate the listing process by \nsoliciting all readily available information. The data and information \nrequest would cover all new and current information regarding water \nquality conditions of a water body or watershed, within the boundary of a \nparticular region, since the last listing. The readily available data and \ninformation would consist of any data andlor written reports documenting \nspecific environmental characteristics pertaining to the physical, chemical, \nand biological conditions of the region's water bodies and watershed \nsystems. This would be the only data and information solicitation during \nthe listing process. \nFor the approval process, each RWQCB would develop a section 303(d) \nlist and be responsible for holding public hearings to consider each \nproposed water body. After receiving testimony, each RWQCB would \ndevelop responses to all comments on the lists from the public and \napprove recommendations for each list. After, each RWQCB has \napproved their lists; they would submit them to the SWRCB. The SWRCB \nwould assemble and approve the final section 303(d) list without review or \nchange to any RWQCB recommendation. Once the final section 303(d) \nlist has been approved by the SWRCB, the section 303(d) list would be \nsubmitted to USEPA for approval. \nUnder this alternative, the RWQCBs will hold primary responsibility in \nmaking water body-pollutant recommendations pertaining to the \nsection 303(d) list. This procedure has been conducted in the past and has \nlead to many inconsistencies in interpreting the data statewide. \n2 \tOnly the SWRCB should solicit readilv available data and information for \nlisting recommendations for transmittal to the RWOCBs and manage the \nlist approval process. The SWRCB would initiate the listing process by \nsoliciting all readily available data and information by following the \nprocedures outlined in Alternative 1. Once the data was received, it would \nbe sent to the RWQCBs. The major disadvantage of this alternative would \nbe that much data and information available to the RWQCBs would not be available to the SWRCB and, therefore, would not be included in the \nadministrative record. \nOnce the RWQCBs received the data and information sent by the \nSWRCB, fact sheets would be assembled with the pertinent information \nfor each potential water body-pollutant combination. All RWQCB- \nprepared fact sheets would be subsequently sent to the SWRCB for review \nand evaluation. The SWRCB would make recommendations for each \nwater body-pollutant combination and assemble the statewide lists. The \nSWRCB would hold public hearings and workshops to hear testimony \nfrom the public. Written responses to public comments would be \naddressed by the SWRCB. The SWRCB would approve the list and \nsubmit the section 303(d) list to USEPA for approval. \nUnder this alternative, the RWQCBs would be limited in their \nparticipation in the section 303(d) listing process. The RWQCBs would \nonly participate in assembling fact sheets and not participate in the \nrecommendation process. Input from the RWQCBs is critical in the listing \nrecommendation process, because they are the experts in their regions in \nregards to the condition of their water bodies. Without the RWQCBs \nexpertise, the likelihood of making an inappropriate decision could be \npotentially high. \n3. Both the SWRCB and RWOCBs would issue a combined data and \ninformation solicitation and manage the avproval process. Under this \nalternative, both the SWRCB and RWQCBs would initiate the listing \nprocess by simultaneously actively soliciting all readily available data and \nassessment information on the quality of the surface waters of the state. \nIn general, readily available data and information should include \ninformation from any interested party, including but not limited to: private \ncitizens; public agencies; State and federal governmental agencies; non- \nprofit organizations; and businesses possessing data and information \nregarding the quality of a region's waters. The solicitation would focus on \nabsolutely all data and information that might be available. The Boards \nmay place emphasis on recent data and information generated since the \nlast listing. Readily available data and information would consist of any \ndata and information in electronic andfor written reports documenting \nspecific environmental characteristics pertaining to the physical, chemical \nand biological conditions of a region's water bodies and watershed \nsystems. \nThis alternative provides the best combination of regional and statewide \ndata solicitation. Each RWQCB would focus on locating data and \ninformation for its region without the burden of soliciting information from agencies that may be statewide in scope. Data from state and federal \nagencies would be more efficiently solicited by the SWRCB. \nInformation solicited should contain the following: \n4 \tThe name of the person or organization providing the information; \n4 \tThe name of the person certifying the completeness and accuracy of \nthe data and information and a statement describing the standards \nexceedance; \n4 \tMailing address, telephone numbers, and email address of a contact \nperson for the information provided; \n4 \tA paper copy and an electronic copy of all information provided. The \nsubmittal must specify the software used to format the information and \nprovide definitions for any codes or abbreviations used; \n4 \tBibliographic citations for all information provided; and \n4 \tIf computer model outputs are included in the information, provide \nbibliographic citations and specify any calibration and quality \nassurance information available for the model(s) used. \nData solicited should contain the following: \n4 \tData in electronic form, in spreadsheet, database, or ASCII formats. \nThe submittal should use the SWAMP data format and should define \nany codes or abbreviations used in the database. \n4 \tMetadata for the field data, i.e., when measurements were taken, \nlocations, number of samples, detection limits, and other relevant \nfactors. \n4 \tMetadata for any GIs data must be included. The metadata must \ndetail all the parameters of the projection, including datum. \n4 A copy of the quality assurance procedures. \n4 A paper copy of the data. \n4 Data from citizen volunteer water quality monitoring efforts require \nthe name of the group and indication of any training in water quality \nassessment completed by members of the group. Data submitted by \ncitizen monitoring groups should meet the data quality assurance \nprocedures as detailed in section 6.1.4. \n4 \tFor photographic documentation, adhere to the guidelines detailed in \nsection 6.1.4. \nThe RWQCBs would evaluate all readily available data and information. \nThey would assemble fact sheets with the pertinent information for each \npotential water body-pollutant combination. Public hearings would be held \nby RWQCBs to consider each proposed listing decision. The RWQCBs \nwould provide written response to comments. The RWQCB would \napprove all recommendations for the section 303(d) list. Each RWQCB would submit to the SWRCB, all fact sheets along with a copy of the \nsupportive documentation (e.g., data and information) for the \nrecommendation, and all documentation and response to comments \npresented during the hearing process. \nThe SWRCB would review each RWQCBs water body fact sheet and \nrecommendation to ensure that the Policy guidelines were followed. After \nreview of the fact sheets and documentation, the SWRCB would add their \nrecommendation to each water body fact sheet for the section 303(d) list. \nThe section 303(d) list would then be made available to the public for \nreview and comment. The SWRCB would hold workshops to consider all \ntestimony presented by the public. The SWRCB would provide written \nresponses to comments from the public and approve the list at a SWRCB \nmeeting. Subsequent to SWRCB approval, the section 303(d) list would \nbe submitted to USEPA for approval as required by the CWA. The \nsupporting water body fact sheets would also be sent to USEPA as \ndocumentation of the recommendations for the section 303(d) list. \nRWQCBs should consider the listing recommendations at workshops or \nhearings. This would provide an opportunity for the public to give \ncomments on decisions and the RWQCB the opportunity to respond to \nthose comments. This would allow RWQCBs to address contentious \nissues before they reach the SWRCB. A second review of each RWQCB \nfact sheet recommendation by the SWRCB would provide consistency in \nthe listing recommendations statewide. \nThis alternative is the preferred alternative because it would allow for \nmore consistency in the development of the section 303(d) list. \nRecommendation: Alternative 3. See Policy section 6.1.2.1,6.2, and 6.3. Issue 70: Documentation of Data and Information \nIssue: How should data and information be documented? \nIssue Description: Evaluation of data and information for the listing of waters on the \nsection 303(d) list is often complex. For listing decisions to be transparent, \nthe assessment of data and information should be documented using a \nconsistent format that allows the RWQCBs, SWRCB, and the public to \nunderstand the reasons for the proposed listings. \nDocumentation of proposed listings has varied widely. Some RWQCBs \nprepare fact sheets that support each listing proposal, while other \nRWQCBs summarize the rationale for listing in staff reports. The \ninformation provided to the SWRCB from the RWQCBs has varied \nconsiderably in content and format. \nBaseline: For the 2002 303(d) list, SWRCB staff developed fact sheets for each \nwater body and pollutant recommended by the RWQCBs for the \nsection 303(d) list. All pertinent information needed to make the listing \ndecision was outlined on each fact sheet. \nAlternatives: 1. Each RWOCB should be allowed to document their recommendations in a \nmanner that thev choose. This alternative represents the status quo. \nRWQCB staff assembles the analysis of data and information in a manner \nthat best informs each RWQCB of the recommendations for placement on \nthe section 303(d) list. One advantage of this approach is that each \nRWQCB could tailor the documentation of their recommendations to the \nstaff resources that are currently available. This approach would also \nlikely result in no or minimal changes in RWQCB workload. The major \ndisadvantage is that it would be difficult for the SWRCB staff to assemble \nthe needed information in a consistent manner. \n2. Use a standard format for the documentation of data and information. \nUnder this alternative RWQCB would be required to submit summaries of \nthe data and information used to support recommendations for the listing \nand delisting of waters in the categories recommended for the \nsection 303(d) list. Depending on the amount of documentation, the \ndevelopment of fact sheets for each water segment and pollutant may \nincrease the workload of the RWQCB and SWRCB staff. To minimize \npotential impacts on staff resources, fact sheets should only be prepared in \ncircumstances where data and information are available. If the data show \nthat standards are met, individual water body fact sheets could be used to \nsummarize data for the many pollutants that meet standards. \nThe fact sheets should contain the following summary information: A. Region \nB. Type of water body (bay and harbors, coastal shoreline, estuary, \nlakelreservoir, ocean, riverslstream, saline lake, tidal wetlands, \nfreshwater wedand) \nC. Name of water body segment (including Calwater watershed) \nD. Pollutant or type of pollution that appears to be responsible for \nstandards exceedance \nE. Medium (water, sediment, tissue, habitat, etc.) \nF. Water quality standards (copy applicable water quality standard, \nobjective, or criterion from appropriate plan or regulation) including: \n1. Beneficial use affected \n2. Numeric water quality objectivelwater quality criteria plus metric \nsingle value threshold, mean, median, etc.) or narrative water \nquality objective plus guideline(s) used to interpret attainment or \nnon-attainment \n3. Antidegradation considerations (if applicable to situation) \n4. Any other provision of the standard used \nG. Brief Watershed Description (e.g., land use, precipitation patterns, or \nother factors considered in the assessment) \nH. Summary of data and or information \n1. Spatial representation, area that beneficial use is affected or \ndetermined to be supported, including a map, any site specific \ninformation, and reference condition. \n2. Temporal representation \n3. \tAge of data and or information \n4. Effect of seasonality and events/conditions that might influence data \nandlor information evaluation (e.g., storms, flow conditions, \nlaboratory data qualifiers, etc.) \n5. \tNumber of samples or observations \n6. Number of samples or observations exceeding guideline or standard \n7. Source of or reference for data andlor information \nI. For numeric data include: \n1. \tQuality assurance assessment \nJ. For non-numeric data include: \n1. Types of observations \n2. Perspective on magnitude of problem \n3. Numeric indices derived from qualitative data \nK. \tPotential source of pollutant or pollution (the source category should \nbe identified as specifically as possible) \nL. Program(s) addressing the problem, if known and any conditions of the \nenforceable program list met \nM. Data evaluation as required by sections 3 or 4 of the Policy \nN. Recommendation \n0.TMDL schedule (developed only for the section 303(d) list as required \nby section 5 of the Policy). This alternative is the preferred alternative because it provides a means to \nadequately document the data quality, guideline selection, and data \nquantity processes required by the Policy. \nRecommendation: Alternative 2. See Policy section 6.1.2.2. Issue 7E: \t Data Quality Requirements \nIssue: \t What data quality should be required? \nIssue Description: \t A wide range of data has been used for section 303(d) listing and delisting \nof water bodies. Knowing the quality of data is essential in determining \nthe strength of the recommendation to list a water body. \nThe quality of the data used in the development of the section 303(d) list \nshould be of sufficient high quality to determine water quality standards \nattainment. Quantitative data are of little use unless accompanied by \ndescriptions of sample collection, the analytical methods used, Quality \nControl (QC) protocols, and the degree to which data quality requirements \nare met. \nQuality Assurance (QA) is an integrated system of management activities \ninvolving planning, implementation, documentation, assessment, \nreporting, and quality improvement to ensure that a process, item, or \nservice is.of the type and quality needed and expected. QA consists of two \nseparate but interrelated activities: QC and quality assessment. QC refers \nto the technical activities employed to ensure that the data collected are \nadequate, given the monitoring objectives to be tested. Quality \nAssessment activities are implemented to quantify the effectiveness of the \nQC procedures. QC is the overall system of technical procedures that \nmeasure the attributes and performance of a process, item, or service \nagainst defined standards. \nTo ensure that high quality data is produced in monitoring efforts, \nprovisions are described in a Quality Assurance Project Plan (QAPP). A \nQAPP describes in comprehensive detail the necessary QA, QC, and other \ntechnical activities that must be implemented to ensure that the results of \nthe work performed satisfy the stated performance criteria. \nBaseline: \t In previous section 303(d) listing cycles, a large array of information and \ndata were accepted. The quality of the data and information used was \ngenerally unknown. In 2002, if the RWQCB provided information on the \nquality of the data, it was recorded in the fact sheet. \nAlternatives: 1. Use all data of any aualitv or of unknown aualitv to make decisions to \nlistldelist waters. Data from major monitoring programs in California are \nconsidered to be of adequate quality. These major programs include \nSWAMP, the Southern California Bight Projects managed by SCCWRP, \nUSEPA EMAP, SFEI-RMP, and the BPTCP. These minitohng \nprograms/organizations follow and adhere to an established QA program. However, there are many organizations, both private and public, that have \nmonitoring programs, but the RWQCBs may not be familiar with the \nquality of their data. Data and information available from organizations \nand/or parties that did not submit data in previous listing cycles must also \nbe considered. If all data and information are used to make listing \ndecisions, the quality of the data needs to be determined to confidently \nmake a judgement as to whether an impairment truly exists. These \nunknowns and/or concerns can be clarified with the development of data \nquality guidelines. \nData without rigorous QC can be useful in combination with high quality \ndata and information. If data collection and analysis is not supported by a \nQAPP, or its equivalent, or if it is not known if the data is supported by a \nQAPP, then the data and information would not be used by itself to \nsupport listing or delisting of a water segment. These data would only be \nused to corroborate other data and information with an appropriate QAPP. \n2. The SWRCB should vrovide general euidance on the aualitv of data that is \naccevtable for use in the section 303(d) listing vrocess. The development \nof data quality guidelines would bring clarity and transparency to the \nprocess of using available data to determine if a water body segment \nwarrants listing. Even though all data and information will be used, data \nsupported by a QAPP should provide the needed data quality assurance \nthat previous listing cycles lacked. Data that are supported by a QAPP \npursuant to the requirements of 40 CFR 31.45 are acceptable for use in \ndeveloping the section 303(d) list. QAPPs drafted in accordance with the \nprovisions of the SWAMP Quality Management Plan also satisfy this \nrequirement. Additional information about QAPP preparation is available \nfrom USEPA (2002d). If a QAPP is not available it would be also \nacceptable to use available information that is equivalent to the \ninformation contained in a QAPP. \nThe QAPP (or its equivalent) should contain a discussion of the QNQC \npractices associated with the following: \n+ Short description of the monitoring project. \n+ Sample collection program. \n+ Sample preservation and transportation. \n+ Field measurements. \nt Laboratory measurements. \n+ Generated data handling. \n+ Past data selection (if used). \n+ Corrective actions. \n+ Summary report at project end. Data supported by a QAPP andor from the major monitoring programs in \nCalifornia are acceptable for use in developing the section 303(d) list. If a \ndischarger monitoring report has been determined to be adequate for \nassessing compliance with WDRs, no further review of the QAPP is \nnecessary. \nNumeric data are considered credible and relevant for listing purposes if \nthe data set submitted meets the minimum QNQC requirements outlined \nbelow. A QAPP should be available containing, the following elements: \nt Objectives of the study, project, or monitoring program; \nt Methods used for sample collection and handling; \nt Field and laboratory measurement and analysis; \nt Data management, validation, and recordkeeping (including proper \nchain of custody) procedures; \nt Quality assurance and quality control requirements; \nt A statement certifying the adequacy of the QAPP (plus name of person \ncertifying the document; and \nt A description of personnel training. \nA site-specific or project-specific sampling and analysis plan for numeric \ndata should also be available that contains: \nt \tData quality objectives or requirements of the project; \nt \tRationale for the selection of sampling sites, water quality parameters, \nsampling frequency and methods that assure the samples are spatially \nand temoorallv reoresentative of the surface water and reoresentative <\t . \nof conditions within the targeted segment of time of sampling; and \nt Information to support the conclusion that results are reproducible. \nThe RWQCBs should make a determination in the fact sheets on the \navailability of a QAPP or equivalent, adequacy of data collection and \nanalysis practices, and adequacy of the data verification process including \nthe chain of custody, detection limits, holding times, statistical treatment \nof data, precision and bias, etc. If any data quality objectives or \nrequirements in the QAPP are not met the reason for not meeting them and \nthe potential impact on the overall assessment should be clearly \ndocumented because these issues may have a large bearing the usefulness \nof the data. \nData without rigorous QC (such as photographic documentation) could be \nused to corroborate other data and information with an appropriate QAPP \nor if justified as part of the situation-specific weight of evidence. For \nthese narrative and qualitative submittals to be most useful, the submission \nshould: + \tdescribe events or conditions that indicate impacts on water quality; \nt \tprovide linkage between the measurement endpoint (e.g., a study that \nmay have been performed for some other purpose) and the water \nquality standard of interest; \n+ \tbe scientifically defensible; \n+ \tprovide analyst's credentials and training; and \n+ \tbe verifiable by the SWRCB or RWQCB. \nFor photographic documentation, the submission should: \n+ \tidentify the date; \n+ \tmark the location on a general area map; \n+ \teither mark the location on a USGS 7.5 minute quad map along with \nquad sheet name or provide location latitudeflongitude; \n+ \tprovide a thorough description of the photograph(s); \n+ \tdescribe the spatial and temporal representation of the photographs; \n+ \tprovide the linkage between a photograph-represented condition and a \ncondition that indicates an impact on water quality; \n+ \tprovide the photographer's rationale for the area photographed and \ncamera settings utilized; and be verifiable by SWRCB and RWQCB. \nThis altemative is the preferred alternative because it includes procedures \nto ensure that data collected are of adequate quality to make decisions to \nplace or remove waters from the section 303(d) list. \nRecommendation: Alternative 2. See Policy section 6.1.4. Issue 7F: \t Spatial and Temporal Representation \nIssue: \t How should spatial and temporal characteristics of the water bodies be \naddressed by the Policy? \nIssue Description: \t Water quality assessment includes monitoring to define the condition of \nthe water body, detect trends, and provide information to establish cause \nand effect relationships. Important aspects of an assessment are the \ninterpretation and reporting of monitoring results and recommendations \nfor future actions. One of the main components in the assessment of water \nquality is spatial and temporal representation of the water body segment. \nIn California, there are many water body types (e.g., lakes, rivers, coastal, \nestuaries and bay,) with varying degrees of climatic, geologic andor \ngeographic characteristics where pollutants (natural or unnatural) can have \nwidely different effects on the aquatic and ecological environment. In \naddition, physical conditions (e.g., flow patterns, flow rate, depth, \ncurrents, storm event, wind, temperature, sunlight, etc.) can vary widely \nwithin a water body, as well as from one water body to the next. When \ncollecting data and information from a water body, one needs to consider \nwhether the data and information is representative of the water body \nsegment during the assessment period. \nBaseline: \t In previous section 303(d) listing cycles, spatial and temporal \nrepresentation were considered on a case-by-case basis. \nAlternatives: 1. \tRWOCBs should intemret spatial and temporal data on a case-by-case \nbasis. Under this alternative, the RWQCBs would have significant \nflexibility in considering spatial and temporal factors in e;aluating data for \na water body segment. \nThe advantage of this alternative is the RWQCBs would be able to \nconsider the various kinds of physical conditions in the assessment of \nwater body. A disadvantage is that the lack of general guidance could lead \nto inconsistencies among RWQCBs, depending on the expertise and \nexperience of the staff preparing the water body listing assessment. \n2. The Policv should establish specific guidance in considering spatial and \ntemporal representation in the evaluation of data and information. \nSpecific guidelines would be outlined in the Policy to consider spatial and \ntemporal factors in evaluating data from the water body segment. One \nadvantage is that more specific guidance could lead to greater consistency \namong RWQCBs. \n3. The Policy should establish general guidance when considering spatial and \ntemporal representation in the evaluation of data and information. Under this alternative, the Policy would provide general guidance on evaluating \ndata so that it is spatially and temporally representative of a water \nsegment. The general guidance could focus on those factors that are \nnecessary to meet the minimal assumptions of virtually any statistical test, \nnamely that the sampling be temporally and spatially independent and that \nsampling is random (in the sense that the measurements are not biased). \nTo the extent possible, all samples used in the listing process should \nstatistically represent the segment of the water body or collected in a \nconsistent targeted manner that represents the segment of the water body. \nIn order to limit spatial dependence of samples, measurements collected \nwithin 200 meters of each other shall be considered the same station or \nlocation. This value is used by other states to represent a small water \nsegment (e.g., Florida DEP, 2002). However, samples less than \n200 meters apart may be considered to be spatially independent samples \nbut these findings should be justified in the water body fact sheet. \nSamples from mixing zones should not be included as part of the data set \nbecause, in these areas, standards are allowed to be exceeded for short \nperiods of time. \nSamples should also be temporally representative of characteristics of the \nwater body. For example, measurements used in the section 303(d) \nassessment should be temporally independent to satisfy the requirements \nof most statistical tests. If the majority of samples were collected on a \nsingle day or during a single short-term natural event (e.g., a storm, flood, \nand wildfire), the data should not be used as the primary data set \nsupporting the listing. \nIn general, to make sure standards exceedances are recurrent, \nmeasurements should be available from two or more seasons or from two \nor more events when effects or water quality objectives exceedances \nwould be clearly manifested. Sampling representation can be either over \nshort or long periods of time or can be from multiple sources; in either \ncase, the measurements should be combined. Measurements from \nephemeral waters, during a specific season, or during human-caused \nevents (except spills) should also be used to assess significant pollutant- \nrelated exceedances of water quality standards. Timing of the sampling \nshould include the time of day in which the sample was taken and the \ncritical season for the pollutant and applicable water quality standard, to \nthe extent possible. To be transparent, the water quality fact sheet should \ndescribe the significance of the sample timing. \nWater body specific information should also be reported when assessing \nthe spatial and temporal representativeness of the available measurements. \nOne of the most important factors is that listing decisions are supported by actual data from the segment. While this may be self-evident, there have \nbeen circumstances when waters with no monitoring data were listed \nbecause they had the same visual characteristics, as other waters with \nmonitoring data that showed standards were not met. To avoid these \nsituations, data used to assess water quality standards attainment should be \nactual data that can be quantified and qualified. Information that is \ndescriptive, estimated, modeled, or projected should only be used as \nancillary lines of evidence for listing or delisting decisions. At a \nminimum, data should be measured at one or more sites in a water \nsegment to justify listing the water. \nIf applicable information is available, environmental conditions in a water \nbody or at a site should also be taken into consideration. Water quality is \naffected greatly by season, events such as storms, the occurrence of \nwildfires, land use practices, etc. In addition, there are a variety of factors \nthat affect measurements of water quality conditions including: (1) depth \nof water quality measurements, (2) flow, (3) hardness, (4) pH, (5) the \nextent of tidal influence (if coastal), and (5) other relevant sample- and \nwater body-specific factors. Information related to these factors should be \nincluded in the fact sheet if it is available so interested parties can more \nclearly understand their influence. \nThis alternative is the preferred alternative because it would provide \ngeneral statewide consistency in evaluating spatial and temporal \nrepresentation of water body segments. Another advantage is that \nRWQCB would still have considerable flexibility to use professional \njudgement in assessing what the available data and information represent. \nRecommendation: \t Alternative 3. See Policy sections 6.1.2.2,6.1.4,6.1.5,6.1.5.1,6.1.5.2, \nand 6.1.5.3. Issue 7G: Data Age Requirement \nIssue: Should older data be used to support decisions to place or remove waters \nfrom the section 303(d) list? \nIssue Description: An underlying assumption of the listing process is that the data and \ninformation assessments represent current conditions in States waters. If \nvery old data are used to make assessments, it is possible that the data do \nnot represent current water quality conditions. Another confounding \nfactor is that as sampling and analysis methods improve, older data may \nbe less relevant or not comparable to newer data and information. \nFor each data set, RWQCBs and SWRCB must determine how much of \nthe data collected is relevant to the decision to list or not list the water \nbody. If data are representative, it is likely that the decision will be correct. \nUnrepresentative data will likely result in incorrectly placing or not \nplacing a water body segment on the section 303(d) list. This could result \nin the unnecessary expenditure of public resources or missing a problem \ncompletely. \nMany states require that the data and information used to justify a listing \ndecision be reasonably current, credible, and scientifically defensible. The \nrange of older data allowed in these programs is generally from 5 to \n10 years. \nBaseline: All data and information of any age were used in the development of the \n2002 section 303(d) list. \nAlternatives: 1. Establish guidance on the age of data acceptable for listing. Under this \nalternative, the Policy would provide general guidance on the age of the \ndata used in the listing decisions in order to provide some assurance that \nthe data used are reasonably representative of water quality conditions. \nSome states use data and information that is no more than five years old, \nwith older data being used on a case-by-case basis (e.g., Arizona); while \nothers allow for older data to be used (e.g., Florida allows data to be \n7.5 years old). As with California, some states use any available data and \ninformation because little data or information is available on many state \nwaters. \nA disadvantage of requiring the use of recent data only is that some data \ntakes years to make its way through the peer review process and the \nresults may not be available until the age requirement has past. For \nexample, peer review and reporting of USGS data may take years to get \nthrough the review process. If data age requirements were too short otherwise high quality data would not be available to be used in the \nsection 303(d) process. \nGeneral guidelines could be provided in the Policy on the age of the data \nbut the RWQCBs should have flexibility in determining the circumstances \nof when to include older data and information. When reviewing the data \n(both newer and older), the RWQCBs should take into consideration \ntemporal factors that could assist in determining whether the water quality \nproblem is persistent or recurrent. Seasonal or year-to-year variations in \nthe transport of the pollutant should be considered when reviewing the \ndata and information. \nGenerally, listing decisions could be limited to using only the most recent \nten-year period of data and information for water chemistry and sediment \nchemistry information. Data older than ten years would then only be used \non a case-by-case basis. Older data could be used in conjunction with \nnewer data, to demonstrate trends or if the conditions in the water body \nhave not changed. In the interest of making listing decisions transparent, \nthe reason(s) for using older data could be described in the water body fact \n' sheet. In any case, older data should meet all data quality requirements \npresented in the Policy. \n2. Use data and information, regardless of age, to determine which data \nshould be used in the section 303(d) list assessments. The use of all data \nand information, regardless of age, ensures that alI readily available data \nand information is used. However, older data may not represent current \nwater quality conditions or may reflect the result of less precise laboratory \nanalytical procedures. Under this alternative, no preference is given to \ncurrent information so older, perhaps unrepresentative, data may bias the \ndecision-making process. \nOlder possibly unrepresentative data could identify a water body segment \nas not meeting standards, when standards are in fact met, or may identify a \nwater body segment as meeting standards, when in fact, standards are not \nmet. \nUsing older data and information can provide context for newer data, such \nas characterizing trends or checking for compliance with antidegradation \nprovisions, provided precautions are taken to avoid inappropriate \ninterpretation of the data. Older data can be used to represent current \nconditions if it can be established that the water body has not changed \nover time. Conversely, if data are available before and after a change in \nthe water body setting (e.g., a cleanup has been implemented or new \npermit conditions exist), it may be appropriate to base assessments on only \nthe most recent data. Older data may be very useful in reevaluating \nprevious listing decisions if guidelines or numeric objectives are enacted Recommendation: or revised subsequent to the previous listing cycle and reassessment based \non those data yield different findings of attainment of water quality \nstandards. \nIf the Policy allows the use of all data, whatever the age, it becomes \nincumbent upon the RWQCBs to use their judgement to assess the \nreliability and quality of the data. All data should meet the data quality and \nquantity requirements as specified in the Policy. \nThis alternative represents the preferred alternative because all data and \ninformation should be used to make section 303(d) listing decisions. If \nolder data are all that is available it should be used to decide if the water \nshould be listed or delisted. \nAlternative 2. Issue 7H: \t Determining Water Body Segmentation \nIssue: \t How should water body segments be identified? \nIssue Description: \t Basin Plans list water bodies within each region and establish water \nquality objectives to protect beneficial uses from degradation. In some \ninstances, beneficial uses and water quality objectives apply to entire \nhydrologic units or areas; in other cases, Basin Plans identify water bodies \nindividually by name, dividing some rivers into segments. For each \nwatershed, water body and segment, beneficial uses are designated. In \nsome Basin Plans, assigned beneficial uses of an identified water body are \nextended to all of its unlisted tributaries. \nIn developing the section 303(d) list, the evaluation of available data \ndetermines whether exceedances of water quality standards have occurred. \nInformation on monitoring strategy, number of samples and the spatial \nrepresentation of the samples determine the extent of the water quality \nimpact within the water body. Together, this information determines if \nwater quality impacts extend to whole watersheds, specific tributaries, \nwhole water bodies, or specific sub-segments of a water body. \nIn order to make credible decisions about the extent of the water quality \nlimited segment, a balance is needed between: (1)considering all grab \nsamples to be representative of merely the cubic foot of water from which \nthey were taken, and (2) assuming each grab sample is representative of \nconditions over hundreds of stream miles or thousands of lake acres \n(USEPA, 2003b). \nBaseline: \t Identification of water quality limited segments during previous \nsection 303(d) listing cycles varied between RWQCBs. Generally, \nRWQCBs based their listings on their Basin Plan surface water \nsegmentation classifications by either listing according to hydrologic unit, \narea, and sub-area or by listing on the basis of water body type and name. \nSome RWQCBs added water body segments not identified in Basin Plans. \nOther RWQCBs established listings throughout watersheds even if the \ndata indicated only a portion of the water body or segment was impacted. \nAlternatives: 1. Use adopted Basin Plan water bodv listings to determine where water \naualitv standards are not beinv met. Allow identification of new segments \nif warranted. Under this alternative, RWQCBs would list water bodies or \nsegments in accordance with the segmentation approach used in the Basin \nPlans but would be allowed to further divide waters if warranted. In the \nabsence of an adequate segmentation system, the RWQCBs would be \nencouraged to use professional judgement to define distinct reaches based \non hydrology (e.g., stream order, tributaries, dams, or channel \ncharacteristics) and relatively homogeneous land use. If available data suggest that a pollutant may cause an excursion above a \nwater quality objective, the RWQCB should, if the information are readily \navailable, identify land uses, subwatersheds, tributaries, or dischargers that \ncould be contributing the pollutant to the water body. The RWQCBs \nwould be encouraged to identify stream reaches or lakelestuary areas that \nmay have different pollutant levels based on significant differences in land \nuse, tributary inflow, or discharge input. Based on these evaluations of the \nwater body setting, RWQCBs would aggregate the data by appropriate \nreach or area. \nAnother important factor is the area impacted in each segment. While \nCWA section 303(d) and associated federal regulations do not require \nestimation of the extent of the impacted water segment, this information is \nuseful in determining the scale of the reported standards exceedance in the \nwater quality limited segment. The length or area of estimated impact \nshould be based on the data used to establish the listing and the extent \nshould be limited to the length or area represented by these data. \nConsequently, water segments should not be placed on the section 303(d) \nlist unless data support this finding. Data should be measured at one or \nmore sites in the water segment &order to place the water body on the \nsection 303(d) list. Segments should only be placed on the list if the listing \nis backed by data. \nThis would reduce controversies regarding extent (miles or acres) \nestimates where impairment may be occurring because the data would be \nevaluated in the context of the measurements or samples, land use, and \nnature of the pollutant source. \nThis alternative is the preferred alternative because by establishing \nsegments in this way, confusion would be avoided regarding applicable \ndesignated beneficial uses, the name of the segment, and the size and \nboundaries of the affected segment. \n2. List entire segments or watersheds if anv data in the watershed show \nim~acts. The primary purpose of listing water bodies under section 303(d) \nis to identify water body segments within a region where water quality \nstandards are not met. If waters are found to not meet standards in one \npart of a watershed it is possible that other parts of the watershed are \nsimilarly impacted. A conservative approach would be to list all segments \nof a watershed, even if data are available showing a small part of the \nwatershed is impacted. \nUsing watershed classification to list water bodies for designating \nbeneficial uses and water quality objectives might provide broad \n comprehensive protection to the waters within each RWQCBs jurisdiction. \nBroad protection of water quality was originally generated by the CWC \nsection 13240 that requires RWQCBs to \"adopt water quality control plans \nfor all areas within the region.\" [emphasis added], and is buttressed by an \ninterpretation of the definition of waters of the United States to mean that \nthe standards of tributary waters are at least as stringent as the standards \nestablished for the waters to which they are tributary. When the Basin \nPlans were established, each RWQCB designated beneficial uses for most \nwaters within the region. However, it was not possible to survey the \nbeneficial uses of all waters of the state or even list all waters of the state. \nIn order to provide full protection to unnamed water bodies, the Basin \nPlans typically include a statement which generally applies the beneficial \nuses of any specifically identified water body to all of its tributaries. \nSuch extension of protection of designated beneficial uses to all waters \nwithin a region is appropriate but the application of the same approach \nwhen developing the section 303(d) list is questionable. Identification of \nwater quality limited segments is based on an assessment of site-specific \nmonitoring data that documents a site within a water body segment where \nstandards may not be attained. \nSite-specific data documenting water quality impacts cannot apply to \nentire watersheds unless the monitoring data covers an entire watershed. \nThe extension of documented water quality impacts to entire watersheds \nbecause beneficial uses are deemed applicable to the entire watershed, is \nnot warranted unless it can be shown that the data are representative of the \nentire watershed. \nRecommendation: Alternative 1. See Policy section 6.1.5.4. Issue 71: Natural Sources of Pollutants \nIssue: How should SWRCB address natural sources of pollutants under CWA \nsection 303(d)? \nIssue Description: Basin Plans address water quality problems caused or exacerbated by \nhuman activities. Natural processes can also cause water quality \nproblems, which usually cannot be controlled. Many Basin Plans contain \nlanguage distinguishing between controllable water quality factors that \nresult in degradation of water quality and those factors that are not \ncontrollable. Controllable water quality factors are those actions, \nconditions, and circumstances resilting from human activities that may \ninfluence the quality of the waters of the state and may be reasonably \ncontrolled. ~~con&ollable factors include those conditions caused by \nnatural processes. \nBaseline: During the 2002 section 303(d) listing process, a number of Lahontan \nRWQCB (Region 6)water bodies not meeting water quality standards for \na particular pollutant originating from natural sources were removed from \nthe 303(d) list. \nAlternatives: 1. Place water bodies not meeting water aualitv standards due to natural \nsources on the section 303(d) list. Under this alternative, there would be \nno guidance regarding impacts relative to natural sources. This would \nprovide the RWQCBs with the flexibility to add, remove, or not list waters \ndepending on whether standards are exceeded and without regard to \nsources or types of pollutants. Water bodies recommended for \nsection 303(d) listing in the future or existing listings recommended for \nremoval from the list due to natural sources would require review and \napproval by the SWRCB. \nOnce listed, the water body would be prioritized and scheduled for \npossible TMDL development. This could result in an attempt to control a \npollutant loading originating from a natural uncontrollable source. \nPollutants originating from natural sources are beyond the SWRCB and \nthe RWQCB capabilities to correct. \nThis alternative is the preferred alternative because water quality standards \nwould be interpreted as they exist in plans and regulations and would not \nbe judged relative to the feasibility of TMDL development or source of \npollutants. \n2. \tDo not place water bodies exceedina water aualitv standards due to \nnatural sources on the section 303(d) list. Under this alternative, water \nbodies not meeting water quality standards due to natural sources would \n245 not be listed on the section 303(d) list. Any waters previously listed would \nbe removed from the section 303(d) list during subsequent listing cycles. \nUnder this alternative, it would have to be demonstrated that natural \nconditions or processes cause a segment of a water body to be considered \na water quality limited segment. Documentation must address the natural \nsource(s) of the substance and explain why human causes can be ruled out \nas the cause of the water quality limited segment. Human-caused sources \n(i.e., \"waste\" as defined in CWC section 13050(d) or \"pollution\" as \ndefined in CWC section 13050(1) and 40 CFR 130.2(c)) can generally be \nruled out where the excursions beyond objectives would occur in the \nabsence of the human caused sources. \nFor example, the densities of fecal and total coliform in urban runoff can \ncome from natural and human sources. It is not possible to determine a \nprion without site-specific study if the source is not a result of human \nactivity. Consequently, it is appropriate for these waters to be listed and \nthe portion of the contamination due to natural sources is determined \nduring the development of the TMDL. \nAnother example is metal concentrations in some saline and geothermal \nwaters. Because of its geological history, the Lahontan Region has a \nnumber of water bodies with concentrations of salts andlor toxic trace \nelements such as arsenic, which exceed drinking water standards or \ncriteria for protection of freshwater aquatic life and wildlife. These waters \ninclude inland saline (desert playa) lakes and geothermal springs. Past \nstate and federal guidance led to listing of a number of Lahontan Region \nwaters which are \"impaired only by natural sources. As documented in \nthe 2002 section 303(d) list staff report (SWRCB, 2003a), saline and \ngeothermal waters are unique ecosystems with their own degree of \nphysical, chemical, and biological integrity, and support aquatic life and \nwildlife adapted to extreme environmental conditions. These waters \nshould not be judged as not meeting water quality standards on the basis \nof freshwater aquatic life criteria. \nFor the above reasons, water body-pollutant combinations would not be \nplaced on the section 303(d) list if the excursion beyond standards occurs \nin the absence of any human-caused sources. Even though standards are \nnot met in this instance, a TMDL is not required. \nWaters could be recommended for listing even though a portion of the \nidentified pollutant(s) are probably of natural origin because there is a \nhigh potential for human-caused sources to contribute to the excursion \nabove standards. \nRecommendation: A1 ternative 1. Issue 8: Priority Ranking and TMDL Completion Schedule \nIssue: How should priority ranking and TMDL scheduling be established for \nwater quality limited segments? \nIssue Description: CWA section 303(d) requires that states develop a priority ranking of \nlisted water bodies to assist in guiding TMDL development. Federal \nregulation further requires that the priority ranking specifically include the \nidentification of waters targeted for TMDL development within the next \ntwo years. \nIn 1998, the SWRCB and RWQCB ranked water bodies as high, medium, \nor low priority for TMDL development. A general set of criteria \nassociated with the importance and extent of the beneficial use threatened, \ndegree of impairment, potential for beneficial use recovery, public concern \nand available information was applied. Once priority ranking was \nestablished, TMDL scheduling was based on considerations of available \nresources, watershed management initiative concerns, and attainability of \nthe TMDL schedule. The TMDL development schedule was further \ndivided into three separate categories. Level 1 waters were targeted for \nTMDL development over the next two years; Level 2 waters were targeted \nfor TMDLs to be initiated over the next five years; and Level 3 waters \nwere tentatively scheduled for TMDL completion over a period of \n13 years. As a result of this priority ranking and scheduling approach, not \nall-high priority waters were targeted for TMDL development within two \nyears. \nBaseline: In the 2002 listing process, factors such as importance and extent of \nbeneficial uses threatened, degree of impairment, potential for beneficial \nuse recovery, public concern, and available information were considered. \nHowever, the resources available within the next two years were used to \ndetermine if a water body should be ranked as high priority for TMDL \ndevelopment. The approach taken during the 2002 listing process linked \npriority ranking with TMDL development schedules. Subsequently all \nwaters determined to be high priority were also scheduled for TMDL \ndevelopment within the next two years. \nAlternatives: 1. Do not include a vrioritv and schedule setting method in the Policv. \nUnder this alternative, each RWQCB would be allowed to establish \npriority and schedules for TMDL development depending on their needs, \npriorities, and resource availability and not necessarily in accordance with \nthe water body priority ranking. There would be no link between priority \nof the water, as far as severity of impact to beneficial uses or the \nsignificance of the water body, and the need to develop a TMDL to \nachieve improvements in water quality. Therefore, water bodies with a \n247 high priority ranking may not necessarily be scheduled for TMDL \ndevelopment. \n2. Use general ~rioritizing and TMDL schedule setting factors used bv the \nSWRCB in the 2002 listing Drocess. Under this alternative water quality \nlimited segments would be priority ranked and scheduled for TMDL \ndevelopment based on the following considerations: \n+ Resource availability; \n+ What is achievable within the next two years; \n+ The importance and extent of the beneficial uses threatened; \n+ Degree of impairment; \n+ Potential for beneficial use recovery; \n+ Public concern; and \n+ Available information. \nBy considering these issues, a link is established between priority setting \nand TMDL scheduling. This allows only those waters ranked high priority \nto be scheduled for TMDL development within the next two years. \n3. Establish a schedule for TMDL completion without prioritizing. water \nbodies according to the severitv of the impacts. the significance of the \nwater bodv, and the need to develov a TMDL. CWA section 303(d) \nrequires the establishment of a priority ranking for waters identified for \nTMDL development. However, in recent guidance, USEPA (2003b) has \nstated that the development of such priorities and schedules should be as \npractical and expeditious as possible. Thus, USEPA has indicated that \nlisted waters do not need to be classified as high, medium, or low priority \nand suggested that the established TMDL schedule, in and by itself, could \nreflect TMDL priority ranking. \nUnder this alternative, a schedule would be established for waters on the \nsection 303(d) list that would identify TMDLs that will be developed \nwithin the current listing cycle and the number of TMDLs scheduled to be \ndeveloped thereafter. The schedule would reflect the State's priority \nranking. Based on factors provided by the Supplemental Report of the \n2001 Budget Act, each RWQCB would use their professional judgement \nto determine when TMDLs are scheduled for completion. It would not be \nnecessary to identify each TMDL as a high, medium, or low priority as \nlong as a schedule is established. The Policy would identify TMDLs \nscheduled for development as required by federal law and regulation \n(currently federal regulation requires a schedule for developing TMDLs in \nthe next two-years). Since resource allotments can not be predicted more \nthan one or two years into the future, schedule dates beyond two years \nwould be considered estimates. USEPA guidance (2003b) recommends \nschedules no longer than 8 to 13 years but because resource commitments \n248 cannot be established over such a long period of time, no limit on \ncompletion time frame should be established in the Policy. \nWhen developing the TMDL-completion schedule for waters needing \nTMDLs, RWQCBs should take into consideration factors articulated in the \nSupplemental Report to the 2001 Budget Act related to TMDL priority \nsetting and scheduling. These include but are not limited to the following \ncriteria: \n+ \tWater body significance (such as importance and extent of beneficial \nuses, threatened and endangered species concerns, and size of water \nbody);\n+ \tDegree that water quality objectives are not met or beneficial uses are \nnot attained or threatened (such as the severity of the pollution or \nnumber of pollutants/stressors of concern) 140 CFR 130.7(b)(4)]; \n+ \tDegree of impairment; \n+ \tPotential threat to human health and the environment; \n+ \tWater quality benefits of activities ongoing in the watershed; \n+ \tPotential for beneficial use protection and recovery; \n+ \tDegree of public concern; \n+ \tAvailability of funding; and \n+ \tAvailability of data and information to address the water quality \nproblem. \nAll water bodies on the section 303(d) list should be assigned a TMDL \ndevelopment schedule date. \nThis alternative represents the preferred alternative because it adheres to \nUSEPA guidance that recommends a TMDL schedule without a set \npriority and because it is a reasonable, efficient way to demonstrate \nTMDL priority. \nRecommendation: Alternative 3. See Policy section 5. ENVIRONMENTAL EFFECTS OF THE PROPOSED POLICY \nThis section provides an analysis of the potential adverse environmental \neffects of the adoption of the \"Water Quality Control Policy for \nDeveloping California's Clean Water Act Section 303(d) List.\" \nThe analysis that follows identifies differences between existing RWQCB \nlisting and delisting practices pursuant to CWA section 303(d), the \nproposed Policy, and the potential environmental effects of these \ndifferences. Also, this analysis examines whether adoption of the \nproposed Policy would result in an environmental impact and, if so, does \nthe impact have the potential for significant adverse effects. \nAfter evaluating the potential adverse effects of each issue in the proposed \nPolicy, no issues were found to have the potential for significant adverse \nenvironmental effects. \nBaseline \nThe baseline conditions comprise the existing practices and procedures \ncurrently employed by the SWRCB and the RWQCBs for assessing the \nsurface water bodies of the state in compliance with CWA section 303(d). \nThe baseline is the process that occurred in the listing and delisting of \nwater quality limited segments in the absence of the proposed Policy. \nSWRCB and RWQCBs implement State (Porter-Cologne Act) and Federal \nlaw (CWA) for the protection of water quality. The SWRCB and \nRWQCBs are required to comply with all the provisions of the federal \nCWA. The section of the CWA pertinent to this Policy is section 303(d). \nTo carry out the requirements of CWA section 303(d), the SWRCB and \nthe RWQCBs have, since 1976 and every two years thereafter, assembled \nall readily available data and information in order to characterize and \nsubstantiate section 303(d) list updates. \nSWRCB used a weight-of-evidence approach to evaluate RWQCB \nrecommendations for the 2002-reporting year (SWRCB, 2003a). The \napproach required the evaluation of different types of data and information \ntogether, as well as an assessment of the strength, value, and believability \nof the evidence provided. The assessment determined whether there was a \npollutant of concern associated with a water quality impact and the \nattainment of water quality standards, resulting in a scientifically \ndefensible determination of whether beneficial uses were attained. \nThe categories of water bodies currently on the section 303(d) list are \nshown in Table 1.These water bodies were placed on the list as a result of \nthe baseline process used by the SWRCB and RWQCBs that occurred in the listing and delisting of water quality limited segments in the absence of \nthe proposed Policy. \nPotentially Significant Adverse Environmental Effects \nThe proposed Policy was evaluated in terms of the baseline described \nabove. The analysis of each issue has been formatted consistently as \ndescribed below. \n1. Existing SWRCB and RWQCB Practices \nThis section provides a brief description of how the SWRCB and \nRWQCBs currently address this issue. \n2. \tProposed Policy \nThis section briefly describes how the Policy addresses the issue and \nbriefly explains why the Policy was developed this way. \n3. \tDifferences Between the Policy and Existing Practices \nDifferences between (1) and (2). \n4. \tPotential Adverse Environmental Effects \nWhat are the potential adverse environmental effects of the differences \nbetween the proposed Policy and the existing RWQCB practices? \n5. \tPotentially Significant Adverse Environmental Effects \nAre any anticipated potential adverse environmental effects in (4) \nsignificant? \nIssue I: Scope of the Listing/Delisting Policy \nExisting SWRCB and RWQCB Practices \nThe SWRCB and the RWQCBs are required to submit a new \nsection 303(d) list every two years. The SWRCB does not have a formal \nPolicy on the listing/delisting factors that should be considered in the \ndevelopment of the section 303(d) list. \nProposed Policy \nThe proposed Policy focuses exclusively on the listing and delisting \nfactors as related to compliance with section 303(d) and does not consider \nrevisions of beneficial uses or water quality standards before any listing \ndecisions ate made. In order to make decisions regarding standards \nattainment, this Policy provides guidance to interpret data and information \nby comparison to beneficial uses, existing numeric and narrative water \nquality objectives, and antidegradation considerations. \nThis approach was selected because it will establish a standardized \nmethodoIogy for developing California's section 303(d) list. Additional \n251 advantages include: (1) deadlines are more likely to be met for \ncompletion of the list; (2) the established triennial review process for \nBasin Plans and Statewide Plans would not have to conform to the 2-year \ntime frame for development of the list; and (3) the process would be \nmanageable with existing staff resources. \nDifferences Between the Policy and Existing Practices \nThe proposed Policy affirms that review of water quality standards and the \nlisting and delisting of water quality limited segments in accordance with \nsection 303(d) are two distinctly different actions. The proposed Policy \nrequires RWQCBs to apply a consistent methodology to the listing process \nused to comply with CWA sections 303(d). \nPotential Adverse Environmental Effects \nThe implementation of this Policy will not have an adverse effect on the \nenvironment. The proposed Policy will establish listing/delisting factors \nthat will provide a consistent, scientifically defensible approach to \ndetermine whether water quality standards are being met as required under \nsection 303(d). \nPotentially Significant Adverse Environmental Effects \nNone. \nIssue 2: Structure of Section 303(d) List \nExisting SWRCB and RWQCB Practices \nIn the past, California has developed the section 303(d) list independently \nof the CWA section 305(b) report. After the section 303(d) list is \ndeveloped it is typically incorporated into the section 305(b) report. In \n2002, the SWRCB developed four lists consisting of the following: \n1. The section 303(d) List; \n2. An Enforceable Programs List; \n3. A TMDL Completed List; and \n4. A Monitoring List. \nProposed Policy \nThis Policy proposes that the California section 303(d) list contain the \nfollowing categories: \n+ Water Quality Limited Segments; and \n+ Water Quality Limited Segments Being Addressed. \nNo other lists or categories are proposed. Differences Between the Policy and Existing Practices \nIn 2002, the SWRCB developed four lists associated with the \nrequirements of section 303(d). The proposed Policy would develop one- \nlist with two categories that would satisfy the requirements associated with \nsection 303(d) only. The SWRCB is not precluded from using the USEPA \nguidance (2003b) to develop the section 305(b) report. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy will provide consistency in the assessment \napproaches used by all RWQCBs while allowing the flexibility necessary \nto address regional differences and site-specific concerns. The resulting \nlist will satisfy the requirements of CWA section 303(d). \nPotentially Significant Adverse Environmental Effects \nNone. \nIssue 3: Weight of Evidence for Listing and Delisting \nExisting SWRCB and RWQCB Practices \nIn 2002, the SWRCB used a weight-of-evidence approach to evaluate \nRWQCB recommendations. The components of the weight-of-evidence \nconsisted of the strength of each measurement endpoint and concurrence \namong endpoints. Confidence in the measurement endpoint varied \ndepending on the quality of the data available or the manner in which the \ndata was used to determine impairment. The factors used to assess the \nquality of the measurement endpoints are listed in the Policy. Each water \nbody-pollutant combination was evaluated on a case-by-case basis. \nProposed Policy \nThe weight-of-evidence proposed in the Policy is a narrative process \nwhere individual lines of evidence are evaluated separately and, then, \ncombined using the judgement of RWQCBs and SWRCB in order to make \na stronger inference about water quality standards attainment. Using this \napproach, a single line of evidence could be sufficient by itself to \ndemonstrate water quality standards attainment. In other situations and \nwith many data types, multiple lines of evidence are needed to determine \nif standards are attained. \nWhile most lines of evidence are addressed by the assessment and listing \nmethodology in the Policy, there may be circumstances when additional \nlines of evidence may compel RWQCBs to place water bodies on the \nsection 303(d) list. The weight-of-evidence approach specifies factors to \nevaluate data and information but also allows the use of a situation- \nspecific weight-of-evidence listing factor where RWQCBs are afforded \nsignificant flexibility in assessing additional data and information. This \n253 approach was selected because it allows for a scientifically valid process \nto consider additional data. \nDifferences Between the Policy and Existing Practices \nPreviously, SWRCB and RWQCB staff evaluated each addition, deletion, \nand change to the section 303(d) list based on all data and information \navailable for each water body and pollutant. The SWRCB accepted the \nrecommendations and analysis of the RWQCBs and reviewed each \nrecommendation on a case-by-case basis, making an independent \nassessment of each water body and pollutant. The SWRCB took into \naccount general factors that would be considered in making a scientifically \ndefensible water quality standard attainment determination and also \nconsidered other facts relating to individual water bodies and pollutants. \nThe SWRCB is required by the Supplemental Report of the 2001 Budget \nAct to use a weight-of-evidence approach in developing a policy for \nlisting and delisting waters and to include criteria that ensure that the data \nand information used are accurate and verifiable. The primary difference \nbetween the Policy and the 2002 section 303(d) list is that the decision \nrules are clearly defined for RWQCBs to use in their water quality \nstandard attainment determinations. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy will provide a consistent methodology for \nplacement of water bodies on the section 303(d) list according to the type \nof water quality problem, availability of data, information, and actions that \nare being implemented in identified water bodies. \nPotentially Significant Adverse Environmental Effects \nNone. \nIssue 4: Listing or Delisting with a Single Line of Evidence \nExisting SWRCB and RWQCB Practices \nIn the 2002 section 303(d) listing process, data were evaluated on a case- \nby-case basis. The data evaluation was usually expressed as the number \nof samples exceeding the standard or guideline out of a total number of \nsamples. When appropriate, the magnitude of the measurements was also \nconsidered. \nRWQCBs used a variety of approaches for evaluating bacterial water \nquality data, postings, and beach closure information, prior to the 2002 \nlisting cycle. In 2002, evaluation of data and information for the \nsection 303(d) list involved following preliminary recommendations by \nthe BWQW. These recommendations include frequency of water quality standards exceedances; additional, site-specific information; and \ncomparison of the number of water quality standard exceedances against a \nrelatively unimpaired watershed. A 10 percent of the total days exceeding \nstandards per year was used as the threshold for listing. Permanent \npostings were counted as exceedances when they were based on site- \nspecific water quality data. \"Precautionary\" postings and \"Rain \nAdvisories\" were not counted as exceeding water quality standards. \nListing was based on sufficient samples to determine if the numeric \nstandards were exceeded with moderate confidence. \nBacterial water quality standards for lakes, rivers and streams are \ncontained in the Basin Plans. Several counties have ordinances that \ncontain bacterial standards that can trigger freshwater beach swimming \nwarnings, postings, or closures. As with marine water bodies, postings are \nindicative of impaired water quality and the number of postings measure \nloss of a beneficial use. Each RWQCB develops recommendations for \nfreshwater bacterial water quality objectives on a case-by-case basis. For \nfreshwater bodies, RWQCBs compare monitoring data to Basin Plan water \nquality objectives. No specific approach or guidelines have been \nmandated. Frequency of standards exceedance has been used to assess \nnonattainment. Typically, RWQCBs used an exceedance frequency of \n10 percent \nThe SWRCB and RWQCBs have used a variety of guidelines or \nscientifically derived values to interpret narrative water quality objectives. \nIn developing the 2002 section 303(d) list of water quality impaired \nsegments, the determination of standard or use attainment were based on \nthe RWQCB and SWRCB interpretation of narrative water quality \nobjectives. Compliance with narrative water quality objectives was \nconsidered on a case-by-case basis using all relevant data submitted to the \nRWQCBs. Data were evaluated using relevant and well-accepted \nstandards, criteria, guidelines, or other objective measures that interpret \nthe sensitivity of a benchmark in determining standards or beneficial use \nattainment. Evaluation guidelines with no scientific basis for judging \nstandards or beneficial use attainment were not used. Overall, constituents \nthat violated narrative water quality objectives and were not supported \n'with acceptable numeric evaluation guidelines were not listed. \nEvaluation of tissue chemical concentrations have been based on \nscreening values established by USEPA, NAS, and additional criteria used \nin the SMWP reports, such as MTRLs for the protection of human health \nand wildlife. In developing the 2002 section 303(d) list of water quality \nlimited segments, measures used to interpret chemical residue \nconcentrations in tissue included MTRLs and public health guidelines. In \naddition to MTRLs, guidelines that were well accepted and had a strong \nscientific basis with high levels of certainty and applicability were used. Nuisance is defined in the CWC and in narrative water quality objectives \nin the Basin Plans. In previous section 303(d) listing cycles, water bodies \nwere listed for trash impacts based largely on qualitative data and \ninformation. During the 2002 303(d) listing cycle, the SWRCB and \nRWQCBs' received several submittals of non-numeric information and a \nlimited amount of data to support listing recommendations for trash. \nNarrative water quality objectives for nutrients have been broadly applied \nby many RWQCBs. Recommendations for nutrient listings for the 2002 \nsection 303(d) list included listings for DO, nitrates, ammonia and other \nnitrogen related substances. The 2002 section 303(d) list also cited \nimpairments related to growth of noxious plants, algae, eutrophication, \nand increased turbidity (i.e., decreased water clarity). \nIn the 2002 section 303(d) listing process, the SWRCB did not list any \nnew water bodies proposed for listing under section 303(d) for invasive \nspecies because, under CWA, invasive species are not a pollutant and it \nwould be very difficult to develop TMDLs for invasive species. In 1998, \nthe San Francisco Bay Estuary was listed for exotic species on the section \n303(d) list. \nProposed Policy \nThe Policy proposes approaches for assessing lines of evidence for water \nquality objectives and beneficial uses that could be used by themselves to \nassess whether water quality standards are attained. They include: \n(1) numeric water quality objectives, criteria, or other applicable \nstandards, (2) marine bacterial standards, (3) freshwater bacterial \nstandards, (4) narrative water quality objectives, (5) tissue data, (6) trash, \n(7) nutrients, and (8) invasive species. \nThe Policy proposes that the evaluation of data be consistent with the \nexpression of the numeric water quality objective, water quality criteria, or \nevaluation guideline. If the water quality objective, water quality criteria, \nor evaluation guideline state a specific averaging period andlor \nmathematical conversion, the data should be converted in a consistent \nmanner prior to conducting list assessments. If sufficient data are not \navailable for the stated averaging period, the available data should be used \nto represent the averaging period. \nThis Policy proposes a consistent process and decision rules to trigger \nlisting recommendations for exceedances of marine and freshwater \nbacterial water quality standards. Data and information generated by \nregulatory activities (including NPDES permits compliance and special \nstudies) conducted by the RWQCBs and various local agencies, \nmonitoring and regulatory activities of local environmental health agencies, and recognized private and public institutions would be \nevaluated. \nGeneral guidance for the interpretation of narrative standards and the types \nof interpretative guidelines that may be used would be established. The \nPolicy recommends the use of evaluation guidelines with appropriate \nquantitative translators, if the translator meets specific criteria. \nThe Policy recommends RWQCBs compare available tissue data and \ninformation to the most appropriate measure to interpret chemical residue \nconcentrations. RWQCBs could also incorporate current research that may \nset values that are more protective of the designated beneficial use as long \nas the evaluation guideline criteria are met. Acceptable tissue \nconcentrations can be measured either as muscle tissue (preferred) or \nwhole body residues. Animals can either be deployed (if a resident \nspecies) or collected from resident populations. Recurrent measurements \nin tissue are required. \nWaters would be placed on the section 303(d) list if visual assessments \nand numeric water quality objectives or evaluation guidelines show that \ntrash is a water quality problem. The types of numeric data that could be \nused include. trash cleanup day data or spatially and temporally \nrepresentative measurements of trash in waterways or at beaches. An \nalternative to a trash evaluation guideline is to compare trash accumulation \nto reference conditions (i.e., waters scarcely impacted by trash \naccumulations). \nSpecific guidance would be applied when nutrient listing decisions are \nbeing made. The Policy discusses guidelines for the use of die1 \nmeasurements for DO or acceptable guidelines to evaluate nutrient \nconcentrations in the absence of die1 measurements. Additionally, the \nPolicy discusses the use of evaluation guidelines for nutrient related \nexcessive algae growth, unnatural foam, odor and taste. \nThe Policy proposes that water bodies impacted by invasive species \nshould not be placed on the section 303(d) list. TMDL development \nwould not be required for these water bodies; other appropriate water \nquality management actions would address the cause of invasive species \nimpacts. \nDifferences Between the Policy and Existing Practices \nPreviously, each RWQCB used its own approach and methodology when \nmaking listing decisions. The magnitude and duration expressed in water \nquality objectives was used to assess the States waters. In most cases, data \nevaluation has been expressed as the number of samples exceeding the \nstandard or guideline out of a total number of samples. The proposed - - Policy recommends rules for evaluating water quality objectives. Prior to \nconducting list assessments, RWOCBs would determine if there are a \nsufficient number of samples and whether those samples are spatially and \ntemporally representative of the water quality in the water body. \nAvailable data would be further evaluated to avoid temporal bias and \nensure, when applicable, that seasonality is represented in the sampling \nplan. Additionally, the duration (i.e., averaging period) of concentrations \nexpressed in the water quality objective would be considered in the \nassessment when standards are achieved. Data sets would, then, be \ncompared to the water quality objective to determine if an exceedance has \noccurred. \nPrior to the 2002 listing cycle, the RWQCBs were given significant \nlatitude in deciding what constituted bacterial water quality standards \nexceedance for marine and freshwaters. For each circumstance, RWQCBs \nwould decide which waters to list after considering the available data and \ninformation for the site based on regional interpretation of standards, \npostings, and closure data and information. The proposed Policy's criteria \nfor addressing bacterial standards in marine and freshwaters to support \nlistings on the section 303(d) list are based on recommendations from the \nBWQW. These guidelines provide a basis for assessing listing decisions. \nThe determination of standard or use attainment, for the 2002 section \n303(d) list, was based on RWQCB and SWRCB interpretation of narrative \nwater quality objectives. Overall, constituents that violated the narrative \nwater quality objective and were not supported with acceptable numeric \nevaluation guidelines were not listed. The Policy would require evaluating \nnarrative water quality objectives using interpretive evaluation guidelines \nthat represent standards attainment or beneficial use protection. The Policy \nestablishes general guidance for the interpretation of narrative standards \nand the types of interpretative guidelines that may be used. \nFor aquatic life tissue data, existing practices include listings based solely \non USFDA action levels and MTRLs. The proposed Policy presents the \nuse of the most appropriate measure to interpret chemical residue \nconcentrations in tissue. This would provide RWQCBs with the flexibility \nto compare available tissue data and information to the most appropriate \nand current values that can be used to interpret chemical residue \nconcentrations. The Policy also recommends tissue sampling from the \nappropriate target species and provides guidance on the minimum number \nof replicates and the number of individuals per replicate. The Policy does \nnot ailow the use of MTRLs and USFDA action levels. \nHistorically, water bodies recommended for section 303(d) listing, due to \ntrash, have been addressed differently by each RWQCB. In general, \nassessments of impairments due to trash have been based largely on qualitative information. The proposed Policy recommends an approach \nusing numerical data and non-numeric information but allows existing \nprograms to address any water related trash problem. \nDuring previous listing cycles, water bodies were placed on the section \n303(d) list for nutrient impacts without determining the specific \nconstituent causing biostimulation. In some cases the stimulatory \nsubstance was inappropriately identified or the guideline used to \ndetermine impacts to specific beneficial uses was inappropriately used. \nThe Policy recommends the use of a consistent systematic approach for \nlisting water bodies impacted by nutrients and provides specific guidance \nto help in the identification of the constituent, and determination of the \nbeneficial use that is impacted. \nIn the 1998 section 303(d) listing process, nine water body segments were \nlisted for exotic species impacts. The Policy would not allow listing water \nbodies impacted by invasive species because a pollutant does not cause \nthose types of impacts and a TMDL is not required. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy recommends a process to consistently convert \ndata when the water quality objective, water quality criteria, or evaluation \nguideline state a specific averaging period andlor mathematical \nconversion. Specific criteria are recommended for evaluating marine and \nfreshwater bacteriological standard exceedances. Guidance is provided on \nthe use of available defensible criteria to quantitatively assess the potential \nfor narrative water quality standards exceedance; to interpret chemicals \nbioaccumulated in fish or shellfish tissue providing consistent \ninterpretation of the levels of residue concentrations in tissue that impact \nbeneficial uses; and a fairly consistent approach for listing water bodies \ndue to trash. The Policy recommends a consistent approach for listing \nwater bodies due to nutrients impacts, providing specific guidance to help \nidentify the biostimulatory substance as well as the beneficial use that is \nimpacted. The Policy recommends against listing for invasive species. \nPotentially Significant Adverse Environmental Effects \nNone. Issue 5: Listing or Delisting with Multiple Lines of Evidence \nExisting SWRCB and RWQCB Practices \nEach RWQCB typically has its own approach to the methodology used for \nlisting. RWQCBs have assessed, case-by-case, which lines of evidence to \nuse, data analysis procedures, and exceedance frequencies depending on \nsite-specific factors. Existing practices specific to each sub-issue follows: \nThe issuance of health advisories by OEHHA or shellfish harvesting bans \nautomatically led to the water quality of the segment being considered \nlimited, especially if the chemical or biological contaminant was \nassociated with sediment or water in the segment. The 2002 section 303(d) \nlist required multiple lines of evidence to list or delist a water body and \ngenerally needed the pollutant(s) that caused or contributed to the adverse \ncondition. \nData and information describing nuisance conditions, for the most part, \nhas been qualitative (e.g., phot&raphs, accounts of individuals, etc.). \nSome numeric data have been provided that describes nuisance conditions \n(e.g., measures of algae cover or water color). During previous section \n303(d) listing cycles, water body segments have been listed for nuisance \nconditions related to coIor, odor, and excessive algae or scum using \nqualitative information. \nDuring the development of the 2002 section 303(d) list, toxicity testing \nwas used as a basis for listing as long as concurrently sampled chemical \ndata was available that showed the chemical caused or contributed to the \nobserved toxicity. Prior to the 2002 section 303(d) list, water bodies were \nlisted with and without the chemical data andlor a pollutant identified. \nDetermining the impacts of sediment (including settleable material and \nturbidity) has been based on non-attainment of narrative and numeric \nwater quality objectives and the threat to designated beneficial uses. \nWater quality objectives for temperature are specified in Basin Plans and \nthe California Thermal Plan. In 2002, section 303(d) listings were \nproposed for several North Coast rivers based on evaluation of MWAT \ndata ranges, as compared to evaluation values for impacts on anadromous \nfish species. In addition, temperature data were evaluated with respect to \ncurrent and historic presence of cold water fish. If a stream exhibited \ntemperatures within the chronic reduced-growth MWAT ranges, and had a \ndecreased salmonid fishery compared with historic levels, it was listed \nbased on inferred historical stream MWATs. \nOrganism response to pollutants is typically assessed with toxicity tests or \nby observations of change in the biological population or communities. In 2002, listings for adverse biological response were not recommended. \nHowever, in previous lists (prior to 2002), some water bodies were placed \non the section 303(d) list for abnormal fish histology. \nDegradation of biological populations or communities has not been, \ntraditionally, assessed by the RWQCBs. In the 2002 section 303(d) list, \ndegradation of aquatic life populations or communities listings required \nmultiple lines of evidence that identified the pollutant(s) causing or \ncontributing to the adverse condition. At present for California, there are \nno widely accepted approaches for documenting trends in water quality. \nNo existing listings are known to be based on findings related to \nantidegradation or trends in water quality. \nProposed Policy \nThe Policy proposes the use of Health Advisories, in conjunction with \nother water quality measurements, to list a water body. When OEHHA or \nDHS issues a health advisory against the consumption of edible resident \norganisms or a shellfish harvesting ban, the water quality of the segment is \nautomatically considered limited if the chemical or biological contaminant \nis associated with sediment or water in the segment. Additional indicators \nto assess attainment with fish and shellfish consumption-based water \nquality are listed in the Policy. \nThe use of both quantitative and qualitative data and information in the \nevaluation of nuisance is recommended. For the section 303(d) list, the \nPolicy recommends the identification of the pollutant or pollutants that \ncause or contribute to the observed impacts. The Policy requires that \nRWQCBs rely on existing numeric water quality objectives (related to \nnutrients or other pollutants) or evaluation guidelines that represent an \nacceptable level of beneficial use protection. \nThe Policy proposes listing for toxicity alone (without the pollutant \nidentified) as one line of evidence to place water bodies on the section \n303(d) list. The RWQCBs have the option to identify the pollutant during \nthe development of the TMDL. \nThe interpretation of sediment impacts on a case-by-case basis is proposed \nin the Policy. Water bodies would be listed based on sufficient credible \ndata and information that indicate water quality standards for sediment are \nnot met, by comparison to acceptable evaluation guidelines, or that \nimpacts to beneficial uses are caused by sediment. \nThe proposed Policy, in lieu of data to directly assess compliance with \nnumeric temperature water quality objectives, recommends comparing \nrecent temperature monitoring data for a specific water body to the \ntemperature requirements of the resident aquatic life. Information on the current and historic condition and distribution of the sensitive beneficial \nuses (e.g., fishery resources) in the water body is necessary, as well as \nrecent temperature data on conditions experienced by the most sensitive \nlife stage of the aquatic life species. Information about presencelabsence \nor abundance of sensitive aquatic life species can be used to infer past \ntemperature conditions. \nGeneral guidelines are outlined requiring the comparison of adverse \nbiological response endpoints to reference conditions, the identification of \npollutants suspected of causing or contributing to the adverse response, \nand the association of pollutants with an adverse response. Endpoints for \nthis factor include fish kills, reduction in growth, reduction in reproductive \ncapacity, abnormal development, histopathological abnormalities, and \nother adverse conditions but no specific cutoff values are proposed. \nThe proposed Policy recommends listing a water segment when \nsignificant degradation in biological populations andlor communities is \nexhibited, represented by diminished numbers of species or individuals of \na single species or other metrics as compared to reference site@) and \nassociated water or sediment concentrations of pollutants. For population \nor community degradation related to sedimentation, the Policy \nrecommends listing, if degraded populations or communities are identified \nand effects are associated with clean sediment loads in water or those \nstored in the channel. \nWaters that currently meet standards but show a declining trend in water \nquality may not meet antidegradation requirements and could be \nconsidered for inclusion on the section 303(d) list. \nDifferences Between the Policy and Existing Practices \nExisting practices allow RWQCBs broad flexibility in determining how to \nevaluate water and sediment measurements in association with health \nadvisories. The proposed Policy recommends, when using health \nadvisories or shellfish bans to list a water quality limited segment, that \nRWQCBs also consider available water segment-specific data indicating \nthe evaluation guideline for tissue is exceeded. More than one criterion \nmay be necessary to determine if the water segment is impaired. \nIn previous section 303(d) listings, qualitative information alone has been \nused to list water bodies for nutrient impairments; some numeric data has \nalso been provided. The SWRCB and the RWQCBs have received \ndocumentation in the form or photographs, and accounts of individuals, \netc. that describes nuisance conditions. The proposed Policy recommends \nusing qualitative information combined with quantitative data related to \nexcessive nuhients to evaluate the potential for nuisance conditions. In ~revious section 303(d) lists. water bodies were listed with and without . , \nthe chemical data andlor a pollutant identified. Listing proposals, without \nthe pollutant identified, were not placed on the 2002 section 303(d) list. \n~he-~ro~osed Policy recommends listing water bodies for impairments \ndue to toxicity on the section 303(d) list. \nDetermining the impacts of sediment has been based on each RWQCBs \ninterpretation of non-attainment of water quality objectives and the threat \nto designated beneficial uses. The Policy provides general guidance to list \nwater bodies due to sediment impacts based on sufficient credible data and \ninformation that indicate water quality standards for sediment are not met \nby comparison to acceptable evaluation guidelines, or documented \nimpacts to beneficial uses that are caused by sediment. \nIn 2002, section 303(d) listings were proposed based on evaluation of \nMWAT data ranges, as compared to evaluation values for impacts on \nanadromous fish species. In addition, temperature data were evaluated \nwith respect to the current and historic presence of cold water fish. The \nproposed Policy would require listing water segments for temperature \nfocusing on beneficial use impacts and likely effects of elevated \ntemperature on sensitive species based on the assumption that aquatic life \nbeneficial uses (e.g., cold and warm water fisheries) are sensitive to \nmodifications to natural temperature. \nIn prior listings, the only adverse biological response considered was \nabnormal fish histology. The proposed Policy recommends general \nguidance when basing a listing decision on adverse biological response \nand provides general criteria upon which endpoints can be compared. The \nSWRCB and the RWQCBs would need to consider additional stronger \nlines of evidence (e.g. endpoints compared to reference conditions, \nidentification of pollutants suspected of causing or contributing to the \nadverse response, and association of pollutants with an adverse response). \nGenerally, the RWQCBs have measured biological conditions indirectly, \nthrough the use of chemical-specific analysis and toxicity; they have not \nused bioassessment by itself prior to 2002 to substantiate a section 303(d) \nlisting recommendation. The proposed Policy recommends specific \nguidance on the use of bioassessment but only if associated with water and \nsediment pollutant measurements. \nThe Policy allows that documented trends in declining water quality, to \nlevels that may not meet the antidegradation provisions of water quality \nstandards, are sufficient to place the water body on the section 303(d) list. \nAlso, an indication is required that the water bodies are toxic, there are \nimpacts on aquatic life communities or populations, or there is other \nadverse biological response. Potential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy only provides a consistent, comprehensive \napproach for: evaluating water bodies listed for impacts, due, to the \nissuance of fish con~u&~tion advisories or shellfish bans; using both \nauantitative and aualitative data and information in the evaluation of \nnuisance conditions; and listing water bodies for toxicity with and without \na pollutant identified. The Policy provides general guidance for placing \nwater bodies impacted by sedimentation on the section 303(d) list on a \ncase-by-case basis and the assembling of sufficient credible data and \ninformation that indicate water quality standards for sediment are not met. \nAdditionally, the Policy provides guidance on: determining whether the \nbeneficial uses of a waterbody are impacted by temperature; evaluating \nadverse biological response data and information while providing \nsignificant flexibility to interpret impacts due to these factors; using \nassessments of biological communities along with water and sediment \nmeasurements to determine water quality impacts; and documenting trends \nin water quality that may eventually exceed water quality objectives or \ncriteria, in violation of the antidegradation provisions of water quality \nstandards. \nPotentially .Significant Adverse Environmental Effects \nNone. \nIssue 6: Statistical Evaluation of Numeric Water Quality Data \nExisting SWRCB and RWQCB Practices \nDuring previous listing cycles, the RWQCBs sampled information, but \nlittle or no statistical validation of data, was used in making \nrecommendations for the 2002 section 303(d). The RWQCBs did not use \nhypothesis testing. RWQCBs and SWRCB did not employ a level of \nstatistical confidence in section 303(d) listing decisions. \nDuring the development of the section 303(d) list, RWQCBs used various \nexceedance rates and a variety of minimum sample sizes in their section \n303(d) listing decision assessments. Data were evaluated on a case-by- \ncase basis. The data evaluation was usually expressed as the number of \nsamples exceeding the standard or guideline out of a total number of \nsamples. When appropriate, the magnitude of the measurements was also \nconsidered. \nWater quality data often include observed measurements that are below or \nless than the QL of the analytical instruments. In 2002, the RWQCBs used \nseveral methods to evaluate non-detect data that ranged from using one \nhalf the value of the detection limit to evaluating the number of exceedances in the total number of samples collected (i.e., the total \nnumber of samples that included non-detects). \nProposed Policy \nThe Policy provides guidance to base section 303(d) listing/delisting \ndecisions on statistics to validate numeric data evaluations. It also requires \nSWRCB and RWQCBs follow appropriate scientific/statistical guidelines \nin establishing hypotheses; statistical procedures; and establishes \nacceptable levels of Type I and Type I1 errors; and preliminary hypotheses \ndesigned to minimize error. This increases confidence in decision making, \nquantifies the level of confidence and power, and follows standard \nscientific protocols for using hypothesis testing in decision-making. \nWhen available data are less than or equal to the QL and that is less than \nthe water quality standard, the value will be considered as meeting the \nwater quality standard, objective, criterion, or evaluation guideline. When \nthe sample value is less than the QL and the QL is greater than the water \nquality standard, objective, criterion, or evaluation guideline, the result \nshall not be used in the analysis. The QL includes the minimum level, \npractical quantitation level, or reporting limit. The Policy recommends a \nstatistical approach that balances the Type I and Type I1 errors. \nDifferences Between the Policy and Existing Practices \nDuring previous listing cycles, the RWQCBs assessed information, but did \nnot statistically validate data used in making recommendations for the \n2002 section 303(d) list. Previously, RWQCBs used critical exceedance \nrates to judge when a water body was not meeting water quality standards \nbut the process was implemented without the use of statistical analysis. \nThe RWQCBs used several methods to evaluate non-detect data. The \nPolicy provides general guidelines to determine the process in interpreting \nwhen and how anon detect value can be included in the 303(d) listing \nevaluation. \nThe Policy contains provisions for using statistics to validate numeric \ninformation to make sound scientific section 303(d) listingldelisting \ndecisions; makes a recommendation as to the form of the null hypothesis \nand alternate hypothesis; and recommends an exact binomial statistical \ntest that balances errors. The Policy requires that a range of critical \nexceedance rates be applied to determine the number of samples needed to \nplace waters on the section 303(d) list. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy recommends using statistics to validate numeric \ninformation and test trends to make sound scientific section 303(d) \nlisting/delisting decisions. The Policy adopts a critical exceedance frequency that assesses only the strength of the decision to list or delist \nbased on the sample population (i.e., grab samples) available. The Policy \nprovides general guidance on interpreting non-detect or below QL data. \nPotentially Significant Adverse Environmental Effects. \nNone. \nIssue 7:Policy Implementation \nExisting SWRCB and RWQCB Practices \nThe SWRCB has used previous section 303(d) lists as the basis for the \ndevelopment of the biennial list. The 1998section 303(d) list formed the \nbasis for the 2002 list submittal. Previous listings were reevaluated if \nnew data and information were available. \nThe RWQCBs and SWRCB, in the process of evaluating whether water \nquality standards are being met, have traditionally relied on data and \ninformation documenting specific environmental characteristics pertaining \nto the physical, chemical, and biological conditions of each region's water \nbodies and watershed systems. \nIn the 2002 section 303(d) listing cycle, SWRCB and RWQCBs solicited \nall readily available data and information. Each RWQCB submitted staff \nreports, along with copies of public submittals, data and information, and \ndocuments referenced in the submittal to the SWRCB. The SWRCB \nreviewed all RWQCBs recommendations and compiled a statewide listing \nfor SWRCB approval. After several public hearings and workshops, the \nSWRCB approved the section 303(d) list for submittal to USEPA. \nFor each water body and pollutant recommended by the RWQCBs for the \n2002 section 303(d) list, SWRCB staff developed fact sheets outlining all \npertinent information needed to make listing decisions. \nIn previous section 303(d) listing cycles, the quality of the data and \ninformation used to determine impairment varied greatly not only among \nthe RWQCBs but among the past listing cycles as well. In the 2002 listing \ncycle, if the RWQCB provided information on the quality of the data, it \nwas recorded it in the fact sheet. \nSpatial and temporal representation were considered on a case-by-case \nbasis and data of varying ages were used for the 2002 section 303(d) list. \nIdentification of water quality limited segments during previous \nsection 303(d) listing cycles varied between RWQCBs. Generally, \nRWQCBs based listings on their Basin Plan surface water segmentation \nclassifications by either listing according to hydrologic unit, area, and sub. \n266 area or by listing on the basis of water body type and name. Some \nRWQCBs added water body segments not identified in Basin Plans; other \nRWQCBs established listings throughout watersheds even if the data \nindicated only a portion of the water body or segment was impacted. \nMost of the RWQCB Basin Plans currently contain language \ndistinguishing between controllable factors that result in degradation of \nwater quality and those factors that are not controllable. \nProposed Policy \nThe Policy recommends revising an existing listing if requested by \ninterested. Existing and readily available data and information in paper or \nelectronic format from all available sources includes but is not limited to \nspecifically listed reports and other sources of information listed in the \npolicy. Data supported by a QAPP or equivalent would be acceptable for \nuse in developing the section 303(d) list. \nThe Policy proposes that both the RWQCBs and the SWRCB manage the \napproval process. The RWQCBs would evaluate all readily available data \nand information and assemble fact sheets with the pertinent information \nfor each potential water body-pollutant combination. Fact sheets shall \npresent a description of the line@) of evidence used to support each \ncomponent of the weight-of-evidence approach. If the data and \ninformation reviewed indicate standards are attained, a single fact sheet \nmay address multiple water and pollutant combinations. Public hearings, \nheld by each RWQCB, will consider each proposed water body fact sheet, \nand provide written response to comments from testimony given at the \nhearing. After considering all testimony, the RWQCB would approve \nrecommendations by resolution for the section 303(d) lists. The SWRCB \nwould consider the RWQCB recommendation at a workshop. The list \nwould be approved at a SWRCB Board meeting after consideration of all \npublic comments. \nThe Policy recommends general guidance on collecting data that would be \nspatially and temporally representative of the water body segment. In \ngeneral, samples should be available from two or more seasons or from -\ntwo or more events when effects or water quality objective exceedances \nwould be clearly manifested. Guidelines are also proposed on the age of \ndata acceptable for listing. Only the most recent 10-year period of data and \ninformation would be used for listing and delisting waters. \nRWQCBs would list water bodies or segments in accordance with the \nsegmentation approach used in the Basin Plans but would be allowed to \nfurther divide waters if warranted. In the absence of an adequate \nsegmentation system, the RWQCBs would be encouraged to define \ndistinct reaches based on hydrology (e.g., stream order, tributaries, dams, or channel characteristics) and relatively homogeneous land use. These \ncomponents of the stream system could be logically grouped depending on \nthe nature of the source of the pollutant and the designation of beneficial \nuses. The RWQCBs would be encouraged to identify stream reaches or \nlakelestuary areas that may have different pollutant levels based on \nsignificant differences in land use, tributary inflow, or discharge input. \nBased on these evaluations of the water body setting, RWQCBs would \naggregate the data by appropriate reach or area. \nDifferences Between the Policy and Existing Practices \nThe proposed Policy presents a process for reconsidering existing listings. \nIn previous listings, each RWQCB has used its judgement in identifying \nwhich data and information to use in its listing process. The proposed \nPolicy recommends existing and readily available data and information in \npaper or electronic format including but not limited to the data and written \ninformation specifically described in the Policy. \nIn the past, the RWQCBs have held primary responsibility in making \nwater body-pollutant recommendations pertaining to the section 303(d) \nlist. This proposed Policy would allow each RWQCB to go through their \nadoption processes by holding workshops or hearings on the proposed \nwater body-pollutant recommendations, provide a public comment period, \nand for the RWQCBs to respond to those comments. SWRCB would \nreview the RWQCB recommendations for consistency and applicability \nwith the Policy. \nDocumentation of proposed listings and the quality of the data and \ninformation used have varied widely. The 2002 listing process and the \nproposed Policy use a standard fact sheet format. The RWQCBs would be \nrequired to submit summaries of the data and information to support \nrecommendations for the listing and delisting of water bodies. Fact sheets \nwould only be prepared in circumstances where data and information are \navailable. All readily available data and information would be considered. \nIn 2002, California used all information and data to support listings \nregardless of age. The proposed Policy provides general guidance on the \nquality data that is acceptable for use in the section 303(d) listing process. \nThe RWQCBs would evaluate and make a finding in the fact sheets on the \nappropriateness of data collection and analysis practices. \nIn previous section 303(d) listing cycles, spatial and temporal \nrepresentation were considered on a case-by-case basis. The RWQCBs \nBasin Plans establish lists of water bodies within each region where water -\nquality standards apply and waters will be protected from water quality \ndegradation. Each identified water body within the established list is \nsegmented by hydrologic unit, area and sub area, and each segments \nbeneficial uses are designated, where such uses are applicable. The Policy establishes general guidance when considering spatial and temporal \nrepresentation in the evaluation of data and information from water body \nsegments. The use of Basin Plan hydrologic units, areas and sub areas, and \nwater body type classifications to determine where water quality standards \nare not being met is also recommended. The water segment would be \nlisted on the section 303(d) list, although it may only be a smaller portion \nof the segment that is impaired. Listings of water segments would not be \nallowed unless data from the segment showed standards are not attained. \nPreviously, some water bodies not meeiing water quality standards for a \nparticular pollutant originating from natural sources were placed on the \nsection 303(d) list. The proposed Policy does not provide guidance \nregarding impacts relative to natural sources. Water bodies recommended \nfor section 303(d) listing in the future or existing listings recommended \nfor removal from the section 303(d) list due to natural sources will require \nreview and approval by the SWRCB. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy recommends a more rigorous method of \ndetermining and specifying the data and information format to ensure that \nany listing recommendation is credible and scientifically defensible. The \nPolicy allows for a more consistent approach in the development of the \nsection 303(d) list. To support listing recommendations, the Policy \nprovides guidance to ensure that data and information is adequately \ndocumented; of sufficiently high quality; and spatially and temporally \nrepresentative of water body segments. The Policy identifies a process for \nestablishing segments avoiding confusion regarding applicable designated \nbeneficial uses, the name of the segment, and the size and boundaries of \nthe affected segment. \nPotentially Significant Adverse Environmental Effects \nNone. \nIssue 8: Priority Ranking and TMDL Completion Schedule \nExisting SWRCB and RWQCB Practices \nIn the 1998listing cycle, the RWQCBs established priority ranking of \nlisted water quality limited segments following a general SWRCBNSEPA \nguidance document. Criteria used to rank water bodies as high, medium, \nor low priority for TMDL development included the importance and \nextent of the beneficial uses threatened, degree of impairment, potential \nfor beneficial use recovery, public concern and availability of information. \nHowever, TMDL scheduling was not linked with priority setting. \n269 The 2002 prioritization process was based on the 1998ranking methods. \nHowever, resource availability and considerations of achievability within \nthe next two years were also taken into account in determining whether a \nwater body should be ranked as high priority for TMDL development. The \n2002 listing process linked priority ranking with the TMDL development \nschedule and subsequently scheduled TMDLs for all water bodies \ndetermined to be high priority. \nProposed Policy \nThe Policy proposes the establishment of a schedule for waters on the \nsection 303(d) list that identify the TMDLs that would be developed \nwithin the current listing cycle and the number of TMDLs scheduled to be \ndeveloped thereafter. The schedule in and of itself would reflect the \nState's priority ranking. The Policy would identify TMDLs scheduled for \ndevelopment using the following three categories of waters. \nDifferences Between the Policy and Existing Practices \nThe listing cycle prior to 2002 determined that water bodies would be \nranked as high, medium and low and TMDL scheduling would not be \nlinked. The Policy provides for each RWQCB to use their professional \njudgement to determine which TMDLs are high priority and which are \nnot; but it would not be necessary to identify each TMDL as a high, \nmedium, or low priority as long as a schedule is established. \nPotential Adverse Environmental Effects \nThe development of this Policy will not have an adverse effect on the \nenvironment. The Policy establishes guidelines for and allows the TMDL \nscheduling to reflect the priority setting for establishing TMDLs. \nPotentially Significant Adverse Environmental Effects \nNone. \nGrowth-Inducing Impacts \nCEQA defines the expected discussion of growth-inducing impacts and \nindirect impacts associated with growth in section 15126(g) of the CEQA \nguidelines. That section states: \n\"...Discuss the ways in which the proposed project could foster \neconomic or population growth, or the construction of additional \nhousing, either directly or indirectly, in the surrounding environment. \nIncluded in this are projects that would remove obstacles to population \ngrowth (a major expansion of a wastewater treatment plant might, for \nexample, allow for more construction in service areas). Increase in the \npopulation may further tax existing community service facilities so \nconsideration must be given to this impact. Also discuss the \n270 characteristics of some projects which may encourage and facilitate \nother activities that could significantly affect the environment, either \nindividually or cumulatively. It must not be assumed that growth in \nany area is necessarily beneficial, detrimental, or of little significance \nto the environment.\" \nThe proposed Policy provides consistent statewide guidance on the \ndevelo~ment of CWA section 303(d) list as required by CWC section \n13191.3(a). The analysis of environmental impacts concludes that each \npart of the proposed Policy will not have a significant effect on the \nenvironment. The proposed Policy is not expected to foster or inhibit \neconomic or human population growth, or the construction of additional \nhousing. \nCumulative and Long-Term Impacts \nCEQA guideline section 15355 provides the following description of \ncumulative impacts: \n'\"Cumulative impacts' refer to two or more individual effects which, \nwhen considered together, are considerable or which compound or \nincrease other environmental impacts. \n(a) The individual effects may be changes resulting from a single \nproject or a number of separate projects. \n(b) The cumulative impact from several projects is the change in the \nenvironment that results from the incremental impact of the project \nwhen added to other closely related past, present, and reasonably \nforeseeable probable future projects. Cumulative impacts can result \nfrom individually minor but collectively significant projects taking \nplace over a period of time.\" \nOne means of complying with CEQA's requirement to consider \ncumulative impacts is to provide a list of past, present and reasonably \nforeseeable future projects that are related to the proposed action. \nForeseeable projects that would result from the placement of waters on the \nCWA section 303(d) can vary greatly depending on the pollutant and level \nof regulatory response needed. \nRWQCBs have wide latitude and numerous options that apply when \ndetermining how to address waters on the section 303(d) list. Irrespective \nof whether section 303(d) of the CWA requires a TMDL, the process for \naddressing waters that do not meet applicable standards will be \naccomplished through many existing regulatory tools and mechanisms. If \na listed water segment meets water quality standards, the appropriate \nregulatory response is to remove the water from the list (to delist). If the \nfailure to attain standards is revealed to be the result of the applicable \nstandards not being appropriate, the regulatory response should be to correct the standards through mechanisms such as Use Attainability \nAnalysis, a Site-Specific Objective, or other modification of the water \nquality standard. In addition, an antidegradation finding may authorize the \nlowering of water quality to some degree, which may address the \nimpairment. \nThe federal requirement to calculate TMDLs for listed waters is limited to \nthose pollutants that USEPA determines are suitable for such calculation. \nAt present this includes all pollutants. However, there are many existing \nregulatory tools that can be used to address water quality problems \nidentified on the section 303(d) list. \nExisting regulatory tools include individual or general WDR (NPDES \npermits or requirements solely under California law), individual or general \nwaivers of WDRs, enforcement actions, interagency agreements, \nregulations, Basin Plan amendments, andlor other policies for water \nquality control. Basin Plan amendments can include implementing a \nspecific water quality control plan, adopting prohibitions, or (where \nappropriate) modifying standards. \nTMDLs are generally adopted at the time programs are instituted to \nimplement actions to correct impairment. TMDLs may be adopted in any \nof the following ways: as part of a Basin Plan amendment, in the \nassumptions underlying a permitting action, in an enforcement action, or \nin another single regulatory action that is designed by itself to correct the \nimpairment. The TMDL is adopted with the regulatory action that \nimplements it. \nAny environmental impacts associated with individual TMDLs or other \nefforts in lieu of a TMDL shall be addressed when the RWQCBs and \nSWRCB develop and approve those efforts. It is not possible for the \nSWRCB to consider potential direct and indirect environmental impacts of \nTMDLs planned for development or foresee all possible ways standards \nnon-attainment will be addressed. It is unknown what actions will be \nnecessary to implement the future TMDLs or other regulatory actions. \nDuring the development of TMDLs and implementation plans, RWQCBs \nand SWRCB will conduct a CEQA review and consider potential \nenvironmental impacts. \nThe response of RWQCBs to the placement of waters on the \nsection 303(d) list is so varied, situation-specific, and site-specific that it is \nimpossible to reasonably foresee the potential cumulative impacts of these \nprojects or of placing waters on the section 303(d) list. ENVIRONMENTAL CHECKLIST \nA. \tBackground \n1. \tName of Proponent: State Water Resources Control Board \n2. \tAddress and Phone Number of Proponent: Division of Water Quality \nP.O. Box 100, Sacramento, CA 95812-0100 \n(916) 341-5560 \n3. \tDate Checklist Submitted: December 2,2003 \n4. \tAgency Requiring Checklist: Resources Agency \n5. \tName of Proposal, if applicable: Water Quality Control Policy for Developing California's \nClean Water Act Section 303(d) List \nB. Environmental Impacts \n(Explanations are included on attached sheets). \nPotentially \nSignificant Unless \nPotentially Mitigation Less Than \nSignificant Impact Incorporated Significant Impact No impact \n1. \nWould the proposal: \na. \t Conflict with general plan designation or [ 1 [ 1 1 1 [XI \nzoning? \nb. \t Conflict with applicable environmental II [ 1 [ 1 [XI \nplans or policies adopted by agencies \nwith jurisdiction over the project? \nc. \t Be incompatible with existing land use in [ 1 I1 [ 1 [XI \nthe vicinity? \nd. \t Affect agriculture resources or operations [ 1 1 1 [ 1 [XI \n(e.g. impacts to sails or farmlands or \nimpacts from incompatible land uses)? \ne. \t Disrupt or divide ihe physical [ 1 I1 [ 1 [XI \narrangement of an established \ncommunity (including a low- income or \nminority community)? \n11. \nWould the proposal: \na. \t Cumulatively exceed official regional or II \nlocal population projections? \n c Potentially \nSignificant Unless \nPotentially Mitigation \nSignificant Impact Incorporated \n[ 1 [ 1 Less Than \nSignificant Impact No Impact \n[ 1 [XI b. \t Induce substantial growlh in an area \neither directly or indirectly (e.g., thmugh \nprojects in an undeveloped area or \nextension of major infrastmctun)? \nc. \t Displace existing housing espcially \naffordable housing? \nIll. \t GEOLOGIC PROBLEMS \nWould the prnporal result in or expose people \nto potential impacls involving: \na. \t Fault rupture? \nb. \t Seismic ground shaking? \nc. \t Seismic ground failure. including liquefaction? \nd. \t Seiche, tsunami, or volcanic hazard? \ne. \t Landslides orrnudflows? \nf. \t Erosion, changes in topography or \nunstable soil conditions from excavation, \ngrading or fill? \ng. \t Subsidence of he land? \nh. \t Expansive soils? \ni. \t Unique geologic or physical features? \nIV. \nWould he proposal result in: \na. \t Changes in absorption rates, drainage \npatterns, or lhe rate and amount of \nsurface runoff? \nb. \t Exposure of people or propeny to water \nrelated hazards such as flooding? \nDischarge inlo surface water or olhcr \nalterdtlon of surface water quality (c.g \ntcmpeaturc, disrol$ed 0x)gen or \nturbidity)? \nd. \t Changes in the amount of surface watez \nin any water body? \ne. \t Changes in currents or he course or \ndirection of surface water movements? ......-... \nSignificant Unless \nPotentially Mitigation Less Than \nSignificant Impact Incorporated Significant lmpact No lmpact \n1x1 f. \t Change in the quantity of gmundwaten, either \nthrough direct additions or withdrawals, or \nthrough interception of an aquifer by cuts or \nexcavations or through substantial loss of \ngroundwater recharge capability? \ng. \t Altered direction or rate of flow of \ngroundwater? \nh. \t Impacts to groundwater quality? \ni. \t Substantial reduction in he amount of \ngroundwater otherwise available for \npublic water supplies? \nV. \t AIR OUALITY \nWould the proposal: \na. \t Violate any air quality standard or \ncontribute to an existing or projected air \nquality violation? \nb. \t Expose sensitive receptors lo pollutants? \ne. \t Alter air movement. moisture. or \ntemperature, or cause any change in \nclimate? \nd. \t Create objectionable odors? \nVI. \tTRANSPORTATION/CIRCUL.ATION \nWould the proposal result in: \na. \t !\"creased vehicle lips or traffic \ncongeslion? \nb. \t Hazards to safety from design features \n(e.g. farm equipment)? \ne, \t Inadequate emergency access or access to \nnearby uses? \nd. \t Insufficient parking capacity on- site ot \noff- site? \ne. \t Hazards or banien for pedestrians or \nbicyclists? \nf. \t Rail, waterborne or air Uaffic impacts? \ng \t Confl~ca ulh adoplcd pol~c~cs \nrupponlng lranrponallon (eg , bur \nturnouts, be)cllrtr racks)? Potentially \nSignificant Unless \nPotentially Mitigation Less ?ban \nSignificant Impact Incorpolated Significant Impact No Impact \nVII. BIOLOGlCALRESOllRCES \nWould the proposal result in impacts to: \ns. Endangered. threatened or rare species or their \nhabitats (including but not limited to plants. \nfish, insects, animals, and birds)? \nb. Locally designated species? \nc. Locall) designated nalunl communit~cr \n(eg. oak forest. coaslal habitat, crc.)? \nd. Wetland habitat (e.g. marsh, riparian and \nvemal pwl)? \ne. Wildlife dispersal or migration corridors? \nVIII. ENERGY AND MlNf3RAL RESOURCES \nWould the proposal: \na. \t Connict with adopted energy \nconservation plans? \nb. \t Use \"an- renewable resources in a \nwasteful and inefficient manner7 \nc. \t Result in the loss of availability of a \nknown mineral resource that would be of \nfuture value to the region and the \nresidents of the State? \nIX. \tHALBQ \nWould the proposal involve: \na. \t A risk of accidental explosion or release \nof hazardous substances (including, but \nnot limited to: oil, pesticides, chemicals \nor radiation)? \nb. \t Possible ,nlcrfcrmcc with an cmcrgcncy \nresponse plan or emergency evacuation \nplan? \nc. \t The creation of any health hazard or \npotential health hazard? \nd. \t Exposure of people to existing sources of \npotential health hazards? \ne, \t Increased fire hazard in areas with \nflammable brush, grass, or trees? \nX. \tNQM \nWould the proposal result in: \na. \t Increases in existing noise levels? Potentially \nSignificant Impact Potentially \nSignificant Unless \nMitigation \nlncorparated Less Than \nSignificanl Impact No Impact \nb. Exposure of people to severe noise levels? \nXI, DLlC SERVICES \nWould the proposal have an effect upon or \nresult in a need for new or altered government \nservices in any of the following areas: \na. Fireprotection? \nb. Police protection? \nc. Schools? \nd. Maintenance of public facilities, including \nmads? \ne. Other governmental services? \nXII. UTILITIES AND SERVICE SYSTEMS \nWould the proposal result in a need far new \nsystems or supplies or subslantiai alterations to \nthe following utilities: \na. Power or natural gas? \nb. Communications systems? \nc. Local or ngional water treatment or \ndisvibutian facilities? \nd. Sewer or septic tanks? \ne. Storm water drainage? \nf. Solid waste disposal? \ng. Local or regional water supplies? \nXIII. AESTHETICS \nWould the proposal: \na. Affect a scenic vista or scenic highway? \nb. Have a demonstrable negative aesthetic \neffect? \nc. Create light or glare? \nXIV. CULTURAL RESOURCES \nWould the proposal: \na. Disturb paleontological resources? \nb. Disturb archaeological resources? Potentially \nSignificant Unless \nPotentially Mitigation Less Than \nSignificant Impact Incorporated Significant Impact \n[1 [1 [1\n c. \t Affect historical resources? \nd. \t Have the potential to cause a physical \nchange which would affect unique ethnic \nculmml values? \ne. \t Restrict existing religious or sacred uses \nwithin the potential impact area? \nXV. \t RECREATIQN \nWould the proposal: \na. \t Increase the demand forneighborhood at \nregional parks or other recreational \nfacilities? \nb. \t Affect existing recreational \nopportunities? \nXVI. MANDATORY FINDINGS OF \nSIGNIFICANCE \na \t Does lhs project havc thc polenlbal to \ndrgradc the qualily of the en%tmnment. \nsbbnanlislly reduce lhe habital of a fish \nor wildlife species, cause a fish or \nwildlife population to drop below self- \nsustaining levels, threaten to eliminate a \nplant or animal community. Reduce the \nnumber or restrict the range of a rare or \nendaneered olant or animal or eliminate -. \nimportant examples of the major periods \nof California history or prehistory? \nb. \t Dws the project have the potential to \nachieve shon-tern, lothe disadvantage \nor long-term, environmental goals? \nc. \t Does the project have impacts that are \nindividually limited, but cumulatively \nconsiderable? (lCumulativek \nconsiderable\" ieans that theincremental \neffeca of a oroiect are considerable when \nviewed in &nn&tion with the effects of \npas1 projects. the effeclr of other cuncnt \nprojects, and the effects of probable \nfuture projects). \nd. \t Does the project have enviranmenlal \neffeca which will cause substantial \nadverse effects an human beings, either \ndirectly orindirectly? C. Determination \nBased on the evaluation in FED (Environmental Effects section), I find that the proposed Policy \nfor the development of the Clean Water Act section 303(d) list will not have a significant adverse \neffect on the environment. \nDecember 2.2003 \nDate Stan art ikon, Chief \nDivision of Water Quality \nState Water Resources Control Board EXPLANATIONS \nLa.,b.,c.e. Land use and planning (e.g., general plans and zoning) delineate those areas that will \nbe developed, and the type and density of development to be allowed. There is nothing in the \nproposed Policy that requires property to be used in any way or prohibits property uses. \nLd. The placement of waters on the section 303(d) list, water quality limited segments category \nwill lead to the development of TMDLs or implementation of other regulatory actions. \nDepending on the pollutant and pollutant source, agricultural operations may be impacted by the \nimplementation of the TMDL or these other actions. Site-specific impacts of individual TMDLs \nwill be considered by the RWQCBs and SWRCB when the TMDL and implementation plans are \ndeveloped. Addressing these kinds on potential impacts at this stage would be speculative. \nILa.,b.,c.;XV.a. There is nothing in the proposed Policy that would affect population, housing or \nrecreation. \nIII.a, b, d. These geologic problems are not caused by water pollution or the development of the \nsection 303(d) list. However, during the implementation of TMDLs people could potentially be \nexposed to such impacts during the construction or operation of new facilities to treat water \npollution to reduce or eliminate pollutant inputs. If such actions are necessary the potential \nenvironmental effects will be addressed during the development of the TMDL and \nimplementation plan. \nIILc. Liquefaction occurs in the subsurface when the mechanical behavior of a granular material \nis transformed from a solid state to a liquid state due to loss of grain-to-grain contact during \nearthquake shaking. It occurs most often in areas underlain by saturated, unconsolidated \nsediments. Seismic ground failure is not caused or affected by water pollution or the \ndevelopment of the section 303(d) list. \nIILa.,b.,d.,e.,f.,g.,i.; V.d.; VLa.,b.,c.,d.,e.,f.,g.; VIII.a.,b.,IX.a.,b.,e.; X.a.,b.; XI.a.,b.,c.,d.,e.; \nXILa.,b.,f; XIII.a.,b.,c.; XIV.a.,b.,c.,d.,e. Exposure of people to geologic actions, landslides, \nerosion, impacts to transportation systems, energy impacts, odors, impacts to public services and \nutilities, impacts to wildlife areas, and impacts to aesthetics or cultural resources could occur \nduring the construction or operation of new facilities to treat water pollution as a result of \nadditional effort to reduce pollutant loads as a result of implementing TMDLs. If such actions are \nnecessary to address pollutant impacts to ensure that water quality standards are met, potential \nenvironmental effects will be addressed in the specific TMDL designed to address the water \nquality problem. \nIILh. Expansion of soils is influenced by amount of moisture change and type of soil (the amount \nof clay in the soil and the type of minerals in the clay). Shrink-swell is measured by the volume change in the soil. Placement of waters on the section 303(d) list does not affect the shrink-swell \ncapacity of soils. \nIV.a.,b.,d.,e.,f.,g.,i. The placement of waters on the section 303(d) list does not affect absorption \nrates, drainage patterns, surface runoff, flooding, quantity of surface or groundwater, surface \nwater currents, or groundwater flow or supply. The proposed Policy does not apply to \ngroundwater; it only applies to surface waters. \nIV.c, The proposed Policy is expected to provide procedures that would enable the SWRCB and \nthe RWQCBs to apply a consistent, scientifically defensible approach for assessing waters of the \nState in terms of water quality standards and beneficial use attainment. The section 303(d) list \nwould also direct the scheduling of waters that receive TMDLs. Depending on the pollutant and \npollutant source, many waters of the State may be impacted by the implementation of a TMDL \nor other regulatory actions necessary to address the listing. Site-specific impacts of individual \nTMDLs will be considered by the RWQCBs and SWRCB when the TMDL and implementation \nplans are developed. Addressing these kinds of site-specific potential impacts at this stage would \nbe speculative. \nIV.h.;V.a.,b. The proposed Policy does not apply to groundwater or air quality. \nV.C. The identification of water quality limited segments does not affect significantly \ntemperature, humidity, precipitation, winds, cloudiness, or other atmospheric conditions. \nVII.a.,b.,c.,d.,e.;XVLa. The proposed Policy is not expected to cause any significant adverse \neffects to plants and animals, including rare, threatened, or endangered species. The provisions \nof the proposed Policy are expected to result in a consistent and scientifically defensible \nsection 303(d) listing methodology. The provisions of the proposed Policy are expected to \nencourage better regulation of waters that do not meet water quality standards. Therefore, the \nproposed Policy will encourage protection of rare and endangered species as will as fish and \nwildlife habitats generally. If there are potential impacts to these resources identified in the \ndevelopment and implementation of TMDLs or other regulatory actions, the potential \nenvironmental effects will be addressed in the environmental documentation supporting the \nfuture action. \nVIILc. The proposed Policy does not involw or affect the availability of a mineral resource. \nIX.c.,d.;XVLd. The proposed Policy is not expected to cause adverse effects to human health. \nThe proposed Policy will identify waters that may pose a health hazard. \nXILc.,d.,e.,g. Effects on water utility and service systems could potentially occur if TMDLs \n(developed as a result of the proposed Policy) cause the regulated community to take compliance \nactions that involved construction or substantial alterations to treatment facilities. However, the \nPolicy will not require dischargers to take such compliance actions. If there are potential impacts \n281 to these resources identified in the development of TMDLs or other regulatory actions resulting \nfrom the section 303(d) list, then the potential environmental impacts will be addressed in the \nenvironmental documentation developed for these actions. For point discharges to waters placed \non the section 303(d) list, final permit limits will be unaffected by the listing because final \neffluent limits will be developed following the State Implementation Policy (SWRCB Order \nNO. 2001-06). \nXV.b. Pollutants in water and sediment can affect recreational opportunities such as swimming \nif water quality standards are not achieved in a water body. The provisions of the proposed \nPolicy establish consistent, scientifically defensible methods to determine if specific waters are \nnot meeting water quality standards. The provisions of the proposed Policy are expected to \nencourage better regulation of waters that do not meet water quality standards. Therefore, the \nproposed Policy will encourage protection of human health. If there are potential impacts to \nthese resources identified in the development and implementation of TMDLs or other regulatory \nactions, the potential environmental effects will be addressed in the environmental \ndocumentation supporting these actions \nXVLa.,c.: See the section of the FED that addresses cumulative and long-term impacts. GLOSSARY \na (Alpha) \nAlternate hypothesis \nBeneficial Uses \nBest Management Practices (BMP) \nBINOMDIST \nBinomial Distribution \nBioaccumulation \nBioassessment The statistical error of rejecting a null hypothesis that is true. \nThis type of error is also called Type I error. \nA statement or claim that a statistical test is set up to establish. \nUses of water that may be protected against degradation include, \nbut are not limited to, domestic, municipal, agricultural and \nindustrial supply; power generation; recreation; aesthetic \nenjoyment; navigation; preservation and enhancement of fish, \nwildlife, and other aquatic resources and preserves (CWC \nsection 13050(f)). \nThe statistical error of failing to reject a null hypothesis that is \nnot true. This type of error is also called Type I1 error. \nMethods, measures or practices selected by an agency to meet its \nnonpoint source control needs. BMPs include but are not limited \nto structural and nonstructural controls and operation and \nmaintenance procedures. BMPs can be applied before, during \nand after pollution producing activities to reduce or eliminate the \nintroduction of pollutants into receiving waters. \nAn Excel@ function that is used to calculate the cumulative \nbinomial distribution. \nA binomial distribution statistically describes the probabilities \nassociated with the possible number of times particular outcomes \nwill occur in series of observations (i.e., samples). Each \nobservation may have only one of two possible results \n(e.g., yeslno, onloff, and violation/compliance). The following \nassumptions must apply in order to reliably employ binomial \ndistribution statistics: \n+ \tEach observation may result in only two possible outcomes. \n+ \tAn \"experiment\" consists of N identical trials or observations. \n+ \tThe probability of one particular result (out of two) remains \nconstant from one observation to the next. \n+ \tThe observations (i.e., samples) are independent, so that the \noutcome of one observation has no effect on the outcome of \nanother. \nThe process by which a chemical is taken up by an aquatic \norganism, both from water and through food. \nBiological assessment is the use of biological community \ninformation along with the measure of the physicalrhabitat quality to determine, in the case of water quality, the integrity of \na water body of interest. \nContamination An impairment of the quality of the water of the state by waste to \na degree which creates a hazard to the public health through \npoisoning or through the spread of disease. \"Contamination\" \nincludes any equivalent effect resulting from the disposal of \nwaste whether or not waters of the state are affected (CWC \nsection 13050(k)). \nCalifornia Toxics Rule (CTR) USEPA established numerical water quality criteria for priority \ntoxic pollutants for California Inland Surface Waters, Enclosed \nBays and Estuaries. \nConventional Pollutants Include dissolved oxygen, pH, and temperature (from the \nsection 305(b) guidance). \nDie1 Pertaining to a 24-hour period of time; a regular daily cycle. \nEffect size The maximum magnitude of exceedance frequency that is \ntolerated. \nEffects Range-Median (ERM) and \nEffects Range-Low (ERL) Values Sediment quality guidelines based on a biological effects \nempirical approach. These values represent chemical \nconcentration ranges that are rarely (i.e., below the ERL), \nsometimes (i.e., between ERL and ERM), and usually (i.e., \nabove the ERM) associated with toxicity for marine and estuarine \nsediments. Ranges are defined by the tenth percentile and fiftieth \npercentile of the distribution of contaminant concentrations \nassociated with adverse biological effects. \nEquilibrium Partitioning (EqP) \nApproach Methodology of developing sediment quality guidelines that \nassumes that an organism receives an equivalent exposure from \nwater only exposures or from any equilibrated phase (e.g., either \nfrom pore water via respiration; or from organic carbon, via \ningestion; or from a mixture of the routes). Approach results in \nguideline values expressed in terms of a sediment phase \ncontrolling contaminant bioavailability (e.g., organic carbon for \nnonionic organic compounds or sulfides for metals). \nEquilibrium Partitioning Sediment \nGuidelines Sediment quality guidelines derived using the EqP approach. \nWhen used in conjunction with appropriately protective water \nonly exposure concentration, a resulting guideline represents the \nsediment contaminant concentration that protects benthic \norganisms from the effects of that contaminant. of Biological Integrity (IBI) \t The response of indicators designed to monitor or detect \nbiological, community, or ecological conditions. IBI is a \nmultimetric index indicating the ability of a habitat to support and \nmaintain a balanced, integrated, adaptive biological system \nhaving the full range of elements expected in a region's natural \nhabitat. \nMaximum contaminant Level \n(MCL) The maximum permissible level of a contaminant in water \ndelivered to any user of a public water system. \nMaximum Tissue Residue Level \n(MTRL) \t MTRLs were developed from human health water quality \nobjectives in the 1997 California Ocean Plan and from the \nCalifornia Toxic Rule as established in the Policy for \nImplementation of Toxics Standards for Inland Surface Waters, \nEnclosed Bays, and Estuaries of California. MTRLs are used as \nalert levels or guidelines indicating water bodies with potential \nhuman health concerns and are an assessment tool and not \ncompliance or enforcement criteria. The MTRLs are calculated \nby multiplying human health water quality objectives by the \nbioconcentration factor for each substance. \nNational Academy of Science \n(NAS) Tissue Guidelines \t NAS guidelines are established guidelines for the protection of \npredators. Values are suggested for residues in whole fish (wet \nweight) for DDT (including DDD and DDE), aldrin, dieldrin, \nendrin, heptachlor (including heptachlor epoxide), chlordane, \nlindane, benzene hexachloride, toxaphene, and endosulfan either \nsingularly or in combination. \nNational Toxics Rule \t USEPA established numerical water quality criteria for priority \ntoxic pollutants for 12 states and two Temtories who failed to \ncomply with the section 303(c)(2)(B) of the Clean Water Act. \nNonpoint Source \t Pollution sources are diffused and do not have a single point of \norigin or are not introduced into a receiving stream from a \nspecific outlet. The commonly used categories for nonpoint \nsources are agriculture, forestry, mining, construction, land \ndisposal, and salt intrusion. \nNull hypothesis \t A statement used in statistical testing that has been put forward \neither because it is believed to be true or because it is to be used \nas a basis for argument, but has not been proved. \nPoint Source \t Any discernible, confined, and discrete conveyance, including \nbut not limited to, any pipe, ditch, channel, tunnel, conduit, well, \ndiscrete fissure, container, rolling stock, concentrated animal \nfeeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants are or may be \ndischarged. This term does not include return flows from \nirrigation agriculture or agricultural storm water runoff \n(40 CFR 122.2). \nPollutants Defined in section 502(6) of the CWA as \"dredged spoil, solid \nwaste, incinerator residue, filter backwash, sewage, garbage, \nsewage sludge, munitions, chemical wastes, biological materials, \nradioactive materials, heat, wrecked or discarded equipment, \nrock, sand, cellar dirt and industrial, municipal, and agricultural \nwaste discharged into water.\" \nPollution The termpollulurion is defined in section 502(19) of the CWA as \nthe \"the man-made or man-induced alteration of the chemical, \nphysical, biological, and radiological integrity of water.\" \nPollution is also defined in CWC section 13050(1) as an \nalternation of the quality of the waters of the state by waste to a \ndegree that unreasonably affects either the waters for beneficial \nuses or the facilities that serve these beneficial uses. \nProbable Effect Concentration \n(PEC) Consensus based PECs are empirically derived freshwater \nsediment quality guidelines (SQG) that rely on the correlation \nbetween the chemical concentration in field collected sediments \nand observed biological effects. PECs are based on geometric \nmeans of various SQG approaches (with matching chemical and \ntoxicity field data) to predict toxicity for freshwater sediment on \na regional and national basis. \nProbable Effects Level (PELS) \nand Threshold Effects Levels (TEL) Sediment quality guidelines based on a biological effects \nempirical approach similar to ERMs/ERLs. A generalized \napproach used to develop effects-based guidelines for the state of \nFlorida and others. The lower of the two guidelines for each \nchemical (i.e., the TEL) is assumed to represent the concentration \nbelow which toxic effects rarely occuf. In the range of \nconcentrations between the two guidelines, effects occasionally \noccur. Toxic effects usually or frequently occurs at \nconcentrations above the upper guideline value (i.e., the PEL). \nRanges are defined by specific percentiles of both the distribution \nof contaminant concentrations associated with adverse biological \neffects and the \"no effects\" distribution. \nRank correlation \t Association between paired values of two variables that have \nbeen replaced by their ranks within their respective samples (e.g., \nchemical measurements and response in a toxicity test). Reference Condition \nSpatial Representation \nStatistical Significance \nTemporal Representation \nTotal Maximum Daily Load \n(TMDL) \nToxicants \nToxicity Identification Evaluation \n(TIE) \nToxicity Test The characteristics of water body segments least impaired by \nhuman activities. As such, reference conditions can be used to \ndescribe attainable biological or habitat conditions for water body \nsegments with common watershed/catchment characteristics \nwithin defined geographical regions. \nThe degree of compatibility or overlap in the study area, \nlocations of measurements or samples, locations of stressors or \npotential pollutant sources, and locations of potential exposure to \npollutants. \nA finding (for example, the observed difference between the \nmeans of two random samples) is statistically significant when it \ncan be demonstrated the probability of obtaining such a \ndifference by chance only is relatively low. \nCompatibility or overlap between measurements (when data were \ncollected or the period for which data are representative) and the \nperiod during which effects of concern would likely to be \ndetected. \nTMDL is the sum of individual wasteload allocations and load \nallocations; a margin of safety. TMDLs can be expressed in \nterms of mass per time, toxicity, or other appropriate measures \nthat relate to a state's water quality standards. \nInclude priority pollutants, metals, chlorine and nutrients (from \nthe section 305(b) guidance). \nTIE is technique to identify the unexplained cause(s) of toxic \nevents. TIE involves selectively removing classes of chemicals \nthrough a series of sample manipulations (e.g. solid phase \nextraction to remove organic compounds), effectively reducing \ncomplex mixtures of chemicals in natural waters to simple \ncomponents for analysis. Following each manipulation the \ntoxicity of the sample is assessed to see whether the toxicant \nclass removed was responsible for the toxicity. \nA test to determine the toxicity of a chemical in ambient water \nusing living organisms. A toxicity test measures the degree of \neffect on exposed test organism. Toxicity is determined when \nthere is a statistically significant difference in mortality, andor \ngrowth and reproduction of an organism in water compared to the \nlaboratory control. Waste Discharge Requirements \n(WDR) \nWater Quality Limited Segment \nWater Quality Objectives \nWater Quality Standard WDRs are issued under State law pursuant to CWC section \n13263 and apply to dischargers that discharge waste to land or to \nwater. WDRs implement water quality control plans, take into \nconsideration beneficial uses, water quality objectives, other \nwaste discharges, the need to prevent nuisance, and the \nprovisions of CWC section 13241. The disposal method may be \nby agricultural or non-agricultural irrigation, ponds, landfills, \nmono-fills, or leachfields. \nAny segment [of a water body] where it is known that water \nquality does not meet applicable water quality standards, and lor \nis not expected to meet applicable water quality standards, even \nafter application of technology-based effluent limitations required \nby CWA sections 301(d) or 306 as defined in the federal \nregulation. \nThe limits or levels of water quality constituents or \ncharacteristics which are established for the reasonable protection \nof beneficial uses of water or the prevention of nuisance within a \nspecific area. \nProvisions of State and Federal Law which consist of a \ndesignated use or uses for the waters of the United States, water \nquality criteria for such waters based upon such uses. 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Washington D.C.: Office of Research and Development, U.S. \nEnvironmental Protection Agency. \nUSEPA. 1991d. Policy on the use of biological assessment in the water \nquality program. Washington, D.C.: U.S. Environmental Protection \nAgency. \nUSEPA. 1991e. Policy on the use of biological assessments and criteria in \nthe water quality program. Washington, D.C.: Office of Water, U.S. \nEnvironmental Protection Agency. \nUSEPA. 1991f. Technical support document for water quality-based \ntoxics control. EPA-505-2-90-001. Washington D.C.: Office of Water, \nU.S. Environmental Protection Agency. \nUSEPA. 1992a. Appendix K procedures for initiating narrative biological \ncriteria. In Water Oualitv Standards Handbook, Second Edition. EPA-822- \nB-92-002. washington, D.c.:Office of Water, U.S. Environmental \nProtection Agency. \nUSEPA. 1992b. Plastic pellets in the aquatic environment sources and \nrecommendations: Final report. EPA-842-B-010. Washington, D.C.: U.S. \nEnvironmental Protection Agency. \nUSEPA. 1993a. Methods for aquatic toxicity identification evaluations: \nPhase I1 toxicity identification procedures for samples exhibiting acute \nand chronic toxicity. EPA-600-R-92-080. Washington D.C.: Office of \nResearch and Development, U.S. Environmental Protection Agency. USEPA. 1993b. Methods for aquatic toxicity identification evaluations: \nPhase I11 toxicity conformation procedures for samples exhibiting acute \nand chronic toxicity. EPA-600-R-92-081. Washington D.C.: Office of \nResearch and Development, U.S. Environmental Protection Agency. \nUSEPA. 1993c. Methods for measuring the acute toxicity of effluents and \nreceiving waters to freshwater and marine organisms. Fourth edition. \nEPA-600-4-90-027F. Washington D.C.: Office of Research and \nDevelopment, U.S. Environmental Protection Agency. \nUSEPA. 1993d. Technical basis for establishing sediment quality criteria \nfor nonionic contaminants for the protection of benthic organisms using \nequilibrium partitioning. EPA-822-R-93-011. Washington, D.C.: Office \nof Science and Technology, U.S. Environmental Protection Agency. \nUSEPA. 1994a. Methods for assessing the toxicity of sediment-associated \ncontaminants with estuarine and marine amphipods. EPA-600-R-94-025. \nWashington, D.C.: Office of Research and Development, U.S. \nEnvironmental Protection Agency. \nUSEPA. 1994b. Short-term methods for estimating the chronic toxicity of \neffluents and receiving water to marine and estuarine organisms. Second \nedition. EPA-600-4-91-003. Cincinnati, OH: Environmental Monitoring \nSystem Laboratory, U.S. Environmental Protection Agency. \nUSEPA. 1994c. Short-term methods for estimating the chronic toxicity of \neffluents and receiving water to freshwater organisms. Third edition. \nEPA-600-4-91-002. Washington D.C.: Office of Research and \nDevelopment, U.S. Environmental Protection Agency. \nUSEPA. 1994d. Water Quality Standards Handbook: Second Edition. \nEPA-823-8-94-005a. Washington D.C: U.S. Environmental Protection \nAgency, Office of Water. \nUSEPA. 1995. Short-term methods for estimating the chronic toxicity of \neffluents and receiving waters to west coast marine and estuarine \norganisms. EPA-600-R-95-136. Washington D.C.: Office of Research and \nDevelopment, U.S. Environmental Protection Agency. \nUSEPA. 1996a. Guidance for assessing chemical contamination data for \nuse in fish advisories. Volume 111: Overview of risk management. \nWashington, D.C.: Office of Water, U.S. Environmental Protection \nAgency. htt~://www.e~a.~ov/ost/fishadvice/vol3/ch0.~df. \nUSEPA. 1996b. Marine toxicity identification evaluation (TIE): Phase I: \nGuidance document. EPA-600-R-96-054. Washington D.C.: Office of \nResearch and Development, U.S. Environmental Protection Agency. USEPA. 1997a. Environmental Monitoring and Assessment Program: \nIntegrated quality assurance project plan surface waters research activities. \nOffice of Research and Development, U.S. Environmental Protection \nAgency. \nUSEPA. 1997b. Guidelines for preparation of the comprehensive state \nwater quality assessments (305(b) reports) and electronic updates. EPA- \n841-B-97-002A. Washington D.C.: Assessment and Watershed Protection \nDivision (4503F), Office of Wetlands, Oceans, and Watersheds, and \nOffice of Waters, U.S. Environmental Protection Agency. \nUSEPA. 1997c. Guidelines for preparation of the comprehensive state \nwater quality assessments (305(b) reports) and electronic updates: \nSupplement. EPA-841-B-97-002B. Washington D.C.: Assessment and \nWatershed Protection Division (4503F), Office of Wetlands, Oceans, and \nWatersheds, and Office of Waters, U.S. Environmental Protection \nAgency. \nUSEPA. 1997d. The incidence and severity of sediment contamination in \nsurface waters of the United States. Volume 1: National Sediment Quality \nSurvey. EPA-823-R-97-006. Washington D.C.: Science and Technology, \nU.S. Environmental Protection Agency. \nUSEPA. 1998a. Evaluation of dredged material proposed for discharge in \nwaters of the U.S. -Testing manual (Inland Testing Manual). EPA-823- \nB-98-004. Washington D.C.: Ofice of Science and Technology, Office of \nWater, U.S. Environmental Protection Agency and Operations, \nConstruction, and Readiness Division. U.S. Department of the Army, \nArmy Corps of Engineers. htt~://www.eva.~ovlost~itmltotal.~df \nUSEPA. 1998b. Guidelines for ecological risk assessment. EPA-630-R- \n95-002F. Washington, D.C.: U.S. Environmental Protection Agency. \nUSEPA. 1998c. National strategy for the development of regional nutrient \ncriteria. EPA-822-R-98-002. Washington, D.C.: Office of Water, U.S. \nEnvironmental Protection Agency. \nUSEPA. 1998d. Guidance for data quality assessment: Practical methods \nfor data analysis. EPA-600-R-96-084. EPA QAIG-9. QA97 Version. \nWashington D.C.: Office of Research and Development, U.S. \nEnvironmental Protection Agency. \nUSEPA. 1999a. California Toxics Rule: Responses to Comments. \nVolumes I and 11. Washington D.C.: U.S. Environmental Protection \nAgency, Office of Science and Technology and San Francisco, CA: U.S. \nEnvironmental Protection Agency, Region 9. USEPA. 1999b. Petition for repeal of 40 CFR 122.3. Office of Wetlands, \nOceans & Watersheds \\ Ocean, Coasts & Estuaries \\ Invasive Species. \nhtt~://www.e~a.govlowow/invasive\n s~ecies/vetitionl.html \nUSEPA. 1999c. Review of California's 1998 section 303(d) list; \nAttachment to letter from Alexis Strauss, USEPA to Water Pettit, \nSWRCB; Staff Report Prepared by D. Smith and J. Karkoski, USEPA. \nSan Francisco: U.S. Environmental Protection Agency, Region M. \nUSEPA. 2000a. Guidance for the data quality assessment: Practical \nmethods for data analysis. EPA-600-R-96-084, EPA QNG-9, QAOO \nUpdate. Washington D.C.: Office of Environmental Information, U.S. \nEnvironmental Protection Agency. \nUSEPA. 2000b. Guidance for the data quality objectives process. EPA- \n600-R-96-055, EPA QNG-4. Washington, D.C: Office of Research and \nDevelopment, U.S. Environmental Protection Agency. \nUSEPA. 2000c. Guidance for assessing chemical contaminant data for use \nin fish advisories. Volume 1:Fish sampling and analysis. Third edition. \nEPA-823-B-00-007. Washington, D.C.: Office of Water, U.S. \nEnvironmental Protection Agency. \nUSEPA. 2000d. Methodology for deriving ambient water quality criteria \nfor the protection of human health (2000). EPA- 822-B-00-004. \nWashington, D.C.: Office of Water, U.S. Environmental Protection \nAgency. \nUSEPA. 2000e. Methods for measuring the toxicity and bioaccumulation \nof sediment-associated contaminants with freshwater invertebrates. \nSecond edition. EPA-600-R-99-064. Washington D.C.: Office of Research \nand Development, Office of Science and Technology, U.S. Environmental \nProtection Agency. \nUSEPA. 2001a. Draft report: Aquatic nuisance species in ballast water \ndischarges: Issues and options. Washington, D.C.: U.S. Environmental \nProtection Agency. \nUSEPA. 2001b. National coastal assessment: Quality assurance project \nplan 2001-2004. EPA-620-R-01-002. Washington D.C.: Office of \nkesearch and Development and Environmental Monitoring and \nAssessment Programs, U.S. Environmental Protection Agency. \nUSEPA. 2002a. Consolidated assessment and listing methodology toward \na compendium of best practices. First edition. Washington, D.C.: Office of \nWetlands, Oceans, and Watersheds, U.S. Environmental Protection \nAgency. USEPA. 2002b. Draft strategy for water quality standards and criteria: \nStrengthening the foundation of programs to protect and restore the \nNation's waters. EPA-823-R-02-001. Washington, D.C.: Office of Water, \nU.S. Environmental Protection Agency. \nUSEPA. 2002c. Short-term methods for estimating the chronic toxicity of \neffluents and receiving waters to freshwater organisms. Fourth edition. \nEPA 821-R-02-013. Washington D.C.: Office of Water, U.S. \nEnvironmental Protection Agency. \nUSEPA. 2002d. Methods for measuring acute toxicity of effluents and \nreceiving waters to freshwater and marine organisms. Fifth edition. EPA- \n821-R-02-012. Washington D.C.: Office of Water, U.S. Environmental \nProtection Agency. \nUSEPA. 2002e. Short-term methods for estimating the chronic toxicity of \neffluents and receiving waters to marine and estuarine organisms. Third \nedition. EPA-821-R-02-014. Washington D.C.: Office of Water, U.S. \nEnvironmental Protection Agency. \nUSEPA. 2003a. EPA Region 10 guidance for Pacific Northwest state and \ntribal temperature water quality standards. EPA 910-B-03-002. Seattle, \nWA: Office of Water, Region 10, U.S. Environmental Protection Agency. \nUSEPA. 2003b. Guidance for 2004 assessment, listing and reporting \nrequirements pursuant to sections 303(d) and 305(b) of the Clean Water \nAct. Washington, D.C.: Office of Wetlands, Oceans, and Watersheds, \nU.S. Environmental Protection Agency. \nUSEPA. 2003c. Marine debris abatement: Trash in our oceans-You can \nbe part of the solution. U.S. Environmental Protection Agency. \nhttp:/www.epa.gov/egi-bin1epaprintonly.egi \nUSEPA. 2003d. Surface waters western pilot study: Field operations \nmanual for wadeable streams. Washington D.C.: Environmental \nMonitoring and Assessment Program and Office of Research and \nDevelopment, U.S. Environmental Protection Agency. \nUSEPA. 2003e. Decision document regarding Department of \nEnvironmental Protection's 303(d) list amendment submitted on October \n1,2002 and subsequently amended on May 12,2003. U.S. Environmental \nProtection Agency, Region IV, Water Management Division. \nUSEPA. 2003f. USEPA Approval of the 2002 section 303(d) List. Letters \ndated: June 5,2003 and June 25,2003. San Francisco, CA: U.S. \nEnvironmental Protection Agency, Region IX. USEPA. 2003g. Denial Letter: Decision to petition for rulemaking to \nrepeal 40 C.F.R. 122.3(a). Washington, D.C.: U.S. Environmental \nProtection Agency. \nUSFDA. 1987. Action levels for poisonous or deleterious substances in \nhuman food and animal feed. Washington D.C. Guidelines and \nCompliance Research Branch, Center for Food Safety and Applied \nNutrition. United States Food and Drug Administration. \nUtah Department of Environmental Quality. 2004. Utah's 2004 303(d) list \nof impaired waters. Castle Valley, UT: Division of Water Quality, \nDepartment of Environmental Quality. \nVeldhuizen, T.C. 2001. Life history, distribution, and impacts of the \nChinese Mitten Crab, Eriocheir sinensis. Aquatic Invaders Digest 12: 1-9. \nVirginia Department of Environmental Quality. 2002. Water quality \nassessment guidance manual for Y2002 305(b) water quality report and \n303(d) impaired water list. \nhtt~://www.dea.state.va.us/watereuidance/pdf/022003.vdf \nWashington Department of Ecology (DEP). 2002. Water quality program \nassessment: Assessment of water quality for the section 303(d) list. \nWashington State Department of Ecology. \nhtto:Nwww.krisweb.com/krisbig-riverkrisdbktm1kris~eb/poIicy/policv.p \n-d f \nWetzel, R.G. 2001. Limnology Lake and River Ecosystems. Third Edition. \nLondon: Academic Press. \nWilliamson, S. 2001. Get comfortable with uncertainty in resource \nmanagement decisions. Arizona Water Resource. U.S. Geological Survey. \nhtto://a~.arizona.eddAZWATER/awr/marap~l/readinr.htm. \nWoodley, J. 2002. Assessing and monitoring floatable debris. EPA-842- \nB-02-002. Washington D.C.: Office of Water, Oceans and Coastal \nProtection Division, Marine Pollution Control Branch, U.S. \nEnvironmental Protection Agency. \nYe, K., and E.P. Smith. 2002. A Bayesian approach to evaluating site \nimpairment. Environmental and Ecological Statistics. 9:379-392. \nYoder, C.O. Answering some concerns about biological criteria based on \nexperiences in Ohio. Columbus, OH: Ohio Environmental Protection \nAgency. Yoder, $2.0. and E.T. Rankin. 1995. The role of biological criteria in \nwater quality monitoring, assessment, and regulation. Columbus, OH: \nDivision of Surface Water, Ohio Environmental Protection Agency. \nZar, J.H. 1999.Biostatistical Analysis. Fourth Edition. New Jersey: \nPrentice Hall. FINAL \nFunctional Equivalent Document \nAppendix A \nWater Quality Control Policy \nSEPTEMBER 2004 \nDIVISION OF WATER QUALITY \nSTATE WATER RESOT TRCES CONTROT, BOARD \n STATEWATERRESOURCES \nCONTROL BOARD \nP.O. I00 \nSacramento, CA 95812-0100 \nTo request copies of the draft Final FED \nand proposed Policy please call \n(916)341-5566. \nDocuments are aiso available at: \nhttp://www.swrcb.ca.gov State of California \nSTATE WATER RESOURCES CONTROL BOARD \nAPPENDIX A \nSeotember 30.2004Atl++%W \n&FINAL \n3247 \n Revisions are based on the comments received at the \nSeptember 8,2004 workshop. The changes are presented in \n&ke& (for removed text) and underline (for added text). \nThe changes recommended in the July 22,2004 version of \nthe Policy are not highlight. These previous modifications \nare available upon request. I -.. 0- 30.20 September \nTable of Contents \n1 INTRODUCTION ............................................................................................................................................. 1 \n2 STRUCTURE OF THE CWA SECTION 303(D) LIST............................ i................................................... 3 \nWATER SEGMEN 2.1 \t QUALITY LIMITED TS\n........................................................................................ .....3 \n2.2 \t SEGMENTS ADDRESSED WATER QUALITY LIMITED BEING \n ............................................................. 3 \n3 CALIFORNIA LISTING FACTORS .............................................................................................................. 4 \n3.1 \t WATER QUALITY OBJECTIVES AND CRITERIA IN WATER NUMERIC \t FOR TOXICANTS ....................... 4 \n3.2 \t NUMERIC WATER QUALITY OBJECTIVES FOR CONVENTIONAL \nOR OTHER POLLUTANTS IN WATE R......................................................................................... .......\n4 \n3.3 \t NUMERICAL WATER QUALITY OBJECTIVES OR STANDARDS FOR \nBACTERIA WHERE RECREATIONAL USES APPLY ......................................................................... 5 \n3.4 HEALTH ADVISORIES .................................................................................................................. ..5 \n3.5 \t OF POLLUTANTS LIFE TISSU BIOACCUMULATION IN AQUATIC \t E.................................................. .....\n5 \n3.6 \t TOXICI WATEVSEDIMENT \t TY...................................................................................................... ...\n6 \n3.7 NUISANC .................................................................................................................................E \t ....\n6 \n3.7.1 Nutrient-related ............................................................................................................... ............6 \n3.7.2 Other Types ................................................................................................................................. 7 \n3.8 ADVERSE RESPONSE BIOLOGICAL .......................................................................................... ..........\n7 \nPOPULATIONS .............................................. 7\n 3.9 DEGRADATION OF BIOLOO~CAL AND COMMUNITIES \n3.10 TRENDS IN WATER QUALITY ........................................................................................................ 8 \n3.11 \t WEIGHT LISTING FACTOR .................................................. 8\n SITUATION-SPECIFIC OF EVIDENCE \n4 CALIFORNIA DELISTING FACTORS ..................................................................................................... .12 \n4.1 NUMERIC WATER QUALITY~BJECTIVES. OR STANDARDS CRITERIA. \nFOR TOXICANTS ........................................................................................................... 12 IN WATER \n4.2 NUMERIC WATER QUALITY OBJECTIVES EOR CONVENTI'ONAL OR \nOTHER POLLUTANTS .................................................................................................. 13\n IN WATER \n4.3 NUMERIC WATER QUALITY OBJECTIVES FOR BACTERIA IN WATER ............................... ......... 13 \n4.4 \t ADVISORIES HEALTH \t .............................................................................................................. ......\n13 \n4.5 BIOACCUMULATION \t LIFE TISSUE OF POLLUTANTS IN AQUATIC \t .............................................. \n 13 \n4.6 \t WATERISEDIMENTTOXICITY \t .............. .................................................................................. ..........\n13 \n4.7 NUISANC E............................................................................................................................ .........13 \n4.7.1 Nutrient-related .................................................................................................................. ............\n13 \n4.7.2 Other Types ....................... ............................................................................................... \t .........\n13 \n4.8 \t BIOLOGICAL ................................................................................................... 14\n ADVERSE RESPONSE \n4.9 DEGRADATION OF B~OLOG~CAL AND COMMUNITIES POPULATIONS \t ........................................... .....\n14 \n4.10 TRENDS IN WATER QUALITY \t 14\n ........................................................................................................ \n4.11 \t WEIGHT DELISTING FACTOR ............................................... 14\n S~TUATION-SPECIFIC OF EVIDENCE \n5 TMDL SCHEDULING ................................................................................................................................ .17 \n6 POLICY IMPLEMENTATION .................................................................................................................... 18 \n6.1 PROCESS FOR EVALUATION\t OF READILY AVAILABLE DATA AND INFORMATION 18 ...................... \n6.1.1 Definition of Readily Available Data and Information .............................................................. 18 \n6.1.2 Adn~inistration of the Listing Process ........................................................................................ 18 \n6.1.2.1 Solicitation of All Readily Available Data and Information \t 18 \nRWQCB Fact Sheet Preparation ........\n........ \n6.1.3 Evaluation Guideline Selection Process ...................................... A ........................... ...\n21 6.1.2.2 20 .................. \n 6.1.4 Data Quality Assessment Process ............................................................................................ .....22 \n6.1.5 Data Quantity Assessment Process ............................................................................ ................... 23 \n6.1.5.1 Water Body Specific Information ........................................................ \t 24 \n6.1.5.2 Spatial Representation .................................... ............................. \t 24 \n6.1.5.3 Temporal Representation ......................................................................................................... 24 \n6.1.5.4 rep regal ion of Data by ReachIArea ................................................................................................... .......24 \n6.1.5.5 O!iantitation of Chemical Concenwations ........................ ................................................................. 25\n - ~\t - ~. \n6.1S.6 \t Evaluation of Data Consistent wilh heExpression of Numeric Water Qual~ty \n..Obiectives .Wa~er Oualirv Criteria .or Evaluation Guidelincs ................................ ................................. 25 ........ .. \n6.1.5.7 Binomial Model Statistical Evaluation ..................................................................................................... .25 \n6.1.5.8 Evaluation of Bioassessment Data \t.............................................................................................................. .....\n26 \n6.1.5.9 Evaluation of Temperature Data ............................................................................................................... 26 \n6.2 RWQCB APPROVAL .................................................................................................................. ..27 \n............................ 6.3 SWRCB APPROVAL ............................................................................ .......\n27 \n7 DEFINITIONS ........................................................................................................................... .................... 28 \n September 30.200-1 \nWATER QUALITY CONTROL POLICY \nFOR DEVELOPING \nCALIFORNIA'S CLEAN WATER ACT SECTION 303(d) LIST \n1 Introduction \nPursuant to California Water Code section 13191.3(a), this State policy for water quality control \n(Policy) describes the process by which the State. Water Resources Control Board (SWRCB) and \nRegional Water Quality Control Boards (RWQCBs) will comply with the listing requirements of \nsection 303(d) of the federal Clean Water Act (CWA). The objective of this Policy is to \nestablish a standardized approach for developing California's section 303(d) list in order to \nachieve the overall goal of achieving water quality standards and maintaining beneficial uses in \nall of California's surface waters. \nCWA section 303(d) requires states to identify waters that do not meet, or are not expected to \nmeet by the next listing cycle, applicable water quality standards after the application of certain \ntechnology-based controls and schedule such waters for development of Total Maximum Daily \nLoads (TMDLs) [40 Code of Federal Regulations (CFR) 130.7(c) and (d)]. The states are \nrequired to assemble and evaluate all existing and readily available water quality-related data and \ninformation to develop the list [40 CFR 130.7(b)(5)] and to provide documentation for listing or \nnot listing a state's waters [40 CFR 130.7(b)(6)]. The methodology to be used to develop the \nsection 303(d) list [40 CFR 130.7@)(6)(i)] is established by this Policy and includes: \nCalifornia Listing Factors and Delisting Factors; \nThe process for gathering and evaluating of readily available data and information; and \nTotal Maximum Daily Load (TMDL) scheduling. \nThis Policy applies only to the listing process methodology used to comply with CWA \nsection 303(d). In order to make decisions regarding standards attainment, this Policy provides \nguidance for interpreting data and information as they are compared to beneficial uses, existing \nnumeric and narrative water quality objectives, and antidegradation considerations. The Policy \nshall not be used to: \ndetermine compliance with any permit or waste discharge requirement provision; \nestablish, revise, or refine any water quality objective or beneficial use; or \ntranslate narrative water quality objectives for the purposes of regulating point sources. \nData and information from water bodies shall be analyzed under the provisions of this Policy \nusing a weight-of-evidence approach. The weight-of-evidence approach shall be used to September 30,2004%4y 33 -1--, 3!?CM . \nevaluate whether the evidence is in favor of or against placing waters on or removing waters \nfrom the section 303(d) list (section 2). The following steps describe the weight-of-evidence \napproach: \n1. \tData and Information Preprocessing: All data and information for existing listings shall be \nsolicited and assembled, as appropriate (sections 6.1.1 and 6.1.2.1). Water body fact sheets \n(section 6.1.2.2) describing the assessments shall be prepared. Evaluation guidelines \n(section 6.1.3), if needed, shall be selected and the quality of the data (section 6.1.4) and \nquantity of data (section 6.1.5) shall be assessed. \n2. \tData and Information Processing: All data and information shall be evaluated using the \ndecision rules listed in sections 3 or 4, as appropriate, and using applicable implementation \nfactors (including, but not limited to, sections 6.1.2.2 and 6.1.5.1 through 6.1 S.9). RWQCBs \nshall also develop a schedule for completion of TMDLs (section 5). All other information \nnot addressed under sections 3,4,5, or 6, shall be evaluated and presented in fact sheets. \n3. \tData Assessment: An assessment in favor of or against a list action for a water body- . \npollutant combination shall be presented in fact sheets. The assessment shall identify and \ndiscuss relationships between all available lines of evidence for water bodies and pollutants. \nThis assessment shall be made on a pollutant-by-pollutant (including toxicity) basis. \nRWQCBs shall approve all decisions to list or delist a water segment (section 6.2). I September 30,200- --.-\n2 Structure of the CWA Section 303(d) List \nThis section describes the categories of waters that shall be included in the section 303(d) list. \nSections 3 and 4 contain the factors that shall be used to add and remove waters from the list. At \na ~ninimum, the California section 303(d) list shall identify waters where standards are not met, \nvollutants or toxicity contributing to standards exceedance, and the TMDL completion schedule. \n?he section 303(d) iist shall conkin the following categories: \n2.1 Water Quality Limited Segments \nWaters shall be placed in this category of the section 303(d) list if it is determined, in accordance \nwith the California Listing Factors, that the water quality standard is not attained; the standards \nnonattainment is due to toxicity, a pollutant, or pollutants; and remediation of the standards \nattainment problem requires one or more TMDLs. \nThe water segment shall remain in this category of the section 303(d) list until TMDLs for all \npollutants have been completed, U.S. Environmental Protection Agency (USEPA) has approved \nthe TMDLs, and implementation plans have been adopted. \n2.2 Water Quality Limited Segments Being Addressed \nWater segments shall be placed in this category if the conditions for vlacement in the water \naualitv limited segments category (section 3) are met and either of the following conditions is .. ~...met:-\t .. \n1. \tA TMDL has been developed and approved by USEPA and the approved implementation \nplan is expected to result in full attainment of the standard within+m-a&@d a specified time I \nframe; or \n-The \t RWQCB has determined in fact sheets that an existing regulatory \nprogram is reasonably exvected to result in the attainment of the water qualitv standard \nwithin a reasonable, specified time frame. \nWaters shall only be removed from this category if it is demonstrated in accordance with \nsection 4 that water quality standards are attained. September 30.20-1 \n3 California Listing Factors \nRWQCBs and SWRCB shall use the following factors to develop the California section 303(d) \nlist. \n?-Waters meeting the conditions in section 311-exceed water \nquality standards. \nIn developing the list, the state shall evaluate all existing readily available water quality-related \ndata and information. Data and information, collected during a known spill or violation of an \neffluent limit in a permit or waste discharge requirement (WDR), may be used in conjunction \nwith other data to demonstrate that there is an exceedance of a water quality standard in the \nwater body. Visual assessments or other semi-quantitative assessments shall also be considered \nas ancillary lines of evidence to support a section 303(d) listing. \nWater segments shall be placed on the section 303(d) list if any of the following conditions are \nmet. \n1 Numeric Water Quality Objectives and Criteria for I \nToxicants in Water \nNumeric water quality objectives for toxic pollutants, including maximum contaminant levels \nwhere applicable, or California'National Toxics Rule water quality criteria are exceeded as \nfollows: \nUsing the binomial distribution, waters shall be placed on the section 303(d) list if the \nnumber of measured exceedances supports rejection of the null hypothesis as presented in \nTable 3.1. \n3423.2 Numeric Water Quality Objectives for Conventional or \nOther Pollutants in Water I \nNumeric water quality objectives for conventional pollutants are exceeded as follows: \nUsing the binomial distribution, waters shall be placed on the section 303(d) list if the \nnumber of measured exceedances supports rejection of the null hypothesis as presented in \nTable 3.2. \nFor depressed dissolved oxygen, if measurements of dissolved oxygen taken over the day (diel) \nshow low concentrations in the morning and sufficient concentrations in the afternoon, then it \nshall be assumed that nutrients are responsible for the observed dissolved oxygen concentrations \nif riparian cover, substrate composition or other pertinent factors can be ruled out as controlling \ndissolved oxygen fluctuations. When continuous monitoring data are available, the seven-day \naverage of daily minimum measurements shall be assessed. In the absence of die1measurements, September 30,200- __,_ I \nconcurrently collected measurements of nutrient concentration shall be assessed using applicable \nwater quality objectives or acceptable evaluation guidelines (section 6.1.3) and using the \nbinomial distribution as described in section 3.14. \n34433.3 Numerical Water Quality Objectives or Standards for \nBacteria Where Recreational Uses Apply \nIn the absence of a site-specific exceedance frequency, a water segment shall be placed on the \nsection 303(d) list if bacteria water quality standards in California Code of Regulations, Basin \nPlans, or statewide plans are exceeded using the binomial distribution as described in \nsection 3.152. \nIf a site-specific exceedance frequency is availabIe, it may be used instead of the ten percent \nexceedance frequency as described in Table 3.2 or four percent as described in the following \nparagraph. The site-specific exceedance frequency shall be the number of water quality standard \nexceedances in a relatively unimpacted watershed (i.e., a reference water segment). To the \nextent possible and allowed by water quality objectives, RWQCBs shall identify one or more \nreference beaches or water segments to compare the measurements. \nFor bacterial measurements from coastal beaches, if water quality monitoring was conducted \nApril I through October 31 only, a four percent exceedance percentage shall be used- \nbacterial measurements from inland waters. if water aualitv monitoring data were collected \nApril 1through October 31 only, a four percent exceedance Dercentage shall be used if \n(1) bacterial measurements are indicative of human fecal matter, and (2) there is substantial \nhuman contact in the water body. If the exceedance is due to a kaebclosure related to a sewage \nspill, the water segment shall not be placed on the section 303(d) list. hwh-p~ostings that are \nnot backed by water quality data shall not be used to support placement of a water segment on \nthe section 303(d) list. \nW3.4 Health Advisories \nA water segment shall be placed on the section 303(d) list if a health advisory against the \nconsumption of edible resident organisms, or a shellfish harvesting ban has been issued by the \nOffice of Environmental Health Hazard Assessment (OEHHA), or Department of Health \nServices and there is a designated or existing fish consumption beneficial use for the segment. In \naddition, water segment-specific data must be available indicating the evaluation guideline for \ntissue is exceeded. \n-3.5 Bioaccumulation of Pollutants in Aquatic Life Tissue \nA water segment shall be placed on the section 303(d) list if the tissue pollutant levels in \norganisms exceed a pollutant-specific evaluation guideline (satisfying the requirements of \nsection 6.1.3) using the binomial distribution as described in section 3.k1. \nAcceptable tissue concentrations may be based on composite samples measured either as muscle \ntissue or whole body residues. Residues in liver tissue alone are not considered a suitable \nmeasure. Samples can be collected either from transplanted animals or from resident \npopulations. I\nI \nI \nI\nI \nI \nI \n September 30.200- __,_ \n3A63.6 WaterISediment Toxicity \nA water segment shall be placed on the section 303(d) list if the water segment exhibits \nstatistically significant water or sediment toxicity using the binomial distribution as described in \nsection 3.k1. The segment shall be listed if the observed toxicity is associated with a pollutant or \npollutants. Waters may also be placed on the section 303(d) list for toxicity alone. If the pollutant \ncausing or contributing to the toxicity is identified, the pollutant shall be included on the \nsection 303(d) list as soon as possible (i.e., during the next listing cycle). \nReference conditions may include laboratory controls (using a t-test or other applicable statistical \ntest), the lower confidence interval of the reference envelope, or, for sediments, response less \nthan 90 percent of the minimum significant difference for each specific test organism. \nAppropriate reference and control measures must be included in the toxicity testing. Acceptable \nmethods include, but are not limited to, those listed in water quality control plans, the methods \nused by Surface Water Ambient Monitoring Program (SWAMP), the Southern California Bight \nProjects of the Southern California Coastal Water Research Project, American Society for \nTesting and Materials (ASTM), USEPA, the Regional Monitoring Program of the San Francisco \nEstuary Institute, and the Bay Protection and Toxic Cleanup Program (BPTCP). \nAssociation of pollutant concentrations with toxic or other biological effects should be \ndetermined by any one of the following: \nA. Sediment quality guidelines (satisfying the requirements of section 6.1.3) are exceeded using \nthe binomial distribution as described in section 3.1?1. In addition, using rank correlation, \nthe observed effects are correlated with measurements of chemical concentration in \nsediments. If these conditions are met, the pollutant shall be identified as \"sediment \nB. \tFor sediments, an evaluation of equilibrium partitioning or other type of toxicological \nresponse that identifies the pollutant that may cause the observed impact. Comparison to \nreference conditions within a watershed or ecoregion may be used to establish sediment \nimpacts. \nC. \tDevelopment of an evaluation (such as a toxicity identification evaluation) that identifies the \npollutant that contributes to or caused the observed impact. \nZLId3.7 Nuisance \nA water segment shall be placed on the section 303(d) list if qualitative assessments of the water \nsegment for nuisance water odor, taste, excessive algae growth, foam, turbidity, oil, trash, and \ncolor are associated with numerical water quality data that meets any one of the following: \nM4'43.7.1 Nutrient-related \nAn acceptable nutrient-related evaluation guideline is exceeded using the binomial distribution \nas described in section 3.&1 for excessive algae growth, unnatural foam, odor, and taste. Waters \nmay also be placed on the section 303(d) list when a significant nuisance condition exists as \ncompared to reference conditions, or when nutrient concentrations cause or contribute to I\nI \nI \nI \nI \nI\nI \nI \n September 30.200- \nexcessive algae growth. If listing for nitrogen or phosphorus specifically, RWQCBs should \nconsider whether the ratio of these two nutrients indicates which is the limiting agent. \n3m3sa3.7.2 Other Types \nAn acceptable evaluation guideline is exceeded using the binomial distribution as described in \nsection 3.&1 for taste, color, oil sheen, turbidity, litter, trash, and odor not related to nutrients. \nWater segments may also be placed on the section 303(d) list when there is significant nuisance \ncondition compared to reference conditions. \nM.8 Adverse Biological Response \nA water segment shall be placed on the section 303(d) list if the water segment exhibits adverse \nbiological response measured in resident individuals as compared to reference conditions and \nthese impacts are associated with water or sediment concentrations of pollutants as described in \nsection 3.&6. Endpoints for this factor include reduction in growth, reduction in reproductive \ncapacity, abnormal development, histopathological abnormalities, and other adverse conditions. \nQualitative visual assessments or other semi-qualitative assessments may be used as secondary \nlines of evidence to support placement on the section 303(d) list. These types of assessments \ninclude fish kills or bird kills related to water quality conditions. \nFor adverse biological response related to sedimentation, the water segment shall be placed on \nthe section 303(d) list if adverse biological response is identified and effects are associated with \nclean sediment loads in water or with loads stored in the channel. Waters shall be placed on the \nsection 303(d) list if evaluation guidelines (satisfying the conditions of section 6.1.3) are \nexceeded using the binomial distribution as described in section 3.&1. \nM3.9 Degradation of Biological Populations and Communities \nA water segment shall be placed on the section 303(d) list if the water segment exhibits \nsignificant degradation in biological populations andlor communities as compared to reference \nsite(s) and is associated with water or sediment concentrations of pollutants including but not \nlimited to chemical concentrations, temperature, dissolved oxygen, and trash. This condition \nreauires diminished numbers of species or individuals of a single species or other metrics when - * \ncompared to reference site(s). The analysis should rely on measurements from at least two \nstations. Comparisons to reference site conditions shall be made during similar season andlor \nhydrologic conditions. \nAssociation of chemical concentrations, temperature, dissolved oxygen, trash, and other \npollutants shall be determined using sections 3..L,1,3.L2.3.&6,3.&7,6.1.5.9, or other applicable \nsections. \nFor population or community degradation related to sedimentation, the water segment shall be \nplaced on the section 303(d) list if degraded populations or communities are identified and \neffects are associated with clean sediment loads in water or with loads stored in the channel \nwhen compared to evaluation guidelines (satisfying the conditions of section 6.1.3) using the \nbinomial distribution as described in section 3.k1 or as compared to reference sites. \nA-7 FINAL-I \nI\nI \nI \nI\nI \nI \nI \nI \nI \n Bioassessment data used for listing decisions shall be consistent with section 6.1.5.8. For \nbioassessment, measurements at one stream reach may be sufficient to warrant listing provided \nthat the impairment is associated with a pollutant(s) as described in this section. \nI \n344-03.10 Trends in Water Quality \nA water segment shall be placed on the section 303(d) list if the water segment exhibits \nconcentrations of pollutants or water body conditions for any listing factor that shows a trend of \ndeclining water quality standards attainment. This section is focused on addressing the \nantidegradation component of water quality standards and threatened waters as defined in 40 \nCFR 130.2(j) by identifying trends of declining water quality. Numeric, pollutant-specific water \nquality objectives need not be exceeded to satisfy this listing factor. In assessing trends in water \nquality RWQCBs shall: \n1. Use data collected for at least three years; \n2. Establish specific baseline conditions; \n3. Specify statistical approaches used to evaluate the declining trend in water quality \nmeasurements; \n4. Specify the influence of seasonal effects, interannual effects, changes in monitoring methods, \nchanges in analysis of samples, and other factors deemed appropriate; \n5. Determine the occurrence of adverse biological response (section 3.&8), degradation of \nbiological populations and communities (section 3.&9), or toxitity (section 3.44); and \n6. Assess whether the declining trend in water quality is expected to not meet water quality \nstandards by the next listing cycle. \nWaters shall be placed on the section 303(d) list if the declining trend in water quality is \nsubstantiated (steps 1 through 4 above) and impacts are observed (step 5). \nI \n3.11 Situation-Specific Weight of Evidence Listing Factor \nWhen all other Listing Factors do not result in the listing of a water segment but information I \nindicates non-attainment of standards, a water segment shall be placed on the section 303(d) list \nif the weight of evidence demonstrates that a water quality standard is not attained. \nWhen recommending listing based on the situation-specific weight of evidence, the RWQCB \nmust justify its recommendation by: \nProviding any data or information supporting the listing; \n~escribin~ in fact sheets how the dataor information affords a substantial basis in fact from \nwhich the listing can be reasonably inferred: -\nDemonstrating that the weight of evidence of the data and information indicate that the water \nquality standard is not attained; and \na Demonstrating that the approach used is scientifically defensible and reproducible. September 30.200 -1 \nTABLE 3.1: MINIMUM NUMBER OF MEASURED EXCEEDANCES NEEDED TO \nPLACE A WATER SEGMENT ON THE SECTION 303(~) LIST FOR TOXICANTS. \nNull Hypothesis: Actual exceedance proportion 542 percent. \nAlternate Hypothesis: Actual exceedance proportion >-?O_Ls percent. \nThe minimum effect size is 15 percent. \n1 Sample Size List if the number of exceedances equal \nor is greater than \nexceedances reauired using the binomial test at a samole size of 16 is extended to smaller \nsample sizes. \nFor sample sizes greater than-127129, the minimum number of measured exceedances is I \nestablished where a and P 5 0.2 and where la -PI is minimized. \na = Excel@ Function BINOMDIST(n-k, n, 1 -Ma, TRUE) \np = Excel@ Function BINOMDIST(k-1, n,-GO0.18, TRUE) 1 \nwhere n = the number of samples, \nk = minimum number of measured exceedances to place a water on the \nsection 303(d) list, \nM O = acceptable exceedance proportion, and \nM0.18= unacceptable exceedance proportion. \n I I September 30.200- --, -\nTABLE 3.2: MINIMUM NUMBER OF MEASURED EXCEEDANCES NEEDED TO \nPLACE A WATER SEGMENT ON THE SECTION 303(~)LIST FOR CONVENTIONAL \nOR OTHER POLLUTANTS. \nNull Hypothesis: Actual exceedance proportion 510 percent. \nAlternate Hypothesis: Actual proportion > 25 percent. \nThe minimum effect size is 15 percent. \nSample Size List if the number of exceedances equal \nor is greater than \n*Ap~lication of the binomial test reauires a minimum sample size of 26. The number of \nexceedances reauired using the binomial test at a sample size of 26 is extended to smaller \nsample sizes. \nFor sample sizes greater than 121, the minimum number of measured exceedances is \nestablished where a and P 50.2 and where la -PI is minimized. \na =Excel@ Function BMOMDIST(n-k, n, 1 -0.10, TRUE) \np = Excel@ Function BINOMDIST(k-1, n, 0.25, TRUE) \nwhere n = the number of samples, \nk = minimum number of measured exceedances to place a water segment on \nsection 303(d) list, \n0.10 = acceptable exceedance proportion, and \n0.25 = unacceptable exceedance proportion. I I September 30.200---. - September 30,2004My224WI \n4 California Delisting Factors \nThis section provides the methodology for removing waters from the section 303(d) list \n(including the Water Quality Limited Segments category and Water Quality Limited Segments \nBeing Addressed category). \nAll listings of water segments shall be removed from the section 303(d) list if the listing was \nbased on faulty data, and it is demonstrated that the listing would not have occurred in the \nabsence of such faulty data. Faulty data include, but are not limited to, typographical errors, \nimproper quality assurance/quality control procedures, or limitations related to the analytical \nmethods that would lead to improper conclusions regarding the water quality status of the \nsegment. \nIf objectives or standards have been revised and the site or water meets water quality standards, \nthe water segment shall be removed from the section 303(d) list. The listing of a segment shall be \nreevaluated if the water quality standard has been changed. \nAny interested party may request an existing listing be reassessed under the delisting factors of \nthis Policy. In requesting the reevaluation, the interested party must, using the delisting factors: \nstate the reason(s) the listing is inappropriate and the Policy would lead to a different outcome; \nand provide the data and information necessary to enable the RWQCB and SWRCB to conduct \nthe review. \nWater segments or pollutants shall be removed from the section 303(d) list if any of the \nfollowing conditions are met. \n4.1 Numeric Water Quality Objectives, Criteria, or Standards for \nToxicants in Water \nNumeric water quality objectives for toxic pollutants, including maximum contaminant levels \nwhere applicable, or California/National Toxics Rule water quality criteria are not exceeded as \nfollows: \nUsing the binomial distribution, waters shall be removed from the section 303(d) list if the \nnumber of measured exceedances supports rejection of the null hypothesis as presented in \nTable 4.1. \nThe binomial distribution cannot be used to support a delisting with sample sizes less \nthan 28. I September 30.2004My3%NM --, I \n4.2 Numeric Water Quality Objectives for Conventional or Other \nPollutants in Water \nNumeric water quality objectives for conventional pollutants are not exceeded as follows: \nUsing the binomial distribution, waters shall be removed from the section 303(d) list if the \nnumber of measured exceedances supports rejection of the null hypothesis as presented in \nTable 4.2. \nThe binomial distribution cannot be used to support a delisting with sample sizes less \nthan 26. I \n4.3 Numeric Water Quality Objectives for Bacteria in Water \nNumeric water quality objectives or standards for bacteria are not exceeded using the binomial \ndistribution as described in section 4.2. If a site-specific exceedance frequency was used to \nplace the water on the section 303(d) list, then the same exceedance frequency shall be used in \nthe assessment to remove waters from the section 303(d) list. To the extent possible and allowed \nby water quality objectives, RWQCBs shall identify one or more reference beaches or water \nsegments in a relatively unimpacted watershed to compare the measurements. \n4.4 Health Advisories \nThe health advisory used to list the water segment has been removed or the chemical or \nbiological contaminant-specific evaluation guideline for tissue is no longer exceeded. \n4.5 Bioaccumulation of Pollutants in Aquatic Life Tissue \nNumeric pollutant-specific evaluation guidelines are not exceeded using the binomial \ndistribution as described in section 4.1. \n4.6 WaterISediment Toxicity \nWaterISediment Toxicity or associated water or sediment quality guidelines are not exceeded \nusing the binomial distribution as described in section 4.1. \n4.7 Nuisance \nThe water segment no longer satisfies the conditions for a nuisance listing or associated \nnumerical water or sediment data meets any one of the following: \nFor excessive algae growth, unnatural foam, odor, taste, applicable numerical nutrient-related \nevaluation guidelines are not exceeded using the binomial distribution as described in \nsection 4.1. \n4.7.2 Other Types \nAcceptable numerical evaluation guidelines are not exceeded using the binomial distribution as \ndescribed in sections 4.1 and 4.2 for color, oil sheen, turbidity, trash, taste, or odor not related to \nnutrients. These types of nuisance shall also be removed from the list when there is no significant \nnuisance condition when compared to reference conditions. September 30,200- --,-I \n4.8 Adverse Biological Response \nAdverse biological response is no longer evident or associated water or sediment numeric \npollutant-specific evaluation guidelines are not exceeded using the binomial distribution as \ndescribed in section 4.1. \n4.9 Degradation of Biological Populations and Communities \nBiological populations and communities degradation in the water segment is no longer evident as \ncompared to reference site(s) or associated water or sediment numeric pollutant-specific \nevaluation guidelines are not exceeded using the binomial distribution as described in \nsection 4.1. \n4.10Trends in Water Quality \nThe factors for assessing trends in water quality (section 3.&10) are not substantiated (steps 1 1 \nthrough 4) or impacts are no longer observed (step 5). \n4.11 Situation-Specific Weight of Evidence Delisting Factor \nWhen all other Delisting Factors do not result in the delisting of a water segment but information \nindicates attainment of standards, a water segment shall be removed from the section 303(d) list \nif the weight of evidence demonstrates that :water quality standard is attained. If warranted, a \nlistinn mav be maintained if the weight of evidence indicates a water aualitv standard is not I \nattained. I \nWhen recommending delisting based on the situation-specific weight of evidence, the RWQCB \nmust justify its recommendation by: \nProviding any data or information supporting the delisting; \nDescribing in fact sheets how the data or information affords a substantial basis in fact from \nwhich the delisting can be reasonably inferred; \nDemonstrating that the weight of evidence of the data and information indicates that the \nwater quality standard is attained; and \nDemonstrating that the approach used is scientifically defensible and reproducible. Sevtember 30.2004MyZ4MM I \nTABLE 4.1: MAXIMUM NUMBER OF MEASURED EXCEEDANCES \nALLOWED TO REMOVE A WATER SEGMENT FROM THE SECTION 303(~) \nLIST FOR TOXICANTS. \nNull Hypothesis: Actual exceedance proportion &OB percent. \nAlternate Hypothesis: Actual proportion <53percent of the samples \nThe minimum effect size is 15 percent. \nSample Size Delist if the number of exceedances \nequal or is less than \nW28-36 2 \n29-3737-47 3 \nW48-59 4 \n-60-71 5 \n$4-4472-82 6 \n65-43 83 -94 7 \n74-8? 95 -106 8 \n&3--9&107-117 9 \n92--KK)118-129 10 \n-l4&-w9 4-4 \n444-L% 42 \n4-%-47 443 \nFor sample sizes greater thanWU, the maximum number of measured exceedances \nallowed is established where a and P 5-&2&.!Q and where la -PI is minimized. I \na = Excel@ Function BINOMDIST(k, n,-KNM, TRUE) \np = Excel@ Function BINOMDIST(n-k-1, n, 1 -M.03, TRUE) \nwhere n = the number of samples, \nk = maximum number of measured exceedances allowed, M.03 = acceptable exceedance proportion, and \nWO = unacceptable exceedance proportion. \n I September 30.2004Jt+bp-rrr-WF)4 .._,_ \nLIST FOR CONVENTIONAL OR OTHER POLLUTANTS. \nNull Hypothesis: Actual exceedance proportion 2 25 percent. \nAlternate Hypothesis: Actual exceedance proportion < 10percent. \nFor sample sizes greater than 121, the maximum number of exceedances allowed is \nestablished at a and P 50.2 and where la -PI is minimized. \na = Excel@ Function BINOMDIST(k, n, 0.25, TRUE) \np = Excel@ Function BINOMDIST(n-k-1, n, 1 -0.1, TRUE) \nwhere n = the number of samples, \nk = maximum number of measured exceedances allowed, \n0.10 = acceptable exceedance proportion, and \n0.25 = unacceptable exceedance proportion. \nA-16 \n September 30,2004Wy224W-1-I \n5 TMDL Scheduling \nA schedule shall be established by the RWQCBs and SWRCB for waters on the section 303(d) \nlist that identifies the TMDLs that will be established within the current listing cycle and the \nnumber of TMDLs scheduled to be developed thereafter. \nFor water quality limited segments needing a TMDL, RWQCBs shall develop a completion \nschedule in compliance with federal law and regulation based on, but not limited to, the \nfollowing criteria: \nWater body significance (such as importance and extent of beneficial uses, threatened and \nendangered species concerns, and size of water body); \nDegree that water quality objectives are not met or beneficial uses are not attained or \nthreatened (such as the severity of the pollution or number of pollutants/stressors of concern) \n[40 CFR 130.7(b)(4)]; \nDegree of impairment; \nw Potential threat to human health and the environment; \nWater quality benefits of activities ongoing in the watershed; \nPotential for beneficial use protection and recovery; \nDegree of public concern; \nAvailability of funding; and \nw Availability of data and information to address the water quaIity problem. \nAll water body-pollutant combinations on the section 303(d) list shall be assigned a TMDL \nschedule date. September 30.2004kbGwwI \n6 Policy Implementation \nThis section provides SWRCB guidance on implementation of this Policy. The most recently \ncompleted section 303(d) list shall form the basis for any subsequent lists. \n6.1 Processfor Evaluation of Readily Available Data and Information \nAll readily available data and information shall be evaluated. To develop the section 303(d) list \nthe RWQCBs and SWRCB shall use the following process. \n6.1.1 Definition of Readily Available Data and Information \nRWQCBs and SWRCB shall actively solicit, assemble, and consider &Ireadily available data \nand information. Data and information that shall be reviewed include, but are not limited to: \nsubmittals resulting from the solicitation, selected data possessed by the RWQCBs, and other \nsources. At a minimum, readily available data and information includes paper and electronic \ncopies of: \nThe most recent section 303(d) list, and the most recent section 305(b) report; \nDrinking water source assessments; \nMunicipal Separate Storm Sewer System (MS4) reports; \nInformation on water quality problems in documents prepared to satisfy Superfund and \nResource Conservation and Recovery Act requirements; \nFish and shellfish advisories, beach postings and closures, or other water quality-based \nrestrictions; \nReports of fish kills, cancers, lesions or tumors; \nDilution calculations, trend analyses, or predictive models for assessing the physical, \nchemical, or biological condition of streams, rivers, lakes, reservoirs, estuaries, coastal \nlagoons, or the ocean; \nApplicable water quality data and information from SWAMP, USEPA's Storage and \nRetrieval Database Access (STORET) or other USEPA databases and information sources, \nthe Bay-Delta Tributaries Database, Southern California Coastal Water Research Project, and \nthe San Francisco Estuary Regional Monitoring Program; and \nWater quality problems and existing and readily available water quality data and information \nreported by local, state and federal agencies (including receiving water monitoring data from \ndischarger monitoring reports), citizen monitoring groups, academic institutions, and the \npublic. The Federal agencies that shall be actively solicited for data and information include \nbut are not limited to: U.S. Deparhnent of Agriculture, National Oceanic and Atmospheric \nAdministration, U.S. Geological Survey, and U.S. Fish and Wildlife Service. \n6.1.2 Administration of the Listing Process \n6.1.2.1 Solicitation of All Readily Available Data and Information \nSWRCB and RWQCBs shall seek all readily available data and information on the quality of \nsurface waters of the State. Readily available data and information shall be solicited from any \ninterested party, including but not limited to, private citizens, public agencies, state and federal September 30.2004My=4oMI \ngovernmental agencies, non-profit organizations, and businesses possessing data and information \nregarding the quality of the Region's waters. \nThough the SWRCB and RWQCBs must specifically solicit all readily available data and \nassessment information, SWRCB and RWQCB may place emphasis in the solicitation on the \ndata and information generated since the last listing cycle. For the purposes of this solicitation, \ninformation means any documentation describing the water quality condition of a surface water \nbody. Data are considered a subset of information that consists of reports detailing \nmeasurements of specific environmental characteristics. The data and information may pertain \nto physical, chemical, andlor biological conditions of the State's waters or watersheds. \nInformation solicited should contain the following: \nThe name of the person or organization providing the information; \nThe name of the person certifying the completeness and accuracy of the data and information \nand a statement describing the standards exceedance; \nMailing address, telephone numbers, and email address of a contact person for the \ninformation provided; \nA copy of all information provided. The submittal must specify the software used to format \nthe information and provide definitions for any codes or abbreviations used; \nBibliographic citations for all information provided; and \nIf computer model outputs are included in the information, provide bibliographic citations \nand specify any calibration and quality assurance information available for the model(s) \nused. \nData solicited should contain the following: \nData in electronic form, spreadsheet, database, or ASCII formats. The submittal should use \nthe SWAMP data format and should define any codes or abbreviations used in the database. \nMetadata for the field data, i.e., when measurements were taken, locations, number of \nsamvles, detection limits, and other relevant factors. \nMetadata for any Geographical Information System data must be included. The metadata \nmust detail all the parameters of the projection, including datum. \nA copy of the quality assurance procedures. \nA copy of the data. \nData from citizen volunteer water quality monitoring efforts require the name of the group \nand indication of any training in water quality assessment completed by members of the \ngroup. Data submitted by citizen monitoring groups should meet the data quality assurance \nprocedures as detailed in section 6.1.4. \nFor photographic documentation, adhere to the guidelines detailed in section 6.1.4. \nData and information previously submitted to RWQCBs, such as Discharge Monitoring Reports, \nneed not be solicited if the data and information are remain available to RWQCBs. I September 30.200- --, \n6.1.2.2 RWQCB Fact Sheet Preparation \nWhen data and information are available, each RWQCB shall prepare a standardized fact sheet \nfor each water and pollutant combination that is proposed for inclusion in or deletion from the \nsection 303(d) list. Fact sheets shall present a description of the line(s) of evidence used to \nsupport each component of the weight of evidence approach. Fact sheets shall be prepared for \nall data and information solicited. If the data and information reviewed indicate standards are \nattained, a single fact sheet may address multiple water and pollutant combinations. \nThe fact sheets shall contain the following: \nA. Region \nB. Type of water body (Bay and Harbors, Coastal Shoreline, Estuary, LakelReservoir, Ocean, \nRiversIStream, Saline Lake, Tidal Wetlands, Freshwater Wetland) \nC. Name of water body segment (including Calwater watershed) \nD.Pollutant or type of pollution that appears to be responsible for standards exceedance \nE. \tMedium (water, sediment, tissue, habitat, etc.) \nF. \tWater quality standards (copy applicable water quality standard, objective, or criterion from \nappropriate plan or regulation) including: \n1. \tBeneficial use affected \n2. \tNumeric water quality objectivelwater quality criteria plus metric (single value threshold, \nmean, median, etc.) narrative water quality objective plus guideline(s) used to interpret \nattainment or non-attainment \n3. \tAntidegradation considerations (if applicable to situation) \n4. \tAny other provision of the standard used \nG. \tBrief Watershed Description (e.g., land use, precipitation patterns, or other factors considered \nin the assessment) \nH. \tSummary of data and/or information \n1. \tSpatial representation, area that beneficial use is affected or determined to be supported, \nincluding a map, any site specific information, and reference condition \n2. \tTemporal representation \n3. \tAge of data and/or information \n4. \tEffect of seasonality and events/conditions that might influence data and/or information \nevaluation (e.g., storms, flow conditions, laboratory data qualifiers, etc.) \n5. \tNumber of samples or observations \n6. \tNumber of samples or observations exceeding guideline or standard \n7. \tSource of or reference for data and/or information \nI. \tFor numeric data include: \n1. \tQuality assurance assessment \nJ. \tFor non-numeric data include: \n1. \tTypes of observations \n2. \tPerspective on magnitude of problem \n3. \tNumeric indices derived from qualitative data \nK. \tPotential source of pollutant (the source category should be identified as specifically as \npossible) \nL. \tProgram(s) addressing the problem, if known September 30,2004Wp%WM --, I \nM. Data evaluation as required by sections 3 or 4 of this Policy \nN. Recommendation \n0. TMDL schedule (developed only for the section 303(d) list as required by section 5 of this \nPolicy). \n6.1.3 Evaluation Guideline Selection Process \nNarrative water quality objectives shall be evaluated using evaluation guidelines. When \nevaluating narrative water quality objectives or beneficial use protection, RWQCBs and SWRCB \nshall identify evaluation guidelines that represent standards attainment or beneficial use \nprotection. The guidelines are not water quality objectives and shall only be used for the purpose \nof developing the section 303(d) list. \nTo select an evaluation guideline, the RWQCB or SWRCB shall: \nIdentify the water body, pollutants, and beneficial uses; \nIdentify the narrative water quality objectives or applicable water quality criteria; \nIdentify the appropriate interpretive evaluation guideline that potentially represents water \nquality objective attainment or protection of beneficial uses. If this Policy requires \nevaluation values to be used as one line of evidence, the evaluation value selected shall be \nused in concert with the other required line(s) of evidence to support the listing or delisting \ndecision. Depending on the beneficial use and narrative standard, the following \nconsiderations shall be used in the selection of evaluation guidelines: \n1. Sediment Oualitv Guidelines for Marine, Estuarine, and Freshwater Sediments: \nRWQCBs may select sediment quality guidelines that have been published in the peer-\nreviewed literature or by state oifeded agencies. Acceptable include-\nselected values (e.g., effects range-median, probable effects level, probable effects \nconcentration), and other sediment quality guidelines. Only those sediment guidelines \nthat are predictive of sediment toxicity shall be used (i.e., those guidelines that have been \nshown in published studies to be predictive of sediment toxicity in 50 percent or more of \nthe samples analyzed). \n2. Evaluation Guidelines for Protection from the Consumption of Fish and Shellfish: \nRWQCBs may select evaluation guidelines published by USEPA or OEHHA. Maximum \nTissue Residue Levels (MTRLs) and Elevated Data Levels (EDLs) shall not be used to \nevaluate fish or shellfish tissue data. \n3. Evaluation Guidelines for Protection of Aquatic Life from Bioaccumulation of Toxic \nSubstances: RWQCBs may select the evaluation values for the protection of aquatic life \npublished by the National Academy of Science. \nFor other parameters, evaluation guidelines may be used if it can be demonstrated that the \nevaluation guideline is: \nApplicable to the beneficial use \nProtective of the beneficial use September 30.200- 1 \nLinked to the pollutant under consideration \nScientifically-based and peer reviewed \nWell described \nIdentifies a range above which impacts occur and below which no or few impacts are \npredicted. For non-threshold chemicals, risk levels shall be consistent with \ncomparable water quality objectives or water quality criteria. \nRWQCBs shall assess the appropriateness of the guideline in the hydrographic unit. Justification \nfor the alternate evaluation guidelines shall be referenced in the water body fact sheet. \n6.1.4 Data Quality Assessment Process \nEven though all data and information must be used, the quality of the data used in the \ndevelopment of the section 303(d) list shall be of sufficient high quality to make determinations \nof water quality standards attainment. Data supported by a Quality Assurance Project Plan \n(QAPP) pursuant to the requirements of 40 CFR 31.45 are acceptable for use in developing the \nsection 303(d) list. \nThe data from major monitoring programs in California and published U.S. Geological Survey \n(USGS) reports are considered of adequate quality. The major programs include SWAMP, the \nSouthern California Bight Projects of the Southern California Coastal Water Research Project, \nUSEPA's Environmental Monitoring and Assessment Promam, the Regional Monitoring--\nProgram of the San Francisco ~stuar~Institute, and the BPTCP. \nNumeric data are considered credible and relevant for listing purposes if the data set submitted ---\nmeets the minimum quality assurance/quality control requirements outlined below. A QAPP or \nequivalent documentation must be available containing, at a minimum, the following elements: \nObjectives of the study, project, or monitoring program; \nMethods used for sample collection and handling; \nField and laboratory measurement and analysis; \nData management, validation, and recordkeeping (including proper chain of custody) \nprocedures; \nQuality assurance and quality control requirements; \nA statement certifying the adequacy of the QAPP (plus name of person certifying the \ndocument); and \nA description of personnel training. \nA site-specific or project-specific sampling and analysis plan for numeric data should also be \navailable containing: \nData quality objectives or requirements of the project; \nA statement that data quality objectives or requirements were achieved; \nRationale for the selection of sampling sites, water quality parameters, sampling frequency \nand methods that assure the samples are spatially and temporally representative of the surface \nwater and representative of conditions within the targeted sampling timeframe; and Documentation to support the conclusion that results are reproducible. \nThe RWQCBs shall make a finding in the fact sheets on the availability of the QAPP (or \nequivalent), adequacy of data collection, analysis practices, and adequacy of the data verification \nprocess (including the chain of custody, detection limits, holding times, statistical treatment of \ndata, precision and bias, etc). If any data quality objectives or requirements in the QAPP are not \nmet, the reason for not meeting them and the potential impact on the overall assessment shall be \ndocumented. \nData without rigorous quality control can be used in combination with high quality data and \ninformation. If the data collection and analysis is not supported by a QAPP (or equivalent) or if it \nis not possible to tell if the data collection and analysis were supported by a QAPP (or \nequivalent), then the data and information should not be used by itself to support listing or \ndelisting of a water segment. All data of whatever quality can be used as part of a weight of \nevidence determination (sections 3.C;ll or 4.11). I \nFor narrative and qualitative submittals, the submission must: \ndescribe events or conditions that indicate impacts on water quality; \nprovide linkage between the measurement endpoint (e.g., a study that may have been \nperformed for some other purpose) and the water quality standard of interest; \nbe scientifically defensible; \nprovide analyst's credentials and training; and \nbe verifiable by SWRCB or RWQCB. \nFor photographic documentation, the submission must: \nidentify the date; \nidentify location on a general area map; \neither mark location on a USGS 7.5 minute quad map along with quad sheet name or provide \nlocation latitudeflongitude; \nprovide a thorough description of photograph(s); \ndescribe the spatial and temporal representation of the photographs; \nprovide linkage between photograph-represented condition and condition that indicates \nimpacts on water quality; \nprovide photographer's rationale for area photographed and camera settings used; and \nbe verifiable by SWRCB and RWQCB. \n6.1.5 Data Quantity Assessment Process \nBefore determining if water quality standards are exceeded, RWQCBs have wide discretion \nestablishing how data and information are to be evaluated, including the flexibility to establish \nwater segmentation, as well as the scale of spatial and temporal data and information that are to \nbe reviewed. The following considerations shall be documented in each water body fact sheet. 6.1.5.1 WaterBody SpeciJicInfomation \nData used to assess water quality standards attainment should be actual data that can be \nquantified and qualified. Information that is descriptive, estimated, modeled, or projected may \nbe used as ancillary lines of evidence for listing or delisting decisions. In order to be used in \ndeveloping the lists: \nData must be measured at one or more sites in the water segment; \nIf applicable and available, environmental conditions in a water body or at a site must be \ntaken into consideration (e.g., effects of seasonality, events such as storms, the occurrence of \nwildfires, land use practices, etc.); and \nThe fact sheet shall contain a description of readily available pertinent factors such as the \ndepth of water quality measurements, flow, hardness, pH, the extent of tidal influence, and \nother relevant sample-and water body-specific factors. \n6.1.5.2 Spatial Representation \nSamples should be representative of the water body segment. To the extent possible, samples \nshould represent statistically or in a consistent targeted manner the segment of the water body. \nSamples collected within 200 meters of each other should be considered samples from the same \nstation or location. However, samples less than 200 meters apart may be considered to be \nspatially independent samples if justified in the water body fact sheet. \n6.1.5.3 Temporal Representation \nSamples should be representative of the critical timing that the pollutant is expected to impact \nthe water body. Samples used in the assessment must be temporally independent. If the majority \nof samples were collected on a single day or during a single short-term natural event (e.g., a \nstorm, flood, or wildfire), the data shall not be used as the primary data set supporting the listing \ndecision. \nDocumentation should include the time of day in which the sample was taken, and, to the extent \npossible, the critical season for the pollutant and applicable water quality standard. In general, \nsamples should be available from two or more seasons or from two or more events when effects \nor water quality objective exceedances would be expected to be clearly manifested. \nSampling ephemeral waters, during a specific season, or during human-caused events (except \nspills) should be used to assess significant pollutant-related exceedances of water quality \nstandards. Timing of the sampling should include the critical season for the pollutant and \napplicable water quality standard. If the implementation of a management practice(s) has \nresulted in a change in the water body segment, only recently collected data [since the \nimplementation of the management measure(s)] should be considered. The water quality fact \nsheet should describe the significance of the sample timing. \n6.1.5.4 Aggregation of Data by ReacWArea \nAt a minimum, data shall be aggregated by the water body segments as defined in the Basin \nPlans. In the absence of a Basin Plan segmentation system, the RWQCBs should define distinct \nreaches based on hydrology and relatively homogeneous land use. I September 30,200- __,I \nIf available data suggest that a pollutant may cause an excursion above a water quality objective, \nthe RWQCB should, to the extent information is readily available, identify land uses, \nsubwatersheds, tributaries, or dischargers that could be contributing the pollutant to the water \nbody. The RWQCBs should identify stream reaches or lakelestuary areas that may have \ndifferent pollutant levels based on significant differences in land use, tributary inflow, or \ndischarge input. Based on these evaluations of the water body setting, RWQCBs should \naggregate the data by appropriate reach or area. \nData must be measured at one or more sites in the water segment in order to place a water \nsegment on the section 303(d) list. \n6.1.5.5 Quantitation of Chemical Concentrations \nWhen available data are less than or equal to the quantitation limit and the quantitation limit is \nless than or equal to the water quality standard, the value will be considered as meeting the water \nquality standard, objective, criterion, or evaluation guideline. \nWhen the sample value is less than the quantitation limit and the quantitation limit is greater than \nthe water quality standard, objective, criterion, or evaluation guideline, the result shall not be \nused in the analysis. \nThe quantitation limit includes the minimum level, practical quantitation level, or reporting limit. \n6.1.5.6 \t Evaluation of Data Consistent with the Expression of Numeric Water Quality \nObjectives, Water Quality Criteria, or Evaluation Guidelines \nIf the water quality objectives, criteria, or guidelines state a specific averaging period andlor \nmathematical transformation, the data should be evaluated in a consistent manner prior to \nconducting any statistical analysis for placement of the water on the section 303(d) list. If \nsufficient data are not available for the stated averaging period, the available data shall be used to \nrepresent the averaging period. \nTo be considered temporally independent, samples collected during the averaging period shall be \ncombined and considered one sampling event. For data that is not temporally independent (e.g., \nwhen multiple samples are collected at a single location on the same day), the measurements \nshall be combined and represented by a single resultant value. For dissolved oxygen \nmeasurements, the minimum value shall be used to determine compliance with the water quality \nobjective. For pH measurements, the minimum or maximum values of the data set shall be used \nto determine compliance with the water quality objective. \nIf the averaging period is not stated for the standard, objective, criterion, or evaluation guideline, \nthen the samples collected less than 7 days apart shall be averaged. \n6.1.5.7 Binomial Model Statistical Evaluation \nOnce data have been summarized, RWQCBs shall determine if standards are exceeded. The \nRWQCBs shall determine for each averaging period which data points exceed water quality \nstandards. The number of measurements that exceed standards shall be reported in the water \nbody fact sheet. September 30.200- --, -I \nWhen numerical data are evaluated, all of the following steps shall be completed: \nA. For each data point representing the averaging period, the RWQCB shall answer the \nquestion: Are water quality standards met? \nB. If the measurement is greater than the water quality standard, objective, criterion, or \nevaluation guideline, then the standard is exceeded. \nC. Sum the number of samples exceeding the standard, objective, criterion, or evaluation \nguideline. \nD. Sum the total number of measurements (sample population). \nE. Compare the result to the appropriate table (i.e., Tables 3.1,3.2,4.1, or 4.2). \nF. Report the result of this comparison in the water body fact sheet. \n6.1.5.8 Evaluation of Bioassessment Data \nWhen evaluating biological data and information, RWQCBs shall evaluate all readily available \ndata and information and shall: \nIdentify appropriate reference sites within water segments, watersheds, or ecoregions. \nDocument methods for selection of reference sites. \nEvaluate bioassessment data at reference sites using water segment-appropriate method(s) \nand index period(s). Document sampling methods, index periods, and Quality \nAssuranceIQuality Control procedures for the habitat being sampled and question(s) being \nasked. \nEvaluate bioassessment data from other sites, and compare to reference conditions. Evaluate \nphysical habitat data and other water quality data, when available, to support conclusions \nabout the status of the water segment. \nCalculate biological metrics for reference sites and develop Index of Biological Integrity if \npossible. \n6.1.5.9 Evaluation of Temperature Data \nTemperature water quality objectives shall be evaluated as described in sections 6.1.5.1 through \n6.1.5.7. When \"historic\" or \"natural\" temperature data are-not available, alternative approaches \nshall be employed to assess temperature impacts. \nIn the absence of necessary data to interpret numeric water quality objectives, recent temperature \nmonitoring data shall be compared to the temperature requirements of aquatic life in the water \nsegment. In many cases, fisheries, particularly salmonids, represent the beneficial uses most \nsensitive to temperature. Information on current and historic conditions and distribution of September 30,200- --,-I \nsensitive beneficial uses (e.g., fishery resources) in the water segment is necessary, as well as \nrecent temperature data reflective of conditions experienced by the most sensitive life stage of \nthe aquatic life species. If temperature data from past (historic) periods corresponding to times \nwhen the beneficial use was fully supported are not available, information about \npresencelabsence or abundance of sensitive aquatic life species shall be used to infer past \n(historic) temperature conditions if loss of habitat, diversions, toxic spills, and other factors are \nalso considered. \nDetermination of life stage temperature requirements of sensitive aquatic life species shall be \nbased on peer-reviewed literature. Similarly, evaluation of temperature data shall be based on \ntemperature metrics reflective of the temperature requirements for the sensitive aquatic life \nspecies, including but not limited to, the maximum weekly average temperature and upper lethal \nlimit. \n6.2 RWQCB Approval \nAt a public hearing, the RWQCB shall consider and approve each proposed list change as \ndocumented in water body fact sheet. Advance notice and opportunity for public comment shall \nbe provided. RWQCB shall develop written responses to alicomments. ~fter consideration of all \ntestimony, RWQCBs shall approve a resolution in support of their recommendations for the \nsection 303(d) list. RWQCBs shall submit to SWRCB the water body fact sheets, responses to \ncomments, documentation of the hearing process, and a copy of &Idata and information \nconsidered. For the 2004 section 303(d) list, RWQCB approval of list changes is not required. \n6.3 SWRCB Approval \nDuring the development of the 2004 section 303(d) list, SWRCB shall perform all tasks required \nby this Policy. \nSubsequent to the 2004 listing cycle, SWRCB shall evaluate RWQCB-developed water body \nfact sheets for completeness, consistency with this Policy, and consistency with applicable law. \nThe SWRCB shall assemble the fact sheets and consolidate all the RWQCB lists into the \nstatewide section 303(d) list. \nBefore the adoption of the section 303(d) list, the SWRCB shall hold a public workshop. \nAdvance notice and opportunity for public comment shall be provided. . . =Requests . . for review of specific listing decisions \nmust be submitted to the SWRCB within 30 days of the RWQCB's decision. The SWRCB shall \nconsider changes only to waters that are requested for review unless the SWRCB, on its own \nmotion, decides to consider recommendations on other waters. Subsequent to the workshop, the \nSWRCB shall approve the section 303(d) list at a Board Meeting. The approved section 303(d) \nlist and the supporting fact sheets shall be submitted to USEPA for approval as required by the \nClean Water Act. - - September 30,200- __,-I \n7 Definitions \na (Alpha) is the statistical error of rejecting a null hypothesis that is true. This type of error is \nalso called Type I error. \nALTERNATE HYPOTHESIS is a statement or claim that a statistical test is set up to establish. \np (Beta) is the statistical error of failing to reject a null hypothesis that is not true. This type of \nerror is also called Type I1 error. \nBINOMDIST is an Excel@ function that is used to calculate the cumulative binomial \ndistribution. \nBINOMIAL DISTRIBUTION is a mathematical distribution that describes the probabilities \nassociated with the possible number of times particular outcomes will occur in series of \nobservations (i.e., samples). Each observation may have only one of two possible results \n(e.g., standard exceeded or standard not exceeded). \nBIOACCUMULATION is the process by which a chemical is taken up by an organism from its \nsurrounding medium through gill membranes, epithelial tissue, or from food and subsequently \nconcentrated and retained in the body of the organism. \nBIOASSESSMENT is an assessment of biological community information along with measures \nof the physicallhabitat quality to determine, in the case of water quality, the integrity of a water \nbody of interest. \nCONVENTIONAL POLLUTANTS include dissolved oxygen, pH, and temperature. \nDIEL measurements pertain to measurements taken over a 24-hour period of time. \nEFFECT SIZE is maximum magnitude of exceedance frequency that is tolerated. \nNULL HYPOTHESIS is a statement used in statistical testing that has been put forward either \nbecause it is believed to be true or because it is to be used as a basis for argument, but has not \nbeen proved. \nRANK CORRELATION is the association between paired values of two variables that have \nbeen replaced by their ranks within their respective samples (e.g., chemical measurements and \nresponse in a toxicity test). \nREFERENCE CONDITION refers to the characteristics of water body segments least impaired \nby human activities. As such, reference conditions can be used to describe attainable biological \nor habitat conditions for water body segments with common watershed/catchment characteristics \nwithin defined geographical regions. I September 30,200- _-,_ \nSTATISTICAL SIGNIFICANCE occurs when it can be demonstrated that the probability of \nobtaining a difference by chance only is relatively low. \nTOXICANTS include priority pollutants, metals, chlorine, and nutrients. \nTOXICITY IDENTIFICATION EVALUATION (TIE) is a technique to identify the unexplained \ncause(s) of toxic events. TIE involves selectively removing classes of chemicals through a series \nof sample manipulations, effectively reducing complex mixtures of chemicals in natural waters \nto simple components for analysis. Following each manipulation the toxicity of the sample is \nassessed to see whether the toxicant class removed was responsible for the toxicity. \nWATER QUALITY LIMITED SEGMENT is any segment of a water body where it is known \nthat water quality does not meet applicable water quality standards, andlor is not expected to \nmeet applicable water quality standards, even after application of technology-based effluent \nlimitations required by CWA sections 301(d) or 306. FINAL \nFunctional Equivalent Document \nAppendix B \nResponses To Comments \nSEPTEMBER 2004 \nDIVISION OF WATER QUALITY \nSTATE WATER RESOT TRCES CONTROL BOARD STATE WATER RESOURCES \nCONTROL BOARD \nP.O. 100 \nSacramento, CA 95812-0100 \nTo request copies of the draff Final FED \nand proposed Policyplease call \n(916) 341-5566. \nDocuments are also available at: \nhttp:/~.swrcb.ca.gov STATE WATER RESOURCES CONTROL BOARD \nDIVISION OF WATER QUALITY \nFINAL FUNCTIONAL EQUIVALENT DOCUMENT \nWATER QUALITY CONTROL POLICY FOR DEVELOPING \nCALIFORNIA'S CLEAN WATER ACT SECTION 303(d) LIST \nRESPONSES TO COMMENTS \nAPPENDIX B \nFINAL \nSEPTEMBER 2004 Page intentionally left blank. FINAL FUNCTIONAL EQUIVALENTDOCUMENT: \nWATER QUALITY CONTROL POLICY FOR DEVELOPING \nCALIFORNIA'S CLEAN WATER ACT SECTION 303(d) LIST \nAPPENDIX B: \nRESPONSES TO COMMENTS \nIntroduction \nThis section of the Functional Equivalent Document contains the \nresponses to all comments received by State Water Resources \nControl Board (SWRCB) on: (1) the draft FED (SWRCB, 2003) \nand (2) the draft Final FED (SWRCB, 2004~). \nThe draft FED was made available for public review and comment \non December 2,2003. The hearing notice was sent to several \nthousand interested parties. This appendix presents a compilation \nof the SWRCB responses to all comments received during the \nJanuary 28 and February 5,2004 hearings (SWRCB, 2004a; \n2004b) and to all written letters received on or before February 18, \n2004. \nThe draft Final FED was made available for public review and \ncomment on July 22,2004. A notice of SWRCB workshop was \nsent to all commenters on the draft FED and to a list of interested \nparties via electronic mail. This appendix also presents a \ncompilation of the SWRCB responses to all comments received on \nor before August 25,2004. If persons testified at the September 8, \n2004 workshop their letters were used to represent their testimony. \nIf any new comments were presented, written responses were \ndeveloped and included in this Appendix. \nPersons or organizations that submitted written comments, or \npresented oral testimony during the public hearings are listed in \nTable 1. Each person or organization submitting comments or \nproviding oral testimony is identified by number. All remarks, \nobservations or recommendations (except as described above) \nwere extracted from each comment letter or oral testimony and \nassigned a comment number. All comments that addressed the \nsame issue were grouped and a response was developed for the \ncomment. Unique comments were answered individually. A \nsummary of all comments submitted and the SWRCB response to \neach comment on the draft FED (SWRCB, 2003) is presented in Table 2. A summary of all comments submitted and the SWRCB \nresponse to each comment on the draft Final FED (SWRCB, \n2004c) is presented in Table 3. \nKey to Reading the Comments and Responses \nThe comments and responses are grouped by the section of the \ndraft FED and draft Policy (SWRCB, 2003) or draft Final FED and \ndraft final Policy (SWRCB, 2004~). General comments, \ncomments unrelated to the Listing Policy, and comments focused \non the Policy adoption process, are presented separately. \nColumn 1Comment Number: Each comment was assigned a \ncomment number consisting of two parts that are separated by a \nperiod. Starting from the left, the comment number begins with a \nnumber representing the person or organization submitting \ncomments or providing oral testimony during the public hearings. \nNumbers less than 100 were assigned to written comments \nsubmitted during the comment period ending on February 18, \n2004. Numbers greater than 100 were assigned to comments \nreceived as oral testimony during the public hearing held on \nJanuary 28,2004. Numbers greater than 200 were assigned to \ncomments received as oral testimony given during the hearing held \non February 5,2004. Numbers greater than 300 were assigned to \nwritten comments received or oral testimony given during the \nworkshop held on September 8,2004. \nThe number after the period represents the individual comment \npresented in the written submittal or testimony. \nColumn 2 Summary of Comment: This column presents a \nsummary of the comment extracted from each comment letter or \noral testimony. When comments are grouped, one comment was \nselected to represent the group. \nColumn 3 Response: This column contains the SWRCB response \nto each comment. \nColumn 4 Revision: This column states whether the Policy andlor \nFED were revised based on the comment. References \nSWRCB. 2003. Draft Functional Equivalent Document: Water \nQuality Control Policy for Developing California's Clean Water \nAct Section 303(d) List. Sacramento, CA: Division of Water \nQuality, State Water Resources Control Board. \nSWRCB. 2004a. Transcripts from January 28,2004 hearing. \nSacramento, CA: State Water Resources Control Board. \nSWRCB. 2004b. Transcripts from February 5,2004 hearing. \nSacramento, CA: State Water Resources Control Board. \nSWRCB. 2004c. Draft Final Functional Equivalent Document: \nWater Quality Control Policy for Developing California's Clean \nWater Act Section 303(d) List. Sacramento, CA: Division of \nWater Quality, State Water Resources Control Board. Table 1: \nList of Commenters \n(December 2,2003 through \nSeptember 8,2004) \n1. Mike Livak \nSquaw Valley Ski Corporation \nP.O. Box 2007 \nOlympic Valley, CA 96146 \n2. \tDavid Jenkins \nDavid Jenkins and Associates \n11 Yale Circle \nKensington, CA 94708 \n3. John Rice \nDepartment of Statistics \nUniversity of California, Berkeley \nBerkeley, CA 94720 \n4. \tNicolas Papadakis \nAssociation of Monterey Bay Area \nGovernments \n445 Reservation Road, Suite G \nMarina, CA 93933 \n5. Art O'Brien \nWastewater Utility \n2005 Hilltop Circle \nRoseville, CA 95747 \n6. Mike Livak \nSquaw Valley Ski Corporation \nP.O. Box 2007 \nOlympic Valley, CA 96149 \n7. \tGreg Scoles \nCity of Santa Rosa \n100 Santa Rosa Avenue \nSanta Rosa, CA 95402 8. \tThomas Herman \nBarman & Herman \nP.O. Box 173 \nEureka, CA 95502 \n9. Jack M. Stewart \nCalifornia Manufacturers and \nTechnology Association \n980 Ninth Street, Suite 2200 \nSacramento, CA 95814 \n10. Alan Levine \nCoast Action Group \nP.O. Box 215 \nPoint Arena, CA 95468 \n11. Rod Kubomoto \nDepartment of Public Works, County \nof Los Angeles \nP.O. Box 1460 \nAlhambra, CA 91802 \n12. Robert Howard \nOperations and Maintenance \nDepartment \n115 Elm Street \nModesto, CA 95354 \n13. William E. Snyder \nDepartment of Forestry and Fire \nProtection \nP.O. Box 944246 \nSacramento, CA 94244 \n14. Thomas Pinkos \nCentral Valley RWQCB \n11020 Sun Center #200 \nRancho Cordova. CA 95670 15. \tMark Smith \nCharles Abbot Associates, Inc. \n371 Van Ness Way \nTorrance, CA 90501 \n16. \tJohn Headlee \nU.S. Army Corp of Engineers, \nSacramento District \n1325 J Street \nSacramento, CA 95814 \n17. \tRita Robinson \nCity of Los Angeles, Bureau of \nSanitation \n433 South Spring Street \nLos Angeles, CA 90013 \n18. \tThomas E. Mumley \nTMDL Round Table, San Francisco \nBay RWQCB \n1515 Clay Steet, Suite 1400 \nOakland, CA 94612 \n19. \tRod Kubomoto \nDepartment of Public Works, County \nof Los Angeles \n900 South Fremont Avenue \nAlhambra, Ca 91803 \n20. \tRoger Briggs \nCentral Coast RWQCB \n895 Aerovista Place, Suite 101 \nSan Luis Obispo, CA 93401 \n21. \tG. Fred Lee \nG. Fred Lee and Associates \n27298 East El Marcero Drive \nEl Macero, CA 95618 \n22. \tCad W. Mosher \nCity of San Jose \n801 North First Street, Rm 308 \nSan Jose, CA 95 110 23. \tAllen Short \nSan Joaquin Tributaries Association \nP.O. Box 4060 \nModesto, CA 95352 \n24. \tPeter McGaw \nTurlock Irrigation District \n2033 North Main Street, Suite 800 \nWalnut Creek, CA 94596 \n25. \tDavid Fike \nCity of Monrovia \n415 South Ivy Avenue \nMonrovia, CA 91016 \n26. \tBruce Reznik \nCalifornia CoastKeeper \n2515 Wilshire Boulevard \nSanta Monica, CA 90403 \n27. \tGerald J. Thibeault \nSanta Ana RWQCB \n3737 Main Street, Suite 500 \nRiverside, CA 92501 \n28. \tPatti Krebs \nIndustrial Environmental Association \n701 \"B\" Street, Suite 1445 \nSan Diego, CA 92101 \n29. \tKeny Schmitz \nSacramento County Department of \nWater Resources \n827 7th Street, Room 301 \nSacramento, CA 95814 \n30. \tCharles Bell \nNational Resource Conservation \nService \n430 G Street #4164 \nDavis, CA 95616 3 1. Karen Henry \nStorm Water Pollution Prevention \nProgram, The City of San Diego \n19710 B Street, MS 27A \nSan Diego, CA 92102 \n32. \tPaul Helliker \nDepartment of Pesticide Regulation \n1001 I Street \nSacramento, CA 95812 \n33. Leslie A. Keane \nCity of Laguna Woods \n24264 El Toro Road \nLaguna Woods, CA 92653 \n34. William Ault \nCity of Fountain Valley \n10200 Slater Avenue \nFountain Valley, CA 92708 \n35. A.J. Holmon III \nCity of Garden Grove \n13802 New Hope Street \nGarden Grove, CA 92842 \n36. \tPhillip Gruenberg \nColorado River RWQCB \n73-720 Fred Waring Drive, Suite 100 \nPalm Desert, CA 92260 \n37. Harold J. Singer \nLahontan RWQCB \n2501 Lake Tahoe Boulevard \nSouth Lake Tahoe, CA. 96150 \n38. Steven Arita \nWestem States Petroleum Association \n1415 L Street, Suite 600 \nSacramento, CA 95814 39. Wendell Kido \nSacramento Regional County \nSanitation District \n10545 Armstrong Avenue \nMather, CA 95655 \n40. Alexis Strauss \nUSEPA Region 9 \n75 Hawthorne Street \nSan Francisco, CA 94105 \n41. Donald Kendall \nCalleguas Municipal Water District \n2100 Olsen Road \nThousand Oaks, CA 91360 \n42. John A. Robertus \nSan Diego RWQCB \n9174 Sky Park, Suite 100 \nSan Diego, CA 92123 \n43. Larry Forester \nCoalition for Practical Regulation \n2175 Cherry Avenue \nSignal Hill, CA 90755 \n44. \tSusan Damron \nLos Angeles Department of Water \nand Power \n111North Hope Street \nLos Angeles, CA 90051 \n45. Douglas S. Stack \nCity of Brea \n1 Civic Center Circle \nBrea, CA 92821 \n46. Williams Huber \nCity of San Juan Capistrano \n32400 Paseo Adelanto \nSan Juan Capistrano, CA 92675 47. \tCraig Johns \nPartnership for Sound Science in \nEnvironmental Policy \n980 9th Street, Suite 2200 \nSacramento, CA 95814 \n48. Larry McKenney \nCounty of Orange \n300 North Flower Street \nSanta Ana, CA 92702 \n49. \tDonald Freitas \nBay Area Stormwater Management \nAgencies Association \n1515 Clay Street, Suite 1400 \nOakland, CA 94612 \n50. \tSharon Duggan \nEnvironmental Protection Information \nCenter \n2070 Allston Way, Suite 300 \nBerkeley, CA 94704 \n5 1. Linda Sheehan \nEnvironmental Caucus of the AB 982 \nPublic Advisory Group \n116 New Montgomery Street, Suite \n810 \nSan Francisco, CA 94105 \n52. Kenneth H. Rosenfield, P.E. \nCity of Laguna Hills \n25201 Paseo de Alicia \nLaguna Hills, CA 92653 \n53. \tVal Connor \nSWRCB, SWAMP Roundtable \n1001 I Street \nSacramento, CA 95812 \n54. Mike Loving \nCity of Irvine \nOne Civic Center Plaza \nIrvine. CA 92623 \n55. \tTerry Roberts \nState Clearing House \n1400 Tenth Street \nSacramento, CA 95812 \n56. Victoria Conway \nLos Angeles County Sanitation \nDistricts \n1955 Workman Mill Road \nWhittier, CA 90607 \n57. Desi Alvarez \nStormwater Program \n11 11 Brookshire Avenue \nDowney, CA 90241 \n58. Desi Alvarez \nStormwater Program \n11 11 Brookshire Avenue \nDowney, CA 90241 \n59. Robert Lucas \nCalifornia Council for Environmental \nand Economic Balance \n100 Spear Street \nSan Francisco, CA 94105 \n60. Karen Ashby \nCalifornia Stormwater Quality \nAssociation \nP.O. Box 2313 \nLivermore, CA 9455 1 \n61. Bill Busath \nDepartment of Utilities, City of \nSacramento \n1395 35th Avenue \nSacramento, CA 95822 \n62. Gary W. LaEorge \nCity of Costa Mesa \n77 Fair Drive \nCosta Mesa, CA 92628 \n 63. Travis Lange \nCity of Santa Clarita \n23920 Valencia Boulevard, Suite 300 \nSanta Clarita, CA 91355 \n64. Sharon Green and Raymond Miller \nTri-TAC and SCAP \nP.O. Box 4998 \nWhittier, CA 90607 \n65. Timothy Piasky \nConstruction Industry Coalition on \nWater Quality \n2149 East Garvey Avenue, Suite A-11 \nWest Covina, CA 91791 \n66. Bruce Wolfe \nSan Francisco Bay RWQCB \n1515 Clay Street, Suite 1400 \nOakland, CA 94612 \n67. Rodney Anderson and Bonnie Teaford \nCity of Burbank \n275East Olive Avenue \nBurbank, CA 91510 \n68. Valerie Nera \nCalifornia Chamber of Commerce \n1215 K Street, Suite 1400 \nSacramento, CA 95812 \n69. RexHime \nCalifornia Business Properties \nAssociation \n1121 L Street \nSacramento, CA 95812 \n70. Jon Van Rhyn \nDepartment of Public Works, County \nof San Diego \n5555 Overland Avenue \nSan Diego, CA 92123 \n71. Clifford Moriyama \nCalifornia Coalition for Clean Water \n1121 L Street, Suite 809 \nSacramento, CA 95814 \n72. Gq Lorden \nCalifornia Institute of Technology, \nDepartment of Mathematics \n355South Holliston Avenue \nPasadena, CA 91 125 \n73. Roberta Larson \nCalifornia Association of Sanitation \nAgencies \n925L Street, Suite 1400 \nSacramento, CA 95814 \n74. David Williams \nEast Bay Municipal Utility District \nP.O. Box 24055 \nOakland, CA 94623 \n75. Tracy Egoscue \nSanta Monica Bay Keeper \nP.O. Box 10096 \nMarina del Rey, CA 90295 \n76. Lawrence Jackson Jr. \nVentura County Watershed Protection \nDistrict \n800South Victoria Avenue \nVentura, CA 93009 \n77. Donald Weston \nUniversity of California, Berkeley \n3060 Valley Life Science Building \nBerkeley, CA 94720 \n78. Lawrence Pierce \nDepartment of Public Works \n33282 Golden Lantern \nDana Point, CA 92629 \n 79. \tDonald Jensen \nCity of Santa Fe Springs \n11710 Telegraph Road \nSanta Fe Springs, CA 90670 \n80. Dennis A.Dickerson \nLos Angeles RWQCB \n230 West Fourth Street \nLos Angeles, CA 90013 \n81. Byron Sher \nCalifornia State Senate \nState Capitol 2082 \nSacramento, CA 95814 \n82. Jane De Lay \n345 Lake Avenue, Suite A \nSanta Cruz, CA 95065 \n83. Emily Dean \nSonoma County Water Agency \n2150 West College Avenue \nSanta Rosa, CA 95401 \n101. Tom Mumley \nSan Francisco Bay RWQCBmMDL \nRoundtable \n1515 Clay Street, Suite 1400 \nOakland, CA 94612 \n102. Linda Sheehan \nThe Ocean Conservancy \n116 New Montgomery Street, Suite \n810 \nSan Francisco, CA 94105 \n103. Sarah Newkirk \nThe Ocean Conservancy \n116 New Montgomery Street, Suite \n810 \nSan Francisco, CA 94105 104. Bill Jennings \nDeltaKeeper \n3536 Rainier Avenue \nStockton, CA 95204 \n105. Leo O'Brien \nWaterKeeper \nP.O. Box 29921 \nSan Francisco, CA 94129 \n106. Alan Levine \nCoast Action Group \nP.O. Box 215 \nPoint Arena, CA 95468 \n107. David Paradies \nThe Bay Foundation of Morro Bay \n875 Santa Ysabel \nLos Osos, CA 93402 \n108. David Beckman \nNatural Resources Defense Council \n6310 San Vicente Boulevard, Suite \n250 \nLos Angeles, CA 90048 \n109. Peter Kozelka \nUSEPA, Region 9 \n75 Hawthorne Street \nSan Francisco, CA 94105 \n110. Tom Herman \nSoper-Wheeler \nP.O. Box 173 \nEureka, CA 95502 \n11 1. Craig Johns \nCalifornia Manufacturer's and \nTechnology Association \n980 Ninth Street, Suite 2200 \nSacramento, CA 95814 112. Valerie Nera \nCalifornia Chamber of Commerce \n1215KStreet \nSacramento, CA 95814 \n113. Tess Dunham \nCalifornia Coalition for Clean Water \n1127 11th Street, Suite 626 \nSacramento, CA 95814 \n114. Sharon Green \nTri-TAC and CASA \nP.O. Box 4998 \nWhittier, CA 90607 \n115. Steven Arita \nWestern States Petroleum Association \n1415 L Street, Suite 600 \nSacramento, CA 95814 \n116. Karen Ashby \nCalifornia Stormwater Quality \nAssociation \n707 4th Street, Suite 200 \nDavis, CA 95616 \n117. Bob Lucas \nCalifornia Council for Environmental \nEconomic Balance \n1121LStreet, Suite 407 \nSacramento, CA 95814 \n118. Armand Ruby \nCounty of Sacramento \n707 4th Street \nDavis, CA 95616 \n119. Sterling McWhorter \nHumboldt Cattlemens Buckeye \nConservancy \nP.O. Box 210 \nPetrolia. CA 95558 \n120. Bill Busath \nCity of Sacramento \n1395 35th Avenue \nSacramento, CA 95822 \n121. Tim Piasky \nConstruction Industry Coalition on \nWater Quality \n1330 South Valley Vista Drive \nDiamond Bar, CA 91765 \n201. John K. Pratt \nCity of Bellflower \n16600 Civic Center Drive \nBellflower, CA 90706 \n202. Desi Alvarez \nLos Angeles County Executive \nAdvisory Committee \n11I1 Brookshire Avenue \nDowney, CA 90241 \n203. \t Canie Inciong \nDepartment of Public Works, Los \nAngeles County \n900 South Fremont Avenue \nAlhambra, CA 91803 \n204. Heather Merenda \nCity of Santa Clarita \n23920 Valencia Boulevard \nSanta Clarita, CA 91355 \n205. \t Clayton Yoshida \nCity of Los Angeles \n433 South Spring Street \nLos Angeles, CA 90013 \n206. \t James Colston \nOrange County Sanitation District \n10844 Ellis Avenue \nFountain Valley, CA 92708 207. \tRichard Watson \nCoalition for Practical Regulation \n2175 Cherry Avenue \nSignal Hill, CA 90755 \n208. \tBIane Frandsen \nCity of Lawndale \n14717 Burin Avenue \nLawndale, CA 90260 \n209. \tEric Escolar \nCity of Inglewood \nOne Manchester Boulevard, Suite 300 \nInglewood, CA 90301 \n210. \tHeather Lamberson \nLos Angeles County Sanitation \nDistricts \n1955 Workman Mill Road \nWhittier, CA 90601 \n21 1. Mary Jane Foley \nSouthern California Alliance of \nPublicly Owned Treatment Works \n30200 Rancho Viejo Road, Suite B \nSan Juan Capistrano, CA 92675 \n212. \tRodney Anderson \nCity of Burbank Public Works \n275 E. Olive Avenue \nBurbank, CA 91510 \n213. \tPhyllis Papen \nCity of Signal Hill \n2175 Cherry Avenue \nSignal Hill, CA 90755 \n214. \tLarry McKenney \nOrange County Flood District \n300 North Flower Street \nSanta Ana, CA 92703 215. \tGerald Greene \nCity of Downey \n11 11 1 Brookshire Avenue \nDowney, CA 90241 \n216. \tRobin Rierdan \n9232 Lapeer Court \nSantee, CA 92071 \n217. \tMark Gold \nHeal the Bay \n3220 Nebraska Avenue \nSanta Monica, CA 90404 \n218. \tSujatha Jahagirdar \nCalPIRG \n3435 Wilshire Boulevard, Suite 385 \nLos Angeles, CA 90010 \n219. \tRick Wilson \nSurfrider Foundation \n215 South Highway 101, # 206 \nSolana Beach, CA 92075 \n220. \tGabriel Solmer \nSan Diego Bay Keeper \n2924 Emerson Street, Suite 220 \nSan Diego, CA 92106 \n221. \tDavid Paradies \nThe Morro Bay Foundation \n875 Santa Ysabel \nLos Osos, CA 93402 \n222. \tConner Everts \nSouthern California Watershed \nAlliance \n5321 Amestoy Avenue \nEncino, CA 91316 301. \tPatti Krebs \nIndustrial Environmental Association \n701 B Street \nSan Diego, CA 92101 \n302. \t 273 Postcards from Concerned \nCitizens \n303. \tMark S. Norris \nPublic Works/Wastewater Division \n6001 South Perkins Road \nOxnard, CA 93033 \n304. \tVictor Weisser \nCalifornia Council for Environmental \nand Economic Balance \n100 Spear Street, Suite 100 \nSan Francisco, CA 94105 \n305. \tCraig S. J. Johns \nPartnership for Sound Science in \nEnvironmental Policy \n980 9th Street, Suite. 2200 \nSacramento, Ca 95814 \n306. \tGreg Scoles \nCity of Santa Rosa \n100 Santa Rosa Avenue \nSanta Rosa, CA 95402 \n307. \tAlexis Strauss \nUSEPA Region 9 \n75 Hawthorne Street \nSan Francisco, CA 94105 \n308. \tCraig Johns \nAB 982 PAG Regulated Caucus \n980 9th Street, Suite. 2200 \nSacramento, CA 95814 309. \tSteven Arita \nWestern Petroleum Association \n11 15 11th Street, Suite. 150 \nSacramento, CA 95814 \n310. \tChris Crompton \nCounty of Orange -Resources & \nDevelopment Management \nDepartment \n300 N. Flower Street. \nSanta Ana, CA 92702 \n31 1. \tArmand Ruby \n1032 Monis Circle \nWoodland, CA 95776 \n312. \tDesi Alvarez \nStormwater Program \n11 11 Brookshire Avenue \nDowney, CA 90420 \n313. \tGary Lorden \nCalifornia Institute of Technology \n355 South Holliston Avenue \nPasadena, CA 91 125 \n314. \tVictoria Conway \nCounty Sanitation Districts of Los \nAngeles County \n1955 Workman Mill Road \nWhittier, CA 90607 \n3 15. \tTom Mumley \nSan Francisco Bay Regional Water \nQuality Control Board \n1515 Clay St., Ste. 1400 \nOakland, CA 94612 \n316. \tRita Robinson \nCity of Los Angeles, Department of \nPublic Works \n433 South Spring Street \nLos Ange.les, CA 90013 317. Rodney Andersen \nCity of Burbank \n275 Past Olive Avenue \nBurbank, CA 91510 325. Mark Gold \nHeal the Bay \n3220 Nebraska Avenue \nSanta Monica, CA 90404 \n318. Roberta Larson and Sharon Green \nTri-TAC \nP.O. Box 4998 \nWhittier, CA 90607 \n3 19. Linda Sheehan and Sarah Newkirk \nThe Ocean Conservancy \n116 New Montgomery Steet, Suite 810 \nSan Francisco, CA 94105 \n320. David W. Moore \nWEC Western Solutions \n2433 Impala Drive \nCarlsbad, CA 92009 \n321. Paul Gosselin \nDepartment of Pesticide Regulation \n1001I Street \nSacramento, CA 95812 \n322. Raymond C. Miller \nSouthern California Alliance of \nPublicly Owned ~reakent Works \n30200 Rancho Viejo Road, Suite B \nSan Juan Capistrano, CA 92675 \n323. Karen Ashby \nCalifornia Stormwater Quality \nAssociation \nP.O. Box 2105 \nMenlo Park, CA 94026 \n324. Laura Giudici Mills \nLCM Consulting \nP.O. Box 71 12 \nSpreckels, CA 93962 Page left blank intentionally. Table 2: Responses to Comments and Testimony \nCOMMENT SUMMARY OF COMMENT \nNUMBER \nDm, Introduction \n51.70 \t In its description of tkPolicy theFED sus forth a variety of measures that if \nimplemented would to som extent mitigate some of the Policy's advase \nenvimmenral impacts. However, Ulwe mrasures cannot be found in the Policy \nitself. There inconsistencies are misleading and cause the FED'S project \ndescription to be inaccurate. \nDFED, Environmental Setting \n51.68 The Environmental Setting secIion of the FED is deeply flawed and falls far \nshotl of CEQA's quiremenu. TheFED utterly fails to desnibe California's \nwidespread pollution problem and degraded beneficial uses. As such it is \ninadequate under the law. The FED dm not describe the at amounts of \noollutants and wllution that have been and continue to be dischareed into \nbalifomia'r Gters. No effort is made to auantifv these disehareLin , 1- of ~ ~~~~ ~~ ~~~~~ ~~ ~~ ~~ ~ ~~ ~ ~ . -~~ \nmarr. tuuc effect aolher lmpael. TheFED wkcs noeifotl lodcs-icnhe Ihc \nwdcspmd violal~ons of rlandmds and impa~rments in each of lhae \nwate&heds. The FED does not describe the numerous water bodies in \nCalifomia that are in daneer of becoming imoaired bv wllutants. Nordoes the \nFED make any nrtmpt todescnbe the b;nef;clal use; &at have ken harm4 by \nthcrc ~ngralrmcnts hfomllon about be envlronmnlal selllng is cssenual to \nsupport an analysis of the cumulative impacts of this policy and the analysis of \nalternatives. Without this information it is impossible for the public to fully \nevaluate SWRCB'r decision. Consequently without this additional information \nthe FED is inadeauate under the law. \nDFED, Issue 1: Scope of the ListinglDelisting Policy \nThe NRC reeommrndauan lhal slala develop appropnale uw deslgnathonr for \nwaln bodtcs pnw lo the 303, d) llrltng pmcas, and thal slates refrnc mc \ndes~gnsuons pnar to TMDL devclopmmt should be ~ncorporalcd ~nlo \nCalifornia' r tisting policy \n43.58.47.10. \n60.49. hn46 RESPONSE \t REVISION \nThe FED should be viewed asthejustification forthe various provisions Of the NO \ndraft Policy. In order to avoid duplication, the draft Policy doer mt include all \nof the information, justification, alternatives, etc. that arepresmted in the \nFED. The Policy provides the requirements for placement mremoval of wten \nfrom UleMion 303(d) list. \nThis sation of Ule FED contains a description of tkphysical envimtal Yes \nconditions using desniptions of the Regions and the wata bodies hom the \nBasin Plans, as they exist, from both a local and regional penpective. This \ndescription represents the baseline condition upon which the environmental \nimvacts were determined at thetime that the FED was commenced. TheFED \nha; been revised to include a table that lists thetotal water bodies on the2002 ~~ ~~~ \n303,d) list and lhe atimlcd sm of the area affcned. by re@on and wata body \ntype. so thst a more complctc plclun. of the baseline condition is represented \nThe purpose of section 303(d) of the Clean Water Act is to list water quality No \nlimited segments relative to existing standards. Re-evaluation of existing \nstandards is usually accomplished undaCWA seaion 303(cX1) and \nim~lementing regulation (40 CFR 131.20). During the triennial review period \n~~~RWQCB~ of reviewing water&ality hid public hearings for the \nstandards and as appropriate, modify w adopt newstandards. \nIf the section 303(d) listing process and the triennial review pmess were \ncombined it would be impassible to complete the section 303(d) list every two \nvean as mandated bv federal regulation. COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \n2.1 \t Agm with the recommendation to make the document as specific and focused Commt acknowledged. \nas paasible \n5.2.12.3.71.4 \t Per National Research Council (NRC) recommendations, SWRCB should (a) Modificatim of beneficial use designations is a wy large task that is beyond No \nimplement appropriate beneficial use designations befon listing; (b) define the xope of preparation of UpCWA section MXd) list Water quality \nwater quality ateria for magnitude, iiequmcy, and duration; and (c) mate abjstives and criteia have been established in Basin Plans and in federal \nboth a preliminary list and an action list in addition to tkfinal 303(d) lit regulation. For numaic objectives and atezia, magnitude has been \nestablished. Far my water quality objgtiver and ateria, duration and \nfrequency have been established. lbesrmcture of he list is addressed in inue \n2. \n7.5 \t Listings should be based on round science. Comment aclolowledged. No \n12.1 \t Support the SWRCB's goal of establishing a standardired appmach for Comment acknowledged. No \nassigning water bodies to the 303(d) lisl. including requiremolt?. for consistent \nand statisticaUy valid data evaluations, requirements for data quality and \nquantity, and implementation provisions. \n18.60 \t TheTMDL Roundtable recammolded that the listine -.D- should not Comment acknowledeed. No \ndcrcnbe a process fa detemunsng whctho water qrulrty standards are \nappropriate lkhfl Lsung Pd,dlcy 1s con~,slmtwthhlusmOmmcnQ31~m \nsince there is nostep requiring review of uses and standards \n20.19,20.18, \t Ehminate burden on RWQCBs beyond performing the assessment of whether Thedraft FU) recommends providing guidance on the listing and delisting No \n20.28.80.13 \t water quality standardsarebeing attained. A number of provisions require the factors necessary to assemble therequired section 303(d) list of waters Ulat do \nRegions to go abave and beyond an assessment of California's surface waters. \t not currently meet existing water quality standards. Some of the factors are \nrelated to the factors listed. While these tasks mav be more wok forthe \nRWQCBs ~nn~ally, there would be a ravrngs dpmblems already being \naddressed aretdenufied at Ihe begtnn~ngof thc pnrcsr tmtead of when \nTMDh arc developed Fedenl rcgulsuon calls for schedulcng wtss on the \nlist for TMDL dev~lopment, therefore, this reqnirenmt is not avoidable. \nMonitorins is not reouired bv the Policv oase but the requirement?. in Policy -\t .. \nwlll lntlumce morutonngcffons throughout the stare ~iihc monltonog \npropm IS bung rmpluncolal to dsrmnc if a wlcr should be plrccd or \nmoved fmm thesenion 303(d) list. \n21.11 \t SWRCB should wok toward developing thefinancial and othermurces to Comment acknowledged \ndevelop site-specific WQSs that anprotective withcut significant messary \ncosts for TMDL implementation (i.e., properly implement the CWA \nreauirement?. for defining a WOS violation). Rather. the SWRCB is admtine a ~~~~~~ -.~ \t . -\n303(d) lisl~ngapproach Ulat vlll rign~6canlly wcakrn uarcr quality prolemon \nby allowing nolafiaor of WQSs ~nCdzfonia usru bod,& \nAs painted out m the tED, 'the pwparatnon ofthc ilst doer nM reqrure rtatn to 'IhcPolicy prondssguidance ro srrwe that ihc &W W to Inst a WZIU body js No \nrcexaminc uhcthcr ..standards are appap\"ale.' Rrcommmd a rlcnific review scientifically credible The section 303(d) hsting pmess llso provldcs for - - COMMENT SUMMARY OF COMMENT \nNUMBER \nbe incomoraed into the303idl listine and TMDLomcess. \n50.10 \t Reevaluations of water quality standards must be subject to legal requirements \nand public review. \n50.9 \t Decisions lo delis must be Nly uansparent to the public and the public must \nbe given the opportunity to participate in any determinations which could affect \nwater quality. \n71.7 \t Rsommend, for those eases whae a standards review prior to listing is \ninfeasible, that SWRCB's approach, derailed in the document. 'A Pmcers for \nAddressing Impaired Water in California,' Dsember 2003, of evaluating the \nappropriateness of water quality standards prior to the development of aTMDL \n73.4 \t Suppons the policy dimtion being provided through the draft policy to narrow \nthe scope of the list slightly. \n76 29 \tInIhght of the State's cum1 budget sltuatlon and Ule tweyeu cycle for \nadapting 303(d) lists, appeciata the SWRCB'r prefcmce to incoprate \nguidance on lirtingldelisting factors only. \n76.30 \t A third alternative should be included in the hue 1 discussion that would \nincarparate aspects of Alternatives 1 and 2 while facilitating the completion of \n303(d) lisu on the w~vearcvcle cumntlv mandated bv federal regulations. \nThis Alternative could &vide midance assure that future listin& are \nconrlstem wth40CFR 130 7 and the cxcrtlng ltrtrngs were rewd for \ncomplnancc 1could also pmally address the 2MI rerommendauons of the \nNAS committee concerning development and refinement of use designations \nprior to TMDL development. 'Ibis Altemative should include guidance that the \nadootion of lmolemtation Ph for TMDk be delaved until Ihe a~olicable.. \nuse deslgnauons and water qwl~ty ob~ecuves uerev~cwd and rrflncd. tf \nnccesury Such a pmcedure auld he incorpanted hnto thc lmplemenlauon Plan \nchapters of the mer quality conml Plans (basin plans) adopted by the various \nRWQCBS and inm st&wi& plans such as Ule ocean Plan. kc&ration of the \nomcedures into the water oualitv manaeement olan would be consistent with . , \nCWA sectlo\" 303(d) md 81th CWC secuon 13242 TheCWAdocr not requlm \nI~lem'ntat!on Plans he adopted wthTMDls. 2nd CWC sccuon 13212 dacr RESPONSE \t REVISION \noublic review of recommended listines and the data used to list UMn A -\nrc~enlthc rcwnvof the man Itrung pmcesr every two yean wwld be an \nenormous and tlm. consumng undmak~ngand would be largely dupheauw of \nthe evaluation of data quality evaluations abdy qukd \nAll TMDU'are pareviewed asrequired by HealUl and Safety Codesmion \n57004. \nThe Policy explicitly states Ihat it is not m be used to 'establish, revise, or No \nrefine any water quality objective or beneficial use'; thexefon, xevaluations of \nwater quality standards anbeyond the scope of this Policy. \nThe draft Policy quim fact shew to be prepared that describe the No \njustification for bath listing and delisting warn. Using lhesc fact sheets, any \nwarn added or deleted fmm the list will be canridered publicly by RWQCBs \nand SWRCB. \nEvaluating the appmpriatenws of warn quality standards is beyond the scope No \nof lhis Policy. \nComment acknowledged \nComment acknowledged. \nThe alternative described is vinually the same as alternativenumber 2. The No \nPolicy is focused on compliance with CWA section 303(d). The scope of the \nPolicy is to develop a lirt of water quality limited semenu wine, existine, - - . . -\nstandards. \nme propmcd Palrcy focuses on rhe drsclopmmt of a narrowly defined rsuon \n303(d) list that includes only those waters that do not meet wata quality \nstandards and a TMDL is needed to resolve the pollutant problem \nRe<valuatlon oiex~sung standwds tr usually accompl~shed under CWA \nsection 303tcXI) and rmplmnung regulation (40 CFR 13 1 20) Dunng the \ntriennial review the RWQCBs hold public hearings forthe purpase of \nreviewing water quality standards &d as appmp\"ate, modify or adopt new \nstandards. COMMENT SUMMARY OF COMMENT \nNUMBER \nnot mandate the cantents of the program of implementation for achieving water \nquality objctives. Another policy guidance that could be included in \nAltemative 3 would be dinnion to the RWOCBr to their bmefidal use ~ ~~ ~~~~~~~~ --~ \ndcsiwtiom lo beconsirunt with CWC secuon L3241(a) toconslda Pmbable \nfumbeneficial ura'na'plentd burficial m.The powual beneficial use \ncategory found in today's basin plans is consistent with State law and has -\nresulted in listingsbased on usesthat do not exist and uehighly impdable in \nthe hefuture. \n206.4 Water quality standards arethe backbone of CWA and to the extent that the \nTMDLpmceu is mved from that in term of there isn't an identified \npollutant and there isn't an established criteria for what the appropriate pollutant \nis in that water body Ulan beTMDL pmces is going to be delayed and take \nmore time and remuma. \n216.2 The gentleman from Dominguez channel said, 'I don't know why we should \neven bother with any of there channels. There's no beneficial uses.' But that \nwater always ends up in the ocean, somebody fishes in it, somebody swims in \nit. Not a ad-thiha.-\nDFED, Issue 2: Structure of the Section 303(d) List \n2.14,Z.Z. 10.14, \n17.4, 18.28, 18.29, \n22.6.28.4.38.5. \n43.6.43.1.43.18. \n43.16.44.13.47.9. \n51.117,51.20, \n56.12.60.62. \n60.27.64.65. \n60.51,60.7,64.9, \n60.50,61.8,64.16, \n64.15.76.14. Considers the policy decision on how to stlucture the State's listing policy to \naddress water body segments identified as not meeting water quality standards \nlo be critical. A number of water bodies were listed on UleZOO2 303(d) list \ndespite the lack of an identified pollutant. 40 CFa 130.7 states that Ule 303(d) \nlist is for those impairments for which pollutants have been identified and \nTMDLS are still quired. \nRequests that a new Alternative 6 be prepared incorporating our comments and \npolicy recommendations above about the smcture of the CWA Section 303(d) \nList We funha recommend that the new Altemative becomethe recommended \nAlternative. RESPONSE REVISION \nFederal regulation quires that TMDLs be developed for the pollutants, No \nincluding toxicity, identified on the reetion 303(d) list USEPA has \ndetermined that all of the pollutants are suitable for'IhlDL developmmt \nComment acknowledged \nThe proposed Policy focuses on the develapmrnt of a narmwly defined section Yes \n303(d) list that includes only those watm that (I) do not meet water quality \nstandards and a TMDL is needed or (2) do not meet standards and a pmgm is \navailable to resolve the pollutant problem \nIn all cases but one, behedran Policy calls for the identification of the pollutant \nthat will become the focus of the TMDL. Federal regulation allows for \ndeveloping TMDLs for the identified pollutants causing or expeeled to cause \nwater quality standards violations (40Cm 130.7(bX(4)). The exceptim is \ntoxicity. The deftnition of a TMDL (40 CFR 130.2(i)) allows for TMDLS to \nexpressed in twms of either mass per time, toxicity or otha appropriate \n76.42,76.31,76.3, measure.' 1-in order for TMDLS to be expressed In of toxicity it is \n83.7.83.8.201.2. \n205.6,207.10, necessary for TMDLs to be developed for toxicity. The Policy allows for fhe \nlistine of waters for toxicitv whether the wllutaat is known or not Therefore -~ ~ ~ ~~ ~~~~ ~ \n207.17.207.3, \n207.7.208.L. \n210.5,210.4, \n219.7.219.6.221.7 whm listlng for toxicity, the statcmnt requiring the identification of the \npuUutant before a TMDL can be developed has been removed. \nW \nW \n0 \nP 18.14.20.22 The Regions are also required to makea distinction between impairments that Fedd regulation (40 CFR 130.7) requires SWRCB and RWQCBs to evaluate \nare due to pollutants versus pollution, which may require an evaluation that all readily available data and information, to identify watas Ulat do not met \ncannot be readily performed with available information. standards, and to identify the pollutants potmtially causing standards \nB-18 No COMMENT SUMMARY OF COMMENT \nNUMBER \n-\n18.93 \t Recommendation is that the response to an impairment listing should be \nconsistent with the Impaired Waters Guidance Policy (TMDL Policy). The \nlisting exerciselaction may recognize that there are various responses, or \nremedies, to a listing, but the listing exercise will not assert which response will \nbe exercised. The response to the listing will be separate from the listing itself. \nThe universe of potential responses, as well as guidance on how to select the \nmost appropriate response to a given listing, is contained in the TMDL Policy \nwhich is the companion policy to the Policy for the Identification of Surface \nWaters Not Meeting Water Quality Standards (A.k.a., Listing Policy). The \nListing Policy describes how to determine if a water should be included on the \nsection 303(d) List; the TMDL Guidance describes how to address waters \nalready on the section 303(d) list. \n56.6 \t The SWKB should revise the Policy to include on the 303(d) list only those \nwaters for which water quality standards are not attained and for which a TMDL \nis required. \n63.5 \t Alternative 5 is supportable only if detailed and specific, not general, guidelines \nare established for each pollutant type. RESPONSE \t REVISION \nexceedances. If certain information is not readily available and the information \nis required by the Policy, then the waters should not be placed on the section \n303(d) list. \nThe Policy has been revised to refer to allow RWQCBs to determine if Yes \nregulatory programs will solve the water quality problem in lieu of a TMDL. \nNo actions are mandated as a result of listing. The Listing Policy simply \nrecognizes management actions that are already in place. \nComment acknowledged. \t No \nComment acknowledged. \t No \nDFED, Issue 3: Weight of Evidence for Listing and Delisting \n2.3,56.13, 63.6 \t Alternatives 1 and 3 will not result in the consistency desired for the 303(d) \nprocess. Alternative 2 is the better choice. \n8.2,40.12,40.46, Suggest that the standard for listing be strengthened from a weight of the \n40.47,51.78, evidence test to a clear and convincing evidence standard such that where there \n51.103,51.25, . exists doubt as to impairment, no listing would occur. Past listings resulted in Alternative 2 could potentially lead to some inconsistencies especially when Yes \nnarrative standards are interpreted. The weight of evidence used by individual \nstaff cannot be confidently combined numerically because each individual , . might overestimate or underestimate a given piece of evidence by distinct \namounts. These estimations cannot be reliably captured using a purely \nstatistical weight of evidence approach. \nIn Alternative 1,data and information could also be lost when combining lines \nof evidence; however, if fact sheets contain an assessment of the way lines of \nevidence were combined, this problem would be minimized. When \nconsidering multiple lines of evidence each line of evidence should be \nevaluated separately to determine whether multiple lines of the evidence for the \nsame water body support the same conclusion. The Policy has been revised to \ninclude a brief description of the weight of evidence approach. \nThe standard of evidence for the Policy as well as for listing or delisting is No \nsubstantial evidence. Substantial evidence is defined in both the \nAdministrative Procedure Act (MA) and CEQA. MA section 11349.1 110.4 COMMENT SUMMARY OF COMMENT \nthe inclusion of far too many waterbadies. The volume of listed water bodies is \nalready far more than can reaswably beaddressed, and many of the listed water \nbodies arelisted on the basis of ~canty questionable evidence. \n10.12, 10.15, The listing and delisting factors in the Draft Policy focuses on the use of a rigid \n10.11, 10.8, 14.5, statistical methodology, backed up only by comparably rigid 'alternative data \n18.16, 18.18, . evaluation' methadology, rather than by a uue 'weight of evidence' apprmch for \n18.20,20.7,27.1, assessing the health of individual water bodies. As a result, the Policy does not \n36.3.37.7.40.81. comply with the federal CWA that, The policy shall include a 'weight of \n4095,40.96,40.9, evidence' approach and shall include criteria that ensure that the data and \n40.32.40.33. information used for identification and listing of impaired water bodies are \n40.31.44.9.44.8. accurate and vaifiablc' SWRCB should revise the Draft Policy to include a \n5 1.86.51.122. true weight of evidence approach as specific in the federal CWA. \n51.120,51.119, \n51.81,51.104, \n51.82.51.83. \n51.80.51.79, \nRESPONSE REVISION \ndefines the henecessity standard to mean 'the hed of thelulemaking pmegding \nthat demonstrates by substantial evidence theneed for a regulatim to effeFNate \nthepurpose of the statute, court decision, or oths provision of hw that the \nreguhtion implements, interprets, ormake specifi c, Iaking into account the \ntotality of therecord. For purposes of this standard, evidam includes, but is \nnMlimited to, facts, studies, and expnt opinion.' Public Rsourcer Code \n~eetion 21082.2 alsodefmes in tarns of what is included and vhl is not \nUnder this law substantial evidence indudes facts, reasanable assumptions \nDredicated umn facts. and ex&. ooinion suomrted bv . . . factr. Substantial \ncndmcc is not argumca. spxulatian, unsubstantiated opinim nnarrative \ncndence which is clearly inaccurate or rnonmur, or endence of social or \neconomic impacts which do not conhibute to mare not caused by phyrical \nimpacts on the envirmmmt. \nUnder the pmvlslons of the draR Polcy, mrcrs would only be hsted ordchsted \n~f substanual evidence tr avatlable doeumenllng the ds~sxon Urlng ms \napproach, substantial evidence is not an unusually large amwnt of evidence \nbutrather theamount of data andinformation that a reasonable pas^ might \naccept as a basis far the decision. \nDoubt regarding the basis for lisdng and delisting decisions will be present \nunavoidably in evay circumstance. The decision lules pmw in the draft \nPolicy make the decisions more certain but the decisions will never be entirely \nfreehall doubt. \nSome lines of evidence could he sufficient alone without additional lines of \nevidence for support. Such cases include aceedance of a numerical water \nquality standard. Other cixumstanees will require suppmting evidence in \nassessing water quality. These cares include assessing human health, nuisance \nconditions, adverse bii@ral wpcmse, degradation of biological ppulations \nor atnmunities and trends in waterquality. \n'Weight of evidence' and 'multiple lines of evidence' as used in the draft Policy Yes \nare accepted collcepts in the scientific literature (e.g., Gwd, 1985; Smith et al., \nZWI), and are therefore discussed and promoted accordingly in the draft FED \nand draft Policy (see Section 3). AE? fust step. in implementing the Policy \nthese approaches are required to be used in conjunction with the binomial mt \nfor numeric sample data. The use of hypothesis or significance testing is one \nway to weigh evidence (Good, 1985). The draft Policy also allows RWQCBs \nto recommend listings or delistings based on the situation-specific weight of \nevidence factors. \nRWQCBr will need to document all listings and delisting decisions in faa \nsheets and SWRCB shall determine if there is substantial evidence to list m \ndelist. \n8-20 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n53.28.60.42, \n76.13.80.6,81.l, The new mion in the inhoducdon pmts thesteps for implementing the \n101.4, 102.7, Policfs weight of evidence approach. The appmach indudes Ihe pmcm for \n106.6, 107.3, data and information prep-sing, dim and information pdg, and data \n107.1, 107.10, assessment The Policy also has wdght of evidence listing and delisting facm \nl08.18, L09.17, that allows RWQCB to make tzwmmadalioos as long as RWQCBs justify its \n217.17.221.1. recommendations by: \n221.8.221.3 \n--Pmvidine. anv data orinformarion sumnine thedecision:.. -\n--&bi& mfael rheeu haw the dam ninformation affords a substantial \nbaris in fael whch the ddsis~onean be reasonably \n--Demanstrating that the weight of evidence of the data and infomatian \nindicate attainment status of rhewater quality slandmt md \n--Dunanswting that theapproach used in scientifically defmsible and \nreproducible \n10.13 The wata body must he listed if standards arenot met. A TMDL may or may If water quality standards arenot mLwater bodies will be placed on the No \nnot be the appmpriale solution. Should a TMDL be aut~~tic? Again, this goes senion 303(d) list (please refer to seetion 2 of the Policy). Placement anthe \nback to Ihe mle of pmfesrional judgment, weight of evidence. multiple tines of list does not automatically mean a TMDL will be wmpleted. ThePolicy allows \nevidence. Consideration of the above should be acknowledged by language placement in another category, if pollution wnlml requinmentsarereasonably \nadded to this section. expected lo result in attainment of the water quality standard. lkRWQZBs \nare afforded significant flexibilily to determine if a water should be listed or \ndelisted sing the situation-specific weight of evidence listing and delisting \nfacton. \n10.6.42 1. 104 8. Thr b~nomlal pmedlm proposed in ihe Policy override the need fox *eight of 'Best pmfess~mal judgemenl' depends on ihc experience and expenire ofthe Yes \n106 8. 106 7, cndencc andlor pmfcssional judgment Not all llsllng cnlcna can be monilnrd penon rendering theludgement Even pmplc wrth reasonably similar \n1085,2194 by devices or in the lab. Rcllance on the welghl of evidence and pmfcrs~onal cxp&ence could judge rimilarstlualions differently. The currmt section \njudgment is necessary. 303(d) list varies substantially bctwem Regiom. 'fhe intent of the Policy is to \nomvide a wnsistent wav to develo~ theseetion 303(d) list and. at the same . . \n;,me inwrporates~le-s&~fic info-uon. To do U~is.fatly specific decision \nml~sarc pmvlded thal rrquan: dm to be cons~stently analy~cd. ltedrah \nPolicy pmndes agnificant bolude to RWQCBs lodelmninc thespatial \nrepresentation, water body segmmtation, and ternporal represenlation of the \nsamols used in the analvsis. RWOCBs need onlv to document these fanon in \nthe htcr body lac1 she; 71usIl&brl!ry la usc;udglgemmt has bcen \nemphasld m lhc drah Pollcy by rnclus~on of l~stnng and dellsung facton lhat \nallow RWQCBs to UK. the wctghl ofcvldence dependrng on rrruaoon- and ale- \nspecific mnridadtions \n12.6, 109.11 The basis and rationale for addiuonal listing decisions is unclear. The The huoductian (Section I) has been revised to insen a description of Ule Yes \nW commenter supports guidance regarding the requirements for and vansparency \nof listing decision. Policy's overall the weight of evidence approach \nW \nA 21.57, 21.61 Suppotl the useof a pmpedy developed Weight of Evidence (WOE) approach Section 303(d) of the federal CWA requires each state to identify thme waters No COMMENT \nNUMBER \n32.1 \n38.4.43.7.56.20. \n60.52.64.18. \n64.11.64.13.76.32 \n77.1 SUMMARY OF COMMENT \ninevalwtlon of exismceof vralm quality impalmnl and 18s cause. Htgh \nqualhly wlmce should be uxd in lirung and dellsung. involv~ng a non-numeric \nBest Profesional Judgement which pmperly inco'p,rates aquatic life toxicity, \nexcessive bioacc&tion, aquatic organism assemblages relative to \naomo~te reference sites. and chemical information on the cause of adverse .. . \nimpacu- no1 laal mcmuations. lie use of WOE appmach should be thmugh \nTlEr lo identify the causeof loxtctty \nThe policy appean pmeme flexibility for the RWQCBr to war* with \nSukeholden lo obtain and evaluate hi& aualitv dafaand lo discuss findines in -. . \nan apm, publlc procur Encourage SWRCB lo cn~we thal such Ilcxlhllll~, \npreserved in the pol~cy so lhal dctnrmnauons on exceedanee of wala quality \nobjectivesarebased on a bmad array of information and on sound science. In \ntbat regard,the policy should promote a wide wiety of investigative strateg$es \nand avoid theaooearance that it endanes or nrexribes r~ecifieomcedures. such \nas the pmposei~ppltcauan of the blnomn~l drrrnbutlon 'RWQC'BS should have \nthe dmrct~on lo cons~der all &la and tnterprctat~ons hat they and slakeholdcn \ndeemappmpriate aspan of a comprehensive, weight-ofevidence approach for \ndelemining water quality impairmen& \nSupports recommendation of Alternative I. Usein the 303(d) listing of a \nweight of evidence appmach. \nGreaterclarity is needed in the distinction betwrm hue 4 (single line of \nevidence) and ksue 5 (multiole Linesof evidence). Toxicitv ao- . .. under ksue \n5. yet it wr my lmpnss!on lhal tortcity could be used alone fn llsung (though \nnm forTMMimplmentauon) It would be helpful to better explan what s \nmeant by multiple liner of evidenee. Some of that information appean towards \nthe end of the dmment, but it would be helpful lahave a brief explanation up \nfmnt when the sinele vs. M116ole issue is fin1 raid. -RESPONSE \nwithin ils boundaries ior which the cffluml l~m~lauons rcqukd by rstion \n301(bkIXA) and section 301mXIXR) are not stringent enough lo implement \nany wafer quality standard applicable m such watm. In addition, tbeMng \nPolicy requires Ule use of a multiple lines of evidence for human health, \ntoxieiw. nnuisancemnditionr. adv- biolaeical resanse. demdation of ,. \" ~7 ~- ~ ~~~~~~ \nbiological populauw or comities and tnndr m waw quality. Any \ncombmnat~on of lhew conditions can be uscd lo suppon a hshllgldclistlng \ndecision. Iheuse of TIESare included in the toxicity stion of &FED and \nPolicy to identify thecause of or Uleconhibum to toxicity. \nIlslng TlEs as he solc bans fn rubstant~aling the pollutant rr causing M \nconmbuong to the slandards exccedancc rr a very high burdm of pmof \nAssociations between pollutanf mncenmtians and effects have been uxd in \nmany scientific studies to link effecu with pollutant levels and are qpqdate \nfor develooment of the section 303(d) list \nThe Policy pmvides guidance anhow to interpret and weigh a wide Mliety of \ndata and infamation and omvides a or-to evaluate data that if iustified. \nallow for the use of addlhonal data Ad nnfarmation lhe Polry hkbem \nrewsed loallow RWQCBs wdcdxscretnon. ~f 11is needed. toevaluale all lrncr \nof evidence that may be available \nComment acknowledged. \nThese sections have been clarified. \nDFED, Issue 4: Listing or Delisting with Single Line of Evidence \n18 57 The Ltrung Polley rhauld use the lechn~cal module apprmch used m he TMDL Sert~on 13 191 3(a) rwuuer the SWRCB lo prepue guldelrna lo be used inW Ciuldanee 'The Ltstmg Pollcy Nwlf should just define pad paramaas for l~sung. delrnmg, dcvclop~ng. and ~mplemcnt!ngTMDLs pmml mCWA m REVISION \n-\nYes \nNO \nYes \nNo \n COMMENT \nNUMBER \nSUMMARY OF COMMENT \neonducung the 303(d) list assessment. Overtim. specific technical modules \nshould bedcwloprl that would pmuidc gwdanee. but not -dam. on how lo \nconduct specific typesof -meats (e.g. bioaccumulation: pathogens: \nnuuiene:sediment). Thenarea wide -ay of technical issues that must be \nconsidered in odormine assessments fordiff-t tws of mllution. The \nscience in pedarmiag such same is evolving and should not be mandated - .. . \nwllun a polncy. Owdance. which auld be updared pnortoeafh hung cycle, \nwould allow the Regions and SWRCB to use the most current science in \n.evaluating available data and infamation to determine standards attainment RESPONSE \nroctlon 303(d) Additionally. thc Rudga Supplemental Rcpnl nquircda \nweight of evidence appmach and the inclusion of cnlma that muredata and \ninformation are ammte and verifiable. The Policy fallowr lhis mandate by \npmviding guidance on how to cmduct specific typesofasrarmeoe for \nvariwr wllutanu while allouine the use ofthe mosI clormt saentifie -\nappmacher'available. If a non--&lay 'tshnical module' approach were \ntaken it a less likely the Policy would pmvidcaconslslml lisong process. \nDFED, Issue 4B: Interpreting Numeric Marine Bacterial Water Quality Standards REVISION \nNo 2.5.60.54.76.34 \n21.1,21.34,21.23. \n51.1W Agree with the recommendation. Rules for determining ocean water quality \nshould be a statewide rather than a neional issue. \n~ \nAllowing a 10% exceedance rate plus a confidence level of 90% in a binomial \ndistribution at marinebeachesis arbiuarv. is not mtective of ~ublic health. and ,. \nsllowr an cxceed3nee ntc far higher than the ureedance nles obsewed at many \npolluted beaches in Cllifamia \nThe policy specifies that if the reference system is not used, a marine beach will \nnot be listed unless the obsewed exceedance rate is 10% or greaterwith a 90% \nconfidence level using the binomial model. This translates to a 17% exceedance \nrate at beaches monitored weekly (the mt common monitoring plan at \nCalifornia beaches) using Table 3.1 of the dnft Policy. This is an extremely \nhiah rate of exceedance of Califmia's health-based standards, which are \ndesigned to meet the federal marine beach criteria. Clearly, lhis policy will \nresult in the failure to list beacm that frequently pose a health risk above the \nUSEPA's recamm~lded health risk rate of 19swimmen per 1.000 for \ngastrointestinal illnesses and that are not supparting a REC-I beneficial use \ndesignation. \nThe recommended 1096 threshold is not supponed by cxlsting dam For \ncxamplc. data analyses conduned for the bactena TMDLs for Santa Monica \nBay do not suppon a 10% exceedance rate. Analysis of five yean of mutine \nmonitoring data at 55 beaches showed that 35 beaches had an average \nexceedance rate of less than 10% oer war. In other words. 61% of the beaches . . \nmutlncly monttored in Sama Momw Bay have an excMdance nte of less than \n10%. yn most of thesc beaches arc monttarcd because they luve sown of \nbacteria n&y suchas st- drains. Thu,my beaches with sources of \nbacteria have a lower enceedance rate thanthe rate the state is using. \nSWRCti povrda nolurufiwuan for applpng the bbrnmal model wth a 10% \ncxccedance ntc to the arrerr-t of manne beaches for pmtectmn of human Comment acknowledged \nThe proposed exeeedance frequency is very low *en compared to the \norecision of bacleria measurements and is recammended in USWA euidance -\ndocuments kg.. USEPA. 1997~). Bacteria measumnts are inhemlly \nimprecise. In the SWAMP QAPP (Puckat, 2002). for example. masurrmcnr \nvariability must be less than 1.000 times the averageof duplicate \nmeasurements to be considered acceptable. With this level of acceptable \nvariabiilitv it is orobable that some measurements exceed standards when in . . \nfact standards an not exceeded If no other exceedance frequency value is \navailable then using a 10 preen1 value (as an avenge) squttc rmallrrlauve \nto the wpened analyucal vanabrl~ty m these baama nndcator mu. Ua lower \nexceedkce frequency is justified based on siNation-specificfaclors, Ule \nalternate value may be used. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nhealth. me policy fails to explain how Ulir 10% relates to implementation of \nthe health standard. Instead. thispacentage is hm an outdated \nmmdation from USEPA forintup~ting fecal califomdata. This \nUrtshold was not recommended by USEPA in their most recent guidelines for \ninierpnting bacleria data falisting purposes in the May 2Mn draft \nlmlemenration Guidance of Ambient Wala Oualilv Criteria faBacleria. In -. \nfa=& none of the USW'PA'r mmt rrcenl guldanu docwnmts on management of \npublle health ptectton or asrwrmnl of recreauonal water bodlw ncommends \nthis high exceedance rate \n31.2 \t Rccomend lhal the 4 pmxnl criteria far bactend tmpalrd walu body The four pcrcenl value ww mmmended by ihe BWQW and hs No \nregmats not be used due to pxsible uqraentauve conditions. This mommndation represented a brmd agreement of scientists \\uho are familiar \nexceedance U~rahold was based on one locauon for a l'ited dwatian of five wth bacterial indicalon in coastal watsi. While the study is Lunilcd lo \nweeks. Support using the 10 pent hequency forthe number of banerial Southem California watm, SWRCB staff how of no other study or \nwater quality objective exeeedance, which is consistent with the hequency circumstance that would conuadict its application to all coastal wafers of the \nexcgdance rate for pollutants listing in this Policy that have been statistically Statc The drafl Policy allow RWQCBs to useoUla studies that anmore \nvalidated. representative of site-specific conditions. If site-specific smdies annot \navailable, then it is appropriate to use the four percent value during the AB 411 \nperiod. \n43.9 \t SWRCB should consider supponing BWQW rewmmendation of monitoring The decision related to the size of Ule area whm standards annot should NO \nstations 25 yards horn stem drain discharges. Agree with the staff- be based on site- and situation-specifie facton related to the segment of the \nmomended Almative 2. water body. Specific guidance would inappmpriately limit needed discretion. \n51.93,51.99, 51.95 The4% wcgdance rate allowed in the policy for assessing dry summer season Few locations along California's coastline have bem identified as nference No \nconditions at beaches in lieu of a reference system is arbitrary. beaches. If reference beaches have been identified and the standards allow, \nreference beaches should be used in the decision to list or not lisl wafers. The \nThe drafl Policy allows a 4% exceedance rate during the AB 41 1 monitning fall back position advocated by BWQW was to use 10 percat fordata sets \ntime paid (summerdry weather), which is far too high, based on statewide fmm year around sampling and Ihefour percent values for monitoring mly \nmonitarine data. In the Santa Monica Bav Beaches TMDL. the reference site is collected duine, the AB 411 wid. The study used to substantiate this \na popular beach located in ndrm ~anta~onica dccirron wxs r&ommnded & the barir for siting this fowpment value. No Bay. Daily rnonitwing for \nhc years showed no cxcecdanM dunng sum dry weather at thls beach. data and information to lhr conlmy was pmvided showng that the study is not \nMore s~gn~ficanlly.waler quality at many beachn in California met the state's hng urcd appmpnately. \nbactdaitandards throughon1 the smm~~. For example, during the AB 41 1 \ntime aeriod of 2W2. at least 34% of the 420 beaches mutinelv monitored \nsho& no ucecdances of swlc hdth standards dunng the AR 41 I timeham?. \nIn fact. most bwcha in the South Bay ponlon of Santa Monrca Bay donot \nexceed the 4% frequency on a year-mund basis, let alone for the sunune~ dry \nweather \nThe 4% excedance rate was dmved hma study of Southern Callfornba \ncompleted hy SCCWRP and athm as pan of the B~ght'98 study. This study \nwas not designed to establish exceedancerats due to backgrod bacterial \nconcentrations. The study did not consider whether anthropogenic sources \nother than stormdms were potentially conhibuting to bacteria at the beach; \nB-24 51.94 COMMENT \n SUMMARY OF COMMENT \ni.e. the study beaches may have been impacIed by a wide variety of sourca \nincluding septic tanlr, boats, anthropogenic-nlated bird and anid wastes, etc. \nAdditionally,thesndy is a snapshM study, in which rampling was conducted \n&ly during a 5-week period of one summa. Theresults are not temporally- \nreoresmtativeof unimcted beaches durine Ule drv season. The draft hlicv \nshould no( rely on snapshot data when lhmare y m of muone monwxmgdata \nawlable for many Calrfamra beachcs in rumrrary, ihc use of hr data m ihc \ncontext of assessing marix beaches foriennent is scientifically \ninappropriate. \nWe support the draft Policy's recommendation that a reference rysternappmach \nshould be used to assess marine beach wateraualiw for lirtine -.oumoses.. . . \nCornpatison to an appropriate dance sptun is ihc most sctentifically \ndefensible and proleeuve appmach toaecountmg for background levels of \nbacteria at marine beaches and to prevent funher degradation of water quality. \nThis appmach is mommended by the State's Beach Water Quality Work Gmup \n(BWQWG), which is coqxised of microbiologists and scientists fmm local \nhealth aeencies. POTWs. stormwater amcis. resexchers. and nonomfit c ~~~~ \nproups c~cd the nay is active mcmk .4dditionally, kereference rystm \napproach is used in the Los Angela RWQCB's bacteria MDL$ for the Santa \nMonica Bay Beaches. Marina Del Rey. and Malibu Creek, based on W \nreeonmendation of a stakeholder technical advisory committee after three years \nof studv and analvsis. RESPONSE \t REVISION \nCamnt acknowledged. \t No \nDFED, Issue 4C: Interpreting Numeric Freshwater Bacterial Water Quality Standards \n2.6,43.10,60.55, \t Agree with the recommendation. Consistency is needed. Comment acknowledged. No \n76.35 \nDFED, Issue 4D: Interpreting Narrative Water Quality Objectives \n2.7 \t For DFED, hsue 4D either Alternative 3 (recommended) or Alternative 4 would \nsuffice. \n8.4.110.5 \t Concerned with adoption of narrative standards and thresholds of concern \nwithout public notice. Numeric (not narrative) criteria, adopted by the SWRCB \nand not the st=& areadvisable. \n21.48,21.58,21.56 \t NAS tissue guidelines, chemically based sediment quality guidelines and Comment acknowledged. \nThePolicy does not develop new or revise existing water quality standards No \n(i.e, beneficial uses, water quality objectives, orthe State's Nondegadation \nPolicv). Evaluation rmidelina areused so decisions reeardine whether to olace .. -\t --\nwaten an the section 303(d) list areuanspawt. These guidelinesaye used \nonly forthe purposes of the section 303(d) list: no other regulatory use is \nauthorized or allowed. Theuse of any evaluation guideline quires the sfh \noresent to RWWBs and SWRCB thereasons for theiruse. \nThese guidelines are leehnieally valid and are used by many RWQCBs as a No \nB-25 COMMENT \nNUMBER \n21.59 \n21 60 \n21.63.21.62 \n21.64 \n43.1 1 \nV \nW 51.124, 51.132 SUMMARY OF COMMENT \nsdimnt appaml effects tkholds fmmCalifamis and olhn rtata amno1 \n~echniwlly mlrd for my purpose asrwialed wlth waw quality %<sersnml. \nAdditional information is needed on what is meant by 'toxicity guidelines,' and \n(Table 1)'USEPA screming' to determine if the particular guideline is \ntechnically valid. \nThe U S Anny Corps of Eng~neerr (USACOE. 1997). Ennmmcntal Restdue- \nEffects Database @RED) andihe USEPA (lamr.cn and hkley. 1999) sholld \nbc used 7he NAS ussue gu~del~nes arenot tcchn~wlly valnd and should not be \nused for Fish ~onsunmti&. \nIn order to be scientifically-based. there must be a critical review of the validity \nof the science used. \nThe NAS limits areno longerconridered reliable by anyone except the SWRCB \nstaff. Table 2 values are not reliable for estimating critical concentrations in \nwater Ulaf lead to adverse impacts. \nSupparts the need for numaic tranrlatm. Federal regulatiom require that \npollutants be suitable for calculation before a TMDL is required. Although \nUSEPA maintains that all pollutants are suitable for calculation under pmper \ntechnical conditions. It is often hard toestablish the needed proper technical \nconditions. Bat professional judgment canbe one of severalnrles of evidence \nbut nn the sale reason for listing if the SWRCB wants a mparent system \nAgree that mtive water quality objectives do not quantify parameters \nnecessary to clearly determine if beneficial uses arebeing protected. The \npresence of a pollutant doer not automatically translate into impairment of a \nbeneficial use. The use of narrative water quality objectives without numeric \ntranslators is often nat scientifically defeasible bucause interpretation of \nimpairment becomes subjective. Alter alternative 4 to reflect the requirement \nfhat impairmenu be suitable for calculation. \nSWRCR should remove the followng lrnguage from requlrcmtr an \nalarnalivegu~dclincr or methods uwd lo tnterprel nvralivc objstavcs 'For non-RESPONSE REVISION \nbenchmark by which execcdancer to ihestandard an:conpard. To om \nknouledgc, the NAS value have no1 bem withdram or superseded by othn \nmlues and antherefore appmpriate to use. The Policy provides the RWQCBs \ntheflexibility to useUlaeguidelines as well as a(her guidelines or more cunwct \ndata as lane as thev meet ihecriteria xlin Poliev. \nThe table contained a typgraphical error. The correctnference is'otherslam \ntoxicity guidelinw.' USEPA saeming' refer to values developed by USEPA \nusing a rirk-based mahod for developing screening values based ona dme- \nresponse variable and certain assumptions regarding exposun. Yes \nThe ED dm not rsommmd the NAS aaucguadclnna for fisheonsumpaon \nThe NAS srreenbng values represent levels tha arepmtsuve of aquauc lrfr \nThe screenrng valua developed by OEHHA and USEPA reprrsent \n~ ~ \nconcenuatiois in water Ihat omtect aeaimt the comunmtiou of aauatic No \norgarusms eonmnlng chenuh at levels grater Ulan predmd to mult \ntn s~gn~ficanl health problem RWQCBs have the optran of ustng the \nguldelrnes suggested, pmnded thcu use rr nfmced in he fact sheas \nin order to select evaluation guidelines, the RWQCBE would have to provide \njustification and nfawce for& apprmch or values used. The quired \ndoeurnentation would need to address the quality assurance requirements of the \nPolicy. No \nThe NAS guidelines arebased on evaluations of tissue residues for sevml \nchemicals; the rsommendatians reflect scientific understanding of the \nrelatiomhip between aquatic organisms and their environment. They are not \nintended to retlect critical concenuationr in water. No \nAlternative4 hasbeen revised to inelude theuse of 'interpretive guidelines.' Yes \nThe Pollcy provides RWQCBs guidmce on the uwof pcmnvreued. NO \nsc$enUficallydefmible&ta and anslysir that could be used in risk COMMENT SUMMARY OF COMMENT \nNUMBER \n&hold chemicals, risk levels shall beconsistent with comparable water \nquality objectives or water quality criteria.' Risk levels arerarely detamined by \nmany scientificallyacceptable mahods fa evaluating biological and emlogical \nimpacts. This is -use, in many cases, risk levels can not be conclusively \ncalculated without the use of multiple assumptions Ulat can be easily \nmanipulated. Thus, this requirement could sigaificantly limit the use of data \nand analysis hm peer-reviewed, scientifidlydefensible efforts or could force \nthe completion of uncertain, and largely useless, risk assasmenu. \n51.125 \t Federal regulations explicitly require that attainment of narrative water quality \nstandards should be assessed in developing the section 303(d) list. Although \n'[tlhe SWRCB and RWQCBs have used a variety of guidelines or scientifically \nderived values lointerpret narrative water quality objectives; other mtive \nobjectives defy such interpretation. Consequently, a state's policy far \ninterprwtion of these objectives must be flexible enwgh to pmvide for \ninterpretation of such objectives. \nThe pmposed policy doer not pmvide a flexible comprehensive policy for \ninterpretation of narrative water quality standards. Rather, it unlawfully \nundercuts thebasic requirement of section 303(d), which does not limit TMDL \npreparation or listing to violations of nanative objectives only when they can be \ntranslated under cenain rules. By imposing Ulese rules, the policy deparfs not \nonly fmm the weight-of evidence approach nquired by state law, but also from \nthe most basic mandates in section 303(d). \n51.131,51.123 \t SWRCB should remove the following language fmm requirements on \nalternative guidelines or methods used to interpret narrative objectives: \n'Reviously used or spsifically developed to assess water quality conditions of \nsimilar hvdrom~hic -. units.'This reauirement is nons~lrical because it has no ~ ~ ~ ~~~ ~ ~~ . \nbearing an thc qrwlily and appmpriatencss of tkgudcl~ne in queslioh Fur \nexample. 3 new numc guideline my bedeveloped as a result of extenswe \n-\tstudies to evaluate a specific wata quality problem According lothe draft \npolicy, this guideline dd not be used in the listing process if is has never been \nused before or if lhe developer did not specifically state it's use for cerfain \nhydrogaphic units. \nW 51 149.5 1 148, Thme arc sevr~dl lyper of lmwmnl !ha1 CaMOt be adqrwtrly assessed by \nW 51 129 51 147, avallablc numcnc gwdellnn Most rrgnrficanlly, lhcrcare no unlvmal numene \n5 1 126 51 127. gutdel~ncs for lmpatrmenls such as those isroclaud wth numents. algae. Y RESPONSE \t REVISION \nassmments. However, it is also recoguized that the calculation of & \nassessments include multiple assumptions Ulat can be,manipulated The \nPolicy, therefore, gives RWQCBs the flerdbility to intapm data and justify the \nuse of Ihat data in fan sheets. \nThe Policy adhm to federal replation3 regarding the assessment of mtive Yes \nwater quality standards. Following USE?ACALM guidance (2002ah it is \nmommended that listings bas& on nanative water quality objectives be \ninterprwd using a uanslator. SWRCB staffinterpw Vdnslafor dimtly from \nUSEPA (2Mna) 'A 'tranrlaM' identifies a process, m(hodoIogy. or guidance \nIhat Stater or Tribes will useto quantitatively intapm narrative ail-\nstatements. Translators may consist of biological assasmen1 (cg., \nfield measures of the biological comunity), biological monitoring methods \n(eg., laboratory toxicity tats), models or fomlae Ulat useinput of silb \nspecific informationldata, or other scientifically defensible methods.' Under \nthis definition, wive water quality objectives w be manslated using \nwious interpretive guidelines. Additionally. the necessary criteria are \npmvided in the Policy to validate evaluation guidelins outside of those \nrecommended in the Policy. \nFurther, the Policy includes a weight of evidence appmach for evaluating data \nand information and has been amended to include a silution-saecifie weieht ~r~~~~~ ~~-\nofevidence listing or dellsling process by whchRWQCBs can lor1 or delist \nany water body-pollutant combination cvm if it doer not meet the listing \nrequirements of lhe Policy as long as the decision can be reasonably infemd \nfrom the data and information. \nThe Policy has been revised to incoprate this eonmat. \t Yes \nSevcral uf !he Lsung Faclm have km revlsed lo lncludc the use of Yes \nmtcrpreuve guldelmes. this would rnclude the use of models, reference-based \nor ~nd~en approaches, btolwcal asressmnt mcthods. and uanslarmof all COMMENT SUMMARY OF COMMENT \nNUMBER \n51.128.53.7 \t turbidity, ah, color and oil. Moreover, there aresevd reliable quantirative \ndads that asrsr ndvebbiectives Ihat do not rclv on available numrie \neuidelioes. most notablv reference svstem based ammaches and use of -~ ~~~~~ ~~.~ ~~ ~ ~, ~,~ ~ ~ ,. \ntranslators of all types, asrsomdd by USEPA lhedraft Policy does \nallow for thew of cvaluatmn gu~dclines aha ban t h speifically namd in \nthe policy. Howver, the pmvisioasof the Alt-Ie Data Evaluation section so \nmwly drrumsaibe the use of these guidelines that my available numeric \nguidelines-panicuMy Ulercferencbsystm based appmacbes and oanslators-\nwould be unusable. Consequently, these resuctions eliminate much af the \npranieal value of mtive water quality objectiver. \n60.57.60.56.76.36 \t Remnmmds that Alternative 4 be snenglhened and mommended. Urge mat \ntheSWRCB recognize theneed for impairmenu to be'suitable for calculation.' \nNarrative water QualiO, obiectives areinsufficient determiners of impaimmt. \nThe ramification; of a-303(d) lirtine aretw enat to allow listings without .. -- -\nscientific basis. If this is oot done, narrative wataqual8ty objeeuves should \nrequire multiple lrna of cvidmfc until num&c mrlaton are developed. \n113.2 \t The Poliev allows inammariate inlemretation of nanative standards. . for .,\nexmple Uuough the health advlmes and Ulrough btoaccumulaoon data \nThcrc watn quality cntena were never offictally adopted, and shwld not be be \nbasis for 303(d) listings \nDFED, Issue 4E: Interpreting Aquatic Life Tissue Data \n2.8 \t For DFED, Issue 4E either Alternative 3 (recommended) or Altwativc 4 would \nsuffice. \nThe Sfate should rectify Table 3 in the Policy and use the wst appmpriate \nscreening value for arsenic in fish tissue-1.2 mgkg ww for inorganic arsenic \n(see EPA (2GQOb) pg. 5-1 1 and discussion in Newpon Bay Toxic Pollutant \nTMDLs pp. 69-70). \n43.12 \t Agrees with the staff-recommended Alternative 4 as long asrpeeifie pollutanIs \nareideatifid. \n60.58.76.37 \t Suppa the recommended Almative 4. RESPONSE \t REVISION \ntypes. These senions havealsobeen revisedIoallow theuse of referenee \nsvrm aolnoacha whea Ulevare amm!xiatc The Altanate Data Evaluation \n&on da;bem delned andmlackh 6th listine anddelistine-factnr \nallowng RWQCBs to wigh data and informaurn and make dsisioar to list or \ndeli* based rn the merits of the site and riruation specific &la and \ninformation. \nThe mommended Alternative 3 provider gad guidance on interpntive No \nguidelines to assess compliance with nanative water quality objectives. This is \nintentional to allow the RWQCBs theflexibility to incmwate the most-1 \nversions of euidelines or the &?st recent aoolifable m&h -\nIn der to inmlement a consistent aomch for olaciae and mwvine .. . --watm No \nfmm bc secuon 30Xdj IN. the polley rcqutrcs that quaaulartve gutdebu be \nused to help interpret nmuve water quabty objsuva Withohout amrlatorta \nintapret Ihese standards, there could be multiple and pimps conflicting \nintapremions. The draft policy limiIs the use of Ulese values to the sstion \n303(d) lia develaomt mas. For emmle. human bcalth adviwries ace an \nack\"o~ldgemen; that a'bencficial use is &v&ly impacted or lost The only \nurc of health advlsmies is asan indicator that bmeficlal uses related lo \nconsumpuon of fish areImpacted \nComment acknowledged. For clarification, Alternative 4 was Ulerecommmded No \nalternative. \nThe table has bem re* Ioidentify this weening value for arsenic. Ya \nAlternative 4 encompasss the use of NAS, OEHHA and USEPA mning No \nvalues Ulat arebared on detected levels of dendeals bioaccumulated in fish \ntissue. Hence, the mllutant is identified \nComment acknowledged. \t No COMMENT SUMMARY OF COMMENT \nNUMBER \n77.3,77.2 The text states: 'Bioaccumulation is the uptake and retention of chemicals by \nliving organisms. A pollutant bioaccumulates if the rate of intake in the living \norganism is greater than the rate of excretion or metabolism resulting in an \nincrease in tissue concentration relative to the exposure concentration in the \nambient environment.' This definition is in error. First, bioaccumulation is \ngenerally considered to be the uptake from all routes (i.e., food and water, as \nopposed to bioconcentration which is only from the dissolved phase). A \npollutant that is taken up but rapidly metabolized (no retention) still \nbioaccumulates. Secondly, for all compounds the rate of uptake is initially \ngreater than excretion/metabolism. As the tissue concentration rises, and for \nsome compounds as eliminatiodmetabolism becomes more effective, a steady \nstate balance is reached between uptake and loss. So the definition provided is \nnonsensical since the balance between rate of intake and rate of \nexcretiodmetabolism depends entirely on when during the exposure it is \nmeasured. Given enough time and constant exposure conditions, a steady state \nwill be achieved and uptake will equal excretiodelimination. By the definition \nprovided then, everything would be bioaccumulative in the early stages of \nexposure, and nothing would be bioaccumulative at steady state. \n77.4 \t There is an inconsistency in the statements \"merely identifying the presence of a \nchemical substance in the tissue of an organism is not sufficient information to \nconclude the chemical will produce an adverse effect' and 'pollutants detected in \nfish not only indicate pollution impacts on aquatic life and other wildlife. ..'. \nPotential exposure to piscivorous predators is meant, not impacts, in the second \ncase. \n77.5 \t In all the tables of tissue guidelines provided, in this section there is no \nindication of whether these values are on a wet or dry tissue basis. \n77.6 \t It is claimed that the FDA action levels were developed to protect human health \nfrom consumption of seafood involved in interstate commerce. It is unclear \nhow these levels would not be appropriate for the protection of human health if \nthe seafood was consumed locally. The rationale for this distinction is unclear. RESPONSE \t REVISION \nThe definition has been revised to conform with USEPA's definition (USEPA Yes \n2000d) and reads 'Bioaccumulation reflects the uptake and retention of a \nchemical by an aquatic organism from all surrounding media (e.g., water, food, \nsediment). Bioconcentration refers to the uptake and retention of a chemical by \nan aquatic organism from water only. Both bioaccumulation and \nbioconcentration can be viewed simply as the result of competing rates of \nchemical uptake and depuration (chemical loss) by an aquatic organism \n(USEPA 2000d).' \nThe second statement has been revised with the following: Concentrations in Yes \naquatic organisms from highly bioaccumulative chemicals may pose \nunacceptable human health risks from fish and shellfish consumption and may \nalso biomagnify in aquatic food webs, a process whereby chemical \nconcentrations increase in aquatic organisms of each successive trophic level \ndue to increasing dietary exposures (e.g., increasing concentrations from algae, \nto zooplankton, to forage fish, to predatory fish) (USEPA 2000d). \nThe screening values are based on wet tissue samples. This has been added to Yes \nthe tables as a footnote. \nIn their 'Guidance for 2004 Assessment, Listing and Reporting Requirements No \nPursuant to Sections 303(d) and 305(b) of the Clean Water Act (2003b), \nUSEPA stated 'Finally, some fish and shellfish consumption advisories and \nNSSP classifications are based on Food and Drug Administration (FDA) action \nlevels as opposed to EPA's risk-based methodology for the protection of human \nhealth. FDA action levels are established to protect consumers of interstate \nshipped, commercially marketed fish and shellfish rather than fish and shellfish \ncaught and consumed within a State. FDA action levels also include non-risk- \nbased factors (e.g., economic impacts) in their derivation, while WQC must \nprotect the designated uses without regard to economic impacts. EPA has \ntherefore concluded that FDA action levels do not provide a greater level of \nprotection for consumers of fish and shellfish caught and consumed within the \nState than do human health criteria. In such instances, or where water bodies \nhave a fish or shellfish consumption advisory, they need not be listed as \nimpaired under Section 303(d) unless there are water-specific data (and the . COMMENT SUMMARY OF COMMENT \nNUMBER \n777 The prefcnrd altanauve(numbcr4) sunclear The text either reilcrata basrc \ninfomuon given previously on uhy one would want lo imk at conuninants m \ntissues, ar says nothing at all. Thetext dm not clearly state what Alternative 4 \nis, and what little demiption there is makes it sound no different Ulan \nAlternative 2 \nBoltom-feedmg fish are rud loaccumulate contam~n3nls from dtrect contact \nwith contaminated sedlmmt TIUSis unltkely as fish rk~nand scales are vny \neffective barrim. Uptake is mnr likely Ulmugh consumption of benthic \ninvertebrates on which the fish feed. The dir&don between 'bottom- feeding \nfish' and Predator firh' which fnms the basis for this paragraph is unclear. A \nbouom-feeding fish canbe a predator fish \n77.9 The last sentence of mm~h 4 of alternative 4. state that 'tissues horn . -. \nappropnale Iargnrpeeta pll companron of fish and shellfish eontamnauon \nover a wde geognphtc ara' No!swe what rr uyng to kwd hem If 11 is thst \none can compare data between sites, that is hardly a quality unique to tissue \n-RESPONSE REVISION \ndata wae not considered duine the develoomeot or review of anon- -\npmwlonary NSSP classification), showing mattaim1 of Section IOl(a1 \nuses.' Smff incmporated this recommn&tioo unto the altcmative. \nAllcmauves 2 and4 arc vny similar The bastc diffmce is that Altcmative 2 No \nbases bioaecwnulation dam on a sue-by-sismnd~uon unlhoul a pmerr that \nwould allow for consistency among the Regions. Alternative4, bwever, \nprovides guidance on Ihe variousmeasuresavailable to intapref chemical \nresidue concentrations in tissue. Under this alternative. RWOCBr would be . . \nable to compm s~te spefifie &la sns lo the moat appmpnale measure usmg a \ncanristenUy applied and scientifically valid listing mlhcdolagy. \nIhemtmce has Leen revid, Ule words 'homdirst contact with Yes . \ncontaminated sediment dhas been deleted. ?he distinction baween bottom- \nfeeding fish and predator fish was meant loemphasize the effect of fwd web \nsmcture on bioaccumulation, i.r, the effect of species with diffmt diemy \nprefermcer: specifically, bottom feeding fish species (mphic level h)and \non top predator species (-hie level four). This dirtindon has bem clarified. \nWhile the cornoarison of data between sites is not a oualitv unioueto tissue No ... \nconcmml~on~, have a ihc point lhar ussuc sample from appmpnale spcc~es \nwide gmgraphlcal appl~cab~l~ly With ihe small sampltng is an impanan1 one. \nbudgets that most RWQCBs work with, the ability loaccurately bmaden the \napplifability of fish tissue sampling is a cenvdlconsideration of where to \nalloeate resources. \nDFED, Issue 4F: Interpreting Data on Trash Impacts to Water Bodies \n2.9.43.13.60.59. Support the recommended Alternative 3 \n76.38 \n109.13 Concerns about trash as apollutant not being covered in the draft Policy. \nDFED, Issue 4G: Interpreting Nutrient Data \nAgne with the recomdation. Alternative 3 is OK, but Alternative 2 should \nbe substituted when RTAWSTAG report is ready. Phosphorus is misspelled (as \nphnsphm) in a couple of places in this Section (p.82, paragraph 2 line 3 and \n0.83. oaraeranh 3 line 31. \n43.14.6060.76 39 4 10rqulre placancnl of water regmnu on a Polluwt Crc3ie a new d~emal~ve \nldcnlificauon 1.1~1 and not ihc303(d) Lirl kfom RTAWSTRTAG cnlena have Comment acknowledged. NO \nThe Draft FEDaddresses trash as a pollutant. Please refer to Policy sections \n4.7.2.3.1.7, and 3.1.7.2. Please also refer toDrafl FE!J Issue 4F: Intqreting \nData on TrashImpacts toWater Bodies. No \nAlternative 3 is written in such a way that once Ule RTAGISTRAG nutrimt \ncriteria is developed it can be used. Phosphorus misspellings havebem \ncorrected. Yes \nAllcrnatlvc 3 provides gudulce upon whrch lo base nutncnl lialngs in lieu of No \nthe RTAWSTRTAG mileria. The conccpt of a Polluuan ldenufication List. 2.10 COMMENT SUMMARY OF COMMENT \nNUMBER \nbeen established. \n51.108. 51.IO5, \t Agreewith the overall appmach of Altmative 3. In particular, suppan the \n51.107,51.106 \t following '...RWQCBs shoulduse models, scientific lituature, data \ncomparisons, to historical values or to similar but unimpacted streamr, Basin \nPlan objectives, or other SCi~tifically defensible mthods to demonstrate that \nnutrients are to blame forthe obxlved impacts.' However, rhe draft Policy \nseem to contradict his rsommdation bv stricUv muirine the use of .. -\nnummic guldcl~nes that meet the quireme of Srmon 6 2 3 in conjunction \nwith the binom~al model. %lion 31.71 of the draA Polkcy slam that '[Om \nexcessive algae growth. unnatural foam odor, and taste, acceptable nutrient- \nrelated evaluation guidelines areexceeded as described in section 3.1.1: \nSection 3.1.1. specifies listing requirements when numeric water quality \nobjectives are exceeded (specifically, the use of the binomial model), and \nSection 6.2.3 requires the use of numeric guidelines for narrative objectives. \n5 1109.5 1.110 \t To assess oulrient-related impaimnu. ux of a reference ryslm appmrh ~sa \nquanlllalne method lhal 8s sc~cntifically round and rechnlcally delenslble Tlis \napproach is consistent with Alternative 3 in the FED. Therefore, we urge \nSWRCB to: \nRemove the Ianguagc in Sccuon 3 1.7.1 of the draft Policy that is numea. \nrelaled and add in language fmm the ED AllemaUvc 3, ~ncluding the \nlollamng: \"RWQCBs should use mdelr. scientific lilcnture. data comparisons \nto historical values or to similar but unimpacted sueams, Basin Plan objectives, \nor other scientifically defensible methods to demonstrate that nutrients are to \nblame for the observed impacts.\" \nEmphasire the use of a reference system approach for identifying impairments \nrelated to nutrients and algae as a defensible and technically-sound appmach. \nDelete the language in the FED Issue 40 regarding the use of nutrient ratios, \nsince there is no scientific bases for determine nutrient limitation in freshwater \nsystems based on nutrient ratios alone \nAlternative 2 is the preferred option. In lieu of Our, Alternative 3 is acceptable \nwith some caveats: \n-Models for nutrients have drawbacks (e.g., aerial deposition). \n-Guidance is needed for how to work with aerial deposition of nitrates and \nB-31 RESPONSE \t REVISION \nMonitoring List, or Planning List has been msidered and is addressed in \nrapanrer dated to the List Shucture. The suunure of the list has been \noarrowed to two categories: a water quality L~mifed wgmnt and those Mlgs \nnot meeting smdads where the attainmmt pmblm is beingaddRssed \nWaters withwt adequate infomation or Out are clean would be acknowledged \nin the fact sheets but nojudgemnt would be madem their disposition. TWs , \ninformation will be used in the wetion M5@) repar. \nSection 3.1.7.1 is intended to reflect the applicability of madels, scientific Yes \nliteratun, data comparisons to historical values or to similar but wimpacted \nstreans, numeric Basin Plan objectives, orother scientifically defensible \nmethads to demonstrate that nutrients anto blame forthe obsmed impacts; \nthis section has been revised to suppan their use. Additionally, the welion of \nthe Palicv that desoiba an evaluation euideline amrr was nn meant to relv -\t ~~, \nexclus~vely on numc evaluation guidelina: numetic has bemdcleled fmm \nthis rstion. \nThe language ctted edin Section 3 1 7 1 has been revised as suggested. lhc Yes \ninrml of this secuon is toe~luav the wdesl posr~ble array of information \nsuppaning decisions regarding nutrients. While nuuimt ratios my not be \nuseful aloie they should be considd when evaluating nutrient &ncentrations \nin water bodies. The Policv has been revised to state: 'If lirtiae far nitmeen or ~~ \nphosphorus specifically, RWQCBS shouldemrider whether ie ratio ofkere \nluonulnents provldes an indication of whjch is the lirmting agent.' \nWhile the comment is applicable to TMDL development, it is beyond the scope No \nof the Listing Policy to pmvide detailed guidance on the impact of aerial \ndeposition. Since the appropriate method forapplying a nutrient madel may \nvary fmm site to site, it is not porrible to adequately address this subject in the 63.8 ---- COMMENT \nNUMBER SUMMARY OF COMMENT RESPONSE REVISION \nammonia. \n-Along with those facmn, pH and ternpaam must be ionsidered. FED. It will Likely be necessary to consider pH andtemperature ht the enent \nto which that is needed is kt detmnined by the chosen modeL \nWeight of evidenfe should also be required. \nDFED, Issue 4H: Impacts of Invasive Species on Water Quality \n2.11,60.61.76.40 \t Suppm thereconmended Alternative 3. Support USEPA's mation that a \npollution list would be an appmpriate place for water bodies Listed for invasive \nswcies. \n~~ ~~-p~- ~ \n13.2 \t Suppon timely adoption of the pmpmed Policy in order to pmmate therapid \nmvery of impaired water bodies by focusing resow effectively on warn \nbodies where they areneeded \n43.15 \t Agree with the staff-mmmended alternative 3. Suggest that water bodies \npreviously listed for inwive species should go to a pollution lirt. \n51 23. 108 6 \t Lhsape wth the pmpos~uon lhal only those waters lmpahrcd by pollumu' \nshall be ltrted Water bodta that am inpared. mgudlar of the source of \npolluuon. must be lrrlcd Swongly dIwgne wth the FED'S ncomendallan \nthat waters impaired by invasive species not be listed because invasive species \narenot 'pollutants.' lnwrive species cleady fit Uledefinition of 'pollutant' under \nCWA section 502f6l. Coum have intermeted the definition of 'wllutant' \nexpanslvtly, statlng that 11 'acomparr rubrtancw no1 spec~fically en-led \nbul subsumed unda the bmad genenc tern' l~rled in Sffuon 502(6) In the \ndefmition of pollutant the term biological materials' has been interpreted by \nUSEPA and the coum to include harmful organisms, which would include \ninvasive soecies. For wamole. in nmaosine revisions to the TMDL rermlatians. ., -\t -\nUSEPA stated that 'all mcmbtal contarmnanu that may be dtrcharged to watcn \nof the U S (e g. bactma. vtruwr and other organisms, fall under the rcm \n'b!olog~cal malenals\" USEPA'r findtng rsconsrrlmt wlh a common smse \ninterp&tion of the term biological materials\" as including organisms, and \nmakes no artificial distinctions as to the location or source of Iheoreanism.-\nUSEPA r~mlarly has acknowlcdgcd that diffmt bioloacal organisms. such as \nbacms (e.g.. fml col~form). algae. dead fish,live fish. fish wnw~ns. and plant \nmaterials have been considered pollutants under Ihisdefinition by Mliour \ncourts.' Waters proposed for listing for invasive species will be acknowledged in fact No \nsheets but no judgemmt will be made an their dirpmition. This information \nwill be useful in thedeveloomnt of the senion 305fi) mvnt \nComment acknowledged. \nComment acknowledged \nCWA sen~on 502(6) defintuon includes 'blologtcal malenals'as a pollutant No \nHowever, although some couns have delemuned that rome b~olog~cal malcnals \n(bactcna, algae. dead firh, lrvc firh. fish rmns.and plant mamals) m \npollutanu (Draf~ Repon: Aquatic Nuisance Species in Ballast Water \nDischarges: Issues and Options dated September 2001). USEPA has not yet \ndetermined whether all aauatic nuisance s~ecies areoollutanu. USEPA \nlherefore cunmlly belrcves that lmpacu fromtnvaslve spec~es should no1 be \n~ncludedon the 303(d) Ins1 Dunng the 1998 303(d) lhsung pmes the San \nFranc~wo Bay RWQCB lrsvd the San Francrsco Bay for rmpacls due lo \ninvasive species. USEPA did not disapprove Ulislisting butstated that neither \nthe state or USEPA had Ule obligation under cum1 federal regulation to \ndevelop aTMDL to ad& theproblem \nIn uWIZ, USEPA added several water body-pollutant combinations to the \nState's adopted section 303(d) list. USEPA did not find IhaIinwive species \nshould be added to the section 303fdl list. Ihe infomatian omvided reeardins . . \t -\nCaulmpa lax~folia dld not 1ndIca1e lo USEPA lhat Ihis mvas~vespcria w3sa \npollutanl ortht walerqual~ry standards were exceeded. \nFurthmre, beyond issues of current federal regulation and associated \nregulatory definitions, implementation of a TMDls may not be the most \nefficient or appmpriate way to address thistype of biological problem This is \na namral biological pmcess wacetbated by human activities where naml \nbialoglcal entities aretranslocated from one sosystem Io another. When an \ninvaduced species becomes inwive Ihey eanaffect some specific designated \nbeneficial uses of water but mst documnted impacu to beneficial uses due to \ndegraded water quality arenot caused by invasive speeies. lnvasive species COMMENT SUMMARY OF COMMENT \nNUMBER \nDFED, Issue 5A: Interpreting Health Advisories \n2.12 \t FTefer Alternative 2 for DFU), Issue SA, unless Ulehealth advisory canbe \nshown to be a one shot deal (accident. act of Gad.etc.). \nDFED, Issue 5B: Interpreting Data Related to Nuisance \n2.13 \t Am with the recommendation DFED. Issue 58. \n43. I7 \t Conmaulate the SWRCB because durine-the2M)Z listine omcess. water -\t -. \nregmenu wcrc not recommended for placement on the rmuan 303(d) llrl for \nnuisance condllnons relalrrl to assessmu of color, odor. cxcess~ve algar, and \nstum \nMany legacy listings related to nuisance remain on thelist because Uley were \ncanied forward from previous listings. These should be delisted and placed on \neither a pollution list ar a pollutant identification lisr Waters should not be \nplaced on the 303(d) list unless pollumtr. identified aresuitable for calculation. \nSuitability far calculation is a benefit of listing based on numeric watm quality \ncriteria. Agree with rhe staff-recommended altanative 3. \n51.111 \t Many of thehellutanu charactaired as \"nuisancs\" mav oose serious threats to .. \naqruuc hab~kl. mauon, fishng. and other imponan1 bmcficial uses. The \nFED rccommmdcd a nuisance rule th~twould use both quaotira\"ve and \nqlwlllauve rnfumtion The policy should contain a pmcedure that allour both \nquantitative and qualitative data and information in the evaluation of nuisance. \nAccording to theFED: When qualitative information is combined with \nquantitative data related to pollutants, such as excessive nuuients, multiple lines \nof evidence provide smng suppon for placement on the section 303(d) list.' \n51.113 Other types of nuisance conditions, including taste, color, oil, sheen, turbidity, \nW litter. trash and odor- when lheyare nat related to nuhents -may be Listed \nW when 'there is a significant nuisance condition when compared to reference \nconditions.' We suppon the use of refaence condition appmaches in evaluation U \nRESPONSE \t REVISION \ncanprevent indigenous organism fmm maintaining a 'balanced indigmous \npopulation' but this impan is not theresult of a water quality paramererbdng \naffected. A TMDLawmpu to restmdemaded beaeficial usesof waters by \nreduane wllumt load aAunu from different into rsdvine wat.&. If \ntheint&t'ir lo prevent funha inuoducuons of self pmpgahg c&im or \nto stop invoduecd %pi& horn hming invdsivg h it doe msean \nappropriate to allow a predetamined load of noaindigenous organisms to be \ndischarged by human activities into receiving waters. \nCommmt acknowledged \nComment acknowledeed. \t No \nSeveral listines \" on the eumnt section 303(d> list would not ~., be olaced on rhe No \n~ ~~ ~~ ~ ~~~~ ~~~ ~ ~ \nlfrt under the provisions of the pmparcd Policy. If the wars hody no longer \nrausfia the requirements to be l~rted for nusancc cond~tions lhcsc l~stings \nshould be &ved. \nThe Policv has been revised to reauire the use of both aualitative and Yes \nquantitati;r infomuon. \nThe Policy has been revised to include the use of reference condition Yes \nappmaches for these parameters. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nof these paranmar, and we request that this provision be expanded to include \nnutrients and nuuient-related nuisance conditions. However. other aualitative \nappmachn may be useful in assessing nuisance condinons as well. which Ule \ndraft Pol~cydas not appear to pmvlde far iheuse oC The draft Poltcy should \nbe modified to explicitly pmvide for the use of other scientifically-baed, \naualitauve avvmcha. \n60.64 \t Suvm m-nded Alternative 3. Comment acknowledzed. No -\nDFED, Issue 5C:Interpreting Toxicity Data \n40.112 \t Tables 5 and 6 must be updated with these fallowing methods to be consistent The FED has been revised to include this information Yes \nwithCFRPan 136. \n-4thedition fmhwter shon-term test methods (USEF'A 2002a) \n-5th edition freshwater and marine acute mt mahods OJSEF'A 2002b) \n-3rd edition marine and estuarine shon-lam test methods (USEF'A 2002~) \n40.113 \t Under the discussion of toxicity test methods, Ihe text needs to be clarified Ihat The FED has been revised to incaporate lhir change. Yes \nthe ambient water tests ancompared to eik standard conlml waters or \nuncontaminated receiving wter as specified in the testing manuals whereas the \nsediment tests are compand to a reference condition. \n40 114 \t Reword the senlence on page 103. Cunmtly no rxnglc taxtc!ly test can The tED has ken rcvlscd lo meopntc Uur change Yes \nadcqwtely characlmze lhc lox~c~ly ' polluLvlls may cause in mln or scdtrncnl \nChange to testing wth multiple test species of fish, invertebrates and plant \nspecies is impoltant as no one test species is most sensitive to all toxicants all \nthe time (see Daee 59 of rheTSD). \n40.115 \t Unda the discusion of assessing significant toxicity, the 2nd paragraph is an Calculation of the percent MSD is not neessary for measurements of toxicity No \navoroach for the sediment testine scenario. However. for ambient toxicitv (see on ambient waters. The oercent MSD is calculated mine a dilution series test \nUSEPA 2MM section 6.4). shouid mommend a pcre;nr MSD (PMSD) td The MSD is more appropnale for arnbtml water loxtcily usung because the \nminimize withm-Iesl vsnablllty (Denlon cl al.. 2003) As staled on page 108. results ofan arnb~cnl mla ramplcir compared direclly toa wference or \n'The MSD considers lab variation only and is specifif to each toxicity test conlml water. \npmtocol.\" lhe MSD pmvides an indication of &in-test variability and \nsmaller values of MSD areassociated with increased wwerto detect a toxic \neffect (Dcnton ct al ,2003) lkmumum s~gn~firant difference (MSD) \nrcpresens the SmzllrJl &ffc-rmcc bctwwn lhe conlml man and 3 trealmnt \nmean that leads to the statistical rejection of the null hypot~s (i.e., no \ntoxicity) at each concentration of the loxicity test dilution series. \n40.116 \t Denton and Nmaez 1996 is ciled as finding Ulat toxicity measurements should 'Ilir statement har, been removed from IheFED. Yes \nW \tbe obrained quarterly, for three years, to pmvide a good basis of health of the \nsystem this sentence is taken out of context and ngds to be clarified.\nW COMMENT SUMMARY OF COMMENT \nNUMBER \n40.117 \t The section on persistence of toxicity needs to be rewritten to be accurate. \nPenistence of toxicity is typically examining whethera sample is persistent on \ntheday of collection (baseline toxicity)compd to thesample being re-tested \ndays later after being stored What is needed is asssing themagnitude and \nfrequency of toxicity. We disagree a higher false acceptance (alpha error) is \nnm acceptable and appropriate for toxicity. The alpha enw must be set at rhe \nsmified level as discussed in the toxicitv testins manuals of aloha emr late of \n6.05. If any, regulatms should be concerhed wi& the beta that is not \ndemting toxicity whm toxicity is pent (USEPA, ZWO). \n51.91 \t At its most basic level, Ihetoxicity seetion of the policy is inconsistent with \nexisting Basin Plan standards, which add- toxicity by requiring 'no toricr in \ntoxic amounts.' The rection should be revised to be consistent with the Basin \nPlans. \n51.92 \t The draft Policy should require the use of lower effects level Sediment Quality \nGuidelines in addition to the 50% median level currently required when \nanalyzing sediment toxicity for causative pollutants. \nThe restriction of using only SQGs that cordate with observing effens in 50% \normre of the samples is far ~o restrictive forevaluation of all contaminated \nsediments Ulrouehout the State. The imncire ~redictive -\t ca~acitv.of SOGs . \nclled as lhe reason the pollcy is rertnctlve 1% exaclly why 11 s lmpwuvc Ihat the \nKWQCBr alro cons~derrd SQGr that reprcrent lawn taxtctly pmbabtl~llu in \nlhelr analys~s of causauve pollutants Lower effects levcl SQGs ~ndtcae that \ntoxicity was observed in numerous species, based on rigorous scientific and \nstatistical analysis. For example, NOAA's 'Effects Range bd (ERL) values \nwere calculated based on abservine toxicitv in 10% of all test roeeies -\nrepresenled in a nal~onwde database Accord~ng lo he researchers who \ndeveloped ihe ERUERM approach. concmtrauons ahove Ihc ERLr nnhcate \npossible toxicity. Since exceedances of lower effect SQGs such as ERLs \nre~resent statisticallv sienificant toxicitv observed in a Dercentaee of swies. \ncic&dulrcs of low& eiect SWs shouid he e~sldaed as one ine olevldence \nm he analysls of caurauvr pollutantr \nThere are numerous situationsin which restricted analysis of sediment toxicity \nto only ERMequivalent SQGs could result in a failun to identify the pollutants \ncansine the toxieiw. For examole. in situations where the sediment contains -\nmany d~ffennl pollutants (wh~d 1% oflrn hecase for sediment). tf mulllple \npollutants exceed lower effects lcvclr. tt is hghly llkcly thcsc polluunts \ncollectively areconuibuting to the toxicity, even if ERMs arenot exceeded in \nfact, SWRCB acknowledges that SQGr are most predictive of toxicity if several \nvalues are exceeded. bwer effect levels shwld also be considered if the \ntox~c~ly particularly wnsll~ve lo benthic is hcmg obscrved in spccles Ihat am \nconrarmnalton, or for walcr W~es wh rpec~sl specln olconccm For RESPONSE \t REVISION \nThe Policy has been mse to clarify persistence in warn versus scdimeaL Ya \nThe provisions of the policy allows a listing for toxicity if then is toxicity No \nalone or if there is toxicity with associated concenhdfions of pollutants at levels \nthat cause or conuibute to toxicity in the warn body. This decision rule is \nconsistent with toxicitv obiectives in the Basin Plans. \nERL andTELr. are not highly or moderatdy cdated wiIh biological effects No \nin sediments. Only a small ponion of the studies available show effects at \nthese chemical caneenhations in sediments. The likelihd of biological \neffects is low at the ERLr and lEh. No evidence is prided by conunenrn \nthat synergistic effects of multiple low level chemical coneenhations cause \nhigh levels of toxicity. If multiple ERMs, for exaqle, are exceeded it is much \nmore likelv Ihat toxicitv will be observed. -- COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nexample, the pmpd ERM-based listing policy would allow sediments tonic to \nghinderms (often the most sensitive category of marine organism) without \nlisting the sediments as impaired, thereby accepting this degraded condition. \nWe therefore urge SWRCB to quire consideration in draft Policy Section 6.2.3 \nof exGxdances of lawereffgts level SQOS including NOAA's ERLF and \nRonda's thrahold effects level m), in addition to thehigher effms-level \nSQOs, for identification of pollutants causing sediment toxicity, and revise the \nlanguage in lsrue 5Cof Ihe FED accordingly. \nLn many mpts the local 1998 and ZOO2 IOl(d) l~sting pmcnses appeared to Canmmt acknowledged. \nborder on ihecapriciaus, due mpollulant lisongs that were unidentified \n(toxicity), Ihe canmction and demolition of new lists (watch), wholesale \nlistings and delirtingr based on scant or dubiws data. and consemative water \nuualitv obiectives texmlated CTR standards). The final Policv document \n&ould aile much of the confu~on thal clouiwhat should be auanspmncy \nregulatory pmers, Ihercby allowlng municipal agencies lo roncmmtc on the \nmost significant and achievable water quality issues \n61 9 \t Am ulth Ihc rhonee of Allematrvcs 2 and 3 m eonem. However, ihe cause of Comment acknowledged \nlox~cxly should berapndly tdmufied in order for the problemto be solved \n64.17 \t Disagree that fewer exwedances are acceptable to suppat a listing for toxicity. Comment acknowledged. No \n77.10 \t Four approaches are listed Ulat may be used to determine which pollutants are The FEDhasbeen revised to remove the fwnh section and to rely an the TIES, Yes \nresponsible for observed toxicity. A lengthy discussion is pmvided for the fist sediment guidelines, or cnrelations to establish association between pollutants \n2 approaches IJE and SQO). a brief discussion is omvided fa thethird and toxicitv or other imam on omisms. . . \n(correlations). but no text is omvided emlainine -Ule faunh (measures of \nloxlcologlcal rcsponsc) Explanatory lext s needrd for llur appmach smec \n'mcasms of toxlcolog8cal response's parucularly rryptlc Also, a lox~cjly un~t \nanalysis can be used to establish pmbable causality, but I am not sure this is \namonz the list of 4 a~~maehes \n pmvided. \n77.11 \t Table I1 does not indicate the literaturerouree for the'othersediment quality The FED has been revised to include the so- of Ihi;information. Yes \nguidelines' given fa lindane and total PAH. \n77.12 \t This Issue states 'EqPs were developed fa no\"-ionic chemicals and metals'. The FED has been revised to comet the statement. Yes \nThis is simlv wrone. The &P amroach is totallv unsuitable fa metals. .. -. \t.. ... .-\nDFED, lssue 5D: Interpreting Sedimentation Data \nw \nW \nP \n10 2.15 \n8.15 Agree with the recommendation. This type of pollution is so sitdeffect specific Comment acknowledged. \nthat a case-bycase consideration is bwer. \nAdopt a policy that pmvides that river systems will not be listed for sediment Comment acknowledged. \nB-36 No \nNo COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \ninmairment unless there is Quantitative scientific evidence that clearlv and \ncokncindv show that thcsediment conditions in the subiect river& bevond\n -, \nthe nngeof mtunlly ffcumng mdruans Exnrung poltcna \nhave mulled m nvm wth nalurally hgh sed~-I loads lo be lrrted on bc \nbasis that sediment is impairing salmonid repmductian even while these riven \nan~mducins salmonidsat what areconsid& record levels. Where \npopulations iave evolved under heavy sedimentcoaditions, they have adapted, \nand touy to fir suchnaNd conditions is a waste of public \nand private resources. \n8.16 \t Support Alternative 2 instead of Alternative 1under sedimentation. Specific Comment acknowledged. No \nguidance should be used in an effort to avoid unnecmq listings. Spific \nateria may not be applicable throughout Ule state, however, the criteria must \nconsiderld conditions. \n8.17.8.19, 110.6 \t In the DED, page 119, a mean based on a population of 60 mot be Thestudies were included to pmvide examples of what the RWQCBs have Yes \naveraged with a mean based on a population of one. Even if the studies were done in regard to sedimentation TMDh in the past. Tbincmren information \ncomparable, an assumption that may not be valid, the avenge that should be has been removed fmm the FED. \nused would be very nearto 21, not 15. Had this metric bpn subjected to public \nnotiec and hearing, it is likely an appmpriate number would have be\" used, \nand petbaps some water bcdier would not have been unnecessarily listed. \n-\n8.23 \t If the understanding of sediments and it's effects onaquatic life is poor, a policy Comment acknowledged. No \nshould not be adopted that leaves listing to bureaucratic discretion other than \nscience. Necessary scientific effons should be taken in order to make the \nappmpriate decisions. \n10.16, 106.2 \t Timber and agricultural pmponents do not like the sediment science Comment acknowledged. No \n(thresholds) used [in the 2002 listing pmessl. This is because they do not like \nthe cost in money to correct and fix problems. The science that was used was \nmore than sufficient -with use of multiple lines of evidence (with biolagie and \nfunction impairment scientific references) and best pmfessional judgment. \nThere was not a lot of evidence onsediment mrmiforine in all thefiles of the -\nInsled nven But. the multtplc bncs of evldenccand soenlsfic \nd~scuss~on\n supported the Itrungs Now, almost 10 yean later and wth mon \nsediment monitoring and assessment, the monitoring data and science metadata \nTimber Harvesting Plans Ws) \n(Coast Case ReeiomNorth Coast Riven) in anv sediment listed watershed. \n~ ~ -\t . . \nthe rvldcncccan be in almost any IHP that lhe watercowsand major \ndrainagesam suffmng fmm ongoing rmpactr (dimnt armmulation, lass of \nhabitat, pool filling) fmm histnie and near-rkent timber harvst mrationr. \n~p \n13.11 \t Bedmsrian and Custis (2002) concluded that natwdJbackgmund rates of The requkted change is tm vague to be easily implemeatable. HOWV~T. the No \nsedimentation far Nonh Coast watersheds range fmm 300 to 3000 tonslsquare public process required by the Policy will bring out those dtuatioas when \nmilelyear in Franciscan terrain. This wide range in sdi-t inappropriate extrapolations nmethodsanpmposed. While the Policy -1 fact, if one wae to review In is huge. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \ngenmuon rakes 11 vay &ffieult to bake absolute valuer fmm pecr renewed pmnda RWQCBr significant flexibilty in selection of redimtation \npaps in oncarca and extrapolate thcm loanothrr area In adopting the guidelina, the guidcltns uwd must be justified m fact she=. \npmpnsed policy, the SWRCB should state that it is not the intent of the Board \nthat inappmpriate exwpolatioar orinappmpriate methads be used in \nfomlatin~ sediment uualitv widelines \n43.19.60.66 \t Staff-recommended Alternative 1 seems reasonable. Given the complexity and Commmt acknowledged \nvariabilitv of dimtation. eeneral euidelkmes are amrooriare.\n .---..-. .. .. .. . ..-\nDFED, Issue 5E: Interpreting Temperature Water Quality Objectives \nAgree with the recommendation for DFED. Flexibility is needed to deal with Comment acknowledged. \ncase-bycase specificity. \nCancemed with the evalnatiw of temperature data, in most cases, the input of Comment acknowledged. \nlhemal energy to water is not the rsult of human activity, cannot be conlmlled \nand should not be considered a pollutant unless anificially heated water is being \ndixharged into the State's waters. Despite these concerns, it is recognized that it \nis impmsible to determine whek mst water bodies are affected by \ntemxmture wllution because there exists no evidence of the historic \nrcmpcnturcs lhr rams rmour doubts as to the valldlly of a !,sung based on \ntemperatun Ewn so, if the Pollcy is gorng to use cvaluatron of bendicral user \nto determine thermal pollution. the adapted Policy should establish numuie \nobjectives bared on application of ri&tific, peer reviewed research that \nconsiders the differences in temeratura based on drainaee ana. swam size-\ngeographc locat,on. cl~mauc con&ttons. elevauon and other relevant factors \nNummc cntma must be based on an undcntandtng of the needs of argmtrms \nthat have evolved in the climates where we intend to regulate. The costs of \nlisting should nat burden this state bared an inferen- and assumption about \nhaw cool the water in California used to be. \np--~~~\n ~ ~ ~ \n43.20.60.68. \t In most circumstances, natural receiving water tm~erature is not defined. The Basin Plans identify watm where wateruuatiw obistives for temoerarun NO \n60 67.76 44 \t warn tcmpmm of smms vanes Also, id control channels should apply. In nnually ill mm.'hstonc' or . \nnatural' .. \ntempmture baeigmund data \nnor be sub)ffl lo a vmpmture requrremmL Concerned about what ran of mnot avatlablc Altcmattve appmaeha am pmposed lo make sure potenual \nwaterbody Ihis would apply to; it should not apply to intermittent sarams, impacts of increased water temperatun anaddressed in thePolicy. It is tw \neffluent-dominated watm, or flmd conlml channds. limiting to require that a specific, presumably point so- wuld have to be \nidentified before lirtine could mu. Nonwint sources mav cause OT -\nAll~rrecomnmnded alrcmauve 2 to state that a waterscggmnt may only be conlnbule lo trmpmlure-related lmpacrs The tdenufiwuon of watacyahty \nplaced on he 303td) Itst if a spstfic th& d~seharge is ~denufied If no l~mlcd segments is not bascd on the source of the pollutant but rarhcr on \nspecific thermal discharge is identified, a water segment may be place on a whether water quality slandards are attained in the water body \nPollution List\nW \nW 51.89 \t The listing factors in thedraft guidance should be revised to include the The recommended decision rule provides an appmach that appevs to Yes \nfollowing statistical decision rule for tempmatun and dissolved oxygen: conwdict Basin Plan water quality objectives for temperature. mePolicy is \nh) 8-38P COMMENT \n63.10 \nW SUMMARY OF COMMENT \nOrdinarily, water segments shall be placed on the section 303(d) list when \nnumeric waterqualjty objectives for te-lure and dissolved oxygen are \nexceeded in more than one sevw4ay ayaeerge of daily maximum (for \ntemperature) M minimum (for dissolved oxygen) measurements. \nTempaNm and dissolved oxygen vary on an annualcycle, and me \nimpairment only when there is tm much or taa little in the water. Water quality \nstandards are desiened to address the hishest IemDeratures of the vex and the \nlowest dissolved axwen levels of the v&. which'senerallv occurdurinz ,- \" -\nrumnu monh.or sometunes faU mnths for dssrolved oxygm llmfne, any \nassessment dsnrtons should be based on the h~ghesl and Iowa1 muremu \nof thse pollutants, nrpstively. When continuous monitoring data an \navailable, the sevenday average of daily maximum (for tempature) or \nminimum (for dissolved oxvm),-murements should be assessed. When \nrontrnuous mon~lonngdata anot avalable, but dataam awlable fmm at least \nrevcn days in any 30day pmod, theaverage of the hghest (far lcmperature) or \nlowest (fordissolved oxygen) measuremmt on sew consecutive days on which \nmunments were taken should be assessed. \nSomtimcs. thc data available for a watcr segmenl w+ll be inadequate to \npm@) cvalune temperalum and dssolvcd oxygen under lhir appmach. When \ndata are available fmm fewer than seven days in any 30-day period, the highest \n(for temperam) or lowest (far dissolved oxygen) single measmt within \nthat ~eriodshould be assessed. A water seement should be olaced on the 3031d) . . -Itu for temperature or dtsxllved oxygm when these dam show a vlolaton of the \nwster quahry standard on 31 leas1 one day in at least three d~ffncnl ywri \nUnder Ihe water quality standards, a measurement of temperatun (or other \noollutant) in ex-of a standard is not a violation of the standard if the \ncxceedance results from nalual condhttons in the case of ~empenture and \ndluolved oxygen, when natural condlrtons nceed the nandard, l~songs wtll bc \nbased upon human confributions in excerr of natural backgmund. All relevant \nnaNral conditions issues relating to temperalure and dissolved oxygen for which \ndata or other evidence areavailable. such as veak hourlv termeralure increases . . \nand exuem ar lcmperatures should be consldmd The hollerr day or y-\nshould no1 autamaucally exempt a watm rcgmrnt fmm conrrdemoon for Itrung \nbased on temperalure. \nTemperature varies with theshallow naNre of Southem Califamia streams that \nmay have nothing lodo with discharges, but anihe natural condition of arroyo \ntype systems. This natural condition could result in enoneow exceedances, and \ndefine a critical condition. Please considR omvidine soecific midance on the u. \n-\ntopic of IcmpcraNn in dry sueam, for routhem Cal~fomna rum thal havr \nlou flows naturally st emln lrmer of the year and in confl~nulth the cnltcd RESPONSE REVISION \nnot intended to address revision of any water quality standard but, rather, to \ninterpret the smdardr as they arepresented in Basin Plans, statewide Plans, \nand regulatioa \nThe RWQCB Basm Plans water qwl~tyoblecuves for tempmNrc and \ndlrsolved oxygen should be d ThePol~cy pmwda adbumal gutdance lo \nthe implementation section to asses impacls on bmeficial nser related to \nincreased water temperature. Thissection compliments the Basin Flan \nobjectives and provides an appmach thatmay be mm svaightfonvard to \ndocument than exceedance of wat~ quality cbjectiva based oa background \ntemperature conditions \nRevisions have been made to the Policy to incorporate thesuggested appmach \nfor using the minimum dissolved oxygen conditions. The use of the 7-day \naverage for temperature is incorporated in the MWAT appmach hdy \nincluded in the Policy. Using Ulis averaging period when allowed by the \nstandards, helps to makethe measurements moreindependent. The suggested \nrule for small data setsconflicts with the intent of balancing errors dseribed in \nthe response to comments rZlated to statistid testing and, therefore, has not \nbeen used. \nThesuggested changes- to be focused on changing water quality No \nobjectives for temperahlre to better address intermittent or shallow water \nconditions present in many southem California streams. Modifying M \ndevelooine new water oualitv standards is bevond Ule seaaeof theListine . . , -\nPolsq COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nconditions. lo gd, Basin Plans describe allowable chanpes in water te--re. For \nexample, theLos Angeles RWQCB Basin Plan \\Mta quality objective for \ntempenture stam 'heaaaual recdving water leqwmm of all regional \nwaters shall not be altd unless it can be demonsuated to the ratisfaction of \nUle Reeional Board that such alteration in tenmeratwe dm not adverselv -\naffect bmeficral uses Altcrauons that areall04 must ma hereqlurmmnts,' \nm the Bun Plan. Thekey prowston that must beevaluated by RWQCB u \nwhat is considered to be natural receiving water leqwmm Since low flow \ncondttlons areso prevalent, these must be considered by RWQCBs. \nDFED, Issue 5F: Interpreting Data Related to Adverse Biological Response \n2.17 \t Agree with the recommendation. This is too complex for use of a simplified \napproach. \n43.21. W.69. \t In 2WZ. listings for adverse bioloaical resmnses were not reco-ded. These \nW.70.76.45 \t should be an &other Ihrt. Wala balm shbuld not be lrsled for a eondltion \nwithout idenuficat~on of a polluwL Advme b~olog~cal response may be an \nlndlcatton that there is a prohlcm but the pollutant is not ~dent~Ged. \nDisagree with the staff-recommended altanative I. A Pollutant Identification \nList is the appmpriate list for water segments for which no pollutant has been \nidentified \n51 164 \t IhePollcy dacs allow the uxof a rcfcmce system approach for evaluation of \nadverse b~alagtcal response (Snt~on 3 1 81 Thts type of appmch, along with \nother scientifically-accepted methodologier should be allowed by the draft \npolicy for consideration of listing related to sedimentation and degradation of \nbiological populations and communities, in addition to adverse biological \nresponse. \n56.22 \t Sunwn the muinmen1 to assess multinle lines of evidence for this listine .. \t -\nfaclor, and urge the SWRCB to exercise caution whm evaluating advme \nbiological mpse, because. as acknowledged in the drah FED.Iherc types of \ndata aretypically water body-specific: often arenot collected using standard \npmctdures: areusually the result of research projects: and arenot pm of major \nambient monitoring pmgrams.' \n63.11 \tThePolin, does not take a sound scientific avrrroach tothe issue of Internretina . -\nData elated to Adverse Biological ~esponr; TheSWRCB should adopt \nAltemativeZ. Specific guidance and evaluatim twls tointerpret this data an \nneeded. Comment acknowledged \t No \nThe Policv does not ilow listins related to this factorunlss the wllutant is No \nidentified: The gend gu~dan; recommended for interpmung b;alogical \nrcsponx qulra the compxison endpoints to refernee cmdiuons, the \nidentification of pollutants suspected ofcsusing acoombuting totheadvmc \nresponse, and to associate the pollutant with an adverseresponse. \nThe draft Pallcy and FED has been rcvlred toallow the usc of rrferencc srlem Ya \napproaches for asressmnls of b~olog~cal populauons and communtues md for \nimpacts related to sedimentation. \nComment acknawledeed. \t No \nThe data and information used to intwret adverse biological resmnse is No \ndiverse, therefore, it is very difficult t~.~rovide Many types specific &dance. \nof data and infwmatim couldbe used to determine the biological effect (e.g., \nreproduction, histopathalogy, growth, etc). If rpsifie guidance was used it \nwould eliminate potential ms of data to address and assess the impact. \nGeneral guidance provides the flexibility necessary to addm a variuy of COMMENT \nNUMBER SUMMARY OF COMMENT \n77.13 IhetiUe is awfully vague. This issue seem to be a 'calch-all' rection addressing \nresponses ranging from individual gmwth rates to carcinogens. Agreeas the text \npoints out, that with measurements of this type it is particularly impoltant lha~ \nthere be strong evidence blthe adverse effect is due to a paUumt before these \ndata are used in 303(d) listing. RESPONSE REVISION \ndmtances. \nComment acknowledged. No \nDFED, Issue 5G: Degradation of Biological Populations or Communities \n2.18 \t Agree with the recomm~ldation. \n43.22.643.71, \t Disagres with Uleretolmnended Altmative 4, as well as the other- \n76.47.76.46 \t Alternatives. While bioassssmenu ~mvide im~ortant information about water \nquality, they arc nasuN~ant for lirtrng. Thm sans of assessments should be \nused in dewloptng 30S(b)rrpons. PoUutants must be identified to jurtify lisung \non the 303(d) list. \nSdppon SWRCB's qu~rcmenr to use btoasrcrrmnt data and mfo-uon only \nrf 11 sasroclaled wth wtn and sediment nxaruremmts However. the \nassessment af water bodies based on these listing facton canstill be pmblematic \ndue to the reliance an comparison of the response or community stru;ture to \nthat of a reference condition. Althoueh. the draft FED nmvides some midance \" \non rcfcrmcc rrte wlecuon and uu,the selecuon of ~ppmpnalc rcfmnu rttrs is \ndrfficult (c g .highly urban~zed walashed), yet cnllcal lothe determ~nauon of \nimpairment \n56.2.2, M.20 \t The FED provides same guidance on selection of reference sites. Concerned \nthat: a dadnation may need to be made that a reference site represents the \nbest attainable condition. how will this be determined? Com~ariron to refemce \nsltes may be difficull because ecologically more d~ffmcocet (due to factors no1 \naccounted for) could be found as sample size in-. Co~nent acknowledged. \t No \nIheFED dm not neonmend bioassessmenl as a lone lisling factor. me FED No \nrecommends that omDmed listins wine bioassssment data need mvlti~le . . \nlrnes of evidence: association with water nsediment concenvationr of \npollutants is requird \nSclccl~on of appmpnale mfmnee sllcs is enud lo ihc dcvmunauon of No \nlllndards atlalnmcnl The t€D pravldcr only general gutdcltnes on reference \nsite selection which may pmvide assistance to Ule RWOCBE in the .. \ndevelopment of their bioassessment programs. \n\"Best attainable condition\" refm to the selection of a reference site using the No \njudgement of RWQCBs based the site-specific factors present in a water \nbody. Soecific mideline cannot be orowred beeaure of the divemitv of water . . \t . . \nbdn in the Slate. The cffeclaveness of blolqrcal mmitonng pmpms nrt \non chmring biological atwibutcr that pmvidc consirlent and reliable stpls \nabout thensource condition. A successful biological mitoring program \ndernonsmes blan amibute has a reliable empirical &tiomhip-a consistent \nquantitative change-amr a range, or gradient, of human influence. \nComparison toreference sites is dzffieult but RWQCBs can optimize their \ncomparisons by focusing on sampling design prior to the initiation of sampling \nand culminating with the use of indexes to compile and evaluate large munu \nof biological data for evaluation. Sampling design will largely be dwrmined \nbv the reeion-sosific needs of lheRWOCBs but will include a determiaation -. \nof the s~lcspelfic or polen1131 pmblcm the morutonngablecnvc. and ihc \nava~labthty. qualaly and applrcabdrty of tnfomwt~on A gmd sampltng dnlgn \nalso considers seasonal and spatial miation in the water body, sample \nrepresentativeness, and variations in magnifude, duration, and fmluency - - COMMENT SUMMARY OF COMMENT \n56.25 \t Refaence sites may be difftcult to determine because the site may be changing \nindependently fmm thetest site, due to factors other Ulan water quality, however \nit may appear Ihat the test is impaired due to the difference beween it and the \nreference. \n64.19 \t Suppats the requimnt to use bioassessment data and information only if \nassociated with water and sediment measurements. \n77.14 \t Benthic Macminvertebrate lndex discussion is ubiquitous. The text is refening \nto themaaoinvenebrdtes and not the index \n77.15 \t Allcmal~vc 4 is given a$ the prdd altmat~ve. but 11 is nor clear what \naltcmauve4 is. The t~lle of the allcmativc impher thnc has to be some linkage \nof bioassessment data with simultanarusly c~llected chemistry data, yet the; is \nnever any mention of this linkage throuehout thediscussion. &mila&. the title \nindtcales some requirement to do'arsoc~at~on assessment', but then is no funhcr \ndiscussion of Uusasswsmnl. insread. the entrre text is dedicated to hou to \nchoor a reference sue and a listing of thc type of blota that one might want to \nassess \n77.16 \t Alternative 4 discussion is an ova-emphasis on superficial primary issues on \nhow to do envimnmental assessments. I question whether this basic information \nis relevant to the question of what &fa canbe used for 303(d) listine. Wnlv \nom: would want taw braasrersmnt dam lhat includd an anppmpnate \nrefmncc snte. but does lh~r dmumcnt need to rpmd pages descnbmg how to \npick that reference rite? Il is possible to go too far in describing how to do the \nassessment, and thisdocument has done so. Its Lena could be~ub~tantiall~ \nreduced if it assumed the reader had a grater a prini understanding of \nenvimmmtal assessments or let the reader obtain such information fmmother \nsources. \nDFED. Issue 5H: Trends in Water Oualitv \n1.13,1.14,30.9, The discussion on vend analysis should be expanded to consider uends in \n57.7,202.7,212.8 meteorological conditions, such as extended dmughts or in-ing tempwture \n8-42 RESPONSE \t REVISION \nFunher, RWQCBs will selm appropriate water quality indicators based on the \nwtential fa inwarn on smific beneficial uses of water. \nThe general guidelines in the Policy should pmvide assistance in the selection No \nof reference sites. However, reference site selenion is depeadent on many site- \nspecific fanon that cannot be adequately capd in thePdicy (e.g., \nidentification of least disturbed areas). Once reference sites are selected, \nbiological surveys anneeessay to evaluate the biological inIegtity of the site. \nEstablishing the reference site condition provides the necessary infamation far \ndng comparisons and for dewling impacts mbeneficial uses. Monitoring \nof the referem site should remain a Dart of Ihe bioasressment omwm: in. -\nwh~chcaw, changes in thcbsologtcal integrity of the rcfmce sntc would be \nnoted before co~sons would be made lo test st- \nComment acknowledged. \nThe text has been revised to refer to the macroinvenebratw and not tbe index. Yes \nThe altmative failed loclearly establish thclink with lssua SC CToxicity) and Ya \nSD (Sedlmntauon). Thcsc lssues conuln the full dlxusslon of chernisw data \nin water and sedimtation. Alternative 4 has been revised to make this iink \nand discuss the immimce of assmiation assessmL \nThe information on the selection of reference site and indicator species was No \npresented to pmvide RWQCBr with a reference on environmental \nassessments. mere is not vet one environmental assessment method adooted \nm Calrfornra and many KWQCBs approach btaasscssment ulng &ff-t \nmethodology Th~s mfmuoo was presenlzd an the tntrrut of caprunng \navailable approache in one place\n~ ~ \nThese faam analready required under the data quantity assessment section No \nof the tisting Policy. Data and information to substantiate the dech of water 2.19 COMMENT SUMMARY OF COMMENT \nNUMBER \nrepi-, which may exacerbate or improve contaminant concenuations. Thae \nuenowidely accepted approaches for documenting trends, and the data is oflen \ndifficult to interpret. \nAgne with the recommendation. \n5.10.9.3. 12.10, \t Theuseof mends in waterquality as a basis for listing water segments is \n18.95. 19.11. \t opposed. The use of such a basis allows water segments to be listed in the \n21.27.29.8.39.4. \t absencc of information that water aualiw standards areexceeded or that \nbeneficial uses are impaid. \nThe muiremen1 that advme bioloeical reswnse. demdation of biolaeical \npopulat~ons or tox~c~ly is observed is too onemus because most watc~qual~ty \nmonlmnng does not tncludc these more erpms!vc and sophmeated tesls \nUnder th~s polkey, many wter bodm u~th dsllntng wter qwllty would not be \nlisted because these csis were not conducted. importantly, beriwou~d be a \ndisincentive to &om these tests or assessments. The end result of Uus wlicv ,. \nwould be a sevm lmpacl must beobserved bcfar the State candctmtnc that \nanltdcgradauon nquvrmenu ambelng nolared lhtr rr unacceptable and m \nvlolauon of the anudcgndauon requrements of the CWA and State pobcy. and \nas a result the Iquireknt that staff must '[dldetemine the mum& of \nadvme bioloeical reswnse. dewdation of bioloeical woulations and - .. \ncommun~l~cs. or lox~crty'musl bexmoved fmm the llsl of requlremnls the \nRWQCRs must mt to ltrt a wrcr body for dechnnng mnds m water qual~ty RESPONSE \t REVISION \nquality Iqui~ the application of nonstandard trend analyris appmaches to \nacmunt for such factors as seasonal or weekly systematic variations, \nautmelation of the data due to intaventions, or -ling pmcedloal \nchanges. Thwe anmany widely aceepted trend analysis appmaches available \nbut Ule use of any specific approach will depend on Uledata available for \nanalvris or rmific characteristilr aswriated with the data. Rovidine -.soedfic \nguidancc may nuaUow the use of ihc mmt rppmpiate tmd analysts \napproach. FnUur r-n only general guidancc on how to address mnds m \nwater quality hasbeen pmvided. \nComment acknowledged. \t No \nThe Policy provides general guidelines for listing waters due to declining water No \nquality. Waten that eurreaUy meet water quality standards but where a \ndeclining trend in water aualin can be substantiated should be listed when a - . . \nwcond line of evidence (eg .adverse biolog~cal raponus, degradatim of \nb~ologtcal populauons andlor rommuntties, or toxicity) suppans daennimtion \nof walcr quality impam. The Pollcy does not allow listing waten with \ndeclining water quality by itself unless thae is additional evidence showing \nthat beneficial uses of such warn arebeing impacted lBis is consistent with \nthe provisions of the federal antidegradation policy. \nWhen substantiation of a declining trend in water quality or the m d line of \nevidence cannot be established the information remains recorded in fact sheets \nbut no iudeement will be made on their diswsition. ibis infomtion will be \nuseful ince development of the section 365(b) npon. \nThe Policv muires that anv decline in water aualilv be suvwrted with data . , . \t No . . \t . \nand mfomtion eonfimjng that beneficial uxs are being impacted. A \ndeclining mnd m waterqwlity is usually caused by the gradual innease of one \nor more pollutants in the receiving warn. However, it is possible to defect an \nin-sing mend in pollutant concentration, and consequently a defline in water \noualiw. without a wateraualitv obiaive exceedance. In the absence of a water . . . .. \nquality objective exfeedance it is important that addit~onal endencc is used to \ndrnum~nt that warn quality rmpacts arc actually ocmng. 7hc substantiated \ndecline in water quality plus associated data and inf-tion penaining to \neither adverse biological response or evidence of degradation of biological \npopulations andlor cmnities help list such watas in a mon consistent, \nscientifically defensible manner. \nThe appmach proposed in the Palicy is consirtent with federal antidegradation \nrequirements. Federal antidegradation policy applies to situations where \nuistine water aualitv mav be chaneed. These siolarions indude: establishment -... -\nor rcnslon of water quahly objccuves. changes in Mler qualrty objsuve \n~mplementauon pmedlvcr. pemut and mte discharge reqw~ement dcc~stons. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nsome cleanup and abatement ordas -aI action plans, waken or \nexceptions fmm Plans, and water right decisioas. Where the antidegradation \npolicy applies, it daer not absolutely prohibit h in 1 ty. The \napplication of the policy depends on thebeditions existing in waterbcdies. \nThe antidegradation policy (40 CFR 131.12) laymt a -tiered approach \nforthemtectionofwataauali~. 7iar(40CFR 131.12faX1)~of . . \t . .. .. \nanudegndaoon mntains and pmvets eusung usaand the wata qual~ty \nneussary lo prorect there urer Tm ll'(wut~on 131 IZ(aX2)) pmvets the \nwater quality in waters whose quality is betterthan IhaInecerrary to protect \n'firhabl&wimmable' user of the waterbady. OuLstanding national resource \nwaters (ONRWs) are provided a high levei of pmt&oiunder the \nantidegradation policy (T~erW). \nThe focus of the Listing Policy provisions related to omds is focused on \ndetermining compliance with Xer I or Tier IU.In gad, SIates must assure \nomteetion of beneficial uses. infludine amtie life. Reductions in water \nquality (decltn~ng mds) should na be ailowed if thischange wouldresult in \nserious harm to any species found nalwally in the water Waler quallty must be \nmaintained at levels Ulat results in no mortalityor significant gmwh or \nrepraductive impact of resident species. If numeric water quality standards are \nmetbut there is a declining trend (the prohibited change in water quality) and \nbeneficial uses are impacted, the antidemtion portion of sfandanis is not \nmet. \nTier ll waters arenot addressed under the Listing Policy beeawe (I) no action \nor activity is being proposed that would require a finding that the lowered \nwater aualitv is necwarv to accommcdate imwmt economic or social . . \ndevelopment in the area in which the waten arelocated, (2) beneficial usesare \nnot impacted, and (3) numeric watw quality objectives anachieved. \nDFED, Issue 6: Statistical Evaluation of Numeric Water Quality Data \n1.21 \t To address inherent sample bias, a note should be added la indicate that the The FED has been revised to incorporate this change Yes \nsample population is repnsentative of the dwion being measured. \n2.20,43.23,60.73, \t Agree with therecommendation. Commnt acknowledged. No \n76.49 \n10.7, 18.4,20.10, \t Under the SWRCB's dran Policy, it will become exuemely difficult, if not The provisions of the draft Policy identifies the data and information needed to No \n20.5.21. LO, 21.14. \t immsible under the current level of fundine for water aualitv monitorine in Ule create a dble section 303(d) List. The draft Policv was not develd . . \n376.51 75.53 6. \tsil.'. to dewlop ihe necessary infomation lia waxer bodles or waterbody eons~denng theexisung lcvelr of mon&lonng cffo&available to sW~CB and \n53.20.66 2. 101.7. \t segments lhll munly ~mpatrcd -LC.. do no1 ma.1 water quality rundards. RWQCBr becaw the level of fundlng for SWAMP and other mon~tmng \n101.5. 1064,221 2 efforts flucluales from yew lo year. The requiremmts of the drafI Policy set \nthe target for the kinds and amounts of monitoring and the statistical \n844 COMMENT \nNUMBER \n13.9.51.166. \n104.7.218.4, \n218.3,218.2,218.5 \n20.4,21.8. 21.6, \n21.9.21.16,21.7, \n40.l6,40.2,40.67, SUMMARY OF COMMENT RESPONSE REVISION \n~medures that area- to ensure Ulat the dgirions mde. based on \nlnfercnees from sample data, are asaror frce aspossible lo wppm placement \nor remval of w-hom the sti ion 303(d) IisL lkse smistid tools help \ninme the confidence and power of Ule available data and infomation \nevaluated to make section 303(d) listing decisions. \nVolunteers sampled UneSan Gabriel River for contamination and found elevated Several comments focused onUle speeifie data in creek and theamounts of No \nlevels of zinc. They found 4 out of 26 samples contained zincat dangernus data available far Ulere warn. Thaecornmots arebased on theunfounded \nlevels. And zinc is a toxin. It poisons aquatic wildlife. Under the proposed oremise that the water bod\" in uuatioa is imoairaF How can the cwvnmter . . \nguidance policy, you would npd six samples of zinc erceedances to meet the how Ibis with assurance? In contrast, the pped Policy lays out a \nrrquiremmis of abinomial approach. Soagain, we have an example of a scientificallydefensible pmedure to establish if a water body isnot meeting \nwaterway that is clearly contaminated, has a lot of community investment, yet it water quality standards. 0th-valid, albdt lers preferable, alternatives are \nwould never havebeen put on the list to get cleaned up in the first place and is possible and have beendiscussed in detail in the drahFED.But until a valid \nin danger of falling off the list if the suggested revisions are implemented. procedure is applied, the conclusion that a warnbody das ordoes not met \nwafer qualify sfandads is prermNn. \nConcerning the San Gabriel River example, the dcah Policy qni~lent has \nbeen revised. At least Ulreeexceedances out of a -le of 26 needs to be seen \nin order to list the wafer body, Ulis reuukmnt is sfaGstidly valid. It ensurer \nthat on the averaee over five.owcmt df ~ossible water sanmies fmm the River \nwll exceed the uic standard'wth at l&t 80 pant confi'dcna A dcuslm \nto Inst based on a sample wth fourcxcecdanees would mt the dcrrred level of \nassurance \nThe Policy ignores water quality standards, especially with respect to toxicity SWRCB has been criticized by USEPA and others for not interpreting toxics Yes \nand the CTRtoxic pollutants. It violates USEPA regulations that require Ule WQC consistent with the expressed frequency of the criteria. Specifically; \nstate to develoo existine and readilv available data. USEPA has said 'acute and chmnic standards are not to be exceeded more than \nonce in every thee conxcuove)ear penod: SWRCR staff reviewed the \nprovisions of the CTR (40 CFR 13138(c)(Z)(iii)) md the uceedance \nfrequency is stated as: \nI. For acute criteria: %MC ... is the water uualitv criteria m ~mteclaeaiost \nacute effeeu in aquatic life and is the highkt in con&tration~f a \nprinity toxic poUum consisting of a short 1- averagenot to be exceeded \nmore than once every threeyeam on the average.' \n2. Far chronic criteria: 'CCC ...is the water uualitv criteria to Dmtm against . . -\nchron~ceffeeisin aqwtlc llfe md is the tughest in Stream concenmuon of a \npnanty toxic pollutant conssung of a 4day amgc not la be exceeded rmrc \nthan once every three years onthe average.' \nTheCTRappeam not to be expressed as a maximum not tobe exceeded value \nbut rather as an average. USEPA documentation related m be develooment of -\nthe CIR and wta qualny rtandards in general acknowledge that the \ncxcecdancc fmqumcy is 'on the avmge'(USEPA, 1999~. USEPA. 1991f: COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nUSEPA. 1994d). Guidance documents related to the don 3031d) ..IisIine \nprocers dcscnbe the frequency panion of the WQC as n mimum (USEPA, \n2W3b; USEPA. 2002a; USEPA. 1997~1. \nExwedance frequency is not amenable to averaging likecontinuwr data. \nHowever. exeeedance frenuencv can be aveneed as a ommrtim. The . . -. . \nbinomial dirtnburion woks well with thm kindsof data. The averageof a \nbinomial dismbution rs the aumbaof sanplo urn the pmpoluon of -In \nexceeding the value. To get an average of I with n= 3 (years), p has to equal \n0.33. One exceedance each year over the 3-year miod wuld be allowed. A \nwater would be listed if m& than three hitiare ;brewed during a 3-year \nperiod. \nAnotherway to int~pnt Ik'on the averagee phrase is that Ihe 'once every three \ny-on average' is bawd on the recovery time for va&ms aquatic life \norganism. TheUSEPA Tshnieal Suppan Doeument WD) (19910 describe \nthat macminvmebm may recover in lsr than two years; whenas, fish my \nrequire tw or more years to mover. \nAltanatively, once every 3-yeam on the average mightbe enended to mean \nUuee times in nine yean is acceprable, using this scenario--three exceedancer \noccur in Ihe fin1 3-y- and followed by noexceedances during the next six \nyean, thus the aquatic life has recovered sufficiently. If thescenariois \nreversed. that is three erceedancer were to occur in the most men1 years (out \nof 9). then this would be considered impaired water quality conditions at \npresent and sufficimt =son to list the waterbody. \nThus oneexceedance is allowed per 3-year period and multiple 3yearperiods \nare necessary to deternine the average. \nNeither of these intapreations are panicularly clear cut. The TSD s- to \nsav Ulat nun'e than one excursion durine the averaee ~eriod is aceenable and u. \n01; only ateraging pmod mmlioned is 3 years ir e .Appendix D (p. D-4): \nThe purpose of the average frequency of allowed cxcurrionr is to provide an \nappropriate average period of time during wfich the aquatic mmmmity can \nrecover hm the effect of the excursion....') 'Exc~~~im~seemsto \nacknowledee that more Ulanone is acceoable. Other oarts of the TSD (D.124) \" .. . \nrap that more lhvlone violation of a effluent liml is allowed on a shorn ume \nfnme: ' .EPA rscummends thal mnlNy average limitation violations be \nreviewed ... whenever two armore violations ocnv in a 6-mth period. Seven- \nday average and daily mimum violations should likewise be reviewed if a \nminimum of two or four. resomivelv. occur durine the enuse of 1 month.' \nEffluent llmtts am d~ffcmt[han WQC but it seek tmposstblc far dnuent \nlxmu to be exceeded mom frequenlly than WQC and sull be in fomplzance COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nwith a once-in-three-yearnmimum. \nlheTSD also acknowledges lhat mmt wcuntons (MU be morlnd wUbe \nd~fftc~ltto delr~~The TSDstales These dala indxcate lhat asa gad rule. \nthe purpose of theheaveraw frequency of allowed urnions wiuk achieved -.. . \nif &&U'encv is set at once em 3 vean on the awe' (Aoomdix D. D. D-. .. \n5). ~n a&ag&g frequency is no& average unless there is mae fhanone \nvalue and 'excursions' reemsto indicate that more than one excursion is needed \nFor section 303(d) listing purposes thesensible, workable. practical, and \nlogical interpretation is to use the available data collected in usually relatively \nrhon time frames(4vears) lo make decisions an whetherto lace watm on .~,~. \nthe list. Perhaps the mt clear way to resolve lhk mauer is lo uuone of the \nCALM @,dance (USWA. 2M)Za) approaches fa stausocal guidelines lo \ninterpret chmnic and acute cntma in Table4-3 of heguidance, USEPA COG acute and chmnic criteria, asscciated exceedaice frequencies, and \nexamole statistical aomches for analwine chemical data. Forthesecriteria . . . -\nUSU'A wcommendr urmg the blnomal 1st wth a 5 percent exceedma \nfrequency and a 15 prrcent cffect slue whm alpha and beta ermn arc held at 4IS Resurmbly, th~r analyslr corresponds to he USEPAdmved averaging \nfrequency for acute and chronic criteria. \nTlus appmch should he used to dclnrmnc cornpltancc wth CTRand s~rmlar \nchem~cal walerqwltly ob~ect~va The FED and Pollcy have been revised to \ninclude the CALM guidance ncommmdation regarding em balancing. The \nresponse related to balancing emn is me th&ughlypnvnted in ~srue6 of \nthe FED. \n21.67 Emphasis on developing stalirtical evaluation of data is mng. Most statistical \nmani~ulatian af water aualitv data does not orooerlv reflect how chemicals . . .. . \nIWCI aquarlc-llferclated bzncficial user of water bodies. Tox~cily is based on \na convnmtion of toxic chcrmcal fom-durauonof expmwe relationship fora \npanicular chemical and type of organism TkUSEPA national criteria and state \nstandards based on these criteria are designed to be protective in aU types of \nwaten and far most arganisms typa. Reliance on statistical inference is a valid approach to lake when dealing with \nwater aualilv samole data. Without comlete knawledee of the mterbod\" in .,. \" ~ ~ \nqucstlon. lnvesugalon mu1 rely on samples. lhs inuoducer unceday. \nOnly rtatisucal analysrs gives investigators ramequantifiahlc lcwl of \nassurance in conclusions based on samples. No \n22.3.22.1.25.3, \n38.10.44.1.47.3. Smgly supports the use of a standardized statistical approach for data analysis \nas well as a muiremen1 to clearlv document the weieht of evidence ht is -Comment acknowledged. No \nW \nW \nW 48 2.6045.63 2. \n64 6.71 23.71 19. \n71.20,71.l4,72.2, \n72.1,72.5,72.3, \n76.28 \n38.9.59.2 nwkd to Itst and de-lrn a waterbody Hlstonc l~stxngs haw at Urns bem made \nwth less than adequate documcntat~on of an actual tmpa~rment \nThe precautionary principle mentioned by other commenten dunng the Comment acknowledged. No COMMENT \t SUMMARY OF COMMENT \nhearings is an exm precaution that fails to base environmental threat or harm \non evidentiary standards or procedural criteria. \n47.5 \t The 303(d) list developed by lhefinal listing policy should only contain Wer \nsegmmts with real water quality pmblems. Rather Ulan maintaining an \nappmafh where dually 'anyuling and eveything' is placed on the TMDL list, \nremless of the technical or objective mrit for doing so, it is vital that the \nSWRCB establish a credible 'triage' approach that achieves the mt benefit for \nIhe resources dedicated. \n5 1 48. 105 4.217.5 \t The bias in the Policy is evident in evny statisueal option chosen (~nthe FED)-- \nin sclecuon of the confidence internal. the rwalled cntieal exccedance raw. 1hc \nnull hypothesis. the binomial mbhod, and minimum sample size. For all of \nth&e decisions for which an my of choices is available~the policy always \npicks the choice that will reduct tk chance of not listing unimpaired water \nbodies over the chance of failure to list impair& wata bodies. \n5 1.57.51.56.51.58 \t The FED readilv admits that the statistical method of establishine the303(d) list \nwll ~mve cumntly l~rtd wata bodtes fmm that 1st wthour any ncw \nrnformauon that dcmonsmtcs that wawr body IS not mly impatred 'Tlx \nresult~ngablndonment of TMDk and thew aucndant uasre load allowuons for \nthese p~viously listed water bodies would, or at least could potentially, result in \nan increase in massemissions of wllutanu to these water bodies over and above \nwhal would bc allowed wvh a TMDL was m place Thnr tncrcasc in cmss~ons \nrr ruffictrnt to lnggnthe sate's ant~degradauoo poltcy \n51.73 \t The methodology is virmally impossible to adrmn~sler fmm a pract~cal \npenpstive. As nawd in the NRC repwt.'uater quality rwdardr must be \nmeasurable by reamably obtainable mnitoringdata.' Data-hunw models \ncannot be the sole method by which water is assessed in situation where \nthe state lags in monitoring. The NRC Repon agrees, staling that govemmt \n'should not advocate detailed mechanistic models for TMDL development in \ndata-pmr situations. Eik simpler. possibly judgmental, models should be \nused or, preferably, data needs should be anticipated so that these situations are \navoided.' \nThedraft Pollcy appcan toassume that Caltfoma has a database of surface \nWtN qual~ty lnformauon capable of supporuog numc calcdat~on \nrequiremenu such as those set forth in thePolicy. This is not the case. \nCalifamia cutrenUy relies upon anarchy as a data management stpdtegy for \nsurface water quality informtion. Because of Ibis fan, the draft Policy as \nwritten cannot be implemented on a consistent statewide basis. \nOne step California must tahe in order to begin to implement numeric \nrequiremenm associated with a Policy of Ibis type in a defensible fashion is to \nB-48 RESPONSE \t REVISION \nComment acknowledged \nAs outllned in the FED. the rtatirtical altcmaoves pmposed are lntended to. if Yes \na! all posslblc. reduce the chance of ~ncomctly listing a warn body ihat is vuly \nmeeting water quality objectives. The second type of aw, that of failing to \nlist a &ly impaired kt& body, can be ewtmlled with larger ~ lsik, e \nlarger effect sizes, or greater type I etmr rates. The Policy has bem revised to \ninclude an appmach for balancing the statirtifal enas. \nThe Policv. as revised. would likelv result in feww lishes. However. the No \nprnnsloni of the Pollcy on the when 303(d) 11% have no effect on exsung \nprmutr Consequmlly there would be no change in drscharges rf watm were \nnot placed in the sstlon 30yd) llsr Anudepdauon nq~urcmnts apply \nind&ndently of Ihe Policy. Nothing in &~olic~ allows greater oriisf as \nemission from mint sources. Placement on the section 303(d) list does no1 \nconool or pmvrnt pollutant drseharge \nThe process dacribed in the listing Policy for summizing data and No \ninformation was implemented by SWRCB slaff dlrnng the development of the \n2002 scrtion 303(d) Inn. hnng that pmess over 1.W fact sheets were \ndeveloped using a variety of informat&. \nWork to develop a database to hold all data continues fhmugh SWAMP. \nStoring other informationhas been challenging and is continuing to be \naddressed in revisions and updates of the Om-spatial Water Body System \nA dala svstem that holds absolutelv all data and information is not nsessarv' \nfor SW<CB and RWQCRs to lmpirment the stal~sucal pruv~r~onr of the \nLtsung Polrcy Data cvaluauan can ocew on a msc by- bas13 dependmg \non the deeision mles of the policy. The NRC Mmmenl.3 on the tyw of \nmadeling to use for TMDL development annot relevant to the &cepu \npresented in the Listing Policy which is focused exclusively on the \ndevelopment of Ihe section 303(d) list. - - \n- - COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nfallow the lead of otha states that uultzt the USEPA SlDRtT walcr quality \ndata managcmnt system. SWAMP is movlng forward to tmplrmcnt SlURET \ncompatibility, but Ihis will solve only a portion of the problem: benw \nintegration of othaawilable data will be necsrarybefae the state can begin to \neven unridw a statistical methodoloev as data-hunw as the one oromsed. \n~ ~ ~~ \nIhestatistical methods identified in the draft Policv an~robablv the most Comments acknawledeed . . \nrmpoml asp1 of Uur document They have the potmual loel~rmnatc the \npcrcrpuon that som l~rungs have been sn arbntanly. or that drltrrlng is ovenly \nonemus and subjm to political decisions that cannot be rationally objectified. \nWith this in mind, we encourage the SWRCB staff to carefully review the \ndescriptions and clarify their meanings to the greatat degree poarible. Ihefinal \nwlicv should include additional lanrmaee withrsaect to analvlical limitations . , \t --\nand the confurran raulttng fmm mamx effects, dnmo~Jqquanulicatron ltrmts \nand Ule impact of dublous data for one param* (hardness) on the standards \napplied to other ccrrelated paramelm (melak). \n83.1 \t Support the SWRCB's goal of establishing a standardized approach for Comment acknowledged. No \nassigning watw bodies to the 303(d) list, including nquinmmtr for consisrent \nstatistically valid data evaluation, requirements for data quality and quantity, \nand implementation provisions. \n102.4 \t The FED dm not uolain the methadoloev bv which the orovwed binomial The FED oresen6 in detail the rationale and alternatives for the ~mmralo made No -. . . . \t . . \nrodel was developed, rts impleat~onr, and th* polccy dec~r~ons Thc ~nUle Polrcy Ln FED sectton 6 thechanu of whether toanalyrenummc data bchlnd 81 \ndocummlatton docs not show hou llur rtaurucal &el actually idcnufier IS d~seussed The FED then gocs on to cxarmne how data should be dyzd \nimpaired bodies because it does not do so. by looking at the initial hypothesis to analyze, the statistical test to ux, the \nlevel of statistical confidence and powerdesired, the rate of excedmcs judged \ncritical for lirtine orddistine. and the minimum samole sizs &d. The \nFED presents a Innsparent oull~ne of the ~ssucs and pmeedures involved m \nanalping numrie wamqual~ty data \nLO7 6 \t Use of xlentlfically dcfenrrble procedures fw measuremenls and assaunmtr Stausucal analyrns a a rsogntzed and objecuve way to analyze numenc No \nprondc a level of confideoce wal lo thal for !he Itsung facton in Sccuon 3 1 rnfmmalton so that a level of assurance can be idenufied and quaotlfied \nand the pmpmed useof the 'standard' null hypothesis (i.r, watw is not \nimpaired). Statistical testing of a null hypatheses is not theonly mahad of \nhum reamnine. U can be emblematic in manv situations. \n111.7 \t Based on a recent Disuict Coun opinion in the Rodda rase,thebinomial Commmt acknowledged. No \napproach is not a revision of water quality standards. \n202.6 \t Encouraee review of the statistical methadr. to darifv their mine to the Effort has been made to satisfv this eonmeat in thedraft Policv and FED. Yes \ngroterl degree and provide addrtional language to clanfy any analylical Sevaal revisions have bem made to clarify the dcscnpuons of the statisucal \nconfusion to Ule mamx effeef. dctstim quantification limits, and impact of lnlr and conccps behind the tesu uud. A Definitions section has bem added \nW core data about one parameter or anotha \t to he Policy in response to this comment. \nW \nM \tB-49 COMMENT SUMMARY OF COMMENT \nNUMBER \nDFED. Issue 6A: Selection of Hv~otheses to Test \nNo comments. The details of statistical analysis are wtside my area of uptise. \nDiscussion conforms to standad statistical theory. \nIt is imponant fa the hegement water resou~ces that waters that do not met \nwater quality standards are listed, pmmptly, so that the planing procw for \npmtecting and restoring these resow may commence, and the heath, safety, \nand welfare of the citizens of California are protected. \nThe Draft Policv chmss as the statistical null hwothesis to be tested that a .. \nwater body mextr water qualiry standards This altmauve is counter tnlu~tive \nand inconsistent wth other wataqual~ty programs such as the Surface Wata \nAmbnmt Monitoting Rograrn and TMDL Guidance It enales a d~s~nemuve \nfor theregulated community to monitor because less monitoring will likely to \nresult in fewerlirtings. \nThe altematlve prermse. that a water body does not ach~evewater quahty \nstandards. IS most appropnatc when there IS ~nfomtlon lndlcatlng there IS or \nmay be impairment. Its use does not mean that all waters in California are \nassumed to be imoaired. Use of the hwothesis should be restricted to riolationr .. \nwherethere is so& infmtion indicating impairment. Its use will create \nincentives to monitor and is consistent with the TMDL Guidance. \n7he pal~cy dlscusru the null hypothesis ya it does nac clearly define the state's \nd~finluon 01 the null hypothes~s for lksnng wstm {whch is buried in the fFD) \nThis is especially critical for the de-listing section of the policy. \nB-50 2.21 \n3.1 \n10.1, 10.2 \n18.59.40.57. \n51 64.51 47. \n51 162,5135, \n102 13. 102 14. \n102.3, 103.4, \n103.1, 108.11 \n40 55 RESPONSE REVISION \nComment acknowledged. No \nComment acknowledged. No \nComment acknowledged. No \nTo aoolv the exact binomial test to analwe dichotomous water aualiw rmle Yes .. . .-. \ndata (la.the sample cttho daaor dm not satisfy perunent standads). \ninvesttgaton must sran with one of two inttial premises to be mlcd. The \nsbng null hyplhuir can be ertha \n1. The wafer body und~ eonridmtion is assumed to satisfy the patinat water \naualitv standard. or . , \n2 The water body is assud not to sausfy the watcr qualtty standard in \nquestion. \nThe null hypothesis represents an assumption that has bem put fnward, either \nbecause it is believed to be uueor becaux it is lo be used as a basis for \nargument, but has not been proved. Once data have been analyzed in an \nattempt to reject a null hypothesis, the null hypothesis is rejected only if the \nevidence against it is sufficiently smg. The alternative hmthesis on the \nother handris a statanent of what a staiistical hypofhesis &st is set up to \nestablish. \nIf it is concluded that the null hypothesis cannot be rejected, it does not mean \nthat the null hypothesis is me, it only suggests that then is not sufficient \nevidence against it in favor of the alternate hypthesis. \nThe fomof the null hypothesis recommended in thePolicy is appropriate \nbecause theintent of thePolicy is to establish the section 303(d) lia by using \ndata and information that shows the wdta does not meet standards. Using I& \n'reversed' hvwthesis would establish onlv which water at slandanb. The .. \ndistinction between Ule differmt null hypotheses is reduced if statistical -TS \nare balanced (Smith el al., 2031). \nThe null and allemate hypotheses have been included in the tablu of values Yes \nuxd to list and dclia watm. 76.50 \n-1 developments in C'ifamia in COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nNUMBER \n43.25.47.6.60.74. \t Agree with the staff-recommended alternative I. Comment aclmowledged. No \n51.1, 103.2 The conrequmcer for listing unimpaired wten aninrignifi-L lagal The impact of listing a water body Ihatactually meets wter quality standards Yes \nyean have esmtiallv eliminated any is &at thecosts of develooine aThfDL will be emended uonecsmilv. The \nnegatrve conrequenn of a mismken king (ic, including a 'clean' wa1er.m k cmrs of faillng lo list a Alabady no! meting s&dards include pot&tial \n303(d) IBSI) threats lo the mvimnmenl and to human health. Both pential cornan \nsignificant \nGiven the undisputed fact that section 303(d) functions as the last effective \nregulatory appmach to dying threatened or impaired waters, it is clear that The costs associated with missing real wter aualiw noblems can be alleviated . .. k~mplicau&r of not lirunganacrually impairedwatcnvay are far more sevcrc by expendbgrcraurca lo mnilk m thomughly. humbly, si@fi-I \nthan thmc attendant tomy impropx listing of a non-~mp~red walerqualily pmblems wll be identified with rufficirnl monilmingcffntr. walenvay. \nThe FED har been revisedtodiwuss this more cleady and to include the \nestimated costs to avoid thsemrs \n51.5.51.9,51.8. \t The Recaulianary Rinchple is ~nlended todeal with uncmatnty 11expresses Several comu were received rtaung that kdevelop-t and mlmt of No \n51 7. 105.5.219.1 \t thr'rafc'way of hmdlingunMainly. Thedrafl Pollcy mka mmu- #he draft Lining Policy and FED do not comply with the pmvirians of the \nprecautionary appmach and lolaates a high level of potential harm before Recautionary %nciple (PP). The process undemken todevelop the Policy, \nraking action. It uses uncMainty asa rationale for inaction. It adopts the the drah Policy itself, and the FED embody the spirit of the PP. \nposition Ihat a water bcdy is clean until pmven dirty. It creates disincentive for \ndischargerr to contribute to additional, much-needed monitoring, because such The PP was developed in 1992 atthe Rio Conference on the Envimnment and \nmonitoring might be used to build the ease that the water segment is, in fact, Development. Tkrdled 'Ria Declaration' uasadopted at the conference \nimpaired. \t Oneof the ~rineioles of theDeclaration (Princble IS) state: '...in order to . . \npmlut thccnv~ronmn~. the precauttonary appmch shall bc wdely applted by \nStaler accardlng lo melr capab~l~ly Where thae mUlreals of senous or \n!nevers~ble damage, lack of full scrmufic cma!nly shall no1 be used asa \nreason for postponing cost-effective measurn to prevent envimnmental \ndegradation.' \nStales' nfer lo Wdd Tnde Organtwoon couolnes The PPis a pmvlslon of \n~nlnnsuonal law PP as rrated m Ihc Rto Dslmuon is a very general \nstatcmcnt, the Comrmsr~on of Eurwan Cammues (a) (2000) has \ndeveloped guideliner for implementing PP to fmd the mnect balance so that \nomvattionate. non-disaiminatorv. tram-t and coherent actims can be . . \nIskm. ThcCtC p-5 also lmks PP ~mplcmenWton wtha nwmd \ndcctslon mhng process wth dcmlcd wtenofic and othcrob~ecuve \nThe relationship between the CEC guidelines for applying PPand hedrah \nListing Policy ispresented below. \nI. 'Recoune to the precautionary principle presuppases: [a] identification of \npotentially negative effects resulting froma phmomenon ...;[and b] a scientific \nevaluation of the risk which bgause of the insufficiency of hedam, their zs-a \n*urn wwsie PW :9vd286 avaw 30 sawam 9% @nonll \n!Ki!onurmm pn@a qpue 'K1!~oa @1U?ULqnua am 'sg-fig \n'vmn%mu! =ploqaqos~o ws &%nanll pedola~ap=a \nK~!lodgqam30 mo!sy.cud a= ;alq!ssod se idsw re aq mpmd \n. .. . .. .. . . \nasam ro IW .K3i& aamdme oue ';ns uana a~aeida& a~uerua~xa \n. . ... \nseaq oipumk s! koenp~ssw=inswJOsmmJOJ aiqepne i~m \nieq~uos~luoju~ q~sdde hlod yw pue e~epnmpn~ol pamunos e w~wu \nau ;huymm =UnwpsJO dap aw aaos qaeaie aud~suap! 'alqmod \n. . . . . ..-. ..-. .. . . . \noplo u! suo!sv?phqod panas 3~ u 83~sol v .produrn r! isuw \nq~ uow&am q01alqmdwm s!teql Lana[ 7s\" aw JO uosxn, e 'uoemp \nlwptlod ejo ilnsuw snw st uoomle u2r8 e u! ~suodsasieudoldde~~ 'Z \nrgw ao$uwap 4an!sdqi!saw%leu as-dw! w, ah!mpumu! \nNOISIAm SNOdSml \nmam \nANZIZW403?I0AXVWWIS .LNZIWW03 \n COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \ninformation available to make decisions. All measures of water quality are \ninherently variable and subject to uncertainty. Implementation of the Policy \nwill miss some water quality problems; the Policy is not aimed at establishing \nzero risk. But as new information is developed, problems will be identified \nand addressed by the TMDLpro,mm. The types of problems addressed by the \nPolicy are long-term exposures to pollutants; shorter-term or periodic problems \nmay not be caught but those are also not addressable by TMDLs (e.g., \nintermittent spills, etc.). TMDLs are best focused on problems that are \nreversible. \n7. 'Measures should not be discriminatory in their application.' The Policy \nrequires that comparable situations to not be treated differently. The Policy \nalso has provisions that allow different situations to not be treated in the same \nway, unless there are objective grounds for doing so (e.g., the situation-specific \nweight of evidence listing and delisting factors). Further, there are provisions \nthat allow RWQCBs to request additions to the list even if the conditions are \nnot allowed by the provisions of the Policy. \n8. 'Measures should be consistent with the measures already adopted in similar \ncircumstances or using similar approaches.' The provisions of the draft Policy \nare consistent with many States (but not all) listing processes. \n9. 'Themeasures adopted presuppose examination of the benefits and costs of \naction and lack of action. This examination should include as economic \ncosthenefit analysis when this is appropriate and feasible.' The impact of \nalternative actions are presented in the FED and the recommended approach is \nto balance the various kinds of errors and costs associated with those actions. \n10. 'The measures, although provisional, shall be maintained as long as the \nscientific data remain incom~lete, im~recise or inconclusive and as long as the \nrisk is considered too high ti be impdsed on society.' The Policy will beused \nto create a list that will be reviewed every two years; consequently the \nprovisions of the list are provisional and subject to change depending on the \navailability of scientific data and information. \n11. 'Maintenance of the measures depends on the development of scientific \nknowledge, in the light of which they should be reevaluated. This means that \nscientific research shall be continued with a view to obtaining more complete \ndata.' Monitoring data is key to implementing the provisions of the Policy. \nMonitoring must be continued and incorporated into the section 303(d) \ndecision making process. Monitoring data can come from State programs as \nwell as programs operated by others. \n12. 'Measures based on the precautionary principle shall be reexamined and if COMMENT \n51.85,51.161, \n51.84, 105.9, \n108.12.217.8 \n104.11,107.7 SUMMARY OF COMMENT \nThe draflPolicy should rely on lhc following statistical deciriontule: \nWater segmnts shall be placed on the section 303(d) list as impaired for \neoaventional ~ollutants oIher thantemeratm and dissolved oxveen unless the .-\nnumeric water qualrry objecttver for convea~oml pollumts mexceeded in \nlar than 10% of sampler wth a confidenet level of 90percent urlng a bknomlal \ndisuibution (Table 2). \nThis mommended alternative ado~u SWRCB's DmDosed statistical method in . . \nall wpccu ba one: the null hypothesir has been rcvsrcd. Unda this \nalremauw. the null hypothesis I*. 'the water segment is impaxred' in contrast ro \nthenull hyprhcsir under SWRCB'r recommendation. 'the water ugmnt is \nContraryto common dogma, the use of Ihenull hypothesis has little utility in \nscience. Binomial methodology is highly contmvenial. There are hundreds of \npeer reviewed paper. questioning the indiscriminate and inappropriate use of \nUlat statistical hypothesis test. RESPONSE REVISION \nnecessary mcdified depending aa rhe results of the scientific research and the \nfollow up of their impact' CWC section 13143 allows SWRCB U,petiadically \nreview and revise policy for water quality eonml. If provisions of thePolicy \nUley eanand should be revid \n13. 'Meas- bas4 on the pncautionary principle may asJign responsibility \nfor pmducing the scientific evidence nccesaq for a comprehensive rish \nevaluation.' The Policy provisions allow interested Wes U,develop and \noreoare fact sheets soRWOCBs and SWRCB eanconridaadditionn and 7 ~ ~ 7 ~ ~ ~ ~ ~~~~~ ~~ ~ ~~ .-~~~ ~ ~ \ndeletions to thc IBSL When n-rary RWQCBr have authmity to require the \npmparatian of rrpons of water qual~ty Mnmtions (CWCrsuon 13267). \nUsing fixed significance appmach (SWRCB, 2003cX thisrecOmMtldation No \nwmld place California water bodies on the section 303(d) list using very sdl \nnumbersof exceedances. \nThe 'smdwd \"dl hypth~sts IS themore cnuuous agamit lncomlly labebng \n3 water body asnor mffltng smdards, ba at the expense of fatlmgto rdcnufy \nall rmly polluted warn. This null hypothesis choiee is considered more \nappropriate when economic or social consequences aredeserving of prnlection \nThe'rrverrcd' null hypothesis effecovely guards against Iheamr of \noverlooking polluted waten. but wth a h~ghlikelihmd of incomectly listing \nunnpanmd wats Mia. Thischoice is considered fitling when ecological or \npublic health consequences aredesening of protenion \nBothchorces are rtausucally valld and *odd result m mpmt \nl~st~ngldeltsung pmccdurn The dcctrton to useether formof null hypothesis \nis a policy choice. Balancing of decision mn minimizes differences tetween \nthese hypotheses and the differences in thenumber of uceedances needed. \nThere are two basic pmcedures in statistical inference to base decisions on: No \nhypothesis testing and confidence intervals. Both procedures anive at the \nram conclusions and are, at Uleir foundations, maUlematically similar. \nHypothesis testing is a valid and appropriate means to makedecisionsbased on \nsamples of quantitative infmtiae \nDFED. Issue 6B: Choice of Statistical Tests for the Evaluation of Water Oualitv Data \nW \nW 2.22 \n3.2.43.26.60.75. \n71.22.76.51 No comments. Thedetails of statistical analysis areoutside my area of erpatise. \nRecommendation of exact binomial test seems reasonable. Comment acknowledged. \nComment acknowledged. No \nNo - - \n- - COMMENT \n3.3.51.118 \n3.4 \n10.5. 14.4.20.8, \n51 50, lMl2 \n18.84 \n40.56.43.29. \n51.101.51.88. \n56 16.56 14.63 7. \n101 13. I05 3, SUMMARY OF COMMENT \nMajor shortcoming of exact binomial test is that it does not mke mgnitnde into \naccount \n-\nFigure 16 lacks information on the Critical Exceedance Rate used to modd the \nrates of Type ll error for the binomial and Raw Score approaches. \nUse of binomial madel is not tem~ered -r~atial andlor temral distribution \nproblems may not fil withorwork well with the modcl. If a pollutant hasa \nrearanal variation, uscof b~nomial model eannot account for chis-monitoring \nmay miss a pollutant if done in the wmng time or season. Pollutant spatial \nconcentrations can not, or arenot likely to be t&en into aeeount -or missed \nentirely. \nThe TMDL Roundtable recommended that a water body should be listed if any \noneof three recommended criteria is met. The draft Listine Policv is aartiallv u \n.. \nconslslent wth thns recamdal~on Thedraft L~sllng Pollcy allows the weof \nIhe Ecrcenlng values and guldelmcs suggerled in thts recommendauon Illhe \ndrah hung Polrcy uses Ule b~nomtal method utth a 10% cxcecdance ratz \nrather than the mean or median as war originally recommended \nUSEPA guidance and pmfssimal literdhlre recammend that Type1and Type 2 \nerrorrats should be balanced if Ihere is no clearammt Ihat one form of \nmr is more rmportant lhan the other, as a pollcy mancr, in lhat stare (rcc \nIJSEPA, 2001. USEPA.2003a. and Srmthet al ,2001 ) RESPONSE REVISION \nBeeawe of thenam of the RmlLp-m and befausenhawata quality No \npropans exist to deal with other problem nM handled by TMDIs, wgnitude \nof an exceedance of an obiective is not a critical irsue forlistinddelistine. \nInstead. the number of times a water body is sem to exceed, or UM, an \nobjective is the manrmcial factor. In addition, magniMe asa facforis \nalready built in to water quality objectives. Forthesereasms, useof Ule -\nbinomial madel is adequate for senion 303(d) listingldelisring pup-. \nFurthermore, RWOCBs arenot =vented hm wine maenitude if iustified -\nusing the simtion-specific listing and delisting factors. \nThis has been corrected. Yes \nNotlung m the drah Pollcy prevmLs invesugaton from us~ngdam homecwn No \nllnuled urns of the year m order to captun temporary or sporadic rmpacu lo \nbeneficial use. Ifdesigned prvpwly, water quality sampling, inmajunction \nwith binomial analpis, will be adequate to locate me water quality problems \nA more av~licable. non~aramehie statistical vrOFedurs was selected meciselv No. ~. \nbecause ikmcvic rtauslics would not alwair be valid, specially for small \nsamplw bared on not-normal populations of data The btnonual IS the most \nreadily applicableand most eflieml slatisuwl choice for dichotomous daw \nfrom large populations (e.g., a water body such asa river or lake). Useof the \nmedian or arithmetic mean as an exeeedance frequency is not sufficiently \nprotective (50% exceedance fqumcy). \nThis recommendation has been incorporated into the Policv and FED. use of a Yes \ntest with'baland statistical mrsis now the recammended pd& foruse \nin the statistical test in the Listing Policy. The following is a description of the \ntechnique used. \nStatistical emn balancine usine theexact binomial lest amu to 'balance' cn \nmake eaual estimates ofbe two ~~..twesof oossible decision-&% error rhat . ~- ~~~ ~~ ~~~ \nmay result at each sample sire. Wise equality between the Iwo mr rates is \nnot actually possible formany sample sires. Instead, Type Iand Type llerror \nrates arecalculated atvarious exmedance frequencies mbe asclwe to one \nanotheraspossible with both at or below a critical maximum errorrate. \nA key &ffcrencr brlween thenan-balanced pmedwcrecommmdcd in the \nDevmhcrZW3 vmion and the balanced prawdure is ihat two, not one. \nexceedance rates areemployed. An exceedance rate stands in for the lmlmown \nttue exmedance late in thewater body. Because thelikelihd lhat a sampled \nallounent of water in a water body will exceeda peRinent water quality COMMENT SUMMARY OF COMMENT \nNUMBER \n43.60 \t In developing 303(d) policy, the SWRCB should address the following \nquestion: What is the statistical meUtod on which to base 303(d) lislinm? \n51.3,51.54,51.2 \t The current draft Listing Policy is inconsistent with both the clear maadate of \nsection 303(d) and Cfin5essional policy and intent &lying section 303(d) in \na number of wavs. Far examole, the Listing Policv'r binomial aoomch fails to -. \t . . \naccurdlely asses: ~mpalrrd wirer bodter Thus. the ltrrtng poley'r blnomsl \nappmach 1% connary lo secuon 303(dl's clear mandatc lo sdenlrfy waters in \nCalifornia where effluent limitations are not stringent enough to implemnt any \nwater quality standds \n71.21 The FED presents a thmugh'review of different slalistical methodologies Ihal \nwere considered for use in testing compliance with a waterqdity standard \nW \tTable 12). \nTheSWRCB should incorporate the use of a smistica1 test or,at the vay least,W 71.29 \nsimple graphical methods to identify outliers or anomalous data, and that those RESPONSE \t REVISION \nenterion canna be known, a mimum rate of exeeedance, a highel toterable \nrate above which a water body should definitely be listed, is ehosm for \nbinomial mrafe calculations. \nIn the previous draft Policy, one exceedaocerate was used Howeva, for Ihe \nbalanced pmcedure, a remnd, higherexceedance rate is also needed. me \nlower exceedance rate is usedasan estimate of the Lowst quality acceptable as \nan avetaee. This lo- value is an estimate of the likelihmd of makine a 'he \" \t u .. \nI em (in ihcPoley. the nor of rncamaly lislinga water body). Thehgha \nexcecdance rate ir ihrhighest frequency lhal would be allowed in a single \nramplc. The higher value IS used lo calculate the l~kelihmdof Type O aror \n(theem of failing to list a water body). This -d ereeedan&& must be \nhieher thao low exceedance rate in ordm for the two enor rater 'balance' at an \" \nacfeptahlc lcvel If the ram exccedanee ratc(eg .10%) #sued for both mr \nrate calculal~ons. balancnng occm a1 a mutual erw rateof 5W \nTo 'balance' Type I and Type Uemrates, the (a) critical number of \nexeeedances (k) hl must be observed in orda to list the water body and m) \nstandard m raln a1 each llkely qlc rrx arc first calculated urmg the \nlower exoxdance rate lo dctemune thchecmaled Type 1mr raw and hrghcr \nexc&mce Fateto calculate estimatedType!Irn rate. Next, theahsolute \ndifference between Type I to Type Uemr rate is minimized by adjusting kup \nor dow. When the two em rates are asclore ar wrrible. the modified k used \nto achieve Ulis 'balance' is used in place of the oriiiual k. \nThe FED has been modified to include a description of the balancing pmcedure \naspmvided by USEPA. \nThis issue is addressed in detail in the draft FED Section 6 \nAssessments of the results of water quality samples areused to detamine if a No \nwater body should be listed. The exact binomial test is one valid tml that can \nbe used lo anal= samle results and to auantifv the likelihood of decision- \nlruktng mor he allematlves for this &k areoulllned in FED SecUon 6 B \nThe use of and results from theb~normal pdum do not wolalr fedml or \nState laws. \nComment acknowledged. \t No \nTheexact binomial test, withits use of tramfamed data(i.e., numric datais No \ntransformed into counts of nominal, 'yes' or ho' information) addresses tbe COMMENT SUMMARY OF COMMENT \nNUMBER \noutlying data points be eldy examined for mlidity and usefulness in the \nanalysis. Even with sound QAlQC pmedures, anomalous data will \nwcasionally pass hgh lhe data quality men. \n102.5 The Policy is not scimtifidy defensible. Therefore, claims in Ule FEDthat the \nPolicy doer not have significant advase envimnmental impacts anunuue. One \nof the pmblenn is the effort by the Policy to be consistent by using the binomial \nmodel. The validity of the whole ~~~~~~~mllv hinges on the ~m&red binomial . .-. . \nmodel being app&riate. But Ihe binomial model can not validly be applied \nanoss all pollutants, all suessors, and all s m throughout lhe rtak \n207.16 What is thestatistical method on which to base 303(d) listings? \n217.9 Another alternative is to consider using a simpler appmach that doesn't assume \na LO perrent exceedance rate in order to counter for variability, uncertainty, and \nem. A simole T test in which the Smles comoared to the standard with a \ncan canLdcnce limit can be uxd and would account for vanablllly. \nunemnty, and em. RESPONSE REVISION \nproblem of outliers. High and law values will not influence nrults unduly; as \nused in the Policy, there is no 'mean' to be gr~atly affefted \nMore sophisticated statistical pmcedures are available The act binomial fest No \nis a modest, yevappmpriatej fitst attempt to inboduee scientific validity into \nsection 303(d) liitinidelirting decision-makin% other tests canbe used if -\nwananted. \nAs expla~ncd in the drafr FED.the exm b~nom~al a rtaurucal pmcedm tes~ No \n~nlended for uw m analyug drchmomous dam, uproposed for use m \nevaluaung M3(d) l~rung data and for bst~ng and dd~sungdenrrms Thlr \nomceduri is valid beesuse wateraualitv ramole data dher doesor doesnot ... \nrausfy appl~cable wata quality objecnves. Once mainkey variables are \nxlsted (exexdance rate(%)and a destrcd level of rmurtical confidence or \npower,. the binormal lest generates the critical number of cxeeedanca that \nmust be observed in a sample of a particular size in order to accurately decide \nwhether or not to list a water body. \nAs fhedmfi FEDshow, the SNdent's t-Test alternative weonridered. No \nHowever, paramhie tests paform more pdy Ulannon-parameoic tests (e.g., \nthe exact binomial test) when s-le sizes aresmall and in cam when the \npopulalion of dala is no1 normally &rhiburcd. Thesimpleand effic~ent \nbinormal lest was the bcst ovcrall cho~ce for section 303(d) dam analyr~r. ms \ntest is not precluded from use; the t-test may be used if wananted. \nDFED, Issue 6C: Selection of Statistical Confidence Level \n2.23 \n3.7.3.6.3.5 \n3.8.43.27.76.52 \n51.41.51.66 No comments. The details of statistical analysis are outside my area of expertise. \n?he statement, statistical confidence is the probability thaI a hypothesis is me., \nis not literally true exat for Bavesian stalistical testinp. \nThe selection of the pnfemd a level ao- to be iustified. \nUnder the draft Policy's binomial approach, the level of confidence required to \nreject the null hypothesis is too high. One consequence of requiring Ulis level of \nconfidence before the hypMhesis can be rejected is Ulat the data must not only \ndemonsoate difference from the hypathesized condition, they must demonsafe \nsignificant difference. In the case of SWRCB's binomial approach, the evidence \nrequired is practically unaltainable. \nB-57 Comment acknowledged. No \nThelanguage in question has been revised. Yes \nComment aelcnowledeed. No \nA desired 90 percent confidence is a commonly-aeeepted level in scientific \nstudies; 80 percent is also acceptable if the preliminary findings arefollowed \nup with mare rseareh or monitoring (Hahn and Meeker, 1991). Many \nscientists insist on even higha confidence levels in order to reject a smting, \nnull,hypothesis (e.g., 95% or even 99%). Yes \nThe Policy has been revised to use a lower yet justified level of confidence and \nto require more certainty when delisting. COMMENT \n51.87 \n60.76 SUMMARY OF COMMENT \nSWRCBI proposed approach Cstandard' null hypothesis) is 81 to 362 times \nmore likely to fail to list an impaired water body than it is to list a clean one. \nWe believe thatthis prefmce flis in the face of the prsautionary principle \nand does not rdect the water quality priorities of Californians or those \nexprerred in the CWA. A better policy would err in favor of listing, rhereby \nminimizing the possibility of leaving impaired water bodies offthe list and \nminimizing the attendant risks to human health and aquatic life. The reverse \nnull appmach discussed above, would do this. At a minimum though, the \nlistine criterion should ~mvide for a more eouilable aooonionment of these -\t . . \nmn A'fatr'l~sung \t of mtenan would bconc for which the pmbab~l~ty \nmaking each type of ermr is equal. \nSupporn recommended Alternative 3 RESPONSE \t REVISION \nThe claim that thenon-%=lanced' appmach with 'standard' null hypothesis is 81 \nto 362 timer more likely mult in aType U rhao Type I emxis not acuuate. \nThessclaims are too hieh. The statistical orobabilities rmwnted bv the -Yes \ncommenterare the sumof all pmstble aaust~cal mrr ova aU posvble \nalmtc exceedanee rates llus unneccsmly =hangshc hesmeromales for \nthe b~normal test uslng a fixed s~gntficmce level. The use of a moo to coopare \nermrs is alsn misleading. W~threal sampling &fa, it is impossible to have both \ntypes of em occur simultaneously. \nWhtle there are dtffemccr m the detatlr of how Type I and Type U emn rats \nshould bc presented, the concept of balanctng a pnon the two types of ermrs to \nattempt to equally avoid the mrr has merit The Policy and FED baw bem \nrevised to inelude wtions for balancing statistical mi \nComment acknowledged No \n-\nDFED, Issue 6D: Critical Rate of Exceedances of Water Quality Standards \n2.24 \t No comments. The details of statistical analysis areoutside my area of expatise. \n3.12 \t The case for using a gmter rhao rem critical erceedance rate is clear when \nconsidering measurement error, sample unit definition, and averaging period. \n3.9,3.11,3.10 \t The discussion confuses the concept of pmponion of samples between the \npmponion within a water quality sample and the hypothetical proportion within \nthe population of all possible water samples. \nAIUlaugh, the binomal method with a 10% acceptable exceedance rate is an \nappmach that would provide consistency in how standards are evaluated, it is \ninconsistent which how standards are wntten. Few standards are written with a \n10% allowable exceedance rate. Comment acknowledged. \t No \nComment acknowledged. \t No \nThe language in question has been revised. \t Yes \nThe first step in applying the provisions of the Policy is to assess if standards No \nam met based on the terms of Ule standard. The ssond step would be to apply \nthe binomial statistical analysis, in order to determine thelevel of confidence \nand powathat exists in the decision that the data haw shown an exceedance \nof a water quality standard occurred. \nThe actual proportion of water in a water body that mly exceeds applicable \nwater quality objectives cannot be known with 100 percent assurance. \nTherefore. statistical analvsis must be oerfarmed on data to esfablish with some \nquant~fiablr. level of cehl~nly how to rmke vahd decrs~nu onsample data As \ndctaalcd in the dnh ED. thns rates propored have bcen propored by USEPA \n(20023) and as pmmted are conr!dend by USEPA to pmwdr a deeiston rule \nfor assessing cahpliance with standards. ~onse~uentli, Ulir apprazeh is \nconsistent with water quality standards as written. Som level of exceedaxe \nmterthan zao must be seen in order to account for sampling and malyrical \nuncenaimy. COMMENT \n51.49.51.53.80.3. \n80.4, 103.3, \n104.10. 106.9, \n107.2, 109.6, 109.7 \n21.65 \n43.28.60.77.76.53 \n51.160 \n51.39 \n104.9 SUMMARY OF COMMENT \nTIE statement. The critical exceeduKe rate is theornoonion of ramles that . . \nuceed an apphcablc warerqual~ty mlenon provadtng ovenvhelrmng evldence \nthat a waln segment falr to mea water quallry standards for the pameular \npollutant is biased against listing and water quality pmtection \nAgree with the staff-recommended alternative 4. Although we wwld prefa the \n15 perm1 exfeedance data in alternative 3, uznote that ok states using the \nexact binomial test are usinn a 10 m t critical rate of exfeedance. \nThe binomial model, as implemented in the FED, is hmed in the following \nwax 'eiven Ulat the me exceedance rate is 0.1.9W of samles of sire N will \ncailai k n fewer rxceedanfes; thus, if we obime k+ I or more cxccedances. \nwe have ww for concern ' lheproblem with thtr frarmng is that 11 arsumes \nthat the mcuceedanw rate isboth knowable and know. and fixer it at 0 I. \nSince the exceedance me is what we would like to know, this framing puts the \ncan before the horsa in fact, we don't actually know what the exceedance rate \nis. \nUSEPA stated plainly that the reliance on the 10% exfeedance lule is based on \nan incorrect reading of USEPA guidance eonceming allowable water quality \nexceedance rates. USEPA retommended criteria development appmaches \nbared on a 95% wmliance ratefor conventional aollutanu and a mare \nslnngcnl cornpl~ance rate for laxtc pollutants of'at least 99%)\" the conwxl of a \nbinormal mthod, or 'whcn 2 amore samples cxeeed the [CTR mlr standards \nfor aquatic hfe] many 3 pu pmod ' USEPA also mbcmd the useof the \nmodel's arbiVary selectii offive exceedances for sample sas less than 20, \nfinding Ulat 'there is no technical rationale for this decision.' \nThe reversenull hypothesis ora balanced probability appmach are not \nnecessarily pmtective. The 10 pmmt mle may be pmtective and comply with \nwater quality sfandards. In Florida the binomial method lead to the delistinn of \na lareenumber of wamw. which USEPA ommotlv out back on their lire - . .,. \nIurge the Boanl lo d~rect staff to canvmca fae~lrraled proeesr ht ~nvolvcs the \nRWQCBs. USEPA, the PAC. and ~ntncsled pantrr to develop an appmarh that RESPONSE REVISION \n~ ~~- ~ - ~ ~ \n?he laaeuake has been revised for elariw. Yes \" -\nComment acknowledged \nThe Policy and FED follow standard statistical pmtocols in using the binomial Yes \ntest (acceotance samoline bv attributes). Thecommter is wmct that the . . . -. \nINC exceedMce rate is unknowable. lt'ir for this reason that a ucecdance \nraws are used in ealculallons in place of the me exceedance rare. Tlus rate is \npn-selected and is a policy decision It is lhe. rate abave which polcy-makers \nhave significant concan IhalIhe water body should be listed. For listing, the \nimporwt question is related to whetha the exceedance me is telow orabove \ncritical levels. The actual level is of interest but it is nm necessary to delemine \nthe prsise value before listing ordelisting can occur. \nLanguage in the Policy and FED have been revised for clarity on this issue \nAs detailed in the draft FED, many viable altanatives for excdance rate No \nchoices were considered. The ten percent option for conventional pollutanu \nmay, now, he disavowed by various authorities. But as the draft FED show. \nits use for water quality analysis has been widespread and well~stablished. \nThePolicy has been revised to ux one of the statistical approxhm related to \ninterpretation of the CTR critaia (please refer to CALM at table 4-3) (USEPA, \n2W2a). The aoomach listed in the comment is also sueeested in the CALM .. -\ngu~&ncr. as a \"on-stausucal approach for damning compltance. In \ndcvelopng the Pollcy 11 was asrumcd statlsucal appmacha would be used \nrplease refer to Issue 6 ofthe ED) \nThere is admittedly more than one valid way to accomplish the goal of section No \n303(d) listingldelisting. The draft Policy prerenu an apch Ulat is \nfunctional. rrmtective, and uanmarent. \nA ncw 'fac8l1tated pmar' !r unnecaq The SWRCR has worked wth \nregulated and nvlm~lenul communlly reprcwnwlrvcr (through the PAC). \nthe RWQCBr, and tntnested pames, tocnfi the draft Pol~cy COMMENT SUMMARY OF COMMENT \nis functional, protective, and transparent. A multi-step, pxr-reviewed process \nUlat includes bi-statisticians is needed. \nDFED, Issue 6E: Minimum Sample Size \n1.12, 1.8, 1.4, 1.19 \t Forconventional pollutants, suggest a minimum samplesize of 30 \nrepresentative samples for a valid listing. \n2.25 \t No commem. Thedetails of statistical analvsis are outside mv area of FXDeRiSe. \n3.13.3.14 \t The last oaramoh under Alternative 3 is nM ouite rieht in detail. althouah it is . -. \t . \n~nrplnt By calculatton if a=O 10and n=22. the decnrcon to lm would requtm \nfive or mrcexceedancer. whnle thedec~s~on lodellst would rqum m \nexceedances, when the exact binomial test is used. If Ihe qle size were less \nthan 22, it would be impossible to conduct an exact binomial test to delist with \nas. 10. \n10.4,40.4L, 40.83, Use of binomial statistical inface daes not work well with small data sets. \n40.62.40.40, Small sample sizes will show no reliable effect or small data sets can not \n51.67.71.28.72.4. \t reliably show presence or absence. \n106.5 \n11.7, 19.7 \t The number of samples exceeding the evaluation guideline required for listing is \ninconsistent with Table 3.1; thisstatemnt allows far inclusion with only 3 \nsamples. Theuse of a sample population of 20 may be man appropriate to place \nwatm on the 303(d) list \n13.13 The recommended minimum samples may work well for chemical pollutants, \nId paramem with high variability like sediment, require maoy more samples. The \nproposed policy should state that highly variable parameters like suspended W sediment and turbidity require larger sample sizes, and Ihat sample sim should RESPONSE \t REVISION \nAlthough a minimum sample sii of 30 would help decrease- n error No \nsamewhaI, Ule advantage would be minimal. A better way to addms emr \nrates is a balanced aooroach. \nComment acknowledeed. \t No \nThe laneuaee in ouestion has been revised. \t Yesuu \n . \nDecision making with d l data sets is difficult no mam what test is used. No \nOw of the reasons to use the binomial rest is Ihat it can be used if sample size \nis relatively small (L.in et al.. 2000). Ifa great amount of data is available, one \nis more sure of Ihe conclusions compared IO situations where little data are \navailable (Hahn and Meeker, 1991). Relatively small samples can be used if \nthe level of confidence and pwer needed is not ex-ively high. High \nconfidence is needed when the immediate outcome of a decision is to build a \nnew fanltly IOmeat water or some expcnstve rcmcd~al achon W~th nrpect to \nthe wellon 30kd) Itst. theoueome of the decnrron is to develop a planning \ndwumrnt (a TMDL) lhat wll ulumarely adkr Ihc standards exceedance \nLower confidence and therefore smallersample sizes are appropriate because \nthere is oppntunity to perfom additional research and monitoring to \nchmcterize thewater quality problem during the development of theTMDL. \nUsing a relatively low confidence in the statistical test (such as 80 parmt) is \nsuppnred because it is likely that when IheTMDL is developed the initial \nconclusions to place waters on the section 303(d) list will be cmobrated. \nThere was no inconsistency. As described in Table 3.1, three excgdances Yes \nmust be obsaved in order to list a water body. The FED has been revised to \ndescribe the rationale for using thisvalue when qle populations are small. \nNo justification is provided torequire larger sample sizes for iurbidity and No \nsediment No change is indicated - - \n- - \n-- COMMENT \n4063.71 26. \n71 25. 1099 \n40.80 \n51.40.51.45. \n51.46.51.43. \n51 44.51 37. \n101.6. 106.1. \n60.78.76.54 SUMMARY OF COMMENT \nbe appropriate to Ule variability of parameter king monitored \nIn tk proposed draft Policy, a small slmplc snu. Is dcfincdas fcwa than lOor \n20 samples to llst and fewa than 22 rampla to delnsr These arc reasonable \ndefroitions of small samples, since statistical tests based on sampler of smaller \nsize will have less pow= Ulan larp.ersamle for makine sound &d reliable \ndecision$. It is appmpriaw for listing pwpmes to mihe lower limt for sample \nsiz at 10 n20 rampla, since raiung the rmnimum sample size will mmt likely \nprevent listing decisions for intermediatesized samples. It is also necwary, as \nshown by calculation assaeiated with the binomial test. Ulat the minimum sile \nto delirt must be 22 sampler. \nThewlicv should more clearlv wolain how data would be evaluated in cass in ~ ~ ~ ~~~~~~ ~~ ~- . . , . \nuhlch fever Ulan 4-5 samples areavatlabkin any panicular month. We an: \nconcerned tha exclusmn of data hom funhereonrrderation ~lmply because the \nminimum monthly sample sizes arenot available could result in incomt \nconclusions that the objectives areanained \nThe minimum sample nquirwents can only encourage dischawen to ov~ose . . \ninmed monita~a -budeets or lead them ruuctu~ sam~le c~lleetion to -\navoid toxlc pulse; In other words, to anangc for the mjonty of the sawllng to \noccur when there ir naa problem \nSuppons recommended Alternative 4. It provides target sample sizes while \nsatisfying USEPA guidance. RESPONSE REVISION \nWhen Type I and U amnare balanced uskng theapproaches pmposed m tbe Ya \nCALM Guidance (USEPA. 20024 Smth n al ,2001). the lowat smle szvs \nwith acceptable ermn nnge hom 21-26 samles. Ratherthan use these \nsamale sizes as minimumbe tirtine poliev is f d on the ninimum -. \nnumber of exmdanfes that are allowed for listing and delisting. For example, \nifthe lhrahold lor listing is 2 ar marc sampla above the slandard thm the \nsample size could be aslow as 2 to suppon the decision to list because the \nlisting &hold has been reached. \nThe FED has been revised to include &rationale for listing with small sample \npopulations. \nIf wata quality objectives call for the evaluation of duration hugh a shon NO \nterm avaage the policy allows for the interpretation of standards using the \navailable data and information. The policy does not prevent the interpretation \nof data and information based on the absolutenumber of sampler available for \ntheevaluation. \nThere is nothine in the Policv to orevent invcstieatm from scheduline . . No \nmonitarine to collect samales when toxicitv is oresent. The binomial-based ~ ~~ ~ ,~. ~~~ \npmedum with the mnrmum sample rim are an appmpriate choice far \nanalyrtr of rampled data By balanetng em, lnmuvn to monttor would \nComt acknowledged. No \nDFED, Issue 6F: Quantitation of Chemical Measurements \n2.26 \n2.27.3.15. W.84, \n76.59 \n43.30.60.79.76.55 Not sure which of Alternative 2 or 3 is tk better for DFED. Altrmative 2 gives \nless wiggle roam but I do not know if it is better horn a statistical point of view. \nOne of the advantages of the exaa binomial test is that there is no ambiguity in \nhow to Veat measurements below the amtitation limit. so lone as that limit is . ~\" ~~ \nIns than the warcr quality objecuve. When the quanlitation limit is larger than \nthe walaqrul~ly ob~suvc, mcarurrmmts between the two are indeed di&cult \nto interpret. The labeling of Figure 22 is incomplete (the upper horimntal line \nshould be labeled QL and the lower WqO). \nAgree with the staff-recomded alternative 2. Guidance is needed to pmmote \ncansislency. Comment acknowledged. No \nThe FED has been revised to clarify the figure. Yes \nComment acknowledged. No \n COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n63.12.204.2 \t A third alternative, that \"in-detects should only beinteqxaed as unknowns, This alternative is not needed because it is already addresed under Altematiive Yes \nshould be added to this issue. \t I. Nondetect values are dot know but if themaquality objective is above \nthe quantitation level it is lolow Unt the standard is achieved. \n63.13 \t If more sen*tive/expmsive tests are desired, then themulls of Ulese tests Cmmmt acknowledged. No \nshould be used even if compliance monitoring costs go up. The staLs areton \nhigh to assume that pollutants arepresent when they may not be. \nDFED, Issue 7A: Review of the Existing Section 303(d) List \n2.28.43.44.60.47 \t Ifjust therecnnmnded Altanative 2 section 303(d) list, is done and the Board me FED has been revised to include an analysis of this alternative Yes \nstaff situation remains the ~ameyou will also be behind in the I&and it will \neel wane and wone astimc eoes bv. Whv not use a combination of Alternatives i and2 in whch accmtn nkbcriora c.mn fractnon) of the cx~rungl~rt that \ndm not have new dald~nfomon rr rcnskred in each cycle Ln thtr #hen \nwould be a chance of eventually aching up. \n7.12,7.11,7.16, It is both reasonableand fair toexamine and adopt a third option that would This new option has been included in the FED. Yes \n7.14,7.13,7.10, allow review of existing seg-1s upon submittal of a request showing why the \n9.1,47.12,47.2, listing was improper without requiring the data or information to be new. \n60.63 \n43.31,60.80,64.4, \t Disagrees with recommended Alternative 2. Recommend that an Alternative 3 Delistins should be based ansubstantial evidence in the record. If it is found Yes \n76.56 \t be develooed. This Alternative should include delistine of all listines for which lhar an &alyrrr ofthc wlcr body rnd~cala that it doer not met the \npolluunkhave not been tdenlrfied andcreal~ng a whzulc lo ten& the rqulrernents oilhe Lsong Polrcy. the water should be removed horn the Itst \nrcmnda of the watn segments lrsled pnw to adopl~on of the Poltcy Pnonty RWQCBr should bc glvcn the ab~l~ly ,f no new informaurn is to del~rt \nshould be given to reviewing water segment-pollutant wmbinatiom listed prior available but a delisting is warranted. \nto 2002. me July draft provided for reviewing existing listings over three listing \ncvcles. Three twc-vear lirtine ewles would be acceotable. but not Ulree four- me draft Policv and FED have been revised to allow RWOCBs to remove \nGar llrttng cycln.me newil~mauvc 3 rhauld addrsr Ule pmrrb~bty hat thr. waters ham thc bst if hc pmwr~ons of the Polxcy annot I& \nlength of the bsttng cycle could bechanged \n56.10 \t The SWRCB should adopt Alternative 1 in reviewing existing listing of the Co~nents acknowledged. No \ndraft FED, and incorporate a requirement to revise theexisting list so it is \nwnsistent with the Listing/DeI'iting Policy. Suppon the SWRCB's \nrecommendation to establish an application pmcess, whexeby an interested party \ncan request that an existing listing be reassessed under the provisions of the \ndlaft listing Policy. \n60.81 \t SWRCB needs to ensure that the ~roxrdocumentation occurs for each ofthe The draft Paliev and FED have been revised to include a reauiremmt to earn Yes . . \t ~~, -- ~ ~~ ~~ ~ ~ ~ ~~ \t ~~~~ ~~~ ~ ~~ \nlistings (past. pmmr. and fuweJ so that he h~storyand rahalc for each fo~uard tk swnmary of ilau and lnfomlim evm if it docs nM suppon the \nl~sungeprcservcd If past listings do not have propn dacumcntauon they need finding lhal the water should be placed on the lisl. \nto be questioned instead of simply carried fonuard. \nThis information is needed to develor, the CWA section 305@) rewn. COMMENT \nNUMBER SUMMARY OF COMMENT RESPONSE REVISION \n63.14.204.3 Add a lhird ahemaive: mimiortodevela~ine aTMDL the listine data should be . \nevaluated wth the new cntcna lhe is nwdd to lakc umecerrary TMDls off \nthe llsk reduce the RWQCBISWRCB om hurden, md stahhrh qual~ty %,\"red \ndata sets that will redueeTMDL timelines. This comment is addnsred bv theTMDLOuidancePolicv. No \nDFED, Issue 7B: Defining Existing Readily Available Data and'1nformation \n2.29 Agree with the reeonmendation, but add that a review of current appropriate \nliteramre published in archival journals should be reviewed. This could be a \ntask prepand by a canhaelor for all RWQCBr. \n11.3, 19.3 Requests the inclusion of annual Municipal Separate Storm Sew System \n(MS4) monitoring repon data as a sourn of informalion for listing decisions \nand canalso serve as additional data that can be used to reevaluate listed \nwaters. \n21.41.51.24, The bady of regulations and guidance that bear on 303(d) listing are \n51.26.60.43. unambiguous about the information that should be considered in making listing \n76.26.76.2, decisions: all of it. USEPA'S mls with respen to the use of data in listing \n102.15. 109.10 dsirianr could not be clearer: AU readilv available information should be \nconr8derd: Data should not be dtscounled solely on the basis of age: and use of \nminjrnum sample sira arc not appmpnate. \n43.32.60.82. Supporn reeonmended Alternative 2. \n63.15.76.57 Comment acknowledg@. No \nThis change has been made. Yes \nAll readily available dam and information shall be reviewed when the section \n303(d) list is developed. All data and information include everything available \nFrom whatever source whether it identifies pallutants or no^ Thepmcss d \ndefinine existine readilv available data and information includes two ohes. -~~ ~~~~~~~ 7 ~~-~ \nOneis dcfinlngall thc soww ukre the data and informauon can corn fmm \nIheother is whether thcdata and information gathered is acceptable forlis~ng \nTheFEDdiscussed two altematives and include a \"an-inclusive list of \npossible soum for the data and informatioh and monmends that readily \navailable data and information should be in written or in elecmnic fom. In \nspecifying the typeof data and information to be solicited, the Policy \nestablishes a prcferurce for dataand infmfim that amd-mtcd mpptr \nor in elecmnic form. Otherwise readily available data and information should \nbe requested From all sauces of whatever quality. The FEDand the policy \nhave been revised, data age and minimum sample size requiremenu have been \nmoved fmm the Policy. Yes \nComnt acknowledged. No \nDFED. Issue 7C: Process for Soliciting Data and Information and ADD~OV~~ of the List \n2.30 Agree with recommendation number3. Use the greatest psible numherof \nresources to collect data! This will help reach the most informed decision. Comment acknowledged. No \n43.33 Resonmend Ulat fact sheets be developed for 1998 listings that were farried \nfoM to the ZOO2 lief, indicating when they were originally listed. Agree with \nthe staff-recommended alternative 3. New fact sheets will be developed in accordance with the approved Policy \nwhen existing section 303(d) listings arereevaluated. No \nB-63 - - \n-- COMMENT SUMMARY OF COMMENT RESPONSE \t REVlSlClN \n~p \n6083.76.58 \t SuppoRS recommended Alternative 3 with one change. RWQCBs should be The RWQCB would evaluate all readily available data and infomation, No \nrequired to consida Ihelisting mmmendations at workshops or hearings. \t prepare fact sheas on all peninent information for each pomtial water body- \npollutant combination and then hold public meetings to midm lisling or \ndelistin% based urntheidentilied information. - -\nDFED, Issue 7D: Documentation of Data and Information \nAgree wth the rrcommndatlon but add a catch-all rccuon (hher Commcnl acknowledged \nConstdcratiomIlnformation lo knclude porrihlc polnts thal may not fit my of \nlisted categories \n43.34 \t Agee with the staff-recommended alt~native 2, but we advocate revising it to Comment acknowledged. \nseparate pollumts and pollution. Pollutant and type of pollution should be \nseparated \n50.2 \t Standardizing the Listingldelisting process should not be so inflexible as to Comment acknowledged. No \npreclude data, analysis, and monitoring if it dog not meet some standard \nformat. To do so would mult in a significant impad that would have to be \nevaluated and mitigated. \nDFED, Issue 7E: Data Oualitv Reauirements \n2.32 \t Agree with the mommendation. Obvious choice if data are to be defensible. Coment acknowledged. No \n43.35.60.85.76.60 \t Agree that we need to know the quality of the data. Agree with the staff- Comment acknowledged. \nrecommended alternative 2. \n51.36 \t Whether dala was cnrectly collected, analyzed and reported -is addrusedat the QAWs only manage m, quality assurancepwcsses do wt remove themr. No \nmonitoring and dysis stage, for which the draft Policy sets 'dam quality Sometimes monitoring pmgrams allow substantial m because Iheonly \nrequirements.' QAPPs develo~ed according to either the federal or SWAMP available cast effective medurer are inhaentlv variable. The aoolication of . \t .. \ngu~del~nes \t staurtin ism achuwlcdgcmnl Ulat crmr in decision makh is em-prewnt will eonlaln arruranccr against meour laboratory pmedurcs. \nsystematic crrn sourcn, exmcuon and insuwnrnl error. and data msfa and thal these ems should be cons~dncd mspmly. 1hc use of swostics \npmlocols lo pmect against transfer mn. and transcription, calculal~on. and almg with the rquiremnt of QAPPs (or equivalmr) ro the tisung Paliiy does \ninput erron. mese assurances substantially mitigate lhe possibility of opaator not create a duplication of em management. \nand instrument mor, and create a very high level of confidence that samples \nunder these mmms were orooerlv collected. analvred. and recated. The . - .. . \nappllcatlon of statlcucr in the mner prapored would dupl~salc the cnnr-\nmanagement muchantsms of QAPPI \nDFED, Issue 7F: Spatial and Temporal Representation \n2.33.43.36.60.86. \t Suppnts recommended Alternative 3. Cancur that spatial and temporal Comment acknowledged. \n76.61 \t representation of water body segments is essential information for use in the \nB-64 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nlisting and delisting pas. Support the idea that samples canbe less Ulan 200 \nmeten apan and still be considered spatially independent ifjustiIied in thefact \nshm. \n2 17 12.217 10 \t The end mull of this palrcy ulll be !ha1 water Ms shown to have excceded The Policy pmndes a mechancsm lo address Uendr la wala qualtty to asas No \nnwwnc smdards hmugh chmucal adyrts wll he easm to hrl than thore pmhlcna whac nwnac wala quallly slandards m not uaeded but severe \nwater bodies Ulalareexhibiting more severe impacts, which anoften caused by biological impxu arepresent. \nlow levels of multiple ~ollumts. \n220.2 \t If thesource of Iheprc4Iemis clear and ongoing, as it is in so many hahm and Sampling representahon canbe either over short orlong periods of time Yes \n\"winas, why should the timing of the samples prevent it horn being listed? It Requiremenu for spatial and temporal npmentation canbe found in UK Dnfl \nis unclear whaher samples can be accumulated over the years: the dran FED, Issue 7F. me sections of the Policy focused on spatial and Iemporal \nguidelines are silent; I dt find clear guidance representation havebeen clarified. \nDFED. Issue 7G: Data Age Reauirement \n2 34.8 21, 19.16. Age of data per re is nor tmponanl lheimpnant things to dctcmunc am the lhe -1 irnpomt aspecl of age of data 1s its relevance lo describing cumnl Yes \n3010.43.37.44 7. quallly and relevance to the cumnt situation lfdau score high on these counts conduonr of the waterscgmnl and its qualily. Recent data arealwayr more \n50.3.63.16 \t there is evny justification to use them even if bey areold. representative of current conditions. However, if only old data areavailable, it \nshould be used in Ule listing pnxess. The age of data requiremenu have been \nremoved fmm the Policv so Ihat all relevant data and infomtion cm be wed. \n~p ~p ~~~p \t ~p\n -\n60.87.76.63.76-62 \t California should nsuire Ihat the data and information used to iustifv a listing. . - R-nablv current and reoresentative data should alwm be used. Ifolda Yes \ndeclston arc reamably cumnr Other rwr hve such qu~rcmems and we data a all that NSavdllablc tt should be uxd aswell The data age requ~mnenu \nasscn that Ihls isanother necesrary mIhod of tnfustng rauonaluy rnla the have bem deleted rommunge ihcuse of all data and rnfamtlan \nlisting pmss. Agrees with recommended Alternative 1, although we would \nprefera shorn tlme penad such as the 7 5 year old data llmt used by nonda \nDFED, Issue 7H: Determining Water Body Segmentation \n2.35 \t Agree with therecommendation. Tnis allows better focus on problematic areas Commnt acknowledged \nand mncenIrates murces on the realuroblem \n~ ~ \n43.38 \t Agree with staff-reeonmended alternative 1 with modifications to policy The last two sentences in the section have been removed horn thePolicy. Yes \nseetion 6.2.5.6 to prevent incranental addition of segmenu to listed water \nbodies with only one sample exceeding water quality standards. \n50.4 \t The Policy should not ignore the need to consider nlated and connected water Comment acknowledged. No \nbody components or segments and the effects of mnditions fmm one segment to \nthe orher. \nW 60.88,76.65,76.64 Agrees with recommended Alternative I. Commnt acknowiedged. No \nW COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nDFED. Issue 71: Natural Sources of Pollutants \n1.2, 18.51. 18.13, lnappmpriale 303(d) listings due to legacy problem and ram1 sources arenot The Policy has been revised to remove guidance regarding impam relative m Yes \n19.20,30.7,40.19, adequately adbed in the policy. natural mm. This pmvides the RWQCBs with the flexibility Inadd, \n40.20,43.39,505, remove, or not list waters due to naml sources. Water bodies mmM \n51.98.203.1L for 303(d) listing in Ule future M existing listings mxmnnmded faremoval \nfrom the 303(d) hst due to natural sow will require review and appmval by \nthe SWRCB. \n2.36.8.7.60.89 \t Agrees with mommended Alremative 2. Agrees with staff that waten should Comment acknowledged. No \nnot be listed if the pollutant causing them to not meet water quality stand& \noriginated born natural mums \nDFED, Issue 8: Priority Ranking and TMDL Completion Schedule \nSupp me FED Alternative 2 recommendation. The TMDL pmcesr should be CWA rstion 303(d) requires Uleestablishment of a priority tanking for listed Yes \nprioritized based on the factan listed in Alternative 2 in order to result in waten and the development of TMDIs far such waters in acmrdance with Ihe \nimproved water quality listings. Further, the development of TMDLs should be established priority. The schedule for TUDL development will identify which \nlinked co thepriarity of thewater quality pmblm TMDLs will be established within lhecmt cycle and thenumber of TMDLs \nscheduled to be developed thereafter. The general intent of prioritizing and \nscheduling is to assist in work planning and to help the public and USEPA \nunderrtand the priorities for TMDL development. In developing schedules, the \nRWOCBr need to determine which TMDLs are hieher oriorities and which are ~~ ~~ \t ~~~ ~-0~~~. \nnot, but in &log soit is unncccrsvy lo identify cachTUDLas hgh, medium \nor low if the schedule lor each TMDL is crtablished. The Policy has been \nrevised to require the establishment of a schedule for TMDLdevelapment as \nsuggested in the 2004 USFPA listing guidance (USFPA, 2003b) and let the \nschedule in and of itself rdlect the state's priority ranking. The Policy has been \nrevised to drop priorily-setting requirements to be consistent with the 2004 \nUSEPA listing guidance. \n50 6 \t Pnonty ranking and the TMDL complcllan schedule ,hould rncorpmle It IS not poss~ble la ~ncorponte cffccttvcncss ofTMDLlmplrmenmon at the No \neff<cllvc implemntauon of any TMDL IhI ruse berausr theTMDL hs ye1 lo be developed \n50 7 \t Cons~deralron forpnonty should hc gnven. as appmpnalz m more thanpaa The Pollcy has knnv~sed lo mnr~der srhedulmg w3lm far MDLs when Yes \nrrngulu wJtubady if lmpa~mnl is documcnled throughout the walenhell or there could be wlcr quality bcnefiuof acttvll~es in ualashedr \nin more than one M tw segments. COMMENT SUMMARY OF COMMENT \n51.156 \t The CWA'r TMDL pmpm is a safety neI that is designed to induce action on \nwatersegmenu in which water quality objectives are not being meL As such, \nwaterregmenu should be identified and TMDh should be developed as swiftly \nas pmsible. The USWA Integrated Guidance states lhat WDLs should be \nestablished 8 to13years fmm the dale of theoriginal wamlpollutant \ncombination listing.' This is hardly an expedited schedulz but thedraft \nPolicy's pmvisions areeven more relaxed, stating in Sstion 5 lhat low priority \nTMDLE: 'will be completed in more than 5 years.' \nThe 2W2 3031d> lillables indisatcthat aaomximamv 800 TMDlm are - .r , ~ ~~~~~~ ~~~ \nrequired in Califomla water regmenu. However, aecord~ng I\" the 2002 305(b) \nrepon, only 18 haw been adopted by SWRCB todate, and only ninecompleted \nTMDLc currently amir adoption by SWRCB, OALor USWA lblack of \nadequate monit&ng also c&tribut& substantially to the delay in TMDL \ninmlemtation. &discussed elsewhere ia this letter. mbnitnine effms in the ~ ~ \t ~~~~~~~~~. -~~- ---------\nstate of Caltfomta often do not pmduw adequate data to comply with the \nrmnlmum sample s~rerequiremenu the dnR Pal~cy. let alone provide far mvlew \nof already listed segmts and devclopmt of TMDLs. This delay in \nimplementation of our water quality safety net is unjustified and threatens \nfunha deeradation in the quality of California's waten. A- with USEPA - . . \t -\nthat 'Ihe dndpiw of medium priority in 5 years md low priority after 5 ym \nneeds to be mcufied,' and lhat the rule's schedule, which lags fir behind what \nis reconmended in the USEPA Integrated Guidance, and should be revised to \nbe at a minimum consistent with theGuidance. \nDFED, Environmental Effects Section \n10.23, 10.22.51.61 \t in the event that CEQA review is mandated for Ulis rrmiect. discussion of . . \naltcmativcs (withandysls) may bring some insight to what may or my not help \nthe pmas work more cfficicnIly fmm both thcennmnmenlal objective potnt \nof view and organizational policy. \n18.54 \t The Alternatives Analysis in the FED should be revised to pmvide a rationale \nfor each alternative that is chosen. CurrenUy, the FED dexriber different \nalternatives and identifies the preferred alternative, but provides no apparent \nrationdc for thechoice of alternative. This approach does not appear to be \nconsistent with CEQA requiremenu. \n21.68 \t The statcmntr in 'Potcntlal Advm Environmental Fffecu'and the Yutenudly \nSlgnrficant Advcrx Envimnmtal Effects' arein enor if the pop& Pol~cy is \nadopted as propared, pmperly defining thewavr hdes with impanred \n-beneficial uses which need attention will be inadequately addressed. There win \nbe far fewer 303(d) listed water bodies that really exist in accordance with CWA \n8-67 RESPONSE \t REVISION -\nThe Policy and FED have been revised to include a requimt for a Yes \ncompletion date for all TMDLs. The USEPA guidance (2003a) has n~ been \nincluded that require TMDLs to be completed in 8 to 13 years bemuse future \nreaurce levels eanonly be predicted one to two yean into the fum. \nTheamcess the SWRCB used to develoo the Policv has been certified bv the No . \t ,- ~r \t~ \nKewrurecs Agency to be funcuorully equivalent tothe CEQA pmecss. The \nFED fulfills the requiwmnts of CEQA for preparation of an mvlmmcnlal \ndocument The FED discusses alternatives far eachisnre. \nThe alternatives analysis for each issue fallows CEQA requirements by Yes \npmviding the pms and cons for each alternative: the rationale for thechosea \naltemative is contained within the pro qumat. For each major~on of the \nPolicy, the FED describes how the Policy addresses the issue and briefly \nexplains why the Policy was developed this way. Brief statemenu of the \nr-n(s) an alternative was selected has been added to the prefemd altemative. \nThe analysis ofrheenvimnmmul effects of the Pol~cy foeuses on the NO \ndkffmces between existing RWQCB Insung and delisting peuca and thc \nprnd Policy and whnhcr adopuon of ihz Policy would have a significant \nadverse effect. A significant effect on the envimnknt is generally defined as \na substantial or potentially substantial advm change in thephysical COMMENT SUMMARY OF COMMENT \nNUMBER \nrequirements. \n19 5 \t The drab Polrcy should dirm the staff to revise the FED to bnng it into \ncompliance with SWRCB regulattons and the CEQA. \n50.1 \t Baseline conditions desnibed in the FED lacks evidence of current conditions \nand doer not take tnto account that ~mplementatton plans for TMDh langutrh \n51.167 \t 'IhePolicy will cause a demonsuablv hieher level of wllution with anseauent . -\nhum health and ennronmnlal impacts. Thnc effects are advcnc and \ns~gtuficanr Cmscqucntly, the FED must identify, analyze and mtlgate for \nlhem In the abrmceof such idenuficauon, analysis and mitigation any \napproval of the policy violates CEQA \nW 51.62 \t The FED fails to identify, analyze and mitigate numerous significant and \npotentially significant advene envimnmental effects of thepmjeet. The FEDW \tsummarily concludes that &re will be absolutely no impact fmm this sweeping \nfn RESPONSE \t REVISION \nenvimnmenr Using this definition, the adoption of the Policy will not have a \nsignificant adverse environmental effect because IhePoliev wrrmrises a \npmas hy wluch th?SWRCB and KWQCBr will arrrqlykth tbc listing \nrquiremmts of the CWA and in and of ilself doer not change the phys~cal \nenvimnment. In addition, wdtabodies with impaired beneficial urs will be \naddressed during the biennial listing pmcen. CWA section 303(d) addresses \nimpired water bodies. The Policy pmvides a pmcsr, adhaingtosection \n303(d) requiremenu, to document and list water bodies not meeting water \nquality standards. The Policy defmes the existence of waten that do not met \nctln.l.nl. \nSWRCB staff prepand thedrdh FED and Pohcy under the dimtionof No \nCalrfomla Water Code ssuoa 13191.3(a). The FED is incomplrancc withLlus \nsection and meets the regulatory pmgram exemFion under section 21080.5 of \nthe Public Resources Code requirements to plrpare an EIRunder CFQA and \nwith other applicable laws and regulations As such the FED and Policy \ncomply with SWRCB regulations and therequirements of CEQA. \nThe baseline conditionsconmrise the existine naetiees and amced- Yes -. \ncurrently employed by the SWRCB and the RWQCBs for asswrtngthc surface \nwater bcdles of the slatc in compltance ulth CWA rcctton M3(d) The \nbaseline is the pmes Ulatoccurred in the listing and delisting of water quality \nlimited segments in the absence of theproposed Policy. However, Ihe 6ED has \nbeen revised to include the twe of water bod\"., wUufant. and estimated area ,. \naffected that wm placed on the ltrt as a result of the baselme pmcsr used by \nthe SWRCB and RWQCBr that occurred in the Idrung and delrsung of water \nquality limited segments in the absence of the pmpased Policy. Implemmtation \nplans for TMDLF are addressed in the haft Water Quality Control Policy for \nAddressing Impaired Walen: Regulatory SrmcNre and Options (SWRCB, \n20041 \nThe adootion of the Policv will not result in human health and envimnmental No ~~~~ ~-\nimpacts and mrs CEQA requmntents by identifying the issues. andping \nalvrnauvcs and sclccung the sup&or alrcmalivc. The analysts of ~uues is \nhased on the lmpacls due tothe adoptionof the Policy. Adopuon of tk Pol~cy \ndoes not result & a higher level of $llution, wnsequ&cer hum health or \nenvimnmenfal inmacts. The Policvnrovides midance in methodoloev to be ,. - ~ ~ ~~~~~-\nused to list, not lisL or de-list water bodes. ldrnufieation and niti@tion of \nsignificant advmc impacts dur to pollulanu in watn bodies is pan of the \nTMDLdevdopment pms; ~denuficauon, analysis, and miug3uon for \nsignificant and adv&e imts will be addressed at that time.. \nThe analysis of the envimnmental effects of the Policy focuses on the No \ndifferences between existing RWQCB listing and delisting practices and the \npmposed Policy and whetha adoption of the Policy would havea significant 51.63 COMMENT SUMMARY OF COMMENT \nNUMBER \nand dramatic policy change, not even a less than significant impact.' \nPotentially adverse envimnmenlal effects aredis~med of in a series of curt and \ncorrlusoj paragraphs with noanalyses wham>r Potentially significant \nadumeennronmnul effecu are afforded only a single word of discussion -\ntheword 'None' Thae findingsare na rupponed by any evidence in the \nrecord and arein fact wnuadicted by numemus other findings and evidence set \nforth in theFED. Since thedraft Policy applies to virtuaUv even, regulated \npollulanr, and duarmnes whether disch&a of thesc poliutaniwiibe reduced \n~nthe futw, it is self cnderu that ihr.policy uiU impact ihcquantiues of thae \npollutanu bng released inlo the ennmnmnl. \nThe FED fails to identify, analyze and mitigate significant adverse impacts to \nimpaired warnays Ulat will not be listed or will be removed fmm the list. The \n~ollcy guaranlecrihat numemus impaired warn bodes will not be l~sted (or wll \nbedcl~rtedj including: wager bodla whose mpat-1 is penodlc or cpirodic. \nwatn bodes whose impaimwnt is m1. evm if the dam shows a clev wend \naver time toward the cmt uceedance of standards, walerbodies whose \nimpaimrat is supported by older data even in the absence of mare recent \ncounter-indicativ~data: water bodies in which an impairment is not uniformly \ndisuibuted in the water body: impaired watnways in which only a moderate \nnumber of samples have been taken; water badies impaired with toxic \nchemicals whose sampling das not satisfy the 'Critical Exceedance Threshold \nset fonh in the Policy: warnbodies whose impairments arenot amenable lo \nstatistical testinz; water bodies impaired bv wllution ratherthan ~ullutants: \nwater bodicr imiaired by exol!c skier: &;cr bodies impured bynalwal \nsources; and warm bodies impatred by loxic~ly whm no palluml has been \nidentified. \n51 69 \t The FED falls toadeqlwlely cons~der uld nuugate Ule cumulal~ve lmpacls of the \npol~cy Nocffon 1smade toanalyze impacts lhal may result fmm lndlvldual or \nrepeated failures to list impaired waterways. This contravenes CEQA's \nrequirement that cumulative imrraa be considered and mitieated. No effon is -\nmade in the FED to analyze impacts that my msult from individual wrepeated \nfailurrr to lisl impaired wumys when combined with ihcimpacts of atha \npolicy decisions such as therecently adopted waivers for agricultural and \nsilvicultural waste in the Cenml Valley, the proposed California Noa-Point \nSource Plan, the proposed amendments lo the Ocean Plan, the ongoing NPDES \nEnnittine-.meram or numerous other SWRCB warn oroiects. . , Likewise no ~ ~~~~~ -iffmhas been made to idcnufy. analyze or mhugalc rhe Mth impacts that \narise ham rhc rrpealed exposwe of humans to the pollutants and palluuon \nnrulting fmm this policy when combined with ok sources such as fmm air \nsources, fd sources, workplace exposures, etc. Nor hasa similar analysis of \nthe cumulative ecological effecu of these pollutants and this pollution when \nB-69 RESPONSE \t REVISION \nadverse effect. A significant effect on theenvironment is generally defined as \na substantial ormtmtiallv subsmtial adverse chance in Ule nhvrieal. , \ncnvimnmmt ubng this iefinilion, theadoporn of& Policy wiU not have a \ns~gn~fimladwre mvimnmrntal effect bemuse the Policy wmpnma \npmcerr by which the SWRCB and RWQCBs wll cooply with thelisting \nrequirements of the CWA and in and of itself dm mchange the physical \nenvimnmenL Additionallv. the Policv omvides midancem wine scientific \ndata and information lo d&umnt r&da& at~nmnt to a wa& body and \nwhether the Impact -nu placement on the section 303(d) lirL ThePolicy \nluclf does not dnmnine whether pollutant discharges wll be reduced: the \nimplementation of a TMDL deals& allocation id reduction of pollutant \nloads. \n~p \nThe analysis of the envimnmmlal effects of the Policy focuses on the No \ndiff-ces between existine RWOCB lirtine and delirtiae ~ractices and the -. -. \npmpmed Policy and whclher adoption of &policy would have a significant \nadvcne cffsl. A slgnnficanl effect on the nviroommt is gcnually defined as \na substantialnpolentially subrtanual advmc change in the physlcal \nenvimnmL Using this definition, the adoption of ihe policy will not have a \nrimificant advme envimnmenlal effect because the Policy wm~riser a \np&ess by which the SWRCB and RWQCBs will comply;ith the listing \nrequirements of the CWA and in and of itself dm not change the physical \nenvimnment. In addition, the Policy does not guarantee that numemur warn \nbodies will not be listed or will be de-listed. The Policy pmvides guidance an \nthe listing factors mentioned based on scientifically cndible data id \ninformation and omvides a nmerr lo evaluate data using a sihlatian-soecifie\" r~~ ~ ~~~~ \nweight of cndcnce l~sl~ng faclor ihePolicy provides the methodology lo \nassess all available data. 3s well as a pmcns lo valkdale dae \n'me analyslr of thcennmnmcntal ellens of the Poltollcy focuses on the No \nd~ffmcer betwem exrsl~ng RWQCB Ilnlng and debsunz mcltea and the \npmpored Policy and wh&& adoption of th;policy would he a sigaificant \nadverse effecL A sienificant effect on the envimmt is eeneraliv defined as-. ~ ~~ ~ ~~~~~~~~ ~~ -~~~~~-~, \na substantialnpotentially substantial advenc change in the physical \nmvironml. Using thlr defiruuon. Ihradoption of the Policy wiU not have a \nsignificant adverse envimnmental effect because the Policy comprises a \nprocess bv which the SWRCB and RWOCBs will comlv with the !istine \n;quirem&ts of theCWA and in and of &elf does not.&& the \nenvironment -\n~ ~ ~ ~ \nhaddnuon, in Ihealtmauves analysis far Ihe vanow issues, the FED \naddresses the impacts of listing and delisting decisions as compared to the \nbaseline wndition -decisions made without a Policy. Staff selected the \nalternative thatbest wmplia with the listing requirements of the CWA and 51.71 COMMENT SUMMARY OF COMMENT \ncombined with that of other sources been conducted. This conmvenes \nCEQA's requirement that cumulative impacls be identified, consided and \nmitieated \nThe Policy does not makeclear what legal significance the FED will have after \nadoption of the policy. Among the measures ser forth in IheFED which do not \nappear in the Policy an:a weight of evidence alternative listing ~rocedun: a \nieieht of evidencea~~roach .. cause - ti determine themlluIants(r) that& \ntox~c~ty.a pmcedure for listing numentr uhkh allow the use of 'lmdels. \nwtenufie l~leralm, data cornpansons, lo hislotical values or to similar but \nunimpacled slrums, Basins Plan ob)ecuv?s, other wienufially &faribl< \nmethods' in making a listing decision; a procedure, which allow 'both \nquantitative and sualitative data and information in the evaluation of nuisance.': \na case-bv-case in.mretive amroach to the listine of sedimoltation omvidine .. - .~ \" \nthat 'gcnml guidellnes to trigger Ilsling' and stating that a mler body ean be \nllrled if any oneof the following condruons arc met. bcncfinal use lmpai-I \ncaused by ina'eased sediment loads, evidence that beneficial use impacts an \ncaused by sediment', nuisance caused by ~edimenIloads, or wceedances of \nturbidin obiectives. The FED reveatedlv describes a robust alternative listine -\nprocedure ilia1 nlles on 1wetghl bf the evtdmce Vst. The Policy doer no1 \ncontatn such a produn. Lnslcad secuons 3 1.1I and 4.10 of the Policy set \nforth a pmedure that is no less reruictive than the binomial hypothesis \nstatistical test The procedure excludes qualitative information and other non- \nauantitative 1001s. The weight of evidence lanrmaee in the FED -- ao-. . to be \n60th inaccurate and mislcailng. To the cxlenl these maswa are no1 a binding \npan of the Policy, a decision by SWRCB based upon thr FED ~olatesCEQA. RESPONSE REVISION \nestablishes a standardized listing approach. This Policy applies only m the \nlisting pmeess melhodology used to comply with CWA don 303(dX The \nPolicv is not intended to be uxd to detarrdne conmliance with anv oem6l m.. \nwaste dtwhargc nq~urrmenl pmnuoo. establish. renr arcfine any warn \nqualtly objecove or benefiaal use. or vanslale narrauw watR qual~ry \nobjectives fw thepurposa of regulating point Y)UTC~S. The adoption of the \nPolicy has no impact on health impacts hwnthesourcs cited nor dm the \nadoption of the Policy mull in sological impacts: thepotential for lhgetypes \nof impacs will be addressed during theTMDLdevelopmentpmess.The \nadoption of Ihe Policy wiU not result in a cumulative impae and under CEQA \nguidelines would result in a de minimus impact \nThe draft FED supporn the Policy by exploring various alumatives, providing No \noptions and recommendations, and evaluating the envimnmmral impacts of the \n~ilieyzuidelines. SWRCB regulations reguik Ihalsuch a do cum en^ \nmuikimt to a CEOA docunint. acco&v a wlinr omwsed for &tioh ... ... \nIn addiuon lo ruppoming thePol~cy adopuon procar, the €ED pronda the \nrallonale for pmvlrionr ofthe Policy and in someeasa. mmdekulcd \ninfoml~on logu~dr thefulwe implmtauon of rhe Policy \nThe mess the SWRCB used to develw thePolicv has been certified bv the \n~eswrces Aeencv to be functionallv miivalent toke CEQA omcess. fne -, . . .. \nFED fulfills the rcqurrmenls of CWA for prrparation of an rnnmnmlal \ndocwnmt. The ED discusses altrmalives for each tsrue \n'Weight of evidence' and'multipie lines of evidence' as used in the dranPolicy \nareacceotedumds in the scientific literature kc..Gxd. 1985: Smith et al.. . -. \n2001 ), and mtherefore dircurxd and pmmorcd accordingly in thedraft FED \nand drah Policy (see Sso'on 3). As a first ncp, in implemling the Policy \nthese approachesare mind m be used in conjunction with the binomial test \nfor numeric sample data. Tne use of hypothesis orsignificance testing is one \nwav to weieh evidence (Good. 1985). The draftPolicv also allow RWOCBs \nlo iecom&nd lirtlngs dellsings bgsed an the situa;lon-spccific wight of \nevidence factor. \nThe FED inacculately describes the project and is mitigation measures. This is \nmisleading to the public and defeats the cenM purpose of the statute. RWQCBs will need to document all listings and delisting decisions in fact \nAdditionally, the failure lo incorporate these measures into the policy sheets and SWRCB shall delennine if there is substantial evidence to list or \ninvalidates the FED'Sfindie of no sienificant imaae. Moreover man\" of delist. ~~~~~ ~ ~~ ~~ ~~~ -- ~~.~~-~, \nthere policy pmnrionr conrutulc mrlgaoon measures, whl* lesxn the poltcy'r \nlnpact on the cnnmnrnent CEQA mandaln thal such requiremnb be carried \nout contemporaneQusly with thepmjeet The new ration in thc ~nlmduclron of the Pol~cy presents therleps far \nimplementing the Policyls weight of evidence aiimach The ap&ch \nincludes the process for data and information pnpmeessing, data and \ninformation noeessine. and combinins lines of evidence. The Palicv also has \" -\n ~ ~ \nwclght of ckdenrc IlrUng and delisting factors xhal allows RWQCB'IO ma kc^ \nrccommendauons aslong asRWQCBs junify as reeonwsllalim by: COMMENT \nNUMBER \n51.77.51.7L58.16 \n55.1 \n60.91 \n102.8, 105.7 \n105.2 \nW \nW \nVI \ncP SUMMARY OF COMMENT \nThrelativeease with which we found these waters belies the draft Policy's \nassertion that \"no issues [in the d& Policy] were found to have the potential \nfor significant advene enrimmental effece\" and illurmtes the need for \nsignificant modifications to thePolicy in order10 ensure fhat similar, yet- \nunidentified waters are not left behind. \nSWRCB has complied with the State Clearinghouse review requirements for \ndraft environmental documents, pursuant to theCEQA. \n'This section of the FED will also need to be revised. Recommend that you \ncarefully consider all policy recommendations that you receive and make \nrequired changes to the FED. \nAll segments of thccoal~t#on am potcnltally impacted by the dnlt Poltcy. \ntncludlng construcUon cmployecs who rely on jobs in the Slaw. landowmen \nwithin the State's boundary and potential builders attempting to satisfy the ever-\ngrowing demand for housing. \nThe propased policy will violate antidegradation requirements by allowing \nsignificant degradation of state waters. The pmposed binomial model will over \nfounts em and allow far significant lack of infnmation about impaired \nwaters. It will therefore allow impaired watm to continue to degrade rather \nthan identifying them for clean up. \nIf the RWQCBs and SWRCB implement a TMDL for every listed wata body, \npollution will be reduced when impaired water bodies are listed. 'bt sounds to \nme like a significant adverse envimnmental dfeet. \nB-71 RESPONSE REVISION \n--Providing any data or information supponing the decision: \n--Desnibing in fan sheets how the data or infannation affords a rubstantial \nbasis in fact which Ule dsii~on can bemnably infw. \n--Demonsuatine that the weieht of evidence of Lhedata and infomation --\nindicate attainmnt starus of the wata quality standard; and \n--Demmsmag that ihe appmach uwd in seienufically defmdbleand \nreproducible \nTheanalysis of the envimnmental effects of the Policy focuses on the No \ndifferences between existing RWQCB listing and delisting praeties and the \nom& Policy and whck adoption of Ule Policy would have a simificant \nid- effect.-A significant effst on the envim&t is gdy defiaed as \na substantial or potentially substantial adverse change in the physical \nenvimnmnt. Using this definition. the adaption of the Policy will not have a \nsignificant advene envimnmntal effect because the Policy comprises a \npmesr by which the SWRCB and RWQCBs will comply with the listing \nrequirements of theCWA and in and of itself does not changeUle phyxical \nenvimnmnt \nCammentackmwledgcd. No \nAll public comments on the draft Policy and FED have b&n carefully NO \nanalyzed. Changes lo the policy and FED wen made where merited. \nThme a notlung in the Pol~cy that nqulres pmpeny to be used ma cmam way No \nor pmhtbru pmpmy fmm king developed Adoplhon of the Poltcy would not \naffect housing or population growth, \nTheListing Policy does not allow degradation but rather identifies which No \nwatm do not meet standards, the pollutants contributing to or wing the \nstandards excgdance (in most cases), which of these waters still need TMDLs, \nand the schedule fordevelopingTh4DLs. \nThebinomial model daes not overcount amn but rather identif~es theamrs \nthat may be made given excgdance frequency, sample sire, and other factors \ndated to the decision. \nIt is true that the redunion of pollution and associated management measures No \nrequired forthe implementation of a TMDL may represent a significant \nenvimnmental impact. However, the significance of the impan is reviewed \nduing the implementation of the TMDL: pollution is nn reduced when an \n -- COMMENT SUMMARY OF COMMENT \n105.8 \t To imrrlement the Policy. a statement of ovenidbe considerations iSOC) is \nrqurid me SOC is deslgned lo reveal exactly #he ktnd olpohcy assumpl~ons \nbang made in thc draft Poltcy-lhat econormc consrquenar anmore ~mpomt \nlhan ccolag~cal consequences Thc Pollcy should rml#galr. thlr r~gntficanl \nDraft Policy, Section 1:Introduction \n10.3 A consistent listing process should be sought for many reasons \nincluding but not limited to: \n-economic efficiency, \n-reliancz \n-mr limitation. \n-reasonable confidence levels. \nThese goals will all go down Ule drain if the policy fails to address the \noverriding goal of pmtecling and rehabilitatingthe state's wata re~~urcw. \nPolicy must take into account vast diffaences in water bcdies, pollutants, \nbiologic hetion, chemical interactions, drainage area, geology, and long term \neffects on these resources. btine a consistent mocess (oolicv) with all of .. .. \nthere va!iables u difficull, a1 besrThc gml of cksistmcy should na l~mit \ncffeclivcnas of pnwess lo acsonmadav nppmpnale llsling of impaired walm. \n1x21 \t Language regardng how the Pollcy 1% not to be used in s~aon I should be \ndelcled 7he purposeof the Pollcy isalrndy dcscnbcd, so 11 is unnecessary to \nidentify how it shall not be used. \n23.3 NRC recommendations arebased on a recognition that listing decisions may be \nW based on outdated or inappropriate data. \nW 40.8 Il is unclear how my policy elements will actually be interpreted and applied RESWNSE \t REVISION \nimpaired water body is listed. hpcu wiU be-\nimplementation p-. The implementation of IkPolicy ifself does not \nresult in a decrease in pollution in a panicular MIB body, hence, Ik Policy \ndoer not result in a significant envimnmtal impacL \nSection 21080.5 of thePublic Resow Code omvides chat a neulatorv -No-. \npmgramof a sate agency shall be eanfied by &c bcary for Raouna as \nbelng exempt from the requ~remnu for prepanog EMS, Negative Drrlarauons. \nand lnntlal Studtes ~f the Ssmcary finds lhal heprogam mu themuna \ncontained in that ccde section. 6edraft Policy Ulis exemplion and, \ntherefore. is not rgluirrd to noa are an EIR which would contain the statement . . \naf ovmndtng cons~dmlrons A rtavmnl of avanbg cons~deraoons is no1 \nnded because thm anno tmpacu Funher. heFEDanaly-m al-nva for \neach of the identified issues and has sdected the superior alternative, per \nCEQA requiremenu. \nThls lnlomwllon snccasuy hcca~se the provrslans of the Polley could No \npa5slhly be used for purposes other than dwcloptng the sectton 303(d) last. I1 \nis, for example, inappropriate to use the provisions of the Policy in order to \nvanslate narrative &.&quality objectives into numeric effluent Limiu or \nreceiving water limiu using the Policy. \nComment acknowledged. \t No \nAll elements of Ule Policy will be implemented by SWRCB and RWQCBs. No COMMENT SUMMARY OF COMMENT \nNUMBER \nby SWRCB and RWQCB rlaff because they arenot explained cldy in the \ndraft policy. The policy is inconsistent in its description of assessment methods \nas requirements or as didonary guideline. \n43.42, m.19, \n60.18,60.17,76.7, \n76.8 Sect~on I should be expanded byno more thana page to pmvide a more \neomplele explanation of thelegal and regulatcny hameworL for 30Nd) listing. \nParagmph 2 of Iheinuaduction should be expanded to provide more thomugh \ndexriptianr of bath CWA section 303(d) and 40 CFR 130.7. \n53.5 \t The introduction to the Estine Poliev should slate that the SWAMP mer ram is \". \t . -\nintended forgeneral ascssmenl of mewide water qual~ty. SWAMP s \n-dated as an ambient mnntonng pmgram and lhe Repon la the Lcgtrlarure \nthat lad !he foundation for SWAMP rpsrifically directs lhat RWQCBs shall not \nfocus SWAMP Nowa exclusively on sites with known or suspected \npmblem. Listing under thcproposed Listing Policy guidelines will require \nadditional monitoring resows Ulat annot currently available thmugh \nSWAMP. \n76.9 \t The lnocducl~on should also rnclude the staenknt from the Kot~ce of Publtc \nHearing lhal specifies that the Senlon 303(d)ltrt must include water quality \nlimitcd rcgments, asswialed pollurants. anda pnanly ranking of the warm for \nthe purpose of developing total maximum daily loads (TMDLs) in the next two \nYears. \n222.1 \t Proaclive approaches need to be used by the cities of the dischargers rather than \nspending the time to go back. We hape you arenot going back m the 1998 \nlisting. \nDraft Policy, Section 2: Structure of the List \n1.1. 19.6 \n5.7,7.8,7.4,7.2, \n7.3.9.2. 11.4, \n11.6, 12.4, 17.1, \n18.65, 18.50, \nW \t18.22, 18.96, 19.4, \n22.2,23.7,24.4,W 25.6.25.7.25.5. Thedtst~nctm belween watm lo be placed on the'watcr Quality L~rmted \nSegmmts Category' (section 2 I) and mlas lo be placed in the Enforceable \nhogram Category (wcuon 2 3) is not clev and seem crmular. \nSvangly suppon the concept of dual lists, and encourage the SWRCB to re-\ninstate the use of dual lists in its final listingldelisting policy. Use of a planning \nlist wonld be appropriate for impairments with undetermined causes, for use \nwhen insufficient data exist to determine a water body impairment status, orfar \ncases where water quality standards may be inappmpriate. RESPONSE \t REVISION \nThe explanation of the section M3(d) listing process is mtained in theFED. \nBrief descriptions of senion 303(d) and 40 CFR 130.7 have been included to \nenhanec clarity. Repeating large portions of the CWA or federal regulation is \nnot necesrary and may not be in compliance with APA section 11349(D. The \nobjective of lhepolicy has also been expanded lo eahance the description of \nSWRCB'r intent Yes \nSWAMP data will be used to help implement the Policy as will thedaLz fmm \nmy ollrr monltonng l% rtalemrnt doesnot clarify the sefuon \n303(d) list requirement. dw~snon mles, or implemntauon procedures presented \nin the draft Polncy. NO \nThe dnll Pollcy dexnbes cxpltcilly the decisron mles and procedures to be \nused for placemnl and removal ofwalm horn the sccuon 303td) lisL The \nslalemenl would be dupl~cative of descriptions already contained inlhe Policy. NO \nThepmeesr proposed in the drah Policy is very different than the 1998 p-s. NO \nThe Pollcy has bccn revised: the Enforceable Ropm Categoty (section 2 3) \nhas hen defined and is now mcumpassed in section 2.2 WalR Quallly \nI.muted Sections Bring Addrased category which also includa MDb Ulat \nhave been developed and approved by lhe USEPA Yes \nThe focus of the Listing Policy is to pmvide the requirements for the \ndevelopment of the saion 303(d) list; guidance on other lists is not included \nin Ule Policy. The Policy has teen revised m focus on those waters still needing. \nMDLs and identify lhose watem where TMDb or other regulatory actions \nhave been completed in all cases but one, the Policy calls for the identification \nof thepollutant that will become the focus of the WDL. Federal Rgulation \nallows fordevelaping TMDU for the identified polluranu wing or expected Yes COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n28.2 29.2.29.15, to cause water quality standards violatiom (40 CFR IM.7(bX(4)). lk \n38.3.38.7.39.2. exception is toxicity. The definition of aTMDL (40 CFR 130.20) allows for \n40.25.43.54. 1- 'IMDLF to expressed in of dthsms per time, toxicity orother \n43.55.43.43. \n43.46.44.3.47.7. \n47.8.47.1.56.7. \n8.20 \t Assessments based on narrative smdards or other qualitative assessments \nshould be added to the list of excluded assessments. The Policy should allow for \nlisting only where Ulae is clear and convincing quantitative scientific evidence \nthat h m activity hhas caused imi-nt bt canbereasonably rmedied. \n14.7,18.12,18.62, \t Recommend that the policy should not dexribe the actions to be taken as a \n20.20.20.23 \t consequence of listing. The dnn Listing Policy is not consistent with this \nrecommendation. The303(d) list would include oriorities and schedules for the . . \ndevclopmcnt of 7MDIs for all listed w3m TheEnfmcable Ro-\nCalcgory spofier the rypes of acuonr that must take place for walm lo be \ncomnded an Enfmeablc Program. 'mcse rcqumd 3rUons may be in conflrct appropriate measure.' In orda far ThfDLs m be expressed in terms of mxicity \nit is necessary forTMDU to be developed for toxicity. Thedraft policy aUows \nfor the listing waters for toxicity if the pollutant is know or UM. \nThe section 303(d) list now has two categories: Water quality limiw ssgments \nand those waters not dng standards where the attainmmt problem is being \naddressed. Waters without adequate infmmation or that are clean would be \nacknowledged in fact sheets but no judgement would be made on their \ndirpasition. This infmtion would be used in the development ofthe sstion \n3050) npan \nFed4 regulation quires that narrative warn quality standards be evaluated No \nand that warn be placed an the seetion 303(d) list if these waters exceed these \nnanative standards. \nThe appropriate response can and should be developed afferthe water bady is Yes \nlisted. b is also appropriate that if the SWRCB and RWQCB eandelennine \nthe aoorontiate action at the beginnine ofthe - ~locess, lhese oroccsses should -\nbe a~idweh to continue wthoul an interventnistep to delrm$nc what action ir \nnscssq to address lhepmblcm ThePolicy slmuld requrre the ~dentification \nproblem 21 lhr. lhsung swge and, UDthe crlmt posslblc adom Ular address - - - COMMENT \nNUMBER \n18.58 \n18.92, 18.94. \n18.91.42.3 \n23.1,H.l. 28.1, \n29.1,39.1,49.1, \n59.1.71.8,71.9, \n207.1,211.1 \nW 39.9 \nW 43.41.-SUMMARY OF COMMENT \nwith the haired Waters Guidance being develod. \nRammmended that the listing policy shwld address all assessed surface waters \nnot attaining wara quality standards. Water quality standards include numeric \ncriteria, narrative criteria,beneficial uses. and antidegradation considerations. \n'hedraft Listing Policy is not consistent with this recommendation. The draft \nListing Policy would fail to identify wata quality pmblems related to invasive \nspecies, habirat degradation, flow modification, or other non-pollutant sows \nOnly thore waters not meeting standards due to pollutants (cg. pesticides. \nnutrients, rediment, etc) would be identified \nThc TMDL Roundtable recommends that the 303(d) lirt should be an all- \ninclusive list of Impaired waters and not just a list of those waters USEPA \ndetermines to need a TMDLs. Establishment of an all-inclusive lirt of impaired \nwaters include waters that do not currently meet water quality standards. \nAttainment of water quality standards is the only factor that is used to determine \nif a water should be listed. If a water is not attaining water quality standads, a \nsepmte and subsequent analysis is needed to determine the most appmpriate \nregulatory remedy to address thc impairment. Determination of the appmpriate \nremedy is not pan of the listing pmcess as there is typically insufficient \ninformation to do so. \nFully suppons SWRCB's goal of a standardized appmach for listing, consistent \nand statistically-valid data evaluations, requirements for data quantify and \nquality, andimplementationpmvisions. \n'hemost recently completed section 303(d) list should form the basis for any \nsubsequent lists. \nThe current draft policy reverts back to considering the 303(d) list a list of all RESPONSE REVISION \nthese umblems. It seem to be a dwlieation of effon to develop a TMDL or to \neven &I the TMDL development brocwif an existing program,or \nenforcement action uill completely address the water quality pmblrm \nThe Policy,has been revised to allow RWQCBs to detemdne if aregulatmy \nomeram can be used to addmr a wllutant-related waleraualitv ~mblan \nCreating an 'impaired waters' lirt goes beyand the requiremmu of state law in No \ndeveloping the listing and delis- policy. SB 469 quires theSWRCB to \noman euidelins to be used bv the state board and the rreional boardsfor the 77 u -\npurpose of lrsung and dehrung walm and dmlaptng and tmplcmung the \nTMDL pmgram and towlmaxmum dally loads pursuant lo s~uon 303(d) \nDeveloping a mter list of all pmblems in state warn would be a difficult and \ncontmversial task that would reach far beyond Ulescopeof rheTMDL \namaan Federal reeulation renuires slam to develoo a liSt of waters that do . -\nnot mrt water quallly standards and whmTMDLs atsnll needed The dnh \nPol~cyaddrases wlen ~mpacted hy pollutants lhal do not meu walcrqual!ty \nrlandards and wi~mTMDls arc rttll needed The Poltcy also qmlrrung \nof waters where standards arenot met and a TMDL has been completed or \nanotherDmmm is available to correct the identified wllutant related uroblm \nThis recommendation is very similar to thestructure of the section 303(d) list No \nas adooted in 1998 and is included in the FEDas onealternative. The 1998 \nl~rl~ncludedall walen ht wm tdcnttfied as no! merttng standards The \nexpenauon a1 that lmews ht the RWQCBs wuld dcvclop TMDLs for all \nwaters on the 1998 bn. Many of the l~sungs are not amwble WTMDL \ndevelopment for a vatiefy of iasons including the standards exceedance not \ndue to a pollutant, additional research and monitoring is needed to identify \npollutants causing adverse conditions, etc. \nThis recommendation also gms beyond the -date of SB 469 which requires \nthe SWRCB to develop a listing and delisting policy for the purposes of \nimolementine the CWA section 303(d). This recommendation would erne a \nlisiof all problems not just those required by Ihesection 303(d) and 40 CFR \nnn7 \nComment acknowledged. No \nComment acknowledged. No \nThe pmpased list srmcture is predicated an the assumption that if water quality No COMMENT \nNUMBER \n43.45.43.56.48.4, \n49 2.58.2.60.25. \n6016.60 21. \n60.10, m.13, \n60.L1,60.12, \n60.14.61.4.76.1 1, \n76.6.76.5.2023, \n207 19.21 1.3 \n51.19 \n56.8 \n60.8\nW SUMMARY OF COMMENT \nimpaired waters, ratha than a list of waterquality-limited segments stiU \nmuirine TMDLs. wrruant to 40 CFR 130.7. and that two of Ule semte lists \npmpmc;i in the JUI; drah are now nnappmprialely ronridued pan oithe 303(d) \nIN. We quest that tkSWKCB adopt a Ilrting pohcy that IS generally \nconsistent with USEPA's Guidance fn 2004 Arras-!. listing, and \nReporting Requirements Pursuant to Sections 303(d) and 3050) of the Clean \nWater Act. No water segment should be listed on the 303(d) lin udess specific \npollutants areidentified. \nThe revised draft wliev aooean to have abandoned the conceot of an ht-ted . . .. ~\" ~~ \nWatcr@al~ly Repon consistent with Ulc 201 EPA mmnardum that pmwdn \ngutdance for integrating ihedcvelopmt and rubmislan of Section 305(b) \nwater quality repons and Section 303(d) lists of impaired wtm. Theuse of \ndtiple assessment categories July 2003 haft Poliw was Consistent with EPA \nguidance and would havivmvided a much neededn$hanirm for focusine \nappmpnate resources and ittmtion an thc Stater watur. Because mour& are \nlimited, cort~ffoct~ve man must be used to address rlmdards that arcnot met. \nThe Stale must list waters impaired by 'Pollution.' \nSection 3.1 of the drah Policy similarly states that water segments for which \nstandards exceedmces reflect 'pollutian'(e.g., 'physical alteration of the water \nbody that cannot beconmlled') shall not be vlaced an the 303(d) list This \nporlllon s re~tmled in Sectton 2 1, uhch llnuts llstlng to watm lmpamd by 'a \npollutant or pollutants ' Wed~ragrec wth thlr pmpoosllon, and malntann thP \nwater bodes that are~mpanred by any soum of polluuon must be llsled Tlur \nposition is suppnted both by the plain language of seaion 303(dXI)(A) and bv \niegal opinions &terpreting it, andhas b-subfled by the RWQCBs as weli \nin testimony and elsewhere. \nThis position is also supported by the NRC, which found that the TMDL \npmpm'should encompass all sarra~, both pollutants and pollution, that \ndeterminethecondition of the waterbody.' The NRC found this step to be \nimnant because'advities that canovercome the effects of 'wllution' and \nbnng about waur body restoratton -such ahabttat mstant~on and channel \nmodlilcatton 'should not be excluded from cons~derauon dunng TMDL plan \nimplementation.' \nUnclear what will happen to waters that arecurrently listed an the 2002 \nMonitoring List \nTheDecember 203 draft is not consistent with 40 CFR 130.7(a) and 40 CFR \n130.70). which specify fhat theState isto identify those Mter 4ualiN limited \nsegments still reqhrin; TMDk It is for this reason that USEP~S &idance \n(2003b). separated waters Ulat are'impaired or fhreatened and a TMDL is RESPONSE REVISION \nstandards arenot met, the exceedance is due to a pollutant (the exception is \ntoricitv). and a TMDL is still reauired.then watm should he old on the ~ ~ ~~~~~ ~~ . . ~ ~~~~~-~---. ~ 7 ~ ~~~ -~ \nsKu& %3(dl list. If smdards annot met and a TMDL has been corrplacd \nor therearcother cleanup program addrasing the pmblem thm a TMDL is not \nneeded. SWRCB iscomblnin~ Ule4A. 48, and 5 Catceories wnded in \nUSEPA mi- (USEPA. &b) huse water standardsare not \nmet Wh& standards ace met aRer rmplemmtat~on bf a k~or 0th-\nprogram these wales wll be mved fmm thc secoon 303(d) llst \nCalifornia is required to comply with therequinments of CWA seetion 3050) No \nas well as the requikments for section 303(d). The draft Policy and CWC \nsection 13191.3(a) quire SWRCB to develop guidelines for listing and \ndelisting related to the section 303(d) List. The Policy is namwly focusedon \naddressine the section 303(d) list reauire-ts. SGCBis still-bund bv \nCWA to &loo the sectioh 3056) ~DOR me USEPA miuidelines for ~~-~~.. ~ ~ -~ \n~ ~ ~ \ndeveloping the hO4 section 303(d) lid and thc integrated water quality rcpon -- \ncan be us& when SWRCB develops the section 30S(b) npon. \nThe Slate must lhsl warus for pollutants in comphanw u~th 40 CFR 130 70) No \n~nonier to tdenofy and rhedulr TMDLs for wala qualtty Innuled segmmls \nsl~llrequnng TMDIJ USWAGu~dance (2003a) holds that 'pollunon' \nshould beplaced in separate categories horn those ktasthat need \nTMDLs. This Policy is consistent with that guidance from USEPA. \nThe Listing Policy does not limit listings to panicular pollutznf sources. \nRather the policy quires listing of all waters that do notmeet standads due to \noollutants (the excation is loxicitv). Pollution' like habitat modification. flow \nksuietionr, etc. shduld not be inci\"ded on the section 303(d) list. \nTheinformaion on the 202 Monitoring List may be used to develop the No \nsection 3050) repon. \nAll water quality limited segments not meeting water quality standards still NO \nrauirine TMDLs should be laced on the section 303(d) list in accordance \nwik the-policy and in compkance with 40 CFR 130.7(a) and40 CFR \n130.70). If toxicity is identified, the water will be placed on the list whetha COMMENT \nNUMBER SUMMARY OF COMMENT \nneeded' fmmMher waters that are 'impaired athreatened but a TMDL is not \nnealed.' \n210.3 When listings anevaluated, maybe rome waters may comeoffthe M3(d) list \nin cases where impairments are underermined, whether cause of impairment is \nunknown, or in cases where data in insufficient in order to detsmine if an \ni-ent exists. Thosearethe reasonstoestablish a monitoring list. Waters \nfar where there is thisrime of uaeenaintv should not be on Ihe 3031d) list. \n217.4 One of our concerns is that all tw often the current appmach results in sm of \nan awroach of when in doubt. take it out or don't list the water bod\" at all. \n~ndkc example that 1 heard, mt has ir much better lhan a warch (st \nappmach. whleh wll never lad to a cleanup, I can't lmagnne any appmach \nwhere anything an a watch list would actually get cleaned up. \n221.5 This draft of Ule policy is much impmved over the previous one bemuse there is \nless lists. There are two lists, the 305(b) and the 303(d); the 305@) is the \nplanning list \n221.6 If Ulen were a planning list, you might tice it the section 13267 list because it is \nthe only place you are going to get the resources to get the sample counts. \nDraft Policy, Section 2.1: WQLS Category \n60.6 \t If specific pollutants have not been identified, how can the SWRCB certify Ulat \na water seemt is not emected to meel aoolicable wateraualitv standards. even -\t .. . . \nafter appllcatron of appltrable whnology-based cmurnt I~rmwt~ons~ Funher. ~f \nwe do not know thepollutanrs wuslng the impa!ma. we cama know the \napplicable technology based effluent limitations. \nDraft Policy, Section 2.2: TMDLs Completed Category \n207.22 \t Recommend that the California Impaired Water List contain a TMDLs \nCompleted List consisting of water quality limited segments far which TMDLs \nhave been comoleted -. \nDraft Policy, Section 2.3: Enforceable Program Category \n17 2 \t The Enforceable Pmpm Category should be separate fmm the soellon 303,dl \nllrt Separation fromthe 303(d1 llst acknowledge that all-ttvc pmpm arc \nan acceptable way to addnss impaired water in a timely matter without the need \nto devote additional resources to TMDL development. RESPONSE \t REVISION \nthepo1Iutant isidentifiedoram. \nThe draft Policy is focused exclusively on the development of the section No \n303(d) list. SWRCB is nM precluded from developing a mnitaing lirt aspart \ndthe development of the CWA section 3050) repon. \nComment acknowledged. \nComment aclcnowledged. \nComment acknowledged. \t No \nThe Draft Policy requires the identification of the pollutant prior to listings No \nmade on the 3031dl lirt. with the exceation of toxicitv. \nThe Policy has been revised to focus on those warn still needing TMDU and Yes \nidentify those waters whereTMDls are being addressed either through other \nremlatm actions ora TMDL hasbeen &veld and aamved bv USEPA. -, \t-- . . \nThe Pollcy hu hem revused to rncludc a catcgory that allows fwatmnment of Yes \nthe watcrqual~ty standard lhmugh pollut~on conml reqluMvns akhm \nTMDLs. COMMENT SUMMARY OF COMMENT \n41.9 \t The Enforceable Program section of the Policy (Senion 3.3) should be moved \nand instead addressed solely in the Implementing Policy section. Suppcm the \nEnforceable Programs approach pmted in Ule documents, but believe it is \nbest to address this imponant issue in a single document to avoid confusion and \ndiffaing iotapretationr. \n44.16.76 4 1. Legacy pollutants should be addresrcd hugh rom other enforceable pagram. \n208.2.208.4,213.8 \n51.10 \t The Enforceable Promam list still remains in effm an 'off-m' list that must \nbe ~ntegratedcompl&ly into the 303(d) lts~ Section 2 of thedraft Policy \nmaker the Enforceable Pro- list a mbsct of the 303(d) lin. \nThe FED makes clear Ular'the ininlent of the draft Policy is to allow impaired \nwaters on the vamdY defined and often unenforceable 'Enfomable' M m \nlirt to rpecifical$ avoid TMDIs. In effect, then, there watas arenot 'lis-k \nwaters, a pint Ihat must be comted. \n51 11 \t Stmngly oppw SWRCB's proposal to crealc the Enforcable Rograrn Its! for \nthe iolluwlng reasons \nThere is absolutely no basis under the CWA for failing to list any impaired \nwater body, as that term is defined unda section 303(d), on the section 303(d) \nlist and preparing a lUDL far that water bady. The proposed list will therefore \nsetionsly undercut the state's TMDL program \n51.12 \t Stmngly oppose SWRCB's propal to create the Enforceable Rogram list for \nthe following reason: \nThe pmposed Enforceable Pmgramlirt is inconsistent with the plain text of \nsection 303(d). Section 303(d) emslv reauires each State to identihe waters . . \nwithin it% hou\"d-mcs fur whj&'&efflucnt l~mlalionr nqutred by skuon \n301CbXI XA) and sectim 301(hKIXR) of this title arc no1 slnngcnt enough to \nimplement any wur quality standard applicable to such waters.' 33 U.S.C. \n91313(d)(l)(A). Thus, waten areto be listed, and mDLs developed, \nwhenever the effluent limits described in section 301m)(lXA) and (B) are . . .. . . . \ninsufficient to atah and maintain water quality standards. \nIn conuavention of the dear dictates of the CWA, staff have proposed to \nexclude impaired waters fmmthe senion 303(d) list for a variety of improper \nreasons, including the alleged availability of a remediation planning d&uments, \nB-78 RESPONSE \t REVISION \nThe Enforceable Rograms component of the section 303(d) list has been Yes \nrevised. \nThe section 303(d) lia, addresses warm Ulat do nrn meet wur plality NO \nsundads and idmlifia the pollutanl(s) that are the likely caw of the \nstandards uceedance. The problems identified on the wetion 303(d) list \nshould be addressed by mechanism that most eaJily and ccmpletely address \nthe problem. If legacy pollutants arebater addressed by another program then \nthey should be addressed that way. \nThe Enforceable Prowm fomoonent ~ ~ ~ of~ the section 303(d) list T - ~ ~ . .-has been Yes \nrevised and 8nforporated unto the Water Qdallty Ltmled Segments Being \nAddmsed category and acknowledges when pollullon contml requimmnts are \nreasonably expected to fir the identified problem This seetion of the list is not \nan off-ramp because the waters will be addrzssed by the regulatory program \nidentified bv the RWOCB and within a saecified tim fram ~ ~~~~ ~~ \n. \nThe Enforceable Program Category has bur, revlxd All waters in the Wata Yes \nQuallty Ltmted Segments Rcmg Addressed sectlon of Ule lhst are on the \nsection 303(d) list. \nThe Policy has been revid, waters in this category annow included in the Yes \nWater Quality Limited Segments Being Addwed Categoryof the section \n303(d) list. As certified by RWQCBs, waters in Ulir new category will have \nprom in place to add- the problem These programs should be allowed \nto be imolemented. If these orowms do not wmk within the adorned time . \nframe, MDLs should bedeveloped and lmplcmmted. Watm ~nthis category \nare already on the 303(d) list. \nUSEPA guidance (2003a) allows waten to not be listed if a program is \naddressine the water aualitv oroblem The Policv eoes bevond thisbv -. .. .-\nrequiring waters to be placed on the section 303(d) list. COMMENT \n51.13 \n51.14 \nW \nW \nm \nSUMMARY OF COMMENT \nunenforceable Nonpo~nl pollul~on best mgemmt practlm. slam water \npermits. and enforcmMl actions. \nThedraft Pollcy is pmposing hat the exa\"seof enfmemnl prcrugatlva can \nconsutule a basis nci In Inst an impured warnway. This pmposcd 'out' rs \nbeyond the scope of sstim M3(d). \nSimilarly, SWRCR has pmpmed lo dc-Inn or has refused to l~st seved wata \nSegments for hash bared on covrragc by munietpal st- water pmm. Ye1 \nagun, th%s excepnon excctds the languagc of the CWA. \nMore disturbingly, the draft Policy pmpoasto place on an Enforceable Ragram \nlist impaired warn for which no enforceable program exists! NOM of thme \n'iustificationr' for failing to list impaid waters can be squared with the statute. \nStmngly oppose SWRCB'r pmposal to mate the Enforceable Rogram list for \nthe following reason: \nThe language of rrcuon 303td). uhrn read m the overdl context of the CWA ir \nwll as secl~on 301. clorly rndrcalcr that Congress rnlended he NDL program \nto coexist with other enforcement and clean up program under the Act. Tkm \nis no indication that Congress intended the operation of the CWA as a whale to \ndisable any rpefifie element of the Act. Yet,this would be the effect of the \nEnforceable Fmgram list Such an impact cannot be countenanced. \nStmngly oppose SWRCB's proposal to mate the Enforceable Pmgram list for \nthe following reason: \nThe proposed Enforceable Pmgram list contravenes the USEPA's 2004 \nIntegrated Water Quality Monitoring and Assessment Report Guidance ('2004 \nInteerated Guidance'). While the 2004 Inteerated Guidance is also inconsistent \nvnlhsecuon 303(d), SWRCB'S proposal beyond even whal ir \nconlemplated by the 2004 Cnudmce Spectfically, the 2002 Integrated \nGuadancr dacnks an altematrvc calegoly of waters for whcholher poUuuon \nwnml requirem~lu ansuingent enough to implement any applicable water \naualiw standard. On their face. theenforcemnt actionsand clean uo..orom \npm&ed by SWRCB do no1 fall wthn the amh~l of 'other polluuan wntml \nrequ8remcnu' Funhm. the 2002 Integrated Gudmce stater that Ulne \nrequirements must be specifically applicable to the particular water quality \nproblem' and that 'monitoring should be scheduled ...toverify that the wata \nquality standard is attained as expected.' The Ouidanc'e also requires bt the \nwata quality standard must be expected to be atrained within a short amount of \ntime. The FED instead expands this to allow the watcrs to remain wiUlou1 a \nTMDLunless there are 'umeasonable delays' (again, undefmed). RESPONSE REVISION \nmePolicy has been revired to include these waters where action areundenvay Yes \nin the Water Quality Segments Being Addmsed wction of Ule section 303(d) \nlirt. ~aumase of this new cateearv is to allow coxistence of omms and . . -, \nlo svold dupltcatton of program cffom \nSWRCB is not implementing the ponion of USEPA guidance (Category 48) No \nthat says wafers that have an enforceable pmgram should be placed on a \nseparate list and ncion the section 303(d) IiSt. b is proposed hat waters not \nmeeting standards will be placed on the =don 303(d) list. 51.15 COMMENT \nNUMBER \n51.16 \nW \nkd 217.19 \nW SUMMARY OF COMMENT RESPONSE REVISION \nStrongly oppose SWRCB's pmposal to ereate the Enforceable Ragram list for Comment acknowledged. No \nthefollowing reason: \nThe legitimacy of an Enforceable Fmgram list is sevdy undercut by the \ntiming of this pmpmal. lkrequirements of section 301 areover 25 yeanold, \nwhile man\" of the merams. oermirs. or enforcemat omions lhat would we .-. \nas bss lo exclude walm fmm lhe secuoa 303(d) bst arc also years 11not \ndew& old lo resolve waterqual~ly problem5 ovm Cabforn~a's palat tnab~l~ty \nthe yean through the useof the very sameoptions it nowtouts as definitive \nsdutiws und-Ores that thescpregmm annqin fact, necers;oiIy'solulions' \nto theidentified imainnents. If they were, the waten at issue would be in \nattainmt by now.' Aside from the hebther legal problems discussed above. it is \nsimply too late at Ihisjuncture to usethespew of xctian 301@XlXA) and \n03)effluent limirs enforcemI, municipal rmrm water permits, or any other \nprogram such as BPTCP, as a basis to end- sextion 303(d). This conclusion \nis also suppaned by the fact that impaired wales wen required to be listed and \nTMDL develowd Snd imvlemented wnut to section 303(d) over 20 ~ars. . \nago. ~alifomia'r own deiay in eslabiishing TMDL mnnow open ie dmr \nto theuse of laterdeveloped alternatives to fuRherlimit the-tion of the \nalready delayed TMDLpmgram Because the pposed Enforceable Rogram \nlist imores SWRCB's ownexperiace with the'altmatiues' to 303(d) Qstine .. -and the temporal intent of section 303(d), it is unlawful and unwise. \nSlmngly oppose SWRCB's proposal to create the Enforceable Ragram list for The RaftPolicy has been revised and the Enforceable Fmgramcategny has Yes \nthe following reason: been replaced with the Water Quality Limited Segments Being Addressed \ncategory. Walm shall only be rempved from this categny if water quality \nWe areconcaned mat the proposed Enforceable F'mgram list will create a standards an attained or pollution eonlml mchanisms are not effective. If the \ncircular feedback loop whereby numerous impaired watm will never be determination that the pmblem will be addresed by the regulatory program is \npmpdy listed and subject to a TMDL that will ensun the water body will be removed. a TMDL must be comoleted.\nkr<ond. ~orinsmce,under the orowsed Dmm SWRCB mav eieet to dace .. .- , -~-~~ ~~~~ \na wocr My on lhe Enforceable Pmgrarnlist due to the exlnence of an \n\"altemativc enforceable program\" dunng any given litsung cycle. with very litde \n~usufication oraswce that water quallly smdards will be mcL Then, a! the \nnext listing cycle, evenif the wata body is still impaired, SWRCB may again \nelect to olace the water on the Enforceable Pmeramlist based on the same ~ ~ \nallmatt've program. Ths may contiouc lndefiL~ly under the programas \npmposed by SWKCB. The msull of suchan indefinite feedback Imp will be \nthat numerous waters that areimpaired will remain impaired. This is \ncompletely at odds with the intent of section 303(d). \nWe urge SWRCB to eliminate the unimplementable and illegal Enforceable \nPmgram list. \nIf there is an enforcement program then thepollumt can't be listed on the Waters that do not meet smdards due to pollutants (except for loxicity) are Yes \n303(d) list That's throughout the daewnenc and it's very, very confusing in a recommended for placement on the sectim 303(d) list. \nB-80 0 - - COMMENT SUMMARY OF COMMENT \nNUMBER \nlot of p h Instead a geu put on the enforcement 1st \nDraft Policy, Section 3: Listing Factors \nSuppm theexelurionof visual assessmtsor oh rcmiquanutauve \naswsrmcnu as thc sole basls for a lirung. The Pol~cy should allow for listing \nonly mere there is clear and conviaciog qmmtitative scientific evidence that \nhuman activity has caused impairment lhat can be reasonably remedied. \n18.36.20.14.48.6. \t The proposed Policy unnecessarily repeats the same information on the \n51.112 \t application of the binomial method. In the conlext of cMain water quality \ninformation (ex.. bioassssmenls, nuisance). the -led referenee to the \nhinomial mthoddther dm not makemi (how can it be applied lo \nqualitat~vc informal~on? (see secuon 3 1.7) ornrra morrqunlions IIWI it \nanswers (i.c, different listing criteria anapplied to Ihesediment quality \nguideline (seesection 3.1.6 vs. 3.1.9). \n18.71 \t Recommended delisting or not listing factors as follows: \n(a) Readily available data and information indicates that water quality standards \nare beins-attained. \n(b)Some data and infomuon lnd~wlc pas1 nan-attamment of wata quabty \nnandar&, but orhn informallon or data mhcales thal lhc water qualrty problem \nis not recmmt or persistent. Overall, the available information indicates lhat \nwater quality standards are cumntly being aaained. \n(c)New data or infomation indicates that faultv data led to the orieinal listine. \nArrersmml of rematnlng (dblc and \"on-faully)&u clthcr nndtcares #ha \nwalrr quallty mdds arc allalned or is lnconclurlvc Faulty data include, bul \nare not limited to, typographid amn, improper quality assurancdquality \ncontrol vmedm, or limitations related to the analvtical methods tht would \nlead lo lnproper conclusions regarding thc walnqualrly status of the segmeol \n(d) Slandvds have been revised or benefiual w des~pal~ons have been \nmodified and havcmnved all Wwred Stale and fed4 approvals and \navailable data and information indicate that water quality standards are being \natlained. \n(e) lieRWOCB has made findings vursuant to SWRCB Resolution 68-16 to -. \nallow demdauon of the hlgh qualtty of ihc water body Data and rnformauan \nlndtcales lhat the depdat~an does not exceed that whch 1s permlltcd in such a \nfinding \nThe draft Listing Policy is partially wnsistent with this recommendation. \nRecommendations tc) and (dl have been incommted. A binomial diruihution ~.. \t .--. ~~~ ~ \nmthod ,sused to delermlne altainmcnl, ratha than Rcrommm&!ian (a). \nRsommmdauon (b) IS panidly addresed by sectnon 4 lOof the Dnft 1.1stlng RESPONSE \t REMSION \ncornen1 ack\"0wledged. \nSections 3.1.6.3.1.7, and 3.1.9 have been clarified. l%erepetition of the Yes \napplication of the binomial model references was included to allow SWRCB \nthe widest wssible oooonunitv to consider alternate exceedance freauencies . . \nand con6duue levcls for the various paramten Listed. Tothe exlent that \nelanly of the section is not reduced the repelltlon of the binomial model \nlanguage has been summarized \nReadily available data and information are used to help lMLe infmnces No \nregarding water quality attiainmenl. Statistical pmedures such as the binomial \nmodel ody helps to ensure that Uledecisions made, based on inferences from \nsample data, are as ermr freeas possible to suppon placement or removal of \nwaters fmm the section 303(d) lisL The sole purpose of the statistical tool is to \n~nrrease the confidence and reliability of the available data and information \nevaluated to make section 303(d) listing decisions. The Policy also provides a \nlist of factors to consider when removing listed water quality limited segmmu \nfmm the sstion 303(d) list. The Policy provides guidance in cases where data \nand information does not fit the conditions listed under sections 4.1 -4.10 or \nwhen the lineof ewdence doer not suppm removal. The policy also provides a \nnew section, the situation specific wight of evidence factor, to pmvide the \nRWOCBs the flexibilitv to mve waters fmm the list if annlicable water \nqualrty abjcctlva arc no longer exceeded COMMENT SUMMARY OF COMMENT \nNllMRPR \nPolicy, but it is unclear how don 4.10 wwld be applied. Recommendation \n(e) doesnot appearto be included in the Drah Listing Policy. \n18.81 Rewmmd that RWQCBs should use the decision pmeesss described by the \nTMDLRoundtable Figure I and 2 to evaluate the attainment of beneficial uses \nand narrative and numerical obienives in surfacewaters. and to evaluate \ncompllanre wlh the mlldegradauon component of ualer qual~ty standards The \ndrah Lrtlng Policy is pantally conrwtent mth th~s recommendauon Thcdraft \nLsung Poltcy adopts many of the pmcm steps contamed m ltus \nrecommendation. The dranListing Policy goes beyond in providing RESPONSE REVISION \nMuch of the information pmvided in this recommendation is desaiptive of No \nhow data can be used and does not specifically establish a pmms IIWcan be \nusedpredictably. The recommended fig= do present a -ism1 prwes but \nUE tablesareso general that the lists genmted fromthe p m could be very \ndiff-t hnm oneanother simply becauseof diffmt inmpretations of the \nRWQCB staffs. In addition to the p-in thefig= it is atsoimponant to \n~rexntcleardsision lules. Many of the tams o-ted in Ule fim are \nprcscnpuve requirements formanyoftheiocesr &pr 1.-in of haw data Led wthoul clear dct%ition (eg.: rsumnt. hn&pretativc mdpoik. \nshould be evaluated, allowable age of data. mntmum sample riz, and penistent, uc.) The deciston ~les proposed in ihe drafi Policy p-nts \nlimitations on thc lemporal and rpalial representativenas of mdndual data \npoints. pmpmals that msure conrirtency sratewidc wkik preserving ihe use of \nRWQCB judgement to establish which data sets &pntionrof data sets should \nbe used in the section 303(d) asressmenfs. \n~ ~~ \n18.83 Recommended that the evaluation of aquatic habitadaquatic life-supporting The approach recommended is impossible to assas for several reasons: (1) the No \nbeneficial uses incaporates several types of toxicity and chemical data listing values for sediment (i.e., TELs and ERLs) are lower than my evaluation \nincluding both water column data and sediment quality data. Each type of data . guideline used in any California listing process to date, (2) the uceedance \nmay generally be evaluated independently of the others, and listing for non- frequency is much more stringent than may of Ule RWQCBs have used (except \nattainment of the aquatic life use results when an adequate amt of data \nindicates impaired beneficial use. A determination of iqaimnt should be for Region 5). (3) the phnm used to allow flexibility allow staff to not use the \ndecision rule under all circumstances. his suggested in the recommendation \nbased on an envimnmenrally-repnxntative number of samples collected overa that the pollutant be identified and correlated to an effect hugh SQG,TIES \ntimeframe reasonably representative of existing conditions. The draft Listing or other evaluation ctiteria, although, it would not be a nquirement in the \nPolicy is not consistent with this recommendation. The tiered approach for Policy. \nassessing toxicity to aquatic life is not reflected in the drah Listing policy. \n18.89 The TMDLRoundtable recommended that water bodies that have beneficial The Policy is f-ed on addressing pmblems related to pollutants that may No \nuses that are impaired due to factors such as lack of flow, degraded aquatic cause water quality standards attainment problems. ThePolicy is not focused \nhabitat, and physical changes to stream channels should be identified on the on addressing pollution problems such as habitat and physical changes in \nList. The draft Listing Policy is not consistent with this recommendation. The stmm charnels. Federal guidancedoes not require inclusion of pmblems \nproposal is for such waters not to be listed. related to habitat or physical changs in the waterenvimnnrmt be included on \nthesection 303(d) list (USEPA, 2W3b). \n40.5 Appreciate that the policy pmvides for the evaluation of all data and Comment acknowledged. No \ninformation types and the application of all numericand narrative water quality \nstandards in the assessment pmcess. \n43 47.60.30.70.5, This secuon should br redrafted to cllmlnatc cunent saxions3.2 and 3 3. The Fedml law calls for all waus no1 dng waler quality standards to he placcd No \n70 4.76 17 TMDLr ComplcId List and the Enforceable RognrnList should no1 be pan of on the scruon 303(d) list. kclining trends in ~lerquality should be iocluded \n#he Stalr.'s 303td) bst. Seclionr 3.1.10and 3.1 I I should also be dclcled As on the list if it is rubrtanl~aled hl there are im~actson aauauc life. \nW amntly drahed it would allow water segments to be placed on the 303(d) list \neven though water quality objectives were not exceeded and no specific \nW pollutant was identified for water body conditions. This factor is inconsistent \nwith 40 CFR 130.7. \nQI\nul B-82 COMMENT SUMMARY OF COMMENT \nNUMBER \n44. 10 Impairment listing decisions should not be based on probabilistic data or \nevaluated data. \n51.74 \t Table 3.1 of thedd Policy presents an exuemdy misleading view of the \namount of samples available to RWQCBs. lhehigh sample counts depicted in \nTable 3.1 arein aces of current resm allocations and arenot scientifically \nnecersarv to conduct wateraualitvassesunem. . . Monitorine of mnventional -\nwataqdify paramten ohm takes place an a monthly basis. Monllonng of \nmetals. rynthet~c organic chmucals. PAHr. b~oaswsrmts,and toxicity tating \ntypically takeplace onceor tdce a year at a limited numba of -toring \nsites. lhedraft Policy's arbiuary minimum sample count requirement appears \nto prevent a water body that is out of mmpliance with standards four months \nout of twelve fmmbeing listed. For numanus conventional water quality \nparameten thisis scientifically indefensible. For example, if surface water \nnitrate concentrations in a streamaced the drinking water standard for rhree \nmonths of the year, the water body is most cmaialy impair&, yet the Policy \nwould nn recognize thisfact. \nFor mny analyst$, the hgh ranple counts dcp~rled in the Pol~cy are \nunneccrrary for making sc~enulically sound waterqual~ty asxsrmts Since \nthe SWAMP budgel IS not 11kcly to Increase In the near future, the hleh mle - . \ncount requirements could have ihe effect of either placing an unreasonable \neconomic burden on holders of permits and waivers or, if that burden proves \neconomically (or politically) infeasible, will ensure that impaired waters do not \nget listed. \nAs an example, a typical sampling strategy mnducted in a region often involves \nsampling conventional water quality analyses monthly and conducts other more \ncorUy sampling a few times a year at a limited numba of monitoring sites. \nTable 3.1 depicts sample count requirements for a single monitoring rite (or \nsingle water body), which range as high as 500 samples. For most sampling \ntypes, the sample counts depicted in the table are sfientificallyunnecessary and \neconomically impassible. \n56.21 \t Suppon the draft Listing Policy's requirement that if adverse biolagjcal response \nor degradation of a biological population is demonruated, these impacts need to \nbe shown to be associated with water or sedilnent concentmion of pollutants in \norder to be listed. \n60.26,76.12 \t This section should be rewritten toclarify that the only factors to beused to \ndevelop the California Section 303(d) list anthose factors in Section 3.1. \nbJ 61.15,65.10, 83.10 Sections dealing with Tmds in Water Quality and Alternate Data Evaluations \nW \twill ereate loopholes for listing of waters without sufficient data or technical \nbasis. 0 \nB-83 0 \nRESPONSE \t REVISION \nAs required by federal regulation, all ~adily available data and information No \nmust be used in the section 303(d) listing pmeess. \nTable 3.1 is included in UlePolicy in order to show thenumber of excedances Yes \nthat will cause a water body to be place in thesection 3Wd) list Most of the \ndata sets available have lss than 50 samples. Con-tirmnl pollutants can be \nereaUv influenced bv seaurn. weatha. and other faem. Havine data fmm -, \t -\nmultiple reasonsand ycan will only svengthen thefase to place a wata body \non the wcuon 303(dJ list. lhePollcy dm not require large sample rim but \nrather pmvides the cut off values fa bothlarge and small data sets. \nThe sample munts in the Tables have been reduced. \nComment acknowledged. \t No \n%s section ofthePolicy mfilutes thelisting factors to be used in California. No \nPlease refer to the response for Commmt No. 84.10. \t NO COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n73.2 \t Waten should not be listed because of isolated or temporary incidents Ulat may Comment acknowledged. No \nhave no advuse impaets and for which development and implementation of a \nTMDL wuuld be meaningless, and puhapr even impassible, given the msitory \nnature of the excursions. \nDraft Policy, Section 3.1: WQLS Factors \n8 6. 1825. 18 9. Thm arcconcerns mgml~ng irmtauonr put on the usc of mformatlon fmma Data on splllr. wolauon of pmnt or WDRr and nrual infmmauon can be used Ya \n?O 15 rptll, nolauon of a pemut or WDRr and nrual ~nfowt~on in can~unet~on These lmutat~ons wth other data to demonstrate that there is an wceedance of \nare not justified ornecessary. Any infmli~ and data on the conditions of a water quality standards in Ule water bcdy. However, thisinformtion cannot \nwater body must be considered regardless of the so- It appears that Lhe be used solely for the listing. This section has been revised clarify Ihir \nintent is to preclude listing a water body if the cause of nonattainmmt water language. \nOualiw standards is due salelv to a mill or violation. lhis hiscent mav be ~ ~~ . , \t . 7 ~ --~ ~ ~ ~ -\nappmpnatr undcreena~n runxior such as when the nanattainmnt is shm \nlived andlor mediated via eomct~vcacl!on When Ulm is a rplll or wolauon \nin conjunction with other discharges andlor spills or violations, it would make \nno sense to limit use of information or data associated with Lhe event to assess to \nwater bodv. Funhemwe. a resoonsive action to a soill or violation is often \ncollection of data on candnuans thmughout a water bcdy not only wtlun the \nvlctntry of a dscharge hnutlng use oftku data a clearly an untnrended \nconquenec. \n18.24 \t Delete references to other sections on data preparation, as well as references on Reference to these sections allows the reader to obtain more description on the No \nlimitations on the use of certain types of data. The sections on data preparation evaluation of data and information (i.e., data quantity and quality). In \nstand on their own. Reference to a limited number of thou Eenions implies that addition, it references the process ofuanrfwmingdata fw evaluation and rules \nthe other sections on data preparation may not be applicable. far using visual information. \n18.30. 18.23, 18.8 \t The omnosed Policv unnecessarilv reveats the same information on the The Policv has been revised to address this concern. Each liaine factor in Yes . . . . \t -\napplication of the binomial method. In the context of ccmm water qualit) secuon 3.1 mfm to standard exceedances a&dernbeJ in section 31.1 or \ninformation (eg bioassessments. nutrance), the repealed refmncc to the 31.2. The urof qualitative and qwnulat~vc ~nfomuon to ruppon listing has \nb~nomal mehod either doer not dc sew (how can it be appl~edlo been clarified in tk Policy. \nqualitative information? ) or raises more questions than it answus (i.e., different \nlisting crileria are applied to the sediment quality guidelines -see section 3.1.6 \nvs. 3.1.9). \n30.5 \t The Draft Policy states: 'Visual assessment M ok semiaantitative The intent is to use semi-auantitative and oualitative assessments as ancillarv Yes \nassarmnu may not be used as the sole line of rndmce to suppon a section llncs of evidence. Theclsnfication on the use of wsual aswsrmnts and --\n303td) I~sung ' However, muon 31 7 appean la suggcn oth\"wirc. \\ma IS the quant~tativedata has ten incorporated in the Pol~cy \nSWRCB intent? \n40.23 \t The state would need to adopt and receive USEPA appmval of water Reevaluation of existing standards is accomplished under CWA section Yes \nstandards changes pursuant to section 303(c) in order to apply natural source 303(cKI) and implementing regulation (40CFR 131.20). During Lhe triennial \nexclusions or the reference watershed approach to implementing bacteria review the RWQCBs hold public hearings far the ptupose of reviewing water \nstandards as pan of lhe Section 303(d) listing methcdolagy. quality standards and as appropriate, modify or adopt new standards. lhis COMMENT SUMMARY OF COMMENT \n51.163 \t Data used to assess impairment related to biological impacts from \nsedimentation, adverse biological response, and d&mlation of biological \npopulations and communities often doer not lend itself to the narmwly allowed \ndata analysis methodologies of the draft Policy. For example, the draft policy \nstates sedimentation and demdation of bioloeical maulations and communities \nshould be evaluated uungGe bmomal modei(~ec~dns Even 3 1 8 and 3 1 9) \ntian altemat~ve evaluatton mthod was allowed hy thc Poltcy for these zmpacu \n(the Policy is unclear on this issue), the requirements for this alternative \nevaluation areseverely limited by statistical requirements (Section 6.2.3) \nEnlualnon of 8mpacU related to rcdtmntat,on, advme hiolog~cal response, and \ndegradauon of btolog~cal populauons and commurut8n reqwmr multtplc ltna \nof ev~dmce (as nolcd in the mD). Currently. the draft Polley dm not app \nto allow a weight of evidence appmach for thme impairments. ~uthmiie, the \ndraft Policv aDDearr to eliminate the use of man\". scientificallv-accmted and . . .. \t . \nmommended appraaehe to evaluat~ng blolog~al tmpacu Far example. the \npol~cy reems tonot allow the use of ihc DFG's IBI. By dolng so. thedraft \nPol~cy effecuvcly blocks ihe use of many typ of bnalog~eal datasets and \nbioassessment studies from consideration in the listing pmess, and effectively \nblocks mdsf listing related to bioloeical imoaets. \n220.1 \t Some of the cumnt waters on the 303(d) list would not have been listed under \nthis wliw... RESPONSE \t REVISION \nPolicy is not intended to change any water quality rtandat&v Mnr, the \nPolicy pmvirim adking listings for nanual s~yces has bem removed \nThis vrovides the RWOCBr with the fluibilitv to add remove or not list \nwat& due to natural s&%. Wata bodies m&mmended fa.303(d) listing in \nthe future or existing listings mmmcndcd far mval fmm the 303(d) list \ndue to natural sources wll require review and appmval by the SWRCB. \nIt is not required or desirable that bioassessmt data be evaluated using the Yes \nbinomial test. \nThe ~umose of incorntine the use of a statistical aovroach in the tistine . . -\t . . \" \nevaluat#ons is to venfy the valrbty of data collmed to support a pamcular \nlrrung Sedtmtauaa caobe evaluated uong acceptable pdelules or ownenc \nstandards that calcukte impacu on beneficial uses hom measured biological \neffects due lo sedimentation. The data is then submined to a statistical \nanalysis to help determine if the data is sufficient at a specifled level of \nstatistical confidence to say Ulat water quality standards areexceeded. The \nPolicy recommends the use of the binomial disuibution but it also allows other \napproaches to be used. \nIn addition, The Policy also requires documented impans due to advme \nbiological response ordegradation of biological populations and communities \nto be associated with water orsediment coneenvations of pollutanls prior to \nplacement on the section 303(d) lis~ This assessment is separate from the \nanalysis used to evaluate chemical or physical data such as tulbidity \nmeasurements. The Policy has been revised to clarify this diffemtce. \nComment acknowledged \nDraft Policy, Section 3.1.1: Numeric Water Quality Objectives and Criteria for Toxicants in Water \nThe valueson Tables 3 1 and 4 1 re tm fu d-te unless a wgorous \nconfirmat~on pmpm ir ~mplemmted for all valuer that cxcgd the standards Ihc ~lucs in draft Poltcy Tablcs 3 1 and 4 Idlffer due to the natureof the NO \nmathemaucal foundauon of the exact btnomal test in one me (I~n~ng. Table \n3.1). the statistical assumption is made that each candidate wata body in \nquestion isactually meeting water quality standards. This prepreliminary \nassumption is then tested. \nFor delisting, the initial assumption, for statistical purposes only, is that the \nwata bodies already on the list do not satisfy water quality standards (a \nreasonable assumption, since they were previously listed). lheappmp~iate \nstatistical analysis is @od. \nB-85 \n COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nAs the draft FED discusses, each methadology is valid, and wimtifieally \ndefensible. The diffemcs between these tables is reduced if amn are \nbalanced. \nDraft Policy, Section 3.1.2: Numeric Water Quality Objectives for Conventional or Other Pollutants in \nWater \n1.11, 1.3. 1.7. If 4-t is considered a conventional pollutant, guidance should be pmvided Guidance is provided in the Policy in section 6. For any spedfic averaging No \n1.15, 1.16 for listing/delirting of water bodies whose numeric criteria are expressed as period, data should be considered as the first step in evaluating mmpliance \nMean of MonUllv Measurements. \t with waterqualitv standards. For exmle, if the standard isesmblished as a \nmean of I2 bnkv meansthen the data would reo-1 the fom~liaaee \ndelemunauon for a year In thlr example, mull~ple years of data wld be \nnccasary lo use the slatlrttcal approaches premlcd m the Pol~cy \n11 8. 19 8.203 5 \t D~rrold oxygen data isinadequate as a sole nndncatnon of tmpa~mvnt It would be #deal to have a second ltneof evidence (c g .nummt mformatton) No \nNurnenl data should also be endml Please mnre Secuon 3 12 lo relleet thrr forexeeedance of dtssolved oxygcn standards Howcvew, smce thm IS 3 \nnumerical water quality objective for dissolved oxygen, wceedancs can be \nused to determine impacts. Iherefore, a listing anstand alone based on the \nexceedance of the dissolved oxygen WQO aslong as there is some indication \nthat the exceedance is due to pollutants. \n18.26 \t The discussion of the cause of deomsed dissolved oxveen should be The discussion is necssarv to rule out no\"-wllufant ma of the deDwed No .-\nDO For example. 'T~~gare nwdxfied \nconfusing to have a llrmled dxrcusrlon of oncposrtblecause (numcntr) S~nce physncal habttats \nit is not clear why such direction is necessary to conclude dissolved oxygen \nstandards are not met, the discussion is deleted. clrmnaled Depressed dtrsolved bxygcn can have a number of causer and 11IS \t not needed fir DO problem caused b; \n21.24 \t With respect to DO depletions related to nutrients, the impact ofnutrients needs 'Be section on temporal repmentation has be% revised to document the time Yes \nto be carefully examined in terms of what constitutes a nuuient that leads to of the measurement. \nexcessive fertiliatiation and die1 DO changes. MmnicuLv con- is the time of \nday that measuremmts of DO are made.\"If the tihe of the DO measurement s \nnot documented, data can be generated that do not properly assess DO \nviolations of the water quality objective. \n40.70 \t USEPA's 1997 guidance recommends methods forevaluating relatively small- lnstead of using the section 305(b) guidance (USEPA, 1997b. 1997~) for this No \nsized sampleseu to assess cmpliance with theapplicable water quality purpose, SWRCB used more recent guidance focused on thesmcfure of the \nstandards, which specify allowable exceedance rates in the entire waler body. list and interpretation of standards (USEPA, UX)3b) as well asguidance on \nThe guidance does not directly identify allowable water quality standards statistical evaluation related to the section 303(d) list (USEPA, ZOOZa). \nexceedance rates for conventional pollutants. \nW Draft Policy, Section 3.1.3: Numeric Water Quality Objectives or Standards for Bacteria Where \nW Recreational Uses Apply \n01 \tB-86 \nU) COMMENT \nNUMBER \n11.11, 19.13.203.8 \n18.85 \n29.5.61.12 \n29.6.61.13 \n29.7.61.14 \n40.22.40.102 \n40 78.40.77, \n40.79.51.102, \n53.13 \n51.97.51.96 SUMMARY OF COMMENT \nThe termrelatively unimpacted should be defmed in order to help clarify the use \nof ribspecific exchce frequencies for bacteria in recreationallydesignated \nareas. \nReeonrmended that data requirements and pmesses should be used in \nassessment of compliance with numericbactaiological water quality \nobjstives. Thedrafl Listing Policy is not consistent with this \nrecommendation. The TMDLrecommendation fauses on an evaluation based \non the existing water quality objectives, whereas the draft Listing Policy uxr \nlhe binomial method and a 10 pment exceedance rate or a 4 pment \nexceedanceme formastal beaches between April 1 and Octoba 31. \nClarify the language that applies specifically to contact recreation. \nImpacts on mntact recreation uses in fmhwater should be evaluated in the \ncwtext of seasonal and site-specific variation in actual use pattemr. \nLatitude should be allowed to consider actual pathogen data for the receiving \nwater, if it exists, to suppmt either listing or delisting, especially when the \nexceedance hepuencv is close to LO%. \nThe provision that encourages application of a reference watershed appmach to \nassessment of bacteria standards exceedances is inconsistent with state water \nqualtty standuds except in Regton 4. the only Region in which 3rcfmrc \nwtmhed approach to baetena standards ~rnplemmlatton has kenadopted as a \ncomponent of its water quality standards. \nThe policy provisions for assessing bacterial standards exceedances should be \nrevised because theprapased niteda appear to conflict with the State's cvrrent \ntwonumber water quality standards or objectives which have both an \ninstantaneous maximum as well as soeeific data muirements and 3-v \nonluat,on pcnodr ihc 10% blnaial aspect uoulh potenuslly be mnsistmt \nwth lhe numnc standard usmg the 3-y gcommc mavmgtng pcnod \nSWRCB offers no iustification for allowine anvothertwe of assessment aside -. ,, \nfrom the reference syrtcmappmach Based on Heal the Bsy's comprcknslve \nd3uhuc of baclena mnhtonng results hm County hwllh agenclcs acrarr the RESPONSE REVISION \nThis phrase was used to allow RWQCBs to consider a wide range of factors \nwhen using this refmnee condition approach. Tmmuch detail in UlePolicy \nmay limit the appropriate application of this concept forthe evaluation of \nbacterial indicator dam. No \nEx RWQ& recommendation provided no specific &dace on lhe approach \nfor evaluating bacterial indicator data. iheexceedance fmpencia pmpared \nto be included in the Policy were developed by BWQW. ibis gmup had \nseveral memberr of RWQCB staff that concumd in the recommmdations No \nThe section appean to clearly state the decision rules for interpreting bacterial No \nindicator data and beach posting information. \nWater contact-related water quality objectives should be implemented as stated No \nin UleBasin Plans. Thefact sheets that will be pnpaRd to implement the \nPolicy will contain infomuon related to seasonal variation and site-specific \nvariation. \nif pathogen data (lie virus density) is available it must be included in the No \nassessment of all readily data and information. \nThis section of the Policy has been revised to aclmowledge Ulir point and to Yes \nreouire that water oualitv obiectives be imolemented as adwted. . ., \nThe use of Ule binomial approach is consistent with the use of the 30-day No \ngeometric mean because the standards must be analyzed fist in tern. of the \nexpression of the standardand then using the binomial test For example, \nRWOCBs would assess comoliance with the 3-v ,-eeometric meanfor each \n30Gy penod wth data and& it uould be detemuned if Lhe swndard rs \nexceeded Thc'ya'or 'no'answ would be used m the rraurueal tat along \nwith all the other appmpriately grouped nominal data. Sample sh is \ndependent on the level of enor allowed and the extent to which standards ace \nnot achieved (please refer to the Issue related to statistical analysis for more \ncomplete description). \nUnder the Policv. RWOCBs anmuired to use dndecision rules to No . \ninterpret extslrng mter qual~ty sunhrdr To the extent rt smnsrrtent with \nwater qualtry standards. a refmcc. rytm should be used COMMENT SUMMARY OF COMMENT \nNUMBER \nState, it should notbe very difficult for the RWQCBs throughout theState to \nidentify reference beaches for all beaches used forxaeational purpmes. The \ndraft Policy should be revised to quire a reference-system appmach for the \neduation of marine xaeational beaches. \n53 12 Thcappltcable baclena standards arc not spec~fied Reamnmd the nced to \nspectfy vtuch standards areapplrcable and cons~rtenlly define a stte-spectfic \nwceedaoce frequency as a percent of water quality uceedances in a relatively \nunimacted watershed. ' \n71.24 If a sitespecific exceedance rate is used instead of 10 perrent (e.g., for bacteria \nin water quality ~ae mcmational uses apply), then similar tables should be \neonsuucted and used for deferminine cornlime with bacteria in water aualitv -. . . \nobjeeuves at those spec~fic locat!ons \nDraft Policy, Section 3.1.4: Health Advisories \n24.5 \t Modify the final sentence to read: Inaddition, water segment-specific data \nmeeting the data requirements of this Policy must be available indicating the \nevaluation guideline for tissue is exceeded. \n44.12 \t The Policy should require that fish tisue data specifically come fromthe water \nsegment Ihat is suspected of being impaired; the use of generic or area-wide \ndata is not aoom~riate. \nThe pmpmed listing factor would facilitate continuation of the pmblem of water \nsegments being listed without pollutants being idmtified. Health advisory is \nonlv an indicator of an imoaimt unless a wllutant is identified. RESPONSE \t REVISION \nApplicable bama standards arecontained in theOcean Plan. Callforma Code No \nof Rcgulauons (adopled pwuanl AB 41 1 J, and Bauo Plans \nfact sheet should conrain the rationale for the use of a site-specific No \nexceedance frequency. A large table is not neuary. A description of how \nthevalue is to be calculated and the aitical dues faconfidence and power \nare~ncluded m the Pollcy \nThis request would mke Ulir section duplicative of Section 3.1.5. No \nllis request wauld make this section duplicative with Section 3.1.5. No \nHealth advisories areacknowledged indicators Ihal a beneficial use has been No \nlost. The Policy also advacates the use of water segmen1-specific data to show \nthat the oollutant is oresent in the seemen1 ~m~osed - for listim. -\nDraft Policy, Section 3.1.5: Bioaccumulation of Pollutants in Aquatic Life Tissue \n18.27 Thediscuston on bioaccumulation should be eliminated The lirm1t.d nalure of \nIhe dlrussion provides lrttlr policy direction. and, lhmlorc is unneeessq. \n21.35 The minimum 10 percent exceedance approach for numeric water quality \nobjective for bioaccumulation of pollutants in aquatic life tissue is not a valid \napproach for the protection of beneficial uses of water badis. Fewer \nexceedance Ulan LO men1 can have significant adverse effect on a water \nhody 7he facus rhkld be on arsesrm;bt of jmprls on hcneficd uses, lnrlad \nof some wblvary pmuge of samples wth exceedances \nB-88 7he Pollcy discusses Ule excecdvlce *ma nerssaq to lia based on ussue No \npollutant levels. Add~uonslly, the Polley provides guidance on how those \nlevels aremeasured \nPast USEPA guidance recommends making nonatlainment decisions for No \nconventional pollutants where more than 10 percent of samples exceed \napplicable water quality standards. Additionally, this exceedance appmach has \nbeen used bv mvlv states to dace waten on the section 303(d) list The use of \nthe cnucal &ceed&ee rale s apprapnaely used m slausucal malyns Jfter an \nassc~~mnt of tmpacw to the benefic~al usp has alry been mde, 11 is not \nused lojusufy allowang an cxcecdmcc 10 pcrcenl of the urn The 10 percent \ncritical exceedance rate applies to the defemination of thenumber of samples \nneeded to place waten on the section M3(d) list . . .. .. . ... . . -.. . ... . ... . \n31~1x-ie pue - PPB~~OI awnpe ue pue nu;xutpas nxddlu! uJJmlq qutl ej0 IULU\"IP!I~~S~ ,el svnlpoG~em;o ram lepyauaq aq uo I>&! \nalu .pmecb! 2- mKpoq men alllo sacn le!Jg>!q aql lev SuoneJlpul u,mlem u! iwnlpsua> e jo uo!iesua~um @101aq uwmuq d~qsuosela lmrp \nleuseare Apoq mm e uww sa~~~unlmuo> pue suope~ndcd im%o~o!q e s! aaq~ lew %onunsse'psn sue nwnllod lepwlcd ja suapenu~uo~ le>nuaq> \nON \nON 10UOPT&~PIO m!ue& spenbe loap!mp mcdm @~@o[o!q asanpv \n20u m pag!~uap! are stueanl~od \nJWq* IVlW mm d aq mKl!~!xo.I 1Vl (P)EOE wpms am uolalem a41 \n%mwd amW nwn~lodjo suopenunum ~uaru!pas lo niem qiw paiewsse \na7 lm~ ~ a p mpw suo!~e~ndod 1m@010!q jo m!~ep&ap 20 asuodm \n@~!%010!q mpE 01 anP SJV~UI! WUWlucp 'i[l!J!xOljO WUdaJxa 241 WZM \nON \n.uo!s!mp Sups!! 'pa%palmoml~e luaunu03 \neaseq 4q>!qm uodn samm wpdoldde m mqm Ka!lod %U!IS!I (P)EOE ijem am 1noq8nang sua~qard ~mg@!s am aau '61.12 '92.1~ '6.01 \n~~rno~ IS![ a~pu~ld \nam mj alzudwdde mm pue (P)EOE aw mj mudoldden! s! s!u 'lwnncd 's1.1' 2.~0~ '6.19 \n~gpdse 01 malaElnow+ soone~ndod uopepw%ap '8.85 BVEP @~@o~o!qjo \n'asuh @J@OlO!q aSlaAP2 '~l!3!~0101 SIlP WS!l ?q4Kpaq mem EMOl@ '88.W 'E'6E 'E.6Z \n4maas PInOM .(3!10d 14130 6.I.E Pw '8.I.E '9.I.E SllO!lJaS U! a%n%uel '8'EZ '8.21 '8.5 \n.salhues anssp aj!l ~!ianb= uo \npaseq %ups!l 103 p;u!nba~ sa~uepaaxa $0mqmvurmu!up~ aw ww &es!a PI'W \n'SVN pw 'VH~ %u!mx uo paseq'swpenya~uo~ .sap!ununuoJ pue suo!lelndod ie2!%o1o!qJo uopvp&ap pue xucdsa leq%olo!q 'vdzsnruay san~e~ \nON @JpuaqJ anss!ljo m!len~ehq .iuamu!we pmpws aensuomap 01 smwaw \nKq IW!J~PS annuapya 30 sang amm 'vwdde ampma lo lq%wm elapun \nON lev slanalo~ muasqns ~1x01 aluluaxmmq pue a!elnmnJ>mtq Kaql ameaq \npaldlueram rwr~ueko ~nenbv pal~wpaqo~ holsw~lomol WI wyo \nsue nlpoqolw ui suonesua~uog wstu~%o ~uenbe uh pue wnlo3 mlem aqi \nu! sa~msq~ ~!xo~jo ruo!~esunum u-uq uoplaum e SAW@ IOU s! aau \nON ~paapa1moq~e IU-03 \np%p~moua~e ~uxuruog lulnpe jo uogenleha aqi loj p;u!nba s! se 'q~eo~dde nmpys jo iq%!am e no \npaw aq plnoqs anss!] aj!~ =!]enbe u! nunnllcd jo uo!ielnmnneo!q loj SZu!lsq ZI'W '61'95 \nnep ansrli qsg 10~SIJIP~S Jlenlena 01-a3 \npue rlun am iouo~ mueptn8 sagws uoddns suonuloa>uo> munlo3 \nmlem pue spa1 ansr81 umrmq dqsuosela paqr~lqn~ \n ue amba plnoqs \n'I@ le pan J! 'sau![ap@ uo!lenpa annp jo ~a3uepmxa uo pmq SZugsq 8 1 '95 \n'lu.uua!nbar \naep wnm!onu sw jo asn swasoddo 'p!nba are saJuepaaJxa aldm \naOUI 105 'OZ uem ssal uope~ndcd aldures lOJ auanl!suoJ urunlml?leM a1gM \n'IS!~ (P)EOE aw uo wuwwdmj mpeulena anssp ajg apenbejo sa~uep~xa \nE =!nbar Kluo &lad qe~pau 5IWNpSUOJ urunlo~ wem 01 plrecbm \nse SZups!~ paseq anss~l 10).awnq a41 FWMOL Al@puasd seq mas au L1'95 \nnmw ~lqotns 10\" sue auo@?nnli nhllx,Kaupq 1et11 pue smssa~se \n$41UI pam qplnoqs Apoq ~loqm ~o~l~snru maw3 98 OP wag qnsa annn ~ew \n~ -\n-stin= annp jo apw@mu \nSu!ienlena no sau!iapW apnlan! 'wpwpe UI (.lsa%re~ lw $0MWIu! \nBSL s! lms allmw 'sa!Jads am am~o SI~~P!AIPII~ -loExo iisnum \n COMMENT \nNUMBER \n16.1 \n21 37.21 21, \n2 1 18.21 46. \n0122.65 12. \n65.14.67.6 \n21.42 \n40.89 \n56.15 \n65. I3 SUMMARY OF COMMENT \nof a constituent is an unreliable indicator of a beneficial use impact \nSubmitted a memorandumdated 10/28*)8 on the useof Sediment Quality \nGuidelines in Dredged Mataial Management Decision Making. \nThcdraA Polrcy tncluda a number of techntcally ~nvalld approaches as Itsung \npmmtm, such asthe Long and MmgmMacDonald eooecumnce-based \nsed~menl quahly gu,delnnes and IhcCaltfom~s SWRCB 'NAS cnlena' \nCare must be exercised in allowing dilution or other predictive models. Most of \nthe orediclive models do nm adenualelv relate cause and effect Dilution . , \ncalculat~onscan g~vcerroneous results under cond~uonr where the ConsuNents \nof con-can accumulate at cmn lwauons in the water My, ruch as those \nthat accumulate in sediments. \nThe propored toxicity evaluation method also needs to be revised to better \naccount for the complexities of assessing the p-ce and mamitude of acute \nand chmnic toxicity in multiple species tests. \nQuestion whether 3 conseeutlve samples arerequired for toxicity and are the \nthree toxic samples hom different reasons of the same year. The reliance upon \nsuch few sam~le mav make it more diffteult to sufficientlv n~nrent the . , . . \ntemporal chmctcnrucr of the water body, to drtcmune if thecondrttons arc \npenlstenl Thc plannrng llrl or rnonllonng llsl may be 3 morcappmpnare plxe \nfor there listing until it can be characterized. \nSediment toxicity is heavily inlluenced by site-specific factors (e.g., organic \ncarbon content, acid volatile sulfides, sediment grainsize) and guidelines \ndeveloped in otha iurirdictionr are not lezallv 6mul~ated standards within -.. \n~alifomia. Theref& this approach is inappropriate &d would not result in \nscientifically sound listing decisions. RESPONSE REVISION \nmrtitutes an exceedance of a water quality standard and must be placed on \nthe senion 30Xd) list \nCo\"mx\"t acknowledged. No \nIllhe Polkey docs not qu!n thc use of any rpectfic dmnt gu~dcllnes No \nRWQCB areafforded sngn~fi-I flexthbry to wlst Ur most appl~cable \nyldelme. The gu~del~na acceptable, published mmuoned as exanpla an \nvalues that may be used. Many of the sedimmt guidelines arepredictive of \nsediment toxicity. \nComment acknowledged. No \nCommmt acknowledged. No \nThe Listing Policy is not specific on which season toxicity should accur. Yes \nUsing the proposed binomial test with balanced errormtes, if threesamples \nshowed simificant toxieitv it would suffieimt to dace the water on the list. \nMany appmaches havebeen used to develop SQGs. Data was gathered fmm No \nmany available sources, including thme fmm equilibriumpartitioning models, \nspiked sediment bioassaw, and numemus field surveys. Model studies and \nspiked sediment biaassas establish cause-sffect relationships for a single \nchemical, whereas data from field studies reflect complex mixtureand real \nwar14 natural conditions in ambient sediments. Therefore, the mast \nmeaningful assessment tmls are based evidence fmm the combination of these \nmethads. Data compiled hom different study areas, with different pollution \nhistories and physicalehemical pmpeties convergeupon ranges of \ncantaminant concenmtian Ulatareusuallv associated with effects. therefore \ngllldrltnes dcnvcd from thew srudler can be broadly applhcablc la may other \nareas 2nd rlluauonr Unltl Calhfomla wd~ment qualtly abjecuver are developed \nand adopted, other scientifically valid SQGs can be used to assess sediment \ncontamination. In addition, the draft Policy does allow Iheuse of other \nevaluation methods ruch as: equilibrium partitioning, toxicity identification \nevaluation along with nher lines of evidence (i.e. bioassessmenC tissue - - COMMENT SUMMARY OF COMMENT \nNUMBER \n217.11 \t This cause and effect lmk typically mot be established thmugh simple or \nstandardized tests. Instead, spgial nudies are required. 711e listing policy is \nshining the burden of~rablishingabsolutecaure to the Regional Boards. \nDraft Policy, Section 3.1.7: Nuisance \n58.9 \t If it is currmUy impossible to identify the cause of the nuisance, it is unlikely \nthat a source can be demonsmted. \n2 17.20.217.2 1 Then are specific exampla that lalk aboul vash tbt anmoa mubling. If you \nhave local antr-ltnkng ordlnanecr, for example, one can inmpret that there is \nno way thst body would be 303(d) lind. regardless of whether or not thse is \nsevere water quality lmpmrment \nDraft Policy, Section 3.1.7.1: Nutrient-Related \n18.86 \t The TMDL Roundtable recommended that the parameterr previously \nrecommended for theevaluation of numenu mav be useful for ertablishine ~~~~ ~ ~ ~~ \nnutrient larl~ngr The utility of hue paramten vans, bas€d on our cumnt \nstate of knowledge, and on the d~nelncrs of their lnnkagc to nument-relaled \nbeneficial use impairment. Thepmcess for listing andlor delisting water bodies \nfor nuuient impairment is to utilize a weight of evidence approach using this \naarameten. asaoomoriate. for each beneficial use desimtion in combination .. . \t -\nw~h the dcctslon pnx'esr m dacrnunrng complrmc ~lth Waerqusllty \nstandards Other scrmt!fically drfenstblccntena my dso bc used Thc dnR \nLlrl~ng Pol~cy is panmlly conrtslen~ wth lhls recommendauon The drah \nListing Policy di&sxs algae pwTh as pan of a discussion of nuisance \nconditions and dissolved oxveen unda Conventional Pollutants. A eenRal \ndlccusr~on of nutnenb rr no1 tncluded in the draft 1~9mg Pol~cy In addlllon. \nthe dran hrt~ng Pol~cy appltcs a 10% exceedvlu rate and Ulc use of the \nbinomial meUlod to dissolved oxygen data. \n58.7 \t The policy is becoming overly prescriptive; the appropriate solution is lo take \ndissolved oxygen samples in the morning, when the critical condition eriru, \nlilther than making assumptions. RESPONSE \t REVISION \nanalysis, advase bialogeal mponse, etc.). \nComment acknowledged.~ \t No \nCornmeat acknowledged. \t No \nWatm can be ltstcd lor aash lf evaluauon guidelines arc acceded or if tnsh No \naemrnulal~on is grcala than a reference condition If there areenforceable \nmechantrms thal solve the pmblrm they should be used in lieu of a TMDL \nComment acknowledged \nDie1 measurements arerecommended because DO levels fluctuate seasonally No \nand over a 24-hm period. They vary with water tempafure and altitude. Cold \nwater holds mare oxygen Ulan warm water and water holds less oxygen at \nhigher altitudes. Aquatic animals are most vulnerable la lowered DO levels in \nthe early morning on hot su~days when sueam flows are low, water \ntemratuns are high. and aauatic olants have not . been omlucine-oxwen.- - . \nrrnce sunxt Therefore, dtcl measuremts are reeommrndcd to arm that \nthe data is suffictent lodocument the extent and rcvmty of the impmrmenl as \nwell as any temporaVm trends. 212.6 COMMENT \nNUMBER \nSUMMARY OF COMMENT \nlherearesome nuisance listins for the Burbank Western Chamel: algae. odor, \nand scum that were on the1998 tistins and were earried to Ule ZOO2 lists. It's ~~~ ~ ~ ~ ~ ~ \nunclur how those listing mmLCd and what additional data can be \nsubrml!ed to get thme dcii~ted. It's unl~kely that indtndual observat~ons will he \naccepted asnewdata to have those reevaluated, even thwgh we believe that's \nhow Ulme listings were mated in 1998. \nDraft Policy, Section 3.1.7.2: Other Types \n1.23. 1.5 Clarification of inconsirtencv wmted in section 3.1.7.2 aowan to oermit .. \nlhstlng based solely on vlsual asressmu or serm-quant~taovc assessmenu \nwhle muon 3 1 slats they may not be used as the role ltnc of cvldmce to \nsuppon a 303(d) listing. RESPONSE \t REVISION \nif wllutanu arenot &lied ascausing or canuibutiw to theobserved No \nconditions. then it is wrrible Ihat the Ponditions aredie to somenon-iwllutant \nfactor (cg. loss of habital. \"aural algae @oh. m.). \nIn using aualitative visual assessmenu andlor othersemi-auantitative Yes -. \nassessmu to evaluate waters nmpacted by nwrance pollulants, the polrcy \nrequ~resthe use of cstabl~shcd cvaluauon gwdelrna lo detarmoe excecdance \nof water quality standards as well as site comparison against refemce site \nconditions, when available. Saion 3.1.7 has ken clarified furfher to reflect \nconsistency with sestion 3.1. \nDraft Policy, Section 3.1.8: Adverse Biological Response \n1.6 \t The term'associated with' should be renlaced with Uletem'are scientilicallv \nanddcmonrmbly cad by' The mere asrocral~an ofeffrclr wth red~mcnt \nlads should no1 be used as a Itrung cnlcnan, pantcularl) m the absence of a \ndefinition for the term associated with. \n44. I4 Biologi&l impaeu should have a smg association with (i.e., a known or \nruspgted causation) water or sediment pllutanu. \n51.21 \t The policy must allow Itsting for adverse biological response and degradation of \nbiological populations and communities alone, without identification of Ihe \ncausative poflutanu. The draft Policy requires the identification of the speciflc \npollutant orpollutants causing adverse biological response andlor degradation \nof biologid populations and communities before waters can be listed for these \nimpairments. \nThe policy must allow listing and move fonvard with TMDL development even \nwhere the imairine constituents arenM known. \n~~ ~ ~ \n210.6 \t When considerine listine factors such asadverse bioloeical reswnse \npopulations, thePolicy doesn't really provide any on how baseline or \nreference conditions are to be established. populations. Additional guidance \nshould be provided in the Policy on how to establish these conditions \nSo that's --as you canimagine, this is going to make all the difference on how \n8-92 Determinine if aneffest is caused bv the suswted wllutant is not namw in No \norder to list and to be@\" the dcvelopmcnt of aThtDL If there is substanual \nev8dence that the pollutant is lhnked to the observed dfect that is ruflic!enl to \nimplicate the pollutant \nComment acknowledged. \nIdentifying the potentially casual agent pmvides a smng line of evidence Ihat a No \nproblemexists. There are many envimnmtal facm that eanincrease or \ndecrease an organism respanre to a pollutant (cg., temperature, flow, other \npollutants, pH etc.). By identifying the potentially casual agent, we are more \nconfident Ihat there is adverse response in a biological community due to a \npollutant \nThe Policv is vame in identifying reference conditions because Ulese condition No . -\ndepend on many rite-specific~fack. A discussion of these factors is contained \nin the FED under Issue 50. 1.10 COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nthese evaluations turn out, what the baseline and thereface condition is. So \ntherefore, we would recommend some add~tional guidance be pmvided in rhe \npolicy on how to establish these mditionr. \nDraft Policy, Section 3.1.9: Degradation of Biological Populations and Communities \nFor population or community degradation related to sedimentation, the term The use of theterm'mociated with' is delibaate. Association is precautionary No \nassociated with should be replaced with the term scientifically and \ndemonstrably caused by. \n1.22. 19 \t Guidance must be prowded regarding the li~frame over which degradation \nmust be mured toestahllsh s~gnnficance: at least several yearr of s~gn~ficant \ndata must be considered. \nLO.10 \t Flexibility must be demonstrated by this policy to accommadate biologic \nimpaimL Again, the mle of professional judgment, weight of evidence, \nmultiple lines of evidence, should be acknowledged and encouraged as \nacceptable policy for developing criteria, thresholds, and making determinations \nof exceedance. Language should be altered in this section to reflect thisneed \nand be integrated with section 3.19 forconsistency. \n18.88 \t The TMDL Roundtable recommended that ~ t shall be listed based on m \nsufficient credible data and information hat indicate that water quality \nstandards for sediment are not met, or Ulat impacts to beneficial uses wew and \narecaused by sediment. The draft Listing Policy is pattially consistent with this \nrecommendation. The drdl Listing Policy discusses sediment issues in a \nmanner generally consistent with this recommendation, but appears to apply the \nbinomial methad in Section 3.1.8 and 3.1.9, which was not recommended by \nthe Regions. \n44.15 \t Comparisons of conditions in a water body to conditions in a refmce water \nbody mua be made during similar season andlor hydrologic conditions for both \nwater bodies. \n48.7 \t The proposed meuics to assess biological degradation should be conducted over \na number of yean (2-3) to accurately assess the iapiment of the community. \nUsing rhon term measweme may not be indicative of the long term effe& \non the community. \n53.16 \t Concerned that the draft policy does not appear to aniculate how bioassessment \ndata can be most efficiently utilized in listing and de-listing decisions. \n8-93 and pmvides the RWQCBr some flexibility in analysis of their data. \nDegradalion of biologml populauons and cornmumties mure the No \ndimiairhed nwnben of species or ~ndivlduals of a singlespeciesorother \nmetncr when compared to a reference sile. In the facl sheets. RWQCBr should \ndocument the indei period that sampling will mu. For example, index \nouiods shwld be established for a oanicular season. time of dav.,. or other \nwindow of oppormnity when signals aredetemined m be smmg and reliable. \nOnly resulu from sinular index periods should be compared. \nThe Policy uses a multiple line of evidence appmach to detamine if standards No \nareexceeded Degladation must be exhibited as compared to a refermce site \nand associated water and sediment concenmtians of pollum~s. ThePolicy. \nprovides guidance in Ule selection of evaluation guidelines but leaves the \nselection of theguidelines up to theRWQCBs with justification in the fact \nsheets. \nThe binomial mefhod is to be applied to theasraciated water or sedimt No \nconcentrations of pollutanu only and not to the bioassessmmt data \nThe Policy has been revised to reflect this condition. \t Yes \nIt is difficult to prescribe the appropriate test for theanalysis of biological data No \nThese data should be reviewed on a case-bycase basis. \nThefirst recommendation is unnecessary; the Policy provides thenecessary Yes \nguidance to document the listing facton. The second recommendation, 53.18 COMMENT SUMMARY OF COMMENT \nRefommend to amend sections 3.1.9 and 6.l(B) of the dnti policy to split \nPWPb. \n1. In the first sentence of the fmt wram~h under 3.1.9 Dewdatian of . -. -\nRtologtcal Population and Communities add m ' pollulants arc documnted as \ndwenbed m section 3.1.6 ' \n2. Aher the fin1 rmtcnce in the fin1 paragraph under 3.1.9 Degradat~on of \nBiological Population and Communities add the sentence, 'Assofition may also \nbe made with other stresson, such as temperature, nuhiem, disrolved oxygen, \ntrash, etc. For impairments not associated with toxicity (i.e., where section \n3.1.6 does not apply), a 'weight of evidence' appmach may be used to doeument \ntile associated pollutant(s).' \n3. The last sentence in the fint paragraph under 3.1.9 should read, Tox~city \nanalyses should rely on measurements from at least two stations.' \n4. Add a paragraph after the second paragraph stating, 'Bioasswsment used for \nlistine decisions shall beconsirtent with section6.2.3.4 and sectim 6.2.5.11. ~ ~ ~ ~~~ -~~~-~.-. -\nFor blmssasml, masurmts at one rucamreach may be sufficient to \nwarrant listing pmblded that impairmmt rr asroc~aled with a pollutant(r) ss \ndetail above.' \nBecause biaarsesrments canbe used to indicate where or when an impact exists, \nbut do not often reveal hespecific cause(s) of theimpact, it is reasonable to \nrequire that an association with a pollutant be demonstrated prior to listing. RESPONSE \t REVISION \n'Association may also be made with other smxm. such astonpaamre, \nnutrients, dissolved oxygen, uash, etc' has been added afterU1.e flrst reatenee. \nIn rsponse to Ule next statemeat, the Allanate Data Evaluation don has \nbeen deleted and situation-specific weight of evidence listing and delisting \nfanon have been added. The third rsommendation will nM be added. Relvinn -. \nonly on toxncny analpis wuld severely hampa Ihe hemeasurem~lt of effecu of \nthe addruonal impam hat you nquesled be added to the dm. The fourth \nquested addition will beadded tothe section. \nThis revision has been made to the Policy \t Yes \nSection 3.1.6 (WafsISediment Toricitvl amvides onlv a oartial list of the ~ ~~~ ~~ ~ \t ~~~~ ,.- , r~-~~- .~~~~. \nposs~ble pollwanlr that could lmpair biological inlegnly. For example, altered \nlevels of temperature, nutrients. dissolved oxygm, lnrh inputs, or mstcnt \nchemical pollulams that am alone or in combination can also impair biological \nintegrity without exhibiting toxicity in standard taxicity tests. The hA policy \nshould be supplemented to allow for listing whenever bioassessment data \nindicates impairment and a scientifically valid association with a pollutant of \nany type can be demonstrated. \n53.19 \t Because bioassessments normally evaluate swam (and reaches), not d~screfe \n'stations.' it is not clear what methods ancovered by the sentence: Theanalysis \nshould rely on measurements from at least two stations.' (We assume thaf this \nwas meant to apply to toxicitv tests. not bioasswrment.) The intemtive \nevaluation of a-single rep-tative swam reach -as i; mutinel&erfd by \nthe bioassessment methods utilized by the SWAMP pro- -should be \nrecognized by the policy as sufficient to demonshate impairment. \n53.21 \t That paragraph is problematic because nmltiplc issues are lumped into the same \nparagraph, which cnates confusion and leaves the listing requirements open to \nwide intapretation. Specifically, it is unclear whether and how the second and \nthird sentences modify the fint sentence. The fint sentence makes perfect sense \n8-94 The reference to 'stations' was meant to represent the vastly different mter Yes \nMies Ulrough out the state. Thesentence hasbeen revised to include \ncomparisons to similar lwtions. Evaluation of a water My, as performed by \nthe bioassessment methods utilized bv the SWAMP om-. - is sufficient to \ndemonstrate impairmeat. \nThe binomial statistical test is not intended to be used for bioassessments. The Yes \nfint sentence of this paragraph has bgn separated as suggested. Thelanguage \nhas been revised to reflect that the binomial a~lies to the assofiated wllumt \nonly SUMMARY OF COMMENT \nif it is m t to stand alone, and we recomd that, for clarity, it be separated \nfmm theremainder of the paragraph. The last two sentences of this pangraph \n(i.e.. resuirine a minimum numberof 'samolcr' with a confidence level of W \npercent uun& b~normal drsmbuoon)appiY togurdelma for sedlmcnt quality. \nfirNshellfish conswnpuon, w btGluumulauon They are not applicable to \nbiaasresnnmts (whichrely anintegntivecompmirs samples and multimcuic \normultivariate-derived indices). To amid confusion, the policy should clearly \nacknowledge that bioassessments do nM (dCannot) properly dym thesame \nstatistical tests as guidelines for sedi-t oualitv. fishlshellfish mnsumDtion. or - . . \nb~aaccumulauon. llur can be accompl!shed by adopung the suggestrons of lhc \nTMDL roundtable, or by spl~tung the second paragraph of sectton 3 1 9 and \nAcknowledges that Section 3.1.1 1 (Alternate Data Evaluation) may pmvide for \n303(d) listings based mbioas5essment data if 'cotxhmting evidence from \nindependent lines of evidence rhow ndve standards arenot attained.' \nHowever. eiventhe wide acceotance and disaiminatorv wwer of modem - .. \nbtoassasmma. the draft poltcy should be rupplemnted to anrculate Men \nbtoauasmenu may be used wthout the need fn'tndcpendent ltncs of \nevidence.' This eon- can also be molved by adopting the suggestions of the \nTMDL mundtable, or by adding language to section 3.1.9 as recommended \nabovc. \nWhen considering listing factors such as degradation of biological populations, \nthe Policv daern't mllv orovide anv guidance on how baseline or reference ,r ,-\ncondtttonsare to be establlrhed Add~tlonal guldancc should be provtded in the \npaltey an how to estabhsh these condtt~onr \nThe rend at the federal level on regulation and research is to focus on biological \neffects and impacts, because the whole point is to protect our water resources, \nyet this listing policy is Leading California in the exact opposite dimtion. \nDraft Policy, Section 3.1.10: Trends in Water Quality \n11.9, 13.4, 13.12, Item 1states that at least threeyears of data will be used. Based on work \n13.3.19.9.22.5. conducted bv several rerda. includine Benda RJSFS 2002. Benda 2003). -\n23 10.30 8.64 9. tt is clev that m my mvlronmnu. rnclumng landsl~dc prone tmn. \n71 4,203 6 background condruons and mds m w3mqusllty cannot be dctrmuned in such \na shon time \nW \nW COMMENT \n53.22 \n~p \n210.7 \n217.13 RESPONSE REVISION \nThe alternate data enluation section has been deleted but theadded situation Yes \nspecific weight of evidence factors ran be implemented using bioassessments. \nGuidance for the evaluation of bioarrssment data is provided in sdon 6. No \nThe section oumoselv orovides eeneral euidelines to allow RWOCBS . . .. --\nflextbtl~ty foradopltng methodology that bcn meea the,, needs and at the same \ntrmc allows for the use of data fmm rxlsung b~oauessmmt programs \nComment acknowledged. No \nIn providing general guidance for assessing trends in water quality, the Policy No \nestablishes that the amount of datato be used in assessine mds, should not be \nCS~thanLhree yean llusurncham was wlccted bsau; thnrshould be \nruffictrnt Umc to tdenufy baselme condluons The Policy calls for31 least two \nyem of data to list water bodies and this seemsto be a reasonable amount of \ntime and data to establish baseline conditions. An additional year would be the \nabsolute minimum to establish Ihedecliningaendin water quality.ThePolicy \ndoes \"at establish an uppa limit on the amount of data tobe used by the \nRWQCB in listing for a decline in water quality. COMMENT SUMMARY OF COMMENT \n51.17.76.4. Consideration of threarened wambcdies is clearly required by USEPA CWA-\n102.10, 108.7, related regulations. It is iguored in the pmpased Policy. \n115.4 \n2129 \t For a normal listing with data. there sa rrqulrrmnt thal 10 percent of sarnpln \nwith a confidmce level of 90 percent, ulng b~normal dinributions, show one \ngels listed. For lhe wends, it's aol clov. Then is no eancmlc gutdellns on thal. \nPhps rpeeific guidelines, such as at least 5 percent of urceedances, or there is \na 25 pent rnc-e in the pollutant wncenwtions over a five-year wad, or \nif there is a minute number of sam~les. The onlv statement is that there are* yean, and they have lo lmk a1 some general gudel~nes. So those critcnan \nare sorubledive. they need lo be nuled do- a litllc bit more if tmdr are lo be \nused at all. \nDraft Policy, Section 3.1.11: Alternate Data Evaluation \n5 1. I 1 10. 12 11. Cancmed thal lnslurton of thls satton wuld rrsull in the cooltnued tnclusran \n19 12.29 9.39 5. of ualm bodla on the State's 303rdl lrsl m theabsence of nnformal~on that \n68 4.71 1.73 3, \twarn quallry swndd arc exceeded or ht bencfinal uses are ~mparcd RESPONSE REVISION - ~ ~~p \nThe Policy sectionon tends he,?, been revised to adh thw concerns. The Yes \ndefinition for a water quality limited segment, as defined by 40 CFR 130.2 (j) \nstates that, any segment whae it is known that water quality does not meel \napplicable wata quality standards, andlor is not -led to meet applicable \nwarn quality standards. even after the application of lhe technology-based \neffluent limitations required by sgtimr 301@) and M6of the An BPolicy \nis consistent with this definition and requires that the assessment include a \ndescription of whefher Ihe declining uend in water quality is upeeted to not \nmeet water quality standards by the next listing cycle. \nThe b~noniial lesl helps evaluate dichotomou data in ndcr to as- No \ncompliana with walerqual~ty standards. Trend analysis mnhods help delect \nand esl!mle changes in water qualily data over urn. For example, one of the \nmost mmman pmeedures for &sing vends is linearregrcssici lXs tool is \nused lo determine temporal or spatial mends where temparal or spatial panm \nare smne. Iinearreerssim calculations are oerformed on a data set - ~ ~ ~~~~ \neantain~ng palnof obmtionr (Xi. YI), ro as loobta~o heslopeand intercept \nof a line that 'best fils' the data. For temporal uends, the Xi values rcpraea \ntime and the Yi values represent the observations, such as pollutant \nconcentrations. An estimate of the magnitude of trend canbe obtained bv \nperfomung a rcpslon ofthe data \"&us tlme and ulng the slope of the \nrcgresslon line as tkmeasure of the slmgth of the ocnd. Urlng the btnomal \nlesl is no1 appropnate far crnmung decllnes in water quality \nThe Policy also establishes lhat the amount of data to be used in asscssing \ntrends. should not be less than three vm but it daer not establish an u~oer \nllml on the amounl of data lo be u& by the RWQCB in listing for* d&line \nin wan qualily. Funhmore, datalo properly subnanuate the decline of \nwater quality may require the application of other unique and analysis \napproaches to account for such factors as seasonal or weekly systematic \nvariations. data autocornlation or iumvs in the data due to intaventions a \nsampling praccdmlchanges. There ar; many widely acrepled trend analysis \napproaches curmlly available. The use of any specific apprwh wll depend \non the data available for analysis orspecific chammaistics asroeiated with the \ndata. Providing specific guidance does not allow theuse of thc most \nappropriate umd analysis approach in the area when the water bady is \nlafaled. For this reason only a general guidance on how to address trends in \nwater quality is provided. \nThe Polley has bm revtsed and theallmale data rvaluauon recllon has hem Yes \ndclelcd The Policy now ~neludcr a Sltuaum-rpeofic We~ghl of Ev~dence \nLrtmg Factor The jusl~firauon to suppon llrtlng an the %coon 303td) lrrt COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n83.11,208.8, Alternate data evaluation methods as specified in lhedraft Policy could allow using this factor is now more inclusive and includes pmviding dalaor \n220.4.221.4 \t considenble discelion in evaluatine wafer bodies and may lead to infomtiw to su~ilon the lirtin~, dewribinn in the hefa *eels thesubstanrial -\nlnappmpnate llsongr Encourage IheSWRCB to carefully add- these bar6 ~nfact hom.khtch the lls~&can be &sonably lofrrrcd, demonswung \nconcerns soUiat oblect~ve methodsanused to edrute ~mpatmnts and that the wclght of endence shows the wlm quahly standard tr not wned and \npmduce rc~enufically defmlble 303(d) l~sungr demnslnt~ng lhat the appmach rr w~enuhcally dcfens~ble and rcpmduoble \n89.61 10. 102.6. 7lur Section rhulld be removed fmm the policy Good dcc<s;on-ding rcrullr The rooion huhem removed fmm thePolicy and repland wth lisling and Yes \n107 5.203.7 from lnrmted discretion in othen than the pol~cy dm. Allow for alt~mauve delisung factors that allow RWQCBs to use a weight of evidenceapproach to \nmethods of evaluation off sets the paitiv; changes othenvire effected list or delist waterr. \nand adds additional discretion at agency levels far below the policy maken. \nMove away fmm subjective policies and toward objective measurable criteria \nfor listing. \n18.19.48.8,53.8 \t It ir not clear if all or only a kw of the)usuficationr pmndcd need to be mt for The Policy has b&n nvired to prnvide rnorediscreUan in establishing limngs Ya \nlisl~ng on the 303(d) list. It is also not clear if only the cxccedance frequenqar and dcltrnngr when the pmnsions of the Policy are not met or are not \nbiological and phyrical pmm will be used as the basis for listing. applicable. \nErceedance frequency by itself may not be reprerenrative of an impaimt \nunless it can be shown that there is biological degradation to the community or \nphysical degmdation to the water body that is negatively impacting the \ncommunity. \n18 32. 18 7. I8 17. \t Th~s seeuon should be renamed the Wcrght of Evtdcncc method The Woght of Ihe Polley prander guldancc on the wctght afev!denee approach and rmplayr Yn \n20 9.20 11.40 53. \t Evldrnrc mrthod would be mod~hed lodacnbe the types of documntauon a nmtrvc pr-s uhcre indlmdual lrnes of endenrc ue cvalruted xparalely \n80 5. 101 5 that must be pmv~ded to jusufy ttstlng a wstn body. dthe b~normal muhod 1% or combtned urmg the judgcmnt of lhc SWRCB and RWQCBs Uslng lhls \neither inappli&ble or would suggest not listing. Delete text fmm various approach, for some listing factors, a single line of evidence could be suficient \nidentified Listing Factors and combine either into one section or include into the byitself to demanslnte Mter quality standards auainmmt. For other listing \nWrivht of Evidence method. factors. multiale lines of evidence would be needed to determine standards \nattammcnl In rltll othnctreumswnces, som lnfomutlon may stdl indcarc \n\"on-attamment of standards in those ntuauans, s~Nauon.spec~fir wcrght of \nevidence listing and delisting facton have been added to the policy Ulat \npmvide processes to allow the use of additional lines of evidence provided that \nthe RWQCBr justify their decision. \n18.33 \t It is not clear what types of scientifically defensible pmcedures would be mhis section har. been deleted from the Policy. However, the ure of statistical NO \nacceptable faranalydng data and how catain types of pmcedures wuld be analysis is necessary loraise confidence in decisions Ulat arebased on limited \nshorn to beequivalent to thebMal method in tm ofconfidencelevel and information (i.a, Ihat thesamples arerepresentative of actual conditions). \nhypotilesir testing. For example, it is scientifically defensible to evaluate data Graphs are useful to observe relationships among variables but they do not \ngraphically and to consider seasonal pat- of ereeedances, but it is not clear numaically address the issues of bias, variability, unCa&ty, and the \nhow such an evaluation would meet this criteria. potential for -that sampling inevitably inuoduces. Graphs are valuable \ntools thatgive a visual presentation of the data being gaIheIed. When '.combined with slatisties, graphs can prnvide an effective visual representation \naf the recorded connu overtime. For example, graphs can pmvide an effectiveW visual of seasonal patterns of exceedances. This is valuable information for \nestablishing sampling design and parameta but not for establishing theW validity of the sampling data. a, \tB-97A COMMENT \nNUMBER \n18.35, 18.34 \n18.6.40.90.40.30. \n40.92 \n25.11 \n40.91 \n40.94.51.130, \n51.142 \n53.9 \nW 64.7 \nW \n00 IW.8 \nI-' SUMMARY OF COMMENT \nThis section appean to require Ular a mtive objective not be attained in order \nto list underthe Alternate Data Evaluation. \nThe policy is unclear asto whether and how alternative data evaluation and \nweight of evidence analysis procedures will be applied in Ule assersmnt \nP--\nConcurs with concerns presented by the Executive Advisory Committee for the \nStamwater Fmgram County of Las Angela, and Richard Wawn on the \nproblems associated with h'ends in water quality andalternate data evaluation. \nnKseprovisions for listing warn based on alternate data evaluation should \nmore clearly apply to all data typsincluding sediment, tissue, toxicity. and \nbiological response data. \nConcerned that the dranpolicy mntly states 'the measuremenu can be \nanalyzed using a rcientifieally defensible pmeedure that provides an equivalent \nlevel of confidence as the listing factors in section 3.1.' This seems to require \nany and all data must have 90% confidence level to be used in assessing \nimpaired warn, which may be inconsistent with the concept of a weight of \nevidence approach. \nme intent of SWRCB appears to be to allow the use of a weight-of-evidence \napproach in some circumtanees. 7he weight-of-evidence appmach is for the \nintnpretation of nanative objectives because of the nature of the data and \nanalvlical methods necessarv to evaluate narrative abiectives. Such an aooroach .. \nshould bc outl~ned in a new draft Pol~cy secuon 'Evaluatton of Nsrrat~ve \nCntena ' Ln lhlr rect!on. use of ~nlcrprctat~ve tools akr than the nwncnc \nguidelines--including biological assessment methods, biological monitoring \nmethods, madelr or formulae that use input of sil~specific infarmation/data, \nrefereneebased systems, and other scientifically defensible methods--should be \nexplicitly pnmitted. \nThe reference to Section 4.2 is not clear. Why does hissection refer to \ndelistins reouiremenh? \nThis subsection should be renumbered 3.2. Section 4: California Delisting \nFactors \nMainlain the requirements for RWQCBs justitifations currently included in Ihe \nAl1RMte Data Evaluation listing factors. \nThe dranPolicy rays, 'RWQCB may use alternate exceedanee frequency, if RESPONSE REVISION \nThis section hasbeen deleted and replaced with a more nanativeand inclusive \nsituation-specific weight of evidence listing factor. Yes \nThenew situation-specific weight of evidence listing and delisting factors will \nbe applied when RWQCBr have somevidence that water quality standards \nare attained or not attained but the amount or qualily of data dona meet the \nmuiremenu of Uleok factom in the Policv. No \nComment acknowledged. No \nThe situation-specific weight ofevidence listing and delisting factors apply to No \nall types of data and informtion. \nThe alternate data evaluation section has been deleted and replaced with a No \nsituation-specific weight of evidence listing factor. This new approach is \nconsistent with weight of evidence appmaches used or suggested for section \n303(d) purposes. In addition, Listing Policy's weight of evidence appmach \nnow allows RWQCBs to request placement of a water on the list even if the \nprovision of the Policy are not met aslong as there is evidence hat standards \nare not attained and that the listing can be reasanably infesred fmrnthe \ninformation at hand. \nThe new situation-rpecih weight of evidence listing and delisting factors Yes \nallow RWQCBs to use a wide range of data and information as well as \napproaches for listing and delisting. To use this information RWQCBs need to \ndescribe how data and information affords a substanfil basis in fact which the \ndectrmn wn be reasonably nnfmed RWQCBr also need to dcmonsuale that \nthc appmch ured is sc~enufically defens~blc and rrpmduelble \nThe reference to Section 4.2 was in emr. Yes \nComment acknowledged. \nComment acknowledged. No \nA situation-specific weight of evidence listing factor has been added to pmvide Yes \nB-98 60.32.76.19 -- COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \njustified. lustification may include ...' That eanbe interpreted in multiple RWQCBr flexibility to interpret data for ure in listing decisions that do not \nways. This section says, 'At a minimum the justification must damnsoate ...' meet the listing decision des. \nfollowed by a series of bulleted requiremts. W~th proper modification, Ihis \ncan omvide an auan and mechanism for makis mad decisions. \n~ \n108.17 \t SWRCB Comment: If Ule binomial rmuiremts cannot be met lhealternative Comment acknowledged \ndata evalual~on can be used RWQCB; wU set cnlma Thm n suffic~enl \nfleubtltly Thoc.aresuWe~enl allemalves \nResponse: Disagne. The'altematives' are unguided. The RWQCBs will have \nno power to fix problem. The alternatives are burdensome. You premise is \nincorrect. \n109.3 \t Evidence fmm oihm stater shows that the alternative data evaluation-+he Corn acknowledged. No \nweight of evidence appmach-cwld reduce conflicts between USEPA and the \nState over fum~ 303(d) lists. \nDraft Policy, Section 3.2: TMDLs Completed Category Factors \n60.31 \t The special condition of this subsection should be revised Iospecify that a This seetion has been revised for clarity. Yes \nTMDL has either been appmved by or established by USEPA for the pollutant- \nwater segment combination. The special fondition Ulat an Implementalion Plan \nhas been approved for theTMDL should be deleted since implementation plans \nare not required by the CWA and USEPAertablishes technical TMDLs wiUlout \nlmplementauon plans \nDraft Policy, Section 3.3: Enforceable Program Category Factors \n13.6 \tThis section clearly applies to foresuy operations on non-federal lands in Comment acknowledged. No \nCalifornia where the Forest Ractiee Rules (FPRs) are an 'enforceable pmgramm, \ndirected in large part to protgt water quality that could be used to reduce \nTMDL assignments in Ule fulure. \n13.7 \t It is not clear what is meant bv 'site-soecifie rtudv. case soldies fmm similar While the cixumtances cited mav verv well be me, an assessment should be Yes \nloe3uons. or research results fmmapplicablc srlualions' Monilonng mulls wmpleled in light of all the iofo&l& a\\uhble forwatn wgmts with \nruggat that npanan leave rcqu~mrnts, pvucularly under thc'lhrealened and putrntlal ~mpacts fmmelcvaled waler temperature To allow mom flexibllily in \nImpaired Watersheds Rule Package. are adequale to prcvcnl uatn vmperalun RWQCB dccirion.nwk~np. lhis c3legory has been eliminated and a new \neffects related to forestw omtions, with wt-harvest canopy exceeding FPR category has been created: the Water Quality Limited Segments Being \n~ddmsed. Under this new category, if the RWQCB has certified under the \nomvisions of the Water Oualitv Contml Policv for Addressing baked -, \t -. \nWalea: Regulatory Smcrwe and Options Ihal lhc pollution control \nrcqulremenls olhm Ulm TMDLs arc rwonably expected la d l in the \na~tainmmt of the water qull~y smdard. Ule impairment will beaddressed COMMENT \nNUMBER \n13.8 \n14.8 \n2l.31.40.26, \n40.27.48.9.48.10. \n108.3 \n21.32 SUMMARY OF COMMENT \nSWRCB could greatly increaseregulatory effectiveness and efficiency by \nacknowledging bt California Farert Practice An and FPRs arean enforceable \nprogram for purpose related to this category, while at Ulerame time providing \nguidance on whal additional sNdis or monitoring pmgra~ are needed for \ndocumentation under the proposed policy. \nRecommend that the Listing Policy not address enforceable programs since the \nTMDL Guidance already pmvids a mechanism for recognizing such programs. \nIn order for this Enforcable Rogram pmvision to apply, the policy states hat \nthedischarge SO- subject to the enforceable pm- need only comprise the \nmajority of the pollutant load causing the iimpeimt. This provision is \npotentially inconsistent with federal regulations because minority sources not \ncovered by theenforceable programmay be sufficient to cause wata quality \nstandards violations even if themajority source is conmlled. \nThe Agricultural Waiver Fm- is not an appropriate Alternative Enforceable \nProgram to conml runoffldischarge fmm irrigated agriculture. \nDraft Policy, Section 4: Delisting Factors \n8 10.51 143. Wc recommend that the deltslrng pollcy be retired to qurr the demonsoauon \n51 144 that the dellsung hhold is morcngorous lhan ihc llslnng liveshold In most \nsituations, the listing and delisting evaluation melhodologies should be \nconsistent to ensure that the delisting threshold is more rigorous. \n18.63 Recommended that lhePolicy should describe how waters areremoved from the \nlit. Walen should beremoved from the List when the data and information \nindicate &at water aualitv standards arebeine attained. The draft Listine Policv . , \" -, \nIS pmlally constslenl wth Uur recommm&l,an Secuon 4 dacnba how \nwaters cm be removed fmm rhc 303(d, hn Waters can be ddrslcd tf fewer \nthen 10% of the samples arenot exceeding standards. The Policy, thenfore, \nallow waten in \"on-atlainmen1 of standards to be delirted. \n40.107 For de-listing waten fromthe 303(d) list, the'pmposed policy appears to utilize \nthe same statistical aoomach and underlvine assunmtions (fewu than 10% .. . \ncxccedances wrth 90% confidmcc level) as dermbed m the l~rl~ng \nmethodology We ruppn the State's dec~s!on loapply a dlfferml null \nhypothesis in assessing potential delisting decisions RESPONSE REVISION \nunder this category. \nThe Policy should remain gend so that the RWQCBs can make their own \ndeterminations as to wheIherornot a program is wnking and/or should be \nconsidered. A blankd exception for any propro aclmowledged as an \nenforceable program cannot be made. The RWQCB have the discretion to \ncertify, under the provisions of the Watu Quality Control Policy for \nAddwing Impaired Walen: Regulatory Shuclure and Options, thatpollution \nconuol requiremenu other lhan TMDIs arereasonably expeued to result in the \nattainment of the water quality standard. No \nThis seuion of the Policy has been revised to avoid duplication with the \nTMDL Guidance. Yes \nThe statement has been removed fmm the Policy. Yes \nComment acknowledged. No \nBased on the commrnls received at the Seplcmk 8.ZW wotkshop, the Yn \ndcl~rungrequrremnls have been mdc marc ngomus by qulnng more \ncertainty to delist than to lisL \nAs it does for listing, the Policy establishes a statistical pracedure to judge with No \na orescribed level of confidence and vower when a certain numba of \nekedances (aless) observed in water aualiN ramles should Uieeer theneed \nlo dcl~sl a wter bcdy The ngor and val;&ty bf thehelsung mod~qual that \nforthc ltrttng prdurc \nComment acknowledged. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n40.108,51.136, \n51.138.51.139. \n51.140,51.135, \n51133.51 134. \n217 15 Delisting requirements should include specific requirements on data \nrenresentatioa. The drahPolicv currentlv reauirer a minimum of 22 samles . . \nbcfmawalcrbadycan beevaluated fordelirung. However.thepolicy \nconulns no spenfir data representauon requirmrnu for there 22 samples. such \nas the rmnirmm timehame in which Ulaerampla w be collected and specific \nconditions that should be captured. All data representation requirement described in the Section 6 (Policy \nirwlementaIion) must be met in the evaluation of delisting a wata body.-\nIn terms of rpmfic data reprcsmwuon. the Polley is intended to allow the \nRWQCBs the Il~~b~ltry to use samples c~llmcd in a n~ietyof uay~to make \nlisting decisions. 'Ex t m and spatial representation requimfs arethe \nsame for listing and delisting. These requiremenu aregmeral so RWQCBs \ncan make decisions to list or delist with all the available data and information. No \nToomuch specificity might mderlhe Policy unworkable in cedn \nei~cumstanee~. \n41.2 The fint sentence of the second paragraph should be modified as follows. All \nlistings of water segments shall be removed fmm the section 303(d) list if Ihe \nlisting was based an faulty data. It is necessary to clarify Ihat the RWQCB \nshould not only reevaluate but delist water segments Ihat were listed based on \nfaultydata or information The Delisting Factors establish the criteria to remove waters from the lisL This \nsentence is not needed. No \n43.49.60.34.76.22 The delistine fadon section does not omvide far removine water se-u from \nthe 303(d) ~btif specific pollutants have not bcen idenufi;d A factor \nshould be added to rpccify that existing water segment-pollutant combinations \nthat have been Insled urllhoul sprr~fie pollutanu ident~fied shall be removed \nfmm the 303(d) List and placed on a ~ollutantIdentification List. In the delistine factors. the Policy stafer Ihat watm should not be listed if \npollutanu arenot idenufied (tox;cay is an umpuon). The Policy pmvida \nd~reeuonon thc dispm~tton of waters and pollutanu relauvc to the srstion \n303(d) Its1 Plavmmt of waln on s 'Polluuon Lirt'is bcymd the scope of the \nPolicy. No \n48.11 The last sentence should be revised to clearly state that a water body can be \nremoved fmm the 303(d) list if the applicable section requirements under which \nit was orieinallv olaced areno loneer aoolicable. The sentence cannow be ,. .. \n~ntcrprrted tomad that dl eond~ttanr l~rtcd m the hersuon must be ma pnor to \ndellrung a water body For Instance. Sgtlon 4 3 is mended solely fn barlena \nand theinylairing pollutant may be a metal. In thir case, it does not make rmse \nto require thir section to be met. The sentence hasbeen clarified. Yes \n50.8 An effort to delist a water requires full compliance with all laws and should \ninclude a mechanism that verifies the existing condition and identifier any \ncanduct that would defeat a delisting and would not be obsaved or documented \nuntil afm the sampling results could authorize a delisting. Any decision to remove a water from the section 303(d) should comply with \nfederal law and regulation. There areseverallistin@ Ihat should be \nreconsidered in light of the data that areavailable. Requiring new data in all \ncases reems to contradict fedml requirements to base decisions on all readily \navailable data and information. No \nW \nW 51.141 \n51.146,5L.145, \n217.18 Thisitem should be added to this section. \n-Recvduatim of existing data should not be conducted unless it can be \ndemonstrated by the questioning party that the listing was based on faulty data \nor if objectives and standards have been revised. \n'Ex deliaing policy for marine recreational watm should require the use of a \nreference system approach to msun consistency between the listing and Review of listings should be performed if wananted. The provisim of the \nPolicy may influence which warn areincluded on Ihe hel. \nThe Policy has been revised to allow Ihe use of the refereact system appmach \nto remve listings related to bacteria if Ule water quality standards allow. No \nYes 58.10 COMMENT SUMMARY OF COMMENT \ndelirting decisions regarding thse water bodies. \n7he listing policy for rparioe tcaeational waters recommends the use of a \nreference site to amount for exwedances of health-based bacteria standards that \noccu due to natural sources The dellrung pal~cy for recreauonal beaches uses \nan exceedvlce threshold of 10% usmg the btnormal d~smbutlon for a \nconfidence level of 90%. These two approaches are inconsistent, and could \nresult is a delining Uwhold that is lss rigorous than the listing quiremenu, \ndepending on reference beach used to list. For example, a beach could be listed \nbecause it has an exceedance rate greater than its associated reference beach. \" \nbut if the nfaence beach has an cxcecdancc rate low than those lasted in \nTable 4 1 (the b~nomal model fordel~sl~ng). lh beach could then be el~g,ble for \ndelirting- not because water quality at the beach has improved, but because the \ndelisting threshold is lower Uw the listing threshold. \n5 1.165,51.137 \t The draft Policy currently does ncipmvide fortbe '-in of safety' dled for \nin the CWA. For instance, a fixed time period will not be sufficient for many \ncircumstances. As an amle. if a Wor is listed for smthetic chemicals that \nadhm lo fine sedlment parucla, 11wll need lo be mon~tored far a suff,eiml \npenod of tlme to mclude ramy reasons that dnve the fale and mrpon of lhc \nsubstances. A draft Policy Ulat had an appropriate delisting margin of safety \nwould include guidance establishinia minimum (rather than fixed) sam~ling - -\t . .-\ntime period, as well as a minimum sample count. \nIn addition to requiring a minimumsample size of 22, the delisting policy \nshould clearly require that data mt the following specific representation \nrequirement for all delisting evaluations: \n-A mntmum tsmcfram for data ~ollectton must be estabhshcd Wc \nrecommend lhal the data represent a mrumurn of three yran It is itqmallre \nthat a minimum time period be represented in the data to acmnt for temporal \n-ability, which eanbe significantly related to a host of factors including \nclimate and reasons. In wnicular. rainfall conditions mtlv-. influence water \nqual~lyin most water bohm in Cal>fomm. drought condluons have 13sted for m than rtx ym 31 a umc So, a W-ycar requlremcnt should he wewed as \nan absolute minimum \nThesecond paragraph allow for delisting based on faulty data, however, it is \nunclear how this pmcess might be initiated (RWQCBs and SWRCB) and how \nlhe quality of data might be asserred \nThe delisting criteria assumes an incomt null hypothesis Ulat the water is \ncontaminated RESPONSE \t REVISION \nA minimum of Ihm-yean of data to suppon removing a water horn the section \n303(d) list is not justified unless therequirement for 3-yean of data is \nnecessarv for listine as well. Lareer data setsthat cover sed vearsare - -\npreferable for both llrnng and dellsong dectrrons bul hs amounl of data is \nmly amllablc lfcondluons repeal over a two year penod, confidmcc in the \nassessment decision is increased. If a 3-year timeframe is used, water quality \n~roblem that are manifested within two years will be ignored. \nThe 'margin of safety' concern is focused on the development of TUDLE not \nthe section 303(d) List pmss. The'minimum' sample sire concerns are \naddressed in the FED sections related to balancing statistical errors. No \nThereview of existing listings has been clarified in the Policy. Yes \nThe hypothesis selected for assessing if a water should be removed fromthe \nsection 303(d) list assumes Ulat the water doer not meet water quality standards . . . . \nbecause in a previous listing cycle the water was judged m not meet water \nquality standards. The hypothesis that thewater does not meet standards wiU No COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nnot be accepted if data and information show standards areattained ff data \nshow ht standads arenot met then waterr will remain on the seetion 303(d) \nlist. \n60.33.76.21.76.20 \t Subseetions4.1 hugh 4.9 shouldbe renumbered 4.1.1 hugh 4.1.9. Commmt acknawiedged. No \n72 7 \t The draft pollcy suggest5 uslnga (worstcase)'moneour dclln~ng' probab~l~ty If it is mar approwale to use a diff.1 slatisod tat or diffcrmt wnfidrnec Yes \nof 10%- L e a 90% worstcase probabil~ty of'aroneous fGlun to de-list'- fa level RWIXBs mallowed flexibility to use altunale tau as long asthe use is \nsuch decisions. This seem too ittingent &less standards for subsequent data justified under the situation-specific weight of evidence delisting factor -\ncollection are immed to monitor clorelv oasrible imorovements in imvairment ~~ ~~ ~~ ~ ~ ~ 7 ,. \nIrrels. To be effmtivc, such mnltoring would probably nqutrc man \nrophisucated rtaustical sampling designs Ulan the 'fixed n' dcsiw of the Exact \n74.6 \t Ws seetion should be expanded to include speeific language to allow the The Policy has been revised to address this comment Yes \ndelisting of a water body if the data quality and data quantity requiremenu \nunder the new ~olicv are not metbv the existing listing. \n216.1 \t Concerned about ?hedelisting pmcess: concerned that we wm't be able to Comment acknowledged. No \nprotect thiswater, and nor will we be able to improve this water. \nDraft Policy, Section 4.5: Bioaccumulation of Pollutants in Aquatic Life Tissue \n21.36 \t me concept that excessive tissue residues depend on fish consumption rates The issue of fish consumption nter and susceptible populations is addressed in No \nneed to be considered especially for certain key populations who depend on fish Section 3.1.4. \nfmm a water body as their primary source of fd. \nDraft Policy, Section 4.9: Degradation of Biological Populations and Communities \n53.23 \t The use of bioasmsments in de-listing decisions. A significantnumber of water Revisions to Ihir section have been made to address this issue. Yes \nbodies in Califamia have been listed as impaired based on little (or no) actual \ndata to document violation of objectives or impacts la beneficial uses. In many \nsuch eases. bioasseument could be a costeffective tool to demonsoate \natu~nmcnt of aquaoc ilk user. thmhy jusuh/mg de-lrssngand savlng \nrubstant~al resources for addre~srng real problems Far example. where uater \nbodies have been listed for sediment based an anecdotal evidence. \nbioassersment could document non-attainment of aquatic life uses (thereby \nconfuming impairment). Alternatively, bioasrersment could document the \nattainment of aquatic life beneficial user, thereby justifying de-listing. But the \ndrafl delisting aiteria could be interpreted to impede or even preclude reliance \nW \tan biavrwment for such delisting decisions. \nW 53.24 \t For de-listing to occur under this seetion, the draft Policy specifies a minimum The statistical test is to be applied to the asmiated pollutant not to the Yes \nsample size of 22, and statistical tests not appropriate for bioassersment data. biaassessment data. 'Ilis section has been revised to clarify Ulispoint.00 \tB-I03OI \n COMMENT SUMMARY OF COMMENT \nNUMBER \nThe omvisions would make it infeasible to de-list under this Section Minx -\nhtoas-~mmu, because 22 bioasresrmenl 'rampla' would be prnhbitively \nexpensive, and broaswsrncnl data eannol be mingfully analyrcd using the \nbtnormal msmbutloa method. \nDraft Policy, Section 4.10: Alternate Data Evaluation \n53-25 \t For delisting lo occur under this rection, there must exist 'comborating \nevidence fmm independent lines of evidence: and an alternative appmach as \ndefined bv Section 3.1.1 1 must havebeen used arieinallv to dace the water .. \nrepent in Ur 1st These prnvls~ons could make 11 infeassble lo delis1 under \nthis secuon usmg b~oassessmenls, hsauc: (I)evm though bioaswsrmnt may \ndocument healthy insueam communities, independent Bnes of evidem may be \nunavailable orcnst-prohibitive: and (2) few (if any) of the currmtly-listed \nwaten that may be asteffenively shown to be'healthy' using bioassersment \nwere listed following the criteria at Section 3.1.1 1. \n60.35 \t SubMion 4.10 should be renumbered 4.2. \nDraft Policy, Section 6: Policy Implementation \n7.6 \t The Policy should allow appropriate time frames to collect adequate temporally \nand spatially representative data. \n11.14, 19.22.203 9 \tSection 6 1 stales that 'data and nnfomralton older lhan 10 ycars' sinconsirt<nl \nwth Sccl~on 6.2.5.2. \n11.18. 19.21 \t Section 6 should be moved ahead of its many referenw in the Policy dccumznt. \n19.1 \t Suppnts the inclusion of requirements regarding (data) quality and quantity \nasrwments. \n25.4 \t There hasbeen much discussion on the pmblems with water body listings in the \n1998 and 2002 listing pmess, and better requirements for data qualily and \nevaluations will prevent these problems fmm reoccurring. \n40.97 \tThecornenter developed and applied a semiquantitative method of evaluating \nwatercolumo, sediment, and fish tissue data for toxic pollutants in the process \nof developing sevaal TMDLs for Newpat Bay, CA. Recommend that the State \nconsider the use of this twe of a~~roach as oanof the lirtine mlicv. RESPONSE \t REVISION \nThe Policy has been revised to include a situation spgific weight of evidence No \nlisting factor that provides IheRWQCBs the flexibility to delist using \nbioasrerrment data if it can be documents that waragualiw standards are met \nand that the dau and inlomuon affords a subslanuai bast; in fact Ulat the \ndellrung can be masonably inferred. \nComment acknowledged. \t Yes \nComment acknowledged. \nSecllon 6.1 has been deleled. Ageneral rlalemenl regarbng revision of cxisllng No \nlistings has been incorporated lnlo #he dellsting fadorr, Secuon 4 \nThe document is organized todesnibe the section 303(d) list, the listing No \nfactors, delisting factors, and then the rupponing guidelines needed to develop \nthe list Moving Section 6 to the fmnt of the document may confuse the main \ngoal of the policy which is to: establish a standardized appmach for \ndeveloping Califania's Mion 303(d) list \nComment acknowledged. \t No \nCamment aclolowledged. \t No \nThese approaches were considered. - -- - COMMENT SUMMARY OF COMMENT \n44.6 \t It is important for the SWRCB explicitly recognize in the Policy that the mle of \nall =Milable data assembled in determining water body impaimt will be \nrubien to data aualitv and mantitv scmtinv. \n61.18 \t Requat clarification m the dwriptions of spatial reprerentation and \nreprerentation temporal bgause the technical meaning of thesesections is \nunclear. \n65.4 \t Endm the inclusion of renuiremenu for data aualiN and auantiN. .. . . \nqummts for eonnstrnt Bnd stausnally val~d data cvaluauons, and \n~rnplemntat~on pmvlraonr However. the bullQng and consrmclnon 8nduslnes \nwant to asure that these effom are practical, aehiemble and effective. \n217.23 \t Mort NPDES permit pm- are set up when you have the outfall and you're \nlmking at water quality impact at the outfall and below the outfaU. And if you \nwere to combine those togerher, that just makes no sense. And thesamesonof \nappmach mews for spatial dismbution where if you collected samples within \nthe sameweek. \nDraft Policy, Section 6.1: Evaluating Existing Listings \nRequests re-evaluation of each previously listed water body as proposed in the \nJuly 2W2 draft policy. \n43.51.44.2.47.13. \nThe paragraph at the end of section 6.1 should be moved to a new section and \nmodified as follows: 6.2. An interested party may request an existing listing be \nreassessed under the pmvisions of Ihe Policy. In requesting the reevaluation, the \ninterested pany must describe the reason(s) thelisting is inappropriate, state the \nreason the Policy would lead Ioa different outcome, and provide any new data RESPONSE \t REVISION \nComment acknowledged. \nCommen~s.acknowledged. \t No \nComment aeknowledeed. \t No \nCommmts acknowledged. \nThe Poltcy hasbeen changed lo allow for the reevaluation of an existing tisting Yes \nif new data are available or not. To reduce the workload on RWQCB and \nSWRCB staff, the quest for a reevaluation from interested pdes must \ninclude an assessment of all the readily available data and information. \nThis recornendation has been incorporated into Seaion 4 of the Policy. Yes - - COMMENT--~ ~ \nNUMBER \n8.11 \n10.18 \n18.61 \n1868 \n24.3 \n25.10 \n25.9 \nW 36.2 \nW \nal \nrD SUMMARY OF COMMENT ~ ~~ \nand information that would assist the RWQCB and SWRCB in conducting the \nreview. \nme policy should ret forth specificguidance for the RWQCBs as to the burden \ninterested parties must show in order to mgger a pmcedure fw a thorough \nreevaluation \nTimb and agricultural proponents would like review of historical listings. \nRe-mviemngall thwe Itrung would result m the sm outcome l~st~ng. Gang \nthrough Uur process would be a huge me of rnources and set the schedule for \nimplementation (you are not going to iwlenmt if you need to re-review) back \nanother2 M 3 yean. \nThe Policy should be applied ramactively within time and resource consuaints. \nApproaches for applying Uli policy to currently listed waten should be \ndescribed. The draft Listine Policv is dallv consistent with this -.. \nrecommmdatran Ex~rtrng Itrungs must be reevalwled 11new dam and \n~nfomuonam avanlable. &-re. reevaluatnm rppean to be drwret~onary \nand based primarily on whether an interested pany quests such an evaluation \nThe TMDLRodndrahle mommended that all watm currently on Ihr Swtlon \n303(d) Itst (as of 2002, should be renewed fa cons~slrncy mth ths lrsung \nwlicv within the fint two listing cycles following adoption of the listing \nilici. Recommendations wr (hi;~istine ~olic;should be made for these . , -. \nuaers Watcn on the cumnt Sectson 303(d) hn may also be renewed between \npenod~e updarcs as desenbed in Reconnrndaum 10 above Thedraft Lst~ng \nPol~yis parually consistent mlh lhts rccommenda~an The dnft Ltrtmg \nPolicy includes provisions for reevaluating mntly listed waten, but dm not \neive a timeline for conmletine the reevaluation. \nThe last sentence is misplaced and belongs at the begimning of section 4. It \nshould read: The most recently completed don 303(d) list shall form the \nbasis for anv subseauent lists. This section arovides the methodoloev for ~ ~~ -\nremoving waten hm Ihesection 303(d) lit (including the water quality limited \nsegments category, enforceable pro- category, and TMDIs completed \nListings on the 1998 and 2002 lists may have been inappropriate. \nSWRCB should consider the mevaluation of each water bady identified on the \nprevious 303(d) list. \nThe draft Policy specifies that all water bodies on the UX)Z303(d) list would be \nreevaluated using the Policy over the next two listing cycles. This would place a \ntremendous svdin on RWQCB already limited staff resources. RESPONSE REVISION \nThe Policy ha. been revised to add clarifying language Yes \nComment acknowledged. No \nComment acknowledged \nThe draft Pallcy does not state wh~n the renew of thc ssuon 303(d) llst 1s I0 No \nbe complcled Rcvls~on of the l~stsa rmff mlcnnve effon and 11 is not \nadvised that RWQCB be mandated to complete the review within a cenain \ntime frame. \nComment aclnowledged. \nComment acknowledged. No \nComment acknowledged. No \nThe draft Policy dosnM maadate review of Ule entire section303(d) list over No \ntwo cycles. No timeframe for complete reevaluation is included \nB-106 COMMENT \nNUMBER \n39.7.41.5,41.4, \n41.6,53.15,53.l4 \n39.8 \n41.1 \n44.17 \n51.159 \n53.17,53.26,53.27 SUMMARY OF COMMENT \nThe following steps should be used to complete the reevaluation of a faulty \nlisting: \nA. Doeument the basis far the original listing. \nB. Pmvide information documenting that the listing was based on faulty data or \ninformation, including, but not limited to, typographical m,impmpa \nquality assurancdquality conml pmeedurrs, limitations related to the analytical \nmelhcdsUlat wld lead to impper eonelusions regarding the wata quality \nstatus of the segment, or deviation fmm listing policies in effect at the time of \nthelisting. \nThe following steps should be used to complete a reevaluation based on new \ndata and information: \nA. All readily available data and information sMI be used to asswa water \nsegment. Data and information older thanten years may be used if the original \nlisting was based on the data. \nB. In oerformine the reassessment the RWOCBs shall use the California Lirtine ~ ~ -~~~~~ -~ ~~ \nFactan (ic..,walcr slwll be assessed as if they had never b&n ltrted before) lo \nassess each water segmenl-polluml combination. The mignal ltsllng was \nestablished using the pronrlons of llus Policy. the Callforma Delirung factan \nshall be used. \nThe Policy provision regarding listing reevaluation and delisting need to be \nclarified. The urnvisions areambieuous and subiect to varvine intmretations. \nThe Policy should reflect Ulat the delisting pmess can be initiated at any time \nand need not camswnd to the listine evcle. \nThe draft Policy no longer calls for an automatic review of all of the cumnlly- \nlisted waten. A comprehensive review of every water body on the 2W2 section \n303(d) list would be coslly, would not result in a subsmtial improvement in the \naccm of Ihelist and would cause inordinate additional delav in California's \nalready d~latory tmplemntauon of the TMDL program T~me 1s of the eswncr. \ntfwe arc to rev-the funher degradal~on of ow lamud and dwvmdltng supply \nof clean wale^ \nThe first paragraph under Section 6.1 Evaluating Existing Listing it should read \nas follows. RESPONSE REVISION \n7he Delisting Factor don coneins provisions lhat allows a watabaly to be No \nremovedfrom the list data and information anfaulty. 'Ihir clarification is not \nneeded. \nComment acknowledged. No \nThe pmvisionr of this section have been clarified Yes \n. Developmmt of the section 303(d) list is a Bourne inwive effm. If No \nRWOCBr were to be muired to consider listine and delistine decisions \nbclwn blmnlal Itst reneur, 11 would be a rubrmual dnnn on staff \nresources Staff wuld havc to be redrxcled hornother acunues. such as \nTMDLdevelopment, to address these requests \nComment acknowledged. \nThis sectionof the Policy has been deleted and a placed with a brief No \nstatement in Section 4 on the process for reevaluating existing listings. \nWater segment and pallumt on the section 303(d) list sMl be reevaluated if \nnew data and information becomeavailable. The steps to complete a \nreevaluation are: \nA. AU readily available data and information shall be used ... \nB-107 COMMENT SUMMARY OF COMMENT \nNUMBER \nB. In oerfomdne the hereasment the RWOCBs shall either: (If use the -\n(Aallfanta hrttng Fancrs (I r. ,wagen shll be aswed as ~f they hd never \nbeol lhsted before) lo ass each warn segmntpollutant mmbknauon. a(21 \nwhere bioassssmnt would be an appropriate indicator, fallow the pmess \nspecified at section 6.23.4. \n57.5,202.5 \t Periodic reevaluation of contaminant listins should be mandatory and new \nlistings should be balanced by delistings (due to new data or objective \nachievement) so that a predictable workload exists for both the regulated and \nreg\"Iat0ry co\",\",\"\"ities. \n58.13 \t RPpolicy listingr should be revisited to daermine whether appmpriate criteria \nwen utilid esespedally as it relates to analytical Quality Assurance and Conml. \n70.8 \t SWRCB should adopt a policy that bMh allows and com@s staff to evaluate \npreviously listed warn bodies if, based on current policy and available data, that \nreview might mmbly lead to a different listing decision. \n114.8 \tSome listed water bodies merit a reevaluation \n211.5 \t Commend the SWRCB for providing a mechanism far the reevaluation of water \nbodies identified in the 303(d) list using the Listing Policy. \n218.6 \t I would just like to emphasize that when we're talking about this policy. what \nwe really aretalking about anvery concrete waterways that arein jeopardy of \nfalling off the 303(d) list. And what this means is a very real impact to \ncommunities and to the local economy, and I would urge you to took with great \ncareat the rueeestionr of mv eolleames in dne vour final determinations. - 0 \", RESPONSE \t REVISION \nThe level of work does not drive which waters should be listed ordelbted. All No \nreadily available data and information is used to asras waters. \nComment acknowledged. No \nComment acknowledged. No \nComment acknowledged. No \nCommmt acknowledged. No \nComment acknowledged. \nDraft Policy, Section 6.2: Process for Evaluation of Readily Available Data and Information \n18 80 \t The TMDI. Roundtable recommndsd llwt ruff fromthe KWQCDs and \nSWRCB rhould mllabate lo rpecnly some grnpral gundance on managing data \nand infomt~on. DWQ and Omstaff ofthe SWRCB wll ~nvestigatca \nnetworked data management system (eg., utilizing ArcGlS and GwWBS) in \nwhich the RWOCBs' data and recomndations will be comoiled. Some \napproach forprksnng, rtonng and relnev~nghta and ran& infonnauun \nwll be requtred Accesslblr arch~ves of all lnfomubon subrmttrd are an \ninmasing challenge, due to volume and variety of formats. Support, with \nstaffing, hardware, and software, will need to be long-term and distributed \namone the SWRCB and RWOCB offices. Office of Infomtion Technologv - -\t -. \nstaff should evaluate the following alternatives: \na. State Board investigates contract services, via commercial vendor, to provide \na web site outside the state network, to improve access and security for public 'lhe dcvdopmenl of a data management ryncmrr an adrmn~rtralive usk that is No \nourqide the rcw of this lisung Pol~cy Data managunent is being developed \nunder contncl. Data management is wl a matlcr that should be included in lhe \nPolicy because the technical aspects of the data sysfem are best addressed by \nthe scientists and engineers completing this task. In any case, the data \nmvlagcmnt syrtem~wll ~mplrmenl the Pollcy as adopled \n8-108 COMMENT SUMMARY OF COMMENT \nNUMBER \nand slate employees. \nb. State Board and Regional Boards develop &is web siteusing state network \nfacilities. \nAt the end of the list update process, theentire contmts of the web site could be \nvdnsmitted to a State Board saver for pesewation as the AdminisVdtive \nRecord. The haft Listing Policy is not consistent with thisracommendation \nThe Draft Listing Policy dm not discuss data managemeaL \n40.13 \t The proposed policy and suppaning documentation do not contain sufficient \nrationale for a decision to exclude available data and infomation fmm \nconsideration, as required by 40 CFR 130.7(b)(6). Data and infamation are \noften useful within a 'Wightdf-evidence\" assessment context even if Uley do \nnot meet everv aualitv assurance exoeftation. ,. . RESPONSE REVISION \nData will not be excluded homevaluation. The policy has been revised to Yes \naddress this issue. \nDraft Policy, Section 6.2.1: Definition of Readily Available data and Information \n18.37 \t Delete language regarding the order that information should be reviewed It is The Policy hasbeen revised to make this change. Yes \nunclear why the Policy should specify the order in which Ioevaluate \ninformation, since Regions would just evaluate aU relevant infomation \ntogether; therefore this language is deleted. \nDraft Policy, Section 6.2.2: Administration of the Listing Process \n14.10, 18.56 \t The Listing Policy does not establish a clear listing cycle. Currently, federal \nremlations muire an \"miate to the 303(dl list everv two vears. The omcess . . , , \no&lned in th;drah \t Liriing Policy ir simlat to the process used in 1998 and \n2002. Thcrequircrnena for RWQCR heanngs may add addittonal time to what \nuc have observed in the pasL It should benaed that for the 1998-303(d)lisl \nupdate, IheRegions began the assessment process in the spring of 1997 and \nUSEPA did not aomve the list until the summer of 1999. For the 2002-303<dl \nlust update. the <imuon pracesr began in Febnrary 2001 and US EPA dnd not \napprove th* l~sl until July 2003 The llrhng pess defined m the draft Pallcy \nwill likely continue to me more than 2 ym to complete. This will put the \nState in a situation of continually updating the 303(d) list As an altemative, \nthe SWRCB should Dursue a loneer 303(dl-list u&te cycle (ex. four veml. If -\t -. \nfedml rcguhbonr rqurc a 2-yev update. the State Board could dcfine an \nrntens~vr uphte every lour yean (1 e full revlev of all avolable data) wtth a \nless intense update in between (e.g. a review of specific requests for changes) \nW 18.67 \tThe TMDL Roundtable recommended that the RWQCBs should be responsible \nfor assessing the existing and readily available information, including W \t information racewed dwing the solicitation process. The RWQCBs shauld also The two year cycle to update the section 303(d) list is required by federal Yes \nreemlation and is not defined by SWRCB. Performing a less intensive swey \ndocs nm comply with federal &lation that requimktates to evaluale all \nreadily available data duhg each cycle Mng the development of the 2004 \nIISI, SWRCB will use a mcdifird sppmch toconplctcUle list. SWRCB will \ncomplete all tasks related to Ihedevelopment to the 2004 section 303(d) list. \nThe DO~~CY has been revised to acknowledge the abbreviated mess to be used \n~n2d04 . \nThe last sentence is an administrative task that will be addressed when the list No \nis developed. 43.4 COMMENT \nNUMBER \nSUMMARY OF COMMENT \nbe responsible fa identifying wat~ on theList. The RWQCBs may hold a \nworkshoo andloroublic hearine to take comments on staff recomdations. \nThe RW~B~ amon to adopt raommendedehanga lo shdd then &formal \nthe Igsl llw RWQCBE wll be raponrtblc for rubrmlung lo the SWRCB the \nadrmntstrat~ve nrord wbch suppons them rsommndauons The SWRCB \nshould review each ~~QCB's~mom~ndatioos fa consistency with the \nListing Policv. The SWRCB should aeeeot RWOCB recommendations. unlesr -. -\nthey aninconsistent with the Listing policy orapplicable law. TIESWRCB \nshould then adopt the statewide List hugh a formal action. The draft Listing \nPolicy is consistent with Ihis recommendation. The drah Listing Policy also \nmaka it clear that only issues raised before theRWQCBr will be considered \nThe Listing Policy m&alu,need to erpliciuy limit the time period for \nsubmission~af data and infmtion. RESPONSE REVISION \nIn developing 303(d) policy, the SWRCB should address the following The mles of the SWRCB and RWQCBs are explained in the Listing Policy. No \nquestion: What anthemla of the State and Regional Boards in making and \niml~m~ntinonnlicv7...r .-.-=. . . ., \nDraft Policy, Section 6.2.2.1: Solicitation of All Readily Available Data and Information \n18.66 \nl8.69,80.9,80.10 \n18.75 TheTMDI. Roundtable mommended that each KWQCB should be rnponrtble \nfor rol~ciung information from mreresled pr~plnlcs rvlllun tu Rc~on.The \nSWRCB should be rermnrible forreques&n information fro& agencies/entities . -\nthat are likely ahave ~nformation relevant to multiole reeions (e.;.. from. --\nfrdmVState agencler ahorn he Statc unrvcntry systems) The sol~c~tauan \nprocess rhould take place dunng the same penod of ttm m cach Regton The \ndrafl Listing Policy is consistent with Ulis mommendation. The draft Listing \nPolicy should explicitly state that the solicitation pmess will take place \nconcurrenUv at Ule SWRCB and Rezions. \nThe solieitation for data and information and assessment needed for changes to \nthe list should rakeolace everv four wan. The RWOCB mav. on its own . . \nmouon. rsommmd changes to the list bet- penodic up&tes. Any such \nchanger mun go Uuoughthe ram process as the pmodte updales (eg. \nRWQCB adoption of the recommmded change. SWKCB approval, and USEPA \nappmval for Section 303(d) listed waters). The draft Listing Policy is not \nconsistent with Ihis mmmdation. The draft Listine Policv makes no -. \nmnuon of the frqmcy of the assessment procar. Currently vlnual 305(b) \nrcpom are qu~rcd and b#enneal303(d) lists Withohout a defined State pol~cy on \nthe frequency of assessment, Ihe State will likely be conducting continual and \npossibly overlapoiina assessment processes. \nThe NDL Roundtable recommended that lo pronde 3 minimum rtateuldc \nlevel of conrirtcncy and complcrmers in solictting existing and rcadlly avstlable 1kPol~cyhas bun revised to add VLlt SWRCB and RWQCBs shall lnltialc Ycr \nthe lrsling pmar by cancurrenlly and acuvcly rollciting all redly available \ndata and information. The division of task to be completed will be \naccomolirhed administratively when the data solicitation is initiated \nFedaal Regulations (40 CFR 130.7(d)) currently requires that &e warn quality No \nlimited semen& list be submitted to USEF'A evw ovoyears. This deadline . ~ \ncould be changed in ihe fum.By not including any spcnfic dradlinc in the \nlvlgrwge the Policy, it assures that the Polncy wll remain meor with 1cgard to \nsubmittal ufthe 303(d) Inst rcgardlwr of any frdenl regulatory change in \nsubmittal deadline. \nLanguage rquinng that each RWWB dmmcnl its solicitation pmccss is nM No \nnecessary. Ttur docummtation issue is adrlmred when RWQCBs submit - - 18.78 COMMENT SUMMARY OF COMMENT \nNUMBER \ndata and information, each RWQCB will solicit, and document its methods and \nsources for soliciting, existing and readily available data and information. In \ngend, RWQCBs shall seek readily available data and information genmted \nsince lhe prior list e~luation perid. For purposes of dam and information \nsolicitation, information is any doamentation describing Ihecurrent or \nanticipated water quality condition of a surfacewater body. Data are \nconsidered to be a subset of information that consists of npom daailing \nmeasunments of specific environmeatal characteristics. Data and information \nnot submitted by intaested panies in response to the solicitation are not \nconsidered to be readily available. The draft Listing Policy is consistent with \nthis recommendation. A requirement Ihat each Region document its solicitation \npmess should be added to be fully consistent with this remmmendatian. \n18.77, 18.76 \t The TMDL Roundtable recommended that the SWRCB shwld provide a list of \ngend methods for acquiring data and information (e.g., mailings lo Basin Plan \nmailine lists and llsls of other interesled &es: - website matine: direct reauests . \nlo relecl agcnncs. and lnlemal RWQCB rtaffrequests) that Ulc RWQCBr vnll. \na1 a mnrmum use ro sollc~l exlsungand reahly avslabledata and \ninfmtion. The dran Listing Policy is not consistent with this \nrecommmdatian. No description of the methods to be used to condun the \nsolicitation is orovided. \nThe TMDL Roundtable refommended that the data and information submittals \nto lhe RWOCBs should contain the followine: \n(a, The name of the paron andlor agaruralron provldtng the ~nformatnon \n(h)Thc namc of the prnon ccntfylng thecomplelrnns and accuracy of the data \nand information provided \n(c) The penon cenifying data and information may also provide a statement as \nto what impairment they believe is accuning. \n(d) Mailing address, telephone numbers, and email address of a contact person \nfor the information provided. \n(e) Two hard copies and one electronic copy of all information provided. Data \nshould be submitted in electronic form. Data may be submitted in other formats \nneemiated with Ule ominen1 Reeion. \n(0If compula model outputs or CIS hln are inc1uJC.d in the mfomttan. \nrubrmllen phould pmvldc b~hltoppluc clwllons and specify any caltbmt~an \nand qu3111y assutancc ~nformauon svatlable for the modcl(r) used Mctadata for \nthe field data should be provided (i.e., when measlrmnents were taken, \nlccations, number of samples, detection limits, and other relevant faetm). For \nCIS files, Ihemetadata must detail all the parameters of the projection, \nincluding daNm \n(g) Bibliographic citations far all information pmvided. \n01)A description of, and refaence for, the quality assurance pmcedurcs and \nwhether data quality objectives were attained (seeSection 4.1 below) \n(i) In addition, data from citizen volunteer water quality monitoring effons RESPONSE \t REVISION \nlisting recommendations and fact sheers to the SWRCB (section 6.2). \nThe Policy provides general guidance regarding thetype of data and No \ninformation that should be solicited. Solicitation methods should be left to \neach RWOCB . lo determine. \nThe Policy has been revised to include requiremenu whether data quality Ya \nobieetives were attained as om of Ule OAPP. faification rmuirements -\nregarding data complclencsr, and accuracy. ceruficauon regarding wht \nlmpa~rmmls the data and informallon demonrmtc The Policy pmv~dcr \nguidancc for the information required for photo documentation submitfals \nB-I11 48.12 COMMENT SUMMARY OF COMMENT \nNUMBER \nshould include an indication of any uahiig in water quality assessment \ncompleted by memberr of the group. \n(j)Forphotographs, the information listed for photo dacumentation in Section \n4.1. \nThe draft tirtine Policv is oartiall\" consistent with this mommendation. The \ndran hnmg ~uicy c&&s moslof ihc compooents of reco~dauon 20. \n~UIdoes not include a requtranolt to state whether data qualnty objslaves wcn \nanained as W of Ule QAPP, nor does it include item b, c, orj. \nThe last bullet regarding citizen groups should be clarified. The cumnt \nstatemt may be interpreted as suggesting that only the mining received by \nsuch a group needs to be identified. It should be made clear that the \nrequirements, including quality asnvdnceprocedures, are also required for \ncitiren mom dam. --r --RESPONSE REVISION \nThe Policy has been revised to include language requiting citim groups data Yes \nto be subjected to data quality asswance pmcedunr. \nDraft Policy, Section 6.2.2.2: RWQCB Fact Sheet Preparation \n18.38 The don requires pnpantion of individual fan sheets. Rewording is \nsuggested to ensure Ulat theRWQCB documents the basis of each decision, but \ndoes not require repeat information that might be cornon to a number of \nncommendations. Redundancies in the type of documentation required should \nbe deleted. Tiis sectionbbeen revised to remove unclear and redundant language. Yes \n21 44 It a important that the summary of nan-numenc data and lnformatlon is not \nbased on chemcal concenttauon data, but on data that relate to rmpacts Uuough Comment acknowledged No \nproperllE or other val~d and appropnate studies \nDraft Policy, Section 6.2.3: Evaluation Guideline Selection Process \n118 Gutdance must be provlded rcgardnng lhc means lo eslabltrh Evalual~on \nGu~dehnes'appl!cab~l~ly and pmecuon of bmcficlal uses \n~ - ~ ~ \n8.12,8.5,49.4, \n64.21.67.5 Concerned about Ihe adoption of numeric guidelines by other than policy-\ndig bodies using rule-making procedures with public notice and opponunity \nto provide input. Numeric guidelines or thresholds should not beadopted \nsummarily by hard staff. \nThe draft Polin, should direct RWOCB staff to ado~t numeric obiectives when \nappropriate. conrrrlmt ulth thcCal~fom~a Water Code (ren~ons 13241 and \n13242), rather than use'numnral cvaluuon gutdellncs' to rntcrpm nmuve The Pollcy promdrs guxdanc~ on the use of evaluauon gudelmes The Policy No \nquires that the pollumt, bmeficlal wand narrauve wur qullty objecuve \nbeidentified when selecting an evaluation guideline. For some pollutants \nspecific consideration in the selection pmcss aredetailed; for otha parameters \nfunher guidance is detailed. \nAdoption of guidelines as water quality objmives is beyond thehescope of the No \nListing Policy. Evaluation guidelines use is limited to intapretation of \nnarrative water quality objectives. Quantitative guidelines are used so \nnarrative objectives interpretation can be more consistent and predictable \namong the RWQCBs. The Policy states in thehevoduetion that the guidelines \narenot to be used for any I)- other than the develwment of the section \n303tdl llst - - COMhLENT \n8.13, 14.6. 18.39. \n18 10.20 16.36 4. \n1OL.ll \n13.10 \n17.5.22.7.205.5 \n18.40 \n21.29 \n21 45 \n21.47 \n21.50, 21.49 SUMMARY OF COMMENT \nobjectives. \nNo justification is provided to ruppon the rtalmt Ulal the Policy rupcnedes \nany reg?mal watn qualtly conml plan or water quallly conlml polkcy lo the \nextent of any conflict when evaluating nanative water quality objectives. \nRWQCBr selection of sediment quality guidelines has led to problems in the \npast and will continue to cause pmblems in the future. \nRmmd Ihat only guidance approved and referenced by Basin Plan \namendments be used in makine listing decisions. Such euidance would thus be \" -\nrub)ect la the publ~c remrw and comment procar. enrunng lhat gu~dance are \napplcahlc lo our water hodla Pmmulgauon and dmmntat~on of numene \nguideline in Basin Plans ensureuansparency of the listing pmwr. \nThe omedure for selecting evaluation euidelines need to be clarified with State \ngurdeltncr preferred over federal lhs should bcdonc lo mrure conrtstrncy \nbelween Slale agcncm and hnween Rc@ons in selcn~ng appropnale guidel~nes \nThe most imp4nant parameter in evaluation of concentration data is to \ndetermine wheUm the concentration is a cause of toxicity or is a source of \nexcssive bioaccumulation. The presence of a constituent above some numeric \nguideline (e.g. section 6.2.3) is not a valid approach for listing the water body as \nimpaired. \nCauuon musl be taken in the Evalwt~on Ciudel~ne relecuon procers Thc \nRWWBr and SWRCB arena well cqutppcd lecheally and finannally to \nproperly evaluate numeric water quality objectives. \nNo provisions are necessarily included in the Evaluation Guideline for the \nProtection of consumption of fish and shellfish to protect papulations whose \nsubsistence de~ends on fish and shellfish. Theoovulation is not vmtected as . . \nlong as regulatory agencies do not include appropriate consumption rate \ninfamatian. \nScientifically-based and peer review can by highly subjective. Peerreview does RESPONSE REVISION \nIn iu listing guidance, USEPA (2W2a) pmvides guidance on therrmctunfor \ndocumenting listing and assessment meIhodolagy and pmvides information on \nthe content of these melhodoloeies. Additionaliv. iustification for the useof -.. \nevaluat~m gundel~ne mt be -led in the fact shm Thcnforz the use ul \nthe documentanon wll be sub~eclto publlc sallny dunng the Itsung pmas \n'fir rratement has been mved fmmlhc draft listing Policy. Wata quality Yes \nconuol plans must conlorm lo stare policy for wataqualityconml (CWC \nsection 13240). \nThe Policy provides specific guidance in the selection of sediment quality No \nguidelines and resuicu Ule use of sediment guidelines to thase that aremat \noredictive of toxicitv. \nThe Policy provides guidance on the identification of quantitative evaluation No \neuidelines that re~resenu standards attainment orbmeficial use orotection. -\nhml!ng use of guldellnes lo only lhosc approved and mfermced m the \nDmn Plan amendments would, m somecases, excludea way lo prcd~ctably \ninterprei narrative water quality objectives. In any case, the listing and \njustification of these guidelines in the fact sheets would provide an opponunity \nfor public satiny during the listing p-r. Incorporation of these values in \nthe Basin Plan is beyond the scope of theListing Policy. \nDistinrmishine a oriori between federal and state euidelines is imoossible. To No --. -\nprovide the nbshty for use of thc mosl appl~cable gu~dcl~nc or newly developed \nsc~mlnfie research. Ulc Palscy does not splcnfy rpec~fic documenlr or \npreferences for state over federal values. By doing so, applicable federal \nguidelines or Ule most recent research may not be useable. \nThe Evaluation Guideline Selection Raess section has bgnrevised. 'Numeric' Yes \nhas been deleted and will be rewritten to dect theappmpriate use of \n'interpretive' evaluation guidelines. \nThe purpose of lhns vcuon sto provlde pdance to make the wlectlon of No \nevalwuon guidelines mreconuslmt and msparent ihmugbul the stale \nConsumption rates protective of populations whose subsistence depends on No \nfish and shellfish are refommended by OEHHA and is oneof the listing \nomte~s included in Section 3.1.4, Health Advisories, vlease refer to this \n&on of the poCcy for ~eclarifiation.r \nThe selection of scientifically based and peer reviewed data relies on the No \n8-113 COMMENT \nNUMBER SUMMARY OF COMMENT \nnot necessarily lead to a credible or reliable discussion. \n21.51 Thestatement, identifies a range above which impacts acur and below which \nno or few impacts are predietd caneasily be an mneous appmach especially \nif it is based on sediment quality guidelines. \n44.11 Abrmt a promulgated translator. narrative criteria. wth or without numerical \ngundel~ner cannot be ued to make listtng dec~r~ons. \n67.7 Recommend Ulat the final Listing Policy require the RWQCB and SWRCB \nassess the appropiatmess of the guideline in the hydrographic unit and not only \nnlv onaidelines ~reviouslv used. \n71.18 The proposed draft policy wuld allow listing decision to be made on the basis \nof the concentrations of chemical constituents in sediment. California mntly \ndoes not have adooted sediment aualiw obiectives (SOOs) uwn which to base . .. -. \nllrung ds~smr Gu~dclrncs developed for uw elsewhere are not lcgdly \nprnmulgaled swndards wtlhln Cal~fomna. therefore this appmch 1s \ninappropriate and would not the mult in scientifically sound listing decisions. \nRequest that the SWRCB modify the draft policy so that listing decisions be \nbared upon actual masurements of sediment toxicity or upon properly adopted sm. \n109.14 There are no clean sediment guideline or mebics. Rsommend clarifying \np-ures far assessing sediment conditions. RESPONSE REVISION \nprofessional judgement of RWQCB staff. ThePolicy, however. does pmvide \nstaff guidelines on how to determine data quality and requires that \ndocumentation used to verify impairment contaii a QAPP. \nComment acknowledged. No \nA promulgated translator would he nscswy if emuenr llmits wse bung No \ndeveloped. This Policy only appl~a lo senloo 303(d) listing anddcliaing \ndecisions. \nThis section has been revised in response to this comment. However, Yes \nevaluation guideline appropriateness will primarily be a detsmination of the \nRWWBs. \nIf sediment quality objectives were available sediment chemistry data would be No \nused as a single line of evidence to support a listing decision. In theabsence of \ntheobiectives. thePolicv requires an effects measurement associated with \npotent~ally causattvc ch;rmcblr With the currenlly drafted Polcy. m no cass \nwould red~ment ckm~rzl measurcmcnts alone be alloued as the sole has~sfor \nlisting. \nThis section has been revised to allow a reference system approach. Yes \nDraft Policy, Section 6.2.4: Data Quality Assessment Process \n8.14, lL.1,40.4, We endone the inclusion of requirements for data quality and quantity Comment acknowledged \n213.2 requirements far conrirtmt and statistically valid data evaluations, and \nimplementation provisions. This would immediately improvethe scientific \nmerit of Ihe303(d) list. \n21.43 Data fmmsuch data so-such as; SWAMP, STORm, the Bay Delta Comment acknowledged. \nTributaries database. SCCWRP. SanFrancisco Estuarv RMP. and data rewned \nby local, stat^ fedd agencies (~nclud~ng rsctv~ng water monaonng dam from \ndrrchargcr mmrtonng rcporu),cluzm monrtonng groups. and scadem~c \ninstitution, and the public may not necessarily valid and must be critically \nevaluated with resp&se to their validity in properly assessing water quality. \nThe dataset should be critically evaluated with respect m its reliability and \napplicability to properly characterizing water quality, independent of who \ngenerates the data. \n8-114 -- \n- - COMMENT \nNUMBER \n21.52 \n29.11, 60.44. \n61.17.76.27 \n40.43 \n40.44 \n40.45.40.42, \n40.1 1.53.1 1.53.10 \np~ \n44.4 SUMMARY OF COMMENT \nIn regards to data quality assessment pmcess, not all of the data produced by \nagendeslentitia listed are reliable. To simply assume Ulatdata are reliable \nbeeawe they were generated by oneof these pups is technically invalid. An \naoomved OAJOC nmm bv the SWRCB and RWOCBs doern't mean that the .. . . \ndam are rel~ablc or appropriate for asrcs~ng water qualtty Subsmansal amoms \nof unnl~able dsla are generated that pass the QAJQC tatmg, whvheh an not \napplicable to an emluatian of Wmquality. \nSubsenion 6.2.4 should be revised to clarify that photogaphic dacumntation \nis used only as supportive iaforrnation since listing requires scheduling ofa \nTMDL and development of a TMDL requires data suitable for calculation in \norderto develoo load allocations and waste load allocations. \nEncourage the Smte to define the basic QAlQC components that correspond ta \nthe 'eauivalent' of a OAPP. For examole. if a monitorine emun --. war to mvide . \ndacummmt~on of study ohjsuva, rauonal for selmlon of umpl~ng slles, \nsamplnng frequency. field techn~ques. analyucal methods, and pssanncl \ntraining, then we see no legal rationale to exclude the analytical results and \nmonitorim data hmthe assessment \nThe policy lists major monitoring program in California considend to be of \nhigh quality. Recommend the State include all EPA monitoring data (not just \nEMAP) as well as o&a aeenciu that onerate hieh aualitv samline Dmeram - -. . . -. -\nte g .U S Fish and Wtldllfe Scrvlcc. US Depan-1 of Agncultum, U S \nArmy Corps of Engmccn. and Natlmal Oeeante and Atmarphcnc \nThe policy includes provisions far excluding fmm consideration dam and \ninformation that do not meet all of the State's prefared tests of data quality and \nrearesentativeness. These pmvisians an~ear to conflict with 40 CFR 130.7@), \nwhich muires the state toeather and consider all existine and readilv available \ndam and infarmatton in the Insling pmar lhir requlreml crntes a stmng \nprrrumpuon that dam and rnfomtion wll be ued in the assessment pmccsr \nunlnr 11 is complacly unrel~ablc. \nAdditional assessment categnies of infamtion should be included in the \nminimumOAlOC muimts. Sueeest revisine Ihe bullets as follows: -\n-~cth&uwd f&sample collenran and hanzllng. \n-Fald and labontary measurement and analys~r. RESPONSE REVISION \nComment acknowledged. No \nThis rmtion has been revised to clarify his issue. Yes \nThis section has been revised to apply the we rgluirenEUts for QAPPs Or any Yes \n'eauivalent'document. \nThe commentmdid not submit the named QAPPs so their quality Can not be No \nevaluated. \nThis section has been revised to mke it clear that all readily availabledata and Yes \ninformation will be considered. As outlined in the Policy, data without rigorous \nquality control (such as photographic documentation) can be used in . -\ncombhion with hi& aualitv data. Data that is not suovnred bv . a QAPP. or \n -. . . . . \nits cquiual~ml, cm not be used by lwlf to support a lirung decir~on unlar \njutificd by the riNal!on-specific weight of evidence lisung factor(sectlm \n3.1 I I or 4 1 I). The Policy pmvlsnons do not conflict wiIh40 CFR 130.7@). \nand the state will gathaand considm all existing and readily available data and \ninformation in the listing DIC-XS as muired. \nThis section has been revised for clarity Yes \n-Data magcmcnt. val~dalnon. and rsord kccptng (msludtng proper chaw \nof custody) profedures: \nQuality assurance and quality control requirwenU \n(including mUix spikes, duplicates, blanks, lab QNQC samples, lab \nB-115 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \ncertification. etc.! \nRWQCBs should be required to identify the criteria used to review, vcrify, and Theruggerted revidon has been included Yes \nValidatedata. The fifth oaram~h after the second set of bulleu be revised as: \nThe RWQCRs shall el&iyedlwte and mkea finbng in the faa sheers on the \nenLena used tomview and validate the data. the appmpnalcnns of data \ncollection and analrjis practices, and the data veiification pmess including the \nchain of custody, detection limits, holding times, statistid aearment of data, \norsirion and bias. etc. \np~\n ~ \n51.31 \t The nquiremnt shwld be removed to rralistically allow the submission of data The Policy is pamissive on theformat of data submiaals. Thepreference is for NO \ncollected from a varietv of different source. in oanicular. nonorofit all data to be submitted in a SWAMPcommtible famat, for the~urrxse of \norgaruzauonr, academc sources, and pnvate cnttzens Requlnng all data la be in data managemenL \nSWAMP format lo be conskdmd by SWRCB athc RWQCBs udd \nsubstantially limit the amount of data Ulat could be included in Ule review \npmcns because many mtitia such asnonprofit pups, academic professionals. \nand private citizens would have ro invest significant resources to submit data in \nthe SWAMP-fmL \nDraft Policy, Section 6.2.5: Data Quantity Assessment Process \n18 11.2017 \t Secllons 6 2 5 3 and 6 2 5 4 prottde drreclton on sample colleelton, whach Thwc sccuonr art needed lo assun that the asrumpuonr ofany slallsucll lest No \nrcpm msplaced m a poltcy on how loassns avarlable ~nfomllon are met RWQCBs have approached my of these lsrun ~nconrlrlcnlly m the \nA proper assessment of water quality requires Ulat samples collected should be \nreorermtative tsoatial and Iemrall of the area and conditions of the water \nbody in qualson dunng a specific ume pmod Therefore. In order for \nasresrmcnts to bc conuamt unh ReBons and Stalewde. gudrlmer need lo \nbe established. In addition to spatiat and temporal npresentation, \nenvironmental conditions need to be Iakm into constderation. Environmental \nconditions (e.g., stom, fm, land use practice, etc.) eanhave a dramtic \neffect on Ihe water body. \n40 48.4049 \tTtus sectron is ~nconr~rtml All data and lnfomuuon shall becanridered The relauonsh~ps between No u~th fedrral gudulce that uaVr qwllty modclmg \nrnulls by themselves axsufinent mwns of asrwstng wcr quallly standards exceedanccs and mmputcr model uurpuu arcdubour Modcllng \nconditions. Fedd regulations require Ihe consideration of infonqation from information is useful in combination with nmaical data. \ndilution eal~lations &predictive models in the assessment prnek (40 CFR \n130.7tbY5)tiiM.. . , . . ,. \nDraft Policy, Section 6.2.5.2: Age of Data \n29.l0,61.16 Clarify the language regarding use of data older than 10 years. Lirtingr based on it eideal to &e the mst recent data in theevaluation of water quality Yes COMMENT SUMMARY OF COMMENT \nNUMBER \nsuch data may have had inadequate wientific basis, or may not reflect anent \nconditions and may no longerbe valid. \nDraft Policy, Section 6.2.5.3: Spatial Representation \n21.53.51.32. \t Samples collected within 200 meten of each other shall be considered the same \n217.22 \t station or location is an arbitrary appmach that should not be followed. Site- \nspeeific evaluations of how replicate samples collected at one time and location \nvary should be the appmach that is used -not an arbitrary definition of distance \nas set fom in the Policy. RESPONSE \t REVISION \nassessment. The disadvantage of the requirement limiting the data age to 5-7 \nyear, for example, is thepossibility Ulat high quality data will be missed in the \nassssment. For example. previewed and repons of wnne data (eg., USOS) \ntakes many years to get Uuough lhereview process. Ifolderdata we the only \ndata available it should be used in decision &g. For this rrasoa, the Policy \nhas bem revised; the age of data used is up to theRWQCBr dimetion It is \nideal to use the mart recent data in theevaluation of water quality assessmenL \nnKdisadvantage of the requiranent limiting the data age to 5-7 year, for \nexample, is the possibility that high quality data will be missed in the \nassessment. For example, peer reviewed and repais of somedata (eg., USGS) \ntaLer many yean to get thmugh the review process. If older data am the only \ndata available it should be used in deeision making. Fa this the Policy \nhas bem revised; the age of data used is up to the RWQCBs dimetion. It is \nideal to use the mast recent data in theevaluation of water qualily assessment. \nThe disadvantage of the requirement limiting the data age to 5-7 year, for \nexample, is the possibility that high quality data will be missed in the \nassessment. For example, previewed and repom of some data (cg., USGS) \n~&es many years to get through the review proms. Uolderdata arc the only \ndata available it should be used in decision ding. For this mason, the Policy \nhas been revised, the age of data used is up to the RWQCBs disaetion. It is \nideal to use the most went data in Ule evaluation of water quality assssment. \nThe disadvantage of the requirement limiting the data age to 5-7 year, for \nexample, is the gossibility that high quality data will be missed in the \nassessment. For example, peer reviewed and repons of some data (e.g., USGS) \ntakes many years to get Uvough the review procss. Uolderdata we the only \ndata available it should be used in decision making. For this reason, the Policy \nhas been revised: the age of data used is up to the RWQCBs discretion. \nin order to provide consistency within and between Regions, guidelines should No \nbe to seIin thePolicy. The general guidance stated in the Policy f-\nqmxntation is provided to avoid biasing samples in mwly defined \nI-tians. For example, samples collected near each other, may not rdect the \ntruecondition of a large water body (if the listing is focused on the larger water \nbody). Samples should be collected in a manner that characterizes the \ncondition of the water being considered for listing. Guidance is provided to \nrequire that spatial independence of samples is maintained and, if smaller \nareas, must be characterized that this be described in fact sheets. \nA 200 meter sample site separation has bem used by several states to maintain \nspatial independace of rites. The 200 m designation is not mandatory but \nrathrr used as a uigger to demmine when additional justification is needed. \nB-I17 -- - COMMENT \nNUMBER \n29.12 \n71.30 SUMMARY OF COMMENT \nClarify the descriptions of spatial representation. The technical meaning is \nunclear. \nTo theextent passibk data should be collected at more rhan one spatially \nindependent station to better capture Ihe me condition ofthe water body. Even \nif a nelwark af stations is located in the sam water body, thesample \nmeasurement will vary amg stations and over time due to naturally mng \nfactors. \nDraft Policv. Section 6.2.5.4: TernDora1 Re~resentation \n18.42 \t Language in this section regarding how samples should be collected should be \ndeleted, since this provides monitoring guidancethat is not appmpriate for a \nListing Policy. Language rewng the use of data collected on a single day or \ndutina a sinale event should also be eliminated. since this laneuaee sueeests \nlhal i;shoul~ no1 be used as the pnmqdata to suppon Ilsong. The \njustrfication for such a rcquiml is unclear and the meaning of pri- data \nin rhc context of this sect~on is not clear \nl8.70,51.168, \t Data should be collected to capture temparal variability (e.g., by requiring data \n71.31 \t collected from at least two seasons). From a statistical perspective sampling \nshould not be ~lduned only (or even mostlv) when 'waterqualitv obiective \nexceedance would be exoected to be cleadv &nifested or durine-,iud the \ncnlical conditions for a panicuLv pollutant. The besl esltmawr of the mc \ncondition of a water body wth respect lo a given uatn quality pmer in \nsome measure of cenhal tendency, not an exfreme value. The mctbodology for \ndetermining compliance with a numeric water quality criterion is predicated on \nthefact that random samoline will omvide a reoresentative data set fmm the \nppulation (1.e.. that each indrvidual sample pmvidrs a ransom snapshot of \nwala qualay at a given moment ~ntrm). The god then ir loeslimlc the rmc \nstate of the water body, bath spatially and temprally, not the maximum state at \na single time or place. \nW 19.17 Requests that when how changes have taken place in a water body (such as \nimplementation of magement practices) only recent data be considered during \nIP re-evaluation. \n0 \nRESPONSE \t REVISION \nThe Policy hasbeen revised to clarify thedescription of spatial reprerentation. Yes \nA single station may be representative of water body conditions if Ihac are No \nmany samples in time and Ule samples wen ~eleeted to qxxr.1 the water \nbody. It is irapossible toprovide a simple rule that would be applicable to the \nwide range of water body types in California. Of me, samples should be \nrepresentative of the areabeing asserred and the representation of the samples \nshould be desuibed in fact sheell documting thelisting decision. \nThe language provided in Ihe Policy is appropriate in orderto avoid individual No \nsamples over- or under-representing conditions in the water body. Virmally \nany smistical tert requiressamples to be independent and randomand unless \nthese conditions are built into the oolicv it is . . \"en,.likelv,that inferences made \nfrom sample data could mivepraml wata body conditions. If rhe Policy dm \nnot establish there rtmple rules for random and ~ndrprndmt sqla, it is \nparriblc that data wll result ~na hngher pmbabilnly of placemen1 of waters on \nthe section 303(d) list \nJudgcmcnt should not be used in place oflhe randomiranan needed lo make \nprobabiltrtic infacntial rtatcmmts (Hahn and Meckcr. 1991). Thts problem \ncan be avoided by describing what the samples represent and making sure \nsamples are independent. \nThe goal is to determine if water quality standards are attained or not attained No \nin the water segment under consideration. Data and information should be as \nmresentative as wssible of true conditions of the water bodv but 'me' \nconditims are never achlallv known. If historical data and information shows ~~~ ~ ~~~~~~ ~ \t ~ , \nlhal water qualily runduds are cxceeded dung panicular even8 nseasons. \nlhen asrrssnrnl should be l~rmted lo that piad Olhervnw. Urre events my \nnot be detected Random samples canbe collected that represenll events. The \nsignificance of the timing of sampling must be included in the fact sheers. \nAverage cxczedance of smdards cquates lo an cxceedvlce fqumcy of \nroughly 50 pcrccnl of the data are normally dsuibuted amund the man). 'This \nexceedance frequency wauld prevent the Boards from listing many watas ht \ncan be identified with relativelv sdl s-le rim. \nThedrafI Policy has bm revised to incorporate this comment. In cader for Yes \nsfatistical analysis to be used the data must be independent The requirement \nwould help in meeting theindependenceassumptions of statistical tests. \n8-118P COMMENT SUMMARY OF COMMENT RESPONSE REVISION \n21.54 Thetemporal representation approach stated in the Policy is technically invalid. \nRunoff fmm a&ultural areasor urban areas where pesticide toxicity that \noccurs only during a -off event eanhave a si@ifieant advase effect on the \nbeneficial use of -~ta bodier. Samples collected during storm evenu (eg., during -off) my be used in the \nassessment aslmg as they have been collected overtwo or more amevenu. \nThis is to ensurethat theewgdance of water quality smW noceur over \nrevd evenu and the problemuiru. No \n29.13 Clarify the descriptions of temporal representation. The technical meaning is \nunclear The Policy has been revised to clarify the desaiptian of temporal \nrepresentation. Yes \n51.33 \t Thetemwral rensentation muirement is unclear and could be Thereason for this &on is to avoid problem related to indepcndenee of the No \nmirintaprcted 'kmparal independme rr based on sitc.specific conditrons. samples. Considadtion of temporal independence is not eaough. Forrsults to \nand p-hed guldaneeor reqummnts should be aw8dcd toensure all mild be mt useful some conml on temporal representation must be included in the \ndata is used in the listing pmcwr. The provisions of thefunent draft Policy Policy. \nshould be replaced with a requirement that data evaluations consider the \ntemporal repmentation of the sampler, particularly in light of site-specific \ncharacteristics including seasonal variability and input evmts. . ~~ \n217.16 \t Critical conditions must be samaled. and this includes a rearesentativenumber Samoles collected in storm events should be re~resentative of the entire event No . . \t . e~~~~~ \n ~ \t ~ \nof wet weather samples during varying levels of storm duration intensity. The \t in order to accurately assess thepotential problem In addition, sampler should \npolicyrelated to small sample size must be modified as well. \t be collected over two or more events to accurately raect themmce and \nextent of theproblem \nDraft Policy, Section 6.2.5.5: Minimum Number of Samples \n18.43,29.14,61.19 \t Thesection describing minimum number of samples, should be eliminated. The section has been removed fmm the Policy. The second paragraph has been Yes \nThis section refm to a PlanningLirc which is not described elsewhere. In included in the'Aggregation of Data by ReaMArea' section of fhePolicy. \naddition. the aoolicatian of the binomial method alreadv drseusses how small . . \t , ~ ~~~~~ ~ ~ \nsample slur would be handled, rothir section appean unnecessarily \nredundant. There is no need to rnlnn the number of samples far the RWQCB \nstaff Waght of Evidence method. since multiple liner of evidence wn bc used \nto surrrran a listing ordelisting decision \n111.2 \t Confused that USEPA does not support minimum sample sirer. Seems contlary Comment acknowledged \nto the 2002 CALM midance. Suom the Polids minimum samole size - .. \nrcqurcmenu Also ruppons connnmt and valtd data cvaluatrons and the \nsmng move towards marc clabomtz publtc and smkeholdn ~nvolvemnt \nDraft Policy, Section 6.2.5.6: Aggregation of Data by ReachIArea \n1.20.28.5 \t If data is to be pooled for considention, the data should be combined regardless References to pled data have been removed from the Policy. Yes \nof whether one of the meuwements is above the applicable water quality \nobiective. \n5.9.11.16. 12.9, Concerned with language contained in Section 6.2.5.6 that would allow data to References to pooled data have been removed fmm the Policy. Yes \n19.L9.19.18.. 23.9, be pooled togetha for the p-e of impairment evaluations. U appears that a \n8-119 --- - - - COMMENT ~~~~~ \nNUMBER \n25.8.29.4. 38.6, \n51.28.51.22, \n51.34.57.8.58.14. \n60.40.60.41.61.1. \n18.41 \n18.44 \n18.64 SUMMARY OF COMMENT ~~ \nreachcould be listed as impaired if only one sample horn Ulat reach met the \nlisting critaia, provided Ihalsufficient data related to the \nsam pollumt were available fmm adjacentreachs. \n~ ~~ ~ ~~-~p~-\n'Ibis section should be eliminated since Section 6.2.5.6 dircusra aggregation of \ndata by reach(e.g. spatial repnsentation). \nThe fint paragraph in thesection should be eliminated since a similar \ndescription of amgation ofdata canbe fmd in the following paragraph. \nRecommended that the mliev should addnss how waterbodies axidentified on . . \nthe LirL Tothe exlmt practicable. water body wgmnts no1 m3lng rundards \nshould be identified in a consirtent manner. The draft Listing Policy is \nconr~rt~ll Sccuon 6 2.5.6 descnha how data wlh this mommndauon \nshould be a-ated by reacNana and pnsumably how such reaches should be \ndefmed. Thm is an apparent inconsistency betwm sections 6.2.5.3 and \n6.2.5.6. Section 6.2.5.3 (Spatial Rep-tation) implies Ihat data fmm a given \nstation canonly represent 200 meten of a streamsection, whereas, section \n6.2.5.6 suggests a nwnbaof facton be ured to define stream or waterbody \nsegment. \nDraft Policy, Section 6.2.5.7: Natural Sources \nl1.17,20.21,22.4, \n40.99.40.21. \n40.101,40.98, \n41.11,51.18,58.3, \n109.8 TheState must list warn impaired by natural sources. \nSection 3.1 of thedraft Policy states that water segments for which standards \nexceedanees reflect 'natural background conditions' sMI not be placed on the \n303(d) lisL This directly contradicts the 9th Circuit's recent rejectim of the \nproposition that section M3(d) only applied with respect to waten where \neffluent limits existed fara oarticular mllutant. In doine so. the corn -\nemphized that both the lirtingobligalian mdTMDL dcvsloprnmt obl~galion \narc mggmd whm walm bodln do no1 alun walnquality standards, regardless \nof the source of pollution. It alsocontradicts the position of the NRC, which \nfound Ihat the TMDL pmgam 'should encompass all saesson . . .Ulat \ndetermine the condition of the wa-y.' \nMu= ,1gn8ficanlly. 11conlra&cts bath the CWA (whrch conutns noexernpt~on \nfor rmp~tmnts due lo nalunl sources) md thcTMDL rrgulaltons For RESPONSE REVISION \nThis section is needed to pmvide specific guidanceon how to addnss water No \nbody segmentation. \nThis section has been revised. Yes \nSection 6.2.5.3 is needed to make sureassumptions of statistical tests are met. No \n.kction 6 2.5 6 addresses a complaely dhffeint issue regard%? way; to \naggregate dam within regrmsnh RWQCBs have used dramaucally dlffml \napproaches in assipng -of impact. This secuan pmvides some modest \nguidelines to make listing decisions morepredictable. \nIf a water body does not meet water quality rmdads it should be placed on Yes \nthe seetian 303(d) list. Some Basin Plans contain language regarding the \napplicability of nanative and numac water quality objectives to \nunconmllable soma. For these regions no listing for natural sources would \noccur. For other regions warn would have tobe placed on the section 303(d) \nlist. Inthese eases, it is unlikely that a TMDL would be completed because the \nso-is uncontmllable. The Policy will not provide any guidanceconcaning.. \n#he lirtingldsl~rung of walu se5wnts due lo n3w-d sowus of pllulants \nRWQCBs wll determine hou lo proceed wlh l~slings ordelnstlng relaled to \nnatural causes COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nexample, 40 C.F.R. P 130.2(g) defines 'load allocation\" for purposer of \ndeveloping a TMDLas '[[]he portion of a receiving water's loading capacity that \nis athibuted either to. . . \"onmint sources of ooUution or to natural backmound\n-\nsowccs 'The regulauanr thus clearly conlemplale the Itrung for mtcn ~mplund \nby nalunl so-Moreover, the language of scrtton 130 2(g) m&calu that \nPmnrol'io's appmval of TMDLs for nonpoint pollution extends logically to \nnatural souma as well, as both are addressed in the definition of load \nallocation.' \n... .. \t . ... -\nDraft Policy, Section 6.2.5.8: Quantitation of Chemical Concentrations \n21.55 \t Using a valueat one-half that leads to a pan~cular mncluston on llsung is an Thtr section of the Pol~cy has becn rend and the reference lo onc-half lhc Ycs \ninapproprialeapprmch. Usually. a more appmpriatc analytical mhod can be quantilation limit has bem removed. \nused to define Ihe actual concenmtion. \n58.4 \t Standard deviation from a single sample analysis may rise as the detgtion limit Comment acknowledged. \nis approached and samples are often subject to matrix interference effects that \ninduce an additional source of em, these false positives may lead to \nunwarranted diversion of effoR \n58.6.215.1 \t Concaned about how thae new rules interact with things like CTR. when we The RWQCBs have Ihe diraetian to interpret the CTR at low hardness levels No \nhave seen oast listines based on vm. vm low and unusual hardness levels. where a~~rwriate. . . his beyond the scow of the Listing Policy to modify \nCTR Itrungs for rnctalr hat arc msrasung wlh very, vcy low hvdnesr standard; \nmeasursrrmts that are cssent~ally atypeal and mqum the CTR to be \nexmpolalcd beyond uhal srepresenled in CTR dorumnu at the level of, I~ke, \ntwo pans. per million hardness when the . CTR tables stop at 25. There are \nexceptions that pop up; its not a perfen science. We appreciate that the \nRegional Board would take tho% kinds of analytical anomalies essentially into \nconsideration. \nDraft Policy, Section 6.2.5.9: Transformation of Data consistent with expression of numeric water quality \nobjectives, water quality criteria, or evaluation guidelines \n2.4 \t Agree with the recommendation. This refleets real effeeWconditions better Ulan Comment acknowledged. No \ninstantaneous maxima (which oventate the severity of the condition) and \nstatistically arerare events. \n18 3 \t ThePolcy. aspmpord. das not reflcrl the dewlls of many spee~fic watn The Pollcy rcqulrrs all waln qual~ly nand&.. to be nntcrpreld based on ihe No \nqual~ty sundand, such as sp3ual and lmparal applrcabrhry and fqucncy and slruclurc and form of the standard as adopted kfurc any slallsllul lesls %re \nduration of allowed non-attainment. performed. Staff will compare data to Ihe applicable standard and applicable \naveraging period(s) and the result will be either'yes' the standard is exceeded \nor 'no' the standard is not exceeded. Then the series of 'yes' and 'no' answen \nwill be analyled statistically using the binomial test. \nB-IZL COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER .. \nThe form of the standard is -ed, the averaging periods areused and a \nstatistical assessment of the smgh of thedata sample is completed No \nstandard is changed in this evaluation. \n1815.43 8.60 53, Alter thestaff-recommended allemau,e 2 to requtre ranpltng greater than the The Policy does no1 wek to change the form and wprsslon of ihc waln No \n76 33 nnae sample rcqutremmt eumnlly recammnded whm RWQCB5 do not have qualnly ob,ect~vc used in 11% as~ssmnu Therefore. the Poltcy pmwdes \nenough data to match specific avenging periods. guidance to ensure that sampling data is interprwd appropiately. \nRemmmendations fora single sample to q-t the averaging period allows \nthe use of available data in a manner that is precautionary and pmvides the \nRWQCBs some flexibility touse what's available toasas compliance. \n37.3 'Ex draft Policy's direxion on uansformatian of data for use in the binomial Sampled data for virtually all water quality objectives lend thedva to No \nmodel is inappropriate for assmrment of compliance with most of the Lahontan analysis by binomial statistics. This is bsause data are easilytrsnsformed into \nRWQCB's numeric water quality objectives. 'this didon could result in nominal information: 'yes' the sample falls below the standard ar'no' the \nlistine of water bodies thal are actuallv attainine standards. standard is exceeded. \n51.30 The policy's generalized requirrmenu for data averaging and combining data Tk7day averaging paid is recommended in orderto reduce thepmsibility No \nfrom adjacent -her do not seem to be based on seientifle methods and will that the rerulu used in statistical analysis are autpeorrelated ordepeadmt. \nhave the effect of eliminating data that should be considered. For example, the Autocornlatian oflhe measurements has been observed in samedata seu from \npolicy indicates that 'If the averaging period is not stated for the standard, California waters. S~urlock et al. (2000) showed that a chlmyrifos sample . . \nobjective, criterion, or evaluation guideline, then the samples collected less than collected on a given day is influenced by conulloalionr I lo6 dayspnor lothe \n7 days apan shall be averaged' Samples collected within a 7-day time frame sampling (pm~tivcauloeomlation) If the data are positively autocorrelaled \nmay be considered temporally independent if justified. The sevenday time then 11 is probable ht thcobsrrveJ vanvlee lo be rmller than expected. This \nframe is arbimrv. No iustifieation or data are oresented that indicates that the , , \ndurauon of seven days bclum rampllng evenu a requ~red loensure tcmporal could then leads to an inflated Type I ermr. Averaging samples collected \ndunng a 7-day pcnod would reduce lhs pmblun \n~ndependmce Mom tnpartantly. lhe ume fnmc requtrfd fn temporal \nindependence is specific to each location and site-rpecific conditions that \nexisted at the time of sample such as the weather conditions. \n107.9 The draft Policy states all samples taken in one day should be avuaged and This section of Ihe Policy has been revised to recognize to use ofdissolved Yes \nreprerented as one sample. This is scientifically pmblematic for certain kinds of \noarameta. e.e.. dissolved axwen. A characteristic omblem with dissolved - ,-oxygen minima. \noxygen due to numentr is that read~ngs am laghin the dayurnand fall sharply \njust bcfore daw An average of the hngh and law values ewes results that \nwould not allow listing, yet fish will be dying at dawn for lack of oxygen and at \nnoan from super-saturation. The test requiremenu do not fit thisreal-life \nsituation. With only a few minor modifications the problem can probably be \nremedied... .... \nDraft Policy, Section 6.2.5.10: Binomial Model Statistical Evaluation \n18.46 \t The redundaa language in this section should be climinalcd and references to The rrrlton hm bm rev~scd forclanty. Although numeric sanpled Ye0 \nsampler and nwsurenwnls should he changed to data pnnu The change to the infomt~on is msformd intonomlnal (N~J infomution. it remans dm. COMMENT SUMMARY OF COMMENT \nNUMBER \nterm data points is pmpmed because once individual samples or measurements \nareaveraged M hansM thebinomial method is applied to the new data \npoint and not to lheindividual -la or masumts. \n1882.21 IS \t lhcdraft Policy focuses on developtng statistical evaluation of thedara RaUler \nthan slal~sl~cal manipulation of the dam. the focus rhould be on proleciion of \nwata quality. Mmt statistical manipulation of water quality data doer not \npmpedy reflect how chemicals impact aquatic-life related beneficial user of \nwater bodies. Toxicants do ncn imoact fish based on the mean. median. mode. \nmaximum. range. elc .but rather tomcay rr based on a mcenhauon of toxtc \nehemd for, duraoon of cxpaoun: relalnonsh~p for a pameular chcmcal and \ntype of organism. \n40.28.40.29, \tThepolicy dm not require verification that data sets are suitable for analysis \n40.52.40.51. \tthmugh the pmposed binomial statistics method. Unless evaluated data exhibit \n40.50.51.76 \t e articular characteristics (e.n. normal distribution, -1e indamdenez \nibrence of svstematic bias& it mav be invalid to drawvalid s&tistical \n~nfmnccs bawd on blnomal rursucal la& (see Lin el al ,2000) \n104.4 \t Rigomus QAQC procedures, pehapr a standard deviation method, is the pmper \nway to address sample uncertainties. The hypothesis testing pmedures \ndescribed in USEPA testing manuals andguidance documents certainly pmvide \nadequate pmlstion against indirectly concluding that warn are toxic when \nthey are not RESPONSE \t REVISION \nSamples eiIher pmvide readings above a numeric objectiveor not The Policy \nand FEDuseof sample data is appropriate, even if it IAes the f-of a '+or \n'nd. \nThe focus of the Listing Policy is to pmvidc dr~tioo on the mrktent NO \ndevelopment of Uteseclion 303(d) list Stat~rtia arc used as a ml lo de \ndecision making more uansparent and to allow policy maken toestablish the \nparameten thatshould be uwd when listing decisions are made. The \nrelationshiosbetween toxicin, and chemical conwhation is a standards issue \nthat IS beybnd the scopeof &c Linmg Policy \nThe data collected in ml, if not all, water quality sampling pmgram is Yes \napplicable to appropriate statistical evaluation. The use of the exact binomial \nrest requires that the likelihwd of 'success' and of 'failure' (i.e.. standards not \nmet and standards met) remain constant in the mulatian (i.e.. water bodv). . . \nand that samples be todependmt of one amihct and be reprnenlaovc (e g . \nrandom) The qutnmmtr mnow lncludd in the Pol~cy Howvn. hng a \nnanp~uie procedure, the exact binomial test does not require an \nassum~lion of normally dislributed data. \nComment acknowledged. \t No \nDraft Policv. Section 6.2.5.1 1:Evaluation of Bioassessment Data \n18.90 \t Recommend that the assessment process for biological standards (bianiteria) The development of biocriteria is beyond Ihe scope of the Listing Policy. No \nwhen incorporated into RWQCB's Basin Plan should be followed. At that time \nthere standards would necessarily guide listing decisions for the affected \neeoeraohic areas. RWOCBs (esoeciallv the lareer Reeions) will mbablv adoot --. \t . . \" , . \nb~omtena for one or a few m&s at a urn. nor for the whole Regton at once \nAfl* the b~rrnlma are adopld fora spmfic area, wtershcd,ecoregian or \nwaterbody type, those established bionitaia would guide listing or delisting \ndecisions far that areaonly. The remainder of the Region (for which no \nbianitaia have vet been adooted) would still follow the recommended mess. \nThednn hslmg Pohcy is putrally conrtrtent wth hr recammcndauon The \ndnfl Lsl~ng Polley &rcussesevaluauon of b~oassessmnl &la in a manner \ngenerally consistent with the recammendation in Section 6.2.5.1 1. The draf~ \nListing Policy quires that a link between speeific pollutants and degraded \nconditions must be made before a water is listed. 51.116 COMMENT \nNUMBER \nSL.115,51.114 SUMMARY OF COMMENT \nAs cumenflydrafted the drafi Policy app- to block the use of bioassessment \nstudies that arenot completed by the RWQCBs. SWRCB'r chosen alternative \nfor assessing degradation of biological populations arcomunities repeatedly \ncontains language requiring IheRWQCBr to \"dearly document how refamce \nsites areselected and used\" and \"desmibe the habitat thev aresam~lme and wh~ . -\n11was chm \"lhs language appears to ~mply that only data collccled from \nb~oassersmcnl studla conducted by the RWQCBs can be wedm the \nassessment of biological communities for the purposes of listing. In \npranieality, bioassessmt studies arecompleted by othez State and fed4 \nagencies (nrowe agencies), research wps, academia, the regulated \ncommunity, and \"an-pmfiu. \nWe therefore wee\"~SWRCB to revire the Ian-ee --in the FED that all readilv ~ ~ \n~ \navailable bioasswrmee data will be considered for Insung purposes, and aid \nIhls language lo appropriate sections of ihedraft Pollcy. In add~tion. the drat? \nPolicy should explicitly state that assessment for biologically-related impcu \noften requires Ihe use of multiple lines of evidence. in a weight of evidence \nappmach. RESPONSE \t REVISION \nThe Policy has been revised to allow bioassessment data from all SOuIceS to be Yes \nused. \nUnda the rrrovisions of the Policy, bioassessment-related impacts alwayr No \nrequlrc muitiple lina of cndcne; for lirung \nDraft Policy, Section 6.2.5.12: Evaluation of Temperature Data \n18.47 \t The language in this section that pmvides examples should be removed to This revision has been made. Yes \nemphasize the pans of the discussion that provide policy direction. \n18.87 \t Recommended that when data of sufficient auantitv and aualitv areavailable. a Comment acknowled~ed. No .. \t . . ., \nconplnson of cum1 and turtanc or natural warn temperalms can be made to \ndetmnc whether waler qual~ty objecttvcr am bctng m If thecurrent \ntemperature regime of COLD or WARM warm has been altered fmm the \nnaml or histmic temperature regime in a manner prohibited by the applicable \nobiective. then the wateroualitv abiective is not beine met and the water body\n ~ ~ . ., -\nshall be determined impaired by lenperalurr. The provisions of the SWRCB'S \nThermal Plm should also be considmd. When historic or natd Icmpcraturc \ndata arenot available, alternative approaches must be employed to ams \ntemperature impaimt. One such appraach is based on the assumption that the \nbeneficial uses associated with aouatic life aremost sensitive to mdifications \nto natural tempenlure regims. OIher knefinal usa that may also bcaffcsled \nby lemperatwc include mum and aqwrullwe; other appmches for \nassessing temperature impairment may be more appropriate for these beneficial \nuses. The draft Listing Poticy is pattially consistent with this recommendation \nThe draft Listine Policv discusses tenmature issues in a manner eenaalh -. \t -\ncons~slenl wlh hs mommd3llon in Section 6 2 5 12. but appears loapply \nIhc binormal method m Scct~on 3 1 2. which ms no1 recommended by the \n COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nDraft Policy, Section 6.3: RWQCB Approval \n8.22 \t There is no policy regarding appeal of RWQCB decisions m the SWRCB. Pmvisions requesting reevaluation of existing listing is included in lhePolicy. No \nPmvisions should be added to specifying the pmeedure forreqwsting re-\nevaluations of existing IirtingS including an appeal pmcedun. \n18.48 \t Changes should be made to the description of the RWQCB approval pmedum The RWQCBs approval pmeedum are consistent with all legal requimnts. No \nto be more consistent with legal requirements and standard pranices. \nDraft Policy, Section 6.4: SWRCB Approval \n18.49 \t References to fact shew should be changed to documentation for consistency If the requirements were changed to provide simply documentation No \nwith changes suggsted to Section 6.2.2.2. \t consistency, it is unlikely that RWQCBs would pmvide consistent, combinable \ndata and information needed to support SWRCB's adoption process. The \nspecificity of the information needed is intended rnmakethelisting pmeess \nconsistent among regions and m allow for easy combination of Uledata and \ninformation summaries. \nComment related to Policy Adoption Process \n21.20 \t SWRCB should start over with respen to drafting a 303(d) listing palicy that The Policy recommendation for listing decisions due to adverse impacts of No \nproperly incorporates protection of aquatic life hom adverse impacts of chemical constituents implements water quality standards as they exist in \nchemical constituents, which refiects how USEPA national wata quality criteria plans, policies, and regulation and is consistent with USEPA guidance and \nare to be wed to protect !he designated beneficial uses of water badies. policies. \n30.6 \t Recognize that economic concemr are not a facmr in developing the list. It Economic considerations are addresxd when TMDIs are developed. No \nshould be recognized lhat both the listing and the subsequent development of a \nTMDL and associated BMPs and Management Measures (MMs) may have \nsignificant 1-1 and regional economic impacts. The overall process dm not \naddress how mious senm of the economy will absorb thecosts. \n~~ \n40.10 \tWhen the State develops its 2W4 Section 303(d) list based on the adopted Comment acknowledged \nmliev. USEPA will carefullv scrutinize the mooosed listine decisions and 7 , . . -\nassactatcd aswrsmt nt~onales If the actual lrstrng decrrtons are conslslrnl \nwth appltahlc water quality standards and federal ltrttng requ!rcmmts. the lssl \n40.36 \t USEPA expressed these concans in comments to SWRCB staff dated June Comment acknowledged. \n2003 on the previous draft of the pmposed policy. Concerned that mast of the \ninconsistencies with federal listing requirement identified in previous comments \nremain in the December 2303 draft mlicv. COMMENT SUMMARY OF COMMENT \nNUMBER \n40.37 \t Unless the policy is modified to ad-ow remining concerns, it appears \nlikely that the State will develop section 303(d) listing decirionr that do not \ncomply with fed& listing mnts. \n602,603 \t Several of Ihcw ronm arc dated lo what appean to be a poky revmal \nfrom the July lo Ihe Dxemba drafts Lnstad of bu~ldmg oo ihc l~rlrng pracesr \nimprovements that resulted in the 2002 303(d) list, the December draft policy \nmoves back toward the policy that pmduced the inclusive but flawed 1998 \n303(d) list in which many water segments were ermnenusly listed. \n60.4 \t Concerned that the Decemberdraft Pohcy does not comply with the federal \nregulations for implementing section 303(d) of the CWA. Asnoted on page 1 \nof the Notice of Public Hearing for the January 28 and February 5 hearings on \nthe draft listing policy, ihesection 303(d) list must inelude the water quality \nlimited segmma, associated poUutanls, and a priority ranking of the waten for \npurposes of developing Total Maximum Daily Loads (TMDLs) in the next two \nyears: \n65.11.70.6.73.5 \t Encouraee the SWRCB to adoot a wlicv that will ensure scientificallv ... -\ndefensible and appropriate methods are applied consistently in evaluating all \npotential 303(d) listings. \n101.9 \t RWQCBs will provide assistance (e.g., ideas and suppon) to ensure that the \npolicy is workable, effective, and technically and legally valid. \nMiscellaneous Comment \n4.1 \t No comment at this time. \n5.4 \t Endone SWRCB's intention to evaluating the appropriateness of water quality \nstandards mior to the develo~ment of a TMDL \n5.5 Suppon the following concepts from he SWRCB' s draft listing/de-li&ng \nDOLY: \n:Ma& listines contained in Ule State's 1998 and 2032 303(d) lists were based ,~~~~ ~ ~ ~ ~~~~ , ~~~. \nupon Ihmlled &la, or have occurred despite evidence that natural sowes have \ncaused orconmbuted to the impa~mnt The basis and ntionalc far additional \nlisting decisions is unclear. \n-Suppon guidance regarding the requirements for and transparency of listing \ndecisions. \n-Encourage the SWRCB to reinstate language fmmthe July 2003 dran that \nwould provide for a re-evaluation of each water bcdy identified on the 2002 RESPONSE \t REVISION \nFederal listing requirements arecontained in CWA %tion 303(d) and 40 CFR No \n130.7. The Policy is in compliance with these requi~menrs \nWlr there ansome r~gn~fieant \t No revlrtons beween the July and Deambcr \ndrah Polrcy, a rtan&zed appmach for Ihc uxlststmt tdmuficaum of warn \nthat do not mea wataquali6kandards was retained. lhePolicy ouUines the \ndecision rules fordiffez& kinds of data; an appmach far analydng data \nstatistically; and requirerents for data quality, data quantity, wd \nadministration of the listing pmeess. \nThe Policy complies with fedd regulations far implementing section 303(d). No \nThe CWA requires stam to identify mtas that do not met applicable water \nquality standards and prioritize for thedevelopment of TMDLs. USEF'A \nguidance allows the States to develop a TMDL schedule Ulat itself can reflect \nthe priority ranking and funher believes thisisa reasonable, efficient way to \ndemonstrate priority ranking. The Policy follow this guidance. \nComment acknowledeed. \t No \nComment acknowledged. \nComt acknowledged. \t No \nComment acknowledged. \nCommnts acknowledged \t No \nB-I26 - - COMMENT \n7.1.8.1.8.3. 13.1,. \n25.1.30.1 1.56.4, \n56.2,60.1,67.1, \n70.1.83.2 \n14.1,36.1,42.2. \n53.1.53.3.66.1. \n101.2,IOl.3, \n115.2.205.1 \n15.1,25.2,31.1, \n38.1,40.39,43.2, \n48.1.56.1.56.26, \n56.28,56.27.61.3. \n61.2. G4.1.65.3, \n65.2.68.2.71.2. \n74.8,74.1,79.1, \n181.802 \n18.2,20.3,41.10, \n101.1 \n18 52. XO 8 SUMMARY OF COMMENT \n303(d) list. \nS-n the SWRCB's efforts to establishartatewide appmach toassessing \nCalifornia's Surface Waters. Applaud staffs effons in seelting bmad stakehdder \ninput into development of the current draft of the Listing Policy. Staff has gone \nto extraordinary lengths to work with all interested panies in developing, for the \nmost pan, a very objective and scientifically mund listing Policy. \nSupport the comments submitted by the TMDL Round Table, which includes \nRWQCB staff and managen who have years of experience interpreting water \nquality smdards and evaluating a vast my of envimnmental data and \ninformation. \nCommendSWRCB staff fortheir effotls to develop the propored Listing Policy. \nTheaccessib~lity and willingness to answs questions and clarify issues raised \ndurine thereview of these doc~m~lts the has been umlv hebful. Su~wn \nSW~B'S goal of establishing a standardized appmach ior &signing'&ater \nbodies to theStateSs 303(d) list. \nWe pmv~ded dclatlcd nmmnvndat~ons on a rnult~tude of tcchntcal and \nprocedural ~ssues for fonrtdcrauon m developnng the polley, but regrettably. \nmast of thcsc rrcomrrmdat~ons have becn word or overlookrd in the \npmposed Policy. \nThePolicy should becornpared to the draft PrecessGuidanceand the Draft \nhlementine Palicv and anv consistencis identified should be resolved. -. \nLncons~stcnr~es between the dacwnent wll likely lead to lnconrnstenrles \nbowem RWQCBr m how Ulry ~ntrqmand apply the polteies \nChange references of pollumtr to polluuon in ordmtoel~rn~~tc the add~llonal \nhurdrn an KWQCtls kyond Lhlt of pcrfomung the as~ssmmt of whether wata \nquality standards are being attained.~ection 303(dXlXA) of the Clean Water \n&uim the identiticarion of all watnr not attainine standards. and reauires \na pn&ty radlng bored onthe wvmty ofthe po~~utlon ' TMDLS are only \nrequired fm certain pllutsnu. Thcsc distinctions arc irnpomt rincc the Clean \nWater Act defines pollution bmadly, whm, pollutants are defined as a subset \nof pollution. IheListing Policy should require theidentification of all waters \nnot meeting standards to be consistent with federal law and use the TMDL RESPONSE REVISION \nComment acknowledged. No \nComment acknowledged. No \nComment acknowledged \nKecornrnendat~ons horn theTh4DI. Roundtable dated 18 December2002 wen No \nevaluated by staff Of the 35 rccommendauons nude as pmted by the \nRWQCB staff. SWRCB staff agreed wth 9 m thetr murely. 7 for the rnmt \npan; 2 provided a gmd staning point; and agreed Ihat 3 of the \nrecommendations should fm the basis for the listing policy. \nThePolicy has been revised to makesure that inconsistencies areminimired to Yes \nthe extent aossible. \nThefocus of the Lstlng Pollcy IS to pmndc the rqu!remenn far the No \ndcvcloprnmt of the rect~on 301d) llsL Fedcd regulauon LmtsIhesccuon \n303(d)list to those ~tnr where water quality standards arenot met, pollutant \ncantibutine to or eausine the exmedance a& identified (with limited \nexcepttons). andlMDLs are still mquied hclurlmgsll pollution on the \nscrtgon 303(d) list goes beyond the hacrc requirrnrnts and USEPA gundance. COMMENT \nNUMBER \n18 55. 301 \n18.74.20.1.51.L50 \n18.79.20.13. \n43.53, 101.10 \n20.12.27.2.53.2. \n101.6, 102.1 \n20.2 \n21.17 \nW 21.3 \nbP \nP \nP \nSUMMARY OF COMMENT \nGuidance to idmtifv the ootions for addressine diff-t wUution omblans. . . \nTrylng lo dlrtnngwrh bclwn pallulron and pollulanu may qutrc addirrmal \ncvaluauan a not pan of the waler quallly assessment poccsr \nThe Lisung Pollcy shwld include a clrar sunrel provlrron The L~rttng I'olicy is \nlargely untated and the consequences of implemaauon of hr Pol~cyare n~ \nclear. A sunset pmvision would allow the SWRCB and public to review \nwheUlcrthe POI& is effective& imlementing fed& lah and -tine the \ngoals of the POIIC; A runset dHtc if2008 aims suggerled loallo~ thc \nPol~cy10 be applied at least twcc pnor to review. \nIt appears as if the detailed recommendations pmvided by theTMDL \nRoundtable have been ignored or overlooked. There arestill significant, \ntechnical. medural. and Id mblems with the oromed Policv. -. . . \nThe Policy should be brief, \"on-\"petitive, and focused on the requiremenu \nSWRCB wishes to establish to assess the status of theState's surface watus. \nAny guidance or suggestions should be developed as separate technical modules \n(as is being done with the TMDLGuidance). \ninmany places the Policy is confusing, is redundant, or includes unnecessary \ndirection. \nSuggest that you revisit therecommendations and consider the co~nent \nsubmitted hv Ihe TMDL Round Tahle \nRather lhan trying to make it more difficult to have a water body listed on the \n303(d) list as proposed in the draft Policy, there should be a need to increase the \nnumber of water bdies that are listed as beneficial use CWA 'impaired.' \nThe proposed appmach is drastically different fmm the approach that has been \nused in the past and that should be followed to pmlect aquatic-life-related \nbeneficial uses of the Srate's waten and that is necessary to \npmperly implement lhe CWA. RESPONSE REVISION \nThe requiremu for dcvelaping the rsuon 303(d) Itst have been in place No \nsince Ur mid-1970s and it is not likely that Ur rq~uronmu will be repealed \nanytime won. Uthe Policy sunsets or was made aon4fdve at some future \ndate. SWRCB would have to do~tlheF%licv to address fumlisting \npmeerxs. Toavo~d lhir murce in~mstveerrdn, SWCB could ad&s \npmvirionr peridically, review the Policy and revise any rstion lhat a \nineffective or less effective lhanit could be. l3is pms is wnsistent with the \nreview and revision requiremenu for State palicy for wata quality control \n(CWC section 13143). \nApproximately two-thirds of IheTMDL Roundtable cornmenu wm No \nincopmated into the drafl Policy in thepreferred alternative. Most of the \nremainine comments were included in the draft FED as alternatives to be \nconsidcmd by SWRCB. Comnu focus4 on adminiruativc matters such as \nthemration of Ihe data system were no1 iwluded in thedraft ED or Policy \nbecause these issues should be addressed based on feasibleoptions given \nstaffing and convact resources and not as a matier of SWRCB policy. \nOneof the goals of lhedraft Policy is to provide consistent and transparent No \nappmaches for theidentification of water quality limited segments using a \nstandardid set of tools and orincioles to be used bv RWOCBs to evaluate \nd3ta The ~o~lcy has been daflcd lo nnclude surficlkl &I so ihe18sling \napproaches are umurtmt among Reponr and so the tmls urnandardmd U \nthe approaches and tools were voluntary guidance or suggestions then it would \nbe unlikely that SWRCB would achieve the stated goal. Thedrafl Policy is as \nbrief and focused as necessary topmvide consistent appmaches and a \nstandardid set of listing and delisting tmls. \nThe Policy has bearevised and sevd of issues have beenclarified. Yes \nEach of the recommendations have been carefully considered by SWRCB. No \nComment acknowledged. \nComment acknowledged. \nB-I28 COMMENT \nNUMBER SUMMARY OF COMMENT \n21.4 The proposed 303(d) listing approach is technically invalid and suongly \nconuary to protecting the beneficial uses of the srare of California's unten. \n21.5 The draft Policy is W on a hdammtally flawed interpretation of thefederal \nCWA'r key provisions regmding the intent and approach that is to be followed \nin protecting and, where degraded, improving the beneficial usa of the nation's \nwarn. \n21.66 TheTMDL implmtation approach should, as the fint step, verify the \nreliability of thelisting with respect to current violation of WQS. ?his \nevaluation should include determination of the need for adjusting theWQO for \nsit~pgific conditions. If the validity of the listing is confirmed through a \nspecial-purpose mdis, then it is appmpriate to peeedeto iwlmmt the \nTMDL to conuol the WQS violation. \n21.69 TIedraft FED falls far rhm of presenting a cndible discussion in support of \nthe staffs draft Policy. h contains numemus technical problems, which reflst a \nlack of understanding of haw chemical constituents potentially impact the \nbeneficial uses of water bodies and how the USEPA national water quality \ncriteria and state standards based these criteria should be used in developing the \nrWA ?O?,AI I;** \n22.8 Suongly recommends that a review of the applicability of a water quality \nstandard be made part of all TMDL development. \n22.9 loins and incorporates by reference herein comments that have been submitted \nan the hft Policy by Tri-Tac and CASA. \n23.2 NRC recommendations from its July 2001 repot7 on the TMDL program are \nimpomt and shotlld be incorpmed into the Policy. \n23.4 Perthe December 2003 SWRCB TMDLGuidance, water quality sfandanis \nshould be evaluated before a TUDL is developed. \n23.5,114.4,206.2, \n212.1 Supports transparent process. Support3 public access to the suppobng data. \n26.1,75.1, 82.1, \n217.1.222.3 Suppat andjoin in the AB 982 EnvimmIal Caucus Comments mthe State's \nvmvosed 303(d) Listing Policy and the WDL Guidance. \n33.1,34.l,35.l, \n45.1,46.1,52.1, 54.1.62.l.78.1 Suppon comments made by County of Orange Resources and Development \nDeparunent. \n36.5 All surface water bodies should be assessed, including waters that have no \nprevious monitoring data, along with the development of extensive fact sheets, RESPONSE REVISION \nComment acknowledged. No \nComment acknowledged. No \nComment acknowledged. \nComment acknowledged. \nComment acknowledged. \n. Comment acknowledged. \nComment acknowledged. \nComment acknowledged. \nComment acknowledged. No \nComment acknowledged. \nComment acknowledged. \nThedraft Policy does not mandate reviw of all surface waters, including water No \nwith no monitoring data. This issue is not within thescopeof thePolicy. \nB-I29 COMMENT \nNUMBER \n37.2 \n37.4 \n40.1 \n40.3.56.3.73.1. \n210.1 \n40.38.51.152, \n109.16 \n40.6 \n43.52 SUMMARY OF COMMENT \nis impractical given staff and budget constraints. \nSuppon the February 2004 comments of theTMDL Roundtable on the drall \npolicy, including ihe suggsted changer in policy language. \nThe draft Poley. as pmposed, wll greatly incrwscdemands an RWQCB staff \nresources for Section 303(d) arrnrmcnt. The rmpam wll be pter for regions \nwith mm surface wter biles. If addit~onal funding cannot be pmvided, fewer \nreroumes will be available foroIher important tasks, including TMDL \ndevelopment. SWRCB should consida revising the policy to minimize \nincd demands on RWOCB staff time. merevised ooliev andlor the. , \nSWRCB resolutton for adopum of the Polley should rsogntv that. xn the \nabsrnceof addtthonal resource, RWQCBr may not be ablcto performmuon \n303(d) assessments at the level of detail envisioned by thewlicy. \nUSEPA is responsible for acting upon the State's section 303(d) listing \ndecisions that will be based on the assessment methodology contained in the \nPolicy, we carefully evaluated the drall policy to determine whether it is \nconsistent with aoolieable wataaualiw standards. the CWA and associated .. . . \nfederal regulatory requinmms. USEPA doer not mke fod aellon on the \nassessment meU~odolagy isclt \nAlthough the policy needs to be revised, the dtaft policy represents a step in the \nright direction. Rso~ize that the SWRCB has devoted substantial effon in \ndeveloping the draR listing policy and understand Ulat it is difficult to define \npolicies that account for Ihe full range of water quality assessment challenges \nthat face California. \nUSEPA would be comoelled to diraoomve anv listine decision that conflicu . -\nwith these requiremen&. EPA par~Bi~y dnsapproved and added waVn and \npolluunu to theCahfomi3 Section 303(dJ lists suhmtted in 1992. 1996. 1998. \nand 2003 an outcome we want toavo~d in futurc lnsllng decirlons \nAppreciate your mff's effon to solicit input from USEPA during the initial \nphases of policy development \nThe pmeedures outlined seemrearonable and technically valid as long as the \ndata requirements are modified to reflect that listings quire pollutant \nidentification. and the pmcess for evaluating readily available data and \ninformatjon includes the pmposals for statistical evaluation based an the use of RESPONSE REVISION \nComment acknowledged. No \nThe draft Poltcy wiU place moredemds on RWQCB raourca. However. Ycs \nlhcse new demands may be offsel by bettn quality l~stings Resolnus for \nTMDLdcvelapmnt at SWRCB and RWQCBr rhould be facussed on ihe well \ncharacteked kter quality standards attainment problems. The Boards' should \nmake every effon to minimize spending TMDL rsw- on warn where \nomblemr; do not exist. -\nTo the extenl porr~blc, the Pol!cy qu~remnts have bm reduced to rmntmre \nthe drain on RWQCB rswrees. \nCamnt aclmowledged \nComment acknowledged. No \nUSEPA makes an indeoendent assessment of whether the section 303(d) list No. . \nadequaely describes thore watm thst do not meet water quality standards. \nDunngat least the Isst fow lisungcycles. USFPA has dlwgrced w~th some of \nthe Itsting dw!s#ons of SWRCB Far example, in 2002. USEPAdi-ed with \nappmximately 1 pereat of the water body listing mmmendations and 1.5 \nDement of the wata biv-oollutant combination recommendations Given the .. \nscopeof the Inst and the lypes of data and rnfarrmuan aviulable it stnevltable \nthat IlSEPA would dtragrec wth some ponlon of the pruposed l~sllngs Gtvm \nthe results of the 2002 listing cycle, there is gwd cmpondence between \nUSEPA's evaluation and SWRCB's evaluation. \nComment acknowledged. \nComment acknowledged. \n8-130 COMMENT SUMMARY OF COMMENT RESWNSE REVISION \nNUMBER \nthe binomial model. \n48.13,58.1,62.2, Appredate that the SWRCB held the addrtioaal public hearing on thispolicy in Comment aclmawledged. No \n202.1 \tTonance on February 5,2004. Holding thehearing locally in Southem \nCalifornia facilitated the panicipation of many local gomwnts and \nstakeholders. Appredate yourefforts to include all stakeholders in this \nimpartant issue. \n48.3 \t Smngly suppan the elements of the Listing Policy that will ensure that the \nlisting procar is 'mr-t.' including the requirements for fact sheets, public \nhearin@ by RWQCBs, and oppormnities to commmt anthe list prior to review \nby the SWRCB. \n51.l51 \t USEPA raised examples of its numaws significant problems with the dmR \nPolicy in oral testimony before SWRCB on January 28.2004. Unfommately, \nmany of these had been raised with staff eight months ago but remain \nunaddressed \n51.154.51.153 \t USEPA's comments areenulled la significant deference, far mre than they \nhaw rrreived lo date. See Arkansas v. Oklahoma. 503 U.S 91. 105-06 (1992) \n(USEPA is entitled to discretion to intapret its own regulations and Ulose \nregulationsareentitled to considerable deference). Coum have conrirtentlv \ngiim deference to USEPA's mnruuaton of the CWA. Lmponantly. m ag&cfs \nlong-standlng knterpretallon of law or its own power is due he~ghtencd \ndeference. SWRCB should address fully USEPA's concerns with ngard lo \nconsistency with water quality standards, data inclusion, the weight of evidence \napproach, nuisance/nunienUsedimnt guidelines, priority setting and \nscheduling, and other mncems, through madifications to the draft Policy as \ndescribed in our Mher eomts. \n51 155 \t In oral usumony before SWRCB on Janw 28.2M4 and elrewhcre. lncludtng \nmttm commentr pm)ecled lo k rubrmlud to SWRCB by February 18.2001. \ntk RWQCBs' representative listed a number of concern with the dnfl Policy, \nmany of which had been raised previously in numaous communications. These \ninclude he following foneans: \n.Rmary rcllancc on the b~nomtal method would lk3d lo a redcfinltlon of \nalmost all state and federal watm quallr) standards As cumolly dermkd. the \ndraft Policy would allow thase standards not to be attained, but would not \nrequire listing. \n-This defieiencv of the binomial method necessitates the descriation of an . ~ ~ ~~~ \neifccuve 'waght of evidence' methodology. lheem1 'Allcmative Data \nEvaluation' section does no1 pmwde m sppropnsuly robust and camprehmsivs \nalternative to thebinomial model. Along these lines, the number of ramples for \na'weight of evidence' approach should not be resnicted, as called for in the draft \n8-13] Comment acknowledged. \t No \nCnnment acknowledged. \t No \nUSEPA'S comments are bctng addressed as pan of the p-s todevelop the Ycs \nLirung Polncy. SWRCB will fully comply wnhCWA section 303(d) and the \nassociated federal regulations. USEPA has also offd sevaal guidance \ndocument to be usedbv States in develo~ine the section 305(b)-m and . - .. . \nsecl~on 303td) lin. Th&erepons often pmvide a mu of appmachcs that \nshould be canridcwd by Stales in their Itrung pmeesres. Noneof these \nguidance documents have the farce of law or rcgulalion. SWCB has \nreviewed lhese guidance documents and used the appmaches that can kt be \nimplewnted in California. Many revisions are pmpased in response to \nUSEPAs commentr. \nRWQCB's commmtr are kng addressed as pan of the process to develop the Ycs \nL~rlnng Palrcy. Many rcvnrtonsare prapmed m response to the!rmmmrnts COMMENT \nNUMBER SUMMARY OF COMMENT RESPONSE REVISION \nPolicy, since mdtipk lines of evidence can be used to support a listing or \ndelisting decision. \n-The purpase of the Poticy needsto be stated as the attainment of standards in \nsurface waters. Policy should not be limited to attainment of pollutant- \nbased standards, since section 3M(dXlXA) requires thestate to identify waten \nnot attainine anv standard and to account for the svuitv of wllution (not iust -, , . . . \n'poUurants') in priaity ranking. \n-The analyris in the FED does not provide apparmt rationale for the choice of \nalternatives, and so does nol appear to be consistent with CEQA requireme&. \nThe RWOCBs are the entities that will have to imolement this rnlicv. Simolv . . . . \nput, the concas they rase tndicate slmngly that the draft Polkey wll be \nunworkable in practice. Significant revisions must be made if the Poltcy eto \nbe credible and implementable. \n51.4 Giventhat we have found so many waters impaired with the limited information \nthat we have, n seems to follow that we could expect a numberof additional \nlistings if an ap~mpriate level of monitoring is wrformed in the state. Comment acknowledged. \n51.6 The section 303(d) pmgmms are our last line of defense in the pmtection of our \nwaterway, applied cnly aftu other CWA provisions have failed. As such, it is \nall the mare important that these program ensure that all impaired wat-yr \nare identified; the consequences of missing them include threats to human \nhealth and aquatic life, and if impaired water bodies are ignored by the 303(d) \npmmm they are ignored altogether. Cament acknowledged \n57.1 Appreciate Ulat SWRCB recognized the significant level of lwal interst in \nthese draft policy documents and chase to hold a hearing in Los Angeler \nCounty. The effon of the SWRCB to hold this hearing and then carefully \nconsider local aemcv innut is both laudable and welcomed. Comment acknowledged. \nThe current 303(d) listings geatly exceed govanmental resources and the \nemahasis should be on cost effective manaeement effons. Comment acknowledged \npp~~~ ~ ~~ \n63.1 The Policv must omvide rnllutant-soecitic. detailed midance. Comment acknowledeed. No \n68.1 Support comments made by the California Coalition for Clean Water and other \nindusuy representatives as expressed at theJanuary 28 workshop and subrrdtted \nin wiling. Comment acknowledged \n69.1 Supports comments submitted by the California Coalition far Clean Water. Commnt acknowledged. No \nW \nI& \nP \nUI 76.1 The SWRCB staff has prepared a comprehensive, well-researched document to Comment acknowledged. \nsupport theDsembu Draft Water Control Policy. However, it must be updated \nand revised to address the alternative policy recommendations made in response \nto the Board!s request for comments on the Draft Policy and the FED. \n8-132 -- \n- - COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n80.1, 110.1.11 1.1, Ca-d Uleeffort to establish consistency to the 303(d) listing process. Comment acknowledged. No \n119.1,204.1 \n102.1 I, LM.12. \t The Policy will result in mon work at the RWQCBs, more wwk at USEPA, and Thedran Pol~ds ~mplemntauon may rcqum more wali. toclearly document No \n111.3 \t ultimately more wok at Ule SWRCB, *ere staff and Board Members will have and conr~slenlly analp readrly awlable data and lnfarmatron However, llus \nto review different applications and petitions for water bodies tobe looked at additional wark will likely duce lirtinp Ulat aremore scientifically \nagain because the original policy was unclear. defensible. \n102.2 \t The policy fails on lhm grounds: science, legal Ad actual practical application, Comment acknowledged. No \nthe policy aspect of it. \n104 1 \t Development of the dmfl Pol~cy is not a iechnlcally dnvm, batomup pmcess Comments acknowledged. No \nLostead. 11 1% a top dow, pol~ueally dnvcn pmar lhal isblared in favor of no1 \nlxst~ng or dellrung wrerbodtw SWRCB rtaffrgnorcd optn~ons lhat don'l \nwnform to its preconceptions or predeteminations. \nFor examole. theDecember '02submittal bv all nine RWOCBs that aiticizes \nthe proposed b~nomal mlM for tts lack of Ilexnb~l~ry \n and la ~nconslsvncra \nullh water qual~ly ab)ecuves Also, tn June'03 IlSEPAdeta~led a rnullr~de of \nconcerns about the binomial appmach, its inwnsistency with regulatoty \nrequirements and water quality standards. Again in October of 03 the \nRWOCBr submitted a ioint recommendations wntainine a sVike-Ihroueh of \nproposed pollcy Thal submtwl ustgnared SWAMP staff has men \nexpressed senous concerns rcgudlng Ule polcy. bul nau thefvt been forbndden \nfrom wmmenting or even contacting SWRCB stzft \n106.3 \t The current (303(d)) system warked well. All the Nonh Cast riven arelisted Comment acknowledged. No \nexcept for the Smith River, and 600 water badies or mare arelisted statewide. \nThebie problem is a lack ofim~lelementation plans. \n108.1 \t Isthis policy one that you, each of you as Board Members, want to approve? Comment acknowledged. No \n108.14 \t The SWRCB's jurisdiction is protecting water. The proposed Policy is far more Comment acknowledged. No \nlikely to result in the failure of water qualily programs than in their success. \nThe draft Policy should be rethought. \n108.15 \t The SWRCB and staff should read the comments with an opm mind. The Comment aclolowledged. No \n303(d) list and TMDL p-m arevery impatant. Effon should not be put in \nsolely to reduce the list. \n108.16 TheFED paints out lhat implementation of the draft Policy will acmally reduce Comment acknowledged. \" No \nW the number of listed watm bodies. \nI4 108.19 \t SWRCB Question: In 2Mn. 200 water bodies were added to the list. There does not exist any definitive information to show whethaor not, all of No \nHopefully, the really badly polluted Wen have been identified. Now it is a the'really badly pollutes water bodies have been identified andlm havebeen P \n0 \tB-133 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nmatter of fine tuning. \nResponse: Disagree All the badly impaid men have not yet been \nidentified. SWAMP shows that Wfomia moniton only a small portion of its \nwaterbodies. Funhermore, then may be pre-to reevaluate the existing list. monitored. To be 100 percent sureme way or theother, we would need \ncomplete monitoring forthe entire State of California, which to date we do not \nhave. \n108.2 lhis policy almt always reaches a conclusion which reinforces either not \nlisting an impaired water body or provides mkind of exape, some kind of \nexit fmm Ihe TMDL appmach. Comt acknowledged. No \n108.20 SWRCB memberquation: Then is a lot of significant ma-\nramifications of a warn body being listed about Ihe The draft Policy is primarily focussed on waters that do not meet water quality \nstandards. No \nResponse: Diragne. The Policy should guidethe identification of impaired \nwaterbodies, not try to reduce thelist due to resourre limitations. Stories that \nCalifornia business is hurt by 303(d) listing are apwyphal. Recent decisions \nby the SWRCB have minimized impacts of listing. Having a water body listing \nis in the public interest, and doesnot ham business to the level claimed. \n108.4 The TMDL program is still then and should be used. Other speakers \nrecommended this, including RWWB staff. The program is being severely \nlimited. if not ovemled entirelv in manv circumstances. Comment acknowledged \n108.8 As pertaining to ASBSs, section 303(d) hsts are supposed to include both \nimmired water bodies and those that do not or mav not meet standards. The \n~oilrydoes no1 adequately addrrss llur requ~rem&l 11 should. becaure thw \nproblem an easy to mcufy raoner nthcr than later The draft policy is focussed on waten that do not meet water quality standards \nas dseribed in CWA section 303cdXI) and 40 CFR 130.7. No \nl09.12 The methods of nuisance and nuvient assessment are vague. Recommend \nclarifying pmcedures for assessing nuisance and nutrient conditions. The provisions have been clarified. Yes \n109.2 lack of clarity in the Policy makes it hard to evaluate how USEPA would read \nto a resulting lisr USEPA has provided comments to SWRCB on theirreaction to the draft \nPolicy. No \n109.4 Good aspects of the Policy: Comments acknowledged. No \n(1) Intapreting unconventional data, biological informtion, sediment tissue, et \ncetm. \n(2) Translation of nanative objectives into numerical criteria or guidehes for \nassessments. \n(3) Attemps to provide some clear assessment criteria. \nW \nlP \nP 4 110.2 Thegoal of the Policy should be to streamline assessments as well as to provide \ngreatermsistency. \nListing is expensive to public fundsand results in significant reductions in land Conmat achowledged. \nB-134 No COMMENT SUMMARY OF COMMENT \nNUMBER \nmanagement pmducuvity and land values. \n110.3 \t Compare the large aumbaof listed water bodies scheduled for actions that \nresult in an expenre and impaet on land. to budget shortages. R-\"able \ndecisions are therefore needed. The Policy should assures that no water body is \nlisted unngersarily. \nSupports a Policy that elevats listing decisions to the top levels, subject to \nscmtiny by the vow. Only water bodies with credible scientific evidence of \nhumsad impairment should be listed, and only where implemmtation of \nconml measures is feasible to achieve amal remedial results. \n111.5 \t How many existing listings are problematic? Another Commenter may be able \nto answer. \n114.1 \t Endorses comments by Craig Johns and Tess Dunham. . \n114.3 \t Need more rigor in Ule 303(d) process. Need to account for variability in water \nquality and capmre real world complexities. \n119.4 \t Offen participation suppon Conmed about casts of theprogram \n120.1 \t Suppons comments by Armand Ruby and Karen Ashby with CASQA. \nSuppons standardized approach to 303(d) listing. Suppons use of planning and \nmonitoring list. Supports re-evaluation of listed water bodies. \n206.1 \t Suppon the comments of the California Association of Sanitation Agencies. \n207.2 \t The 303(d) Listing Policy is one of the most significant policy decisions that the \nSWRCB will make this year. Impairments that alter included on the 303(d) list \nwill require TMDLs to be developed. \n207.27 \t Support comments that othm have made at the Tomce Public Hearing. \n207.4 \t SWRCB should look carefully at 40 CFR 130.7, which provides Ule regulation \nfor implementing CWA Section 303(d) asthe envimnmenral community \ncontinually refers to the general requirements of the CWA section 303(d). \n207.5 \t The 1998 list becam a general impaired water list rather Ulana 303(d) list \nconsistent with 40CFR lm 7~ \nWho makes policy: What arethe roles of Ule SWRCB and RWQCBr? RESPONSE \t REVISION \nComment acknowledged. \nThe number of listings that areproblems could be large. This has been No \nacknowledged by RWQCB staff (Commenter 53). \nComment acknowledged. \t No \nComment acknowledged. \t No \nComments acknowledged. \t No \nComments acknowledged. \t No \nComnt acknowledged. \t No \nComment acknowledged. \t No \nComnt acknowledged. \t No \nComment acknowledged. \t No \nComment acknowledged. \t No \nSWRCB is ultimately responsible for submission of the section 303(d) list to No \nUSEPA. RWQCBs provide water body specific understanding and n-sw \nlocal perspenive an listing decisions. In this sinmion, SWRCB makes Ihe \n~olicv to meet the coals stated in the introduction to the ED. COMMENT \nNUMBER SUMMARY OF COMMENT RESPONSE REVISION \n207 9,208 10 is Callformn gomg lo have a standardnzd, sc~mt~fically bed 303(d) ltstrng At present, the rmmdauon is for ihe draft Pollcy lo conmcm~stmt and \npolley or arc the RWQCBs and staffgoing lohave the sam level offlcx~b~l~ly vdnrparent apprmcher for the ndcnuficauan of warn qual~ly l~rmled xgmens \nand lack of SWRCB ovasrghl in developing 303(d) llss that they h3d pna to \ndevelopment of the 2W2 list? \"rung a standardtzd set of tools and pnncbpla la be used by RWQCBs lo \nevaluate data. No \n208.9.213.9 Suppon comments of the Wition of Practical Regulation given by Richard \nwason. Comment acknowledged \n209.1 Suppan ofcomments that havebem made so far. and hope Ulat the decisions \ntaken by theSWRCB are someUling that canhelp the cities in these difficult \ntimes sothat resources can be invested to mate solutions that would provide \nthe results that we are all looking for. Corns acknowledged No \n212.2 With this new policy, we I& fonuKd when this palicy is implemented, rhat \nwe canget the delistings that we think arejustified. Comment acknowledged. No \n213.1 Thanks the SWRCB and staff for recent meres on the State's 303 (d) List. \nTlur wxs a gncd stm at scrutcmnng the leeiilcal and xtenufic suppon used by \nthe RWQCRs and the,, staffs for Insong and dellrung Wc rmgly suppon \ncstabbsh~ng a nandd~cd appmach to Itrung Comment acknowledeed. No \n216.3 As you go Ulraugh this process of listing and delisting, thin* very, vety carefully \nand remember that you are not here just to represent the cities or the industries \nthat feel overburdened, you're here to represent people who dly don't have the \nknowled~e to s& for themselves. ~eoDle who wu'll never ue.male who -. . . .. . \nyou'll never know. BW you will know that they are there beeause they are just \nthe faceless, nameless people of California. Comment acknowledged \n217 14 Thls exact debate has mmd for the last 25 ycm on the -hole 301th) watver \n~ssuc.and llnt argument made by the d~whargcrs has Ion ltme and t8mr awn \nwhere if there is impairm~lt, then you must indeed upgrade your facilities. Camcot acknowledged \n217.2 Suppon the bulk of USEPA's comments that were given last week as well. We \nwen very happy to see that we ueeye to eye with them on most of Ule issues \nand concerns that they had on the listing and delisting pmcess as well. Comment acknowledged. No \n217.3 Our goal at Heal TheBay is to seemore cenainty in the listing and delisting \nprocess, which could be obtained thmugh a more rigomus and better document \nlisting DMess. And we believe that the SIatees effon to date is ddnitelv a start -. \nto move in that dlrect~on, but not rvmclw to ukrc we need to go to \nadeqwlely prast water qudlly in the Stale of Callfomla Comment acknowledged. No \nThe quallons tht I would ask are what Iypa afwalenvayr would ncvm have \nbeen l~rted in the fin1 phcc if thts pol~ry were to be adopled ar 11 is today?lbe \nsecond question is what types of waterways will dmp offthelist if Ulis &rent \ncriteria is applied to wat&ays that are akdy on the 303(d) list? The answer is Commns acknowledged \nB-136 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nthat the impact will be that lralwaterways thatarepart of communities that are \npan of the fabric of this state that people fish in, swimin, and reply upon to \nescape the hurtleand bustle of their daily lives will never be cleanedup \nUnrelated Comment \n10.17 Timber and agricultural ppanene implied that the ZW2 listing pms was Spgific comment on the 2002 section 303(d) listing procar is beyond the NO \nnot public. There was a public hearing pmess. Thetimber landowners were scope of the Listing Policydevelopment process. \njust not paying attention and want a second chance. A second chance is \navailable which at the TMDL development level, hplnnentation Plan \ndevelopmnt level, andlor new (credible) evidence canbe added to the file. \n10.19 Timber and agricultural pmponents feel that it is nM the listing tht is the Specific comment on the ZW2 section 303(d) listing procss is beyond the No \nproblems, it is the implementation and it diminishes land values. land values scope of the Listing Policydevelopment pms. \nare not diminished by implementation planning by any measurable amount -\nGarcia land values seem stable as evidenced by ncmt land sale prices. \n10.20 Timber and agricultural proponents feel that over fishing killed the firh: loss of Specific comment on the ZOO2 section 303(d) listing process is beyond the No \nhabitat is not mponsible for fishery loses and at the same time there are plenty scope of the Listing Policydevelopment pms. \nof fish in ow riven. \nFtrh populal~ons dogo in cycles and then hu been over fishng There has bm \na sl~ghl resurgmcr in the numbers of coho salmon rrluming la some rivers. Thc \noverall trendsare still down (to a large extent) from historic levels. There has \nalso been a precipitous decline in spawning and rearinz habit values. This has \nbeen subr&tiated by suomned sc&tific&iew and CDFGrurvew.ete.. \nhge numben of baby (i'ywr old or less) salmonnds found in a rlrarnda not \nrndtcatc tncrearcs in populsoonr \nSurvival of adult spawnen returning to the rivers is indicative of population \ntrends. \n10.21 \t Implementation Planning (Basin Plan Amendment) was argued to the SWRCB Specific comt on theZOO2 section 303(d) listing procss is beyond Ule No \nto be panof the long term solution and hasis of suppon of the NCRWQCB scope af the Listing Policydevelopment process. \nConditional Waiver of Waste Discharge (Policy) for logging operations. \nlmplementation Planning has fallen way behind schedule. It would be nice to \nseeproms. Ifthe Conditional Waiver Policy is to have mait and be supported \nby Implementation Action Plans, progress must be demonstrated by approval of \nTMDL related Implementation Plans. \n38.2 \t SWRCB should also develop statewide policy on beneficial use determination This comment is beyond the scope of the Listing Policy development process. No \nguidelines and criteria 43.3 COMMENT \nNUMBER \n104 2 \n119.2 \n119.3 \n201.3 \n208.5 SUMMARY OF COMMENT \nLmk clmely at 40 CFR 130.7, the [USEPA] regulations for implementing \nCWA rectim 303(d). The 1998 list was not consistent with the USEPA \nrepulations. \n--~~~ ~ ~ ~ ~~ ~~ \nThe Santa Clara River pmvides an example wheiein aerial dwaion and \nsewage treatment, not stormdrains, were found to be the primary $ounces of \npollutants. \nAn ~llusuauon of how pclty and paranold this pmcrrs has became is that there \n8sa Rcglonal Board Radndlahle S~IC~Y sesslon I~sllng. SWRCB staff left the \nmom and then anonymously eavesdmpped on the convenation. While not \nillegal, it is certainly unprofessional and unethical. Rather than engag$ng in a \ntransparent collaborative process to develop a workable, pmtective policy, \nSWRCB staff has asmtially '%=led the wgons' to fend off criticism of a \npolicy that war largely proposed by the regulated community. \nSpeaks highly of wter quality conditions in Nonh Coast rivers. \nListing is not a problem. Implementation plans for TMDL will be the \npmblem Loss of the fisheries is not due to pollution but to over-fishing. \nThe ponion of the SanGabriel River that flow along the eastem edge of \nBellflower is a concrete-lined channel. TheLARWQCB should review the \nbeneficial uses that it has assigned to flood contml channels such as the San \nGabriel River above the estuary. These uses were defined several y- ago, and \nsome of them may nM be applicable. \nConcerned about the listing of the Dominguez Channel for high califom count; \nit is a fld eontml am with no recreational use. RESPONSE \nComment acknowledged \nComment acltnowledged \nCommenl acknowledged \nComment acknowledged. \nComment acknowledged. \nSpecific comment on the 2002 section 303(d) listing pmas is beyond the \nscope of the Listing Policydevelopmt pmcess. \nSpecific comment on the ZWZ section 303(d) listing praters is beyond the \nscope of the ListingPolicydevelopment process. REVISION \nNo \nNo \nNo \nNo \nNo Table 3: Responses to Comments and Testimony Received Mer February 18,2004 \nCOMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nDraft FFED, Introduction \n31634 \t ThcTujunp Wash a !nu)mexly plcrund as the Lm Angcles Rxwr ~nfigure4 Tlur map rsprovldcd as a general owrvlcw of the water raourca of the Ins NO \nof the Funeuonal Fau~valent Doewnent 7heTujung3 Wash is a mbuLvy lo the Angcles Ream The laallon of Tujlmga Wash is acknowledged \nLmAngela River. The uppaponion of the Ins Angeles River is located \nsouthwest of the Tuilmea Wash and is not vicmed. . -\nDraft FFED, Issue 6:Statistical Evaluation of Numeric Water Quality Data \n307.9.307.6. ~. \tTheFED misreansmts EPA rmidanee assuomnine rhe omwred aoomach. In The FED relies on Chavter 4 of the CALM euidanee (USEPA. 2002a) for the No~~ - .. -. . . . \t -\n307 8,30725. paniculu. the FED relies heavily anexampla presmlrd in thr. C0nsolid;ncd ~nterpmatton of chronic and acule criteria. It is me the appendica arc 'draft' \n307 10.307.14. Assessment and Lirtmg Mnhodology document (USEPA. 2002a) and in as is the enure CALM gu~dancc ihc CALM documml is nonetheless widely \n307 11 pmeular. draft appendlea to lhat gutdanee, that an inapplicable in quolcd by USEPA ~nthe 2004 list~ngguidance (USEPA. 2003b). As dcscnbed \n~alifomia's situatii. EPA's guidance indicates that application of the in FED hues 4A, 6, and 6C, the Policy outlines an appmaeh that preserves the \nbinomial appmch as pmpored in thedraft Policy is clearly inconsistent with use of magnitude, frequency and duration ponions of allwarn quality \nthe applicable California water quality standards and sound statistical practice. standards applicable to California waters. \nDraft FFED, Issue 7A: Review of the Existing Section 303(d) List \n306.2 \t According to the Draft Functional Equivalent Dacument (FED) discussion of Comment acknowledged. \nthis issue(FED at p. 216-218). Sute Board recommends Alternative 3. which \nprovides 'Reevaluate existing listings on the section 303(d) list as resources \nallow with no other requirement for new data and information. (FED at p. 217, \nemhasis added.) Suowrls Alternative 3 as oresented in the FED. . . \nDraft Final Policy, Section 1:Introduction \n303.1 \t Paee A-2 of the document describes the weight-of-evidence aaamach to RWOCBs mst document all data and information used in a lirtine decision in No - - .. \t -\nwaterbody I~stmg, ~nclud~ng \t thc uaterbody fact shcct Such drmmentatton would br acccsrtble lo the Data and lnfomum kpmcaslng. Dau and \nInfomoon Praesrmg. and Data Assessment Ln the final rlep. fact sheets wll pubhc when the llrlr arc cons8dcrul fa approval Addnt~onally, the RWQCBs \nbe presented dseribing the action Wen. We recommend that the data in must submit all data and information considered when the fact rheeu are \nsuppon of the decision as well asthe fact sheets be made easily accessible to the submitted Iothe SWRCB (Section 6.3). This provides an oppomity for \npublic. additional review of the damentation used in a listing decision. \n308.2.312.5. Havine a clear definition of the term 'weieht-ofevidence.' and an emlanation of A definition for the weieht of evidence avmch is already mtained iathe No \n3119,3148. how the wclght-of-cv~dmnappmaeh is to be applml uould prowde Inuodunton uf the POI#& Any defin~uo'r'develo~ed for sAuon7 would be \n316 8.316 7.318 3 \tcons~strncy and a grcaar undenmdlngof the uoght-of-evrdmce approach and redundant of tht, language \nhaw it is to be used in the listingldelisting pmess. - - - COMMENT SUMMARY OF COMMENT \nNUMBER \nThe following definition of 'weight-of-evidence approach' should be added to \nthe Definitions section of the Policy: \nThe weight-ofsvidence approach is a p-sr by which multiple lines of \nevidence are aswmbled and evaluated fmmoneor more sets of data. 7he lines \nof evidence areevaluated based on the rmgth or persuasiveness of each \nmeasurement endpoint, and eoncumnce, or lack thereof, among various \nendpoints. Confidence in themeasurement endpoints is assessed and factored \ninto the evaluation of the available lines of evidence. tines of evidence can be \nchemical meas-, toxicity data, biological measuremen@, and eoncenuations \nof chemicals in aquatic life tissue.' (Note: this defmition was developed based \non the text contained in Issue 3 of the FED describian a weisht-of evidence \n308.4.314.12, \t Recommend that the follawinx text be added to the end of Section 1 on ~aeeA-\n316.9,318.4 \t 2 of the draft Policy tom &ly reflect the discussion in Alternative 1 ;<he \nFED (Issue 3, Weight of Evidence for Listing and Delisting): \n'In addition to other infamatian that must be pmvided in fan \nsheets in accordance with Section 6.1.2, the RWQCBs must \ndmment their application of the weight-of-evidence appmach \nwhere multiple liner of evidence are utilized in listing decisions by: \nI) Pmviding any data or information suppotting the listing: \n2) Identifying the pollutant(s) being listed; \n3) Describing how the data or information affords a substantial basis in fan \nfmm which listing can reasonably be inferred, \n4) Demonsuating bat the weight of evidence of Ule data &d information \nindicate that the water quality standard is not attained; and \n5)Demonruating that the approach used is scientifically defensible and \nmroducibk' \n320.1 \t While we share the general concern expressed by the IEA and oUlea regarding \nthe lack of soecific information rekwdine the imolementation of a weight of \nevidence apprmch m mak~ng 30% I~rUngldclrsUng declrlonsac outl~nedin the \ncurrcnr pol~cy doswncnt wr. fully suppon the ueof such an apprmch in \nprincipal. \n320.2 \t A critical component of this weight of evidence is Ule consideration of toxicity \nand other biological data, although it has been suggested by some that the state \nshould forgo consideration of toxicity data in favor of ehemisvy alone, we \nrtmndv disaeree with such a wsition. -. -RESPONSE \t REVISION \nThe addition of the sueeested text would be du~licative of reauirrmenu No \nalready in the Policy. &tion 6.2 requires the RW~S Lo submit a copy of all \ndata and information considered with submission of their section 303(d) list \nchanges. Seetion 2 requires Ulat the pollutant be listed orif the Listing is for \ntoxicity. that must be stated. The Policy also requires that the data uJed be \nsubjected to quality assurance requirements. \nComment acknowledged. \nComment acknowledged. \nDraft Final Policy, Section 2: Structure of the CWA Section 303(d) List COMMENT \nNUMBER \n310.1,312.14, \n316.32.316.33 \n318.7 \n319.28 SUMMARY OF COMMENT \nReconstroct the Enforceable Fmgm and Watch Lists. Recommend that the \nPolicy amtinue to allow the use of alfemate lists. The enforceable p m list \nresulted in a successful effm to wte and distinguish problems that could be \naddmsed rvlthout the risk of extended conmm~. Likewise the Watch list \ncould be used to gather q~ud data by any ~takeholda before it koma a \nconll~cl and each ride bsams hardcoed in th~r views. \nIt is not clear in thedrafl Policy section Water Quality Segments Being \nAddressed' segments at miour stags of theTMDLpmcess will be handled, or \nif waters Ulat have m(WQS due to aTMDL or other ~rmm. - will have to ao \nthrough the delisling promis. Water scgmnl-pollutant combinations shouldbe \nlisted in the appropnale category, regardless of ihc status of the other pollutanu \nInsled in that segmmt 7he hft Pohey should be revised toclarify how a uater \nsegmntlpollutant combination is mved once WQS areanained due to a \nTMDL. ait should be clarified that delisting canhappen from eitha category \nof the list. \nIn addition, the hafl Policy should include a methadology whereby a water \nsegment can be rmved from the 303(d) lirt during the TMDL pmess, if it is \ndemonsmted during the course of theTMDL that water quality swndards are \nbeing attained, in accordance with the delisting provisions of seetian 4 of the \nPolicy. \nThe 'Water Witv Limited Sezments Beine Addmsed Section Should Be -. --\nEhmnnated. In response lo ow prcv~ous comments. staff revtxd the Draft Polrcy \nsuch that the'Enfwccable Fmgram' llrl is now the'watcr Qualtty Lmvd \nSegments Bang Addresred' hrt Swff says that '[alll watm m the Water \nQuality Limited Segments Being Addressed section of the list areon the section \n303(d) list.' In response loour comment that the Enforceable Program lirt \nwould oermit WOLS to swcificallv avoid a TMDL. staff states that: 'ltlhis .. \nsecuon of the Itst rr not an off ramp bsaur the waters wll be addressed by the \ncenlfied program tn llru of a 7MDL and wthm an adapted urn hame ' RESPONSE \t REVISION \nBy focusing the Policy on the section 303(d) list, the list include only thre NO \nwaters that do not meet water quality standards. as is requid by law. The \ninclusion of the WgtaQuality Limited Segments Being Ad- Categay is \nan acknowledeem~nt Ihat standards areexceeded but eika 'IUDLhas been ~ ~~~~ \napproved by I?SEPAor an enforceable pmgram is io &&t that ad- tbe \nwatnqual~ty impan. The add~uon of these subcalegoria mswa Ihat these \nstandards exceedances will be addmsedasrequired unda the CWA. \nWater Quality Limited Segments can be mved from the water quality No \nlimited segment category list or the water quality limited segment being \naddressed cateeon, lirt in accordance with the rmui~ments of sedan 4 of the \nPolicy. ~el~su~ghll occw only when it is demokrraled Ihat water @ty \nstandards arebeing atwed, listing was origiaally bvcdon faulty data a \nstandards have been remred and the xgmmt in questron currently mets wata \nquality standards. \nComment acknowledeed. \t No \nDraft Final Policy, Section 2.2: Water Quality Limited Segments Being Addressed \n308.8.318.8 \t Section 2.2.2 allom a Regional Board to place a water segment in the 'Water \nQuality Limited Segments Being Addressed' category if the Regional Bavd \ncdfies that the provisions of the 'Water Quality Control Policy for Addressing \nImpaired Waten' (presumably) will address theimpairing conditions of the \nwater segment (A-3). The second condition for allowing Regional Board \ncdfication is not provided There is no language provided in Section 2.2.2 that \nspecifies what the Regional Board must certify. In addition, the language should \nbemodified to allow placement in this category if the State Board &es a Placement on the Water Quality Limited Segment Category list aecurs when Yes \nthere is a TMDLalready approved and being implemented and the pollution \ncontrol program is expected to result in full attainment of water quality \nstandards. The second circumstance refers to the RWQCB certifying that an \nalmative regulatory programalready in place will also result in full \nattainment of water quality standards as well. The reference has been removed \nfrom the Policy. \nB-141 e \"m~qo s! muvamxa awpue spquels dadPKq PSS;UPPE %!aq \nON XI!@nb=~em law IOU op IW =em mol@ ssp sa~ms am 01a~uep!nS vd'd3sn \n.lam IOU m VMIUJ \nlonnwalqoK~t~rnbi~~ern J! n>h! am I=!>J=U;YI ~uwnu i~ensu'ms~ \nolr(ressmu IOU s! II.suouelrdsl IWJ pue IJV DIEM urn13 aql jo \nON nwumimba am iaam aou PIMM aswaqlo op a~,.a~emnes! luaw~ns sn~l \nON ~pa8pa~moml~e 1-03 \npassa ass^ aq I!leql w!nba~ s! I!'alqel!eAe ae \nuoneuuqu! pue aep 11 Lallod am JO suo~s~nmd wmo lo '8ulinpoq~1 I~WI \n'smlaej Sola~lap'uolsej 8u!e!l am u! pssqpe IOU rt IIj! u?.~ saqr 13q \nON yl pazuwns aq UO!I~UUOJU! pue nep 11e IW mtnh LJLIO~ jo IUOII~S ~ql \n. .. .. . ~. . . - ~ \naun pytxds e o!mlm wms aql jo iu-!me am u! 11~1 SUO!I~D 941 OI \nynba mmsmnv~ moa ~uawutole u( ~psa 01 pawadra ax nwuamba \n~onuoa uopnllod IW sauya~ap am j! JO vd3snKq pa~oldde E~MB pue \nON padola~ap j! czuopms u! p~wd ndas S~EM nxq seq~ame aq ue~ \n. .. .. . \nIOU iren~poq wmasq IW saapalmoua~e is81 (P)EOE uonns am OIUI \nUOlolS WPV %t2a SIlWJJaaS WlNlq LlllE@ nblalGM 10uOO~OJL!~ *-. \nw!nh suogaw!! auanuja am, q~nlm mj salrppvnoq s! uwp uaaem Kjpuap! \n01alas vrra samba K~s=dxa (P)EOE wpxs Ypno!bad palo\" aneq am sv OE'61E rn \nwauurehr \nxn let~yawqjo inoqum %!~nlqoL~!lenb alem \n ~~wp!r~il~!p~od\\wo~ \nanlleueu 10 pwnu ejo mmprnxa Supnpm'muapL\\a jo ~u!lsuoKuejo \na~w~xa apvn slalem lo Su!~s!l n@ z'11E uopaseq (P)EOE iro!~~es Kxlod au \n.IS!I (P)EOE uon~es am uo ua~m pauawaq~ \nPU~P=!*! i(lpoap! wZU!IFJJO nm weaq qqnd pue ~suaruuollnua \nam azldom .GIN llaru leln eualua auamssasm mamea amru ~dom 01 alms \ns! lem Kpal smEIS![ 01 jmd JO uapmq e saqsqqasa Qgod pasodold \nam lev paura~uo~ ~oudmo sv PZ'LOE\n cxmma am 's~ummm u! map o! pass~usrp \n.s?mpa~md ~unussam pay!a?p! lo\" an lem lama am uo paseq 8ups!1 ~oj \nwalem I@ SurSSasse ~OJq~eoldde uouenwa muapua to 1@ram B 10 uollmqdde ... \n241hoicpuw aw pup Kjuel~ 01 pxua aq prnm L,!lod at^ a~uaprn~ \na41 jo muwpuodad e uo pa- uaem psualeaql pue pxwdwt 11. Ljnu'p~ \npue a~uap!naalqel~ene jo sauq 11. mp!suo~Kllnj aql pawa~uo~ \n IOU Leu ~I~IS 91'U)C \n.. . . awleql xnsw m pg am q?qm npun oueums K~uo aq nsnu ol=K= \n%UIISII lxau am 01 loud plEpuelS .41l@nb alem 241 jo luuu!ala loj ~plnold \nmmBcudSu!~s~raaql +nba e plncqs it'uo!~ pnsappy\n ~eql ,unw!up \n. .. .. . .. . .. . \npa aql'wu&d Ltelxa jo s!nq 141 uo lurudolan~p~a~ \n uolj ualm \nutsw 1dunx2 ol SUM jo pmlsq ,wlm vans JO ~peu\naq 01 sm qpue \nuo!lnllod amjo Lluanas 2111lumue alu! Zu!yel'ua~em qms a]su(yw Ktuoud \nE qs!lqmsa lleqs alms ~[II.:IW mas (P)EOE oop% 'K~~e~yrJeds .uog~e~oj \nnuarua 8uapuoud :suo!l~as e!l lo ss!l @uopppz jo uopeau aq~ \nu! papmu! \nS! IT* KI=!=~ ZU!OP 101m~q~cxu ZE'61E ESPVOJ~ uv aleM WI3 307.17 COMMENT SUMMARY OF COMMENT \nNUMBER \nby section 30l(bXIXA) and senion 30l(bXlXB) of lhir tiUe aren~ stringent \nenough to implement any water quality standard applicable to such warn.' \nThus, warn areto be listed, and TMDIs developed, whenever theeffluent \nlimia described in section 30l(bXIXA) and (B) are insufficient to anain and \nmaintain water qualily standads. \n320.4 \tY- of mearch have been devMed to the topic of using chemistry to predia \nimpacts in theenvimment and the mounding conclusion bas been that \ncherrdruv in of itself is onlv mareinallv useful asa eo-uenee of the manv .\", \nother fadm that can control bioavallahrlrty (and thmcfok the effects of lh; \nconlamnants). h addition, standard analyte llrts includeonly a lmutcd subset \nof chemicals (LC.. gendly a few &s, PAHr, and sow chlorinaled \norganics); my afthe pesticides included on standard analyte lira have not \nbgn in use for man\" veam and newlvemaeine contaminants of concw (i.e., . . . --\nPBDEr) arc generally not mncluded ConuquenUy, a mllance on chatusrry \naloneor even usmgehmstry as the pnmary mdtcauon of tmp~~munl mll \nltkely rault in missing polentially impaired wafer bodies. RESPONSE \t REVISION \nTMDL to be mved w not placed on the &on 303( lit The draff Policy \nrequires all warn not meeting standards to be placed on Ihedon 30Hd) list. \nAdequate monitaing chemistry data indicating that a spsific water quality No \nobjective or criteria arebeing exceeded ansufficient by imlf tosuppat \nolacing an imacted water body segment on the 303(d) list ThePolicy allows . -\nl~rting or deli;ting with a nngl; line of evidence and establlsha lhat &y \ncxcccdances of numeric or water qualily objecover w be used by Urmdva \nlo assess whether water qualtly standards are being attained. \nDraft Final Policy, Section 3.1: Water Quality Limited Segments Factors \n306.5.306.6. \n3M.4.308.18, \n314.19.314.18 \n308.10.314.15. \n314.16. 316.18' TheJuly Draft Listing Policy continues to allow use of guidelines instead of \nadopted WQO as a basis for listing a water segment. Such listings can fall under \nhealth advisories. biaaccumulation in aauatic life tissue. waterlsediment \ntox~c~ty. nunmrc. advme b~ological response, degradalion of biolog~cal \ncommunilia. urn& in uamqualily. and stluauon spstfie weight of evidence \nTheproblem wth this appmach is that gutdellnes are not legally adopted WQO \nand &errfore have not undergone the public review and comment and \ndetermination if thev are aoomoriate based on Water Code section 13241 and , .. . \n13242 factan which balancc the pmposed smdards wth other faclon such as \ncconomcs and the need for recycled water Lo addhuon. gu~del~nes can and have \nbeen used in lieu of legally adopted standanis. \nWe areconcerned Ihalthe draft Policy provisions meeming evaluation of \npossible clean sediment, ternpaam, toxicity and nutrient impairment rdn \ntm vague to provide meaningful guidance to staff who would canduct the \nassessmenU. -\nThe Draft Policv should be ammded to add the following statement in Sgtion \n3 I: 'If rmdards erceedances are asurtalcd with phys& alteration of lhc \nwater bdy thal cannol be controlled or by nalwal background condit~ons. the \nwater rcgmmt shall no# he placed an the section 303(d) list. Innod. he \nRegional Board shall conduct an expedited use attainability investigation, and \nmake any appropriate standards changes before the next listing cycle. If it is \ndetermined that the standards areappmpriate and the water segment is not The use of the evaluation guidelines, and the justification of use which must be No \npresented in the fact sheet, as well as thedocumentation of guidelines used \nwill all be subiect to public smtiny during the listing process. Evaluation .. \nguidelines use is lmulcd ro inlerpnution of -live wala qualnly objsliva. \nQwnl~lal~ve guidelines arc used so narrative objccliva inlaprecation can be \nmore conristenl and predictable among the RWQCBs The Policy stales in the \nhtmduetion that the guidelines are not to be used for any plupose Mher than \nthe development of the section 303(d) list. \nComment acknowledged. \nThe Policy is focused specifically on developing thesection 3W(d) list Re- No \ncmluatio\" of existing &ndar& ;r acconplihcd under CWA scdon 303(cXI) \nand implrmmung regulauon (40 CFl1 13 1.20). A use uiainabiliry analysis is \nbeyond the scopc of Uus Policy - -- COMMENT SUMMARY OF COMMENT \nNUMBER \nattaining standards according to the listing factors, then that segment shall be \nlisted as expeditiously as possible.\" \n308.1 1, 308.12, Listings should be scientifically based on objective and verifiable information. \n316.13 Because some listing factors are based on comparison with a reference \ncondition (rather than comparison to an adopted numeric standard), this infers \nthat the assessments do not have to be quantitative in nature. For adverse \nbiological response, qualitative visual assessments or other semi-qualitative \nassessments may be used as secondary lines of assessments. Degradation of \nbiological populations and communities requires at least two lines of evidence. \nTherefore, our concerns with reliance on visual and semi-qualitative \nassessments in the listing context remain. \n308.14,308.15, Prior drafts of the Policy excluded data collected during a known spill or \n308.16, 309.3, violation. The current draft now allows data collected during a known spill or \n310.2,314.17, violation of an effluent limit in a permit or WDR to be used in conjunction with \n3 16.19, 317.4, other data to demonstrate there is an exceedance of a water quality standard. \n318.10 The commenter objects to the use of data collected during a known spill or \nviolation of an effluent limit to be used in the listing process, because these \nconditions are generally anomalous, episodic events that are not representative \nof typical conditions in the water segment. The commenter strongly advocates \nthat language removed from the previous draft of the policy be re-instated, so \nthat data and information collected from a known spill is not used in the \nassessment process. \nRecommended language as follows: \n1. 'Data and information collected during a known spill or violation of an \neffluent limit in a permit or waste discharge requirement (WDR) shall not be \nused in the assessment of objectives and beneficial use attainment as required \nby this Policy.' \n2. Alternatively, 'Data and information collected during a known spill or \nviolation of an effluent limit in a permit or waste discharge requirement (WDR) \nmay be used in conjunction with other data as ancillary lines of evidence to \ndemonstrate there is an exceedance.' \n308.5, 308.13, Previous drafts of the Listing Policy have allowed listings based on visual and \n308.6, 314.13, semi-qualitative assessments. Object to the use of these types of listing factors. \n316.1 1,317.3, At minimum, visual and semi-qualitative assessments for listing factors such as \n318.6,323.2 nuisance, adverse biological response, and degradation of biological populations \nand communities should only be used as ancillary lines of evidence, consistent \nwith the general statement outlined on A-5 of the draft policy (Section 3.1 states \nthat 'Visual assessments or other semi-quantitative assessments shall also be \nconsidered as ancillary lines of evidence to support a section 303(d) listing'). (A-\n6 through A-1 1). RESPONSE REVISION \nThe Policy allows qualitative visual assessments or other semi-qualitative No \nassessments to be used in support of evidence that a water body does not meet \nwater quality standards. This is in keeping with the federal mandate to consider \nall readily available data and information when making a listing/delisting \ndecision. However, the Policy does not allow the use of visual or semi- \nqualitative assessments as the only lines of evidence to support a listing. \nData on spills, violation of permit or WDRs and visual information can be used No \nin conjunction with other data to demonstrate that there is an exceedance of \nwater quality standards in the waterbody. However, this information cannot be \nused solely for the listing. The alternate language is similar in meaning to the \nproposed language. \n-\nPolicy Section 3.1 (page A-5) is consistent with the requirements set forth in No \npolicy section 3.17 (Nuisance), 3.1.8 (Adverse Biological Response) and 3.1.9 \n(Degradation of Biological Populations and Communities) of the policy. Water \nbodies proposed for listing under these factors can only be considered for \nlisting when they are shown to be significantly different to a reference \nconditions or when nutrients, pollutant concentrations or other factors are \nshown to cause or contribute to observed effects. COMMENT SUMMARY OF COMMENT \nNUMBER \n312.1 \t Acknowledge the SWRCB and 1-1 RWQCBs fortheir effon to standardize the \ndelisting and listine amcnsbv inwmoratinz mmducible sdentific \nmthcd~lwam zr appma;h 'hiuss cxcrwi86ed bgh the useof the \nb~nomd d~stnbuuon andnull hypothms trsung Thpsccomponmts of the \n303(d) lirt pnparatim should havebgn a cornerstone of IheentiR pmgram \nhowever Ulir more accessible and rigorous policy, will increase the public \nwnfidenee in 303(d) listing and delisting p-s and thereby promote a less \ncontentious and pmdudn atamphere. \n313.2 \t The appmach to listing and delisting decisions outlined in this latest draft is \nvery sensible and statistically round. T%evinues of the 'Exact Binomial Method' \nare as I outlined in my February 18,2004 lem to you: it provides a mbust, \ndishibution-free statistical framework for ding listing decisions. That letter \nconcaned the December 2,2M)3 SCRCB drafl policy. I think the cunent draft \nis considerably better, in that it provides an 'even-handed' ueatment of the null \nand alternative hypothesa for the test. \n314.22.318.15 \t A minimum of 3 samoles erceedine WOOS are needed to list toxics and 5 \". \nsample exceeding wwsmneeded to ltrt wn\\cntional pollutants. wirh no \nrequired mnlmum sample size. For debsong. the mnrmum numkr of samples \nrequired is 2 I for convenuolwl pollutants and 26 for toxic pollulants The tssuc \nof-knimum number of sampleb becomes more acute with Apst to so-called \n~hirtarical listine.' Historical listins based on little lo no data should not be \nnqulwd to met the highcrdcl~sung qummnts (A-S to A-6. A-22 to A-23. \nA-34) Thts secoon should be rcvrsed to achowledge that revlcw of hstoncal \nlistings do not quire the number of samples --that waters should be assessed \nas if they had never been listed before to determine whether this historical \nlisting was appropriate. \n315.3.315.4 \t Federal regulations or water quality control plans may already provide specific \norovlsions on Ule a~alicatian of wateraualitv standards (e.e.. how narrative 7 . . . , . -. \nobjcc~~va wll he inurpmted). Tothe extent the Listing Policy suggests a \ndlffmnt intnprerationof Iheapplicauw of wata quality standard$ we \nunderstand that the spec~lic pmv~sions m ldml regulsuonr or water quality \ncontrol plans mke precedent. \n315.7 \t The draft Poljcy xqu~res usc ofthe null hypothes~s Ulat Haterquallty rtandardr \narestla~ned uhen evaluaung dam. Ths is wunrer inluitivc. incanrirtenr with \nother water quality pro& such as the Surface Water Ambient Monitoring \nProgram and our mtly developed TMDL Guidance, and creates a \ndisincentive to monitor. Hypothesis testing is fundamental to implementation of RESPONSE \t REVISION \nComment acknowledged. \t No \nComment acknowledged. No \nTo make sure Ulat waters are mved avvmvriatdy fmm the rstion 303(d) \nl~st. the dclisung fanors should bc used-so&ere is a reamably bgh dnry No \nthat walsqwlity standards are met. Stmply using tklisting factors as if the \nlrning had not been done bclorc tgnorer the fact Ulat the water body and \npollutant analready on the list. \nThe Policy complies with state and fed& regulations and dies on the CALM No \neuidance (USEPA 2000a). The Policy addrsres section 303(d) listing issues: it \nices nor change water q&tty smdudr; lntnpretation of standards i; not \n2ddr~~SCd~nthe Pol~cy. Slalisucal analysts is applied to the populauon of \nsamples alter the dctmrunarion has been made as lo whether the standard has \nbeen exceeded or a has not. \nThe Policv does not suezest a different internretation of water auatitv standards . . -- \nand wes as Caltfmla's mrthcdology far dcvelaprng the swum 303(d) llsl \nAs such thc Policy should be uwd for all Itstjog and dellsung dslrtons \nThe form of the null hypothair recommended in the Polley IS appropriate No \nhecaw the intent of the Policy is toeslablish the sfflion 303(d) lirt by uslng \ndata and information that shows the wata does not meet standards. Using the \n'reversed' hypothesis would establish only which water meets standards. me \ndistinction between the different null hypotheses is further reduced if statistical COMMENT SUMMARY OF COMMENT \nthe scientific method wherein a hypothesis is formulated based on considedon \nof available knowledge and information. 'Then the hypothesis is tested resulting \nin its acceotance or reidon. 'The use ofthe hwothesis that water aualitv . . \t . . \nstandards arenot attained is clearlvaoomoriate when there is information -~--- ~~~~ ~~ ~ ~~ ~,7-, \ninbcating Lhem rr or my be imp aim^ ihm the cornplec readily available \ndata set would be used lo venfy the hypothes~s. Nole that use of the hypoUlerir \nthat water quality standards arenot attained dm not mean that all waten in \nCalifornia are assumed to be impaired a priori. Use of the hypothesis is \nmuicted to situations where there is some infomation indicaIing impaimt. \n315.8 \tUseof the nullhwothesis that water aualiw standards . . are attained muires a .. \nhigh burden ofpmofand data rcqunremrnts well beyond what wll be eenerated \nby the Surface Waln Ambent Man~lming Pm- Funhemme, it mates a \ndisincentive for the regulmcd community lo monitor rince a smaller data set is \nless likely to malt in listing. On the other hand, use of the null hypothesis Ulat \nwater quality standards are nM attained createsin~tiue to monitor since there \nis less chance that a water body will be found impaired incarrectly. \n319.15 \t As we demonstrated mathematically in our February UXll comment letter, a \nsuict application ofthe 10% wle actually results in 'balanced mr nler, which \nmeans Ihat the likelihmd of mistakenly listing an impaired water body as clean \nis the same as the likelihmd of mistakenly identifying a clean water body as \nimpaired. We would ofcwrse prefer to err on Iheside of clean water. which is \nthe stated position of the Board as well; but at a minimum the error rates must \nbe the same. The current draft continues to erron the side of diny water, which \nwe maintain is not the policy that this state should adopt. \n319.19 \t The choice of statistical test (acceptance sampling by attributes) actually \ninstitutionalizs the failure to list impaired watns. Acceptance sampling by \nattributes, which is Iheproposed statistical methodology in the current Draft \nPolicy, may be a reasonable means to balance aron in eetlain statistical \ndecision-ding scenarios. However, in the context of water quality assessmenf, \nit reouires the amlieation of both a mimum acccotable excedmce nteand a 7 7 \nmtnlmum acecptable cxceedance nte (correspond~ng lo Lie 'tqectable wallty \nlevel' and the 'aeccptable qual~ty level' In mdusmsl quallly control applmuans' \nthe context in which this method is usually employed). 'Thereareobvious \nphilosophical difficulties with theimplication that any water body can have tm \nfew exceedances: the Bmd should never seek to 'balance urm' at the expense \nof clean water. \n319.20 \t Staff has atbitrarily chosen to set the parameter values for hypothetical clean \nand diny populations at 0.1 (0.05) and 0.25 (0.2) respenively. Thismeans that \nthe fmer EPA listing criterion of 10%. rather than a dmum exceedance \nfrequency, is now ihe'acceptable quality level' -Iheminimumnumber of \nexceedanees below which the Draft Policy assumes it is not cost effective to go. RESPONSE \t REVISION \nerrm arebalanced (Smith et al., ZWI). \nTheconclusion Ihat standards are not met eanonly be made if thestandard null \nhwothesir is reiected. Uoriordata and informatiin were used to olace Ihe ,. \nwater and pollutant on the lin then 11is appmpnalc lo usc the nww \nhypothesis to rwr if current rnfonnauon supports mving warn from the bst. \nThe use of either null hwoUKsis is statistically valid. Balanciw of decision No .. \nmorr mintmrcr differences bclwem thee hkthaa and thedrfferences in \nihe number of excecdvlces needed Lncenllvcs lo incease monitoring arc \nincluded in the lining and dclirUng pmccss (please refa to Issues 6Cand 6D). \nThe approach presented in the previous letter balanced errors at 50 pwrent. A No \n50 pecent error nte means Ihat the test is no better than random guessing \nSWRCB has yet to establish the Policy on listing or delisting watm \nComment acknowledged. \t No \nThe justification for the mommended exceedance frequencies is wntained in No \nthe FED,Issue6C. COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nThere is absolutely no biological or rtatirtical justification for this propasition, \nwhich shifts the thxshold excedanee frequency far upward of the uaditional \n10%. \n319.21 \t The requirement far a minimum of Ulree exceedances to list for low sample The rationale for extending the number of exceedma is prsented in the FED, No \nsirs bas no scientific basis and is inconsistent with Mherliting criteria Issue 6E. ' \nStaff has proposed a uniform, nonscientific, and arbitmy rule far low sample \nsirs: the 'Rule of W. In ather wards, three exceedances are required to list \nanv water bod\" for which the total number of sanmles is 20 or fewer. reeardless -\nof uhat underlying wccedanee fnqucncy is impbed. Thns porilion is \ninconsislent wth staffr 'kienu6c ngn' argument for ustng slalirucal \ntechniques in the first place, and creates a trrmendous disincentive for \nmonitoring. \n319.22 \t The policy should instead require listing for any water body with a 10% Thepohcy have been revired to create an incurrive to monitor for toxicants by Yes \nexceedance fnquency, including water bodies for which the total sample siz is requiring at least 28 samples to delist. \nless Ulan21. TXir would create an imdiate incentive to gather additional \nsam~les fmm waters that either the Board or Ule reeulated fomnitv believes -\nto be aclually clan Cmfrary lo staffs assenlons ('[tlhe lnpact of lhsung a \nwata body that actually mats water quahty swdardr isthat the costs of \ndcvelopnng a TMDL wll be expended unneeessmly' ), wch ltsung'even if \nermn&u?would not trigger immediate TMDL development with;ancomitant \ncosts to the aeencv and Ihereeulated communitv. Common sense and\n -. -\nrxpenence tell us that confirmlory rnonllonng would corn fin! Funhermorc. \nthe SWRCB's own Draft lmpured Wntm Gutdance exphcltly pmvrdcr for \nmonitoring as an initial step in TMDL development to confirm impairment \n322.5 \t We concur with the regulated community that the use of the binomial approach Comment acknowledged. \nand other minimum data requirements is natan illegal revision of water quality \nstandards. Arima. Florida. Nebraska and Texas have all incamorated this \napproach in Uldr listing guidelines and policies, and it was also an accepted \napproach in the National Academy of Sciences Repon (Assessing the TMDL \nApproach to Water Quality Management). \nDraft Final Policy, Section 3.1.1: Numeric Water Quality Objectives and Criteria for Toxicants in Water \n307.13 \tThemanner in which the dran Policy fra- the binomial statistical tests for The approach being proposed is different fmmthe approaches used in Florida No \nlisting and delisting waters is inconsistent with Uleapproaches discussed in and Arizona but the approach is proposed in the CALM guidance (USEPA, \nEPA midance and aDD1i.d bv other states (ex.. Florida and Arizona) that use 2OOZa). The error balancing muvisions areadvocated in the 2004 listing - .. . . -\nthis appmach. \t guidance (USEPA, 2003b) id scientific litmove (Smith et al., UW)I).-\n307.7.319.16. \t Aoolicable water aualitv standa& far mast toxic oollutants in California are The CTR exeeedance huencv .for toxic wllutants in California arenot to be Yes\n~ .~ . . . . \t . \n319 18,31917 \t bmd on lh assumplion thal they wll nor be vlolsted more lhvl oncr.evq 3 exceeded more than once every 3 years oo the svcragc. If il is as& that two \nyran on avmge (re California Toxics Kule 1C1R)at 40 CFK I31 38 samples am available for a three ycar pied on theavengeand thc samples are - - COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n(cX2Xiii)). This correspands to an allowable enceedance kquency of roughly repre~~tative of the period, then if two hits were observed in the two samples, \n0.1% of lhe time, in conuast to Ule5% assumed in the draft Policy. We it would be sufticient data to suppon a listing. \ninterpret theCTR to mean that a wm must be listed if then are2 or more \nindependent excursions of acute or bnic water quality standards within any 3 The Policy has been revised to include this approach \nconsecutive year time frame during the asrersmmt paid, or 2 or more \nindependent excursions on average ova the mtire assessment period (e.g., four \nexcursions in 6 years). \n308.17,309.1, \t Supports the binomial dishibution using the null hypmhesis approach We Comment aclrnowledged. No \n3 14.7.316.2 believe this smistical approach is lhe bet available dad of providing much- \n317.5.318.1, neededobjectivity to the listing(and delisting) pmers. Urges the StateBoard \n318.11 \t to adapt the proposed statistical approach as amUy included in the July 2004 \nDraft Policy. \n308.3,314.11, \t The Policy needs to be clear that the presumption of Ihe null hypothesis is that 'me null hypathesis and alt-te hypotheir areprsented in Tables 3.1 and No \n318.5 \t the watubcdv meets waleramliw standards. 3.2 For listing and Tables 4.1 and 4.2 for delistinp. \n319.1 \t Delece and replace the following language in quotes to section 3.1.1: ThePolicy has been modified to require a 3 percent ex~xdance frequency Yes \nNumeric water aualiw obiectiva for toxic wllutane. ineludine maximum (DIUS 15 ~ereent effect size) to be used for listine decisions reeardine \nconlamnant levilr wL-app~lcab~c. or~airfomtwNatlonal ~cxlcr Rule water tbxtcanls At low sample rrza two of mom exeZcdanea will result ~n \nqwllty cntm3 arc exceeded 'I\" two or more sampler whn a th-year pend ' placement ola watcr body and pollutant on the rccuon 303(d) lls~ \n'Using the binomial distribution, waters shall be placed on the section 303(d) \nlist if the number of measured eiceedances suppons rejection of the null \nhwothesis as orerented in Table 3.1. ' \n ,. \n-For rample populations less lhvl 2 1. uhm 3 or more samples exceed \nstandards. the regmnt shall be lrsted ' \nDraft Final Policy, Section 3.1.2: Numeric Water Quality Objectives for Conventional or Other Pollutants \nin Water \n308 20.312.7. IheDraft Policy idmtifiw W,pH and tcmpcntun as the conwnlional Pollutants idenufied under secuon 303(d). whether ronvmuonal or toxicants. No \n314.10,316.14, pollutanu All aha pollutantr are rrmlially treated as taxier in the Draft arc show to inpan the warm quality of spdfic w-ts rcgudless oforigin \n318 14 Policy Thecumnt propowl for toxic and convenrional pollutants isnot of the pallutanl. Fcdenl regulauon. 40 CFR 123.45 applies spmfically lo \nconsistent with pmpms, definitions or uses of standard tams used in the Code repati& pmedum for p&t effluent discharges thatare inviolatimof \nof Federal Regulations (CER) and the Water Code. 40 CFR $ 123.45 identifies established permit requirements. These violations arelepmted depending upon \nGrou~ 1 and &can 2 wllutants. The list of conventional wllutanu should be the magnitude andlor frequency of the violation evaluated on a parameter-by- . . \nrcnsed Thc l~st of convent~onal polluunu should be based on EPA's category parameter and outfall-by-oudall basis. Violations reported on this regulation \nof Group 1 palluunts and toxle polluunts be based on Group 2 pollutants. as specifically pertain to NPDES permit point some violations for which specific \n~dcnttfied in 40 CFR 123 45 Appmdtx A Othn pollutants that do not fall nnto permit holders are liable. IheGroup Iand U list of pollutants simply dsnibes \nthese two categories (e.g., uash)should be dealt kth explicitly. (A-5 Ihmugh A- two different levels of violations for two groups of pollutants. \n11 and A- 39 to A-40). \nIt is inappropriate to use federal regulations intended for enforcement purpases COMMENT SUMMARY OF COMMENT \nNUMBER \n313.3 \t In Table 3.2 concaning conventional pollutants, the hypothesis that theactual \nexceedance proportion is less than 10% and the competing hypohis that it is \ngreater than 25% are mated snnmelricallv in Ulesense that the vmbabilities of -\nerror in not choming theearnet hypoheris areequal. or at 1-1 as ndy equal \nas pors~blc.'T3isavoids intenminable argumenls about which hypothats should \nbe accorded the slaw of'null hypothesis' and puts ihccrrphaus onthe \n'operating characteristic curve', which is more huitful. In teachinz hypothesis... \nt&ting t~scientiru and engineen over the last forry years, I have vigmusly \nencowaged ihe same kind of 'even-handed' specifications as a means of \nchmrine tests. \n313.5 \t I independently verified that the numbers in Table 3.2 are eorreet, given the \ncriterion of minimizing the absolute nlue of the difference between the two \nermrpmbabilities. RESPONSE \t REVISION \nin the context of placing wales on or removing watas horn the senion 303(d) \nlia. Since thesection 303(d) list is used as part of the State's pmcw for \ncompliance with section 305(b), we have opted to use USWA's senion 305(b) \nguidance (USWA, 1997b) to eategori2e pollomts. \nComment acknowledged \nComment acknowledged \nDraft Final Policy, Section 3.1.3: Numerical Water Quality Objectives or Standards for Bacteria Where \nRecreational Uses \n3193 \t Add and replace ihc followng Ianguagc m quotes to reelton 3 1 3 \nFor baclensl mcaruremmts horn coastal bwchn. ~f waterqual~ty rnonllonng \nwas conducted April 1 through October31 only, a four percent exceedance \npercentage shall be used 'only if a reference water segment or beach cannot be \nidentified.' If fhe exceedance is due to a beach closure related to a sewage spill, \nthe water seement shall not be olaced on Ule seetion 303(dl list. 'though -\nreeumng beach closures due lorewage sprlls shall be conrldmd for Itsung ' \nBeach postlngs !hat are not backed by waterquahly data shall not br used lo \nsuppon placement of a water segmt on the senion 303(d) list. 'Rain \nad$sori& shall be considered when evaluating beach waters for listing where \nmutine wet weather mitoting is not conducted.' \n319.35 \t The Draft Policy's A~vroach To Bexh Water OualiN Is Deficient. In our . .. \t . . \nFeb- 18.2001 cornmenu. we ~vummcnded the use of 3reference spcm \napproach to cvaluale rccrrauonal user As cumntly drafted. the Draft Polley \ndoer not suangly rammend using a reference system appmeh. Additionally, \nwhen the reference system approach is used, the site-specific exceadance \nfrequmcv daived from Wrefeference svstem is w~lied in eoniunction with the .. \nbinbmiairnodel' an approach Ulatremits in overcompensati& for potential mr \nand an unreasonably high bar for listing. In its response ta comments, staff Thesc camnls have been prevrously conr~dcred and arc not consrstent wth \nthe nvo-ndauons ofthe Bwch Wata Qudnty Workgroup Thc refcrmce \nbeach approach can only be used if it is consistent with water quality smdards No \nThe Policv calls for the use of the reference beach amroach if it is consistent .. \nwth standards me rnformatron needed to suhstanuatc a rcfncofc approach is \nnot wvldely avalahle No 319.36 COMMENT SUMMARY OF COMMENT \nNUMBER \nindicated that the EPA remmmends using 10%. ref-cine a 1997 document ~ ~ ~~ ~~~ ~ ~~ -. - -\nI\\s we pointed oul in our February cammcnts. this rmmmendatim was made \nwith lo the wldated EPA standard for fa1 cohfmThe m ment \nimplemtation guidance document for the EPA entemcofeus criteria does not \nre~mrnend 10%. \nStaff apparently believes that thebinomial model should be used with thesite-\nswdfic freauencv bemuse there is much uneertaintv associated with bacteria . . \nmeasurements Howeva. thlr par8l~on falls to acknowledge lhal ermr \nassoemled wth labralory measmmrnl of baclcnn can alro result in \nunderestimating bacteria densities. Importantly, it seems that staff failed to \nconsider that the bacteria standards are based mepidemiological results that \nwere develo~ed eivine consideration to this same labomtarv m. \nConsequenlly, lheippl~caoon of a stat~st~eal approach in thus conlexl wll result \n~novercampenral~on for potrnual error and a hgh nsk of erronmusly fatling la \nlist impaired warn. \n319 37 \t Run advlrona should be conssdaad m the emluauan pmws for beaches m \nwhlch mullne mon~lonng is suswnded dunng ~et Ar cumlly w-arhcr \ndrafted, the Policy nuards local agencies that use rain advisories in lieu of \nmonitoring becausc this informatiin need not be the basis of 303(d) listing. If \nrain advisories and wet weather water quality monitoring were equivalent for \nthe plupores of 303(d) listing, the incentive to not monitor would be removed. \n325 1 \tIhcA841 1 4% bactena excecdanse frsquency for coastal beach wlcn should \nbe appllcd lo freshwater bearha ar well RESPONSE \t REVISION \nComment acknowledged. \t No \nTlur comnmt confl~cls wth Ule recommndauon of the BWQW. If mn No \nadnsones an: backed by data Ihc data musl be used in IksUng dsnshons If data \ndo notback a rainadvisoty it is uncertain if warn quality slandards are \nactually not met \nThr Pollcy has br~n rcvlsed lo requrn a 4% wceedance value U,be used for Yw \nfecal bactcnal mearunments for frwhuatcr as uxll as coastal waun Allhough \nthere is no study that could be used to develop an exceedance frequency for \nfreshwates, this change war. made because application of the 4% exceedance \nfrequency to freshwater bodies would be protective. Application of the 4 \npercent value should be limited to bacterial measurements that areindicative of \nhuman fed matter and to locations with substantial human contact \nDraft Final Policv. Section 3.1.5: Bioaccumulation of Pollutants in Aauatic Life Tissue \n303.2,306.1 \t Section 3.1.5 of the dacument, Bioaccumvlation of Pollutants in Aquatic Life \nTissue, addrwes the listing of a water segment for exceeding a pollutant- \nspecific guideline using Ihe binomial distribution. his unclear whether the Sm \nintends to delist seemens that did not have adeauate data for the orieinal -\nlnstnng For ~nstance. Tox~r Substances Monttmng Program data may have low \nsets of snalym that caused !he lhrllng of a scgmnl The segment would not he \nlisted under Ulis section of the Policy, nor could it be delisted under the Policy \ndue to theneed for a much larger data set. We shongly recommend a review of \nthe existing 303(d) list using the guidelines of thePolicy. Many of the water \nbodies remain incmeetly listed when evaluated using the Policy. Far waten to be removed from the section 303(d) list an adequate number of No \nsamples as desaibed in the delisting facton must be available. Waters will not \nbe removed from the list unless thedata availableshows with the specified \ncertainty that standards are met. \nB-150 COMMENT SUMMARY OF COMMENT \nNUMBER \n308.22.314.23. The relationshio between fish tissue levels and links to water or sediment \n3 16 10.318.16 eoncmuauons of pollulants is oftm unclear wth aquauc llfe tissue ramplcs, \nbecause of faam such uihc mbtltty of kh. b~wmlab~l~ly. pamt~on~ng. \nspeciesspecific fanom, etc. Listings based on aquatic life tissue should require \nan established relationship between time levels and water calm \nmncenuations in the wate seemeot. and should be based on multiole lines of \" . \nevidence, as is required fn theevaluuian of advcne biological response. \ndepdauon of blolo@c31 populauons and comlmtua, and health advirones. \nRecommend that Ihir listing factor be modified to require application of a \nweixht-of-evidence av~roach. \n310.3 The last sentence of Section 3.1.5 should be clarified. The term'uansplanted' \nanimals should be limited to species native to and cumntly inhabiting the water \nbody. Currently, the termmuld be interpreted to mean that bioaccumulation \ncould be evaluated from \"on-native or nonacwring species transplanted to the \nwater body. \n319.4 Delete the following language in quota in section 3.1.5: \nA water segment shall be plad on Ihe section 303(d) list if the tissue pollutant \nlevels in organisms exceed a pollutant-specific evaluation guideline (satisfying \nthe requirements of section 6.1.3) 'using Ule binomial distribution' as described \ninseetion 3.1.1. \nAcceptable tissue concentrations may be 'based on composite samples' \nmeasured either as muscle tissue or whole body residues. Residues in liver \ntissue alon.? annot considered a suitable measure. Samples can be collected \neither from Vansplanted animals or horn resident populations. RESPONSE REVISION \nA direct conelation doernM alw exist be-coneentrationsof toxic No \nrubrtanca in Ihe wala column or sedtmnl Concenuauons In Mter bodres \nare enther too low or uans~tory to be daeual The Polscy rsmmmds \ncomposite fish samples to increase accuracy and ddmce. me \nrecammended screening values, developed by OEHHA and NAS anwell \naccented and mmt coaeentrations in water that are omIesfiveof hum \nhcalth and aquatlc llfc The Pollcy rccognt,rs that some lines of evidence arc \nsufficient by thonsclva to dcrmnsuatc standard analamt. Evalualaon hom a \nsingle lie of evidence, i.e., tissue data based on dng values from \nUSEPA, OEHHA, or NAS aresufkicient to demanrme standard attainment \nAs written the section allow uansplanted organism to be used in rhe listing No \nassesrmnts. lkis appropriate because oansplanted species, such asmussels, \ncan be used to assess if pollutants anpresent at levels that affect beneficial \nuses. \nThe Policy has been modified to require a 3 percent exceedance fqvency No \n(plus I5 percent effect sire)to be used for listing decisions regarding \ntoximts. At low sample sires two of mm excgdances will result in \nplacement of a water body and pollutant on the section 303(d) list. \nComposite samples area useful way to reduce some of the variation in tissue \nsampling and to get a broaderrepresentation of mncenuations of pollutants in \ntissue. \nDraft Final Policy, Section 3.1.6: WaterISediment Toxicity \n301.1 . . Fmm a oractical standmint. it dm wt seem feasible to allocate load limits to a \nwaln body based on loucjty. Such a listmg would sull require the identification \nof whichcanrtirumWcontaminants wmcausing toxicity, using =TIEtype \napproach. with thc ltmits then set based on those results. Thts would cjrclc you \nback to remlatinp so-invuts for those constimentslcontaminants that \nconuibutetoxici~. Therefo& there does not seem to be any logic in toxicity- \nbased load limits Ihat cannot be direcUy applied. \nWhile attempting to use a meuic, such as toxicity, may seem to pmvide a single \nanswer for regulation, the applicability of Ihis shoncut lacks validity when faced \nwith real world complexities of the studies and data thatareneeded to \naccurately set limits. In summary, we feel Ulat there is no shortcut for good \nscience. It is difficult to allocate waste load and load allocations for toxiciw but it is No \npoas~ble. me Pollcy acknowledges this difficulty but also acknowledges Ihat \noncethe pollutants causing or mnvlbuting to the lox~c~ly that the are ~denlnhed \npollutants be added lo the lirL To give the full range of options lothe \nRW~CBS for listing andTMDL develovment. it i;neces& to allow TMDb \nto bedeveloped forioxieity. The definition of a TMDL (40 &R 130.2(i)) \nallow for TMDkto expressed in terms of either mas per time, toxicity w \notherappropriatemeasure.' , ~ ~ ~ \n- - COMMENT \nNUMBER \n308.19.312.4, \n314.20.314.21. \n318 13.3205 SUMMARY OF COMMENT \nThe hfi Policy allows waters to be placed on the seetion 303(d) list for \ntoxicitv alone. even if thewllutant &usin% or eonuibutine to the toxiciw is not \nidenuied. Srudles idmtif>ng the pollu&arwvialed wilh the lox~c effkl are \n00 longer required prior lo dcvrlapmmt of aTMDI- (A-7) \nDraft Final Policy, Section 3.1.7: Nuisance \n308.24.308.23. \n314.26.314.24. \n314.25.316.17, \n317 6.31817 \n319 5 The Draft Policy pmvides no guidance reganling the methodology Ulat should \nbe employed to determine appropriate reference ~0\"diti~s for a particular water \nsegment. Thedelistine criteria for nuisance rauira that The water seement no \nlongusatirfies thccond~uons for a nuisance listing (kction 4.7). however smee \nnulrancc Instings can be highly subjsuve. dellrung bared on there conditions \nwll be problemric. How rimlar lo a reference condnlron doer the water \nsegment need to be in order for it to be no longer considered inmaired? \n~&mmendationr: Due to the highly subjectGe manner in whiih these types of \nlistings areto be made under theJuly ZW Draft of the Policy, the Regulated \nCaucus recommends that the SWRCB remove this listing factor fmm the Policy. \nAs mentioned eadier, as the Policy is currently written, it is not clear whether \nwata segments evaluated by this factor would then be listed for the factor itself \n(i.e.. thewater segment would be listed for 'huisance\"), which would be \nconsidered 'pollution\" and not a 'pollutant\", or whether the waEr segment \ncould only be listed for the nutrient or other pollutant causing thenuisance. \nDclclc and nplaee wth the followiog language in quotes to section 3.1.7. A \nwalu xgmnt shall be placed on the smloa 303(dj list if qualitative \nassessments of the wata segment for nuisance water ador, taste, excessive algae \npwih, foam, turbidity, oil, trash and color, ParticuMy but not neewarily \nwhere\"are' associated with ndcal water quality data, 'Ulat' meets any one of \nthe following. RESPONSE \t REVISION \nWith the exce~tion of toxicitv. the drift Policv muires the identification of . . \t No \n~ollutants in herto dace awatebodv seement on the~303(dI list. Althowh -~~ ~ ~ \nioxicrty is no1 a pollukt it is a m~fetauon of thehcffslsuused by polluml \nconcmuaoons and yields a dlrecl measuremen1 of tkblth of a specific waler \nbody segment. Federal regulation does allow TMDLs to be developed baxd on \nload allocarions and also based on toxicity, or other appropriate masurs (40 \nCFR 130.2(i)). However, raulting TMDLs based on toxicity must be based m \ntoxicological dam, such as toxicity test me- and statistically valid \nassessment of endpoints as compared against ambient water or sediment \nrefaence conditions. ~ ~~~ \t ~~~ ~~~~ ,~~-~~ ~~ \nNuisance conditions are address& in most of the RWQCBs Basin Hans; No \ntherefoq it is legitimate far the Policy to pmvide guidance far stion 3M(d) \nlirtiner. The Policv recommends the use of aualitalive assessments of nuisance -\t . ~ ~ ~ ~ \ncondntionr m askation with numerical uater quality data and acceptable \nnummt-mlaled emluauon gwddtnes; qual~tauve asresrmcnts alone wuld not \nma the cntena for lnsllnga water body ihe Policy alsoallows the RWQCBr \nto conmare lhe affected witer segmentto a refetenie condition. if one exists. \n~uidadce lo delemination of appropriate reference conditions .are pmvided in \nthe FED (pg. 145-146). However, in recognition of the site-specifcity involved \nin determining an appropriate reference site. the Policy is worded to provide \nthe RWQCBs needed flexibility in making their detemdnations. Hen% the \ndegree of simil~ty to a refereice site to either list or de-list a water body is a \ndetermination best left to the RWQCBg. \nAcceptable evaluation guidelines are \"ceded to assess nuisance eonduions No \nhecause wlhoul themrmpaa to beneficial uses cannot be quantified \nDraft Final Policy, Section 3.1.8: Adverse Biological Response \n308.25 \t All listings in Section 3.1.8 should be evaluated using the excgdance threshold \nusing the binomial approach, notwiUlnanding the comment that, as with \nNuisance and Degradation of Biological Populations and Gmmunities listings, \nit is not clear what degree of differ& fmmreference conditions is requiredi \nplace a water segment on Ule 303(d) list Section 3.1.8 stat es... 'and there impacts areassociated with wata orsediment No \nconcenvations of pollutants as described in section 3.1.6.' Pollutants as \ndescribed unda &tion 3.1.6 are evaluated using the exceedance Ulnrhald \nfrom the binomial appmach. Endpoints for adverse biological response (i.e., \nreduction in gmwth, reduction in reproductive capacity, etc.) do not lend , ~ COMMENT \nNUMBER SUMMARY OF COMMENT \nRecommendations: This section of the Draft Policy shauld be revised so Ihalit \nis dear that all listings of this type will beevaluated using the binomial \ndismbution. \n310.7 Tkfollowing comment was not addressed in Appmdix B:W~thii rectioa 3.1.8, \nAdvase Biological Response, the proposed metria to mess biological \ndegradation should be conducted overa number of ym (2-3) to aecmtely \nassess the impairment of the comity. Using shan term measurements may \nnot be indicative of the long Ism effects of the community. RESPONSE \t REVISION \nthemselves to analysis using the binomial appmach bgause kse endpoints \nare in rpspnre to a toxic condition. \nDueto Uletomplexity of intapreling m€asmts of adverse biologid No \nrespnse in an organism the Policy pmvides the RWQCBs significant \nflexibility in interpreting the data and infodon used to reconnmd a \nlisting. Therefore, the timeline in which Ulse type of assessmeolr will be \nmade is a RWQCB decision. \nDraft Final Policy, Section 3.1.9: Degradation of Biological Populations and Communities \n308.26.314.27. \t It is unclear fmm the language contained in Section 3.1.9 regarding \n314.28.316.20. \t bioassessmt would allow multiple segments, or an entire water body, to be \n318.18 listed based on measurements taken fmm a sin& saam reach. This omvision \nin Section 3.19 should be clarified. ~eas&ts fmm one sectiw of stream ~ ~ ~ ~ ~ ~ ~ ~ ~~~~ ~ ~ ~~~~~~~~~~~ \nshould not be used to list anenure water segment, rtnce the reach in quesuon \nmay not be reprewntativc of wnditionr present along the entire length of the \nsegment. A single reach may spatially repwent a very small water segment, \nhowever most segments will pmbably contain same variation in physical habitat \nwhich could account for difference in the biological community. \n3ll.l.320.3 \t 11 is our understandine that lhe 303(d> listin* ameess is lo identifv wata bodies --. \nthat are ~mpatred for a drrtgnated kneficral use Many of ihceumnt \nderrgnated bmcficlal user relate to he nbiltty of a watm body to suppn hral~hy \naquatic comities. Whether or not a panicular wntaminant or pollutant can \nbe measured in a water body is not in of itself an indication of impaimnt. \n314 29 \t It should be rpecrficd m hr sectton that obsaved diffmncn from rrfcrrnec \ncondltlcns whech arc detmoed to beduc to physical habltat or otha hcton \nthaf mot be controlled, should not be used as a basis for listing. \nBioassessment data should be reauired to be collected overa mini-3-vear \npenod. I\" order to d~sungulsh st&tficant dcgradatton' fmmnatunl vmadrltty \n~nthe b!olo~cal comtty wrhn a sue In addttton. Ihe DDft I-#sung Pol~ey \nshould specify that measurements horn one section of sfream should not be used \nto list an entire water segment, since the reach in question may not be \nre~resentative of conditions rrrpsent along the entire lenah of the segment. A \nsingle reaeh may spatially <present a very small water &ment, however most \nsegments will probably conrain some variation in physical habitat thlt could A water body segment would only be placed on the section 303(d) list due to No \nbiaassessment data when thedata used for listing fin1 complies with the \nreauirements in section 6.1.5.8 and the documented bioassessmt inmacts are \n&oeiated with mUulant(s> as dscribed in section 3.1.9 of the hlicv: ~ection ~~~ . . \n31.9 rtater.'A her segment shall be placed on thesection 303(d) lkt if the \nuatn rcgmcnras compared to reference rites.' Staff believesUur adequately \nreflects the conditions that may wanant a listing or delisting are to reflect the \nsegment fmm which the samples were obtained. Additionally, inteqmtations \nof repnrentativeners of measurements is best lef~ to theRWQCBs wixn faced \nwith data and information for speeific water bodies. \nCWA section 303(d> nauirer the identification of water bcdv seemem within . No \nthe state that do not meet or are nor expeeled to meu appl~cable water quality \nstandvds rflrr appllcauan of cmn technology-basedsontrols Water quahty \nimpacts can only demonstrated when water quality objectives, criteria, \napplicable water quality guidelines or ather scientifically valid measurement \nindicate that the designated beneficial uses are not being ma Thmc waters \nexceeding water quality objectives or criteria arewired to be placed on the \nsection 303(d) list far TMDL development \nThe Policy pmvnder gutdance m Srctron 6.1 5 8 on theevaluauon of No \nbroassessmcnl data In the fan checn, the RWQCBr should document the \nindex period that sampling will acw, comparison of reference sites include \nresults fmm similar index Daiods. Additionallv. because of the site-soecificitv \nmhmenl in boassessrnenl data. the Pol~cy pmhdcs the RWQCBs the'flerxblliy \nto remew the data on a case.bysasc bass -1to COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \naccount for observed differences in the biolozical community. \n319.6 \t Delete the following language hm last paragraph in section 3.1.9. Linkage to section 6.1.5.8 is necessary. Senion 6.1.5.8 provides guidance to No \nBi-wment data used far listing decisions shall be consistent with section theRWQCBs on Ihe evaluation of bioasseument data WlIhout this guidance, \n6.1.5.8. For bi-essmt, measuremenu at one stRam reach may be sufficient consistent interpretation of bioassessment data would be last \nlisting Provided that the impairment is associated with a pollurant(s) \nas described in this smion.' \nDraft Final Policy, Section 3.1.10: Trends in Water Quality \n307.18 \t We appredate the inclusion of provisions authorizing the inclusion of The Policy is in compliance wiIh federal listing requiremu contained in No \nthreatened waters on the Section 3M(d) list (Smion 3.1.10). However, the CWA section 303(d) and 40 CFR 130.7. Section 3.1.10 of the Policy alw, \nprovision requiring the dmmnstntion of current adme effecu to beneficial complies with 40 CFR 131.12. 'Ihis provision requires that uata quality must \nuses as a condition for projecting that a water is expected to violate standards in be maintained at levels that d t in no mMality or significant gmwih or \nthe future appean inconsistent with fedepdl listing requirrments. We thus reproductive irnpact of resident species (Attwater, 1987). \nrecommend this provision be deleted. \n308 27.314 30. \t %s secuon mmalns ambiguous and rub)ccttvc 'lkReganal Bauds arcnow The fanors hsted should not be dfied becaus* step 6 is slmply pan of ihe NO \n318 19 \t dlncted to assess whether the decl~ne isupected to mult in not meeung WQS asserrmcnt Watur should be plad on the muon 303(d) hst rf Urfin1 Eve \nbefore the nat listing cycle, however, this step is not included in the decision steps are satisfied without regard to step 6. It does not make me Iolist only \nfacton in Section 3.1.10. Recommendations: ?he last sentence in Sectian 3.1.10 if short-term exceedances are projected. If the exceedance is projected to be \non Paee A-LO should be amended to state: Watns shall be alad on the section laneer bevond the next lirtine cvcle. the beneficial use is imoacted and the -\t -, -. \n303(d) Ila II thcdsltnlng umd in ualer quslnly is subswnualrd (sleps I poll~tant trend is decl~n~ng The rnfarmalron m step 6 is needed to help \nthrough 4 ahove). and the impacu .ve observed (acp 5). and the md is dcrcmunc uhen the cxcmlance should kdddressed \nexpected not to meet water quality standards by the next listing cycle (step 6).\" \nThe sentence in Section 4.10 on Daze A-19 should be similarly edited. \n313.6 \t It is quite reasonable to include the 'exception pmfess' to address multiple lines Comment acknowledged. \nof evidence, to be analyzd separately and then synthesized. It is alsn a good \nidea, I think, to be careful about dng listing decisions based on negative \ntrends in water quality, with safeguards of the sort listed in section 3.1.10. \n317.8 \t We disaaee that 'ends in water aualim' should be used as a criterion to list 40 CFX 130.2 (i) defmes wateraualitv limited seement. as anv seemeat where No ~ ~ \" ~. , \t -. . , . \nwater segmenu that would not athenvise met the conditions in ihc Orah iris known that water quality daes not mcrt applicable uaterquality standards. \nLisung Pol~cy. Th~s rnleion allous tnclusion of water scgmmu on the 303ld) andlor is no1 expected to mut applicable mter qual~ty standards, even after the \nlist in absence of information that wata quality standards are exceeded or that application of the technology-baxd effluent limitations required by ON \nbeneficial uses are impaired. That is not the purpose of the 303(d) list, which is 301(b) and 306 of the Act The Policy should be co~istmt with this definition \nto sel forth thme waters that do not meet water quality standards and for which and requires that the assessment include a description of whekthe decliing \nTMDh areto be completed. Irend in water quality is expected to not meet water quality standards by the \nnext listing cycle. Numeric, pollutant-specific water quality objectives do not \nneed to be exceeded to list under Ihis listing factor. However, tkpolicy \nLd \trequires a ~ubstantiation of a decline in water quality plus Wer \nlb \tdocumentation that water quality impacts are observed COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nDraft Final Policy, Section 3.1.1 1: Situation-Specific Weight of Evidence Listing Factor \n306.3.308.29, \t Sstion 3.1.1 1 should be revised to include funher description of the weight of The Policy pmvides guidance an the weight of evidence approach in section 1 No \n314.31,316.12, 1- evidence appmach, and should include careful definition of used in the (Inuodudon). 'Ibis &on is cawistent with weight of evidence appmzches \n318.20 \t section, such as 'substantial basis in fact' and 'nasonably infd to provide used or suggested for &on 30Xd) purposes. The lema 'reasmably infd \nmore -nfy to thir factor. OIbeMise, thissection of the ha* Policy will and 'subsmial basis in fact' quires the RWQCBs, when using thislisting \nbsame a loophole for listins (or&listings), when more objective criteria may factor, to describe in the fact she& the factual basin for Ule data and bow this \nindicate that water quality standards are attained or not attained. Without relates to the decision at hand 'Ibis evidence must be dwunmited in the fact ~ ~ ~ ~ ~ ~~~ \nfunhcr devclopment~, thi;smion should be rrmoved entirely hm the Policy rs shees which areanilable for public rcmtiny dwing the public comment \n11undemina the scienl~fic nga the Polrcy otha-wise achieves. 1- Defining these period. in advance may limit the applicability to some \ndata w. \n307.15 \t The draft Policy includes some provisions authorizing the inclusion of warn The provisions provide significant discretion in placing or removing warn No \nand pollutants on the Section 303(d) list based on a weight of evidence from the section 303(d) list. With thisdisaetion Ule Bds arc required to \nappmach (Sections 3.1.1 1 and 4.1 I). These pmvisions appear vague and their explain the rationale for Ule decisions made under these pmvisions of the \napplication diseretionq on the pan of the State and Regional Boards. We refer Policy. \nto ourprior comments on this issue, which have not been addressed in the draR \nfinal Policv. \n314.33 \t Section 3.1.1 1 should be removed entirely from the Policy as it undermines the The Policy states in Section 3.1.1 1, 'When all otha Listing Factors do not No \nscientific rigor the Policy othekse achieves. Recommend that thir section be result in the listing of a water segment..'This pmvides ample direction to the \ndeleted, and be replaced with Ule Alternative Data Evaluation pmvision €mm RWQCBs to only apply thir section to those listing decisions where the weight \n~ ... \nthe December 2003 draft of the Policy. If, however, the current Kction 3.1.1 1 is of evidenee demonstrates that a water aualitv standard is not attained but a - . . \nto be rerained. the Policy should ma& clear that a Regional Board my not use listing decision cannol be made usmg all aha Listing Factors. In these \nthis factor in the fint instance: rather. the Reeional board must fmt evaluate the circumstances. RWQCBs must)ustify their decision in the water body fan ~ ~ ~ ~~ ~~~~ ~~ ~ \nwaer body segment using the aher lirung faclors This is critical to ensure thal sheet. providedata and information thal suppon the latlng, and demonstrate \nthe exccplim pmvlded by this Insung factor dm not become the rule. To that the appmach is scientifically defensible and qmducible. The stamrent at \naccomplish hts. the following bullct should be added to he required theend of the comment is assumed if the WOE is used. \njustification that must be pmvided to suppnt listing based on &is factor \n'Demonstrating that the Regional Board has considered the oUler listing facton \nand determined that they have not been satisfied.' \n315 2 The rile-specific Mat of evidenceapproach should allow the Region Boards In those SIIIL~U~~S, NO whae the Listing Facton do not result m the Lsting ofa \nto dca masoned argument for l~stingor delisting, even if the binomial water body but infmt!on ~ndicater \"on-arwinmcnt of standards. tk Poky \nmethod would lead to conuary conclusion. The b~nomialhod does not dce allow plmt on the section 303(dj 11s~f thc weibl of evidenee \neffectively address aitical water quality considerations such as mamitude of demonst&es non-attainment. The Policv ~mvides somesnirmidance bv which \ncxceedance: timing arreasonal~lyofeiceedanew; land use orohaactivitia in the RWWBr my jusufy lhclrmmm&datian. For rniy of the tacton listed \nthe watershed that ~nfluence pollution paum; walerqwlity trends: mon~lming in the commenL ihe Pol~cy provides guidance (such as mds, emporal and \ndes~pl:or pcvcntive arcomuve actions In many cases, such facton must bc spatial rrpmwntalion, scgmnwtioo.and nhrr rite-ppeclfic constdmtions) \nconsidered in order to ensure the completeness and accuracy of the 303(d) List. \n321.1 \t Encouraged the State Warn Resources Contml Board to preserve flexibility in Comment acknovvledged \nthepolicy to asrun: that regional wata quality contml boards (regional boards) \nhave discretion to consider all data and interpmations tbat they&d \nB-I55 321.2 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nstakeholders deemappropriate aspan of a comprehensive, weight of evidence \nappmach for determining wat~ quality impairmenu. We are satisfied that our \ncomments were appmpriately addressed in the most m t -ion of the policy. \nAs described in DPR' s Fmcess for Responding to the Resence of Pesticides in Comment acknowledged. No \nSurface Water, we will be relying on regional boards to determine when water \nquality objectives are exceeded for -11s related to pesticide use. Then, DPR \nand the regional baa& can wok collaboratively to identify the bert responses \nthat will attain and maintain wer quality objectives. Your pmpased policy will \n~rovidecommonmiteria reeional boards will use to make such determinations. -\nDraft Final Policy, Section 3.2: Water Quality Limited Segments Being Addressed \n308.30.312.1 I. \t Refer to Edrtine Policv -It is difficult to identifv areas of scientific rubiectivitv ~, The reference to the The Water Oualitv Contml Policv for Addresine Yes ~~ ~ ~ ~~ -, \t ~.~~ ~ ~ \n3 14.34; 3 16.22, \t when the hung Policy refen to documnls thahc not olficial policy yet. swh \n318.21 \tasThe Wata Quality Control Policy far Addwsing hnpaired Walm'. It is \nrecommended that the Listing Policy only refer to existing policy. (Section 3.2). \n319.29 \t Clearly, then, the change from the 'Enforceable Programs' list to the'water \nQuality Limited Segments' section is purely eosmetic. At least under the \nprevious version of the Draft Policy, the intent to avoid a TMDL by providing \nfor a separate lirt was explicit: under the cumt venian, it is disguised as a \nseparate 'section' of a 303(d) list for which hysteriously and without any legal \nauthority whawvex' a TMDL will apparently not be required. Consequently, \nthe Water Oualitv Limited Seemenu Beine Addressed list renmins in effect an -. - -\n'off ramp' a means of providing a ticket out of doing something (developing a \nTMDL) that the law explicitly requires. \n319.31 \t The language of Section 303(d), when read in the overall context of the Clean \nWater An as well as Section 301, clearly indicates that Congress intended the \nTMDL program to coexist with other enforcement and clean up pm- under \nthe Act. keis no indication Ulat Congnss intended the opaatian of the \nClean Water Act as a whole to disable any specific element of the Act. Yet, this \nwould be the effect of IheWater Quality Limited Segments Being Addressed \nsection. Such an impact cannot be allowed lmp.~~red \t Policy. he Policy has &o Waten' has bem mmo;ed &;the \nwvlred to include a bnef statcmenr that wlm will be placed in Urcategory if \na regulatory program or program can reasonably be expected to result in the \nattainment of standards wi?Ain a reasonable, adopted time hamc The rationale \nfor the lanmaee is included in Issue 2. \nUSEPA midance (ZW3a) allows waters to be listed if a ~merarhis . addressing - -\t - No \nthe walcrqu3ltty problem ThePol~cy gm beyond th~9 by rrqulnng the wtas \nlo be placed in thc recum 303(d) Its1 Tht, secuon of the lhst is not an off-ramp \nbecause the warn will be addressed by a program determined by the \nRWQCBs to meet water quality standards and within an adopted time frame \nComment achowledged. \t No \nDraft Final Policy, Section 4: California Delisting Factors \n308.7.312.13. \t It is not completely clear how segments at various stages of the TMDL pr-s A review of past listings canoccur but only when the listed changes are being No \n314.14.317.1 \t will be handled, or if watm that have met WQS due toaTMDL orother considered. More frequent changes to the list would require a significant \nprogram will have to go through the delisting process. Water segment-pollutant commionent of resow. As stated in the Policy. for the re-evaluation of a - - \n- - COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nNUMBER \ncombinations shauld be listed in the aoomoriate cateeow. reeardlers of the oanicular listine to occur. the intaated oanv may request an existinn listinn ~ ~ ,. \t --\n~Wurof the other pollutants Itsled in &Ifegmenr The hfi Policy should be be rraswrsed b; Ihe RWQCB unds the helt;lingiacl&s of the Policy. The \nrrvlsed to clarify how a waln vgmnVpolluiant combination is rcmrved once quea must include he iofomtim requited by the Policy. \nWQS areattained due to a ThfDL or it should be clarified thaidelistingcan \nhappen homeithercategox-j of the list. In addition,the Dr& Policy should \ninelude a mIhcdoloev wherebv a warn seem1 canbe removed fmmthe \n303(d) list dunng ihclMDLpmccrs, if it is dumnsualed duingthe corn of \ntheTUDL that wta qualtty standards are in fan bnnganained. in accordance \nwith the delisting pmvisim of section 4 of the Policy \n310.4 \t The modifications toTables 4.4 and 4.2 area significant impmvernent hom the Comment acknowledged. \nprevious draft and appropriately ensure cansirtmcy between evaluations fw \nlistine and de-listinn water bodies. \n312.2.312.3.316.5 \t Leaving the regulated communities to self prioritize impairments reparats A review of past listings canoccur. As stated in the Draft Fmal Policy, for the No \nobjectivity from scienceand 'possible' fmm'uisting'impairments, does a reevaluation of a panicular listing to occur, the intuested party may request an \ndissavice to the wblic and wastes valuable resources. Recommmd existine listine be reassessed bv the RWOCB under the delilisnn factors of the \nreeons~derauoa of the followlag issues to rerlom wtenbfie rigor and encourages Pollcy \nthe Board to undrmke a thomugh review of pas1 llsl~ngs wensure that the \npolicy has been uniformly implemented and integrated into thecurrent list \n313.4 \t Another vime of the statistical approach outlined in the July 2004 documt is Comment acknowledged. \nthe elegant symmefly of the listing and delisting crituia. For example, \ncomparison of Tables 3.2 and 4.2 illustrates that a given number of exceedances \nout of a given sample size will alwayr yield the same nsult-'should be on the \nlist' or 'should not be on the list' -regardless of whether thewater body is \ncumntly on the list or not \n316 28.316.31 \t Conemed as la whether older impaimt lirungr uould be rc-evaluated wlhn The Pollcy provlda the mnhodology for re-evaluau~g exirling llsongs In NO \na mronablc urnhame ORRIS theolda l~n~ngs Sguon 4. 'Any intmtd pany may requesl an exlsung lhsung be nasscsred wcre not transparent and wm \nbased on subiective infomation, without ruppnt fmm numrical, statistically under the delisting faaon of thisPolicy.'The section goes on to list the \nsignificant amounts of data. Old listings onen did not have a winen rationale, appropriate steps to take to request a reevaluation. \nand essential repom have been found to be missing, with only photocopies of \nspreadsheets and noquality assurance documentation on file. \n3192.319.8. \t Accordingly. we rccammnd that mow ngomur and mngful dccirron mles The recommended raw wore apprmch doer not mge mr rales and 11has No \n319.14.31923 \t beappliul lo lisltng and dcl~sl~ng. As noled above. we belleve that lhc'raw been suggested that Ihe approach be replaced with othn stauslical appmacha \nwore' 10% mle is adequate lo make listing decisions. as it dm not make (Srmth el al.. 2001) The -on to use the binomial 1st only for delisling is \nimqlausible assumptio\"~ abut thecondition of the water body, pmvides not stated. The use of the binomial test without balanced emn biases the \ninsurance against undnty, and is easy to apply. For delisting, however, we result in favor of the null hypothesis. Statistical errors should be balanced in \nmmmend the application of the binomial statistical method to test the order to fairly address the 0x1s and consequences of either typeof em. \nhypothesis that the water body hasan underlying exceedance rate of 10% with \n95% confidence, against thealternative hypothesis that the actual exceedance As presented by the commente, the appmach is nol scientifically defensible. \nrateis lower than 10%. lhis method pmvides the additional statistical rigor that The same statistical appmach should be applied to bth Listing and delisting \nis necessary to overcome the data-based position that the warn body is impaired pmeesses. - - \n319.7 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \n(i.e., has an underlying exceedmce meof greater Ulan 10%). \n319.23.319.26 \t The Statistical Appmafh To Delisting Will Miss Numerous Impaired Watm The Policy hasbeen modified to require far toxicants that thw be more No \nand May Result In Inefficient and Problematic tisting Delisting Lmpr. The certainty when delisting. In this way more data wuld be requind befar a \nBoard has stated that it should be easier to list than to delis1 a common-me water body or pollutant is removed hom the list \n~osition for which we commend Ule B d However. staffs omred ~.~ ~~-~,~-~-7 \nstat~slical alappmach sinply dm not reflect the Bds stated pos~t~on in this \nregad, and in fact mva us hmheraway fmm that gal Specifically. the \npmposed rule exphdtly makes delisting at least as easy as listing. ~unhamore, \nthe method could result in absurd cycles of listing and delisting, with water \nbodis bouncing off and on the lirt. We urge the Board to adopt a mme \nrigomus appmach to delisting waters. \n319 24 \t Staff's responss to cammmts expltcttly acknowledge that the dellsung \nrequrmunu annm mom ngorous than the Insung nqutmmnts. 'so the burden \nof pmof is equivalent' This makes little sense. In con- to listing decisims, \nwhere water body health is an open question to be evaluated, in deliiting \ndecisions we eanhypothesize that the water being evaluated is impaired, since it \nis almdv on the list. Conseouentlv. the d- of mmf renuired to reiect this . . \nhypothcs~s should be gnaw than the degree of pmof requtnd to lcrt a water \nMy when noth~ng is bow abut the water qualtty to hegm wth. \nAdd the following language in quotes to Section 4: \nIf obiectives or standards have been revised and 'it is demonstmted that' the site \nor vier mts 'the new vatn qtulity standards or 'objecuves', the water \nsegmcnt shall be removed from the section 303(d) lirt Thc listing of a segment \nshall kreevaluated if the uatnqual~ty standard has been changed'and data \nand information are provided to demonshate that thenew standard or objective \nis not exceeded. Such data and information shall be independent of the data and \ninformation used to make the original listing decision, and shall be spatially \nrepmtative of the water body, and temporally representative over a period of \nat least three years; and shall othenviw ma or exceed Ihedata and related \nstandards set fonh in this Policy for listing of waten.' If new data becam available it should always be used even if it changes the \nlisting status fmm l~song period lo l~sting penal. The 'cycles' dtrnused in the \nco&t could not acc& at present, m& than one ti& every two yam. \nThis is mc Using the balanced enorappmach, the delisting quirmmts an Yes \nnot more rigomus by desigo so the burden of proof is equivalent lixPolicy \nuses a statistical produn Iojudge with a pRscribed level of confidence and \npower when obs&ed U&E& in wat.&qdity samples uiggmthe need to \ndelis a water body. \nThe Policy has been modified ~orequire for toxicants that there be more \ncenainty when delisting because of the concerns about the expected impacts of \nthese chemicals. The blicyrequirer mare data to remove a &ta bod;or \nnollutant from the lisi \nThis change is unnecessary. The Policy adheres to federal regulation by No \nrauirine that all data and information will be used in a lirtine assess-1. . \" \t -\nData and information will kmcasured againrt the cxisung WQS unless the \ndata are deemed not val~d, all data and information should be used in the \narrarmcnt. Ad&t~onslly. requ~rements xs to the qual~ty of the data already \n~ ~ \nexist in the Policy. \nDraft Final Policy, Section 4.11: Situation-Specific Weight of Evidence Delisting Factor \n308.28.314.32 Thesituation-specific weight of evidence pmedure is a delislingeon-as Coment acknowledged. \nwell. The conm is that it is harder to prove a positive under this scenario, \nrather than a nedve. For examale. a wata eanbe listed usine the situation- ~ ~ ~ ~ ~ ~~~ ~~~~~ -~~~~ - . \nspecific wenght of cvidmcc factor even when multiple lmcr of evadmce show \nthat the water is not impaced (1.e When all othn Lining Factors do not mult \nin the listing af a water segment) It is simple to say that one line of evidence \n8-158 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nmay point to impairmenk and thaefm the water should be listed ia this \ninstance. However. the comllarv. when all Mher delistins facton do not mult in\n -\nthe dellsung of a msvgnmt, is much mom d~fficult to pmvc In such a \nanmuon. the burden of pmof lr lo show that iheItsung dam are faulty, rather \nthan determining hat the waterbady my be clean. \n319.27 \t The alternative data analysis process for delisting should be modified to ensure As it does for listing, the SimtionSpefific Weight of Evidence Delisting No \nthat greater care is taken in delisting wht has brm already chancraized as an Factor provides the RWQCBs an alternative meIhodology to delist water \nimpaired water body. bodies when data and information dwonsfnte that a water quality standard is \natminedbut lhe Delisine Fanon donm-It in Ihe delisline ofthewater \nbody. This ration pkviics flex~bnlily to the RWQCBr but,: the-time. \nrequim that the doemlatian used to make n listing dsision via this faftor \nbe documented in the fact sheetr and the data and information used m e a \npart of the mod. In this ma, msparency in decision-making is \noresaved. \nDraft Final Policy, Section 5:TMDL Scheduling \n307.20.308.31, \t The Poliev does not ~mvide for a means of atablirhine a orioritvrankine for The Policv adherer to the DrioriN rankine reouiremmts of CWA Mion No \nbodies & required unda CWA Sstion 30j(dnl~~j \naltemsuve approach produces a numerical'Pollumnt Sevnity Sene'that can be the csmbl~shmenl of a sckdulc forTMDLdevelopmnl and let iheschedule \nused to produee a priority ranking for Section 303(d)-listed water badies. reflect the States priority ranking. 31 1.3.323 3 \t Itsled wa& The 303(d)l I I(A) by followin; US&A lisung (USEPA. 2003b) lo rcqulre \n318.22 \t Section 5 of the Drah Policy states Ihat a schedule shall be established by the Currently federal regulation requires a schedule for developing TMDLs in the No \nRWQCBs and SWRCB for warn on the'section 303(d) list that identifies the next twpycars. The Policy includes requiremenu to schedule forTMDLs that \nTMDLs Ulat will be established within the cumt listing cycle will be developed within the current listing cycle plus the number of TMDLs \nand the number of TMDLs scheduled to be develowd thereafter. The last ~~-~ scheduled robe develooed thereafter. USWA midance 12003b) reeommended ~ \t ~~ ~~ ~ ~ \"~~~~ . . ~ ~ \nrcntcnee of Secllon 5 however eonmdlcts this by specnfylng that rU ualer body schedules no longer than 8 lo 13ycan Hawcvn: since remurceallauncnts \npollutant combinations on the SectLon M3(d) Itst shall be assigned a TMDL mnot be predicted more thanme or two ycvs lnlo the fumrc, schedule data \nschedule date. It is unclear in the policy whether or not all listings quire a beyond two yean should be considered estimates \nTMDL completion dale. \nRsammcndauons Scum 5 of the Draft Pollcy should be wvnred la be \nEOnSlSlCnt ulth the SWRCB's ~ntent ~gardtng esmbl~rhmnt of theTMDL \nschedule CASA ad Tn-TACrerommends that the schedule rncludc only the \nTMDLs that will be established within Ule current listing cycle, due to the need \nfor adminisUative flexibility to make adjments in the schedule as \ncimumtances and resources change. \nDraft Final Policv. Section 6: Policv Im~lementation \n318 26 \t The Draft L>stlng Policy a ~ncomlstent rzgardlng the approval of Thc RWQCBs approval pmss rcfrn toapproval of all dectsrons tohn or No \nl~rttngldelxsung declslons (A-38) New language has bcen added to Senlon I ddlrt wala body rrgmnu wbn thew own regronr Thcse approved regional ~ ~ ~ ~ - ~ \nCOMMENT \nNUMBER \nSUMMARY OF COMMENT \nOf theListing Policy re~ardinx aomval of decisions to list or delist a water \nregmnt (~tip NO.~ on p. ~>l'ihe haft Pol~cy pmvlda that 'RWQCBr shall \nappruvc all decisions to 1st or dellst a wata segment (=tion 6.2): llowevcr \nSsoons 6.2 and 6.3 ip. A-38) indrcatc that the Regmal Board's listing \ndecisions arerecammendations only, and that all final listing decisions& \nsubject to SWRCB approval, prior to submission to USEPA for final appmval. \nTksenmce on page A-2 regarding Regional Board appmval should be \nmved M altered to Men that appmval of the303(d) list is to be performed \nby the SWRCB. (A-2, A-38) RESPONSE \t REVISION \n~ ~~ ~~ ~~ ~ \t ~ Fits form the basis for theconsolidated statewide stion 303(d) lirL The ~ --,-,-- ~~-~ ~ ~ ~ \nSWRCB appmval pmcrsr pehns to a final cvaluaum of heregtonal \nappmved liru far compleumas. conrlsancy wth he Palicy aodcomirtavy \nwth applicable law. ARcr hihiscvaluatioh the SWRCB assembles all regional \nliru into one statewide senion 303(d) list, holds a public workshap to hvided \nhutheroppmtunities for public mmment and makes additional changes to the \nstatewide lin as deemed necessary. The fmal urrnplued statewide list is Ulen \nappmved by the SWRCB for submittal to USWA forappmval. \nDraft Final Policy, Section 6.1: Process for Evaluation of Readily Available Data and Information \n303.3 \t Section 6.1 dseribes the Rocas for Evaluation of Readily Available Data and \nInformation. Thedraft final doeu&~t has added Municipal Separate Storm \nSewer System(MS4) mpms under Definition of Readily Available Data and \nInformation. We strongly ncommet~d additional clarifying language ngarding \ntypes of MS4 data that areacceptable in theMS@) and 303(d) pmwcr. \nCumntly, municipal stormwater programs arerequired to compare their \nmonitoring data to water quality objectives. These data include land use, mass \nenission, wet and dry weather receiving warn, and BMP effectiveness \nmonitoring. As a relative compariron exercise, Ulis is not tao objectionable: \nhowever, as a potential basis for fuhm TMDLs, the use of these data is \ninappropriate and unacceptable. \n308.21 \t This section should be revised to acknowledge that review of 'historical listings' \ndo nMrequire the number of samples --that waters should beasswed as if \nthey had never been listed before to determine whether Ulis historical listing was \nappmpriate. \n308.9.310.6. \t The303(d) list is designed to identify waters that require a TMDL TMDLs are \n312.9,317.2 318.9 \t not the appropriate mechanism for addressing waters that areimpaired due to \nnatural background conditions or physical alterations that cannot be controlled. \nAlthough it is possible that the State Board will propose, in iu draft 'Water \nQuality ConUol Policy for Addressing Impaired Waters: Regulatory Smcm The SWRCB is compelled by federal regulation to consider all readily available \ndata and information when making listing and delistings dmsions. The \nMunicipal Separate Stom Sewa System repom provide an impom1 and \nrelatively new source of data and information that should be used. Some the \ninformation in these repas may not be useful for section 303(d) purpors but \nmuch of the data will be applicable, especially ambient water quality nu. No \nComment acknowledged. No \nFor the most patt, Basin Plans address pollutants that exceed water quality \nobjectives due to conditions that arenaturally occurring but there are \nexceptions. Since the Listing Policy is focused specifically on Ule \nmethodology for campletion of the section 303(d) list, it is beyond the scope of \nthe policy to exclude waters from listing Ulat are due exclusively to natural No \nand Options' (see ww.swcb.ca.gav/tmdUdaes/i~~wate~, sources: \nthat thesolution for these twes of waters is to chanee the aoolicable water . . \nquallty standard, that d&nt har oabzen appro& Moreover. ne~thmthe \nSlatc nor Kcgtonll Boards have comned to address these water qualrty \nsfandarcis sihlatianr in a comprehensive and expedited fashion, and it is \ninappropriate fo allow such listings to occw irrespective of the circumtanees, \nW since an effective TMDL cannot be developed. \nI@ 315.5 The current Listing Policy suggests a significant increase in the level of scrutiny \nprovided to data and the amount of documentation that must be orovided bv the Comment acknowledged. No COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nRegions. Also, thedata quiremu for application of thcbinwnial meUlod \nbased listing factom are not consistent those achieved with current funding of \nthe Surface Wata Ambient Monitorine-Pm-- Since the Reeionr we TMDL \nresourus toconduct listing efforts, any significant la- in the 303(d) \nassarmcnt pmeess could undermine or delay 7MDL devclapmnt and \nimplementation efforts. Conseguently, we upa the State Board will grant m latitude and consider resource limitations in its direction for and review of \nRegional Board implementation of the Listing Policy. \n316.29.3 16.30 \t In theassociated July ZW4 response to connnent, the SWRCB indimted Ulat In orda to remove a water hm the section 303(d) list, the delisting factms No \na~olications for reevaluation of an existine inmaimt Listine is mssible must be used. -. \" ~\t 7 ~ ~ ~ ~ ~ \nduhg each llrtingcycle, whelhR new data is availableor not (page B-103). It \nir assumed lhal lh~sre-evaluation. thadar, could indude rc-cvaluat~on of \nolder ltrtingr. Upan clmcrexmnalion of the final Draft documnt. however. \nthe exact p-s and timeframe for reevaluation of older listingsbeeoms \nunclear. As witten. unlsr 1case for faultv data. or inm- aualitv.. . . \nasswancdquallly conml, or llmtauons relaled lo analyrrcal mcthads could be \nmdc, or if arsoetated standards have changed. one mght have to perform the \nreassessrncnt urtng dellchng f3cton of the tirung Polley and the burden ofthe \nanalysis would be placed on the applicant \nDraft Final Policy, Section 6.1.2: Administration of the Listing Process \n319.38 \t Add the following language in quotes to section 6.1.2: The SWRCB and RWOCBs are reauired to solicit all readilv available dats and No \nTbueh the SWRCB and RWOCBs must s~ecificallv solicit all nadilv available arwssmml information-. Once as&mbled. the Policy guidance on \ndata id asrprrment mfomuin. SWRCB~~ RW&B my place ekphaslr m assessing the adequacy of the data and information. A 'citation' to a docummt \nthe sohctranon on the data and \\nformat~on grncraucd wnce the last lmng would notbe considered adequateasstaff would havcno-r U,assas thc \ncycle. For the purpores of this solicitation, infodon means any adequacy of the documentation. This would create additional burdm on staff \ndocumentation, 'or citation to such documentation,' describing the water quality to &ck dawn reference UI data. The propose of the solicitation praess is to \ncondition of a surface water body. Data areconsidered a subset of information fm the record for listing decisions. Just nquiling a reference would wt \nthat conslrls of reports detallrng masurrments of specrfic cnvlmnmenlal hmher this purpose. \nchvancnsucr The data and ~nfamallon my mn lo physical. chmcal, \nandlor hlolo@cal cond~uans of the Slav's warn or watmhcds 'Fach RWQCB Daeumenting pmeess is an additional wok load without substantial benefit \nand the SWRCB sball document its methods and sources for so lie it in^-exisring \nand readily available data and infomation.' - ...-..-.. . \nDraft Final Policy, Section 6.1.2.1: Solicitation of All Readily Available Data and Information \nConcerned that thepropmed Policy creates public participation expectations Absolutely all readily available data and information will be considered in No \nthat may discourage public input to the praeess and conflict with federal developing the section 303(d) list \nrequirements. Members of Ulepublic may be less willing to submit data and \ninformation farconsideration in the asreument process if they must also \npmnde detailed quality assurance information and assessment 307.22 COMMENT SUMMARY OFCOMMENT RESPONSE REVISION \nNUMBER \nreco~dationr. In manv cases useful data and information arecontained in \nreliable infamallon sow such as journals and agency repom that should be \ncunsldmed evm if QAIQC informaurn is not fully available lo the rubmtrer \nThe State is required to -rider any dm and information submitted, even if \nquality assmce information and assessment recommendations arenot \nrmvided (40 CFR 130.7mN511. . . .. \nDraft Final Policy, Section 6.1.2.2: RWQCB Fact Sheet Preparation \n307.21 Documtation Needed For All Assessed Waters: We support the pmpmal to \nrequire development of water body-specific fact sheets to suppon assessment \ndeterminations. As drafted, IheFmposal appean to require fact rhea \npnparatioa only for waten that arebeing newly listed or delisted (ktion \n6.1.2.2). The State must prepare documentation demonsmating how data and \ninformation for all waters was considered in lheasssrment mess. even in \nnrawhere lhc waten in question are not pmpd for lining or delisting (40 \nCFR 1307(bK6,). Comment acknowledged. \n312.12 A consistent complaint with early 303(d) listing episodes is inability of the \nregulated community to identify the source of impairment data, which therefore \nimpedes the source conhol and delisting pmcers. Thejustification or mionale \nreferenced in the Fact Sheet or staff repon should be included for stakeholder \nreview and made a pan of the herecord. mir would also facilitate data collection \nfor future reviews by all of the involved groups. All data and information will be a pan of the mrd. No \nDraft Final Policy, Section 6.1.3: Evaluation Guideline Selection Process \n316.24.3L6.27, \t Anotha key pan of the problem with this approach is that guidelines are not \n318.12 \t legally adopted water quality objenives and therefore have not undergone the \npublic review and comment to determine if they are appromiate based on Water \nCode $1324 and 13242 factors which balance the &ok& standards with \nother facm such ar.economics and the need for recycled water. The City is \noften blindsided by new studies referenced at each Listing cycle, dislupting \napproved work plans and projects. Therefore, recommend increased stakeholda \nreview and comment of those guidelines when applied lacally, including \npmmulgation and doeurnentation of numaic guidelines in Basin Plans. This \nwill ensure ttansparency in the listing process, resulting in the fair and cost- \neffective application of numeric guidelines and references. \n316.25 \t Past experience indicates that guidelines sometimes are applied inappropriately \nto local conditions, with justification rationale such as. 'this is the mmt \nprotective or stringent guideline' or 'this is the best anilable reference water \nbody.' Comments have been provided on the variation of circulation pamans, as The Policy provides guidance on the use of evaluation guidelines that represent No \nstandards attainment or beneficial use attainmenL Fmmulgation and \ndocumentation of evaluation aidelines within the Basin Plansare bevond the \nscope of the policy. ~ustification for the evaluation guideline must bebresented \nin the fact sheet. \nThe Policy provides niteria to follow in the selection of evaluation guidelines No \n(Section 6.1.3). AdditionaJly, the RWQCBs must reference the mluation \nguideline in Uu water body fact sheet and include the documentation ia the \nlistings submitted to the SWRCB. All documentation included in a listing -- ' COMMENT SUMMARY OF COMMENT \nNUMBER \nwell as tidal activity, water body smcNre, water use, climate, ue., but the \nguidelines or references areapplied locally with no adjustment. Therefae, \nrecommnd that not only the justification rationale be refenneed in the Fact \nSheet, but alsn that it be included for weh holder review along with the Fact \nSheet. in addition, 'bst available' or'mt stingent' should not be considered \nan acceptable justification ratonale forloral application. \n319.39 \t paragraph in section 6.1.3: Add the following language in quotes to the f~t \nNmtive water quality objectives shall be evaluated using 'interpretive' \nevaluation guidelines. When evaluating nanative water quality objectives or \nbeneficial use pmtenion. RWQCBr and SWRCB shall identify evaluation \nguidelines that re-t standards auainment or beneficial use pmtection. The \nguidelinesarenot water quality objectives and shall only be used for the \nDurwse of devclo~ine the don 303(d) IiiL 'If aoomoriate evaluation . . . \t- . . ,. . \nguidclincs cannot be tdenufied or ifemluanon gwdeltncsdo not result in losung \nIn waters where some data indicate impaimrat. aha data ainfmt~on may \nbeuredperssuon3 111' RESPONSE REVISION \ndecision is rubjecl to public review during Ule public commmt period. \nThe suggested revisions are unnecessary. The third bullet in the section \npmvides guidance on the use of 'interprwive' evaluation guidelines. \nAdditionally, it is already stated in section 3.1.1 I that the purpme of this \nsection is to provide another mesas to evaluate data and information. No \nDraft Final Policy, Section 6.1.4: Data Quality Assessment Process \n307.19 \t The Policy should be revised to authorire the listing of waters based solely on \nancillv data and information smes that may not meet all of the pmposed \nqualityassurance expectations in Section 6.14, but which together satisfy a \nreasonable weight of evidence test demonswting pmbable water quality h t \nor impaimnt. For example, available water quality data indicating high \nfrequencies and magnitudes of water quality standards erceedancs would likely \nprovide a reliable basis for listing even if supponing quality assurance \ninformation is not pnfeft. It appears the Policy does not authorize listing in this \ntype of situation ease beeause no data are available that meet all of rheproposed \nquality assurance tests. \n308.32 \t Recommmd that tbe Listing Policy establish that all data and information be \nevaluated and screened to enrm that only high quality data that are accurate \nand verifiable be used to make listinglde-listing determinations. Data of sub- \nstandard quality should not be used . . develorrIhe 303(d) list. Oualitv assurance -. \nshould bc an overndlng pnnclplr in the Policy, as it ensures 3lewl ofrc~rnufic \nngor necessary for Ulc listing pmcsr. 'therefore. a data qualiry assessnmt \nshould accompany all listing decisions, and should be p-ted in the fact \nsheets for the water segment. \n312.6 \t If visual and semiqualitative assessments for listing factors such as nuisance, \nad- biological response, degradation of biological m~dations and \ncommunities,&d bi~ccumula~ion lines of evidence' are aeeepted ~anciliq \nthen steps should be Wen to insure that they refer to quantifiable conditions in As drafted, the Policy allows for the use of all data and information under the No \nprovisions of the rite-specific weight of evidence listing and delisting facmrs. \nWhile the Policy says that all dam and information shall be used in the section No \n303(d) listing process, the data and information must still meet the data uualitv . \nreuuiremen<as defined in the Policy unlesi it is determined Ulaf the dara' \nshould be considered underthe si&tion saeeifie weieht of evidence listine \n ~~ ~ \nfaaor If pur quality data are used then the rationale for its use will bc \ndcscnbed in faet sheell. \nA data uualitv assessment is muired to be included in fact sheets \n~ \nThe Policy contains language fhat the data and information used to make No \ndecisions far certain listine facm (suchas nuisance. adverse bioloeical \nresponse, and degmdation-of biological populations &d mmitik), are \ncompared to reference conditions (Sections 3.1.8.3.1.9.3.1.7). COMMENT \n312.8, 314.37. \n314 36.314.35. \n316.15. 318.23 \n322.7 SUMMARY OF COMMENT \nthereference eanditiom \nLn prcvious drahs of the Pol~ey. the Regional and Stare Bavds were able to \nexcludedata that was older, or &d no1 mcet lhcquality assurance rcqturements \nestablished by Uuhung Policy. The July 2004 hfl Pol~cy provlder in rcctlon \n6.1.4 that, 'Even though &I data and information must be used'.... (A-31). Use \nof the word 'used' imlia that Reeimal Boards must include all information in \ntheir lis~ngldclining'dsisions. lnaddition. Sexion 61.4 of the current drift \nPolicy spmfies thal'[a]ll'data of whaleverquality can be used aspan ofa \nweight of evidence determination (sections 3.1.1 1 or 4.1 I).' The commenter \nncommmds that the Listing Policy establish that all data and information be \nevalualed and %wed to ensure that onlv hi& &itv .data that are accurate \nand verifiable be used to make lisl~ngldelirtlng determinations. Data of sub- \nstandard quality should not be used todewlop lhc 303cd) lisl. Quality arsurancc \nshould be an overriding principle in the Policy, as it ensuns a level of scientific \nrigornecessq for the listing &ess. Therefore, a data quality assessment \nshould acmmpany all listing decisions, and should be presented in the fact \nsheets for thewater segment. \nData must be dwnstrably uedible and the listing of waters asimpaired based \nupon less lhan credible science wastes scarce reram and resulll in the public \nperception that our envimnment is in much wnse condition lhan it actually is. \nThe 303(d) listing process has been loosely intspmed over the past decades, \nresultine in far too manv listins with vav little data m file to substantiate whv . \nthe llrlligoccumd Ln a state insuch dl& financtal rrraxu. credible data qualtiy \nrequlrcrnenls is not only gmd publlc polcy. 11is gmd fiscal pollcy RESPONSE \t REVISION \nDunng the data and dmum solicitation phue, Ihe SWRCBand RW(2CBr No \nwould rimultanmusly acuvely solicit all madrly availabledata and assesma \ninformalson on the qdfy of thesurface watm of the sue Thcsolicitation \nwould foeus m absolute$ all data and information that might be available. \nRpadilv available data and information would include infamatian fmmanv ~ ~~ \nint-ied pany, tncluding but not limilcd lo: pi~tecitirms; publicagcnck; \nStas and fedaal governmental agencies: nonprofit o~@zaioas: and \nbusingxs possessing data and iaformation regarding the qualityof a region's \nwatm. All data and information received by the SWRCB and theRWQCBs \nduring the solicitation Daiod will be rubiected to 1data oualitv ar-mmt -\t ~, -~~~~~, ~ ~ ~ ~ ~~ \nprocas to detcrminc its qualily. Data Supported by a Quality Assurance \nProiecl Planor equivalent pmgranrr or gateraled by wellenabbshed major \nmonitoring program, nu&c data that meers the list of elemnu listed on the \nPolicy (s&tion 6.1.4) would be eonsidaed endible and relevant for listing \npurposes. Data considered of less rigomus qualily can also be used but only \nwhen in combination with high quality data and infamgtion. Such less \nrigomus data and information would not be wd by itself to suppart a listing. \nComl ackaowledged. \t No \nDraft Final Policy, Section 6.1.5: Data Quantity Assessment Process \n314.5 \t Many of the changes that have been made actually rsult in an approach that \nwill not necessarily be tshnically wd. In fan, the Draft Listing Policy now \nspecifically states Ulat 'Before determining if water quality standards are \nexceeded. RWOCB's have wide discretion establishine how data and -\nlnformatian areto be cvalualcd, including the llcxibiliry lo establ~rh water \nrcgmmtauon, 3swell as the scak of Spaual and lemporal data and informat~on \nthat arem be reviewed.' (Draft Listing Policy, pg. A-33) We believe that this \n'wide discretion' is exactly whal thepolicy was being designed to avoid -water \nsegmenls listed in an inconsistent and subjective manner, employing a wide \nvariety of assessment methodologies, sometimes rsulting in listings made with \nW \tminimal, andlor nm-nprsentative data. The Policy dm provide the RWQCBs with discretion in the Data Quantiry No \nAssessmentProcess (section 6.1.5). However, in subsectimr 6.1.5.1 -6.1.5.9 \nthe Policy pmvides guidance on the facm m be considered in this \ndetermination. Funhemore. the Po~~N reouirerUlat these considerations are ~ ~ ~ ~ , , \ndocumted in the water body fact rhee~ in this way. Ihc basis for a decision \nis subject lo public and agency review. \nb Draft Final Policy, Section 6.1.5.2: Spatial Representation \n - - COMMENT SUMMARY OF COMMENT \n312 10 The llsong Pollcy seem la rnfer that measmnls fmm one rcach rccuon can \nbe ued to hnan enurr segmml In ram ma, lhs ir unnemranly bmad and \ncould be due to habitat or spefific discharge issues. In these cases it would be \nmon appmptiate lo a h Ikspecific problem rather than an entire reach \nConsisMg of many stream mils. RESPONSE \t REVISION \nSamplm should be rcprrwntal~ve of the walu bcdy regmmt w pocuon of the No \nregmmt Sampler should be collected mamsUlal charanmm che water \nbeing considend for listing. Guidance is provided to quire that spatial \nind&dem of samples i;maintained \nDraft Final Policy, Section 6.1.5.3: Temporal Representation \n308.33.314.4. 7he Policv should mire ht olda data murt be ruool-ted.. withnewadata \n3146,316.23, for lirtiagpurposes. kth the rumval of reqturemu Rgardnng the age of data. \n31824 the Policy porntially allow Itstings to be made based on data hat is likely no1 \nrefleftive of ewent conditions. Although thecurrent dnR aUow older data (no \nage specified) to be discarded from the evaluation if new facilities and \nmanagement pmticer have been implanented that resulted in a ehange in the \nwaterse-t (See. Section 6.1.5.3). absent sosific information regardine - \" \t ~-~-- ~ \t ~ ~ \nfaciliticrand managernen1 actions, it is assumed thal warm bcdy conoitions \nhave na chvlged. baddition, molder data may be of lown quality as \ncompd to more rsmt data, due to improvements in fidd and analytical \nmechods, such as clean sampling pmeedures. \n308.34.314.1, Originally, the draft Policy provided that, 'Sampler shall be collected to be \n3L4.38,316.l6, rwresentative of temDoral characteristics of the water bcdv.' In the Julv 2004 \n318.25 \t &h of the Policy, me languageof Iha seclron was changk. To say &at \n'Samples should be represenlalive of the cnl~wl umng Ihal the pollumt is \nexpected to impact the ualer body'. It is unclear what the SWRCB mns by \nIhis sratement. (A-34). Thecommenter svongly recommend that Ihis section \nbe modified. The first senIence of section 6.1.5.3 should reven back to warding \ncontained in the December 2003 Draft. This section already included laneuaee \nthat mqulres Ulat mtrcal condmonr be appwalely qresrntcd m the dam re1 \nwth the stalcmml, Ttrmng of the sampllng should include the mural Feaaun \nfor thepollumt and applicable wata quality standard.' (A-34) Also stmngly \nmomd hat the policy include specific language in Ihis xction regarding \ntheaoolicatiod of water ~~ih~obiectives as ammiate for seasonal . . . .. .. . \neon&t~cns Chrontc water qwl~ly cntma should na be used lo drtmne walm \nqual~ly slandds atarnmcnt dunng wndnttons where chmrue exparum rr not \nexperienced (i.e, during storms and floods). \n310.5 \t Il is recommended that when data used to list a water body indicates Ulat the \nimpahmt occun only during specific wet or dry seawnal weather conditions, \nthe listing on Ihe303(d) list should specify season or condition (such as wetidry \nseason, st- flowldry flow conditions) for which Iklisting applies. \n316.21 \t Into-te WA Trend ~1dmce -WA Guidance requires listing of warn that \nwill exceed Ule associated standard before the next listing cycle. mi statement Thedata aee~ui-ts we~deletedfmmthePolicv \t No . to encm -~the \n~ \nRW&BS to mnridu all data and infmuon. The rmpartant aspst of data is \n16relevana to dwcnbing em1 conditions of the water quality scgm~lLFor \nsome water bodies only older data areavailable However. even oldadata must \nmeet the data quality quiremarts as defmcd in IkPolicy. u\t~ ~ ~~~~ \n~p \nThe goal is to determine whether water quality standards arebeing attained in a No \nsaeeifie water semt. In someeases. exe&Ces of warn oualiN standards . , \nwill only occur duringrpsilic cnlleal llmes during the year Data and \ninformal~on todelemine water quality tnpscls should be as rcpataon as \nposriblr of me condillonc. If h~starical data and lnfomuon show that water \nquality standards are exceeded during particularevenrs or seasons, then the \nassessment should be limited to that critical period. \nThe Policy outlines the information that wiU appear in the water body fact No \nsheet (section 6.1.2.2). Included in the summary of data and information is \ninformation on temporal representation including seasonal conditions. \nAssessment of declining umds in water quality is addresredin Senion3.1.10 No \n(Trends in Water Quality) and thestatement is included in tha~section. - - COMMENT SUMMARY OF COMMENT RESPONSE \t REVISION \nshould be included in the Listing Policy. (Section 6.1.5.3), \nDraft Final Policy, Section 6.1.5.5: Quantitation of Chemical Concentrations \n314.39.314.40 \tNPDES monitoring conducted using QLr that arehigher than water quality \nobjaives areconducted in accordance with pamit provisions using EPA- \naDmved methals and in accordance with the Oh in the State lomlernentltion \nPoiicy or ocean Plan, and assuch should not berimply ignored &d dsscarded \nfrom tk dam w~ lhe QLs ~denufiedin these doeumenu are bawd on the best \navailable technology, and the discharger conducting mitoring under these \nconditions is determined not to be out of compliance. During iheevaluation of \nthese dam in reasonable patentid analyes, this condition resulu in the \ndetermination that there is not sufficient information IO determine that effluent \nlimitations arenecessary. Under this scenario, dischargers are required to \nconduct additional monitoring and are required to describe actions undertaken \nto achieve lower QLs during the pamit period QLs arenot ignored in thePolicy but rather areaddrased simply by No \nconsidention of magnitude of the water quality criterion or objective and the \nusefulness wine thebinomial tesL lkreasonable mtential analvsis is used \nfaanolhcr pu&c olkr than the =\"on 303(d) li;~ Likewise. &it \nmmpl~anccis gomed by different rules than the development of the seaion \n303(d) list. \nDraft Final Policy, Section 6.1.5.7: Binomial Model Statistical Evaluation \n307.12 \t For a binomial statistical test to yield valid inferences in su~wrt of a water \naualitv assessment. the evaluaG data sets need to be clasei; examined to . . \nensue that samples are~ndcpcndent and do not exhibit autocamlar~on or serial \ncmlatlon characterislics. Data collecled through my monitoring programs \ndoer not meet these tests. The draft Policy daer not reeognire Ihese limitations \nto the nltd application of the binomial appmh. As a result of these \ndeficiencies, the drah Policy would likely result in inaccurate assessments and \nthe failure to include on the Saion 303(d) list large numbem of warn and \npollutants that are reasonably likely to exceed applicable water quality standards. \nDraft Final Policv. Section 6.2: RWOCB A~~roval \n315.6 \t 'IkListing Policy calls for Regional Boards to provide written rsponses to all \ncomments. This will be pmblematic if written responses arerequired for oral \ncomments received at the Rebonal Board meetina, or for written comments \nreceived at the last minute. This would muire twa meetiner befan a Reeional \nBoardcan act on nu listing recomnun~t~ons. one to reccive testimany and one \nlo rake action with no funher lestimuny This is conq to normal Regional \nBoard meeting procedures, and due to Regional Board meeting frequencies and \nconstraints, two meetings would add an additional manth to the process. This \nwould not be necessan if writtm remonses will onlv be reauired for mitten \ncomments received in a umely matla in accordance wIh a publ~e nouce fn a \nhcanng, the Rcg~onal Board need not consider is1 mnnute umttsn comments. The Policv recornires hat data autm~~elation miv influence Ule sireof the No \namal aloha valie used. This is one reason that f&thore standards where ~ ~ ~ ~~ ~ ~ ~~~~~ ~~~~~~~~ -~~~ -~~~ ~~~ ~ \nssmplcs are collected close together in lime or space it is necessary to avmge \nthe valuer Thir averaging will likely reduce the impacts of data that arc not \nindependent. If data remain highly auuromelated this issue should be \naddressed during data analyi;and fact sheet preparation (pabps by using the \napproaches suggested in USEPA (ZWZa)). \nThe response to comments is needed fork SWRCB approval pmeess. No \nRWQCBs should follow the existing meeting practices when thelist \nrecommendations arearmroved and fmarded to SWRCB. Resmnse to \ncomments eanbe eamoi&d a~er RWOCB action. Thir is allau;ed beeawe .-- ~~~ ~-~~ ~---~ ---- \nRWQCBr are only required to approve llsung decisrons not the supporting \ninformation. COMMENT SUMMARY OF COMMENT \nNUMBER \nand oralammnts muire onlyoral resmses. \nDraft Final Policy, Section 6.3: SWRCB Approval \nTheJuly 2W DraR Policy mmm mput at the Stare Board level to issues \nbrought up to the Regional Boa& However, the State Board, on its own \nnotion, can change a listing dsinon. There cmlly is noavenue for mmmnl \non these changes unless they have been addmsed the Re@onal Board level. (A- \n38). Public comment should be allowed at the Stale Board level when the State \nBoard decides. on its own motion. to change a listing decision. -\nThe Drah Poltcy shauld be mvlsed to allow public eommenls (both written and \na1 any public h-g \t beforc the State Baadl on proposed listing or delisung \ndecisions where me State Bead aes up its own~mition in eithkcase FU& \ntheDraft Policv should be revised to allow cornmenu Ulat mieht not have beea \nprovided a1 thk~qlonal Board hearing on a pmpored listingor delistmg \ndecision uhue such comments rarsc ~ssucs or provide informalion that was no# \nreasonably available a1 the ume the Regional Bavd considered the lisl~ng n \ndelisting decision \n308.35 \t The sentence on page A-2 regarding Regional Board approval should be \nremoved or altered to retlect that appmval of the 303(d) lirt is to be perfamed \nby the SWRCB. \n319.40 Add the following language in quotes to the last ~arama~)h . . in section 6.3: \nBefore the adop&n of the section 303(d) Itst. th; SGCB shall hold a public \nworkshop. Advancenotice and opponunily for publrc comment rhall bc \npmnded. Comenoshall be Inmired lo thc ussuer raised hcfare the RWQCBr. \nRequests for review of specific listing decisions mwst be submitted to the \nSWRCB within 30 days of the RWQCB's decision. The SWRCB shall conside \nchanges only to waters that aremuerted for review unless the SWRCB. on its \nOW -muon: decides toronslder Aomdatioos oaother ~ 1 ~ s \nSWRCB shall eve subrtantrsl defnmce to the RWQCB on decisions mJe \nunbc the Wcighl of Endenceappmachdcrnibed in Smon 3 1.11. \nSubsequent to the workshop, the SWRCB shall approve the section 303(d) list \nat a Board Meeung. Theapproved section 303(d) list and the suppwling fact \nsheets shall be submitted to USEPA fa approval as required by the Clean Water \nAct. RESPONSE \t REVISION \nThe SWRCB approval pmcas is thc last slage of renew, and final Ya \neansolidauon of a statewide section 303(d) list befm the lust is submitted to \nUSEPA fw appmval At his poml, the SWRCB holds a public wrkshop thal \nnot only considen all issues raised before Ihe RWQCB but alsoadditional \nlistings, delisting orchanges that have been made by the SWRCB on its own \nmotion. Prior to aublic workshoo. the SWRCB will make available the ~ ~ ~~ ~ ~ ~~~~ ~, ~ ~ ~ \nconsolidated reclion 303(d) sta&rde llst with all addition, delcoons or \nchange pmpowd by either the SWRCB or the RWQCBs fa public review and \ncommmr lhepublic and ~nterested parties will also have ~aqlw~fy \nto dims the &nralidated statewideiist and any other issues relatzlo the \nsection 303(d) list at the SWRCB wnkshon. The Poliev has been revised to ~. . -\nmom clearly reflect the public's nghl lo commnl. \nDuring the data assessment step of the weight of evidmee appmach, decisions . No \nto list or delist a watersegmmt anappmved by the RWQCBs and a resolution \nis aomved in suown of their mommadations for thehesection 303(d) list. ~. . ~~ \n~fi;;appmval. Ih; RWQCBs submit their lirt changes to the SWRCB. me \nSWRCB appmva thc section 303td) lirl and submis rt and the supporting fact \nshccts lo USEPA as required by the CWA. As discussed in seaion 6.3 of the \nPolicy, SWRCB will a&e thesect& M3(d) list before it is submitted to \nUSEPA. -\nThe Policv ~mvider that SWRCB slaff will evaluate RWOCB fact sheets for No .. \ncomplcwnesr. coosirlency with the Policy, and conslstenc~ with applieablc \nlaw. Evaluation of RWQCB l~sltng dff~sioos will be pafad as descnbed in \nthe Pol~cy.'subslantial defmnv would undmoed lhc SWRCB's nvicw mle COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nComment related to Policy Adoption Process Received After February 18,2004 \n319.12 \t In addition, IheDraft Policv. FED and Resmnse to Commnts fail to comolv 7, \nwth CtQA In ow Febluary 18.2004 mmments we pmvlded extenswe deal \non thae fulm The have not bm adequately addmred Thc Drafi Pohey. \nFED and Response IOComments do naadequaWy identify, lnalyle or mitigate \nthe numemus significant impacts of thePolicy, as mon specifically described in \now first lener. \n319.13 \t To the extent that comments made in our February 18,2W letter have not been \naddmsed in this version of the Ihaft Policy, we incorporate by ref-ce those \ncomments. \nAppendix B, Response to Comments, Table 2 \n304.2.304.1, \t Extensive concern regarding application of the precautionary principle. \n305.2.305.1 \t Following aresom of those concerns: \n*The application of the principle encourages prohibitions or limitations on \nactivity based on mere allegations of ham \n*The minci~le does not allow consideration of benefits. . .* Evidmtiary standards are not a~llable for what type. quantity and qwllty of \nlnfomulion would be required lo assen a threat of harm or to prove thal there is \nnot a risk of hann (setting aside the impwibility of pmving a negative in the ~~ .. \nfint place). \n* Its a~~lication -. would create conmlete reeulatorv uncenaintv for businesses. \nUrge the Stale Bad lo drrect Suff lo delne the cunenl reponre m Append,?. \nB related Io the pmuuonary pnnc~plc A response that cxplalns why the Pol~cy \npmtects the environment and now that the Legislature andthe state Board have \nnot setfonh Ule precautimary principle as applicable policy in California would \nbe appropriate. \n316.26 \t The response to comment on Page B-Ill of the FED indicates that Basin Plan \nreview of guidelines used for Ihe listing pmeess is outside the scope of the \nListing Policy. However, guidelines used in the Listing Policy have been \ntransferred to asswiated TMDTMDls. The regulated community must Ulen comply \nwith these guidelines and, only at specified reeonsideration dates, \nsometimes 4 m5 years dawn the mad, may they be reconsidered again. It seems \nas if theseguidelines arebeing used as standards and should be fondly \naddressed as such. Ideally, guidance and references applied m ow local watm \nbodies for a number of years should be subject to a full public review and \ncoment process at some point, ensuring that they are \napplicable to those waterbodies. This type of review daes take time, but it also Comment achowledeed. No \nComment acknowledged. No \nThe Recautionary Rinciple PP)as described in the Rio Declaration is not the \nbasis for the Listing Policy or the FU). The justifications for Ihevarious \nprovisions of the Policy arecontained in the issue papen presented in the \nFED. No \nThe CEC documnl pmwdes one definition of PP and it is lncldcntal Uul the \nprovisions of the Policy coincide wth the CEC dwumenl. The intent was to \nshow that the Policy describe a Drocess for listing Ulaf is taken in advance to \nprotect against pasiible failure aimking wmng decisions \n7hc response lo thts rommenl s not ~mpl~c~tly orupl~etUy SWRCB poltcy \nAny reference or lnlerpreuuon to the conw a nor appmpnale Rulhcr, the \nrnponscdoer nor conflrct or undcmune any otkr CalEPA ml~cv or nutdchnc..-\nEvaluation guidelines used to interpret nanative water quality objectives mt \nbe referenced in the water body fact sheet Additionally, Ulis dmmmrarion \nmust accompany the RWQCBs list submission to the SWRCB. Faa sheets \nand acmmpanying documentation areavailable for public review and commmt \nduring the public comment paiod for RWQCB appmval of list changes and at \nthe SWRCB hearing for approval of Ulelist No \nB-I68 COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nallows the reeulated commmitv adeauate time to olan for studies that mavtake - . . md y- lo budget and complete, asweU as urn lo plan and budget for \nfuwrc wata body cleanup. In addtuon, this type ofnvicw Jlows thecnty'r \nwastewater treaunent plants and indusuial disebargers enough time to comply \nwith theguidelines, or u110K-d standards, if tky uetransferred to an \nasraiated TMDL as same have been. \n3 19.34 \t 'lkState Must List Wafers Impaid By Pollution. As staff stated in its Fedd regulation limits the section 303(d) list to pollutants for which TMDLs No \nRerwnse to Comments. 'lilf a water bod\" dm not meet water oualitv standards cam be develooed \n~ ~ ... \t . , ~- ~, \nit should be placed on tk M3(d) lirL' dapte this lwid and weurale \naniculalion of the law. theIkah Policy continua lo llrnll listing of inpaid \nwater segnars only when the impairmmt is due to toxicity, a pollutant or \npollutants. Wata. bodies that are impaid by any sow of pollution must be \nlisted. li%s mit ti on is su~wned both bv tk nlain laneuaee of Section \n . . \n303(dXlX~j and by legioprnrons mterpretnng 11, anduhashasbeen rupponed by \ntheRwonal Boards as well in tesumoy and elsewhere Tlus positton is also \nsupponed by the Nallonal Rerearch Council. which found that the TMDL \nprognm'sbould encompass all smsns, both pollutants and polhtion, that \ndetermine the condition of the waWy.' The NRC found this step to be \nimvortant beeause'activitia that can overram the effects of 'oollution' and \nbring about wala body mlad~on such 35hab~tat renomuon kd channel \nmodlficalton should no1 kexcluded fmm ronsldcratran dmng TMDL plan \n~mplementatlon.' \nMiscellaneous Comment Received After February 18,2004 \n302.1 \t Concerned the hsting Policy proposed by the SWRCB will mll back critical Comment acknowledged. No \nprotections for California's waterways and cause irreparable ham to human \nhealth and the environment. \n307.1 \t The commenter has reviewed the draft final Water Oualitv Conml Policv for Comment achowledeed. No \ndevcloplng the Clean Warn Act &\"an 303(d) bs&tcd July 22,2004' \nAlthough EPA is rerponstblc for rcnovlng and acung upon State 303(d) Insung \ndecisions which will be based on an assessment methodology, we do not take \nformal action on he methodolorn itself. \n307.2.307.3. \t We share theState's goal to develop clear listing guidelines Ulat will strengthen ThePolicy is in compliance with federal listing requirements contained in No \n307.4.307.26 \t the water quality assessment process and promate statewide consistency in CWA section 303(d) and 40 CFR 130.7. It is anticipated that Ulen will be \nlisting decisions. It is vay important for the State to adopt assessment broad agreement between the State and USEPA on the vast majority of listing \nguidelines that will also result in listing decisions that EPA can fully approve. and delisting decisions. \nWe are concerned that the draft final Policy is inconsistent with federal listing \nW \t requirements and applicable California water quality standards, and would \ntherefore yield listing decisions that EPA cannot appmvc. I& COMMENT SUMMARY OF COMMENT \nNUMBER \n307.5 \t We recognize and appredate that the draft final Policy incmprata \nmdificationr that fullvaddress several of our orior corn-. includine: \n-acknouledgemmt af Ur nqlurcmmt thal State staff must dmttly assemble \nawlable dam and infomt~on, and not nly solely upon public data \nsubmissions. -deletion of minimum sample sire quinmenu. \n-inclusion ofpmvisions for listing based on ambient toxicity testing results \nreeardlers of whether the wllutanu at issue have beea identified \ndclmon of namral sounr exclusion language, and .clanficabon of pronslons \nconccmrng nltance on enforceable programs as a basks for not tncludrng \nimpaired waters on the Sdon 303(d)list \n308.1 \t Urge the State to approve and adopt ihe Final Policy - - with the suggested \nchange below --as soon as reasonably pible. As you know. the 2W4 \nSection 303(d) List Update pmcm is underway, and it is imperative that any \nfuture TMDLlisting decisions be made using a consistent and objective seI of \nguidelines. \n309.2 \t The develooment of the draft 303(d) List Policv is bv far one of the mast . . , , \nimpomt documents dewloped by the SWRCB in the past few years and it will \nhe the fim nme the SWKCB has rpeclfic Policy gurdanee for local Reg~onal \nBoards to follow and hopefully will ensure water body listings are done on a \nmore consistent and technicallv sound basis. \n309.3 \t Suppon and endone the comments of the Regulatory Caucus of the AB982 \nPAC in full. \n309.5 \t Urge the SWRCB to consider and incorporate oursuggestions and urge the \nBoard to formallv ado~t the final 303(d) list Policv as soon as reasonablv . . \nposnble, so that Reganal Boards and the regulated community can ~mmedralcly \nmkeadvanugeof the 303(d) Pobcy'r enena, gutdance and ob,ccuves on water \nquality bodies and segmenu of concern. \n312.15 \t Appreciate the opportunity ta provide input on Ule303(d) listingdelisting \nPolicy. \n313.7 \t The current draft of the policy represents solid progress in your effon to create a \nstatistically round Iiamswork for Section 303(d) listing and delisting decisions. \n314.2.322.4 \t Agnes with the daailed commnu and recomendatioos provided by CASA \nand Tri-TAC. These recommendations reston some measure of consistency, \nDdctabilitv and technical merit and without them we see no immvement to \nthe current pra-as This drafi Polley is very drscomgmg afto w, much cffan \nand hard work went into impronng thtr pmees \n3143.3164, After revlewng the cumnt dnft ofthe lisung Poltcy. many changer have \n3182 3222 occumd in thc Pol~y If consrdered sepmtely thcrc change could be RESPONSE REVISION \nComment acknowledged. No \nComment acknowledged. No \nComment aeltnowledeed. No \nComment acknowledged. \nComment acknowledged. \nComment acknowledged. \nComment acknowledged \nComment acknowledged \nComent acknowledged COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nNUMBER \nconsideredminor:however, when considered in totalthey tend to substantially \nreduce thewientific rigor of the listing policy. Unfommtely this reduction \nincrraser the potential for imnsistent application of the Listing Policy betMm \nregions and lowen confidence in the Listing Policy and impairment listings bt \nmight begenerated by iL meresponsible pds mirely on the mrreehless \nand immianee of theselirtines in cornminine funds to runediale thun \n~~~p ~p - ~ -- \n314.43 We would like to thank the SWRCB for their hard wnk Ulus far in develo~inc \nthe listing Policy. Weconunuc to suppan the SWRCB in theirgod lo have ihc \nPolicy in plaee before Uunext updale of lhe 303(d) list is complael The \nSWRCB n& lo modify thecwrrnt Diafl Lisung Policy. accord~ng to the \nrecommendations outlined above, in dalore-instill the elmts of \nconsistency, transpanncy and scientific rigor that arenecessary fora tshniczlly \nsound anamach to develooment of the Sete's 303id) list. W~thout these . . \nproposed changes. wcarecmmcd lhat the end mull wll be umlar lo ihe \nsubjalvc and mable approach that occurred in prenous lrsung cycles Comment acknawledeed. \n315 1 Thank you for theopponun~ly lo comma1 on the subject drah final lisung \nPol~cy My eommenls reflect ihe new of the xlcnusts and engtneen who will \nbe responsible for carrying the load of implemmting the Listing Policy. We \nhave provided specific recommendations and submitted commenU over the \nmore than two ym that this policy has been in development. We appreciate \nthat a number of our recommendations havebeen incorporated, however we still \nhave concerns that reflect interpretation of listing policy provisions or our \nprevious recommendations and comments that have not been accommodated. Commnt acknowledged \n316.1 Acknowledgs the SWRCB and local RWQCBs for their joint effortto \naandardize the delisting and listing pnxess by incoprating commonly \nacceDted and mmducible scientific methodolorn in their ~rocessmvmach. Commmt acknowledged. \n316.3 The Listing Policy is a comerstone of the TMDL Program and an integral \ncomnent. W~th a more msmt. accessible. and scientificallvrieomur. Comment acknowledged \nlisubg~oltcy, publac confidcdce in M?(d) lisr~ngs wll improve;heiptng polnl \nlocal TMDL program an a less conlmaous and pmducuvc &rmlon \n31635 Appmales and !hanks the SWRCR and isstaff for the effon they have pul \nfonh m draR~ngthe 303( d) lisung Pollcy and addmmg pmnous issues that \nhave been raised llmk you for fhe oppommity to submit commenU (:ommen1 acknowledged \n316.6 Agreed with and ruppoRed scientific provisions included in the December 2003 \nwt Listing Policy. meprovisions ensured pollutants would be identified prior \nto TMDL development. Supported the fKt TMDL cannot be completed \nwithout load or wasteload allocations. unless a ooUutant is identified. Also Comment acknowledged. \nagreed 1ha1 llsl~ngs should kbasd on rumable x~rnufic nuasurcs. and \nrub~eclrve -urn should not be the sole bne of evldencc Themfore would COMMENT SUMMARY OF COMMENT RESPONSE REVISION \nlike to see the xience-based approach to impairment detaminationr restored to \nthePolicy. \n319.10 We appreciate stafTs respoasivenerr to many of the commnts we submined on \nprior iterations of the Policy. We particttlaly appreciate the changes that \nstrengthen the'weight of evidence' altmative data analpis and that add \nlanguage emphasizing that all data can and must be considexed in evaluating \nwhder a warn body is impaired. Comment acknowledged. No \n319.11 On Febw 18,2004 we submitted extensive comments outlining serious \nproblems with the initial version of the DraR Policy. While a number of Ulose \nissues have been addressed in the current version, the doe-t has significant \nremaining pmblems. In an effort to comment on thisversion as efficiently and \neffectivelv as wssible. we have chosen to omvide our comments in the fm of \nline-editsro tde haft Policy itself. The &jorremaining conems with the \nDraft Policy are specifically: The linedts to theDraft Policy havebem-tided to individually. No \n-The statistical technique used for listing waters is inappropriate. In particular. \nits application to toxicants is illegal; \n-The statistical technique used for delisting waten is not sufficiently rigorous \nand will result in numerous delistings of impaired waters and listingdelisting \nloops: \n-The 'Water Quality Limited Segments Being Addressed' section should be \neliminated, \n-The state must list waters impaired by pollution: and \n-The Draft Policy's approach to beach water quality is deficienL \n322.1 Appreciates the opportunity to provide comments regarding the July 22,2004 \ndraft of the Water Quality Control Policy for Developing California's Clean \nWater Act Section 303(d) List (haftListing Policy). Comment acknowledged. No \n322.3 The p-e of the Listing Policy is topmvide clear direction to theRegional \nBoards and the public with regard to how listing decisions aretobe made \nthroughout California. meJuly 2004 haftListing Policy falls well shon of \nthat goal. Commt acknowledged. \n- -\n322.6 Federal law and the Consolidated Assessment and Listing Methodology \nGuidance encourages states to develop monable data requirements that an \nrationally and technically sound Comment acknowledged. No \n323.1 Supports the State Water Board's goal to establish a standardized approach for \ndeveloping California's Section 3W(d) lisr The pmcess employed in \ndeveloping the 2W2 list was a vast impmvement overthe processes used in \nprevious years. Theeomnter continues to pmvide gmd support fwthe \ndevelopment of the 303(d) Listing Policy, as represented by the July 2004 draft. Comment acknowledged. No COMMENT \nNUMBER \n323.4 \n324.1 \nW \nI4 \nr n SUMMARY OF COMMENT RESPONSE REVISION \nIn pmcular, the strcngthmed b~numial dislribuuon slatistical approach is very \ngmd. However. ~nseveral impanant wayr the July 2004 drah rrpresenlr a \nweakening of the policy over that presented in p~evious venionr. We are \nconcerned lhat the cumulative effect of the revisions since the July 2004 drafl \nhas beea to imvardize the ~rior em~hasiron establishhe clear. obiective. \ntechrudy -d erilena ior lrsung and dehst~ng darrks in pkcular. the \nlmrenlng of the polncy dtmuon to the Regional Watn Boards has wdmed \nthe policy. \nThe scope of the July 2004 drah policy is overly ambitious and attempts to be Comments acknowledged \ntan many thingsto tm my stakeholders, resulting in a draft that unduly \ncomplicate the definition of a 303(d) list. The section 303(d) list is supposed \nto include: I) water aualitv-limited seements. 2) misted wllutants. and 3) a \npriority rankkg of ihewa&. ineludl& wales-targeted forh~~ develop-t \nIn thc nut two year pxicd The current drah dm not provide a mthcdalagy \nlhat meetsevea these basic criteria and yet the policy attempts to go beyond \nthem by mating more thanone category and subcategories of lists within the \n303(d) list. These categories and subcategories belong in the Stme's Clean \nWater Act section 305lb) rm. In fact. the\" are statutnilv mired under . . . , \nrecuon 305cb) To avnd these mgulaloty mswkes and the tmpend~ng \nconfusion they wll cause, thr comlcr recommnds the followtng delettons \nand additions: \n1) Remove Toxicity from the Water Quality Limited Segments rectim (2.1). \n2) Delete the 'Water Quality Limited Segments Bdng Addressed' seetion \n(2.2). \n3) Make all necessary revisions to the rest of the draft pol~cy so that all sections \nare consistent with this definition of the 303(d) list \n4) Develop a 305(b) rewldne oolicv that dovetails with the 'frontad' of the .. . -. . \n303(dl lirung policy and provides an appmpriarc regulatny hom for many of \nthe carcga!ies ad rubcalcgoner of water segmnts lhal. under lh\"current drah \n303(d) listing policy, would be inappropriately lu@ in the 303(d) lists. \n4. Adopt a version of them Water Quality Contml Policy for Addressing \nlmaired Waten Ulat dovetails with the 'backad' of the 303(d) listine pol&. .. -. . \nAgain, this policy would provide a home for some of the categories and \nsubcategories of water segments. \nSteps 3 and 4 have the added benefit of providing places for reraining the base \nof information on water semnts established during the2002 listing pms. \nWhen you are considering the listinglde-listing Policy, you should consider the Comment acknowledged. No \nAg Waiverhgram as well as Best Management Practices and Ule fuading \navailable. The Policy provides an opportunity ta delist warn hmthe 303(d) \nList. The ability to delist watcn may give people an incentive to voluntarily \nparticipate in IheAG Waiver pro-in Region 3. "
} |
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"text": "LEGISLATURE\nOF\nTHE\nSTATE\nOF\nIDAHO\nSixtieth\nLegislature\nSecond\nRegular\nSession\n\n2010\nIN\nTHE\nHOUSE\nOF\nREPRESENTATIVES\nHOUSE\nBILL\nNO.\n664\nBY\nSTATE\nAFFAIRS\nCOMMITTEE\nAN\nACT\n1\nRELATING\nTO\nTHE\nSTATE\nTREASURER;\nAMENDING\nSECTION\n671212,\nIDAHO\nCODE,\n2\nTO\nREVISE\nPROCEDURES\nREGARDING\nUNPAID\nWARRANTS.\nTO\nALLOW\nINTERFUND\n3\nTRANSFERS\nUNDER\nCERTAIN\nCIRCUMSTANCES\nAND\nFOLLOWING\nCERTAIN\n4\nREQUIREMENTS\nAND\nTO\nMAKE\nTECHNICAL\nCORRECTIONS;\nAND\nDECLARING\nAN\n5\nEMERGENCY.\n6\nBe\nIt\nEnacted\nby\nthe\nLegislature\nof\nthe\nState\nof\nIdaho:\n7\nSECTION\n1.\nThat\nSection\n671212,\nIdaho\nCode,\nbe,\nand\nthe\nsame\nis\nhereby\n8\namended\nto\nread\nas\nfollows:\n9\n671212.\nUNPAID\nWARRANTS\n\nINTEREST\n\nRECORD.\n(1)\nAll\nwarrants\nd\nr\na\nw\nn\n10\nupon\nfunds\nt\nh\ne\nb\na\nl\na\nn\nc\ne\nin\nwhich\nt\nh\ne\nb\na\nl\na\nn\nc\ne\nis\ninsufficient\nto\npay\nthem\nmust\n1\n1\nbe\nt\nu\nr\nn\ne\nd\no\nv\ne\nr\nr\ne\np\no\nr\nt\ne\nd\nto\nthe\nstate\ntreasurer\nby\nthe\nstate\ncontroller.\nAll\n12\no\nf\nsuch\nwarrants\nshall\nbe\nregistered\nby\nthe\nstate\ntreasurer\nas\nfollows:\n13\nhe\nshall\ndate\nand\nsign\ns\nu\nc\nh\nw\na\nr\nr\na\nn\nt\ns\no\nn\nt\nh\ne\nb\na\nc\nk\nt\nh\ne\nr\ne\no\nf\nu\nn\nd\ne\nr\nn\ne\na\nt\nh\nt\nh\ne\n14\nw\no\nr\nd\ns\n\"\nP\nr\ne\ns\ne\nn\nt\ne\nd\nf\no\nr\np\na\ny\nm\ne\nn\nt\na\nn\nd\nn\no\nt\np\na\ni\nd\nf\no\nr\nw\na\nn\nt\no\nf\nm\no\nn\ne\ny\ns\n\"\nt\nh\ne\nr\ne\np\no\nr\nt\nand\n15\nreturn\nthe\nsame\nto\nthe\nstate\ncontroller\nf\no\nr\nd\ne\nl\ni\nv\ne\nr\ny\nt\no\nw\nh\no\ns\nh\na\nl\nl\nn\no\nt\ni\nf\ny\nthe\n16\nrespective\npayees.\nIt\nis\nthe\nduty\nof\nthe\nstate\ntreasurer\nto\nkeep\na\nr\ne\ng\ni\ns\nt\ne\nr\n17\nr\ne\np\no\nr\nt\nof\nall\nwarrants\nnot\npaid\nfor\nwant\nof\nmoneys,\nin\nwhich\nr\ne\ng\ni\ns\nt\ne\nr\nr\ne\np\no\nr\nt\n18\nsuch\nwarrants\nshall\nbe\nlisted\nin\nnumerical\norder,\nand\nwhen\npaid\nthe\ntreasurer\n19\nshall\nnote\no\nn\ns\nu\nc\nh\nr\ne\ng\ni\ns\nt\ne\nr\nthe\namount\nof\ninterest\npaid\nand\nthe\ndate\nof\n20\npayment.\nAny\nsuch\nwarrants\n,\nregistered\nby\nthe\nstate\ntreasurer\n,\nshall\nfrom\n21\ndate\nof\nregistration\nuntil\npaid\nbear\ninterest\nat\na\nrate\nto\nbe\nfixed\nby\nthe\n22\nstate\ntreasurer.\n23\n(2)\nIn\nlieu\nof\nregistering\nwarrants\nas\nprovided\nin\nsubsection\n(1)\na\nb\no\nv\ne\n24\no\nf\nt\nh\ni\ns\ns\ne\nc\nt\ni\no\nn\n,\nthe\nstate\ntreasurer\nshall\nhave\nauthority\nto:\n25\n(a)\nPay\nsuch\nwarrants\nout\nof\nany\nmoneys\navailable\ni\nf\ni\nt\na\np\np\ne\na\nr\ns\nt\nh\na\nt\n26\nm\no\nn\ne\ny\ns\nu\nf\nf\ni\nc\ni\ne\nn\nt\nt\no\np\na\ny\ns\nu\nc\nh\nw\na\nr\nr\na\nn\nt\ns\nw\ni\nl\nl\n,\nw\ni\nt\nh\ni\nn\nt\nh\ni\nr\nt\ny\n(\n3\n0\n)\nd\na\ny\ns\nb\ne\n27\na\nv\na\ni\nl\na\nb\nl\ne\ni\nn\nt\nh\ne\nf\nu\nn\nd\n,\no\nr\na\nc\nc\no\nu\nn\nt\ni\nn\nt\nh\ne\nc\na\ns\ne\no\nf\na\nc\nc\no\nu\nn\nt\ns\ni\nn\nt\nh\ne\na\ng\ne\nn\nc\ny\n28\na\ns\ns\ne\nt\nf\nu\nn\nd\n,\nr\no\nt\na\nr\ny\nf\nu\nn\nd\n,\no\nr\na\nn\ny\no\nt\nh\ne\nr\nf\nu\nn\nd\nm\na\ni\nn\nt\na\ni\nn\ne\nd\no\nn\nt\nh\ne\na\nc\nc\no\nu\nn\nt\n29\nl\ne\nv\ne\nl\n,\nu\np\no\nn\nw\nh\ni\nc\nh\ns\nu\nc\nh\nw\na\nr\nr\na\nn\nt\ns\na\nr\ne\nd\nr\na\nw\nn\na\nl\nl\no\nw\ni\nn\ng\nt\nh\ne\nf\nu\nn\nd\nt\no\nr\ne\nm\na\ni\nn\n30\nn\ne\ng\na\nt\ni\nv\ne\nf\no\nr\nu\np\nt\no\nt\nh\ni\nr\nt\ny\n(\n3\n0\n)\nd\na\ny\ns\n;\nthe\nstate\ntreasurer\nshall\ncharge\n31\nthe\nfund\nor\naccount\nfor\nwhich\nsuch\nmoneys\nare\nadvanced\na\ns\ne\nr\nv\ni\nc\ne\nf\ne\ne\na\nn\nd\n32\nan\namount\nof\ninterest\nsubstantially\nequal\nto\nwhat\ncould\nhave\nbeen\nearned\n33\nhad\nthe\nadvanced\nmoneys\nbeen\ninvested,\nand\nthe\namount\nof\nthe\ns\ne\nr\nv\ni\nc\ne\nf\ne\ne\n34\na\nn\nd\ninterest\nshall\nconstitute\nan\nappropriation\nfrom\nthe\nfund\nor\naccount\n35\nfor\nwhich\nthe\nadvancement\nwas\nmade\n;\no\nr\n.\nI\nf\nm\no\nn\ne\ny\ns\na\nr\ne\nn\no\nt\ns\nu\nf\nf\ni\nc\ni\ne\nn\nt\n36\ni\nn\nt\nh\ne\nf\nu\nn\nd\na\nf\nt\ne\nr\nt\nh\ni\nr\nt\ny\n(\n3\n0\n)\nd\na\ny\ns\n,\nu\nn\nl\ne\ns\ns\no\nt\nh\ne\nr\nw\ni\ns\ne\ne\nx\nc\ne\np\nt\ne\nd\nb\ny\nl\na\nw\n,\n37\nt\nh\ne\ns\nt\na\nt\ne\nt\nr\ne\na\ns\nu\nr\ne\nr\ns\nh\na\nl\nl\nm\na\nk\ne\ni\nn\nt\ne\nr\n\nf\nu\nn\nd\nt\nr\na\nn\ns\nf\ne\nr\ns\ns\nu\nb\nj\ne\nc\nt\nt\no\nt\nh\ne\n38\nf\no\nl\nl\no\nw\ni\nn\ng\nr\ne\nq\nu\ni\nr\ne\nm\ne\nn\nt\ns\n:\n39\n(\ni\n)\nA\nl\nl\nt\nr\na\nn\ns\nf\ne\nr\ns\ns\nh\na\nl\nl\nb\ne\ni\nd\ne\nn\nt\ni\nf\ni\ne\nd\nb\ny\n:\na\nv\na\ni\nl\na\nb\nl\ne\nf\nu\nn\nd\ns\n40\nf\nr\no\nm\nw\nh\ni\nc\nh\nm\no\nn\ne\ny\ns\na\nr\ne\nb\no\nr\nr\no\nw\ne\nd\n,\nt\nh\ne\nf\nu\nn\nd\nt\no\nw\nh\ni\nc\nh\nt\nh\ne\nm\no\nn\ne\ny\ns\na\nr\ne\n41\nt\nr\na\nn\ns\nf\ne\nr\nr\ne\nd\n,\na\nm\no\nu\nn\nt\no\nf\nt\nr\na\nn\ns\nf\ne\nr\n,\nt\nh\ne\na\nn\nt\ni\nc\ni\np\na\nt\ne\nd\ni\nn\nt\ne\nr\ne\ns\nt\nr\na\nt\ne\n42\n 2\nc\no\nn\ns\ni\ns\nt\ne\nn\nt\nw\ni\nt\nh\nt\nh\ne\na\nv\na\ni\nl\na\nb\nl\ne\nf\nu\nn\nd\ns\n’\nc\nu\nr\nr\ne\nn\nt\nr\na\nt\ne\no\nf\nr\ne\nt\nu\nr\nn\n,\ni\nf\n1\na\np\np\nl\ni\nc\na\nb\nl\ne\n,\nt\nh\ne\na\nn\nt\ni\nc\ni\np\na\nt\ne\nd\nr\ne\np\na\ny\nm\ne\nn\nt\nd\na\nt\ne\na\nn\nd\nt\nh\ne\nr\ne\na\ns\no\nn\nf\no\nr\nt\nh\ne\n2\nt\nr\na\nn\ns\nf\ne\nr\n;\n3\n(\ni\ni\n)\nI\nn\nt\ne\nr\ne\ns\nt\n,\ni\nf\na\np\np\nl\ni\nc\na\nb\nl\ne\n,\ns\nh\na\nl\nl\nb\ne\np\na\ni\nd\no\nn\na\nn\ny\nt\nr\na\nn\ns\nf\ne\nr\n,\nw\nh\ne\nr\ne\n4\nr\ne\nq\nu\ni\nr\ne\nd\nb\ny\nl\na\nw\n,\nu\nn\nd\ne\nr\nt\nh\ni\ns\np\nr\no\nv\ni\ns\ni\no\nn\n;\n5\n(\ni\ni\ni\n)\nT\nh\ne\nt\nr\ne\na\ns\nu\nr\ne\nr\ns\nh\na\nl\nl\nm\na\ni\nn\nt\na\ni\nn\na\nn\na\nn\nn\nu\na\nl\nr\ne\np\no\nr\nt\no\nf\na\nl\nl\ns\nu\nc\nh\n6\ni\nn\nt\ne\nr\n\nf\nu\nn\nd\nt\nr\na\nn\ns\nf\ne\nr\ns\n.\n7\n(b)\nIssue\ntax\nanticipation\nnotes\nas\nprovided\nby\nchapter\n32,\ntitle\n63,\nor\n8\nsection\n571112,\nIdaho\nCode.\n9\nSECTION\n2.\nAn\nemergency\nexisting\ntherefor,\nwhich\nemergency\nis\nhereby\n10\ndeclared\nto\nexist,\nthis\nact\nshall\nbe\nin\nfull\nforce\nand\neffect\non\nand\nafter\nits\n1\n1\npassage\nand\napproval.\n12\n"
} |
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"text": "DOCUMENT RESUMEED 194 173 JC 800 612AUTHORTITLEINSTITUTIONSPONS AGENCYPUB DATENOTE!DES PRICEDESCRIPTORSBaenziger, BettyPersonal Achievement Mathematics: Data Processing.Kirkwood Community Coll., Cedar Rapids, Iowa.Fund for the Improvement of Postsecondary Education(DHEW1, Washington, D.C.7733p.MF01/PCO2 Plus Postage.Addition; Algebra; Charts: *College Mathematics;Community Colleges; *Data Processing; Division;Fractions: *Mathematical Applications; *MathematicalConcepts; Measurement; Multiplication; NumberSystems: *Problem Sets: Problem Solving; Ratios(Mathematics): StatistiCs; Subtraction; Two YearColleges; Whole Numbers; WorkbooksABSTRACTUtilizing word problems relevant to the dataprocessing field, this workbook presents a concept-oriented approachto competency development in ten areas of basic mathematics: (1) theexpression cf numbers as figures and words; (2) the multiplication,addition, and division of whole numbers, fractions, and decimals: (3) ratios and proportions; (4) percents:(5) number systems; (6)measurement; (7)introductory algebra; (8)problem-solving; (9) statistics: and (10) illustrative aids such asgraphs, charts, andtables. For each competency area, the workbook presents a series ofword problems designed to reinforce student learning and todemonstrate the applicability of the concept to the data processingwork environment. An answer key for the exercises is appended.(JP)\n***********************************************************************Reproductions supplied by EDRS ate the best that can be madefrom the original document. ***********************************************************************\n PERSONAL ACHIEVEMENT\nMATHEMATICS\nData Processing\nProduced byBetty Baenziger\nKirkwood Community CollegeCedar Rapids, Iowa\nFund for the Improvement of Postsecondary Education\nU.S. DEPARTMENT OF HEALTH,EDUCATION & WELFARENATIONAL INSTITUTE OFEDUCATIONTHIS DOCUMENT HAS BEEN REPRO-DUCED EXACTLY AS RECEIVED FROMTHE PERSON DR ORGANIZATION ORIGIN-ATING IT. POINTS OF VIEW OR OPINIONSSTATED DO NOT NECESSARILY REPRE-SENT OFFICIAL NATIONAI ,NSTITUTE OFEDUCATION POSITION OR POLICY\n2\"PERMISSION TO REPRODUCE THISMATERIAL HAS BEEN GRANTED BYJean Goodnow.\nTOTHE EDUCATIONAL P.ESOURCESINFORMATION CENTER (ERIC).\"\n loRkw000 community college\n6301 Kirkwood Blvd. S.W.P.O. Box 2068Cedar Rapids, Iowa 52406\nCURRICULUMMATERIALSDEVELOPED\nUNDER THE AUSPICES OFMr TO IMPROVE POST SECONDARY EDUCATION\nPrepared, ByBetty BaenzigerMathematicsCurriculum Developer1977\n The problems found in this booklet are notmeant to instruct you in the field of DataProcessing.They are practices of the variousmathematical concepts and are content orientedto help show the practicality of each concept.Study each mathematical competency in thegeneral learning packets before attemptingthese applied problems.\nThis is your raster copy. You are encouragedto duplicate it for use with your students.You may not duplicate this material for corn-nercial,use, profit, or use outside your in-stitution.\n4\n INTEREST AREACONTENTSDATA PROCESSING\nNUMERATIONWHOLE NUMBERSADDITION AND SUBTRACTIONMULTIPLICATIONDIVISIONFRACTIONSADDITION AND SUBTRACTIONMULTIPLICATIONDIVISIONDECIMALSINTRODUCTIONADDITION AND SUBTRACTIONMULTIPLICATIONDIVISIONRATIO AND PROPORTIONPERCENTNUMBER SYSTEMSMEASUkEMENTINTRODUCTION TO ALGEBRAPROBLEM SOLVINGGRAPHS, CHARTS, AND TABLESSTATISTICS\n Numeration\n1.In the data processing lingo, K stands for approximately1300 (actually 1024). Thus, a 64K has approximatelymemory units.\n2.A data processing machine can do one million twohundred thousand operations per second. Expressin numeric form.\n3.The ValComp Company recently had a theft of eightmillion seven hundred thousand dollars worth ofcircuit boards and computer memories. Express innumeric notation.\n4.Graphnet Systems is a data communications networkwhich has $3,300,000 in equipment. Express in words.\n5.Applied Data Research had a net income of $375,000in 1976 on a revenue of $3,9000,000,000. Expressthe numbers in words.\n6.Applied Data Research in 1975 had a gross income oftwo billion nine hundred million dollars and a netprofit of ninety seven thousand seven hundred andthirty four dollars. Express in numeric form.\n6\n Addition&Subtraction\n1.Software systems for computers are sold by the manu-facturers of the computers. If you had a DEC systemand wished to provide COBOL ($7,000), DOS ($1,700),SORT ($3,130), APL ($1,500), and BASIC ($750), foryour users, how much would all of these systemscost?\n2.A 36 inch digital plotter sells for $7,600 withadditional options of a 12 inch paper handling drum($900), a paper take-up spool ($300), a plexiglasscover ($450), and a paper tear-off bar ($125). Thetotal cost of the plotter with all its options wouldbe\n3.There are 80 columns on an IBM card. If 5 columnsare used for statement numbers, 1 column for a con-tinuation symbol, 72 columns for program statements,how many columns are left unused?\n4.A computer system had a fast core memory of 494K(actually 494304 bytes), slow core memory 1500K(actually 1,482,912 bytes), and a disk pack with2,916,600 bytes of storage. What is the totalmemory storage (in bytes) of the system?\n5.A typical line printer can print 132 charactersacross the page. If yOu have a title which is 49characters long and wish to center it in the page,how many spaces should be allowed before beginningthe title?\n Multiplication\n1.A new IBM data processing system, model #278, isproposed to rent for $85K/month. The yearly rentalcost would be\n2.A video terminal display will show 24 lines with80 characters per line. The total number ofcharacters which can be displayed at one timeis\n3.United Airlines sells computing time on its IBM360-195 for 57t per second. How much would itcost per hour?\n4.A Kodak K0M-85 microfilmer can microfilm 24,000pages per hour. How many pages can it do in aneight-hour day?\n5.A computing system had auxiliary memory stores con-sisting of 8 disk packs, each disk pack having 200cylinders of 20 tracks, each track holding 7,294bytes of 8 bits. What is the total number of bitsin the memory store?\n6.A computer scores one hundred fifth answers fromeach of 3000 examination papers in a very shorttimeHow many total answers were scored?\n8\n Division\n1.In a study of data terminal systems, 250 companiesused 1771 terminals. What is the average number ofterminals per company (round to the nearest wholenumber)?\n2.If a computer system rents for $300/hour, how muchis the cost per second?\n3.If you rented an IBM 278 for $85K/month, how muchwould you have to charge customers for its use foreach hour of its time? (Assume 425 hours of useeach month.)\n4.If a line printer can print 1285 lines per minute,how long will it take to print 24,700 lines?\n5.If the line printer prints 61 lines/page, and 1285lines per minute, approximately how many pages canit print per minute?\n Fractions,+-\n1.In creating new software programs and maintainingthe programs after creation,\nt-1of the time is spent1' on designing the program, is spent on testing theprogram, and 1-I is spent on coding. The remainder 6of the time is spent on maintenance. The fractionof the time spent on maintenance is4INIMNw\n2.In recording on magnetic tape, the total tape spaceutilized depends on the recording density, the lengthof the record, and the inter-record gap. A recordof 1000 bytes, recorded at a density of 800 bytes per1 inch would take 1-ETinch.The inter-record gap is2 inch,so the total space required for a 1000 byte 4record is inches.\n3.The standard print spacing is 10 characters per inch.132 characters takes up 13]inch.The paper width,51 between guideline sprocket holes is 17 -13-inch.Theamount of margin space left (total) is inches.\n10\n 4.Using a print train which prints 12 characters perinch, a title is to be centered on thesis paper forms1which is 8 y inches wide (neglecting the tear-offsprocke.ted guide strips). If the title is 32characters long, how many inches from the left handmargin should the title begin?\n5.Fraction decimal numbers are expressed in hexadecimal1 eetc.A form as so many Tes, -- 1s256''4,...,'.,ut.s...n,uvohexadecimal fraction 0.9999 is equivalent to 73- +\n256 ++ 65,536Add the fractions to obtain4776the number equivalent.\n6.The model 82 card sort will sort a card in 111ofa second where as the model 83 will sort a card in\nT6of a second.What is the differenc- in thesetwo sorting times?\n MultiplyingFractions\n1.A record of 2000 bytes recorded at 800 bpi (bytesper inch) will occupy 31inches on the magnetictape (including 1 inch for the inter-record gap).4How much space will 800 records of 2000 bytes occupy?\n1 3-8 2.An IBM card is 3 -4- inches by 7inches.What isthe area of the card in square inches?\n13.If-4- desk pack has a capacity of 7 million characters,what is the capacity of 6 disk packs?\n4.A tape transport can move tape 1 inch in of asecond when it is up to writing speed. If the trans-port writes 800 bytes per inch, so that each byte\ntakes800of an inch, what is the length of timeneeded to write each byte? Express your answer bothas a fractionand as a decimal number.\n5.An advertisement claims that a programming language,MARK IV, requires of the program statements of COBOL.CCPIN.: in turn, requires only2271- of thestatements of1' FORTRAN, which requires onlyof the statements of BASIC.What fraction of statements of BASIC does MARK IV require?1 2\n DividingFractions\n1.A record of 2.000 bytes recorded at 800 bpi (bytes1 3 per inch) will require 3 4inches (including --if inchesfor the inter-record gap) on magnetic tape. Howmany records can be put on a 2400 foot tape?\n2.If 22-million characters of disk storage cost1X collars per month, how much is the cost per2character?\n3i 3.If a character on a video display takes wnchesin width, how many characters can be put in a lineon a 12 inch video tube?\n4.A typical video display character can be consideredas a dot matrix which is 10 x 15 dots in dimension.The character itself occupies a 5 x 7 grid, leavingthe rest of the matrix for spacing. If the character3width is To- of an inch, how many dots are there perinch across the screen?\n5.Using the data from problem #4, what is the number oflines per inch down the video tube? (NOTE:The\n-23 depth of the character is the width.)13_\n IntroductionTo Decimals\n1.In a computer a basic operation can be done in a\"nano second\" or one billionth of a second. Writethat number in decimal form.\n2.The basic clock rate of a microcomputer is 4megahertz (4 x 10 cycles per second).. If a basicoperation takes 8 clock cycles, what fraction of asecond does the operation take? Write the answerin decimal form.\n3.A card reader reads 600 cards/minute, so that the\n1 time per card is 600th ofa minute.Express indecimal form.\n4.A wire matrix printer can print up to 1000 lines perminute.Express the length of time to print a linein decimal form.\n5.In a magnetic tape unit, the tape moves at speeds upto 24 inches per second. Express the length movedin one second in decimal form.14\n i ion&SubtractionDecimals\n1.The average time between the billing date of an oilcompany credit office and the postmark on the bill is3.65 days.The average time lag between the post-mark date and the date the bill is received is 8.35days.The total average time between billing by theoil company and receipt of the bill by the customeris\n2.In a microprocessor with a cycle time of 0.5 micro-seconds, operations take 2 to 7 cycles for completion.If a series of operations takes 1.0, 2.5, 2.0, 1.5,and 3.5 microseconds for completion, the total timerequired is\n3.In conversion of hexadecimal fractions to decimalfractions, 0.1 (H) in hexadecimal = 0.0625 (D)0.2 (H)0.3 (H)0.4 (H)= 0.125 (D)= 0.1875 (0)= 0.250 (D), etc.Thus, 0.5 (H) = 0.1 (H) + 0.4 (H) = 0.062 (D) +0.250 (D) =\n 14.The hexadecimal fraction 0.01(H) =2560.0039065;20.02(H) = ,0.0078125;2560.03(H) 0.1171875;=2-2564_0.04(H) =2560.015625.The hexadecimal number 0.i4(H) = 0.0625 + 0.015625 =\nThe hexadecimal number 0.99(H) = 0.4(H) + 0.4(H)0.1(H)+ 0.04(H) + 0.04(H) + 0.01(H) =0.250 + 0.250 + 0.0625 0.015625 + 0.015625 +0.00390625 =\n5.A record on magnetic tape consists of the bit patterof the record itself recorded at 800 bpi (bytes perinch) plus a longitudinal check sum with a gap of0.012 inches, a cyclic redundancy check character ata gap of 0.00125 inches and an inter-record gap of0.625 inches.A record of 1200 bytes thus requires1.500 inches + 0.012 inches + 0.00125 inches +0.625 inches +\n MultiplyingDecimals\n1.A decimal fraction can be converted to a hexadecimalfraction by repeated multiplication by 16, clearingoff the integer portion as the first hexadecimalcharacter, multiplying the remaining fraction againby 16 to get the second hexadecimal character, etc.An example:The decimal fraction 0.25..25 x 16 = 4.0 ====0.4(H)The decimal fraction 0.1\n.1x 16=1.6====>s0.1(H).6 x 16=9.6===#0.19(H).6 x 16=9.6====>.0.199(H)A.Convert the decimal fraction 0.4375 to hexa-decimal.\nB.Convert the decimal fraction 0.01 to hexadecimal.\n2.A record of 1200 bytes recorded on 800 bpi magnetictape takes 0.1786 feet. How many feet do 540 recordstake?\n3.If a byte of memory costs $0.02, how much do 2.5 x106bytes of memory cost?\n1 711\n 4.In recording data on IBM cards, 80 bytes can bestored on 3.25\" x 7.375\". The area of the cardis .The area per byte is 8a of thisvalue.Find the area per byte.\n5.On punched paper tape, punches are located 0.1\"apart and 8 punches (one byte) are placed across a1\" paper tape. How much area do 80 bytes take onpaper tape?\n6.Many high speed computer memories have transfertimes of 275 nanoseconds (one billionth of a second).How long would it take to transfer 120 pieces ofinformation?Express in decimal form.\n rDividingL Decimals\n1.The cost of a reel of magnetic tape for use with com-puters is about $15 for a 2400 foot reel. What isthe cost of magnetic paper per foot?\n2.A disk storage device provides 2.5'x 10 6charactersof storage.If it rents for $516/month, how muchdoes one character of memory storage cost per month?\n3.A microprocessor memory board costs $90 for 4.096 x103bytes of memory. What is the cost per byte?\n4.If a character takes 0.15\" in width on a video dis-play, how many characters can be displayed on an11\" width video screen?\n5.The Series/1 mini-computer from IBM has an averageinstruction execute time of 310 x 10 -6seconds formodel 5.How many instructions can it do per second?\n RatioandProportion\n1.Computer Power, Inc., a data processing service,handles work for banks totalling 1,250,000mortgages and loans valued at 24 billion dollars.What is the average value of a loan?\n2.If a computeran do 230,000 instructions persecond, how many can it do per minute?\n3.If a 300' reel of magi. `ic tape can hold 1300records of 1600 bytes ea:.' corresponding to 26,000IBM card images, how many card images can be put ona 2400' magnetic tape using the same recording format?\n4.There are 7294 bytes per track on an IBM 2314 diskunit.How many bytes are there in 400 tracks?\n5.An IBM card of 24 square inches can hold 80 bytesof information. An 8 channel punched paper tapecan hold 10 bytes per square inch. How many feetof paper tape are required to hold the informationof a box (2000) of IBM cards?\n20\n Percent\n1.In 1976 John Hancock Insurance Company, through the use of a network of 550 terminals called Hanstar, handled an increase of 18% in data transactions, more than a quarter of a million transactions, without increased staff or transaction time. What was the total number of transactions handled per year?\n2.With an old form of data base, the centralprocessor unit was involved 100% of its time while retrieving data.Using a randomaccess management informationsystem, the CPU time was reduced so that it was in-volved only 28% of the time. By how much was the CPU time reduced?\n3.A communications satellite network system had a per station cost of $3,000,000 in 1965, but in 1976, the per station cost was $37,000.What percent is the 1976 cost of that in 1965?\n4.A study of the clients of a billing agency showedthat while 20% of them had a legitimate reason tocomplain, only 1% of the clients did so.Whatpercentage of the clients who had reason to complain did not write letters?\n.A department store billing office had an average time lag of 7.12 days between the billing date and the post- mark date.The average time lag between postmark andthe date received was 10.53 days. What percent of thetime between billing and the receipt of the bill was due to delays in the billing office?\n Measurement\n1.Currently, magnetic tape reels are sized in feet, i.e.,300', 1200', and 2400' reels. What is the length ofeach of these reels in meters?\n2.An IBM card is 3.25\" x 7.375\". What are itsdimensions in centimeters?\n3.The typical running speed of a magnetic tape trans-port is 24\" per second. What is its speed incentimeters/second?\n4.Aline printer prints 10 characters per inchhorizontally and 6 lines per inch vertically.What are the dimensions (in centimeters) for 131characters across the page?\n5.If the recording density on magnetic tape is.1600 bytes per inch, how many bytes is this percentimeter?\n IntroductionTo Algebra\n1.The amount when the interest and the principal iscompounded annually is:A = P(1 + .Solve for the principal (P).\n2.At simple interest, the amount after n years isthe principal multiplied by the quantity: one plusthe number of years times the interest rate. Expressas an algebraic expression.\n3.For efficient evaluation of a polynomial, theoperations can be nested as follows:y=(Ex + D)x +Cx +B x+ AExpand this expression to show the form of thepolynomial.\n4.The volume of a cylindrical tank with hemisphericalends can be expressed in terms of the diameter.ofthe tank and the length of the cylindrical portion.The volume is equal to the quantity: the lengthplus 3 the diameter multiplied by pi times thediameter squared divided by 4. Express in algebraicform.\n 1.The Shugart mini-floppy disk has 110K byte storageand a data transfer rate of 125K bits per second.How long would it take to transfer all of theinformation on a floppy disk at this data transferrate?(1 byte = 8 bits; K = 1000).\n2.In storing information on magnetic tape, 800 bytescan be stored per inch.3,,is required betweenstorage records for start and stop of the tape unit.If a record contains 800 bytes, how many bytes canbe stored in 10 feet of tape?\n3.An IBM 2314 disk has 400 tracks which can hold 7294bytes per track. In backing up a disk on magnetictape, the entire disk contents are to be storedon magnetic tape at 1600 bpi (bytes per inch) withthe records blocked at 7294 bytes. The inter-record\"5gap is8How many feet of tape are required forthis backup?\n24\n 4.In evaluating a polynomial with terms up to the 4thpower in the variable requires loading 2 registers,4 multiply operations, and 4 addition operations.If loading a register requires 1.5 microseconds, anaddition requires 4.1 microseconds, and a multi-plication requires 4.3 microseconds, what is thetotal time to evaluate the polynomial?\n5.What is the most economical way to store data:IBM cards at 80 bytes per card, 1000 cards/$1.00;paper tape, 8 bytes per inch, 1000' roll @ $1.28/roll; magnetic tape, 800 bytes per inch, 2400'reel @ $15.00/reel.\n rS toand Base\n1.A decimal integer number can be converted to any basenumber by repeated dividing by the base number, keepingthe remainders in order from the least significant tothe most significant digit.\nExample:100(D) =?in hexadecimal\n100 + 16 =6, remainder 46 + 16=0, remainder 6\n100(D)= 64(H)\nA.Express 1000(D) in hexadecimal.\nExample:500(D) +? in octal\n500+8=62,remainder 462+8=7,remainder 67+8=0,remainder 7\n500(D)=764(octal)\nB.Express 4095(0) in octal.26\n 2.A decimal fraction can be converted to any base numberfraction by repeated multiplication by the base number.The integers formed are kept in order as the mostsignificant to the least significant. The fractionremaining is multiplied by the base.Example:Express 0.3(D) in hexadecimal.\n0.3x16 =4.80.8x16 = 12.80.8x16 = 12.8 ,etc.(Hexadecimal numbers: 0, 1, 2, 3, 4, 5, 6, 7, 8,9,,A, B, C, D, E, F)\nA.Express 0.01(D) in hexadecimal.\nExample:Express 0.432(0) in octal.0.432 x 8=3.4560.456 x 8=3.6180.618 x 8=4.9440.944 x 8=7.5520.552 x 8=4.416OR0.432(D) = 0.33474 (octal).\nB.Express 0.203125(D) in octal.\n 3.Using problems #1 and #2, express pi = 3.1416 in(a)hexadecimal\n(b)in octal\n4.In the ABEND dump of a computer run, the startingmemory location of the program was at 38778(H).The program status work at ABEND was 46760(H). Findthe relative location in the program at which theABEND occurred.\n5.In conversion from a hexadecimal or octal numberto a decimal number, the same operations are per-formed as in problems #1 and #2, i.e., repeateddividing by the new base (or repeated multiplicationby the new base).Example:Convert 4CA3(H) to decimal4CA3A= 7A9, remainder 97A9 + A=01, remainder 4Cl + A13, remainder 313 + A=1, remainder 91 + A=0, remainder 1OR4CA3(H)=19349(D)A.Convert F1F(H) to decimal.28\n Graphs\n1.A speaker on software indicated that the con-ventional distribution of time shown at the rightwas incorrect: that it should be design, 12%;Code 6%; Test 12%; and Maintenance, 70%. Drawa new circle graph to show the correct relation-ships.\n2.From the table below, what is the largest capacityof a drum memory?\nMEMORY CAPABILITIES111=10217=1MHHODTRANsFER RATEIrnillion bpi,CAPACITYNWAVERAGE ACCESSTIME(milliseconds)COST/BITIC)\nDrumDiti anddi-cpockLOWHIGHl( 1WHIGHLOWHIGHLOW'UGH\n1.6I12.57.716660096604.273.820.0339.20.060.011.6051.48\nSOURCE: W. Sharpe the Et on 'mu, r1 Computers (New York: Columbia university Pr .ss,39691. pp 402. 514.\n297R\n 3.The adoption of IBM's MVS (multiple virtual storage)system by John Hancock Mutual Life Insurance Companyin 1976 gave the results shown in the bar graphbelow:\nHow much time reduction occurred in making policyreinstatements?\nCustomer Service Improvement\nMay 1976 ISept. 1976 V////1\nAddress Changes:TrEDZIll=111:=10\nReinstatements://////////////////7if\nHome Office Loans:days1 days\nidays//////////1_ 44\n12345678910\n30\n 4.In a technology forecast made in 1975, thefollowing predictions were made for data trans-mission costs:\nWhat is the predicted cost of transmission at 2400 bps in 1980?\n17.0\n10.0\n6.0\n2.0\n1.0111s1975 1980 1985\n %aerationDATA PROCESSINGANSWER, KEY\nMultiplying fractions\n1.2.3.4.\nS.\n6.64,000 memory units1,200,000 operations/second$8,700,000three million, three hundred thousanddollars in equipmentthree hundred seventy-five thousanddollarsERROR:in writing the numeral$2,900,000,000 income$97,734 profit1.2.\n3.\n4.S.2600\"\n6.714=431 million characters1sec. =.00005 sec.200001\nAddition F, Subtraction Dividing Fractions\n1.about 8861 records1.$14,0802.$9,375 2.1dollars/character3.2 columns unused 5,000,0004.4,893,816 bytes 3.80 charactersS.41 spaces 4.333 dots/inchMultiplication 5.Tr56lines per in.\n1.2.$1,020,000/year1920 charactersIntroduction to Decimals\n3.$2052 1.0.000000001 seconds4.192,000 pages 2.IR: (4 x 100 cycles per second)S.1,867,264,000 0.000002 seconds6.ERROR:fifty not fifth 3.0.001450,000 answers 4.0.001 min/line5.24.0 inches/secondDivisionAdditionSubtraction Decimals1.7 terminals/company2.8.3S/second3.$2004.19 minutesS.about 21 pagesFractions + -1.12 days2.10.5 micro seconds3.0.3125 (D)4.0.078125 (D)0.59765625 (D)5.2.13825 inchesMultiplying_ Decimals 1.\n2.\n3.\n4.5.\n6.117 spent on maintenanceERROR:11 1,notfluIf\n393216333651716- of a second2 in. 1.2.3.4.5.6.Dividing.028F5C96.444 ft.$50,0000.2996 sq. in./byte8 sq. in.0.000033 secondsDecimals\n1.2.$0.00625/ft.$.0002064/characters32\n 3. $0.02197/byte4.73 charactersS.3225 instructions/secondRatio & Proortion\n1.$19,2002.13,800,000 instructions/second3.208,000 images4.2,917,600 bytesS.NOTE:8 channel tape is 1\" wide1333.ft.Percent\n1.1,388,889 transactions2.72%3,1.2314.95%S.40.3%Measurement\n1.91 meters; 366 meters; 732 meters6.26 an x 18.73 an3.60.9 cm/sec.4.33.27 anS.630 bytes /anIntroduction toMeta\n1.P = A (1 +2.A = P(1 + nr)3.E R R O R y =( p l c +,D) x + C) x + B) x + Ay = Ex4 + DX + CX4 + BX +A4. V= ((L4.d) T:12)44Problem Solving\n1.7.04 seconds2.55,200 bytes3.173'4.36.6 micro secondsS.magnetic tapeNumbers, Systems and BasesAll \"+\" signs should be \".\" except in example\n1.A.3 a 8 B.7777 (octal)2.A.0.0(H)B.0.15 (octal)A.3.243FE5C9 (H) B.3.11037745 (octal)FFE8 (H)A.38712 500Graphs1.\n2.600 million bits3.4 days4.Impossible.Graph notlabeled\n(D) \"+\"\n33shouldbe \"=\"sign.\nUNIVERSITY OF CALIFORNIACLEAMICE1017SE roaMINnnnoit com.sc.ssrOVVELL LIERAILy BUILDWOLOS 144110.12, CALIFOUNIA 90014DEC5 1980\n"
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] | {
"pdf_file": "OAAZZPSDEIQQH4F3ND5HZDC7MTB4GXXU.pdf",
"text": " The Commonwealth of Massachusetts \nExecutive Office of Environmental Affairs \n100 Cambridge Street, Suite 900 \nBoston, MA 02114-2119 \n \nMitt Romney \nGOVERNOR \n \nKerry Healey \nLIEUTENANT GOVERNOR \n \nStephen R. Pritchard \nSECRETARY \n Tel: (617) 626-1000 \nFax: (617) 626-1181 \nhttp://www.mass.gov/envir \n \nTRAFFIC ADVISORY \n \nFor Immediate Release Contact: Vanessa Gulati \nMarch 31, 2006 (617) 626-1119 \n \n \n \nLANE CLOSURES OUTBOUND AND INBOUND ON BOWKER OVERPASS \n \nWHAT: The Department of Conservation and Recreation (DCR) will be performing repair work \non the Bowker Overpass on Storrow Drive. During the repair process lanes will be \nreduced going outbound and inbound. \n \nWHEN: Sunday April 2, 2006 through Friday April, 7, 2006 \n 8:00 P.M – 4:00 A.M. \n \n \n \nWHERE: Bowker Overpass, Storrow Drive at the Fenway Exit over Commonwealth Ave. Boston, \nMA \n \n \n \n \n### \n "
} |
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"pdf_file": "CTMYRF75O3COU6UV5KWIFEF6TLJF4REJ.pdf",
"text": "OFFICE OF THRIFT SUPERVISION \nApproval of an Application to Acquire Assets and Assume Liabilities \nI \nOrder No: 2000-25 \nDate: February 29, 2000 \nSovereign Bank, Wyomissing, Pennsylvania (“Sovereign”), has applied to the \nOffice of Thrift Supervision (“OTS”), under $+’ LItiti ion 18(c) of the Federal Deposit \nInsurance Act (“FDIA”), 12 U.S.C. $ 1828(c), and 12 CFR 9 563.22 to acquire certain \nassets and liabilities from: Fleet National Bank, Providence, Rhode Island; Fleet Bank- \nNH, Manchester, New Hampshire; and Bar&Boston, N.A., Boston, Massachusetts. \n(Collectively, the “Application”). \nThe proposed transaction will be consummated in accordance with the Amended \nand Restated Purchase and Assumption Agreement By and Among Fleet Boston \nCorporation, Fleet National Bank, Fleet Bank-NH, Bar&Boston, N.A., Sovereign Bank \nand Sovereign Bancorp, Inc. dated February 28,200O (herein the “Agreement”). \nThe OTS has considered the factors set forth in 12 U.S.C. $ 1828(c), and 12 C.F.R. \n9 563.22(a) and other applicable statutes and regulations. The OTS also has considered \nthe Application under the Community Reinvestment Act (the “CILA”), 12 U.S.C. 9 2901 \net seq., and the OTS regulations thereunder, 12 C.F.R. Part 563e. In addition, the OTS \nhas considered a digest from the Northeast Regional Office and a legal opinion from the \nRegional Counsel (collectively, the “Staff Memoranda”). \nAccordingly, the Application is hereby approved, subject to the following \nconditions: \n1. \n2. \n3. Each Closing (as defined in the Agreement) shall be consummated in accordance \nwith the Agreement, the Application, all applicable laws and regulations and this \nOrder, not less than fifteen nor more than 180 calendar days after the date of this \nOrder, unless the Northeast Regional Director (“Regional Director”) or his designee \ngrants an extension of the 180 calendar day period for good cause; \nPrior to the date of each Closing, Sovereign shall: (a) receive all required regulatory \napprovals and submit satisfactory evidence of those approvals to and (b) promptly \nnotifl the Regional Director of any action by any governmental entity that may \nimpact on the ability of Sovereign to consummate the proposed transaction; \nSovereign shall: \n(a) not proceed with any scheduled Closing if, after giving effect to such Closing, it \nwould be less than “Well Capitalized” as that term is defined in 12 CFR Part 565; \nand Order No: 2000-25 \nPage No: 2 \n4. \n5. \n6. \n7. \n8. (b) at all times after such Closing maintain: \n(i) “Well Capitalized!’ status; and \n(ii) “Tier 1 Leverage” (“Leverage”) and “Risk Based Capital” ratios that \nequal or exceed the ratios set forth in the schedules entitled “Capital Ratios \nAnalysis” as submitted to the OTS on February 8,200O (the “Capital \nSchedules”); \nAt each Closing date, and at each quarter thereafter, Sovereign Bancorp, Inc. \n(“Bancorp”) shall maintain its “Tier 1 Leverage” ratios at levels that equal or exceed \nthe levels set forth on the Capital Schedules. For purposes of this Condition 4, such \ncomputations shall be made in accordance with the definition of “Sovereign \nLeverage Ratio” contained in the Agreement; \nNeither Sovereign nor Bancorp shall make any payment related to the “Deferred \nContingent Amount” (as defined in the Agreement), except in accordance with \nSection 3.6 of the Agreement. Any discretionary payment of the Deferred \nContingent Amount that is not contractually required, but is permitted by Section \n3.6(f) of the Agreement, shall require 15 days advance notice to and written non- \nobjection by the Regional Director; \nOn the business day prior to each Closing, the Chief Executive Officer of Sovereign \nand Bancorp shall certify in writing to Regional Director that no material adverse \nevents or material adverse changes have occurred with respect to the financial \ncondition or operations of the respective entities since the last date of the financial \nstatements submitted with the Application; \nBancorp shall not make any voluntary principal payments on any debt issued to \nsupport the proposed transaction that would leave less than $240 million in liquid \nassets available at Bancorp to make scheduled principal payments on any debt \nwithout: (a) providing 30 days advance notice to the Regional Director and (b) \nreceiving written non-objection of the Regional Director. This condition shall expire \non June 30, 2001, unless extended by the Regional Director; \nNo later than five calendar days after the date of each Closing, Sovereign and \nBancorp shall file with the Regional Director a certification of legal counsel stating \nthe effective date of the Closings and that the Closings: (a) have been consummated \nin accordance with the provisions of the Agreement, all applicable laws and \nregulations, the Application, and this Order and (b) Sovereign’s and Bancorp’s \nactions toward effecting such Closings have not triggered a default under the terms \nof anv outstanding debt instruments: Order No: 2000-25 \nPage No: 3 \n9. No later than 30 days after the date of each Closing, Sovereign shall submit to \nRegional Director: (a) a detailed description of the accounting treatment and entries \nmade to effect the Closing, (b) a statement that the Closing has been consummated \nconsistently with the pro forma statements of condition and the description of \nproposed accounting treatment set forth in the Application and (c) an opinion from \nBancorp’s independent auditor stating that the accounting for the Closing is \nappropriate under GAAP; \n10. Sovereign shall advise each accountholder whose withdrawable accounts in \nSovereign would increase above $100,000 as a result of the proposed transaction of \nthe effect of the Transaction on insurance coverage no later than 30 calendar days \nafter the date of the Closing that causes such accountholder’s withdrawable accounts \nto exceed $100,000. Please submit a copy of the proposed accountholder notice to \nthe Regional Director; \n11. No later than 45 days prior to the last Closing, Sovereign must deliver: \n(a) executed definitive agreements for the proposed sale-leaseback and branch sale \ntransactions described in the Application in a manner acceptable to the Regional \nDirector; or \n(b) commitments for such other transactions which provide Tier 1 Capital to Bancorp \nprior to the final Closing, on a basis which shall be more advantageous to Sovereign \nthan those described in 1 l(a) above, each on a basis acceptable to, and approved by, \nthe Regional Director; \n12. For each of the four states in which it is acquiring branches, Sovereign shall \ncompute, on a monthly basis, whether the total assets attributable to all branches in \nthat State would qualify the branches as a whole, were they otherwise eligible, for \ntreatment as: (i) a domestic building and loan association under 26 USC 3 \n770 1 (a)( 19) or (ii) a qualified thrift lender, as determined under 12 USC $ 1467a(m). \nSovereign shall immediately notify the Regional Director in the event that it \ndetermines that it would fail to meet those tests in any of the four states. \nAlternatively, and in lieu of such calculations, Sovereign may submit a reasoned \nopinion of counsel in support of its representations that the state law requirements \nreferred to in 12 U.S.C. 5 1464(r)(2)(C) are satisfied with respect to each of the four \nstates in which it is acquiring branches. To be acceptable, the opinion must, at a \nminimum, be prepared by counsel who is licensed in the state on which the opinion \nis being rendered and who has substantial experience and background in the \ninterpretation and application of state banking law; \n13. Within 10 days of each month-end prior to the final Closing and within 30 days \nfollowing each quarter-end after the final Closing, Sovereign and Bancorp shall \nsubmit to the Regional Director updated financial statements in a form similar to the \nfinancial projections submitted to OTS as supporting schedules to the Application. Order No: 2000-25 \nPage No: 4 \nManagement must provide a complete description of any material adverse deviations \nfrom the financial projections and describe what actions management is taking to \nrectify any such deviations. This condition shall expire on June 30,2001, unless \nextended by the Regional Director; \n14. Sovereign shall take all steps necessary to ensure that, upon completion of each \nClosing, and at all times thereafter, it will comply with the aggregate limitations on \ninvestment in commercial loans set forth in 12 U.S.C. 3 1464(c)(2)(A). Sovereign’s \nChief Financial Officer shall certify compliance and submit supporting \ndocumentation of such compliance to the Regional Director no later than: (i) 15 days \nfollowing each Closing and (ii) 30 days from the end of each calendar quarter. This \ncondition shall expire on June 30,2001, unless extended by the Regional Director; \n15. Within 30 days of the end of each calendar quarter and continuing for a period of two \nyears following the final Closing, Sovereign shall provide to the Regional Director a \ndetailed written analysis of its progress in meeting the goals contained in its \nCommunity Reinvestment Plan submitted on February 8,2000, as amended through \nFebruary l&2000, for loans, investments, and services in both its historical \nassessment areas, and those assessment areas added by this transaction. The first \nreport shall be as of June 30,200O and shall be submitted to the Regional Director no \nlater than July 3 1,200O. The written analysis shall include, at a minimum, the total \nnumber and dollar volume of loans granted in each assessment area: (a) within low- \nand moderate-income census tracts; and (b) to low- and moderate-income persons, by \nspecific loan type; \n16. At each Closing, Sovereign shall refrain from accepting any asset that is not a \npermissible investment for a federal savings association; \n17. Sovereign and Bancorp shall not, directly or indirectly, pledge any of its assets or \notherwise permit any of its assets to be used as collateral (including any blanket lien) \nto secure repayment of the Deferred Contingent Amount; and \n18. Considering the scope of the proposed transaction, and to assure the proper \nsupervision of Sovereign’s expanded business affairs and operations: \n(a) Within 30 days of this Order, Sovereign shall submit and implement a risk \nmanagement plan in a form acceptable to the Regional Director; and \n(b) Within 45 days of this Order, Sovereign must submit a written comprehensive \ncompliance management plan, acceptable to the Regional Director, that addresses the \nimplementation of effective compliance management systems into its operations. \nThe compliance plan must: Order No: 2000-25 \nPage No: 5 \n(i) specifically address all consumer protection laws and regulations as well as \nthe Bank Secrecy Act (“BSA”) and implementing regulations (3 1 CFR Part 103, 12 \nCFR 563.177, and 12 CFR 563.180); \n(ii) provide a detailed framework and timetable for implementing compliance \nand BSA policies and procedures, internal controls, and training for personnel of the \nhistorical and acquired operations; and, \n(iii) identify specific individuals responsible for implementation and monitoring \nwithin each business unit of Sovereign. \nWithin 30 days of the end of each calendar quarter, for a period of two years \nfollowing the final Closing, Sovereign shall provide a detailed written analysis of \nimplementation activities to the Regional Director, including any changes in \npersonnel responsibilities for implementing the compliance plan, and the results of \nself-assessment reviews conducted to monitor compliance with the consumer \nprotection laws and regulations, and the BSA. \nAny time specified herein may be extended by the Regional Director, for good cause, for \nup to 120 calendar days. \nBy order of the Director of the Office of Thrift Supervision, or her designee, \neffective February 29,200O. \nManaging Director \nOffrce of Supervision "
} |
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Creek\n ELSTON SHORE RD KILBOURN DR ELSTON SHORE RD \nTalbot County\nUnincorporated \nAreas\n240066JOINS PANEL 0257JOINS PANEL 0258\nJOINS PANEL 0278\nJOINS PANEL 0270LIMIT OF\nMODERATE \nWAVE ACTIONLIMIT OF\nMODERATE \nWAVE ACTION\nLIMIT OF\nMODERATE \nWAVE ACTIONZONE AE\n(EL 6)\nZONE VE\n(EL 7)\nZONE VE\n(EL 7)\n!ZONE AE\n(EL 6)\n!ZONE AE\n(EL 5)\n!\nZONE AE\n(EL 6)\n!\nZONE AE\n(EL 5)!\nZONE AE\n(EL 5)!ZONE AE\n(EL 6)ZONE\nAE\n(EL 5)!ZONE AE\n(EL 5)\n! ZONE AE\n(EL 6)\n!ZONE AE\n(EL 6)!ZONE AE\n(EL 5)ZONE VE\n(EL 7)!\nZONE AE\n(EL 5)\n38°41'15''\n76°16'52.5''38°43'07.5''76°16'52.5''\n38°43'07.5''76°15'00''\n38°41'15''\n76°15'00''1520000 FT\n1525000 FT\n375000 FT380000 FT\n4283000mN4284000mN4285000mN4286000mN\n389000mE 390000mE 391000mE\nFIRM \nFLOOD INSURANCE RATE MAP \n \n \n \n \n \n \n \n(SEE MAP INDEX FOR FIRM PANEL LAYOUT) \n \nCONTAINS: \n \nCOMMUNITY NUMBER PANEL SUFFIX \n \n \n \n \n \n \n \n \n \n \n \n \n \nNotice to User: The Map Number shown below should be \nused when placing map orders; the Community Number \nshown above should be used on insurance applications for the \nsubject community. \n \n \nMAP NUMBER \n \n \nMAP REVISED \n \n \nFederal Emergency Management Agency \n MAP REPOSITORY \nRefer to listing of Map Repositories on Map Index \n \nEFFECTIVE DATE OF COUNTYWIDE \nFLOOD INSURANCE RATE MAP \n \n \nEFFECTIVE DATE(S) OF REVISION(S) TO THIS PANEL \n \n \n \nFor community map revision history prior to countywide mapping, refer to the Community \nMap History table located in the Flood Insurance Study report for this jurisdiction. \n \nTo determine if flood insurance is available in this community, contact your Insurance \nagent or call the National Flood Insurance Program at 1-800-638-6620. \n \n \n \n \nPANEL 0259D\nMAP SCALE 1\" = 500'\nFEET250 0 500 1000\n METERS\n150 0 150 300\nPRELIMINARY\nSEPTEMBER 12, 2013* Referenced to the North American Vertical Datum of 1988\n18N\nAugust 5, 2013\nTALBOT COUNTY,\nMARYLAND\nAND INCORPORATED AREAS\nPANEL 259 OF 455\n24041C0259DTALBOT COUNTY \n \n \n \n \n \n \n \n \n \n 240066\n \n \n \n \n \n \n \n \n \n 0259\n \n \n \n \n \n \n \n \n \n D\n \n \n \n \n \n \n \n \n \n 5000-foot grid values: Maryland State Plane coordinate system \n (FIPSZONE 1900), Lambert Conformal Conic projectionNOTES TO USERS \n \nThis map is for use in administering the National Flood Insurance Program. It \ndoes not necessarily identify all areas subject to flooding, particularly from local \ndrainage sources of small size. The community map repository should be \nconsulted for possible updated or additional flood hazard information. \n \nTo obtain more detailed information in areas where Base Flood Elevations \n(BFEs) and/or floodways have been determined, users are encouraged to consult \nthe Flood Profiles and Floodway Data and/or Summary of Stillwater Elevations \ntables contained within the Flood Insurance Study (FIS) report that accompanies \nthis FIRM. Users should be aware that BFEs shown on the FIRM represent \nrounded whole-foot elevations. These BFEs are intended for flood insurance \nrating purposes only and should not be used as the sole source of flood \nelevation information. Accordingly, flood elevation data presented in the FIS \nreport should be utilized in conjunction with the FIRM for purposes of \nconstruction and/or floodplain management. \nCoastal Base Flood Elevations shown on this map apply only landward of \n0.0' North American Vertical Datum of 1988 (NAVD 88). Users of this FIRM should \nbe aware that coastal flood elevations are also provided in the Summary of \nStillwater Elevations tables in the Flood Insurance Study report for this jurisdiction. \nElevations shown in the Summary of Stillwater Elevations table should be used for \nconstruction and/or floodplain management purposes when they are higher than \nthe elevations shown on this FIRM. \n \nBoundaries of the floodways were computed at cross sections and interpolated \nbetween cross sections. The floodways were based on hydraulic considerations \nwith regard to requirements of the National Flood Insurance Program. Floodway \nwidths and other pertinent floodway data are provided in the Flood Insurance \nStudy report for this jurisdiction. \n \nCertain areas not in Special Flood Hazard Areas may be protected by flood \ncontrol structures. Refer to Section 2.4 \"Flood Protection Measures\" of the \nFlood Insurance Study report for information on flood control structures for this \njurisdiction. \n \nThe projection used in the preparation of this map was Universal Transverse \nMercator (UTM) zone 18. The horizontal datum was NAD 83, GRS80 spheroid. \nDifferences in datum, spheroid, projection or UTM zones used in the production of \nFIRMs for adjacent jurisdictions may result in slight positional differences in map \nfeatures across jurisdiction boundaries. These differences do not affect the \naccuracy of this FIRM. \n \nFlood elevations on this map are referenced to the North American Vertical Datum \nof 1988. These flood elevations must be compared to structure and ground \nelevations referenced to the same vertical datum. For information regarding \nconversion between the National Geodetic Vertical Datum of 1929 and the \nNorth American Vertical Datum of 1988, visit the National Geodetic Survey \nwebsite at http://www.ngs.noaa.gov or contact the National Geodetic Survey at \nthe following address: \n \nNGS Information Services \nNOAA, N/NGS12 \nNational Geodetic Survey \nSSMC-3, #9202 \n1315 East-West Highway \nSilver Spring, Maryland 20910-3282 \n(301) 713-3242 \n \nTo obtain current elevation, description, and/or location information for bench \nmarks shown on this map, please contact the Information Services Branch \nof the National Geodetic Survey at (301) 713-3242, or visit its website at \nhttp://www.ngs.noaa.gov. \n \nBase map information shown on this FIRM was provided in digital format. \nStreamlines, road centerlines and political boundaries were provided by the Talbot \nCounty Department of Public Works. Digital aerial photography tiles, published in \n2006, were also provided by Talbot County. Adjustments were made to specific \nbase map features to align them to 1:200 and 1:400 scale orthophotos. \n \nBased on updated topographic information, this map reflects more detailed and up-\nto-date stream channel configurations and floodplain delineations than those \nshown on the previous FIRM for this jurisdiction. As a result, the Flood Profiles and \nFloodway Data tables in the Flood Insurance Study Report (which contains \nauthoritative hydraulic data) may reflect stream channel distances that differ from \nwhat is shown on this map. Also, the road to floodplain relationships for unrevised \nstreams may differ from what is shown on previous maps. \n \nCorporate limits shown on this map are based on the best data available at the \ntime of publication. Because changes due to annexations or de-annexations may \nhave occurred after this map was published, map users should contact appropriate \ncommunity officials to verify current corporate limit locations. \n \nPlease refer to the separately printed Map Index for an overview map of the \ncounty showing the layout of map panels; community map repository addresses; \nand a Listing of Communities table containing National Flood Insurance Program \ndates for each community as well as a listing of the panels on which each \ncommunity is located. \n \nThe AE Zone category has been divided by a Limit of Moderate Wave Action \n(LiMWA). The LiMWA represents the approximate landward limit of the 1.5-foot \nbreaking wave. The effects of wave hazards between the VE Zone and the LiMWA \n(or between the shoreline and the LiMWA for areas where VE Zones are not \nidentified) will be similar to, but less severe than those in the VE Zone. \nFor information on available products associated with this FIRM visit the Map \nService Center (MSC) website at http://msc.fema.gov. Available products may \ninclude previously issued Letters of Map Change, a Flood Insurance Study Report, \nand/or digital versions of this map. Many of these products can be ordered or \nobtained directly from the MSC website. \n \nIf you have questions about this map, how to order products or the National \nFlood Insurance Program in general, please call the FEMA Map Information \neXchange (FMIX) at 1-877-FEMA-MAP (1-877-336-2627) or visit the FEMA \nwebsite at http://www.fema.gov/business/nfip. LEGEND \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!\n!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!\n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n 87°07'45'', 32°22'30'' Geographic coordinates referenced to the North American \nDatum of 1983 (NAD 83), Western Hemisphere \n \n 2476000mN 1000-meter Universal Transverse Mercator grid values, zone \n \n \n 600000 FT \n \n \n \n DX5510 [ \nBench mark (see explanation in Notes to Users section of this \nFIRM panel) \n \n \nM1.5 \nRiver Mile \n \n 23 23 A \n# A SPECIAL FLOOD HAZARD AREAS SUBJECT TO INUNDATION \nBY THE 1% ANNUAL CHANCE FLOOD \nThe 1% annual flood (100-year flood), also known as the base flood, is the flood that has a 1% \nchance of being equaled or exceeded in any given year. The Special Flood Hazard Area is the \narea subject to flooding by the 1% annual chance flood. Areas of Special Flood Hazard include \nZones A, AE, AH, AO, AR, A99, V, and VE. The Base Flood Elevation is the water-surface elevation \nof the 1% annual chance flood. \n No Base Flood Elevations determined. \nBase Flood Elevations determined. \nFlood depths of 1 to 3 feet (usually areas of ponding); Base Flood \nElevations determined. \n \nFlood depths of 1 to 3 feet (usually sheet flow on sloping terrain); average \ndepths determined. For areas of alluvial fan flooding, velocities also \ndetermined. \n \nSpecial Flood Hazard Area formerly protected from the 1% annual chance \nflood by a flood control system that was subsequently decertified. Zone \nAR indicates that the former flood control system is being restored to \nprovide protection from the 1% annual chance or greater flood. \nArea to be protected from 1% annual chance flood by a Federal flood \nprotection system under construction; no Base Flood Elevations \ndetermined. \nCoastal flood zone with velocity hazard (wave action); no Base Flood \nElevations determined. \n \nCoastal flood zone with velocity hazard (wave action); Base Flood \nElevations determined. \n FLOODWAY AREAS IN ZONE AE \nThe floodway is the channel of a stream plus any adjacent floodplain areas that must be kept free \nof encroachment so that the 1% annual chance flood can be carried without substantial increases \nin flood heights. \n \nCross section line \n \nTransect line \n \nCulvert, Flume, Penstock or Aqueduct \n \nRoad or Railroad Bridge \n \nFootbridge \n \n OTHER FLOOD AREAS \n \nAreas of 0.2% annual chance flood; areas of 1% annual chance flood with \naverage depths of less than 1 foot or with drainage areas less than 1 square \nmile; and areas protected by levees from 1% annual chance flood. \n \nOTHER AREAS \n \nAreas determined to be outside the 0.2% annual chance floodplain. \n \nAreas in which flood hazards are undetermined, but possible. \n \n COASTAL BARRIER RESOURCES SYSTEM (CBRS) AREAS \n \nOTHERWISE PROTECTED AREAS (OPAs) \n \n \n \nCBRS areas and OPAs are normally located within or adjacent to Special Flood Hazard Areas. \n1% annual chance floodplain boundary \n \n0.2% annual chance floodplain boundary \n \nFloodway boundary \n \nZone D boundary \n \nCBRS and OPA boundary \n \nBoundary dividing Special Flood Hazard Area Zones and \nboundary dividing Special Flood Hazard Areas of different Base \nFlood Elevations, flood depths or flood velocities. \n \nLimit of Moderate Wave Action \n \n \nBase Flood Elevation line and value; elevation in feet* \n \nBase Flood Elevation value where uniform within zone; elevation \nin feet* \n # # # # # # # # # # # # # # # # # # # # \n# # # # # # \nZONE A \nZONE AE \nZONE AH \nZONE AO \nZONE AR \nZONE A99 \nZONE VE ZONE V \n# # # # # # # # # # # # # # # # # # # # \n# # # # # # \nZONE X \nZONE X \nZONE D # # # # # # # # # # # # # # # # # # # # \n# # # # # # \n# # # # # # \n (EL 987) # # # # # # # # # # # # # # # \n 513 \ni i \ne e \n"
} |
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"pdf_file": "R77SNILPJ5SSKNRBECOMST54VSPJ3RVT.pdf",
"text": "The Internal Revenue Service\nNeeds to Encourage Taxpayer Use,\nImprove Customer Service, and\nEnhance Computer Controls\nof the 941 TeleFile Program\nOctober 1999\n Reference Number: 200020004\nThis report has cleared the Treasury Inspector General for Tax Administration (TIGTA) disclosure\nreview process and information determined to be restricted from public release has been redacted\nfrom this document. DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C. 20220\n INSPECTOR GENERAL\n for TAX\n ADMINISTRATION\nOctober 14, 1999\nMEMORANDUM FOR COMMISSIONER ROSSOTTI\nFROM: Pamela J. Gardiner\nDeputy Inspector General for Audit\nSUBJECT: Final Audit Report - The Internal Revenue Service Needs to\nEncourage Taxpayer Use, Improve Customer Service, andEnhance Computer Controls of the 941 TeleFile Program\nThis report presents the results of our review of the 1998 TeleFile Program used\nby small business taxpayers to file an Employer’s Quarterly Federal Tax Return(Form 941). We evaluated the effectiveness of the Internal Revenue Service’s (IRS)processes for ensuring that the 1998 Form 941 TeleFile Program was successfullyimplemented. This was the first year for nationwide TeleFile processing of Forms 941.\nIn summary, we found that the IRS established effective processes for ensuring that the\n941 TeleFile Program was successfully implemented. The vast majority of Form 941TeleFile returns filed in 1998 were accurately processed and posted to the IRS'Business Masterfile. However, to achieve its long-term goals of increased 941 TeleFileProgram participation, the IRS needs to encourage eligible taxpayers to use the system,educate taxpayers on program changes, and provide quality customer service to allTeleFile users. In addition, improvements to the 941 TeleFile System would prevent thefiling of multiple returns by a taxpayer and would allow the system to verify the filinghistory and electronic signature of TeleFile users.\nThe report recommends that the IRS analyze customer feedback information gathered\nin 1997 during the 941 TeleFile Program limited expansion to identify ways to increaseparticipation. It also recommends that the IRS educate taxpayers on the requirementsfor using the 941 TeleFile System, as well as any program changes, and ensure qualitycustomer service. In addition, the report recommends enhancements to the system toprevent the processing of duplicate Form 941 TeleFile returns and to verify the filing 2\nhistory and electronic signatures of the taxpayers, or taxpayer representatives, who file\nForm 941 TeleFile returns.\nThe Chief Operations Officer agreed with the facts cited in the report and is taking\nappropriate corrective actions. Management’s comments have been incorporated intothe report where appropriate, and the full text of their comments is included as anappendix.\nCopies of this report are also being sent to the IRS managers who are affected by the\nreport recommendations. Please contact me at (202) 622-6510 if you have questions,or your staff may call Scott E. Wilson, Associate Inspector General for Audit(Information Systems Programs), at (202) 622-8510. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nTable of Contents\nExecutive Summary .................................................................................. Page i\nObjective and Scope ................................................................................ Page 1Background............................................................................................... Page 2Results ...................................................................................................... Page 3\nThe Internal Revenue Service Needs to Encourage\nEligible Taxpayers to Use the 941 TeleFile Program ..................... Page 4\nThe Internal Revenue Service Needs to Provide Quality\nCustomer Service to TeleFile Users............................................... Page 7\nThe Internal Revenue Service Needs to Improve 941 TeleFile\nComputer Controls to Prevent Taxpayers From Filing MultipleReturns and Allow the System to Verify a TeleFile User's\nFiling History and Electronic Signature........................................... Page 11\nConclusion .............................................................................................…Page 15\nAppendix I – Detailed Objective, Scope, and Methodology....................... Page 16Appendix II – Major Contributors to This Report ...................................... Page 18Appendix III – Report Distribution List ....................................................... Page 19Appendix IV – Memorandum #1 – Business Masterfile TeleFile\n1998 Expansion ........................................................................................ Page 20\nAppendix V – Management’s Response to Memorandum #1 ................... Page 22Appendix VI – Management’s Response to the Draft Report.................... Page 24 The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage iExecutive Summary\nTeleFile is an Internal Revenue Service (IRS) voice response system that allows\ntaxpayers to file tax returns using a touch-tone telephone. In 1997, the IRS expanded theTelefile System to allow a limited number of small business taxpayers to file theEmployer’s Quarterly Federal Tax Return (Form 941) through the 941 TeleFile System.In 1998, TeleFile was further expanded to allow small businesses nationwide to use thesystem. For the first six months of 1998, almost 460,000 Form 941 returns were filedusing the 941 TeleFile System. TeleFile is an important initiative in the IRS’ overallplans to increase electronic filing of tax returns. The IRS has a goal of 16 million\nemployment tax returns being filed electronically by the year 2002.\nThe TeleFile Program is coordinated through the National Office and includes all of the\nactivities that enable taxpayers to file tax returns using the Telefile System. Theobjective of this audit was to evaluate the effectiveness of the IRS’ processes for ensuring\nthat the 1998 941 TeleFile Program was successfully implemented.\nResults\nThe 941 TeleFile Program experienced a successful 1998 filing season, its first year of\nnationwide use (for the period January 1998 through the end of our fieldwork inNovember 1998). The IRS had effectively corrected prior audit findings, and ensuredthat Form 941 tax returns were accurately processed through the Telefile System andrecorded on the taxpayers’ accounts in the IRS’ computer systems. However, to achieve\nthe long-term goals of the 941 TeleFile Program, the IRS needs to:\n• Encourage eligible taxpayers to use the 941 TeleFile Program.\n• Provide quality customer service to TeleFile users.\n• Improve 941 TeleFile computer controls to prevent taxpayers from filing multiple\nreturns and allow the system to verify a TeleFile user’s filing history and\nelectronic signature.\nThe Internal Revenue Service Needs to Encourage Eligible Taxpayers to\nUse the 941 TeleFile Program\nThe customer feedback information gathered during the 1997 limited expansion\nshould be used to increase 941 TeleFile Program participation . The IRS obtained\ninformation from taxpayers who chose not to use the 941 TeleFile System. Thiscustomer feedback showed that many taxpayers had not used the 941 TeleFile Systemeither because they used a paid preparer or because they wanted a paper copy of the The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage iireturn. This information could have been used to focus the IRS’ marketing efforts to\naddress any taxpayer misconceptions about the system. During 1998, there was nosignificant increase in the percentage of eligible taxpayers who used the TeleFileProgram. The IRS needs to focus its marketing efforts to encourage more taxpayers touse the 941 TeleFile System. This will enable the IRS to achieve its goal of 16 million\nelectronically filed employment tax returns by the year 2002.\nThe Internal Revenue Service Needs to Provide Quality Customer\nService to TeleFile Users\nA more effective method for resolving taxpayer problems needs to be established .\nThe IRS has not implemented a process for delivering effective one-stop customerservice to taxpayers using the 941 TeleFile Program (correctly handling their questions orconcerns during their first contact with the IRS). Taxpayers with questions regardingForm 941 TeleFile returns are instructed to contact a customer service call site. The callsite representative will then either contact the TeleFile Coordinator to ask the question for\nthe taxpayer or will instruct the taxpayer to contact the Coordinator directly.\nTaxpayers should be informed when they are no longer eligible to participate in the\n941 TeleFile Program . If a taxpayer’s annual Form 941 liability exceeds a certain dollar\ncriteria, then the taxpayer is no longer eligible to use the 941 TeleFile System. The IRShas no procedures to notify taxpayers of this and to suggest other electronic methods for\nfiling the Form 941 returns.\nThe 941 TeleFile forms and instructions should be timely updated to reflect\nprogram changes . The 941 TeleFile tax package (which includes the forms and\ninstructions mailed to taxpayers) was not timely updated to indicate that the IRS wouldaccept returns with a higher balance due amount than had been accepted previously.Some taxpayers may not have used the 941 TeleFile System because of the incorrect\ninstructions.\nThe Internal Revenue Service Needs to Improve 941 TeleFile Computer\nControls to Prevent Taxpayers From Filing Multiple Returns and Allow\nthe System to Verify a TeleFile User’s Filing History and Electronic\nSignature\nThe 941 TeleFile System should prevent multiple returns from being filed by a\ntaxpayer . Normally, TeleFile returns are received at one processing site, with a backup\nsite available to handle the excess volume. If both sites are receiving returns, and ataxpayer files a second (amended) return on the same day the first (original) return wasfiled, both returns could be accepted by TeleFile if the returns were processed at separatesites. The IRS would not be aware of the potential duplicate or amended return becausedata from the two sites are only merged and updated at the end of the day. When thisoccurs, TeleFile always processes the return received at the main processing site, and not The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage iiithe return from the backup site, even though the taxpayer may have intended otherwise.\nWhile this should not be a common occurrence, we performed some limited testing andidentified several instances where a taxpayer filed more than one return on the same day.This is a systemic problem that will be compounded as the population of TeleFile users\nincreases.\nThe look-back period could be used to ensure businesses are authenticated\n(i.e., verified) to use the 941 TeleFile System . The IRS requires taxpayers to be in\nbusiness for at least 12 months before using the 941 TeleFile System. However, theexisting 941 TeleFile System will accept and process returns from taxpayers, even thoughthey are not authenticated to use the 941 TeleFile System. The IRS has a current processin place (the look-back period) that could be used to provide the IRS with more assurance\nthat taxpayers have an established filing history when using the 941 TeleFile System.\nThe process for verifying the electronic signature of 941 TeleFile System users needs\nto be improved . There is not an effective process to ensure that returns filed using the\n941 TeleFile System were actually filed by the taxpayers or their representatives. Theprocess for verifying the electronic signatures of the taxpayers is incomplete because(1) only a sample of the electronic signatures are verified as correct, and (2) there are no\nprocedures for following up on invalid signatures.\nSummary of Recommendations\nThe IRS should analyze the customer feedback information gathered during the\n1997 limited expansion to determine how 941 TeleFile Program participation can beincreased. In addition, the IRS needs to ensure 941 TeleFile Program taxpayers are givenquality customer service when resolving taxpayer problems with the 941 TeleFileProgram. Also, the 941 TeleFile computer controls need to be enhanced to preventduplicate Form 941 returns from being filed and to improve the process for verifying the\nfiling history and electronic signature of taxpayers using the 941 TeleFile System.\nManagement’s Response: IRS management agreed with the conditions cited in the report\nand has designed and, in some instances, implemented actions to correct the problems.\nTo improve its marketing effort to increase participation in the 941 TeleFile Program, theIRS has contracted with a vendor to develop a comprehensive marketing andcommunication strategy that will focus on the Form 941 products. In addition, the IRShas made several enhancements and clarifications to the 1998 TeleFile tax package to\naddress customer feedback received in 1997 and 1998.\nTo ensure 941 TeleFile Program taxpayers are given quality customer service, the IRS\nwill update the instructions for its telephone representatives to include additional programdetail, processing guidelines, and questions and answers. In addition, the IRS tested an The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage ivEmployment Tax call site for small businesses this past filing season and, based on the\nfavorable results, plans to request the establishment of the call site.\nTo prevent duplicate returns from being filed, the IRS has implemented a process to\neliminate duplicate returns when multiple sites are used to process returns. To improvethe process for verifying the identity of taxpayers using TeleFile, the IRS will redesign\nthe return filing confirmation number to make it unique for each taxpayer.\nManagement’s complete response to the draft report is included as Appendix VI. (Note:\nthe report recommendations were renumbered after management issued their response,and, therefore, do not correspond directly with the recommendation numbers shown in\nAppendix VI.) The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 1Objective and Scope\nThe TeleFile Program for the Employer’s Quarterly\nFederal Tax Return (Form 941) was designed to providebusinesses with flexible and convenient ways to filereturns. The overall objective of the audit was to evaluatethe effectiveness of the Internal Revenue Service’s (IRS)processes for ensuring that the 1998 941 TeleFile Program\nwas successfully implemented.\nSpecifically, we:\n• Evaluated actions taken in response to a prior audit\nreport titled, “Evaluation of the 1997 TeleFile Pilot -\nBusiness Masterfile” (Reference Number 080704,\nDated December 2, 1997) on the 1997 TeleFile\nlimited expansion for Form 941 tax returns.\n• Evaluated the effectiveness of the IRS’ processes for\nensuring Form 941 TeleFile returns were accurately\nprocessed nationwide.\n• Evaluated the effectiveness of the IRS’ publicity\nefforts to increase the number of businesses that file\nreturns using the 941 TeleFile System.\nThe review was conducted between July 1998 and\nNovember 1998 at the National Office and theCincinnati Service Center (CSC), with limited testing atthe Tennessee (TCC) and Martinsburg ComputingCenters (MCC). These centers are the IRS officeswhere TeleFile returns are filed and processed. Weperformed this review in accordance with Government\nAuditing Standards .\nAppendix I provides the detailed objective, scope, and\nmethodology used to conduct the audit; Appendix II liststhe major contributors to this report; and Appendix III\nreflects the Report Distribution List.\nDuring the review, we issued two audit memoranda\ncommunicating several issues requiring immediateattention. This report presents a summary of thetwo memoranda and additional audit results completedThe overall objective was to\nevaluate the effectiveness ofthe IRS’ processes for\nensuring that the 1998 941\nTeleFile Program wassuccessfully implemented. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 2after the memoranda were issued. IRS management\nresponded to the first memorandum. A copy of the firstmemorandum and management’s response are included\nin Appendices IV and V, respectively.\nBackground\nTeleFile is a voice response system that allows\ntaxpayers to file tax returns using a touch-tonetelephone. The Telefile System uses Electronic Filing(ELF) to process returns. The Program is coordinatedthrough the Electronic Tax Administration (ETA) Officeat the National Office and includes all of the activitiesthat enable taxpayers to file tax returns using the TelefileSystem. Beginning in 1996, the TeleFile Programenabled individual taxpayers across the nation to filereturns over the telephone. The IRS expanded theProgram in 1997 by allowing a limited number of smallbusiness taxpayers to file Form 941 returns through the\n941 TeleFile System.\nOn December 2, 1997, the IRS Inspection Service (now\nTreasury Inspector General for Tax Administration)issued a report titled, “Evaluation of the 1997 TeleFile\nPilot - Business Masterfile.” The purpose of that audit\nwas to evaluate controls over the 941 TeleFile Programand determine whether it was properly implemented.We concluded that the IRS experienced a successfullimited expansion with 48,834 Form 941 returns filedand 99 percent of the businesses able to access thesystem on their first attempt. However, the following\nissues were also identified:\n• The 941 TeleFile Program allowed new\nbusinesses and businesses that were not current\nwith their filing requirements to participate in the\nProgram.\n• Taxpayers in the 941 TeleFile Program were not\nalways properly verified.\n• Instructions in the Form 941 TeleFile package\ncontained an error that could be confusing to\ntaxpayers. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 3ETA management generally agreed with our\nrecommendations and established plans for correctiveaction. In 1998, TeleFile was further expanded to allowsmall business taxpayers nationwide to file Form 941\nreturns electronically.\nResults\nOverall, the IRS has established effective processes for\nensuring that the 941 TeleFile Program was successfullyimplemented. For example, Form 941 TeleFile returnsfiled in 1998 were accurately processed and posted tothe taxpayers’ accounts. In addition, the IRSimplemented corrective actions from the 1997 audit,which increased assurances that only authorized\ntaxpayers participated in the Program.\nNearly 460,000 employment tax returns were filed for\nthe first six months of calendar year 1998 using the941 TeleFile System. In addition, approximately94 percent of the business taxpayers that attempted tofile over the telephone in the second quarter of calendaryear 1998 were successful. The remaining six percentof the taxpayers were either not allowed by the IRS tocomplete their TeleFile return because they did not meetthe eligibility requirements or they hung-up before\ncompleting their return.\nAlthough the IRS had a successful 1998 filing season\n(January 1998 through December 1998) for the941 TeleFile Program, additional actions are needed tomarket the 941 TeleFile Program to eligible users and toimprove customer service for TeleFile users.Improvements in these two areas should enhance theIRS’ ability to achieve its goal of 16 millionemployment tax returns being filed electronically by the\nyear 2002. The IRS needs to improve its marketing and\ncustomer service by:\n• Using the customer feedback information gathered\nduring the 1997 limited expansion to increase\nTeleFile Program participation.ETA management agreed with\nthe results from the prior\nreport and established plansfor corrective action.\nNationwide implementation of\nthe 941 TeleFile Program wassuccessful.\nAdditional actions are needed\nto ensure the IRS achieves its\ngoal of 16 million employment\ntax returns being filed\nelectronically by theyear 2002. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 4• Establishing a more effective method for resolving\ntaxpayer problems with the 941 TeleFile Program.\n• Informing taxpayers when they are no longer eligible\nto participate in the 941 TeleFile Program.\n• Ensuring that 941 TeleFile Program forms and\ninstructions are timely updated to reflect program\nchanges.\nOur review also showed that improvements to the\nTeleFile computer controls would help ensure that the\ncorrect return is processed by:\n• Preventing the filing of multiple returns by a\ntaxpayer.\n• Using the look-back period to ensure businesses\nusing the 941 TeleFile System are authenticated\n(i.e., verified) to use the system.\n• Improving the process of verifying the electronic\nsignatures of 941 TeleFile System users.\nThe Internal Revenue Service Needs to\nEncourage Eligible Taxpayers to Use the 941\nTeleFile Program\nThe IRS should use the customer feedback\ninformation gathered during the 1997 limited\nexpansion to increase 941 TeleFile Program\nparticipation . We found no evidence that the IRS\nfocused its marketing on the 941 TeleFile Programnon-users (those 941 filers who were eligible to useTeleFile but did not do so) to increase the number of\nbusinesses participating in the Program.\nThe IRS obtained customer feedback information during\nthe 1997 Customer Satisfaction Survey, which includedthe reasons why taxpayers used or did not use theTelefile System. Customer feedback obtained fromeligible non-users of the 941 TeleFile Program indicated\nthat:Improvements to the computer\ncontrols would prevent a\ntaxpayer from filing more than\none return per day.\nThe IRS has not used customer\nfeedback from 1997 to identify\nways to better market theProgram to eligible users. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 5• Approximately 39 percent of eligible non-users\nemployed a paid tax preparer (called a third-\nparty preparer) to complete and file their\nquarterly returns.\n• Another 23 percent of the businesses did not use\nthe Program because they wanted a copy of the\nreturn.\nThe IRS does not know why the third-party preparers\ndid not file clients' returns electronically. The TeleFileteam that measures quality recommended that the IRSmarket and educate third-party preparers to increasefuture use of the 941 TeleFile Program. However, theETA office did not use the information gathered orprepare a 941 TeleFile Program marketing strategy forcalendar year 1998 and there were no coordinatednationwide efforts toward third-party preparers. During1998, IRS employees again traveled around the country\nto obtain customer feedback from businesses. The\nfeedback contained some of the same issues as theprevious year, further emphasizing the need for the IRSto analyze and use this information to address any\ntaxpayer misconceptions about the System.\nThe National Office also did not provide any of the\nmarketing information to the district TeleFilecoordinators after nationwide implementation of the941 TeleFile Program. These employees wereresponsible for marketing the 941 TeleFile Program andindicated that they received no marketing informationspecifically on the 941 TeleFile Program from theNational Office. In addition, we were informed that theoverall ETA marketing strategy efforts in 1998 focusedprimarily on the IRS’ TeleFile Program for individualtaxpayers (known as “Individual Masterfile (IMF)\nTeleFile”), and not on the 941 TeleFile Program.\nThe IRS sent TeleFile tax packages to eligible taxpayers\nin 1998; however, the lack of emphasis on marketing the941 TeleFile Program in 1998 may be reflected in thelow volume of participation in the Program. Wedetermined that the percentage of eligible filers usingthe Telefile System in 1998 was almost the same asNo marketing strategy was\ndeveloped for the 941 TeleFileProgram. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 61997 (6.7 percent of the eligible filers in 1998 compared\nto 6.2 percent in 1997). Through the second quarter ofcalendar year 1998, approximately 460,000 employmenttax returns were filed by businesses using the 941TeleFile System. Unless there is a significant increasein the number of 941 TeleFile returns filed for thesecond half of calendar year 1998, the IRS will be about24 percent below its estimate of 1.2 million 941 TeleFile\nreturns filed for 1998.\nThe IRS has taken steps to improve its marketing efforts\nby contracting with an outside vendor to develop astrategy for marketing the 941 TeleFile Program. Thecontract will go into effect the first quarter of calendaryear 1999. With the emphasis on customer service andon increasing the number of electronic returns, the IRSneeds to consider any information that could be used tohelp achieve its goal of 16 million employment taxreturns being filed electronically by the year 2002.\nRecommendations\n1. The IRS needs to improve its marketing towards\neligible businesses to increase participation in the\n941 TeleFile Program. Specific actions include:\n• Using the non-users’ customer feedback\nresponses to determine where to concentrate\nmarketing efforts (i.e., third party preparers).\n• Clarifying the 941 TeleFile Program instructions\nand educational material to address taxpayers’\nmisconceptions with the system (e.g., informingtaxpayers that they will receive a confirmation\nnumber as proof of filing).\nManagement’s Response: The IRS has evaluated the\nnon-user responses and determined that since the IRS\nidentifies eligible users prior to filing, and sends taxpackages to those taxpayers, it will continue toemphasize a direct marketing approach by using the taxpackages to communicate messages directly to eligible\nusers.\nETA management has written tax package instructions\nto be easy to read and understand. They have alsoThe IRS has evaluated the\nnon-user responses from the1997 limited expansion and\nwill continue to use tax\npackages as its primary\nmethod for communicating\ndirectly with eligible users. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 7addressed many misconceptions of users, eligible non-\nusers, and tax preparers. For example, the instructionregarding proof of filing or return acceptance has beenrevised to draw more emphasis to this benefit and to theissuance of a confirmation number by the Telefile\nSystem.\nETA management has also established a group to\npromote awareness and education to internal andexternal audiences. In addition, the IRS periodicallyprovides articles and Questions and Answers on the 941\nTeleFile Program to employees and taxpayers toimprove publicity, education, and instructions for IRS\nelectronic filing programs.\nThe IRS has contracted with a vendor to develop a\ncomprehensive marketing and communications strategythat will focus on the “941 Suite” of products. The finalplan “IRS Marketing for Business Masterfile (BMF)Initiatives” was delivered December 23, 1998. The plangave further direction and provided recommendationsfor the best marketing approach for electronic business\noptions.\nThe Internal Revenue Service Needs to Provide\nQuality Customer Service to TeleFile Users\nThe IRS needs to establish a more effective method\nfor resolving taxpayer problems with the 941\nTeleFile Program . The IRS has not established an\neffective method for delivering quality customer serviceto taxpayers using the 941 TeleFile Program. Currently,business taxpayers with questions about their 941TeleFile return contact IRS Customer Service. Thecustomer service representative then either contacts theTeleFile Coordinator or has the taxpayer contact theCoordinator. We were advised that the TeleFileCoordinator currently handles about 20 phone calls per\nday.\nSince this was the first full year of nationwide use, most\nof these calls could be handled by the TeleFileAn effective method for\nresolving taxpayer problems isneeded. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 8Coordinator. However, the current process does not\nmeet the IRS’ goal of resolving taxpayers’ problemsduring their initial contact with the IRS. In addition, asthe number of TeleFile users increases, a more effectivemethod will need to be implemented since TeleFile is\nnot adequately staffed to handle taxpayer problems.\nThe IRS is testing an Employment Tax call site for 90\ndays at the MCC and an employment tax web page onthe Internet. These two options, if implemented, couldimprove the customer service provided to businesses\nusing the 941 TeleFile Program.\nTaxpayers should be informed when they are no\nlonger eligible to participate in the 941 TeleFile\nProgram . The 941 TeleFile Program will not allow\nbusinesses with tax liabilities greater than $50,000 touse the system because those businesses are required tofile an additional supporting schedule with the Form 941\nreturn.\nThe IRS uses a taxpayer’s prior filing history to\ndetermine the taxpayer’s requirements for depositingemployment tax payments (known as Federal TaxDeposits or FTDs) towards their yearly tax liability.Specifically, the IRS uses the taxpayer’s Form 941 filinghistory for 12 months (e.g., beginning July 1\nst and\nending June 30th of the prior year). This period is called\nthe look-back period. Once the taxpayer’s total taxliability exceeds $50,000, they are required to deposittheir FTDs on a semi-weekly basis and are also requiredto file an Employer’s Record of Federal Tax Liability\n(Schedule B), with the Form 941 return. \nWhen business taxpayers exceed the $50,000 liability\nthreshold, the IRS issues an Annual Notification of FTDDeposit Requirements (CP-136 notice), advising themthat their FTD requirements have changed from monthlyto semi-weekly. However, the notice does not mentionthat the taxpayer is no longer eligible to use the941 TeleFile Program because they exceeded thethreshold. It also does not indicate that they are now\nrequired to file a Schedule B with the Form 941 return.Some current 941 TeleFile\nProgram users will not be\nallowed to use TeleFile for\n1999 because their tax\nliabilities have exceeded the\ndollar threshold, but the IRSdoes not inform them of this. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 9Once a taxpayer is required to file a Schedule B, they\ncannot file electronically through the Telefile System.During the first six months of 1998, there were 236,344filers who attempted to use TeleFile and 8,294 of thesefilers were not allowed to use the System because theywere required to file a Schedule B with the Form 941return. These Schedule B filers (3.5 percent of thepopulation) received a CP-136 notice and may havesubsequently called the IRS to determine why they wereno longer eligible to use TeleFile. These types of callscould be prevented if the IRS notifies the taxpayer whenthey are no longer eligible to use the 941 TeleFileSystem. The IRS could use the CP-136 to advisetaxpayers that they are no longer eligible to use TeleFileand that they are now required to file a Schedule B with\nthe Form 941 return. The notice could also advise the\ntaxpayer of other alternatives for filing their returns,\nsuch as ELF.\nThe IRS needs to ensure that the 941 TeleFile\nProgram forms and instructions are timely updated\nto reflect program changes . On October 2, 1998, we\nissued a memorandum advising the IRS that theinstructions to the 941 TeleFile package had not beenupdated to reflect a revision to the criteria scheduled foruse with the Telefile System in the fourth quarter ofcalendar year 1998. This criteria change involvedpermitting taxpayers with a balance due tax liability of$1,000 or less to use the 941 TeleFile System. Prior tothis criteria change, taxpayers could only use the 941TeleFile System if they had a balance due of $500 orless.\nOur review of the fourth quarter TeleFile tax package\ninstructions and the 941 TeleFile tax form showed thatthey had not been revised to reflect that the balance duecriteria of $500 was raised to $1,000. Line 15 of the941 TeleFile tax form incorrectly instructed thetaxpayers that if they owed a balance due of $500 ormore, then they could not use the 941 TeleFile System.This information was also included on Page TEL-1 ofthe tax package instructions.\nTeleFile packages had not\nbeen updated to reflect therevised balance due limitationof $1,000. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 10The IRS was expected to mail approximately 3.5 million\nfourth quarter TeleFile packages to taxpayers inDecember 1998. The omission to the instructions mayhave caused some eligible taxpayers to not use the941 TeleFile System. The incorrect instructions mayimpact IRS management’s ability to achieve their goalof 16 million employment tax returns being filed\nelectronically by the year 2002.\nThe IRS is currently in the process of enhancing the\n941 TeleFile Program to accept all balance due returnseffective January 4, 1999. This change will eliminate\nthe balance due dollar restriction.\nRecommendations\n2. The IRS should ensure that Customer Service\nrepresentatives located at Customer Service sites are\nadequately trained to handle 941 TeleFile Program\nproblems.\n3. The IRS should provide additional wording to the\nCP-136 notice to advise taxpayers they are no longereligible to use the 941 TeleFile Program and toadvise them of other electronic alternatives for filing\ntheir returns, such as ELF.\n4. In a memorandum dated October 2, 1998, we\nrecommended that the fourth and subsequent quarterTeleFile tax packages be revised to correctly instruct\ntaxpayers on the revised criteria.\nManagement’s Response: The IRS will supplement\nPart 21 of the Internal Revenue Manual (IRM) for\ncustomer service representatives to include additionalprogram detail and processing instructions when\nresponding to calls from taxpayers.\nThe test for the new Employment Tax call site was\nconducted between October and December 1998. Basedon the results of the test, the IRS has proposed the\nestablishment of the call site.\nIRS management has requested a computer code for the\n941 TeleFile Program to enable them to track and retaineligible filers. Based on Information Systems resources,The IRS is supplementing\nPart 21 of the IRM to includeadditional detail and\ninstructions when responding to\ncalls from taxpayers, and has\nproposed the establishment of an\nEmployment Tax call site. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 11the assignment of this code may not be possible until the\nyear 2001.\nThe IRS will explore the recommendation to include\ninformation in the CP-136 notice that will advise thetaxpayer that if they are required to file a Schedule B,they are no longer eligible to use the 941 TeleFileSystem.\n The IRS is also working on incorporating the\nSchedule B into the 941 TeleFile System, which is the\nbasis for the expansion of the 941 TeleFile Program.\nThe IRS explained that it could not revise the 941\nTeleFile tax package prior to mailing the fourth quarterpackages. The TeleFile instructions and tax packagewere subsequently updated and the changes wereeffective in the mailout for the first quarter of calendar\nyear 1999.\nThe Internal Revenue Service Needs to Improve\n941 TeleFile Computer Controls to Prevent\nTaxpayers From Filing Multiple Returns andAllow the System to Verify a TeleFile User's\nFiling History and Electronic Signature\nThe 941 TeleFile computer system should prevent the\nfiling of multiple returns by a taxpayer . Form 941\nTeleFile returns are primarily processed at the TCC. Ifthe TCC cannot handle the volume of returns beingfiled, or if the Telefile System is not working at TCC,the CSC serves as the backup site to handle the excessvolume. The CSC currently accepts TeleFile returnsonly during peak filing periods, which are the last twodays of the filing month. Returns from the two locationsare merged and updated on the 941 TeleFile System atthe end of each day. In contrast, the IRS’ IMF TeleFilecomputer system, which processes Individual Income\nTax Returns (Form 1040), is updated every 15 minutes.\nOccasionally, taxpayers file a second, or amended,\nreturn to correct errors or omissions in their original taxreturn. The TeleFile tax package instructions state thatamended returns cannot be filed through TeleFile andThe IRS is exploring the\nrecommendation to include\ninformation about a change in\na taxpayer’s eligibility for the941 TeleFile Program in theCP-136 notice.\nMultiple Form 941 TeleFile\nreturns are being filed. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 12must be filed on paper. However, if a taxpayer attempts\nto file more than one Form 941 TeleFile return in thesame peak filing day, both returns could be processedseparately at the two sites. Since the Systems are onlymerged and updated at the end of the day, TeleFilewould not be aware of the potential duplicate oramended return and would accept both returns.However, when there are duplicate returns, TeleFilealways processes the return received at the primaryprocessing site (TCC). The return filed at the CSC, thebackup site, would not be processed even though the\ntaxpayer may have intended otherwise.\nOur audit showed that the 941 TeleFile System did not\nprevent multiple returns from being filed when both theTCC and the CSC were receiving TeleFile returns. Wetested the peak processing period for the second quarterof calendar year 1998 and identified 17 businesstaxpayers that filed more than one 941 return on the\nTelefile System.\nThis process may cause the taxpayer to contact the IRS\nto ensure the correct return was processed, whichincreases taxpayer burden. This problem will becompounded as the volume of both Form 1040 andForm 941 TeleFile returns increases and there are moredays when both the TCC and the CSC are accepting\nTeleFile returns.\nThe IRS could use the look-back period to ensure\nbusinesses using the 941 TeleFile System are\nauthenticated (i.e., verified) to use the System . Under\nexisting processes, business taxpayers can participate inthe 941 TeleFile Program without being authenticated.Each quarter, the IRS creates a database of taxpayerswho are eligible to use the 941 TeleFile System. Eachof the taxpayers in the database has been in business forat least the last 12 months. Requiring taxpayers to be inbusiness for at least a year assures the IRS that the 941TeleFile System is only used by businesses with anestablished filing history. Using the look-back period,which relies on the Form 941 filing history over the pastyear, will provide the IRS with more assurance that\nBusinesses are filing returns\nthrough the 941 TeleFile\nSystem without beingauthenticated (i.e., verified) touse the system. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 13taxpayers have an established filing history when using\nthe 941 TeleFile System.\nTo verify the taxpayer’s identity, the IRS requires the\ntaxpayer to enter the prior year’s third quarter total FTDamount each time a Form 941 return is filed. If thetaxpayer did not file a prior year third quarter Form 941return or have any FTDs for that quarter and enters azero in the FTD amount field, the computer allows thetaxpayer to file the current Form 941 return. As a result,businesses are able to participate in the Program eventhough they have not established a filing history todetermine their filing requirements.\nHowever, it is possible due to timing for an eligible\ntaxpayer (in business for at least 12 months) to not havea prior year third quarter FTD amount. For example,taxpayers eligible to file for the fourth quarter of 1998(October 1998 - December 1998) would only have to bein business since the fourth quarter of calendar year1997 (October 1997 – December 1997). Thesetaxpayers would not have a prior year third quarter FTDamount because they were not in business during the\nthird quarter of calendar year 1997.\nThe IRS should improve the process of verifying the\nelectronic signatures of the 941 TeleFile System\nusers . Currently, taxpayers electronically sign their\nreturns by entering their Social Security Number (SSN)and their last name. After TeleFile accepts the return,the System provides a confirmation number to thetaxpayer. The confirmation number is based, in part, on\nthe date the return is filed.\nBecause the taxpayer’s electronic signature (name and\nSSN) cannot be verified on-line against the IRS’computer system, a sample of electronic signatures ismanually reviewed at the end of the quarter as a qualitymeasure. The TeleFile Coordinator selects a randomsample of returns and manually matches the names andSSNs to the IRS’ Masterfile to ensure the returns were\nfiled by the taxpayer or his or her representative.\nThe TeleFile Coordinator’s review at the end of the\nfirst quarter of calendar year 1998 showed that about\nFive percent of the electronic\nsignatures were not valid. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 1495 percent of the electronic signatures were valid. Five\npercent of the signatures were not valid because the SSNdid not match the name control. However, the IRS doesnot have procedures to follow up on the invalid\nsignatures, allowing potential invalid returns to be filed.\nThis raises the question about the purpose of this quality\nreview. If it is important to verify the signature bymanually reviewing a sample of returns, then the IRS\nshould follow up on the invalid signatures.\nRecommendations\n5. The IRS should update the 941 TeleFile System\nusing the same update process used by the IMFTelefile System. This process would result inupdates every 15 minutes, which reduces the risk of\nmultiple returns being filed.\n6. The IRS should require taxpayers to be in business\nfor the entire look-back period to be eligible to\nparticipate in the 941 TeleFile Program.\n7. The IRS should assess the risks associated with the\nelectronic signature process and develop appropriateactions based on this assessment. If the IRS elects tocontinue the existing process, we recommend thatthe IRS determine an acceptable error rate forinvalid signatures and take appropriate action when\nthe error rate is exceeded.\nManagement’s Response: To prevent duplicate returns\nfrom being filed, the IRS has implemented a Data\nReplication process to eliminate duplicate returns whenmultiple sites are used to process returns . This process\nwill be tracked to ensure it is successful.\nETA management will analyze the computer program\ncriteria for determining if a taxpayer is eligible to usethe 941 TeleFile System to ensure it is capturing eligiblefilers for the full look-back period. ETA management isalso researching the possibility of allowing all newbusinesses that otherwise meet the 941 TeleFile\nProgram requirements to use the System. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\nPage 15The IRS is researching a random sample of SSNs for\ninvalid electronic signatures. The IRS is sending lettersto the taxpayers who provided the invalid signatures,and informing them their tax return may be delayed untilthe letter is returned with a valid signature. The IRS isalso working on redesigning the return filingconfirmation number so that it will be unique to eachtaxpayer, which will allow the IRS to continue to trackthe electronic signature information on a quarterly basis.The results of the electronic signature information andan assessment of the error rate will continue to be\nreported.\nConclusion\nOverall, the IRS experienced a successful 1998 filing\nseason for the 941 TeleFile Program. Returns wereaccurately processed and approximately 94 percent ofthe business taxpayers attempting to file electronicallythrough the 941 TeleFile System were successful.Improving the marketing and customer service processeswill increase assurances that more of the eligible filerswill use the 941 TeleFile Program in the future. Inaddition, improvements to the 941 TeleFile System willprevent taxpayers from filing multiple returns and willimprove the process for verifying the filing history andelectronic signatures of taxpayers using the 941 TeleFile\nSystem.The IRS is redesigning the\nreturn filing confirmation\nnumber to make it unique foreach taxpayer.\nNinety-four percent of the\nbusinesses that attempted touse the 941 TeleFile System in\nthe second quarter of calendar\nyear 1998 were successful. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 16Appendix I\nDetailed Objective, Scope, and Methodology\nThe overall objective of this audit was to evaluate the effectiveness of the Internal Revenue\nService’s (IRS) processes for ensuring that the 1998 941 TeleFile Program was successfully\nimplemented. To accomplish the overall objective, we conducted the following tests:\nI. Evaluated whether the IRS took appropriate actions to address the following\nissues identified in the prior review.\nA. Determined whether taxpayers were adequately identified by selecting a\nsample of 50 Employer’s Quarterly Federal Tax Return (Form 941)TeleFile returns to determine whether the taxpayer had to enter the correctamount in the security field (total third quarter Federal Tax Deposit\namount from the prior year) before being allowed to file.\nB. Determined whether only eligible taxpayers filed 941 TeleFile returns.\nII. Matched the Martinsburg Computing Center requirements for extracting\n1998 eligible 941 TeleFile businesses to the 1998 TeleFile package.\nIII. Reviewed 941 TeleFile returns filed for the second quarter of calendar year 1998\nto determine whether only eligible businesses filed.\nIV. Determined the effectiveness of the IRS’ processes for ensuring 941 TeleFile\nreturns were accurately processed and accounted for during the nationwide\nimplementation.\nA. Reviewed a sample of 114 Form 941 TeleFile returns filed for the second\nquarter of calendar year 1998 and determined whether taxpayer return\ninformation posted correctly to the Masterfile.\nB. Tracked the second quarter 941 TeleFile returns from the Tennessee\nComputing Center and Cincinnati Service Center Telefile Systems to the\nMasterfile.\nC. Evaluated the IRS’ efforts to verify the electronic signatures (Social\nSecurity Numbers and last name) used to sign the 941 TeleFile returns.\nV. Assessed publicity efforts for increasing the number of businesses who filed\n1998 returns using the 941 TeleFile Program.\nA. Evaluated the IRS’ efforts to market the 1998 941 TeleFile Program by\nreviewing marketing materials and interviewing project office employees. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 17B. Reviewed the 941 TeleFile Program customer feedback gathered in 1997\nand determined whether the IRS had an effective strategy to increase the\nnumber of filers.\nC. Determined whether the IRS provided adequate information to Customer\nService personnel to enable them to resolve 941 TeleFile Program\nproblems. The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 18Appendix II\nMajor Contributors to This Report\nScott E. Wilson, Associate Inspector General for Audit (Information Systems Programs)\nM. Susan Boehmer, DirectorNancy A. Nakamura, DirectorJames V. Westcott, Audit ManagerEdward Gorman, Senior AuditorJohn W. Baxter, AuditorGregory W. Holdeman, AuditorNancy L. Prather, AuditorSharon R. Shepherd, AuditorMichael R. Van Nevel, Auditor The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 19Appendix III\nReport Distribution List\nChief Operations Officer C:OP\nAssistant Commissioner (Electronic Tax Administration) OP:ETAAssistant Commissioner (Forms & Submission Processing) OP:FSAssistant Commissioner (Program Evaluation and Risk Analysis) M:OPNational Director, Electronic Program Operations OP:ETA:ONational Director, Tax Forms and Publications Divisions OP:FS:FPNational Director for Legislative Affairs CL:LAOffice of Management Controls M:CFO:A:M The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 20Appendix IV\nMemorandum #1 - Business Masterfile TeleFile 1998 Expansion\nOctober 2, 1998\nMEMORANDUM FOR NATIONAL DIRECTOR\nTAX FORMS AND PUBLICATIONS DIVISION OP:FS:FP\nFROM: (for) REGIONAL INSPECTOR\nSOUTHEAST REGION \nSUBJECT: BMF TeleFile 1998 Expansion – Internal Audit Memorandum #1\nThis memorandum is to advise you of an error in the fourth quarter 941 TeleFile\nInstructions that may adversely effect the number of taxpayers participating in the BMFTeleFile program. Although Internal Revenue Manual 1289 provides 30 workdays forresponding to an Internal Audit memorandum, we are requesting that you advise us of theaction you plan take in a written response within 10 workdays. This request is beingmade as a result of the time sensitivity of the issue. If you have any suggestions forimproving or clarifying this memorandum, please contact me or Audit Manager Jim\nWestcott at (606) 292-5162.\nInstructions to the BMF TeleFile package have not been updated to reflect program\nenhancements scheduled for the Telefile System in the fourth quarter.\nWe determined that the 941 TeleFile Tax packages have not been revised to show that the\n$500 balance due limit is no longer in effect. The Service is in the process of enhancingthe BMF TeleFile program to accept all balance due returns effective January 4, 1999.This change will eliminate the restriction for taxpayers who owe a balance due of $500 ormore. Previously, if a taxpayer attempted to file and had a balance due of $500 or morethey would receive a message indicating that their balance due exceeded the balance dueamount that TeleFile can accept and that the Service cannot continue with the processingof their return. Furthermore, taxpayers would be advised to file a paper return for thequarter.\nOur review showed that the TeleFile package instructions and the 941 TeleFile Tax\nRecord have not been revised to eliminate the balance due criteria of $500 or more. Line15 of the 941 TeleFile Tax Record incorrectly tells the taxpayer that if they owe a balancedue of $500 or more, they cannot use 941 TeleFile. This information is also included onPage TEL-1 of the tax package instructions. Modifications to the 941 TeleFile Programfor the fourth quarter eliminated the restriction of taxpayers who owe a balance due of The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 21$500 or more. The BMF TeleFile packages are scheduled to be mailed in December\n1998, for the fourth quarter.\nThis oversight to the instructions will cause taxpayers not to use the BMF TeleFile\nprogram. We estimate the Service plans to mail approximately 3.4 million 941TeleFilepackages for the fourth quarter. With the emphasis on customer service and on increasingthe number of taxpayers filing returns electronically, the Service cannot afford tooverlook issues that may impact these goals.\nRecommendation\nTo minimize losing potential taxpayers that are eligible to file 941 TeleFile, we\nrecommend that the fourth and subsequent quarter TeleFile tax packages, including the941 TeleFile Tax Record line 15, be revised by removing the reference to the $500balance due.\ncc:\nAssistant Commissioner (Electronic Tax Administration) OP:ETA\nNational Director, Electronic Program Operations OP:ETA:OAssistant Commissioner (Forms and Submission Processing) OP:FS The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 22Appendix V\nManagement's Response to Memorandum #1\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 23\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 24Appendix VI\nManagement's Response to the Draft Report\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 25\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 26\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 27\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 28\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 29\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 30\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 31\n The Internal Revenue Service Needs to Encourage Taxpayer Use, Improve\nCustomer Service, and Enhance Computer Controls of the 941 TeleFile Program\n Page 32\n"
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"pdf_file": "NM76DD2NN5OG5VHK5TQMZV3OO3T6UDAK.pdf",
"text": "51572 Federal Register / Vol. 68, No. 166 / Wednesday, August 27, 2003 / Notices \ninstructions on the Commission ’s Web \nsite under the ‘‘e-Filing ’’ link. \nComment Date: August 25, 2003.\nMagalie R. Salas, \nSecretary.\n[FR Doc. 03 –21899 Filed 8 –26–03; 8:45 am] \nBILLING CODE 6717 –01–P\nDEPARTMENT OF ENERGY\nFederal Energy Regulatory \nCommission \n[Docket No. RP03 –570–000] \nColorado Interstate Gas Company; \nNotice of Proposed Changes in FERC Gas Tariff \nAugust 20, 2003. \nTake notice that on August 15, 2003, \nColorado Interstate Gas Company (CIG) tendered for filing as part of its FERC Gas Tariff, First Revised Volume No. 1, First Revised Sheet No. 358A, bearing a proposed effective date of October 1, 2002. \nCIG states that the tendered tariff \nsheet adds a recently approved revenue crediting provision to the currently effective Tariff. \nAny person desiring to be heard or to \nprotest said filing should file a motion to intervene or a protest with the Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, in accordance with Sections 385.214 or 385.211 of the Commission ’s \nRules and Regulations. All such motions or protests must be filed in accordance with §154.210 of the Commission ’s \nRegulations. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceedings. Any person wishing to become a party must file a motion to intervene. This filing is available for \nreview at the Commission in the Public Reference Room or may be viewed on the Commission ’s Web site at http://\nwww.ferc.gov using the eLibrary \n(FERRIS) link. Enter the docket number excluding the last three digits in the docket number field to access the document. For assistance, please contact FERC Online Support at FERCOnlineSupport@ferc.gov or toll-\nfree at (866) 208 –3676, or TTY, contact \n(202) 502 –8659. The Commission \nstrongly encourages electronic filings. See 18 CFR 385.2001(a)(1)(iii) and the \ninstructions on the Commission ’s Web \nsite under the ‘‘e-Filing ’’ link. Comment Date: August 27, 2003.\nMagalie R. Salas, \nSecretary.[FR Doc. 03 –21900 Filed 8 –26–03; 8:45 am] \nBILLING CODE 6717 –01–P\nDEPARTMENT OF ENERGY\nFederal Energy Regulatory \nCommission \n[Docket Nos. RP00 –327–005, RP00 –604–\n005] \nColumbia Gas Transmission \nCorporation; Notice of Compliance Filing \nAugust 20, 2003. \nTake notice that on August 14, 2003, \nColumbia Gas Transmission Corporation (Columbia) tendered for filing as FERC Gas Tariff, Second Revised Volume No. 1, the tariff sheets listed on Appendix A to the filing, bearing a proposed effective date of September 1, 2003, and tariff sheets listed on Appendix B to the filing, bearing a proposed effective date of April 1, 2004. \nColumbia states it is making this filing \nin compliance with the Commission ’s \nJuly 30, 2003, Order in the above-referenced dockets. In the July 30 Order, the Commission held that Columbia ’s \nAugust 19, 2002, filing to comply with the Commission ’s July 19, 2002, order \non Columbia ’s compliance with Order \nNos. 637, 587 –G, and 587 –L generally \ncomplied with the requirements of those Orders. Columbia states however, the Commission required that Columbia make certain compliance changes by filing actual tariff sheets within 15 days of the date of issuance of the July 30 Order. The Commission directed Columbia that those tariff sheets should have a September 1, 2003, effective date. Columbia states that in addition, the Commission identified other compliance changes that were to have an effective date of April 1, 2004. Columbia further states that these revised tariff sheets reflect the changes required by the Commission in the July 30 Order. \nColumbia states that copies of its \nfiling have been mailed to all firm customers, interruptible customers and affected state commissions. \nAny person desiring to protest said \nfiling should file a protest with the Federal Energy Regulatory Commission, 888 First Street, NE., Washington, DC 20426, in accordance with §385.211 of \nthe Commission ’s Rules and \nRegulations. All such protests must be filed in accordance with §154.210 of the \nCommission ’s Regulations. Protests will be considered by the Commission in \ndetermining the appropriate action to be taken, but will not serve to make protestants parties to the proceedings. This filing is available for review at the Commission in the Public Reference Room or may be viewed on the Commission ’s Web site at http://\nwww.ferc.gov using the eLibrary \n(FERRIS) link. Enter the docket number excluding the last three digits in the docket number field to access the document. For assistance, please contact FERC Online Support at FERCOnlineSupport@ferc.gov or toll-\nfree at (866) 208 –3676, or TTY, contact \n(202) 502 –8659. The Commission \nstrongly encourages electronic filings. See 18 CFR 385.2001(a)(1)(iii) and the \ninstructions on the Commission ’s Web \nsite under the ‘‘e-Filing ’’ link. \nProtest Date: August 26, 2003.\nMagalie R. Salas, \nSecretary.[FR Doc. 03 –21890 Filed 8 –26–03; 8:45 am] \nBILLING CODE 6717 –01–P\nDEPARTMENT OF ENERGY\nFederal Energy Regulatory \nCommission \n[Docket Nos. ER03 –1088–000] \nDirect Energy Marketing Inc.; Notice of \nIssuance of Order \nAugust 20, 2003. \nDirect Energy Marketing Inc. (Direct \nEnergy) filed an application for market-based rate authority, with an accompanying tariff. The proposed tariff provides for wholesale sales of electric energy at market-based rates. Direct Energy also requested waiver of various Commission regulations. In particular, Direct Energy requested that the Commission grant blanket approval under 18 CFR part 34 of all future issuances of securities and assumptions of liability by Direct Energy. \nOn August 13, 2003, pursuant to \ndelegated authority, the Director, Division of Tariffs and Market Development —South, granted the \nrequest for blanket approval under part 34, subject to the following: \nAny person desiring to be heard or to \nprotest the blanket approval of issuances of securities or assumptions of liability by Direct Energy should file a motion to intervene or protest with the Federal Energy Regulatory Commission, 888 First Street, NE., Washington, DC 20426, in accordance with Rules 211 and 214 of the Commission ’s Rules of \nPractice and Procedure (18 CFR 385.211 and 385.214). \nVerDate jul<14>2003 16:00 Aug 26, 2003 Jkt 200001 PO 00000 Frm 00024 Fmt 4703 Sfmt 4703 E:\\FR\\FM\\27AUN1.SGM 27AUN1"
} |
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] | {
"pdf_file": "U36BZP574S3IQ7SGZYCFBDLL7ZYAAG6I.pdf",
"text": "My OLD address was: \n(\"In care of\" other person, if any) \n(Number, Street, Apartment)\n(City, State and ZIPCode) \n(Country, if other than U.S.)My NEW address is: \n(\"In care of\" other person, if any) \n(Number, Street, Apartment) \n(City, State and ZIPCode) \n(Country,if other than U.S.) \n(New Telephone Number)Name: Alien Number: AAlien's Change of Address Form/ \nImmigration CourtU.S. Department of Justice \nExecutive Office for Immigration Review\nImmigration Court \nYou are required to notify the Executive Office for Immigration Review (EOIR) of any change of address and any change of telephone\nnumber within five (5) days of moving or changing your address or phone number. You will receive notification as to the time, date, andplace of hearing or other official correspondence only at the address which you provide. \nFailure to appearat any hearing before an Immigration Judge, when notice of that hearing orotherofficial correspondence\nwasserved on you orsent to the address you provided, may result in one ormore of the following actions:\n●If you are not already detained, you may be taken into custody by the DHS and held for further action; and\nIf you are in removalproceedings :\nYour hearing may be held in your\nabsence under Section 240 of the\nImmigration and Nationality Act (INA),and an order of removal may be entered\nagainst you. Furthermore, you may\nbecome ineligible for the followingforms of relief from removal for a period\nof 10 years after the date of the entry of\nthe final order: \n1. Voluntary Departure as provided\nfor in Section 240B of the INA; \n2. Cancellation of Removal as provided\nfor in Section 240Aof the INA; \n3. Adjustment of Status or Change of\nStatus as provided for in Section(s) \n245, 248, or 249 of the INA. If you are in \ndeportation proceedings :\nYour hearing may be held in your\nabsence under Section 242B of the\nImmigration and Nationality Act (INA)(1995), and an order of deportation may\nbe entered against you. Furthermore, you\nmay become ineligible for the followingforms of relief from deportation for a\nperiod of 5 years after the date of the\nentry of the final order: \n1. Voluntary Departure as provided\nfor in Section 242(b) of the INA\n(1995); \n2. Suspension of Deportation or Vol-\nuntary Departure as provided for in Section 244 of the INA (1995); \n3. Adjustment of Status or Change of\nStatus as provided for in Section(s)\n245, 248, or 249 of the INA(1995).If you are in \nexclusion proceedings :\nYour application for admission to the\nUnited States may be considered\nwithdrawn, and your hearing may beheld in your absence and an order of\nexclusion and deportation entered\nagainst you.\nPROOFOFSERVICE \n(You Must Complete This)\nI mailed or delivered a copy of this Change of Address Form on to the\nAssistant Chief Counsel for the DHS (U.S. Immigration and Customs Enforcement-ICE) at .✍SIGNHERE ➜➜\nSignature DateX\n✍SIGNHERE ➜➜\nSignatureX(Name) (Date)\n(Number and Street, City, State, Zip Code)\nForm EOIR - 33/IC\nRevised 8/06 Fold Here\nFold HereMAILING INSTRUCTIONS\n1) Fold the page at the dotted lines marked \"Fold Here\" so that the address is visible. \n(IMPORTANT: Make sure the address section is visible after folds are made.) \n2) Secure the folded form by stapling along the open end marked \"Fasten Here.\" 3) Place appropriate postage stamp in the area marked \"Place Stamp Here.\" 4) Write in your return address in the area marked \"PUT YOUR ADDRESS HERE.\" 5) Mail the form. \nU.S. Depar tment of Justice\nImmigration Court\n1900 E. Whatley Road\nOakdale, Louisiana 71463Place\nStamp\nHere\nFasten HereUnder the Paperwork Reduction Act, a person is not required to respond to a collection of information unless it displays a valid OMB control number.\nWe try to create forms and instructions that are accurate, can be easily understood, and which impose the least possible burden on you to provide us with\ninformation. The estimated average time to complete this form is three (3) minutes. If you have comments regarding the accuracy of this estimate, or suggestions for\nmaking this form simpler, you can write to the Executive Office for Immigration Review, Office of the General Counsel, 5107 Leesburg Pike, Suite 2600, Falls Church,\nVirginia 22041 . \nPUTYOUR ADDRESS HERE\nForm EOIR - 33/IC\nRevised 8/06"
} |
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"pdf_file": "NG33GO534UD2QX6Z7DBE7KHLGNGIEU4R.pdf",
"text": "53495 Federal Register / Vol. 72, No. 181 / Wednesday, September 19, 2007 / Proposed Rules \nunder Executive Order 13132. This \nproposed AD would not have a substantial direct effect on the States, on the relationship between the national Government and the States, or on the distribution of power and responsibilities among the various levels of government. \nFor the reasons discussed above, I \ncertify this proposed regulation: \n1. Is not a ‘‘significant regulatory \naction ’’ under Executive Order 12866; \n2. Is not a ‘‘significant rule ’’ under the \nDOT Regulatory Policies and Procedures (44 FR 11034, February 26, 1979); and \n3. Will not have a significant \neconomic impact, positive or negative, on a substantial number of small entities under the criteria of the Regulatory Flexibility Act. \nWe prepared a regulatory evaluation \nof the estimated costs to comply with this proposed AD and placed it in the AD docket. \nList of Subjects in 14 CFR Part 39 \nAir transportation, Aircraft, Aviation \nsafety, Safety. \nThe Proposed Amendment \nAccordingly, under the authority \ndelegated to me by the Administrator, the FAA proposes to amend 14 CFR part 39 as follows: \nPART 39 —AIRWORTHINESS \nDIRECTIVES \n1. The authority citation for part 39 \ncontinues to read as follows: \nAuthority: 49 U.S.C. 106(g), 40113, 44701. \n§39.13 [Amended] \n2. The FAA amends §39.13 by adding \nthe following new AD: \nGrob-Werke Gmbh & Co Kg: Docket No. \nFAA –2007 –28670; Directorate Identifier \n2007 –CE–060–AD. \nComments Due Date \n(a) We must receive comments by October \n19, 2007. \nAffected ADs \n(b) None. \nApplicability \n(c) This AD applies to the gliders Model \nG102 CLUB ASTIR III, serial numbers (SNs) 5501 (suffix C) through 5652 (suffix C); Model G102 CLUB ASTIR IIIb, SNs 5501 (suffix Cb) through 5652 (suffix Cb); and Model G102 STANDARD ASTIR III, SNs \n5501 (suffix S) through 5652 (suffix S), that are certificated in any category. \nSubject \n(d) Air Transport Association of America \n(ATA) Code 27: Flight Controls. \nReason \n(e) The mandatory continuing \nairworthiness information (MCAI) states: GROB received isolated difficulty reports \nregarding cracks on welded parts of the flight control system of the type G102, model CLUB ASTIR III & IIIb, and STANDARD ASTIR III. The cracks progress slowly from the welding seams periphery, and may eventually result in rupture at a matured stage. \nThe MCAI requires all welded parts to be \ninspected and replaced if any cracks are found. \nActions and Compliance \n(f) Unless already done, do the following \nactions: \n(1) Within the next 25 hours time-in- \nservice (TIS) after the effective date of this AD or within the next 6 calendar months after the effective date of this AD, whichever occurs first, inspect the welded parts of the flight control system for any cracks, deformations, or distortions following Grob Aerospace Service Bulletin No. MSB 306 –35, \ndated April 27, 2007. Thereafter, repetitively inspect at intervals not to exceed 12 calendar months. \n(2) If you find any cracks, deformations, or \ndistortions as a result of any inspection required by paragraph (e)(1) of this AD, before further flight, replace the affected part following Grob Aerospace Service Bulletin No. MSB 306 –35, dated April 27, 2007. \nFAA AD Differences \nNote: This AD differs from the MCAI and/ \nor service information as follows: No differences. \nOther FAA AD Provisions \n(g) The following provisions also apply to \nthis AD: \n(1) Alternative Methods of Compliance \n(AMOCs): The Manager, Standards Office, FAA, has the authority to approve AMOCs for this AD, if requested using the procedures \nfound in 14 CFR 39.19. Send information to ATTN: Greg Davison, Glider Program Manager, FAA, Small Airplane Directorate, 901 Locust, Room 301, Kansas City, Missouri 64106; telephone: (816) 329 –4130; fax: (816) \n329–4090. Before using any approved AMOC \non any airplane to which the AMOC applies, notify your appropriate principal inspector (PI) in the FAA Flight Standards District Office (FSDO), or lacking a PI, your local FSDO. \n(2) Airworthy Product: For any \nrequirement in this AD to obtain corrective actions from a manufacturer or other source, use these actions if they are FAA-approved. Corrective actions are considered FAA- approved if they are approved by the State of Design Authority (or their delegated agent). You are required to assure the product is airworthy before it is returned to service. \n(3) Reporting Requirements: For any \nreporting requirement in this AD, under the provisions of the Paperwork Reduction Act (44 U.S.C. 3501, et seq.), the Office of Management and Budget (OMB) has approved the information collection requirements and has assigned OMB Control Number 2120 –0056. \nRelated Information \n(h) Refer to MCAI European Aviation \nSafety Agency (EASA) Emergency AD No.: 2007 –0135 –E, dated May 14, 2007, and Grob \nAerospace Service Bulletin No. MSB 306 –35, \ndated April 27, 2007, for related information. \nIssued in Kansas City, Missouri, on \nSeptember 13, 2007. \nKim Smith, Manager, Small Airplane Directorate, Aircraft \nCertification Service. \n[FR Doc. E7 –18443 Filed 9 –18–07; 8:45 am] \nBILLING CODE 4910 –13–P \nDEPARTMENT OF TRANSPORTATION \nFederal Aviation Administration \n14 CFR Part 39 \n[Docket No. FAA –2007 –29226; Directorate \nIdentifier 2006 –NM–256–AD] \nRIN 2120 –AA64 \nAirworthiness Directives; McDonnell \nDouglas Model DC –9–81 (MD –81) and \nDC–9–82 (MD –82) Airplanes \nAGENCY : Federal Aviation \nAdministration (FAA), Department of Transportation (DOT). \nACTION : Notice of proposed rulemaking \n(NPRM). \nSUMMARY : The FAA proposes to adopt a \nnew airworthiness directive (AD) for certain McDonnell Douglas Model DC – \n9–81 (MD –81) and DC –9–82 (MD –82) \nairplanes. This proposed AD would require, for certain airplanes, inspecting for cracking of the fuselage skin at the upper corners of the forward passenger doorjamb, installing or replacing doublers as applicable, and doing applicable repairs. This proposed AD results from reports of fatigue cracking in the fuselage skin at the upper corners of the forward passenger doorjamb. We are proposing this AD to prevent cracking of the fuselage skin at the upper corners of the forward passenger doorjamb, which could lead to loss of overall structural integrity of the airplane. \nDATES : We must receive comments on \nthis proposed AD by November 5, 2007. \nADDRESSES : Use one of the following \naddresses to submit comments on this proposed AD. \n•DOT Docket Web site: Go to \nhttp://dms.dot.gov and follow the \ninstructions for sending your comments electronically. \n•Government-wide rulemaking Web \nsite: Go to http://www.regulations.gov \nand follow the instructions for sending your comments electronically. \n•Mail: U.S. Department of \nTransportation, Docket Operations, M – \n30, West Building Ground Floor, Room \nVerDate Aug<31>2005 16:41 Sep 18, 2007 Jkt 211001 PO 00000 Frm 00008 Fmt 4702 Sfmt 4702 E:\\FR\\FM\\19SEP1.SGM 19SEP1mstockstill on PROD1PC66 with PROPOSALS 53496 Federal Register / Vol. 72, No. 181 / Wednesday, September 19, 2007 / Proposed Rules \nW12 –140, 1200 New Jersey Avenue, SE., \nWashington, DC 20590. \n•Fax: (202) 493 –2251. \n•Hand Delivery: Room W12 –140 on \nthe ground floor of the West Building, 1200 New Jersey Avenue, SE., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. \nContact Boeing Commercial \nAirplanes, Long Beach Division, 3855 Lakewood Boulevard, Long Beach, California 90846, Attention: Data and Service Management, Dept. C1 –L5A \n(D800 –0024), for the service information \nidentified in this proposed AD. \nFOR FURTHER INFORMATION CONTACT : \nRoger Durbin, Aerospace Engineer, Airframe Branch, ANM –120L, FAA, Los \nAngeles Aircraft Certification Office, 3960 Paramount Boulevard, Lakewood, California 90712 –4137; telephone (562) \n627–5233; fax (562) 627 –5210. \nSUPPLEMENTARY INFORMATION : \nComments Invited \nWe invite you to submit any relevant \nwritten data, views, or arguments regarding this proposed AD. Send your comments to an address listed in the \nADDRESSES section. Include the docket \nnumber ‘‘FAA –2007 –29226; Directorate \nIdentifier 2006 –NM–256–AD’’ at the \nbeginning of your comments. We specifically invite comments on the overall regulatory, economic, environmental, and energy aspects of the proposed AD. We will consider all comments received by the closing date and may amend the proposed AD in light of those comments. \nWe will post all comments we \nreceive, without change, to http:// \ndms.dot.gov , including any personal \ninformation you provide. We will also post a report summarizing each substantive verbal contact with FAA personnel concerning this proposed AD. Using the search function of that Web site, anyone can find and read the comments in any of our dockets, including the name of the individual who sent the comment (or signed the comment on behalf of an association, business, labor union, etc.). You may review DOT ’s complete Privacy Act \nStatement in the Federal Register \npublished on April 11, 2000 (65 FR 19477 –78), or you may visit http:// \ndms.dot.gov . \nExamining the Docket \nYou may examine the AD docket on \nthe Internet at http://dms.dot.gov , or in \nperson at the Docket Operations office between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. The Docket Operations office (telephone (800) 647 –5527) is located on the \nground level of the West Building at the DOT street address stated in the \nADDRESSES section. Comments will be \navailable in the AD docket shortly after the Docket Management System receives them. \nDiscussion \nWe have received a report that fatigue \ncracking has been discovered in the fuselage skin at the upper corners of the forward passenger doorjamb on certain Model DC –9/MD –80 airplanes. This \ncondition, if not corrected, could lead to loss of overall structural integrity of the airplane. \nRelevant Service Information \nWe have reviewed Boeing Alert \nService Bulletin MD80 –53A298, dated \nAugust 1, 2006. The alert service bulletin describes procedures for a low- frequency eddy current (LFEC) or a high-frequency eddy current (HFEC) inspection, depending on airplane configuration, for cracking of the fuselage skin at the upper corners of the forward passenger doorjamb; and applicable corrective actions. The compliance time for the initial inspection is before accumulating 37,500 total flight cycles, or within 3,575 flight cycles (whichever is later). \nThe corrective actions include: \n•For Group 1, Configuration 1, \nairplanes on which no cracking is found: Either repeating the LFEC inspection at intervals of 3,575 flight cycles; or installing external aluminum doublers within 3,575 flight cycles after the last inspection, and doing an HFEC inspection within 28,000 flight cycles after doing the installation, and repetitively at 20,000-flight-cycle intervals. \n•For Group 1, Configuration 1, \nairplanes on which any crack is found that is 2.0 inches or shorter in length: Repair before further flight, and do an HFEC inspection within 28,000 flight cycles after the repair, and repetitively at 20,000-flight-cycle intervals. \n•For Group 1, Configuration 1, \nairplanes on which any crack is found that is longer than 2.0 inches; for Group 1, Configurations 2 and 3, airplanes on which any crack is found beyond the edge of the doublers; and for Group 1, Configuration 4, airplanes: Contact Boeing for repair instructions before further flight. \n•For Group 1, Configuration 2, \nairplanes on which no crack is found beyond the edge of the steel doublers: Replace existing steel doublers with aluminum doublers, and repair upper corners within 6,000 flight cycles after the initial inspection; and do an HFEC \ninspection within 28,000 flight cycles after the repair, and repetitively at 20,000-flight-cycle intervals. \n•For Group 1, Configuration 3, \nairplanes on which no cracks are found beyond the edge of the aluminum doublers: Repeat the HFEC inspection at 20,000-flight-cycle intervals. \nAccomplishing the actions specified \nin the service information is intended to adequately address the unsafe condition. \nFAA ’s Determination and Requirements \nof the Proposed AD \nWe have evaluated all pertinent \ninformation and identified an unsafe condition that is likely to exist or develop on other airplanes of this same type design. For this reason, we are proposing this AD, which would require accomplishing the actions specified in the service information described previously, except as discussed under ‘‘Differences Between Proposed AD and \nAlert Service Bulletin. ’’ \nDifferences Between Proposed AD and \nAlert Service Bulletin \nFor all airplanes, the alert service \nbulletin specifies to contact the manufacturer for instructions on how to repair certain conditions, but this proposed AD would require repairing those conditions in one of the following ways: \n•Using a method that we approve; or \n•Using data that meet the \ncertification basis of the airplane, and that have been approved by an Authorized Representative for the Boeing Commercial Airplanes Delegation Option Authorization Organization whom we have authorized to make those findings. \nFor airplane configuration 4: Where \nthe alert service bulletin specifies to contact the manufacturer for repair instructions before further flight, to avoid unnecessarily grounding airplanes, this proposed AD would require performing repairs within 90 days after the effective date of this proposed AD. \nCosts of Compliance \nThere are about 76 airplanes of the \naffected design in the worldwide fleet. This proposed AD would affect about 46 airplanes of U.S. registry. The following table provides the estimated costs for U.S. operators to comply with this proposed AD, at an average labor rate of $80 per work hour. The proposed actions vary depending upon the airplane configuration. \nVerDate Aug<31>2005 16:41 Sep 18, 2007 Jkt 211001 PO 00000 Frm 00009 Fmt 4702 Sfmt 4702 E:\\FR\\FM\\19SEP1.SGM 19SEP1mstockstill on PROD1PC66 with PROPOSALS 53497 Federal Register / Vol. 72, No. 181 / Wednesday, September 19, 2007 / Proposed Rules \nESTIMATED COSTS \nAction Work hours Parts Cost per airplane Fleet cost \nLFEC inspection ...................... 1 None needed .......................... $80, per inspection cycle ........ Up to $3,680, per inspection \ncycle. \nHFEC inspection ..................... 1 None needed .......................... $80, per inspection cycle ........ Up to $3,680, per i nspection \ncycle. \nAuthority for This Rulemaking \nTitle 49 of the United States Code \nspecifies the FAA ’s authority to issue \nrules on aviation safety. Subtitle I, Section 106, describes the authority of the FAA Administrator. Subtitle VII, Aviation Programs, describes in more detail the scope of the Agency ’s \nauthority. \nWe are issuing this rulemaking under \nthe authority described in Subtitle VII, Part A, Subpart III, Section 44701, ‘‘General requirements. ’’ Under that \nsection, Congress charges the FAA with promoting safe flight of civil aircraft in air commerce by prescribing regulations for practices, methods, and procedures the Administrator finds necessary for safety in air commerce. This regulation is within the scope of that authority because it addresses an unsafe condition that is likely to exist or develop on products identified in this rulemaking action. \nRegulatory Findings \nWe have determined that this \nproposed AD would not have federalism implications under Executive Order 13132. This proposed AD would not have a substantial direct effect on the States, on the relationship between the national Government and the States, or on the distribution of power and responsibilities among the various levels of government. \nFor the reasons discussed above, I \ncertify that the proposed regulation: \n1. Is not a ‘‘significant regulatory \naction ’’ under Executive Order 12866; \n2. Is not a ‘‘significant rule ’’ under the \nDOT Regulatory Policies and Procedures (44 FR 11034, February 26, 1979); and \n3. Will not have a significant \neconomic impact, positive or negative, on a substantial number of small entities under the criteria of the Regulatory Flexibility Act. \nWe prepared a regulatory evaluation \nof the estimated costs to comply with this proposed AD and placed it in the AD docket. See the \nADDRESSES section \nfor a location to examine the regulatory evaluation. \nList of Subjects in 14 CFR Part 39 \nAir transportation, Aircraft, Aviation \nsafety, Safety. The Proposed Amendment \nAccordingly, under the authority \ndelegated to me by the Administrator, the FAA proposes to amend 14 CFR part 39 as follows: \nPART 39 —AIRWORTHINESS \nDIRECTIVES \n1. The authority citation for part 39 \ncontinues to read as follows: \nAuthority: 49 U.S.C. 106(g), 40113, 44701. \n§39.13 [Amended] \n2. The Federal Aviation \nAdministration (FAA) amends §39.13 \nby adding the following new airworthiness directive (AD): \nMcDonnell Douglas: Docket No. FAA –2007 – \n29226; Directorate Identifier 2006 –NM– \n256–AD. \nComments Due Date \n(a) The FAA must receive comments on \nthis AD action by November 5, 2007. \nAffected ADs \n(b) None. \nApplicability \n(c) This AD applies to McDonnell Douglas \nModel DC –9–81 (MD –81) and DC –9–82 (MD – \n82) airplanes; certificated in any category; as identified in Boeing Alert Service Bulletin MD80 –53A298, dated August 1, 2006. \nUnsafe Condition \n(d) This AD results from a report of fatigue \ncracking in the fuselage skin at the upper corners of the forward passenger doorjamb. We are issuing this AD to prevent cracking of the fuselage skin at the upper corners of the forward passenger doorjamb, which could lead to loss of overall structural integrity of the airplane. \nCompliance \n(e) You are responsible for having the \nactions required by this AD performed within the compliance times specified, unless the actions have already been done. \nRepetitive Inspections and Corrective \nActions for Configuration 1, 2, and 3 Airplanes \n(f) For airplanes identified as Configuration \n1, 2, or 3 in Boeing Alert Service Bulletin MD80 –53A298, dated August 1, 2006: At the \napplicable times specified in paragraph 1.E., ‘‘Compliance, ’’ of the alert service bulletin, \ndo a low-frequency eddy current (LFEC) or \nhigh-frequency eddy current (HFEC) inspection, as applicable, for cracking of the fuselage skin at the upper corners of the forward passenger doorjamb; and do all \napplicable corrective actions (repetitive inspections, installation of doublers, replacements, and repairs), except as \nprovided by paragraph (g) of this AD. Do the actions in accordance with the Accomplishment Instructions of the alert service bulletin. Where the alert service bulletin specifies a compliance time after the date on the service bulletin, this AD requires compliance within the specified compliance time after the effective date of this AD. \nRepair of Certain Conditions \n(g) If any crack is found during any \ninspection required by paragraph (f) of this AD and Boeing Alert Service Bulletin MD80 – \n53A298, dated August 1, 2006, specifies to contact Boeing for repair instructions: Before further flight, repair using a method approved in accordance with the procedures specified in paragraph (i) of this AD. \nCorrective Action for Configuration 4 \nAirplanes \n(h) For airplanes identified as \nConfiguration 4 in Boeing Alert Service Bulletin MD80 –53A298, dated August 1, \n2006: Within 90 days after the effective date of this AD, repair using a method approved in accordance with the procedures specified in paragraph (i) of this AD. \nAlternative Methods of Compliance \n(AMOCs) \n(i)(1) The Manager, Los Angeles Aircraft \nCertification Office (ACO), FAA, has the authority to approve AMOCs for this AD, if requested in accordance with the procedures found in 14 CFR 39.19. \n(2) To request a different method of \ncompliance or a different compliance time for this AD, follow the procedures in 14 CFR 39.19. Before using any approved AMOC on any airplane to which the AMOC applies, notify your appropriate principal inspector (PI) in the FAA Flight Standards District Office (FSDO), or lacking a PI, your local FSDO. \n(3) An AMOC that provides an acceptable \nlevel of safety may be used for any repair required by this AD, if it is approved by an Authorized Representative for the Boeing Commercial Airplanes Delegation Option Authorization Organization who has been authorized by the Manager, Los Angeles ACO, to make those findings. For a repair method to be approved, the repair must meet the certification basis of the airplane and 14 CFR 25.571, Amendment 45, and the approval must specifically refer to this AD. \nVerDate Aug<31>2005 16:41 Sep 18, 2007 Jkt 211001 PO 00000 Frm 00010 Fmt 4702 Sfmt 4702 E:\\FR\\FM\\19SEP1.SGM 19SEP1mstockstill on PROD1PC66 with PROPOSALS 53498 Federal Register / Vol. 72, No. 181 / Wednesday, September 19, 2007 / Proposed Rules \nIssued in Renton, Washington, on \nSeptember 10, 2007. \nAli Bahrami, Manager, Transport Airplane Directorate, \nAircraft Certification Service. \n[FR Doc. E7 –18447 Filed 9 –18–07; 8:45 am] \nBILLING CODE 4910 –13–P \nDEPARTMENT OF TRANSPORTATION \nFederal Aviation Administration \n14 CFR Part 39 \n[Docket No. FAA –2007 –29227; Directorate \nIdentifier 2007 –NM–100–AD] \nRIN 2120 –AA64 \nAirworthiness Directives; Boeing \nModel 747 –100, 747 –100B, 747 –100B \nSUD, 747 –200B, 747 –200C, 747 –300, \n747–400, 747 –400D, and 747SR Series \nAirplanes \nAGENCY : Federal Aviation \nAdministration (FAA), Department of Transportation (DOT). \nACTION : Notice of proposed rulemaking \n(NPRM). \nSUMMARY : The FAA proposes to adopt a \nnew airworthiness directive (AD) for certain Boeing Model 747 –100, 747 – \n100B, 747 –100B SUD, 747 –200B, 747 – \n200C, 747 –300, 747 –400, 747 –400D, and \n747SR series airplanes. For certain airplanes, this proposed AD would require a material type inspection to determine if the lower forward corner reveal of the number 3 main entry doors (MEDs) is a casting. If the reveals are castings, this proposed AD would require repetitive inspection of the \nreveals for cracking, and corrective action if necessary. If the reveals are not castings, this proposed AD would require a detailed inspection of the reveals for a sharp edge and repetitive inspection of the reveals for cracking, and corrective action if necessary. For certain other airplanes, this AD would require only a detailed inspection of the reveals for a sharp edge and repetitive inspection of the reveals for cracking, and corrective action if necessary. For certain other airplanes, this AD would require repetitive inspection of the reveals for cracking only, and corrective action if necessary. This proposed AD results from reports of cracking and/or a sharp edge in the lower forward corner reveal of the number 3 MEDs. We are proposing this AD to detect and correct fatigue cracking of the lower forward corner reveal of the number 3 MEDs, which could lead to the door escape slide departing from the airplane when the door is opened and the slide is deployed, and consequent injuries to passengers and crew using the door \nescape slide during an emergency evacuation. \nDATES : We must receive comments on \nthis proposed AD by November 5, 2007. \nADDRESSES : Use one of the following \naddresses to submit comments on this proposed AD. \n•DOT Docket Web site: Go to http:// \ndms.dot.gov and follow the instructions \nfor sending your comments electronically. \n•Government-wide rulemaking Web \nsite: Go to http://www.regulations.gov \nand follow the instructions for sending your comments electronically. \n•Mail: U.S. Department of \nTransportation, Docket Operations, M – \n30, West Building Ground Floor, Room W12 –140, 1200 New Jersey Avenue, SE., \nWashington, DC 20590. \n•Fax: (202) 493 –2251. \n•Hand Delivery: Room W12 –140 on \nthe ground floor of the West Building, 1200 New Jersey Avenue, SE., Washington, DC, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. \nContact Boeing Commercial \nAirplanes, P.O. Box 3707, Seattle, Washington 98124 –2207, for the service \ninformation identified in this proposed AD. \nFOR FURTHER INFORMATION CONTACT : Ivan \nLi, Aerospace Engineer, Airframe Branch, ANM –120S, FAA, Seattle \nAircraft Certification Office, 1601 Lind Avenue, SW., Renton, Washington 98057 –3356; telephone (425) 917 –6437; \nfax (425) 917 –6590. \nSUPPLEMENTARY INFORMATION : \nComments Invited \nWe invite you to submit any relevant \nwritten data, views, or arguments regarding this proposed AD. Send your comments to an address listed in the \nADDRESSES section. Include the docket \nnumber ‘‘FAA –2007 –29227; Directorate \nIdentifier 2007 –NM–100–AD’’ at the \nbeginning of your comments. We specifically invite comments on the overall regulatory, economic, environmental, and energy aspects of the proposed AD. We will consider all comments received by the closing date and may amend the proposed AD in light of those comments. \nWe will post all comments we \nreceive, without change, to http:// \ndms.dot.gov , including any personal \ninformation you provide. We will also post a report summarizing each substantive verbal contact with FAA personnel concerning this proposed AD. Using the search function of that Web site, anyone can find and read the comments in any of our dockets, including the name of the individual \nwho sent the comment (or signed the comment on behalf of an association, business, labor union, etc.). You may review DOT ’s complete Privacy Act \nStatement in the Federal Register \npublished on April 11, 2000 (65 FR 19477 –78), or you may visit http:// \ndms.dot.gov. \nExamining the Docket \nYou may examine the AD docket on \nthe Internet at http://dms.dot.gov, or in \nperson at the Docket Operations office between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. \nThe Docket Operations office (telephone (800) 647 –5527) is located on the \nground floor of the West Building at the DOT street address stated in the \nADDRESSES section. Comments will be \navailable in the AD docket shortly after the Docket Management System receives them. \nDiscussion \nOn June 30, 2004, we issued an \nNPRM, Docket No. FAA –2004 –18583, to \naddress the identified unsafe condition. That NPRM was prompted by reports from eight operators indicating that cracking of the lower forward corner reveal of the number 3 main entry doors (MEDs) was found on several Model 747 airplanes. Of the twelve reveals that were cracked, eleven were made of cast 356 aluminum and one was made of machined 6061 aluminum. The cause of the cracking of the reveals made of cast 356 aluminum is fatigue. The cause of the cracking of the reveal made of machined 6061 aluminum was a manufacturing defect, which led to fatigue cracking. \nSubsequent to issuing the NPRM, we \nhave been working with the manufacturer to ensure that the unsafe condition is adequately addressed and appropriate service instructions are available. We have also received new data showing other issues related to the unsafe condition. In addition to the comments received for that NPRM, the data include reports that forward corner reveals installed on certain airplanes have a ‘‘sharp edge ’’ detail at the \nforward edge, which could lead to fatigue cracking, and that additional airplanes are affected by the identified unsafe condition. We have determined from these data that the corrective actions proposed by that NPRM are inadequate for addressing the identified unsafe condition; therefore, we have withdrawn that NPRM and are issuing this new proposed AD. \nVerDate Aug<31>2005 16:41 Sep 18, 2007 Jkt 211001 PO 00000 Frm 00011 Fmt 4702 Sfmt 4702 E:\\FR\\FM\\19SEP1.SGM 19SEP1mstockstill on PROD1PC66 with PROPOSALS"
} |
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"text": "631Internal Revenue Service, Treasury §1.818 –2\nownership and co-ownership of land or\nimprovements thereon and leaseholdsof land or improvements thereon. Suchterm shall not, however, include min-eral, oil, or gas royalty interests, suchas a retained economic interest in coalor iron ore with respect to which thespecial provisions of section 631(c)apply. The term ‘‘interest in real prop-\nerty’’ also shall include options to ac-\nquire land or improvements thereon,and options to acquire leaseholds ofland or improvements thereon.\n(8) Interest in a commodity. The term\ninterest in a commodity shall include the\nownership and co-ownership of anytype of personal property other than asecurity, and any leaseholds thereof.Such term shall include mineral, oil,and gas royalty interests, includingany fractional undivided interesttherein. Such term also shall includeany put, call, straddle, option, or privi-lege on any type of personal propertyother than a security.\n(9) Value. The term value shall mean,\nwith respect to investments for whichmarket quotations are readily avail-able, the market value of such invest-ments; and with respect to other in-vestments, fair value as determined ingood faith by the managers of the seg-regated asset account.\n(10) Terms used in section 851. To the\nextent not inconsistent with this para-graph (h) all terms used in this sectionshall have the same meaning as whenused in section 851.\n(i) Effective date —(1) In general. This\nsection is effective for taxable yearsbeginning after December 31, 1983.\n(2) Exceptions. (i) If, at all times after\nDecember 31, 1983, an insurance com-pany would be considered the owner ofthe assets of a segregated asset ac-count under the principles of Rev. Rul.81–225, 1981 –2 C.B. 12, this section will\nnot apply to such account until Decem-ber 15, 1986.\n(ii) This section will not apply to any\nvariable contract to which Rev. Rul.77–85, 1977 –1 C.B. 12, or Rev. Rul. 81 –225,\n1981–2 C.B. 12, did not apply by reason\nof the limited retroactive effect of suchrulings.\n(iii) In determining whether a seg-\nregated asset account is adequately di-versified for any calendar quarter end-ing before July 1, 1988, debt instru-ments that are issued, guaranteed, or\ninsured by the United States or an in-strumentality of the United Statesshall not be treated as government se-curities if such debt instruments aresecured by a mortgage on real property(other than real property owned by theUnited States or an instrumentality ofthe United States) or represent an in-terest in a pool of debt instruments se-cured by such mortgages.\n(iv) This section shall not apply until\nJanuary 1, 1989, with respect to a vari-able contract (as defined in section817(d)) that (1) provides for the pay-ment of an immediate annuity (as de-fined in section 72(u)(4)); (2) was out-standing on September 12, 1986; and (3)the segregated asset account on whichit was based was, on September 12, 1986,wholly invested in deposits insured bythe Federal Deposit Insurance Corpora-tion or the Federal Savings and LoanInsurance Corporation.\n[T.D. 8242, 54 FR 8730, Mar. 2, 1989; T.D. 8242,\n54 FR 11866, Mar. 22, 1989]\n§1.818 –1 Taxable years affected.\nSections 1.818 –2 through 1.818 –8, ex-\ncept as otherwise provided therein, areapplicable only to taxable years begin-ning after December 31, 1957, and allreferences to sections of part I, sub-chapter L, chapter 1 of the Code are tothe Internal Revenue Code of 1954, asamended by the Life Insurance Com-pany Income Tax Act of 1959 (73 Stat.112).\n[T.D. 6558, 26 FR 2785, Apr. 4, 1961 as amended\nby T.D. 7469, 42 FR 12181, Mar. 3, 1977]\n§1.818 –2 Accounting provisions.\n(a) Method of accounting. (1) Section\n818(a)(1) provides the general rule thatall computations entering into the de-termination of taxes imposed by part I,subchapter L, chapter 1 of the Code,shall be made under an accrual methodof accounting. Thus, the over-all meth-od of accounting for life insurancecompanies shall be the accrual method.Except as otherwise provided in part I,the term ‘‘accrual method ’’ shall have\nthe same meaning and application insection 818 as it does under section 446(relating to general rule for methods ofaccounting) and the regulations there-under. For general rules relating to the\nVerDate 11<MAY>2000 01:46 Apr 14, 2001 Jkt 194087 PO 00000 Frm 00631 Fmt 8010 Sfmt 8010 Y:\\SGML\\194087T.XXX pfrm08 PsN: 194087T 63226 CFR Ch. I (4 –1–01 Edition) §1.818 –2\ntaxable year for inclusion of income\nand deduction of expenses under an ac-crual method of accounting, see sec-tions 451 and 461 and the regulationsthereunder.\n(2) Section 818(a)(2) provides that, to\nthe extent permitted under this sec-tion, a life insurance company ’s meth-\nod of accounting may be a combinationof the accrual method with any othermethod of accounting permitted bychapter 1 of the Internal Revenue Codeof 1954, other than the cash receiptsand disbursements method. Thus, sec-tion 818(a)(2) specifically prohibits theuse by a life insurance company of thecash receipts and disbursements meth-od either separately or in combinationwith a permissible method of account-ing. The term ‘‘method of accounting ’’\nincludes not only the over-all methodof accounting of the taxpayer but alsothe accounting treatment of any item.For purposes of section 818(a)(2), a lifeinsurance company may elect to com-pute its taxable income under an over-all method of accounting consisting ofthe accrual method combined with the\nspecial methods of accounting for par-ticular items of income and expenseprovided under other sections of chap-ter 1 of the Internal Revenue Code of1954, other than the cash receipts anddisbursements method. These methodsof accounting for special items includethe accounting treatment provided fordepreciation (section 167), research andexperimental expenditures (section174), soil and water conservation ex-penditures (section 175), organizationalexpenditures (section 248), etc. In addi-tion, a life insurance company may,where applicable, use the crop methodof accounting (as provided in the regu-lations under sections 61 and 162), andthe installment method of accountingfor sales of realty and casual sales ofpersonalty (as provided in section453(b)). To the extent not inconsistentwith the provisions of the InternalRevenue Code of 1954 or the regulationsthereunder and the method of account-ing adopted by the taxpayer pursuantto this section, all computations enter-ing into the determination of taxes im-posed by part I shall be made in a man-ner consistent with the manner re-quired for purposes of the annual state-ment approved by the National Asso-\nciation of Insurance Commissioners.\n(3)(i) An election to use any of the\nspecial methods of accounting referredto in subparagraph (2) of this para-graph which was made pursuant to anyprovisions of the Internal RevenueCode of 1954 or prior revenue laws forpurposes of determining a company ’s\ntax liabilities for prior years, shallhave the same force and effect in deter-mining the items of gross investmentincome under section 804(b) and theitems of deduction under section 804(c)of the Life Insurance Company IncomeTax Act of 1959 (73 Stat. 112) as if suchAct had not been enacted.\n(ii) For purposes of determining gain\nor loss from operations under section809(b), in computing the life insurancecompany ’s share of investment yield\nunder section 809(b) (1)(A) and (2)(A),an election with respect to any of thespecial methods of accounting referredto in subparagraph (2) of this para-graph which was made pursuant to anyprovision of the Internal Revenue Codeof 1954 or prior revenue laws, shall notbe affected in any way by the enact-ment of the Life Insurance CompanyIncome Tax Act of 1959 (73 Stat. 112).\n(iii) For purposes of determining gain\nor loss from operations under section809(b), in computing the items of grossamount under section 809(c) and the de-duction items under section 809(d), anelection to use any of the special meth-ods of accounting referred to in sub-paragraph (2) of this paragraph must bemade in accordance with the specificstatutory provisions of the sectionscontaining such elections and the regu-lations thereunder. However, where aparticular election may be made onlywith the consent of the Commissioner(either because the time for makingthe election without the consent of theCommissioner has expired or becausethe particular section contained noprovision for making an election with-out consent), and the time prescribedby the applicable regulations for sub-mitting a request for permission tomake such an election for the taxableyear 1958 has expired, a life insurancecompany may make such an electionfor the year 1958 at the time of filingits return for that year (including ex-tensions thereof). For example, a life\nVerDate 11<MAY>2000 01:46 Apr 14, 2001 Jkt 194087 PO 00000 Frm 00632 Fmt 8010 Sfmt 8010 Y:\\SGML\\194087T.XXX pfrm08 PsN: 194087T 633Internal Revenue Service, Treasury §1.818 –2\ninsurance company may elect any of\nthe methods of depreciation prescribedin section 167 (to the extent permittedunder that section and the regulationsthereunder) with respect to those as-sets, or any portion thereof, for whichno depreciation was allowable underprior revenue laws, for example, fur-niture and fixtures used in the under-writing department. Similarly, a lifeinsurance company shall be permittedto make an election under section461(c) (relating to the accrual of realproperty taxes) with respect to realproperty for which no deduction wasallowable under prior revenue laws.Any such election shall be made in themanner and form prescribed in the ap-plicable regulations.\n(iv) For purposes of subdivision (ii) of\nthis subparagraph, the method usedunder section 1016(a)(3)(C) (relating toadjustments to basis) in determiningthe amount of exhaustion, wear andtear, obsolescence, and amortizationactually sustained shall not preclude ataxpayer from electing any of themethods prescribed in section 167 in ac-cordance with the provisions of thatsection and the regulations thereunderfor determining the amount of such ex-haustion, wear and tear, obsolescence,and amortization for the year 1958. Forexample, if the amount of depreciationactually sustained, under section1016(a)(3)(C), on a life insurance com-pany ’s home office building (other than\nthat portion for which depreciationwas allowable under prior revenuelaws) is determined on the straight linemethod, the life insurance companymay elect for the year 1958 to use anyof the methods prescribed in section 167for determining its depreciation allow-ance for 1958. However, such electionshall be binding for 1958, and for allsubsequent taxable years, unless con-sent to change such election, if re-quired, is obtained from the Commis-sioner in accordance with the provi-sions of section 167 and the regulationsthereunder.\n(4)(i) For purposes of section\n805(b)(3)(B)(i) (relating to the deter-mination of the current earnings ratefor any taxable year beginning beforeJanuary 1, 1958), the determination forany year of the investment yield andthe assets shall be made as though thetaxpayer had been on the accrual\nmethod prescribed in subparagraph (1)of this paragraph for such year, or theaccrual method in combination withthe other methods of accounting pre-scribed in subparagraph (2) of thisparagraph, if these other methods ofaccounting are used by the taxpayer indetermining the investment yield andassets for the taxable year 1958. How-ever, where the method used for deter-mining the deduction under section 167for the year 1958 differs from the meth-od used in prior years, the amount ofthe deduction actually allowed or al-lowable for such prior years for pur-poses of section 1016(a)(2) (relating toadjustments to basis) shall be theamount to be taken into account in de-termining the current earnings rateunder section 805(b)(3)(B)(i).\n(ii) For purposes of section\n812(b)(1)(C) (relating to operations losscarrybacks and carryovers for yearsprior to 1958), the determination forthose years of the gain or loss from op-erations shall be made as though thetaxpayer had been on the accrualmethod of accounting prescribed insubparagraph (1) of this paragraph forsuch year, or the accrual method incombination with the other methods ofaccounting prescribed in subparagraph(2) of this paragraph, if these othermethods of accounting are used by thetaxpayer in the determination of gainor loss from operations for the taxableyear 1958. However, where any adjust-ment to basis is required under section1016(a)(3)(C) on account of exhaustion,wear and tear, obsolescence, amortiza-tion, and depletion sustained, theamount actually sustained as deter-mined under section 1016(a)(3)(C) foreach of the years involved shall be theamount allowed in the determinationof gain or loss from operations for pur-poses of section 812(b)(1)(C).\n(b) Adjustments required if accrual\nmethod of accounting was not used in1957. The items of gross amount taken\ninto account under section 809(c) andthe items of deductions allowed undersection 809(d) for the taxable year 1958shall be determined as though the tax-payer had been on the accrual methodof accounting prescribed in paragraph(a) of this section for all prior years.Thus, life insurance companies not on\nVerDate 11<MAY>2000 01:46 Apr 14, 2001 Jkt 194087 PO 00000 Frm 00633 Fmt 8010 Sfmt 8010 Y:\\SGML\\194087T.XXX pfrm08 PsN: 194087T 63426 CFR Ch. I (4 –1–01 Edition) §1.818 –2\nthe accrual method for the year 1957\nshall accrue, as of December 31, 1957,those items of gross amount whichwould have been properly taken intoaccount for the year 1957 if the com-pany had been on the accrual methoddescribed in section 818(a). Likewise,life insurance companies not on the ac-crual method for the year 1957 shall ac-crue, as of December 31, 1957, thoseitems of deductions which would havebeen properly allowed for the year 1957if the company had been on the accrualmethod described in section 818(a). Forexample, if certain premium amountswere received during the year 1958 butsuch amounts would have been prop-erly taken into account for the year1957 if the taxpayer had been on the ac-crual method for the year 1957, thenthe taxpayer will not be required totake such premium amounts into ac-count for the year 1958. If, for example,certain claims, benefits, and losseswere paid during the year 1958 but suchitems would have been properly takeninto account for the year 1957 if thetaxpayer had been on the accrualmethod for the year 1957, then the tax-payer will not be permitted to deductsuch expense items for the year 1958.For a special transitional rule applica-ble with respect to changes in methodof accounting required by section 818(a)and paragraph (a) of this section, seesection 818(e) and §1.818–6.\n(c) Change of basis in computing re-\nserves. (1) Section 806(b) provides that if\nthe basis for determining the amountof any item referred to in section 810(c)as of the close of the taxable year dif-fers from the basis for such determina-tion as of the beginning of the taxableyear, then for purposes of subpart B,part I, subchapter L, chapter 1 of theCode (relating to the determination oftaxable investment income), theamount of such item shall be theamount computed on the old basis as ofthe close of the taxable year and theamount computed on the new basis asof the beginning of the next taxableyear. Similarly, section 810(d)(1) pro-vides rules for determining the amountof the adjustment to be made for pur-poses of subpart C, part I, subchapterL, chapter 1 of the Code (relating tothe determination of gain or loss fromoperations), if the basis for deter-mining any item referred to in section\n810(c) as of the close of any taxableyear differs from the basis for such de-termination as of the close of the pre-ceding taxable year. Under an accrualmethod of accounting, a change in thebasis or method of computing the\namount of liability of any item re-ferred to in section 810(c) occurs in thetaxable year in which all the eventshave occurred which determine thechange in the basis or method of com-puting the amount of such liabilityand, in which, the amount thereof(whether increased or decreased) can bedetermined with reasonable accuracy.\n(2) The application of subparagraph\n(1) of this paragraph may be illustratedby the following examples:\nExample 1. Assume that during the taxable\nyear 1960, M, a life insurance company, de-termines that the amount of its life insur-ance reserves held with respect to a par-ticular block of contracts is understated onthe present basis being used in valuing suchliability and that such liability can be moreaccurately reflected by changing from thepresent basis to a particular new basis. As-sume that M uses such new basis in com-puting its reserves under such contracts atthe end of the taxable year 1960. Under theprovisions of section 818(a) and subparagraph(1) of this paragraph, the change in basis forpurposes of sections 806(b) and 810(d) occursduring the taxable year 1960, the year inwhich all the events have occurred which de-termine the change in basis and the amountof any increase (or decrease) attributable tosuch change can be determined with reason-able accuracy. Such change shall be treatedas having occurred during the taxable year1960 whether M determines that its liabilityunder such contracts was understated for thefirst time during 1960, or that its liabilityunder such contracts has, in fact, been un-derstated for a number of prior years.\nExample 2. Assume the facts are the same\nas in example 1, except that during the tax-able year 1960 the insurance department ofState X issues a ruling, pursuant to author-ity conferred by statute, requiring M to usethe particular new basis which more accu-rately reflects its liability with respect tosuch contracts and that as a result of suchruling, M uses the new basis in computing itsreserves under such contracts for the taxableyears 1958, 1959, and 1960. Under the provi-sions of section 818(a) and subparagraph (1)of this paragraph, the change in basis forpurposes of sections 806(b) and 810(d) occursduring the taxable year 1960, the year inwhich all the events have occurred which de-termine that a change in basis should be\nVerDate 11<MAY>2000 01:46 Apr 14, 2001 Jkt 194087 PO 00000 Frm 00634 Fmt 8010 Sfmt 8010 Y:\\SGML\\194087T.XXX pfrm08 PsN: 194087T 635Internal Revenue Service, Treasury §1.818 –3\nmade and the amount of any increase (or de-\ncrease) attributable to such change can bedetermined with reasonable accuracy.\n[T.D. 6558, 26 FR 2785, Apr. 4, 1961]\n§1.818 –3 Amortization of premium and\naccrual of discount.\n(a) In general. Section 818(b) provides\nthat the appropriate items of income,deductions, and adjustments underpart I, subchapter L, chapter 1 of theCode, shall be adjusted to reflect theappropriate amortization of premiumand the appropriate accrual of discounton bonds, notes, debentures, or otherevidences of indebtedness held by a lifeinsurance company. Such adjustmentsare limited to the amount of appro-priate amortization or accrual attrib-utable to the taxable year with respectto such securities which are not in de-fault as to principal or interest andwhich are amply secured. The questionof ample security will be resolved ac-cording to the rules laid down fromtime to time by the National Associa-tion of Insurance Commissioners. Theadjustment for amortization of pre-mium decreases the gross investmentincome, the exclusion and reduction forwholly tax-exempt interest, the exclu-sion and deduction for partially tax-ex-empt interest, and the basis or ad-justed basis of such securities. The ad-justment for accrual of discount in-creases the gross investment income,the exclusion and reduction for whollytax-exempt interest, the exclusion anddeduction for partially tax-exempt in-terest, and the basis or adjusted basisof such securities. However, for taxableyears beginning after May 31, 1960, onlythe accrual of discount relating toissue discount will increase the exclu-sion and reduction for wholly tax-ex-empt interest. See section 103.\n(b) Acquisitions before January 1, 1958.\n(1) In the case of any such security ac-quired before January 1, 1958, the pre-mium is the excess of its acquisitionvalue over its maturity value and thediscount is the excess of its maturityvalue over its acquisition value. Theacquisition value of any such securityis its cost (including buying commis-sions or brokerage but excluding anyamounts paid for accrued interest) ifpurchased for cash, or if not purchasedfor cash, its then fair market value.The maturity value of any such secu-\nrity is the amount payable thereundereither at the maturity date or an ear-lier call date. The earlier call date ofany such security may be the earliestinterest payment date if it is callableor payable at such date, the earliest\ndate at which it is callable at par, orsuch other call or payment date, priorto maturity, specified in the securityas may be selected by the life insur-ance company. A life insurance com-pany which adjusts amortization ofpremium or accrual of discount withreference to a particular call or pay-ment date must make the adjustmentswith reference to the value on suchdate and may not, after selecting suchdate, use a different call or paymentdate, or value, in the calculation ofsuch amortization or discount with re-spect to such security unless the secu-rity was not in fact called or paid onsuch selected date.\n(2) The adjustments for amortization\nof premium and accrual of discountwill be determined:\n(i) According to the method regularly\nemployed by the company, if suchmethod is reasonable, or\n(ii) According to the method pre-\nscribed by this section.\nA method of amortization of premium\nor accrual of discount will be deemed‘‘regularly employed ’’ by a life insur-\nance company if the method was con-sistently followed in prior taxableyears, or if, in the case of a companywhich has never before made such ad-justments, the company initiates inthe first taxable year for which the ad-justments are made a reasonable meth-od of amortization of premium or ac-crual of discount and consistently fol-lows such method thereafter. Ordi-narily, a company regularly employs amethod in accordance with the statuteof some State, Territory, or the Dis-trict of Columbia, in which it operates.\n(3) The method of amortization and\naccrual prescribed by this section is asfollows:\n(i) The premium (or discount) shall\nbe determined in accordance with thissection; and\n(ii) The appropriate amortization of\npremium (or accrual of discount) at-tributable to the taxable year shall bean amount which bears the same ratio\nVerDate 11<MAY>2000 01:46 Apr 14, 2001 Jkt 194087 PO 00000 Frm 00635 Fmt 8010 Sfmt 8010 Y:\\SGML\\194087T.XXX pfrm08 PsN: 194087T"
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] | {
"pdf_file": "37RZ6AARR76UDY2JH4LRVGQBIPYUQ2A2.pdf",
"text": "MONDAY, JANUARY 8, 2007 \n \n NO. 10 \n#23983 \n \n \nSTEVEN C. ANDERSON, Appellant, vs. SOUTH DAKOTA BOARD OF PARDONS AND PAROLES, Appellee. Mr. Michael J. Butler (FOR APPELLANT)\n \nButler Law Office, P.C. Attorney at Law 100 S Spring Avenue Ste 210 Sioux Falls SD 57104 Ph 331-4774 \nMr. Gary Campbell (FOR APPELLEE)\n \nAssistant Attorney General \n1302 E Hwy 14 Ste 1 Pierre SD 57501-8501 Ph 773-3215 \n \n \n \n \n \n \n NON ORAL "
} |
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"pdf_file": "HLGUA2TVCFAMJQDFC5IC43JBVUOFXDWB.pdf",
"text": "STARK STATEMENT ON HOUSE VOTE TO DEFUSE THE MEDICARE TRIGGERThursday, 24 July 2008\nRep. Pete Stark released the following remarks today after the House voted 231-184 to defuse the Medicare trigger for\nthis year.\r\n\r\n \r\n\r\n\r\nFOR IMMEDIATE RELEASE\n\r\n\r\nThursday, July 24, 2008\n\r\n\r\nCONTACT: Brian Cook, 202-225-3202\n\r\n\r\n\r\nSTARK STATEMENT ON HOUSE VOTE TO DEFUSE THE MEDICARE TRIGGER\n\r\n\r\n\r\nWASHINGTON, D.C. – Representative Pete Stark (D-CA), Chairman of the Ways and Means Health\nSubcommittee, released the following remarks today after the House voted 231-184 to defuse the Medicare trigger for\nthis year:\n\r\n\r\n“I want to thank my colleagues in the House for voting to turn off the Medicare trigger. We in Congress are the\nfiscal stewards of Medicare. In general, we’ve done well by the program over its lifetime, but there’s\nalways more to do. When we enacted the Medicare Improvements for Patients and Providers Act earlier this month, we\nactually met the fiscal objectives of this trigger. That bill passed with broad bipartisan support of 355-59 – a rare\nshow of unity in this Congress. The veto override was an even stronger 383-41.\n\r\n\r\n“The Congressional Budget Office has confirmed that both the new Medicare law and the President’s bill to\naddress the trigger would have the same effect regarding postponement of the threshold. \n\r\n\r\n“Frankly, I oppose the entire concept of the trigger. It is not sensible policy. It was dreamed up behind closed\ndoors by Republicans eager to pacify their conservative colleagues in 2003 when they moved forward with the Medicare\nprescription drug legislation. It is nothing more than a means to dismantle – not sustain – the Medicare\nprogram by ending its guaranteed funding. \n\r\n\r\n“We do NOT need an arbitrary, random number to tell us that we need to work together to ensure\nMedicare’s fiscal health. When testifying before the Ways and Means Committee earlier this year,\nMedicare’s Chief Actuary said, “I’m not aware of any specific technical rationale for” the\nnumber. \n\r\n\r\n“This is nothing more than a scare tactic designed by the Republicans to deliver a message to the public that\nMedicare’s going broke. Medicare is no more in danger of going broke that our defense department or any otherThe Online Office of Congressman Pete Stark\nhttp://www.stark.house.gov Powered by Joomla! Generated: 6 October, 2009, 23:36 governmental function. We have no such trigger in law for limiting defense spending – and I challenge any of my\nRepublican colleagues to support a trigger policy for defense.\n\r\n\r\n“Through the years, we have always acted – usually on a bipartisan basis -- to ensure Medicare’s\nfuture. That’s how we should continue to manage the program. \n\r\n\r\n“Putting my strong opinions on the trigger aside, this entire debate today is unnecessary. All this rule does is\noverride the process for the remainder of this Congress – and it does so for good reason.\n\r\n\r\n“Given the fact that the newly enacted Medicare law postpones the trigger threshold, I urge my colleagues on both\nsides of the aisle to join me in support of this rule change. That law was enacted with broad bipartisan support. This rule\nchange should as well.”\n\r\n\r\nBACKGROUND: Current law establishes three main sources of financing for Medicare: payroll taxes, general revenues,\nand beneficiary premiums. The Medicare Modernization Act created a new mechanism -- the “45 percent\ntrigger” -- to allegedly measure the adequacy of Medicare’s finances. The trigger looks at the amount of\nMedicare spending financed by general revenues.\n\r\n\r\nThe trigger is set in motion if the Medicare Trustees project, in two consecutive annual Trustees Reports, that funding\nfrom general revenues will exceed 45 percent of Medicare spending within a 7-year window. If so, a “Medicare\nfunding warning” is issued, setting in motion various processes. The President is required to submit legislation\nwithin 15 days of the submission of the next budget, and there are expedited procedures in the House and Senate for\nconsideration of legislation, which may be the President’s bill or another bill. Both the 2006 and 2007 Trustees\nreports projected general revenues would exceed the 45% threshold within the designated timeframe; thus, 2008 is the\nfirst year that the “trigger” is pulled, setting in motion a requirement for the President to submit legislation.\n\r\n\r\nIn order to meet the target threshold, legislation needs to cut benefits, provider payments, shift more of the burden to\nbeneficiaries in the form of higher cost-sharing, or rely more heavily on payroll taxes. The President sent such a bill to\nCongress. It proposed raising drug benefit premiums for 1.5 million beneficiaries (4.5 percent of total beneficiaries) in\n2009, growing to 3.7 million beneficiaries (8.0 percent) hit with higher costs by 2018. According to the Office of the\nActuary, more than 800,000 beneficiaries would drop out of the Administration’s drug program as a result of this\nproposal.\n\r\n\r\nThe House-passed CHAMP Act, which passed the House by a vote of 225-204, would have repealed the trigger. \nCHAMP’s provisions for reducing overpayments to private plans would also have extended Medicare’s\nsolvency.\n\r\n\r\nThe recently enacted Medicare Improvements for Patients and Providers Act (P.L. 110-235) will also extend\nMedicare’s solvency and will result in a one-year delay in when Medicare financing crosses the 45 percent\nthreshold. In fact, according to the Congressional Budget Office, its impact on Medicare financing is the same as to the\nPresident’s bill.\n\r\n\r\n# # #\n\r\n\r\nThe Online Office of Congressman Pete Stark\nhttp://www.stark.house.gov Powered by Joomla! Generated: 6 October, 2009, 23:36"
} |
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] | {
"pdf_file": "5LSCLZ4YEU5LZUAPARZB6QKKYSPSLW26.pdf",
"text": "Buchanan Announces Office Hours In Wauchula\n \nWashington, DC -- Congressman Vern Buchanan announced today that a member of his staff\nwill hold open office hours in January. Constituents with questions, comments, or concerns\nregarding a federal matter are encouraged to attend open office hours to share their views or\nseek assistance. Buchanan’s field representative, Kirstin Minor will be available to meet with\narea residents:\n \nTuesday, January 15, 2007\n11:00 a.m. to 1:00 p.m. \n412 West Orange Street, Room 202\nWauchula, Florida 33873\n \nFor additional information, please call Kirstin at (941) 747-9081.\n 1 / 1"
} |
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"pdf_file": "KWPQYSUTIEVQHMZBL2UDE4OKV53YYSG3.pdf",
"text": "IN THE UNITED STATES COURT OF APPEALS \nFOR THE FIFTH CIRCUIT \n \n \nNo. 14 -50358 \nSummary Calendar \n \n \nUNITED STATES OF AMERICA, \n \nPlaintiff - Appellee \n \nv. \n \nJOSE RAUL BRUNO-SANDOVAL , \n \nDefendant - Appellant \n \n \nAppeal from the United States District Court \nfor the Western District of Texas \nUSDC No. 2:13 -CR- 929-1 \n \nBefore SMITH, BARKSDALE, and PRADO, Circuit Judges. \nPER CURIAM:\n* \n In contesting his 52-month within-advisory Sentencing Guidelines-\nsentence, imposed following his conviction for illegal reentry, in violation of 8 \nU.S.C. §§ 1326(a) & 1326(b)(1)(2), Jose Raul Bruno-Sandoval challenges the \nsubstantive reasonableness of his sentence, asserti ng it is greater than \nnecessary to accomplish the sentencing objectives of 1 8 U.S.C. § 3553(a). In \nsupport, he contends the district court’s application of Guideline § 2L1.2 (the \n* Pursuant to 5 th Cir. R. 47.5, the court has determined that this opinion should not \nbe published and is not precedent except under the limited circumstances set forth in 5 th Cir. \nR. 47.5.4. United States Court of Appeals \nFifth Circuit \nFILED \nJanuary 6, 2015 \n \nLyle W. Cayce \nClerk \n Case: 14-50358 Document: 00512890316 Page: 1 Date Filed: 01/06/2015 No. 14 -50358 \nillegal reentry G uideline) double-counts his prior conviction and fails to \naccount for the nonviolent nature of his offense, which he describes as an \n“international trespass”. Bruno also asserts the district court failed to account \nfor his personal circumstances and the circumstances of this offense. In that \nregard, he stat es he returned to the United States for family reasons. \n Although , at sentencing, Bruno objected to the substantive reason-\nableness of his sentence, subject to review for abuse of discretion, Gall v. \nUnited States, 552 U.S. 38, 51 (2007), he claims, for the first time on appeal, \nthat his sentence is substantively unreasonable as a result of Guideline \n§ 2L1.2. Therefore , regarding § 2L1.2, review is only for plain error. E.g., \nUnited States v. Rodriguez, 15 F.3d 408, 414 (5th Cir. 1994 ). Under that \nstandard, Bruno must show a forfeited plain (clear or obvious) error that \naffected his substantial rights. Puckett v. United States, 556 U.S. 129, 135 \n(2009). If he does so, we have the discretion to correct the error, but should do \nso only if it seriousl y affects the fairness, integrity, or public reputation of the \nproceedings. Id. Nevertheless, regardless of whether review is for plain error \nor abuse of discretion, Bruno has identified no reversible error. \nBruno acknowledges his challenge to Guideline § 2L1.2 is foreclosed; he \nraises it only to preserve it for possible future review. E.g., United States v. \nMondragon-Santiago, 564 F.3d 357, 366 -367 (5th Cir. 2009). Our court has \nalso rejected his “double-counting” claim. E.g., United States v. Duarte, 569 \nF.3d 528, 529-31 (5th Cir. 2009). Similarly, our court is un persuaded by the \ncontention that the Guidelines fail to account for the nonviolent nature of an \nillegal reentry offense. E.g., United States v. Aguirre-Villa, 460 F.3d 681, 683 \n(5th Cir. 2006). \n The district court considered Bruno ’s request for a lesser sentence but \nfound that a sentence in the middle of the Guidelines -sentencing range was \n2 Case: 14-50358 Document: 00512890316 Page: 2 Date Filed: 01/06/2015 No. 14 -50358 \nappropriate. His contentions regarding mitigating factors and benign motive \ndo not rebut the presumption of reasonableness. E.g., United States v. Cooks, \n589 F.3d 173, 186 (5th Cir. 2009); United States v. Gomez- Herrera , 523 F.3d \n554, 565 -66 (5th Cir. 2008). \n AFFIRMED. \n3 Case: 14-50358 Document: 00512890316 Page: 3 Date Filed: 01/06/2015"
} |
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"pdf_file": "QLBRTJBPTEPSW266VK6E34FMP47KXTDL.pdf",
"text": "Are you helping someone with Medicare compare \ndrug discount cards? Start Here.\nSTEP 1: Know the Basics\n•What? T wo new options for people with Medicare: (1) Medicare-approved drug discount cards \nand (2) a $600 credit to pay for prescriptions.\nWho? Cards are for anyone with Medicare, except people who already have drug coverage from \nMedicaid. The $600 credit is for people with a card who have lower incomes.\nWhen? Enrollment starts May 2004. Cards can be used as early as June 2004. Program lasts until \nDecember 31, 2005.\nWhy? To save money on prescription drugs.\nHow? People with Medicare compare discount cards with a Medicare-approved seal on them, \nwhich are offered by private companies. They can choose a card that offers the best discounts on the drugs they need. Cost for enrolling varies by card, but is no more than $30 per year. If eligiblefor the $600 credit, enrolling is free.\nSTEP 2: Get Personal\nFill out the information on the back of this sheet, paying special attention to the tips. If the person isn’t ableto answer some of the questions, give him or her time to gather the information before moving on to Step 3.\nSTEP 3: Find Card Options\nIf you have access to a computer, go to www.medicare.gov and click on “Prescription Drug and OtherAssistance Programs.” Use the information you collected on the back of this sheet to answer the questions and learn about the drug discount cards (and other options) that are available to the person youare helping. If you don’t have a computer, call 1-800-MEDICARE (1-800-633-4227) instead. The opera-tor will walk you through these questions and mail you a list of options.\nSTEP 4: Compare Cards\nCompare what each card offers to find the one that best meets this person’s needs. Some things to consider:\n Look for the Medicare-approved seal. Keep in mind that a person can have only one Medicare-\napproved discount card. The $600 credit (if the person is eligible) can only be applied to a Medicare-approved discount card.\nIf the person needs multiple drugs, check total savings andsavings by drug. Sometimes the best \ncard won’t discount every drug the person needs, but could provide bigger discounts on his or her most expensive drugs. Generic alternatives for brand-name drugs might also provide the best savings.\nIf the person is loyal to a particular pharmacy, look for a card that includes that pharmacy.\nIf the person has addresses in more than one state or near a state border, look for a card with a \nnational service area.\nSTEP 5: Enroll in a Card\nOnce the person determines the best card, he or she will need to fill out an enrollment form. Enrollmentforms for Medicare-approved drug discount cards are available from the private company that offers thecard. If the person applies for the card and the $600 credit, he or she will need to mail or fax a copy of the enrollment form with a signature. Some plans are able to enroll people over the telephone.Medicare-Approved Drug Discount Card Tip Sheet Complete this sheet before comparing drug discount cards.\nThis isn’t an enrollment form.\nName of Person with Medicare _______________________________________\n(Must have Medicare to be eligible)\nOther Health Insurance (check all that apply)\n___Medicaid with drug coverage ___ TRICARE for Life\n___Veteran’s benefits ___ Employer group health plan\n___FEHBP (for federal employees/retirees) ___ Medigap plan H, I, or J\n___Indian Health Service benefits ___ Long-Term Care policy\n___State Prescription Assistance Program ___ PACE \n___Medicare Advantage plan (like a Medicare ___ Other \nmanaged care plan)\nTIP: If person has outpatient drug coverage from Medicaid, STOP HERE - not eligible for drug discount card.\nTIP: If person is enrolled in a Medicare managed care plan or other Medicare Advantage plan, STOP HERE\nand call that plan for guidance. Discount card options might be limited.\nZIP Code (primary address first, then others) ______________________________\nTIP: If person lives near a state border or in more than one state during the year, check for drug discount\ncards with NATIONAL service areas.\nCheck One: ___Married __ Single (includes widowed, divorced)\nIncome $________________ per month/ $ _________________ per year\n(if married, total income for both spouses)\nTIP: If annual income is $12,569 or less for singles or $16,862 or less for a married couple, person\nshould apply for a $600 credit on his or her drug discount card.\nPreferred Pharmacy: _____________________________________________\n(If the person is loyal to a specific pharmacy or location, write it above.)\nCurrent Prescriptions Used (list most expensive to least expensive)\nTIP: Generic alternatives might save money.\nDosage of \nprescription (ml, mg) Amount paid each\nmonthNumber of times a day\nprescription is taken Prescription name Personal Information Sheet\nCMS Pub. No. 11071"
} |
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"pdf_file": "LY6DBD3U5M6JGXFEYE54PAAMXND6XZ23.pdf",
"text": "Vendor Payment Summary\nFranklin CountyPage 1 of 1 1/2/2010 4:39:04PM\nFiscal Court\nContract Category Total Payments\n$23,030.00 1010000 : DIRECT PURCHASE\n$7,500.00 1020000 : APPRAISAL FEES\n$30,530.00 Vendor Total\nLouis & Henry Architects\nContract Category Total Payments\n$527,677.63 3010000 : ARCHITECT FEES PHASE A, B, C\n$44,900.00 3040000 : ARCHITECT FEES ADDITIONAL SERVICES\n$1,725.92 3050000 : ARCHITECT FEES REIMBURSEABLES\n$574,303.55 Vendor Total"
} |
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"pdf_file": "QCAENKSZWWWKYHPTET6HQGFKTLKEUTEO.pdf",
"text": "459 Environmental Protection Agency § 141.76 \n(E) Number of instances where the \nresidual disinfectant concentration is not measured and HPC is >500/ml; \n(F) For the current and previous \nmonth the system serves water to the public, the value of ‘‘V’’ in the following \nformula: \nVcde\nab=++\n+×100\nwhere: \na=the value in paragraph (b)(2)(iii)(A) of this \nsection, \nb=the value in paragraph (b)(2)(iii)(B) of this \nsection, \nc=the value in paragraph (b)(2)(iii)(C) of this \nsection, \nd=the value in paragraph (b)(2)(iii)(D) of this \nsection, and \ne=the value in paragraph (b)(2)(iii)(E) of this \nsection. \n(G) If the State determines, based on \nsite-specific considerations, that a sys-tem has no means for having a sample transported and analyzed for HPC by a certified laboratory within the req-uisite time and temperature conditions specified by §141.74(a)(3) and that the system is providing adequate disinfec-tion in the distribution system, the re-quirements of paragraph (b)(2)(iii) (A)– (F) of this section do not apply. \n(iv) A system need not report the \ndata listed in paragraph (b)(2)(i) of this section if all data listed in paragraphs (b)(2) (i)–(iii) of this section remain on file at the system and the State deter-mines that the system has submitted all the information required by para-graphs (b)(2) (i)–(iii) of this section for at least 12 months. \n(3)(i) Each system, upon discovering \nthat a waterborne disease outbreak po-tentially attributable to that water system has occurred, must report that occurrence to the State as soon as pos-sible, but no later than by the end of the next business day. \n(ii) If at any time the turbidity ex-\nceeds 5 NTU, the system must consult with the primacy agency as soon as practical, but no later than 24 hours after the exceedance is known, in ac-cordance with the public notification requirements under §141.203(b)(3). \n(iii) If at any time the residual falls \nbelow 0.2 mg/l in the water entering the distribution system, the system must notify the State as soon as possible, but no later than by the end of the next \nbusiness day. The system also must no-tify the State by the end of the next business day whether or not the resid-ual was restored to at least 0.2 mg/l within 4 hours. \n[54 FR 27527, June 29, 1989, as amended at 65 \nFR 26022, May 4, 2000] \nEFFECTIVE DATENOTE: At 69 FR 38856, June \n29, 2004, §141.75 was amended in paragraph (a)(2)(viii)(G) by removing the citation ‘‘§141.74(a)(3) ’’ and adding in its place \n‘‘§141.74(a)(1) ’’, and in paragraph (b)(2)(iii)(G) \nby removing the citation ‘‘§141.74(a)(3) ’’ and \nadding in its place ‘‘§141.74(a)(1) ’’, effective \nJuly 29, 2004. \n§ 141.76 Recycle provisions. \n(a) Applicability. All subpart H sys-\ntems that employ conventional filtra-tion or direct filtration treatment and that recycle spent filter backwash water, thickener supernatant, or liq-uids from dewatering processes must meet the requirements in paragraphs (b) through (d) of this section. \n(b) Reporting. A system must notify \nthe State in writing by Decemeber 8, 2003, if the system recycles spent filter backwash water, thickener super-natant, or liquids from dewatering processes. This notification must in-clude, at a minimum, the information specified in paragraphs (b)(1) and (2) of this section. \n(1) A plant schematic showing the or-\nigin of all flows which are recycled (in-cluding, but not limited to, spent filter backwash water, thickener super-natant, and liquids from dewatering processes), the hydraulic conveyance used to transport them, and the loca-tion where they are re-introduced back into the treatment plant. \n(2) Typical recycle flow in gallons per \nminute (gpm), the highest observed plant flow experienced in the previous year (gpm), design flow for the treat-ment plant (gpm), and State-approved operating capacity for the plant where the State has made such determina-tions. \n(c) Treatment technique requirement. \nAny system that recycles spent filter backwash water, thickener super-natant, or liquids from dewatering processes must return these flows through the processes of a system’s ex-isting conventional or direct filtration \nVerDate May<21>2004 03:50 Aug 06, 2004 Jkt 203160 PO 00000 Frm 00459 Fmt 8010 Sfmt 8002 Y:\\SGML\\203160T.XXX 203160T\nEC15NO91.137</MATH> 460 40 CFR Ch. I (7–1–04 Edition) § 141.80 \nsystem as defined in §141.2 or at an al-\nternate location approved by the State by June 8, 2004. If capital improve-ments are required to modify the recy-cle location to meet this requirement, all capital improvements must be com-pleted no later than June 8, 2006. \n(d) Recordkeeping. The system must \ncollect and retain on file recycle flow information specified in paragraphs (d)(1) through (6) of this section for re-view and evaluation by the State be-ginning June 8, 2004. \n(1) Copy of the recycle notification \nand information submitted to the State under paragraph (b) of this sec-tion. \n(2) List of all recycle flows and the \nfrequency with which they are re-turned. \n(3) Average and maximum backwash \nflow rate through the filters and the average and maximum duration of the filter backwash process in minutes. \n(4) Typical filter run length and a \nwritten summary of how filter run length is determined. \n(5) The type of treatment provided \nfor the recycle flow. \n(6) Data on the physical dimensions \nof the equalization and/or treatment units, typical and maximum hydraulic loading rates, type of treatment chemi-cals used and average dose and fre-quency of use, and frequency at which solids are removed, if applicable. \n[66 FR 31103, June 8, 2001] \nSubpart I—Control of Lead and \nCopper \nSOURCE : 56 FR 26548, June 7, 1991, unless \notherwise noted. \n§ 141.80 General requirements. \n(a) Applicability and effective dates. (1) \nThe requirements of this subpart I con-stitute the national primary drinking water regulations for lead and copper. Unless otherwise indicated, each of the provisions of this subpart applies to community water systems and non- transient, non-community water sys-tems (hereinafter referred to as ‘‘water \nsystems ’’ or ‘‘systems ’’). \n(2) The requirements set forth in \n§§141.86 to 141.91 shall take effect on July 7, 1991. The requirements set forth in §§141.80 to 141.85 shall take effect on \nDecember 7, 1992. \n(b) Scope. These regulations establish \na treatment technique that includes re-quirements for corrosion control treat-ment, source water treatment, lead service line replacement, and public education. These requirements are triggered, in some cases, by lead and copper action levels measured in sam-ples collected at consumers’ taps. \n(c) Lead and copper action levels. (1) \nThe lead action level is exceeded if the concentration of lead in more than 10 percent of tap water samples collected during any monitoring period con-ducted in accordance with §141.86 is greater than 0.015 mg/L (i.e., if the ‘‘90th percentile ’’ lead level is greater \nthan 0.015 mg/L). \n(2) The copper action level is exceed-\ned if the concentration of copper in more than 10 percent of tap water sam-ples collected during any monitoring \nperiod conducted in accordance with §141.86 is greater than 1.3 mg/L (i.e., if the ‘‘90th percentile ’’ copper level is \ngreater than 1.3 mg/L). \n(3) The 90th percentile lead and cop-\nper levels shall be computed as follows: \n(i) The results of all lead or copper \nsamples taken during a monitoring pe-riod shall be placed in ascending order from the sample with the lowest con-centration to the sample with the high-est concentration. Each sampling re-sult shall be assigned a number, as-cending by single integers beginning with the number 1 for the sample with the lowest contaminant level. The number assigned to the sample with the highest contaminant level shall be equal to the total number of samples taken. \n(ii) The number of samples taken \nduring the monitoring period shall be multiplied by 0.9. \n(iii) The contaminant concentration \nin the numbered sample yielded by the calculation in paragraph (c)(3)(ii) is the 90th percentile contaminant level. \n(iv) For water systems serving fewer \nthan 100 people that collect 5 samples per monitoring period, the 90th per-centile is computed by taking the aver-age of the highest and second highest concentrations. \nVerDate May<21>2004 03:50 Aug 06, 2004 Jkt 203160 PO 00000 Frm 00460 Fmt 8010 Sfmt 8002 Y:\\SGML\\203160T.XXX 203160T"
} |
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"pdf_file": "LFZ2QRA2LGRXD2XOPAY4WY36PZYT4IJ4.pdf",
"text": "This publication is available upon request in alternative accessible format(s).MISSOURI DEPARTMENT OF REVENUE\nMISSOURI INCOME\nPERCENTAGE1999\nFORM\nMO-NRI\nFEDERAL RETURN MUST BE ENCLOSED\n• If your home of record is Missouri or you had Missouri source income, complete this form onlyafter Form MO-1040, Lines 1 through 23 or Form MO-1040C, Lines 1\nthrough 14 are completed.\n• If you filed a joint federal return, you mustfile a combined Missouri return (even if only one of you had Missouri income) and complete each column below. Do not\ncombine Missouri source income for yourself and your spouse.\n• Military pay of a nonresident stationed in Missouri should not be included in Missouri source income.\n• If you are a nonresident stationed in Missouri or you moved into Missouri after December 31, 1999 and neither you nor your spo use had Missouri source income, check this\nbox and complete Part A and Part B below. You are not required to file a Missouri return. Sign Form MO-NRI on reverse side and se nd Form MO-NRI along with all Form\nW-2(s) to: Missouri Department of Revenue, P.O.Box 3900, Jefferson City, MO 65105-3900. Military personnel must enclose a Leave and Earnings Statement.\nPART A — CHECK YOUR STATUS ON EITHER LINE 1,LINE 2 OR LINE 3 BELOW.\nNAME OF YOURSELF OR ONE INCOME FILER NAME OF SPOUSE(ON A COMBINED RETURN)\nADDRESS ADDRESS\nCITY, STATE, ZIP CODE SOCIAL SECURITY NUMBER CITY, STATE, ZIP CODE SOCIAL SECURITY NUMBER\nWHAT WAS YOUR STATE OF RESIDENCE DURING 1999?\nPART B — MISSOURI INCOME PERCENTAGE\nYOURSELF OR SPOUSE (ON A\nONE INCOME FILER COMBINED RETURN)\n1.Missouri income — enter wages, salaries, etc.from Missouri. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 001 00\n2. Taxpayer’s total adjusted gross income (from Form MO-1040, Line 5 or Form MO-1040C, Line 3 or from\nyour federal form if you are a military nonresident and you are not required to file a Missouri return). . . . . . . 002 00\n3.MISSOURI INCOME PERCENTAGE (divide Line 1 by Line 2).If greater than 100%, enter 100%.\n(Round to a whole percent such as 91% instead of 90.5% and 90% instead of 90.4%.However, ifpercentage is less than 0.5%, use the exact percentage.) Enter percentage here and on Form MO-1040,Line 25 or Form MO-1040C, Line 16. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . % 3 %\nMO 860-1096 (11-99)1. NONRESIDENT OF MISSOURI\n2. PART-YEAR MISSOURI RESIDENT\na. INDICATE THE DATE YOU WERE A DATE FROM: DATE TO:\nMISSOURI RESIDENT IN 1999.\nb. INDICATE YOUR OTHER STATE OF DATE FROM: DATE TO:\nRESIDENCE AND THE DATE YOURESIDED THERE.\na.Missouri Domicile \nI did not at any time during the 1999 tax year maintain a permanent place ofabode in Missouri nor did I spend more than 30 days in Missouri during the year.I did maintain a permanent place of abode in the state of ____________________________________________.\nb.Non-Missouri Domicile \nI resided in Missouri during 1999 solely because I was stationed at ______________________________ on military orders, my home of record is in the state of________________________________.\nIf you qualified as a nonresident and you had no Missouri source income, enter0% on Form MO-NRI, Part B, Line 3 below, and on Form MO-1040, Line 25 orForm MO-1040C, Line 16. If you have wages in Missouri (other than militarypay), you must complete Part B and include your Missouri wages on Line 1. Ifyou are a military nonresident stationed in Missouri and neither you nor yourspouse had Missouri source income, enter 0 on Part B, Line 1 below and enteryour federal adjusted gross income on Part B, Line 2.WHAT WAS YOUR STATE OF RESIDENCE DURING 1999?1. NONRESIDENT OF MISSOURIDLNEnclosure Sequence No.1040-04\n3. MILITARY/NON-RESIDENT TAX STATUS — Indicate your tax status\nbelow and complete Part B—Missouri Income Percentage.2. PART-YEAR MISSOURI RESIDENT\na. INDICATE THE DATE YOU WERE A DATE FROM: DATE TO:\nMISSOURI RESIDENT IN 1999.\nb. INDICATE YOUR OTHER STATE OF DATE FROM: DATE TO:\nRESIDENCE AND THE DATE YOURESIDED THERE.\na.Missouri Domicile \nI did not at any time during the 1999 tax year maintain a permanent place ofabode in Missouri nor did I spend more than 30 days in Missouri during the year.I did maintain a permanent place of abode in the state of _____________________________________________.\nb.Non-Missouri Domicile \nI resided in Missouri during 1999 solely because I was stationed at _____________________________ on military orders, my home of record is in the state of________________________________.\nIf you qualified as a nonresident and you had no Missouri source income, enter0% on Form MO-NRI, Part B, Line 3 below, and on Form MO-1040, Line 25 orForm MO-1040C, Line 16. If you have wages in Missouri (other than militarypay), you must complete Part B and include your Missouri wages on Line 1. Ifyou are a military nonresident stationed in Missouri and neither you nor yourspouse had Missouri source income, enter 0 on Part B, Line 1 below and enteryour federal adjusted gross income on Part B, Line 2.3. MILITARY/NON-RESIDENT TAX STATUS — Indicate your tax status\nbelow and complete Part B—Missouri Income Percentage.\nComplete ONLY PART B,if income consists of only wages or salaries with no adjustments on Federal Form 1040A,\nLine 17 or Federal Form 1040,Line 32. Otherwise,complete Part C and then complete Part B. PARTC — WORKSHEET FOR MISSOURI SOURCE INCOME1999 FORM MO-NRI PAGE 2\nADJUSTED GR OSS INCOME\nCOMPUTATIONSFEDERAL\nFORM1040A\nLINE\nNO.FEDERAL\nFORM\n1040\nLINE\nNO.YOURSELF OR\nONE INCOME FILERSPOUSE (ON A\nCOMBINED RETURN)\nMISSOURI SOURCES MISSOURI SOURCES\nMO 860-1096 (11-99)A.Wages, salaries, tips, etc . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77A 00A 00\nB.Taxable interest income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8a8aB 00B 00\nC.Dividend income . . . . . . . . . . . . . . . . . . . . . ..................... 99C 00C 00\nD.State and local income tax refunds . . . . . . . . . . . . . . . . . . . . . . . . . none 10D 00D 00\nE.Alimony received . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 11E 00E 00\nF.Business income or (loss) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 12F 00F 00\nG.Capital gain or (loss) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 13G 00G 00\nH.Other gains or (losses) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 14H 00H 00\nI.Taxable IRA distr ibutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10b15bI 00I 00\nJ.Taxable pensions and ann uities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11b16bJ 00J 00\nK.Rents, royalties, partnerships,\nS corporations, trusts, etc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 17K 00K 00\nL.Farm income or (loss) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 18L 00L 00\nM.Unemployment compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1219M 00M 00\nN.Taxable social secur ity benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13b20bN 00N 00\nO.Other income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . none 21O 00O 00\nP.Total (add Lines A through O) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1422P 00P 00\nQ.Less:federal adjustments to\nincome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1732Q 00Q 00\nR.SUBTOTAL (Line P min us Line Q) If no modifications to income\nSTOP and ENTER this amount on re verse side, Part B, Line 1. . . . .1833R 00R 00\nS.Missouri modifications — additions to f ederal adjusted g ross income\n(from Form MO-1040, Line 2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S 00S 00\nT.Missouri modifications — subtr actions from f ederal adjusted\ngross income (from F orm MO-1040, Line 4 or F orm MO-1040C , Line 2) . . . . . . . . . . T 00T 00\nU.MISSOURI INCOME (Missouri sources) (Line R plus Line S , \nminus Line T)Enter this amount on re verse side,Part B,Line 1. . . . . . . . . . . . . . U 00U 00\nFrequently Asked Questions\n1.What are the f ederal line ref erences on the w orksheet used f or?\nYou must determine what por tion of each line on the f ederal return is Missour i Source Income .The federal line references will help y ou find the inf ormation needed on\nLines A through R.\n2.What is Missouri sour ce income and ho w do I determine the Missouri sour ce income f or myself and m y spouse?\nMissouri source income is the income ear ned in Missour i.It includes: (1) wages earned in Missour i;(2) income from b usiness, trade profession or occupation carr ied\non in Missour i;(3) income from real or tangib le personal proper ty in Missour i;and (4) interest, dividends and pension income receiv ed during the time y ou/your spouse\nwas a Missour i resident. You should use the schedule on page 6 of the F orm MO-1040C and on page 4 of the F orm MO-1040 to allocate y our income betw een you\nand your spouse .You should deter mine what por tion of each line on y our federal income tax retur n is Missour i source income f or yourself and y our spouse and enter\non the appropr iate line on the w orksheet abo ve.\n3.If I have only rental pr operty in Missouri, do I have to complete the Form MO-NRI?\nYES!!The amount of rental income receiv ed from a Missour i property is taxable to Missour i, if $600 or more .\n4.Should I enc lose a cop y of my federal return?\nYES!! A copy of your federal return is needed to v erify information and ma y prevent a delay in the processing of y our Missour i return.\n5.If I am in the militar y,stationed in Missouri, but my home of recor d is not Missouri and m y spouse had Missouri sour ce income ,is he/she required to\ncomplete the Form MO-NRI?\nYES! Both of you need to complete the F orm MO-NRI. If you had militar y income only , your Missour i income percentage w ould be 0 percent. If your spouse’ s\ntotal income w as Missour i source, 100 percent should be entered as the Missour i income percentage .As a nonresident of Missour i, any income from a Missour i\nsource (excluding militar y pay) will be tax ed by Missouri.The Form MO-NRI should be completed to indicate y our and your spouse’ s Missouri income percentage .\n6.If I have a Missouri domicile and I am stationed outside of Missouri, but my spouse remained in Missouri, do I have to pay Missouri tax on m y military\nincome?\nYES! 100 percent of y our military income and y our spouse’ s income w ould be taxab le to Missour i.\nUnder penalties of perjur y, I declare that I ha ve examined this f orm and to the best of m y knowledge and belief it is tr ue, correct and complete .Declaration of preparer (other than taxpa yer) is based on all inf ormation of\nwhich he/she has an y knowledge.As provided in Chapter 143, RSMo , a penalty of up to $500 shall be imposed on an y individual who files a fr ivolous retur n.\nYOUR SIGNA TURE DATE SPOUSE’S SIGNA TURE DATE"
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] | {
"pdf_file": "VIM7QYT5BTQU2DZ5YSODAFBLJFMZUPUY.pdf",
"text": " \nPage 1 of 1 307.070 Repealed, 1976. \nCatchline at repeal: Trustee's reliance on cemetery's certification. \nHistory: Repealed 1976 Ky. Act s ch. 294, sec. 12. -- Created 1960 Ky. Acts ch. 227, \nsec. 5, effective June 16, 1960. "
} |
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"pdf_file": "FPX7XMI7AP2GAD23QJNSAKAGCRPSZKTD.pdf",
"text": " \n It’s Cool to Be Safe Printed on Recycled Paper \n \n \n \nForest Service FY 2010 Guidance fo r Use of Incident Job Codes \nAttachment A – August, 2009 \n \n \nThe following direction and procedur es will be used to establis h and charge to wildland fire, \nseverity and support job codes in FY 2010: \nIncident job codes will have the region/unit override of the incide nt host unit. Incidents that \nqualify for a unique incident job code are as foll ows and will be established in the FireCode \nsystem: \n Wildfire incidents 300 acres or more \n Type 1 or Type 2 IMT is ordered \n Type 3 organization is used \n P codes will be established only for direct suppression expenditure s through the FireCode \nsystem. Base salary will be charged to w ildland fire suppression (WFSU) for all employees \nassigned to fire incidents. \nEach land based unit will have one code for ABCD fires. These codes will be the same as in \n2009, and will be reestablished by ASC for 2010. (see spreadsheet at http://www.fs.fed.us/fire/ibp/co st_accounting/cost_accounting.html\n ) All ABCD codes will be \nused with the region/unit override. The ABCD code format will be P#XXXX (where # is the \nregion number and XXXX is created by the FireCode system). The ABCD codes will be used \nfor the following: \n Initial response to wildfires. \n False alarms (including FS re sponse to DOI false alarms) \n Extended response to wildfires under 300 acres (except as noted above) \n Each land based unit will have one code for fire support. These codes will be used for salary and \nother project support charges by dispatch cente rs, local caches, and unit employees providing \ngeneral fire support that have tr aditionally been charged to ABCD Misc. Support codes will be \nused when an employee is working on multiple fires with different P codes and time cannot reasonably be separated out. If personnel ar e working on actual support to ongoing ABCD fires, \nthey should charge to the ABCD code. Thes e codes will be the same as 2009 and will be \nreestablished by ASC for 2010. \nP-codes generated from the National Interagency Coordination Center (NICC) will use “W” as \nthe second digit in the code. \nThe following non-land based units will have a support code for all salary charges: The ASC, \nNational Caches, GACCs, NICC, NIFC, ROs and the WO. When converting from WFPR work \nto WFSU fire support, salary charges will be ma de to this support code. Employees at these Regional Foresters, Station Direct ors, Area Director, ITTF Director, Deputy Chiefs and WO \nDirectors \n units will charge to a P or F code when they ar e specifically assigned to an incident or supporting \nonly one incident and can identify time in mi nimum four hours blocks . WFSU fire support \ncodes for non-land based units will change in 20 10 from a “WFSU” code to a pre-established \ncode generated from Firecode with a WG pref ix (WG#### where # is th e generated Firecode). \nEach Region will have one P code for staging and/or transporting unassigned resources. The \ncode of the requesting Region will be used on re source orders. Use of this code will be short \nterm in nature and be limited to times when res ources are being ordered for active fire incidents, \nbut the location of the resource as signment is not known. These code s will be pre-established and \nwill use the region/unit override in the followi ng format: P#XXXX, where the XXXX is created \nby the FireCode system. \nUnits are asked to limit the number of additional codes created in the FireCode system. While it \nis understood there are situations where the established codes are not adequate for specific needs, \nunits should adequately describe the purpos e of the code in the FireCode name field. \nThe following information is provided to update th e appropriate use of in cident and severity \ncodes for the FY 2010 season. \nP-codes: Costs for responses for all size cla ss A, B, C, and D wildfi res for each forest will \nbe collected under one P-code per Forest, except as noted below. Format is \nP#XXXX (where # is region and XXXX is created by the FireCode system), region/unit override will be used. Establ ished codes will be posted to the Forest \nService Incident Business website: \nhttp://www.fs.fed.us/fire/ibp/co st_accounting/cost_accounting.html\n. \n Do not issue a unique P-code for wild fires under 300 acres unless you are certain \nit meets at least one of the following criteria: \n Human caused \n Trespass \n Expected reimbursement \n Cost share \n Type 1, 2, or 3 Incident Management Team assigned \n \nCharge to the ABCD code until such time as you have determined one of the \nabove criteria exists. All wild fires that are size class E , F, or G will be issued a \nunique P-code with the region/unit override. \n \nP-codes for \nDOI Fires: All Department of Interior (DOI) fi re codes will be issued by dispatch personnel \nor a DOI representative through the FireCode system. Fire codes will pass to the FS Financial system only if the fire code is flagged in the FireCode system with \na value of “Y” for FS Assist . FS Assist should not be checked unless there is \ncertainty that there will be Forest Service resources responding. These codes \nallow FS resources to charge to a FireC ode in support of DOI fires and will be \nassigned the appropriate lett er (D=BLM, A=BIA, P=NPS, R=FWS) after the P. \nAn override of 1502 will be used for all DOI fires. Regional Foresters, Station Direct ors, Area Director, ITTF Director, Deputy Chiefs and WO \nDirectors \n H-codes: Use H-codes for approved BAER proj ects. One H-code will be established for \neach Region to track assessment expenditures for BAER teams. The H-codes will be established in the format: H#BAER (where # is the Region number). A \nRegional override will be used. \n These unique codes will enhance the abil ity of each Region to monitor annual \nassessment costs and simplify the process of establishing codes in time-critical \nsituations. It also provides for the tran saction code (in accordance with Public \nLaw 106-558) to be used for overtime rate equal to one and one-half times the \nhourly rate, which is appropriate for indi viduals involved in the preparation of a \nBAER plan. The overtime provisions appl y only until the initial BAER plan is \nsubmitted for approval. (See FSM 2523.) \n Each unit is responsible for cont acting the ASC Incident Finance at \nasc_ipc@fs.fed.us\n to request H-codes for BAER plan implementation, once the \nplan is approved. The H-code should mirror the P-code, including the region/unit \noverride. If the P-code was a non FS juri sdictional incident and reflected a \nregion/unit override of 1502, the H-code w ill reflect the region/unit override of \nthe requesting unit. \n AD Support: A WFSUAD code for AD (Casual) tr aining and Work Capac ity Test will be \nissued for each Region. These codes are to be used for allowable expenditures for \nsuppression funds. A Regiona l override will be used . \n \nExclusive Use \nAviation \nContracts: \nEach region will be assigned a code for Exclusive Use contract availability as \ndesignated in the FY 2010 Program Direction. These codes will be pre-\nestablished code generated from Firecode with a WA prefix (WA#### where # is \nthe generated Firecode) w ith Region/Unit override. \nNational aviation contracts wi ll also be assigned a unique code for availability \npayments. \n \nS-codes: Each Forest will have two S-codes for severity. One code for Washington Office \napproved severity and a second code for Regional Office approved severity. \nNational severity codes will be esta blished in the format: S#9999 and the \nRegional codes in the format: S#1111. Region/Unit overrides will be used. Please note that OMB is cl osely monitoring FS use of se verity and funding levels \nare being controlled through the apportionment process. Regions should insure \nthat severity funds have been approved prior to charging to severity job codes. \n Regional Foresters, Station Direct ors, Area Director, ITTF Director, Deputy Chiefs and WO \nDirectors \n \nS-codes for \nDOI Severity: Assistance to Department of the In terior severity authorizations will be tracked \nseparately. S-codes will be established to be used by individuals assisting a DOI \nBureau under a severity request. Use the following S-codes on all related \ntimesheets and travel vouchers. Do not use the individual severity codes \nestablished by DOI in the FireCode system as they will not be compatible with our systems. \n \nJob Code Override Agency \nS70001 1502 Bureau of Indian Affairs (BIA) –\nSeverity assistance. \nS70002 1502 Bureau of Land Management \n(BLM) – Severity assistance. \nS70003 1502 Fish and Wildlife Service (FWS) \n– Severity assistance. \nS70004 1502 National Park Service (NPS) – \nSeverity assistance. \n FS Support of Non-Federal Fires: States will not be utilizing the FireC ode system to establish codes for non-federal \nfires. When federal resources respond and provide support to non-federal fires, \nthe FS or DOI will create a fire code. The agency that receives the request initially, and fills an order, is responsib le for generating the fire code. These \ncodes will be established with PN as the first two characters and the remaining four characters/digits will be generated by the FireCode system. These codes will have an override of 1502. \n Non-Wildland Federal Fire Departments/ Agencies: Non-wildland Federal fire departme nts and agencies, including but not limited to \nDOD and Tennessee Valley Authority, will not be utilizing the FireCode system \nto establish codes for their federal fire s. When federal resources respond and \nprovide support to Federal non-wildland fire departments or agencies, the FS or \n DOI will retrieve a fire code. The agency that receives the request initially, and \nfills an order, is responsible for generating the fire code. These codes will be established with PF as the first two characters and the remaining four characters/digits will be generated by the FireCode system. Use override 1502. \n F-codes for FEMA Activations: \nNon-Fire FEMA Incident\n: A unique F-code will be established for each Mission \nAssignment received from FEMA for E SF4 non-fire activation. ASC-IF will not \npre-establish these codes in FFIS, however a protocol has been provided in the \nattached spreadsheet for use on non-fire FEMA responses. FEMA codes will use Regional Foresters, Station Direct ors, Area Director, ITTF Director, Deputy Chiefs and WO \nDirectors \n the region/unit override in the following format: F#0000 where # is the Region in \nwhich the response is taking place. AS C-Incident Finance shall be notified by the \nRegion or National Office, as soon as a j ob code has been assigned so that it can \nbe established for use in FFIS. ASC-IF must also be provided a copy of the \nMission Assignment (MA). Fire ESF4 Incident: \nUtilize FireCode for ESF4 wild land fire activations. ESF4 \nFire Mission Assignments are the only MAs where multiple job codes can be assigned. The majority of FEMA ESF4 fires will start out with a PN**** or \nP#**** Firecode. When the fire is assigned to ESF4, the P code will change to a F#**** where # is the Region number, and **** is the same Firecode as the P \ncode. For example PNLMNO would change to F#LMNO. In situations where the \nfire did not start out as a state PN code, assign a Fireco de with a prefix of F#. \nThis will provide consistency with the current job code process for wildfire and will maintain the integrity of the fire costs for the specific fire. Each fire covered by the MA will have a unique F code. AS C-IF will be notified, as soon as a job \ncode has been assigned or converted from a P# so that it can be established for use \nin FFIS. ASC-IF must also be provided a copy of the Mission Assignment. \n \n Base salary of all employees on assignment to a declared emergency will be paid \nfrom the Emergency Operations (WFSU) account. \nNon-Fire \nEmergency Job Codes: Upon execution of an interagency reimbursable agreement the Unit should request \na unique reimbursable job code with the appropriate reimbursable program and \nfund. Contact ASC-Incident Finance to create the code prio r to incurring any \nexpenses. Do not create a fire code in the FireCode system for non fire \nemergencies. \nFire codes are processed into FFIS as they are created in the FireCode system. The job code \ncycles in FFIS do not run on Friday and Saturday night. Therefore, incident job codes passed to \nFFIS on Friday and Saturday nights will not be av ailable for use (in Paycheck and other systems) \nuntil after processing on Sunday night. \nFor Fire Code questions, contac t Marylea Lockard, ASC Incident Finance at 505-563-7411; Fire \nand Aviation funding policy questions, Bran ch Chief, Fire Planning 202-205-0996; \nimplementation questions MaryAnn Szymoniak at 208-387-5944. \n "
} |
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"pdf_file": "3G2C6NNZ42WCE3GQ2SREVI2FQIJMQTVT.pdf",
"text": "CompanyLLC \nDecember 18, 2014 \nMr. R. M. Seeley \nDirector, Southwest Region \nPipeline and Hazardous Material Safety Administration \n8701 South Gessner, Suite 1110 \nHouston, TX 77074 RECEl\"'IED \nDEC 1 9 2014 \nBY: \nRe: Panther Control Room Management Inspection CPF 4-2014-5033M. Notice of \nAmendment. \nDear Mr. Seeley: \nPanther has reviewed the Notice of Amendment, dated December 10, 2014, \nassociated with the subject inspection and does not contest the alleged inadequacies. \nUpon receipt of the Notice of Amendment, Panther began reviewing, evaluating and \nmodifying the procedures noted by the inspector and will be continue modifying those \nprocedures in question during the coming weeks. Panther anticipates completion of \nthe modifications by March 1, 2015 and will submit the revised procedures to your \noffice upon completion. \nI trust this plan and timeline is agreeable and if there are any questions do not hesitate \nto contact me at the number below. Please note that Panther Pipeline, Ltd. had a \nname conversion and is now Panther Operating Company, LLC. There were no entity \nchanges made, other than the name change. \nSincerely, \n~ ·:L1n~ \nVice President and Secretary \n16000 Stuebner Airline • Suite 4200 \nHouston, Texas 77379 \nVoice-(832) 552-3600 extension 1 04• Fax-(832) 552-4030 "
} |
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"text": "!!\n!\n!\n!!!\n!\n!!!!\n!!\n!!!!!!!!\n!!!!!! !\n!!! !!!!\n!\n!\n!!\n!!\n!\n!!\n!\n!\n!\n!!!!!!!\n!!!\n!\n!\n!!!!\n!!\n!\n!!\n!!!!!!!!\n!\n!!!\n!\n!!!!!!!!!!!\n!\n!\n!\n!!!\n!\n!\n!!\n!\n!\n!!!!!!!!\n!\n!!!\n!\n!!!!!\n!\n!\n!! !\n!\n!\n!!!!!!\n!\n!\n!\n!!!!\n!\n!\n!!!!!!\n!\n!\n!!\n!\n!\n!\n!!!!!!!!!\n!\n!\n!!\n!!\n!!!!!\n!\n!!!! ! ! ! ! ! ! ! ! ! ! ! ! !!!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!! !!!!!!!!!!!!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! ! ! ! ! ! ! ! ! ! ! ! !! ! ! ! ! ! ! ! ! ! ! ! !! ! !! ! !! ! !! ! ! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!\n!\n!\n!!\n!\n!\n!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!\n!!\n!!!!!!!!\n!\n!\n!!!!!!!!\n!\n!!!!!!!! !!!!!!!!!!!!!!!!!!!!!!!!\n!\n!\n!!!!!!!\n!\n!\n!\n!\n!!!!\n!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!! !!!!!!!!!!!!!\n!\n!!\n!\n!!!!!\n!\n!!!\n!! !!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!\n!\n!\n!!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!!!!!!\n!\n!!!!!!!!!\n!!\n!!!!!!\n!\n!\n!\n!\n!\n!\n!!!\n!!!!!!!!!!!!!!!!!!!\n!!\n!\n!!!!!\n!!\n!!\n!!\n!!!!\n!!!!!!!!!!!\n!!\n!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!\n!!!!!!!!\n!!\n!!\n!\n!\n!\n!\n!!\n!!\n!!!!\n!!\n!!\n!\n!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!!!!! 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!! !! !! !! !!!!!!\n!!!!!!\n!!\n!!!!!!!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!\n!!!!!!!!!!!!!! !!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!! !!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!!!!! !!!!\n!\n!!!!!!!\n!\n!\n!\n!!!!!\n!\n!\n!\n!\n!!\n!\n!\n!\n!\n!!!!!!!!\n!!\n!!\n!!\n!\n!\n!\n!!!!!!!!!!!!!!!!!!!!\n!!!!!!!!!!!!!!!!\n!\n!\n!\n!!!\n!!\n!!\n!\n!!!!!!\n!\n!\n!\n!!\n!!\n!!!!!!!!\n!! !!\n!!\n!!!!\n!!\n!!!\n!\n!\n!\n!\n!\n!! !! !!!!!!!!!\n!\n!!!!!!!!\n!!!!!!!!!!!!!!!!!!!!!!!!!\n!!!\n!!!!!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!\n!!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!! !! !!\n!!\n!!\n!!!!\n!!\n!!\n!!!!\n!\n!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!!\n!!\n!!!!!!!!\n!\n!\n!\n!\n!!!!!!!!!\n!\n!!!!!!!!!! !!\n!!\n!! !!!!!!!!!!!!!!!!!!!!!!!!!!!!\n!!!\n!!!!!\n!!\n!\n!\n!\n!!!!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!\n!\n!\n!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !! !! !! !! !!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!!\n!!\n!!\n!!\n!\n!\n!\n!!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!\n!\n!\n!!!!!!!!!\n!!\n!!\n!!\n!!\n!\n!!!!!!!!!!! !! !!!!!!!!!!!!!!!!\n!!!!!! !!\n!!!!!!!!!!!!!!\n!\n!\n!!\n!!\n!!!! !!!!!!\n!\n!\n!!!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!! !!!!!!!!!!\n!!!!!!!!!!!\n!!!!!!!!!!!!!!!!!!!!!!!!!\n!!\n!!\n!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!!\n!!!!!!!!!!\n!\n!\n!\n!\n!\n!!!!!\n!!!!!!!! !!!!\n!!\n!\n!!!!!!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!\n!!!! !! !!!!!!\n!!\n!\n!\n!!\n!!\n!!!!!! !!\n!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!\n!\n!\n!\n!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!!!!!! !!!!!!!!!!!!!!!!\n!!\n!!!!!!!!!!!!\n!\n!!!!!!!!!!!\n!!!!\n!!!!!!!!!!!!!!!\n!! 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!! !! !! !!\n!\n!\n!!!!!!!!!!!\n!!!!!!!!!!!!!!!!!!!!!!!!!\n!!\n!\n!\n!\n!\n!\n!\n!!!!\n!\n!\n!\n!!!!!!\n!\n!!!!\n!\n!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!!\n!!\n!\n!\n!\n!\n!!\n!!\n!!\n!\n!!!!!!!!!!!!!!!!!!!!\n!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!\n!!\n!!\n!!\n!!\n!!\n!!\n!! !!\n!!\n!\n!\n!!\n!\n!!!!!!!!!!!!!!!! !!!!!!!!\n!!\n!!!!\n!!!!!! !!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!!!!!\n!!!!!!!!!!!!!!!!!!!\n!!\n!!\n!!!!!!!!!!!!!!!!!!!!!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!! !!!!!!!!!!!!!!!!!!!!\n!!\n!!\n!!\n!!\n!\n!!!!!!!!!!!!!\n!!!!!!!!!!\n!!\n!!!! !!!! !!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!\n!\n!!!!!!!!!!!!!!!!!\n!!\n!\n!!!!!!!!!!!!! !!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!\n!!!!!!\n!\n!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!!\n!!\n!!!\n!\n!!!!!!!!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!! !!\n!\n!\n!! !!\n!\n!\n!\n!\n!\n!\n!!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!! !!\n!!\n!!\n!!\n!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!\n!!!!!!!!!!!!!!!!!!!!\n!!!!!!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!!\n!\n!!!!!!!!!! !!\n!\n!\n!\n!\n!!!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!\n!! !!\n!\n!\n!\n!\n!\n!\n!!!!!!!!!!!!!!!!!!!!!!\n!!\n!\n! !!!!\n!\n!\n!\n!\n!!\n!\n!\n!!\n!!!!!!!\n!\n!!\n!\n!\n!\n!\n!\n!\n!!\n!\n!\n!\n!!!\n!!!!!!\n!\n!\n!!\n!!\n!!\n!! !\n=\nææ\n=æ\næææ\næ=\næ=S\nS\nSSS\nSS\nS\nSSS\n4060\n50\n3070\n50\n6060\n60\n404060606060\n50506060\n6060\n6060\n50\n406060\n506060\n5060606060\n5060\n60\n5060\n40606060\n60\n60\n506050\n506060\n506060\n6060\n60\n6060\n60\n60\n5070\n60\n5060\n50\n5060\n50\n405060\n50\n60506060\n50\n5060606060\n5060\n50\n5060\n50\n5060\n6060\n4060\n5060\n6060\n6060\n6060\n50605050\n60\n607060\n60\n5060\n60\n60\n6060\n50\n60\n6060\n6060\n60\n5060\n4060\n60\n50\n5050\n60\n3060\n50 506060\n40\n60\n4060\n505060\n505060\n60606060\n60\n605060\n4050\n60\n60\n406060\n6050\n606060\n606050\n6050\n50¬«14¬«12\n¬«314\n¬«317Brownsville RdWhiteleysburg Rd\nFox Hunters RdPark Brown Rd\nGregg Rd\nParker RdSugar Stick RdHills Market Rd\nBurrsville RdSpectrum Farms Rd\nJohn Hurd Rd\nAndrewville RdKnife Box RdWhites Ln\nIngram\n Branch RdHopkins Cem\netery Rd\nHigh Stump RdBates Rd\nGallo RdTwo M\nile Rd\nHemping RdBullock Rd\nLayton Corners Rd\nWilhelm RdRed Bird LnChandlers Rd\nEdwardsville Rd\nCattail Branch RdSandtown Rd\nBlack Swam\np Rd\nProspect Church RdHayfield Rd\nEllwanger RdCedar Grove Church RdHolly Spring Rd\nSpider Web Rd\nDrapers Corners RdCornish RdPlummers LnAmsterdam Rd\nBoyce Mill Rd\nPear Tree LnLords Corner Rd\nLobo RdFlat Iron RdIrwin Chapel Rd\nW\nhite Marsh Branch RdMeredith Rd\nAnthony Mill RdMurffs RdJump School House Rd\nCourtland Dill Rd\nToby Collins Ln\nGreenville RdCurvy Ln\nUnnamed Street Equitation Ln\nPlummer Ln\nHammondtown RdWelch RdMarebear LnDrapers Mill Rd\nRuritan RdKeep Out Dr\nWolfpit Ridge RdFitzbrian Dr\nBowdle DrBurrsville Branch RdPine Pitch RdMarshyhope RdBayberry Ln\nDeerwood Farm Ln\nLewis RdBassin Ln\nArrowhead Hill Ln\nFishers Bridge RdTodds Chapel RdTriangle Rd\nChesters Ln\nGreen BranchHorsepen Arm\nMarshyhope Ditch\nCattail BranchMarshyhope Creek\nProspect BranchPrice ProngHerron Run\nWhite Marsh Branch\nPoint BranchShields ProngMeredith Branch\nBeaverdam BranchSangston ProngGreenlees Ditch\nWebber BranchBlack Swamp Creek\nSpring BranchGravelly Branch\nBurrsville BranchBullock ProngGarey Mill Pond BranchSandtown Branch\nBlack Arm Prong\nHopkins Prong\nHerring RunWatts Creek\nNumber Two, ProngW\nildcat Branch\nBright Haines Glade Branch\nTomahawk BranchIngram BranchHerron Run\nGum IslandGreens Corners\nDrapers CornersAnthonys Corners\n75°37'30\"W75°37'30\"W\n75°39'0\"W75°39'0\"W\n75°40'30\"W75°40'30\"W\n75°42'0\"W75°42'0\"W\n75°43'30\"W75°43'30\"W\n75°45'0\"W75°45'0\"W39°0'0\"N\n39°0'0\"N38°58'30\"N\n38°58'30\"N38°57'0\"N\n38°57'0\"N38°55'30\"N\n38°55'30\"N38°54'0\"N\n38°54'0\"N38°52'30\"N\n38°52'30\"N34\n34435000mE\n3536\n3637\n3738\n3839\n39440\n44041\n4142\n4243\n4344\n4445\n4546\n446000mE02\n4302000mN03030404050506060707080809094310431011111212131314141515161617174318000mN18Burrsville QuadrangleDelaware DataMIL\n7.5 Minute Series (Topographic)\nQuadrangle\nLegend\nSBoundary Monument\n!y Boat Ramp\n8Campground\næChurch\n((Gaging Station\n5Gate\n.Helipad\nÌSand/Gravel Pit\n4Picnic Area\n!Tank\n. Tower\n= Well%%%%%%%%%%%%%%%%Boardwalk\nBoat Ramp\nEmbankment\nFence Line\nLanding Strip\nPier/Breakwater/Jetty\nPipeline\n! !Power Transmission Line\nRacetrack\nSea Wall\nRailroad or Siding (Underpassing)\nRailroad or SidingMunicipalities\nAirport\nAthletic Field\nBuilding\nCemetery\nLandmark Site\nOil Sump/Sludge Pit\nPier/Breakwater/Jetty\nPipeline Regulation StationPower Site\nRaceway\nRailroad Yard\nRefinery/Industrial Site\nRest Site\nSubstation\nTank\nWater Treatment Site\nFederally Administered Area\n!!State Lands\nPark\nSwamp\nRapids\nDisclaimer\nThis Delaware DataMIL 7.5-minute topographic map replaces the USGS 7.5-minute Primary Map Series for the State of Delaware. Reasonable efforts have been made by Delaware DataMIL staff to\nverify that this map and the digital data provided hereon accurately portray the source data used in its preparation; however, this map may contain omissions and errors in scale, resolution, rectification,\npositional accuracy, development methodology, and other circumstances. This map is also date specific. Date information on the individual layers comprising this map are given as part of the marginalia\nof this map. This map was prepared for a scale of 1:24,000 and should not be used at larger scales, nor should this map should be used for navigational, engineering, legal, or any other site-specific\nuse. Nothing contained herein shall be deemed an expressed or implied waiver of the sovereign immunity of the State of Delaware or its duly authorized representatives, agents, or employees.Magnetic Declination\nApprox. 11 degrees³\n1 0 1 0.5\nKilometers1000 0 1000 2000 3000 4000 5000\nFeet0.5 0 0.5\nMiles\nCONTOUR INTERVALS: 0-10 Feet / 2-foot Contour Interval; 10-100 Feet / 10-foot Index with a 6-foot Intermediate Contour Interval; \nGreater than 100 Feet / 10-foot Contour Interval\nVERTICAL REFERENCE:\nNORTH AMERICAN VERTICAL DATUM OF 1988 (NAVD88)\nDEPTH CURVE DATA COMPILED FROM NOS CHARTS IN FEET\nSHORELINE SHOWN REPRESENTS THE APPROXIMATE LINE OF MEAN HIGH WATER\nMD, PA, AND NJ BORDER QUADRANGLES SHOW USGS DRG IMAGES OUTSIDE OF DELAWARE BORDER WITHIN QUADRANGLE\nHORIZONTAL REFERENCE:\nNORTH AMERICAN DATUM OF 1983 (NAD83) HIGH ACCURACY REFERENCE NETWORK 1991 (HARN 91)\nMAP PROJECTION IS 1983 DELAWARE STATE PLANE METERS\n1,000-meter grid: Universal Transverse Mercator, zone 18\n10,000-foot tick: Delaware Coordinate System of 1983\nLatitude/Longitude grid tics:NAD83(HARN91)Map Produced by the Delaware DataMIL\nUsing the following Data Sources\nUSGS Delaware Geographic Names 2006\nUSGS Delaware Boundaries – County Boundary [lines] 1993\nUSGS Delaware Boundaries [areas] 1993\nUSGS Delaware Miscellaneous Features [points] 1993\nUSGS Delaware Miscellaneous Features [lines] 1993\nUSGS Delaware Miscellaneous Features [areas] 1993\nUSGS Delaware Railroads 1993\nUSGS 7.5-minute Digital Raster Graphics 1992-93 (DRG)\nUSGS National Hydrography Dataset (NHD) – High Resolution – \n DE Lakes Ponds Areas 2005\nUSGS National Hydrography Dataset (NHD) – High Resolution – \n DE Rivers and Streams 2005\nDelaware 7.5-minute Quadrangle Index 2002\nDelaware Boundary Monuments 2002\nDelaware State Boundary [line] 2002\nDelaware Contours 2005 (Sussex) and 2007 (New Castle and Kent)\nDelaware Municipal Boundaries 2009\nDelaware Land Use and Land Cover 2007 \nDelaware Private Schools 2007\nDelaware Public Schools 2007\nDelaware Road Centerline (DelDOT) 2009\nNew Castle County Communities 2006\nKent Communities 2006\nSussex County Communities 2006\nCreated: 10/11/2009Burrsville\nDelaware DataMIL: http://datamil.delaware.govState of Delaware\nQuadrangle Location\nHobbsDentonMarydel\nBurrsville\nHickmanWyoming\nHarringtonGoldsboro\nGreenwood1:24,000 SCALE"
} |
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"text": "VIRGINIA REGISTER OF REGULATIONS \nOCTOBER 2009 VOLUME 2, ISSUE 1 VIRGINIA REGISTER NEWS \nNews you can use \nRIS TRAINING \nThe Virginia Registrar's Office is presenting its RIS Basic and Intermediate Training Session \non October 28, 2009. Please let us know if you would like to attend the following session: \nOctober 28 — 10 - 11:30 a.m. RIS Basic Training \n 12:15 - 2 p.m. RIS Intermediate Training \nAttendees may sign up for the morning session, afternoon session, or both. \nWHERE: General Assembly Bldg, 6t h Floor, DLAS training room. \nSeating is limited, so please make reservations with Terri Edwards at \ntedwards@dls.virginia.gov . \nIf you would like to attend both morning and afternoon sessions, the cafeteria on the 6th Floor of the GAB is available for lunch purch ases or for enjoying a lunch you bring. \nVirginia Register of Regulations, 910 \nCapitol Street, 2nd Floor, Richmond, Vir-\nginia 23219, (804) 786-3591. \nFor comments and questions contact Terri \nEdwards at tedwards@dls.virginia.gov. \nSEPTEMBER \nNOIRA 9 \nProposed 11 \nFinal 27 \nFast-Track 2 \nEmergency 1 \nTOTAL 50 \nRIS automatically places a regulation in the ne xt available Virginia Register volume and \nissue for publication when submitted from the Town Hall. Therefore, if you enter a later \nvolume and issue in Town Hall, rather than use the default, RIS still places it in the \ndefault issue. Be sure to call our office if y ou intend for your regulation to be published in \nan issue other than the default, and we will manually move it to the issue you specify. WHAT’S YOUR ISSUE? \nFor the latest Virginia Register publication schedule, click here . \nInside this issue: \nRIS TRAINING 1 \nREGULATION \nBREAKDOWN 1 \nWHAT’S YOUR ISSUE? 1 \nGETTING TO KNOW YOU 2 \nINTEGRITY CHECK 2 PAGE 2 VIRGINIA REGISTER NEWS \nCindy Berndt, the regulatory coordinator for the \nDepartment of Environmental Qu ality, started with the State \nWater Control Board 39 years ago. The State Water Control \nBoard then merged with the Department of Air Pollution \nControl, the Department of Waste Management, and the \nCouncil on the Environment to form the Department of Environmental Quality in 1993. She became the regulatory coordinator for the Water Control Board in 1984 and for the Department of Environmental Quality in 1993. Over the years, Cindy has worn many different hats. In the early years, she worked in enforcement, before moving into the financial end doing contract management and financial services. Since 1984, she has focused on regulation development through the APA. She also serves as staff to the \nthree regulatory Boards (Air, Waste, and Water). Cindy has two children and a dog. She enjoys reading, \nspending time with friends, and doing most any kind of puzzle: crossword, suduko, daily jumble, and jigsaw. \n “If anyone needs help with it \n(a regulation), contact the staff at the Registrar’s office. They’re the best.” \n \n- Cindy Berndt \nINTEGRITY -- WE ALL WANT IT! (PART I) \nWith the implementation of RIS came the In tegrity Check feature. Here's how it works and how you can use it to ensure the \nintegrity of the sections you amend in the Virginia Administrative Code. Click \"integ \" in the list of RIS actions as shown. \n \n \nThe program performs a document compare routine of all text in th e current section in RIS with the text in the online VAC, but \nskips the following punctuation marks: commas, periods, semicolons and colons. This means it is up to agencies and the \nRegistrar's staff to pay particul ar attention to those items. Pa rentheses are not skipped and are treated as \"letters\" in text so if a \nword with an opening or closing parenthesis is being amende d, strike through the old word including the parenthesis and \nunderscore the new word with the appropriate parenthesis. \nFor example: (2004) (2008) . \nFor numbered lists, strike the num ber and its period and underscore the new number and its period. \nFor example: 2. 3. \nCapitalization matters to the integrity check program. So, when a dding text to the beginning of a sentence, strike the word wit h \nthe uppercase first letter and underscore the word in lowercase. \nFor example: The Prior to su bmitting the application, the applicant shall ... \nWhat happens if the text does not match? \nIf the text is an exact match, the program responds wi th If the text is not an exact match, the \nprogram responds with and marks th e spot of the discrepancy with There's a problem starting here \n==> \nCheck the text in the current online VAC to determine if a letter or word is inappropriately stricken, underscored, or missing. \nMore ways to troubleshoot an integrity check failure in Part II of Integrity -- We all want it! \nIntegrity check passed! \nIntegrity check failed! "
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"text": " \nUSDA is an equal opportunity p rovider and employer \n \n \n \n \n \n \n \n \n \n \nArkansas Chick Placements Up 4 Percent from Last Year \n \nBroiler -type chicks placed for meat production in Arkansas were 19.6 million dur ing the week ending \nJanuary 30, 2016. Placements were up 4 percent from the comparable week in 201 5 but down 5 percent from the previous \nweek. \n \nArkansas hatcheries set 21.8 million broiler -type eggs d uring the week ending January 30, 201 6, down 2 percent from the \nsame period last year and down slightly from the previous week. \n \n17181920212223\nJan Feb Mar AprMay Jun JulAug Sep OctNov Dec\nMonthChicks Placed In Arkansas, 2015 -2016\n2015 2016Million Chicks\n \n181920212223\nJan Feb Mar Apr May Jun JulAug Sep Oct Nov Dec\nMonthEggs Set In Arkansas, 2015 -2016\n2015 2016Million Eggs \n30-Jan 30-Jan\nAlabama 29,249 29,562 29,902 29,261 29,669 21,587 22,653 22,745 22,369 21,707\nArkansas 21,735 21,680 21,764 21,764 21,753 19,067 18,792 21,043 20,540 19,567\nDelaware 4,888 4,856 4,876 4,853 4,822 6,137 6,077 5,593 6,920 5,730\nFlorida 1,225 1,224 1,225 1,224 1,175 1,311 1,320 1,072 1,098 1,283\nGeorgia 33,441 34,019 33,273 34,409 34,811 27,462 26,306 27,244 25,339 27,577\nKentucky 7,801 7,496 7,828 7,967 7,934 6,119 6,051 5,731 6,295 6,068\nLouisiana 3,419 3,455 3,500 3,470 3,726 3,291 3,164 3,042 2,994 2,997\nMaryland 7,777 8,118 8,113 7,796 7,333 4,746 5,206 6,770 4,740 6,440\nMississippi 16,942 17,798 17,692 18,125 18,051 15,215 15,560 14,900 14,400 15,142\nMissouri 8,062 7,964 8,071 7,877 8,071 5,657 6,059 6,111 6,126 5,675\nN. Carolina 20,890 20,731 20,915 21,421 21,101 16,818 16,455 16,487 16,134 16,008\nOklahoma 6,752 6,689 6,962 6,738 7,036 5,014 5,218 3,342 3,856 4,912\nPennsylvania 4,848 4,586 4,632 4,299 4,325 4,018 3,959 3,754 3,882 3,736\nS. Carolina 5,701 5,760 5,627 5,612 5,614 4,580 5,723 4,812 5,647 5,100\nTexas 14,522 14,557 15,237 15,200 15,231 12,628 12,198 12,221 11,754 11,852\nVirginia 6,315 6,374 6,349 6,305 5,941 5,936 5,087 4,755 5,527 5,014\nCA,TN & WV 12,078 12,292 12,040 12,442 12,402 10,327 11,192 10,668 10,671 11,348\n19 State Total 205,645 207,161 208,006 208,763 208,995 169,913 171,020 170,290 168,292 170,156\n% of Prev. Year 100 101 101 101 102 100 101 100 99 101\nOther States 7,219 8,191 7,980 7,909 7,883 6,615 6,495 6,595 5,996 6,490\nU.S. Total 212,864 215,352 215,986 216,672 216,878 176,528 177,515 176,885 174,288 176,646Broiler Eggs Set and Chicks Placed in 19 Major States by Week, January 2, 2016 - January 30, 2016\nStateEggs Set Chicks Placed\nWeek Ending Week Ending\n2-Jan 9-Jan 16-Jan 23-Jan\nRev isions made to the prev ious four-w eek's data during the current w eek are published in this report.2-Jan 9-Jan 16-Jan 23-Jan\n1,000 eggs 1,000 chicks\n \n \nBroiler -Type Eggs Set in the United States Up 2 Percent \n \nHatcheries in the United States weekly program set 217 million eggs in incubators dur ing the week ending \nJanuary 30, 2016, up 2 percent from a year ago. Hatcheries in the 19 State weekly program set 209 mi llion eggs in incubators \nduring the week ending January 30, 2016, up 2 percent from the year earlier. Average hatchabilit y for chicks hatched during \nthe week in the United St ates was 84 percent. Average hatchability is calculated by dividing chicks hatched during the week \nby eggs set three weeks earlier. \n \nBroiler -Type Chicks P laced in the United States Up 1 Percent \n \nBroiler growers in the United States weekly program placed 177 million chicks for meat prod uction during the week ending \nJanuary 30, 2016, up 1 percent from a year ago. Broiler growers in the 19 State weekly program placed 170 million chicks \nfor meat production during the week ending January 30, 2016, up 1 percent from the year earlier. Cumulative placements \nfrom the week ending January 9, 2016 through January 30, 2016 for the United States were 705 million. Cumulative \nplacements were up 1 percent from the same period a year earlier. Cooperating with the University of Arkansas – Division of Agriculture \n10800 Financial Centre Parkway, Suite 110 · Little Rock, Arkansas 72211 \n(501) 228 -9926 · (501) 224 -5630 FAX · www.nass.usda.gov /ar \n \n \nUnited State Department of Agriculture \nNational Agriculture Statistics Service \nArkansas Weekly Broiler Report \nReleased: February 03, 2016 "
} |
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"pdf_file": "PA46QOQAP7BJ3PS4GXSHDZ4YRVB5EAJZ.pdf",
"text": "8672-3704000-School Lunch Equipment\nWorkflow Data Version: Current Version\nSchool District: 3704000-LAFAYETTE COUNTY SCHOOL DISTRI\nContact Information: \nContact Name: Mark Keith\nContact E-Mail Address: keithm@lcs.k12.ar.us\nContact Phone: 870-921-5500\nDistrict Website URL: http://lcs.k12.ar.us\nDUNS: 100003318\nLegal Business Name: Lafayette County School District\nAddress: P.O. BOX 950\nCity: LEWISVILLE\nState: AR\nZip: 718450000\nCounty: LAFAYETTE\nFilter Statement 1: Will it invest in the economy?\nFilter 1: Yes\nFilter Statement 2: Is it a one-time, short-term (no longer than two years) investment with long-term benefits?\nFilter 2: Yes\nFilter Statement 3: Is the expenditure allowable under the funding mechanism (Title 1, IDEA, SFSF)?\nFilter 3: Yes\nFilter Statement 4: Will the program, activity or item proposed lead to improved student academic achievement?\nFilter 4: No\nDate of School Board \nApproval: May 19, 2009\nDate of ADE Review: May 2, 2011\nTOTAL ALLOCATION: $5,305.00\nRun Date: Jun 2, 2011 Run Time: 6:00:23 AM 8672-3704000-School Lunch Equipment\nWorkflow Data Version: Current Version\nSchool District: 8672-3704000\nDistrict Plan Input\n1 District/School Allocation Level 3 Dummy Data Item\nAllocation Funds 00000 $5,305.00\n3704013-LAFAYETTE COUNTY HIGH SCHOOL\nBudget Amount: $5,305.00\nProject Narrative: Purchase double Convection Oven\nGoals: \nIntensive Support and Effective Interventions\nGoal Justification: Goal #4- Support and Interventions: A convection oven can provide for safe, hot meals for \nstudents so they can focus on learning\nStart Date: July 01, 2009\nEnd Date: August 28, 2009\nAllocation Funds\nBudget Amount: $5,305.00\nProject Narrative: \nGoals: \nGoal Justification: Be sure to address each goal selected in the goal justification.\nStart Date: \nEnd Date: 8672-3704000-School Lunch Equipment\nWorkflow Data Version: Current Version\nSchool District: 8672-3704000\nDistrict/School Program Allocation\nProject (elist) Level 2 Dummy \nColumn \nSpacer \nItemBudget Amount\n3704000-LAFAYETTE COUNTY SCHOOL DISTRI 00000 $5,305.00\n050-Buildings/Additions to Buildings $0.00\n051-Major Renovations $0.00\n052-Equipment $5,305.00\n053-Vehicles $0.00\n054-Technology Hardware & Software $0.00\n055-Infrastructure $0.00\n056-Program Direct Service $0.00\n057-Professional Services $0.00\n058-All Other $0.00\nTOTAL $5,305.00 8672-3704000-School Lunch Equipment\nWorkflow Data Version: Current Version\nSchool District: 8672-3704000\nDistrict/School Program Allocation\n3 Districts/Schools All Level 1 Dummy Column Spacer Item Budget Amount\n3704013-LAFAYETTE COUNTY HIGH SCHOOL 00000 $5,305.00\n3704013-LAFAYETTE COUNTY HIGH SCHOOL 050-Buildings/Additions to Buildings $0.00\n051-Major Renovations $0.00\n052-Equipment $5,305.00\n053-Vehicles $0.00\n054-Technology Hardware & Software $0.00\n055-Infrastructure $0.00\n056-Program Direct Service $0.00\n057-Professional Services $0.00\n058-All Other $0.00\nTOTAL $5,305.00"
} |
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"pdf_file": "HKZAYT5MELBWIO3KEUOMDX42ENWUWSHD.pdf",
"text": " House Passes Matsui’s Clean Tech Manufacturing and Export Promotion Legislation\nToday, the House of Representatives passed legislation introduced by Congresswoman Doris Matsui (CA-05), H.R.\n5156, the Clean Energy Technology Manufacturing and Export Assistance Act of 2010, which would boost the\ncompetiveness of the U.S. clean technology industry in both domestic and international markets. The legislation received\nbipartisan support and passed by voice vote. \r\nFOR IMMEDIATE RELEASE \n\r\nWednesday, July 28, 2010 \n\r\n\r\nCONTACT: MARA LEE\n\r\n(202) 225-7163 \n\r\n \n\r\n\r\nHouse Passes Matsui’s Clean Tech Manufacturing and Export Promotion Legislation\n\r\nKey Component of ‘Make it in America’ Agenda will Create Jobs, Support Sacramento’s Growing\nClean Energy Sector\n\r\n\r\n\r\nWASHINGTON, DC – Today, the House of Representatives passed legislation introduced by Congresswoman\nDoris Matsui (CA-05), H.R. 5156, the Clean Energy Technology Manufacturing and Export Assistance Act of 2010, which\nwould boost the competiveness of the U.S. clean technology industry in both domestic and international markets. The\nlegislation received bipartisan support and passed by voice vote.\n\r\n\r\n“Providing clean energy entrepreneurs with the tools they need to sell their products in new markets and increase\ntheir production will have substantive multiplier effects on our communities and our economy as a whole,” said\nCongresswoman Matsui. “As part of the Make it in America Agenda, H.R. 5156 will help put families back to work\nand strengthen America’s manufacturing sector. Investing in American-made technology and products is a clear\npath to economic recovery, renewed financial stability, and measurable job growth.”\n\r\n\r\nThe Clean Energy Technology Manufacturing and Export Assistance Act is part of the “Make it in America”\nAgenda introduced last week by Rep. Matsui, House Majority Leader Steny Hoyer (MD-05), Dean of the House John\nDingell (MI-15), and other Members of Congress committed to reviving America’s manufacturing sector and\ncreating good-paying American jobs. The Make it in America Agenda is a manufacturing strategy based on the idea that\nwhen more products are made in America, more people will be able to make it in America. The Make it in America\nAgenda creates incentives for investment in industry, will strengthen manufacturing infrastructure and innovation, and\nhelps to level the playing field for American companies that compete globally.\n\r\n\r\n“Our national manufacturing strategy creates the high-skill, high-wage jobs of the future by promoting American\ncompetitiveness, innovation, and exports,” added Rep. Matsui. “As the Department of Energy reports,\nclean energy technology exports could increase by $40 billion per year and create more than 750,000 jobs by 2020. \nPassage of my legislation will help the Sacramento region seize this opportunity to create new jobs and position\nourselves as a clean tech capital.”\n\r\n\r\nH.R. 5156 would create a $15 million Clean Energy Technology Manufacturing and Export Assistance Fund to support\nthe development, implementation, and sustainability of a National Clean Energy Technology Export Strategy, and assist\nU.S. clean tech firms by finding and navigating foreign markets to export their goods and services abroad. The Matsui\nlegislation would also strengthen America’s domestic clean tech manufacturing industry by promoting policies thatThe Online Office of Congresswoman Doris Matsui\nhttp://www.matsui.house.gov Powered by Joomla! Generated: 6 November, 2010, 05:45 will reduce production costs and encourage innovation, investment, and productivity in the clean energy technology\nindustry here at home.\n\r\n\r\nAccording to the Trade Promotion Coordinating Committee, more than 30 percent of non-exporting small and medium\nsized companies would export if they had more access to market information, export opportunities, and the export\nprocess. The Clean Energy Technology Manufacturing and Export Assistance Act will provide the assistance many U.S.\nsmall businesses are seeking. \n\r\n\r\n“Currently, our nation is running a trade deficit in green technologies ranging in the billions,” Rep. Matsui\nsaid today on the House floor during consideration of H.R. 5156. “Our nation should not be dependent on foreign\nenergy which threatens our national security, hurts our environment, and weakens our economy. We must be the world\nleader in manufacturing and export American-made clean energy technologies.”\n\r\n\r\nThe Clean Energy Technology Manufacturing and Export Assistance Act was introduced by Rep. Matsui on April 27,\n2010 and passed unanimously out of the Commerce, Trade and Consumer Protection Subcommittee on June 30, 2010. \nIt was passed with broad support in the full Energy and Commerce Committee on July 21, 2010. \n\r\n\r\n\r\n\r\n# # #\n\r\n\r\nThe Online Office of Congresswoman Doris Matsui\nhttp://www.matsui.house.gov Powered by Joomla! Generated: 6 November, 2010, 05:45"
} |
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"pdf_file": "KAX2V43VIPOF5R7SL2YYD2JQFRQCPWQ5.pdf",
"text": "Bachus Enlists Congressional Support To Save Air National Guard Units\n \nWASHINGTON- Congressman Spencer Bachus today sent a letter to House\nArmed Services Committee Chairman Duncan Hunter requesting that he\nhold a hearing on the Base Realignment and Closure Commission's decision\nto realign the 117th Air Refueling Wing and 22 similarly\nsituated air units.\n \n \n \nCongressman Bachus was joined by members of the Alabama,\nDelaware, Michigan, Missouri and Ohio delegations. Some of\nthe concerns the letter expressed were:\n \n \n \n· While Congress deemed \"military value\" to be the\noverriding factor upon which the BRAC recommendations were\nto be based, six Air National Guard Tanker wings determined to\nhave less military value than Birmingham are remaining in place\nwith some seeing an increase in aircraft.\n \n \n \n 1 / 3 Bachus Enlists Congressional Support To Save Air National Guard Units\n· To date, $73 million has been spent on Birmingham's\ninfrastructure to make it a world-class tanker base. There is\ncurrently space to bed down 13 aircraft, and next year the\nBirmingham International Airport runway will be lengthened to\n12,000 feet, yielding an increased capability that is greater than\nthat of any of the airports to which the 117th ARW aircraft\nare to be relocated.\n \n \n \n· The ability of \"enclave\" bases to sustain expediti\nonary c\nombat units is not clear.\n \nOnce flying units are removed, many bases will no\nlonger be able to support military or civilian aircraft\noperations, and recruitment and retention could be\nmade more difficult. \n \n \n \n 2 / 3 Bachus Enlists Congressional Support To Save Air National Guard Units\nIt is anticipated that another letter, detailing\nmore specific concerns with additional\nCongressional support, will be sent to Chairman\nHunter next week .\n \n \n \n###\n 3 / 3"
} |
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] | {
"pdf_file": "OIBFL53UO6KGYL6PN27JMGWOJKWD62FK.pdf",
"text": "Fermi Summer School 2012 Application Form (Submit via e-mail to fermischool@bigbang.gsfc.nasa.gov) Applicant Name: Applicant E-mail: Institution: Date or Anticipated Date of PhD: Room preference Double ($1000): or Single ($1500): (singles subject to limited availability) Adviser Name: Adviser E-mail: If you would like to give a brief oral presentation of your work, please provide a title and abstract. Title: Abstract: Statement of Interests Please provide a brief summary of your current research activities and science interests (Please do not exceed one page) "
} |
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"text": "United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n1The court’s use herein of “plaintiff” in t he singular is purely a stylistic choice, as\nall arguments are addressed to both plainti ffs and all rulings apply equally to both. United States District Court\nFor the Northern District of CaliforniaUnited States District Court\nFor the Northern District of CaliforniaUNITED STATES DISTRICT COURT\nNORTHERN DISTRICT OF CALIFORNIA\nXXXXXX and XXXXXXX\nXXXXXX,\nPlaintiffs, No. C 07-2360 PJH\nv. ORDER GRANTING DEFENDANT’S\nMOTION FOR SUMMARY JUDGMENT\nSAN MATEO UNION HIGH SCHOOL AND DENYING PLAINTIFFS’ MOTION\nDISTRICT, FOR SUMMARY JUDGMENT\nDefendant.\n_______________________________/\nThe parties’ cross-motions for summary judgment came on for hearing on April 9,\n2008 before this court. Plaintiffs, XXXXXXX and XXXXXXXX (collectively\n“plaintiffs”)1, appeared through their counsel, Susan Foley. Defendant San Mateo Union\nHigh School District (“defendant” or “District ”) appeared through its counsel, Kimberly A.\nSmith. Having read all the papers submitted and carefully considered the relevant legal\nauthority, the court hereby GRANTS defendant ’s motion for summary judgment, and\nDENIES plaintiffs’ motion for summary judgment, for the reasons stated at the hearing, and\nas follows.\nBACKGROUND\nThis case arises under the Individuals with Disabilities Education Act (“IDEA”), which\nrequires school districts to provide qualifyi ng disabled children with a “free appropriate\npublic education” (“FAPE”). See 20 U.S.C. § 1412(1). \nA. Background FactsCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 1 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n2Plaintiff XXXXXXX, who is currently twenty years old, was first made eligible as\na student with a Specific Learning Dis ability and a Speech Language Impairment, on\nNovember 26, 1990, during his 3rd grade year. See Administrative Reco rd (“AR”) at 240. \nHe remained eligible for special education under these two categories for the duration of\nhis school career, including the time periods that are relevant for purposes of this lawsuit,\nnamely 2003-2006. During that relevant time period, plaintiff attended Hillsdale High\nSchool as a freshman during the 2002-03 school year, and as a sophomore for part of the\n2003-04 school year. AR at 242, 251. \nDuring plaintiff’s 9th grade year at Hillsdal e, in fall of 2002, defendant San Mateo\nUnion High School District conducted plaintiff’s tr iennial review. The tr iennial review refers\nto the process of assessing and determining a student’s eligibility and placement needs\nonce every three years. AR 852. As part of the 2002 triennial review, defendant conducted\nseveral assessments of plaintiff. These a ssessments included administration of the Wide\nRange Achievement Test (WRAT”), a Bruckner diagnostic math test, and the Peabot\nIndividual Achievement Test (“PIAT”). AR at 587-88. On the WRAT, plaintiff demonstrated\nweakness in math and spelling, and high level decoding skills. Id . at 589. On the\nBruckner, plaintiff scored very well in addition and subtraction, but was weak in\nmultiplication and division. AR at 591. Pl aintiff performed above grade level on the PIAT. \nId. \nPlaintiff was also observed in the classr oom by an educational assistant, in order to\nassess how plaintiff interacted with others in the classroom environment. The educational\nassistant reported that plaintiff did not r equire assistance, was not easily distracted by\nothers, and did not distract ot hers, although he at times appeared le thargic. AR at 594-95. \nFinally, a District psychologist reviewed plaintiff’s student records and spoke with\nplaintiff’s teachers. AR at 852-53. Based on this review, she determined that no further\npsychological testing of plaintiff was needed. Id . She sent plaintiff’s mother, XXXXXXX\nXXXXXX, a confirming letter. Id . Ms. XXXXXXX did not request further assessments. Id .Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 2 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n3at 855. \nFollowing the completion of these triennial assessments, plaintiff’s Individualized\nEducation Plan (“IEP”) team convened on October 4, 2002 for the triennial review. AR\n1145-63. Among others, plaintiff and his mother were present at the meeting, as well as\nMs. Pam Rianda, plaintiff’s special education t eacher, and Ms. Lisa Fox, plaintiff’s speech\nand language therapist. AR 1148. The IEP team noted plaintiff’s areas of strength and\nweakness, with plaintiff’s written language and ma th skills included in the latter category. \nAR 1145. The team also noted that plainti ff was experiencing problems with punctuality\nand attendance, and was demonstrating some “defi ant behaviors” and a “level of anger that\ncontribute[d] to [plaintiff’s] not being successf ul in school.” AR 1148, 1223-25. The IEP\nteam recommended that plaintiff continue to be placed in a Special Day Class (“SDC”) for 3\nto 4 periods a day, and in order to address plaintiff’s observed speech and language\nproblems, it recommended that plaintiff be given 3 periods per month of direct speech and\nlanguage therapy. AR 1146-48. The team also recommended that plaintiff participate in\nHillsdale’s anger management program. Id . Ms. XXXXXXXX received notice of the\nProcedural Safeguards, indicated she understood her rights, and consented to the IEP. AR\n306; 1148. \nOn November 12, 2002, plaintiff’s IEP t eam convened again, in order to draft a\nBehavior Support Plan (“BSP”). AR 1243-49. Prior to the meeting, the defendant had\nrequested consent to conduct an environmental assessment, which examines a student’s\nbehavior, discipline and school functioning. AR 601-02; 1242. The purpose of the\nenvironmental assessment was to determine if plaintiff needed more support or services,\nand to determine if plaintiff needed a BSP. AR 602-03. It appears that the environmental\nassessment never took place. Nonethele ss, based on plaintiff’s general behavior and\nschool performance, the IEP team developed a BSP on November 12. AR 603-05, 1249. \nThe BSP noted that plaintiff was exhibiting “inappropriate classroom behavior” that was\nimpeding plaintiff’s learning, and that the behavior was being caused by “anger,”Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 3 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n4“frustration,” and a failure of success. AR 1249. To that end, the BSP outlined certain\ninterventions that were to be undertaken by defendant in an effort to modify plaintiff’s\nbehavior. The interventions consisted of specific teaching strategies, positive\nreinforcement, one-to-one assistance when nec essary, a tutorial study period, anger\nmanagement counseling, and weekly progress re ports. AR 604-05; 1170; 1249. The BSP\ndid not, however, address any truancy issues that plaintiff was having, which had beenremarked upon earlier by the School Safety Advocate. AR 1240. \nPlaintiff and his mother participated in t he November 2002 IEP meeting, received the\nNotice of Procedural Safeguards, indicat ed she understood her rights, and consented to\nthe IEP. AR 308; 1246. De fendant then implemented the BSP. AR 605. While plaintiff\ncontinued to receive disciplinary referrals and suspensions after the creation of the BSP,\nthey were less frequent than the disciplinary refe rrals that plaintiff received prior to the\nimplementation of t he BSP. AR 652; 977. \nSeveral months later, on April 8, 2003, Ms. XXXXXXX wrote to Marvin Meyers, the\nDistrict’s Director of Special Education, and requested a change of placement for her son,\ndue to plaintiff’s continuing behavior problem s and his inability to benefit in his current\nplacement. AR 248-49; 1252. In response, an IEP team meeting was thereafter held on\nMay 1, 2003. AR 1257-66. As the reports s ubmitted in connection with the May 2003 IEP\nstated, plaintiff was continuing to exhibit negative behaviors, including tardiness, defiance\nof authority, and use of profani ty, among other things. AR 1265. Plaintiff’s behavior was\ndescribed as “totally distracting to the class and instruction.” Id\n. Nonetheless, based on\nthe information discussed with plaintiff’s teacher s at the IEP team meeting, plaintiff’s\nmother “rescinded her request for change in plac ement,” and the May 2003 IEP resulted in\nno changes to the October 4, 2002 and Novem ber 12, 2002 IEPs that were already in\nplace. AR 249; 1258; 1262. \nShortly thereafter, on May 13, 2003, plainti ff was arrested for stealing beer from a\nSan Mateo supermarket during school hours. AR 995; 1285. Defendant District was notCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 4 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n5notified of plaintiff’s arrest, however, or of any subsequent juvenile court proceedings. \nOn November 13, 2003, plaintiff’s IEP team once again convened, this time for\nplaintiff’s annual review. AR 1268-81. The IEP team noted that plaintiff’s “greatest\nweakness [was] his truancy.” AR 1274. The t eam further noted that it was difficult to\ngauge whether plaintiff’s current placement wa s effective, due to excessive absences on\nhis part. AR 695; 974. In the area of s peech and language, plaintiff’s truancy prevented\nthe IEP team from formally assessing pl aintiff. However, the speech and language\npathologist, Ms. Fox, was also plaintiff’s tr eating therapist for the past two years, and\ntherefore was able to review records and refl ect on her observations of plaintiff during\ntherapy sessions, in order to identify speech and language needs, and draft accuratepresent levels of performance. AR 695; 974; 1279. Ms. Fox also recommended modifying\nplaintiff’s speech and language goals, and changing to consultation speech services,because of plaintiff’s frequent truancy. AR 690- 91. Specifically, Ms. Fox was concerned\nabout the effect of pulling plaintiff out of hi s academic classes for speech, given his truancy\nand poor grades. By switching to speech and language services on a consultation basis,the idea was to afford plaintiff a chance to improve his attendance. Id\n. \nIn the area of academics, the November 200 3 IEP team – which included plaintiff’s\ngeneral education and special education teacher s – developed accurate present levels of\nperformance based on current observations of plai ntiff in the classroom. AR 616-22; 969;\n971. The team noted that plai ntiff’s strengths included reading comprehension, vocabulary,\nand creative writing. Weaknesses incl uded attendance, expository writing, and\nmathematics. AR 743-45. The IEP team recommended placement in SDC for three\nperiods per day. AR 968. \nThe IEP team also found that the Nove mber 2002 BSP was no longer appropriate,\nas plaintiff’s primary struggle was now with tr uancy. Accordingly, the IEP team developed\na new BSP at the November 2003 meeting. Th is revised BSP provided for daily planner\nchecks, one-one-one assistance during tutorial at least twice a week, weekly progressCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 5 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n6reports, positive progress reports sent home, and counseling from the District probation\nofficer to discuss the legal rami fications of plaintiff’s truan cy. AR 748; 750; 975. The\nNovember 2003 BSP also required plaintiff’s s pecial education teacher to personally call\nplaintiff on his cell phone when he did not appear in class, or to call Ms. XXXXXXX. AR751. Plaintiff was not referred to the County Mental Health Department. Ms. XXXXXXX\nparticipated in the November 2003 IEP team m eeting, received the notice of procedural\nsafeguards, and consented to the IEP. AR 315-16. \nIn the first two months following impl ementation of the BSP, between November\n2003 and January 2004, plaintiff’s grades improv ed. AR 752. In December 2003 and\nJanuary through February 2004, however, plaint iff received suspensions for truancy from\nschool, and for disrupting activities and defying school policies. AR 1237-38; 1250. \nOn March 4, 2004, plaintiff’s May 2003 arrest was adjudicated by the Alameda\nCounty Juvenile Court. The court adjudged plaint iff a ward of the court and ordered plaintiff\nto serve 60 days in juvenile hall. AR 1000. However, as an alternative to this sentence,\nthe court approved plaintiff’s enrollment in a wilderness program called the Rocky Mountain\nAcademy, in Colorado – at his parent’s expens e. AR 998-99; 1287. Ultimately, Ms. \nXXXXXXX enrolled plaintiff in the Ascent program in Idaho, a six week wilderness\nintervention program. AR 281; 380; 2006. Plaintiff began the program at some point\nbetween March 18 and March 21, 2004. AR 998; 1002. On March 22, 2004, Ms.\nXXXXXXX informed plaintiff’s special educat ion teacher, Ms. Hahn, that plaintiff was\nattending the Ascent program. AR 837. S he made no request that the District fund the\nprogram. AR 325-26. \nPlaintiff attended Ascent from March 22, 2004 through May 5, 2004. AR 998; 1411. \nWhile there, he made progress with certain ma ladaptive behaviors. AR 384-85. Upon his\ncompletion of the program at Ascent, it wa s recommended by Ascent staff that plaintiff\nattend a residential CEDU High School in San Bernardino. AR 998; 1301. On May 6,\n2004, the Juvenile Court adopted this recommendation, and upon the court’s order, plaintiffCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 6 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n7attended the CEDU High School until its closur e in March 2005. AR 997; 1006; 1333. \nWhile at CEDU, plaintiff earned a 2.60 GPA. AR 1335. After the CEDU school’s closure,\nplaintiff was sent home while an appropriate school placement could be located. Plaintiff’s\nprobation officer noted in her report that no pub lic or private schools met plaintiff’s needs in\nthe surrounding area. AR 1296. Court records indicate that, after weighing the options,\nplaintiff and his parents concluded that the M t. Bachelor Academy in Oregon was the best\nplacement, and that the court allowed plaintiff to be placed there at the parents’ expense. \nAR 1006; 1296; 1304. \nPlaintiff enrolled at Mt. Bachelor on May 11, 2005, where he finally graduated with a\nHigh School Diploma in June 2006. AR 1401. Wh ile at Mt. Bachelor, plaintiff earned As,\nBs, and Cs, although he also continued to demonstrate behaviors such as truancy, lowgrades, refusal to participate in class, and alcohol and tobacco abuse. AR 1110-11; 1113;\n1115; 1360-67; 1370-71- 1383- 89; 1398-99; 1400; 1404. \nOn July 20, 2006, Ms. XXXXXXX filed a request for due process, seeking\nreimbursement for plainti ff’s private placements. \nB. The ALJ Decision\nThe due process hearing occurred on December 18-20, 2006. See\n AR 228; 2106. \nThe Administrative Law Judge (“ALJ”), Suzanne Brown, considered the following issues at\nthe hearing:\n1. Did the District deny plaintiff a FAPE from July 19, 2003 through the 2005-06\nschool year by failing to: (a) assess plainti ff’s behavioral needs; (b) meet plaintiff’s unique\nneeds for behavioral and mental health services;\n2. Did the District deny plaintiff a FAPE from November 12, 2003, through the\n2005-06 school year by failing to: (a) have a school psychologist attend the November 13,\n2003 IEP team meeting; (b) assess plaintiff in the areas of behavior, speech and language,\nand academics; (c) provide adequate present leve ls of performance in the November 13,\n2003 IEP in the areas of behavior, speec h and language, and academics, which deniedCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 7 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n8plaintiff educational opportunity and his parent an opportunity to participate in the decision-\nmaking process; (d) include adequate goals in t he November 13, 2003 IEP in the areas of\nbehavior, speech and language, academics, and m ental health, which denied plaintiff\neducational opportunity and his parent an opportuni ty to participate in the decision-making\nprocess; and (e) meet plaintiff’s uni que speech and language needs in the areas of\ndysfluency, and expressive rec eptive and pragmatic language skills; and\n3. If the District denied plaintiff a FAPE, is Ms. XXXXXXX entitled to\nreimbursement for private school placements from March 2004 to June 2006, and related\ntransportation costs.\nALJ Brown issued a decision on February 8, 2007. With respect to the first issue,\nthe ALJ concluded that plaintiff failed to demonstrate that the District denied him a FAPE\nfrom July 19, 2003 through the 2005-06 school year . AR 158. Specifically, the ALJ found\nthat the District had not failed to assess plai ntiff’s behavioral needs, and furthermore did not\nfail to assess plaintiff’s unique behavioral and mental health needs. Id . Similarly, on the\nsecond issue, the ALJ also found that plaintiff had failed to establish that the District denied\nhim a FAPE from November 12, 2003 through t he 2005-06 school year, and made specific\nfindings with respect to each of the sub-iss ues presented. AR 158-59. Finally, the ALJ\nfound that, with respect to the last issue, plai ntiff’s mother is not entitled to reimbursement\nfor the private school placements or rela ted transportation costs. AR 159. \nPlaintiff now seeks reversal of the ALJ’ s decision, reimbursement for educational\nexpenses, and attorneys’ fees and costs. De fendant, by contrast, seeks an order affirming\nthe findings of the ALJ in their entirety. \nDISCUSSION\nA. Legal Standards\n1. Summary Judgment\nSummary judgment shall be granted if “the pleadings, depositions, answers to\ninterrogatories, and admissions on f ile, together with the affidavits, if any, show that there isCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 8 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n9no genuine issue as to any material fact and t hat the moving party is entitled to judgment\nas a matter of law.” FRCP 56(c). Material facts are those which may affect the outcome of\nthe case. See Anderson v. Liberty Lobby, Inc ., 477 U.S. 242, 248 (1986). A dispute as to\na material fact is genuine if there is sufficient evidence for a reasonable jury to return a\nverdict for the nonmoving party. Id . The court must view the facts in the light most\nfavorable to the non-moving party and give it the benefit of all reasonable inferences to be\ndrawn from those facts. Matsushita Elec. Indus. Co. v. Zenith Radio Corp ., 475 U.S. 574,\n587 (1986).\n2. IDEA ClaimsThe IDEA requires school districts to provide disabled children with a “free\nappropriate public education” (“FAPE”). 20 U. S.C. § 1412(1). The education to which\naccess is provided must be “reasonably calculated to enable the child to receiveeducational benefits.” Bd. of Educ. of Hendr ick Hudson Central Sch. Dist. Westchester\nCounty v. Rowley , 458 U.S. 176, 207 (1982). To that end, the IDEA requires school\ndistricts to create an “individualized education program” (IEP) for each disabled child. Id . It\nfurther authorizes parents challenging their child ’s IEP to request an “impartial due process\nhearing.” See id . at § 1415(f). The party that has requested the hearing bears the burden\nof proof at the hearing. See Schaffer v. Weast , 126 S.Ct. 528, 537 (2005). \nA party aggrieved by the findings and decis ion made in a state administrative due\nprocess hearing has the right to bring an original civil action in a state court of competent\njurisdiction or in federal district court in or der to secure review of the disputed findings and\ndecisions. See 20 U.S.C. § 1415(i)(2). The party challenging the decision bears the\nburden of persuasion on its claim. See Clyde K. v. Puyallup Sch. Dist. No. 3 , 35 F.3d 1396,\n1399 (9th Cir. 2004). In reviewing the administr ative decision, the district court “shall\nreceive the records of the administrative pr oceedings; shall hear additional evidence at the\nrequest of a party; and basing its decision on the preponderance of the evidence, shall\ngrant such relief as the court determines is appropriate.” 20 U.S.C. § 1415(i)(2)(B). Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 9 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n2This claim is distinguishable from plai ntiff’s claim that, because the November\n12, 2002 IEP was not based on an Environmental Assessment, the BSP that was developed\nand which was in operation from July 2003 to November 2003, reflected a denial of a FAPE.\n10Judicial review of state administrative proceedings under the IDEA is less deferential\nthan the review of other agency actions. S ee Ojai Unified School District v. Jackson , 4\nF.3d 1467, 1471 (9th Cir. 1993). However, “becaus e Congress intended states to have the\nprimary responsibility for formulating each indivi dual child’s education, [courts] must defer\nto their ‘specialized knowledge and experience’ by giving ‘due weight’ to the decisions of\nthe states’ administrative bodies.” Amanda J. Ex rel. Annette J. v. Clark County Sch. Dist .,\n267 F.3d 877, 888 (9th Cir. 2001). This review requires the district court to carefully\nconsider the administrative agency’s findings . See Susan N. v. Wilson Sch. Dist ., 70 F.3d\n751, 758 (3d. Cir. 1995). “The amount of defer ence accorded the hearing officer’s findings\nincreases where they are thorough and care ful.” Capistrano Unified Sch. Dist. v.\nWartenberg , 59 F.3d 884, 891 (9th Cir. 1995). After such consideration, “the court is free to\naccept or reject the findings in part or in whole.” Susan N ., 70 F.3d at 758. When the court\nhas before it all the evidence r egarding the disputed issues, it may make a final judgment in\nwhat “is not a true summary judgment proc edure [but] a bench trial based on a stipulated\nrecord.” Ojai , 4 F.3d at 1472. \nB. The Parties’ Cross-Motions for Summary Judgment\nThe parties’ cross-motions raise the followi ng issues for resolution: (1) whether the\nALJ properly concluded that the District did not deny plaintiff a FAPE from July 19, 2003\nthrough the 2005-06 school year; (2) whether t he ALJ properly concluded that the District\ndid not deny plaintiff a FAPE from Novem ber 13, 2003, through the 2005-06 school year;\nand (3) whether the ALJ properly conclude that Ms. XXXXXXX was not entitled to reim-\nbursement for private school plac ements from March 2004 to June 2006. \nPreliminarily, however, the cour t notes that in addition to these issues, plaintiffs raise\nothers that defendant has correctly noted are time- barred. For example, plaintiffs argue in\ntheir papers that the November 2002 IEP that was drafted constituted denial of a FAPE,2Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 10 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n3The ALJ noted July 19, 2006 as the operat ive date of filing for statute of\nlimitations purposes.\n4A Behavior Intervention Plan is usually developed following a Functional Analysis\nAssessment (“FAA”) or Functional B ehavioral Assessment (“FBA”). See Cal. Code. Regs. Tit.\n5, § 3001 (aa, f).\n11and that a FAPE was further denied when defendant District failed to include necessary\nmembers at the November 12, 2002 and May 1, 2003 IEP meetings. See Pl. Mot. Summ.\nJudgm. at 22:24-23:10; 25:24-26:19. Neither party disputes, however, that plaintiff’s\nclaims, which were administratively filed on July 20, 2006, are subject to a three year\nstatute of limitations. See Cal. Educ. Code § 56505(l), eff. October 7, 2005 to October 8,\n2006 (amended by Cal. Educ. Code § 56505(l), eff. Oc tober 9, 2006). Accordingly, plaintiff\ncannot assert any claims arising out of conduct occurring prior to July 20, 2003, and hisclaims relating to defendant’s denial of F APE in connection with the November 12, 2002\nIEP and IEP meeting, and the May 1, 2003 IEP meeting, are barred.\n3 Moreover, because\nthe ALJ did not have occasion to pass upon these claims, they are furthermore barredbecause plaintiff failed to exhaust all administr ative remedies in connection with the claims.\nThe court now turns to the substantive issues before it. 1. Whether the District denied plaintiff a FAPE from July 19, 2003 through the\n2005-06 school year\nPlaintiff contends that the District denied him a FAPE for the above-referenced\nperiod when it (a) failed to properly assess hi s behavioral needs; and (b) failed to meet his\nbehavioral needs. With respect to the former, plaintiff argues that the District failed to\nconduct an environmental assessment in c onnection with the November 12, 2002 IEP\nmeeting, leading to an ineffective BSP that fail ed to meet plaintiff’s needs, and furthermore,\nthat the District failed to offer a Behavior Intervention Plan.4 See Pl. Mot. Summ. Judgment\nat 21-23. With respect to the latter, plaintiff argues that the District failed to meet his unique\nbehavioral needs when it failed to refer plaintiff for County Mental Health Services, despiteCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 11 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n12the fact that plaintiff’s behavior, grades, and attendance record mandated as much. See id .\nat 25; see also Pl. Opp. to Summ. Judgm. at 8-10. For the reasons that follow, however,\nthe court finds that plainti ff’s arguments are without merit. \na. District’s failure to assess plaintiff’s behavioral needs \nThe issue before the court is whether t he District failed to conduct an environmental\nassessment and a FAA or FBA leading to a Behavior Intervention Plan, and if so, whethersuch failure constituted a denial of a FAPE. In the underlying administrative decision, the\nALJ found that it was unclear whether the District conducted an environmental assessment\nin November 2002, as witness testimony on the matter was not conclusive. However, the\nALJ found that the team member s present at the November 2002 IEP did identify plaintiff’s\nbehavior problems and adopted a BSP to deal wit h those problems, which BSP actually\nresulted in a decrease in frequency of those behav ior problems. AR 149. As for whether\ndefendant District was obligated to provide a F AA or FBA, the ALJ found that plaintiff’s\nbehavior, as noted in the IEP meeting notes , did not constitute a “serious behavior\nproblem” requiring an FAA, which would have resulted in a Behavior Intervention Plan. While acknowledging that plaintiff’s truancy problem did become a behavior problem in fall\nof 2003, the ALJ concluded that this was deal t with by defendant District in the November\n2003 IEP and BSP. Id\n.\nPlaintiff has not pointed to any evidentiary dispute that demonstrates error on the\nALJ’s part. First, even assuming that the Dis trict failed to undertake an environmental\nassessment before the November 2002 BSP wa s developed and implemented, this failure\ndid not constitute a denial of a FAPE. Procedural violations – such as the failure to conduct\nthe environmental assessment – only constitute a denial of a FAPE if the violation caused a\nloss of educational opportunity to the student or significantly infringed on the parents’ right\nto participate in the IEP process. See, e.g., R.B., ex rel. F.B.v. Napa Valley Unified School\nDist., 496 F.3d 932, 938 (9th Cir. 2007). Here, t he BSP that resulted from the November\nIEP was intended to address plaintiff’s probl ems with attendance, punctuality, motivation,Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 12 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n13anger, and defiant behaviors. AR 604-05; 1170; 1249. And, as the ALJ found, the BSP\nactually succeeded in decreasing plaintiff’s disruptive behaviors by the beginning of the\n2003-04 school year. AR 652; 977. Moreover, pl aintiff and his mother were present at the\nNovember 2002 IEP team meeting at which t he BSP was developed. Plaintiff’s mother did\nnot object, and even consented to the November 2002 IEP and BSP. AR 306. \nAccordingly, even if the District fail ed to conduct an environmental assessment in\nconnection with the November 2002 IEP, this did not rise to the level of a denial of a FAPE.\nPlaintiff asserts that his behavior – spec ifically, plaintiff’s truant behaviors –\nnonetheless deteriorated following the November 2002 IEP, such that plaintiff’s truancy\nbecame the target behavior by the time t he November 13, 2003 IEP was prepared and\nconducted. Yet the District continued in its failu re to conduct proper assessments, resulting\nin an ineffective November 2003 BSP that failed to properly address plaintiff’s truancy, and\ntherefore also denied plaintiff a FAPE. While plaintiff contends that his truant behaviors\nwere ignored, the testimony of certain Nove mber 2003 IEP team members was that the\nNovember 2003 BSP was developed with the express purpose of targeting plaintiff’s truant\nbehaviors, and that this focus had shifted from the prior BSP entered in November 2002. \nAR 748. The November 2003 IEP also expressl y noted that plaintiff’s “greatest weakness”\nwas truancy, and set forth increased attendance as a goal and objective. AR 966, 969,971. To that end, the revised BSP that was developed at the November 2003 IEP team\nmeeting set forth several proposed adjustments in plaintiff’s educational services in order to\naddress the truancy issues. Specifically, the revised BSP required daily planner checks,one on one assistance, referral to a truancy pr obation officer, and phone calls to plaintiff\nfrom plaintiff’s teacher and mother when he was not in attendance at school. AR 748-51;\n975. According to testimony given at the hear ing, implementation of this revised BSP did,\nin fact, help improve plaintiff’s attendance after it was implemented. AR 752. Thus, not\nonly was the BSP adopted in November 2003 tailor ed to meet plaintiff’s unique behavioral\nneeds in the area of truancy – the primary tar get behavior identified at the time – but theCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 13 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n14BSP also resulted in some improvement. Accord ingly, there is no evidence that a failure to\nproperly assess plaintiff’s needs in c onnection with the November 2003 IEP and\nsubsequent BSP resulted in a loss of educational oppor tunity for plaintiff, or the denial of a\nFAPE.\nFinally, with respect to plaintiff’s content ion that the District’s wrongfully failed to\nconduct an FAA or FBA and to implement a B ehavior Intervention Plan, the ALJ properly\nconcluded that no FAA or FBA – and theref ore no Behavior Intervention Plan – was\nnecessary. California law requires that a FAA be undertaken whenever a student develops\na “serious behavior problem,” which is defi ned as a student’s actions exhibiting self-\ninjurious, or assaultive tendencies, or a student’s actions in causing serious property\ndamage or other pervasive and maladaptive tendencies. See Cal Code Regs., tit. 5 §\n3001. Plaintiff, however, has not pointed to any affirmative evidence in the record that\ndemonstrates, prior to November 2002, either plaintiff’s self-injurious or assaultive\ntendencies, or plaintiff’s actions causing se rious property damage, or defendant District’s\nknowledge of such. Accordingly, there is no evidence that supports the existence of a\n“serious behavior problem” that would hav e warranted a FAA, FBA, or Behavior\nIntervention Plan. \nb. District’s failure to meet plaintiff’s behavioral needs\nPlaintiff also asserts that the District deni ed him a FAPE by refusing to refer him for\nCounty Mental Health Services. The ALJ found that no referral to Mental Health Services\nwas necessary. AR 149-51. This was bas ed on the finding that the only significant,\nfrequent behavior preventing plaintiff from benef itting from his education – and possibly\ntriggering a mental health referral – was truan cy. AR 149. Yet the ALJ found that the\nDistrict attempted to address the truancy behavior through the November 2003 revisedBSP, which in part referred plaintiff to a truancy officer. AR 150. This, combined with the\ntestimony of plaintiff’s teachers stating that they did not think plaintiff exhibited a need for\nmental health services, led the ALJ to conclude t hat the District’s failure to refer plaintiff didCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 14 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n5Furthermore, the ALJ provided sound re asons for discrediting plaintiff’s\nwitnesses, who testified that plaintiff needed mental health serv ices while at Hillsdale: those\nwitnesses were not familiar with plaintiff’s placem ent or services at Hillsdale, and two of them\nworked with plaintiff more than two years after plaintiff left Hillsdale. AR 151. Accordingly,\ntheir testimony was speculative. \n15not constitute a denial of FAPE.5 AR 151.\nIn general, the ALJ correctly noted that a local educational agency (“LEA”) such as\ndefendant District may refer a student for comm unity mental health services when the\nstudent has emotional or behavioral characteri stics that: (1) are observed by qualified\neducational staff in educational and other settings, as appropriate; (2) impede the pupilfrom benefitting from educational services; (3) ar e significant, as indicated by their rate of\noccurrence and intensity; (4) are associat ed with a condition that cannot be described\nsolely as a social maladjustment as demonstrated by deliber ate noncompliance with\naccepted social rules, a demonstrated abilit y to control unacceptable behavior and the\nabsence of a treatable mental disorder; and (5 ) are associated with a condition that cannot\nbe described solely as a temporary adjustment problem that can be resolved with less than\nthree months of school counseling. See\n AR 157; see also Cal. Gov’t Code § 7576 (b)(3). \nThe LEA must also first have provided appropriate services, however, such as counselingor behavioral intervention, and the IEP team mu st have determined that the services do not\nmeet the student’s individual needs. See id\n. at § 7576 (b)(5). \nHere, plaintiff does not actually identify the emotional or behavioral characteristic\nthat he contends warranted a referral to mental health service. Plaintiff states only that the\nDistrict should have made such a referral “based on [plaintiff’s] behavior and the District’sown failed BSPs of November 2002 and Novem ber 2003,” and that plaintiff “failed his\nclasses, became a habitual truant and had numerous referrals for discipline.” See\n Pl. Opp.\nto Summ. Judgm. at 9. Even assuming, however, that truancy, failed classes, and\ndiscipline referrals constituted qualifying em otional and/or behavioral characteristics as\noutlined above, it has not been dem onstrated that the District attempted to provide services\nthat were unable to meet plaintiff’s indi vidual needs. Indeed, as discussed above, theCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 15 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n6Defendants point out in their motion for su mmary judgment that the ALJ’s opinion\nsometimes states that the No vember 13, 2003 IEP meeting o ccurred on November 12, 2003.\nThis appears to be a confusion wit h the November 12, 2002 IEP me eting. Accordingly, all\nreferences herein are to the November 13, 2003 IEP meeting, not withstanding the ALJ’s\nstatement to the contrary. \n16evidence demonstrates the opposite – i.e., that the November 2002 and November 2003\nBSPs actually did succeed in improving the maladaptive behaviors that were noted in\nplaintiff’s respective IEPs. Furthermore, a Behavior Intervention Plan was not mandated,\nbased on the record presently before the court. \nIn sum, the ALJ’s finding that no referral to County Mental Health Services was\nrequired, is supported by the record. See also AR 150-51; 375-394; 530-32; 553-54; 750-\n52; 760-63; 965-975; 989. \nThe court therefore affirms the ALJ’s findings and conclusions with respect to the\nfirst issue before the court – i.e., whether t he District denied plaintiff a FAPE from July 19,\n2003 through the 2005-06 school year, by failing to properly assess and/or meet plaintiff’s\nbehavioral needs. Defendant’s motion for summary judgment as to this issue isaccordingly GRANTED, and plaintiffs’ cro ss-motion for summary judgment on the same\nissue is DENIED. \n2. Whether the District denied plaintiff a FAPE from November 13, 2003 through\nthe 2005-06 school year6\nPlaintiff contends that the District denied him a FAPE for the above-referenced\nperiod for several reasons. Each issue considered by the ALJ, is addressed in turn. \na. failure to have a school psychologist attend the November 13, 2003\nIEP team meeting \nThe November 2003 IEP meeting consis ted of: general education teacher Ms.\nRianda, special education teacher Ms. Hahn, speech and language pathologist Ms. Fox,\nplaintiff, and plaintiff’s mother. AR 151, 963- 975. Plaintiff, however, contends that the\nDistrict violated procedure and denied plaintiff a FAPE, because it did not have a school\npsychologist attend the meeting.Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 16 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n17The federal IDEA and the California Educati on Code require that IEP team meetings\ninclude: parents, at least one regular educati on teacher, at least one special education\nteacher, a representative of t he public agency who is qualified to provide or supervise the\nprovision of instruction designed to meet the needs of children with disabilities, an individual\nwho can interpret the implications of evaluat ion results, and the child if appropriate. The\nlast individual may already be a member of the team. See 34 C.F.R. § 300.344(a)(1999);\nCal. Educ. Code § 5634. \nThe ALJ noted that California law provides that where a student is suspected of\nhaving a learning disability, at least one mem ber of the team shall be qualified to conduct\nindividual diagnostic examinations of childr en, such as a school psychologist, speech-\nlanguage pathologist, or remedial reading teac her. The Code of Federal Regulations\nfurther clarifies that a school psychologist’s attendance is required only when determining\neligibility under the learning disab ility category. Accordingly, since plaintiff here had already\nhad his eligibility under the law determined, t he ALJ concluded that no school psychologist\nwas required to attend the November 2002 IEP meeting. Furthermore, the ALJ noted that\nin addition to the attendance of speech and language pathologist Ms. Fox at the November\n2002 IEP meeting, Ms. Rianda and Ms. Hahn both gav e testimony at the hearing that their\neducation and training included training in dra fting BSPs. Accordingly, the ALJ concluded\nthat while helpful, a school psychologist was not required by either state or federal law. \nNot only are the ALJ’s observations with respect to the law thorough and accurate,\nbut plaintiff has not introduced any law or evi dence here that contradicts these conclusions. \nAccordingly, the court concludes that the ALJ was correct in deciding that the District did\nnot deny plaintiff a FAPE by not having a school psychologist attend the November 2003IEP meeting. \nb. failure to assess plaintiff in the areas of behavior, speech and\nlanguage, and academics \nThe ALJ concluded that the District did not deny plaintiff a FAPE by failing to assessCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 17 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n7Plaintiff does contend that the District fa iled to offer plaintiff direct speech\nlanguage therapy when it switched to consultation services as part of the November 2003 IEP.\nHowever, this is more properly construed as an argument that defend ant failed to provide\nproper services, rather than an argument relating to defendant’s failure to assess plaintiff, and\nis addressed below, in connection with defendant’s pur ported failure to meet plaintiff’s unique\nspeech and language needs.\n18plaintiff in the areas of behavior, speech and language, and academics. With respect to\nbehavior, and as mentioned above, the ALJ concl uded that the District assessed plaintiff’s\nbehavioral needs when it modified plaintiff’s BSP in November 2003. With respect to\nspeech and language, as well as academics, the ALJ concluded that the District wasrequired by law to assess plaintiff in all areas related to his disability at least once every\nthree years, unless the parent and the school agree in writing that a reassessment is\nunnecessary. AR 152. And since the District c onducted its triennial assessment of plaintiff\nin fall 2002 with three diagnostic tests – the WRAT, Bruckner math test, and the PIAT –there was no need to reassess plaintiff between fall of 2002 and March of 2004, when\nplaintiff left Hillsdale. AR 152, 587. Fu rthermore, the ALJ noted that plaintiff had\nintroduced no evidence warranting reassessment in November 2003, nor did the record\nreflect that plaintiff’s mother had requested reassessment. AR 152. \nAs is repeatedly the case in the motion paper s, plaintiff has failed to present any\nevidence that presents a dispute of fact on the re levant issues. Plaintiff mentions almost no\nevidence\n7 relating to the District’s purported failure to assess plaintiff academically, and as\nfor the District’s speech and language assessment, plaintiff also fails to point to any\nevidence that would indicate a failure to asse ss plaintiff as required by law. Moreover,\nplaintiff’s mother never requested reassessm ent as to the District’s speech and language\nassessments. AR 316. \nIn sum, there is no dispute present that calls into question the ALJ’s conclusion that\nthe district properly assessed plaintiff’s behavioral, academic, and speech and language\nneeds from July 19, 2003 through the 2005-06 school year. \nc. failure to provide adequate present levels of performance in theCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 18 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n19November 13, 2003 IEP in the areas of behavior, speech andlanguage, and academics\nPlaintiff also asserts that the District failed to provide adequate present levels of\nperformance in the November 2003 IEP in the areas of behavior, speech and language,\nand academics. As defendants acknowledge, t he IDEA requires that a student’s annual\nIEP contain a statement of the student’s present levels of academic achievement and\nperformance, including the manner in which t he student’s disability affects his or her\ninvolvement and progress in the gener al education curriculum. See\n 20 U.S.C. §\n1414(d)(1)(A)(i); Cal. Educ. Code § 56345(a)(1)(A). \nThe ALJ noted that the November 2003 IEP contained limited information about\nplaintiff’s present levels of performance. While it listed some information, such as plaintiff’s\nstrengths and preferences, his scores on some te sting, and his areas of need, the IEP did\nnot contain specific information regarding ac ademic assessments, or regarding the goals\nand objectives for plaintiff. AR 152. This was because of plaintiff’s excessive truancy. The\nIEP states: “current testing has not been performed due to excessive absences...”. Id .; see\nalso AR 969. Nor did the November 2003 IEP contain any “baseline” data from which\nplaintiff’s student performance may be assessed. AR 152. The ALJ found, however, that\nbecause plaintiff’s teachers and speech therapist established that they were familiar with\nplaintiff’s needs from working with him in the past and seeing him occasionally in fall 2003,\nthey were able to make knowledgeable recommend ations about plaintiff’s IEP program. Id . \n Now, plaintiff contends that the AL J’s conclusion was error, because the District’s\nfailure to assess his present academic levels made it (a) impossible to determine if the\ngoals proposed adequately addressed plaintiff’s academic needs, and (b) made it\nimpossible for Ms. XXXXXXX to determine if t he District’s offered program met plaintiff’s\nneeds. \nThese arguments fail to persuade. As to t he former, while true that the November\n2003 IEP expressly stated that current test ing could not be performed due to “excessiveCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 19 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n20absences,” the IEP does contain descriptions of plaintiff’s performance to the extent\npossible, including notations regarding plainti ff’s attendance problems, failure to turn in\npaperwork, GPA score, and the credits requir ed to graduate. AR 1274. The IEP also\nstates that until plaintiff “attends school regul arly, the current placement will continue to be\nthe least restrictive and most appropriate environment for [plaintiff.]” Id . Moreover, the IEP\nthat was left in place was designed, as the ALJ found, by teachers with knowledge of\nplaintiff’s needs and past performance, and t he BSP that was newly revised at the\nNovember 2003 IEP meeting was specifically done with the purpose of aiding the truancy\nproblems so that plaintiff could get back on tr ack academically. Therefore, even though the\nDistrict was admittedly unable to assess plai ntiff’s present levels of performance\nthoroughly, the District was still able to ma ke knowledgeable recommendations regarding\nplaintiff’s proposed IEP, and to recommend a BSP that would target plaintiff’s truancy and\nallow him to benefit from his education. \nAs for plaintiff’s argument that the lack of present levels of performance made it\nimpossible for Ms. XXXXXXX to partici pate and determine whether the District’s\neducational offerings met plaintiff’s needs, plaint iff does not dispute that Ms. XXXXXXX was\npresent at the November 2003 IEP team meeting, or that Ms. XXXXXXX subsequently\nconsented to the November 2003 IEP without rais ing any objections, either at the meeting\nor afterwards. AR 315-16. Nor does plaintiff s ubmit any legal authority that suggests that a\nparent’s lack of meaningful participation in the IEP process occurs under factual\ncircumstances similar to the case at bar.\nIn sum, to the extent that the District fa iled to include present levels of performance\nin connection with the November 13, 2003 IEP, it did not constitute a denial of a FAPE. \n d. failure to include adequate goals in the November 13, 2003 IEP in the\nareas of behavior, speech and language, academics, and mental\nhealth\nThis issue is related to the preceding issue. Plaintiff contends that, since the DistrictCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 20 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n21failed to ascertain plaintiff’s present levels of performance in connection with the November\n2003 IEP, then the District also failed to prov ide adequate goals, as required by IDEA. See\n20 U.S.C. § 1414(d)(1)(A)(i)(II); Cal. Educ. C ode § 56345(a)(2). For the following reasons,\nplaintiff is incorrect. \nFirst, as discussed above, the District’s failure to include present levels of\nperformance did not constitute a denial of FAPE. Accordingly, plaintiff’s argument that the\nsame led to a failure to provide adequate goals, fails. Second, the evidence demonstrates\nthat the November 2003 IEP did include goals that were adequately tailored to plaintiff’s\nneeds. Specifically, the IEP included a st atement of goals related to academic\nperformance (through improved attendance), lit eracy skills (through the writing of\nexpository essays), in math skills (through completion of math homework), and mental\nhealth skills (BSP stated goal of “cooperative and positive attendance”). AR 966-67; 976. \nPlaintiff, moreover, does not dispute that these goals were included. \nAccordingly, the ALJ’s conclusion that t he District’s purported failure to include\nadequate goals in the November 13, 2003 IEP in the areas of behavior, speech and\nlanguage, academics, and mental health did not constitute a denial of a FAPE, is well-\nfounded. The court hereby affirms the ALJ’s decision in this regard.\ne. failure to meet plaintiff’s unique speech and language needs in the\nareas of dysfluency, and expressive receptive and pragmatic languageskills\nFinally, plaintiff contends that the District denied him a FAPE when it failed to meet\nhis unique speech and language needs, and expressive receptive and pragmatic languageskills. Specifically, plaintiff asserts that the Dis trict failed to do so when it adjusted plaintiff’s\ndirect speech therapy to a consultation based service as part of the November 2003 IEP. \nPlaintiff was receiving direct speech l anguage therapy until the No vember 2003 IEP. \nAt the November 2003 IEP, plaintiff’s teac hers determined that the best therapy would be\nvia consultation services. This was in part bec ause of plaintiff’s truancy. As plaintiff’sCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 21 of 24 United States District Court\nFor the Northern District of California1\n23456789\n10111213141516171819202122232425262728\n22speech and language therapist testified, although s he was reluctant to switch plaintiff to\nconsultation services, she felt that “there wa s a power struggle that was going to get set up\naround speech.” AR 690-91. She wanted speech “to be the place [plaintiff] comes to ... towork on goals.” AR 691. Furthermore, plainti ff was missing so many classes that he was\nfailing, and it would be “counterproductive” from “an educational point of view,” to have\nplaintiff show up on the rare occasion, only to have to pull him out of general education\nclasses for speech therapy. To that end, t he recommendation was made to switch plaintiff\nto consultation services, to “hopefully give the behavior plan a chance to work, get himback into school more regularly so that [the speech-language therapist] could re-engagewith him in a productive way.” AR 690. Otherwis e, plaintiff’s therapist continued, “it was a\ntotally unproductive, unworkable therapeutic plan.” Id\n.\nThe ALJ found that plaintiff’s speech and language therapist, who testified to the\nabove, was a “credible and persuasive witness,” and that her testimony established the fact\nthat direct speech therapy “no longer facilitat ed [plaintiff’s] overall educational needs.” AR\n153. Furthermore, because plaintiff had already benefitted from years of speech therapy,\nthe pause in direct therapy sessions would only minimally impact plaintiff’s ability to\nimprove his speech fluency. Finally, the ALJ found that plaintiff had presented no contrary\nevidence on the issue. \nHere, plaintiff argues only that the Distric t’s decision to switch to consultation\nservices was akin to “giving up” on its student – precisely what Congress sought to prevent\nwhen it enacted the IDEA. However, plaintiff offers no authority or contrary evidence in\nsupport of this argument. Indeed, the only evi dence in the record – Ms. Fox’s testimony –\nestablished that the District was not giving up on plaintiff, and that it was attempting\neverything possible to ensure plaintiff’s cont inued improvement. In sum, plaintiff has not\npresented evidence that warrants reversal of the ALJ’s holding on this issue. \nIn conclusion, and with respect to the se cond issue presented before the ALJ – i.e.,\nwhether the District denied plaintiff a FAPE fr om November 13, 2003 through the 2005-06Case 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 22 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n23school year – the ALJ’s decision is affirmed, and summary judgment is GRANTED indefendant’s favor, and DENIED as to plaintiffs.\n3. Whether Ms. XXXXXXX was entitl ed to reimbursement for private school\nplacements from March 2004 to June 2006 \nHaving concluded that the ALJ’s decision is to be affirmed, the court also concludes\nthat Ms. XXXXXXX was not entitled to reim bursement for private school placements from\nMarch 2004 to June 2006. For without proof that plaintiff was denied a FAPE, no\nreimbursement for such denial is appropria te. See Burlington v. Dep’t of Educ ., 471 U.S.\n359, 374 (1985)(“If the courts ultimately det ermine that the IEP proposed by the school\nofficials was appropriate, the parents would be barred from obtaining reimbursement for\nany interim period in which their child’s placement violated § 1415(e)(3)”). \nMoreover, as the ALJ noted, for the entire length of plaintiff’s attendance at private\nschools, Ms. XXXXXXX failed to notify the Distric t of any intent to seek reimbursement. AR\n154. The IDEA provides that reimbursement may be denied or reduced if the parents do\nnot give the school district notice of their int ent to remove a child from public school before\nthey do so. See, e.g. , 20 U.S.C. § 1412(a)(10)(C)(iii)(I). Generally, parents must provide\nsuch notice at the most recent IEP meeting t hat the parents attended prior to the removal of\nthe child from the public school, or by writt en notice ten business days prior to the removal\nof the child from public school. Id . \nHere, plaintiff was arrested in May 2003. AR 995. Several months later, the\nNovember 2003 IEP meeting took place. Ar ound that time (in November or December\n2003), plaintiff’s private therapist first recommended that plaintiff attend the Rocky\nMountain Academy as an alternative to Hillsdale. AR 345-46. Yet there is no evidence that\nplaintiff or his mother informed the District of ei ther plaintiff’s arrest or the private therapist’s\nrecommended education placement, at the November 2003 IEP team meeting, or\nthereafter. Subsequent to 2003, plaintiff appeared in court in January 2004, at which\nappearance the court stated that plaintiff c ould go to Rocky Mountain Academy, which isCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 23 of 24 United States District Court\nFor the Northern District of California1\n23\n4\n56\n789\n101112131415161718\n19202122232425262728\n24\npart of the CEDU program. AR 323. Two mont hs later, in March 2004, plaintiff was\nadjudged a ward of the court. AR 996. Still, throughout all this time, there is no evidence\nthat plaintiff or his mother informed the Distric t of the potential private placement. In fact,\nMs. XXXXXXX did not contact the District to info rm them of plaintiff’s private placement until\nMarch 22, 2004, after plaintiff had been adjudged a ward of the court and after plaintiff had\nalready left for private placement at Ascent [plaintiff went to Ascent instead of Rocky\nMountain Academy]. AR 837, 998, 1002. Ev en then, Ms. XXXXXXX never requested\nreimbursement from the District. The first ti me the District learned of the request for\nreimbursement was when she filed the due process complaint in the underlying\nadministrative action. \nOn balance, these facts demonstrate a co mplete failure to provide adequate notice\nto the District of plaintiff’s private placemen t. Accordingly, even if a denial of a FAPE had\nbeen demonstrated, no reimbursement would be appropriate. For all the foregoing\nreasons, therefore, the court also affirms the ALJ’s decision that reimbursement is not\nwarranted. Defendant’s motion for summary j udgment on this ground is GRANTED. The\ncourt DENIES plaintiffs’ cross-motion with respect to the reimbursement issue. \nC. Conclusion\n The ALJ’s decision is thorough, organized, and detailed, warranting a higher level of\ndeference. To that end, the decision is affi rmed in all respects. Defendant’s motion for\nsummary judgment is GRANTED, and plainti ffs’ cross-motion for summary judgment is\nDENIED. \nIT IS SO ORDERED.Dated: July 3, 2008 \n______________________________\nPHYLLIS J. HAMILTONUnited States District JudgeCase 3:07-cv-02360-PJH Document 36 Filed 07/03/2008 Page 24 of 24"
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"text": "Review and Evaluation of Clinical Data \n \nNDA (Serial Number) 20823 (SE1-016) \nSponsor: Novartis \nDrug: Exelon® (rivastigmine tartrate) \nProposed Indication: Dementia Associated With Parkinson's Disease \nMaterial Submitted: Supplemental New Drug Application \nCorrespondence Date: 8/31/05 \nDate Received / Agency: 9/1/05 \nDate Review Completed 4/18/06 \nReviewer: Ranjit B. Mani, M.D. \n TABLE OF CONTENTS \nExecutive Summary ..............................................................................................3 \nRecommendation ..............................................................................................3 \nProposed Indication ...........................................................................................3 \nSummary Of Clinical Findings ...........................................................................3 \nConclusions .......................................................................................................6 \n1. Background ....................................................................................................7 \n2. Contents Of Submission ................................................................................7 \n3. Contents Of Review .......................................................................................8 \n4. Key Diagnostic Instruments Used in Efficacy Study (Study 2311) .................9 \n4.1 UK Parkinson’s Disease Society Brain Bank Clinical Diagnostic Criteria \nFor Parkinson’s Disease ...................................................................................9 \n4.2 DSM-IV Criteria For Dementia Due To Parkinson’s Disease ................10 \n5. Efficacy Outcome Measures And Select ed Additional Instruments Used In \nEfficacy Study .....................................................................................................10 \n5.1 Alzheimer’s Disease Assessment Scal e – Cognitive Subscale (ADAS-\nCog) 10 \n5.2 Alzheimer’s Disease Cooperative Study – Clinician’s Global Impression \nOf Change (ADCS-CGIC) ...............................................................................10 \n5.3 Alzheimer’s Disease Cooperative Study – Activities Of Daily Living \nScale (ADCS-ADL) ..........................................................................................11 \n5.4 Cognitive Drug Research Co mputerized Assessment System .............11 \n5.5 Delis-Kaplan Executive Functioni ng System (D-KEFS) Test Battery ....12 \n5.6 Mini-Mental Status Examination ...........................................................13 \n5.7 Neuropsychiatry Inventory ....................................................................13 \n5.8 Ten-Point Clock Test ............................................................................13 \n5.9 Symbol-Digit Modalities Test ................................................................14 \n5.10 Health Economic Parameters ...............................................................14 \n5.11 Unified Parkinson’s Disease Rating Scale (UPDRS) ............................14 \n6. Summary Of Key Efficacy Study (EXPRESS Study; Study 2311) ...............15 \n6.1 Outline ..................................................................................................15 \n6.2 Results Of Primary Efficacy Analysis ....................................................15 \n7. Description Of Efficacy Study 2311 (EXPRESS Study) ...............................16 \n7.1 Protocol ................................................................................................16 Ranjit B. Mani, MD, HFD-120 Medical Review Page 2 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.2 Study Results .......................................................................................27 \n7.3 Sponsor’s Conclusions .........................................................................45 \n7.4 Study Abstract ......................................................................................46 \n7.5 Additional Observations And Comment s By Agency Statistical Reviewer \nAbout Study 2311 ............................................................................................47 \n7.6 Reviewer’s Comments ..........................................................................49 \n8. Study 2311E1 (Open-Label Uncontroll ed Extension To Study 2311) ..........50 \n8.1 Protocol 2311E1 ...................................................................................50 \n8.2 Safety Results Of Study 2311E1 ..........................................................52 \n8.3 Sponsor’s Conclusions Regarding Safety .............................................56 \n8.4 Reviewer’s Comments ..........................................................................56 \n9. Study 2314 (Non-Interventional Validation Study) .......................................57 \n9.1 Protocol ................................................................................................57 \n9.2 Main Results .........................................................................................60 \n9.3 Sponsor’s Conclusions .........................................................................66 \n10. Summary Of Earlier Meeting Between Division And Sponsor Regarding \nThis Application. ..................................................................................................67 \n11. Sponsor’s Current View Of Dement ia Associated With Parkinson’s \nDisease, And Appropriateness Of ADAS-Cog And ADCS-ADL In Evaluating \nTreatment Effects In Dementia Asso ciated With Parkinson’s Disease ...............69 \n11.1 Dementia Associated With Park inson’s Disease (Expert Report: \nDiagnosing Dementia Associated With Parkinson’s Disease And Distinguishing \nIt From Alzheimer’s Disease) ..........................................................................69 \n11.2 Appropriateness Of Using The ADAS- Cog And ADCS-ADL As Outcome \nMeasures In Dementia Associated With Parkinson’s Disease ........................74 \n12. Financial Disclosure Certification .............................................................77 \n12.1 Components Of Certification .................................................................77 \nThis certification has been provided on FDA Form 3454. ...................................77 \nThis certification has been provided on FDA Form 3455. ...................................77 \n12.2 Reviewer’s Comments ..........................................................................77 \n13. Site Inspection Report ..............................................................................77 \n14. Review Of Proposed Labeling ..................................................................78 \n15. Comments ................................................................................................78 \n15.1 General .................................................................................................78 \n15.2 Efficacy .................................................................................................78 \n15.3 Safety ...................................................................................................92 \n16. Conclusions ..............................................................................................93 \n17. Recommendation .....................................................................................93 Ranjit B. Mani, MD, HFD-120 Medical Review Page 3 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \nExecutive Summary \nRecommendation \nDeferred, pending discussion of this appl ication at a scheduled meeting of the \nPeripheral and Central Nervous Systems Drugs Advisory Committee \n \nProposed Indication \n“Treatment of mild to moderate dementia associated with Parkinson’s Disease” \n \nSummary Of Clinical Findings \nExelon® is currently approved for marketing in this country, as both capsule and \noral solution formulations, for the treatment of mild to moderate dem entia of the \nAlzheimer’s type. \n \nThe sponsor has provided evidence from two completed clinical studies in \nsupport of the efficacy and safety of Ex elon® for the proposed new indication. \nThese are: \n \n Study 2311, which was randomized, double-blind, placebo-controlled, and \nparallel-arm in design \n Study 2311E1, the open-label uncontrolled extension to Study 2311 \n \nIn addition, the sponsor has performed a non-interventional study (Study 2314) of \nthe validity of a number of assessment scales in the Parkinson’s Disease \nDementia (and vascular dementia); parti al results for this study have been \nsubmitted in this application. \n \nThe data for these studies as they pertain to the efficacy and safety of Exelon® in \nthis population are summarized below, as are the results of the non-\ninterventional validation study listed above. \n \nEfficacy \nThe results of a single randomized, double- blind, placebo-cont rolled study (also \nreferred to as the EXPRESS Study) of the efficacy of rivastigmine in the \nproposed entity of dementia associated with Parkinson’s Disease (also referred \nto interchangeably as Parkinson’s Dis ease Dementia) have been submitted in \nthis application. The main features of this study were as follows \n \n This was a randomized (2:1 [Exelon®:Placebo]), double-blind, placebo-\ncontrolled, parallel-arm study \n \n The key inclusion criteria for the study were as follows \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 4 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \no Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank clinical diagnostic criteria \no Clinical diagnosis of Parkinson’s Disease Dementia according to DSM-IV \ncriteria (Code 294.1) with onset of sy mptoms of dementia within at least \n2 years of the first diagnosis of idiopathic Parkinson’s Disease \no Mini-Mental Status Examination score of 10 – 24 at entry \n \n• The study was of 24 weeks’ duration \n \n• The 2 parallel treatment arms were \n \no Rivastigmine 3 to 12 mg/day (flexible dose) as BID dosing \no Placebo \n \n• The primary efficacy measures were the Alzheimer’s Disease Assessment Scale-\nCognitive subscale (ADAS-Cog) and Alzheimer’s Disease Cooperative Study – \nClinician’s Global Impression Of Change (ADCS-CGIC). \n \n• The secondary efficacy measures were the following: Alzheimer’s Disease \nCooperative Study – Activities of Daily Living Scale (ADCS-ADL); Neuropsychiatry Inventory-10; Mini-Mental Status Examination; Cognitive Drug Research Computerized Assessmen t System; Delis-Kaplan Executive \nFunctioning System (D-KEFS) Verbal Fluency Test; and Ten Point Clock-Drawing Test \n \n• Safety was assessed through adverse events, vital signs, safety laboratory tests, \nelectrocardiograms, and Unified Parkinson’s Disease Rating Scale motor score \n \n• The sponsor’s primary efficacy analysis was performed on the intent-to-treat plus \nretrieved dropouts dataset using the following statistical models \n \no The change from baseline to endpoint in the ADAS-Cog score was to be \ncompared between the treatment groups using an analysis of covariance with \ntreatment, country, and baseline ADAS-C og score as explanatory variables \no The ADCS-CGIC score at endpoint was to be analyzed using a Cochran-Mantel-\nHaenszel test with modified ridits sc ores and with country as a stratification \nvariable \n \nKey results for this study were as follows. \n \n541 patients were randomized, of whom 442 patients completed the study. Their \ndistribution by treatment group was as follows: \n \nTreatment Group Exelon® Placebo\nNumber randomized 362 179 \nNumber completed 263 147 \n \nThe main efficacy results of this study were as follows \n \n The primary efficacy analysis, using Study Week 24 as the endpoint, revealed \nstatistically significant differences between the treatment groups on the ADAS- Ranjit B. Mani, MD, HFD-120 Medical Review Page 5 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nCog (difference in mean change from baseline score at endpoint: 2.90; p < \n0.001) and ADCS-CGIC (difference in mean score between treatment groups at endpoint: 0.5; p = 0.007). Note that an Agency statistical reviewer has judged the \ndistribution of ADAS-Cog data not to be normal and therefore in violation of the \nassumptions of the analysis of covariance model proposed; however, even with the use of a non-parametric model, the Wilcoxon rank sum test, the Exelon® group showed a statistically significant superiority over placebo on this measure \n \n Nominally statistically significant differences were seen between the treatment \ngroups on all secondary efficacy variables at Week 24 in the same dataset as that used for the primary efficacy analysis \n \n Analyses of the primary efficacy parameters using other datasets (intent-to-treat \nlast-observation-carried-forward, and observed cases) yielded similar results. \n \nSafety \nStudy 2311 \nThis study has already been summarized abov e. Salient safety findings for this \nstudy were as follows. \n \n The incidence of nausea, vomiting, and tremor was appreciably higher in the \nrivastigmine group than in the placebo group; a similar adverse event profile was seen in the key controlled clinical tria ls of Exelon® in Alzheimer’s Disease \n Several treatment-emergent adverse events that may have represented a \nworsening in the motor manifestations of Parkinson’s Disease, and tremor in particular, were more frequent in those treated with Exelon® than in those \ntreated with placebo. However, changes in UPDRS total and individual motor \nscores, probably a more objective measure of change in the motor manifestations of Parkinson’s Disease than the incidence of treatment-emergent adverse events, showed no meaningful difference between treatment groups. \n \nStudy 2311E1 \nThis was a 24-week open-label uncontro lled extension to Study 2311 intended \nprimarily to evaluate the safety and tolerability of Exelon® in the study \npopulation. Patients given the option of enrolling in this study had either \ncompleted the double-blind treatment phas e of Study 2311 or discontinued early \nduring that study, but returned for all the remaining scheduled efficacy \nassessments without significant protocol vi olations. Regardless of their previous \ntreatment assignment, patients enrolled in th e extension study were all re-titrated \nto a flexible dose of Exelon® that ranged from 1.5 mg BID to 6.0 mg BID, based \non tolerability. \n \n433 patients enrolled in Study 2311 were eligible to enroll in Study 2311E1, of whom 334 patients actually consented to participate in, and 273 patients, completed the latter study. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 6 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nThe adverse event profile of Exelon® in Study 2311 was broadly similar to that \nseen in Study 2311E1. \n \nNon-Interventional Vali dation Study (Study 2314) \nThis 4-week cross-sectional study wa s intended to evaluate the validity and \nreliability of several measures of cognition , activities of daily living, executive \nfunction and behavior in patients with Parkinson’s Disease Dementia and \nvascular dementia, and to compare the per formance of the same measures in \nthose conditions with their performance in Alzheimer’s Disease. This submission \ncontains an interim report that only per tains to Parkinson’s Disease Dementia. \n \nThe interim report indicates that 55 pati ents with Parkinson’s Disease Dementia \n(diagnosed using the DSM-IV criteria) and 58 patients with Alzheimer’s Disease \n(diagnosed using the NINCDS- ADRDA criteria) were enr olled in the study; \npatients with each diagnosis were fu rther grouped into mild and moderate \ncategories based on Mini-Mental Status Examination scores of 18 to 24 and 10 to 17, respectively, at st udy entry. The efficacy inst ruments evaluated were the \nADAS-Cog, Global Deterioration Scale, ADCS-ADL, D-KEFS Verbal Fluency \nTest, Ten-Point Clock Test, Trailmaking Tests A and B, Neuropsychiatry Inventory, including Neuropsychiatry In ventory-Distress, and Cognitive Drug \nResearch Computerized Assessment System tests for the assessment of attention. Each enrolled patient was to be evaluated using these measures at \nbaseline and Week 4; a ll but 2 patients, both in the Parkinson’s Disease \nDementia group, complet ed their evaluations. \n \nThe results of this study have been inte rpreted as demonstrating the following: \n \n That the ADAS-Cog score can differentiate between dementia associated with \nParkinson’s Disease of mild and moderate severities, as can the scores for \nseveral of the other instruments evaluated in this study \n That the ADAS-Cog and several other efficacy measures had test-retest \nreliability in dementia associated with Parkinson’s Disease \n That the ADAS-Cog scores correlated with those of several other efficacy \ninstruments in dementia associated with Parkinson’s Disease, whether the latter measures assessed cognition or other domains \n A factor analysis that compared populations with Parkinson’s Disease Dementia \nand Alzheimer’s Disease on ADAS-Cog sub-item scores had indicated that the sub-items grouped differently in each population, suggesting that the cognitive \nand behavioral profiles in these populations might differ \n \nConclusions \nDeferred, pending discussion of this appl ication at a scheduled meeting of the \nPeripheral and Central Nervous Systems Drugs Advisory Committee Ranjit B. Mani, MD, HFD-120 Medical Review Page 7 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n1. Background \nThis submission, a Supplemental New Dr ug Application, seeks the approval of \nExelon® (rivastigmine tartrate) for the tr eatment of “mild to moderate dementia \nassociated with Parkinson’s Disease.” \n \nThe data supporting this application are stated to be derived entirely from the \nresults of the EXPRESS (“Rivastigmi ne for Dementia Associated with \nParkinson’s Disease”) Study, also refe rred to as Study 2311. An open-label \nuncontrolled extension to t hat Study 2311, designated as Study 2311E1 has also \nbee completed. \n \nA meeting to discuss this submission and the results of the EXPRESS Study was \nheld between the Division and sponsor on May 18, 2005, and is summarized \nlater in this review. \n \nExelon® (rivastigmine tartrate) is an acetylch olinesterase inhibitor drug approved \nby this Agency on April 21, 2000, for the tr eatment of mild to moderate dementia \nof the Alzheimer’s type, as immedi ate-release capsule and oral solution \nformulations. Please refer to the primar y reviews of NDAs #s 20823 (for the \nimmediate-release capsule formulation) and 21025 (for the oral solution \nformulation) for full details. \n \nIn this review, the terms “Exelon®” and “rivastigmine” are used interchangeably. \nAlso note that “dementia a ssociated with Parkinson’s Disease” is also referred to, \napparently interchangeably, as Parkins on’s Disease Dementia (PDD) in the \nsponsor’s submission. \n \nThe Biometrics Reviewer of this submission is Dr Juan (Joanne) Zhang. \n \n2. Contents Of Submission \nThis submission has been provided in acco rdance, as per the sponsor, with the \nguidance for industry entitl ed Providing Regulatory Submissions In Electronic \nFormat-NDAs (January 1999) \n \nThe key items in this application are: \n \n• Cover letter \n \n• Proposed product labeling \n \n• Application summary \n \n• Clinical and statistical secti on, containing the following: Ranjit B. Mani, MD, HFD-120 Medical Review Page 8 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n Tabular listing of all clinical study reports \n Reports of efficacy and safety studies: Study 2311 and Study 2311E1 \n Report of Study 2314 (non-interventional validation study) \n Publication references \n Tables for Summary of Clinical Safety \n Tables and appendices for Summary of Clinical Efficacy \n \n• Case Report Tabulations \n \n• Case Report Forms \n \n• Patent Information \n \n• Debarment Certification \n \n• Use Fee Cover Sheet \n \n• Financial Disclosure Information \n \n• Confidentiality Statement \n \n3. Contents Of Review \nThe contents of this submission will be addressed under the following principal \nheadings and in the same order as below \n \n Key diagnostic instruments used in efficacy study (Study 2311) \n Efficacy outcome measures and selected additional instruments used in efficacy \nstudy \n Summary of efficacy study \n Description of efficacy study \n Study 2311E1 (open-label uncontrolled extension to Study 2311) \n Study 2314 (non-interventional validation study) \n Summary of earlier meeting between Division and sponsor regarding this \napplication \n Sponsor’s current view of dementia associated with Parkinson’s Disease, and \nappropriateness of ADAS-Cog and ADCS-ADL for evaluating treatment effects in \ndementia associated with Parkinson’s Disease \n Financial disclosure certification \n Site inspection report \n Review of proposed labeling \n Comments \n Conclusion \n Recommendation Ranjit B. Mani, MD, HFD-120 Medical Review Page 9 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n4. Key Diagnostic Instruments U sed in Efficacy Study (Study \n2311) \nThe criteria for 2 diagnostic instrument s used in the efficacy study are listed \nbelow: \n \n4.1 UK Parkinson’s Disease Society Brain Bank Clinical Diagnostic Criteria \nFor Parkinson’s Disease \n \nStep 1 Diagnosis of Parkinsonian syndrome \n Bradykinesia (slowness of initiation of volunt ary movement with progressive reduction in \nspeed and amplitude of repetitive actions) \n \n And at least one of the following: \n \no Muscular rigidity \no 4-6 Hz rest tremor \no Postural instability not caused by primary visual, vestibular, cerebellar, or proprioceptive \ndysfunction. \n \nStep 2 Exclusion criter ia for Parkinson’s disease \n History of repeated strokes with stepwis e progression of parkinsonian features \n History of repeated head injury \n History of definite encephalitis \n Oculogyric crises \n Neuroleptic treatment at onset of symptoms \n Sustained remission \n Strictly unilateral features after 3 years \n Supranuclear gaze palsy \n Cerebellar signs \n Early severe autonomic involvement \n Early severe dementia with distur bances of memory, language, and praxis \n Babinski sign \n Presence of cerebral tumor or co mmunicating hydrocephalus on CT scan \n Negative response to large doses of levodopa (if malabsorption excluded) \n MPTP exposure \n \nStep 3 Supportive prospective posit ive criteria for Parkinson’s disease \n(Three or more required for diagnosis of definite Parkinson’s disease) \n Unilateral onset \n Rest tremor present \n Progressive disorder \n Persistent asymmetry affecting side of onset most \n Excellent response (70-100%) to levodopa \n Severe levodopa-induced chorea \n Levodopa response for 5 years or more \n Clinical course of 10 years or more Ranjit B. Mani, MD, HFD-120 Medical Review Page 10 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n4.2 DSM-IV Criteria For Deme ntia Due To Parkinson’s Disease \n294.1 Dementia Due To Parkinson’s Disease \n \nThe essential feature of Dementia Due To Parkinson’s Disease is the presence of dementia that is judged to be of \ndirect pathophysiological consequence of Parkinson’s dise ase. Parkinson’s disease is a slowly progressive \nneurological condition, characterized by tremor, rigidity, bradykinesia, and postural instability. Dementia has been \nreported to occur in approximately 20%-60% of individuals with Parkinson’s disease and is more likely to be present in \nolder individuals or in those with more severe or advanc ed disease. The dementia associated with Parkinson’s disease \nis characterized by cognitive and moto r slowing, executive dysfunction and impairment in memory retrieval. Declining \ncognitive performance in individuals with Parkinson’s disease is frequently exacerbated by depression. Findings on \nphysical examination include the characteristic abnormal motor signs of resting tremor, evidence of slowness and poverty of movement (such as micrographia), or muscular rigidity and loss of associated movements. At autopsy, \nneuronal loss and Lewy bodies are evident in the substantia ni gra. There are a number of syndromes that manifest \nwith dementia, Parkinsonian movement disorders, and additional neurological features (e.g., progressive supranuclear \npalsy, olivopontocerebellar degeneration, and Vascular Dementia). Some individuals with Parkinson’s disease and \ndementia are found at autopsy to have coexisting neuropathology indicative of Alzheimer’s disease or of diffuse Lewy \nbody disease. \n \n5. Efficacy Outcome Measur es And Selected Additional \nInstruments Used In Efficacy Study \nThese instruments are outlined below: \n \n5.1 Alzheimer’s Disease Assessment Scale – Cognitive Subscale (ADAS-\nCog) \nThis is a validated instrument consisti ng of the following 11 items: Word Recall \nTask, Naming Fingers and Objects, Orientation Questions, Constructional Praxis \nTask, Following Commands, Ideational Pr axis Task, Word Recognition Task, \nRating of Spoken Language, Rating of Language Comprehension, Rating of \nWord Finding Difficulty and Rating of Ability to Recall Test Instructions. The total \nscores range from 0-70 with higher scores indicating greater cognitive impairment. \n \n5.2 Alzheimer’s Disease Cooperative Study – Clinician’s Global Impression \nOf Change (ADCS-CGIC) \nThis instrument provides for a rating of overall (global) change from baseline by \nan independent clinician experienced in the assessment of patients with \ndementia. The term “independent” implies that the rater is not to be involved in \nany additional manner in the evaluation and/ or treatment of patients enrolled in \nthis study \n \nAssessments will be performed at baseli ne and at subsequent visits. It is \nrecommended that the baseline interview be conducted by 2 independent raters, one designated as the primary rater and t he other as a backup. Post-baseline \nratings are to be conducted solely by the pr imary rater or, in his/her absence, by \nthe back-up rater. Ranjit B. Mani, MD, HFD-120 Medical Review Page 11 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \nAt baseline both raters will have access to all of the patients’ available records \nand evaluations. At all subsequent visits, t he rater is to rely (for baseline data) \nsolely upon information obtained during t he baseline assessment of the patient \nand caregiver by that rater (including written notes and, if available, the baseline \ninterview audiotape or videotape). At post-baseline visits, data obtained directly \nfrom the patient may be supplemented by that obtained from the caregiver. The \nrater will not have access to other safety or efficacy data, including all previous \npost-baseline ADCS-CGIC ratings by either rater. \n \nA standard 7-point categorical rating scale and its dichotomized version will both \nbe used for rating and are further described below: \n \n• The 7-point categorical scale is as follows: \n \nChange Rating \nMarked improvement 1 \nModerate improvement 2 \nMinimal improvement 3 \nNo change 4 \nMinimal worsening 5 \nModerate worsening 6 \nMarked worsening 7 \n \n• The dichotomized version of the 7-point categorical scale is derived as follows \n \nRating On 7-Point Scale Rating On Dichotomized Scale \n1, 2, or 3 1 \n4, 5, 6, or 7 2 \n \nThe format for assessment is semi-structured wit h a guideline provided for \nassessing the global impression of change based on ratings of change for the following individual domains: cognition, behavior, and function. \n \nA semi-structured format for assessing the severity of disease at baseline has also been used, again with a guideline provided for assessing the global \nimpression of severity based on ratings of change for the following individual \ndomains: cognition, behavior, and function. \n \n5.3 Alzheimer’s Disease Cooperative Study – Activities Of Daily Living \nScale (ADCS-ADL) \nThis is a rating scale used to assess basic and instrumental activities of daily living. 23 items are rated by the invest igator using information supplied by the \ncaregiver. The maximum total score is 78. Higher scores indica te better function. \n \n5.4 Cognitive Drug Research Com puterized Assessment System \nThis is a computer-based system for asse ssing cognitive function. A series of \ntasks is used to assess each of several specific functions as indicated in the Ranjit B. Mani, MD, HFD-120 Medical Review Page 12 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \ntable below. Only Level I (Attention) is assessed in the study contained in this \nsubmission. \n \n \nLevel Function Assessed Tests \nLevel I Attention Simple Reaction Time \nChoice Reaction Time \nDigit Vigilance \nLevel II Short-Term or Working Memory Numeric Working Memory \nSpatial Working Memory \nLevel III Long-Term or Episodic Secondary \nMemory Word Recall \nWord Recognition \nPicture Recognition \nFace Recognition \nLevel IV Motor Control Tracking \nPostural Stability \nOther Miscellaneous Functions Rapid Visual Information \nProcessing \nLogical Reasoning \nTapping Rates \nCritical Flicker Fusion Frequency \nDigit Symbol Substitution Task \nPencil and Paper Procedures \nVisual Analogue Scales \n \nA description of each of the test s at Level I is presented below \n \nTest Description \n \nSimple Reaction Time The patient is asked to press t he “YES” response button as qui ckly as possible every time \nthe word “YES” is presented on the monitor \n \nDigit Vigilance Task A target digit is randomly selected and constantly displayed to the right of the monitor \nscreen. A series of digits is presented in t he center of the screen at the rate of 80 per \nminute and the patient is required to press t he “YES” button every time the digit in the \nseries matches the target digit \n \nChoice Reaction Time Either the word “NO” or the wo rd “YES” is presented on the monitor and the patient is \ninstructed to press the corresponding button as quickly as possible \n \n \n5.5 Delis-Kaplan Executive Functioning System (D-KEFS) Test Battery \nThis test battery assesses verbal and non- verbal executive functions. 9 tests are \nincluded in this battery; each test is intended to be used as either a stand-alone \ninstrument or in conjunction with other tests in the same battery. The tests are as \nfollows: Trail Making Test, Verbal Fluency Test, Design Fluency Test, Color-\nWord Interference Test, Sorting Test (fo rmerly called the California Card Sorting \nTest), Twenty Questions Test, Word Cont ext Test, Tower Test, and Proverb Test \n(formerly called the Calif ornia Proverb Test). \n \nOnly the Verbal Fluency Test from this battery was eventually used as a uniform \noutcome measure for this study; only one cond ition of this test, letter fluency, was \nused; here the patient was asked to generate as many words as possible for 3 different letters of the alpha bet (“F,” “A,” and “S,”) with 60 seconds being allowed \nfor each alphabet tested. 2 other tests, the Sorting Test and the Color-Word Ranjit B. Mani, MD, HFD-120 Medical Review Page 13 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nInterference Test were used at selected ce nters. The main outcome variable for \neach of these measures is listed below: \n \nTest Main Outcome Variable \nD-KEFS Verbal Fluency Test Number of correct responses \nD-KEFS Sorting Test Sort recognition description score \nD-KEFS Color-Word Interference Test Completion time adjusted for errors \n \n \n5.6 Mini-Mental Status Examination \nThis is a validated multi-item instrument that examines orient ation, registration, \nattention, calculation, recall, visuos patial abilities and language. The maximum \nscore is 30, with higher scores indi cating better cognitive function. \n \n5.7 Neuropsychiatry Inventory \nThis is a validated instrument that assesses the following 12 domains \n(subscales): delusions, hallucinations, agitation/aggression, depression/dysphoria, anxiety, elation/euphor ia, apathy/indifference, disinhibition, \nirritability/lability, aberrant motor behavior, sleep/night-time behavior, and \nappetite/eating changes . Each domain is ra ted according to its frequency (score \nranging from 1 to 4) and seve rity (score ranging from 1 to 3); rating is based on \ninterviewing a caregiver; if a symptom subsumed by a particular domain is absent, it will receive a rating of 0. For eac h domain, the score is the product of \nfrequency and severity, with a maximum score of 12. The maximum total score for the 12 domains (the sum of the subscale scores) is 144 with a higher score indicating greater behavioral abnormality. \n \nAn earlier version of the Neuropsychiat ry Inventory (Neuropsychiatry Inventory-\n10), consisting of the first 10 items above, and with a maximum total score of 100 \nhas also been used. \n \n5.7.1 Neuropsychiatry Inventory – Distress \nFor each of the 12 items on t he Neuropsychiatry Inventor y, caregiver distress is \nrated on a 5-point scale from 1 to 5, with higher scores indicating greater \ndistress. \n \n5.8 Ten-Point Clock Test \nThis test is intended to m easure executive functioning and visuospatial skills. The \nsubject is asked to insert the numbers on the face of the clock and when that \ntask is completed to insert the hands of t he clock so as to indi cate a time of ten \nminutes past eleven o’clock. The maximu m score on this task is 10, with lower \nscores indicating greater degrees of impairment \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 14 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n5.9 Symbol-Digit Modalities Test \nThis test is intended to measure in formation processing speed and attention. \nSubjects match numbers to symbols using a key; the symbols are printed and the \nnumbers written in by the subject. 110 items are to be filled in a period of 90 \nseconds. \n \n5.10 Health Economic Parameters \nThese are to include the following \n \n• Caregiver burden \n• Caregiver productivity costs \n• Caregiver and patient outpatient visits and hospitalizations \n• Time to institutionalization \n \n5.11 Unified Parkinson’s Disease Rating Scale (UPDRS) \nThis is a composite scale intended fo r rating patients with Parkinson’s Disease. \nThe scale is composed of 6 sections, each of which is rated categorically \n \nPart Functions assessed Number Of Items Rated \nPart I Cognition, behavior and mood 4 \nPart II Activities of daily living 13 \nPart III Motor examination 14 \nPart IV Complications of therapy 11 \nPart V Modified Hoehn and Yahr staging Overall single rating \nPart VI Disability scale Overall single rating \n \nIndividual items are rated as follows \nPart I, II and III 0-4 (0 = normal; 4 = ma ximal deficit, symptoms or impairment) \nPart IV 0-4 or 0-1 (0 = normal; 1,4 = maximal deficit, symptoms or impairment) \nPart V 8 stages from 0 to 5 (0 = no signs of di sease; 5 = wheelchair bound or bedridden unless aided) \nPart VI 11 percentile points from 0% (loss of vegetative functions; bedri dden) to 100% (completely \nindependent) \n \nPart III of this scale (Motor Examinati on) will be used as an outcome measure in \nthis study. The individual items in Part III are \n \n• Speech \n• Facial expression \n• Tremor at rest \n• Action or postural tremor of hands \n• Rigidity \n• Finger taps \n• Hand movements \n• Rapid alternating movements \n• Leg agility \n• Arising from chair \n• Posture Ranjit B. Mani, MD, HFD-120 Medical Review Page 15 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n• Gait \n• Postural stability \n• Body bradykinesia and hypokinesia \n \n6. Summary Of Key Efficacy St udy (EXPRESS Study; Study \n2311) \nThe study protocol and main efficacy results for this study are summarized \nbelow. \n \n6.1 Outline \nThe study outline is below \n \nDesign Randomized, double-blind, placebo- controlled, parallel-arm study \n \nDuration 24 weeks \n \nKey Inclusion Criteria Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank clinical diagnostic criteria \n \nClinical diagnosis of Parkinson’s Disease Dementia according to DSM-IV criteria (Code 294.1) with onset of symptoms of dementia within at least 2 years of the \nfirst diagnosis of idiopathi c Parkinson’s Disease \n \nMini-Mental Status Examination of 10 – 24 \n \nPrimary Efficacy Measures ADAS-Cog \n \nADCS-CGIC \n \nPopulation For Primary Efficacy Analysis Intent-to-treat plus retrieved dropouts \n \nSecondary Efficacy Measures \n Cognitive Drug Research Computerized A ssessment System-Power Of Attention \nD-KEFS* Verbal Fluency Test \nNeuropsychiatry Inventory-10 \nMini-Mental Status Examination \nTen-Point Clock Drawing Test \n \n(*D-KEFS: Delis-Kaplan Executive Function System) \n \nSafety Measures \n Adverse events, vital signs, safety laborat ory tests, electrocardiograms, Unified \nParkinson’s Disease Rating Scale score \n \nDose Arms Rivastigmine \n(3 - 12 mg/day) \n Placebo \nNumber randomized 362 179 \n \nNumber completing 263 147 \n \n \n6.2 Results Of Primary Efficacy Analysis \nThe results of the primary efficacy anal ysis as performed on the intent-to-treat \nplus retrieved dropout population is summarized below \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 16 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n Rivastigmine Placebo Parameter \nN Mean ± SD N Mean ± SD Mean \ndifference p-value \nADAS-Cog change from baseline to Week 24 \n 329 2.1 ± 8.2 161 - 0.7 ± 7.5 2.88* \n(LS means) \n \n < 0.001** \nADCS-CGIC at Week 24 329 3.8 ± 1.4 165 4.3 ± 1.5 0.5 0.007*** \n \n*95% confidence interval: 1.44 to 4.31 \n**Based on two-way analysis of covari ance model using treatment and country as factors and baseline ADAS-Cog as a \ncovariate \n***Based on van Elteren test blocking for country \nNote that in the above table, negative ADAS-Cog change scores indicate a worsening and positive ADAS-Cog change \nscores an improvement \n \n7. Description Of Efficacy St udy 2311 (EXPRESS Study) \nThis study was conducted outside the pur view of an IND application, and the \nprotocol was not submitted to this Division for review prior to the study being \nconducted or at any time while the study was ongoing. \n \nNote that the results of this study hav e also been published. The abstract of that \npublication has been provided later in this section \n \n7.1 Protocol \n \nThe protocol described below is the final version \n \n7.1.1 Title \nA 24-Week, Prospective, Randomized, Multicenter, Double- Blind, Placebo-\nControlled, Parallel-Group St udy Of the Efficacy, Tolerabi lity, And Safety Of 3 – \n12 Mg/Day Of Exelon® (Rivastigmine) C apsules In Patients With Parkinson’s \nDisease Dementia \n \n7.1.2 Objectives \n7.1.2.1 Primary \nTo evaluate the efficacy of Exelon® (3 to 12 mg/day) compared with placebo for \na treatment period of 24 weeks in pati ents with Parkinson’s Disease Dementia. \nEfficacy will be evaluated on the following: \n \n• ADAS-Cog, a measure of cognition \n• ADCS-ADL, a measure of global function \n \n7.1.2.2 Secondary \n• To evaluate the effects of Exelon® on attention, executive functioning, \nactivities of daily living, behavior, caregiver distress, and health economic \nparameters Ranjit B. Mani, MD, HFD-120 Medical Review Page 17 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n• To explore differences of effica cy of Exelon® depending on pre-existing \nattentional deficits \n• To explore potential genetic factor s related to Parkinson’s Disease \nDementia \n• To explore potential biomarkers rela ted to Parkinson’s Disease Dementia \n• To evaluate the safety and tolerability of Exelon® \n \n7.1.3 Design, Duration, Sample Size, Dosage \nThis was to be a 24-week randomized, double-blind, placebo-c ontrolled, parallel-\narm study. \n \nAbout 540 patients were to be randomized 2:1 to Exelon® or placebo (i.e., about \n360 patients to Exelon® and abo ut 180 patients to placebo). \n \nThe overall study design is summ arized in the following table: \n \n \n \n4 dose levels were to be used for Exel on® (and for matching placebo). The dose \nlevels for Exelon® are show n in the following table \n \nDose Level Exelon® Dose \n1 1.5 mg BID \n2 3.0 mg BID \n3 4.5 mg BID \n4 6.0 mg BID \n \nThe actual dosing regime was to be as follows: \n \n• For the titration period \n \n All patients were to begin at Dose Level 1 \n After 4 weeks, the dose was to be increased to Dose Level 2 unless \ntolerability was impaired \n Subsequent increases to Dose Levels 3 and 4 were to be based on the \ntolerability of the preceding dose, and were to be considered only after 4 \nweeks of treatment at the previous dose \n In the event of poor tolerability, an investigator could decide to reduce a \ndose to the preceding level, with increases to the next dose level being made as clinically indicated \n All patients were expected to have found their highest tolerated dose by \nWeek 16. Ranjit B. Mani, MD, HFD-120 Medical Review Page 18 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n• For the maintenance period \n \n The highest well-tolerated dose for each patient was to be maintained for \nthe entire maintenance period \n However, dose adjustments were permitted at any time \n \nAfter completing the double-blind phase, patients were to have the option of \nreceiving open-label treatm ent for up to 6 months. \n \nNote that the Exelon® dose range proposed fo r use in this trial was identical to \nthat used in clinical trials in Alzheimer’s Disease. \n \n7.1.4 Selection \n7.1.4.1 Key Inclusion Criteria \n• Male or female \n \n• Age ≥ 50 years \n \n• Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank \n \n• Diagnosis of Dementia Due To Pa rkinson’s Disease according to DSM-IV \ncriteria \n \n• Mini-Mental Status Examination score of 12 to 24 \n \n• Sufficient education to read, write, and communicate effectively during the \npre-morbid stage \n \n• Cooperative \n \n• Able to ingest oral medication \n \n• Capable of completing the study eit her alone or with the assistance of a \nresponsible caregiver \n \n• Reliable caregiver \n \n• Informed consent \n \n7.1.4.2 Key Exclusion Criteria \n• Any advanced, severe or unstable di sease that could in terfere with study \nevaluations Ranjit B. Mani, MD, HFD-120 Medical Review Page 19 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n• Any disability that interferes with completion of study requirements \n \n• Active uncontrolled peptic ulcera tion within the previous 3 months \n \n• Women of child -bearing potential \n \n• Bradycardia (< 50 beats per minut e), sick sinus syndrome, conduction \ndeficits (S-A block, second or third degree A-V block) \n \n• Current diagnosis of any primary neurodegenerative disease other than \nParkinson’s Disease or any other causes of dementia \n \n• A current diagnosis of probable or possible vascular dementia according \nto the NINDS-AIREN criteria \n \n• Deep brain stimulation implants \n \n• Current diagnosis of active, uncontrolled seizure disorder \n \n• Current diagnosis of major depressive episode according to DSM-IV \ncriteria or any other DSM-IV Axis I diagnosis that may interfere with the \nresponse of the patient to study medication, including bipolar disorder or \nschizophrenia as assessed by psychiatric examination \n \n• A known exaggerated pharmacological sensitivity or hypersensitivity to \ndrugs similar to Exelon ® or other cholinergic compounds \n \n• Participation in a previous study of cholinesterase inhibitor therapy during \nthe 6 months prio r to randomization \n \n• Use of any of the following subst ances during the 4 weeks prior to \nrandomization \n \no Any investigational drug \no A drug or treatment known to cause major organ toxicity \no Other cholinesterase inhibitors or cholinergic drugs (except topical \npilocarpine) \no Centrally acting anticholinergic drugs, including tricyclic antidepressants \no Neuroleptics other than clozapine, quetiapine, or olanzapine \no Lithium \n \n• Commencement of any of the fo llowing medications or change in \nmedication dose during the 4 w eeks prior to randomization \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 20 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \no Psychotropic medications (clozapine, quetiapine, olanzapine, \nantidepressants, anxiolytics or hy notics, including benzodiazepines and \nanticonvulsants) \no Anti-Parkinsonian medications \n \n7.1.4.3 Concomitant Medications \n7.1.4.3.1 Prohibited \n Any investigational drug \n A drug or treatment known to cause major organ toxicity \n Other cholinesterase inhibitors or cholinergic drugs (except topical \npilocarpine) \n Centrally acting anticholinergic drugs, including tricyclic antidepressants \n Neuroleptics other than clozapine, quetiapine, or olanzapine \n Lithium \n New psychotropic medications (c lozapine, quetiapine, olanzapine, \nantidepressants, anxiolytics or hynot ics, including benzodiazepines and \nanticonvulsants) \n New anti-Parkinsonian medications \n Dose increases for dopaminomimetic medications \n Dose increases for anxiolytics or hypnotics, including benzodiazepines \n \n7.1.4.3.2 Permitted (With Limitations) \n Psychosis should be treated accord ing to the clinical standard. If \npersistent and if clinically indicated: \n \no In patients already treated with atypical neuroleptics, a dose increase is \npermitted \no In neuroleptic-naïve, atypical neuroleptics, such as clozapine, quetiapine, \nor olanzapine should be started at very low doses that are increased \ngradually \n \nWhile a decrease in dose or discontinuation of anti-Parkinsonian medication as a treatment for psychosis is permitted, elimination of all dopaminomimetic treatment is not recommended. However, changes in dose of amantadine and selegiline are not permitted during the trial, even during a psychotic episode. \n \n For isolated insomnia, the use of non-benzodiazepine hypnotics such as \nzopiclone, is permitted \n \n Patients on Vitamin E, estrogens, Ginkgo biloba, and nootropics, and in \nwhom discontinuation of these drugs is not feasible, may continue with \nthese agents, but the dose should re main unchanged throughout the trial \n \n Peripherally-acting anticholinergic dr ugs are permitted if patients have \nbeen on a stable dose for 4 weeks prior to randomization, and if doses are Ranjit B. Mani, MD, HFD-120 Medical Review Page 21 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nkept stable during the study. In addition, if urinary urgency and \nincontinence develop newly during the trial, and cannot be overcome by \nnon-pharmacological means, initiati on of treatment with peripheral \nanticholinergics such as tolterodine and oxybutinin will be permitted \n \n7.1.5 Schedule \nThe study schedule is summarized in t he following table, which I have copied \nfrom the submission. \n \n \n \n \n \nNote that brain imaging (i.e., co mputerized tomography or magnetic \nresonance scanning) was not required prior to entry into the study. \n \nSpecial diagnostic laboratory tests at screening included serum TSH, folic acid, \nVitamin B12 and RPR. \n \nAlso note the following \n \n All primary and other cognitive outcome variables were to be assessed \nbefore lunch, beginning 1 hour af ter the intake of dopaminergic Ranjit B. Mani, MD, HFD-120 Medical Review Page 22 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nmedications, at the same time of day throughout the study for each \npatient, and using the same sequence of tests \n For patients with motor fluctuations and/or dyskinesias, efficacy \nassessments were to be performed duri ng their “on” time (defined as \nintervals when parkinsonian symptom s were replaced by increased \nmobility) \n For patients with an acute psychosis, efficacy assessments were to be \nperformed after remission of the psychosis \n Raters were advised to identify and discount if possible potential \nbehavioral and functional changes due to the motor symptoms of \nParkinson’s Disease \n \n7.1.6 Outcome Measures \n7.1.6.1 Primary Efficacy Measures \n• ADAS-Cog \n \n• ADCS-CGIC \n \n7.1.6.2 Secondary Efficacy Measures \n• Cognitive Drug Research Computerized Assessment System tests for the \nassessment of attention \n \n• ADCS-ADL \n \n• Neuropsychiatry Inventory \n \n• Neuropsychiatry Inventory Caregiver Distress Scale \n \n• Executive Function Battery \n \n Ten-Point Clock Drawing Test \n D-KEFS Verbal Fluency Test \n D-KEFS Color Word Interference Test* \n D-KEFS Card Sorting Test* \n Symbol Digit Modalities Test* \n \n*These were designated as exploratory assessments \nand were considered optional for English and French \nspeaking patients \n \n• Health Economic Parameters, incl uding caregiver burden, and patient and \ncaregiver resource utilization \n \n• Mini-Mental Status Examination \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 23 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.1.6.3 Safety Measures \nAdverse events, safety laboratory tests, vital signs, body weight, \nelectrocardiograms, and UPDRS Part III \n \n7.1.7 Safety Monitoring \nAdverse events, safety laboratory tests, vital signs, body weight, \nelectrocardiograms, and UPDRS Part III \n \n7.1.8 Analysis Plan \n7.1.8.1 General \nThe data from each center were in tended to be pooled with data from other \ncenters so that an adequate num ber of patients would be available for analysis. \n \nUnless otherwise specified, all statistica l tests were to be conducted using a two-\nsided Type I error of 0.05. \n \n7.1.8.2 Study Populations \n7.1.8.2.1 Intent-To-Treat With Retrieved Dropouts \nThis population was to include all randomiz ed patients who received at least one \ndose of study medication and had at l east a pre- and post-baseline assessment \nfor one of the primary efficacy variables. \n \nThe imputation scheme that was to be used to create a score for every \nrandomized subject is described as follows in the study protocol: If available, the \nendpoint assessment is used; if missing, the retrie ved dropout assessment is \nused; if the retrieved dropout assessment is unavailable, the last observation \navailable on the subject is used. \n \n7.1.8.2.2 Intent-To-Treat-Last-Observation-Carried-Forward \nThis population was to include all random ized patients who received at least one \ndose of study medication and had at l east a pre- and post-baseline assessment \nfor one of the primary efficacy variables. \n \nThe imputation scheme that was to be used to create a score for every \nrandomized subject is described as follows in the study protocol: If available, the \nendpoint assessment is used; if missing, the immediat e preceding observation \navailable, scheduled or unscheduled, is ut ilized, provided that the assessment is \nmade while the subject is still considered to be a participant in the study, i.e., at \nmost 2 days after the last dose of study medication. \n \n7.1.8.2.3 Observed Cases Ranjit B. Mani, MD, HFD-120 Medical Review Page 24 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nThis population was to consist of a ll randomized patients who had an evaluation \non treatment at the desi gnated assessment time (either interim scheduled or \nendpoint). Evaluations done more than 2 days after the last dose of study \nmedication were not to be included. No im putation is involved with this population \n \n7.1.8.2.4 Safety Population \nThis population was to consist of all patients who have received at least one \ndose of study medication and had at least one safety assessment after baseline. \n \n7.1.8.3 Demographic And Other Baseline Characteristics \n• These characteristics were to be presented by treatment group and \ncountry \n• Continuous variables were to be su mmarized using descriptive statistics \n• Discrete variables were to be summarized by frequencies and \npercentages \n• Descriptive p-values were to be g enerated using appropriat e test statistics \n \n7.1.8.4 Study Medications \nDescriptive statistics for study drug expo sure by treatment and data listings for \nstudy drug doses administered we re also to be provided \n \n7.1.8.5 Concomitant Therapy \nDescriptive statistics (frequency count s and percentages) for concomitant \nmedication were to be presented by treatment group for patients in the safety population \n \n7.1.8.6 Primary Efficacy Parameters \n The primary efficacy parameters were the following \n \no Change from baseline to endpoint in ADAS-Cog score \no ADCS-CGIC rating at endpoint (on the 7-point scale) \n \n[Note that the statistical analysis plan does not explicitly state that the endpoint \nused for the primary efficacy analysis was to be Week 24, rather than Week 16.] \n \n The population for the primary effica cy analysis was to be the intent-to-\ntreat plus retrieved dropouts population as defined above. Analyses on \nother populations were to be considered supportive to the main efficacy analysis \n \n The main analysis for the change from baseline to endpoint in ADAS-Cog \nscore was to be as follows \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 25 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \no The treatment groups were to be compared using least square means \nderived from an analysis of covariance model with the following \nexplanatory variables: treatment, country, and baseline ADAS-Cog score \no 95% confidence intervals for the difference in treatment groups based on \nthe analysis of covariance were to be reported \no In addition, summary statistics were to be presented by treatment group \nfor baseline and post-baseline evaluations for the populations being analyzed \n \n The main analysis of the ADCS-CGIC was to be by comparing the \ntreatment groups using a Cochran-Mant el-Haenszel test with modified ridit \nscores with country as stratification variable. In addition, a proportional \nodds regression analysis with the follo wing explanatory variables was to \nbe performed: treatment and country. A secondary analysis was also to be \nperformed on the dichotomized ADCS-CGIC using logistic regression with \nthe same explanatory variables as the proportional odds regression model \n \n7.1.8.7 Secondary Efficacy Parameters And Additional Analyses \nSecondary efficacy variables were to be analyzed using an analysis of \ncovariance model with treatment, c ountry, and the corresponding baseline \nmeasurement as the covariates. \n \nSecondary efficacy analyses of the prim ary efficacy variables were to be \nperformed on population subgr oups defined by the presence of impaired \nattention and concentration on the basel ine attentional task scores of the \nCognitive Drug Research computerized battery. \n \n7.1.8.8 Safety Parameters \n The safety parameters were to be adverse events, vital signs, \nelectrocardiograms and safety laboratory tests. \n \n Adverse events will be coded using the MedDRA dictionary and presented \n(number and proportion) by treatment group, body system, and individual \nevent, and also grouped according to severity, relationship to study \nmedication, and outcome. The proportion of patients in each treatment group discontinuing prematurely for any reason and for adverse events \nwas to be compared descriptively \n \n Laboratory data were to be summariz ed by presenting shift tables for \nchange from baseline to most ex treme post-baseline value, and \ndescriptive statistics of raw data a nd change from baseline values, and by \nflagging notable values in data listings. \n \n• Data from vital signs and electrocar diograms were to be listed, notable \nvalues were to be flagged, and any other information collected was to be Ranjit B. Mani, MD, HFD-120 Medical Review Page 26 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nlisted as appropriate. Any statis tical tests performed were to be \nexploratory \n \n• The change from baseline on the UP DRS score was to be analyzed using \nan analysis of covariance model \n \n7.1.8.9 Sample Size Rationale \nSample size estimates were perfo rmed using the two primary efficacy \nparameters the ADAS-Cog and the ADCS-CGIC, and is further summarized \nbelow \n \n7.1.8.9.1 Sample Size Estimate Based On ADAS-Cog \nEstimates of standard deviation from t he intent-to-treat analysis of 6-month \nchange from baseline ADAS-Cog data in clinical trials of Exelon® in Alzheimer’s \nDisease range from 6 to 7 points \n \nTo ensure adequate power in case of a higher variability in 6-month change from \nbaseline ADAS-Cog scores in those with Parkinson’s Disease as compared with \nthose with Alzheimer’s Disease, a standard deviation of 7.5 points was assumed \nfor this sample size estimate \n \nUsing a two-sided test with a signific ance level of 0.05, and a pooled standard \ndeviation of 7.5 points, a total sample size of 531 patients (354 on Exelon® and 177 on placebo) is required to detect a differ ence of at least 2.25 points in the \nADAS-Cog change from baseline score between Exelon® and placebo with a \npower of 90%. \n \n7.1.8.9.2 Sample Size Estimate Based On ADCS-CGIC \nAssumptions regarding the variability and treatment differences for the ADCS-\nCGIC are based on data available for t he CIBIC-Plus from completed Exelon® \nstudies in Alzheimer’s Disease; the ADCS -CGIC and CIBIC-Plus are very similar \ninstruments. \n \nTo ensure adequate power in case of a higher variability in ADCS-CGIC scores in those with Parkinson’s Disease as compared with those with Alzheimer’s \nDisease, a standard deviation of 1.3 points was assumed for this sample size \nestimate \n \nUsing a two-sided test with a signific ance level of 0.05, and a pooled standard \ndeviation of 1.3 points, a total sample size of 525 patients (350 on Exelon® and \n175 on placebo) is required to detect a diff erence of at least 0.40 points on the \nintent-to-treat analysis in the ADCS-C GIC score at Month 6 between Exelon® \nand placebo with a power of 90%. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 27 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.1.8.9.3 Overall Sample Size Estimate \nTo ensure that the study has adequate power to detect statistically significant \nresults for both primary efficacy variables , 540 patients were to be enrolled. \n \n7.2 Study Results \nThe study was conducted in Austria, Be lgium, Canada, France, Germany, Italy, \nthe Netherlands, Norway, Portugal, S pain, Turkey, and the United Kingdom, \nbetween October 10, 2002, and January 20, 2004. \n \nA total of 68 centers participated in the study. \n \n7.2.1 Patient Disposition \nA total of 650 patients were screened, of whom 541 were randomized, 362 to the \nExelon® group and 179 to the placebo. \n \n \n \nAs the above sponsor table indicates, a total of 410 patients (263 [72.7%] who \nreceived Exelon®, and 147 [82.1%] who rece ived placebo, completed the study). \n \nAs the table above also indicates, the ma jority of discontinuations were due to \nadverse events: 17.1% of patients in the Exelon® group and 7.8% of patients in \nthe placebo group discontinued on account of adverse events. \n \n7.2.2 Protocol Deviations \nProtocol violations are summarized in the following table, which I have copied \nfrom the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 28 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nThe table indicates that prot ocol violations were sli ghtly more frequent in the \nExelon® group than in the placebo group. The most common protocol violation \nwas an increase in dose or the new introduction of a psychotropic or \ndopaminergic medication; this category of violation was about equal in incidence \nbetween the treatment groups. \n \n7.2.3 Groupings For Analysis \nThe groupings for analysis are summarized in the following sponsor table. \n \n \n \nITT: Intent-to-treat \nLOCF: Last-observation-carried-forward \n \nNote that similar proportions of those in the Exelon® and placebo groups are in \nthe intent-to-treat plus retrieved dr opout groups used for the primary efficacy \nanalysis. \n \n7.2.4 Demographic And Other Baseline Characteristics \nAs the sponsor table below indicates, baseline characteristics for age, gender, \nand race were comparable between treatment groups. The table pertains to the \nrandomized/safety population \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 29 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nBaseline Parkinson’s Disease and dementia characteristics were also broadly \ncomparable between treatment groups, including entry Mini-Mental Status \nExamination scores; the table depicts the randomized/safety population. \n \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 30 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.2.5 Study Medication \nThe cumulative duration of patient exposur e is summarized by treatment group in \nthe next table, which I have copied from the submission. As might be expected \nfrom the discontinuation ra tes in each treatment group alluded to before, the \nmean duration of exposure was slightly lower in the Exelon® group than in the \nplacebo group. \n \n \n \nThe average daily Exelon® dos e per treatment interval is in the next table, which \nI have copied from the submission. T he average daily Exelon® dose for the \nentire study (± standard deviation ) is 6.3 mg (± 2.3 mg). \n \n \n \n7.2.6 Concomitant (And Prior) Medication \nNon-central nervous system related concom itant medications, taken both prior to \nand after the start of the study, were us ed by 80.7% of pati ents in the Exelon® \ngroup and 79.3% of patients in the plac ebo group. The most frequently reported \nmedication was aspirin (16.3% of Exelon®-treated patie nts and 19.6% of \nplacebo-treated patients). \n \nCentral nervous system-related concomit ant medication taken within 4 weeks \nprior to start of the study were used by 100% of those in the Exelon® group and \n99.4% of those in the placebo group as might have been expected for a Ranjit B. Mani, MD, HFD-120 Medical Review Page 31 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \npopulation with Parkinson’s Disease. Concom itant medications that were central \nnervous system-related were used by 100% of patients in both treatment groups. \nThe most widely used central-nervous system related concomitant medications \nwere those in the dopaminergic class. The pattern of dopaminergic agent use in \nvarious classes is summarized in the follo wing table, taken from the submission. \n \n \n \n7.2.7 Efficacy Results \n7.2.7.1 Primary Efficacy Results \n7.2.7.1.1 ADAS-Cog \nIn the protocol-specified primary efficacy analysis of the ADAS-Cog (intent-to-\ntreat plus retrieved dropouts), the Exel on® treatment group improved by a mean \nof 2.1 points, whereas t he placebo group deteriorated by a mean of 0.7 points, \nboth at Week 24, with the difference being st atistically significant as displayed in \nthe following table \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 32 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nSomewhat greater treatment differences, wh ich were again nominally statistically \nsignificant, were seen for both the intent -to-treat last-observation-carried-forward \nand observed cases populations. \n \nThe time-course of the change in ADAS-Cog score in the intent-to-treat plus \nretrieved dropouts population in this study is displayed in the next figure, which I \nhave copied from the published report of this study. \n \n \n \nA categorical analysis of the ADAS- Cog based on the proportion of patients \nimproving (i.e., improving by at least 4 points) in each treatment group at Weeks \n16 and 24 is summarized in the following sponsor table. Ranjit B. Mani, MD, HFD-120 Medical Review Page 33 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nFor the categorical analysis above, nominal ly statistically significant treatment \ndifferences were seen, as indicated by the table for the both the intent-to-treat \nlast-observation-carried-forward and observed cases populations. \n \n7.2.7.1.2 ADCS-CGIC \nIn the protocol-specified primary effi cacy analysis of the ADCS-CGIC (intent-to-\ntreat plus retrieved dropouts), the Exelon® treatment group showed a mean \nscore of 3.8 at Week 24, whereas t he placebo group showed a mean score of \n4.3 at the same time timepoint, with the di fference being statistically significant as \ndisplayed in the following sponsor table. \n \n \n \nThe categorical data for the intent-to-tr eat plus retrieved dropouts population in \nthe above table are also displayed in the following figure which I have copied from the published r eport of this study. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 34 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nSimilar treatment diffe rences, which were nominally statistically significant, were \nseen for both the intent-to-treat last-observation-carried-forward and observed \ncases populations. \n \nThe categorical analysis of the ADCS-CGIC in the next sponsor table indicates that there were nominally st atistically significantly hi gher proportions of patients \nimproving in the Exelon® group relative to the placebo group in all populations \nanalyzed. \n \n \n \n7.2.7.2 Secondary Efficacy Results \n7.2.7.2.1 ADCS-ADL \nNominal statistically significant treatm ent differences favoring Exelon® over \nplacebo were seen at Week 24 for the mean change from baseline to endpoint in Ranjit B. Mani, MD, HFD-120 Medical Review Page 35 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nthe ADCS-ADL in all 3 populations anal yzed, including the intent-to-treat \nretrieved dropout population. These results are in the sponsor table below. \n \n \n \n7.2.7.2.2 Neuropsychiatry Inventory \nNominal statistically significant treatm ent differences favoring Exelon® over \nplacebo were seen at Week 24 for the mean change from baseline to endpoint in \nthe 10-point Neuropsychiatry Inventory total score in the intent-to-treat retrieved \ndropout and intent-to-treat last-observation-carried-forward populations (these \nresults are displayed in the table below). \n \n \n \nThe proportion of patients with an improv ed 10-point Neuropsychiatry Inventory \ntotal score was also reported to show a nominally statistically significant \nsuperiority to placebo in all 3 analysis populations. Treatment group differences \non the 12- point Neuropsychiatry Inventory were not even nominally statistically significant. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 36 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nA nominally statistically significant treatment difference favoring Exelon® was \nseen for the Neuropsychiatry Inventory Caregiver Distress score for a single \nitem: aberrant motor behavior. \n \n7.2.7.2.3 Health Economic Parameters \nThe analysis of these measures is to be reported separately. \n \n7.2.7.2.4 Cognitive Drug Research – Attention Battery \nThe combined Power of Attention mean change from baseline score at Week 24 \nshowed a nominally statistically significant difference from placebo. \n \n \n \n7.2.7.2.5 Executive Functioning Tests \nSince D-KEFS executive function tests we re not performed at all centers, the \nanalyses were performed only in the Observed Cases population. \n \nOn the D-KEFS Letter Fluency test c hange score, a nominally statistically \nsignificant treatment difference was s een at Week 24, with the Exelon® group \nimproving and placebo group deteriorati ng on mean scores (see sponsor table \nbelow). \n \n \n \nIn the D-KEFS Color Word Interferenc e and Card Sorting Tests, a few sub-\nscores showed nominally statistically significant differences favoring Exelon®. Ranjit B. Mani, MD, HFD-120 Medical Review Page 37 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \nOn the Symbol Digits Moda lity Test, the number of co rrect substitutions showed \na nominally statistically significant improv ement in favor of Exelon® at Week 24. \n \n7.2.7.2.6 Ten Point Clock Test \nThis test too was performed only on a subset of the study population and \nanalyses were confined to the Observed Cases dataset. As the sponsor-supplied \ntable below indicates, the mean change from baseline score for this small subset \nimproved slightly in the Exelon® group and deteriorated slightly in the placebo \ngroup, with the difference being nomi nally statistically significant. \n \n \n \n7.2.7.2.7 Mini-Mental Status Examination \nIn the intent-to-treat plus retrieved dropouts population, mean Mini-Mental Status \nExamination scores increased by 0.8 points in the Exelon® group and decreased by 0.2 points in the placebo, at Week 24, with the difference being nominally \nstatistically significant. Similar result s were seen with the other two analysis \npopulations. \n \n7.2.7.3 Overall Efficacy Response \nAn overall responder was defined as a pat ient with a combination of the following \n \no An improvement in ADAS-Cog of at least 4 points \no ADCS-CGIC category of 1 to 4 \no ADCS-ADL change ≥ 0 points \n \nThe categorical analysis of the percentage of overall responders showed a nominally statistically significant treatment difference favoring Exelon® over placebo at Week 24 for the intent-to-treat-last- observation-carried-forward \npopulation only (20% of pati ents in the Exelon® group and 13% of patients in the \nplacebo group were considered responders in this dataset). \n \n7.2.7.4 Pharmacogenetic Analyses \n302 out of 541 randomized patients consented to pharmacogenetic sampling. \nThe results of these analyses ar e to be reported separately. \n \n7.2.7.5 Biomarker Analyses \n356 and 324 patients consent to biom arker serum and urine sampling, \nrespectively. The results of these analyses are to be reported separately. Ranjit B. Mani, MD, HFD-120 Medical Review Page 38 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n7.2.8 Safety Results \n7.2.8.1 Overall Adverse Event Experience \nThe overall incidence of all adverse events (i.e., proportion of patients \nrandomized who had any adverse event) was higher in the Exelon® group \n(83.7%) than in the pl acebo group (70.9%). \n \nThe following table, copied fr om the submission, summarizes the incidence of the \nmost common adverse events (those with an in cidence of at least 5% in either \ntreatment group) in this study, in descending order of frequency. \n \n \n \nAs the table above indicates, the most common of the adverse events, all of \nwhich were more frequent in the Exelon® group than in the placebo group, were \nnausea, vomiting, tremor, diarrhea, and anorexia. The incidence of dizziness was \nalso substantially greater in the Ex elon® group than in the placebo group. \n \nThe next table, also copied from the s ubmission, indicates the overall incidence \nof adverse events during each (4-week) treatment period. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 39 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nAs the table above indicates, these events appear to have been more frequent, \nin the Exelon® group, during the titrat ion phase of this study than during the \nmaintenance phase. \n \n7.2.8.2 Deaths, Serious Adverse Events, And Discontinuations Due To Adverse Events \nThe incidence of adverse events in each item in this grouping is summarized in \nthe following table, which I have copied from the submission. \n \n \n \n7.2.8.2.1 Deaths \n4 patients (1.1% of those randomized) in the Exelon® group and 7 patients in the \nplacebo group (3.9% of those randomiz ed) died during the study. All deaths \nlisted occurred while receiving study drug or within 15 days of study drug \ndiscontinuation (all deaths that occurred while on study drug or within 30 days of \nstudy drug discontinuation were to be captured). \n \nIndividual deaths in bot h the Exelon® and placebo gr oups are listed in the \nfollowing table, which I have c opied from the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 40 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n7.2.8.2.2 Non-Fatal Serious Adverse Events \n13.0% of those in the Exelon® group and 14.5% of those in the placebo group \nexperienced a non-fatal serious adverse ev ent during this study. The incidence of \nsuch events by system organ cla ss is in the following table. \n \n \n \nI have read the listings for all individual se rious adverse events. It is hard to link \nthe individual events that occurred in patients treated with Ex elon® to the drug. \nAll events appeared to be consistent with intercurrent illnesses common in the \nelderly, and their complications. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 41 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.2.8.2.3 Discontinuations Due To Adverse Events \n66 patients (18.2%) receiving Exelon® and 20 patients (11.2%) of those \nreceiving placebo discontinued study drug prematurely on account of an adverse \nevent. \n \nIndividual adverse events leading to discontinuation that occurred in at least 2 \nExelon®-treated patient s are in the following table which I have created from one \nsupplied by the sponsor. \n \nExelon® (n = 362) Placebo (n = 179) Adverse Events \nN % N % \nNausea 13 3.6 1 0.6 \nVomiting 7 1.9 1 0.6 \nDiarrhea 4 1.1 2 1.1 \nAsthenia 2 0.6 0 0.0 \nAbasia 2 0.6 0 0.0 \nDehydration 2 0.6 1 0.6 \nTremor 6 1.7 0 0.0 \nParkinson’s Disease 3 0.8 0 0.0 \nDizziness 2 0.6 0 0.0 \nHeadache 2 0.6 0 0.0 \nParkinsonism 2 0.6 0 0.0 \nBalance disorder 2 0.6 0 0.0 \nHallucination 4 1.1 2 1.1 \nConfusional state 3 0.8 1 0.6 \nHypotension 2 0.6 0 0.0 \n \nI have read the listings for all individual adverse events that led to treatment \ndiscontinuation. With the exception of events such as nausea, vomiting, and \ndiarrhea, which could be a consequence of the cholinomimetic effects of \nExelon®, it is hard to link the individual events that occurred in patients treated with Exelon® to the drug. All other events appeared to be consistent with \nintercurrent illnesses common in the elderly (and in the study population) and their complications.\n \n \n7.2.8.3 Other Significant Adverse Events \nAdverse event terms that might be cons idered to possibly represent a worsening \nof Parkinson’s Disease were pre-specified in the study protocol . The incidence of \nall such events was higher in the Exel on® group (27.3%) than in the placebo \ngroup (15.6%). The incidence of individual adverse ev ents is summarized in the \nfollowing table. [A number of additional event terms did not occur at all]. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 42 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nA higher incidence of tremor, worsening of Parkinson’s Disease, worsening of \nparkinsonism, bradykinesia, dyskinesia, abnormal gait, and salivary \nhypersecretion in the Exelon® group is noteworthy. \n \n7.2.8.4 Laboratory Tests \nThe sponsor has highlighted changes from baseline in serum amylase, lipase, \nand prolactin, which were more appar ent in the Exelon® group than in the \nplacebo. \n \nAs the sponsor table below indicates, the mean change from baseline in these \nparameters was greater in the Exelon® group than in the placebo group. The \ntable also shows the mean levels for each parameter at Week 24. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 43 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nThe proportions of patients in each treatment group who had normal serum \namylase, lipase, and prolactin levels at baseline, but higher than normal values at \nWeek 24 are in the following table. Again, the proportion of such elevations is higher in the Exelon® group than in the placebo group. \n \nProportion with normal values at baseline and elevations at Week 24* Parameter \nExelon® Placebo \nSerum amylase 17.1% 10.1% \nSerum lipase 9.0% 3.6% \nSerum prolactin 9.5% 7.9% \n*The data for serum prolactin are for values outside the reference range, not merely \n \nNarratives have been provided for all pat ients with elevated serum amylase \nand/or lipase during the study. \n \nThe sponsor also point s out the following: \n \n The maximum serum amylase at Week 24 was 196 U/L (reference range \nof 1 to 88 U/L); the maximum seru m lipase at Week 24 was 342 U/L \n(reference range of 0 to 63 U/L) \n No patient was diagnosed to hav e pancreatitis (as an adverse event \nduring the study) \n No patient discontinue d treatment on account of elevated serum amylase \nor lipase \n \nThe incidence of other newly occurring notable laboratory abnormalities is in the following table which I have c opied from the submission: \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 44 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n7.2.8.5 Vital Signs \nThe number of patients with newly occurri ng or worsening vital sign and weight \nabnormalities was comparable between treatment groups, as indicated in the \nfollowing sponsor table. \n \n \n \nThe mean changes from baseline in these parameters were comparable in the 2 treatment groups. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 45 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.2.8.6 Electrocardiograms \nSummary statistics for electrocardiogram parameters have been reviewed fully. \nThe sponsor has drawn att ention to the following: \n \n The mean QT c interval remained unchanged in the placebo group over the \ncourse of the study, but decreased slightly in the Exelon® group at Week 24 \n A slight increase in mean RR interval was seen in the Exelon® group, but the \nchange was not felt to be statistically significant \n Newly occurring clinically significant electrocardiogram abnormalities were seen \nin 1.4% of patients in the Exelon® group and 1.1% of patients in the placebo \ngroup. The new abnormalities seen in the Exelon® group were artificial \npacemaker rhythm, right bundle branch block, inferior myocardial infarction, and \nT wave inversion \n \n7.2.8.7 UPDRS Part III Scores \nThe UPDRS motor scores were used as a means of assessing changes in the \nmotor manifestations of Parkinson’s Disease during the st udy. The mean change \nfrom baseline scores at Weeks 16 and 24 are summarized in the following table, \nwhich I have copied from the submission. \n \n \n \nThe changes in each treatment group at each timepoint were similar and were \nnot considered clinically significant. T he differences in change score were not \neven nominally statistically significant. \n \nThe sponsor also points out that statistically significant treatment differences \nwere not seen for any of the individual UPDRS Part III item scores. The mean \nchange from baseline for the tremor score at Week 24 was 0.1 ± 2.6 for the \nExelon® group and 0.0 ± 2.1 in the placebo group. \n \n7.3 Sponsor’s Conclusions \nIn this trial, which was conducted in dementia associated with Parkinson’s \nDisease, the efficacy of Exelon® in a dos e of 3 to 12 mg/day for 24 weeks was \nsignificantly superior to that of plac ebo on a measure of cognition (which was \nassessed by the ADAS-Cog) and on a measur e of the clinical global rating of \nchange (ADCS-CGIC). The primary objecti ve of the study was therefore \nachieved \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 46 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nSecondary efficacy measures that assess ed activities of daily living, behavior, \nattention and executive functioning also improved more significantly in those \ntreated with Exelon® than in those treated with placebo. \n \nThe safety profile of Exelon® in this study was consistent with published data for \nExelon® administered to patients with Al zheimer’s Disease. While the incidence \nof adverse events associated with a wo rsening of Parkinson’s Disease was \nhigher in the Exelon® group than in t he placebo group, the UPDRS Part III \n(motor) ratings did not reveal any clinica lly or statistically relevant difference \nbetween treatment groups for either the tota l score or any of the individual item \nscores. Changes in laboratory tests and electrocardiograms were considered \nclinically insignificant. \n \n7.4 Study Abstract \nEmre M, Aarsland D, Albanese A, Byrne EJ, Deu schl G, De Deyn PP, Durif F, Kulisevsky J, van \nLaar T, Lees A, Poewe W, Robillard A, Rosa MM, Wolters E, Quar g P, Tekin S, Lane R. \nRivastigmine for dementia associated with Park inson's disease. N Engl J Med. 2004;351:2509-18 \n \nBACKGROUND: Cholinergic deficits are prominent in patients who have dementia associated with \nParkinson's disease. We investigated the effects of the dual cholinesterase inhibitor rivastigmine in such patients. \n \nMETHODS: Patients in whom mild-to-moderate dementia developed at least 2 years after they received a \nclinical diagnosis of Parkinson's disease were randomly assigned to receive placebo or 3 to 12 mg of \nrivastigmine per day for 24 weeks. Primary efficacy va riables were the scores for the cognitive subscale of \nthe Alzheimer's Disease Assessment Scale (ADAS-cog) and Alzheimer's Disease Cooperative Study-\nClinician's Global Impression of Change (ADCS-CGIC). Secondary clinical outcomes were the scores for \nthe Alzheimer's Disease Cooperative Study-Activities of Daily Living, the 10-item Neuropsychiatric \nInventory, the Mini-Mental State Examination, Cognitiv e Drug Research power of attention tests, the Verbal \nFluency test, and the Ten Point Clock-Drawing test. \n \nRESULTS: A total of 541 patients were enrolled, and 410 completed the study. The outcomes were better \namong patients treated with rivastigmine than among those who received placebo; however, the differences \nbetween these two groups were moderate and similar to those reported in trials of rivastigmine for \nAlzheimer's disease. Rivastigmine-treated patients had a mean improvement of 2.1 points in the score for \nthe 70-point ADAS-cog, from a baseline score of 23.8, as compared with a 0.7-point worsening in the placebo group, from a baseline score of 24.3 (P<0.001). Clinically meaningful improvements in the scores \nfor the ADCS-CGIC were observed in 19.8 percent of patients in the rivastigmine group and 14.5 percent of \nthose in the placebo group, and clinically meaningful worsening was observed in 13.0 percent and 23.1 percent, respectively (mean score at 24 weeks, 3.8 and 4.3, respectively; P=0.007). Significantly better \noutcomes were seen with rivastigmine with respect to all se condary efficacy variab les. The most frequent \nadverse events were nausea (affecting 29.0 percent of patients in the rivastigmine group and 11.2 percent \nof those in the placebo group, P<0.001), vomiting (1 6.6 and 1.7 percent, P<0.001), and tremor (10.2 and 3.9 \npercent, P=0.01). \n \nCONCLUSIONS: In this placebo-controlled study, ri vastigmine was associated with moderate improvements \nin dementia associated with Parkinson's disease but also with higher rates of nausea, vomiting, and tremor. Ranjit B. Mani, MD, HFD-120 Medical Review Page 47 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.5 Additional Observations And Comments By Agency Statistical \nReviewer About Study 2311 \nThe Agency Biometrics Reviewer for th is submission, Dr Joanne Zhang, has \nmade the following main observations, and drawn the overall conclusions \noutlined below regarding the effi cacy results of this study \n \n7.5.1 Observations \n• Dr Zhang has independently perform ed the protocol-s pecified primary \nefficacy analyses and has obtained results that agree with those obtained by the sponsor. However she has the following concerns about these analyses \n \n An assumption underlying the use of an analysis of covariance (used in \nthis instance for the primary efficacy analysis of the ADAS-Cog) is that \nthe data be normally distributed. Dr Zhang tested the residuals for the analysis of covariance model used fo r the ADAS-Cog analysis with the \nWilk-Shapiro test; the hypothesis of normality of the residuals was \nrejected (p-values of 0.0072 for Week 16, and < 0.0072 for Week 24). Dr \nZhang therefore used a non-parametric method, the Wilcoxon rank sum test, for the analysis of the ADAS-Cog and demonstrated statistically significant differences favoring Exelon® over placebo at both Weeks 16 and 24 (p < 0.005 at both timepoints) \n \n Another assumption underlying the use of an analysis of covariance \nmodel to test for differences between the drug and placebo groups is that of a constant regression relationship between the 2 treatment groups; if that assumption is violated it is indicative of an interaction between the \ntreatment groups and independent variable (i.e., the baseline value) and \nthis interaction renders difficult the interpretation of the final treatment effect due to the drug. Dr Zhang tested the heterogeneity of the slopes for the 2 treatment groups for the ADAS-Cog at Weeks 16 and 24 in the intent-to-treat plus retrieved dropouts population; while the slopes at Week 16 were similar, those at Week 24 were statistically significantly \ndifferent, as indicated by the table below. Therefore, if the analysis of \ncovariance model is relied on to predict the treatment effect due to the drug, the drug will be underestimated at low baseline values and \noverestimated at high baseline values. The results of the sponsor’s \nanalysis of covariance applied to the ADAS-Cog change from baseline \ndata at Week 24 therefore need to be interpreted with caution \n \n \n Timepoint Estimate Standard Error P-values for the \nheterogeneity of slopes \nSlope for Exelon® Week 16 0.216 0.037 \nSlope for placebo Week 16 0.215 0.051 0.982 \nSlope for Exelon® Week 24 0.270 0.041 \nSlope for placebo Week 24 0.120 0.057 0.034 \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 48 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n When the percentage of those improving on the ADCS-CGIC at Weeks \n16 and 24 in the Exelon® and placebo groups was compared by country \n(Austria, Norway, and Portugal were combined as the sample size for \neach was very small), the Exelon® group performed better than the \nplacebo group for most countries whereas the placebo group performed better than the Exelon® group for the remaining countries \n \n• Dr Zhang also repeated the prim ary efficacy analyses on subgroups \ndefined by gender. Some of her findings are reproduced below \n \n The number of male and female patients in each treatment group was as \nfollows \n \nTreatment Group Exelon® \nN Placebo \nN \nWomen 128 62 \nMen 234 117 \n \n Her subgroup analyses for the intent-to-treat plus retrieved dropouts \npopulations on the ADAS-Cog change from baseline score at Week 24 are below \n \nSubgroup Exelon® \nMean change (SD) Placebo \nMean change (SD) p-value \nWomen 1.9 (8.4) -0.9 (8.0) 0.027 \nMen 2.2 (8.1) -0.7 (7.2) 0.001 \n \n Her subgroup analyses for the intent-to-treat plus retrieved dropouts \npopulations on the ADCS-CGIC score at Week 24 are below \n \nWomen Men \n Exelon® Placebo Exelon® Placebo \nN 116 57 213 108 \nMean ± SD 3.9 ± 1.5 4.3 ± 1.4 3.8 ± 1.4 4.3 ± 1.5 \nMarkedly improved (%) 2 2 6 3 \nModerately improved (%) 19 14 14 11 \nMinimally improved (%) 19 11 22 18 \nUnchanged (%) 28 30 24 27 \nMinimally worse (%) 14 21 24 19 \nModerately worse (%) 15 19 8 15 \nMarkedly worse (%) 3 4 2 8 \np-value 0.350 0.045 \n \n• She has noted that the sponsor has used the intent -to-treat plus retrieved \ndropouts population for the primary effi cacy analysis, whereas the Agency \nusually recommends that the intent-to-treat last-observation-carried-\nforward population be us ed for that purpose. She does, however, also \nnote that when the same analysis was repeated for the intent-to-treat last-observation-carried-forward populati on, the results were similar. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 49 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n7.5.2 Conclusions \nDr Zhang has concluded that the data provided support the efficacy of Exelon® \nin Parkinson’s Disease Dementia, based on the prospectively-specified statistical \nanalysis plan; several sensitivity anal yses support this conclusion. She does, \nhowever, note that a gender-based subgroup analysis suggests that this benefit \nmay not extend to women. \n \n7.6 Reviewer’s Comments \n7.6.1 Efficacy Of Exelon® \nThis study does indicate that Exelon® in a dose of 3 to 12 mg/day did have \nefficacy in the entire study population, bas ed on prospectively-specified criteria. \nAlthough a statistically significant treatment effect was not seen in women alone on the gender-based subgroup analysis for the ADCS-CGIC per formed by the \nAgency Biometrics Reviewer, the effect size s (and variance) in that subgroup for \nthe mean change from baseline to W eek 24 in ADAS-Cog score and mean \nADCS-CGIC score were similar to thos e seen in men, while fewer women than \nmen were enrolled in the study. \n \nThe implications of the results of this st udy in the context of the new claim (i.e., \n“treatment of mild to moderate dementia associated with Parkinson’s Disease”) \nsought by the sponsor in this Supplemental Application are discussed later in the \nreview. \n \n7.6.2 Safety Of Exelon® \nThe safety data for this study indicate that the adverse event profile of Exelon® in \nthe study population was largely similar to that seen in clinical trials with \nAlzheimer’s Disease, in that there was a distinctly higher frequency of nausea, \nvomiting, diarrhea, and anorexia in thos e exposed to Exelon® than in those \nexposed to placebo. \n \nOf special relevance to a population with Parkinson’s Disease, was the \nobservation that tremor (which was not further characterized) was recorded as a \ntreatment-emergent adverse event in about 10% of those received Exelon® and \n4% of those who received placebo in this st udy (in the controlled clinical trials of \nExelon® that were conducted prior to its approval for Alzheimer’s Disease, \ntremor was seen in about 4% of those who received Exelon® and 1% of those \nwho received placebo). Several other adver se events that may conceivably have \nbeen linked to a worsening in Parkinson’ s Disease were also more frequent in \nthose treated with Exelon® than in those treated with placebo, but their incidence \nin the Exelon®-treated group was lower than that of tremor. However, changes in \nUPDRS total motor scores, probably a more objective measure of change in the \nmotor manifestations of Parkinson’s Disease than the incidence of treatment-\nemergent adverse events, showed no meaningful difference between treatment groups. Ranjit B. Mani, MD, HFD-120 Medical Review Page 50 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n8. Study 2311E1 (Open-Label Uncontrolled Extension To Study \n2311) \nThe protocol and main safety results for this study will be summarized briefly \nbelow. Note that I have not summarized t he efficacy data for this study at all, \ndespite presentation of those data by the sponsor in the study report, as \nuncontrolled data are not used to determi ne efficacy for regulatory purposes. \n \n8.1 Protocol 2311E1 \nOnly a brief outline of the pr otocol has been provided below. \n \n8.1.1 Title \nAn Open-Label 24-Week Extension To A 24-Week, Prospective, Randomized, \nMulticenter, Double-Blind, Placebo-Cont rolled, Parallel-Group Study Of The \nEfficacy, Tolerability, And Safety Of Exel on® (Rivastigmine) Capsules In Patients \nWith Parkinson’s Disease Dementia \n \n8.1.2 Objectives \n8.1.2.1 Primary \nTo evaluate the safety and tolerability of open-label Exelon® (3 to 12 mg/day) for \nup to 24 weeks in patients who previously completed Study 2311, and to provide continued access to Exelon® \n \n8.1.2.2 Secondary \nTo evaluate the effects of Exelon® on c ognition, including executive function, \nactivities of daily living, behaviora l symptoms and health economic parameters \nincluding caregiver distress and caregiver burden \n \n8.1.3 Design, Duration, Sample Size, Dosage \nThis was to be an open-label uncontrolled extension study. \n \n540 patients were planned to be enroll ed in the preceding double-blind study. \n \nThe design of this study and its predecessor are summarized in the following table, which I have copied from the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 51 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n4 dose levels were to be used for Exel on® (and for matching placebo). The dose \nlevels for Exelon® are show n in the following table. \n \nDose Level Exelon® Dose \n1 1.5 mg BID \n2 3.0 mg BID \n3 4.5 mg BID \n4 6.0 mg BID \n \nThe actual dosing regime was to be as follows: \n \n• For the titration period \n \n All patients were to begin at Dose Level 1 (regardless of their treatment \nassignment in Study 2311) \n After 4 weeks the dose was to be increased to Dose Level 2 unless there \ntolerability was impaired \n Subsequent increases to Dose Levels 3 and 4 were to be based on the \ntolerability of the preceding dose, and were to be considered only after 4 \nweeks of treatment at the previous dose \n In the event of poor tolerability, an investigator could decide to reduce a \ndose to the preceding level, with increases to the next dose level being made as clinically indicated after a minimum of 2 weeks \n The aim was to find the highest tolerated dose for each patient by Week \n16. \n \n• For the maintenance period \n \n The highest well-tolerated dose for each patient was to be maintained for \nthe entire maintenance period \n However, dose adjustments were permitted at any time \n \n8.1.4 Key Inclusion Criteria \n Fulfilled eligibility criteria for Study 2311 \n Either completed double-blind treatment phase of Study 2311 or \ndiscontinued early during that study, but returned for all the remaining \nscheduled efficacy assessments without si gnificant protocol violations Ranjit B. Mani, MD, HFD-120 Medical Review Page 52 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n Informed consent \n Not treated with other acetylcholinesterase inhibitors or cholinomimetic \nagents, and anticholinergic drugs (incl uding tricyclic antidepressants) \nwithin 4 weeks prior to entry into the study \n \n8.1.5 Study Schedule \nThe study schedule is summarized in the following table, which I have copied \nfrom the submission. \n \n \n \n8.1.6 Safety Outcome Measures \nAdverse events, safety laboratory tests, vital signs, body weight, \nelectrocardiograms, and UPDRS Part III (Motor Function). \n \n8.2 Safety Results Of Study 2311E1 \n8.2.1 Patient Disposition \n433 patients enrolled in Study 2311 were elig ible to be enrolled in Study 2311E1; \n334 patients actually consented to parti cipate in the latter study, which 273 \npatients completed. \n \nPatient disposition is summarized in the following sponsor t able, with patients \ngrouped according to whether they took Exelon® (“Exe”) or placebo (“Plc”) in the preceding double-blind study. Note that all discontinuations as well as Ranjit B. Mani, MD, HFD-120 Medical Review Page 53 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \ndiscontinuations due to adverse events were more common in those earlier \nexposed to placebo than in those previously exposed to Exelon®. \n \n \n \n8.2.2 Exposure To Study Drug \nThe mean duration of exposure to Exelon ® in this study was 21.6 weeks, and \nwas similar in those exposed to Exelon® earlier as compared with those exposed \nto placebo (see the sponsor table below). \n \n \n \n8.2.3 Concomitant Medication \nA slightly larger proportion of those who previously received Exelon® (than those \nwho earlier received placebo) initiated new dopaminergic therapy or increased their dose of dopaminergic medication durin g the open-label extension phase, as \nindicated by the table below, which I have copied from the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 54 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n8.2.4 Overall Adverse Event Experience \n75.4% of patients enrolled in this study experienced adverse events with the \nincidence being comparable across t he 2 pre-treatment groups. However, \ngastrointestinal adverse events were more common in those previously exposed \nto placebo (38.2%) than in those previously exposed to Exelon® (27.5%). \n \nAdverse events that occurred in ≥ 5% of patients in the entire study cohort are \nlisted in the following sponsor table. Naus ea, vomiting, and tremor were all more \ncommon in those previously exposed to placebo than in those previously \nexposed to Exelon®. \n \n \n \nThe incidence of adverse events potent ially indicating a worsening in the \nsymptoms of Parkinson’s Disease was 18.0% overall, 26.0% in those previously \nexposed to placebo, and 13.3% in those previously exposed to Exelon®. The \nmost common of these adverse events wa s tremor which had an incidence of \n6.9% overall, 12.2% in those previous ly exposed to placebo, and 3.8% in those \npreviously exposed to Exelon®. Worsening of Parkinson’s Disease had an Ranjit B. Mani, MD, HFD-120 Medical Review Page 55 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nincidence of 3.6% overall, 4.1% in t hose previously exposed to placebo, and \n3.3% in those previous ly exposed to Exelon®. \n \n8.2.5 Deaths, Serious Adverse Events, And Discontinuations Due To Adverse \nEvents \nThe overall incidence of deaths, serious adverse events, and adverse event \ndiscontinuations in this study is summari zed in the following table, which I have \ncopied from the submission: \n \n \n \nA full listing of deaths that occurred in this study is in the following table, which I \nhave copied from the submission. \n \n \n \nI have read the narratives for each death. None can be clearly linked to study \ndrug; all appear to be due to intercu rrent illnesses common in the study \npopulation. \n \nAs noted above, 17.1% of patients enrolled in this study experienced a serious adverse event, and 15.1% of patients enroll ed experienced an adverse event that \nwarranted treatment discontinuation. \n \nThe most frequent adverse events leading to treatment discontinuation were as \nfollows, based on treatment assignment in the earlier double-blind study. \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 56 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nAdverse Event Leading To Disconti nuation Exe-Exelon® Plc-Exelon® \nNausea 0.5% 4.0% \nHallucination 1.4% 1.6% \nTremor 0.5% 1.6% \nVomiting 0.0% 2.4% \n \nI have read the listings and narratives for serious adverse events and \ndiscontinuations due to adverse events. Wi th the exception of those events that \ncould be attributed to the cholinomimetic effects of Exelon®, the adverse events \ndescribe are all consistent with intercu rrent illnesses that are common in this \npopulation. \n \n8.2.6 Laboratory Data \nNo laboratory testing was performed dur ing the open-label extension phase of \nthis study. \n \n8.2.7 Vital Signs And Weight \nMean changes from baseline in vita l sign parameters and weight, and the \nproportion of patients with notable vital sign or weight abnormalities have been \nsummarized in tabular form by the sponsor. These changes were small. \n \n8.2.8 Electrocardiograms \nNo electrocardiograms were performed during this study. \n \n8.2.9 UPDRS Part III Scores \nPatients enrolled in the open-label extension study worsened by a mean (± standard deviation) of 1.8 point s (± 9.6 points) on the to tal UPDRS Part III score. \nIndividual tremor score worsened by a m ean (± standard deviation) of 0.1 points \n(± 2.3 points). \n \n8.3 Sponsor’s Conclusions Regarding Safety \nIn patients treated with Ex elon® or placebo in Study 2311, the safety and \ntolerability of Exelon® in a dose of 3 to 12 mg/day in Study 2311E1 remained \nfavorable, with no new unexpected adver se events reported and no clinically \nsignificant worsening of the motor symptoms of Parkinson’s Disease. The \ntolerability profile of profile of Exelon® did not change over the 24-week open-label extension study. \n \n8.4 Reviewer’s Comments \nI agree with the sponsor’s conclusions \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 57 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n9. Study 2314 (Non-Interventional Validation Study) \nNote that the study report contained in this submission is an interim report which is \nconfined to the validation of various study instruments in Parkinson’s Disease Dementia \nalone, whereas the original study protocol planned to validate these instruments in \nvascular dementia as well. The description of the study protocol and results below is, \ntherefore, also confined to the validation of these study instruments in Parkinson’s \nDisease Dementia alone. \n \n9.1 Protocol \n9.1.1 Title \nA 4-Week, Non-Interventiona l, Cross-Sectional, Multic enter Study To Assess The \nValidity Of Various Assessment Scales Me asuring Cognition, Executive Function, \nBehavior And Activities Of Daily Living In Patients With Mild To Moderate \nParkinson’s Disease Dementia \n \n9.1.2 Objectives \n9.1.2.1 Primary \n To assess the criterion-related valid ity through determination of the ability \nof the ADAS-Cog to differentiate betw een mild and moderate severities of \nParkinson’s Disease Dementia \n \n To assess the test-retest reliabili ty of the ADAS-Cog in Parkinson’s \nDisease Dementia \n \n9.1.2.2 Secondary \n To assess the criterion-related valid ity through determination of the ability \nof other dementia rating scales to differentiate between mild and moderate \nseverities of Parkinson’s Disease Dementia \n To assess the test-retest reliability of other dementia rating scales/tests \n To assess the convergent and diver gent construct validity of the ADAS-\nCog in patients with Parkinson’s Disease Dementia \n To compare scores on dementia rating scales and tests in patients with \nAlzheimer’s Disease with those who hav e Parkinson’s Disease Dementia \n \n9.1.3 Design \nNon-interventional cross-section study \n \n9.1.4 Duration \n4 weeks \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 58 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n9.1.5 Sample Size \nThe planned sample size was 100 patients, comprising 50 patients with \nParkinson’s Disease Dementia and 50 patients with Alzheimer’s Disease. \n \n9.1.6 Main Inclusion Criteria \n Age: 50 to 85 years \n \n For patients with Alzheimer’s Disease \n \no Clinical diagnosis of Alzheimer’s Di sease according to DSM-IV criteria \no Probable Alzheimer’s Disease according to the NINCDS-ADRDA criteria \n \n For patients with Parkinson’s Disease Dementia \n \no Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank \no Diagnosis of Dementia Due To Parkinson’s Disease according to DSM-IV \ncriteria \n \n Mini-Mental Status Examination sc ore at entry between 10 and 24, further \ndivided into mild dementia (Mini-Mental Status Examination score of 18 to \n24) or moderate dementia (Mini-Mental Status Examination score of 10 to \n17) \n \n Stable dose of existing therapy for at least 6 weeks prior to baseline and \nnot expected to change medication doses during the study \n \n9.1.7 Study Schedule \nThe study schedule is summarized in t he following table, which I have copied \nfrom the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 59 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n9.1.8 Assessment Scales To Be Validated \n• ADAS-Cog \n• D-KEFS Verbal Fluency Test \n• Ten-Point Clock Test \n• Trailmaking Tests A and B \n• Neuropsychiatry Inventory, including Neuropsychiatry Inventory-Distress \n• ADCS-ADL \n• Cognitive Drug Research Computerized Assessment System tests for the \nassessment of attention \n \n9.1.9 Assessments Used For Staging \n• Mini-Mental Status Examination \n• Global Deterioration Scale Ranjit B. Mani, MD, HFD-120 Medical Review Page 60 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n9.2 Main Results \n9.2.1 Patient Disposition \nPatient disposition by dementia type and Mi ni-Mental Status Examination stratum \nis summarized in the following table, wh ich I have copied from the submission. \n \n \n \n9.2.2 Demographic And Other Baseline Characteristics \nThese are summarized in the next table, which I have copied from the \nsubmission. \n \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 61 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n9.2.3 Primary Analysis Results \nThe sponsor table below is intended to illustrate the ability of the mean ADAS-\nCog score at baseline to differentiate between mild and moderate Parkinson’s \nDisease Dementia (and Alzheimer’s Dis ease), based on a t-test and supported \nby an analysis of variance with severity group and center as fixed effects. \n \n \n \nThe sponsor points out that the mean ADAS-Cog score at baseline shows a \ndistinct separation between mild and moderate patients in both the Parkinson’s \nDisease Dementia and Alzheimer’s Dis ease groups, with a similar variance \nassociated with the mean in each dementia type and severity. The difference in \nmean ADAS-Cog score between the mild and moderate groups was statistically \nsignificant for each dementia type. \n \nThe size of the mean difference between Mi ni-Mental Status Examination strata \nwas also examined using a Cohen’s effect size computation. Using that computation, effect sizes of 0.2, 0. 5, and 0.8 are generally considered small, \nmedium, and large, respectively. Cohen’s effect size for the mean difference \nbetween disease severities by dementia ty pe, as determined by the sponsor, is in \nthe following table; while this effect si ze was larger for the Alzheimer’s Disease \ngroup, it remained large for the group with Parkinson’s Disease Dementia as \nwell. These results also suggest that t he ADAS-Cog is a scale that can produce a \ngood separation between Mini-Ment al Status Examination strata in the patients \nstudied. \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 62 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nThe test-retest reliability of the ADAS- Cog in this population was evaluated by \ndetermining the correlation coefficient between the ADAS-Cog value at baseline \nand that at Week 4 for each dementia ty pe and severity; the results are in the \nfollowing table contained in the submission, which indicates, according to the \nsponsor, that the correlation coefficient s for the ADAS-Cog at baseline and Week \n4 were strongly positive regardless of dementia type and severity; the sponsor \nfurther states that although the confidence intervals for each correlation coefficient were wide, even their lowe r limits showed a positive correlation. \n \n \n \n \n9.2.4 Secondary Analyses \n9.2.4.1 Ability Of Dementia-Rating Sc ales And Tests Other Than The ADAS-\nCog To Differentiate Between Alzhei mer’s Disease Of Mild And Moderate \nSeverity (Assessment Of Criterion-Related Validity) \nThe ability of dementia rating scales and tests other than the ADAS-Cog to \ndifferentiate between mild and moderate severity Parkinson’s Disease Dementia and Alzheimer’s Disease were evaluated as with the ADAS-Cog by comparing the mean values obtained for each severity category at baseline and at Week 4, \nusing a t-test. The results are in the following table, which indicate that for both types of dementia, the separation between mild and moderate severities was nominally statistically significant fo r the ADCS-ADL, Ten-Point Clock Test, \nTrailmaking Test A, and D-KEFS Verbal Fluency Test. Ranjit B. Mani, MD, HFD-120 Medical Review Page 63 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nThe differences for other measures are in the above table. \n \nTest-retest reliability by dementia ty pe and Mini-Mental Status Examination \nstratum is summarized in the following table, taken from the submission; \nreliability was determined, as with the ADAS-Cog by calculating correlation \ncoefficients based on the baseline and Week 4 scores . The correlations were best for the ADCS-ADL and Neuropsychiatr y Inventory-10 for both populations. Ranjit B. Mani, MD, HFD-120 Medical Review Page 64 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \n9.2.4.2 Comparison Of Scores On Deme ntia Rating Scales In Patients With \nAlzheimer’s Disease Versus Park inson’s Disease Dementia \nThe total scores at baseline in the 2 popul ations were compared as indicated in \nthe following table. The sponsor points out that statistically significant differences \nbetween the 2 populations were not apparent except for the ADCS-ADL score. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 65 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n \nThe sponsor has performed a factor anal ysis of the ADAS-C og sub-item scores \nat baseline for the Parkinson’s Dis ease Dementia and Alzheimer’s Disease \npopulations, as indicated in the following table, taken from the submission. The \nsponsor has observed that the sub-items group differ ently in each population, \nwhich may indicate a different profile of cognitive impairment. The sponsor does \nacknowledge that the sample sizes were small for these analyses. \n \n \n \n9.2.4.3 Convergent And Divergent Construct Validity Of The ADAS-Cog In Patients With Alzheimer’s Disease And With Parkinson’s Disease Dementia \nThe degree of association between the ADAS-Cog and other scales was \nexplored by performing a correlation test between the ADAS-Cog scores and \nthose of each of the other scales at base line. The sponsor considers the results, \nsummarized in the table below, to indicate at least a moderate correlation of the ADAS-Cog with all assessments other than the Neuropsychiatry Inventory and Ranjit B. Mani, MD, HFD-120 Medical Review Page 66 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nNeuropsychiatry Inventory-Distress. Correlation was best between the ADAS-\nCog and Mini-Mental Status Examination, in both populations. \n \n \n \n9.3 Sponsor’s Conclusions \nThe following is a summary of the sponsor’s conclusions: \n \n In patients with Parkinson’s Disea se Dementia, grouped into “mild” and \n“moderate” categories by baseline Mini -Mental Status Examination score, \nthe ADAS-Cog score at baseline showed a statistically significant \ndifference between these categories, thus demonstrating criterion-related validity for the ADAS-Cog, based on severi ty as the criterion. In the same \npopulation, a similar criterion-related validity was also demonstrated for \nthe ADCS-ADL, Ten-Point Clock Tes t, Trailmaking Test A, and D-KEFS \nVerbal Fluency Test \n \n The ADAS-Cog and several other scales demonstrated test-retest \nreliability when used in patients with Parkinson’s Disease Dementia. \n \n When the ADAS-Cog was correlated with scales that measured similar \nand different symptom domains, c onvergent and divergent construct \nvalidity was demonstrated for the ADAS-Cog in pat ients with Parkinson’s \nDisease Dementia. \n \n For patients with a similar severity of dementia, as determined by Mini-\nMental Status Examination score, total scores achieved on specific \ndementia rating scales in patients wit h Parkinson’s Disease Dementia \nwere similar to those in patients with Alzheimer’s Disease. However, a factor analysis that compared the 2 populations on AD AS-Cog sub-item \nscores has indicated that the sub-items group differently in each Ranjit B. Mani, MD, HFD-120 Medical Review Page 67 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \npopulation suggesting that cognitive and behavioral symptom profiles in \nthese populations may differ. \n \n10. Summary Of Earlier Meeting Between Division And Sponsor \nRegarding This Application. \nA meeting was held with the sponsor on May 18, 2005, at which the results of \nStudy 2311 (EXPRESS Study) were discussed in outline and on a preliminary basis, in the context of a sponsor proposal to expand the current indication for \nExelon® to include “the treatment of mild to moderate dementia associated with \nParkinson’s Disease.” \n \nThe following is a summary of the salient views conveyed by the sponsor’s team at that meeting. \n \n The entity of dementia associated with Parkinson’s Disease (as exemplified by \nthe patients enrolled in the EXPRESS Study) is linked to distinctive \nneuropathological findings (i.e., widespread Lewy bodies and Lewy neurites), with more recent publications strongly suggesting that the contribution of co-existing Alzheimer’s-type neuropathological changes (e.g., senile plaques and \nneurofibrillary tangles) to the dementia are minor \n \n A cholinergic deficiency state is the basis for dementia associated with \nParkinson’s Disease, just as with Alzheimer’s Disease \n \n The population enrolled in the EXPRESS trial was distinct from that enrolled in \nthe pre-approval clinical trials of rivastigmine in Alzheimer’s Disease (and was \nactually excluded from those trials) \n \n Although patients enrolled in the EXPRESS trial were not selected based on \nthose neuropsychological deficits that, according to the DSM IV definition of \n“Dementia Due To Parkinson’s Disease,” (294. 1) are distinctive for that disorder \n(i.e., “cognitive and motor slowing, executive dysfunction, and impairment in \nmemory retrieval”), selecting patients based on the extent of such deficits is unlikely to help differentiate them from patients with Alzheimer’s Disease \n \n The results of the EXPRESS Study are sufficiently robust for that study alone to \nbe the basis for the expansion of the current claim to include dementia associated with Parkinson’s Disease, especially since the mechanism by which rivastigmine may have its effect in that condition and in Alzheimer’s Disease may be the same. \n \nThe Division’s key concerns about an expansion of the current claim for \nrivastigmine to include dementia associ ated with Parkinson’s Disease, especially \non the basis of the result s of the EXPRESS study alone, were as follows \n \n The criteria used to diagnose dementia when including patients in the EXPRESS \nStudy were no different from those used to enroll patients in the pre-approval Ranjit B. Mani, MD, HFD-120 Medical Review Page 68 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nefficacy studies of rivastigmine in Alzheimer’s Disease; i.e., these patients were \nnot identified on the basis of any purportedly distinctive features of dementia associated with Parkinson’s Disease. In addition, the clinical course of the \nplacebo arm and the size of the effect seen with rivastigmine in the EXPRESS \ntrial were no different from similar observations in pre-approval efficacy trials of rivastigmine in Alzheimer’s Disease. These observations call into question how distinct the patients in the EXPRESS trial were from those enrolled in the pre-approval Alzheimer’s Disease trials, and whether any effect of rivastigmine on performance that was seen in the former study was mediated through its effects \non co-existing Alzheimer’s Disease. \n \n DSM-IV is a standard reference manual containing diagnostic criteria for the \nentire spectrum of psychiatric and neuropsychiatric disorders, including “Dementia Due To Parkinson’s Disease” (294.1). In the EXPRESS Study, \npatients with dementia associated with Parkinson’s Disease were enrolled based \non their having dementia, but without the more distinctive cognitive deficits described in DSM-IV, thus raising the possibility that the appropriate diagnostic criteria for that entity may not have been applied in that study. \n \n The sponsor is currently seeking a claim for the use of rivastigmine in dementia \nassociated with Parkinson’s Disease based on a single study (i.e., EXPRESS). While the sponsor considers the results of that study to be robust, the Division has generally required that evidence for the efficacy of a drug in a distinct clinical entity be replicated, and a second study would, therefore, ordinarily be required to address the claim that the sponsor is currently pursuing \n \nThe Division was of the view that the entity of dementia associated with \nParkinson’s Disease should be discussed at a meeting of the Peripheral and \nCentral Nervous Systems Drugs Adviso ry Committee. The sponsor proposed \nsubmitting a Supplemental NDA based on efficacy data from the EXPRESS \nStudy only, with a request for a standard review and the possibility of holding a \nmeeting of the Advisory Committee duri ng the course of that review was \ndiscussed. \n \nThe Division was, very shortly after the m eeting, to discuss internally whether it \nwould be prepared to file a Supplemental NDA for rivastigmine in the treatment of \ndementia associated with Parkinson’s Disease, based on efficacy data derived \nfrom the EXPRESS Study al one, given the proposed common mechanism of \naction of rivastigmine in both dementia associated with Parkinson’s Disease and \nAlzheimer’s Disease, and was to inform t he sponsor of its view shortly. \n \nOn May 24, 2005, the Division informed the s ponsor that it would accept the filing \nof a Supplemental NDA for Exelon® in t he treatment of demen tia associated with \nParkinson’s Disease based on the results of the EXPRESS Study alone and that \nreview of that application would include a discussion with the Peripheral and \nCentral Nervous Systems Drugs Advisory Committee during the 10-month review \nperiod. \n \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 69 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n11. Sponsor’s Current View Of Dementia Associated With \nParkinson’s Disease, And Appr opriateness Of ADAS-Cog And \nADCS-ADL In Evaluating Treatment Effects In Dementia Associated With Parkinson’s Disease \nSeparate independent expert reports have been commissioned by the sponsor to \naddress each of these 2 subjects. The c ontents of these repo rts, with which the \nsponsor appears to concur, are summariz ed below. Note that the sponsor has \nsupplemented the results of the second of the reports below with the conclusions \ndrawn from Study 2314. \n \n11.1 Dementia Associated With Parkinson’s Disease (Expert Report: \nDiagnosing Dementia Associated With Parkinson’s Disease And \nDistinguishing It From Alzheimer’s Disease) \nThe report has been prepared by 3 academic s at the request of the sponsor. \nThese individuals are Professors J. Cummings, M. Emre, and C. W. Olanow. \n \nIn the report they have provided their opinion in 2 areas \n \n• Whether the dementia asso ciated with Parkinson’s Disease is a different \ndisease entity from the dementia a ssociated with Alzheimer’s Disease \n• Whether practitioners can diffe rentiate the 2 conditions \n \nThey have concluded that \n \n• There is a distinction between dem entia associated with Parkinson’s \nDisease and Alzheimer’s Disease \n• Operational criteria pe rmit the 2 conditions to be readily distinguished \n• The same operational criteria can be applied by community practitioners \nto easily differentiate between the 2 conditions \n \nThe basis for their conclusions, as st ated in the report, is provided under the \nheadings below, which are the same as th ose used by the author s of the report; \nPlease see the text of the report for full details. Note that although many publications are cited in t he report, full citations are provided for only some of \nthose publications; also note that so me publications cited are untraceable \nthrough standard search engines. \n \n11.1.1 Prevalence And Incidence Of Dem entia Associated With Parkinson’s \nDisease \n• Based on a published meta-analysis, the prevalence of dementia in \npatients with Parkinson’s Disease is about 40%. However, since dementia \nin Parkinson’s Disease is associated with increased mortality, it is likely to be under-represented in cross-sectional studies or in longitudinal studies \nthat do not account for differential mortality Ranjit B. Mani, MD, HFD-120 Medical Review Page 70 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n• Incidence studies, which are relatively free of survival bias indicate a 4-6 \ntimes higher incidence of dementia in patients with Parkinson’s Disease \nas compared with age-matched controls; since the incidence of dementia \nin the control population probabl y represents the occurrence of \nAlzheimer’s Disease and other degener ative and symptomatic dementias \nin the population, the increased incidence of dem entia in populations with \nParkinson’s Disease in all likelihood represents an excess of dementia \nthat is directly attributable to Parkinson’s Disease \n \n11.1.2 Risk Factors For Dementia A ssociated With Parkinson’s Disease \n• The most significant risk factors fo r dementia in patients with Parkinson’s \nDisease are old age, duration of Park inson’s Disease, age at onset of \nParkinson’s Disease, akinetic-rigid form of the disease, and the severity of \nmotor symptoms \n \n• The presence of subtle involvem ent of executive functions in non-\ndemented Parkinson’s Disease pati ents predicts the emergence of \ndementia later \n \n• Dementia becomes more common with advancing Parkinson’s Disease \n \n• Risk factors for dementia associated with Parkinson’s Disease differ from \nthose for Alzheimer’s Disease, with t he principal risk factor for the former \nbeing the presence of Park inson’s Disease itself \n \n• The diagnostic entities of dementia associated with Parkinson’s Disease \nand probable Alzheimer’s Disease are mu tually exclusive by definition, \nsince the diagnosis of probable Al zheimer’s Disease (NINCDS-ADRDA \ncriteria)/dementia of the Alzhei mer’s type (American Psychiatric \nAssociation criteria) requires the ex clusion of other brain disorders \ncapable of causing a dementia syndrome \n \n11.1.3 Genetic Distinctions Between Al zheimer’s Disease And Parkinson’s \nDisease \n• The majority of cases of both Parkinson’s Disease and Alzheimer’s \nDisease occur sporadically. However, genetic mutations have been \nidentified in some Alzheimer’s Diseas e and Parkinson’s Disease patients; \nthe genetic mutations associated with Parkinson’s Disease differ from \nthose associated with Alzheimer’s Disease, and no gene mutation has \nbeen identified which causes both. Such genetic defects as have been associated with Alzheimer’s Disease t end to be associated with disorders \nof amyloid production and metabolism, while some genetic forms of \nParkinson’s Disease are associated with mutations and increased deposition of alpha-synuclein Ranjit B. Mani, MD, HFD-120 Medical Review Page 71 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n• There is no excess of Alzh eimer’s Disease among probands with \nParkinson’s Disease as might be anticipated if the major genetic factors \ncontributing to their etiologies are shared \n \n• Specific APOE alleles tend to be associated with Alzheimer’s Disease and \nParkinson’s Disease, respectively. \n \n• The genetic distinctions between Alzheimer’s Disease and Parkinson’s \nDisease are summarized in the table below \n \nGenetic Feature Dementia Associated with Parkinson’s Disease Alzheimer’s Disease \nCausative mutations Alpha-synuclein, PARKIN, UCH-L1, PARK-8, PINK-1, DJ-1 PS1, PS2, APP \nAPOE-4 influence No effect on PDD; increases age-related or AD-type pathology Major risk factor \nAPOE-2 influence Increases PDD Decreases AD \nAD: Alzheimer’s Disease \nPDD: dementia associated with Parkinson’s Disease \n \n11.1.4 Neuropathological Distinctions Between Alzheimer’s Disease And \nParkinson’s Disease \n• Stains that are specific and sens itive for detecting Lewy body and neurite \npathology in Parkinson’s Disease hav e been helpful in understanding the \nbasis for dementia associated with Parkinson’s Disease \n \n• Cortical Lewy bodies and the extent of Lewy neurites in the CA2 region of \nthe hippocampus show a strong correla tion with the extent of cognitive \nimpairment \n \n• Marked nigrostriatal dopaminergi c neuronal degeneration is a unique \npathological feature of dementia associated wit h Parkinson’s Disease. \nPathological abnormalities in the locu s ceruleus may also contribute to \ndementia associated with Parkinson’s Disease \n \n• In Parkinson’s Disease, there is also a loss of cholinergic neurons in the \nnucleus basalis of Meynert and a mark ed cholinergic deficiency, both of \nwhich may occur early in the course of that disorder. These changes are \nmost pronounced in patients with dementia associated with Parkinson’s Disease. The severity of the cholinergic deficiency in dementia associated with Parkinson’s Disease is greater than that occurring in Alzheimer’s \nDisease. Ranjit B. Mani, MD, HFD-120 Medical Review Page 72 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n• While the pathological abnormalities c haracteristic of Alzheimer’s Disease \n(i.e., neurofibrillary tangles and senile plaques) are commonly present in \npatients with dementia asso ciated with Parkinson’ s Disease, they are \nmore commonly present when dementia is advanced, and they do not \naccount for all or even a majority of cases of dement ia associated with \nParkinson’s Disease \n \n• Differences in the neuropatholog y of dementia associated with \nParkinson’s Disease and Alzheimer’s Disease are summarized in the following table, which I have c opied from the submission \n \nPathological Feature Dementia Associated with \nParkinson’s Disease Alzheimer’s Disease \nLewy bodies Correlate highly with cognitive \nimpairment Rare \nSenile plaques Low sensitivity fo r dementia Present in all cases \nNeurofibrillary tangles Low sensitivity fo r dementia Present in nearly all cases \nCholinergic deficit More marked Less marked \nDopaminergic deficit Present Absent \nNoradrenergic deficit Present Present \n \n11.1.5 Neuroimaging In Dementia A ssociated With Parkinson’s Disease \nOnly limited neuroimaging studies have been done in dementia associated with Parkinson’s Disease. \n \nPreliminary MRI observations suggest that while atrophy of t he temporal lobes, \nincluding the hippocampus and parahippocam pal gyrus, is more severe in \npatients with Alzheimer’s Disease, severe atrophy of the thalamus and occipital \nlobes is more characteristic of Parkinson’s Disease. \n \nFunctional imaging studies (single-phot on emission computerized tomography; \npositron emission tomography) using r adiolabeled ligands which provide a \nmeasure of pre-synaptic dopaminergi c neurons and terminals have revealed \nsignificant reductions in striatal uptake or binding of these ligands, as compared \nwith patients who have Alzhei mer’s Disease or controls. \n \n11.1.6 Neuropsychological Differences Between Dementia Associated With \nParkinson’s Disease And Alzheimer’s Disease \nThese differences are summarized in the following table, which I have modified \nslightly, for the sake of clarity, from one contained in the submission. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 73 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nNeuropsychological Domain Dementia Associated with Parkinson’s Disease Alzheimer’s Disease \nMemory Retrieval deficit syndrome Amnestic type of memory disturbance \nExecutive function deficit Prominent Moderate \nLanguage deficit Limited Prominent \nVisuospatial deficits Prominent, ma y be attributable to executive \nabnormalities Milder, independent of executive dysfunctio n\nBradyphrenia Present Absent \nFluctuation in attention Characteristic Uncommon \n \n11.1.7 Distinction Between Dementia Associated With Parkinson’s Disease And \nAlzheimer’s Disease Based On Non- Cognitive Clinical Features \nThese differences are summarized in the following table, which I have modified, \nfor the sake of clarity, from one contained in the submission. \n \nNon-Cognitive Feature Dementia Associated with Parkinson’s \nDisease Alzheimer’s Disease \nMotor signs of Parkinson’s Disease Present Absent (parkinsonism may emerge late) \nNeuroleptic sensitivity Present Absent \nAutonomic dysfunction Common Uncommon \nREM sleep behavior disorder Common Absent \n \n11.1.8 Parkinson’s Disease Can Be Distinguished From Alzheimer’s Disease By A Practitioner \nThe currently available diagnostic cr iteria for dementia associated with \nParkinson’s Disease are thos e contained in DSM-IV. According to the authors of \nthe report, all major criteria, which ar e listed below, should be present for a \ndiagnosis to be made. \n \n• Parkinson’s disease \n• Dementia comprising the following \no Memory impairment \no Impairment of at least one other cognitive domain \no Impairment represents a decline from a previous level of function \no Impairment sufficient to cause occupational or social disability \no Impairment not present exclusively during a delirium \n• Onset of Parkinson’s disease preceded the onset of dementia \n• Alternate causes of dementia have been excluded \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 74 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nReviewer’s Note: What is actually stated in DSM-IV (see below) is not \nquite the same as the above \n \n294.1 Dementia Due To Parkinson’s Disease \n \nThe essential feature of Dementia Due To Parkinson’s Disease is the presence of dementia that is judged to \nbe of direct pathophysiological consequence of Parkins on’s disease. Parkinson’s disease is a slowly \nprogressive neurological condition, characterized by tremor, rigidity, bradykinesia, and postural instability. Dementia has been reported to occur in approximately 20%-60% of individuals with Parkinson’s disease and \nis more likely to be present in older individuals or in those with more severe or advanced disease. The dementia associated with Parkinson’s disease is char acterized by cognitive and motor slowing, executive \ndysfunction and impairment in memory retrieval. Dec lining cognitive performance in individuals with \nParkinson’s disease is frequently exacerbated by depr ession. Findings on physical examination include the \ncharacteristic abnormal motor signs of resting tremor , evidence of slowness and poverty of movement (such \nas micrographia), or muscular rigidity and loss of associated movements. At autopsy, neuronal loss and \nLewy bodies are evident in the substantia nigra. Ther e are a number of syndromes that manifest with \ndementia, Parkinsonian movement disorders, and additional neurological features (e.g., progressive \nsupranuclear palsy, olivopontocerebellar degeneration, and Vascular Dementia). Some individuals with \nParkinson’s disease and dementia are found at autopsy to have coexisting neuropathology indicative of \nAlzheimer’s disease or of diffuse Lewy body disease.\n \n \nA medical practitioner can apply these criteria easily. \n \n11.2 Appropriateness Of Using The ADAS-Cog And ADCS-ADL As \nOutcome Measures In Dementia Associated With Parkinson’s Disease \nAn expert report prepared by Philip D. Ha rvey, PhD, has been provided in this \nsubmission. Although this report addre sses both the use of the ADAS-Cog and \nADCS-ADL in this condition, it is entitled: “Reliability and Validity of the \nAlzheimer’s Disease Assessment Scale – Cogn itive Subscale in Clinical Trials for \nDementia Associated with Parkinson’s Disease.” \n \nThe report was created partly in response to comments made by the European \nAgency for the Evaluation of Medicinal Products/Committee for Proprietary \nMedicinal Products after review of an earlie r version of the protocol for the non-\ninterventional study 2314. \n \nNote that this report, which was comp leted on October 28, 2004, does not cite \nthe results of either Study 2311 or Study 2314, and appears to have been \ncompleted without taking these data into cons ideration. It is based on a review of \nthe medical literature (but that review does not include the published results of \nStudy 2311). \n \nThe contents of this report are brie fly summarized below under the following \nheadings. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 75 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n11.2.1 ADAS-Cog \n11.2.1.1 ADAS-Cog In Alzheimer’s Disease \nThe author of the report states that t he ADAS-Cog has the following properties \nwhen used in Alzheimer’s Disease. \n \n Reliability \n Face validity and sensitivity to impairment \n Sensitivity to change (criterion validity) \n \nThe author also points out t hat in efficacy studies in this population, the benefits \nof active treatment are evaluated in re lation to placebo groups which experience \na decline in cognition over the study; in some of these studies, the active \ntreatment group experienced no improvement relative to baseline. In other \nwords, a net benefit relative to plac ebo is assessed rather than an absolute \nimprovement with active treatme nt relative to baseline. \n \n11.2.1.2 ADAS-Cog In Parkinson’s Disease Dementia \nThe following is a summary of what is stated by the author of this report. \n \n11.2.1.2.1 Face Validity Of ADAS-Cog \nParkinson’s Disease Dementia is characterized by the following \n \n Impaired memory, but of less severi ty than that seen in Alzheimer’s \nDisease. (The memory deficit seen in Pa rkinson’s Disease Dementia is of \nthe subcortical variety with impaired ra te of learning and free recall, but \nwith preserved delayed recognition memory [the impairments of memory \nare related to changes in cort ical cholinergic function]) \n Executive function deficits along with deficits in motor speed and working \nmemory, which in themselves are unlik ely to fully account for the memory \ndeficits seen in this condition. (The author also indicates that cognitive test \nperformance may be influenced by depression, motor symptoms, bradykinesia, and bradyphrenia) \n \nWhile executive dysfunction is not well assessed by the ADAS-Cog, it is a feature \nof both Alzheimer’s Disease and Parkinson’s Disease Dementia. \n \nThe ADAS-Cog is sufficient to eval uate episodic memory impairment in \nParkinson’s Disease Dementia and therefore capt ures critical f eatures of that \ncondition. \n \n11.2.1.2.2 Temporal Change In ADAS-Cog \nThe course of cognitive decline in Pa rkinson’s Disease Dementia has not been \nadequately studied; existing published studies have a number of limitations. The Ranjit B. Mani, MD, HFD-120 Medical Review Page 76 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nfew treatment studies in this condit ion prior to Study 2311 suggest that the \ncognitive change that occurs in Parkins on’s Disease Dementia over time is not \nas rapid or extensive as that seen over a similar period in patients with \nAlzheimer’s Disease. \n \n11.2.1.2.3 Sensitivity To Impairment And To Effects Of Treatment \nThe very limited literature covering the use of the ADAS-Cog in Parkinson’s \nDisease Dementia suggests that scores on t hat instrument correlate with those \non the Mini-Mental Status Examination, suggesting that the ADAS-Cog is \nsensitive to impairment in that conditi on. The limited literat ure available also \nsuggests that the ADAS-Cog is as sensitiv e to treatment effects in Parkinson’s \nDisease Dementia as in Alzheimer’s Disease. \n \n11.2.1.2.4 Criterion Validity: Clinically Relevant Differences \nBased on the small number of published studies, treatment effects in Parkinson’s \nDisease Dementia, as measured by the ADAS-Cog, are at least as large as \nthose in Alzheimer’s Disease and, therefore, at least as clinically meaningful. \n \n11.2.2 ADCS-ADL \n11.2.2.1 ADCS-ADL In Alzheimer’s Disease \nThe author highlights the following properti es of the ADCS-ADL in Alzheimer’s \nDisease, based on the publis hed literature: \n \n• Good test-retest reliability \n \n• Convergent validity \n \n Good correlation of individual items on the scale with the level of \ndementia severity as measured by the Mini-Mental Status Examination \n Ability to detect a decline in activities of daily living across levels of \ndementia severity \n Significant correlation with scores on various cognitive measures such as \nthe ADAS-Cog and Mini-Mental Status Examination \n \n• Sensitivity to treatment effects in clinical drug trials in Alzheimer’s Disease \n \n11.2.2.2 ADCS-ADL In Parkinson’s Disease Dementia \nWhile there are no published studies of t he use of the ADCS-ADL in Parkinson’s \nDisease Dementia, the experience in Alzheimer’s Disease supports its use as a “secondary” outcome measure in Parkinson’s Disease Dementia. \n \nHowever, clinical changes in domains in Parkinson’s Disease other than \ncognition can result in changes in performance on activities of daily living. Ranjit B. Mani, MD, HFD-120 Medical Review Page 77 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n12. Financial Disclosure Certification \nFinancial disclosure information has been co llected for the following studies: \n2311, 2311E1, and 2314. \n \n12.1 Components Of Certification \nThis certification provided by the sponsor has 2 components. \n \n12.1.1 Certification Perti nent To Investigators/Sub-Investigators Who Declared \nThat They Did Not Have Any Relevant Financial Interests \nThe sponsor has supplied a list of all su ch investigators and sub-investigators \nwho were involved in these studies. In regard to this list the sponsor has \n \n• Certified that it has not entered into any financial agreement with the clinical \ninvestigators listed in the applicati on, whereby the compensation to the \ninvestigator could be affected by the outcome of the study in which the \ninvestigator was a participant, as defined by 21 CFR 54.2 (a) \n• Certified that each listed clinical in vestigator required to disclose to the \nsponsor whether the investi gator had a proprietary interest in this product or a \nsignificant equity in the sponsor as defined in 21 CFR 54.2 (b) did not \ndisclose any such arrangements \n• Certified that no listed investigator was the recipient of significant payments of \nother sorts as defined in 21 CFR 54.2 (f) \n \nThis certification has been provided on FDA Form 3454. \n \n12.1.2 Certification Pertinent To In vestigators/Sub-Investigators With \nDisclosable Financial Interests \nThe sponsor has provided the name of a si ngle investigator participating in Study \n2311 who had a disclosable financial interes t. This investigator had received a \ngrant from the sponsor to conduct a st udy of rivastigmine in nursing home \npatients with severe dementia. \n \nThis certification has been provided on FDA Form 3455. \n \n12.2 Reviewer’s Comments \nIt appears unlikely that the financial arrangements disclosed above introduced \nsignificant bias into the results of trials submitted with this application. \n \n13. Site Inspection Report \nPending Ranjit B. Mani, MD, HFD-120 Medical Review Page 78 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n14. Review Of Proposed Labeling \nDeferred \n \n15. Comments \n15.1 General \nIn this supplemental New Drug Application, the sponsor is seeking the approval \nof Exelon® (rivastigmine tartrate) capsules for the treatment of “mild to moderate \ndementia associated with Parkinson’s Disease .” The putative entit y of “mild to \nmoderate dementia associated with Park inson’s Disease” has also been referred \nto, interchangeably, as “Parkinson’s Dis ease Dementia” in this application. \n \nExelon® is currently approved for marketing in this country, as both capsule and \noral solution formulations, for the treatment of mild to moderate dementia of the \nAlzheimer’s type. \n \nThe sponsor has provided evidence from two completed clinical studies in \nsupport of the efficacy and safety of Ex elon® for the proposed new indication. \nThese are: \n \n Study 2311, which was randomized, double-blind, placebo-controlled, and \nparallel-arm in design \n Study 2311E1, the open-label uncontrolled extension to Study 2311 \n \nIn addition, the sponsor has performed a non-interventional study (Study 2314) of \nthe validity of a number of assessment scales in the Parkinson’s Disease \nDementia (and vascular dementia); parti al results for this study have been \nsubmitted in this application. \n \n15.2 Efficacy \n15.2.1 Summary Of Study 2311 \nThe results of a single randomized, double- blind, placebo-cont rolled study (also \nreferred to as the EXPRESS Study) of the efficacy of rivastigmine in the \nproposed entity of Parkinson’s Disease Dementia or dementia associated with \nParkinson’s Disease has been submitted in th is application. The main features \nof this study were as follows \n \n This was a randomized (2:1 [Exelon®:Placebo]), double-blind, placebo-\ncontrolled, parallel-arm study \n \n The key inclusion criteria for the study were as follows \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 79 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \no Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank clinical diagnostic criteria \no Clinical diagnosis of Parkinson’s Disease Dementia according to DSM-IV \ncriteria (Code 294.1) with onset of sy mptoms of dementia within at least \n2 years of the first diagnosis of idiopathic Parkinson’s Disease \no Mini-Mental Status Examination score of 10 – 24 at entry \n \n• The study was of 24 weeks’ duration \n \n• The 2 parallel treatment arms were \n \no Rivastigmine 3 to 12 mg/day (flexible dose; BID administration) \no Placebo \n \n• The primary efficacy measures were the ADAS-Cog and ADCS-CGIC. The \nprimary efficacy analysis was performed on the intent-to-treat plus retrieved \ndropouts population. In the sponsor’s primary efficacy analysis, the 2 treatment \ngroups were compared on the ADAS-Cog using an analysis of covariance, and \non the ADCS-CGIC using the Cochran-Mantel-Haenszel test \n \n• The secondary efficacy measures were the following: ADCS-ADL; \nNeuropsychiatry Inventory-10; Mini-Mental Status Examination; Cognitive Drug Research Computerized Assessment System; D-KEFS Verbal Fluency Test; and Ten Point Clock-Drawing Test \n \n• Safety was assessed through adverse events, vital signs, safety laboratory tests, \nelectrocardiograms, and Unified Parkinson’s Disease Rating Scale score \n \n• The sponsor’s primary efficacy analysis was performed on the intent-to-treat plus \nretrieved dropouts dataset using the following statistical models \n \no The change from baseline to endpoint in the ADAS-Cog score was to be \ncompared between the treatment groups using an analysis of covariance with \ntreatment, country, and baseline ADAS-C og score as explanatory variables \no The ADCS-CGIC score at endpoint was to be analyzed using a Cochran-Mantel-\nHaenszel test with modified ridits sc ores and with country as a stratification \nvariable \n \n• Note that the study procedures included a number of precautions to minimize the \neffects of the motor manifestations of Parkinson’s Disease on the efficacy \nassessments \n \no All primary and other cognitive outcome variables were to be assessed before \nlunch, beginning 1 hour after the intake of dopaminergic medications, at the \nsame time of day throughout the study for each patient, and using the same \nsequence of tests \no For patients with motor fluctuations an d/or dyskinesias, efficacy assessments \nwere to be performed during their “on” time (defined as intervals when parkinsonian symptoms were repl aced by increased mobility) \no For patients with an acute psychosis, efficacy assessments were to be performed \nafter remission of the psychosis \no Raters were advised to identify and discount, if possible, potential behavioral and \nfunctional changes due to the motor symptoms of Parkinson’s Disease Ranjit B. Mani, MD, HFD-120 Medical Review Page 80 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \nKey efficacy results for this study were as follows \n \n• 541 patients were randomized, of whom 442 patients completed the study. Their \ndistribution by treatment group was as follows: \n \nTreatment Group Exelon® Placebo\nNumber randomized 362 179 \nNumber completed 263 147 \n \n \n• The primary efficacy analysis, using Study Week 24 as the endpoint, revealed \nstatistically significant differences between the treatment groups on the ADAS-\nCog (difference in mean change from baseline score at endpoint: 2.90; p < \n0.001) and ADCS-CGIC (difference in mean score between treatment groups at \nendpoint: 0.5; p = 0.007). Note that an Agency statistical reviewer has judged the distribution of ADAS-Cog data not to be normal and therefore in violation of the assumptions of the analysis of covariance model proposed; however, even with the use of a non-parametric model, the Wilcoxon rank sum test, the Exelon® group showed a statistically significant superiority over placebo on this measure \n \n• Nominally statistically significant differences were seen between the treatment \ngroups on all secondary efficacy variables at Week 24 in the same dataset as that used for the primary efficacy analysis \n \n• Analyses of the primary efficacy parameters using other datasets (intent-to-treat last-observation-carried-forward, and observed cases) yielded similar results.\n \n \n15.2.2 Sponsor’s View Of The Entity Of Parkinson’s Disease Dementia \n(Dementia Associated With Parkinson’s Disease) \nThe sponsor’s view of the entity of dementia associat ed with Parkinson’s Disease \nappears to be consistent with an expert repor t included in this submission. The \nmain conclusions of the expert report may be summarized as follows: \n \n• Based on epidemiologic, genetic, neuropathological, neuroimaging, and cognitive \nand non-cognitive clinical data, dementia associated with Parkinson’s Disease is an entity distinct from Alzheimer’s Disease. \n \n• The severity of dementia associated with Parkinson’s Disease is better correlated \nwith pathological changes that are distinctive for Parkinson’s Disease such as the presence of cortical Lewy bodies. Although neurofibrillary tangles and senile plaques are frequently present in the brains of patients with dementia associated with Parkinson’s Disease, the extent of these changes is less pronounced than those that are distinctive for Parkinson’s Disease and less well-correlated with \nthe severity of dementia. The neuropathological changes in the brains of patients \nwith dementia associated with Parkinson’s Disease include lesions of cholinergic pathways distinct from those seen in Alzheimer’s Disease. \n \nMarked nigrostriatal neuronal degeneration is a unique feature of dementia associated with Parkinson’s Disease; cell loss in the medial substantia nigra is Ranjit B. Mani, MD, HFD-120 Medical Review Page 81 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nassociated with the presence of dementia. Pathological abnormalities in the locus \nceruleus may also contribute to the dementia of Alzheimer’s Disease. \n \n• The diagnostic entities of dementia associated with Parkinson’s Disease and \nAlzheimer’s Disease are mutually exclusive by definition. The diagnosis of \ndementia associated with Parkinson’s Disease should be based on the presence \nof all of the following criteria [which the sponsor believes are stipulated in DSM-IV (294.1)] \n \no Presence of Parkinson’s Disease \no Presence of dementia syndrome \no Evidence of Parkinson’s Disease prior to the onset of dementia \no Exclusion of other causes of dementia \n \n• Dementia associated with Parkinson’s Disease is an entity that be diagnosed by \na community medical practitioner \n \n15.2.3 Implications Of Efficacy Results Of Study 2311 (EXPRESS Study) \nStudy 2311 may be considered “positive” in that it demonstrates the efficacy of \nExelon® in the study popul ation based on prospectively-specified criteria for \nsuccess. The dual efficacy outcome measure paradigm used for demonstrating \nthe efficacy of Exelon® in this study is the same as used to demonstrate the \nefficacy of drugs approved for the treatment of Alzheimer’s Disease (dementia of \nthe Alzheimer’s type). \n \nHowever, the key regulatory question that needs to be addressed in the \ncontext of this application is whethe r the results of Study 2311 establish \nthat Exelon® is effective in the treatme nt of an entity (dementia associated \nwith Parkinson’s Disease [Parkins on’s Disease Dementia]) that is \nsufficiently distinct from mild to mode rate dementia of the Alzheimer’s type \n[for the treatment of which Exelon® is already approved] to justify a \nseparate regulatory claim . \n \nNote that for a drug to be approved for a specific condition the following must \ngenerally be true \n \n The condition can be defined without ambiguity using criteria that have wide \nacceptance, and are both valid and reliable \n Appropriate instruments be used for measurement of the clinical effect of the \ndrug on that condition; such instruments must measure what they are intended to \nunder the conditions under which they are actively employed \n Clinical trials should be appropriately designed to measure that effect \n The effect measured should be clinically meaningful \n \nI will address the question (in bolded text) above, and several additional \nquestions under the following headings \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 82 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n15.2.3.1 Is Parkinson’s Disease Dementia (dementia associated with \nParkinson’s Disease) a distinct entity (i.e ., distinct from Alzheimer’s Disease) and \ndo widely accepted, valid, and reliable criter ia exist for its clinical diagnosis? \n While it is widely accepted that there is an increased prevalence of \ndementia in Parkinson’s Disease, the pathological basis for that dementia has been a matter of cont roversy, in regard to both the specific \nhistopathological abnormalities seen and their location. The medical \nliterature indicates that in patients with Parkinson’s Disease who develop \ndementia, the neuropathological findings are varied; while a number of the \npathological abnormalities seen are cons idered distinctive for that entity \n(e.g., cortical Lewy bodies and degener ation of the medial substantia \nnigra) and may correlate best with the severity of dementia, Alzheimer’s-\ntype pathology (such as neurofibrilla ry tangles and amyloid plaques) \nfrequently co-exists, albeit often not to a sufficient degree for a separate \npathological diagnosis of Alzheime r’s Disease to be made; pathological \nlesions attributed to cerebrovascula r disease may also co-exist. The \nvariability in pathological abnormalities described in those studies may, in part, reflect differences in the methods used in each instance. \n \nMore recently published studies are cons idered by some to indicate that \nearlier histopathological data may have underestimated the extent to which Lewy bodies were present in the brain (and especially in the \nneocortex and limbic cortex) of pa tients with Parkinson’s Disease and \ndementia; these studies were done prio r to the availability of modern \nimmunohistochemical techniques such as stains for ubiquitin and alpha-synuclein. The earlier studies may, t herefore, according to the sponsor \nand others, have attributed a greater-t han-justified role for Alzheimer’s \ntype pathology in the pathogenesis of dem entia in these patients, while \nmore recent studies suggest that co rtical Lewy bodies may have a greater \nrole in the pathogenesis of dementia, \nalthough their extent may not \ncorrelate with the severity of dementia (see Braak H et al below) . \n \nThus, recently published data suggest that the pathological substrate \nunderlying the dementia that occurs in Parkinson’s Disease may be more distinctive for that disease than previ ously believed. Note that a recent \nconsensus report (McKeith et al [ 2005]) for a closely-linked disorder, \ndementia with Lewy bodies (see below ), states that “the relative \ncontributions of Lewy body formation\n and synuclein pathology, Alzheimer’s \nDisease-type pathology, neuron loss, or neurochemical deficits as \ndeterminants of dementia in Parkinson’s Disease remain unresolved \nalthough recent studies suggest that Lewy-related pathology is more \nstrongly associated than Alzheimer’s Disease-type changes. \n \nThe cholinergic deficit seen in pati ents with Parkinson’s Disease dementia \nhas been linked to the loss of neurons in the nucleus basalis of Meynert Ranjit B. Mani, MD, HFD-120 Medical Review Page 83 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nand to a more marked brain choliner gic deficiency than in Alzheimer’s \nDisease. \n \n• A further question is whether the dementia that occurs in Parkinson’s \nDisease is clinically distinct or dissimilar from that which occurs in \nAlzheimer’s Disease, and in other types of primary degenerative dementia, and whether validated criteria exist for the diagnosis of the former. \n \nMany publications, including relatively recent articles, state that the \ncognitive deficits that are seen in t he dementia that occurs in Parkinson’s \nDisease are distinctive to at least so me degree, with the following higher \ncortical process being impaired to a greater degree, and, in some \ninstances, qualitatively, as comp ared with patients with Alzheimer’s \nDisease: \n \n Attention (fluctuations in attention are also seen) \n Executive functions \n Free recall memory (with preserved recognition memory) \n Visuospatial function \n Verbal fluency (with other aspects of language function, as well as praxis, \nbeing preserved) \n Speed of mental processing \n \nBehavioral and personality changes are also stated to be more common in \nParkinson’s Disease than in Alzheimer’s Disease \n \n• Criteria for diagnosing “Dementia Due To Parkinson’s Disease” exist \nunder DSM-IV (294.1). These criteria state that “the essential feature of \nDementia Due To Parkinson’s Disease is the presence of dementia that is \njudged to be of direct pathophysiological consequence of Parkinson’s \ndisease” but do not provide a further indica tion of how that judgment is to \nbe made beyond stating that “dementia associated with Parkinson’s \nDisease” is “characterized by cogni tive and motor slowing, executive \ndysfunction, and impairment in memory re trieval.” The criter ia are primarily \ndescriptive, and, importantly, do not clearly state how this entity is to be distinguished from other dementias such as Alzheimer’s Disease; they \nhave never been validated against the hist opathological abnormalities that \nhave recently been described as being more distinctive for dementia in Parkinson’s Disease; in fact, these cr iteria are deficient enough in their \nspecifications, or lack thereof, that they are likely to be difficult to apply in \na validation study. Note that a just-issued American Academy of \nNeurology Practice Parameter (see Mi yasaki et al, below) suggests that \ngiven the pattern of deficits report ed to seen in patients with dementia \nassociated with Parkinson’s Disease, the DSM-IV criteria for establishing dementia per se may not be appropriate to use. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 84 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \nA recently published relatively large st udy (see Braak H et al below) that \ncorrelated cognitive status with neuropathological stage in Parkinson’s \nDisease, and concluded that the burden of Alzhei mer -type pathological \nchanges was relatively low in such pat ients, did not require that patients \nwith dementia who were included in that study needed to have a specific pattern of cognitive deficits such as that considered by some authors to be distinctive for Parkinson’s Disease (see above). The criteria used were as follows \n \n Clinical diagnosis of Parkinson’s Disease \n Presence of dementia, without that dementia syndrome needing to have \nany distinctive features \n Evidence of Parkinson’s Disease more than a year prior to the onset of \ndementia \n \nA number of other published studies t hat have reported clinicopathological \ncorrelations in demented patients with Parkinson’s Disease have also not required such patients to have a specif ic qualitative pattern of cognitive \ndeficits \n \nThus, there do not appear to be validated diagnostic criteria for \nParkinson’s Disease Dementia, let alone criteria that st ipulate that a \nspecific pattern of cognitive deficits must be present. The remaining \nquestion is whether the clinical diagnos is of Parkinson’s Disease together \nwith the presence of dementia (but without a specific pattern of cognitive \ndeficits), with the onset of Parkins on’s Disease preceding the onset of \ndementia by not more than two years and the exclusion of other causes of \ndementia to the extent clinically possi ble, are together su fficient to define a \nclinical syndrome that is sufficiently distinct from Alzheimer’s Disease to \njustify a separate treatment claim. \n \n• Note that the recently-issued American Academy of Neurology Practice \nParameter (see Miyasaki et al, below ) contains the following statements, \namong others, in regard to dementia in Parkinson’s Disease (PD) \n \n “The etiology of dementia in PD is unclear” \n \n Cognitive decline in PD is characterized by impaired executive function, \nvisuospatial abnormalities, impair ed memory, and language deficits. An \nappropriate scale that reliably incorpor ates executive function (e.g., frontal \nassessment battery and other practical tests of executive function) should be \nincorporated into a screening test fo r PD dementia. When evaluating new \nscreening tools, the DSM-IV criteria for dementia may not be the most appropriate gold standard for patients with PD. DSM-IV criteria for dementia have not been \nvalidated in PD. In PD patients, it may be difficult to assess impairments in \ndomains other than memory. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 85 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n15.2.3.2 What are the implic ations of the diagnostic criteria for dementia with \nLewy bodies for the entity of Pa rkinson’s Disease Dementia? \nAnother entity that combines dementia with features of Parkinson’s Disease is \ndementia with Lewy bodies for which revised diagnostic criteria have recently \nbeen proposed (see McKeith et al [2005] bel ow). In the more recent medical \nliterature, this entity has generally been distinguished from Parkinson’s Disease \nDementia by the (arbitrary) “one-year ru le” criterion where the onset of dementia \nwithin 12 months of the ons et of parkinsonism is st ated to be consistent with \ndementia with Lewy bodies whereas if parkinsonism has been present for more \nthan 12 months prior to the onset of dem entia, the condition is considered to \nrepresent Parkinson’s Disease Dementia . The neuropathological abnormalities \nthat underlie both conditions are cons idered to be similar with changes \nconsidered distinctive for Parkins on’s Disease being combined with other \npathology, notably Alzheimer-type changes. W hether these entities are the same \ndisease or separate distinct entities is still a matter of some controversy, although \nthe consensus view appears to be that they are the same neurobiological entity \nwith clinical phenotypes that differ, based so lely on the arbitrary “one-year rule.” \n \nNote that the revised criteria for t he diagnosis of dementia with Lewy bodies \ninclude the following “centra l” (required) feature: “Dementia defined as \nprogressive cognitive decline of suffici ent magnitude to inte rfere with normal \nsocial or occupational function. Prominent or persistent memory impairment may not necessarily occur in the early stages, but is usually evident with progression. \nDeficits on tests of attention, executive function, and visuospatial ability may be \nespecially prominent.” The publication that describes these revised diagnostic \ncriteria (McKeith et al [2005]) further states the following: “The cognitive profile of \ndementia with Lewy bodies (DLB) co mprises both cortical and subcortical \nimpairments with substantial attentional deficits and prominent executive and \nvisuospatial dysfunction. A “double discrimination” c an help differentiate DLB \nfrom Alzheimer disease (AD), with relative preservation of confrontation naming \nand short and medium term recall as we ll as recognition, and greater impairment \non verbal fluency, visual perception and performance tasks.” These cognitive \nabnormalities are similar to those descr ibed by a number of authors as being \ndistinctive for Parkinson’s Disease Dementia \n \nThus the same (reportedly) distinctive c linical features may be common to both \ndementia with Lewy bodies and Parkin son’s Disease Dementia, while both \nentities may also have the same neuropathological basis. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 86 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n15.2.3.3 Was the population en rolled in Study 2311 selected appropriately in the \ncontext of the proposed new indication, such that the effects of Exelon® in that \npopulation could be consider ed distinct from those already established as \noccurring in patients with Alzheimer’s Disease? \n The key inclusion criteria used to identify patients as having Parkinson’s \nDisease Dementia were prospectively specified as being as follows \n \n Clinical diagnosis of idiopathic Parkinson’s Disease according to the UK \nParkinson’s Disease Society Brain Bank clinical diagnostic criteria \n Clinical diagnosis of Parkinson’s Di sease Dementia according to DSM-IV \ncriteria (Code 294.1) with onset of symptoms of dementia within at least 2 \nyears of the first diagnosis of idiopathic Parkinson’s Disease \n \nAs noted earlier, there are serious limitations to t he practical application of \nthe DSM-IV criteria for “Dementia due to Parkinson’s Disease.” In addition, \nno evidence has been supplied in this submission that dementia \nassociated with Parkinson’s Disease was diagnosed at study entry based on the features that are stated to distinctive for that condition such as \ndeficits of attention, executive functi on, and memory retrieval (which in any \ncase have never been validated). In fa ct, the criteria used to diagnose \ndementia itself in these patients may have been no different than those \nused for patients enrolled in the key pr e-approval efficacy trials of Exelon® \nin Alzheimer’s Disease. Admittedly, the NINCDS-ADRDA criteria for the \ndiagnosis of probable Alzheimer’s Disease, which were used to enroll patients in the pre-approval efficacy trials of Exelon®, if strictly applied, \nrequired the exclusion of pati ents with Parkinson’s Disease. \n \nIn their essence, the criteria us ed to diagnose dementia associated with \nParkinson’s Disease in Study 2311 consisted of the following \n \n Presence of Parkinson’s Disease \n Presence of dementia syndrome, without that dementia syndrome \nneeding to have any distinctive features specific to Parkinson’s Disease \nDementia \n Evidence of Parkinson’s Disease prior to, but within 2 years of, the onset \nof dementia \n Exclusion of other causes of dementia \n \nWhile the latter criteria do have face validity for diagnosing dementia in \npatients with Parkinson’s Disease, they themselves do not appear to have \nbeen correlated with neuropathological findings in a formal study \n(especially one that was prospective) of sufficient size (the recently-published study by Braak et al [see below] might, however, address that objective to some extent) \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 87 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n• It is noteworthy that the effects or rivastigmine on the primary efficacy \nmeasures in Study 2311 are not very different from those observed for \nrivastigmine, and, indeed other acetyl cholinesterase inhibitors, on the \nsame measures in the key pre-approval efficacy trials of those drugs in \nmild to moderate probable Alzheimer’s Disease: in addition, the clinical \ncourse of the placebo group in Study 2311 and the placebo groups in the \npre-approval efficacy trials of Exel on® in Alzheimer’s Disease were \nsimilar, also suggesting that the study populations in each instance may \nhave been similar too (see below): \n \nThe following were the changes seen in the Exelon® and placebo groups on the \nADAS-Cog in a key pre-approval efficacy trial in Alzheimer’s Disease (the figure is taken from the approved product labeling \n \n \n \nThe following were the corresponding changes seen in Study 2311 \n \n \n \n \nAs noted earlier, in patients with Park inson’s Disease who develop dementia, \nAlzheimer’s-type pathology (neurofib rillary tangles, amyloid plaques) \nfrequently co-exists, albeit often not to a sufficient degree for a separate \npathological diagnosis of Alzheimer’s Dis ease to be made. If a similar mixed \npathology underlay the dem entia in patients enrolled in the Study 2311, it is \npossible (and no evidence to the cont rary has been supplied) that the Ranjit B. Mani, MD, HFD-120 Medical Review Page 88 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \napparent benefit of rivastigmine in that study was mediated through its effects \non co-existing Alzheimer’s-type pathology. It is unlikely that the criteria used \nto diagnose dementia associated with Parkinson’s Disease in Study 2311, \ncould have excluded those with co-exi sting Alzheimer’s-type pathology, \ndespite a stipulation in those criteria that other c auses of dementia should be \nexcluded. \n \nThese observations raise the question of whether the efficacy of rivastigmine \nin dementia associated with Parkinso n’s Disease, as seen in the population \nenrolled in Study 2311, is really distinct from its already-established effects in \nmild to moderate probable Alzheimer’s Dis ease, and for which rivastigmine is \nalready approved. \n \nAs explained further below, the overa ll design of this trial was otherwise \nsimilar in many ways to the now-st andard study design used to demonstrate \nthe efficacy of drugs intended for the tr eatment of Alzheimer’s Disease, again \nraising the question of how distinct the e ffects of Exelon® in this study were \nfrom those already establis hed in Alzheimer’s Disease. \n \nUnless the efficacy of rivastigmine as demonstrated in Study 2311 is judged to be mechanistically dist inct from its established effects in Alzheimer’s \nDisease, the grant of a s eparate claim for the treatm ent of mild to moderate \ndementia associated with Parkinson’s Disease may not be justified. \n \n15.2.3.4 Was the populatio n enrolled in Study 2311 otherwise selected \nappropriately? \n• Among the exclusion criteria for th is study were the following (I have \nemphasized elements of these cr iteria in bold underlined font) \n \n Current diagnosis of any primary neurodegenerative disease other than \nParkinson’s Disease or any other causes of dementia (e.g., Alzheimer’s \nDisease, frontotemporal dementia, Huntington’s Disease, dementia with \nLewy bodies, Parkinson-plus syndromes such as progressive \nsupranuclear palsy or olivopontocerebellar degeneration, Vitamin B12 or folate deficiency, hypothyroidism or syphilis) \n A current diagnosis of probable or possible vascular dementia according \nto the NINDS-AIREN criteria, i.e., clinical and brain imaging evidence of \ncerebrovascular disease and a relationship between dementia and \ncerebrovascular disease (Reviewer’s note: these are criteria for the diagnosis of probable vascular dementia only; the diagnosis of possible vascular dementia does not require the demonstration of a clear relationship between dementia and stroke) \n \n• Special diagnostic laboratory test s that were performed at screening and \nwhich were intended to help exclude other causes of dementia were \nserum TSH, folic acid, Vitamin B12 and RPR. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 89 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n• However, under the protocol for St udy 2311, brain imaging (i.e., \ncomputerized tomography or magne tic resonance scanning) was not \nrequired prior to entr y into the study. Study Case Report Forms do not \ndocument which patients may have had br ain imaging prior to entry into \nthe study, and at the time that this re view was completed, data as to the \nproportion of study patients who had undergone brain imaging had not yet \nbeen made available by the sponsor in response to a request from us. The \nfollowing observations may be pertinent in this context: \n \n The American Academy of Neurology Practice Parameter for Dementia \n(see Knopman et al below) recommends the use of a neuroimaging \nexamination (either a non-contrast CT scan or MRI scan) “under most circumstances” at the time of the initial dementia assessment to identify pathology such as brain neoplasms or subdural hematomas, although it is \nalso stated that a third condition, normal pressure hydrocephalus, which \nmight be detected by CT or MRI is very rare \n \n The UK Parkinson’s Disease Society Brain Bank clinical diagnostic \ncriteria for Parkinson’s Disease list as an exclusion criterion (Step 2) “the presence of cerebral tumor or communicating hydrocephalus on CT \nscan.” [However, it can hardly be considered standard clinical practice for \nbrain imaging to be performed routinely for the diagnosis of Parkinson’s Disease] \n \n In key efficacy trials of drugs in Alzheimer’s Disease, it is standard \npractice to perform either a CT scan of the head or MRI at screening, if \nnot performed within the preceding 12 months \n \n A standard neurological examination directed at detecting focal \nneurological deficits is more difficult to perform in patients with \nParkinson’s Disease, and often considerably more difficult \n \n• The question may therefore be raised as to how adequately patients \nenrolled in Study 2311 were evalua ted for “non-degenerative” causes \nof dementia such as cerebrovascula r lesions, brain tumors, subdural \nhematomas, and communicating hydrocephalus in the absence of \nbrain imaging. Admittedly, tho se conditions are often associated \nwith additional symptoms and si gns on neurological evaluation, but \na standard neurological evaluation can be more difficult than usual to perform in patients with co- existing Parkinson’s Disease so that \nsubtle physical signs may not be detected. \n \n15.2.3.5 Was the overall design of Study 2311 appropriate and were the primary \nefficacy measures used suitable for evaluating the efficacy and safety of \nrivastigmine in mild to moderate dementia associated with Parkinson’s Disease? \n• The paradigm used for designing this st udy is very similar to that used in \nstandard efficacy trials in Alzheimer’s Disease. More specifically: Ranjit B. Mani, MD, HFD-120 Medical Review Page 90 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n \n This was a randomized, double-blind, placebo-controlled, parallel-arm \ntrial of 6 months’ duration \n The stipulated entry Mini-Mental Status Examination score range was \nconsistent with that used to define the “mild to moderate” range for \nAlzheimer’s Disease \n For the study to be considered to have demonstrated the efficacy of \nExelon® in treating mild to moderate Parkinson’s Disease Dementia, it was required that a statistically significant superiority of Exelon® be demonstrated on both cognitive and global primary efficacy measures \n The cognitive and global primary effica cy measures used in this study, \nthe ADAS-Cog and ADCS-CGIC were identical to those used in the efficacy studies in Alzheimer’s Disease \n \n• Whether this design is an appropriate one for trials in Parkinson’s Disease \nDementia is a matter for further di scussion. Assuming that the condition \nitself is a distinct ent ity justifying a separate claim, the following might \nneed consideration in dec iding whether the desi gn for that study was \nappropriate for the proposed indication: \n \n The natural clinical course of Parkinson’s Disease Dementia, for which \ninformation is lacking \n The nature of the cognitive deficits seen in that entity \n Whether the outcome measures, and especially, the ADAS-Cog were \nappropriate to use in Parkinson’s Disease Dementia. The ADAS-Cog is not, for example, particularly appropriate for evaluating executive function (also note that the just-issued American Academy of Neurology Practice Parameter [see Miyasaki et al, below] also states that in patients with \nParkinson’s Disease, it may be difficult to assess impairments in domains \nother than memory). \n \n• The results of non-interventional study (Study 2314) that was intended to \nvalidate several assessment scale s used in Study 2311 have been \ninterpreted by the sponsor to demonstrate the following: \n \n That the ADAS-Cog score can differentiate between dementia associated \nwith Parkinson’s Disease of mild and moderate severities, as can the scores several of the secondary efficacy assessment instruments used in this study \n That the ADAS-Cog and several secondary efficacy measures had test-\nretest reliability in this population \n That the ADAS-Cog scores correlated with those of several other efficacy \ninstruments, whether those measures assessed cognition or other domains \n A factor analysis that compared populations with Parkinson’s Disease \nDementia and Alzheimer’s Disease on ADAS-Cog sub-item scores had indicated that the sub-items grouped differently in each population, suggesting that the cognitive and behavioral profiles in these populations might differ \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 91 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n• This study does not address whether the efficacy measures used in Study \n2311, and especially the ADAS-Cog, had “c ontent” validity; i.e., did the \ncomponents of the ADAS-Cog evaluat e the main cognitive domains \nbelieved to be impaired in that conditi on. It is currently unclear as to \nwhether it is currently possible for a conclusion to be reached that the \nADAS-Cog has content validity in this population. The factor analysis \nreferred to above suggest ed that the cognitive profiles in Alzheimer’s \nDisease and Parkinson’s Disease differ. \n \n15.2.3.6 Could the apparent beneficial effects of Exelon® on cognition and/or \nglobal function in Study 2311 have been due to a beneficial effect on the motor \nmanifestations of Parkinson’s Disease rather than on the dementia itself? \nIf there was a beneficial effect of Exelon® on specific motor manifestations of \nParkinson’s Disease such as bradykinesia or dysarthria, it is possible that such a \nbenefit may have been reflected in a benef icial effect on the ADAS-Cog and/or \nADCS-CGIC, in the absence of a tr ue effect on the dementia itself \n \nSuch a possibility is unlikel y for the following reasons \n \n There was no overall difference between treatment groups in the mean change \nfrom baseline to endpoint in total UPDRS motor scores. Notable differences \nbetween treatment groups were not seen for important individual UPDRS item \nscores \n Adverse events that might be considered to represent a worsening in the motor \nmanifestations of Parkinson’s Disease were, in aggregate, more common in \nthose assigned to Exelon® than in those assigned to placebo \n \n[Also note that the study procedures included a number of precautions to \nminimize the effects of the motor manifestations of Parkinson’s Disease on the \nefficacy assessments]. \n \n15.2.3.7 Do the results of Study 2311 wa rrant replication for a claim for the \ntreatment of dementia associated wit h Parkinson’s Disease to be granted? \nAll drugs approved by this Agency so fa r for the treatment of dementia of the \nAlzheimer’s type (Alzheimer’s Disease) have been approved based on the demonstration of the desired treatment effect in at least 2 adequate and well-\ncontrolled trials; the same has applied to the approval of drugs for other discrete \nclinical entities. This Division’s view so far is that the same principle must apply \nto other types of dementia, unless they are variants or grades of severity of \nAlzheimer’s Disease not subsum ed under the current claim. \n \nTherefore, if dementia asso ciated with Parkinson’s Disease is indeed a form of \ndementia that is distinct from Alzheimer’ s Disease, it would be appropriate to \nrequire that the results of Study 2311 be replicated. \n Ranjit B. Mani, MD, HFD-120 Medical Review Page 92 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \n15.2.3.8 References \nThe references, based upon which a num ber of the above comments have been \nmade are listed \n \nBraak H, Rub U, Jansen Steur EN, Del Tredici K, de Vos RA . Cognitive status correlates with neuropathologic stage in \nParkinson disease. Neurology 2005;64:1404-10 \n \nAarsland D , Perry R , Brown A , Larsen JP , Ballard C . Neuropathology of dementia in Parkinson's disease: a \nprospective, community-based study. Ann Neurol 2005;58:663-5. \n \nEmre M . Dementia associated with Parkinson’ s disease. Lancet Neurol 2003;2:229-37 \n \nAarsland D , Litvan I , Salmon D , Galasko D , Wentzel-Larsen T , Larsen JP . Performance on the dementia rating scale \nin Parkinson's disease with dementia and dementia with Lew y bodies: comparison with progressive supranuclear palsy \nand Alzheimer's disease. J Neurol Neurosurg Psychiatry 2003;74:1215-20 \n \nMcKeith IG, Dickson DW, et al . Diagnosis and management of dementia with Lewy bodies: third report of the DLB \nConsortium. Neurology 2005;65:1863-72 \n \nMcKeith I, Mintzer J, Aarsland D, Burn D , Chiu H , Cohen-Mansfield J , Dickson D , Dubois B , Duda JE , Feldman H , \nGauthier S , Halliday G , Lawlor B , Lippa C , Lopez OL , Carlos Machado J , O'Brien J , Playfer J , Reid W ; International \nPsychogeriatric Association Expert Meeting on DLB . Dementia with Lewy bodies. Lancet Neurol 2004; 3:19-28 \n \nMiyasaki JM , Shannon K , Voon V , Ravina B , Kleiner-Fisman G , Anderson K , Shulman LM , Gronseth G , Weiner \nWJ; Quality Standards Subcommittee of the American Academy of Neurology . Practice Parameter: evaluation and \ntreatment of depression, psychosis, and dementia in Parkinson disease (an evidence-based revi ew): report of the Quality \nStandards Subcommittee of the American Academ y of Neurology. Neurology 2006;66:996-1002 \n \nKnopman DS , DeKosky ST , Cummings JL , Chui H , Corey-Bloom J , Relkin N , Small GW , Miller B , Stevens JC . \nPractice parameter: diagnosis of dementia (an evidence-based review). Report of the Quality Standards Subcommittee of \nthe American Academy of Neurology. Neurology 2001; 56:1143-53 [Guideline reaffirmed: February 13, 2004] \n \n15.3 Safety \nEvidence for the safety of Exelon® in dementia associated with Parkinson’s \nDisease is derived from 2 sources \n \n15.3.1 Study 2311 \nThis study has already been summarized abov e. Salient safety findings for this \nstudy were as follows. \n \n The incidence of nausea, vomiting, and tremor was appreciably higher in the \nrivastigmine group than in the placebo group; a similar adverse event profile was \nseen in the key controlled clinical tria ls of Exelon® in Alzheimer’s Disease \n Several treatment-emergent adverse events that may have represented a \nworsening in the motor manifestations of Parkinson’s Disease, tremor in \nparticular, were more frequent in those treated with Exelon® than in those \ntreated with placebo. However, changes in UPDRS total motor scores, probably a more objective measure of change in the motor manifestations of Parkinson’s Disease than the incidence of treatment-emergent adverse events, showed no meaningful difference between treatment groups. \n \n15.3.2 Study 2311E1 \nThis was an 24-week open-label uncontrolle d extension to Study 2311 intended \nprimarily to evaluate the safety and tolerability of Exelon® in the study Ranjit B. Mani, MD, HFD-120 Medical Review Page 93 of 93 \nNDA 20823 (SE1-016), Exelon® (rivastigmine tartrate) , Novartis 4/18/06 \npopulation. Patients given the option of enrolling in this study had either \ncompleted the double-blind treatment phas e of Study 2311 or discontinued early \nduring that study, but returned for all the remaining scheduled efficacy \nassessments without significant protocol vi olations. Regardless of their previous \ntreatment assignment, patients enrolled in th e extension study were all re-titrated \nto a flexible dose of Exelon® that ranged from 1.5 mg BID to 6.0 mg BID, based \non tolerability. \n \n433 patients enrolled in Study 2311 were eligible to enroll in Study 2311E1 of \nwhom 334 actually consented to parti cipate and 273 completed the study. The \nadverse event profile of Exelon® in St udy 2311 was broadly similar to that seen \nin Study 2311E1 \n \n16. Conclusions \nDeferred, pending discussion of this appl ication at a scheduled meeting of the \nPeripheral and Central Nervous Systems Drugs Advisory Committee \n \n17. Recommendation \nDeferred, pending discussion of this appl ication at a scheduled meeting of the \nPeripheral and Central Nervous Systems Drugs Advisory Committee \n \n Ranjit B. Mani, M.D. \n Medical Reviewer \n \n \n \nrbm 4/18/06 \ncc: \nHFD-120 \nNDA 20823 (SE1-016)\n \n \n "
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"pdf_file": "J5ZSV4CEZDUKODXRBOAVGJVB5XTR5QMA.pdf",
"text": "ENewsletter\nComing Soon!\r\nThe Online Office of Congressman Danny K. Davis\nhttp://www.davis.house.gov Powered by Joomla! Generated: 29 January, 2009, 21:18"
} |
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"text": " \n \n \n \n \nPUBLIC DISCLOSURE \n \n \nJUNE 23, 2004 \n \n \nCOMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION \n \n \nBARRE SAVINGS BANK \n90148 \n \n56 COMMON STREET \nBARRE, MASSACHUSETTS 01005 \n \nDIVISION OF BANKS \nONE SOUTH STATION \nBOSTON, MASSACHUSETTS 02110 \n \n \nNOTE: This evaluation is not, nor should it be construed as, an assessment of the financial \ncondition of this institution. The rating assigned to this institution does not represent \nan analysis, conclusion or opinion of the Division of Banks concerning the safety \nand soundness of this financial institution. \n \n \nGENERAL INFORMATION \n \nThe Community Reinvestment Act (“CRA”) requires the Massachusetts Division of Banks (the \n“Division”) to use its authority when examining financial institutions subject to its supervision, to \nassess the institution's record of meeting the needs of its entire assessment area, including low and \nmoderate-income neighborhoods, consistent with safe and sound operation of the institution. Upon \nconclusion of such examination, the Division must prepare a written evaluation of the institution's \nrecord of meeting the credit needs of its community. \n \nThis document is an evaluation of the CRA performance of BARRE SAVINGS BANK, prepared by \nthe Division, the institution's supervisory agency, as of JUNE 23, 2004 . The Division evaluates \nperformance in the assessment area(s), as they are defined by the institution, rather than individual \nbranches. This assessment area evaluation may include the visits to some, but not necessarily all \nof the institution’s branches. The Division rates the CRA performance of an institution consistent \nwith the provisions set forth in 209 CMR 46.00. \n \nINSTITUTION'S CRA RATING: This institution is rated \"Satisfactory \" \n \nThe Bank’s overall CRA rating is based upon its performance under the five criteria contained \nherein. The following is a summarization of the findings, presented in descending order of weight \ngiven to each criteria, that were utilized in formulating the bank’s overall CRA rating: \n \nDistribution of Credit among Different Income Levels \n \nThere was a substantial distribution of HMDA-reportable lending to individuals of low- and \nmoderate-income, given the demographics of the Bank’s assessment area. \n \nComparison of Credit Extended Inside And Outside of the Assessment Area(s) \n \nA majority of the Bank’s HMDA-reportable lending was originated inside its assessment area. \n \nLoan to Deposit Analy sis \n \nThe Bank was determined to have a reasonable level of net loan to deposit ratios over the eight \nquarter period reviewed. \n \nGeographic Distribution of Loans \n \nThe Bank made a strong penetration of HMDA-reportable lending to the middle-income c ensus \ntracts in its assessment area. There are no low- or moderate-income census tracts within the \nBank’s assessment area. \n \nReview of Complaints/Fair Lending Policies and Practices \n \nThe Bank’s fair lending policies and practices are considered reasonable. No weight was given to a \nreview of complaints, as none have been received since the prior examination. \n \n \n 1 DESCRIPTION OF INSTITUTION \n \nBarre Savings Bank is a mutual savings bank, incorporated under the laws of the Commonwealth of \nMassachusetts in 1869. \n \nAs of March 31, 2004, the Bank had $126,465,000 in total assets. Of these total assets, \n$83,458,000, or 66.0 percent, were in the form of loans (net). The following table depicts the \nBank’s loan portfolio composition, based on its March 2004 Federal Deposit Insurance \nCorporation (“FDIC”) Quarterly Call Report. \n \nBarre Sav ings Bank Loan Portfolio as of March 31, 2004 \nType of Loans % of Total \nLoans \nConstruction & Land Development 3.1 \nSecured by Farmland 0.8 \nResidential Real Estate \n a. 1-4 Family Mortgages 78.7 \n b. Home Equity Lines (includes second mortgages) 8.7 \nMultifamily 1.7 \nCommercial Loans \n a. Commerc ial Real Es tate 4.4 \n b. Commercial & Industrial Loans 0.6 \nConsumer Loans \n a. Credit Cards & Related Plans \n b. Loans to Individuals/Other Loans 2.0 \nTotal Loans 100.0 \n Source: F DIC Call Report, 03/31/04 \n \nAs indicated, overall residential real estate lending represents the majority of the Bank’s portfolio, at \n87.4 percent. The second largest segment of the loan portfolio is overall commercial lending at 5.0 \npercent. \n \nThe Bank operates three branch office locations: its main office located on Common Street in Barre, \na branch office in Paxton, and an office in Princeton. \n \nThere appears to be no legal or regulatory impediments that would affect the Bank in meeting \nthe needs of its community. The FDIC conduct ed the previous CRA evaluation on February 3, \n2003. That examination resulted in a “Satisfactory” rating. The Division conducted its previous \nCRA evaluation as of January 11, 1999. That examination resulted in a “High Satisfactory” \nrating. \n \n \n \n \n 2 Description of Assessment Area \n \nThe following table reflects the Bank’s assessment area by Metropolitan Statistical Area (“MSA”) \nand by county. Also included in the table are the Department of Housing and Urban Development’s \n(“HUD”) estimated Median Family Incomes (2002 and 2003) for the respective MSA. \n \nAssessment Area by Metropolitan Statistical Area (MSA) \nWorcester Massachusetts Non \nCounties \nWorcester Worcester \nCom munities \nPrinceton, Rutland, Oakham, Barre, Paxton, and \nHolden Phillipston, Petersham, Hubbardston, Hardwick, and \nNew Braintree \nMedian Family Incomes ($) \n2002 2003 2002 2003 \n58,400 68,000 52,100 60,300 \nSource: PCI Services, Inc., CRA Wiz Softw are.\n \n \nDemographic and Economic Data \n \nChange in Demographics \n \nIn 2003, the US Census Bureau released its revised demographics based upon 2000 census data. \nHowever, the number of census tracts and income groupings of the tracts in the Bank’s assessment \narea did not change. \n \nThe following table reflects selected housing characteristics, based upon 1990 census data, for \neach of the census tract income groupings in the Bank’s assessment area. \n \nSelected Housing Characteristics by Income Category of the Geography Based on 1990 Census Data \nPercentage Geographic \nIncome \nCategory Census \nTracts Households Housing \nUnits Owner-\nOccupied Rental \nUnits Vacant \nUnits Median \nHome Value \n($) \nMiddle 36.4 40.4 42.3 38.0 55.6 66.4 127,027 \nUpper 63.6 59.6 57.7 62.0 44.4 33.6 164,287 \nTotal or \nMedian 100.0 100.0 100.0 100.0 100.0 100.0 148,517 \nSource: U.S. Census \n \nIn addition, the following table reflects selected housing characteristics, based upon 2000 census \ndata, for each of the census tract income groupings in the Bank’s assessment area. \n \nSelected Housing Characteristics by Income Category of the Geography Based on 2000 Census Data \nPercentage Geographic \nIncome \nCategory Census \nTracts Households Housing \nUnits Owner-\nOccupied Rental \nUnits Vacant \nUnits Median \nHome Value \n($) \nMiddle 36.4 42.2 43.6 39.3 60.2 70.6 137,764 \nUpper 63.6 57.8 56.4 60.7 39.8 29.4 170,522 \nTotal or \nMedian 100.0 100.0 100.0 100.0 100.0 100.0 156,252 \nSource: U.S. Census \n 3 Description of Aggregate Data Utilized/Lending Activity \n \nAggregate data, for residential mortgage lending performance purposes only, constitutes 270 \n(both large and small) mortgage companies, savings banks, commercial banks, cooperative \nbanks, and credit unions, which have originated and/or purchased at least one residential \nmortgage and/or home improvement loan within the Bank’s assessment area (source: PCI \nServices, Inc., CRA Wiz). The total number of originations/purchases received by these lenders \nin calendar year 2002 was 4,856. The following table reflects the top five lenders (in \ndescending order) within the Bank’s assessment area in 2002: \n \nLending Activ ity in Barre Sav ings Bank’s Assessment Area \nRank Lenders Number of Loans Market Share \nPercentage \n1 Fleet National Bank 338 7.0 \n2 Washington Mutual Bank, FA 314 6.5 \n3 Countrywide Home Loans 260 5.4 \n4 Wells Fargo Home Mortgage 216 4.5 \n5 Ohio Savings Bank 194 4.0 \nSource: PCI Services, Inc., CRA Wiz Softw are.\n \nBarre Savings Bank ranked 11th with 113 loans and a 2.3 percent market share. \n \n \n \n \n \n \n \n \n \n \n \n \n 4 PERFORMANCE CRITERIA \n \n1. LOAN TO DEPOSIT ANALYSIS \n \nBased upon the following, the Bank’s net loan to deposit ratio appears to be reasonable and, as \nsuch, was determined to meet the standards for satisfactory performance. \n \nAn analysis of the Bank’s net loan to deposit ratios was performed. The calculation incorporated \neight quarters of the Bank’s net loan to deposit figures, as reflected in its quarterly FDIC Call \nReports. The quarters reviewed included the periods from June 2002 through March 2004. The \nBank’s net loan to deposit ratio, on average, was 74.4 percent. This ratio has fluctuated from a low \nof 69.2 percent in December 2002, to a high of 78.4 percent in September 2003. \n \nThe following illustrates Barre Savings Bank’s net loan to deposit trends. \n \nBarre Sav ings Bank’s Loan to Deposit Ratios* \nDates Ratio (%) \nJune 30, 2002 70.4 \nSeptember 30, 2002 70.8 \nDecember 31, 20002 69.2 \nMarch 31, 2003 73.5 \nJune 30, 2003 77.8 \nSeptember 30, 2003 78.4 \nDecember 31, 2003 77.5 \nMarch 31, 2004 77.2 \n* Source: FDIC Call Reports. \n \nOver the period reflected in the table, the Bank’s net loan portfolio increased by 14.0 percent, \nwhile deposits grew by 4.0 percent. From March 31, 2003 through March 31, 2004, the Bank’s \nloan portfolio increased by 5.7 percent, while deposits grew by 0.6 percent. \n \nThe Bank retains the majority of its originated mortgage loans for its own loan portfolio. \nHowever, since 2002, the Bank has sold some of its fixed rate 30-year mortgages to Federal \nNational Mortgage Association (FNMA/FannieMae). Since that time, the Bank sold 25 fixed rate \nmortgages, totaling $3.3 million. \n \nA comparison of the Bank’s loan to deposit ratio to that of a representative selection of area \nfinancial institutions was also performed. As of March 31, 2004, the Bank had total assets of \n$126,465,000 and a net loan to deposit ratio of 77.2 percent. The following table reflects the \ntotal assets and loan to deposit ratios of the Bank’s closest competitors: \n \nCOMPARATIVE NET LOAN TO TOTAL DEPOSIT RATIOS* \nInstitution Total Assets \n$(000) Net Loan to Total Deposit Ratios \n(%) \nAthol Savings Bank 255,288 77.7 \nBarre Savings Bank 126,465 77.2 \nCountry Bank For Savings 982,593 79.6 \nWare Co-operative Bank 61,185 77.8 \n*As of March 31, 2004. \n \nBased on the aforementioned analysis, the Bank has achieved a reasonable loan to deposit level \ngiven its capacity to lend and the credit needs of its assessment area. \n \n 5 2. COMPARISON OF CREDIT EXTENDED INSIDE AND OUTSIDE OF THE ASSESSMENT \nAREA (S) \n \nBased upon the following data, the Bank’s penetration of its HMDA-reportable lending within its \nassessment area is considered to be reasonable. Consequently, this pattern of lending was \ndetermined to meet the standards for satisfactory performance. \n \nResidential Mortgage Lending \n \nAn analysis of Home Mortgage Disclosure Act (“HMDA”) reportable lending extended both inside \nand outside the Bank’s assessment area for the period under review was performed. For the \npurposes herein, the period under review for HMDA-reportable lending was calendar years 2002 \nand 2003. A HMDA-reportable loan is defined as home purchase loans (including originations, \npurchases, and refinances) as well as home improvement loans. \n \nThe following table illustrates the Bank’s level of HMDA-reportable lending both inside and outside \nits assessment area. \n \nDistribution of Home Mortgage Loans Inside and Outside of the Assessment Area \nInside Outside Total \nNum ber of \nLoans Dollar Volume \n(000) Num ber of \nLoans Dollar Volume \n(000) Num ber of \nLoans Dollar Volume \n(000) Year \n# % $ % # % $ % # % $ % \n2002 113 67.3 13,615 65.1 55 32.7 7,314 34.9 168 100.0 20,929 100.0 \n2003 199 71.3 25,878 68.9 80 28.7 11,665 31.1 279 100.0 37,543 100.0 \nTotal 312 69.8 39,493 67.5 135 30.2 18,979 32.5 447 100.0 58,472 100.0 \nSource: HMDA LAR, CRA Wiz \n \nAs indicated, the Bank granted a majority of the number and dollar volume of its HMDA-reportable \nlending to those communities within its assessment area. \n \nThe Town of Barre accounted for the most HMDA-reportable lending. For calendar year 2002, the \nBank granted 43 loans (25.6 percent) for $4,325,000 (20.7 percent) in Barre. For calendar year \n2003, the Bank granted 66 loans (23.7 percent) for $7,532,000 (20.1 percent) in Barre. \n \nTherefore, given the size and the resources available to the Bank, the level of HMDA reportable \nlending within its assessment area is considered reasonable. \n \n \n 6 3. DISTRIBUTION OF CREDIT AMONG DIFFERENT INCOME LEVELS \n \nBased upon the subsequent analysis, the Bank’s distribution of its HMDA-reportable lending within \nits assessment area to borrowers of different incomes i s considered to be substantial. Therefore, \nthe Bank was determined to exceed the standards for satisfactory performance in this criterion. \n \nAn analysis of HMDA-reportable lending extended within the Bank’s assessment area, among \nvarious income levels for the period under review, was performed. Originations were categorized \nby the ratio of the applicants’ reported incomes to the 2002 and 2003 estimated median family \nincomes of the appropriate MSA (refer to the Performance Context Section). \n \nLow-income is defined by the US Census Bureau as income below 50 percent of the median family \nincome level for the MSA; moderate-income is defined as 50 to 79 percent of the median family \nincome; middle-income is defined as income between 80 and 119 percent of the median family \nincome; and upper-income is defined as income greater than 120 percent of the median family \nincome. \n \nThe following analysis also includes 2002 aggregate data (exclusive of Barre Savings Bank) of \nHMDA-reportable lending by percentage, as well as demographic data on the percentage of \nhouseholds (per 1990 and 2000 census data) in the assessment area in each respective \nincome group. \n \nRefer to the following. \n \nDistribution of Home Mortgage Loans by Borrow er Income \n2002 Bank \nData 2003 Bank Data Total Median \nFamily \nIncome \nLevel % Total \nFamily \nHouseholds \nPer 1990 \nCensus \nData 2002 \nAggregate \nLending \nData \n(% of #) \n # % % Total \nFamily \nHouseholds \nPer 2000 \nCensus \nData # % # % \nLow Ø 19.0 1.8 3 2.7 17.6 10 5.0 13 4.2 \nModerate 17.9 10.2 22 19.5 19.8 33 16.6 55 17.6 \nMiddle 26.3 24.9 33 29.2 23.6 70 35.2 103 33.0 \nUpper 36.8 49.2 51 45.1 39.0 84 42.2 135 43.3 \nNA 0.0 13.9 4 3.5 0.0 2 1.0 6 1.9 \nTotal 100.0 100.0 113 100.0 100.0 199 100.0 312 100.0 \nSource: HMDA LAR, CRA Wiz \n \nØ Included in the low-income category (per the 1990 census data) are 266 households within the assessment \narea whose income is considered to be below poverty level, and thus, unlikely to qualify for a residential \nmortgage loan. \n \nIncluded in the low-income category (per the 2000 census data) are 262 households within the assessment \narea whose income is considered to be below poverty level, and thus, unlikely to qualify for a residential \nmortgage loan. \n \nIt should be noted that those originations designated as not applicable (NA) loans are either: \n The borrowers’ income was not taken into account when granting the loan; \n The borrower is an employee; or \n The loan was purchased. \n 7 DISTRIBUTION OF CREDIT AMONG DIFFERENT INCOME LEVELS (continued) \n \nAs indicated in the table, the Bank’s percentage of lending to low- and moderate-income borrowers \nis significantly above that of the aggregate in 2002. For calendar year 2003, the percentage of \nlending in the low-income category has increased, while the percentage of lending in the moderate-\nincome category declined somewhat. \n \nBy dollar volume in 2002, the Bank originated 1.3 percent of its HMDA-reportable lending to low-\nincome borrowers, exceeding the 2002 aggregate data by dollar volume of 0.9 percent to low-\nincome borrowers. Lending by dollar volume to moderate-income borrowers was 14.0 percent, \nwhile aggregate lending was 7.5 percent to those borrowers in 2002. \n \nFor calendar year 2003, the Bank’s HMDA-reportable lending by dollar volume was 2.5 percent to \nlow-income borrowers and 13.0 percent to moderate-income borrowers. Also of particular note is \nthe marked increase in the dollar volume of loans granted in these two income categories. \n \nTherefore, over the period reviewed the Bank’s level of HMDA-reportable lending to borrowers of \nlow- and moderate-income is considered to be significant. \n \n \n 8 4. GEOGRAPHIC DISTRIBUTION OF LOANS \n \nThe following analysis indicates that the Bank appears to have achieved a reasonable penetration \nof its HMDA-reportable lending to the census tracts within its assessment area. Therefore, the \nBank was determined to meet the standards for satisfactory performance at this time. \n \nBased upon both 1990 and 2000 census data, the Bank’s assessment area contained eleven \ncensus tracts. Of those tracts, four (36.4 percent) are middle-income, and seven (63.6 percent) \nare upper-income. There are no low- or moderate-income census tracts within the Bank’s \nassessment area. \n \nFurther, an analysis of the Bank’s HMDA-reportable lending extended within the various census \ntracts contained within its assessment area for calendar year 2003 was also conducted. It should \nbe noted that, as of January 1, 2003, a revision to Regulation C (HMDA reporting) went into effect. \nThis revision states in part…”For all applications and loans reported on lenders’ 2003 HMDA/LARs, \nlenders must use the census tract numbers and corresponding geographic areas from the 2000 \ncensus.” \n \nAn analysis of HMDA-reportable lending extended within the various census tracts contained within \nthe Bank’s assessment area was also conducted. The following table presents the Bank’s \nperformance, as well as the 2002 aggregate data (exclusive of Barre Savings Bank) of HMDA-\nreportable lending by percentage. In addition, th e table also reflects the percentage of owner-\noccupied housing units (per 1990 and 2000 census data) in each of the census tract income \ncategories. \n \nDistribution of Home Mortgage Loans by Income Category of the Census Tract \n2002 Bank \nData 2003 Bank Data Total Census \nTracts % Total \nOwner-\nOccupied \nHousing \nUnits Per \n1990 \nCensus \nData 2002 \nAggregate \nLending \nData \n(% of #) \n # % % Total \nOwner-\nOccupied \nHousing \nUnits Per \n2000 \nCensus \nData # % # % \nMiddle 38.0 35.6 69 61.1 39.4 120 60.3 189 60.6 \nUpper 62.0 64.4 44 38.9 60.6 79 39.7 123 39.4 \nTotal 100.0 100.0 113 100.0 100.0 199 100.0 312 100.0 \nSource: HMDA LAR, CRA Wiz \n \nOf particular note is the Bank’s lending to the middle-income census tracts within its assessment \narea in both 2002 and 2003. For that period, the percentage of the Bank’s HMDA-reportable \nlending was consistently and significantly above both the aggregate and the demographic data. \n \nBy dollar volume in 2002, the Bank originated 55.8 percent of its HMDA-reportable lending to the \nmiddle-income tracts. This was also well above the 2002 aggregate data by dollar volume of 32.4 \npercent to those tracts. In 2003, the Bank had 57.4 percent of the dollar volume of its HMDA-\nreportable lending going to the middle-income census tracts. \n \nIn conclusion, although lacking low- and moderate-income census tracts within its assessment \narea, the Bank’s penetration of its middle-income census tracts within its assessment area is \nconsidered to be very strong. \n \n \n 9 5. REVIEW OF COMPLAINTS/FAIR LENDING POLICIES AND PRACTICES \n \nThe Bank received no CRA related complaints in the period under review. The Bank has a \nsatisfactory record of implementing fair lending policies and practices. The following discussion \nis based on the guidelines of the Division’s Regulatory Bulletin 2-3-101. The institution’s loan \npolicy prohibits discrimination against all the prohibited classes listed under the Equal Credit \nOpportunity Act and the Fair Housing Act. In the area of fair lending, the Bank’s compliance \npolicy addresses second review and employee training. \n \nAs a portfolio mortgage lender, the Bank offers 1-year (1/1), 3-year (3/3), 5-year (5/5), and 5/1 \nAdjustable Rate Mortgage (ARM) products. In addition, the Bank offers 15-, 20-, and 30-year \nfixed rate mortgage loans. The maximum loan to value (LTV) for mortgage products is 95 \npercent, with private mortgage insurance required for LTV’s over 80 percent. All mortgage loan \napplications are underwritten to FNMA standards. \n \nThe Bank’s first time homebuyer product consists of a discounted 5/1 ARM with a 95 percent \nloan to value (LTV), and expanded qualifying ratios. In the twelve months prior to this \nevaluation, the Bank originated 3 first time homebuyer 5/1 ARMs for a total of $403,000. In \naddition, the Bank promoted its mortgage products in November 2002, and again in March and \nApril of 2003, by offering a reduced closing cost option via a special $500 off coupon. The \ncoupons appeared in the Bank’s newspaper advertisements and on the Bank’s website. \n \nThe Bank offers both Home Equity Loans and Home Equity Lines of Credit (HELOC). Home \nEquity Loans have a fixed interest rate, a maximum term of 15 years and an 80 percent LTV. \nHELOCs have a variable rate (tied to the Prime Rate), a 10-year draw period (with a 15-year \nrepayment term) and maximum LTV of 80 percent. Currently on HELOCs, the Bank offers two \ndiscounted interest rate options; the first is a 2.99% (for the first six months) and the second a \n0% interest rate (for the first 2 months). \n \nThe Bank continues to offer consumer loan products offerings including new and used \nautomobile loans, unsecured personal loans, overdraft protection lines of credit, passbook \nloans, and other types of secured personal loans. Applications for Home Equity Loans and \nHELOCs, car loans, and overdraft protection are offered via the Bank’s website, \nwww.barrebank.com. \n \nThe Bank utilizes two local weekly publications, The Landmark , published in Holden, and The \nBarre Gazette , published in Barre, to advertise both its banking services and credit products. \nBoth these publications are circulated in the towns within the Bank’s assessment area. In \naddition, the Bank periodically advertises its loan products in the Worcester Telegram and \nGazette , which is circulated throughout all of Worcester County. In March of 2004, the Bank \nparticipated as an exhibitor in the Worcester County Home Show, held at the Worcester \nCentrum. \n \nIt is the Bank’s policy to provide all staff members with ongoing training opportunities in order to \nkeep staff informed of changes in banking regulations and to enhance job knowledge and skills. \nThe Bank’s lending staff recently attended seminars on the changes to the Home Mortgage \nDisclosure Act and teleconference (and internet based) training on FNMA’s Desktop \nUnderwriter program. \n \nThere is a second review committee comprised of three members of senior management. The \ncommittee reviews all denied loan applications, including mortgage, equity, and consumer loan \nrequests. \n 10 Minority Application Flow \n \nFor the period reviewed, the Bank received a total of two residential mortgage applications and \noriginations from various minority groups, representing 0.6 percent of all applications received \nfrom within its assessment area. The 2002 aggregate data indicated 3.4 percent of all the \nresidential applications from within the assessment area were to minority applicants. \n \nIn addition, the following table reflects the minority demographics of the Bank’s assessment area \nbased upon both the 1990 and the 2000 census data. \n \nRefer to the following. \n \nDistribution of Home Mortgage Loan Applications by Race \n2002 Bank \nData 2003 Bank \nData Total Race Racial \nDemographics \nPer 1990 \nCensus Data 2002 \nAggregate \nLending \nData \n(% of #) \n # % Racial \nDemographics \nPer 2000 \nCensus Data # % # % \nNativ e \nAmerican 0.1 0.2 0 0.0 0.1 0 0.0 0 0.0 \nAsian 0.7 0.5 0 0.0 0.7 1 0.4 1 0.3 \nBlack 0.5 0.4 0 0.0 0.5 1 0.4 1 0.3 \nHispanic 0.8 0.3 0 0.0 1.1 0 0.0 0 0.0 \nJoint Race 0.0 1.0 0 0.0 0.0 0 0.0 0 0.0 \nOther 0.0 1.0 0 0.0 0.8 0 0.0 0 0.0 \nTotal \nMinority 2.1 3.4 0 0.0 3.2 2 0.8 2 0.6 \nWhite 97.9 62.2 130 100.0 96.8 221 98.8 351 99.1 \nNA 0.0 34.4 0 0.0 0.0 1 0.4 1 0.3 \nTotal 100.0 100.0 130 100.0 100.0 224 100.0 354 100.0 \nSource: HMDA LAR, CRA Wiz \n \nGiven the almost non-existent minority population within its assessment area, the Bank’s level \nof minority applications is considered reasonable. \n \n \n \n \n \n \n \n 11 \nTHE COMMONWEALTH OF MASSACHUSETTS \n \n \nTo the COMMISSIONER OF BANKS: \n \n THIS IS TO CERTIFY, that the report of examination of the \n \n BARRE SAVINGS BANK \n \nfor compliance with applicable consumer and fair lending rules and regulations and the Community \nReinvestment Act (CRA), as of the close of business JUNE 23, 2004 , has been read to or by the \nundersigned and the matters referred to therein will have our immediate attention. \n \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n ______________________________ ______________________________ \n \n \n A majority of the Board of Directors/Trustees \n \n Dated at _________________ this ____________ day of __________ 20 ____ \n \n \n PERFORMANCE EVALUATION DISCLOSURE GUIDE \n \n Massachusetts General Laws Chapter 167, Section 14, as amended, and the Uniform \nInteragency Community Reinvestment Act (CRA ) Guidelines for Disclosure of Written \nEvaluations require all financial institutions to take the following actions within 30 business \ndays of receipt of the CRA evaluation of their institution: \n \n 1) Make its most current CRA performance evaluation available to the public; \n \n 2) At a minimum, place the evaluation in the institution's CRA public file located at the \nhead office and at a designated office in each assessment area; \n \n 3) Add the following language to the institution's required CRA public notice that is \nposted in each depository facility: \n \n \"You may obtain the public section of our most recent CRA Performance Evaluation, \nwhich was prepared by the Massachusetts Division of Banks, at ( Address at main \noffice ).\" \n \n [Please Note: If the institution has more than one local community, each office (other \nthan off-premises electronic deposit facilities) in that community shall also include the \naddress of the designated office for that assessment area.] \n \n 4) Provide a copy of its current evaluation to the public, upon request. In connection \nwith this, the institution is authorized to charge a fee which does not exceed the cost \nof reproduction and mailing (if applicable). \n \n \n The format and content of the institution's evaluation, as prepared by its supervisory \nagency, may not be altered or abridged in any manner. The institution is encouraged to \ninclude its response to the evaluation in its CRA public file. \n \n \n \n \n \n \n "
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"text": "Train -the-Trainer Participant Guide \n \n \n \nMoney Smart \nfor Small \nBusiness \n \nFinancial \nEducational Cur riculum \nPublished: 09 -2016 MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 2 of 92 Table of Contents \nINTRODUCTION .........................................................................................................................................................4 \nABOUT THIS PARTICIPA NT GUIDE ...............................................................................................................................4 \nMSSB: TRAIN -THE-TRAINER LEARNING OBJ ECTIVES .....................................................................................................4 \nMSSB: WHAT IT IS ......................................................................................................................................................5 \nMSSB: WHY IT WAS CRE ATED .....................................................................................................................................5 \nMSSB: WHO CAN BENEFI T ..........................................................................................................................................5 \nMSSB: HOW THEY BENEF IT .........................................................................................................................................6 \nMSSB: CURRICULUM COMPO NENTS ...........................................................................................................................7 \nMSSB: CURRICULUM MOD ULES ..................................................................................................................................7 \nBANKING SERVICES .................................................................................................................................................................. 7 \nCREDIT REPORTING .................................................................................................................................................................. 8 \nFINANCIAL MANAGEMENT ........................................................................................................................................................ 8 \nINSURANCE ............................................................................................................................................................................ 9 \nORGANIZATIONAL TYPES .......................................................................................................................................................... 9 \nRECORD KEEPING .................................................................................................................................................................... 9 \nRISK MANAGEMENT .............................................................................................................................................................. 10 \nSELLING A BUSINESS AND SUCCESSION PLANNING ....................................................................................................................... 10 \nTAX PLANNING ..................................................................................................................................................................... 10 \nTIME MANAGEMENT ............................................................................................................................................................. 11 \nIS SMALL BUSINESS OWNERSHIP A GOOD FIT FOR YOU? ............................................................................................................. 11 \nPLANNING FOR A HEALTHY BUSINESS ........................................................................................................................................ 11 \nMANAGING CASH FLOW......................................................................................................................................................... 12 \nTHE DEEP DIVE ......................................................................................................................................................... 12 \nEVALUATION BEST PRAC TICES .................................................................................................................................. 12 \nEVALUATE FOR QUALITY AND IMPACT ....................................................................................................................................... 12 \nEVALUATE WHAT IS NEXT ........................................................................................................................................................ 13 \nGETTING STARTED WITH MSSB ................................................................................................................................. 13 \nSELECTING MODULES ............................................................................................................................................................. 13 \nSELECTION OPTIONS .............................................................................................................................................................. 13 \nWORKING WITH EXPERTS ....................................................................................................................................................... 15 \nJOIN THE MONE Y SMART ALLIANCE .......................................................................................................................................... 15 \nELIGIBILITY ........................................................................................................................................................................... 15 \nIS YOUR ORGANIZATION READY TO OFFER TRAINING ? A SELF-ASSESSMENT ................................................................................... 15 \nAPPENDIXES ............................................................................................................................................................ 17 \nGLOSSARY OF TERMS ............................................................................................................................................................. 17 \nMSSB MODULES MATRIX ...................................................................................................................................................... 21 \nMANAGING CASH FLOW PARTICIPANT GUIDE ............................................................................................................................ 25 \nMANAGING CASH FLOW INSTRUCTOR GUIDE ............................................................................................................................. 46 \nMSSB PLAN OF ACTION WORKSHEET TEMPLATE ....................................................................................................................... 72 \nMSSB TTT INVITATION AND AGENDA TEMPLATE ....................................................................................................................... 74 \nCHECKLISTS .......................................................................................................................................................................... 76 \nPREPARATION ....................................................................................................................................................................... 77 MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 3 of 92 SAMPLE INSTRUCTION PLANNER .............................................................................................................................................. 78 \nTRAINING DAY ...................................................................................................................................................................... 79 \nSUCCESS TIPS ........................................................................................................................................................... 80 \nMATERIALS AND EQUIPMENT NEEDED ...................................................................................................................................... 81 \nGIVING INSTRUCTIONS ........................................................................................................................................................... 82 \nFACILITATING DISCUSSIONS ..................................................................................................................................................... 82 \nCLASSROOM SET-UP .............................................................................................................................................................. 83 \nUSING CHART PAPER ............................................................................................................................................................. 83 \nUSING HANDOUTS ................................................................................................................................................................. 83 \nUSING VISUAL AIDS ............................................................................................................................................................... 83 \nCONSIDER THE THREE LEARNING STYLES WHILE TEACHING .......................................................................................................... 84 \nTHINGS TO AVOID DURING A PRESENTATION ............................................................................................................................. 84 \nQUESTIONS FOR SELF-REFLECTION ........................................................................................................................................... 85 \nACCOMMODATING STUDEN TS WITH DISABILITIES .................................................................................................... 86 \nAMERI CANS WITH DISABILITIES ACT (ADA) OF 1990 .................................................................................................................. 86 \nREQUESTS FOR ACCOMMODATIONS ......................................................................................................................................... 86 \nHOW TO MAKE CLASSES ACCESSIBLE TO STUDENTS WITH DISABILITIES ........................................................................................... 87 \nEFFECTIVE COMMUNICATION .................................................................................................................................................. 87 \nGUIDELINES FOR TALKING ABOUT DISABILITIES ........................................................................................................................... 89 \n10 COMMANDMENTS OF ETIQUETTE FOR INTERACTING WITH PEOPLE WITH DISABILITIES .................................................................. 89 \nCONTACT INFORMATION ......................................................................................................................................... 91 \n \n \n \nDISCLAIMER \n \nThese training materials are intended as general guidance only and may or may not apply to a particular \nsituation based on the circumstances. The materials do not create any legal rights or impose any legally binding requirements or obligations on the Federal Deposit Insurance Corporation (FDIC) and U.S. Small Business Administration (SBA). The FDIC and SBA make no claims or guarantees regarding the accuracy or timeliness \nof this information and material. \nThe content of this traini ng material is not designed or intended to provide authoritative financial, accounting, \ninvestment, legal, or other professional advice which may be reasonably relied on by its readers. If expert assistance in any of these areas is required, the services o f a qualified professional should be sought. \nReference to any specific commercial product, process, or service by trade name, trademark, manufacturer or \notherwise does not constitute an endorsement, a recommendation or a preference by the FDIC and SBA or t he \nUnited States government. \n \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 4 of 92 Introduction \n \nMoney Smart for Small Business (MSSB ) is an instructor -led curriculum developed jointly by the Federal \nDeposit Insurance Corporation (FDIC) and the U.S. Small Business Administration (SBA). The 13 modules in \nthis curriculum provide introductory business training for aspiring and existing entrepreneurs on the basics of \nstarting and growing a business. In addition, the curriculum serves as a foundation for more advanced training and technical assistance. \n The MSSB Curriculum was created to assist financial institutions and community organizations (Small Business \nor Economic Development Organizations, Community Banks, Financial Institutions, Government Programs, Chambers of Commerce, Business Chambers/Trade Associat ions and Independent Small Business Consultants) \ndeliver introductory business training. The FDIC and SBA invite financial institutions and community organizations to order and begin teaching this free curriculum. \n The MSSB Curriculum is a tool for partner ships. For example, financial institution staff can deliver a MSSB \nProgram in collaboration with small business resource providers. \n The topics in the MSSB Curriculum were selected through focus groups and interviews with small business \ntechnical assistan ce practitioners. \n \nAbout This Participant Guide \n \nThis Train -the-Trainer Participant Guide is designed to help financial institutions and community organizations \nconduct effective Money Smart for Small Business introductory business training f or aspiring a nd existing \nentrepreneurs in their communities. \n \nThis guide includes complementing information to the Train- the-Trainer PowerPoint presentation, a matrix \nsummarizing the 13 MSSB modules, a Participant Guide, Instructor Guide and PowerPoint presentation for the \n“Managing Cash Flow” module to showcase how the three components of all 13 MSSB modules interact; and a \ncomprehensive Success Tips section. A glossary of terms is also provided to explain the use of specific terms within the context of the MSSB TtT C urriculum . Words in italic can be found in the MSSB TtT Curriculum \nGlossary of Terms. \n \nMSSB : Train -the-Trainer Learning Objectives \n \nAfter completing a Train -the-Trainer Workshop, you will be able to: \n \n1. Register as a MSSB Alliance member, order the 13 module s on CD -ROM or download the modules, \nwhich include an Instructor Guide, Participant Guide and PowerPoint presentation for each module. \n2. Present the MSSB Curriculum with confidence and describe effective ways to make the content of each \nmodule compelling and engaging. \n3. List and describe at a high level, the goals and objectives of the MSSB Curriculum . \n4. Describe several ways to customize a MSSB program to meet the diverse needs of small business owners \nwho represent a range of business development stages and learning needs. MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 5 of 92 5. Describe best practices for working with subject matter experts to co -train modules and evaluating the \nquality and impact of the MSSB Program within the MSSB Alliance Member network. \n6. Identify several ways to connect MSSB Training participa nts to additional training or technical \nassistance by providing resources and success tips to ensure MSSB Instructors host a successful MSSB \ntraining program. \n \nMSSB: What It Is \n \nMSSB is an instructor -led business curriculum or tool collaboratively developed by the FDIC and SBA that \nprovides introductory business training for aspiring and existing entrepreneurs on the basics of starting and \ngrowing a business. \n In 2012, the FDIC and SBA created 10 modules that cover a wide range of business topics. \nIn 2015, three new modules were created and all 13 modules were translated into Spanish and made available \nfor download.\n \nEach module takes between 60 -90 minutes to present and includes three components: an Instructor Guide, a \nParticipant Guide and PowerPoint. \nThe modules are instructor led; can be edited or customized; delivered as stand -alone modules; mixed and \nmatched to meet the specific needs of entrepreneurs; and integrated into the training programs that financial \ninstitutions and community organizations currently utilize to create a lasting impact in their communities. \n \nMSSB: Why It Was Created \n \nMSSB was created as a tool to: \n• Assist financial institutions and community organizations to engage and assist aspiring and existing \nentrepreneurs. \n• Help aspiring and existing entrepreneurs think through their business model, and to start and grow their businesses. \n• Have sustainable impact in all types of communities from urban to rural. \n• Spur economic activity. \n \nMSSB: Who Can Benefit \n \nFinancial Institutions and Communi ty Organizations \n• Small Business or Economic Development Organizations \n• Community Banks/Financial Institutions \n• Government Programs \n• Chambers of Commerce or Business Chambers/Trade Associations \n• Independent Small Business Consultants MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 6 of 92 Aspiring and Existing E ntrepreneurs \n• Aspiring entrepreneurs have many questions, passion, determination and fears. They need a solid \nfoundation to success fully start and grow a business. \n• Existing entrepreneurs have successfully started their business , but as their business grows, they have \ngrowing business demands including different skill sets. \n \nUrban and Rural Communities \n• Communities, both urban and rural, can benefit from Money Smart for Small Business . \n \nMSSB: How They Benefit \n \nFinancial Institution and Community Organization B enefits \n• They become a catalyst for innovation and job creation in their community. \n• They become a catalyst for revitalizing a local economy. \n• They anchor themselves to the communities where they operate and serve. \n• Financial institutions may receive positive consideration under the Community Reinvestment Act \n(CRA) (except credit unions and loan funds, which are not subject to the CRA Regulation). \n• If the organizations offering MSSB are Certified Development Financial Institutions (CDFIs), they may be able to es tablish or enhance MSSB programs to meet the needs of low to moderate -income \nbusinesses. \n \nAspiring Entrepreneur Benefits \n• Build a business and create wealth \n• Understand skills required in a startup \n• Use MSSB modules as input to develop a business plan \n \nExisting Entrepreneur Benefits \n• Learn skills in maintaining a business \n• Learn skills in business management and operations \n• Ability to find more advanced training or access other resources and services \n \nCommunity Benefits \n• Revitalized local economies and create more jobs \n• Wealth created by aspiring and existing entrepreneurs tends to stay in the community through reinvestment. \n• Jobs created keep talent in the community. Job seekers don’t need to leave the community. \n• Entrepreneurs in rural areas are more likely to becom e community leaders and reinvest through \nphilanthropy and volunteer work. \n• As the economy grows, so does civic pride and community spirit. \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 7 of 92 MSSB : Curriculum Components \n \nThere are three components to each of the 13 module s. Every module is formatted and structured the same way. \nThe components of each module consist of: \n \n• A fully scripted Instructor Guide in Word and PDF formats. \n• A Participant Guide in Word and PDF formats. \n• Overhead slides (visuals) in PowerPoint and PDF formats. \n \nThe Instructor Guide is your roadmap for presenting the modules. It includes: \n \n• The purpose and objectives of the module. \n• A detailed lesson plan. \n• A copy of the overhead slides (visuals). \n \nThe topics for the training modules provide a practical introduction to aspects of starting and gr owing a \nbusiness that can be taught in any order or independently in 60 to 90 minutes each. In addition to grounding \nparticipants in the basics, the curriculum serves as a foundation for more advanced training and technical \nassistance. \n \nMSSB : Curriculum Modules \n \nThe first ten modules, launched in 2012, we re: \n• Banking Services • Record Keeping \n• Credit Reporting • Risk Management \n• Financial Management • Selling a Business and Succession Planning \n• Insurance • Tax Planning \n• Organizational Types • Time Management \n \nThe th ree newly created modules are: \n• Is Small Business Ownership a Good Fit for You? \n• Planning for a Healthy Business \n• Managing Cash Flow \n \nThe original 10 modules are 60 minutes long. The three new modules are 90 minutes long and contain case \nstudies and interact ive tools. \nPlease look at the Appendix: MSSB Modules Matrix to learn more about each module. \n \nBanking Services \n \nThe “ Banking Services ” module will introduce banking products and services available to entrepreneurs and \nsmall business owners, including bus iness checking, payroll processing, merchant services, business loans and \ncash management services. MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 8 of 92 This module also explains how to select the best banking products and services for their business. \nAt the end of the module, entrepreneurs will : \n• Gain a soli d understanding of the banking products and services available to small business owners \n• Understand the importance of building effective long- term relationships with a banker or lender \n• Recognize the role of a personal credit score in the lending process \n \nIt may be best for b usiness owners at early stages or those who are seeking a loan from a financial institution. \nThe most important aspect of this module is to emphasize that entrepreneurs should start a relationship with a financial institution well before they need a loan. \n \nCredit Reporting \n \nThe “ Credit Reporting” module highlights the impact of credit reports on the operation and growth of a business \nand the impact that the business owner’s personal credit can have on it. \nIt identifies credit reports and other systems used to assess the risk of extending credit to entrepreneurs and \nsmall business owners. \nAt the end of the module, entrepreneurs will : \n• Understand the full scope of credit reporting and the impact of credit reports on the operation or growth \nof a small business \n• Discover strategies for building or improving business credit \n• Appreciate how personal credit scores impact the ability of a business to get credit \n It may be best for companies in all stages of business development, especially for those who may have concerns \nabout their credit scores and/or those who plan to apply for loans. \n \nThere’s plenty of content provided by various organizations about personal credit scores , but this module may \nbe one of a few resources related to business credit. \nSome financial institutions and community organizations use this module as a stand- alone module or as a \ncompl ement to other business development initiatives. Others have used i t as part of a one -day session where \nthe “Credit” and “Banking” modules were tau ght in partnership with financial institutions and credit counseling \norganizations. \n \nFinancial Management \n \nThe “ Financial Management ” module identifies financial management practices, rules and tools commonly \navailable for small businesses and how the y all work. \nAt the end of the module, entrepreneurs will : \n• Grasp the importance of sound financial management \n• Understand small business financial management basics including: \n• Startup financing \no Financing for a growing business \no Financing working capital \no Financi ng fixed assets MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 9 of 92 It may be best for companies in a ll stages of business development, especially business owners who are \ninterested in obtaining a loa n from a financial institution. \n \nInsurance \n \nThe “ Insurance ” module identifies the types of insurance that s mall businesses should understand and consider. \nAt the end of the module, entrepreneurs will : \n• Recognize the importance of small business insurance \n• Understand the full range of insurance products and services \no Required coverage \no Other coverage \nIt may be best for companies in a ll stages of business development, especially those who don’t yet have \ninsurance or find some insurance terms and concepts confusing. \n \nOrganizational Types \n The “ Organizational Types ” module analyzes the most common legal entities or str uctures. \nAt the end of the module, entrepreneurs will : \n• Know that the legal structure of a business determines how a company operates and is taxed \n• Distinguish the general characteristics, advantages and disadvantages of organizational types: \no Sole proprietor ship \no Partnerships \no Limited liability company \no C-corporation \no S-corporation \n \nIt may be best for companies in e arly stages of business development, especially those who have not yet \nincorporated and may be confused by the risks and benefits of each organiza tional type. \nStatistics show that the majority of small businesses operate as sole proprietorships. Business owners need to \nunderstand how to protect themselves and their business assets. \nRecord Keeping \n \nThe “ Record Keeping ” module identifies practical re cord-keeping techniques. \nAt the end of the module, entrepreneurs will : \n• Comprehend the necessity for good record keeping \n• Learn about small business record -keeping practices and rules \n• Discover record keeping software tools \nIt may be best for companies in al l stages of business development, especially those who lack formal record -\nkeeping disciplines. \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 10 of 92 Risk Management \n \nThe “ Risk Management ” module identifies the common risks associated with a small business and how to \nmanage those risks. \nAt the end of the module, entrepreneurs will: \n• Understand the common risks associated with a small business \n• Identify the external and internal factors which affect risk for a small business \n• Implement, monitor and evaluate a risk management plan for a small business \nIt may be b est for companies in a ll stages of business development, especially those who want to learn about \nminimizing internal and external risks to their business. \nThis module could be considered a more in- depth version of a SWOT (Strengths, Weaknesses, Opportunit ies \nand Threats) analysis and it may work well if combined with the Insurance Module. \n \nSelling a Business and Succession Planning \n \nThe “ Selling a Business and Succession Planning” module explains how to establish an exit strategy for a \nbusiness through eit her a sale or transfer of ownership to successors. \n \nAt the end of the module, entrepreneurs will : \n• Learn how to change the ownership of a business through selling, closing or passing the business to \nsuccessors \n• Know how to establish an exit strategy for ret irement which includes a succession plan, transferring \nownership of the business and paying taxes \n It may be best for companies in all stages of business development, especially those who plan to sell or transfer \nownership to others in the future. \n \nTax Planning \n \nThe “Tax Planning” module introduces the entrepreneur or participants to tax requirements at the local, state \nand federal levels and helps them to create a plan to pay their taxes. \nAt the end of the module, entrepreneurs will : \n• Understand the range of state, local and federal tax reporting requirements of a small business and its \nowner \n• Be able to research general tax reporting requirements \n• Understand the importance of establishing a plan to pay taxes \n It may best for companies in all stages of busine ss development, especially those who have not yet set up \nsystems and processes for paying taxes in a timely manner. \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 11 of 92 Time Management \n \nThe “Time Management” module explains the concept of time management and why it ’s important to a small \nbusiness. \nAt the e nd of the module, entrepreneurs will : \n• Understand the importance of time management \n• Discover commonly used time management practices like \no Pareto analysis \no ABC method \no Eisenhower method \no POSEC method \nIt may be best for companies in all stages of business development as the nature of small businesses is that they \nare typically short staffed. As such, time management is critical to the ir success . \nThe Time Management module may work well if combined with the Organization Types module as it fosters \nthinking about how to fulfill the needs of the business, who is involved and what other human resources are \nneeded. \n \nIs Small Business Ownership a Good Fit For You? \n \nThe “ Is Small Busines s Ownership a Good Fit For You?” module is one of three new modules and helps the \naspiring entrepreneur think about the realities of starting a business and their readiness to start a business. \nAt the end of the module, entrepreneurs will : \n• Discern between the myths and realities of small business ownership \n• Start a self -assessment to det ermine their readiness to become a small business owner \n• Gain insight about their readiness to start a business \nIt may be best for a spiring entrepreneurs at the early stages of their decision -making, but existing business \nowners can also benefit from the se lf-assessments in the Participant Guide. \nIt’s also recommended that this module be offered first in a program as it helps set the stage for later modules or \nclasses. \n \nPlanning for a Healthy Business \n \nThe “ Planning for a Healthy Business ” module is the seco nd of the three new modules and introduces aspiring \nentrepreneurs to the benefit s of planning and making smart decisions. \nIt’s recommend ed that this module be part of the second class in a program as it covers four different forms of \nplanning, from simple to complex. \nAt the end of the module, entrepreneurs will : \n• Discover a 4 -Step Business Planning process, via a case study, that will help them create a long- term \nhealthy business \no Back -of-Napkin Plan \no Resource Plan \no Business Plan MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 12 of 92 o Action Plan \nIt may be best for aspiring entrepreneurs who are thinking about starting a business. The planning process will \nelevate their decision -making. Existing business owners can also benefit from some of the planning tools \nprovided in their Participant Guide. \nEntrepreneurs attend ing this class will be introduced to business planning, but should seek alternative business \nplanning resources to develop a business plan on their own or with the assistance from the organization hosting \nthe training and/or its partners. \n \nManaging Cash F low \n \nThe “ Managing Cash Flow ” module is a great overview of cash flow and how to manage cash flow. This is the \nthird new module and should be scheduled after the Financial Management module. \nAt the end of the module, entrepreneurs will : \n• Learn about the cr itical importance of cash flow management in a small business \n• Act as advisors to Bob and the Wired Cup \n• Understand the need for expert assistance and advice \nIt may be best for companies in all stages of business development, especially those who lack fina ncial \nmanagement expertise. This module is especially helpful for new business owners who need to prepare to work \nwith accountants, as it demystifies a lot of cash flow terminology. \n \nThe Deep Dive \n \nThe “ Managing Cash Flow ” module is a highly interactive le arning experience that encourages participants to \nfocus on cash flow management as an essential competency of business ownership. No matter where learners \nare in the development of their businesses, this 90- minute module encourages them to ask questions about their \nbusiness and prepare to interact with accountants to analyze the flow of cash in and out of their business. On page 27 in the ap pendix, you will find the Participant Guide for the Managing Cash Flow Module. \n \nEvaluation Best Practices \n At the en d of every module or class , each module should be evaluated for two main reasons : \n \n1. To evaluate the q uality and impact of the module \n2. To help identify what is next \n \nEvaluate for Quality and Impact \n \nThe Participant Guide for each module includes an evaluatio n form on the last page. The forms are easy to \ncomplete. Evaluation forms are effective tools for gauging immediate reactions to a class. Another great way to \nevaluate impact is to conduct an anonymous follow -up survey about a week after the class. Conside r using a \nfree online tool to create a survey for the participants. MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 13 of 92 Ask questions such as: \n• Now that you have had time to reflect, what do you feel were the most compelling learning points of the \nManaging Cash Flow module? \n• What steps have you taken to apply the Managing Cash Flow module key principles to your own small business? \n• If you have not applied the principles of Managing Cash Flow to your small business, what prevented you? \n \nEvaluate what is next \n Here are some ways to identify which modules your participants will most want/need: \n \n• At the end of a class, conduct a debriefing conversation. Ask, “What should happen next?” \n• Scan the Parking Lot for questions that indicate a need for additional classes. \n• Interview guest experts for their ideas. They can o ffer great advice based on the questions the \nparticipants asked them. \n \n \nGetting Started With MSSB \n \nSelecting Modules \n \nWhen selecting which modules to deliver and in what sequence, please consider the following information: \n \n• The modules can stand -alone and be presented topic by topic \n• The modules can be mixed and matched to meet the entrepreneur’s needs \n• The modules can be integrated into an existing training program \n• The modules are free of copyrights, which means financial institution and community logos can be \nadded to the materials \n• The modules are available in Word and PDF formats and thus customizable \n \nSelection Options \n \nIdeally any program will start with the two fundamental modules: Is Small Business Ownership a Good Fit for \nYou? and Planning for a Heal thy Business . These modules cover fundamental principles of small business \nownership. They are very interactive , which helps host organizations learn more about the entrepreneurs \nbusinesses and concerns. Some financial institutions and community organizati ons offer individual classes once \nor twice a week for a number of weeks, as shown on the following page . A benef it of this approach is that host \norganizations can plan and advertise an entire program ahead of time. It ’s easy to recruit and orient experts a s \nwell. The downs ide to this approach is that host organizations are locked into a plan that may not fit the needs \nof their entrepreneurs. \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 14 of 92 Week Module Name \n1 Is Small Business Ownership a Good Fit for You? \n2 Planning for a Healthy Business \n3 Financial Management \n4 Managing Cash Flow \n5 Credit Reporting \n6 Banking Services \n7 Tax Planning \n8 Time Management and Graduation \n \nOther financial institutions and community organizations may prefer to offer combinations, such as full -day \nprograms on Saturdays once or twice per month allow ing them to combine two or more modules. As depicted \nbelow, the modules have been selected for Day 1 and the modules for Days 2, 3 and 4 are not set. This allows \nthe host organization to custom design a program based on focus g roup feedback and from questions the \nentrepreneurs and small business owners ask. This option may be challenging to manage in terms of advertising and for recruiting any experts that might be need ed.\n \nThe entrepreneurs in attendance will be invaluable advis ors on the selection and sequencing of modules. Ask \nthem what they want to know and ideal times to offer classes. Be flexible. While it’s a great idea to have a \nsequence of modules in mind, be prepared to adapt plans based on each entrepreneur’s questions and feedback . \n \nDay Modules \n1 Is Small Business Ownership a Good Fit for You? \nPlanning for a Healthy Business \nCredit Reporting \nFocus Group: What should be next in this program? \n2 TBD Focus Group \n3 TBD Focus Group \n4 TBD Graduation \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 15 of 92 Working with Experts \n \nMany MSSB Alliance members use guest experts to augment the experience and expertise of the host \norganization instructor. Guest experts bring a wealth of experience and expertise to Money Smart classes. \n \nThere are three main categories of experts: \n \n1. Smal l business owners who have great stories to share (both success stories and cautionary tales) \n2. Representatives from such fields as banking, credit reporting and taxation \n3. Professionals who advise clients on a regular basis, such as accountants or insurance b rokers \n Guest experts contribute a great deal to Money Smart classes. They tell interesting stories and share real -life \nexperiences about what to do, or not to do. There are some risks associated with working with experts, as well. If they are unprepared they can be ineffective. They can lose track of time or provide examples that are not relevant to the questions the learners ask. Some experts tend to use jargon or technical language which might confuse participants more than help them . When working with experts, provide them with clear directions and \nparameters to ensure success. \n \nJoin the Money Smart Alliance \n \nAnyone can download the Money Smart for Small Business curriculum which is available at the FDIC Catalog . \nHowever , we encourage organizations to j oin the Money Smart Alliance to benefit from meeting other MSSB \nusers . \n \nThere is a short form to fill out and the most updated link will always be available at the MSSB Webpage. \nBoth joining the alliance and downloading the curriculums are very easy. The m aterials available for download \nare: Instructor Guide, Participant Guide and PowerPoint presentation for each of the modules. A CD -ROM \nincluding all modules can also be ordered by using the FDIC Catalog ordering system. \n \nEligibility \n No certifications are required to use the curriculum; however, it ’s ideal that MSSB instructors have experience \nin the delivery of training, technical assistance or coaching f or small businesses. The website (under the heading \n“Money Smart for Small Business Alliance”) includes a self -assessment questionnaire that should help \norganizations determine whether they are ready to adopt MSSB. The most current questionnaire is below: \n \nIs Your Organization Ready to Offer Training? A Self -Assessment \n The following questions can help you gauge your organization's readiness to offer Money Smart for Small \nBusiness as a member of the Money Smart Alliance. These questions can also help you think about the steps \nyou’ll need to take to set up a training program in your community. \n \n• Does your orga nization have experience providing training to small businesses (including technical \nassistance, mentoring, coaching, etc.)? \n• Does your organization work with small businesses to help them raise debt or equity? \n• Does your organization provide finance directl y or in partnership with others? MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 16 of 92 • Are your organization’ s marketing efforts able to reach into the small business community? \n• Are you able to reach unbanked/underbanked populations? \n• Do you have partners to help you in these efforts? \n• Do you have your target m arket for the training in mind? \n• Does your organization have subject matter experts in- house? If not, do you have access to experts to \ndeliver the course? \n• Is your organization or your partners able to provide follow -up support after the completion of the cl ass? \n \nIf you ’ve answered “Yes” to the majority of these questions, then you’ re in good shape to deliver quality \ntrainings! \n \nSign up to become an Alliance Member , and learn about the MSSB Town Halls at: \n \nhttps://www.fdic.gov/consumers/consumer/moneysmart/bu siness.html \n \n \n \n \nTo download any Money Smart curriculum and collateral material: \n \nhttp://catalog.fdic.gov/ \n \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 17 of 92 Appendix es \nGlossary Of Terms \n \nTerm Definition \nAcronyms • MS = Money Smart \n• MSSB = Money Smart for Small Business \n• TtT = Train the Trainer \n \nFDIC Comm unity Affairs \nSection FDIC Community Affairs Section is under the Di vision of Consumer \nProtection. The Community Affairs Regional Manager’s contact \ninformation is provided as a reference for organizations that want to know more about MSSB. More information about the role of the Community Affairs Section is available at the FDIC website (key word: Community Affairs). \n \nMoney Smart News Money Smart News is the FDIC’s quarterly newsletter featuring tips, \nupdates, and success stories for financial educators. \n \nMoney Smart Alliance Money Smart Alliance is a group of financial institutions and community \norganizations that promote and teach M oney Smart products. There is no \nseparate process to join the MSSB Alliance, however, a separate list of organizat ions that use MSSB is tracked. Organizations that choose to \njoin the MSSB Alliance can share information specific to the MSSB Curriculum . \n \nMSSB Alliance MSSB Alliance is a group of financial institutions and community \norganizations that promote and teach MSSB. FDIC facilitates \ncollaboration between the MSSB Alliance partners through a quarterly \nonline town hall to discuss experiences with the training and share \npromising practices. \n \nMSSB Alliance Town Hall \nMeetings MSSB Alliance Town Hall Meetings are quarterly vir tual online \nmeeti ngs for MSSB Alliance Members. Town Hall Meetings are a space \nto share best practices, ask questions and seek guidance about \nestablishing and running an MSSB program. \n \nMSSB Curriculum MSSB Curriculum is an introductory business training for aspiring and \nexisting entrepreneurs on the basics of st arting and growing a business. \nIn addition to grounding the participants in the business basics, the curriculum serves as a foundation for more advanced training and \ntechnical assistance. The curri culum consists of 13 training modules. \nMSSB Instructor MSSB Instructor is an individual teaching the MSSB Curriculum and/or \nthe Train -the-Trainer Workshop. MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 18 of 92 Term Definition \nMSSB Instructor Guide MSSB Instructor Guide is the roadmap for pr esenting the MSSB 13 \nmodules. T he instructor guide is fully scripted in both Word and PDF \nformats. It includes: \n• The purpose and objectives of the module \n• A detailed lesson plan \n• A copy of the overhead slides (visuals) in PowerPoint and \n• Appendixes with resources to teach an MSSB Module \n \nMSSB Interactive Tools MSSB Interactive Tools are included in two of the training modules: Is \nSmall Business Ownership a Good Fit? and Planning For a Healthy \nBusiness. Interactive tools are hands on approach to helping participants become more engaged, retain more of the learning objectives and strengthen problem solving and critical thinking skills. These tools and instructions to use them are provided as separate attachments to the \ncorresponding modules. \n \nMSSB Program MSSB Program: There are two instanc es in which this term is used 1) \nWhen referring to the MSSB Modules and resources available to \norganizations using MSSB such as the MSSB Alliance, MSSB Town Halls, MSSB TtT Resources; 2) When organizations teaching MSSB Modules, have created a business tra ining or business development \nprogram that entails a set of resources available to their small business audience that may include a recurring training program encompassing more than one module, coaching to MSSB training participants, or more resources made available through partner organizations. \n \nMSSB Training Modules MSSB Training Modules make up the MSSB Curriculum. There are 13 \ntraining modules. The topics for the training modules provide a practical introduction to aspects of starting and managing a business that can be \ntaught in any order or independently in 60 to 90 minutes. Each module includes a fully scripted instructor guide, participant guide/ workbook, \nand PowerPoint slides. In addition to grounding participants in the \nbasics, the curriculum se rves as a foundation for more advanced training \nand technical assistance. There are 13 modules in the curriculum: \n• Banking Services \n• Credit Reporting \n• Financial Management \n• Insurance \n• Organizational Types \n• Record Keeping \n• Risk Management \n• Selling A Business and Succession Planning \n• Time Management \n• Tax Planning \n• Is Business Ownership A Good Fit For You? MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 19 of 92 Term Definition \n• Planning For A Healthy Business \n• Managing Cash Flow \n \nMSSB Participant Guide MSSB Participant Guide is the accompanying guide or workbook \ncreated for aspiring and exist ing entrepreneurs (participants) attending \nMSSB training . Each training module has a corresponding instructor \nguide, participant guide and PowerPoint slides. \n \nMSSB PowerPoint Slides MSSB PowerPoint Slides are accompanying visual aids for the MSSB \nInstruc tor Guide. Each training module has a corresponding instructor \nguide, participant guide and PowerPoint slides. \n \nMSSB Train -the-Trainer \nAudience MSSB Train -the-Trainer Audience consists of financial institutions and \ncommunity organizations considering hos ting the MSSB Program: \n \n• Small Business or Economic Development Organizations \n• Community Banks/Financial Institutions \n• Government Programs \n• Chambers of Commerce or Business Chambers/Trade Associations \n• Independent Small Business Consultants \n \nMSSB TtT Curric ulum MSSB TtT Curriculum is training offered to staff and volunteers from \nfinancial institutions and community organizations planning to offer the \nMSSB Curriculum to aspiring and existing entrepreneurs. The \ncurriculum includes a TtT Instructor Guide, TtT P articipant Guide and \nPowerPoint slides. \n \nMSSB TtT Instructor Guide MSSB TtT Instructor Guide is the roadmap for presenting t he Train -the-\nTrainer Workshop. Given limited resources to host TtT Workshops, the FDIC has created this self -help tool to financial institutions and \ncommunity organizations that want to adopt one or all the MSSB modules and need to train their trainers/instructors to effectively teach introductory business training to aspiring and existing entrepreneurs in \ntheir communities. Organizations organizing a TtT Workshop can contact their Community Affairs Point of Contact to request assistance in designing their TtT W orkshop or co- facilitating it. The instructor guide \nis fully scripted and available in both Word and PDF formats. It includes: \n• The purpose and objectives of the module. \n• A detailed lesson plan. \n• A copy of the overhead slides (visuals) \n \nMSSB TtT Participant MSSB TtT Participant Guide is the guide or workbook created for Train - MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 20 of 92 Term Definition \nGuide the-Trainer Workshop p articipants. This guide w as designed to inform \nfinancial institutions and community organizations about the MSSB \nProgram and help them conduct effective MSSB introductory business \ntraining to aspiring and existing entrepreneurs in their communities. \n \nMSSB TtT ToolKit MSSB TtT To olkit is a collection of resources for MSSB Alliance \nMembers made available as attachments or explained in the MSSB TtT Curriculum. The resources include: \n \n• MSSB TtT Curriculum \n• MSSB Promotional Videos \n• MSSB Promotional Flyers \n• MSSB Training tips \n• MSSB Guide t o teaching participants with disabilities \n• MSSB TtT Workshop Plan of Action worksheet \n• MSSB TtT sample Invitation and Agenda Template \n \nMSSB TtT Workshop MSSB TtT Workshop is a 3+ hour -long workshop designed for financial \ninstitutions and community organizat ions considering hosting the MSSB \nProgram. The workshop provides a comprehensive overview of the \nMSSB Curriculum and training m odules. It also provides practical \nadvice in training delivery , it was designed to help financial institutions \nand community orga nizations conduct effective MSSB introductory \nbusiness training to aspiring and existing entrepreneurs in their \ncommunities. \n \nMSSB TtT Workshop Plan \nof Action worksheet MSSB TtT Workshop Plan of Action worksheet is intended to serve as \nan action oriented exercise at the end of an MSSB TtT Workshop to help \nparticipants craft a Plan of Action by selecting all the modules they want \nto consider and by making a list of all potential stakeholders that they will approach to create an MSSB Program within their or ganization. \n \n \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 21 of 92 MSSB Modules Matrix \n \n \n Learning Objectives Best for… \nBanking \nServices • Identify the banking services commonly \navailable to a small business and explain \nhow these services work. \n• Identify the advantages and \ndisadvantages of each o f the banking \nservices. \n• Explain how small business owners decide which banking services are best for \ntheir business. \n• Define several forms of deposit insurance. \n• Describe some benefits of building effective long -term relationships with a \nbanker or lender. \n• Describe the role of a personal credit \nscore in the lending process. \n• Explain the benefits of separating \nbusiness and personal bank transactions. Business owners at early stages of business \ndevelopment or those who are seeking a loan \nfrom a financial institu tion. \nThe banking module along with the credit module may be two of the most useful modules for financial institutions and community organizations that may already have business training resources. While there are multiple personal banking training resour ces in the marketplace, the MSSB \nBanking module is not designed to promote \nany financial institution. This module \nobjectively explains the different types of \nbanking services available to businesses; and \nit may be complemented by other Money \nSmart products for individuals . Please check \nthe FDIC Catalog (https://catalog.fdic.gov/) for other products that may complement an \nMSSB Program. Further, bankers are \ntraditionally great candidates to lend their \nsubject matter expertise to teach or facilitate \nthis modul e in collaboration with \norganizations serving aspiring and existing \nentrepreneurs. \nCredit \nReporting • Explain the concept of credit reporting \nand the impact of credit reports on the \noperation or growth of a small business. \n• Identify the credit reports and ot her \nreporting systems commonly used to assess the risk of extending credit to a \nsmall business. \n• Explain how credit reports work. \n• Identify the benefits a small business \nderives from a positive record of \nmanaging its debts and obligations. \n• Identify risks to a business from credit -\nrelated scams or frauds and take steps to \navoid or mitigate harm caused by them. \n• Identify the common business practices \nand products, tools, and services that are \navailable for a small business to help in \nproper credit reporting. \n• Identify strategies for building or \nimproving business credit. Companies in all stages of business \ndevelopment, especially for those who may \nhave concerns ab out their credit scores \nand/or those who plan to apply for loans. \n While there are multiple personal credit training programs and resources provided by credit counseling organizations, there are few resources explaining business credit and its relationshi p with personal credit. This \nmodule may also be complemented by other Money Smart products for individuals . P \nlease check the FDIC catalogue for other products that may complement an MSSB Program. \n MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 22 of 92 • Explain how the personal finances of a \nbusiness owner impact the ability of a \nbusiness to get credit. \nFinancial \nManagement • Explain the concept of financial \nman agement and why it is important to a \nsmall business. \n• Identify financial management practices, rules, and tools that are commonly \navailable to a small business. \n• Explain how these financial management practices, rules, and tools work. \n• Explain financial manag ement basics for \na small business. \n• Explain the basics of start up financing. \n• Explain the basics of financing for a growing business. \n• Explain the basics of financing working capital. \n• Explain the basics of financing fixed \nassets. Companies in all stages of business \ndevelopment, especially business owners who are interested in obtaining a loan from a financial institution. This module may be offered as an introduction to entrepreneurs that are interested in business plan writing or a loan packaging session tha t usually has \nmultiple modules delivered on a weekly basis. A pre -requirement to this module may \nbe “Planning for a Healthy Business” \nInsurance • Identify the types of insurance required \nby a small business. \n• Identify other types of insurance a small \nbusiness should consider. \n• Explain why insurance is important for a small business. Companies in all stages of business \ndevelopment , especially those who do not \nyet have insurance or find some insurance \nterms and concepts to be confusing. This module may be effectively offered in combination with the “Risk Management” module and “Organizational Types” for entrepreneurs in their initial or expansion phases. The three modules together provide a strong foundation to assist an entrepreneur in choosing their legal st ructure and \nnecessary protections to engage in growth efforts such as pursuing contracting opportunities. \n \nOrganizatio -\nnal Types • Identify general characteristics, \nadvantages, and disadvantages of each of \nthese organizational types for small \nbusinesses: So le proprietorship; \nPartnerships (general partnership, \nlimited partnership and limited liability \npartnership); Limited Liability Company \n(LLC); C -corporation; S -corporation. Companies in early stages of business \ndevelopment, especially those who have not yet incorporated and may be confused by the \nrisks and benefits of each organizational type. See comments on “Insurance” module. \nRecord \nKeeping • Explain the concept of record keeping \nand why record keeping is important to a \nsmall business. \n• Identify record ke eping practices, rules, \nand tools, which are commonly available Companies in all stages of business \ndevelopment, especially those who lack \nformal record -keeping disciplines. This \nmodule may be well received and marketed \nduring t ax season and it could be offered as a MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 23 of 92 to a small business. \n• Explain how these record keeping \npractices, rules, and tools work. \n• Identify benefits a small business derives from proper record keeping. \n• Explain record keeping basics for a small \nbusiness. \n• Identify software products available for \nsmall business record keeping. complement to, or as requirement to receive \nbusiness tax preparation services. “Record \nKeeping” may also be integrated in other training geared to assist entrepreneurs with loan packaging or business planning. \nRisk \nManagement • Identify the common risks associated \nwith a small business. \n• Identify the external and internal factors, \nwhich affect risk for a small business. \n• Identify situations that may cause risk for a small business. \n• Identify the common warning signs of risk for a small business. \n• Implement, monitor, and evaluate a risk \nmanagement plan for a small business. Companies in a ll stages of business \ndevelopment, especially those who want to \nlearn about minimizing internal and external \nrisks to their businesses. Se e comments on \n“Insurance” module. \nSelling Your \nBusiness and \nSuccession \nPlanning • Explain how to change the ownership of a \nbusiness through selling, closing, or transferring the business to successors. \n• Explain how to establish an exit strategy for retiremen t, which includes a \nsuccession plan, transferring ownership of the business, and paying taxes. Companies in a ll stages of business \ndevelopment, especially those who plan to \nsell or transfer ownership to others in the future. This module may be a good \ncomp lement to “Tax Planning” and could be \nparticularly useful to financial counselors who have aspiring or existing entrepreneur customers; or at the end of training geared to \ncomplete a business plan. \nTax Planning • Identify the federal tax requirements of a \nsmall business and its owner, and \nestablish a plan to account and pay for \nfederal taxes. \n• Identify the general state and local tax \nrequirements for a small business, and \nestablish a plan to account for and pay \nthese taxes. \n• Identify methods for researching the local, municipal, and county \nreporting/licensing requirements for a \nsmall business. Companies in a ll stages of business \ndevelopment, especially those who have not \nyet set up systems and processes for paying taxes in a timely manner. See comments on “Insurance” module. \nTime \nManagement • Explain the concept of time management \nand why it is important to a small \nbusiness. \n• Explain the time management practices, which are commonly employed by a small \nbusiness, including: ABC analysis ; \nPareto \nanalysis ; Eisenhower metho d; POSEC Companies in all stages of business \ndevelopment since the nature of small \nbusiness is that they are typically short staffed. As such, time management is critic al \nto the success of small businesses. This module works very well as a stand- alone \noffer, but it could also be effectively tied \nwith the “Tax Planning” as the tax season MSSB Train -the-Trainer Workshop , Participant Guide \n \n \n Page 24 of 92 method . presents an opportunity to think about the \nfuture and to improve time management. \nIs Small \nBusiness \nOwnership a \nGood Fit for \nYou? • Clarify some of the myths and realities of \nsmall business ownership. \n• Start a self -assessment to determine their \nreadiness to become small business \nowners. \n• Set a plan of action to complete their self -\nassessment s by seeking feedback from \nstakeholders, such as family, friends, and \npotential customers. Aspiring entrepreneurs at the early s tages of \ntheir decision -making but e xisting business \nowners can also benefit from the self -\nassessments in the Participant Guide. “Good \nFit” may be appropriate as a requirement to \nprovide additional counseling or training services, as a client intake process, or as the content for new client orientation sessions that business development service organizations may provide before acc epting \nnew clients or referrals. \nPlanning for \na Healthy \nBusiness • Explain how an evolving planning process \ncan help you make key decisions as \nbusiness owners. \n• Describe how to convert a vague idea into \na resource plan. \n• Explain the importance of a healthy personal credit score and healthy \nrelationships with lenders. \n• Describe how a business plan helps \nmotivate stakeholders to understand and \nsupport your business ideas. \n• Explain the benefits of creating a day -to-\nday action plan for running a small \nbusiness. Aspiring entrepreneurs who are thinking \nabout starting a business. E xisting business \nowners can also benefit from some of the \nplanning tools provided in their Participant Guides . This module may be effectively \ncombined with “Good Fit” as a strong foundation to provide further business counseling services including business plan training. \nCash Flow \nManagement • Describe the purpose of cash flow \nmanagement in a start up small business. \n• Assess a cash flow cycle and make cash flow projections. \n• Describe how a cash flow statement can \nhelp assess and improve the financial health of a startup. \n• Identify ways to manage cash flow in terms of managing costs and potential \nincome. \n• Identify ways to seek out expert technical assistance to improve cash flow \nmanagement. Compani es in a ll stages of business \ndevelopment, especially those who lack \nfinancial management expertise. This module is especially helpful for new business owners who need to prepare to work with accountants as it demystifies a lot of cash \nflow terminology. This module may be \nfollowed by “Financial Management” and it may complement or be incorporated in other business plan training programs, particularly in the financial plan section. The diagram featured in this module is found to be easy to understand. \n \n Managing Cash Flow Participant Guide \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 26 of 92 \n \n PARTICIPANT GUIDE \n \n \n \n \n \nFinancial \nEducation Curriculum \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 27 of 92 Table of Contents Participant Guide – Managing Cash Flow Module \n \n(Page numbers in this Table of Contents correspond to pages in this document , any oth er page \nnumber references have not been edited as the module has been imported exactly as is to showcase in \nthe “Dive in Section of the TtT Workshop ) \n \nCHECKING IN …………………………………………………………………………………………………………………………………………………………. …28 \nLEARNING OBJECTIVES ……………………………………………………………………………………………………………………………….…28 \nINTRODUCING BOB AND THE WIRED CUP ………………………………… …………………………………………………………………….…………29 \nOPENING BALANCE SHEET FOR THE WIRED CUP ……………………………………………………………………………………………………..… 30 \nCASH CONVERSION CYCLE ……………………………………………………… ……………………… ………………………………………………………….31 \nCASH FLOW DIAGRAM ………………………………………………………………………………………………………………………………………………. 32 \nCASH FLOW DIAGRAM DESCRIPTIONS ……………………………………………………………………………………………………………. 33 \nCASH FLOW STATEMENTS …………………………………………………………………………………………………………………………………………. 34 \nWHAT CAN BOB DO? ……………………………………………………………………………………………………………………………………………… …36 \nNEGOTIATING BETTER TERMS ……………………………………………………………………………………………………………………..… 37 \nTOOLKIT OF RESOURCES …………………………………………………………………………………………………………………………………………...38 \nGLOSSARY OF CASH FLOW TERMS……………… ………………………………………………………………………………………………….38 \nCASH FLOW STATEMENT TEMPLATE ……………………………………………………………………………………………………………. …41 \nFOR MORE INFORMATION …………………………………………………………………………………………………………………………… ..42 \nPRE- AND POST -TEST FORM …………………………………………………………………………………………………………………………..44 \nEVALUATION FORM ………………………..…………………………………………………………………………………………………………………………45 \n \nDISCLAIMER \n \nThese training materials are intended as general guidance only and may or may not apply to a particular situation based on the circumstances. The materials do not create any legal rights or \nimpose any legally binding requirements or obligations on the Federal Deposit Insurance Corporation \n(FDIC) and U.S. Small Business Administration (SBA). The FDIC and SBA make no claims or \nguarantees regarding the accuracy or time liness of this information and material. \n \nThe content of this training material is not designed or intended to provide authoritative financial, \naccounting, investment, legal, or other professional advice which may be reasonably relied on by its \nreaders. If expert assistance in any of these areas is required, the services of a qualified professional \nshould be sought. \n Reference to any specific commercial product, process, or service by trade name, trademark, \nmanufacture, or otherwise does not constitute an e ndorsement, a recommendation, or a preference by \nthe FDIC and SBA or the United States government. \n \nRevision Date: 09 -\n2011 MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 28 of 92 Checking In \nWelcome to Managing Cash Flow. By taking this training, you are taking an \nimportant step toward successful small business ownership. As a sma ll business \nowner, it is important to know how much cash is moving in and out of your business. You need to think ahead in order to meet financial obligations and \nrun a profitable business on a long -term basis. \n \nThis class introduces some basic cash flow concepts that can get you started. \n \n \nLearning Objectives \nAfter completing this module, you will be able to: \n \n• Describe the purpose of cash flow management in a start -up small business. \n• Assess a cash flow cycle and make some cash flow projections. \n• Describe h ow a cash flow statement can help assess and improve the financial health of a start -up. \n• Identify some ways to manage cash flow in terms of managing costs and potential income. \n• Identify ways to seek out expert technical assistance to improve cash flow mana gement. \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 29 of 92 Introducing Bob and the Wired Cup \nBob recently opened a new bakery café, The Wired Cup. The café has \na great location in a small college town. To get started, Bob invested \n$30,000 of his own money and received a $20,000 loan from a \ncommercial bank. He spent $45,000 on start- up costs, leaving $5,000 \nto run his business. \n \nThe Wired Cup is already popular with students, university staff, and \nneighbors. Everyone loves the coffee and baked goods. A college \ndean has started to order croissants for the faculty dining hall. Bob is \nbuilding a great new business. \n \nHowever, Bob has concerns. He has not yet paid himself, and he \nwonders when he can. The $5,000 is almost gone. Given that his key \ncustomers are students, he assumes many of them will go home o ver \nholiday breaks and the summer. Questions Bob is now asking: \n \n• How will he pay his bills if there are fewer customers? \n• Will he have enough money to ramp up again in September? \n• Should he buy in bulk to reduce costs? \n• Will suppliers allow Bob to buy on c redit, or does he still have to pay cash? \n \nThe good news is that Bob is thinking ahead . He has time to work to find some solutions. As we review The \nWired Cup’s cash flow issues, you will be able to apply these concepts to your own business. \n \n \nNotes \n \n \n \n \n \n \n \n \n \nThe Wired \nCup MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 30 of 92 Opening Balance Sheet for The Wired Cup \nYear 1 Opening Balance Sheet \nThe Wired Cup \n Assets \n Liabilities \nCurrent Assets: \n Current Liabilities: \n Cash $ 5,000 \n Bank Note $ 3,371 \nAccounts Receivable $ - \n Accounts Payable $ - \nPre-Opening Expenses \n Accounting $ 250 \n Long Term Liabilities: $ 16,629 \nAdvertising $ 500 \n Bank Charges $ 350 \n Total Liabilities $ 20,000 \nCable/Internet Services $ 200 \n Insurance $ 2,000 \n Ingredients $ 3,500 \n Janitorial Supply $ 75 \n Lease $ 1,350 \n Legal Fees $ 2,500 \n Licen ses/Fees/Permits $ 1,500 \n Payroll $ 2,400 \n Payroll Taxes $ 360 \n Telephone Services $ 150 \n Utilities $ 365 \n Total Current Assets $ 15,500 \n Equity \n Owner's Capi tal $ 30,000 \nFixed Assets: \n Kitchen Equipment $ 9,000 \n Total Equity $ 30,000 \nLease Hold Improvements $ 18,200 \n Office/Techn Equipment $ 2,300 \n Total Fixed Assets $ 29 ,500 \n \n Total Assets $ 50,000 \n Total Liability & Equity $ 50,000 \nAssumption s: Loan $20,000 5 years 14.54% ; Payroll 3 workers $10/hr = $30/hr * two 40 hr. weeks = $2,400 \n \nNote: This balance sheet lists pre -opening expen ses as current assets. In this example, the pre -\nopening expenses listed were expensed or realized before the end of the year. Entrepreneurs should \nalways keep track of pre -opening expenses as some may or may not be considered by financial \ninstitutions or investors as a business asset or owner investment/equity. \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 31 of 92 Cash Conversion Cycle \n \n \n \nA cash conversion cycle depicts how business dollars are invested in raw materials, resources, and \nother inputs. Those raw materials can be converted into products t hat are sold to generate payments \nor cash. \n If you have a short conversion cycle, you can quickly sell inventory or turn it back into cash which \nputs money back into the cash flow system in a relatively short period of time. \n \nIf you have a long cash conve rsion cycle, you will not be able to use that money while your inventory is \nunsold, sitting on your shelves. Money will not be flowing back into the system. \n \nNotes \n \n \n \n \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 32 of 92 \nCash Flow Diagram \n \nSee next page for a list of terms in this diagram. \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 33 of 92 Cash Flow Diagram Descriptions \nThe cash flow diagram on the previous page contains several key cash flow elements. It is a \nrepresentation of how cash moves in and out of the system, and many of the key decision points or valves a business owner can control. \nWhen you start a business, money flows into the business via debt or equity . \nThe valves in the diagram represent decision points. Your decisions impact cash flow and \nincrease or decrease your probability of success. Some valves are open all the time (like taxes and \ndebt). They are a constant drain on your cash which is why they are on the bottom. Some valves are partially open, like the sales, general, and administrative valves. You always spend money here; how \nmuch is up to you. As you spend available cas h, balance in the center tank drops. \nInventory . You spend money on raw materials, labor, and other direct costs to produce a product to \nsell (assuming you are producing a product, but the same principles apply for services as well). If you decide to spend a lot on inventory, you are deciding to tie up your money until you sell the inventory \nand turn it into cash. This is called the cash conversion cycle. \nFixed assets are usually expensive items that last, such as buildings, upgrades to space, vehicles, \nequipment, computers, and technology. If you purchase an expensive fixed asset, it ties up available \ncash. A better option is to lease to keep cash flowing. \nProfit generator (sales pump ). In the top left corner is a sales pump. Keep this primed to pump \nsales back into the system. \nAccounts receivable (A/R). You may make a sale, but not the cash until you collect it. Ultimately \nyou want to convert your accounts receivable into cash, so it flows into the center tank and becomes \navailable cash \nAccounts payable (A/P ). In the center tank, accounts payable are represented by bricks. This is \nmoney owed to vendors and suppliers who extend credit to you. For example, you receive a product or service but you have not yet paid for it. You still have use of that money. The bricks elevate the water. \nInstead of having to pay for a product or service, you can use that money for marketing or paying \nanother bill. \nBalancing accounts payable and accounts receivable is challenging. You want customers to pay you as quickly as po ssible (cash in) and you want to pay as slowly as possible (cash out). Your vendors are \ndoing the same thing. They want you to pay quickly, and they may be slow to pay their own vendors. \nUltimately, you want to have and be generating excess cash flow from profitable operations \n(ECFPO). This is the showerhead, which represents your paycheck. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 34 of 92 Cash Flow Statements \nA cash flow statement tells a story: \n \n1. How much money you have to run your business. \n2. How much cash is moving in and out of the business. \n3. Wher e that cash is coming from and going to. \n4. When the cash is moving or needs to move. \n As a business owner, you need to think ahead in order to meet your financial obligations and run a profitable business. A cash flow statement helps identify when your bus iness is generating more cash \nthan you need to meet obligations. Conversely, it tells you when the business is running short. Cash flow statements help you make smart, timely decisions that ensure your business is financially healthy \nover the long term. \n \nA cash flow statement for The Wired Cup is on the next page. \n \nNotes \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nNote : The payroll taxes rate used in this example is 15%. You will need to determine the appropriate local, state, and applicable federal taxes. \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 36 of 92 \n \nWhat Can Bob Do? \nTo stay in business, Bob needs to increase his sales revenue. He also needs to \nnegotiate agreements that decrease costs and help to control ca sh flow. To do \nthis, he needs to juggle some competing demands. He wants to hold on to his \ncash as long as possible. His landlord and vendors want to be paid right away. \nTo balance these expectations, Bob needs to make agreements that benefit all \ninvolved parties. These “win –win” negotiations benefit all parties. Bob has lots \nof opportunities to negotiate win– win agreements. \n \nIf you were advising him, what would you suggest? \n \n \n• How can Bob increase sales revenue at The Wired Cup? \n \n• How could Bob negotiate a b etter deal or two with his vendors and suppliers? \n • How can Bob plan for the seasonal ups and downs in his business? \n • Is it wise for Bob to use a credit card to offset cash flow issues? \n \nNotes \n \n \n \n \n \n \n \n \nWhat NOT To Do \n \n \n• Do not postpone paying estimate d taxes. \n• Do not hide from loan officers – they can provide invaluable advice. \n• Do not pay vendors later (they can cut off supply). \n• Do not overestimate revenue. \n• Do not underestimate costs. \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 37 of 92 Negotiating Better Terms \nTo manage cash flow, you want your customers to pay you right away so \nyou can use that cash to meet your financial obligations. On the other \nhand, you want to pay your vendors as late as possible, usually 30 days. The trick is to manage your accounts receivable (the money others owe \nyou) and yo ur accounts payable (the money you owe). \nCustomers \n• If a customer pays cash, this is great. If a customer pays with a credit or debit card, this is good, but the \nprofitability is lower because the business has to pay a credit card processing service and fee s charged by the \ncredit card issuer. These fees are usually not negotiable. Ask customers to pay in cash to avoid fees. Some small companies no longer take credit or debit cards; the risk is that some customers might not buy if they do \nnot have cash on the m. \n• Sell gift cards. The buyer of a gift card pays you the full amount of the gift card up front. \n• Corporate accounts are a great way to increase sales. The challenge is that these customers do not always pay \nright away. Most invoices are supposed to be pa id in 30 days. That creates lag time between when the product \nor service is provided, and when a business is paid. Most invoices are “net 30 days,” which means the client \npays within 30 days of the date the product or service is delivered. To improve cash flow and to get paid \nearly, a business owner can ask a corporate account to pay when the invoice is received, or maybe in 10 or 15 days. Offer them incentives to pay early. Most businesses offer a “2/10, net 30” discount meaning the \ncustomer will receive a 2% invoice discount if they pay in 10 days instead of 30. \nVendors and Suppliers \n• Most new businesses are required by their vendors to pay cash for supplies, inventory, and the like. After you \ndevelop a good reputation for paying on time (maybe a year), ask vendors to invoice you instead of asking for \ncash. This allows a business to pay in 30 days, which preserves cash flow. \nLandlords \nA major fixed monthly expense for many business owners is a lease or rent payment. Before you agree \nto a lease and the subse quent fixed monthly cost, you may be able to negotiate better terms and \npayment options to free up your cash flow. Carefully review the lease conditions and negotiate any \nadded expenses or fees associated with the lease, such as upkeep, maintenance, common areas, \nutilities, snow removal, landscaping services, or parking lot maintenance. As part of the negotiation you can discuss options, such as sub -leases, exclusivity, and co -tenancy. \n \nThink about what happens if you default. What would happen to your bus iness? You may be able to \nnegotiate those terms as well. A lawyer could provide you advice. \n \nIf you know that your business is seasonal, negotiate a payment plan. Let’s say your rent is $1,000 per month. If you anticipate your revenue to go down because of seasonal issues, ask the landlord to accept \nearly or late payments. Another idea might be to make fewer payments. For instance, multiplying the $1,000 by 12 months equals $12,000. Divide $12,000 by nine, which comes to $1,333 per month. You pay the same $ 12,000 to the landlord but you do not have to pay during the three months when you \nexpect your revenue to be down. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 38 of 92 Toolkit of Resources – Managing Cash Flow Module \nGlossary of Cash Flow Terms \nTerm Definition \nAccounts Payable Accounts payable (A/P) is money a business owner owes to vendors, service \nproviders, tax agencies and so on. Liability that results from the purchase of goods or services (money owed to others). \nAccounts Receivable Accounts receivable (A/R) is money that is due from customers as a r esult of \ndelivering goods or services and extending credit in the ordinary course of business. \nAccrual Basis of \nAccounting The accrual basis of accounting measures the performance and position of a \ncompany by recognizing economic events regardless of when cash transactions occur. The general idea is that economic events are recognized by matching revenues to expenses (the matching principle) at the time in which the transaction occurs rather than when payment is made (or \nreceived). This method allows the c urrent cash inflows/outflows to be \ncombined with future expected cash inflows/outflows to give a more \naccurate picture of a company's current financial condition. \nFixed Assets A fixed asset is a long -term tangible piece of property that a firm owns and \nuses in the production of its income and is not expected to be consumed or \nconverted into cash any sooner than at least one year's time. \nBalance Sheet A balance sheet is a financial statement that summarizes a company's assets, liabilities and shareholders' equity at a specific point in time. These three \nbalance sheet segments give investors an idea as to what the company owns and owes, as well as the amount invested by the shareholders. \nBurn Rate A burn rate describes the rate at which a new company uses u p its venture \ncapital to finance overhead before generating positive cash flow from \noperations. In other words, it's a measure of negative cash flow. \nCapital Capital can mean many things. Its specific definition depends on the context \nin which it is used. In general, it refers to financial resources available for \nuse such as: financial assets or the financial value of assets, such as cash. It is also used to describe the factories, machinery, and equipment owned by a business and used in production. \nCash Conversion Cycle A cash conversion cycle depicts how business dollars are invested in materials, resources, and other inputs. Raw materials can be converted into products that are sold to generate payments or cash. If a business has a short \nconversion cycl e, the owner can quickly turn it back into cash which puts \nmoney back into the business in a relatively short period of time. If a business has a long cash conversion cycle, the owner will not be able to use that money while inventory is unsold. \nCash Flo w Statement A cash flow statement tells a business how much money is available to run the business, how much cash is moving in and out of the business, where that cash is coming from and going to, and when the cash is moving or needs to move. MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 39 of 92 Term Definition \n A cash flow statement helps a business owner to think ahead. It helps \npinpoint when a business is generating more cash than needed to meet \nobligations. Conversely, it alerts a business owner when the business is running short. Cash flow statements are invaluable tool s that permit business \nowners to make smart, timely decisions over the long term. \nCash on Hand Funds that are immediately available to a business, and can be spent as needed. \nCurrent Assets A balance sheet account that represents the value of all assets that are reasonably expected to be converted into cash within one year in the normal course of business. Current assets include cash, accounts receivable, inventory, marketable securities, prepaid expenses and other liquid assets that can be readily conver ted to cash. \nCurrent Liabilities A company's debts or obligations that are due within one year. Current liabilities appear on the company's balance sheet and include short term debt, accounts payable, accrued liabilities and other debts \nDebt Principal Amount borrowed or the amount still owed on a loan, separate from interest \nDepreciation Income tax deduction that allows a taxpayer to recover the cost or other basis of certain property; annual allowance for the wear and tear, deterioration, or obsolescenc e of the property. \nEquity Equity is a stock or any other security representing an ownership interest. On a company's balance sheet, equity is the amount of the funds contributed by the owners (the stockholders) plus the retained earnings or losses. \nFixed Cost A fixed cost does not change with an increase or decrease in the amount of goods or services produced. Fixed costs are expenses that have to be paid by a company, independent of any business activity. It is one of the two components of the total cos t of a good or service, along with variable cost. \nGross Profit Gross Profit is a company's revenue minus its cost of goods sold. It is a company's residual profit after selling a product or service and deducting the cost associated with its production and sale. \nIncome Statement A financial statement that measures a company's financial performance over a specific accounting period. Financial performance is assessed by giving a summary of how the business incurs its revenues and expenses through both operat ing and non- operating activities. It shows the net profit or loss \nincurred over a specific period, typically over a fiscal quarter or year. An Income Statement is also known as a profit and loss statement or statement of revenue and expense. \nInterest Interest is a fee paid for the use of another party's money. To the borrower it \nis the cost of renting money, to the lender the income from lending it. \nInvoice An invoice is a commercial document that itemizes a transaction between a buyer and a seller. It wi ll usually include the quantity of purchase, price of \ngoods and/or services, date, parties involved, unique invoice number, and \ntax information. If goods or services were purchased on credit, the invoice MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 40 of 92 Term Definition \nwill usually specify the terms of the deal and provi de information on the \navailable methods of payment. An invoice is also known as a bill, statement, \nor sales invoice. \nLiquidity Liquidity is the degree to which an asset or security can be bought or sold in the market without affecting the asset's price. Liquidity is characterized by a \nhigh level of trading activity. Assets that can be easily bought or sold are known as liquid assets. The term is also used to define the ability to convert \nan asset to cash quickly. Also known as marketability. Liquidity is often \ncalculated by using liquidity ratios. \nNet Profit Net Profit is your bottom line. This shows how much your company is making on sales after expenses, interest, and taxes. \nVariable Cost A variable cost is a corporate expense that varies with producti on output. \nVariable costs fluctuate depending on a company's production volume. They rise as production increases and fall as production decreases. Variable costs differ from fixed costs such as rent, advertising, insurance and office supplies, which tend to remain the same regardless of production output. Fixed costs plus variable costs equal total cost. \nVendor A vendor is a party in the supply chain that makes goods and services available to companies or consumers. The term is typically used to describe an entity that is paid for the goods that are provided, rather than the manufacturer of the goods. A vendor, however, can operate both as the supplier of goods (seller) and the manufacturer. \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 41 of 92 Cash Flow Statement Template \nThis example was downloaded from the SCORE website. To save space, we show only the first six \nmonths of a 12 -month worksheet. To get an Excel spreadsheet template , go to https://www.score.org/ \nand search key words “cash flow template ”, save the template s of interest and adjust as needed. \n \n Pre-Start-\nup EST Nov 14 Dec-14 Jan-15 Feb-15 Mar-15 Apr-15 Total \nItem \nEST \nCash on Hand (beginning of month) \n \nCASH RECEIPTS \nCash Sales \nCollections from C R accounts \nLoan/ other cash inj. \nTOTAL CASH RECEIPTS \nTotal Cash Available (before cash out) \n \nCASH PAID OUT \nCost of services; includes shop supplies \nPurchases (s pecify) \nPurchases (specify) \nGross wages (exact withdrawal) \nPayroll expenses (taxes, etc.) \nOutside services \nSupplies (office & operations) \nRepairs & maintenance \nAdvertising \nCar, deliver y & travel \nAccounting & legal \nRent \nPhone, Cable, Internet \nHeating oil \nInsurance \nElectricity \nInterest \nOther expenses (all others) \nOther (specify) \nOther (specify) \nMiscellaneous \nSUBTOTAL \nLoan principal payment \nCapital purchase (specify) \nOther startup costs \nReserve and/or Escrow \nOwners' Withdrawal \nTOTAL CASH PAID OUT \nCash Position (end of mont h) \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 42 of 92 For More Information \nBusinessUSA \nwww.business.usa.gov \n \nThis official portal of the United States government provides guides and resources that help businesses \ncomply with business laws and regula tions. It provides self -paced courses on how to apply for financing \nsuch as microloans, how to write a business plan, how to register and run a business, and more. \n \nU.S. Small Business Administration (SBA) \nwww.sba.gov ; www.sba.gov/tools ; www.sba.gov/learning \nSBA Answer Desk: 1 -800- 827-5722 \nThe U.S. Small Business Administration (SBA) website provides resources, answers to frequently \nasked questions, and other info rmation for small business owners. They provide free online tools \nand resources at www.sba.gov/tools . The site provides self -paced information on how to write \nbusiness and strategic plans, how to buy or sell a busin ess, how to compete for government \ncontracts, how to conduct market research, basics of accounting, and more. Al so check out the \nLearning Center: www.sba.gov/learning offers a lo ng list of online courses on topics such as \nattracting investors, cybersecurity, fundamentals of crowdfunding , customer service, and more. \n \nSCORE \nwww.score.org . \nSCORE is a nonprofit association dedicated to helping sm all businesses get off the ground, grow, and \nachieve their goals through education and mentorship. SCORE provides a variety of free online \nresources for start -up small businesses including a gallery of templates for business, finance, and \nmarketing plans. They provide how -to guides and self -paced modules on financing, how to secure \ncontracts, cash flow management, and more . \n \nAmerica Small Business Development Center Network \nhttp://americassbdc.org . \nThe American Small Business Development Center (SBDC) network provides free consulting to \nsmall business owners at all stages of development. This excellent resource provides a variety of \nfeedback and planning assistance to small business owners. Their advisors can help connect you \nto regional and local business resources and lending institutions. \n \nWomen’s Business Center (WBC) \nwww.sba.gov/tools/local -assistance/w bc \nWomen’s Business Centers (WBCs) is a national network of education centers throughout the \nUnited States designed to assist women in starting and growing small businesses. WBCs seek to \n“level the playing field” for women entrepreneurs who still face un ique obstacles in the business \nworld. The network provides comprehensive training and counseling on a variety of topics in \nseveral languages. \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 43 of 92 U.S. Financial Literacy and Education Commission \nwww.mymoney.gov . \n1-888- My-Money (696 -6639) \nMyMoney.gov is the federal government's one -stop website that provides financial education \nresources from more than 20 federal agencies. \n \nFederal Deposit Insurance Corporation (FDIC) \nwww.fdic.gov . \nThe FDIC preserves and promotes public confidence in the U.S. financial system by insuring \ndeposits in banks and thrift institutions for at least $250,000; by identifying, monitoring, and \naddressing risks to the deposit insurance funds; and by limiting the eff ect on the economy and \nthe financial system when a bank or thrift institution fails. \n \nThe FDIC encourages bank lending to creditworthy small businesses. The FDIC encourages small business owners with inquiries or concerns about the availability of credit t o contact the FDIC \nSmall Business Hotline at 1 -855- FDIC -BIZ or www.fdic.gov/smallbusiness\n. Another FDIC \nwebsite, www.fdic.gov/buying/goods provides resources to small business owners who want to \nconduct business with the FDIC. \n For more information about the Money Smart for Small Business Curriculum see \nwww.fdic.gov/consumers/consumer/moneysmart\n. \n \nLocal Resources \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 44 of 92 Pre- and Post -Test Form – Managing Cash Flow Module \nPlease help us assess your learning from this class— Managing Cash Flow. Enter your responses twice: \nBEFORE you take the class and AFTER you complete the class. Circle the number th at shows how \nmuch you agree with each statement. Thank you! \n \n BEFORE Training AFTER Training \n \nStrongly Disagree \nDisagree \nAgree \nStrongly Agree \n \nStrongly Disagree \nDisagree \nAgree \nStrongly Agree \n1. I can describe why cash flow management \nis a critically im portant component of small \nbusiness ownership. 1 2 3 4 1 2 3 4 \n2. I know how to assess the cash flow cycle of \nmy business and make some cash flow projections. 1 2 3 4 \n 1 2 3 4 \n3. I can describe how a cash flow statement can help assess and improve the financi al \nhealth of my business. 1 2 3 4 \n 1 2 3 4 \n4. I can identify at least two ways to manage cash flow in terms of managing costs and potential income. 1 2 3 4 \n 1 2 3 4 \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW PARTICIPANT GUIDE Page 45 of 92 Evaluation Form – Managing Cash Flow Module \nPlease evaluate Managing Cash Flow . Date: _____________________________ \n \nTraining Rating \n1. Overall, I felt the class was (check one): \n Excellent \n Very Good \n Good \n Fair \n Poor \n \nIndicate your agreement with each of these statements by circling a number. \n \n \n \n \n Strongly Disagree \n Disagree \n Neutral \n Agree \n Strongly Agree \n2. I achieved the learning objectives. 1 2 3 4 5 \n3. The instructions were clear and easy to follow. 1 2 3 4 5 \n4. The PowerPoint slides were clear. 1 2 3 4 5 \n5. The PowerPoint slides enhanced my learning. 1 2 3 4 5 \n6. The time allocation was correct for this class. 1 2 3 4 5 \n7. The instructor was knowledgeable and well -prepared. 1 2 3 4 5 \n8. The participants had ample opportunity to exchange experiences and ideas. 1 2 3 4 5 \n \nPlease indicate your degree of knowledge/skill by circling a number. None Advanced \n9. My knowledge/skill level of the subject matter before taking the training . 1 2 3 4 5 \n10. My knowledge/skill level of the subject matter upon completion of the training . 1 2 3 4 5 \n \nInstructor Rating : \nInstructor Name __________________________ ___________________ \n \nPlease rate your instructor by circling a number. \n Poor \n Fair \n Good \n Very Good \n Excellent \n11. Made the subject understandable. 1 2 3 4 5 \n12. Encouraged questions. 1 2 3 4 5 \n13. Provided technical knowledge. 1 2 3 4 5 \n \n14. What was the most useful part of the training? \n \n \n15. What was the least useful part of the training, and how could it be improved? \n \n \nThank you! \n MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 46 of 92 \n \nManaging Cash Flow Instructor Guide MSSB Train -the-Trainer Workshop, Participant Guide \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 47 of 92 \n \n MSSB Train -the-Trainer W orkshop, Participant Guide \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 48 of 92 \nTable of Contents Instructor Guide – Managing Cash Flow Module \n \n(Page nu mbers in this Table of Contents correspond to pages in this document, any other page \nnumber references have not been edited as the module has been imported exactly as is to \nshowcase in the “Dive in Section of the TtT Workshop) \n \nGETTING STARTED …….. ………………………………………………………………………….……………………………………………………49 \nTRAINING OVERVIEW ………………………………………………………………………….……………………………………………5 0 \nTHE CLASS AT A GLANCE ………………………………………………………………………….………………………………………. 52 \nINSTRUCTOR NOTES AND PRESENTATION GUIDELINES………………………………………………………………………….……. 53 \nWELCOME, PRE- TEST, AGENDA, AND LEARNING OBJECTIVES ……………………………………………………………5 3 \nINTRODUCING BOB AND THE WIRED CUP ……………………………………………………………………………………….. 55 \nINTRODUCTIONS: WHERE ARE YOU ON THE CASH FLOW MANAGEMENT CONTINUUM? …………………. 56 \nOPENING BALANCE SHEET FOR TH E WIRED CUP …………………………………………………………………………….…5 7 \nTHREE VIEWS OF CASH FLOW ………………………………………………………………………………………………………….. 61 \nThe Cash Conversion Cycle ………………………………………………………………………………………………….. 61 \nThe Cash Flow Diagram ………………………………………………………………………………………………………. 61 \nCash Flow D iagram Descriptions …………………………………………………………………………………………. 63 \nThe Cash Flow Statement ……………………………………………………………………………………………………. 64 \nWhat Can Bob Do? …………………………………. …………………………………………………………………………. 68 \nSUMMARY, POST -TEST, AND EVALUATION ……………………..…………………………………………………………………… ….…. 69 \n \n \nDISCLAIMER \nThese training materials are intended as general guidance only and may or may not apply to a \nparticular situation based on the circumstances. The materials do not create any legal rights \nor impose any legally binding requirements or obl igations on the Federal Deposit Insurance \nCorporation (FDIC) and U.S. Small Business Administration (SBA). The FDIC and SBA make \nno claims or guarantees regarding the accuracy or timeliness of this information and material. \nThe content of this training mat erial is not designed or intended to provide authoritative \nfinancial, accounting, investment, legal or other professional advice which may be reasonably \nrelied on by its readers. If expert assistance in any of these areas is required, the services of a qualified professional should be sought. \nReference to any specific commercial product, process, or service by trade name, trademark, manufacture, or otherwise does not constitute an endorsement, a recommendation, or a preference by the FDIC and SBA or the United States government. \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 49 of 92 Getting Started \nThese ideas will help you plan and present engaging and productive \nsessions: \n• Effective use of PowerPoint. Use the slides to introduce key concepts only. \nThey are provided to enhance your presentation, they are not the \npresentation. Avoid reading slides to the learners. Add your perspective. \nLearners appreciate examples and brief anecdotes that make the concepts \ncome alive. \n• Introductions. Introductions allow you to break the ice, create active \ninstructor –participan t dialogue, and set the tone for the class. They also \nprovide indicators of the experience levels of your learners. \n• Diversity of learner needs. Assume that some learners are just getting started while others are \nalready business owners. Address the diverse needs of learner groups. \n• Agenda. The agenda helps participants understand how the training will be conducted. \n• Expectations. Discussing expectations gives participants the opportunity to tell you what they hope to learn from the training. \n• Objectives. Estab lishing objectives helps participants place the information to be learned in the \nproper context and ensures that the content is consistent with their expectations. \n• Participant Guide format and contents. The participant guide keeps participants on track wit h the \npresentation. Several worksheets help them apply key concepts to their own specific contexts. \n• Pre-and Post -Tests. The Pre -Test provides a baseline measurement for evaluating the impact of \nthis class. The Post -Test gauges how well participants learned the content. Both the pre - and the \npost-test are on one form at the end of the Participant Guide . \n• Discussion points. Discussion points help participants reinforce learning. \n• Parking lot flipchart/ chart paper. This option is helpful if participants ask que stions that you do \nnot have time to answer. Instead of answering right away, agree to answer at a later time. “Park” the questions on a flipchart or chart paper, and make arrangements to follow up with the \nparticipant(s) after the class. \n• Breaks . No formal breaks are recommended. Encourage participants to take rest room breaks if \nthey need them. \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 50 of 92 Training Overview \nIcons Guide \n Refer participants to the Participant Guide (PG) to locate information, \ndescriptions, or relevant worksheets. \n Engage the group in a conversation about the topic. \n Assess participant comprehension or previous experience with the \ntopic by asking them to complete a quick pre- and post -test. \n Ask “high gain” questions to check comprehension, or present a \nproblem such as “What would you do if this were your business?” \n \nPurpose \nThis module —Managing Cash Flow —is a highly interactive learning experience that \nencourages the participants to focus on cash flow management as an essential competency of \nbusiness ownership. No matter where lea rners are in the development of their businesses, this \n90-minute module encourages them to ask and answer great questions about their business \nand to get ready to interact with accountants to analyze the flow of cash in and out of their businesses. \nThis In structor Guide is the key document for this class. Please read it thoroughly. \nWe provide plenty of white space for you to add notes and examples from your own experience. Please also review the related PowerPoint slides and Participant Guide in detail. \nThese documents contain information or visuals you will reference during the class. \nPreparing for Class \nEach participant will require a Participant Guide (ideally printed two -sided). Participants do \nnot need copies of the slides. Before printing the participant guides , consider adding local \ninformation to the For More Information section. In the space provided\n, list local resources \nthat offer technical assistance or financing options to small businesses. \nObjectives \nAfter completing this training, the particip ants will be able to: \n• Describe the purpose of cash flow management in a start -up small business. \n• Assess a cash flow cycle and make some cash flow projections. \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 51 of 92 • Describe how a cash flow statement can help assess and improve the financial health of a \nstart -up. \n• Identify some ways to manage cash flow in terms of managing costs and potential income. \n• Identify ways to seek out expert technical assistance to improve cash flow management. \nPresentation Time \nTo ensure high engagement levels with your learners, allow a t least 90 minutes to deliver this \nclass. Use the suggested times to personalize the class based on the needs of your participants and the given time. Allow extra time for discussion and questions when teaching larger \ngroups. \nMaterials and Equipment \nYou w ill need the following materials and equipment to present this class: \n• Instructor Guide (for your use only). \n• Participant Guide – ideally printed two- sided – for each participant. As noted above, you may add \nlocal resources to the For More Information sectio n of the Participant Guide . \n• PowerPoint slides (for your use only). \n• Audiovisual equipment such as a computer, Microsoft Office PowerPoint, overhead projector, and \nmicrophone, if appropriate. \n• Optional: flipchart easel, chart paper, markers. \nDiscussion Points \n• Managing cash flow is a core competency of small business ownership. \n• A balance sheet tells a compelling story. \n• A cash flow statement continues that story. Use it to monitor projected and actual income \nand expenses. \n• Plan for seasonal fluctuations. \n• Try to maintain a rapid cash conversion cycle. \n• Manage your paperwork like a pro. \n• Ask an accountant for advice. \nNote \nThe participants should ideally attend this class after they complete the Financial \nManagement module in the Money Smart series. Financial Manage ment introduces \nfundamental cash flow concepts and terms. \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 52 of 92 The Class at a Glance \nThis 90 -minute experience includes several group discussions designed to actively engage the \nlearners. Pay careful attention to timing and pacing. \n \nTime (in minutes) Activity Instructor Comments/Notes \n10 Welcome, Pre- Test, Agenda, and Learning \nObjectives In the back of the Participant Guide; \nparticipants complete the BEFORE \nTraining column \n10 • Introducing Bob and The Wired Cup \n• Introductions: Where are YOU on the \nCash Flow Management Continuum? \n15 • Opening Balance Sheet for The Wired Cup \n• A Few Notes About Debt \n40 Three Views of Cash Flow \n• The Cash Conversion Cycle \n• The Cash Flow Diagram \n• The Cash Flow Statement \n• What Can Bob Do? \n15 Summary, Post -Test, and Evaluation In the bac k of the Participant Guide; \nparticipants complete the AFTER \nTraining column \nTotal: 90 \n \nOptional Ideas \n Consider inviting a panel of small business owners to provide stories about how they \nmanage their cash flow. \no Note: Time management c an be a challenge. Most panelists need at least 15 \nminutes to share stories and respond to questions. If you invite panelists, you may need to adjust the schedule. \n Another option: schedule a follow up session about two weeks after this class. The participants can return with their cash flow statements to share ideas with each other and advisors. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 53 of 92 Instructor Notes and Presentation Guidelines \nInstructor Notes Presentation Guidelines \n \n10 minutes \nSlide1 \n \n Welcome, Pre -Test, Agenda, and Learning \nObjectives \nWelcome to Managing Cash Flow. Taking this class is an \nimportant step to building a better financial future for you and \nyour family. \nAs a small business owner, it is important to know how much cash is moving in and out of your business. You need to think \nahead in order to meet financial obligations and run a profitable \nbusiness on a long -term basis. This class introduces some basic \ncash flow concepts that can get you started. \nMy name is ___________. ( Briefly introduce yourself.) \n \nSlide 2 \n \n \n \n \n \n \n Pre-Test \nBefore we begin, please assess what you already know about this topic. Turn to the Pre - and Post -Test Form in the back of your \nparticipant guide and complete the BEFORE Training column. \nAt the end of this class you will complete the AFTER Training column. \nIf you need to leave a bit early, make sure to return your \ncompleted Pre- and Post -Test and the Evaluation Forms on the \nlast pages of your Participant Guide before you leave. \n \nFacilitation Note \n Do not read the slides to the learners. Instead, use the \nslides to actively engage learners in two -way \nconversations. Add the occasional brief story or anecdote to illustrate key concepts. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 54 of 92 Instructor Notes Presentation Guidelines \nSlide 3 \n \n \n \n \n \n \n Agenda \nHere is the agenda for today’s class. We will discuss concepts, \nstart some self -assessments, complete some interactive activities, \nand respond to your questions. \nTime Management \nPlease help us stay on schedule. We do not include a formal break. If you need to visit the rest room, please feel free to do so. \nOptional: Explain Parking Lo t Chart Paper \nIf you have questions about your own business that we do not have time to answer, I will “park” your questions on chart paper. \nWe can make arrangements after this class to help you find some \nanswers. \nGround Rules \nOne of the best ways to learn is from each other. You probably \nhave some great ideas to offer. You may know of a process that \nworks well for you or some pitfall to avoid. Please speak up. Also, \nif something is not clear, please ask questions! \nParticipant Materials \nEach of you should h ave a copy of the Managing Cash Flow \nParticipant Guide . It contains: \n• Information and discussion points about this topic. \n• Worksheets for you to start in class and finish up on your \nown \n• A Toolkit of Resources to help continue your self -\neducation (including a list of agencies that provide technical assistance to small businesses) \nPlease note that we will not have time to review the entire Participant Guide in class. We suggest that you review it in detail \non your own time. \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 55 of 92 Instructor Notes Presentation Guidelines \n \nSlides 4 and 5 \n \n \n \n \nLearning Obj ectives \nFacilitation Note: \n Do not read the objectives to the learners. Instead, \nwhenever possible, briefly paraphrase the objectives. \n Point out that you will use the Bob’s Wired Cup case to \nintroduce concepts. \n Emphasize that what is most important is how these \nconcepts apply to the unique situations of the learners. \n \n10 minutes \nSlide 6 \n \n Introducing Bob and The Wired Cup \nWe will use a realistic example to review a new business owner’s \ncash flow management decisions. As we review Bob’ s cash flow \nissues, you may find that these concepts relate to your own cash \nflow questions. \nFacilitation Note: \n The case is theoretical. If participants ask questions about \nthe numbers on Bob’s statements, remind them the case \nis intended to introduce fundamental cash flow concepts . \n Ask one of the participants to read Bob’s story out loud \nfrom page 4 in the Participant Guide. \n \n \n \n \n From Participant Guide : \nIntroducing Bob and The Wired Cup \nBob recently opened a new bakery café, The Wired Cup. The café \nhas a great location in a small college town. To get started, Bob \ninvested $30,000 of his own money and received a $20,000 loan \nfrom a commercial bank. He spent $45,000 on start- up costs, \nleaving $5,000 to run the business. \nThe Wired Cup is already popular wit h students, university staff, \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 56 of 92 Instructor Notes Presentation Guidelines \nand neighbors. Everyone loves the coffee and baked goods. A \ncollege dean has started to order croissants for the faculty dining \nhall. Bob is building a great new business. \nHowever, Bob has concerns. He has not yet paid himsel f, and he \nwonders when he can. The $5,000 is almost gone. Given that his \nkey customers are students, he assumes many will go home over \nholiday breaks and the summer. Questions Bob is now asking: \n• How will he pay his bills if there are fewer customers? \n• Will he have enough money to ramp up again in September? \n• Should he buy in bulk to reduce costs? \n• Will suppliers allow Bob to buy on credit, or does he still have \nto pay cash? \nThe good news is that Bob is thinking ahead . He has time to find \nsome solutions. As we review the Wired Cup’s cash flow issues, \nyou will be able to apply these concepts to your own business. \n \n Facilitation Note: \n Thank the volunteer for the assistance. \nSlide 7 \n \n \n Introductions: Where are YOU on the Cash Flow \nManagement Continuum? \nBefo re we go on and learn more about Bob’s cash flow \nexperiences it will be helpful to learn your backgrounds and \nexperiences so far with cash flow management. \nFacilitation Note: \n Ask the participants to briefly introduce themselves and \ntheir experiences so far with cash flow management – \nfrom beginner to expert. \n Validate each person’s experience level as valid. \n Encourage the experts in the class to offer ideas and \nexamples from their experience to the rest of the group. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 57 of 92 Instructor Notes Presentation Guidelines \n15 minutes \nSlide 8 \n \n \n \nSee next page for a copy of the \nOpening Balance Sheet Opening Balance Sheet for The Wired Cup \nPlease turn to page 5 in your Participant Guide to see The Wired \nCup’s opening balance sheet. \n \nFacilitation Note: \n Given the layout of the opening balance sheet, it is not \neasy to read the numbers on the slide. Ask the \nparticipants to turn to the opening balance sheet on page \n5 in their Participant Guide while you refer to the opening \nbalance sheet on the next page of this guide. \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 58 of 92 Year 1 Opening Balance Sheet \nThe Wired Cup \n Assets \n Liabilities \nCurrent Assets: \n Current Liabilities: \n Cash $ 5,000 \n Bank Note $ 3,371 \nAccounts Receivable $ - \n Accounts Payable $ - \nPre-Opening Expenses \n Accounting $ 250 \n Long Term Liabilities: $ 16,629 \nAdvertising $ 500 \n Bank Charges $ 350 \n Total Liabilities $ 20,000 \nCable/Internet Services $ 200 \n Insurance $ 2,000 \n Ingredients $ 3,500 \n Janitorial Supply $ 75 \n Lease $ 1,350 \n Legal Fees $ 2,500 \n Licenses/Fees/Permits $ 1,500 \n Payroll $ 2,400 \n Payroll Taxes $ 360 \n Telephone Services $ 150 \n Utilities $ 365 \n Total Current Assets $ 15,500 \n Equity \n Owner's Capital $ 30,000 \nFixed Assets: \n Kitchen Equipment $ 9,000 \n Total Equity $ 30,000 \nLease Hold Improvements $ 18,200 \n Office/Techn Equipment $ 2,300 \n Total Fixed Assets $ 29,500 \n \n Total Assets $ 50,000 \n Total Liability & Equity $ 50,000 \nAssumption s: Loan $20,000 5 years 14.54% ; Payroll 3 workers $10/hr = $30/hr * two 40 hr. weeks = $2,400 \n \n \nNote: This balance sheet lists pre -opening expenses as current assets. In this example, the \npre-opening expenses listed were expensed or realized before the end of the \nyear. Entrepreneurs should always keep track of pre- opening expenses as som e may or may \nnot be considered by financial institutions or investors as a business asset or owner \ninvestment/equity. MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 59 of 92 Instructor Notes Presentation Guidelines \n Opening Balance Sheet for The Wired Cup, Cont. \nThis opening balance sheet tells a story: how much money Bob \nhad to start his business, how he financed it, what he did with that \nmoney, and how much was left over to run the business. \nThe balance sheet tells us that Bob invested $30,000 of his own \nmoney or owner’s equity, and he borrowed $20,000. The $20,000 loan is over five years, with an 14.54% interest rate. In year one, Bob will pay back $3,371 of principal and will pay the remaining \nbalance of $16,629 in years two through five. \nIf you do not have the necessary capital to start your business, y ou \nhave two options to get the capital that you need: \n• Equity. Friends, family and/or business partners invest in your \nbusiness. They provide you with cash; you give them equity or \na piece of the business. \n• Debt. You borrow the money from family, friends, or a lending \ninstitution, such as a bank. You do not give up equity or \nownership but you do have to pay back the loan. You will pay \nback both principal and interest. There are many types of \nlending or borrowing options. \nSlide 9 \n A Few Notes About Debt \nIt takes some effort to obtain a small business loan. As part \nof the process you will need to provide a business plan. The \nMoney Smart for Small Business module, Planning for a \nHealthy Business provides a lot of information about various \nways to plan a succe ssful business. \nKnow your credit score. The higher your score the lower the risk for creditors. For more information, attend the Money \nSmart module on Credit Reporting . \nBanks have differing criteria for lending. Talk with your local bankers before you ne ed a loan. The stronger your \nrelationship, the more supportive they will be to help you \nsecure a loan if you meet their lending criteria. The Money \nSmart module on Banking Services can help. Be prepared to \npersonally sign for the loan. If a business is una ble to meet \nits financial obligations, you will be held responsible. Also be prepared to pledge collateral. \nOne last note: manage your credit cards to avoid high fees \nand interest. B usiness credit cards may be one of the mo st \nexpensive forms of business c redit. \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 60 of 92 Instructor Notes Presentation Guidelines \nSlide 10 (This slide is \nintentionally repeated – it is the \nsame as slide 8.) \n \n \n \n \n \n \n \n \n Back to the Opening Balance Sheet \nIn total, Bob had $50,000 to spend to open The Wired Cup. He spent $45,000 on equipment, materials, and other assets \nas indicated on the balance sheet ($29,500 fixed assets and \n$15,500 for current assets = $45,000). \nHe had $5,000 cash remaining to run his business ($50,000 -$45,000 = $5,000). \nIf I were Bob’s lender, a potential business partner, or a \nvendo r, I would look at this opening balance sheet and ask \nthe following: \n• Has he invested enough of his own money in this venture? \n• Did he finance the business wisely? For instance, does he carry \ntoo much debt? The terms and time requirements for loan \nrepayment can make a huge impact on cash flow. \n• Did he wisely spend the $50,000 ? \n• Is there enough available cash left over to run the business? Is $5,000 enough to carry him through a six month period? \nWe do not have time to discuss these questions and the \nanswers i n detail. I am just explaining that an opening \nbalance sheet tells a story which can prompt constructive \ndialogues with stakeholders. \nA balance sheet tells a story, but it is just the first chapter. The \nstory continues on into the cash flow statement. \n \nClarify and Transition \nAre there any more questions about opening balance sheets \nbefore we move on ? \n \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 61 of 92 Instructor Notes Presentation Guidelines \n40 minutes \nSlide 11 \n Three Views of Cash Flow \nLet’s look at three views of cash flow: a cash conversion \ncycle , a cash flow diagram , and The Wired Cu p’s cash flow \nstatement . \nCombined together, these three views provide a \ncomprehensive overview of a cash flow system. \n \nSlide 12 \n \n \n Slide 13 \n \n \n \n The Cash Conversion Cycle \nA cash conversion cycle consists of three components: \n1. A business pays for raw materials. \n2. The business makes a product or service using those materials. \n3. The business sells products or services. \nThe trick is to know how long it will take to complete the cycle. That rate of conversion impacts cas h flow. \nIf you have a short cycle , you sell inventory or turn it back \ninto cash quickly, which puts money back into the cash flow \nsystem. \nIf you have a long cash conversion cycle you will not be able \nto use that money while inventory is sitting on your sh elves. \n \nThe Cash Flow Diagram \nAnother way to describe cash flow is with a diagram, like the one on page 7 in your Participant Guide . Page 8 provides \ndescriptions of the elements that make up this diagram. \nWe will review this diagram to get a big picture o f cash flow \nand how all the elements – the pipes and valves – work \ntogether. \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 62 of 92 \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 63 of 92 Instructor Notes Presentation Guidelines \n \n \n \n \n Cash Flow Diagram Descriptions \nThis diagram is a representation of how cash flows in and out \nof the system. It depicts man y decision points or valves you \ncontrol. \nWhen you start a business, money flows into the business via \ndebt or equity. I n the case of The Wired Cup, Bob had \n$30,000 of his own money invested in the business, the \nequity bucket in this diagram. In addition, B ob borrowed \n$20,000, the debt bucket. The combined $50,000 is the \navailable cash working capital. \nThe valves in this cash flow diagram represent decision \npoints. Your decisions impact cash flow and increase or \ndecrease your probability of success. \nSome va lves are open all the time such as sales taxes and \ndebt. You have to pay them. They are a constant drain on \nyour cash, which is why they are on the bottom. \nSome valves are partially open, like the sales, general, and \nadministrative valves. What you spend is up to you. As you \nspend available cash, the balance in the center tank drops. \nInventory . You spend money on raw materials, labor, and \nother direct costs to produce a product to sell -- assuming \nyou are producing a product; the same principles apply for \nservices as well. If you spend a lot on inventory you tie up \nyour money until you sell the inventory, and turn it into cash. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n Fixed assets are usually expensive: buildings, upgrades to \nspace, vehicles, equipment, computers, and technology. If you purchase an expensive fixed asset , it ties up cash. A \nbetter option may be to lease to k eep cash flowing. \nProfit generator (sales pump ). In the top left corner, we \nhave a sales pump. Keep this primed to pump sales back into the system. \nAccounts receivable (A/R). You may make a sale, but not \nreceive the cash until you collect it. Ultimately you want to \nconvert A/R into cash, so it flows into the center tank and \nbecomes available. Some A/R will not be paid; this is called bad debt. Usually after 90 days, an A/R will not be paid. \nWhen you extend credit and create an A/R, you need to \nfollow up t o ensure you receive the payment. \nAccounts payable (A/P ). In the center tank, accounts \npayable are represented by bricks. This is money owed to vendors and suppliers who extend credit to you. For \nexample, you receive a product or service but you have not \nyet paid for it. You still have use of that money. The bricks elevate the water. Instead of having to pay for a product or \nservice, you can use that money for marketing or paying MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 64 of 92 Instructor Notes Presentation Guidelines \n \n \n \n \n \nSlide 14 \n \n \n \n A copy of the cash flow \nstatement is provided on the \nnext page. Descr iptive details \nbegin on page 19 of this guide. another bill. \nIt is challenging to balance accounts payable and accounts rece ivable. You want customers to pay you as quickly as \npossible (cash in) and you want to pay your vendors as slowly as possible (cash out). Ultimately, you want to have and be generating excess cash \nflow from profitable operations or ECFPO. The \nshowerhead r epresents your paycheck. \nThe broken pipe represents how depreciation can be used to \nreduce your taxable income. We won’t get into this in this \nclass for time management issues. This is a good question to \nshare with an accountant. \nThis diagram represents a cash flow system and decision \npoints you control. Of course, in business we would not use a diagram. We use a statement which tells a story with \nnumbers. \n \nThe Cash Flow Statement \nPlease turn to page 10 in your Participant Guide to see a cash \nflow statem ent for The Wired Cup. \n \n \n \n \n \n \n \n \n \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 66 of 92 \n Instructor Notes Presentation Guidelines \n The Cash Flow Statement, cont. \n \n \n The cash flow statement is a valuable decision making tool \nfor business owners, investors, and creditors . It allows \neveryone to make smart, informed decisions about your \nbusiness. \nIn this example, Bob made projections based on two months \nof actual experience in August and September. He does not \nknow how much seasonality --su mmer vacations at the \ncollege -- will affect business. He assumes the impact will be \nsignificant. \nThe first column lists money in categories such as loan \nreceipts, owner’s capital, and so on, and money out such as \noperating expenses for accounting, accounts payable/debt, \nadvertising, and so on. \nThe second column represents Bob’s opening balance sheet start -up costs. You would not typically see this on a cash \nflow statement. We include this information to demonstrate \nhow elements of an opening balance sheet t ransfer over to \nthe cash flow statement. The rest of the columns represent monthly income and \nexpenses. As mentioned before, Bob has had two months of \nactual expenses. Based on what he knows so far, he projected income and expenses for the rest of the yea r. \nNotice that Bob had $5,000 in available cash. His sales were $25,000, and sales tax was $1,563. \n• A note about sales tax. Put this in a separate bank account. Do not co -mingle tax money in your regular \nbank account. You are collecting tax on behalf of the \ngovernment. This is not your money to use. Most likely, \nyou will be required to pay this quarterly or even monthly to the gover nment. The payroll taxes rate used \nin this example is 15%. You will need to determine the \nappropriate local, state, and applica ble federal taxes. \n \nIn August, The Wired Cup had a total inflow of cash: $26,563 \n($25,000 of sales revenue plus $1,563 of sales tax). That means that at the end of August, Bob’s total available cash \nwas $31,563 ($5,000 + $26,563 = $31,563). \nIf we look at the bottom of the spreadsheet for August we see that $29,253 was the cash out flow for the month. \n• Some cash outflows are fixed month to month, such as Bob’s \nlease payment of $1,350 and the cable/Internet payment of \n$200. \n• Some cash outflows are variable, s uch as advertising and \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 67 of 92 Instructor Notes Presentation Guidelines \nutilities. Variable amounts fluctuate from month to month. \nYou have some control over how cash flows in and out of \nyour business. For example, for sales you decide what you \nwill sell, where, to whom, how, and at what price. The same \ngoes for expenses. You can decide what space to lease, how much debt to carry, when to advertise, when and how much \nraw materials to purchase, and how many staff to employ. \nIn August, Bob has available cash of $31,563 and cash outflows of $29,253. $31,563 - $29,253 = $2,309 in his bank \naccount at the end of August. This $2,309 becomes the \nbeginning balance for the month of September, and the \nprocess starts all over again. \n• In September: $2,309 + $27,000 + 1,688 = $30,997 available \ncash for September. Month ly expenses are $29,778. $30,997 - \n$29,778 = $1,218 cash available at the end of September, \nwhich becomes the beginning balance for October. \nTo sum up: Bob is happy. The Wired Cup is doing well, but \nhe is worried about the rest of the year. He projects he will be able to pay all of his financial obligations but he will be \ncutting it close. \nSome business owners overestimate revenue and underestimate costs. This means they will at some point have \na cash flow crunch and will not have cash available to meet \ntheir obligations. To prevent this, consider developing a \ncouple of cash flow statements: \n• Best case scenario: This would be an ideal situation where all \nyour dreams come true. \n• Worst case scenario: This would be a much more conservative \nscenario where you do not get the sales revenue you would \nhope for and costs are higher. \n• Most likely: This would be like the Goldilocks story —not too \nhot, not too cold, but just right. It is the most likely scenario, \nsomewhere between a best and worst case. \nIn this example, B ob created a most likely projection. Given \nthat he knows the students and faculty leave for vacation, in July he projects a negative $4,316. \nYou can’t have a negative cash situation! Negative cash \nmeans game over. \nWhat you want to achieve is excess cash flow from profitable \noperations. This is when you can shower yourself with some \ncash. \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 68 of 92 Instructor Notes Presentation Guidelines \nSlide 15 \n \n \n \n \n \n Slide 16 \n \n What Can Bob Do? \nPlease turn to page 11 of the Participant Guide . Bob needs to \nturn some valves wide open and turn down others in order to \nhold on to his cash as long as possible. If you were Bob’s \nadvisors, what would you advise him to do? \n• How can Bob increase sales revenue at The Wired Cup? \n• How could Bob negotiate a better deal or two with his vendors and suppliers? \n• How can Bob plan for the seasonal ups and downs in \nhis business? \n• Is it wise for Bob to use a credit card to offset cash \nflow issues? \nFacilitation Note: \n These questions motivate the participants to think \nthrough common cash flow management scenarios. \n Thank participants for their ideas and suggestions. \n After the participants have a chance to offer \nsuggestions, reveal the next slide which provides some answers. \n \nPossible Ideas for Bob \nNote that some of the ideas you suggested are on this slide. \nNice job advising Bob! \n• Bob can incr ease the flow of revenue into his business. \n• Bob can reduce outflow, perhaps by making arrangements with vendors or his landlord. If Bob pays his entire rent in 10 \nmonths he will pay more during the 10 busy months and no \nrent in July and August which promi se to be slow. \n• Bob might cut back when he expects business to slow down. \nPerhaps his staff can work fewer hours or he can cut back on \nmenu items. \nThe point is that by managing cash flow, Bob is able to \ncontrol his business over the long term. He can be s trategic \nand plan ahead. \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 69 of 92 Instructor Notes Presentation Guidelines \n15 minutes \nSummary, Post -Test, and Evaluation \nSlide 17 \n \n \n \n \n \n \n Slide 18 \n \n \n \n \n What NOT to Do \nNever use your sales tax as a financing option. Some business \nowners use sales tax in a cash crunch hoping they replace the \ntax w hen things look up. This is a risky bet. Penalties are \nhigh for not paying taxes on time. \nIf you anticipate that you might miss or be late on a loan payment, talk to your loan officer as soon as you know. Loan \nofficers understand cash flow and typical bus iness \nchallenges. It is in their interest to help. They don’t want to see you fail. They make money when you are successful and pay back the principal and loan interest. \n• Do not pay vendors late; they can cut off supply. \n• Do not overestimate revenue. This is a common mistake \nmany new business owners tend to make. \n• Do not underestimate costs. Again, this is a common mistake in start -up businesses. Do your homework to find \nout the real costs of doing business. \nIt Is Professional to Ask for Help \nIt is not a sign of weakness if financial management is new \nfor you. Find a great accountant or technical advisor at \nSBDC or SCORE who can explain cash flow in ways that \nrelate the concepts to your own business. \nAn accountant will encourage you to use a computer to mana ge your cash flow documentation. If you do not already \nuse financial management software, take a course to develop this skill. You also need to manage your paperwork in a professional manner. Set up a reliable filing system to keep \ntrack of all financial documents such as tax forms, receipts, \ninvoices, and so on. \n“Co-opetition”is a real term. Competitors can be good \nadvisors as they cope with the same cash flow issues you do. Find ways to cooperate and share information with them. \nThey have experience to sh are. \nCheck out the Toolkit of Resources in your Participant Guide \nfor ideas about where to locate technical assistance. \n \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 70 of 92 Instructor Notes Presentation Guidelines \nSlide 19 \n \n \n \n \n \n \n \n \nSlide 20\n \n Key Points to Remember \n• Managing cash flow is a core competency of small business \nownership. \n• A balance sheet tells a compelling story. A cash flow statement \ncontinues that story. Use it to monitor projected and actual \nincome and expenses. \n• Plan for seasonal fluctuations. Every business has ups and \ndowns. Ask some of your competitors when t heir usual slow \ntimes tend to occur. \n• Try to maintain a rapid cash conversion cycle. Try not to tie up too much cash in inventory. Lease equipment instead of buying \nit. If you do buy equipment, buy used whenever you can. \n• Manage your paperwork like a pro. Your accountant will \nexpect to see spreadsheets, an accounting program, well -\norganized receipts, invoices, and financial statements such as \nbanking and credit card statements. \n• Ask an accountant for advice. Ideally this class has helped you \nprepare for a seri es of helpful conversations. \n \nToolkit of Resources \nThe Toolkit in the back of your Participant Guide provides \nhelpful information such as: \n• A glossary of common cash flow terms. \n• A sample cash flow template (get the complete template \nonline). \n• Tips for negotiating better terms with customers, vendors and suppliers, and landlords. \n• A list of great resources where you can get more information. \nMany of these are free or very inexpensive. \n \nFacilitation Note \n If you added Local Resources to the list in the \nParticip ant Guide , point out some of these. \n Clarify and Transition \nAre there any questions before we wrap up? \n \n ? MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 71 of 92 Instructor Notes Presentation Guidelines \nSlide 21 \n \n Pre- and Post -Test and Evaluation \nPlease turn to the Pre - and Post -Test form in the back of your \nParticipant Guide . \nIf you have not already done so, complete the BEFORE \nTraining column to assess what your knowledge was before \nyou participated in this class. Then complete the AFTER Training column. \nTake a few minutes to complete the Evaluation Form as well. Please return b oth forms to me before you leave. \nThank you for your feedback and comments. \n \n \n \n \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 72 of 92 MSSB Template for TtT Sessions: \nMSSB Plan of Action Worksheet Template \n Page 73 of 92 \n Considering adopting Money Smart for Small Business (MSSB) or other \nMoney Smart (MS) Products? \nWHAT MSSB MODULES CAN I PROVIDE? WHO CAN OFFER IT AND WHEN? \nDetermine whether these modules can be taught by your organization’s staff, volunteers or partner organizations; \nwhen in the calendar year; and who would be your target audience \n Staff \n Volunteer \n Partner \nModule Target Audience Date/Time Teacher/ \nInstructor \nOrganization Types \nCredit Re porting \nTime Management \nRisk Management \nFinancial Management \nInsurance \nRecord Keeping \nTax Planning and Reporting \nBanking Services Available for Small Businesses \nSelling a Small Business and Succession Planning \nIs Owning a Business a Good Fit for You? NEW! \nPlanning for a Healthy Business NEW! \nManaging Cash Flow NEW! \n \nWhat other MS Products are of interest \nto clients/customers/members? My \nOrganization 1 2 3 \nMoney Smart for Adults \n(Available in various languages) \nMoney Smart for Young People \n(Caregiver and Teacher guides available \nin Spanish) \nMoney Smart for Older Adults \n(Available in Spanish) Benefits and interests of offering MS \nby the organization: What are the small business development \nservices the organization provides that can \ncomplement the MSSB Curriculum? \nEligible MS Alliance* member? Yrs. experience** _____ \n Potential Partners \n1 \nEligible MS Alliance* member? Yrs. experience** _____ \n2 \nEligible MS Alliance* member? Yrs. experience** _____ \n3 \nEligible MS Alliance* member? Yrs. experience** _____ \n*A regulated financial institution, a nonprofit, a government entity ** Yrs. experience training small businesses, in technical assis tance, mentoring, \nand coaching \n \nNow that you’ve identified your interests and resources, please \ndiscuss your plans with your Money Smart representative, \ndownload the curriculums and join the Money Smart Member \nAlliance! More at: www.fdic.gov/moneysmart \n \nNext Steps: \n \n \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n \n \nMANAGING CASH FLOW INSTRUCTOR GUIDE Page 74 of 92 \nMSSB Template for TtT Sessions: \nMSSB TtT Invitation and Agenda Template \n Page 75 of 92 \n \nOrganization A and Organization B \nInvite you to \nWho should attend? \nAnyone whose target market \nis aspiring and existing \nentrepreneurs and has a \nmission to assist small \nbusinesses ; staff of \ncommunity -based \norganizations that offer small \nbusin ess development services \nand loans or work with \nentrepreneurs ; financial \ninstitutions that have small \nbusiness customers ; local, \nstate and federal government \norganizations that provide \nresources and information to \norganizations or entrepreneurs. \n \nRegistrat ion instructions at: \n[Provide a link/other \ninformation] \n \n \nFor more information \nabout MSSB go to \nww.fdic.gov/moneysmart \n 1:00 PM WELCOME, INTRODUCTIONS and OVERVIEW OF MSSB \n• Train -the-Trainer learning objectives \n• MSSB: What it is, Why it was created, Who benefits, How they \nbenefit \n• Overview of the 13 MSSB modules \n1:20 PM DEEP DIVE INTO ONE MSSB MODULE \n• MSSB I nstructors explore the entrepreneur experience by \nlooking inside one of the MSSB Modules \n• Learn the features of the MSSB Curriculum including how to use \nits 3 components: Instructor Guide, Participant Guide and \nPowerPoint slides \n2:20 PM BREAK \n2:35 PM TOOL KIT OF MSSB RESOURCES \n• Design your MSSB program: stand-alone or a combination of modules? Offer directly or through referrals? \n• Working with experts \n• Resources: Training Tips, Sample Instructor Planner, pre and \npost-tests and evaluation forms , case studies, interactive tools \n2:55 PM BEST PRACTICES, NEXT STEPS \n• How to join the MSSB Alliance \n• How to download MSSB Modules and promotional materials \n• MSSB Alliance Town Hall meeting conference calls to learn how \norganizations currently use MSSB \n• Plan of Action exercis e to outline an MSSB support system \n3:30 PM ADJOURN \n \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 76 of 92 \n \nFor partner organizations \nDate: \ninsert date \nTime: \ninsert time \nLocation: \ninsert location \n \n \nDate: \ninsert date \nTime: \ninsert time \nLocation: \ninsert location \n \n \nDate: \ninsert date \nTime: \ninsert time \nLocation: \ninsert location \n \n What and Why? \nMoney Smart for Small Business (MSSB) is an instructor-led curriculum that \nprovides a practical introduction to key topics related to starting and managing a \nbusiness. Developed jointly by the Federal Deposit Insurance Corporation \n(FDIC) and the U.S. Small Business Administration (SBA) in 2012, this free resource has 13 mod ules, is available for download and in Spanish. A list of \nMSSB Alliance members is available at the FDIC website and is updated \nperiodically as a reference for organizations or individuals that want to know who is offering MSSB near them. There is no cost, and it takes minutes to join \nthe Alliance by completing a short online form . MSSB Alliance members \nconvene on a quarterly basis to share their experiences on MSSB Town Hall \nconference calls. \n \nTraining Objectives: After completing a Train- The-Trainer \nworkshop participants will be able to: \n1. Present the MSSB Curriculum with confidence. \n2. Explain how participants can become members of the MSSB Alliance and \nuse the MSSB Curriculum to provide introductory business training to aspiring and existing entrepreneurs in their communities. \n3. List and describe at a high level, the goals and objectives of the MSSB Curriculum and assist participants in align ing MSSB goals with their \norganization’s mission and strategic objectives. \n4. Describe several ways to customize a M SSB Program to meet the diverse \nneeds of small business owners who represent a range of business \ndevelopment stages and learning needs. \n5. Identify best practices for working with subject matter experts to co-train \nsome modules. \n6. Describe effective ways to make the content of each module compelling and engaging. \n7. Define best practices for evaluating the quality and impact of the MSSB \nProgram within the MSSB Alliance Member organization. \n8. Provide resources and tips to ensure MSSB inst ructors host a successful \nMSSB training program. \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 77 of 92 \n Checklists \nPreparation \n \nComplete \n() Action Item Description/ Details Notes \n Attend a Train -the-\nTrainer Workshop or read \nthis Train -the-Trainer \nCurriculum \n Order the CD with the \nMoney Smart materials Go to https://catalog .fdic.gov/, click on \nthe Money Smart -Teach category, and \nthen go to the Money Smart for Small \nBusiness subcategory. \n Select the modules you \nwant to include in your program The Module Selection Guide in this guide \ncan help. \nYou may need to adapt your program based on feedback and questions the small \nbusiness owners ask during classes. \n Thoroughly review the \nInstructor Guide, Participant Guide, and PowerPoint for each \nmodule you select to teach If you plan to co -train with an outside \nexpert, meet ahead of time to clarify \ntiming and expectations. \nMake sure any experts or guest panelists \nalso get access to these materials. \n Adapt the timing to fit \nyour specific needs The time estimates in the Instructor \nGuides are flexible. Adapt to fit your \nallotted t ime, the number of participants, \nand estimations of their knowledge \nlevel(s). Allow plenty of time for \ndiscussions, activities, and question- and-\nanswer sessions. \n Add local resources to the \nParticipant Guide , or \ncreate a handout List local resources the participants can \ncontact to learn more about the topic or to receive technical assistance. \n Print the Participant \nGuides (two -sided) Print o ne for each participant. They will \nnot need copies of the slides; the \ninformation in the slide decks is detailed \nin their guides. \n \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 78 of 92 \n Sample Instruction Planner \n \nConsider creating an instruction planner like the sample below. In this example, the trainer is responsible for \nsetting up and processing activities that reinforce the topics. The expert is responsible for delivering information \non the topics. They share responsibility for implementing the pre -and post -test assessments. This example \nbalances content (knowledge to be shared) and process (participants apply the knowledge to their own \nbusinesses). In order for a plan like this to work, the trainer and the expert need to agree ahead of time on who \nwill handle what. \n \nEstimated \ntime Topic Lead Notes \n5 Welcome/Overview Trainer \n10 Icebreaker and/or Pre -Test Both \n5 Key Topic 1 Expert \n5 Group Discussion Trainer \n5 Key Topic 2 Expert \n5 Group Discussion Trainer \n15 Break \n10 Key Topic 3 Expert \n5 Group Discussion Trainer \n5 Key Topic 4 Expert \n5 Group Discussion Trainer \n5 Summary and Post -Test Both \n10 Evaluation and Next Steps Trainer \nTotal: 90 \nminu tes \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 79 of 92 \n Training Day \n \nHere are some ideas that can help ensure each class is effective. \nComplete \n() Action Item Description/ Details \n Set up participant \nmaterials before the participants arrive • Participant Guides \n• Name tags \n• Note pads and pens \n• Water, coffee, snacks \n Instructor Guide(s) • One for the trainer and one for each expert \n Slide projector and screen • Upload the PowerPoint slide deck for the module(s) \n• Test run to ensure the slides are visible to all participants \n• Have an extra bulb and batteries (if using a remote) on hand \n Chart paper and markers • Set up a Parking Lot ahead of time; when you need it, turn to \nthe page . This helps you save time and avoid turning your \nback on the participants . \n• Use to illustrate key points and to capture your partic ipants’ \ncomments or recommendations \n• Set up a Parking Lot chart for questions you do not have \ntime to answer . Make arrangements to follow up after class . \n Room set up • Ideally, set up tables and chairs in a U -shaped arrangement \nso everyone can easily see th e slides and each other \n Collect data • Collect evaluation forms \n• Identify other modules the participants would like to cover \nnext. \n \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 80 of 92 \n Success Tips \n \nThe MSSB Train -the-Train er instructors/facilitators should have relevant instructor/facilitator skills and \nexperience. The FDIC may conduct orientation workshops to familiarize potential instructors with the \ncurriculum, but neither the FDIC nor SBA certifies trainers to deliver the MSSB curriculum. \n \nAs an instructor, you are responsible for: \n \n• Identifying the learning and communication needs of participants \n• Focusing and directing participants \n• Aiming discussions toward course objectives \n• Making sure every participant has the opportunity to contribute to the discussion \n \nYou can accomplish these objectives by liste ning, asking questions, observing participants’ reactions and leading \nby example. \n A first step to delivering an effective presentation is to know your audience. You must understand the goals of \nthe course and why the participants need this information. Ti ps for delivering effective presentations include: \n \n• Know your material well. Thoroughly review ALL of the training materials. \n• Identify potential trouble spots in the exercises, as well as hints for assisting participants. \n• Practice your presentation. \n• Use language familiar to the participants, avoiding jargon or unfamiliar terms. \n• Select and prepare anecdotes from real -world experiences that can be used to illustrate special \nscenarios, generate discussion and maintain participant interest. \n• Speak clearly. \n• Be aw are of the tone and pace of how you are speaking. \n• Avoid going off on tangents and getting off track during a presentation. \n• Minimize the use of filler words (such as “uh” and “um”). \n• Make eye contact with participants. \n• Use natural and positive body language and facial expressions. \n• Avoid fidgeting, pacing and other nervous habits. \n• Be yourself. \n• Make sufficient copies of the Participant Guide and handouts. \n• If using an LCD projector, make sure beforehand that all computer equipment is functioning and \nprepare a backup hardcopy of the PowerPoint slides for use during the training. \n• Give yourself ample time to set up the classroom and distribute participant materials before the \ntraining is scheduled to take place. \n A successful instructor must be able to introduce act ivities, assign participants to small groups, give instructions \nand process activity results. When introducing activities, explain the objectives, and emphasize the benefits and \npotential outcomes of the learning activity. Connect, or link, activities to previously learned concepts and \ndiscussions . \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 81 of 92 \n Materials and Equipment Needed \n \n• Train -the-Trainer Instructor Guide. \n• Train -the-Trainer Participant Guide. Print one for each participant and one for the trainer to be used \nas a reference. The Train -the-Trainer p articipant guide should be printed on two two -sides. \n• Train -the-Trainer PowerPoint. This should be customized ahead of time, especially if the training \nincludes various sponsoring organizations and/ or speakers . \n• Laptop or computer loaded with the PowerPoint presentation. It is n’t necessary to share the slides \nwith participants. All of the information that’s needed is in their Participant Guides . As a best \npractice, be prepared for technical issues. Print a few sets of the slides ahead of time and bring a \nthumb drive with your presentation just in case. \n• Chart paper and markers for recording responses to key questions and/or to create a Parking Lot for \nquestions you might not be able to answer in class. C hart paper can be created ahead of time. \n• Slide projector , screen or monitor/TV to display the PowerPoint presentation. \n• (Optional) Stopwatch or other timer. \n• (Optional) Painter’s tape for posting chart pages on the wall. \n• (Optional) Post -it Notes and highlighters that participants can use to flag or highlight key information \nin their Train -the-Trainer Participant Guides. \n \nThe Instructor Guide is your roadmap for presenting the Train- the-Trainer workshop. It includes: \n \n• The purpose and objectives of the Train- the-Trainer workshop and the curriculum \n• A detailed lesson plan \n• Thumbnails of the overhead slides \n• Additional information that ’s not part of the Train- the-Trainer Participant Guide. \n \nThe lesson plan is laid out in a two- column format. The left -hand column contains the slides used in the \npresentation. The right -hand column contains a word- for-word script of the module content, as well as more \nlengthy instructions for delivering the content and conducting the practice exercises. \n \nEach module includes a set of visuals to help you present the module content. They are presented in both \nPowerPoint and PDF formats so you can use them with your specific projection equipment. \n You should give each student a Participant Guide to use during the training and as a reference when the training is over. It contains: \n \n• Important c oncepts and facts presented in the Train- the-Trainer workshop. \n• The evaluation form \n• Space for taking notes \n• (Optional) Additional ready -to-use resources such as the MSSB Flyer, Agenda, Invitation and \nWorksheet Templates to be used during Train- the-Trainer wo rkshops \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 82 of 92 \n \nGiving Instructions \n \nThe Instructor Guide provides instructions for all the activities in the modules. However, participants may still \nneed clarification. It ’s important to speak clearly and slowly when presenting the objectives of an activity and \ngiving instructions. Make sure to define important terms and concepts (refer to the MSSB TtT glossary) and, when possible, demonstrate activities or provide examples for the participants. Also, periodically ask if there are any questions. While students are completing an activity, you should circulate to answer questions and encourage discussion. \nKeep track of the amount of time allotted for each activity, and inform the students when time is winding down. When processing results, ask questions about how the participants reached their conclusions. Keep the processing from becoming redundant or repetitive by asking the next group to report findings that are different from the previous group ’s or by asking each group to present just a part of the solution. \n When processing individual comments, make sure a diverse group of students is called on to provide responses. Encourage students with different experience levels and perspectives to contribute their observations. Acknowledge correct responses and provide alternative approaches if incomplete or inaccurate responses are \ngiven. \nFacilitating Discussions \n \nInteraction among students contributes to a successful learning experience. Varying the composition of small \ngroups for exercises and activities not only energizes students, but also creates more opportunity to exchange information and encounter different perspectives. \n There are a number of techniques for assigning students to small groups. Common methods include telling students to partner with someone they don’t know or counting off by a specific number and having all the “ones” \nwork together, all the “twos” work together, and so on. Other ways include arbitrarily grouping people who are close to each other or asking students to turn their chairs around to form groups with people at the next table. \n Informative discussions and exchange of information among instructors and students are other keys to the success of this course. As an instructor, your role is to elicit comments from the students while maintaini ng the \nfocus of the discussion. The following tips may be useful when you are leading group discussions: \n \n• Paraphrase what someone has said so the participant will know he or she has been understood and to \nensure the rest of the class hears the comment. \n• Com pliment students on interesting or insightful comments. \n• Use open -ended questions, because they trigger better discussions than close -ended ones. \n• Mediate differences of opinions. \n• Pull ideas together, showing their relationship to one another. \n• Summarize, and record on chart paper, if appropriate, the major views of the group. \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 83 of 92 \n \nClassroom Set -Up \n \nThe most effective classroom set -up is to arrange the room into table groups that seat four to six students each. \nThis allows students to complete the small group exe rcises comfortably. If this arrangement is not possible, you \nmay have to move desks and chairs into small groups to conduct these activities. \n \nUsing Chart Paper \n \nChart paper lets you capture meaningful information generated by discussion and display it for all students to \nsee. When using chart paper: \n \n• Prepare chart paper in advance. \n• Prepare titles beforehand if students will provide responses. \n• Write with large, clear, bold letters, using 20 words per page as your guide. \n• Use words or short phrases to indica te key ideas. \n• Check your spelling. \n• Write, turn to the audience and then talk; don’t talk while writing. \n• Don’t obstruct students’ view of the chart. \n• Leave the bottom quarter of the paper blank so all of the content can be seen by those in the back of \nthe ro om. \n• Tear off chart paper you want the group to be able to refer to throughout the course, and post it on the walls around the classroom. \n \nUsing Handouts \n \nLike other types of materials, handouts help vary the pace of training sessions by giving students a different \nfocus. Reinforce the connection between handouts and course content by introducing and reviewing them. When using handouts: \n \n• Prepare the appropriate number of copies ahead of time. \n• Make sure your handout is concise and designed for easy reading. \n• Use colored paper to make locating the handouts easier if they ’ll be referred to frequently during the \ncourse. \n• Make sure you distribute handouts to each student before beginning to discuss their content. \n• Don’t distribute handout s as you are speaking; students will focus on the materials rather than what \nyou are saying. \n \nUsing Visual Aids \n \nThese tips for using visual aids will help you to be an effective presenter: \n \n• Keep visual aids out of sight until you are ready to use them. \n• Stand to the side of your visua l aid. MSSB Train -the-Trainer Workshop, Participant Guide \n Page 84 of 92 \n • Talk to and face the audience, not the visual aid. \n• Don’t block your face with the visual aid. \n• Maintain eye contact with your audience. \n• Make sure your audience has the time to fully read and understand the visual aid before removing it \nand moving to the next one . \n• Know where the visual aid goes when you’re finished using it. \n• Switch the projector off when not in use; its noise and light can be distracting. \n \nIt’s helpful to practice using visual aids before delivering the actual presentation. All visual aids should be free \nof grammatical errors and clutter. When presenting visual aids, describe the content and add a few anecdotes or meaningful details. Visual aids should not be read verbatim. \nConsider the Three Learning Styles While Teaching \n \nExperts know that most people learn best in one of three ways: \n \n• Visual : Those who learn best by seeing how things are done. \n• Use visual aids, such as handouts, slides, written instructions, charts and demonstrations. \n• Stand to the side, talk to and face the audience , allow the audience time to fully read and \nunderstand. \n• Prepare charts in advance, using large, clear, bold letters. Write, turn to the audience, and then \ntalk. \n• Design handouts for easy reading, and use colored paper to make locating handouts easier. \n \n• Auditory : Those who learn best by listening or hearing instructions. \n• They are affective learners, that is, they tend to be more intuitive than rational. Therefore, they \nhave to feel the learning experience. \n• They like to get involved with others and share i deas and information. \n• They like thinking out loud about what they are learning. \n• Use exercises that allow them to share their experiences with each other. Lectures and audio \ntapes are also useful for auditory learners. \n \n• Tactile/Kinesthetic : Those who lear n best by doing. \n• They like to experiment. \n• They dislike conventional educational approaches. \n• They get bored with lectures, presentations or anything that doesn’t allow them to be physically active. \n• They learn best from hands -on training and physically ac tive exercises. \n \nThings to Avoid During a Presentation \n \nYou can lose the interest of students by doing any of the following: \n \n• Failing to prepare \n• Reading verbatim from notes or a scrip t \n• Teaching without student involvement MSSB Train -the-Trainer Workshop, Participant Guide \n Page 85 of 92 \n • Diverging from course objectives \n• Avoiding eye contact \n• Using confusing visual aids \n• Behaving in a condescending or superior manner \n• Using jargon or language that ’s either too simple or complex for participant s \n• Lacking empathy for participant s’ needs \n• Using offensive or critical humor \n• Making pr omises you can’t deliver \n \nQuestions for Self -Reflection \n \nHere are some potential challenges you may face. How would you deal with them? \n \n• You have made promises you cannot deliver \n• You are asked a question and you do not know the answer \n• Fewer or more people show up than anticipated \n• Someone is sleeping \n• Someone brought a baby who constantly cries \n• No one responds to your questions \n• One person monopolizes the discussion \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 86 of 92 \n \nAccommodating Students with Disabilities \n \nAmericans with Disabilities Act (ADA) of 1990 \n \nOn July 26, 1990, the Americans with Disabilities Act (ADA) became law. The law is designed to protect the \ncivil rights of people with disabilities. The ADA prohibits discrimination on the basis of disability by guaranteeing equal opportunity for individuals with disabilities in public accommodations, commercial facilities, \nemployment, transportation, state and local government services, and telecommunications. \nThe ADA is built on the principles of equal opportunity, full participation, independent living and economic self -\nsufficiency. It reflects the disability community ’s determination to participate fully in the life of their community \nlike other citizens and to have choice and control over their own futures. It ’s the most comprehensive policy \nstatement ever made in law in the United States about how the nation should address individuals with \ndisabilities . \nAs a civil rights law, the ADA is similar to other civil rights acts that protect individuals from being \ndiscriminated against based on arbitrary criteria such as race, color, religion, age, national origin and sex. For \nother groups with civil rights protection, the problem has generally been discrimination through policies that limit their participation. \nFor people with disabilities, discrimination often also takes the form of inaccessible facilities that make it \nimpossible for them to gain access to or participate in “standard” activities. For example, stairs leading to the only entrance into a building prohibit entry by someone who uses a wheelchair. Sim ilarly, texts and handouts \nprovided only on paper and in standard- size typeface are inaccessible to someone who is blind or has low vision. \nIn these cases, the ADA requires changes to buildings or locations, and modifications to the way products or services are provided. \nMaking the modules useful and understandable for everyone, regardless of whether or not they have a disability, is perhaps the best reason of all for making the courses accessible. \nLow- and moderate -income individuals, especially those with little or no banking experience, often don’t have \nthe tools necessary to save and manage money. This lack of a basic understanding of how money works in our society may keep them from achieving financial independence. These individuals also include a significant number of persons with lifelong disabilities, as well as older individuals who acquire disabilities as they age. Some may have undiagnosed or hidden learning disabilities. \n \nRequests for Accommodations \n You may want to consider using a registratio n form with a space where individuals can indicate whether they \nneed any accommodations and, if so, what types of accommodations may be required. You may also want to ask \nif students require materials in alternate formats. \nPeople with disabilities are nev er required to self -identify as having a disability – even if the disability is \nobvious. Therefore, the registration form should not ask the individual to specifically identify the type of \ndisability. That information is not necessary for you to know, and asking for it could be viewed as a type of discrimination. MSSB Train -the-Trainer Workshop, Participant Guide \n Page 87 of 92 \n However, providing a space on the registration form to request accommodations is neutral and welcoming. It’s \nalso a good idea for you to ask all of the students for a way to contact them, by phone and by email, so that you \ncan communicate with people individually if you have questions about any part of the registration form. Put the request for contact information in the body of the registration form – not in the place where you ask if accommodati ons are needed. \n \nHow to Make Classes Accessible to Students with Disabilities \n There are many things that both you and the sponsoring agency can do to make the modules accessible to people with a wide range of disabilities. An overview of actions that can be taken to ensure accessibility follows. \nNondiscrimination \nQualified individuals with disabilities cannot be denied participation simply because of their disability. You can limit participation in your course to individuals who meet some general criteria – such as being over the age of 62 or unemployed – but if an individual qualifies on those grounds, she or he may not be denied participation because of a disability. \n \nPhysical Access \nWhen deciding where to hold the class, look for a location that is acc essible for people who use wheelchairs or \nscooters or who have other difficulties walking or climbing stairs. People with mobility limitations need to be able to get into the building without using steps or crossing over a high object. If the main entrance is not \naccessible, a sign should be posted there indicating the location of the closest accessible entrance. Classes should be held on the upper floors of a building only if they can be reached by an elevator. The building should also have at least one “u nisex” accessible restroom. \nOther physical access issues to consider in determining the location of the classrooms are clearly marked accessible parking spaces located close to the accessible entrance, Braille signage on the elevator call buttons and on the buttons inside the elevators , and raised letters and Braille signage identifying the restrooms. The \nelevators should also have chimes or a recorded voice indicating the different floors. \nIn the classroom itself, check to be sure that there is at least 3 2 inches of clear space in the aisles and along the \nedges of the seating area. This is how much space someone using a wheelchair needs to move freely around the room. If you are using individual desks and chairs and someone who uses a wheelchair enters the room, ask that \nperson if you should move one of the desks or if she or he prefers to transfer from the wheelchair to the desk chair. Always ask; never assume. People with a disability know what works best for them. \nSimilarly, if the room is arranged like a classroom with long tables and individual chairs, it’s always a good idea to remove one or two of the chairs from the ends of rows in different areas of the room before the class starts, so that individuals using wheelchairs or scooters can have a choice of seating arrangements – the same way that \nothers in the class have a choice about where they want to sit. \n \nEffective Communication \n \nSome individuals have disabilities that affect their ability to communicate – for example, people who are blind or \nhave l ow vision or people who are deaf or hearing impaired. Other disabilities that affect communication include \ncognitive or learning disabilities that may impact the ability to read. People who have cognitive disabilities or \nlearning disabilities may have diff iculty reading written material. MSSB Train -the-Trainer Workshop, Participant Guide \n Page 88 of 92 \n \nUnder the ADA, both private and public entities are required to communicate effectively with individuals with \ndisabilities. The obligation to communicate effectively applies to the presentation and exchange of information \nin all forms, including sound, print, graphics and speech. \n The law says that people with communication disabilities are entitled to appropriate “aids and services where necessary to ensure effective communications.” With respect to the Money Smart cours es, these aids and \nservices could include: \n \n• Assisting someone with cognitive or learning disabilities by reading aloud the pre - and post -course tests; or \n• Helping someone with a disability write their answers to the tests or complete other Money Smart forms ; \nor \n• Making sure not to turn your back on someone who is lip reading; or \n• Wearing a lapel microphone or using a handheld microphone to amplify what is being said for persons \nwho use hearing aids or auxiliary listening devices; or \n• Making sure that any videos used in class are captioned for pe ople who are deaf or hard of hearing and that \nwritten material presented on screen is read aloud, either by the narrator on the video or by the course instructor. \n \nSometimes communication assistance can include providing a sign language interpreter, upon request, if doing so does not result in an undue burden. Undue burden is defined in the ADA as “significant difficulty or expense.” However, even if providing a sign language interpreter or some other type of communication assistance is an undue burden, you still are expected, if at all feasible, to provide some other type of assistance, such as a copy of the Instructor Guide, so that a person who is deaf or hard of hearing can follow along as the class is taught. \nSome peo ple with visual disabilities have difficulty reading standard -size text or viewing materials projected on \nthe overhead screen. Copies of the slides for each module can be printed out and given to these individuals to use as you present the course content. Similarly, handouts used during the course can sometimes be difficult to handle for people who have difficulty using their hands and fingers. \nOther people may have difficulty hearing what you are saying. If individuals can read lips, allow them to sit in \nthe front where they can have an unobstructed view of your face. If you are using an overhead projector, make sure that you continue to face the students as you cover the major points. Keep your Instructor Manual open to the individual slides, or, better s till, print out a copy of the overhead materials so that you can read the text on \nthe slides without turning your head away from the person who has the hearing impairment. When there is class discussion or when someone asks a question, repeat what has been said so that the person lip reading can be part of the discussion. \nSome individuals with significant speech disabilities use an augmentative communication device that uses a \ncomputer to produce synthesized speech. When they want to ask a question or cont ribute to the class discussion, \nthey use a keyboard to key in what they want to say. Since keying in the content can take a few moments, you can acknowledge their intention to speak, saying something like, “Yes, Mr. Jones, we’ll get to you as soon as you a re ready,” and then making certain that you do go back to him as soon as the keying in is completed. (Most \nkeyboards make a small beep as each word or phrase is keyed in.) However, during an interaction between the person with the disability and another individual, etiquette demands that you wait respectfully until the comments are keyed in and played. \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 89 of 92 \n Guidelines for Talking About Disabilities \n \nHere are some guidelines that will help you communicate with your students who have disabilities in ways that won’t offend them: \n \n• Do not refer to a person's disability unless it is relevant. \n• Use “disability” rather than “handicap” to refer to a person’s disability , if indeed you need to refer to it . \nIt’s okay to say that a person is handicapped by obstacles, such as architectural barriers or the attitudes of \nignorant or insensitive people. Never use “ cripple/crippled ” in any reference to disability. \n• When referring to a person’s disability, use “people first” language . In other words, when necessary, say \n“person with a disability ” rather than “ a disabled person” . Since “disabled ” is an adjective, it ’s important \nto avoid ridiculous and improper constructions such as “ disabled group” or “disabled transportation.’ \nInstead, build phrases using the word “ disability. ” For ex ample, “ disability activist, ” or “disability \ncommunity,” are correct and not contradictions to the “ people first ” ideas. \n• Never refer to people with disabilities as “the disabled, the blind, the epileptics, a quadriplegic,” etc. \nDescriptive terms should be used as adjectives, not as nouns. \n• Never use the word “retarded” or the phrase “mental retardation”. You can use “intellectual disability” or \n“cognitive impairment”. \n• Avoid negative or sensational descriptions of a person’s disability. Don’t say “suffers fro m,” “a victim \nof,” or “afflicted with. ” Don’t refer to people with disabilities as “ patients ” unless they are receiving \ntreatment in a medical facility. Never say “invalid.” Treat people with disabilities with r espect and \nacceptance. \n• Don’t portray people w ith disabilities as overly courageous, brave, special or superhuman. This implies \nthat it’s unusual for people with disabilities to have talents or skills. \n• Don't use “normal” to describe people who don't have disabilities. It is better to say “people without \ndisabilities ” if necessary to make comparisons. \n• Never say “wheelchair -bound” or “confined to a wheelchair.” . \n• Never assume that a person with a communication disorder (speech impediment, hearing loss, motor \nimpairment) also has a cognitive disability . \n \n10 Commandments of Etiquette for Interacting with People with Disabilities \n \n1. When talking with a person with a disability, speak directly to that person rather than through a \ncompanion or sign language interpreter. \n2. When introduced to a person with a disabi lity, it is appropriate to offer to shake hands. People with limited \nhand use or who wear an artificial limb can usually shake hands. (Shaking hands with the left hand is an acceptable greeting.) \n3. When meeting a person who is visually impaired, always identify yourself and others who may be with you. When conversing in a group, remember to identify the person to whom you are speaking. \n4. Don’t be afraid to ask questions when you're unsure of what to do. If you offer assistance, wait until the \noffer is accepted. Then listen to or ask for instructions. \n5. Treat adults as adults. Address people who have disabilities by their first names only when extending the same familiarity to all others. Never patronize people who use wheelchairs by patting them on the head or shoulder. \n6. Leaning on or hanging on to a person’ s wheelchair is similar to leaning on hanging on to a person and is \ngenerally considered annoying. The chair is part of the personal body space of the person who uses it. MSSB Train -the-Trainer Workshop, Participant Guide \n Page 90 of 92 \n 7. Listen attentively when you're talking with a person who has difficulty speaking. Be patient and wait for \nthe person to finish, rather than correcting or speaking for the person. If necessary, ask short questions that require short answers, a nod or shake of the head. Never pretend to unders tand if you are having difficulty \ndoing so. Instead, repeat what you have understood and allow the person to respond. The response will clue you in and guide your understanding. \n8. When speaking with a person who uses a wheelchair or a person who uses crutches, place yourself at eye level in front of the person to facilitate the conversation. \n9. To get the attention of a person who is deaf, tap the person on the shoulder or wave your hand. Look \ndirectly at the person and speak clearly, slowly, and expressively to determine if the person can read your \nlips. Not all people who are deaf can read lips. For those who read lips, be sensitive to their needs by placing yourself so that you face the light source, and keep hands, cigarettes and food away from your mouth w hen speaking. \n10. Relax. Don't be embarrassed if you happen to use accepted, common expressions such as “See you later,” or “Did you hear about that?” that seem to relate to a person's disability. \n \n MSSB Train -the-Trainer Workshop, Participant Guide \n Page 91 of 92 \n Contact Information \n \nFDIC is looking forward to hearing from organizations interested in providing Money Smart for Small Business \nin their communities. Feel free to reach out to FDIC Regional Office staff; you ’ll find contact information on the \nweb at http://www.fdic.gov/consumers/community/offices.html and listed on the following pages . \n You can also email FDIC at communityaffairs@fdic.gov\n. \n When sending us a message, don’ t forget to share your or ganization’ s contact information, including a specific \nPoint of Contact within your organization. Support from FDIC Community Affairs Staff is available to plan and design MSSB Train- the-Trainer Sessions \nusing the MSSB Curriculum and implementing the MSSB Program directly or through collaborations with \ncommunity organizations and financial institutions. \nWe are eager to learn about your organization and assist you in creat ing lasting impact within your communities . \n \nCommunity Affairs Leadership Contact Inf ormation Area of Responsibility \nJanet Gordon , Associate Director 550 17th Street NW, F -6006 \n(202) 898 -7181 Community Affairs Branch \nLuke Reynolds , Chief 550 17th Street NW, F -6000 \n(202) 898 -7164 Outreach & Program Development Section \nLessie P. Evans, C hief 550 17th Street NW, F -6024 \n(202) 898 -6997 Community Affairs Section (Regional and Area \nOffices) \nThomas E. Stokes , Regional \nManager Atlanta Regional Office \n10 Tenth Street, N.E. \nSuite 800 \nAtlanta, GA 30309- 3906 \nPhone: (678) 916- 2249 (direct) \nPhone: ( 800) 765- 3342 (toll -free) \nEmail: ATLCommunityAffairs@fdic.gov Alabama \nFlorida \nGeorgia \nNorth Carolina \nSouth Carolina \nVirginia \nWest Virginia \nAngelisa Harris , Regional Manager Chicago Regional Office \n300 South Riverside Plaza \nChicago, IL 60606- 3447 \nPhone: (312) 382- 6940 (direct) \nPhone: (800) 944- 5343 (toll -free) \nEmail: CHICommunityAffairs@fdic.gov Illinois \nIndiana \nKentucky \nMichigan \nOhio \nWisconsin \nEloy Villafranca , Regional Manager Dallas Regi onal Office \n1601 Bryan Street, Suite 1410 \ns, T01 -3479 \nPhone 72) 761- 8010 (direct) \nPhone: (800) 568- 9161 (toll -free) \nEmail: DALCommunityAffairs@fdic.gov Colorado \nNew Mexico \nOklahoma \nTexas MSSB Train -the-Trainer Workshop, Participant Guide \n Page 92 of 92 \n Clinton Vaughn, Area Manager Dallas Region - Memphis Area Offic e \n6060 Primacy Parkway \nSuite 300 \nMemphis, TN 38119- 5770 \nPhone: (901) 818- 5706 (direct) \nPhone: (800) 210- 6354 (toll -free) \nEmail: \nMEMCommunityAffairs@fdic.gov Arkansas \nLouisiana \nMississippi \nTennessee \nTeresa Perez, Regional Manager Kansas City Regional Office \n1100 Walnut St \nSuite 2100 \nKansas City, MO 64106 \nPhone: (816) 234- 8151 \nPhone: (800) 209- 7459 (toll -free) \nEmail: KSCommunityAffairs@fdic.gov Iowa \nKansas \nMinnesota \nMissouri \nNebraska \nNorth Dakota \nSouth Dakota \nValerie J. Williams , Regional \nManager New York Regional Office \n350 Fifth Avenue \nSuite 1200 \nNew York, NY 101 18-0110 \nPhone: (917) 320- 2621 (direct) \nPhone: (800) 334- 9593 (toll -free) \nEmail: NYCommunityAffairs@fdic.gov Delaware \nDistrict of Columbia \nMaryland \nNew Jersey \nNew York \nPennsylvania \nPuerto Rico \nU.S. Virgin Islands \nTimothy W. DeLessio , Area \nManager New York - Boston Area Office \n15 Braintree Hill Office Park \nBraintree, MA 02184 -8701 \nPhone: (781) 794- 5632 (direct) \nPhone: (866) 728- 9953 (toll -free) \nEmail: BOSC ommunityAffairs@fdic.gov Connecticut \nMaine \nMassachusetts \nNew Hampshire \nRhode Island \nVermont \nEmerson Hall , Regional Manager San Francisco Regional Office \n25 Jessie Street at Ecker Square \nSuite 1500 San Francisco, CA 94105- 2780 \nPhone: (415) 808- 8115 (dire ct) \nPhone: (800) 756- 3558 (toll -free) \nEmail: SFCommunityAffairs@fdic.gov\n Alaska \nArizona \nCalifornia \nGuam \nHawaii \nIdaho \nMontana \nNevada \nOregon \nUtah \nWashington \nWyoming \n \n \n \n \n \n \n \n \n \nEnd Of Document \n"
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"pdf_file": "GMASRQ5T6SZJ7CAIU73TNIHTPW7FWCE2.pdf",
"text": "PROGRAM NO.2013-S -- TERM APRIL 1, THROUGH MARCH 31, 2001\nTITLE: \"COPYING OF LEGAL DOCUMENTS\"\nBASIS ALASKA LEGAL COPY Previous\nITEM NO. & DESCRIPTION OF Anchorage, AK IKON\nAWARD UNIT RATE COST UNIT RATE COST\nI. PRINTING/COPYING , PACKING,\nAND DISTRIBUTION: (ALL COPYING ONE SIDE ONLY) Format \"A\" up to and including\n8-1/2 x 11\".\n Format \"B\" over 8-1/2 x 11\" up \nto and including 11 x 17\".Form\na \n(a) Black copying, cost per impression.\n(1) One set\n(1) Format \"A\"................................. 6586 0.065 428.09 0.10 658.60\n(2) Format \"B\"................................. 1646 0.09 148.14 0.15 246.90\n(2) Two or more sets\n (1) Format \"A\"................................. 5645 0.055 310.48 0.08 451.60\n (2) Format \"B\"................................. 1411 0.07 98.77 0.12 169.32\n(b) Color copying, cost per impression.\n(1) One set\n(1) Format \"A\"................................. 134 0.50 67.00 0.69 92.46\n(2) Format \"B\"................................. 34 1.00 34.00 1.25 42.50\n(2) Two or more sets\n(1) Format \"A\"................................. 115 0.44 50.60 0.60 69.00\n(2) Format \"B\"................................. 29 0.75 21.75 1.10 31.90\n \nII. ADDITIONAL OPERATIONS:\n(a) Binders, 2-1/2\" capacity:complete \nwith vinyl covering, sheet lifters, clear vinyl pockets, vellum inserts, copied in black thereon, insertingtext on to the rings & a metal looseleaf element, per binder.................................\n. 48 6.00 288.00 8.45 405.60\n(b) Drilling text for suitable 3-ring\nbinder. Cost per 100 sheets......................... . 94 N/C N /\n(c) Stamping and cataloging text \npages as required.Cost per 100 numbers...................................\n. 76 2.00 152.00 6.00 456.00\n(d) Tabbed dividers: Copying o one side\nin black. Cost to include pre-manufactured tabbed dividers, drilling, collating & insertinginto the binder. Per tabbed divider................. 140 0.30 42.00 0.35 49.00\nCONTRACTOR TOTALS $1,640.83 $2,672.88\nDISCOUNT NET NETDISCOUNTED TOTALS $1,640.83 $2,672.88\nReviewed By:_________"
} |
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"pdf_file": "MRHH3GUV6VPV3RNA7LYJSLK4UGA4QI7Y.pdf",
"text": "CERTIFICATE OF COMPLETION\nThis certifies that\nhas successfully completed OTCnet Web-Based Training for \n7.3 Manage OTC Endpoints"
} |
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] | {
"pdf_file": "QSFKS6NOWMHLYFCXK7RQWFMLMSLY5OVX.pdf",
"text": "H.R. 2916 - To prevent Members of Congress from receiving the automatic pay adjustment scheduled to take effect in 2008\n \nH.R. 2916 : Introduced by Mr. Burton of Indiana \n \n \n \nTitle: To prevent Members of Congress from receiving the automatic pay adjustment scheduled\nto take effect in 2008. \n \n \n 1 / 1"
} |
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"pdf_file": "7DTWNUKZRSFNKJJG3QFPB72M3TBLXVRL.pdf",
"text": "COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 1 of 176 \n Generated 9/9/2010 4:42:44 PM \n 22 \n 23 \n 21 \n 20 \n 18 \n 18 \n 20 \n 27 \n 23 \n 21 \n 25 \n 23 \n 21 \n 472 \n 451 \n 477 \n 473 \n 474 \n 475 \n 475 \n 469 \n 462 \n 463 \n 463 \n 456 \n 463 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5.20 % \n 5.44 % \n 5.65 % \n 5.89 % \n 5.08 % \n 5.04 % \n 4.92 % \n 4.69 % \n 4.91 % \n 5.10 % \n 4.65 % \n 4.91 % \n 4.00 % \n 16 \n 11 \n 10 \n 11 \n 9 \n 10 \n 10 \n 84 \n 87 \n 92 \n 96 \n 82 \n 82 \n 79 \n 75 \n 78 \n 83 \n 75 \n 80 \n 64 \n 1,616 \n 1,600 \n 1,627 \n 1,631 \n 1,613 \n 1,627 \n 1,607 \n 1,600 \n 1,587 \n 1,626 \n 1,614 \n 1,629 \n 1,602 \n 5.39 % \n 4.21 % \n 4.14 % \n 6.13 % \n 5.25 % \n 5.24 % \n 4.58 % \n 5.90 % \n 5.43 % \n 6.08 % \n 4.63 % \n 7.07 % \n 7.94 % \n 2 \n 2 \n 2 \n 5 \n 1 \n 1 \n 1 \n 63 \n 49 \n 48 \n 72 \n 59 \n 59 \n 53 \n 70 \n 65 \n 73 \n 48 \n 72 \n 69 \n 1,168 \n 1,165 \n 1,159 \n 1,175 \n 1,124 \n 1,127 \n 1,157 \n 1,187 \n 1,197 \n 1,201 \n 1,037 \n 1,019 \n 869 \n 104.15 %\n103.37 %\n102.16 %\n100.80 %\n 99.44 % \n100.61 %\n100.47 %\n100.00 %\n 99.68 % \n100.93 %\n100.16 %\n100.89 %\n 96.98 % \n 5,970 \n 5,925 \n 5,856 \n 5,954 \n 5,874 \n 5,943 \n 5,935 \n 5,907 \n 5,888 \n 5,962 \n 5,741 \n 5,783 \n 5,559 \n 5,732 \n 5,732 \n 5,732 \n 5,907 \n 5,907 \n 5,907 \n 5,907 \n 5,907 \n 5,907 \n 5,907 \n 5,732 \n 5,732 \n 5,732 \n 26 \n 16 \n 15 \n 18 \n 21 \n 20 \n 16 \n 14 \n 16 \n 23 \n 19 \n 16 \n 17 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,259 \n 2,243 \n 2,227 \n 2,245 \n 2,215 \n 2,256 \n 2,243 \n 2,210 \n 2,207 \n 2,230 \n 2,207 \n 2,220 \n 2,119 \n 999 \n 995 \n 976 \n 1,001 \n 1,011 \n 980 \n 1,003 \n 1,000 \n 995 \n 1,015 \n 835 \n 844 \n 824 \n 2,688 \n 2,670 \n 2,639 \n 2,690 \n 2,627 \n 2,688 \n 2,674 \n 2,683 \n 2,670 \n 2,700 \n 2,680 \n 2,704 \n 2,599 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 2 of 176 \n Generated 9/9/2010 4:42:44 PM \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 327 \n 1,505 \n 1,500 \n 1,408 \n 1,506 \n 1,449 \n 1,493 \n 1,496 \n 1,487 \n 1,470 \n 1,499 \n 1,468 \n 1,527 \n 1,461 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 1,479 \n 105 \n 100 \n 103 \n 102 \n 101 \n 97 \n 95 \n 97 \n 109 \n 99 \n 94 \n 93 \n 91 \n 626 \n 623 \n 622 \n 623 \n 621 \n 608 \n 604 \n 652 \n 623 \n 647 \n 632 \n 678 \n 676 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,777 \n 2,761 \n 2,780 \n 2,801 \n 2,732 \n 2,749 \n 2,758 \n 2,783 \n 2,779 \n 2,822 \n 2,647 \n 2,643 \n 2,467 \n 2,668 \n 2,668 \n 2,668 \n 2,843 \n 2,843 \n 2,843 \n 2,843 \n 2,843 \n 2,843 \n 2,843 \n 2,668 \n 2,668 \n 2,668 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 478 \n 460 \n 484 \n 479 \n 481 \n 481 \n 482 \n 474 \n 467 \n 470 \n 470 \n 461 \n 472 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 471 \n 3,255 \n 3,221 \n 3,264 \n 3,280 \n 3,213 \n 3,230 \n 3,240 \n 3,257 \n 3,246 \n 3,292 \n 3,117 \n 3,104 \n 2,939 \n 3,139 \n 3,139 \n 3,139 \n 3,314 \n 3,314 \n 3,314 \n 3,314 \n 3,314 \n 3,314 \n 3,314 \n 3,139 \n 3,139 \n 3,139 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4.66 % \n 5.10 % \n 4.40 % \n 4.23 % \n 3.80 % \n 3.79 % \n 4.21 % \n 5.76 % \n 4.98 % \n 4.54 % \n 5.40 % \n 5.04 % \n 4.54 % \n 2 \n 11 \n 8 \n 9 \n 15 \n 20 \n 4 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 3 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,436 \n 1,400 \n 1,318 \n 1,370 \n 1,367 \n 1,379 \n 1,323 \n 1,300 \n 1,264 \n 1,237 \n 1,172 \n 1,178 \n 1,175 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 1,754 \n 128 \n 127 \n 122 \n 123 \n 118 \n 109 \n 115 \n 99 \n 113 \n 119 \n 119 \n 111 \n 109 \n 18 \n 17 \n 16 \n 20 \n 16 \n 24 \n 19 \n 18 \n 17 \n 14 \n 15 \n 11 \n 8 \n 146 \n 144 \n 138 \n 143 \n 134 \n 133 \n 134 \n 117 \n 130 \n 133 \n 134 \n 122 \n 117 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 31 \n 28 \n 30 \n 37 \n 42 \n 43 \n 41 \n 18 \n 5 \n 5 \n 24 \n 17 \n 24 \n 1 \n 22 \n 27 \n 25 \n 20 \n 19 \n 15 \n 16 \n 26 \n 31 \n 34 \n 42 \n 33 \n 20 \n 33 \n 33 \n 22 \n 29 \n 18 \n 16 \n 31 \n 24 \n 28 \n 33 \n 31 \n 25 \n 24 \n 62 \n 63 \n 63 \n 56 \n 46 \n 63 \n 63 \n 66 \n 62 \n 62 \n 44 \n 37 \n 30 \n 118 \n 123 \n 110 \n 105 \n 83 \n 94 \n 110 \n 116 \n 121 \n 129 \n 117 \n 95 \n 74 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 6 \n 5 \n 5 \n 5 \n 6 \n 6 \n 7 \n 9 \n 11 \n 13 \n 11 \n 11 \n 22 \n 31 \n 30 \n 27 \n 35 \n 38 \n 28 \n 25 \n 21 \n 24 \n 15 \n 29 \n 26 \n 94 \n 94 \n 98 \n 89 \n 91 \n 95 \n 85 \n 80 \n 90 \n 62 \n 100 \n 97 \n 106 \n 364 \n 366 \n 348 \n 344 \n 371 \n 384 \n 370 \n 329 \n 319 \n 314 \n 322 \n 314 \n 308 \n 333 \n 338 \n 318 \n 307 \n 329 \n 341 \n 329 \n 311 \n 314 \n 309 \n 298 \n 297 \n 284 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 4 of 176 \n Generated 9/9/2010 4:42:44 PM \n 5 \n 2 \n 3 \n 3 \n 2 \n 5 \n 4 \n 13 \n 17 \n 16 \n 19 \n 16 \n 18 \n 28 \n 31 \n 24 \n 26 \n 27 \n 30 \n 31 \n 50 \n 50 \n 46 \n 55 \n 48 \n 53 \n 33 \n 33 \n 27 \n 29 \n 29 \n 35 \n 35 \n 63 \n 67 \n 62 \n 74 \n 64 \n 71 \n 99 \n 101 \n 103 \n 110 \n 59 \n 84 \n 88 \n 369 \n 331 \n 319 \n 320 \n 275 \n 315 \n 323 \n 468 \n 432 \n 422 \n 430 \n 334 \n 399 \n 411 \n 849 \n 849 \n 849 \n 843 \n 860 \n 858 \n 853 \n 838 \n 840 \n 839 \n 839 \n 837 \n 858 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 787 \n 49 \n 26 \n 13 \n 91 \n 64 \n 64 \n 0 \n 51 \n 0 \n 0 \n 15 \n 24 \n 30 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 19 \n 20 \n 14 \n 16 \n 15 \n 17 \n 20 \n 12 \n 16 \n 15 \n 16 \n 11 \n 14 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 8 \n 11 \n 12 \n 9 \n 8 \n 1 \n 2 \n 7 \n 3 \n 4 \n 7 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 30 \n 33 \n 30 \n 40 \n 39 \n 39 \n 44 \n 43 \n 30 \n 44 \n 46 \n 41 \n 27 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 53 \n 61 \n 55 \n 68 \n 63 \n 64 \n 65 \n 57 \n 53 \n 62 \n 66 \n 59 \n 45 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 5 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 2 \n 2 \n 3 \n 2 \n 6 \n 2 \n 3 \n 3 \n 0 \n 14 \n 5 \n 4 \n 6 \n 9 \n 13 \n 9 \n 7 \n 8 \n 11 \n 11 \n 3 \n 7 \n 24 \n 18 \n 15 \n 21 \n 27 \n 19 \n 19 \n 18 \n 15 \n 30 \n 16 \n 18 \n 25 \n 5 \n 15 \n 8 \n 6 \n 7 \n 6 \n 4 \n 3 \n 6 \n 6 \n 6 \n 7 \n 7 \n 81 \n 91 \n 106 \n 75 \n 84 \n 58 \n 60 \n 98 \n 83 \n 123 \n 85 \n 82 \n 72 \n 3.43 \n 3.07 \n 3.31 \n 2.45 \n 3.49 \n 2.69 \n 3.08 \n 3.11 \n 2.65 \n 4.03 \n 3.15 \n 3.29 \n 3.63 \n 205 \n 182 \n 194 \n 146 \n 205 \n 160 \n 183 \n 184 \n 156 \n 240 \n 181 \n 190 \n 202 \n 3 \n 7 \n 0 \n 0 \n 4 \n 3 \n 3 \n 7 \n 7 \n 2 \n 8 \n 3 \n 7 \n 9 \n 12 \n 11 \n 15 \n 9 \n 11 \n 14 \n 14 \n 11 \n 12 \n 14 \n 9 \n 13 \n 12 \n 19 \n 11 \n 15 \n 13 \n 14 \n 17 \n 21 \n 18 \n 14 \n 22 \n 12 \n 20 \n 45 \n 51 \n 48 \n 50 \n 45 \n 43 \n 49 \n 53 \n 74 \n 76 \n 65 \n 63 \n 49 \n 206 \n 207 \n 212 \n 211 \n 202 \n 206 \n 206 \n 199 \n 197 \n 203 \n 201 \n 204 \n 198 \n 251 \n 258 \n 260 \n 261 \n 247 \n 249 \n 255 \n 252 \n 271 \n 279 \n 266 \n 267 \n 247 \n 5 \n 1 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 3 \n 3 \n 1 \n 2 \n 5 \n 3 \n 4 \n 4 \n 0 \n 1 \n 0 \n 0 \n 3 \n 4 \n 4 \n 2 \n 2 \n 5 \n 8 \n 5 \n 4 \n 1 \n 3 \n 0 \n 0 \n 3 \n 7 \n 7 \n 3 \n 4 \n 10 \n 8 \n 62 \n 33 \n 40 \n 52 \n 56 \n 6 \n 33 \n 32 \n 39 \n 51 \n 53 \n 32 \n 35 \n 44 \n 61 \n 77 \n 68 \n 68 \n 36 \n 68 \n 72 \n 66 \n 70 \n 66 \n 83 \n 95 \n 100 \n 164 \n 117 \n 120 \n 124 \n 42 \n 101 \n 104 \n 105 \n 121 \n 119 \n 115 \n 130 \n 144 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 6 of 176 \n Generated 9/9/2010 4:42:44 PM \n 4 \n 1 \n 10 \n 4 \n 3 \n 8 \n 1 \n 1 \n 3 \n 8 \n 8 \n 3 \n 6 \n 13 \n 18 \n 24 \n 16 \n 31 \n 22 \n 14 \n 22 \n 18 \n 13 \n 22 \n 17 \n 23 \n 4 \n 10 \n 8 \n 4 \n 5 \n 5 \n 3 \n 7 \n 6 \n 6 \n 5 \n 4 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 96 \n 147 \n 150 \n 152 \n 146 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 4 \n 1 \n 0 \n 1 \n 1 \n 0.30 \n 0.32 \n 0.43 \n 0.25 \n 0.51 \n 0.39 \n 0.25 \n 0.32 \n 0.31 \n 0.35 \n 0.45 \n 0.31 \n 0.43 \n 18 \n 19 \n 25 \n 15 \n 30 \n 23 \n 15 \n 19 \n 18 \n 21 \n 26 \n 18 \n 24 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 2 \n 0.65 \n 0.57 \n 0.65 \n 0.50 \n 0.83 \n 0.59 \n 0.42 \n 0.47 \n 0.66 \n 0.57 \n 0.63 \n 0.54 \n 0.61 \n 39 \n 34 \n 38 \n 30 \n 49 \n 35 \n 25 \n 28 \n 39 \n 34 \n 36 \n 31 \n 34 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 7 \n 2 \n 2 \n 7 \n 71 \n 53 \n 60 \n 38 \n 76 \n 62 \n 88 \n 52 \n 38 \n 68 \n 60 \n 77 \n 91 \n 0 \n 4 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 7 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 2 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 1 \n 8 \n 6 \n 2 \n 8 \n 12 \n 2 \n 5 \n 6 \n 5 \n 5 \n 7 \n 4 \n 7 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 8 \n 6 \n 4 \n 8 \n 12 \n 3 \n 6 \n 6 \n 5 \n 5 \n 7 \n 5 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 3 \n 1 \n 3 \n 3 \n 6 \n 1 \n 3 \n 2 \n 4 \n 1 \n 4 \n 5 \n 6 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 3 \n 1 \n 4 \n 3 \n 6 \n 1 \n 3 \n 2 \n 4 \n 1 \n 5 \n 5 \n 6 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 2 \n 1 \n 3 \n 6 \n 2 \n 3 \n 3 \n 5 \n 7 \n 6 \n 6 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 3 \n 2 \n 1 \n 3 \n 1 \n 4 \n 1 \n 4 \n 0 \n 0 \n 3 \n 1 \n 2 \n 4 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 8 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 7 \n 4 \n 2 \n 6 \n 8 \n 8 \n 9 \n 5 \n 5 \n 3 \n 3 \n 3 \n 7 \n 3 \n 12 \n 9 \n 7 \n 3 \n 4 \n 3 \n 5 \n 8 \n 4 \n 5 \n 10 \n 13 \n 5,967 \n 5,913 \n 5,847 \n 5,947 \n 5,871 \n 5,939 \n 5,932 \n 5,902 \n 5,880 \n 5,958 \n 5,736 \n 5,773 \n 5,546 \n 12 \n 11 \n 17 \n 6 \n 11 \n 10 \n 5 \n 9 \n 10 \n 11 \n 9 \n 7 \n 11 \n 0 \n 1 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 3 \n 0 \n 1 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 0 \n 2 \n 1 \n 2 \n 0 \n 1 \n 2 \n 1 \n 2 \n 2 \n 0 \n 2 \n 0 \n 2 \n 0 \n 2 \n 2 \n 2 \n 2 \n 4 \n 1 \n 3 \n 3 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 2 \n 2 \n 4 \n 0 \n 3 \n 0 \n 2 \n 2 \n 0 \n 2 \n 4 \n 5 \n 3 \n 2 \n 2 \n 3 \n 3 \n 1 \n 2 \n 2 \n 4 \n 1 \n 1 \n 2 \n 2 \n 1 \n 2 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 9 of 176 \n Generated 9/9/2010 4:42:44 PM \n 33 \n 30 \n 12 \n 21 \n 9 \n 15 \n 20 \n 14 \n 17 \n 11 \n 15 \n 23 \n 27 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 3 \n 12 \n 7 \n 11 \n 12 \n 12 \n 8 \n 12 \n 20 \n 8 \n 11 \n 9 \n 19 \n 19 \n 11 \n 9 \n 8 \n 12 \n 3 \n 7 \n 7 \n 3 \n 7 \n 7 \n 6 \n 5 \n 6 \n 30 \n 26 \n 27 \n 24 \n 44 \n 40 \n 46 \n 55 \n 32 \n 33 \n 32 \n 28 \n 32 \n 3 \n 3 \n 2 \n 1 \n 2 \n 1 \n 2 \n 1 \n 3 \n 2 \n 0 \n 1 \n 0 \n 5 \n 2 \n 0 \n 3 \n 6 \n 5 \n 3 \n 6 \n 7 \n 11 \n 12 \n 11 \n 9 \n 27 \n 27 \n 25 \n 34 \n 26 \n 22 \n 8 \n 17 \n 11 \n 19 \n 17 \n 13 \n 21 \n 15 \n 14 \n 17 \n 11 \n 20 \n 13 \n 20 \n 23 \n 10 \n 27 \n 28 \n 15 \n 11 \n 3.22 \n 2.63 \n 2.44 \n 2.77 \n 3.22 \n 2.74 \n 2.91 \n 3.30 \n 2.73 \n 3.10 \n 3.19 \n 3.01 \n 3.60 \n 1 \n 0 \n 0 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 5 \n 13 \n 31 \n 48 \n 43 \n 57 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 1 \n 0 \n 4 \n 6 \n 19 \n 9 \n 150 \n 172 \n 126 \n 152 \n 215 \n 276 \n 173 \n 225 \n 111 \n 162 \n 324 \n 290 \n 409 \n 192 \n 156 \n 143 \n 165 \n 189 \n 163 \n 173 \n 195 \n 161 \n 185 \n 183 \n 174 \n 200 \n 342 \n 328 \n 269 \n 317 \n 404 \n 439 \n 346 \n 420 \n 272 \n 347 \n 507 \n 464 \n 609 \n 1 \n 0 \n 2 \n 0 \n 2 \n 2 \n 2 \n 2 \n 4 \n 1 \n 3 \n 3 \n 0 \n 1 \n 0 \n 2 \n 0 \n 2 \n 1 \n 2 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 2 \n 0 \n 2 \n 2 \n 2 \n 1 \n 3 \n 1 \n 3 \n 3 \n 0 \n 2 \n 0 \n 2 \n 0 \n 2 \n 1 \n 2 \n 0 \n 2 \n 0 \n 3 \n 0 \n 0 \n 2 \n 0 \n 2 \n 0 \n 2 \n 1 \n 2 \n 0 \n 2 \n 0 \n 3 \n 0 \n 0 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 10 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 410 \n 410 \n 381 \n 381 \n 419 \n 393 \n 423 \n 62.74 % \n 27.00 % \n 31.88 % \n 98.99 % \n 99.66 % \n 0.00 % \n 0.00 % \n 77.78 % \n 89.61 % \n 88.19 % \n 92.44 % \n 91.65 % \n 83.30 % \n 522 \n 270 \n 300 \n 294 \n 296 \n 0 \n 0 \n 392 \n 440 \n 433 \n 477 \n 439 \n 419 \n 832 \n 1,000 \n 941 \n 297 \n 297 \n 0 \n 462 \n 504 \n 491 \n 491 \n 516 \n 479 \n 503 \n 0.00 \n 3.65 \n 4.40 \n 4.52 \n 4.69 \n 4.63 \n 4.44 \n 5.72 \n 7.11 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 24 \n 36 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 3 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 164 \n 108 \n 119 \n 110 \n 139 \n 163 \n 51 \n 0 \n 0 \n 217 \n 261 \n 267 \n 276 \n 276 \n 255 \n 331 \n 395 \n 0 \n 0 \n 0 \n 0 \n 0 \n 381 \n 369 \n 386 \n 386 \n 415 \n 418 \n 382 \n 395 \n 31 \n 16 \n 11 \n 12 \n 20 \n 20 \n 20 \n 23 \n 25 \n 27 \n 29 \n 23 \n 24 \n 3 \n 2 \n 2 \n 0 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 7 \n 7 \n 8 \n 6 \n 6 \n 7 \n 9 \n 8 \n 14 \n 11 \n 13 \n 17 \n 2 \n 5 \n 6 \n 3 \n 3 \n 2 \n 3 \n 2 \n 7 \n 3 \n 2 \n 2 \n 6 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 5 \n 2 \n 1 \n 2 \n 4 \n 0 \n 2 \n 1 \n 2 \n 2 \n 4 \n 4 \n 4 \n 3 \n 5 \n 3 \n 2 \n 0 \n 3 \n 7 \n 5 \n 9 \n 13 \n 22 \n 11 \n 12 \n 8 \n 7 \n 7 \n 10 \n 7 \n 9 \n 5 \n 4 \n 5 \n 9 \n 8 \n 9 \n 8 \n 3 \n 10 \n 7 \n 8 \n 8 \n 13 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 11 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 4 \n 5 \n 8 \n 0 \n 0 \n 6 \n 2 \n 0 \n 0 \n 0 \n 3 \n 1 \n 4 \n 1 \n 0 \n 6 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 11 \n 3 \n 1 \n 0 \n 0 \n 14 \n 31 \n 36 \n 1 \n 56 \n 65 \n 54 \n 35 \n 75 \n 48 \n 45 \n 16 \n 0 \n 199 \n 159 \n 141 \n 143 \n 146 \n 142 \n 124 \n 22 \n 8 \n 0 \n 101 \n 84 \n 84 \n 83 \n 89 \n 76 \n 74 \n 13 \n 116 \n 2,587 \n 2,413 \n 4,252 \n 1,703 \n 545 \n 0 \n 0 \n 3,276 \n 4,451 \n 9,735 \n 7,555 \n 1,132 \n 5,184 \n 4,075 \n 100 \n 4,175 \n 5,146 \n 4,279 \n 5,529 \n 5,662 \n 0 \n 11,154 \n 11,376 \n 11,216 \n 13,192 \n 7,053 \n 9,693 \n 4,869 \n 6,762 \n 7,558 \n 8,531 \n 7,231 \n 6,206 \n 0 \n 11,154 \n 14,652 \n 15,667 \n 22,927 \n 14,608 \n 10,825 \n 10,053 \n 11,140 \n 6,337 \n 6,065 \n 7,111 \n 3,447 \n 0 \n 9,043 \n 15,504 \n 18,648 \n 24,385 \n 28,809 \n 31,984 \n 32,341 \n 151 \n 53 \n 0 \n 128 \n 220 \n 203 \n 190 \n 267 \n 257 \n 258 \n 98.99 % \n 99.66 % \n 0.00 % \n 0.00 % \n 26.60 % \n 35.45 % \n 24.55 % \n 61.86 % \n 67.44 % \n 60.00 % \n 294 \n 296 \n 0 \n 0 \n 25 \n 39 \n 27 \n 60 \n 58 \n 48 \n 297 \n 297 \n 0 \n 52 \n 94 \n 110 \n 110 \n 97 \n 86 \n 80 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 89.51 % \n105.25 %\n106.56 %\n 99.52 % \n 96.95 % \n 87.71 % \n 0 \n 0 \n 0 \n 0 \n 367 \n 401 \n 406 \n 417 \n 381 \n 371 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 12 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 648 \n 648 \n 756 \n 756 \n 756 \n 810 \n 756 \n 0 \n 0 \n 0 \n 0 \n 80 \n 51 \n 52 \n 51 \n 197 \n 72 \n 0 \n 0 \n 0 \n 0 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 0 \n 0 \n 0 \n 0 \n 114 \n 128 \n 100 \n 98 \n 116 \n 116 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 131 \n 112 \n 113 \n 154 \n 102 \n 113 \n 278 \n 439 \n 407 \n 407 \n 417 \n 428 \n 439 \n 62 \n 64 \n 72 \n 149 \n 181 \n 51 \n 368 \n 585 \n 466 \n 473 \n 515 \n 566 \n 638 \n 7.0 \n 7.9 \n 8.2 \n 7.2 \n 7.2 \n 7.2 \n 8.0 \n 8.0 \n 7.9 \n 7.8 \n 7.8 \n 388 \n 747 \n 655 \n 797 \n 783 \n 786 \n 944 \n 626 \n 232 \n 708 \n 560 \n 616 \n 508 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 10 \n 4 \n 4 \n 0 \n 0 \n 9 \n 11 \n 9 \n 9 \n 0 \n 0 \n 12 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 13 of 176 \n Generated 9/9/2010 4:42:44 PM \n 29 \n 494 \n 487 \n 415 \n 406 \n 373 \n 402 \n 427 \n 435 \n 282 \n 372 \n 341 \n 324 \n 316 \n 0 \n 0 \n 0 \n 250 \n 231 \n 263 \n 220 \n 235 \n 233 \n 221 \n 190 \n 176 \n 138 \n 126 \n 122 \n 117 \n 95 \n 103 \n 91 \n 89 \n 75 \n 72 \n 66 \n 19 \n 323 \n 2,773 \n 4,334 \n 2,993 \n 3,585 \n 3,305 \n 1,907 \n 20,904 \n 4,178 \n 5,082 \n 8,858 \n 8,398 \n 6,562 \n 4,961 \n 2,195 \n 380 \n 2,575 \n 5,839 \n 5,176 \n 3,509 \n 8,306 \n 9,082 \n 3,746 \n 11,541 \n 12,145 \n 13,756 \n 6,495 \n 9,738 \n 5,291 \n 5,348 \n 10,172 \n 8,169 \n 7,094 \n 11,611 \n 10,989 \n 24,649 \n 15,719 \n 17,227 \n 22,614 \n 14,893 \n 16,300 \n 10,252 \n 14,180 \n 11,131 \n 13,164 \n 11,715 \n 14,758 \n 9,977 \n 6,365 \n 7,539 \n 11,119 \n 17,951 \n 23,323 \n 20,564 \n 24,716 \n 132 \n 162 \n 111 \n 87 \n 104 \n 334 \n 138 \n 192 \n 153 \n 182 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n600.00 %\n 87.50 % \n 92.50 % \n 63.04 % \n 71.74 % \n 71.74 % \n 58.51 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 36 \n 35 \n 37 \n 58 \n 66 \n 66 \n 55 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 40 \n 40 \n 92 \n 92 \n 92 \n 94 \n 89.75 % \n100.93 %\n100.00 %\n 98.17 % \n100.00 %\n 93.47 % \n 89.40 % \n 90.76 % \n 89.27 % \n 95.22 % \n 86.52 % \n 78.37 % \n 70.51 % \n 219 \n 218 \n 217 \n 214 \n 218 \n 229 \n 312 \n 324 \n 341 \n 339 \n 308 \n 279 \n 251 \n 244 \n 216 \n 217 \n 218 \n 218 \n 245 \n 349 \n 357 \n 382 \n 356 \n 356 \n 356 \n 356 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 14 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 174 \n 330 \n 334 \n 330 \n 662 \n 657 \n 639 \n 2,497 \n 2,085 \n 2,081 \n 2,107 \n 2,108 \n 2,205 \n 2,427 \n 2,153 \n 2,156 \n 2,183 \n 2,055 \n 2,053 \n 2,088 \n 2,497 \n 2,085 \n 2,081 \n 2,107 \n 2,108 \n 2,205 \n 2,601 \n 2,483 \n 2,490 \n 2,513 \n 2,717 \n 2,710 \n 2,727 \n 99.52 % \n 87.34 % \n 97.02 % \n 90.76 % \n 78.92 % \n 64.16 % \n 10.35 % \n 10,011 \n 10,658 \n 9,376 \n 10,743 \n 11,059 \n 9,608 \n 11,359 \n 9,963 \n 9,309 \n 9,097 \n 9,750 \n 8,728 \n 6,164 \n 1,176 \n 29 \n 21 \n 111 \n 18 \n 17 \n 29 \n 18 \n 19 \n 16 \n 8 \n 15 \n 12 \n 15 \n 421 \n 407 \n 365 \n 384 \n 358 \n 349 \n 376 \n 445 \n 399 \n 380 \n 392 \n 292 \n 214 \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 63.60 % \n 64.80 % \n 66.80 % \n 79.29 % \n 78.12 % \n 72.94 % \n 160 \n 160 \n 160 \n 160 \n 160 \n 160 \n 160 \n 159 \n 162 \n 167 \n 337 \n 332 \n 310 \n 160 \n 160 \n 160 \n 160 \n 160 \n 160 \n 160 \n 250 \n 250 \n 250 \n 425 \n 425 \n 425 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 36 \n 25 \n 42 \n 15 \n 3 \n 12 \n 18 \n 42 \n 25 \n 27 \n 53 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 11 \n 0 \n 0 \n 25 \n 29 \n 14 \n 3 \n 1 \n 0 \n 2 \n 0 \n 0 \n 15 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 2 \n 10 \n 12 \n 17 \n 23 \n 6 \n 5 \n 31 \n 15 \n 14 \n 8 \n 25 \n 4 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 15 of 176 \n Generated 9/9/2010 4:42:44 PM \n 59 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 234 \n 234 \n 0 \n 1,092 \n 2,048 \n 6,429 \n 33 \n 15 \n 11 \n 519 \n 4,347 \n 183 \n 786 \n 9,695 \n 363 \n 474 \n 614 \n 36 \n 52 \n 13,973 \n 16,264 \n 12,228 \n 13,318 \n 6,520 \n 7,951 \n 3,397 \n 627 \n 2,157 \n 314 \n 1,682 \n 564 \n 706 \n 1,346 \n 489 \n 1,272 \n 1,014 \n 1,311 \n 1,505 \n 874 \n 2,420 \n 1,202 \n 1,895 \n 2,362 \n 1,810 \n 950 \n 504 \n 5,519 \n 1,850 \n 1,352 \n 3,911 \n 6,844 \n 4,230 \n 6,474 \n 11,199 \n 10,941 \n 9,614 \n 12,875 \n 4,816 \n 15,915 \n 22,287 \n 15,361 \n 16,203 \n 16,089 \n 16,483 \n 9,287 \n 19,450 \n 15,155 \n 13,624 \n 15,364 \n 17,333 \n 12,953 \n 99.22 % \n 99.22 % \n100.00 %\n 99.61 % \n100.00 %\n100.00 %\n100.00 %\n 98.99 % \n 98.65 % \n100.00 %\n 95.62 % \n 95.62 % \n 81.14 % \n 255 \n 255 \n 255 \n 254 \n 255 \n 255 \n 255 \n 294 \n 293 \n 297 \n 284 \n 284 \n 241 \n 257 \n 257 \n 255 \n 255 \n 255 \n 255 \n 255 \n 297 \n 297 \n 297 \n 297 \n 297 \n 297 \n 1,039 \n 1,350 \n 1,334 \n 2,103 \n 2,108 \n 1,267 \n 3,289 \n 929 \n 803 \n 772 \n 727 \n 607 \n 671 \n 657 \n 975 \n 981 \n 943 \n 924 \n 1,221 \n 1,179 \n 727 \n 651 \n 637 \n 596 \n 511 \n 531 \n 7 \n 9 \n 7 \n 7 \n 5 \n 3 \n 4 \n 4 \n 4 \n 5 \n 3 \n 2 \n 2 \n 664 \n 984 \n 988 \n 950 \n 929 \n 1,224 \n 1,183 \n 731 \n 655 \n 642 \n 599 \n 513 \n 533 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 2.30 % \n 93.43 % \n 94.15 % \n 94.52 % \n 94.02 % \n 94.07 % \n 77.14 % \n 71.90 % \n 93.43 % \n 94.15 % \n 94.52 % \n 94.02 % \n 94.07 % \n 77.14 % \n 67.24 % \n 90.21 % \n 90.60 % \n 89.53 % \n 83.55 % \n 81.00 % \n 75.36 % \n 164 \n 122 \n 114 \n 126 \n 125 \n 504 \n 852 \n 243 \n 234 \n 263 \n 447 \n 515 \n 672 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 156 \n 162 \n 163 \n 322 \n 322 \n 303 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 2 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 158 \n 163 \n 163 \n 322 \n 323 \n 303 \n 2,333 \n 1,963 \n 1,967 \n 1,981 \n 1,983 \n 1,701 \n 1,745 \n 2,082 \n 2,093 \n 2,087 \n 1,948 \n 1,872 \n 1,752 \n 2,333 \n 1,963 \n 1,967 \n 1,981 \n 1,983 \n 1,701 \n 1,749 \n 2,240 \n 2,256 \n 2,250 \n 2,270 \n 2,195 \n 2,055 \n 3,158 \n 3,117 \n 3,174 \n 3,177 \n 3,146 \n 3,187 \n 3,199 \n 3,238 \n 3,225 \n 3,286 \n 3,110 \n 3,067 \n 2,877 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 16 of 176 \n Generated 9/9/2010 4:42:44 PM \n 130 \n 176 \n 105 \n 683 \n 762 \n 0 \n 157 \n 20 \n 158 \n 1,120 \n 1,091 \n 976 \n 773 \n 8 \n 10 \n 6 \n 7 \n 9 \n 0 \n 5 \n 3 \n 6 \n 21 \n 20 \n 15 \n 15 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 2 \n 1 \n 1 \n 1 \n 12 \n 12 \n 14 \n 40 \n 37 \n 40 \n 21 \n 21 \n 38 \n 5 \n 4 \n 6 \n 6 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 1 \n 1 \n 2 \n 36 \n 1,665 \n 3,119 \n 3,119 \n 355 \n 725 \n 5 \n 0 \n 190 \n 426 \n 195 \n 516 \n 452 \n 24 \n 222 \n 297 \n 297 \n 79 \n 161 \n 39 \n 0 \n 95 \n 284 \n 130 \n 258 \n 301 \n 1 \n 4 \n 7 \n 7 \n 3 \n 3 \n 3 \n 0 \n 4 \n 10 \n 3 \n 6 \n 4 \n 644 \n 1,092 \n 2,376 \n 1,620 \n 441 \n 328 \n 11 \n 0 \n 108 \n 438 \n 489 \n 530 \n 293 \n 143 \n 182 \n 264 \n 216 \n 98 \n 82 \n 143 \n 0 \n 54 \n 292 \n 326 \n 212 \n 329 \n 3 \n 4 \n 6 \n 5 \n 3 \n 2 \n 7 \n 0 \n 2 \n 8 \n 6 \n 5 \n 5 \n 4,841 \n 10,150 \n 8,436 \n 9,521 \n 7,655 \n 1,054 \n 488 \n 141 \n 932 \n 7,586 \n 5,049 \n 2,141 \n 2,514 \n 309 \n 592 \n 680 \n 1,236 \n 976 \n 283 \n 360 \n 41 \n 345 \n 1,701 \n 1,551 \n 1,452 \n 1,409 \n 13 \n 19 \n 20 \n 20 \n 16 \n 6 \n 16 \n 4 \n 13 \n 41 \n 30 \n 27 \n 26 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n 3 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 17 of 176 \n Generated 9/9/2010 4:42:44 PM \n 73 \n 71 \n 73 \n 72 \n 72 \n 72 \n 72 \n 73 \n 71 \n 71 \n 70 \n 69 \n 71 \n 0.0 \n 0.0 \n 2.0 \n 1.0 \n 1.0 \n 1.0 \n 1.0 \n 2.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 73 \n 71 \n 71 \n 71 \n 71 \n 71 \n 71 \n 71 \n 71 \n 71 \n 70 \n 70 \n 71 \n 25 \n 24 \n 20 \n 42 \n 43 \n 35 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 14 \n 12 \n 12 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 3 \n 3 \n 3 \n 3 \n 22 \n 24 \n 3 \n 4 \n 4 \n 3 \n 6 \n 5 \n 7 \n 5 \n 6 \n 2 \n 3 \n 116 \n 87 \n 86 \n 99 \n 114 \n 112 \n 127 \n 125 \n 84 \n 92 \n 91 \n 90 \n 88 \n 1 \n 2 \n 2 \n 3 \n 3 \n 5 \n 5 \n 1 \n 2 \n 1 \n 4 \n 5 \n 8 \n 4 \n 4 \n 3 \n 4 \n 6 \n 2 \n 1 \n 6 \n 6 \n 6 \n 6 \n 10 \n 8 \n 1,210 \n 1,224 \n 1,240 \n 1,241 \n 1,224 \n 1,229 \n 1,224 \n 1,223 \n 1,233 \n 1,235 \n 1,214 \n 1,216 \n 1,241 \n 1,332 \n 1,317 \n 1,331 \n 1,347 \n 1,347 \n 1,348 \n 1,357 \n 1,356 \n 1,326 \n 1,335 \n 1,315 \n 1,321 \n 1,345 \n 0.0 \n 0.0 \n 15.0 \n 31.0 \n 31.0 \n 31.0 \n 31.0 \n 21.0 \n -8.0 \n 1.0 \n 2.0 \n 2.0 \n 2.0 \n 1,332 \n 1,317 \n 1,316 \n 1,316 \n 1,316 \n 1,317 \n 1,326 \n 1,335 \n 1,334 \n 1,334 \n 1,313 \n 1,319 \n 1,343 \n 1,909 \n 1,920 \n 1,945 \n 1,946 \n 1,927 \n 1,937 \n 1,927 \n 1,934 \n 1,951 \n 1,947 \n 1,902 \n 1,895 \n 1,956 \n -24,920 \n 500,127 \n 0 \n 383,869 \n 0 \n1,555,686\n 0 \n 0 \n1,331,685\n 0 \n 868,150 \n 868,150 \n 868,150 \n 0 \n6,605,912\n 0 \n6,551,384\n 0 \n7,709,905\n7,709,905\n7,709,906\n7,709,905\n7,025,619\n7,025,619\n7,025,619\n9,039,670\n -1,400,656\n-22,163,952\n 0 \n-23,746,651\n 0 \n-29,124,388\n 0 \n 0 \n-27,134,837\n 0 \n-7,877,388\n-7,877,388\n-7,877,388\n 0 \n176,072,147\n 0 \n152,785,228\n 0 \n150,344,404\n150,344,404\n150,334,403\n150,344,404\n156,814,566\n156,814,566\n156,814,566\n176,386,013\n 4,160 \n 7,392 \n 2,940 \n 4,781 \n 6,858 \n 0 \n 471 \n 140 \n 632 \n 6,720 \n 4,364 \n 1,094 \n 1,768 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 18 of 176 \n Generated 9/9/2010 4:42:44 PM \n 7 \n 7 \n 6 \n 5 \n 5 \n 4 \n 4 \n 5 \n 6 \n 5 \n 6 \n 6 \n 9 \n 29 \n 21 \n 19 \n 22 \n 29 \n 30 \n 37 \n 32 \n 26 \n 33 \n 28 \n 24 \n 40 \n 2 \n 3 \n 2 \n 2 \n 2 \n 2 \n 2 \n 3 \n 3 \n 3 \n 4 \n 3 \n 4 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 1 \n 0 \n 204 \n 204 \n 207 \n 205 \n 199 \n 199 \n 192 \n 197 \n 200 \n 194 \n 186 \n 176 \n 188 \n 236 \n 229 \n 229 \n 230 \n 231 \n 231 \n 231 \n 232 \n 229 \n 230 \n 220 \n 204 \n 232 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n 2.0 \n 1.0 \n 1.0 \n 2.0 \n -1.0 \n 0.0 \n 0.0 \n 0.0 \n -2.0 \n 236 \n 229 \n 229 \n 229 \n 229 \n 230 \n 230 \n 230 \n 230 \n 230 \n 220 \n 204 \n 234 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 41 \n 11 \n 11 \n 24 \n 18 \n 18 \n 15 \n 13 \n 6 \n 1 \n 1 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 33 \n 33 \n 33 \n 33 \n 51 \n 57 \n 57 \n 60 \n 62 \n 60 \n 63 \n 63 \n 65 \n 35 \n 74 \n 44 \n 44 \n 75 \n 75 \n 75 \n 75 \n 75 \n 66 \n 64 \n 64 \n 75 \n -3.0 \n -1.0 \n -31.0 \n -31.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -3.0 \n 38 \n 75 \n 75 \n 75 \n 75 \n 75 \n 75 \n 75 \n 75 \n 66 \n 64 \n 64 \n 78 \n 1 \n 2 \n 3 \n 4 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 1 \n 2 \n 2 \n 6 \n 6 \n 4 \n 6 \n 2 \n 4 \n 6 \n 4 \n 3 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 67 \n 69 \n 70 \n 69 \n 66 \n 66 \n 68 \n 67 \n 69 \n 67 \n 64 \n 65 \n 68 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 19 of 176 \n Generated 9/9/2010 4:42:44 PM \n 17 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 14 \n 14 \n 16 \n 6 \n 7 \n 8 \n 6 \n 8 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 14 \n 9 \n 16 \n 16 \n 19 \n 18 \n 20 \n 23 \n 15 \n 12 \n 8 \n 8 \n 11 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 134 \n 134 \n 132 \n 133 \n 130 \n 131 \n 130 \n 131 \n 128 \n 131 \n 124 \n 124 \n 131 \n 148 \n 143 \n 148 \n 150 \n 150 \n 150 \n 150 \n 154 \n 143 \n 143 \n 133 \n 133 \n 143 \n 0.0 \n 0.0 \n 5.0 \n 7.0 \n 7.0 \n 7.0 \n 7.0 \n 11.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 148 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 133 \n 133 \n 143 \n 13 \n 15 \n 7 \n 10 \n 9 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 28 \n 22 \n 25 \n 35 \n 30 \n 36 \n 34 \n 25 \n 18 \n 14 \n 8 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 1 \n 1 \n 3 \n 0 \n 0 \n 0 \n 2 \n 0 \n 5 \n 1 \n 245 \n 244 \n 251 \n 252 \n 243 \n 241 \n 241 \n 241 \n 244 \n 245 \n 239 \n 238 \n 249 \n 274 \n 272 \n 273 \n 278 \n 279 \n 274 \n 278 \n 276 \n 270 \n 265 \n 253 \n 251 \n 267 \n 2.0 \n 0.0 \n 1.0 \n 6.0 \n 6.0 \n 5.0 \n 9.0 \n 6.0 \n -1.0 \n 1.0 \n -2.0 \n -2.0 \n -2.0 \n 272 \n 272 \n 272 \n 272 \n 273 \n 269 \n 269 \n 270 \n 271 \n 264 \n 255 \n 253 \n 269 \n 23 \n 25 \n 19 \n 17 \n 23 \n 20 \n 2 \n 4 \n 4 \n 4 \n 3 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 20 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,762 \n 1,711 \n 2,095 \n 2,438 \n 2,391 \n 2,430 \n 2,621 \n 1,833 \n 1,699 \n 1,885 \n 1,927 \n 1,852 \n 1,683 \n 75 \n 110 \n 140 \n 209 \n 222 \n 415 \n 293 \n 263 \n 78 \n 54 \n 79 \n 54 \n 7,216 \n 7,588 \n 6,505 \n 6,837 \n 7,065 \n 6,593 \n 6,992 \n 7,756 \n 8,245 \n 8,446 \n 7,278 \n 7,083 \n 7,411 \n 672 \n 835 \n 615 \n 612 \n 707 \n 808 \n 753 \n 689 \n 630 \n 825 \n 710 \n 775 \n 606 \n 56 \n 224 \n 192 \n 88 \n 100 \n 59 \n 132 \n 199 \n 245 \n 299 \n 131 \n 160 \n 187 \n 8,019 \n 8,757 \n 7,452 \n 7,745 \n 8,094 \n 7,874 \n 8,170 \n 8,908 \n 9,197 \n 9,570 \n 8,173 \n 8,097 \n 8,258 \n 6 \n 6 \n 5 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 5 \n 10,566 \n 11,321 \n 10,495 \n 10,996 \n 11,688 \n 11,215 \n 11,430 \n 11,658 \n 11,508 \n 12,380 \n 10,613 \n 10,566 \n 10,592 \n 2,441 \n 2,660 \n 3,030 \n 1,789 \n 1,788 \n 1,670 \n 1,789 \n 1,735 \n 2,341 \n 1,476 \n 1,724 \n 1,846 \n 1,603 \n 1,086 \n 1,117 \n 822 \n 764 \n 765 \n 892 \n 1,397 \n 975 \n 1,258 \n 538 \n 748 \n 1,008 \n 772 \n 243 \n 202 \n 388 \n 146 \n 256 \n 160 \n 117 \n 208 \n 435 \n 0 \n 633 \n 408 \n 116 \n 22,287 \n 16,451 \n 34,222 \n 15,150 \n 18,421 \n 18,408 \n 20,025 \n 19,378 \n 21,888 \n 20,408 \n 20,023 \n 18,027 \n 17,830 \n 2,246 \n 1,741 \n 2,334 \n 1,378 \n 2,301 \n 2,513 \n 2,520 \n 2,392 \n 3,862 \n 2,771 \n 2,504 \n 2,439 \n 3,327 \n 982 \n 419 \n 391 \n 350 \n 559 \n 510 \n 676 \n 653 \n 918 \n 695 \n 520 \n 489 \n 550 \n 25,757 \n 18,813 \n 37,335 \n 17,023 \n 21,537 \n 21,591 \n 23,339 \n 22,631 \n 27,102 \n 23,874 \n 23,679 \n 21,363 \n 21,822 \n 15 \n 12 \n 21 \n 10 \n 13 \n 12 \n 14 \n 13 \n 16 \n 13 \n 14 \n 13 \n 12 \n 29,283 \n 22,589 \n 41,187 \n 19,577 \n 24,089 \n 24,153 \n 26,525 \n 25,341 \n 30,701 \n 25,888 \n 26,151 \n 24,216 \n 24,196 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 4 \n 5 \n 4 \n 3 \n 2 \n 1 \n 1 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 16 \n 12 \n 12 \n 13 \n 14 \n 14 \n 15 \n 15 \n 15 \n 14 \n 12 \n 13 \n 15 \n 17 \n 16 \n 17 \n 17 \n 17 \n 16 \n 16 \n 16 \n 16 \n 16 \n 14 \n 14 \n 16 \n 0.0 \n 0.0 \n 1.0 \n 1.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 21 of 176 \n Generated 9/9/2010 4:42:44 PM \n 593 \n 164 \n 162 \n 256 \n 316 \n 287 \n 294 \n 310 \n 178 \n 73 \n 316 \n 414 \n 349 \n 104 \n 8 \n 0 \n 0 \n 0 \n 0 \n 8 \n 0 \n 0 \n 0 \n 194 \n 168 \n 209 \n 353 \n 386 \n 352 \n 438 \n 502 \n 390 \n 500 \n 545 \n 455 \n 296 \n 207 \n 421 \n 303 \n 155 \n 276 \n 164 \n 174 \n 176 \n 134 \n 104 \n 56 \n 176 \n 128 \n 65 \n 88 \n 120 \n 272 \n 119 \n 32 \n 75 \n 82 \n 42 \n 58 \n 146 \n 152 \n 72 \n 102 \n 104 \n 51 \n 884 \n 790 \n 548 \n 687 \n 760 \n 566 \n 670 \n 746 \n 783 \n 496 \n 568 \n 781 \n 683 \n 1 \n 1 \n 0 \n 1 \n 1 \n 0 \n 1 \n 1 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1,776 \n 977 \n 784 \n 1,179 \n 1,108 \n 862 \n 983 \n 1,160 \n 1,120 \n 595 \n 1,165 \n 1,548 \n 1,422 \n 147 \n 282 \n 204 \n 255 \n 40 \n 258 \n 18 \n 17 \n 148 \n 199 \n 67 \n 390 \n 409 \n 516 \n 251 \n 365 \n 573 \n 819 \n 325 \n 341 \n 332 \n 403 \n 436 \n 430 \n 381 \n 284 \n 0 \n 0 \n 0 \n 0 \n 0 \n 32 \n 8 \n 8 \n 0 \n 0 \n 152 \n 0 \n 160 \n 833 \n 714 \n 397 \n 617 \n 891 \n 627 \n 964 \n 960 \n 1,393 \n 1,123 \n 1,191 \n 613 \n 782 \n 425 \n 486 \n 247 \n 295 \n 392 \n 236 \n 138 \n 112 \n 237 \n 128 \n 141 \n 207 \n 320 \n 144 \n 12 \n 8 \n 33 \n 26 \n 42 \n 42 \n 80 \n 112 \n 56 \n 30 \n 64 \n 11 \n 1,402 \n 1,211 \n 652 \n 944 \n 1,309 \n 937 \n 1,152 \n 1,160 \n 1,742 \n 1,307 \n 1,513 \n 884 \n 1,272 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2,064 \n 1,744 \n 1,221 \n 1,772 \n 2,167 \n 1,519 \n 1,510 \n 1,509 \n 2,293 \n 1,942 \n 2,010 \n 1,655 \n 1,965 \n 190 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 10 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 11 \n 7 \n 13 \n 4 \n 6 \n 9 \n 11 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 786 \n 853 \n 949 \n 813 \n 1,203 \n 912 \n 639 \n 917 \n 612 \n 926 \n 512 \n 618 \n 651 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 22 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 110 \n 122 \n 99 \n 101 \n 90 \n 88 \n 93 \n 24 \n 25 \n 21 \n 17 \n 13 \n 19 \n 12 \n 4 \n 6 \n 7 \n 5 \n 5 \n 6 \n 3 \n 139 \n 153 \n 128 \n 123 \n 108 \n 114 \n 108 \n 1.42 \n 1.28 \n 2.05 \n 1.26 \n 0.94 \n 1.09 \n 0.79 \n 0.78 \n 1.23 \n 0.93 \n 1.12 \n 1.14 \n 0.46 \n 9 \n 8 \n 13 \n 8 \n 6 \n 7 \n 5 \n 5 \n 8 \n 6 \n 7 \n 7 \n 3 \n 0.47 \n 0.23 \n 0.92 \n 0.99 \n 0.93 \n 0.54 \n 0.31 \n 0.31 \n 0.31 \n 0.54 \n 0.47 \n 0.62 \n 0.61 \n 6 \n 3 \n 12 \n 13 \n 12 \n 7 \n 4 \n 4 \n 4 \n 7 \n 6 \n 8 \n 8 \n 6 \n 19 \n 40 \n 22 \n 7 \n 14 \n 13 \n 16 \n 10 \n 9 \n 13 \n 3 \n 4 \n 9 \n 7 \n 12 \n 1 \n 11 \n 5 \n 13 \n 7 \n 3 \n 18 \n 8 \n 5 \n 5 \n 10 \n 6 \n 8 \n 7 \n 10 \n 10 \n 8 \n 9 \n 11 \n 21 \n 15 \n 1,148 \n 4 \n 4.59 \n 4.79 \n 4.57 \n 5.19 \n 4.87 \n 4.83 \n 4.57 \n 3.73 \n 4.01 \n 3.88 \n 4.17 \n 144.99 \n 4.33 \n 29 \n 30 \n 29 \n 33 \n 31 \n 31 \n 29 \n 24 \n 26 \n 25 \n 26 \n 890 \n 28 \n 9 \n 27 \n 35 \n 37 \n 22 \n 19 \n 12 \n 24 \n 8 \n 24 \n 38 \n 15 \n 6 \n 9 \n 7 \n 8 \n 5 \n 14 \n 9 \n 10 \n 12 \n 8 \n 4 \n 8 \n 10 \n 7 \n 9 \n 8 \n 8 \n 8 \n 5 \n 5 \n 6 \n 5 \n 8 \n 6 \n 7 \n 6 \n 11 \n 1.88 \n 1.93 \n 1.37 \n 1.37 \n 1.63 \n 1.47 \n 1.70 \n 1.86 \n 2.00 \n 1.84 \n 2.27 \n 2.03 \n 2.44 \n 24 \n 25 \n 18 \n 18 \n 21 \n 19 \n 22 \n 24 \n 26 \n 24 \n 29 \n 26 \n 32 \n 300 \n 24 \n 74 \n 236 \n 32 \n 8 \n 19 \n 104 \n 160 \n 26 \n 282 \n 354 \n 390 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 23 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 148 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 376 \n 3 \n 0 \n 486 \n 0 \n 0 \n 0 \n 401 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3.55 \n 0.29 \n 3.36 \n 1.40 \n 0.54 \n 1.47 \n 2.32 \n 3.12 \n 1.03 \n 0.25 \n 0.67 \n 0.11 \n 0.28 \n 0.11 \n 0.12 \n 0.00 \n 1.76 \n 0.00 \n 0.00 \n 0.53 \n 0.00 \n 4.86 \n 5.30 \n 4.59 \n 3.76 \n 3.21 \n 2.78 \n 2.71 \n 724 \n 60 \n 694 \n 287 \n 108 \n 293 \n 445 \n 1,335 \n 435 \n 106 \n 288 \n 48 \n 124 \n 48 \n 8 \n 0 \n 123 \n 0 \n 0 \n 35 \n 0 \n 5,022 \n 5,730 \n 4,645 \n 4,196 \n 3,480 \n 2,811 \n 3,106 \n 985 \n 858 \n 1,000 \n 616 \n 516 \n 555 \n 320 \n 192 \n 272 \n 240 \n 116 \n 144 \n 204 \n 80 \n 6,207 \n 6,860 \n 6,008 \n 4,928 \n 4,141 \n 3,604 \n 3,506 \n 8 \n 4 \n 10 \n 9 \n 4 \n 7 \n 7 \n 17 \n 10 \n 7 \n 8 \n 4 \n 5 \n 4 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 24 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 7 \n 8 \n 2 \n 7 \n 8 \n 8 \n 4 \n 2 \n 10 \n 4 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 8 \n 9 \n 5 \n 10 \n 12 \n 8 \n 4 \n 3 \n 10 \n 6 \n 1 \n 3 \n 0.37 \n 0.16 \n 0.51 \n 0.36 \n 0.26 \n 0.26 \n 0.93 \n 0.57 \n 0.15 \n 0.26 \n 0.42 \n 0.11 \n 0.46 \n 7 \n 3 \n 10 \n 7 \n 5 \n 5 \n 18 \n 11 \n 3 \n 5 \n 8 \n 2 \n 9 \n 0 \n 1 \n 4 \n 4 \n 4 \n 4 \n 2 \n 1 \n 12 \n 4 \n 1 \n 2 \n 0 \n 3 \n 17 \n 18 \n 4 \n 20 \n 21 \n 16 \n 8 \n 1 \n 130 \n 7 \n 7 \n 3 \n 3 \n 1 \n 1 \n 3 \n 10 \n 5 \n 2 \n 6 \n 1 \n 2 \n 2 \n 4 \n 0 \n 0.31 \n 0.99 \n 1.18 \n 0.57 \n 1.76 \n 1.55 \n 1.04 \n 0.78 \n 0.72 \n 6.99 \n 0.53 \n 0.69 \n 0.15 \n 6 \n 19 \n 23 \n 11 \n 34 \n 30 \n 20 \n 15 \n 14 \n 136 \n 10 \n 13 \n 3 \n 16 % \n 25 % \n 21 % \n 30 % \n 25 % \n 21 % \n 24 % \n 23 % \n 19 % \n 49 % \n 30 % \n 67 % \n 62 % \n 1 \n 2 \n 1 \n 1 \n 1 \n 7 \n 12 \n 11 \n 4 \n 3 \n 4 \n 2 \n 1 \n 1 \n 2 \n 0 \n 1 \n 1 \n 6 \n 11 \n 13 \n 4 \n 3 \n 3 \n 3 \n 1 \n 769 \n 873 \n 776 \n 1,111 \n 1,037 \n 1,030 \n 1,013 \n 913 \n 678 \n 654 \n 958 \n 1,151 \n 1,505 \n 712 \n 901 \n 877 \n 1,101 \n 1,116 \n 1,038 \n 870 \n 916 \n 731 \n 647 \n 862 \n 892 \n 1,541 \n 284 \n 558 \n 449 \n 510 \n 546 \n 403 \n 368 \n 414 \n 443 \n 366 \n 244 \n 397 \n 335 \n 473 \n 651 \n 583 \n 553 \n 965 \n 686 \n 524 \n 645 \n 435 \n 527 \n 802 \n 589 \n 497 \n 76 \n 105 \n 122 \n 190 \n 115 \n 67 \n 40 \n 119 \n 112 \n 124 \n 136 \n 126 \n 118 \n 78 \n 96 \n 124 \n 198 \n 115 \n 57 \n 50 \n 121 \n 113 \n 126 \n 139 \n 126 \n 148 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 25 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0.37 \n 0.99 \n 0.57 \n 0.31 \n 0.52 \n 1.08 \n 0.16 \n 0.31 \n 0.15 \n 0.26 \n 0.32 \n 0.32 \n 0.05 \n 7 \n 19 \n 11 \n 6 \n 10 \n 21 \n 3 \n 6 \n 3 \n 5 \n 6 \n 6 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 0 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 2 \n 0 \n 4 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 0.00 \n 0.21 \n 0.10 \n 0.00 \n 0.05 \n 0.00 \n 0.00 \n 0.05 \n 0.05 \n 0.10 \n 0.11 \n 0.00 \n 0.20 \n 0 \n 4 \n 2 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 5 \n 4 \n 3 \n 2 \n 7 \n 6 \n 5 \n 6 \n 7 \n 5 \n 5 \n 7 \n 2 \n 3 \n 0 \n 0 \n 3 \n 0 \n 0 \n 2 \n 1 \n 2 \n 0 \n 2 \n 2 \n 12 \n 11 \n 10 \n 10 \n 9 \n 12 \n 7 \n 5 \n 7 \n 8 \n 8 \n 5 \n 7 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 10 \n 0 \n 0 \n 0 \n 2 \n 7 \n 9 \n 2 \n 7 \n 8 \n 8 \n 4 \n 2 \n 8 \n 4 \n 1 \n 3 \n 7 \n 3 \n 9 \n 5 \n 3 \n 4 \n 16 \n 10 \n 3 \n 5 \n 8 \n 1 \n 4 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCCI\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 26 of 176 \n Generated 9/9/2010 4:42:44 PM \n 19 \n 21 \n 22 \n 25 \n 26 \n 26 \n 19 \n 20 \n 20 \n 21 \n 17 \n 20 \n 20 \n 574 \n 575 \n 571 \n 552 \n 559 \n 552 \n 565 \n 567 \n 571 \n 578 \n 565 \n 576 \n 578 \n 12.00 % \n 11.80 % \n 11.83 % \n 12.19 % \n 12.42 % \n 12.14 % \n 12.35 % \n 13.02 % \n 12.34 % \n 11.99 % \n 12.37 % \n 12.89 % \n 13.59 % \n 1 \n 8 \n 1 \n 5 \n 56 \n 63 \n 65 \n 239 \n 235 \n 237 \n 248 \n 254 \n 248 \n 252 \n 263 \n 250 \n 243 \n 258 \n 284 \n 306 \n 1,992 \n 1,992 \n 2,004 \n 2,035 \n 2,045 \n 2,043 \n 2,040 \n 2,020 \n 2,026 \n 2,027 \n 2,085 \n 2,203 \n 2,251 \n 50.00 % \n 44.95 % \n 54.65 % \n 65.74 % \n 57.02 % \n 74.16 % \n 58.82 % \n 46.39 % \n 48.15 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 12 \n 24 \n 22 \n 16 \n 1 \n 3 \n 0 \n 55 \n 49 \n 47 \n 71 \n 65 \n 66 \n 50 \n 45 \n 52 \n 0 \n 0 \n 0 \n 0 \n 110 \n 109 \n 86 \n 108 \n 114 \n 89 \n 85 \n 97 \n 108 \n 0 \n 0 \n 0 \n 0 \n 7.74 % \n 8.48 % \n 8.54 % \n 7.44 % \n 7.63 % \n 7.33 % \n 8.67 % \n 8.67 % \n 8.72 % \n 7.07 % \n 7.32 % \n 6.13 % \n 4.97 % \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 52 \n 54 \n 58 \n 54 \n 66 \n 66 \n 76 \n 78 \n 67 \n 54 \n 55 \n 46 \n 37 \n 672 \n 637 \n 679 \n 726 \n 865 \n 900 \n 877 \n 900 \n 768 \n 764 \n 751 \n 750 \n 744 \n 98.77 % \n 98.30 % \n 99.20 % \n100.76 %\n101.14 %\n101.17 %\n100.59 %\n103.14 %\n100.40 %\n101.22 %\n101.78 %\n100.28 %\n101.38 %\n 5,216 \n 5,191 \n 5,239 \n 5,321 \n 5,515 \n 5,517 \n 5,485 \n 5,478 \n 5,332 \n 5,235 \n 5,264 \n 5,367 \n 5,426 \n 5,281 \n 5,281 \n 5,281 \n 5,281 \n 5,453 \n 5,453 \n 5,453 \n 5,311 \n 5,311 \n 5,172 \n 5,172 \n 5,352 \n 5,352 \n 76 \n 89 \n 89 \n 81 \n 87 \n 86 \n 91 \n 78 \n 80 \n 84 \n 88 \n 88 \n 85 \n 30 \n 16 \n 9 \n 14 \n 22 \n 12 \n 10 \n 12 \n 5 \n 13 \n 11 \n 12 \n 14 \n 1,724 \n 1,681 \n 1,726 \n 1,770 \n 1,894 \n 1,926 \n 1,898 \n 1,865 \n 1,818 \n 1,817 \n 1,797 \n 1,792 \n 1,815 \n 230 \n 229 \n 206 \n 229 \n 242 \n 213 \n 226 \n 242 \n 258 \n 150 \n 207 \n 325 \n 346 \n 3,161 \n 3,183 \n 3,217 \n 3,231 \n 3,279 \n 3,287 \n 3,277 \n 3,288 \n 3,185 \n 3,181 \n 3,171 \n 3,168 \n 3,176 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 27 of 176 \n Generated 9/9/2010 4:42:44 PM \n 450 \n 450 \n 450 \n 450 \n 450 \n 450 \n 450 \n 450 \n 450 \n 432 \n 432 \n 432 \n 432 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 252 \n 253 \n 249 \n 240 \n 243 \n 243 \n 241 \n 247 \n 245 \n 139 \n 249 \n 252 \n 249 \n 1,694 \n 1,696 \n 1,688 \n 1,676 \n 1,660 \n 1,660 \n 1,627 \n 1,793 \n 1,781 \n 1,778 \n 1,786 \n 1,833 \n 1,844 \n 663 \n 627 \n 672 \n 719 \n 858 \n 895 \n 869 \n 894 \n 762 \n 757 \n 743 \n 741 \n 737 \n 734 \n 734 \n 734 \n 734 \n 876 \n 876 \n 876 \n 734 \n 734 \n 734 \n 734 \n 734 \n 734 \n 1,093 \n 1,088 \n 1,081 \n 1,089 \n 1,097 \n 1,096 \n 1,104 \n 1,089 \n 1,111 \n 1,118 \n 1,178 \n 1,255 \n 1,308 \n 1,251 \n 1,251 \n 1,251 \n 1,251 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 1,281 \n 163 \n 194 \n 195 \n 196 \n 199 \n 197 \n 196 \n 195 \n 194 \n 196 \n 195 \n 196 \n 197 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 1,459 \n 1,417 \n 1,398 \n 1,431 \n 1,448 \n 1,405 \n 1,407 \n 1,414 \n 1,407 \n 1,309 \n 1,292 \n 1,343 \n 1,342 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,295 \n 1,174 \n 1,174 \n 1,354 \n 1,354 \n 3,378 \n 3,326 \n 3,346 \n 3,435 \n 3,602 \n 3,593 \n 3,576 \n 3,592 \n 3,474 \n 3,380 \n 3,408 \n 3,535 \n 3,584 \n 3,430 \n 3,430 \n 3,430 \n 3,430 \n 3,602 \n 3,602 \n 3,602 \n 3,460 \n 3,460 \n 3,339 \n 3,339 \n 3,519 \n 3,519 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3.31 % \n 3.65 % \n 3.85 % \n 4.53 % \n 4.65 % \n 4.71 % \n 3.36 % \n 3.53 % \n 3.50 % \n 3.63 % \n 3.01 % \n 3.47 % \n 3.46 % \n 9 \n 9 \n 7 \n 7 \n 4 \n 4 \n 1 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 28 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,208 \n 1,230 \n 1,240 \n 1,247 \n 1,251 \n 1,230 \n 1,225 \n 1,242 \n 1,224 \n 1,210 \n 1,222 \n 1,229 \n 1,233 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 1,234 \n 209 \n 203 \n 201 \n 211 \n 211 \n 213 \n 209 \n 210 \n 213 \n 218 \n 214 \n 208 \n 232 \n 160 \n 166 \n 160 \n 161 \n 161 \n 91 \n 96 \n 97 \n 88 \n 105 \n 112 \n 121 \n 100 \n 369 \n 369 \n 361 \n 372 \n 372 \n 304 \n 305 \n 307 \n 301 \n 323 \n 326 \n 329 \n 332 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 114 \n 104 \n 95 \n 93 \n 76 \n 71 \n 69 \n 72 \n 64 \n 64 \n 62 \n 63 \n 61 \n 42 \n 46 \n 50 \n 43 \n 13 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 24 \n 6 \n 10 \n 5 \n 9 \n 9 \n 10 \n 28 \n 35 \n 35 \n 26 \n 38 \n 21 \n 22 \n 26 \n 61 \n 69 \n 72 \n 72 \n 90 \n 81 \n 49 \n 88 \n 100 \n 107 \n 221 \n 109 \n 10 \n 17 \n 21 \n 30 \n 30 \n 69 \n 49 \n 49 \n 61 \n 57 \n 92 \n 53 \n 60 \n 66 \n 88 \n 95 \n 111 \n 111 \n 169 \n 158 \n 133 \n 184 \n 183 \n 237 \n 295 \n 191 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 7 \n 4 \n 5 \n 6 \n 4 \n 5 \n 4 \n 4 \n 9 \n 11 \n 6 \n 9 \n 9 \n 25 \n 30 \n 34 \n 24 \n 35 \n 27 \n 32 \n 32 \n 35 \n 39 \n 35 \n 33 \n 43 \n 85 \n 93 \n 90 \n 95 \n 81 \n 79 \n 95 \n 96 \n 103 \n 99 \n 109 \n 100 \n 88 \n 434 \n 431 \n 443 \n 437 \n 411 \n 403 \n 371 \n 396 \n 385 \n 353 \n 355 \n 340 \n 361 \n 392 \n 385 \n 393 \n 394 \n 398 \n 403 \n 371 \n 396 \n 385 \n 353 \n 355 \n 340 \n 361 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 29 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 49 \n 41 \n 41 \n 33 \n 34 \n 33 \n 28 \n 34 \n 38 \n 32 \n 38 \n 41 \n 53 \n 50 \n 41 \n 41 \n 33 \n 34 \n 33 \n 32 \n 35 \n 38 \n 33 \n 39 \n 41 \n 53 \n 128 \n 94 \n 89 \n 90 \n 146 \n 130 \n 142 \n 591 \n 538 \n 537 \n 488 \n 528 \n 495 \n 475 \n 719 \n 632 \n 626 \n 578 \n 674 \n 625 \n 617 \n 1,370 \n 1,315 \n 1,336 \n 1,337 \n 1,347 \n 1,350 \n 1,365 \n 1,330 \n 1,311 \n 1,334 \n 1,331 \n 1,320 \n 1,316 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 1,401 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 85 \n 78 \n 71 \n 70 \n 65 \n 70 \n 68 \n 66 \n 63 \n 0 \n 0 \n 0 \n 0 \n 99 \n 99 \n 99 \n 99 \n 99 \n 99 \n 99 \n 99 \n 99 \n 81 \n 81 \n 81 \n 81 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 3 \n 3 \n 2 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 135 \n 139 \n 150 \n 146 \n 151 \n 145 \n 139 \n 134 \n 201 \n 197 \n 202 \n 196 \n 143 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 150 \n 235 \n 213 \n 210 \n 220 \n 211 \n 223 \n 215 \n 207 \n 200 \n 204 \n 199 \n 205 \n 198 \n 249 \n 249 \n 249 \n 249 \n 249 \n 249 \n 249 \n 249 \n 249 \n 231 \n 231 \n 231 \n 231 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 30 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 19 \n 20 \n 22 \n 11 \n 10 \n 17 \n 20 \n 18 \n 13 \n 16 \n 10 \n 15 \n 23 \n 27 \n 9 \n 22 \n 33 \n 13 \n 4 \n 11 \n 18 \n 25 \n 19 \n 18 \n 16 \n 18 \n 9 \n 23 \n 19 \n 7 \n 18 \n 19 \n 16 \n 16 \n 17 \n 11 \n 12 \n 5 \n 21 \n 11 \n 14 \n 6 \n 3 \n 11 \n 4 \n 5 \n 5 \n 7 \n 13 \n 4 \n 11 \n 5 \n 122 \n 137 \n 138 \n 98 \n 117 \n 125 \n 157 \n 124 \n 127 \n 142 \n 146 \n 155 \n 151 \n 5.31 \n 5.53 \n 5.12 \n 4.45 \n 4.55 \n 5.00 \n 5.71 \n 5.26 \n 5.10 \n 5.41 \n 5.49 \n 5.12 \n 6.21 \n 277 \n 287 \n 268 \n 237 \n 251 \n 276 \n 313 \n 288 \n 272 \n 283 \n 289 \n 275 \n 337 \n 18 \n 7 \n 9 \n 10 \n 10 \n 11 \n 5 \n 8 \n 2 \n 2 \n 1 \n 8 \n 9 \n 28 \n 32 \n 35 \n 5 \n 5 \n 5 \n 6 \n 6 \n 5 \n 7 \n 9 \n 21 \n 22 \n 46 \n 39 \n 44 \n 15 \n 15 \n 16 \n 11 \n 14 \n 7 \n 9 \n 10 \n 29 \n 31 \n 81 \n 69 \n 69 \n 73 \n 118 \n 105 \n 99 \n 99 \n 80 \n 106 \n 68 \n 71 \n 83 \n 425 \n 411 \n 411 \n 407 \n 392 \n 365 \n 364 \n 350 \n 347 \n 345 \n 347 \n 341 \n 367 \n 506 \n 480 \n 480 \n 480 \n 510 \n 470 \n 463 \n 449 \n 427 \n 451 \n 415 \n 412 \n 450 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 20 \n 38 \n 8 \n 18 \n 11 \n 7 \n 18 \n 14 \n 34 \n 30 \n 21 \n 27 \n 19 \n 28 \n 17 \n 51 \n 54 \n 50 \n 43 \n 97 \n 92 \n 77 \n 58 \n 63 \n 55 \n 71 \n 58 \n 67 \n 117 \n 72 \n 61 \n 50 \n 115 \n 106 \n 111 \n 88 \n 84 \n 82 \n 90 \n 86 \n 84 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 31 of 176 \n Generated 9/9/2010 4:42:44 PM \n 10 \n 4 \n 12 \n 5 \n 8 \n 9 \n 7 \n 10 \n 6 \n 7 \n 6 \n 8 \n 8 \n 12 \n 11 \n 16 \n 5 \n 11 \n 6 \n 6 \n 16 \n 8 \n 14 \n 13 \n 8 \n 12 \n 5 \n 4 \n 4 \n 4 \n 4 \n 3 \n 3 \n 3 \n 2 \n 2 \n 4 \n 5 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 6 \n 4 \n 9 \n 1 \n 2 \n 4 \n 10 \n 13 \n 14 \n 11 \n 8 \n 2 \n 0 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0.33 \n 0.29 \n 0.44 \n 0.21 \n 0.31 \n 0.29 \n 0.27 \n 0.46 \n 0.34 \n 0.40 \n 0.40 \n 0.32 \n 0.37 \n 17 \n 15 \n 23 \n 11 \n 17 \n 16 \n 15 \n 25 \n 18 \n 21 \n 21 \n 17 \n 20 \n 1 \n 2 \n 6 \n 4 \n 1 \n 2 \n 4 \n 0 \n 4 \n 1 \n 2 \n 0 \n 1 \n 1.27 \n 1.44 \n 1.49 \n 0.70 \n 1.00 \n 0.98 \n 1.06 \n 1.17 \n 1.14 \n 1.13 \n 1.10 \n 0.91 \n 1.14 \n 66 \n 75 \n 78 \n 37 \n 55 \n 54 \n 58 \n 64 \n 61 \n 59 \n 58 \n 49 \n 62 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 3 \n 5 \n 2 \n 3 \n 5 \n 49 \n 84 \n 61 \n 85 \n 82 \n 107 \n 104 \n 107 \n 83 \n 82 \n 99 \n 73 \n 119 \n 0 \n 18 \n 3 \n 5 \n 14 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 32 of 176 \n Generated 9/9/2010 4:42:44 PM \n 3 \n 2 \n 4 \n 2 \n 3 \n 0 \n 1 \n 1 \n 0 \n 1 \n 4 \n 2 \n 3 \n 4 \n 9 \n 6 \n 2 \n 4 \n 8 \n 3 \n 4 \n 4 \n 0 \n 2 \n 1 \n 3 \n 3 \n 2 \n 4 \n 0 \n 4 \n 1 \n 4 \n 3 \n 4 \n 6 \n 3 \n 1 \n 7 \n 7 \n 11 \n 10 \n 2 \n 8 \n 9 \n 7 \n 7 \n 8 \n 6 \n 5 \n 2 \n 10 \n 2 \n 3 \n 1 \n 1 \n 0 \n 2 \n 1 \n 3 \n 4 \n 3 \n 2 \n 0 \n 1 \n 9 \n 7 \n 6 \n 1 \n 6 \n 3 \n 5 \n 5 \n 7 \n 9 \n 4 \n 9 \n 5 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 9 \n 6 \n 2 \n 6 \n 3 \n 5 \n 5 \n 7 \n 9 \n 4 \n 9 \n 5 \n 0 \n 0 \n 0 \n 2 \n 2 \n 0 \n 0 \n 0 \n 3 \n 2 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 5 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 19 \n 5 \n 2 \n 7 \n 5 \n 1 \n 1 \n 5 \n 6 \n 0 \n 9 \n 2 \n 8 \n 6 \n 5 \n 13 \n 13 \n 3 \n 5 \n 7 \n 4 \n 8 \n 4 \n 4 \n 2 \n 2 \n 2 \n 5 \n 0 \n 6 \n 2 \n 0 \n 2 \n 0 \n 1 \n 0 \n 1 \n 0 \n 8 \n 12 \n 9 \n 9 \n 13 \n 5 \n 4 \n 6 \n 11 \n 10 \n 5 \n 7 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 3 \n 2 \n 2 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 0 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 2 \n 1 \n 2 \n 3 \n 3 \n 3 \n 3 \n 2 \n 4 \n 1 \n 5 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 2 \n 2 \n 2 \n 1 \n 1 \n 3 \n 1 \n 2 \n 1 \n 1 \n 4 \n 1 \n 4 \n 0 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 33 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 3 \n 1 \n 0 \n 3 \n 8 \n 2 \n 2 \n 9 \n 3 \n 3 \n 8 \n 7 \n 2 \n 4 \n 9 \n 5 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 2 \n 1 \n 1 \n 0 \n 5,216 \n 5,191 \n 5,238 \n 5,321 \n 5,514 \n 5,517 \n 5,485 \n 5,477 \n 5,331 \n 5,233 \n 5,263 \n 5,366 \n 5,426 \n 8 \n 10 \n 9 \n 5 \n 8 \n 4 \n 4 \n 11 \n 10 \n 6 \n 5 \n 4 \n 7 \n 23 \n 22 \n 18 \n 37 \n 50 \n 15 \n 17 \n 18 \n 7 \n 9 \n 9 \n 3 \n 7 \n 1 \n 2 \n 3 \n 2 \n 4 \n 4 \n 1 \n 3 \n 3 \n 2 \n 0 \n 2 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 3 \n 1 \n 4 \n 3 \n 0 \n 3 \n 3 \n 2 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 5 \n 3 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 1 \n 17 \n 18 \n 22 \n 10 \n 8 \n 16 \n 21 \n 18 \n 13 \n 16 \n 10 \n 15 \n 23 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 1 \n 4 \n 3 \n 1 \n 4 \n 1 \n 1 \n 0 \n 2 \n 5 \n 1 \n 3 \n 9 \n 5 \n 4 \n 0 \n 2 \n 6 \n 8 \n 5 \n 2 \n 3 \n 12 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 34 of 176 \n Generated 9/9/2010 4:42:44 PM \n 42 \n 68 \n 27 \n 51 \n 66 \n 63 \n 60 \n 85 \n 60 \n 49 \n 53 \n 57 \n 74 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 22 \n 22 \n 21 \n 19 \n 26 \n 28 \n 18 \n 26 \n 4 \n 28 \n 9 \n 24 \n 20 \n 8 \n 22 \n 19 \n 19 \n 20 \n 30 \n 23 \n 37 \n 18 \n 38 \n 46 \n 36 \n 45 \n 48 \n 35 \n 48 \n 40 \n 49 \n 37 \n 27 \n 40 \n 25 \n 40 \n 57 \n 41 \n 55 \n 2 \n 5 \n 3 \n 7 \n 4 \n 3 \n 3 \n 1 \n 1 \n 2 \n 3 \n 1 \n 13 \n 21 \n 11 \n 20 \n 26 \n 35 \n 27 \n 15 \n 21 \n 20 \n 15 \n 12 \n 10 \n 17 \n 29 \n 16 \n 19 \n 34 \n 27 \n 15 \n 16 \n 17 \n 12 \n 16 \n 25 \n 16 \n 15 \n 31 \n 30 \n 18 \n 27 \n 24 \n 24 \n 28 \n 38 \n 33 \n 25 \n 41 \n 26 \n 33 \n 6.69 \n 9.81 \n 6.24 \n 7.61 \n 7.65 \n 6.89 \n 6.24 \n 9.27 \n 7.65 \n 8.69 \n 10.07 \n 16.28 \n 14.04 \n 0 \n 0 \n 1 \n 6 \n 3 \n 1 \n 1 \n 3 \n 3 \n 1 \n 4 \n 2 \n 4 \n 0 \n 0 \n 0 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 15 \n 0 \n 0 \n 3 \n 8 \n 37 \n 19 \n 16 \n 16 \n 10 \n 39 \n 30 \n 1 \n 0 \n 21 \n 19 \n 1 \n 0 \n 1 \n 10 \n 1 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 296 \n 318 \n 263 \n 303 \n 366 \n 298 \n 223 \n 354 \n 237 \n 256 \n 307 \n 284 \n 232 \n 349 \n 509 \n 327 \n 405 \n 422 \n 380 \n 342 \n 508 \n 408 \n 455 \n 530 \n 874 \n 762 \n 645 \n 827 \n 590 \n 708 \n 788 \n 678 \n 565 \n 862 \n 645 \n 711 \n 837 \n 1,158 \n 994 \n 19 \n 18 \n 22 \n 10 \n 8 \n 16 \n 21 \n 18 \n 13 \n 16 \n 10 \n 15 \n 23 \n 19 \n 8 \n 16 \n 5 \n 4 \n 10 \n 15 \n 12 \n 10 \n 9 \n 5 \n 8 \n 10 \n 19 \n 21 \n 24 \n 11 \n 7 \n 16 \n 21 \n 19 \n 13 \n 16 \n 9 \n 15 \n 24 \n 18 \n 8 \n 14 \n 5 \n 4 \n 10 \n 15 \n 11 \n 9 \n 9 \n 4 \n 8 \n 10 \n 19 \n 8 \n 14 \n 5 \n 4 \n 10 \n 15 \n 11 \n 10 \n 9 \n 5 \n 8 \n 10 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 35 of 176 \n Generated 9/9/2010 4:42:44 PM \n 135 \n 123 \n 144 \n 161 \n 162 \n 162 \n 162 \n 144 \n 148 \n 144 \n 43.21 % \n 23.28 % \n 61.54 % \n 76.02 % \n 69.46 % \n 80.08 % \n 81.08 % \n 91.85 % \n 91.67 % \n 95.74 % \n 90.54 % \n 98.58 % \n 99.46 % \n 624 \n 312 \n 480 \n 390 \n 348 \n 418 \n 437 \n 496 \n 495 \n 517 \n 507 \n 554 \n 555 \n 1,444 \n 1,340 \n 780 \n 513 \n 501 \n 522 \n 539 \n 540 \n 540 \n 540 \n 560 \n 562 \n 558 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 7.77 \n 4.69 \n 6.48 \n 4.48 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 4 \n 0 \n 2 \n 1 \n 31 \n 36 \n 15 \n 14 \n 1 \n 0 \n 0 \n 0 \n 0 \n 5 \n 15 \n 0 \n 1 \n 442 \n 483 \n 418 \n 214 \n 119 \n 104 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 118 \n 17 \n 30 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 407 \n 247 \n 348 \n 243 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 525 \n 264 \n 378 \n 253 \n 62 \n 59 \n 61 \n 80 \n 71 \n 54 \n 74 \n 101 \n 137 \n 131 \n 153 \n 161 \n 105 \n 0 \n 0 \n 0 \n 0 \n 348 \n 243 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 4 \n 6 \n 14 \n 14 \n 19 \n 13 \n 22 \n 12 \n 19 \n 9 \n 21 \n 16 \n 14 \n 18 \n 13 \n 8 \n 7 \n 6 \n 7 \n 14 \n 11 \n 11 \n 23 \n 21 \n 26 \n 0 \n 0 \n 0 \n 2 \n 3 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 2 \n 0 \n 15 \n 18 \n 17 \n 20 \n 25 \n 16 \n 16 \n 22 \n 11 \n 20 \n 11 \n 19 \n 19 \n 6 \n 17 \n 15 \n 8 \n 7 \n 10 \n 10 \n 16 \n 10 \n 18 \n 24 \n 20 \n 14 \n 15 \n 143 \n 17 \n 28 \n 29 \n 30 \n 15 \n 27 \n 30 \n 22 \n 35 \n 41 \n 35 \n 21 \n 41 \n 23 \n 22 \n 15 \n 18 \n 16 \n 40 \n 24 \n 21 \n 28 \n 30 \n 32 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 36 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 1 \n 0 \n 1 \n 2 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 2 \n 0 \n 2 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 37 \n 1 \n 22 \n 1 \n 1 \n 1 \n 0 \n 1 \n 11 \n 1 \n 2 \n 3 \n 5 \n 50 \n 10 \n 209 \n 311 \n 340 \n 288 \n 272 \n 221 \n 209 \n 196 \n 232 \n 186 \n 182 \n 188 \n 194 \n 163 \n 155 \n 126 \n 119 \n 112 \n 132 \n 106 \n 103 \n 38 \n 81 \n 3,819 \n 3,895 \n 2,882 \n 8,176 \n 23,561 \n 5,862 \n 14,892 \n 6,181 \n 7,937 \n 7,923 \n 7,161 \n 7,242 \n 10,106 \n 3,727 \n 66 \n 3,793 \n 5,510 \n 2,289 \n 1,350 \n 14,921 \n 2,666 \n 4,008 \n 1,487 \n 1,076 \n 5,180 \n 8,788 \n 7,834 \n 1,223 \n 7,612 \n 9,405 \n 5,171 \n 9,525 \n 26,528 \n 8,527 \n 18,900 \n 7,667 \n 9,013 \n 13,103 \n 15,949 \n 15,075 \n 11,329 \n 16,945 \n 12,889 \n 24,632 \n 25,098 \n 17,293 \n 28,254 \n 23,890 \n 26,731 \n 32,827 \n 44,959 \n 44,531 \n 46,086 \n 53,853 \n 477 \n 261 \n 538 \n 421 \n 640 \n 614 \n 624 \n 661 \n 687 \n 719 \n 74.34 % \n 68.25 % \n 83.33 % \n 87.30 % \n 91.53 % \n 90.21 % \n 94.18 % \n 90.38 % \n 99.03 % \n 99.28 % \n 281 \n 258 \n 315 \n 330 \n 346 \n 341 \n 356 \n 376 \n 410 \n 411 \n 378 \n 378 \n 378 \n 378 \n 378 \n 378 \n 378 \n 416 \n 414 \n 414 \n 80.74 % \n 73.17 % \n 71.53 % \n 66.46 % \n 92.59 % \n 95.06 % \n 99.38 % \n 90.97 % \n 97.30 % \n100.00 %\n 109 \n 90 \n 103 \n 107 \n 150 \n 154 \n 161 \n 131 \n 144 \n 144 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 37 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 140 \n 120 \n 129 \n 127 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 312 \n 291 \n 325 \n 326 \n 361 \n 316 \n 240 \n 120 \n 120 \n 120 \n 360 \n 360 \n 360 \n 360 \n 360 \n 360 \n 240 \n 41 \n 51 \n 78 \n 177 \n 209 \n 213 \n 317 \n 324 \n 326 \n 320 \n 381 \n 379 \n 334 \n 34 \n 33 \n 34 \n 313 \n 292 \n 320 \n 399 \n 428 \n 430 \n 482 \n 536 \n 563 \n 489 \n 8.3 \n 6.6 \n 8.0 \n 8.0 \n 8.3 \n 8.3 \n 8.3 \n 8.3 \n 8.3 \n 8.3 \n 8.3 \n 561 \n 683 \n 541 \n 541 \n 679 \n 639 \n 555 \n 470 \n 431 \n 362 \n 423 \n 536 \n 564 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 10 \n 34 \n 17 \n 0 \n 0 \n 0 \n 12 \n 2 \n 23 \n 11 \n 7 \n 0 \n 0 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 38 of 176 \n Generated 9/9/2010 4:42:44 PM \n 7 \n 209 \n 124 \n 66 \n 66 \n 147 \n 121 \n 117 \n 116 \n 116 \n 98 \n 123 \n 140 \n 203 \n 0 \n 0 \n 0 \n 283 \n 256 \n 317 \n 234 \n 270 \n 222 \n 205 \n 208 \n 221 \n 201 \n 161 \n 146 \n 181 \n 147 \n 154 \n 127 \n 117 \n 118 \n 126 \n 121 \n 234 \n 142 \n 546 \n 1,907 \n 3,678 \n 1,748 \n 5,701 \n 3,533 \n 5,986 \n 2,970 \n 1,560 \n 3,984 \n 2,898 \n 1,252 \n 5,081 \n 1,651 \n 287 \n 1,938 \n 2,002 \n 1,503 \n 1,103 \n 771 \n 819 \n 2,403 \n 1,942 \n 1,249 \n 2,843 \n 4,779 \n 4,111 \n 2,506 \n 2,484 \n 3,908 \n 5,181 \n 2,851 \n 6,472 \n 4,352 \n 8,388 \n 4,912 \n 2,809 \n 6,826 \n 7,676 \n 5,363 \n 7,586 \n 4,905 \n 3,728 \n 4,753 \n 5,718 \n 5,155 \n 3,140 \n 8,156 \n 7,163 \n 13,716 \n 17,700 \n 17,854 \n 19,950 \n 20,157 \n 63 \n 42 \n 35 \n 84 \n 100 \n 151 \n 143 \n 171 \n 170 \n 155 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 88.89 % \n100.00 %\n100.00 %\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 48 \n 54 \n 54 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 54 \n 54 \n 54 \n 50.00 % \n 75.00 % \n 72.59 % \n 74.81 % \n 60.74 % \n 73.33 % \n 80.25 % \n 86.83 % \n 91.36 % \n 90.12 % \n 98.61 % \n 99.54 % \n 99.54 % \n 81 \n 81 \n 98 \n 101 \n 82 \n 99 \n 195 \n 211 \n 222 \n 219 \n 213 \n 215 \n 215 \n 162 \n 108 \n 135 \n 135 \n 135 \n 135 \n 243 \n 243 \n 243 \n 243 \n 216 \n 216 \n 216 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 39 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 474 \n 594 \n 594 \n 594 \n 756 \n 756 \n 756 \n 778 \n 1,136 \n 1,136 \n 1,136 \n 2,478 \n 2,360 \n 2,801 \n 2,122 \n 2,149 \n 2,311 \n 2,290 \n 2,196 \n 2,191 \n 2,155 \n 1,977 \n 1,976 \n 1,971 \n 2,478 \n 2,360 \n 3,275 \n 2,716 \n 2,743 \n 2,905 \n 3,046 \n 2,952 \n 2,947 \n 2,933 \n 3,113 \n 3,112 \n 3,107 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 23 \n 17 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 89.47 % \n 92.63 % \n 97.89 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 170 \n 176 \n 186 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 190 \n 190 \n 190 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 10 \n 4 \n 1 \n 3 \n 2 \n 6 \n 9 \n 12 \n 11 \n 0 \n 2 \n 2 \n 0 \n 8 \n 2 \n 7 \n 3 \n 4 \n 6 \n 4 \n 10 \n 8 \n 2 \n 0 \n 4 \n 0 \n 3 \n 17 \n 2 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 10 \n 0 \n 0 \n 0 \n 0 \n 5 \n 9 \n 2 \n 4 \n 9 \n 2 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 40 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,039 \n 1,905 \n 1,149 \n 1,283 \n 1,283 \n 428 \n 286 \n 165 \n 0 \n 260 \n 1,350 \n 2,228 \n 2,761 \n 304 \n 1,132 \n 217 \n 378 \n 560 \n 1,035 \n 958 \n 1,745 \n 489 \n 424 \n 162 \n 550 \n 967 \n 1,063 \n 2,894 \n 2,642 \n 2,390 \n 1,206 \n 1,713 \n 1,010 \n 1,757 \n 328 \n 605 \n 224 \n 171 \n 4,220 \n 2,378 \n 2,890 \n 3,083 \n 2,779 \n 3,223 \n 2,772 \n 2,884 \n 3,400 \n 3,421 \n 3,131 \n 3,099 \n 2,886 \n 3,097 \n 2,078 \n 1,015 \n 757 \n 2,043 \n 1,200 \n 623 \n 1,559 \n 800 \n 514 \n 1,178 \n 1,236 \n 1,090 \n 2,028 \n 6,904 \n 9,833 \n 7,849 \n 8,871 \n 7,469 \n 6,569 \n 6,695 \n 7,535 \n 4,751 \n 5,598 \n 6,070 \n 6,924 \n 13,072 \n 96.41 % \n 94.64 % \n 95.40 % \n 95.67 % \n 96.03 % \n 90.97 % \n 97.11 % \n 97.11 % \n 97.83 % \n 96.03 % \n 98.14 % \n 97.77 % \n 98.94 % \n 242 \n 247 \n 249 \n 265 \n 266 \n 252 \n 269 \n 269 \n 271 \n 266 \n 264 \n 263 \n 280 \n 251 \n 261 \n 261 \n 277 \n 277 \n 277 \n 277 \n 277 \n 277 \n 277 \n 269 \n 269 \n 283 \n 660 \n 722 \n 622 \n 547 \n 831 \n 669 \n 541 \n 400 \n 414 \n 361 \n 449 \n 599 \n 642 \n 652 \n 700 \n 656 \n 617 \n 819 \n 782 \n 523 \n 423 \n 436 \n 379 \n 463 \n 645 \n 679 \n 27 \n 28 \n 24 \n 19 \n 16 \n 13 \n 16 \n 11 \n 12 \n 18 \n 10 \n 16 \n 18 \n 679 \n 728 \n 680 \n 636 \n 835 \n 795 \n 539 \n 434 \n 448 \n 397 \n 473 \n 661 \n 697 \n 0.00 % \n 0.00 % \n 23.21 % \n 95.96 % \n 82.66 % \n 94.44 % \n 78.57 % \n 93.42 % \n 93.18 % \n 75.37 % \n 90.72 % \n 87.53 % \n 80.35 % \n 88.12 % \n 93.42 % \n 93.18 % \n 66.14 % \n 81.37 % \n 77.58 % \n 73.60 % \n 76.00 % \n 82.66 % \n 81.34 % \n 81.90 % \n 77.93 % \n 82.07 % \n 82.39 % \n 163 \n 161 \n 1,109 \n 506 \n 615 \n 767 \n 731 \n 512 \n 550 \n 531 \n 687 \n 558 \n 547 \n 0 \n 0 \n 55 \n 285 \n 244 \n 280 \n 297 \n 331 \n 343 \n 366 \n 514 \n 552 \n 567 \n 0 \n 0 \n 0 \n 0 \n 3 \n 1 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 55 \n 285 \n 247 \n 281 \n 297 \n 332 \n 343 \n 367 \n 514 \n 552 \n 567 \n 2,315 \n 2,199 \n 2,111 \n 1,925 \n 1,881 \n 1,857 \n 2,018 \n 2,108 \n 2,054 \n 2,035 \n 1,912 \n 2,002 \n 1,993 \n 2,315 \n 2,199 \n 2,166 \n 2,210 \n 2,128 \n 2,138 \n 2,315 \n 2,440 \n 2,397 \n 2,402 \n 2,426 \n 2,554 \n 2,560 \n 3,313 \n 3,235 \n 3,320 \n 3,427 \n 3,580 \n 3,614 \n 3,592 \n 3,607 \n 3,509 \n 3,391 \n 3,446 \n 3,568 \n 3,587 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 41 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 25 \n 0 \n 75 \n 75 \n 100 \n 100 \n 25 \n 0 \n 25 \n 25 \n 25 \n 50 \n 0 \n 2 \n 1 \n 3 \n 3 \n 4 \n 4 \n 1 \n 0 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 254 \n 42 \n 38 \n 32 \n 20 \n 20 \n 14 \n 26 \n 30 \n 10 \n 10 \n 4 \n 2 \n 177 \n 354 \n 364 \n 162 \n 138 \n 75 \n 72 \n 72 \n 91 \n 50 \n 96 \n 21 \n 25 \n 17 \n 21 \n 19 \n 16 \n 10 \n 10 \n 7 \n 13 \n 12 \n 5 \n 5 \n 2 \n 1 \n 472 \n 38 \n 40 \n 22 \n 14 \n 24 \n 28 \n 32 \n 33 \n 26 \n 32 \n 20 \n 12 \n 236 \n 313 \n 338 \n 106 \n 112 \n 84 \n 96 \n 97 \n 82 \n 100 \n 303 \n 118 \n 111 \n 18 \n 19 \n 20 \n 11 \n 7 \n 12 \n 14 \n 16 \n 11 \n 13 \n 16 \n 10 \n 6 \n 726 \n 84 \n 78 \n 60 \n 42 \n 52 \n 50 \n 60 \n 63 \n 38 \n 44 \n 26 \n 18 \n 413 \n 692 \n 702 \n 343 \n 335 \n 259 \n 268 \n 194 \n 173 \n 175 \n 424 \n 164 \n 186 \n 35 \n 42 \n 40 \n 30 \n 21 \n 26 \n 25 \n 30 \n 23 \n 19 \n 22 \n 13 \n 9 \n 13 \n 13 \n 11 \n 9 \n 8 \n 7 \n 5 \n 5 \n 7 \n 5 \n 6 \n 6 \n 5 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 42 of 176 \n Generated 9/9/2010 4:42:44 PM \n 65 \n 64 \n 64 \n 64 \n 64 \n 65 \n 66 \n 66 \n 68 \n 68 \n 65 \n 65 \n 65 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 65 \n 64 \n 64 \n 64 \n 64 \n 65 \n 66 \n 66 \n 68 \n 68 \n 65 \n 65 \n 65 \n 70 \n 80 \n 69 \n 60 \n 56 \n 58 \n 46 \n 60 \n 55 \n 16 \n 13 \n 36 \n 65 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 6 \n 52 \n 75 \n 82 \n 56 \n 72 \n 75 \n 71 \n 78 \n 77 \n 74 \n 59 \n 51 \n 64 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,268 \n 1,267 \n 1,260 \n 1,267 \n 1,270 \n 1,273 \n 1,276 \n 1,276 \n 1,277 \n 1,280 \n 1,261 \n 1,274 \n 1,298 \n 1,320 \n 1,342 \n 1,342 \n 1,323 \n 1,342 \n 1,348 \n 1,347 \n 1,354 \n 1,354 \n 1,354 \n 1,320 \n 1,325 \n 1,362 \n 0.0 \n 0.0 \n 0.0 \n -19.3 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 1,320 \n 1,342 \n 1,342 \n 1,342 \n 1,342 \n 1,348 \n 1,347 \n 1,354 \n 1,354 \n 1,354 \n 1,320 \n 1,325 \n 1,362 \n 2,128 \n 2,128 \n 2,122 \n 2,130 \n 2,134 \n 2,142 \n 2,148 \n 2,155 \n 2,149 \n 2,143 \n 2,100 \n 2,119 \n 2,173 \n -36,287 \n 736,856 \n 628,818 \n 617,129 \n-201,120\n-201,120\n-518,699\n-518,699\n-518,699\n-518,699\n-518,699\n-143,243\n-143,244\n 0 \n4,414,674\n4,329,131\n4,329,131\n3,725,164\n3,725,164\n3,725,164\n3,725,164\n3,725,164\n3,725,164\n3,725,164\n5,028,126\n5,028,126\n -836,262\n-23,945,278\n-9,931,339\n-23,985,260\n-23,580,469\n-23,580,469\n-23,784,715\n-5,063,811\n-7,166,183\n-13,668,600\n-13,668,600\n-4,280,213\n-4,280,213\n 0 \n154,627,895\n155,209,161\n155,209,161\n155,719,938\n155,719,938\n155,719,938\n78,928,537\n78,928,537\n78,926,844\n78,926,844\n179,678,030\n179,678,030\n 0 \n 4 \n 0 \n 6 \n 6 \n 8 \n 8 \n 2 \n 0 \n 2 \n 2 \n 2 \n 4 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 43 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 49 \n 43 \n 43 \n 41 \n 39 \n 40 \n 37 \n 36 \n 39 \n 40 \n 19 \n 10 \n 39 \n 4 \n 4 \n 4 \n 4 \n 4 \n 6 \n 6 \n 6 \n 6 \n 7 \n 7 \n 9 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 363 \n 363 \n 364 \n 365 \n 363 \n 360 \n 360 \n 361 \n 356 \n 354 \n 342 \n 349 \n 363 \n 417 \n 411 \n 412 \n 410 \n 406 \n 406 \n 403 \n 403 \n 401 \n 401 \n 367 \n 367 \n 410 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 417 \n 411 \n 412 \n 410 \n 406 \n 406 \n 403 \n 403 \n 401 \n 401 \n 367 \n 367 \n 410 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 7 \n 7 \n 12 \n -9 \n 3 \n 1 \n 1 \n 1 \n 0 \n 0 \n 1 \n 2 \n 1 \n 2 \n 2 \n 2 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 29 \n 29 \n 29 \n 25 \n 33 \n 35 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 33 \n 38 \n 38 \n 39 \n 30 \n 38 \n 38 \n 38 \n 38 \n 37 \n 37 \n 38 \n 39 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n -8.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 33 \n 38 \n 38 \n 38 \n 38 \n 38 \n 38 \n 38 \n 38 \n 37 \n 37 \n 38 \n 39 \n 1 \n 1 \n 1 \n 1 \n 3 \n 6 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 6 \n 7 \n 6 \n 6 \n 7 \n 7 \n 6 \n 7 \n 8 \n 7 \n 7 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 58 \n 58 \n 57 \n 58 \n 58 \n 58 \n 59 \n 60 \n 61 \n 60 \n 58 \n 58 \n 59 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 44 of 176 \n Generated 9/9/2010 4:42:44 PM \n 20 \n 19 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 1 \n 1 \n 2 \n 1 \n 2 \n 2 \n 6 \n 3 \n 4 \n 4 \n 2 \n 4 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 13 \n 20 \n 18 \n 19 \n 15 \n 17 \n 17 \n 15 \n 13 \n 13 \n 9 \n 12 \n 16 \n 0 \n 0 \n 1 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 150 \n 150 \n 151 \n 153 \n 153 \n 153 \n 154 \n 156 \n 158 \n 158 \n 155 \n 152 \n 155 \n 163 \n 170 \n 170 \n 173 \n 170 \n 171 \n 171 \n 171 \n 171 \n 171 \n 164 \n 164 \n 171 \n 0.0 \n 0.0 \n 0.0 \n 3.3 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 163 \n 170 \n 170 \n 170 \n 170 \n 171 \n 171 \n 171 \n 171 \n 171 \n 164 \n 164 \n 171 \n 3 \n 7 \n 6 \n 5 \n 6 \n 3 \n 1 \n 7 \n 6 \n 5 \n 4 \n 4 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 19 \n 17 \n 20 \n 20 \n 23 \n 15 \n 17 \n 16 \n 21 \n 24 \n 22 \n 21 \n 24 \n 3 \n 3 \n 1 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 245 \n 247 \n 246 \n 247 \n 242 \n 248 \n 248 \n 249 \n 244 \n 238 \n 232 \n 233 \n 246 \n 267 \n 267 \n 267 \n 268 \n 267 \n 266 \n 266 \n 266 \n 266 \n 265 \n 255 \n 255 \n 271 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 267 \n 267 \n 267 \n 267 \n 267 \n 266 \n 266 \n 266 \n 266 \n 265 \n 255 \n 255 \n 271 \n 5 \n 8 \n 12 \n 6 \n 12 \n 8 \n 6 \n 4 \n 4 \n 6 \n 3 \n 3 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 45 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,557 \n 1,667 \n 1,379 \n 1,504 \n 1,982 \n 2,670 \n 1,616 \n 1,766 \n 2,099 \n 2,152 \n 1,974 \n 1,858 \n 1,655 \n 127 \n 84 \n 98 \n 132 \n 141 \n 145 \n 171 \n 302 \n 23 \n 4 \n 246 \n 152 \n 8,357 \n 8,299 \n 7,022 \n 7,376 \n 7,440 \n 6,938 \n 6,469 \n 6,778 \n 7,526 \n 8,235 \n 7,931 \n 7,324 \n 6,871 \n 580 \n 613 \n 607 \n 516 \n 585 \n 493 \n 442 \n 642 \n 524 \n 570 \n 501 \n 487 \n 532 \n 178 \n 145 \n 146 \n 138 \n 200 \n 81 \n 44 \n 144 \n 308 \n 299 \n 74 \n 86 \n 80 \n 9,241 \n 9,141 \n 7,871 \n 8,161 \n 8,365 \n 7,655 \n 7,125 \n 7,563 \n 8,660 \n 9,127 \n 8,510 \n 8,143 \n 7,634 \n 6 \n 6 \n 5 \n 5 \n 6 \n 5 \n 5 \n 5 \n 6 \n 6 \n 6 \n 5 \n 5 \n 12,318 \n 12,332 \n 10,706 \n 11,344 \n 11,897 \n 11,506 \n 9,768 \n 11,001 \n 12,058 \n 13,032 \n 11,963 \n 11,565 \n 10,715 \n 6,030 \n 4,889 \n 6,254 \n 4,836 \n 4,928 \n 4,999 \n 6,455 \n 4,639 \n 6,084 \n 4,797 \n 4,952 \n 6,716 \n 4,441 \n 2,505 \n 2,047 \n 2,784 \n 2,027 \n 2,504 \n 2,248 \n 2,623 \n 3,173 \n 3,454 \n 2,857 \n 3,563 \n 3,607 \n 2,737 \n 159 \n 160 \n 69 \n 32 \n 130 \n 521 \n 538 \n 140 \n 76 \n 52 \n 8 \n 76 \n 90 \n 31,878 \n 19,356 \n 41,089 \n 21,845 \n 18,079 \n 16,577 \n 18,471 \n 15,312 \n 16,946 \n 18,510 \n 17,214 \n 20,216 \n 22,509 \n 3,019 \n 2,318 \n 3,521 \n 2,732 \n 2,808 \n 2,599 \n 5,914 \n 2,484 \n 3,054 \n 2,518 \n 2,839 \n 3,257 \n 2,621 \n 1,254 \n 907 \n 859 \n 456 \n 485 \n 392 \n 927 \n 261 \n 889 \n 819 \n 800 \n 1,047 \n 969 \n 36,309 \n 22,741 \n 45,539 \n 25,065 \n 21,501 \n 20,089 \n 25,850 \n 18,197 \n 20,966 \n 21,898 \n 20,861 \n 24,597 \n 26,189 \n 21 \n 14 \n 26 \n 15 \n 14 \n 13 \n 16 \n 12 \n 14 \n 14 \n 14 \n 16 \n 15 \n 44,844 \n 29,677 \n 54,578 \n 31,928 \n 28,933 \n 27,336 \n 34,928 \n 26,008 \n 30,504 \n 29,552 \n 29,376 \n 34,920 \n 33,366 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 3 \n 0 \n 1 \n 2 \n 2 \n 3 \n 2 \n 2 \n 2 \n 2 \n 2 \n 3 \n 1 \n 2 \n 3 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 15 \n 14 \n 15 \n 15 \n 15 \n 15 \n 15 \n 16 \n 16 \n 16 \n 16 \n 16 \n 15 \n 20 \n 19 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 18 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 46 of 176 \n Generated 9/9/2010 4:42:44 PM \n 871 \n 418 \n 379 \n 237 \n 485 \n 622 \n 194 \n 199 \n 261 \n 268 \n 181 \n 275 \n 246 \n 53 \n 80 \n 16 \n 94 \n 8 \n 0 \n 69 \n 0 \n 49 \n 0 \n 0 \n 55 \n 35 \n 2,052 \n 1,168 \n 1,174 \n 956 \n 911 \n 755 \n 440 \n 677 \n 392 \n 394 \n 324 \n 572 \n 432 \n 458 \n 285 \n 19 \n 44 \n 227 \n 60 \n 56 \n 80 \n 179 \n 48 \n 40 \n 144 \n 26 \n 64 \n 88 \n 73 \n 64 \n 98 \n 176 \n 123 \n 71 \n 143 \n 40 \n 54 \n 97 \n 26 \n 2,627 \n 1,621 \n 1,281 \n 1,158 \n 1,244 \n 991 \n 688 \n 828 \n 762 \n 482 \n 418 \n 867 \n 519 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 3,910 \n 2,247 \n 1,938 \n 1,776 \n 2,048 \n 1,884 \n 998 \n 1,252 \n 1,581 \n 1,182 \n 1,065 \n 1,669 \n 1,157 \n 909 \n 536 \n 539 \n 516 \n 583 \n 543 \n 358 \n 487 \n 387 \n 527 \n 481 \n 472 \n 596 \n 445 \n 474 \n 390 \n 326 \n 750 \n 804 \n 328 \n 354 \n 310 \n 412 \n 585 \n 305 \n 420 \n 2 \n 32 \n 16 \n 105 \n 8 \n 0 \n 69 \n 80 \n 49 \n 120 \n 0 \n 30 \n 10 \n 1,796 \n 1,118 \n 1,390 \n 1,039 \n 669 \n 754 \n 477 \n 405 \n 443 \n 389 \n 316 \n 452 \n 470 \n 318 \n 130 \n 19 \n 5 \n 320 \n 30 \n 9 \n 48 \n 151 \n 30 \n 24 \n 60 \n 26 \n 64 \n 0 \n 48 \n 82 \n 66 \n 48 \n 88 \n 34 \n 108 \n 0 \n 24 \n 73 \n 0 \n 2,179 \n 1,280 \n 1,473 \n 1,231 \n 1,063 \n 831 \n 642 \n 567 \n 750 \n 538 \n 364 \n 614 \n 506 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 3,533 \n 2,290 \n 2,401 \n 2,073 \n 2,396 \n 2,178 \n 1,328 \n 1,408 \n 1,447 \n 1,477 \n 1,430 \n 1,391 \n 1,521 \n 166 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 4 \n 0 \n 4 \n 0 \n 1 \n 5 \n 3 \n 4 \n 4 \n 2 \n 1 \n 1,519 \n 1,524 \n 1,456 \n 1,679 \n 1,550 \n 1,181 \n 1,027 \n 1,673 \n 1,298 \n 1,753 \n 1,480 \n 1,564 \n 1,426 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 47 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 0 \n 2 \n 2 \n 1 \n 1 \n 147 \n 141 \n 152 \n 137 \n 133 \n 138 \n 135 \n 9 \n 5 \n 6 \n 13 \n 7 \n 7 \n 8 \n 0 \n 3 \n 6 \n 6 \n 3 \n 6 \n 6 \n 156 \n 150 \n 164 \n 158 \n 145 \n 152 \n 150 \n 20.57 \n 2.74 \n 2.86 \n 1.74 \n 1.74 \n 1.60 \n 1.72 \n 1.83 \n 1.97 \n 2.12 \n 2.18 \n 2.29 \n 2.45 \n 165 \n 22 \n 23 \n 14 \n 14 \n 13 \n 14 \n 15 \n 16 \n 17 \n 17 \n 18 \n 20 \n 2.19 \n 9.81 \n 9.64 \n 12.30 \n 9.34 \n 9.54 \n 9.36 \n 8.16 \n 7.92 \n 7.69 \n 7.58 \n 7.21 \n 7.81 \n 29 \n 130 \n 127 \n 163 \n 124 \n 127 \n 125 \n 109 \n 106 \n 103 \n 100 \n 96 \n 106 \n 42 \n 21 \n 6 \n 9 \n 15 \n 15 \n 3 \n 24 \n 11 \n 12 \n 10 \n 5 \n 5 \n 17 \n 19 \n 9 \n 11 \n 11 \n 10 \n 11 \n 13 \n 4 \n 9 \n 7 \n 8 \n 7 \n 13 \n 13 \n 12 \n 4 \n 11 \n 12 \n 8 \n 2 \n 2 \n 8 \n 5 \n 5 \n 12 \n 4.36 \n 4.98 \n 3.60 \n 2.98 \n 3.23 \n 3.21 \n 2.58 \n 1.95 \n 1.23 \n 1.99 \n 2.05 \n 1.78 \n 2.82 \n 35 \n 40 \n 29 \n 24 \n 26 \n 26 \n 21 \n 16 \n 10 \n 16 \n 16 \n 14 \n 23 \n 42 \n 28 \n 10 \n 15 \n 10 \n 9 \n 13 \n 9 \n 11 \n 15 \n 11 \n 9 \n 14 \n 10 \n 17 \n 4 \n 9 \n 9 \n 8 \n 10 \n 17 \n 10 \n 12 \n 2 \n 10 \n 3 \n 12 \n 14 \n 10 \n 6 \n 9 \n 10 \n 5 \n 4 \n 7 \n 12 \n 11 \n 10 \n 15 \n 2.94 \n 3.55 \n 2.43 \n 2.34 \n 2.33 \n 2.55 \n 2.32 \n 2.40 \n 1.87 \n 1.87 \n 1.74 \n 1.58 \n 1.99 \n 39 \n 47 \n 32 \n 31 \n 31 \n 34 \n 31 \n 32 \n 25 \n 25 \n 23 \n 21 \n 27 \n 413 \n 208 \n 279 \n 381 \n 319 \n 271 \n 117 \n 225 \n 558 \n 433 \n 467 \n 528 \n 392 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 48 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 5,420 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 75 \n 2 \n 283 \n 1,838 \n 0 \n 1,999 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 104 \n 312 \n 930 \n 750 \n 0 \n 0 \n 0 \n 784 \n 151 \n 0 \n 0 \n 0 \n 0 \n 0 \n 35 \n 841 \n 1,002 \n 303 \n 3,750 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 400 \n 0 \n 0 \n 0 \n 0 \n 0 \n 276 \n 0 \n 422 \n 0 \n 544 \n 7,921 \n 0 \n 180 \n 0 \n 0 \n 0 \n 1.06 \n 0.20 \n 0.60 \n 1.01 \n 0.40 \n 0.57 \n 0.60 \n 0.33 \n 0.22 \n 0.40 \n 0.57 \n 0.14 \n 0.69 \n 0.29 \n 0.00 \n 0.14 \n 0.00 \n 0.34 \n 3.33 \n 0.71 \n 0.14 \n 5.02 \n 4.38 \n 4.97 \n 3.83 \n 4.04 \n 3.98 \n 3.84 \n 385 \n 72 \n 219 \n 368 \n 144 \n 204 \n 216 \n 146 \n 97 \n 177 \n 251 \n 64 \n 309 \n 132 \n 0 \n 8 \n 0 \n 20 \n 193 \n 41 \n 8 \n 6,221 \n 5,567 \n 6,157 \n 4,631 \n 4,940 \n 4,991 \n 4,782 \n 432 \n 104 \n 120 \n 328 \n 144 \n 152 \n 205 \n 0 \n 128 \n 264 \n 102 \n 88 \n 116 \n 139 \n 6,653 \n 5,807 \n 6,541 \n 5,080 \n 5,365 \n 5,300 \n 5,133 \n 11 \n 2 \n 5 \n 6 \n 4 \n 11 \n 4 \n 8 \n 6 \n 6 \n 10 \n 5 \n 8 \n 5 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 49 of 176 \n Generated 9/9/2010 4:42:44 PM \n 5 \n 3 \n 2 \n 4 \n 0 \n 5 \n 4 \n 3 \n 4 \n 2 \n 35 \n 5 \n 3 \n 2 \n 0 \n 1 \n 2 \n 0 \n 1 \n 1 \n 1 \n 1 \n 2 \n 0 \n 1 \n 0 \n 7 \n 4 \n 7 \n 4 \n 1 \n 7 \n 4 \n 5 \n 4 \n 2 \n 36 \n 5 \n 3 \n 0.38 \n 0.14 \n 0.28 \n 0.23 \n 0.33 \n 0.14 \n 0.14 \n 0.32 \n 0.05 \n 0.37 \n 0.38 \n 0.14 \n 1.70 \n 8 \n 3 \n 6 \n 5 \n 7 \n 3 \n 3 \n 7 \n 1 \n 8 \n 8 \n 3 \n 37 \n 2 \n 2 \n 2 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 1 \n 3 \n 5 \n 3 \n 4 \n 5 \n 11 \n 9 \n 5 \n 2 \n 59 \n 4 \n 2 \n 4 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0.28 \n 0.33 \n 0.33 \n 0.28 \n 0.28 \n 0.51 \n 0.42 \n 0.23 \n 0.09 \n 2.75 \n 0.38 \n 0.09 \n 0.32 \n 6 \n 7 \n 7 \n 6 \n 6 \n 11 \n 9 \n 5 \n 2 \n 59 \n 8 \n 2 \n 7 \n 18 % \n 33 % \n 24 % \n 18 % \n 15 % \n 20 % \n 12 % \n 10 % \n 9 % \n 12 % \n 7 % \n 10 % \n 10 % \n 23 \n 35 \n 20 \n 15 \n 9 \n 13 \n 1 \n 4 \n 1 \n 3 \n 3 \n 9 \n 2 \n 19 \n 5 \n 20 \n 29 \n 4 \n 14 \n 2 \n 20 \n 4 \n 2 \n 0 \n 8 \n 5 \n 1,832 \n 2,324 \n 955 \n 542 \n 990 \n 970 \n 817 \n 919 \n 460 \n 816 \n 875 \n 786 \n 950 \n 1,750 \n 1,351 \n 1,029 \n 806 \n 1,141 \n 1,089 \n 1,185 \n 1,205 \n 743 \n 1,044 \n 1,176 \n 1,053 \n 1,016 \n 619 \n 778 \n 309 \n 499 \n 320 \n 385 \n 445 \n 268 \n 189 \n 377 \n 259 \n 113 \n 409 \n 2,084 \n 1,119 \n 605 \n 927 \n 1,231 \n 958 \n 1,482 \n 844 \n 734 \n 881 \n 837 \n 1,268 \n 1,997 \n 106 \n 59 \n 62 \n 81 \n 49 \n 33 \n 117 \n 26 \n 11 \n 10 \n 3 \n 8 \n 16 \n 99 \n 62 \n 60 \n 85 \n 50 \n 37 \n 115 \n 29 \n 11 \n 10 \n 3 \n 8 \n 16 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 50 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 3 \n 0.00 \n 0.28 \n 0.00 \n 0.19 \n 0.00 \n 0.14 \n 0.19 \n 0.14 \n 0.05 \n 0.93 \n 1.19 \n 0.47 \n 0.46 \n 0 \n 6 \n 0 \n 4 \n 0 \n 3 \n 4 \n 3 \n 1 \n 20 \n 25 \n 10 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 5 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 6 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 5 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 5 \n 0 \n 3 \n 0.00 \n 0.05 \n 0.00 \n 0.00 \n 0.09 \n 0.05 \n 0.09 \n 0.05 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.32 \n 0 \n 1 \n 0 \n 0 \n 2 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 1 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 2 \n 0 \n 1 \n 1 \n 5 \n 0 \n 1 \n 2 \n 0 \n 2 \n 1 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 5 \n 3 \n 2 \n 4 \n 0 \n 5 \n 4 \n 3 \n 4 \n 2 \n 35 \n 5 \n 3 \n 6 \n 2 \n 3 \n 2 \n 3 \n 2 \n 1 \n 6 \n 1 \n 5 \n 7 \n 2 \n 37 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCOR\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 51 of 176 \n Generated 9/9/2010 4:42:44 PM \n 158 \n 152 \n 142 \n 133 \n 142 \n 140 \n 138 \n 144 \n 130 \n 129 \n 140 \n 151 \n 128 \n 2,660 \n 2,649 \n 2,625 \n 2,639 \n 2,657 \n 2,657 \n 2,634 \n 2,663 \n 2,642 \n 2,669 \n 2,692 \n 2,663 \n 2,624 \n 16.45 % \n 16.03 % \n 17.57 % \n 18.43 % \n 19.12 % \n 19.09 % \n 17.37 % \n 17.65 % \n 19.17 % \n 18.99 % \n 15.49 % \n 16.58 % \n 19.08 % \n 42 \n 34 \n 42 \n 33 \n 33 \n 32 \n 34 \n 99 \n 97 \n 107 \n 113 \n 118 \n 118 \n 107 \n 108 \n 116 \n 116 \n 92 \n 97 \n 116 \n 602 \n 605 \n 609 \n 613 \n 617 \n 618 \n 616 \n 612 \n 605 \n 611 \n 594 \n 585 \n 608 \n 69.66 % \n 67.83 % \n 76.32 % \n 72.27 % \n 75.63 % \n 75.00 % \n 62.83 % \n 70.09 % \n 63.79 % \n 72.27 % \n 69.64 % \n 69.83 % \n 73.45 % \n 1 \n 0 \n 1 \n 4 \n 3 \n 9 \n 10 \n 62 \n 78 \n 87 \n 86 \n 90 \n 90 \n 71 \n 75 \n 74 \n 86 \n 78 \n 81 \n 83 \n 89 \n 115 \n 114 \n 119 \n 119 \n 120 \n 113 \n 107 \n 116 \n 119 \n 112 \n 116 \n 113 \n 2.72 % \n 4.32 % \n 4.35 % \n 5.20 % \n 5.84 % \n 5.32 % \n 5.47 % \n 7.05 % \n 7.52 % \n 8.08 % \n 8.82 % \n 8.33 % \n 6.91 % \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 7 \n 12 \n 13 \n 14 \n 16 \n 16 \n 17 \n 21 \n 23 \n 24 \n 27 \n 24 \n 21 \n 257 \n 278 \n 299 \n 269 \n 274 \n 301 \n 311 \n 298 \n 306 \n 297 \n 306 \n 288 \n 304 \n 99.73 % \n 99.64 % \n100.33 %\n 99.60 % \n100.80 %\n101.54 %\n100.07 %\n100.00 %\n 99.62 % \n 99.69 % \n100.22 %\n 99.47 % \n 99.35 % \n 4,474 \n 4,470 \n 4,501 \n 4,468 \n 4,522 \n 4,555 \n 4,489 \n 4,486 \n 4,469 \n 4,472 \n 4,496 \n 4,462 \n 4,457 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 4,486 \n 29 \n 27 \n 28 \n 24 \n 28 \n 24 \n 25 \n 29 \n 27 \n 26 \n 31 \n 29 \n 32 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,972 \n 1,965 \n 1,979 \n 1,947 \n 1,970 \n 2,011 \n 1,972 \n 1,969 \n 1,958 \n 1,966 \n 1,983 \n 1,946 \n 1,946 \n 208 \n 233 \n 233 \n 237 \n 238 \n 239 \n 231 \n 224 \n 232 \n 237 \n 227 \n 231 \n 228 \n 2,265 \n 2,246 \n 2,263 \n 2,260 \n 2,286 \n 2,281 \n 2,262 \n 2,266 \n 2,253 \n 2,243 \n 2,255 \n 2,256 \n 2,251 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 52 of 176 \n Generated 9/9/2010 4:42:44 PM \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 343 \n 485 \n 440 \n 480 \n 477 \n 496 \n 494 \n 457 \n 450 \n 445 \n 429 \n 447 \n 467 \n 490 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 570 \n 266 \n 267 \n 262 \n 260 \n 256 \n 261 \n 255 \n 264 \n 258 \n 258 \n 260 \n 259 \n 260 \n 1,222 \n 1,228 \n 1,200 \n 1,199 \n 1,203 \n 1,213 \n 1,212 \n 1,269 \n 1,252 \n 1,260 \n 1,274 \n 1,264 \n 1,513 \n 257 \n 278 \n 299 \n 269 \n 274 \n 301 \n 311 \n 298 \n 306 \n 297 \n 306 \n 288 \n 304 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 1,082 \n 1,094 \n 1,063 \n 1,088 \n 1,090 \n 1,092 \n 1,092 \n 1,090 \n 1,095 \n 1,090 \n 1,093 \n 1,099 \n 1,059 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 1,070 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,269 \n 2,274 \n 2,283 \n 2,283 \n 2,303 \n 2,303 \n 2,270 \n 2,290 \n 2,267 \n 2,309 \n 2,305 \n 2,265 \n 2,286 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 2,203 \n 3,608 \n 3,646 \n 3,645 \n 3,640 \n 3,667 \n 3,696 \n 3,673 \n 3,678 \n 3,668 \n 3,696 \n 3,704 \n 3,652 \n 3,649 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 3,573 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5.94 % \n 5.74 % \n 5.41 % \n 5.04 % \n 5.34 % \n 5.27 % \n 5.24 % \n 5.41 % \n 4.92 % \n 4.83 % \n 5.20 % \n 5.67 % \n 4.88 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 53 of 176 \n Generated 9/9/2010 4:42:44 PM \n 871 \n 894 \n 882 \n 880 \n 880 \n 908 \n 913 \n 915 \n 898 \n 905 \n 906 \n 906 \n 887 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 909 \n 122 \n 114 \n 110 \n 106 \n 126 \n 112 \n 104 \n 105 \n 93 \n 95 \n 96 \n 90 \n 91 \n 233 \n 235 \n 241 \n 241 \n 224 \n 240 \n 244 \n 254 \n 250 \n 253 \n 267 \n 251 \n 261 \n 355 \n 349 \n 351 \n 347 \n 350 \n 352 \n 348 \n 359 \n 343 \n 348 \n 363 \n 341 \n 352 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 113 \n 77 \n 71 \n 68 \n 68 \n 54 \n 49 \n 46 \n 41 \n 45 \n 44 \n 39 \n 0 \n 0 \n 147 \n 146 \n 152 \n 151 \n 143 \n 135 \n 87 \n 84 \n 74 \n 63 \n 55 \n 47 \n 30 \n 15 \n 14 \n 17 \n 25 \n 20 \n 26 \n 33 \n 14 \n 18 \n 12 \n 12 \n 8 \n 8 \n 17 \n 23 \n 25 \n 29 \n 21 \n 21 \n 14 \n 17 \n 12 \n 8 \n 20 \n 9 \n 8 \n 179 \n 183 \n 194 \n 205 \n 184 \n 182 \n 134 \n 115 \n 104 \n 83 \n 87 \n 64 \n 46 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 1 \n 2 \n 2 \n 3 \n 7 \n 26 \n 27 \n 23 \n 22 \n 22 \n 23 \n 28 \n 20 \n 21 \n 15 \n 15 \n 18 \n 16 \n 113 \n 140 \n 113 \n 109 \n 113 \n 98 \n 53 \n 50 \n 42 \n 39 \n 40 \n 46 \n 47 \n 154 \n 168 \n 155 \n 154 \n 166 \n 148 \n 138 \n 133 \n 122 \n 111 \n 117 \n 117 \n 136 \n 465 \n 433 \n 417 \n 395 \n 399 \n 395 \n 382 \n 373 \n 369 \n 366 \n 358 \n 353 \n 286 \n 352 \n 356 \n 346 \n 327 \n 331 \n 341 \n 333 \n 327 \n 328 \n 321 \n 314 \n 314 \n 286 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 54 of 176 \n Generated 9/9/2010 4:42:44 PM \n 3 \n 3 \n 9 \n 12 \n 9 \n 14 \n 11 \n 11 \n 15 \n 11 \n 10 \n 8 \n 9 \n 38 \n 36 \n 41 \n 40 \n 37 \n 33 \n 37 \n 36 \n 36 \n 45 \n 39 \n 37 \n 40 \n 41 \n 39 \n 50 \n 52 \n 46 \n 47 \n 48 \n 47 \n 51 \n 56 \n 49 \n 45 \n 49 \n 82 \n 48 \n 80 \n 97 \n 90 \n 79 \n 96 \n 121 \n 134 \n 123 \n 126 \n 116 \n 112 \n 119 \n 203 \n 182 \n 203 \n 223 \n 206 \n 191 \n 215 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 4 \n 3 \n 4 \n 2 \n 5 \n 5 \n 1 \n 8 \n 6 \n 7 \n 8 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 7 \n 6 \n 6 \n 4 \n 5 \n 4 \n 4 \n 3 \n 4 \n 3 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 20 \n 18 \n 15 \n 11 \n 14 \n 13 \n 8 \n 9 \n 14 \n 13 \n 17 \n 7 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 33 \n 29 \n 24 \n 21 \n 20 \n 23 \n 17 \n 14 \n 25 \n 23 \n 27 \n 17 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 55 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 3 \n 0 \n 2 \n 6 \n 2 \n 3 \n 3 \n 3 \n 2 \n 2 \n 3 \n 14 \n 4 \n 12 \n 13 \n 15 \n 16 \n 28 \n 12 \n 4 \n 23 \n 11 \n 23 \n 42 \n 64 \n 32 \n 37 \n 26 \n 33 \n 24 \n 25 \n 40 \n 23 \n 23 \n 42 \n 23 \n 5 \n 4 \n 4 \n 6 \n 7 \n 3 \n 12 \n 5 \n 8 \n 5 \n 16 \n 4 \n 6 \n 95 \n 211 \n 57 \n 102 \n 95 \n 66 \n 99 \n 97 \n 154 \n 117 \n 133 \n 98 \n 92 \n 4.69 \n 8.21 \n 4.29 \n 5.17 \n 4.36 \n 4.13 \n 4.25 \n 4.12 \n 5.50 \n 4.70 \n 5.72 \n 5.22 \n 4.31 \n 210 \n 367 \n 193 \n 231 \n 197 \n 188 \n 191 \n 185 \n 246 \n 210 \n 257 \n 233 \n 192 \n 1 \n 1 \n 0 \n 0 \n 2 \n 3 \n 3 \n 0 \n 0 \n 1 \n 2 \n 3 \n 0 \n 5 \n 5 \n 2 \n 2 \n 2 \n 2 \n 2 \n 1 \n 4 \n 4 \n 4 \n 4 \n 2 \n 6 \n 6 \n 2 \n 2 \n 4 \n 5 \n 5 \n 1 \n 4 \n 5 \n 6 \n 7 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 78 \n 44 \n 71 \n 85 \n 79 \n 62 \n 82 \n 70 \n 74 \n 76 \n 77 \n 99 \n 70 \n 78 \n 93 \n 80 \n 84 \n 77 \n 77 \n 80 \n 75 \n 78 \n 77 \n 68 \n 73 \n 76 \n 156 \n 137 \n 151 \n 169 \n 156 \n 139 \n 162 \n 145 \n 152 \n 153 \n 145 \n 172 \n 146 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 56 of 176 \n Generated 9/9/2010 4:42:44 PM \n 4 \n 6 \n 10 \n 10 \n 14 \n 5 \n 13 \n 11 \n 13 \n 9 \n 8 \n 8 \n 10 \n 6 \n 32 \n 20 \n 17 \n 25 \n 6 \n 10 \n 19 \n 22 \n 17 \n 16 \n 16 \n 13 \n 4 \n 8 \n 5 \n 4 \n 8 \n 4 \n 3 \n 3 \n 3 \n 1 \n 2 \n 1 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0.49 \n 0.89 \n 0.80 \n 0.72 \n 0.86 \n 0.37 \n 0.69 \n 0.82 \n 0.74 \n 0.67 \n 0.58 \n 0.69 \n 0.56 \n 22 \n 40 \n 36 \n 32 \n 39 \n 17 \n 31 \n 37 \n 33 \n 30 \n 26 \n 31 \n 25 \n 1 \n 0 \n 1 \n 0 \n 1 \n 0 \n 2 \n 2 \n 1 \n 1 \n 3 \n 1 \n 1 \n 0.65 \n 1.45 \n 1.11 \n 1.30 \n 1.19 \n 0.81 \n 1.16 \n 1.16 \n 1.16 \n 1.03 \n 1.22 \n 1.32 \n 0.94 \n 29 \n 65 \n 50 \n 58 \n 54 \n 37 \n 52 \n 52 \n 52 \n 46 \n 55 \n 59 \n 42 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 20 \n 74 \n 96 \n 71 \n 56 \n 69 \n 34 \n 28 \n 29 \n 58 \n 59 \n 76 \n 46 \n 2 \n 20 \n 4 \n 9 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 57 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 2 \n 3 \n 2 \n 2 \n 3 \n 3 \n 4 \n 3 \n 3 \n 2 \n 6 \n 1 \n 10 \n 22 \n 9 \n 11 \n 13 \n 6 \n 7 \n 8 \n 9 \n 5 \n 9 \n 12 \n 7 \n 2 \n 5 \n 4 \n 3 \n 2 \n 5 \n 1 \n 2 \n 4 \n 2 \n 2 \n 5 \n 4 \n 12 \n 27 \n 13 \n 14 \n 15 \n 11 \n 8 \n 10 \n 13 \n 7 \n 11 \n 17 \n 11 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 4 \n 2 \n 5 \n 1 \n 6 \n 1 \n 6 \n 3 \n 7 \n 2 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 4 \n 2 \n 5 \n 1 \n 6 \n 1 \n 6 \n 3 \n 7 \n 2 \n 6 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 0 \n 1 \n 0 \n 0 \n 4 \n 0 \n 3 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 2 \n 2 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 11 \n 17 \n 9 \n 12 \n 8 \n 9 \n 9 \n 13 \n 12 \n 8 \n 9 \n 11 \n 5 \n 5 \n 8 \n 5 \n 5 \n 2 \n 1 \n 4 \n 4 \n 5 \n 3 \n 6 \n 5 \n 1 \n 2 \n 2 \n 1 \n 1 \n 5 \n 1 \n 1 \n 2 \n 2 \n 1 \n 0 \n 1 \n 5 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 58 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 3 \n 2 \n 2 \n 4 \n 0 \n 0 \n 2 \n 4 \n 5 \n 3 \n 3 \n 8 \n 0 \n 6 \n 2 \n 6 \n 10 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 7 \n 4,474 \n 4,470 \n 4,501 \n 4,468 \n 4,522 \n 4,555 \n 4,489 \n 4,486 \n 4,469 \n 4,472 \n 4,493 \n 4,459 \n 4,450 \n 4 \n 2 \n 5 \n 5 \n 8 \n 5 \n 4 \n 11 \n 6 \n 12 \n 11 \n 8 \n 5 \n 6 \n 2 \n 1 \n 0 \n 0 \n 1 \n 0 \n 3 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 3 \n 2 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 1 \n 2 \n 1 \n 4 \n 3 \n 3 \n 3 \n 3 \n 1 \n 0 \n 1 \n 5 \n 1 \n 2 \n 6 \n 2 \n 3 \n 3 \n 2 \n 4 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 2 \n 2 \n 5 \n 6 \n 8 \n 1 \n 6 \n 6 \n 5 \n 5 \n 5 \n 3 \n 5 \n 2 \n 9 \n 7 \n 9 \n 3 \n 6 \n 4 \n 2 \n 1 \n 2 \n 6 \n 11 \n 4 \n 0 \n 1 \n 0 \n 2 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 59 of 176 \n Generated 9/9/2010 4:42:44 PM \n 19 \n 10 \n 17 \n 14 \n 10 \n 17 \n 12 \n 23 \n 17 \n 25 \n 18 \n 14 \n 21 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 7 \n 11 \n 7 \n 20 \n 13 \n 17 \n 14 \n 13 \n 12 \n 15 \n 24 \n 7 \n 18 \n 4 \n 7 \n 19 \n 19 \n 22 \n 7 \n 7 \n 17 \n 15 \n 14 \n 10 \n 9 \n 3 \n 29 \n 21 \n 21 \n 17 \n 24 \n 29 \n 17 \n 24 \n 28 \n 34 \n 35 \n 30 \n 39 \n 2 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 3 \n 19 \n 17 \n 19 \n 9 \n 13 \n 6 \n 12 \n 10 \n 9 \n 11 \n 14 \n 11 \n 16 \n 9 \n 13 \n 14 \n 17 \n 6 \n 10 \n 9 \n 10 \n 9 \n 25 \n 24 \n 12 \n 9 \n 16 \n 13 \n 14 \n 25 \n 21 \n 19 \n 7 \n 9 \n 10 \n 23 \n 19 \n 26 \n 22 \n 4.18 \n 3.56 \n 4.27 \n 4.63 \n 4.82 \n 4.32 \n 3.34 \n 4.41 \n 4.56 \n 6.28 \n 5.58 \n 4.84 \n 6.48 \n 2 \n 0 \n 3 \n 1 \n 3 \n 5 \n 1 \n 0 \n 1 \n 2 \n 1 \n 4 \n 3 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 7 \n 10 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 4 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 33 \n 33 \n 59 \n 17 \n 17 \n 12 \n 13 \n 22 \n 21 \n 19 \n 23 \n 21 \n 14 \n 187 \n 159 \n 192 \n 207 \n 218 \n 197 \n 150 \n 198 \n 204 \n 281 \n 251 \n 216 \n 289 \n 220 \n 192 \n 251 \n 224 \n 235 \n 209 \n 163 \n 220 \n 225 \n 300 \n 274 \n 237 \n 303 \n 3 \n 0 \n 1 \n 5 \n 1 \n 2 \n 6 \n 2 \n 3 \n 3 \n 2 \n 4 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 1 \n 0 \n 0 \n 3 \n 0 \n 0 \n 3 \n 0 \n 2 \n 6 \n 2 \n 3 \n 3 \n 3 \n 2 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 1 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 1 \n 1 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 60 of 176 \n Generated 9/9/2010 4:42:44 PM \n 270 \n 270 \n 513 \n 567 \n 648 \n 619 \n 648 \n 767 \n 648 \n 855 \n 59.56 % \n 53.83 % \n 30.42 % \n100.00 %\n 97.41 % \n 0.00 % \n 85.19 % \n 87.50 % \n 94.83 % \n 95.06 % \n 79.40 % \n 89.04 % \n 72.28 % \n 654 \n 591 \n 334 \n 270 \n 263 \n 0 \n 483 \n 567 \n 587 \n 616 \n 609 \n 577 \n 618 \n 1,098 \n 1,098 \n 1,098 \n 270 \n 270 \n 513 \n 567 \n 648 \n 619 \n 648 \n 767 \n 648 \n 855 \n 0.00 \n 0.00 \n 4.50 \n 5.48 \n 4.36 \n 6.10 \n 5.78 \n 6.50 \n 6.21 \n 0 \n 0 \n 13 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 21 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 12 \n 19 \n 11 \n 10 \n 4 \n 3 \n 1 \n 8 \n 8 \n 5 \n 4 \n 9 \n 1 \n 8 \n 9 \n 4 \n 0 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 156 \n 154 \n 158 \n 192 \n 202 \n 198 \n 234 \n 0 \n 0 \n 202 \n 246 \n 195 \n 273 \n 260 \n 290 \n 277 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 358 \n 400 \n 353 \n 465 \n 462 \n 488 \n 511 \n 37 \n 29 \n 40 \n 37 \n 48 \n 54 \n 40 \n 42 \n 60 \n 77 \n 42 \n 49 \n 87 \n 0 \n 0 \n 3 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 7 \n 6 \n 6 \n 6 \n 3 \n 12 \n 6 \n 7 \n 8 \n 9 \n 6 \n 9 \n 6 \n 7 \n 7 \n 6 \n 9 \n 10 \n 6 \n 9 \n 4 \n 8 \n 10 \n 17 \n 15 \n 3 \n 2 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 1 \n 4 \n 8 \n 3 \n 1 \n 3 \n 2 \n 3 \n 2 \n 4 \n 17 \n 1 \n 0 \n 0 \n 0 \n 5 \n 1 \n 0 \n 3 \n 0 \n 1 \n 0 \n 4 \n 2 \n 18 \n 13 \n 16 \n 18 \n 15 \n 8 \n 13 \n 12 \n 22 \n 25 \n 26 \n 13 \n 14 \n 7 \n 7 \n 10 \n 10 \n 17 \n 13 \n 0 \n 17 \n 9 \n 9 \n 16 \n 10 \n 13 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 61 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 7 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 6 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 10 \n 22 \n 1 \n 0 \n 3 \n 2 \n 4 \n 34 \n 13 \n 7 \n 28 \n 10 \n 77 \n 52 \n 26 \n 31 \n 6 \n 383 \n 346 \n 325 \n 272 \n 266 \n 290 \n 271 \n 238 \n 17 \n 4 \n 209 \n 187 \n 177 \n 162 \n 147 \n 170 \n 159 \n 134 \n 204 \n 3 \n 1,653 \n 432 \n 597 \n 1,376 \n 0 \n 5,016 \n 16,251 \n 6,948 \n 5,630 \n 10,062 \n 7,895 \n 6,171 \n 11,525 \n 18,203 \n 50 \n 18,253 \n 19,028 \n 23,396 \n 10,507 \n 6,268 \n 3,546 \n 7,497 \n 6,471 \n 10,474 \n 7,320 \n 13,422 \n 8,063 \n 11,367 \n 19,906 \n 19,460 \n 23,993 \n 11,883 \n 6,268 \n 8,561 \n 23,748 \n 13,419 \n 16,104 \n 17,382 \n 21,317 \n 14,234 \n 22,891 \n 6,359 \n 9,656 \n 3,260 \n 9,322 \n 117 \n 18,009 \n 22,479 \n 29,374 \n 37,482 \n 52,962 \n 47,381 \n 49,882 \n 49,304 \n 103 \n 5 \n 277 \n 315 \n 411 \n 444 \n 453 \n 384 \n 404 \n 400 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 100.00 %\n 97.41 % \n 0.00 % \n 85.19 % \n 87.50 % \n 94.83 % \n 95.06 % \n 79.40 % \n 89.04 % \n 72.28 % \n 270 \n 263 \n 0 \n 483 \n 567 \n 587 \n 616 \n 609 \n 577 \n 618 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 62 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 216 \n 216 \n 216 \n 216 \n 270 \n 270 \n 270 \n 0 \n 0 \n 0 \n 0 \n 20 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 120 \n 0 \n 0 \n 0 \n 0 \n 120 \n 27 \n 115 \n 115 \n 115 \n 113 \n 120 \n 120 \n 120 \n 120 \n 120 \n 27 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 30 \n 34 \n 35 \n 30 \n 6 \n 0 \n 21 \n 33 \n 15 \n 46 \n 84 \n 29 \n 34 \n 20 \n 16 \n 14 \n 83 \n 15 \n 0 \n 24 \n 80 \n 11 \n 74 \n 139 \n 68 \n 47 \n 6.0 \n 5.7 \n 5.7 \n 5.7 \n 5.7 \n 5.7 \n 5.6 \n 5.7 \n 5.7 \n 5.7 \n 5.7 \n 655 \n 626 \n 789 \n 1,082 \n 1,096 \n 870 \n 755 \n 755 \n 723 \n 711 \n 691 \n 653 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 18 \n 7 \n 5 \n 5 \n 0 \n 5 \n 8 \n 0 \n 0 \n 17 \n 0 \n 0 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 63 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 29 \n 24 \n 29 \n 35 \n 41 \n 46 \n 39 \n 39 \n 40 \n 29 \n 0 \n 37 \n 0 \n 0 \n 0 \n 0 \n 34 \n 6 \n 563 \n 544 \n 522 \n 504 \n 472 \n 446 \n 416 \n 385 \n 17 \n 3 \n 273 \n 260 \n 257 \n 246 \n 235 \n 217 \n 198 \n 185 \n 0 \n 0 \n 169 \n 0 \n 169 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 643 \n 3,332 \n 98 \n 3,430 \n 3,921 \n 3,286 \n 4,752 \n 897 \n 3,293 \n 5,038 \n 3,322 \n 3,621 \n 5,013 \n 5,051 \n 6,143 \n 2,469 \n 3,599 \n 3,921 \n 3,455 \n 4,752 \n 897 \n 3,293 \n 5,038 \n 3,322 \n 3,621 \n 5,013 \n 5,051 \n 6,143 \n 3,111 \n 1,264 \n 1,420 \n 1,681 \n 468 \n 0 \n 0 \n 0 \n 520 \n 930 \n 1,371 \n 1,417 \n 0 \n 3,408 \n 5 \n 0 \n 0 \n 0 \n 7 \n 11 \n 12 \n 12 \n 0 \n 28 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 100.00 %\n 98.15 % \n100.00 %\n 88.89 % \n 0.00 % \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 54 \n 53 \n 54 \n 48 \n 0 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 64 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,569 \n 2,565 \n 2,582 \n 1,917 \n 1,917 \n 2,269 \n 2,269 \n 2,269 \n 2,268 \n 2,268 \n 2,268 \n 2,270 \n 2,270 \n 2,569 \n 2,565 \n 2,582 \n 1,917 \n 1,917 \n 2,269 \n 2,269 \n 2,269 \n 2,268 \n 2,268 \n 2,268 \n 2,270 \n 2,270 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 65 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,927 \n 1,905 \n 1,963 \n 2,243 \n 2,300 \n 2,658 \n 2,133 \n 2,043 \n 1,916 \n 1,902 \n 1,977 \n 1,908 \n 1,819 \n 1,307 \n 1,283 \n 1,416 \n 1,709 \n 1,726 \n 2,091 \n 1,622 \n 1,371 \n 1,408 \n 1,380 \n 1,360 \n 1,353 \n 1,302 \n 21 \n 19 \n 20 \n 20 \n 16 \n 21 \n 27 \n 26 \n 26 \n 28 \n 31 \n 29 \n 30 \n 1,328 \n 1,302 \n 1,436 \n 1,729 \n 1,742 \n 2,112 \n 1,649 \n 1,397 \n 1,434 \n 1,408 \n 1,391 \n 1,382 \n 1,332 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 75.94 % \n 78.21 % \n 75.87 % \n 85.81 % \n 85.92 % \n 57.91 % \n 79.11 % \n 75.94 % \n 78.21 % \n 75.87 % \n 85.81 % \n 85.92 % \n 57.91 % \n 79.11 % \n 87.09 % \n 88.49 % \n 89.64 % \n 87.52 % \n 87.40 % \n 88.50 % \n 618 \n 559 \n 623 \n 272 \n 270 \n 955 \n 474 \n 293 \n 261 \n 235 \n 283 \n 286 \n 261 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,951 \n 2,006 \n 1,959 \n 1,645 \n 1,647 \n 1,314 \n 1,795 \n 1,976 \n 2,007 \n 2,033 \n 1,985 \n 1,984 \n 2,009 \n 1,951 \n 2,006 \n 1,959 \n 1,645 \n 1,647 \n 1,314 \n 1,795 \n 1,976 \n 2,007 \n 2,033 \n 1,985 \n 1,984 \n 2,009 \n 3,369 \n 3,443 \n 3,472 \n 3,474 \n 3,525 \n 3,600 \n 3,620 \n 3,622 \n 3,611 \n 3,661 \n 3,633 \n 3,616 \n 3,606 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 66 of 176 \n Generated 9/9/2010 4:42:44 PM \n 450 \n 125 \n 160 \n 160 \n 200 \n 50 \n 150 \n 100 \n 150 \n 0 \n 0 \n 0 \n 0 \n 12 \n 14 \n 8 \n 8 \n 5 \n 2 \n 6 \n 4 \n 6 \n 0 \n 0 \n 0 \n 0 \n 400 \n 150 \n 160 \n 300 \n 300 \n 100 \n 200 \n 200 \n 200 \n 0 \n 0 \n 0 \n 0 \n 200 \n 57 \n 80 \n 150 \n 150 \n 50 \n 100 \n 100 \n 100 \n 0 \n 0 \n 0 \n 0 \n 8 \n 6 \n 4 \n 6 \n 6 \n 2 \n 4 \n 4 \n 4 \n 0 \n 0 \n 0 \n 0 \n 400 \n 400 \n 400 \n 520 \n 650 \n 600 \n 750 \n 750 \n 750 \n 0 \n 0 \n 0 \n 0 \n 200 \n 200 \n 200 \n 260 \n 325 \n 300 \n 375 \n 375 \n 375 \n 0 \n 0 \n 0 \n 0 \n 15 \n 10 \n 10 \n 13 \n 13 \n 12 \n 15 \n 15 \n 15 \n 0 \n 0 \n 0 \n 0 \n 500 \n 404 \n 600 \n 600 \n 1,050 \n 750 \n 1,100 \n 830 \n 830 \n 0 \n 0 \n 0 \n 0 \n 250 \n 202 \n 300 \n 300 \n 525 \n 375 \n 550 \n 415 \n 415 \n 0 \n 0 \n 0 \n 0 \n 15 \n 10 \n 15 \n 15 \n 21 \n 15 \n 22 \n 20 \n 20 \n 0 \n 0 \n 0 \n 0 \n 2,200 \n 1,204 \n 1,480 \n 1,740 \n 2,400 \n 1,550 \n 2,350 \n 1,980 \n 2,080 \n 0 \n 0 \n 0 \n 0 \n 1,100 \n 584 \n 740 \n 870 \n 1,200 \n 775 \n 1,175 \n 990 \n 1,040 \n 0 \n 0 \n 0 \n 0 \n 50 \n 40 \n 37 \n 42 \n 45 \n 31 \n 47 \n 43 \n 45 \n 0 \n 0 \n 0 \n 0 \n 18 \n 17 \n 18 \n 18 \n 18 \n 16 \n 16 \n 16 \n 16 \n 29 \n 29 \n 29 \n 29 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 67 of 176 \n Generated 9/9/2010 4:42:44 PM \n 46 \n 45 \n 44 \n 42 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 42 \n 42 \n 47 \n 0.0 \n 1.0 \n 0.0 \n -2.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 46 \n 44 \n 44 \n 44 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 42 \n 42 \n 47 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 6 \n 6 \n 6 \n 7 \n 5 \n 4 \n 3 \n 3 \n 3 \n 3 \n 3 \n 0 \n 0 \n 4 \n 7 \n 4 \n 1 \n 2 \n 3 \n 8 \n 4 \n 5 \n 5 \n 5 \n 2 \n 2 \n 109 \n 124 \n 90 \n 83 \n 79 \n 79 \n 58 \n 43 \n 45 \n 39 \n -15 \n -9 \n 12 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 0 \n 2 \n 10 \n 21 \n 43 \n 34 \n 40 \n 5 \n 3 \n 4 \n 0 \n 3 \n 6 \n 6 \n 5 \n 6 \n 8 \n 14 \n 11 \n 7 \n 778 \n 770 \n 802 \n 804 \n 819 \n 816 \n 824 \n 844 \n 833 \n 826 \n 829 \n 835 \n 835 \n 892 \n 897 \n 897 \n 887 \n 902 \n 902 \n 888 \n 894 \n 894 \n 894 \n 871 \n 871 \n 894 \n 0.0 \n 0.0 \n 0.0 \n -10.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 892 \n 897 \n 897 \n 897 \n 902 \n 902 \n 888 \n 894 \n 894 \n 894 \n 871 \n 871 \n 894 \n 1,309 \n 1,297 \n 1,325 \n 1,333 \n 1,354 \n 1,355 \n 1,374 \n 1,402 \n 1,385 \n 1,375 \n 1,360 \n 1,367 \n 1,401 \n -17,313 \n 205,547 \n 239,825 \n 54,621 \n 75,202 \n 37,298 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n3,869,313\n3,869,313\n3,700,105\n3,700,105\n3,577,790\n3,577,790\n3,577,790\n 0 \n 0 \n 0 \n 0 \n 0 \n 761,913 \n-14,008,948\n-13,355,469\n-20,844,549\n-21,181,342\n-18,106,763\n-19,600,821\n-19,543,820\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n108,679,916\n108,679,916\n101,063,203\n101,063,203\n104,599,978\n104,599,978\n104,599,978\n 0 \n 0 \n 0 \n 0 \n 0 \n 900 \n 250 \n 320 \n 320 \n 400 \n 100 \n 300 \n 200 \n 300 \n 0 \n 0 \n 0 \n 0 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 68 of 176 \n Generated 9/9/2010 4:42:44 PM \n 8 \n 10 \n 11 \n 13 \n 13 \n 11 \n 12 \n 13 \n 13 \n 17 \n 11 \n 11 \n 14 \n 24 \n 25 \n 30 \n 23 \n 30 \n 24 \n 22 \n 19 \n 22 \n 21 \n 9 \n 6 \n 25 \n 8 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 0 \n 0 \n 1 \n 2 \n 1 \n 2 \n 2 \n 1 \n 1 \n 3 \n 0 \n 2 \n 1 \n 148 \n 142 \n 137 \n 140 \n 138 \n 144 \n 150 \n 154 \n 150 \n 149 \n 142 \n 143 \n 151 \n 179 \n 170 \n 171 \n 168 \n 173 \n 173 \n 178 \n 178 \n 177 \n 177 \n 155 \n 155 \n 181 \n 0.0 \n -1.0 \n 0.0 \n -2.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 179 \n 171 \n 171 \n 170 \n 173 \n 173 \n 178 \n 178 \n 177 \n 177 \n 155 \n 155 \n 181 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 5 \n 15 \n 14 \n 4 \n 3 \n 2 \n 2 \n 3 \n 1 \n 0 \n 1 \n 7 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 22 \n 22 \n 22 \n 23 \n 32 \n 34 \n 35 \n 35 \n 34 \n 33 \n 34 \n 34 \n 36 \n 23 \n 28 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 34 \n 34 \n 35 \n 43 \n 0.0 \n -9.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 23 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 37 \n 34 \n 34 \n 35 \n 43 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 3 \n 2 \n 0 \n 4 \n 4 \n 2 \n 2 \n 2 \n 5 \n 4 \n 4 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 41 \n 42 \n 42 \n 42 \n 42 \n 42 \n 44 \n 44 \n 44 \n 41 \n 38 \n 38 \n 44 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 69 of 176 \n Generated 9/9/2010 4:42:44 PM \n 16 \n 14 \n 14 \n 14 \n 14 \n 14 \n 13 \n 13 \n 13 \n 13 \n 12 \n 12 \n 14 \n 1 \n 1 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 15 \n 11 \n 7 \n 9 \n 8 \n 13 \n 15 \n 13 \n 18 \n 12 \n 11 \n 12 \n 14 \n 1 \n 1 \n 2 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 4 \n 7 \n 4 \n 2 \n 4 \n 3 \n 1 \n 2 \n 1 \n 6 \n 2 \n 1 \n 2 \n 119 \n 120 \n 126 \n 126 \n 124 \n 123 \n 123 \n 124 \n 120 \n 121 \n 114 \n 115 \n 123 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 128 \n 128 \n 139 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 139 \n 128 \n 128 \n 139 \n 5 \n 0 \n 1 \n 2 \n 2 \n 4 \n 4 \n 2 \n 2 \n 4 \n 7 \n 5 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 36 \n 34 \n 40 \n 38 \n 38 \n 40 \n 34 \n 30 \n 32 \n 20 \n 15 \n 16 \n 25 \n 2 \n 1 \n 2 \n 3 \n 3 \n 2 \n 2 \n 2 \n 2 \n 3 \n 2 \n 1 \n 1 \n 3 \n 3 \n 3 \n 3 \n 1 \n 1 \n 4 \n 5 \n 1 \n 3 \n 0 \n 2 \n 2 \n 187 \n 190 \n 185 \n 186 \n 187 \n 185 \n 188 \n 190 \n 193 \n 194 \n 192 \n 191 \n 200 \n 228 \n 228 \n 230 \n 230 \n 229 \n 228 \n 228 \n 227 \n 228 \n 220 \n 209 \n 210 \n 228 \n 0.0 \n -2.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 228 \n 230 \n 230 \n 230 \n 229 \n 228 \n 228 \n 227 \n 228 \n 220 \n 209 \n 210 \n 228 \n 0 \n 1 \n 2 \n 2 \n 2 \n 2 \n 4 \n 2 \n 2 \n 2 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 70 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,769 \n 1,048 \n 1,001 \n 1,528 \n 1,359 \n 1,413 \n 1,546 \n 1,572 \n 1,245 \n 2,045 \n 1,766 \n 1,525 \n 1,826 \n 78 \n 23 \n 128 \n 73 \n 74 \n 104 \n 90 \n 50 \n 168 \n 135 \n 50 \n 64 \n 3,445 \n 3,455 \n 2,665 \n 2,691 \n 3,145 \n 2,841 \n 2,652 \n 3,902 \n 3,030 \n 3,884 \n 3,476 \n 3,427 \n 3,622 \n 315 \n 583 \n 443 \n 363 \n 230 \n 212 \n 212 \n 317 \n 369 \n 309 \n 373 \n 270 \n 173 \n 16 \n 6 \n 24 \n 40 \n 40 \n 52 \n 94 \n 44 \n 20 \n 29 \n 11 \n 232 \n 196 \n 3,854 \n 4,067 \n 3,132 \n 3,222 \n 3,488 \n 3,178 \n 3,062 \n 4,354 \n 3,469 \n 4,389 \n 3,994 \n 3,979 \n 4,056 \n 5 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 5 \n 4 \n 5 \n 4 \n 4 \n 4 \n 6,017 \n 5,609 \n 4,748 \n 5,405 \n 5,536 \n 4,975 \n 5,206 \n 6,474 \n 5,302 \n 6,772 \n 6,081 \n 6,019 \n 6,261 \n 2,291 \n 1,866 \n 2,378 \n 1,701 \n 1,402 \n 1,583 \n 2,173 \n 1,653 \n 2,349 \n 1,489 \n 1,343 \n 1,833 \n 1,343 \n 1,546 \n 1,300 \n 1,668 \n 1,274 \n 1,261 \n 1,282 \n 1,731 \n 1,317 \n 1,480 \n 1,089 \n 980 \n 1,631 \n 1,426 \n 191 \n 40 \n 161 \n 91 \n 78 \n 172 \n 90 \n 49 \n 186 \n 33 \n 54 \n 154 \n 105 \n 23,337 \n 16,707 \n 38,397 \n 14,414 \n 12,844 \n 10,890 \n 13,084 \n 12,751 \n 12,962 \n 11,878 \n 11,570 \n 14,259 \n 10,883 \n 2,133 \n 2,317 \n 2,643 \n 1,494 \n 894 \n 1,538 \n 2,523 \n 1,597 \n 1,764 \n 1,744 \n 1,811 \n 2,544 \n 1,801 \n 817 \n 506 \n 660 \n 298 \n 145 \n 383 \n 606 \n 242 \n 552 \n 545 \n 817 \n 641 \n 630 \n 26,477 \n 19,570 \n 41,861 \n 16,297 \n 13,960 \n 12,982 \n 16,303 \n 14,638 \n 15,464 \n 14,199 \n 14,252 \n 17,598 \n 13,419 \n 23 \n 18 \n 35 \n 14 \n 12 \n 12 \n 15 \n 13 \n 14 \n 12 \n 12 \n 15 \n 12 \n 30,313 \n 22,736 \n 45,907 \n 19,272 \n 16,623 \n 15,847 \n 20,206 \n 17,608 \n 19,293 \n 16,776 \n 16,575 \n 21,062 \n 16,187 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 2 \n 1 \n 2 \n 2 \n 3 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 15 \n 12 \n 12 \n 13 \n 12 \n 12 \n 10 \n 11 \n 11 \n 11 \n 11 \n 11 \n 12 \n 16 \n 14 \n 14 \n 14 \n 14 \n 14 \n 13 \n 13 \n 13 \n 13 \n 12 \n 12 \n 14 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 71 of 176 \n Generated 9/9/2010 4:42:44 PM \n 769 \n 461 \n 289 \n 279 \n 251 \n 234 \n 187 \n 318 \n 322 \n 422 \n 358 \n 501 \n 518 \n 92 \n 87 \n 0 \n 8 \n 48 \n 16 \n 9 \n 8 \n 9 \n 79 \n 12 \n 277 \n 221 \n 2,215 \n 1,149 \n 1,360 \n 1,060 \n 755 \n 1,155 \n 1,001 \n 1,125 \n 754 \n 825 \n 1,209 \n 953 \n 1,202 \n 425 \n 558 \n 280 \n 285 \n 261 \n 194 \n 153 \n 257 \n 243 \n 362 \n 240 \n 194 \n 324 \n 58 \n 52 \n 104 \n 108 \n 28 \n 25 \n 136 \n 116 \n 89 \n 200 \n 41 \n 16 \n 72 \n 2,790 \n 1,846 \n 1,743 \n 1,460 \n 1,091 \n 1,390 \n 1,299 \n 1,505 \n 1,095 \n 1,466 \n 1,502 \n 1,440 \n 1,819 \n 3 \n 2 \n 2 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 2 \n 3,882 \n 2,541 \n 2,252 \n 2,068 \n 1,644 \n 1,744 \n 1,619 \n 1,984 \n 1,469 \n 1,988 \n 1,984 \n 2,059 \n 2,519 \n 322 \n 209 \n 138 \n 373 \n 268 \n 182 \n 249 \n 218 \n 136 \n 355 \n 69 \n 178 \n 121 \n 425 \n 358 \n 146 \n 478 \n 608 \n 492 \n 462 \n 398 \n 475 \n 624 \n 443 \n 232 \n 285 \n 40 \n 87 \n 0 \n 8 \n 48 \n 16 \n 9 \n 8 \n 8 \n 38 \n 8 \n 56 \n 16 \n 1,898 \n 1,016 \n 1,236 \n 1,030 \n 756 \n 1,154 \n 1,051 \n 1,121 \n 770 \n 877 \n 1,030 \n 993 \n 761 \n 141 \n 408 \n 299 \n 192 \n 217 \n 221 \n 140 \n 290 \n 184 \n 311 \n 267 \n 150 \n 309 \n 130 \n 24 \n 48 \n 16 \n 28 \n 110 \n 120 \n 40 \n 65 \n 80 \n 17 \n 8 \n 32 \n 2,209 \n 1,535 \n 1,582 \n 1,246 \n 1,049 \n 1,500 \n 1,320 \n 1,458 \n 1,027 \n 1,307 \n 1,322 \n 1,206 \n 1,118 \n 2 \n 2 \n 1 \n 2 \n 1 \n 2 \n 1 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 2,955 \n 2,101 \n 1,866 \n 2,097 \n 1,925 \n 2,174 \n 2,030 \n 2,073 \n 1,637 \n 2,285 \n 1,834 \n 1,616 \n 1,523 \n 259 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 395 \n 494 \n 616 \n 656 \n 689 \n 384 \n 599 \n 549 \n 588 \n 338 \n 322 \n 516 \n 380 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 72 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 2 \n 0 \n 1 \n 1 \n 2 \n 1 \n 46 \n 58 \n 42 \n 55 \n 52 \n 48 \n 52 \n 3 \n 6 \n 3 \n 3 \n 2 \n 2 \n 5 \n 1 \n 2 \n 2 \n 1 \n 1 \n 0 \n 0 \n 51 \n 68 \n 47 \n 60 \n 56 \n 52 \n 58 \n 7.34 \n 5.97 \n 5.82 \n 5.95 \n 5.28 \n 4.22 \n 3.36 \n 2.92 \n 4.52 \n 4.72 \n 3.45 \n 3.24 \n 2.49 \n 36 \n 29 \n 28 \n 29 \n 26 \n 21 \n 17 \n 15 \n 23 \n 24 \n 17 \n 16 \n 13 \n 7.57 \n 9.85 \n 6.40 \n 7.80 \n 7.90 \n 7.23 \n 7.95 \n 6.64 \n 7.75 \n 8.07 \n 6.57 \n 6.76 \n 5.69 \n 62 \n 80 \n 54 \n 66 \n 68 \n 62 \n 69 \n 59 \n 68 \n 70 \n 57 \n 59 \n 50 \n 3 \n 5 \n 5 \n 0 \n 2 \n 9 \n 11 \n 10 \n 4 \n 14 \n 7 \n 11 \n 4 \n 8 \n 12 \n 3 \n 7 \n 0 \n 1 \n 0 \n 10 \n 2 \n 8 \n 7 \n 8 \n 10 \n 3 \n 6 \n 11 \n 3 \n 1 \n 0 \n 7 \n 4 \n 0 \n 3 \n 2 \n 6 \n 5 \n 2.85 \n 3.09 \n 3.53 \n 3.69 \n 4.06 \n 3.22 \n 4.55 \n 2.53 \n 3.74 \n 3.74 \n 4.46 \n 4.45 \n 4.02 \n 14 \n 15 \n 17 \n 18 \n 20 \n 16 \n 23 \n 13 \n 19 \n 19 \n 22 \n 22 \n 21 \n 21 \n 11 \n 11 \n 9 \n 20 \n 20 \n 15 \n 21 \n 8 \n 19 \n 12 \n 25 \n 10 \n 7 \n 9 \n 6 \n 9 \n 7 \n 6 \n 5 \n 12 \n 12 \n 10 \n 10 \n 11 \n 13 \n 3 \n 2 \n 13 \n 7 \n 4 \n 0 \n 8 \n 4 \n 10 \n 3 \n 3 \n 8 \n 8 \n 3.17 \n 3.33 \n 3.08 \n 3.90 \n 3.48 \n 3.50 \n 3.34 \n 2.59 \n 3.19 \n 2.88 \n 2.31 \n 2.41 \n 2.62 \n 26 \n 27 \n 26 \n 33 \n 30 \n 30 \n 29 \n 23 \n 28 \n 25 \n 20 \n 21 \n 23 \n 323 \n 234 \n 221 \n 329 \n 302 \n 121 \n 134 \n 160 \n 52 \n 101 \n 124 \n 119 \n 183 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 73 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7,733 \n 1,378 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 281 \n 0 \n 960 \n 0 \n 8 \n 13 \n 550 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2.07 \n 0.51 \n 0.06 \n 0.11 \n 0.64 \n 0.74 \n 0.21 \n 0.83 \n 0.57 \n 0.51 \n 0.70 \n 0.91 \n 0.36 \n 0.14 \n 0.18 \n 2.86 \n 0.00 \n 0.10 \n 0.21 \n 0.45 \n 0.11 \n 2.04 \n 2.71 \n 1.79 \n 2.84 \n 2.55 \n 1.19 \n 1.81 \n 306 \n 72 \n 8 \n 16 \n 88 \n 106 \n 32 \n 285 \n 196 \n 175 \n 244 \n 324 \n 127 \n 50 \n 7 \n 120 \n 0 \n 4 \n 9 \n 19 \n 5 \n 1,572 \n 1,726 \n 1,443 \n 2,346 \n 2,124 \n 976 \n 1,432 \n 44 \n 160 \n 32 \n 48 \n 16 \n 24 \n 136 \n 48 \n 192 \n 32 \n 8 \n 48 \n 0 \n 0 \n 1,671 \n 2,198 \n 1,507 \n 2,406 \n 2,197 \n 1,019 \n 1,573 \n 6 \n 3 \n 1 \n 2 \n 1 \n 3 \n 4 \n 16 \n 11 \n 9 \n 15 \n 12 \n 9 \n 5 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 74 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 2 \n 1 \n 4 \n 6 \n 1 \n 6 \n 3 \n 2 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 2 \n 2 \n 4 \n 6 \n 1 \n 4 \n 4 \n 2 \n 3 \n 0 \n 3 \n 1 \n 1.37 \n 1.08 \n 0.08 \n 0.00 \n 0.37 \n 0.66 \n 0.58 \n 0.21 \n 0.29 \n 0.51 \n 0.66 \n 0.15 \n 0.21 \n 18 \n 14 \n 1 \n 0 \n 5 \n 9 \n 8 \n 3 \n 4 \n 7 \n 9 \n 2 \n 3 \n 2 \n 0 \n 1 \n 1 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 3 \n 0 \n 4 \n 1 \n 2 \n 2 \n 2 \n 3 \n 2 \n 4 \n 5 \n 1 \n 44 \n 3 \n 6 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.23 \n 0.15 \n 0.23 \n 0.22 \n 0.22 \n 0.30 \n 0.29 \n 0.43 \n 0.07 \n 3.20 \n 0.44 \n 0.44 \n 0.50 \n 3 \n 2 \n 3 \n 3 \n 3 \n 4 \n 4 \n 6 \n 1 \n 44 \n 6 \n 6 \n 7 \n 2 % \n 4 % \n 5 % \n 5 % \n 5 % \n 5 % \n 4 % \n 3 % \n 6 % \n 8 % \n 4 % \n 3 % \n 4 % \n 4 \n 5 \n 0 \n 2 \n 1 \n 3 \n 3 \n 3 \n 1 \n 8 \n 3 \n 13 \n 19 \n 13 \n 12 \n 3 \n 6 \n 1 \n 3 \n 3 \n 1 \n 2 \n 9 \n 7 \n 13 \n 20 \n 1,702 \n 1,355 \n 1,097 \n 1,697 \n 1,199 \n 1,061 \n 943 \n 1,393 \n 763 \n 1,324 \n 988 \n 827 \n 1,882 \n 1,511 \n 1,465 \n 1,071 \n 1,546 \n 1,385 \n 1,099 \n 1,020 \n 1,515 \n 769 \n 1,336 \n 1,139 \n 1,016 \n 1,753 \n 651 \n 550 \n 526 \n 577 \n 402 \n 418 \n 957 \n 295 \n 506 \n 1,523 \n 398 \n 367 \n 486 \n 792 \n 1,122 \n 905 \n 1,432 \n 1,545 \n 976 \n 6,140 \n 880 \n 977 \n 1,502 \n 1,998 \n 1,066 \n 1,604 \n 105 \n 149 \n 118 \n 191 \n 107 \n 67 \n 62 \n 64 \n 41 \n 63 \n 51 \n 57 \n 137 \n 102 \n 148 \n 117 \n 180 \n 104 \n 70 \n 65 \n 56 \n 51 \n 37 \n 50 \n 63 \n 121 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 75 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0.00 \n 0.08 \n 0.00 \n 0.30 \n 0.37 \n 0.30 \n 0.00 \n 0.07 \n 0.14 \n 0.22 \n 0.37 \n 0.07 \n 0.07 \n 0 \n 1 \n 0 \n 4 \n 5 \n 4 \n 0 \n 1 \n 2 \n 3 \n 5 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 1 \n 2 \n 1 \n 1 \n 0 \n 0 \n 2 \n 18 \n 2 \n 16 \n 16 \n 19 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.07 \n 0.07 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 2 \n 2 \n 2 \n 2 \n 3 \n 4 \n 4 \n 6 \n 6 \n 6 \n 7 \n 8 \n 4 \n 0 \n 1 \n 1 \n 0 \n 1 \n 0 \n 0 \n 4 \n 5 \n 11 \n 3 \n 10 \n 4 \n 11 \n 12 \n 12 \n 11 \n 17 \n 18 \n 19 \n 38 \n 18 \n 36 \n 36 \n 39 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 4 \n 6 \n 1 \n 3 \n 0 \n 2 \n 2 \n 0 \n 2 \n 1 \n 10 \n 13 \n 1 \n 0 \n 6 \n 7 \n 3 \n 3 \n 2 \n 2 \n 1 \n 2 \n 3 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nHDSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 76 of 176 \n Generated 9/9/2010 4:42:44 PM \n 157 \n 161 \n 170 \n 165 \n 160 \n 163 \n 172 \n 155 \n 157 \n 195 \n 191 \n 204 \n 208 \n 3,587 \n 3,685 \n 3,727 \n 3,713 \n 3,713 \n 3,678 \n 3,703 \n 3,711 \n 3,708 \n 3,701 \n 3,718 \n 3,727 \n 3,705 \n 11.52 % \n 10.10 % \n 11.78 % \n 11.89 % \n 10.32 % \n 9.48 % \n 11.46 % \n 11.50 % \n 10.77 % \n 12.87 % \n 13.49 % \n 12.94 % \n 11.43 % \n 54 \n 39 \n 35 \n 48 \n 27 \n 41 \n 48 \n 31 \n 29 \n 35 \n 34 \n 29 \n 29 \n 33 \n 33 \n 32 \n 39 \n 41 \n 37 \n 36 \n 269 \n 287 \n 297 \n 286 \n 281 \n 306 \n 288 \n 287 \n 297 \n 303 \n 304 \n 286 \n 315 \n 40.91 % \n 48.10 % \n 48.00 % \n 52.50 % \n 58.97 % \n 62.96 % \n 69.90 % \n 55.83 % \n 72.17 % \n 57.63 % \n 63.08 % \n 35.94 % \n 37.50 % \n 8 \n 4 \n 3 \n 6 \n 2 \n 5 \n 5 \n 27 \n 38 \n 48 \n 63 \n 69 \n 68 \n 72 \n 67 \n 83 \n 68 \n 41 \n 23 \n 15 \n 66 \n 79 \n 100 \n 120 \n 117 \n 108 \n 103 \n 120 \n 115 \n 118 \n 65 \n 64 \n 40 \n 7.26 % \n 5.36 % \n 5.48 % \n 6.08 % \n 6.65 % \n 6.84 % \n 8.36 % \n 7.24 % \n 9.79 % \n 9.47 % \n 12.35 % \n 10.10 % \n 10.70 % \n 0 \n 3 \n 4 \n 1 \n 0 \n 1 \n 4 \n 22 \n 15 \n 16 \n 18 \n 21 \n 21 \n 26 \n 21 \n 23 \n 23 \n 31 \n 20 \n 26 \n 303 \n 280 \n 292 \n 296 \n 316 \n 307 \n 311 \n 290 \n 235 \n 243 \n 251 \n 198 \n 243 \n 93.78 % \n 97.58 % \n 99.00 % \n100.65 %\n 98.69 % \n 98.34 % \n 98.28 % \n 98.69 % \n 97.01 % \n 97.25 % \n 98.49 % \n 97.35 % \n 97.43 % \n 4,580 \n 4,762 \n 4,831 \n 4,811 \n 4,816 \n 4,799 \n 4,796 \n 4,816 \n 4,734 \n 4,746 \n 4,752 \n 4,697 \n 4,701 \n 4,884 \n 4,880 \n 4,880 \n 4,780 \n 4,880 \n 4,880 \n 4,880 \n 4,880 \n 4,880 \n 4,880 \n 4,825 \n 4,825 \n 4,825 \n 19 \n 22 \n 21 \n 20 \n 19 \n 19 \n 21 \n 22 \n 19 \n 17 \n 21 \n 22 \n 22 \n 1 \n 1 \n 0 \n 8 \n 7 \n 2 \n 2 \n 10 \n 3 \n 1 \n 38 \n 2 \n 4 \n 1,906 \n 2,002 \n 2,027 \n 2,009 \n 2,006 \n 2,005 \n 2,019 \n 1,995 \n 1,923 \n 1,940 \n 1,950 \n 1,952 \n 1,993 \n 329 \n 360 \n 392 \n 400 \n 393 \n 408 \n 385 \n 401 \n 408 \n 415 \n 363 \n 344 \n 349 \n 2,328 \n 2,378 \n 2,396 \n 2,383 \n 2,393 \n 2,369 \n 2,373 \n 2,393 \n 2,393 \n 2,380 \n 2,389 \n 2,388 \n 2,342 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 77 of 176 \n Generated 9/9/2010 4:42:44 PM \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 396 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 421 \n 462 \n 461 \n 456 \n 460 \n 463 \n 463 \n 474 \n 473 \n 469 \n 473 \n 478 \n 484 \n 1,546 \n 1,610 \n 1,595 \n 1,589 \n 1,625 \n 1,623 \n 1,612 \n 1,673 \n 1,651 \n 1,646 \n 1,651 \n 1,654 \n 1,656 \n 303 \n 280 \n 292 \n 296 \n 316 \n 307 \n 311 \n 290 \n 235 \n 243 \n 251 \n 198 \n 243 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 1,754 \n 1,044 \n 1,045 \n 1,032 \n 1,037 \n 1,046 \n 1,054 \n 1,040 \n 1,055 \n 1,075 \n 1,071 \n 1,059 \n 1,076 \n 1,802 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 1,067 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,167 \n 3,007 \n 3,074 \n 3,086 \n 3,079 \n 3,044 \n 3,038 \n 3,084 \n 3,059 \n 3,045 \n 3,046 \n 3,011 \n 2,979 \n 2,386 \n 3,117 \n 3,117 \n 3,017 \n 3,117 \n 3,117 \n 3,117 \n 3,117 \n 3,117 \n 3,117 \n 3,062 \n 3,062 \n 3,062 \n 4,224 \n 4,331 \n 4,411 \n 4,414 \n 4,432 \n 4,397 \n 4,403 \n 4,414 \n 4,349 \n 4,363 \n 4,368 \n 4,268 \n 4,298 \n 4,488 \n 4,484 \n 4,484 \n 4,384 \n 4,484 \n 4,484 \n 4,484 \n 4,484 \n 4,484 \n 4,484 \n 4,429 \n 4,429 \n 4,429 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4.38 % \n 4.37 % \n 4.56 % \n 4.44 % \n 4.31 % \n 4.43 % \n 4.64 % \n 4.18 % \n 4.23 % \n 5.27 % \n 5.14 % \n 5.47 % \n 5.61 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 78 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,323 \n 1,282 \n 1,299 \n 1,293 \n 1,299 \n 1,298 \n 1,295 \n 1,276 \n 1,252 \n 1,221 \n 1,209 \n 1,221 \n 1,215 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 1,300 \n 213 \n 138 \n 138 \n 141 \n 130 \n 139 \n 143 \n 145 \n 141 \n 140 \n 140 \n 132 \n 131 \n 199 \n 200 \n 200 \n 190 \n 201 \n 204 \n 202 \n 204 \n 197 \n 197 \n 196 \n 183 \n 191 \n 412 \n 338 \n 338 \n 331 \n 331 \n 343 \n 345 \n 349 \n 338 \n 337 \n 336 \n 315 \n 322 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 89 \n 91 \n 94 \n 86 \n 86 \n 90 \n 94 \n 88 \n 85 \n 75 \n 103 \n 143 \n 169 \n 0 \n 30 \n 12 \n 31 \n 16 \n 12 \n 20 \n 24 \n 24 \n 24 \n 14 \n 29 \n 14 \n 22 \n 8 \n 10 \n 13 \n 10 \n 11 \n 15 \n 12 \n 18 \n 14 \n 16 \n 14 \n 33 \n 32 \n 16 \n 11 \n 8 \n 6 \n 8 \n 17 \n 12 \n 12 \n 10 \n 6 \n 13 \n 10 \n 12 \n 54 \n 33 \n 52 \n 32 \n 31 \n 52 \n 48 \n 54 \n 48 \n 36 \n 56 \n 57 \n 66 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 1 \n 30 \n 30 \n 33 \n 32 \n 27 \n 30 \n 26 \n 17 \n 16 \n 9 \n 11 \n 14 \n 15 \n 61 \n 58 \n 61 \n 71 \n 65 \n 75 \n 72 \n 71 \n 78 \n 112 \n 113 \n 98 \n 78 \n 107 \n 97 \n 118 \n 114 \n 109 \n 117 \n 115 \n 112 \n 113 \n 108 \n 103 \n 91 \n 97 \n 426 \n 500 \n 490 \n 461 \n 451 \n 473 \n 466 \n 466 \n 448 \n 440 \n 466 \n 548 \n 550 \n 337 \n 409 \n 396 \n 375 \n 365 \n 383 \n 372 \n 378 \n 363 \n 365 \n 363 \n 405 \n 381 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 79 of 176 \n Generated 9/9/2010 4:42:44 PM \n 50 \n 34 \n 50 \n 52 \n 51 \n 87 \n 85 \n 64 \n 67 \n 62 \n 48 \n 52 \n 47 \n 128 \n 122 \n 120 \n 118 \n 118 \n 114 \n 113 \n 112 \n 114 \n 156 \n 139 \n 135 \n 122 \n 178 \n 156 \n 170 \n 170 \n 169 \n 201 \n 198 \n 176 \n 181 \n 218 \n 187 \n 187 \n 169 \n 206 \n 168 \n 173 \n 189 \n 196 \n 204 \n 223 \n 199 \n 194 \n 187 \n 177 \n 174 \n 177 \n 175 \n 405 \n 362 \n 360 \n 366 \n 370 \n 381 \n 398 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 14 \n 9 \n 8 \n 7 \n 10 \n 12 \n 9 \n 8 \n 6 \n 10 \n 12 \n 5 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 89 \n 91 \n 92 \n 88 \n 86 \n 82 \n 87 \n 95 \n 91 \n 93 \n 88 \n 88 \n 94 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 18 \n 17 \n 11 \n 15 \n 15 \n 17 \n 14 \n 14 \n 13 \n 14 \n 20 \n 25 \n 25 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 121 \n 117 \n 111 \n 110 \n 111 \n 111 \n 110 \n 117 \n 110 \n 117 \n 120 \n 118 \n 125 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n 96 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 80 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 5 \n 3 \n 2 \n 6 \n 3 \n 2 \n 5 \n 6 \n 1 \n 5 \n 9 \n 3 \n 16 \n 15 \n 12 \n 15 \n 11 \n 10 \n 15 \n 21 \n 28 \n 9 \n 25 \n 17 \n 12 \n 21 \n 28 \n 23 \n 19 \n 22 \n 20 \n 32 \n 13 \n 18 \n 19 \n 47 \n 16 \n 34 \n 8 \n 10 \n 4 \n 9 \n 5 \n 8 \n 9 \n 9 \n 8 \n 2 \n 6 \n 7 \n 7 \n 94 \n 111 \n 128 \n 105 \n 105 \n 97 \n 137 \n 77 \n 100 \n 123 \n 106 \n 130 \n 138 \n 5.50 \n 5.27 \n 5.71 \n 4.34 \n 5.36 \n 4.33 \n 5.75 \n 4.19 \n 6.25 \n 5.98 \n 6.46 \n 5.43 \n 5.98 \n 252 \n 251 \n 276 \n 209 \n 258 \n 208 \n 276 \n 202 \n 296 \n 284 \n 307 \n 255 \n 281 \n 20 \n 19 \n 18 \n 15 \n 20 \n 17 \n 21 \n 16 \n 16 \n 10 \n 12 \n 14 \n 13 \n 17 \n 16 \n 18 \n 20 \n 18 \n 18 \n 17 \n 18 \n 18 \n 18 \n 20 \n 22 \n 1 \n 37 \n 35 \n 36 \n 35 \n 38 \n 35 \n 38 \n 34 \n 34 \n 28 \n 32 \n 36 \n 14 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 136 \n 115 \n 105 \n 122 \n 125 \n 100 \n 117 \n 129 \n 109 \n 109 \n 140 \n 109 \n 166 \n 54 \n 56 \n 49 \n 39 \n 38 \n 45 \n 45 \n 40 \n 38 \n 37 \n 36 \n 31 \n 42 \n 190 \n 171 \n 154 \n 161 \n 163 \n 145 \n 162 \n 169 \n 147 \n 146 \n 176 \n 140 \n 208 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 81 of 176 \n Generated 9/9/2010 4:42:44 PM \n 14 \n 9 \n 5 \n 12 \n 9 \n 15 \n 8 \n 7 \n 3 \n 6 \n 9 \n 9 \n 8 \n 35 \n 24 \n 21 \n 19 \n 20 \n 28 \n 20 \n 13 \n 16 \n 14 \n 18 \n 20 \n 18 \n 12 \n 13 \n 10 \n 13 \n 10 \n 11 \n 10 \n 12 \n 10 \n 12 \n 13 \n 13 \n 6 \n 1 \n 0 \n 0 \n 6 \n 9 \n 7 \n 9 \n 14 \n 13 \n 5 \n 21 \n 47 \n 31 \n 10 \n 16 \n 56 \n 33 \n 74 \n 65 \n 65 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 3 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0.94 \n 0.80 \n 0.64 \n 0.58 \n 0.66 \n 0.73 \n 0.67 \n 0.56 \n 0.53 \n 0.44 \n 0.53 \n 0.66 \n 0.62 \n 43 \n 38 \n 31 \n 28 \n 32 \n 35 \n 32 \n 27 \n 25 \n 21 \n 25 \n 31 \n 29 \n 3 \n 4 \n 4 \n 2 \n 0 \n 2 \n 2 \n 4 \n 3 \n 3 \n 2 \n 1 \n 0 \n 1.51 \n 1.47 \n 1.28 \n 1.10 \n 1.31 \n 1.21 \n 1.21 \n 1.12 \n 1.12 \n 0.97 \n 1.20 \n 1.32 \n 1.34 \n 69 \n 70 \n 62 \n 53 \n 63 \n 58 \n 58 \n 54 \n 53 \n 46 \n 57 \n 62 \n 63 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 7 \n 9 \n 3 \n 83 \n 82 \n 106 \n 59 \n 109 \n 70 \n 81 \n 77 \n 136 \n 130 \n 118 \n 76 \n 87 \n 0 \n 0 \n 0 \n 0 \n 28 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 82 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 1 \n 2 \n 2 \n 3 \n 5 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 2 \n 5 \n 9 \n 6 \n 7 \n 7 \n 6 \n 10 \n 2 \n 8 \n 4 \n 4 \n 8 \n 2 \n 2 \n 2 \n 1 \n 2 \n 4 \n 1 \n 5 \n 5 \n 2 \n 2 \n 4 \n 2 \n 4 \n 7 \n 11 \n 7 \n 9 \n 11 \n 7 \n 15 \n 7 \n 10 \n 6 \n 8 \n 10 \n 6 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 5 \n 8 \n 3 \n 6 \n 6 \n 5 \n 5 \n 5 \n 2 \n 2 \n 4 \n 8 \n 3 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 5 \n 8 \n 3 \n 7 \n 6 \n 8 \n 5 \n 5 \n 3 \n 2 \n 4 \n 8 \n 3 \n 0 \n 6 \n 0 \n 2 \n 0 \n 3 \n 2 \n 3 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 2 \n 2 \n 2 \n 2 \n 2 \n 4 \n 0 \n 1 \n 6 \n 6 \n 5 \n 4 \n 2 \n 2 \n 2 \n 4 \n 4 \n 3 \n 2 \n 3 \n 2 \n 7 \n 0 \n 4 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 5 \n 2 \n 1 \n 0 \n 4 \n 6 \n 5 \n 2 \n 4 \n 5 \n 5 \n 5 \n 4 \n 5 \n 4 \n 4 \n 11 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 20 \n 13 \n 11 \n 6 \n 11 \n 14 \n 13 \n 12 \n 7 \n 7 \n 8 \n 7 \n 4 \n 3 \n 3 \n 2 \n 3 \n 1 \n 1 \n 2 \n 3 \n 1 \n 2 \n 1 \n 1 \n 3 \n 2 \n 2 \n 2 \n 1 \n 6 \n 1 \n 2 \n 6 \n 1 \n 2 \n 1 \n 1 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 83 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 4,580 \n 4,761 \n 4,831 \n 4,811 \n 4,816 \n 4,799 \n 4,796 \n 4,816 \n 4,734 \n 4,745 \n 4,752 \n 4,696 \n 4,701 \n 13 \n 10 \n 13 \n 10 \n 3 \n 13 \n 14 \n 11 \n 8 \n 11 \n 9 \n 8 \n 16 \n 28 \n 28 \n 24 \n 26 \n 20 \n 38 \n 42 \n 21 \n 39 \n 53 \n 22 \n 16 \n 15 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 1 \n 1 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 1 \n 4 \n 2 \n 1 \n 5 \n 1 \n 2 \n 2 \n 1 \n 4 \n 0 \n 0 \n 2 \n 5 \n 3 \n 3 \n 6 \n 3 \n 2 \n 5 \n 4 \n 1 \n 6 \n 9 \n 2 \n 3 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 1 \n 1 \n 8 \n 3 \n 1 \n 2 \n 5 \n 3 \n 4 \n 2 \n 2 \n 1 \n 2 \n 5 \n 3 \n 12 \n 9 \n 14 \n 13 \n 9 \n 6 \n 7 \n 5 \n 8 \n 7 \n 11 \n 9 \n 9 \n 1 \n 4 \n 1 \n 1 \n 3 \n 2 \n 0 \n 1 \n 2 \n 0 \n 2 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 84 of 176 \n Generated 9/9/2010 4:42:44 PM \n 9 \n 15 \n 10 \n 11 \n 12 \n 15 \n 16 \n 19 \n 15 \n 16 \n 9 \n 10 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 7 \n 22 \n 23 \n 11 \n 15 \n 11 \n 18 \n 32 \n 25 \n 21 \n 24 \n 9 \n 22 \n 21 \n 18 \n 14 \n 14 \n 14 \n 20 \n 0 \n 5 \n 6 \n 7 \n 6 \n 3 \n 3 \n 4 \n 38 \n 43 \n 35 \n 49 \n 38 \n 37 \n 20 \n 21 \n 28 \n 30 \n 27 \n 18 \n 13 \n 3 \n 3 \n 1 \n 2 \n 1 \n 0 \n 3 \n 1 \n 2 \n 2 \n 2 \n 1 \n 0 \n 7 \n 6 \n 15 \n 8 \n 11 \n 11 \n 7 \n 9 \n 11 \n 5 \n 9 \n 5 \n 7 \n 9 \n 9 \n 12 \n 4 \n 14 \n 13 \n 11 \n 6 \n 5 \n 9 \n 6 \n 10 \n 6 \n 27 \n 15 \n 24 \n 15 \n 17 \n 19 \n 26 \n 25 \n 19 \n 26 \n 16 \n 16 \n 10 \n 6.57 \n 6.30 \n 5.38 \n 5.34 \n 5.98 \n 4.63 \n 4.44 \n 11.86 \n 9.38 \n 15.07 \n 11.83 \n 14.78 \n 15.66 \n 0 \n 4 \n 0 \n 0 \n 1 \n 21 \n 19 \n 16 \n 19 \n 0 \n 15 \n 7 \n 7 \n 5 \n 10 \n 1 \n 1 \n 0 \n 0 \n 0 \n 3 \n 1 \n 2 \n 6 \n 3 \n 2 \n 39 \n 23 \n 11 \n 15 \n 14 \n 30 \n 13 \n 34 \n 16 \n 0 \n 2 \n 0 \n 7 \n 2 \n 2 \n 0 \n 2 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 5 \n 0 \n 7 \n 246 \n 733 \n 794 \n 849 \n 828 \n 622 \n 908 \n 651 \n 588 \n 830 \n 873 \n 832 \n 908 \n 301 \n 300 \n 260 \n 257 \n 288 \n 222 \n 213 \n 571 \n 444 \n 715 \n 562 \n 694 \n 736 \n 547 \n 1,033 \n 1,054 \n 1,106 \n 1,116 \n 844 \n 1,121 \n 1,222 \n 1,032 \n 1,545 \n 1,435 \n 1,526 \n 1,644 \n 2 \n 5 \n 3 \n 3 \n 6 \n 3 \n 2 \n 5 \n 4 \n 1 \n 6 \n 9 \n 2 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 1 \n 3 \n 3 \n 1 \n 2 \n 5 \n 3 \n 2 \n 6 \n 3 \n 2 \n 5 \n 6 \n 1 \n 6 \n 9 \n 4 \n 2 \n 0 \n 2 \n 2 \n 3 \n 2 \n 1 \n 2 \n 3 \n 0 \n 5 \n 6 \n 2 \n 2 \n 1 \n 2 \n 2 \n 3 \n 2 \n 1 \n 2 \n 3 \n 1 \n 5 \n 6 \n 2 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 85 of 176 \n Generated 9/9/2010 4:42:44 PM \n 57 \n 80 \n 0 \n 416 \n 321 \n 318 \n 323 \n 323 \n 385 \n 444 \n 43.19 % \n 43.32 % \n 59.82 % \n 89.81 % \n 43.09 % \n 0.00 % \n 0.00 % \n 99.47 % \n101.34 %\n100.00 %\n100.53 %\n 99.54 % \n100.00 %\n 425 \n 428 \n 335 \n 141 \n 81 \n 0 \n 0 \n 373 \n 377 \n 377 \n 376 \n 437 \n 498 \n 984 \n 988 \n 560 \n 157 \n 188 \n 0 \n 469 \n 375 \n 372 \n 377 \n 374 \n 439 \n 498 \n 0.00 \n 9.88 \n 9.49 \n 9.20 \n 9.27 \n 6.41 \n 6.27 \n 0.00 \n 0.00 \n 0 \n 0 \n 1 \n 3 \n 0 \n 6 \n 1 \n 0 \n 0 \n 5 \n 1 \n 2 \n 3 \n 7 \n 1 \n 18 \n 28 \n 1 \n 2 \n 0 \n 0 \n 0 \n 194 \n 141 \n 5 \n 2 \n 0 \n 0 \n 130 \n 108 \n 188 \n 194 \n 214 \n 200 \n 179 \n 202 \n 153 \n 169 \n 155 \n 106 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 239 \n 170 \n 185 \n 137 \n 131 \n 154 \n 0 \n 0 \n 0 \n 474 \n 455 \n 443 \n 439 \n 304 \n 298 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 713 \n 625 \n 628 \n 576 \n 435 \n 452 \n 0 \n 0 \n 101 \n 96 \n 78 \n 75 \n 97 \n 73 \n 44 \n 61 \n 78 \n 72 \n 105 \n 72 \n 86 \n 354 \n 224 \n 462 \n 331 \n 512 \n 554 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 6 \n 7 \n 5 \n 12 \n 6 \n 6 \n 7 \n 4 \n 10 \n 1 \n 5 \n 2 \n 2 \n 4 \n 8 \n 1 \n 7 \n 4 \n 5 \n 6 \n 3 \n 3 \n 6 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 9 \n 16 \n 10 \n 17 \n 7 \n 2 \n 4 \n 2 \n 5 \n 9 \n 7 \n 8 \n 4 \n 1 \n 5 \n 2 \n 4 \n 6 \n 2 \n 2 \n 2 \n 3 \n 6 \n 0 \n 2 \n 0 \n 24 \n 23 \n 22 \n 26 \n 19 \n 15 \n 19 \n 16 \n 16 \n 24 \n 25 \n 6 \n 13 \n 22 \n 22 \n 11 \n 11 \n 16 \n 7 \n 13 \n 11 \n 3 \n 11 \n 5 \n 2 \n 5 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 86 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 10 \n 0 \n 1 \n 38 \n 18 \n 11 \n 139 \n 23 \n 0 \n 195 \n 183 \n 497 \n 126 \n 108 \n 570 \n 341 \n 81 \n 17 \n 0 \n 122 \n 89 \n 150 \n 67 \n 69 \n 133 \n 114 \n 192 \n 21 \n 2,981 \n 2,888 \n 483 \n 4,902 \n 156 \n 0 \n 3,296 \n 3,164 \n 2,240 \n 3,820 \n 8,309 \n 1,795 \n 3,878 \n 7,940 \n 170 \n 8,110 \n 6,795 \n 1,367 \n 1,853 \n 1,158 \n 0 \n 8,474 \n 7,768 \n 9,326 \n 9,190 \n 11,510 \n 17,838 \n 12,918 \n 11,091 \n 9,683 \n 1,850 \n 6,754 \n 1,374 \n 0 \n 11,770 \n 10,932 \n 11,566 \n 13,010 \n 19,819 \n 19,633 \n 16,796 \n 8,956 \n 8,905 \n 5,977 \n 3,246 \n 845 \n 0 \n 5,392 \n 11,349 \n 13,615 \n 21,156 \n 21,343 \n 10,843 \n 15,444 \n 62 \n 13 \n 0 \n 84 \n 125 \n 166 \n 190 \n 175 \n 93 \n 127 \n 84.00 % \n 13.89 % \n 0.00 % \n 0.00 % \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 96.30 % \n100.00 %\n 84 \n 15 \n 0 \n 0 \n 54 \n 54 \n 54 \n 51 \n 52 \n 54 \n 100 \n 108 \n 0 \n 53 \n 54 \n 54 \n 54 \n 51 \n 54 \n 54 \n 100.00 %\n 82.50 % \n 0.00 % \n 0.00 % \n 99.38 % \n101.57 %\n100.00 %\n100.62 %\n100.00 %\n100.00 %\n 57 \n 66 \n 0 \n 0 \n 319 \n 323 \n 323 \n 325 \n 385 \n 444 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 87 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 92 \n 0 \n 0 \n 120 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 0 \n 0 \n 120 \n 120 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 228 \n 120 \n 120 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 260 \n 120 \n 120 \n 0 \n 72 \n 61 \n 69 \n 5 \n 34 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 24 \n 23 \n 9 \n 36 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.0 \n 5.5 \n 5.6 \n 5.3 \n 5.4 \n 5.4 \n 5.4 \n 5.3 \n 5.2 \n 5.1 \n 4.1 \n 561 \n 574 \n 708 \n 1,080 \n 1,174 \n 1,011 \n 901 \n 929 \n 891 \n 922 \n 932 \n 934 \n 1,047 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 3 \n 11 \n 0 \n 5 \n 0 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 88 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 50 \n 52 \n 52 \n 83 \n 93 \n 123 \n 265 \n 227 \n 254 \n 258 \n 211 \n 272 \n 310 \n 0 \n 0 \n 0 \n 31 \n 50 \n 24 \n 281 \n 254 \n 239 \n 211 \n 286 \n 275 \n 193 \n 21 \n 20 \n 4 \n 146 \n 146 \n 140 \n 131 \n 204 \n 196 \n 121 \n 200 \n 57 \n 1,596 \n 1,405 \n 1,852 \n 230 \n 407 \n 125 \n 3,323 \n 3,738 \n 2,581 \n 5,785 \n 5,293 \n 1,060 \n 2,674 \n 4,626 \n 152 \n 4,778 \n 2,425 \n 4,440 \n 3,375 \n 1,025 \n 632 \n 6,904 \n 6,429 \n 7,606 \n 9,384 \n 9,694 \n 18,514 \n 15,309 \n 6,374 \n 3,830 \n 6,292 \n 3,605 \n 1,431 \n 757 \n 10,227 \n 10,167 \n 10,186 \n 15,169 \n 14,986 \n 19,574 \n 17,982 \n 4,046 \n 3,843 \n 3,745 \n 2,453 \n 1,186 \n 310 \n 3,469 \n 4,514 \n 7,558 \n 12,406 \n 14,095 \n 9,726 \n 13,512 \n 27 \n 9 \n 3 \n 53 \n 46 \n 89 \n 106 \n 109 \n 79 \n 110 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 85.19 % \n 72.22 % \n 56.79 % \n 14.81 % \n 9.26 % \n 0.00 % \n 80.25 % \n 87.24 % \n 91.36 % \n 92.22 % \n 96.30 % \n 98.15 % \n 98.15 % \n 115 \n 78 \n 92 \n 24 \n 15 \n 0 \n 195 \n 212 \n 222 \n 249 \n 260 \n 265 \n 265 \n 135 \n 108 \n 162 \n 162 \n 162 \n 243 \n 243 \n 243 \n 243 \n 270 \n 270 \n 270 \n 270 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 89 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 444 \n 444 \n 444 \n 3,180 \n 3,714 \n 2,897 \n 2,404 \n 2,401 \n 2,181 \n 2,181 \n 2,256 \n 2,265 \n 2,265 \n 2,154 \n 2,155 \n 2,101 \n 3,182 \n 3,716 \n 2,899 \n 2,406 \n 2,403 \n 2,183 \n 2,183 \n 2,258 \n 2,267 \n 2,267 \n 2,598 \n 2,599 \n 2,545 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 9 \n 9 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 143 \n 126 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 85.55 % \n 87.50 % \n 92.58 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 219 \n 224 \n 237 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 256 \n 256 \n 256 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 90 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,698 \n 1,963 \n 2,058 \n 2,389 \n 2,454 \n 2,016 \n 2,009 \n 1,955 \n 1,792 \n 1,794 \n 1,694 \n 1,540 \n 1,609 \n 1,918 \n 2,154 \n 2,204 \n 2,404 \n 2,574 \n 2,512 \n 2,564 \n 1,963 \n 1,875 \n 1,851 \n 1,654 \n 1,672 \n 1,571 \n 12 \n 8 \n 10 \n 13 \n 10 \n 14 \n 17 \n 22 \n 20 \n 19 \n 22 \n 18 \n 21 \n 1,930 \n 2,162 \n 2,214 \n 2,417 \n 2,584 \n 2,526 \n 2,581 \n 1,985 \n 1,895 \n 1,870 \n 1,676 \n 1,690 \n 1,592 \n100.00 %\n100.00 %\n 50.00 % \n 50.00 % \n100.00 %\n100.00 %\n100.00 %\n 58.99 % \n 51.83 % \n 66.76 % \n 70.01 % \n 64.43 % \n 69.69 % \n 69.88 % \n 59.02 % \n 51.86 % \n 66.75 % \n 69.99 % \n 64.46 % \n 69.72 % \n 69.90 % \n 93.49 % \n 94.66 % \n 95.37 % \n 87.22 % \n 83.61 % \n 89.51 % \n 1,304 \n 1,789 \n 964 \n 722 \n 854 \n 661 \n 657 \n 147 \n 121 \n 105 \n 332 \n 426 \n 267 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 174 \n 175 \n 181 \n 2 \n 2 \n 1 \n 1 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 45 \n 46 \n 56 \n 2 \n 2 \n 1 \n 1 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 219 \n 221 \n 237 \n 1,876 \n 1,925 \n 1,934 \n 1,683 \n 1,547 \n 1,520 \n 1,524 \n 2,109 \n 2,144 \n 2,160 \n 2,047 \n 1,952 \n 2,041 \n 1,878 \n 1,927 \n 1,935 \n 1,684 \n 1,549 \n 1,522 \n 1,526 \n 2,111 \n 2,146 \n 2,162 \n 2,266 \n 2,173 \n 2,278 \n 4,113 \n 4,340 \n 4,415 \n 4,385 \n 4,434 \n 4,399 \n 4,398 \n 4,390 \n 4,304 \n 4,326 \n 4,271 \n 4,180 \n 4,121 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 91 of 176 \n Generated 9/9/2010 4:42:44 PM \n 147 \n 84 \n 689 \n 396 \n 137 \n 0 \n 229 \n 261 \n 20 \n 0 \n 0 \n 0 \n 0 \n 8 \n 4 \n 33 \n 6 \n 8 \n 0 \n 15 \n 16 \n 8 \n 0 \n 0 \n 0 \n 0 \n 1,200 \n 320 \n 720 \n 64 \n 85 \n 120 \n 5,008 \n 125 \n 25 \n 0 \n 0 \n 0 \n 0 \n 48 \n 32 \n 48 \n 32 \n 17 \n 24 \n 313 \n 25 \n 25 \n 0 \n 0 \n 0 \n 0 \n 5 \n 5 \n 5 \n 2 \n 5 \n 5 \n 16 \n 5 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 26,460 \n 39,312 \n 24,624 \n 9,920 \n 4,097 \n 3,885 \n 6,622 \n 3,180 \n 2,304 \n 54 \n 0 \n 0 \n 0 \n 630 \n 364 \n 432 \n 320 \n 241 \n 259 \n 301 \n 212 \n 192 \n 6 \n 0 \n 0 \n 0 \n 27 \n 18 \n 29 \n 31 \n 17 \n 15 \n 22 \n 15 \n 12 \n 3 \n 0 \n 0 \n 0 \n 30,012 \n 40,976 \n 25,443 \n 12,360 \n 5,278 \n 4,005 \n 15,065 \n 7,481 \n 2,489 \n 54 \n 0 \n 0 \n 0 \n 825 \n 480 \n 1,169 \n 748 \n 395 \n 283 \n 843 \n 498 \n 237 \n 6 \n 0 \n 0 \n 0 \n 40 \n 27 \n 67 \n 39 \n 30 \n 20 \n 53 \n 36 \n 21 \n 3 \n 0 \n 0 \n 0 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 92 of 176 \n Generated 9/9/2010 4:42:44 PM \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 44 \n 43 \n 42 \n 42 \n 45 \n 0.0 \n 0.0 \n 0.0 \n -0.4 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -0.5 \n 0.0 \n 0.5 \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 43 \n 44 \n 43 \n 42 \n 42 \n 44 \n 11 \n 12 \n 13 \n 13 \n 7 \n 8 \n 7 \n 8 \n 17 \n 10 \n 18 \n 19 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 17 \n 19 \n 21 \n 19 \n 21 \n 7 \n 14 \n 11 \n 9 \n 1 \n 1 \n 1 \n 1 \n 74 \n 65 \n 74 \n 67 \n 78 \n 80 \n 72 \n 83 \n 70 \n 70 \n 47 \n 52 \n 101 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,043 \n 1,053 \n 1,044 \n 1,045 \n 1,047 \n 1,045 \n 1,054 \n 1,050 \n 1,058 \n 1,065 \n 1,010 \n 1,012 \n 1,039 \n 1,118 \n 1,118 \n 1,118 \n 1,112 \n 1,126 \n 1,126 \n 1,128 \n 1,133 \n 1,128 \n 1,135 \n 1,057 \n 1,064 \n 1,140 \n 0.0 \n 0.0 \n 0.0 \n -6.0 \n 0.0 \n 0.0 \n 0.0 \n -1.8 \n -7.0 \n 0.0 \n -6.6 \n -1.0 \n 0.0 \n 1,118 \n 1,118 \n 1,118 \n 1,118 \n 1,126 \n 1,126 \n 1,128 \n 1,135 \n 1,135 \n 1,135 \n 1,063 \n 1,065 \n 1,140 \n 1,662 \n 1,674 \n 1,667 \n 1,666 \n 1,672 \n 1,676 \n 1,683 \n 1,686 \n 1,696 \n 1,698 \n 1,595 \n 1,597 \n 1,668 \n -44,837 \n1,368,602\n1,505,964\n1,636,868\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n4,274,409\n4,210,972\n2,944,428\n2,944,428\n3,275,419\n3,275,419\n3,275,419\n 390,086 \n 390,086 \n3,516,461\n3,516,461\n3,516,461\n -1,025,090\n-19,038,099\n-28,662,513\n-28,605,414\n-28,478,789\n-27,168,803\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n124,678,888\n114,811,573\n114,811,573\n114,811,573\n116,998,653\n116,998,653\n116,998,653\n116,998,653\n116,998,653\n122,481,332\n122,481,332\n122,481,332\n 2,352 \n 1,344 \n 99 \n 2,376 \n 1,096 \n 0 \n 3,435 \n 4,176 \n 160 \n 0 \n 0 \n 0 \n 0 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 93 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 27 \n 25 \n 24 \n 24 \n 25 \n 22 \n 24 \n 21 \n 21 \n 19 \n 7 \n 5 \n 21 \n 7 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 4 \n 3 \n 4 \n 4 \n 7 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 158 \n 162 \n 164 \n 164 \n 165 \n 167 \n 166 \n 168 \n 169 \n 170 \n 150 \n 151 \n 166 \n 192 \n 193 \n 194 \n 194 \n 196 \n 195 \n 196 \n 193 \n 193 \n 193 \n 161 \n 163 \n 192 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n -0.6 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n 192 \n 193 \n 194 \n 194 \n 196 \n 196 \n 196 \n 193 \n 193 \n 193 \n 162 \n 163 \n 192 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 6 \n 11 \n 8 \n 6 \n 4 \n 5 \n 5 \n 5 \n 3 \n -7 \n 1 \n 13 \n 0 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 23 \n 22 \n 16 \n 16 \n 24 \n 26 \n 25 \n 25 \n 25 \n 25 \n 23 \n 25 \n 27 \n 24 \n 30 \n 30 \n 24 \n 30 \n 30 \n 30 \n 30 \n 30 \n 28 \n 16 \n 26 \n 40 \n 0.0 \n 0.0 \n 0.0 \n -6.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -10.0 \n 0.0 \n 0.0 \n 24 \n 30 \n 30 \n 30 \n 30 \n 30 \n 30 \n 30 \n 30 \n 28 \n 26 \n 26 \n 40 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 5 \n 5 \n 4 \n 4 \n 4 \n 3 \n 3 \n 4 \n 2 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 42 \n 38 \n 38 \n 39 \n 39 \n 39 \n 40 \n 40 \n 40 \n 41 \n 41 \n 41 \n 43 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 94 of 176 \n Generated 9/9/2010 4:42:44 PM \n 16 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 15 \n 2 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 15 \n 11 \n 13 \n 16 \n 13 \n 13 \n 9 \n 8 \n 8 \n 0 \n 0 \n 8 \n 5 \n 5 \n 6 \n 4 \n 4 \n 5 \n 5 \n 5 \n 5 \n 5 \n 5 \n 5 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 148 \n 149 \n 152 \n 151 \n 150 \n 152 \n 152 \n 156 \n 157 \n 157 \n 152 \n 152 \n 157 \n 167 \n 169 \n 169 \n 168 \n 170 \n 170 \n 170 \n 170 \n 170 \n 170 \n 158 \n 158 \n 170 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 167 \n 169 \n 169 \n 169 \n 170 \n 170 \n 170 \n 170 \n 170 \n 170 \n 158 \n 158 \n 170 \n 4 \n 4 \n 3 \n 3 \n 2 \n 2 \n 2 \n 4 \n 1 \n 1 \n 1 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 20 \n 19 \n 16 \n 18 \n 22 \n 20 \n 22 \n 18 \n 19 \n 17 \n 17 \n 18 \n 31 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 234 \n 237 \n 240 \n 237 \n 233 \n 233 \n 233 \n 234 \n 234 \n 227 \n 205 \n 204 \n 222 \n 254 \n 256 \n 256 \n 256 \n 255 \n 253 \n 255 \n 252 \n 253 \n 244 \n 223 \n 224 \n 254 \n 0.0 \n 0.0 \n 0.0 \n -0.2 \n 0.0 \n 0.0 \n 2.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n 254 \n 256 \n 256 \n 256 \n 255 \n 253 \n 253 \n 252 \n 253 \n 244 \n 224 \n 224 \n 254 \n 2 \n 3 \n 2 \n 3 \n 1 \n 1 \n 2 \n 1 \n 3 \n 4 \n 3 \n 1 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 95 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2,070 \n 2,141 \n 2,197 \n 2,258 \n 2,240 \n 2,056 \n 1,574 \n 1,846 \n 1,682 \n 2,420 \n 2,144 \n 1,739 \n 1,838 \n 84 \n 112 \n 55 \n 47 \n 105 \n 111 \n 99 \n 90 \n 105 \n 79 \n 79 \n 165 \n 122 \n 6,113 \n 5,897 \n 5,991 \n 5,535 \n 5,544 \n 5,846 \n 6,041 \n 6,411 \n 6,658 \n 7,088 \n 6,322 \n 6,541 \n 6,023 \n 426 \n 345 \n 374 \n 352 \n 372 \n 338 \n 345 \n 546 \n 516 \n 499 \n 622 \n 492 \n 488 \n 81 \n 48 \n 40 \n 111 \n 138 \n 86 \n 68 \n 85 \n 64 \n 63 \n 66 \n 116 \n 60 \n 6,704 \n 6,401 \n 6,460 \n 6,044 \n 6,159 \n 6,380 \n 6,552 \n 7,131 \n 7,344 \n 7,728 \n 7,088 \n 7,314 \n 6,693 \n 6 \n 5 \n 6 \n 5 \n 6 \n 5 \n 5 \n 6 \n 6 \n 6 \n 6 \n 6 \n 5 \n 9,357 \n 9,192 \n 9,439 \n 8,934 \n 9,384 \n 9,081 \n 8,761 \n 9,639 \n 9,624 \n 10,928 \n 10,037 \n 9,853 \n 9,104 \n 2,993 \n 2,716 \n 3,786 \n 2,588 \n 3,011 \n 3,024 \n 3,830 \n 2,951 \n 3,716 \n 3,096 \n 3,133 \n 3,693 \n 3,211 \n 3,003 \n 2,560 \n 3,194 \n 2,119 \n 2,226 \n 1,890 \n 2,949 \n 2,108 \n 2,721 \n 1,877 \n 1,802 \n 2,337 \n 2,670 \n 159 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 25 \n 0 \n 9 \n 0 \n 0 \n 0 \n 19,141 \n 15,100 \n 31,450 \n 16,598 \n 18,995 \n 14,614 \n 17,611 \n 19,008 \n 20,479 \n 22,668 \n 24,134 \n 25,823 \n 25,282 \n 2,301 \n 1,936 \n 2,748 \n 2,852 \n 2,092 \n 2,762 \n 2,201 \n 1,986 \n 3,039 \n 2,434 \n 3,251 \n 4,107 \n 3,532 \n 797 \n 716 \n 440 \n 437 \n 372 \n 636 \n 676 \n 700 \n 815 \n 843 \n 731 \n 727 \n 922 \n 22,398 \n 17,752 \n 34,638 \n 19,886 \n 21,459 \n 18,012 \n 20,488 \n 21,719 \n 24,333 \n 25,954 \n 28,116 \n 30,657 \n 29,737 \n 17 \n 14 \n 25 \n 15 \n 16 \n 14 \n 16 \n 16 \n 18 \n 18 \n 21 \n 23 \n 21 \n 28,394 \n 23,028 \n 41,617 \n 24,592 \n 26,695 \n 22,925 \n 27,267 \n 26,778 \n 30,769 \n 30,927 \n 33,051 \n 36,687 \n 35,617 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n -1 \n -1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 14 \n 13 \n 13 \n 14 \n 14 \n 14 \n 13 \n 13 \n 13 \n 13 \n 14 \n 12 \n 14 \n 16 \n 14 \n 14 \n 14 \n 14 \n 15 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 15 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 96 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,367 \n 673 \n 624 \n 861 \n 953 \n 532 \n 393 \n 557 \n 275 \n 582 \n 562 \n 341 \n 724 \n 43 \n 0 \n 0 \n 0 \n 12 \n 0 \n 0 \n 19 \n 2 \n 20 \n 24 \n 26 \n 0 \n 1,243 \n 965 \n 639 \n 788 \n 571 \n 539 \n 617 \n 646 \n 615 \n 518 \n 544 \n 372 \n 502 \n 229 \n 68 \n 173 \n 304 \n 88 \n 88 \n 50 \n 92 \n 77 \n 123 \n 78 \n 15 \n 123 \n 94 \n 39 \n 76 \n 80 \n 58 \n 42 \n 88 \n 90 \n 73 \n 130 \n 48 \n 72 \n 61 \n 1,609 \n 1,072 \n 888 \n 1,172 \n 728 \n 668 \n 755 \n 847 \n 767 \n 791 \n 694 \n 486 \n 686 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 3,275 \n 2,240 \n 1,792 \n 2,280 \n 1,848 \n 1,464 \n 1,336 \n 1,762 \n 1,319 \n 1,530 \n 1,437 \n 925 \n 1,618 \n 215 \n 164 \n 314 \n 239 \n 54 \n 66 \n 66 \n 238 \n 118 \n 64 \n 135 \n 81 \n 154 \n 338 \n 488 \n 284 \n 641 \n 261 \n 365 \n 325 \n 194 \n 151 \n 451 \n 276 \n 182 \n 277 \n 0 \n 0 \n 0 \n 0 \n 12 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,434 \n 1,553 \n 551 \n 741 \n 435 \n 781 \n 696 \n 879 \n 824 \n 614 \n 607 \n 428 \n 417 \n 64 \n 72 \n 16 \n 224 \n 72 \n 88 \n 50 \n 76 \n 69 \n 116 \n 63 \n 8 \n 81 \n 94 \n 35 \n 76 \n 64 \n 58 \n 42 \n 48 \n 58 \n 73 \n 128 \n 48 \n 72 \n 59 \n 1,592 \n 1,660 \n 642 \n 1,029 \n 576 \n 911 \n 794 \n 1,013 \n 966 \n 858 \n 718 \n 508 \n 557 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 1 \n 2,144 \n 2,312 \n 1,241 \n 1,908 \n 891 \n 1,341 \n 1,185 \n 1,444 \n 1,235 \n 1,372 \n 1,129 \n 771 \n 988 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 3 \n 4 \n 4 \n 4 \n 5 \n 9 \n 5 \n 2 \n 0 \n 0 \n 0 \n 2 \n 583 \n 650 \n 782 \n 632 \n 984 \n 645 \n 635 \n 663 \n 598 \n 781 \n 805 \n 800 \n 574 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 97 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 113 \n 93 \n 104 \n 96 \n 90 \n 78 \n 80 \n 8 \n 6 \n 7 \n 5 \n 5 \n 2 \n 1 \n 2 \n 2 \n 3 \n 2 \n 2 \n 3 \n 1 \n 123 \n 101 \n 114 \n 103 \n 97 \n 84 \n 83 \n 2.08 \n 1.20 \n 0.68 \n 1.20 \n 0.85 \n 1.18 \n 1.36 \n 0.67 \n 1.17 \n 0.84 \n 0.92 \n 0.55 \n 0.85 \n 12 \n 7 \n 4 \n 7 \n 5 \n 7 \n 8 \n 4 \n 7 \n 5 \n 5 \n 3 \n 5 \n 0.65 \n 1.01 \n 0.55 \n 0.55 \n 0.28 \n 0.65 \n 1.10 \n 1.10 \n 1.28 \n 1.54 \n 1.24 \n 1.23 \n 0.83 \n 7 \n 11 \n 6 \n 6 \n 3 \n 7 \n 12 \n 12 \n 14 \n 17 \n 13 \n 13 \n 9 \n 2 \n 9 \n 6 \n 3 \n 2 \n 14 \n 6 \n 5 \n 3 \n 2 \n 2 \n 8 \n 6 \n 2 \n 3 \n 1 \n 3 \n 10 \n 1 \n 2 \n 0 \n 3 \n 3 \n 6 \n 2 \n 2 \n 1 \n 9 \n 2 \n 5 \n 3 \n 4 \n 3 \n 1 \n 1 \n 1 \n 4 \n 4 \n 2 \n 1.39 \n 1.72 \n 1.37 \n 1.55 \n 1.54 \n 0.84 \n 1.19 \n 1.17 \n 1.17 \n 0.84 \n 0.55 \n 1.84 \n 1.71 \n 8 \n 10 \n 8 \n 9 \n 9 \n 5 \n 7 \n 7 \n 7 \n 5 \n 3 \n 10 \n 10 \n 9 \n 14 \n 10 \n 7 \n 16 \n 24 \n 14 \n 19 \n 4 \n 10 \n 11 \n 4 \n 10 \n 24 \n 3 \n 5 \n 6 \n 12 \n 2 \n 3 \n 10 \n 6 \n 4 \n 12 \n 4 \n 6 \n 7 \n 11 \n 11 \n 9 \n 4 \n 13 \n 7 \n 3 \n 1 \n 6 \n 6 \n 5 \n 7 \n 2.95 \n 2.93 \n 3.23 \n 3.23 \n 3.13 \n 2.95 \n 2.65 \n 2.48 \n 2.09 \n 2.44 \n 2.09 \n 1.90 \n 2.13 \n 32 \n 32 \n 35 \n 35 \n 34 \n 32 \n 29 \n 27 \n 23 \n 27 \n 22 \n 20 \n 23 \n 299 \n 495 \n 280 \n 247 \n 167 \n 265 \n 189 \n 358 \n 278 \n 158 \n 181 \n 98 \n 209 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 98 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 160 \n 0 \n 0 \n 357 \n 116 \n 3,488 \n 46 \n 349 \n 34 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 365 \n 0 \n 0 \n 153 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3.94 \n 4.40 \n 2.60 \n 0.83 \n 1.12 \n 1.10 \n 0.53 \n 1.69 \n 0.68 \n 0.47 \n 0.73 \n 0.58 \n 0.34 \n 0.52 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.08 \n 0.36 \n 5.28 \n 4.43 \n 4.69 \n 4.04 \n 3.71 \n 3.05 \n 2.89 \n 622 \n 712 \n 426 \n 136 \n 184 \n 184 \n 88 \n 709 \n 285 \n 199 \n 304 \n 245 \n 147 \n 222 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 15 \n 5,330 \n 4,358 \n 4,662 \n 4,039 \n 3,766 \n 3,131 \n 3,089 \n 349 \n 400 \n 336 \n 280 \n 106 \n 40 \n 24 \n 56 \n 72 \n 72 \n 59 \n 152 \n 132 \n 32 \n 5,735 \n 4,830 \n 5,070 \n 4,378 \n 4,024 \n 3,305 \n 3,160 \n 11 \n 11 \n 4 \n 5 \n 4 \n 2 \n 2 \n 12 \n 9 \n 11 \n 11 \n 7 \n 6 \n 4 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 99 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 8 \n 8 \n 10 \n 1 \n 10 \n 8 \n 4 \n 2 \n 0 \n 5 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 0 \n 0 \n 2 \n 0 \n 2 \n 2 \n 1 \n 0 \n 0 \n 0 \n 9 \n 8 \n 12 \n 2 \n 10 \n 13 \n 6 \n 4 \n 0 \n 10 \n 0.24 \n 0.30 \n 0.54 \n 0.72 \n 0.54 \n 0.78 \n 0.30 \n 0.59 \n 0.88 \n 0.35 \n 0.50 \n 0.13 \n 0.66 \n 4 \n 5 \n 9 \n 12 \n 9 \n 13 \n 5 \n 10 \n 15 \n 6 \n 8 \n 2 \n 11 \n 0 \n 10 \n 8 \n 3 \n 4 \n 1 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 0 \n 6 \n 0 \n 6 \n 3 \n 2 \n 2 \n 12 \n 134 \n 13 \n 0 \n 0 \n 0 \n 226 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.06 \n 14.10 \n 0.84 \n 0.18 \n 0.60 \n 0.24 \n 0.12 \n 0.12 \n 0.77 \n 7.95 \n 0.94 \n 0.13 \n 0.12 \n 1 \n 236 \n 14 \n 3 \n 10 \n 4 \n 2 \n 2 \n 13 \n 135 \n 15 \n 2 \n 2 \n 15 % \n 8 % \n 7 % \n 29 % \n 22 % \n 21 % \n 23 % \n 32 % \n 13 % \n 20 % \n 24 % \n 27 % \n 24 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 405 \n 190 \n 623 \n 579 \n 468 \n 789 \n 705 \n 460 \n 354 \n 580 \n 12 \n 649 \n 667 \n 482 \n 584 \n 440 \n 572 \n 651 \n 1,005 \n 558 \n 455 \n 582 \n 601 \n 41 \n 577 \n 675 \n 216 \n 460 \n 464 \n 1,230 \n 982 \n 671 \n 963 \n 1,139 \n 918 \n 842 \n 968 \n 1,119 \n 1,095 \n 1,532 \n 1,239 \n 1,427 \n 1,624 \n 1,207 \n 1,190 \n 1,693 \n 1,141 \n 1,483 \n 1,508 \n 1,135 \n 1,105 \n 1,560 \n 9 \n 16 \n 6 \n 9 \n 20 \n 18 \n 11 \n 23 \n 9 \n 14 \n 30 \n 7 \n 18 \n 9 \n 17 \n 7 \n 10 \n 19 \n 20 \n 11 \n 21 \n 10 \n 10 \n 33 \n 7 \n 15 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 100 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 1 \n 0.00 \n 0.24 \n 0.42 \n 0.18 \n 0.24 \n 0.18 \n 0.30 \n 0.12 \n 0.18 \n 0.29 \n 0.25 \n 0.38 \n 0.42 \n 0 \n 4 \n 7 \n 3 \n 4 \n 3 \n 5 \n 2 \n 3 \n 5 \n 4 \n 6 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 6 \n 6 \n 5 \n 5 \n 5 \n 5 \n 5 \n 1 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 7 \n 6 \n 6 \n 5 \n 5 \n 5 \n 5 \n 5 \n 5 \n 4 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 \n 0.12 \n 0.12 \n 0.06 \n 0.06 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.06 \n 0.00 \n 0 \n 2 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 5 \n 5 \n 11 \n 12 \n 13 \n 11 \n 15 \n 16 \n 11 \n 7 \n 8 \n 11 \n 0 \n 4 \n 4 \n 0 \n 3 \n 3 \n 2 \n 3 \n 1 \n 3 \n 5 \n 3 \n 3 \n 20 \n 16 \n 18 \n 25 \n 24 \n 26 \n 26 \n 27 \n 29 \n 25 \n 23 \n 26 \n 28 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 8 \n 8 \n 10 \n 1 \n 10 \n 8 \n 4 \n 2 \n 0 \n 5 \n 3 \n 5 \n 5 \n 9 \n 8 \n 10 \n 3 \n 10 \n 8 \n 4 \n 6 \n 1 \n 7 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nKVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 101 of 176 \n Generated 9/9/2010 4:42:44 PM \n 30 \n 28 \n 26 \n 28 \n 38 \n 38 \n 43 \n 40 \n 59 \n 62 \n 60 \n 57 \n 47 \n 1,344 \n 1,330 \n 1,318 \n 1,339 \n 1,333 \n 1,354 \n 1,355 \n 1,352 \n 1,455 \n 1,443 \n 1,435 \n 1,436 \n 1,418 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 10 \n 9 \n 9 \n 14 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 51.88 % \n 57.93 % \n 55.75 % \n 56.55 % \n 53.97 % \n 59.52 % \n 49.71 % \n 46.49 % \n 36.67 % \n 42.31 % \n 37.66 % \n 49.28 % \n 43.53 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 83 \n 95 \n 97 \n 95 \n 102 \n 100 \n 86 \n 86 \n 55 \n 33 \n 29 \n 34 \n 37 \n 160 \n 164 \n 174 \n 168 \n 189 \n 168 \n 173 \n 185 \n 150 \n 78 \n 77 \n 69 \n 85 \n 5.38 % \n 5.59 % \n 5.23 % \n 4.15 % \n 3.67 % \n 3.75 % \n 4.36 % \n 6.76 % \n 9.09 % \n 7.11 % \n 6.58 % \n 5.79 % \n 5.41 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 14 \n 16 \n 15 \n 12 \n 11 \n 11 \n 13 \n 19 \n 25 \n 16 \n 15 \n 14 \n 14 \n 260 \n 286 \n 287 \n 289 \n 300 \n 293 \n 298 \n 281 \n 275 \n 225 \n 228 \n 242 \n 259 \n 95.19 % \n 95.94 % \n 96.26 % \n 96.61 % \n 98.03 % \n 97.10 % \n 97.62 % \n 98.12 % \n 95.40 % \n 94.22 % \n 94.22 % \n 94.48 % \n 94.95 % \n 3,283 \n 3,309 \n 3,320 \n 3,332 \n 3,381 \n 3,349 \n 3,367 \n 3,384 \n 3,341 \n 3,210 \n 3,210 \n 3,219 \n 3,235 \n 3,449 \n 3,449 \n 3,449 \n 3,449 \n 3,449 \n 3,449 \n 3,449 \n 3,449 \n 3,502 \n 3,407 \n 3,407 \n 3,407 \n 3,407 \n 11 \n 12 \n 17 \n 20 \n 16 \n 16 \n 15 \n 20 \n 15 \n 14 \n 12 \n 14 \n 11 \n 1 \n 8 \n 11 \n 2 \n 20 \n 1 \n 5 \n 1 \n 1 \n 9 \n 2 \n 0 \n 6 \n 768 \n 781 \n 778 \n 802 \n 815 \n 833 \n 839 \n 849 \n 833 \n 772 \n 778 \n 796 \n 801 \n 160 \n 164 \n 174 \n 168 \n 189 \n 168 \n 173 \n 185 \n 150 \n 78 \n 77 \n 69 \n 85 \n 2,343 \n 2,344 \n 2,340 \n 2,340 \n 2,341 \n 2,331 \n 2,337 \n 2,330 \n 2,342 \n 2,338 \n 2,343 \n 2,346 \n 2,337 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 102 of 176 \n Generated 9/9/2010 4:42:44 PM \n 310 \n 310 \n 310 \n 310 \n 310 \n 310 \n 310 \n 310 \n 246 \n 246 \n 246 \n 246 \n 246 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 301 \n 303 \n 301 \n 302 \n 304 \n 306 \n 305 \n 311 \n 318 \n 317 \n 319 \n 318 \n 320 \n 1,360 \n 1,357 \n 1,348 \n 1,354 \n 1,344 \n 1,341 \n 1,339 \n 1,412 \n 1,411 \n 1,405 \n 1,403 \n 1,409 \n 1,402 \n 252 \n 278 \n 279 \n 281 \n 292 \n 286 \n 290 \n 273 \n 268 \n 219 \n 221 \n 235 \n 252 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 296 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 64 \n 61 \n 63 \n 59 \n 60 \n 63 \n 67 \n 71 \n 68 \n 64 \n 64 \n 65 \n 68 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 1,486 \n 1,487 \n 1,486 \n 1,498 \n 1,530 \n 1,507 \n 1,513 \n 1,514 \n 1,585 \n 1,511 \n 1,493 \n 1,483 \n 1,484 \n 1,540 \n 1,540 \n 1,540 \n 1,540 \n 1,540 \n 1,540 \n 1,540 \n 1,540 \n 1,657 \n 1,562 \n 1,562 \n 1,562 \n 1,562 \n 1,802 \n 1,826 \n 1,828 \n 1,838 \n 1,882 \n 1,856 \n 1,870 \n 1,858 \n 1,921 \n 1,794 \n 1,778 \n 1,783 \n 1,804 \n 1,902 \n 1,902 \n 1,902 \n 1,902 \n 1,902 \n 1,902 \n 1,902 \n 1,902 \n 2,019 \n 1,924 \n 1,924 \n 1,924 \n 1,924 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2.23 % \n 2.11 % \n 1.97 % \n 2.09 % \n 2.85 % \n 2.81 % \n 3.17 % \n 2.96 % \n 4.05 % \n 4.30 % \n 4.18 % \n 3.97 % \n 3.31 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 14 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 103 of 176 \n Generated 9/9/2010 4:42:44 PM \n 255 \n 255 \n 265 \n 274 \n 285 \n 301 \n 300 \n 317 \n 334 \n 348 \n 353 \n 349 \n 354 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 349 \n 76 \n 70 \n 69 \n 72 \n 73 \n 71 \n 74 \n 69 \n 71 \n 67 \n 70 \n 76 \n 62 \n 1 \n 1 \n 1 \n 1 \n 2 \n 3 \n 0 \n 1 \n 2 \n 3 \n 4 \n 3 \n 1 \n 77 \n 71 \n 70 \n 73 \n 75 \n 74 \n 74 \n 70 \n 73 \n 70 \n 74 \n 79 \n 63 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 17 \n 6 \n 11 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 34 \n 34 \n 33 \n 45 \n 41 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 50 \n 48 \n 37 \n 36 \n 21 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 48 \n 48 \n 48 \n 48 \n 48 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 167 \n 169 \n 166 \n 171 \n 132 \n 139 \n 112 \n 96 \n 176 \n 145 \n 134 \n 138 \n 132 \n 0 \n 311 \n 293 \n 291 \n 289 \n 265 \n 232 \n 245 \n 229 \n 225 \n 199 \n 196 \n 190 \n 178 \n 49 \n 53 \n 59 \n 51 \n 47 \n 47 \n 47 \n 47 \n 46 \n 43 \n 46 \n 45 \n 43 \n 5 \n 7 \n 8 \n 8 \n 2 \n 15 \n 8 \n 9 \n 8 \n 6 \n 33 \n 11 \n 6 \n 365 \n 353 \n 358 \n 348 \n 314 \n 294 \n 300 \n 285 \n 279 \n 248 \n 275 \n 246 \n 227 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 47 \n 44 \n 42 \n 40 \n 40 \n 40 \n 39 \n 28 \n 26 \n 13 \n 13 \n 10 \n 15 \n 153 \n 159 \n 166 \n 148 \n 134 \n 138 \n 123 \n 101 \n 83 \n 54 \n 57 \n 46 \n 88 \n 194 \n 192 \n 189 \n 182 \n 179 \n 175 \n 169 \n 159 \n 156 \n 174 \n 182 \n 175 \n 136 \n 414 \n 416 \n 417 \n 420 \n 390 \n 398 \n 374 \n 370 \n 349 \n 319 \n 313 \n 318 \n 319 \n 247 \n 247 \n 251 \n 249 \n 258 \n 259 \n 262 \n 274 \n 173 \n 174 \n 179 \n 180 \n 187 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 104 of 176 \n Generated 9/9/2010 4:42:44 PM \n 14 \n 12 \n 16 \n 6 \n 13 \n 10 \n 19 \n 22 \n 15 \n 36 \n 29 \n 31 \n 45 \n 32 \n 34 \n 42 \n 39 \n 37 \n 38 \n 38 \n 41 \n 45 \n 47 \n 50 \n 52 \n 59 \n 46 \n 46 \n 58 \n 45 \n 50 \n 48 \n 57 \n 63 \n 60 \n 83 \n 79 \n 83 \n 104 \n 49 \n 52 \n 81 \n 72 \n 64 \n 80 \n 81 \n 1,417 \n 1,414 \n 1,403 \n 1,386 \n 1,390 \n 1,357 \n 1,365 \n 1,466 \n 1,466 \n 1,484 \n 1,458 \n 1,454 \n 1,437 \n 1,446 \n 1,115 \n 1,114 \n 1,113 \n 1,116 \n 1,117 \n 1,115 \n 1,114 \n 1,121 \n 1,122 \n 1,121 \n 1,124 \n 1,126 \n 1,120 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 1,109 \n 316 \n 316 \n 305 \n 303 \n 315 \n 329 \n 355 \n 342 \n 372 \n 370 \n 321 \n 333 \n 402 \n 108 \n 110 \n 111 \n 109 \n 108 \n 103 \n 105 \n 111 \n 110 \n 107 \n 117 \n 116 \n 113 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 128 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 98 \n 103 \n 111 \n 105 \n 116 \n 113 \n 116 \n 117 \n 115 \n 111 \n 114 \n 121 \n 112 \n 62 \n 60 \n 60 \n 59 \n 59 \n 63 \n 67 \n 71 \n 68 \n 64 \n 64 \n 65 \n 68 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 160 \n 163 \n 171 \n 164 \n 176 \n 176 \n 183 \n 188 \n 183 \n 175 \n 178 \n 186 \n 180 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n 66 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 105 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 8 \n 4 \n 3 \n 5 \n 5 \n 2 \n 4 \n 2 \n 4 \n 1 \n 3 \n 0 \n 0 \n 0 \n 4 \n 1 \n 0 \n 1 \n 2 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 18 \n 18 \n 9 \n 9 \n 35 \n 4 \n 7 \n 4 \n 5 \n 10 \n 4 \n 9 \n 0 \n 4 \n 4 \n 1 \n 3 \n 3 \n 2 \n 4 \n 0 \n 1 \n 1 \n 4 \n 6 \n 0 \n 56 \n 152 \n 48 \n 138 \n 154 \n 131 \n 140 \n 107 \n 120 \n 151 \n 132 \n 134 \n 0.00 \n 2.45 \n 5.48 \n 2.04 \n 4.55 \n 5.88 \n 4.25 \n 4.58 \n 3.44 \n 4.02 \n 5.17 \n 4.41 \n 4.70 \n 0 \n 81 \n 182 \n 68 \n 154 \n 197 \n 143 \n 155 \n 115 \n 129 \n 166 \n 142 \n 152 \n 8 \n 5 \n 13 \n 19 \n 12 \n 12 \n 11 \n 7 \n 10 \n 9 \n 7 \n 15 \n 14 \n 17 \n 20 \n 10 \n 10 \n 10 \n 11 \n 10 \n 11 \n 10 \n 13 \n 13 \n 5 \n 6 \n 25 \n 25 \n 23 \n 29 \n 22 \n 23 \n 21 \n 18 \n 20 \n 22 \n 20 \n 20 \n 20 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 996 \n 995 \n 999 \n 996 \n 995 \n 996 \n 997 \n 993 \n 989 \n 990 \n 987 \n 986 \n 991 \n 996 \n 995 \n 999 \n 996 \n 995 \n 996 \n 997 \n 993 \n 989 \n 990 \n 987 \n 986 \n 991 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 108 \n 108 \n 111 \n 108 \n 112 \n 103 \n 116 \n 110 \n 110 \n 107 \n 117 \n 122 \n 111 \n 108 \n 108 \n 111 \n 108 \n 112 \n 103 \n 116 \n 110 \n 110 \n 107 \n 117 \n 122 \n 111 \n 0 \n 0 \n 27 \n 35 \n 52 \n 47 \n 39 \n 58 \n 51 \n 32 \n 47 \n 41 \n 51 \n 40 \n 50 \n 264 \n 257 \n 241 \n 233 \n 236 \n 209 \n 204 \n 183 \n 191 \n 184 \n 180 \n 179 \n 176 \n 291 \n 292 \n 293 \n 280 \n 275 \n 267 \n 255 \n 215 \n 238 \n 225 \n 231 \n 219 \n 226 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 106 of 176 \n Generated 9/9/2010 4:42:44 PM \n 6 \n 8 \n 4 \n 5 \n 4 \n 5 \n 9 \n 9 \n 4 \n 4 \n 3 \n 6 \n 11 \n 14 \n 11 \n 31 \n 19 \n 13 \n 20 \n 20 \n 17 \n 7 \n 4 \n 14 \n 16 \n 7 \n 0 \n 2 \n 4 \n 2 \n 2 \n 2 \n 3 \n 3 \n 2 \n 3 \n 2 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0.55 \n 0.39 \n 0.84 \n 0.51 \n 0.35 \n 0.75 \n 0.62 \n 0.62 \n 0.36 \n 0.25 \n 0.44 \n 0.50 \n 0.56 \n 18 \n 13 \n 28 \n 17 \n 12 \n 25 \n 21 \n 21 \n 12 \n 8 \n 14 \n 16 \n 18 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1.19 \n 1.33 \n 1.72 \n 1.35 \n 1.06 \n 1.25 \n 1.16 \n 1.03 \n 0.84 \n 0.65 \n 0.97 \n 0.78 \n 0.96 \n 39 \n 44 \n 57 \n 45 \n 36 \n 42 \n 39 \n 35 \n 28 \n 21 \n 31 \n 25 \n 31 \n 0 \n 2 \n 0 \n 0 \n 6 \n 0 \n 4 \n 1 \n 7 \n 4 \n 1 \n 5 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 107 of 176 \n Generated 9/9/2010 4:42:44 PM \n 3 \n 5 \n 5 \n 3 \n 2 \n 4 \n 1 \n 1 \n 0 \n 1 \n 5 \n 4 \n 0 \n 4 \n 0 \n 8 \n 3 \n 4 \n 9 \n 4 \n 7 \n 0 \n 3 \n 3 \n 1 \n 2 \n 1 \n 1 \n 2 \n 1 \n 2 \n 7 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1 \n 2 \n 5 \n 1 \n 10 \n 4 \n 6 \n 16 \n 5 \n 7 \n 1 \n 4 \n 4 \n 2 \n 4 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 5 \n 7 \n 5 \n 2 \n 3 \n 2 \n 3 \n 4 \n 1 \n 0 \n 1 \n 4 \n 8 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 8 \n 5 \n 3 \n 3 \n 2 \n 3 \n 4 \n 1 \n 0 \n 1 \n 4 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 1 \n 6 \n 7 \n 2 \n 10 \n 2 \n 4 \n 2 \n 4 \n 7 \n 2 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 2 \n 1 \n 2 \n 1 \n 1 \n 3 \n 1 \n 2 \n 0 \n 0 \n 1 \n 1 \n 1 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 108 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 7 \n 6 \n 5 \n 6 \n 7 \n 8 \n 8 \n 8 \n 8 \n 10 \n 11 \n 16 \n 17 \n 3,276 \n 3,303 \n 3,315 \n 3,326 \n 3,374 \n 3,341 \n 3,359 \n 3,376 \n 3,333 \n 3,200 \n 3,199 \n 3,203 \n 3,218 \n 8 \n 13 \n 14 \n 9 \n 10 \n 4 \n 9 \n 8 \n 9 \n 10 \n 7 \n 10 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 5 \n 8 \n 4 \n 4 \n 6 \n 5 \n 2 \n 4 \n 2 \n 3 \n 1 \n 4 \n 0 \n 2 \n 3 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 3 \n 0 \n 2 \n 3 \n 0 \n 2 \n 2 \n 0 \n 2 \n 4 \n 3 \n 0 \n 0 \n 3 \n 0 \n 0 \n 7 \n 7 \n 7 \n 19 \n 11 \n 4 \n 10 \n 9 \n 10 \n 3 \n 7 \n 3 \n 6 \n 0 \n 0 \n 3 \n 2 \n 1 \n 0 \n 2 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 109 of 176 \n Generated 9/9/2010 4:42:44 PM \n 13 \n 37 \n 52 \n 31 \n 58 \n 33 \n 45 \n 43 \n 38 \n 55 \n 68 \n 54 \n 31 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 12 \n 10 \n 17 \n 17 \n 22 \n 23 \n 20 \n 10 \n 12 \n 10 \n 19 \n 19 \n 28 \n 9 \n 12 \n 26 \n 19 \n 31 \n 16 \n 21 \n 6 \n 13 \n 20 \n 19 \n 22 \n 22 \n 8 \n 20 \n 40 \n 39 \n 41 \n 27 \n 28 \n 25 \n 23 \n 30 \n 45 \n 50 \n 68 \n 1 \n 0 \n 1 \n 2 \n 0 \n 5 \n 3 \n 8 \n 0 \n 5 \n 6 \n 3 \n 4 \n 25 \n 77 \n 119 \n 171 \n 201 \n 196 \n 223 \n 158 \n 78 \n 115 \n 92 \n 81 \n 93 \n 8 \n 25 \n 46 \n 48 \n 93 \n 87 \n 13 \n 22 \n 14 \n 34 \n 34 \n 24 \n 31 \n 13 \n 9 \n 19 \n 22 \n 19 \n 18 \n 22 \n 14 \n 6 \n 23 \n 20 \n 29 \n 40 \n 3.62 \n 7.13 \n 12.35 \n 13.09 \n 16.47 \n 14.96 \n 13.04 \n 11.26 \n 7.69 \n 11.59 \n 12.55 \n 10.97 \n 16.75 \n 0 \n 0 \n 2 \n 13 \n 1 \n 7 \n 0 \n 0 \n 10 \n 3 \n 3 \n 6 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 16 \n 12 \n 2 \n 13 \n 5 \n 15 \n 10 \n 3 \n 9 \n 5 \n 1 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 0 \n 1 \n 0 \n 248 \n 248 \n 415 \n 2 \n 0 \n 416 \n 224 \n 270 \n 74 \n 244 \n 196 \n 105 \n 96 \n 119 \n 236 \n 410 \n 436 \n 557 \n 501 \n 439 \n 381 \n 257 \n 372 \n 403 \n 353 \n 542 \n 367 \n 484 \n 825 \n 438 \n 557 \n 917 \n 663 \n 651 \n 331 \n 616 \n 599 \n 458 \n 638 \n 0 \n 5 \n 8 \n 4 \n 4 \n 6 \n 5 \n 2 \n 4 \n 2 \n 3 \n 1 \n 4 \n 0 \n 3 \n 6 \n 4 \n 1 \n 3 \n 3 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 3 \n 3 \n 6 \n 4 \n 4 \n 5 \n 5 \n 2 \n 4 \n 2 \n 4 \n 1 \n 3 \n 0 \n 3 \n 5 \n 4 \n 1 \n 5 \n 3 \n 1 \n 0 \n 2 \n 1 \n 1 \n 1 \n 0 \n 3 \n 5 \n 4 \n 1 \n 5 \n 3 \n 1 \n 0 \n 2 \n 1 \n 1 \n 1 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 110 of 176 \n Generated 9/9/2010 4:42:44 PM \n 378 \n 178 \n 104 \n 105 \n 121 \n 160 \n 160 \n 139 \n 152 \n 150 \n 38.17 % \n 33.75 % \n 20.86 % \n 48.41 % \n 74.16 % \n 75.00 % \n 84.76 % \n 76.86 % \n 86.25 % \n108.75 %\n143.88 %\n109.21 %\n 93.33 % \n 213 \n 216 \n 141 \n 183 \n 132 \n 78 \n 89 \n 93 \n 138 \n 174 \n 200 \n 166 \n 140 \n 558 \n 640 \n 676 \n 378 \n 178 \n 104 \n 105 \n 121 \n 160 \n 160 \n 139 \n 152 \n 150 \n 0.00 \n 2.15 \n 2.94 \n 2.51 \n 2.13 \n 2.27 \n 5.02 \n 5.22 \n 4.02 \n 0 \n 0 \n 2 \n 3 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 12 \n 15 \n 0 \n 0 \n 0 \n 0 \n 0 \n 95 \n 82 \n 65 \n 21 \n 14 \n 10 \n 20 \n 20 \n 20 \n 19 \n 12 \n 27 \n 124 \n 24 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 93 \n 97 \n 111 \n 74 \n 29 \n 60 \n 54 \n 45 \n 0 \n 72 \n 99 \n 85 \n 71 \n 73 \n 161 \n 168 \n 130 \n 0 \n 0 \n 0 \n 0 \n 0 \n 165 \n 196 \n 196 \n 145 \n 102 \n 221 \n 222 \n 175 \n 1 \n 0 \n 2 \n 1 \n 1 \n 2 \n 2 \n 0 \n 1 \n 1 \n 1 \n 0 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 130 \n 0 \n 0 \n 2 \n 4 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 10 \n 13 \n 11 \n 13 \n 22 \n 0 \n 13 \n 12 \n 12 \n 14 \n 14 \n 19 \n 3 \n 7 \n 6 \n 8 \n 16 \n 7 \n 10 \n 16 \n 19 \n 15 \n 23 \n 17 \n 24 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 20 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 10 \n 6 \n 6 \n 5 \n 0 \n 3 \n 3 \n 4 \n 7 \n 5 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 2 \n 2 \n 2 \n 2 \n 11 \n 12 \n 29 \n 34 \n 24 \n 47 \n 18 \n 49 \n 20 \n 27 \n 32 \n 19 \n 11 \n 9 \n 17 \n 28 \n 23 \n 28 \n 13 \n 13 \n 14 \n 17 \n 19 \n 21 \n 13 \n 22 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 111 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 3 \n 0 \n 18 \n 0 \n 0 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 82 \n 64 \n 45 \n 54 \n 91 \n 136 \n 147 \n 184 \n 177 \n 144 \n 97 \n 355 \n 97 \n 32 \n 51 \n 82 \n 115 \n 109 \n 107 \n 87 \n 57 \n 216 \n 62 \n 3 \n 7 \n 54 \n 624 \n 1,721 \n 1,316 \n 4,284 \n 2,776 \n 1,612 \n 91 \n 0 \n 104 \n 0 \n 858 \n 820 \n 4,219 \n 0 \n 4,219 \n 3,273 \n 1,527 \n 693 \n 221 \n 0 \n 0 \n 98 \n 819 \n 780 \n 0 \n 26 \n 768 \n 4,273 \n 3,897 \n 3,248 \n 2,009 \n 4,505 \n 2,776 \n 1,612 \n 189 \n 819 \n 884 \n 0 \n 884 \n 1,588 \n 7,390 \n 6,897 \n 5,333 \n 2,839 \n 1,786 \n 2,517 \n 4,817 \n 5,626 \n 7,248 \n 10,457 \n 9,737 \n 9,061 \n 7,574 \n 31 \n 15 \n 28 \n 49 \n 87 \n 80 \n 89 \n 83 \n 82 \n 61 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 48.41 % \n 74.16 % \n 75.00 % \n 84.76 % \n 76.86 % \n 86.25 % \n108.75 %\n143.88 %\n109.21 %\n 93.33 % \n 183 \n 132 \n 78 \n 89 \n 93 \n 138 \n 174 \n 200 \n 166 \n 140 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 112 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 0 \n 0 \n 0 \n 0 \n 110 \n 109 \n 109 \n 109 \n 120 \n 136 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 0 \n 240 \n 240 \n 301 \n 475 \n 489 \n 538 \n 507 \n 487 \n 492 \n 86 \n 326 \n 240 \n 360 \n 469 \n 480 \n 480 \n 480 \n 480 \n 480 \n 5 \n 4 \n 4 \n 63 \n 128 \n 136 \n 128 \n 292 \n 342 \n 404 \n 379 \n 367 \n 337 \n 5 \n 5 \n 6 \n 120 \n 173 \n 184 \n 257 \n 377 \n 435 \n 446 \n 410 \n 410 \n 487 \n 0.0 \n 4.8 \n 4.8 \n 4.7 \n 4.6 \n 4.5 \n 4.5 \n 4.6 \n 4.7 \n 4.7 \n 4.7 \n 299 \n 379 \n 362 \n 509 \n 520 \n 421 \n 279 \n 251 \n 244 \n 243 \n 211 \n 206 \n 193 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 0 \n 7 \n 18 \n 0 \n 4 \n 5 \n 4 \n 20 \n 10 \n 2 \n 44 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 113 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 2 \n 2 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 2 \n 2 \n 3 \n 6 \n 0 \n 0 \n 0 \n 180 \n 160 \n 305 \n 296 \n 239 \n 238 \n 210 \n 180 \n 150 \n 170 \n 108 \n 270 \n 14 \n 178 \n 143 \n 142 \n 126 \n 108 \n 73 \n 1,020 \n 0 \n 0 \n 65 \n 198 \n 321 \n 80 \n 147 \n 80 \n 104 \n 97 \n 520 \n 416 \n 550 \n 199 \n 317 \n 642 \n 0 \n 642 \n 198 \n 86 \n 140 \n 117 \n 139 \n 325 \n 202 \n 0 \n 91 \n 0 \n 0 \n 174 \n 707 \n 396 \n 406 \n 220 \n 264 \n 219 \n 429 \n 299 \n 520 \n 507 \n 550 \n 199 \n 491 \n 204 \n 680 \n 694 \n 689 \n 926 \n 734 \n 1,060 \n 774 \n 826 \n 1,121 \n 1,205 \n 1,738 \n 2,554 \n 8 \n 8 \n 8 \n 11 \n 12 \n 9 \n 10 \n 10 \n 16 \n 21 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 33.33 % \n 37.04 % \n 37.04 % \n 33.33 % \n 37.04 % \n 51.85 % \n 59.26 % \n 59.26 % \n 55.56 % \n 55.56 % \n 62.96 % \n 70.37 % \n 81.48 % \n 9 \n 10 \n 10 \n 9 \n 10 \n 14 \n 16 \n 16 \n 15 \n 15 \n 17 \n 19 \n 22 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 114 of 176 \n Generated 9/9/2010 4:42:44 PM \n 4 \n 4 \n 4 \n 4 \n 4 \n 6 \n 6 \n 6 \n 21 \n 21 \n 20 \n 19 \n 19 \n 1,069 \n 1,047 \n 1,081 \n 1,023 \n 983 \n 973 \n 857 \n 911 \n 917 \n 929 \n 927 \n 957 \n 965 \n 1,073 \n 1,051 \n 1,085 \n 1,027 \n 987 \n 979 \n 863 \n 917 \n 938 \n 950 \n 947 \n 976 \n 984 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 115 of 176 \n Generated 9/9/2010 4:42:44 PM \n 238 \n 0 \n 0 \n 0 \n 462 \n 133 \n 0 \n 0 \n 0 \n 0 \n 3,822 \n 3,675 \n 4,025 \n 249 \n 0 \n 11 \n 14 \n 139 \n 26 \n 0 \n 7 \n 0 \n 0 \n 5,040 \n 0 \n 36 \n 0 \n 217 \n 303 \n 392 \n 394 \n 171 \n 359 \n 280 \n 147 \n 224 \n 311 \n 193 \n 384 \n 14 \n 57 \n 64 \n 27 \n 65 \n 65 \n 77 \n 55 \n 56 \n 60 \n 58 \n 85 \n 246 \n 218 \n 274 \n 117 \n 352 \n 228 \n 605 \n 437 \n 986 \n 256 \n 410 \n 599 \n 4,736 \n 1,279 \n 718 \n 548 \n 495 \n 785 \n 1,288 \n 1,000 \n 872 \n 1,328 \n 459 \n 694 \n 9,830 \n 8,689 \n 5,970 \n 94.44 % \n 73.91 % \n 78.26 % \n 91.30 % \n 95.65 % \n 88.00 % \n 96.00 % \n100.00 %\n100.00 %\n100.00 %\n 92.00 % \n 98.46 % \n 97.06 % \n 17 \n 17 \n 18 \n 21 \n 22 \n 22 \n 24 \n 25 \n 25 \n 25 \n 23 \n 64 \n 66 \n 18 \n 23 \n 23 \n 23 \n 23 \n 25 \n 25 \n 25 \n 25 \n 25 \n 25 \n 65 \n 68 \n 487 \n 529 \n 568 \n 627 \n 722 \n 726 \n 728 \n 705 \n 637 \n 567 \n 507 \n 512 \n 469 \n 566 \n 613 \n 660 \n 722 \n 823 \n 824 \n 829 \n 760 \n 716 \n 646 \n 583 \n 574 \n 548 \n 9 \n 4 \n 3 \n 5 \n 7 \n 6 \n 7 \n 6 \n 8 \n 8 \n 11 \n 12 \n 7 \n 575 \n 617 \n 663 \n 727 \n 830 \n 830 \n 836 \n 766 \n 724 \n 654 \n 594 \n 586 \n 555 \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 66.67 % \n 66.67 % \n 85.50 % \n 86.91 % \n 80.30 % \n 81.52 % \n 79.65 % \n 79.34 % \n 91.60 % \n 85.55 % \n 86.96 % \n 80.37 % \n 81.60 % \n 79.74 % \n 79.26 % \n 91.43 % \n 91.38 % \n 89.13 % \n 85.79 % \n 85.74 % \n 88.63 % \n 92.38 % \n 155 \n 137 \n 213 \n 189 \n 200 \n 203 \n 74 \n 79 \n 102 \n 135 \n 135 \n 111 \n 75 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 11 \n 12 \n 18 \n 6 \n 18 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 5 \n 12 \n 12 \n 18 \n 6 \n 18 \n 914 \n 910 \n 868 \n 834 \n 783 \n 772 \n 785 \n 833 \n 824 \n 803 \n 794 \n 859 \n 891 \n 918 \n 914 \n 872 \n 838 \n 787 \n 776 \n 789 \n 838 \n 836 \n 815 \n 812 \n 865 \n 909 \n 1,604 \n 1,662 \n 1,639 \n 1,672 \n 1,719 \n 1,727 \n 1,753 \n 1,774 \n 1,739 \n 1,629 \n 1,625 \n 1,637 \n 1,661 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 116 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 7 \n 16 \n 0 \n 16 \n 0 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 36 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 12 \n 15 \n 0 \n 0 \n 25 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,808 \n 720 \n 9 \n 18 \n 0 \n 30 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 72 \n 80 \n 80 \n 80 \n 0 \n 80 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 3 \n 3 \n 12 \n 0 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,730 \n 2,970 \n 42 \n 18 \n 0 \n 36 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 70 \n 90 \n 90 \n 90 \n 0 \n 90 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 11 \n 14 \n 15 \n 0 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5,580 \n 3,774 \n 57 \n 42 \n 0 \n 66 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 149 \n 198 \n 185 \n 186 \n 0 \n 211 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 16 \n 18 \n 28 \n 0 \n 15 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 8 \n 8 \n 8 \n 0 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 117 of 176 \n Generated 9/9/2010 4:42:44 PM \n 51 \n 49 \n 49 \n 51 \n 51 \n 51 \n 51 \n 51 \n 51 \n 47 \n 47 \n 47 \n 58 \n 0.0 \n 0.0 \n 0.0 \n 2.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -4.0 \n 0.0 \n 0.0 \n 7.0 \n 51 \n 49 \n 49 \n 49 \n 51 \n 51 \n 51 \n 51 \n 51 \n 51 \n 47 \n 47 \n 51 \n 0 \n 0 \n 0 \n 43 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 15 \n 16 \n 15 \n 15 \n 15 \n 4 \n 4 \n 4 \n 4 \n 5 \n 6 \n 3 \n 0 \n 4 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 1 \n 2 \n 2 \n 3 \n 2 \n 3 \n 130 \n 127 \n 120 \n 101 \n 103 \n 99 \n 84 \n 73 \n 69 \n 45 \n 31 \n 23 \n 54 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 884 \n 887 \n 893 \n 912 \n 916 \n 917 \n 928 \n 945 \n 949 \n 960 \n 967 \n 975 \n 987 \n 1,014 \n 1,014 \n 1,014 \n 1,014 \n 1,020 \n 1,020 \n 1,012 \n 1,018 \n 1,018 \n 1,005 \n 998 \n 998 \n 1,041 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -13.0 \n 0.0 \n 0.0 \n 25.0 \n 1,014 \n 1,014 \n 1,014 \n 1,014 \n 1,020 \n 1,020 \n 1,012 \n 1,018 \n 1,018 \n 1,018 \n 998 \n 998 \n 1,016 \n 1,439 \n 1,446 \n 1,455 \n 1,469 \n 1,473 \n 1,474 \n 1,479 \n 1,509 \n 1,505 \n 1,513 \n 1,521 \n 1,522 \n 1,550 \n -1,632 \n 0 \n-355,089\n-342,680\n-843,100\n-753,632\n-420,118\n-420,118\n-420,118\n-420,118\n-420,118\n-420,118\n-420,118\n 0 \n 0 \n1,500,749\n2,968,951\n1,035,160\n22,884,260\n22,884,260\n22,884,260\n22,884,260\n22,884,260\n22,884,260\n2,288,426\n2,969,004\n 2,277,249\n 0 \n-21,187,657\n-21,187,657\n-19,278,588\n-19,278,588\n-17,438,013\n-16,187,063\n-16,187,063\n-16,187,063\n-20,119,661\n-20,119,661\n-10,659,750\n 0 \n 0 \n116,315,366\n116,315,366\n116,315,366\n116,315,369\n118,487,441\n118,487,441\n118,487,441\n118,487,442\n122,429,658\n122,429,658\n138,526,832\n 0 \n 0 \n 42 \n 48 \n 0 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 118 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 3 \n 2 \n 30 \n 24 \n 18 \n 21 \n 21 \n 19 \n 26 \n 22 \n 25 \n 23 \n 15 \n 4 \n 29 \n 3 \n 5 \n 5 \n 5 \n 6 \n 7 \n 7 \n 7 \n 7 \n 7 \n 9 \n 8 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 193 \n 197 \n 203 \n 200 \n 198 \n 199 \n 191 \n 197 \n 196 \n 198 \n 199 \n 194 \n 201 \n 226 \n 225 \n 225 \n 225 \n 224 \n 224 \n 224 \n 225 \n 227 \n 227 \n 223 \n 206 \n 239 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 7.0 \n 226 \n 225 \n 225 \n 225 \n 224 \n 224 \n 224 \n 225 \n 227 \n 227 \n 223 \n 206 \n 232 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 4 \n 3 \n 2 \n -1 \n 3 \n 2 \n 2 \n 2 \n 2 \n 2 \n 3 \n 7 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 14 \n 13 \n 13 \n 13 \n 14 \n 14 \n 15 \n 15 \n 15 \n 14 \n 14 \n 14 \n 15 \n 15 \n 17 \n 17 \n 17 \n 14 \n 17 \n 17 \n 17 \n 17 \n 16 \n 16 \n 17 \n 22 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -3.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n 15 \n 17 \n 17 \n 17 \n 17 \n 17 \n 17 \n 17 \n 17 \n 16 \n 16 \n 17 \n 21 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 5 \n 5 \n 12 \n 12 \n 12 \n 9 \n 6 \n 3 \n 2 \n 1 \n -1 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 1 \n 1 \n 1 \n 1 \n 45 \n 44 \n 44 \n 39 \n 39 \n 39 \n 42 \n 45 \n 45 \n 44 \n 45 \n 46 \n 47 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 119 of 176 \n Generated 9/9/2010 4:42:44 PM \n 16 \n 15 \n 15 \n 15 \n 15 \n 15 \n 14 \n 14 \n 14 \n 14 \n 13 \n 13 \n 14 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 2 \n 0 \n 1 \n -1 \n -2 \n -2 \n -4 \n -2 \n -7 \n -4 \n -7 \n -9 \n 5 \n 6 \n 7 \n 7 \n 7 \n 7 \n 7 \n 7 \n 7 \n 7 \n 7 \n 9 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 111 \n 111 \n 112 \n 111 \n 113 \n 114 \n 114 \n 116 \n 115 \n 116 \n 115 \n 116 \n 115 \n 119 \n 119 \n 119 \n 119 \n 120 \n 120 \n 120 \n 120 \n 121 \n 117 \n 118 \n 118 \n 114 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -4.0 \n 0.0 \n 0.0 \n -6.0 \n 119 \n 119 \n 119 \n 119 \n 120 \n 120 \n 120 \n 120 \n 121 \n 121 \n 118 \n 118 \n 120 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 11 \n 13 \n 15 \n 15 \n 15 \n 15 \n 14 \n 12 \n 17 \n 11 \n 9 \n 8 \n 36 \n 2 \n 2 \n 2 \n 2 \n 4 \n 5 \n 5 \n 4 \n 7 \n 6 \n 7 \n 5 \n 7 \n 3 \n 1 \n 4 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 178 \n 181 \n 177 \n 180 \n 179 \n 178 \n 179 \n 181 \n 175 \n 170 \n 171 \n 166 \n 173 \n 193 \n 196 \n 198 \n 199 \n 198 \n 198 \n 198 \n 197 \n 199 \n 187 \n 187 \n 179 \n 216 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 12.0 \n 193 \n 196 \n 198 \n 198 \n 198 \n 198 \n 198 \n 197 \n 199 \n 187 \n 187 \n 180 \n 204 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 120 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,339 \n 1,079 \n 1,257 \n 1,355 \n 1,536 \n 1,571 \n 1,336 \n 1,420 \n 1,270 \n 1,882 \n 1,305 \n 1,329 \n 1,348 \n 112 \n 99 \n 1 \n 20 \n 249 \n 203 \n 51 \n 56 \n 150 \n 165 \n 67 \n 76 \n 201 \n 2,112 \n 2,527 \n 2,905 \n 3,490 \n 3,512 \n 3,045 \n 3,394 \n 3,882 \n 3,937 \n 4,591 \n 4,448 \n 4,413 \n 3,736 \n 235 \n 313 \n 452 \n 294 \n 183 \n 132 \n 194 \n 434 \n 352 \n 338 \n 238 \n 171 \n 184 \n 85 \n 81 \n 147 \n 90 \n 65 \n 44 \n 42 \n 79 \n 110 \n 127 \n 54 \n 48 \n 58 \n 2,543 \n 3,019 \n 3,504 \n 3,894 \n 4,009 \n 3,424 \n 3,680 \n 4,450 \n 4,549 \n 5,221 \n 4,807 \n 4,708 \n 4,178 \n 3 \n 3 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 4 \n 5 \n 4 \n 4 \n 4 \n 4,679 \n 4,760 \n 5,615 \n 5,884 \n 6,452 \n 5,622 \n 5,635 \n 6,619 \n 6,440 \n 8,077 \n 6,641 \n 6,682 \n 6,372 \n 1,279 \n 1,273 \n 1,109 \n 1,175 \n 1,048 \n 1,143 \n 1,228 \n 814 \n 1,199 \n 980 \n 860 \n 1,350 \n 1,196 \n 744 \n 823 \n 1,195 \n 1,269 \n 1,194 \n 1,289 \n 1,563 \n 1,194 \n 1,740 \n 1,642 \n 1,041 \n 1,368 \n 992 \n 43 \n 40 \n 183 \n 52 \n 183 \n 169 \n 16 \n 52 \n 137 \n 112 \n 18 \n 66 \n 69 \n 18,729 \n 22,666 \n 44,937 \n 18,273 \n 19,424 \n 19,382 \n 16,289 \n 15,706 \n 15,964 \n 13,701 \n 11,816 \n 8,645 \n 9,503 \n 2,769 \n 2,913 \n 3,873 \n 2,959 \n 2,525 \n 2,977 \n 4,406 \n 2,260 \n 2,419 \n 2,164 \n 1,860 \n 1,929 \n 1,839 \n 573 \n 563 \n 478 \n 716 \n 693 \n 711 \n 1,279 \n 529 \n 435 \n 460 \n 494 \n 519 \n 631 \n 22,114 \n 26,182 \n 49,472 \n 22,000 \n 22,824 \n 23,239 \n 21,990 \n 18,547 \n 18,954 \n 16,437 \n 14,188 \n 11,159 \n 12,043 \n 17 \n 20 \n 36 \n 17 \n 17 \n 17 \n 17 \n 14 \n 15 \n 13 \n 11 \n 9 \n 9 \n 24,138 \n 28,278 \n 51,775 \n 24,444 \n 25,067 \n 25,671 \n 24,781 \n 20,555 \n 21,892 \n 19,058 \n 16,089 \n 13,877 \n 14,231 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 1 \n 2 \n 5 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 1 \n 1 \n 2 \n 3 \n 2 \n 3 \n 2 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 14 \n 13 \n 13 \n 14 \n 14 \n 13 \n 9 \n 10 \n 10 \n 11 \n 10 \n 11 \n 13 \n 16 \n 15 \n 15 \n 15 \n 15 \n 15 \n 14 \n 14 \n 14 \n 14 \n 13 \n 13 \n 15 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 1.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 121 of 176 \n Generated 9/9/2010 4:42:44 PM \n 207 \n 152 \n 268 \n 209 \n 200 \n 115 \n 43 \n 515 \n 394 \n 258 \n 454 \n 399 \n 342 \n 69 \n 60 \n 0 \n 0 \n 0 \n 27 \n 0 \n 113 \n 242 \n 165 \n 8 \n 42 \n 139 \n 1,675 \n 1,534 \n 1,124 \n 964 \n 937 \n 842 \n 821 \n 1,209 \n 650 \n 765 \n 939 \n 1,072 \n 890 \n 298 \n 77 \n 81 \n 167 \n 168 \n 102 \n 44 \n 312 \n 190 \n 346 \n 204 \n 337 \n 334 \n 106 \n 10 \n 26 \n 76 \n 8 \n 44 \n 21 \n 100 \n 82 \n 40 \n 43 \n 192 \n 304 \n 2,148 \n 1,680 \n 1,230 \n 1,206 \n 1,113 \n 1,016 \n 885 \n 1,733 \n 1,164 \n 1,316 \n 1,194 \n 1,642 \n 1,666 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 2 \n 1 \n 2,631 \n 1,976 \n 1,668 \n 1,591 \n 1,359 \n 1,168 \n 1,117 \n 2,485 \n 1,612 \n 1,959 \n 1,876 \n 2,428 \n 2,108 \n 216 \n 180 \n 109 \n 195 \n 178 \n 74 \n 90 \n 305 \n 133 \n 304 \n 234 \n 261 \n 293 \n 193 \n 287 \n 299 \n 310 \n 409 \n 320 \n 89 \n 417 \n 367 \n 349 \n 251 \n 282 \n 279 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 60 \n 0 \n 144 \n 0 \n 14 \n 1,145 \n 1,108 \n 1,043 \n 976 \n 783 \n 606 \n 600 \n 703 \n 667 \n 340 \n 468 \n 578 \n 465 \n 112 \n 34 \n 60 \n 151 \n 152 \n 102 \n 40 \n 107 \n 124 \n 274 \n 126 \n 154 \n 168 \n 38 \n 98 \n 42 \n 116 \n 8 \n 48 \n 8 \n 68 \n 82 \n 32 \n 146 \n 176 \n 136 \n 1,295 \n 1,240 \n 1,145 \n 1,242 \n 943 \n 756 \n 648 \n 878 \n 933 \n 646 \n 884 \n 908 \n 783 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1,703 \n 1,706 \n 1,553 \n 1,747 \n 1,530 \n 1,150 \n 826 \n 1,599 \n 1,433 \n 1,299 \n 1,368 \n 1,450 \n 1,355 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 797 \n 662 \n 854 \n 635 \n 908 \n 627 \n 619 \n 749 \n 622 \n 974 \n 529 \n 645 \n 845 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 122 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 70 \n 73 \n 65 \n 57 \n 77 \n 74 \n 74 \n 10 \n 8 \n 6 \n 5 \n 7 \n 5 \n 7 \n 2 \n 2 \n 1 \n 1 \n 3 \n 3 \n 2 \n 83 \n 83 \n 72 \n 63 \n 87 \n 82 \n 83 \n 0.00 \n 0.00 \n 0.39 \n 0.97 \n 0.39 \n 0.77 \n 0.79 \n 1.73 \n 1.96 \n 1.77 \n 0.98 \n 1.00 \n 0.58 \n 0 \n 0 \n 2 \n 5 \n 2 \n 4 \n 4 \n 9 \n 10 \n 9 \n 5 \n 5 \n 3 \n 0.00 \n 0.00 \n 0.32 \n 0.21 \n 0.31 \n 0.84 \n 0.62 \n 0.71 \n 0.60 \n 0.40 \n 0.59 \n 0.59 \n 0.87 \n 0 \n 0 \n 3 \n 2 \n 3 \n 8 \n 6 \n 7 \n 6 \n 4 \n 6 \n 6 \n 9 \n 9 \n 0 \n 3 \n 4 \n 4 \n 6 \n 3 \n 9 \n 6 \n 11 \n 13 \n 22 \n 7 \n 4 \n 0 \n 8 \n 5 \n 4 \n 8 \n 6 \n 1 \n 3 \n 2 \n 3 \n 5 \n 3 \n 8 \n 0 \n 2 \n 2 \n 2 \n 0 \n 4 \n 1 \n 3 \n 1 \n 3 \n 3 \n 5 \n 0.00 \n 0.00 \n 0.77 \n 1.74 \n 3.09 \n 2.90 \n 2.75 \n 1.93 \n 2.74 \n 3.34 \n 3.34 \n 3.79 \n 2.71 \n 0 \n 0 \n 4 \n 9 \n 16 \n 15 \n 14 \n 10 \n 14 \n 17 \n 17 \n 19 \n 14 \n 6 \n 0 \n 6 \n 8 \n 16 \n 9 \n 10 \n 33 \n 7 \n 11 \n 28 \n 37 \n 24 \n 11 \n 0 \n 11 \n 3 \n 6 \n 4 \n 10 \n 11 \n 6 \n 5 \n 7 \n 12 \n 12 \n 19 \n 0 \n 3 \n 8 \n 4 \n 5 \n 6 \n 3 \n 2 \n 4 \n 3 \n 4 \n 8 \n 0.00 \n 0.00 \n 2.13 \n 2.21 \n 2.51 \n 2.61 \n 2.47 \n 2.22 \n 2.61 \n 2.69 \n 2.87 \n 2.25 \n 2.23 \n 0 \n 0 \n 20 \n 21 \n 24 \n 25 \n 24 \n 22 \n 26 \n 27 \n 29 \n 23 \n 23 \n 276 \n 144 \n 170 \n 176 \n 47 \n 38 \n 190 \n 237 \n 54 \n 385 \n 228 \n 387 \n 100 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 123 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.15 \n 0.39 \n 0.18 \n 0.55 \n 0.29 \n 0.47 \n 0.16 \n 0.12 \n 0.80 \n 0.68 \n 0.82 \n 1.32 \n 0.86 \n 1.44 \n 0.56 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 3.57 \n 3.93 \n 2.96 \n 2.71 \n 3.18 \n 3.20 \n 2.66 \n 29 \n 76 \n 36 \n 109 \n 57 \n 94 \n 30 \n 39 \n 253 \n 215 \n 261 \n 422 \n 273 \n 458 \n 25 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2,819 \n 3,417 \n 2,696 \n 2,312 \n 2,630 \n 2,881 \n 2,427 \n 458 \n 182 \n 58 \n 200 \n 160 \n 96 \n 96 \n 18 \n 62 \n 24 \n 70 \n 252 \n 88 \n 56 \n 3,320 \n 3,661 \n 2,777 \n 2,582 \n 3,042 \n 3,065 \n 2,579 \n 2 \n 3 \n 2 \n 4 \n 4 \n 4 \n 1 \n 2 \n 3 \n 5 \n 3 \n 6 \n 5 \n 6 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 124 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 2 \n 2 \n 4 \n 4 \n 4 \n 3 \n 2 \n 8 \n 2 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 4 \n 2 \n 3 \n 5 \n 5 \n 4 \n 3 \n 4 \n 9 \n 3 \n 5 \n 0 \n 0.00 \n 0.55 \n 0.48 \n 0.34 \n 0.27 \n 0.14 \n 0.41 \n 0.46 \n 0.07 \n 0.33 \n 0.33 \n 0.26 \n 0.19 \n 0 \n 8 \n 7 \n 5 \n 4 \n 2 \n 6 \n 7 \n 1 \n 5 \n 5 \n 4 \n 3 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 7 \n 2 \n 1 \n 1 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 96 \n 29 \n 13 \n 3 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.14 \n 0.07 \n 0.14 \n 0.14 \n 0.00 \n 0.00 \n 0.54 \n 0.13 \n 0.07 \n 6.41 \n 2.10 \n 1.05 \n 0.19 \n 2 \n 1 \n 2 \n 2 \n 0 \n 0 \n 8 \n 2 \n 1 \n 97 \n 32 \n 16 \n 3 \n 46 % \n 39 % \n 32 % \n 61 % \n 41 % \n 41 % \n 41 % \n 55 % \n 64 % \n 26 % \n 29 % \n 33 % \n 44 % \n 12 \n 32 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 43 \n 13 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 775 \n 901 \n 969 \n 858 \n 853 \n 751 \n 1,051 \n 760 \n 761 \n 1,531 \n 462 \n 316 \n 742 \n 722 \n 895 \n 715 \n 858 \n 901 \n 805 \n 1,013 \n 862 \n 563 \n 1,333 \n 719 \n 510 \n 797 \n 1,460 \n 1,225 \n 1,122 \n 1,336 \n 901 \n 1,135 \n 1,574 \n 656 \n 1,449 \n 851 \n 1,507 \n 1,381 \n 1,224 \n 1,513 \n 988 \n 1,205 \n 1,477 \n 1,246 \n 1,422 \n 1,532 \n 761 \n 1,012 \n 1,318 \n 1,295 \n 1,374 \n 1,529 \n 4 \n 10 \n 9 \n 0 \n 2 \n 1 \n 4 \n 0 \n 2 \n 7 \n 0 \n 1 \n 1 \n 4 \n 10 \n 9 \n 0 \n 2 \n 1 \n 4 \n 0 \n 2 \n 7 \n 0 \n 1 \n 1 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 125 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.42 \n 0.07 \n 0.34 \n 0.48 \n 0.54 \n 0.47 \n 0.27 \n 0.33 \n 0.27 \n 0.33 \n 0.20 \n 0.00 \n 0.26 \n 6 \n 1 \n 5 \n 7 \n 8 \n 7 \n 4 \n 5 \n 4 \n 5 \n 3 \n 0 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.13 \n 0.00 \n 0.00 \n 0.00 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 4 \n 7 \n 3 \n 6 \n 4 \n 4 \n 4 \n 0 \n 5 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 0 \n 0 \n 2 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 4 \n 4 \n 4 \n 3 \n 2 \n 8 \n 1 \n 4 \n 0 \n 0 \n 3 \n 6 \n 4 \n 2 \n 2 \n 4 \n 7 \n 0 \n 2 \n 4 \n 4 \n 3 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nPBSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 126 of 176 \n Generated 9/9/2010 4:42:44 PM \n 71 \n 78 \n 78 \n 90 \n 103 \n 105 \n 96 \n 101 \n 81 \n 83 \n 78 \n 83 \n 81 \n 1,821 \n 1,847 \n 1,842 \n 1,839 \n 1,842 \n 1,816 \n 1,804 \n 1,839 \n 1,804 \n 1,837 \n 1,801 \n 1,825 \n 1,831 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 20 \n 18 \n 20 \n 29 \n 20 \n 28 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 30.17 % \n 41.32 % \n 43.28 % \n 33.10 % \n 29.60 % \n 16.16 % \n 36.90 % \n 38.97 % \n 41.16 % \n 51.37 % \n 49.07 % \n 49.57 % \n 48.87 % \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 1 \n 35 \n 50 \n 58 \n 47 \n 37 \n 37 \n 93 \n 106 \n 128 \n 75 \n 79 \n 57 \n 65 \n 116 \n 121 \n 134 \n 142 \n 125 \n 229 \n 252 \n 272 \n 311 \n 146 \n 161 \n 115 \n 133 \n 4.88 % \n 6.32 % \n 8.01 % \n 8.39 % \n 8.10 % \n 8.04 % \n 9.79 % \n 9.22 % \n 7.77 % \n 7.47 % \n 6.69 % \n 6.79 % \n 3.48 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 14 \n 18 \n 23 \n 24 \n 23 \n 23 \n 28 \n 26 \n 22 \n 21 \n 19 \n 19 \n 10 \n 287 \n 285 \n 287 \n 286 \n 284 \n 286 \n 286 \n 282 \n 283 \n 281 \n 284 \n 280 \n 287 \n 97.52 % \n 98.12 % \n 98.25 % \n 98.12 % \n 97.45 % \n 96.86 % \n 97.37 % \n 97.82 % \n 98.85 % \n 97.48 % \n 97.92 % \n 96.14 % \n 96.98 % \n 2,905 \n 2,923 \n 2,927 \n 2,923 \n 2,903 \n 3,021 \n 3,037 \n 3,051 \n 3,083 \n 2,904 \n 2,917 \n 2,864 \n 2,889 \n 2,979 \n 2,979 \n 2,979 \n 2,979 \n 2,979 \n 3,119 \n 3,119 \n 3,119 \n 3,119 \n 2,979 \n 2,979 \n 2,979 \n 2,979 \n 64 \n 61 \n 61 \n 66 \n 66 \n 68 \n 64 \n 57 \n 58 \n 53 \n 52 \n 58 \n 60 \n 6 \n 4 \n 4 \n 6 \n 2 \n 8 \n 4 \n 3 \n 4 \n 1 \n 1 \n 3 \n 5 \n 990 \n 1,003 \n 994 \n 989 \n 979 \n 994 \n 1,003 \n 992 \n 982 \n 982 \n 971 \n 970 \n 972 \n 116 \n 121 \n 134 \n 142 \n 125 \n 229 \n 252 \n 272 \n 311 \n 146 \n 161 \n 115 \n 133 \n 1,729 \n 1,734 \n 1,735 \n 1,720 \n 1,731 \n 1,722 \n 1,715 \n 1,729 \n 1,730 \n 1,724 \n 1,732 \n 1,718 \n 1,719 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 127 of 176 \n Generated 9/9/2010 4:42:44 PM \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 320 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 347 \n 344 \n 344 \n 338 \n 333 \n 332 \n 333 \n 345 \n 346 \n 341 \n 339 \n 337 \n 335 \n 984 \n 990 \n 989 \n 990 \n 976 \n 962 \n 967 \n 1,050 \n 1,043 \n 1,045 \n 1,042 \n 1,014 \n 1,016 \n 287 \n 285 \n 288 \n 286 \n 284 \n 287 \n 287 \n 282 \n 284 \n 281 \n 284 \n 280 \n 287 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 288 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 384 \n 374 \n 378 \n 374 \n 380 \n 369 \n 361 \n 380 \n 374 \n 369 \n 349 \n 349 \n 351 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 1,598 \n 1,636 \n 1,635 \n 1,653 \n 1,629 \n 1,725 \n 1,735 \n 1,766 \n 1,774 \n 1,642 \n 1,642 \n 1,626 \n 1,652 \n 1,641 \n 1,641 \n 1,641 \n 1,641 \n 1,641 \n 1,781 \n 1,781 \n 1,781 \n 1,781 \n 1,641 \n 1,641 \n 1,641 \n 1,641 \n 2,269 \n 2,295 \n 2,301 \n 2,313 \n 2,293 \n 2,381 \n 2,383 \n 2,428 \n 2,432 \n 2,292 \n 2,275 \n 2,255 \n 2,290 \n 2,313 \n 2,313 \n 2,313 \n 2,313 \n 2,313 \n 2,453 \n 2,453 \n 2,453 \n 2,453 \n 2,313 \n 2,313 \n 2,313 \n 2,313 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3.90 % \n 4.22 % \n 4.23 % \n 4.89 % \n 5.59 % \n 5.78 % \n 5.32 % \n 5.49 % \n 4.49 % \n 4.52 % \n 4.33 % \n 4.55 % \n 4.42 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 128 of 176 \n Generated 9/9/2010 4:42:44 PM \n 829 \n 829 \n 828 \n 804 \n 823 \n 837 \n 850 \n 856 \n 878 \n 830 \n 833 \n 831 \n 834 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 1,104 \n 141 \n 142 \n 143 \n 145 \n 123 \n 139 \n 144 \n 147 \n 142 \n 144 \n 149 \n 146 \n 146 \n 58 \n 56 \n 55 \n 61 \n 68 \n 73 \n 25 \n 20 \n 20 \n 24 \n 22 \n 23 \n 21 \n 199 \n 198 \n 198 \n 206 \n 191 \n 212 \n 169 \n 167 \n 162 \n 168 \n 171 \n 169 \n 167 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 73 \n 76 \n 74 \n 74 \n 77 \n 74 \n 74 \n 74 \n 76 \n 66 \n 71 \n 74 \n 82 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 10 \n 15 \n 14 \n 8 \n 9 \n 4 \n 6 \n 5 \n 21 \n 35 \n 38 \n 27 \n 30 \n 19 \n 15 \n 14 \n 21 \n 19 \n 14 \n 10 \n 14 \n 21 \n 14 \n 14 \n 16 \n 15 \n 15 \n 11 \n 8 \n 14 \n 15 \n 13 \n 8 \n 6 \n 14 \n 9 \n 10 \n 5 \n 15 \n 44 \n 41 \n 36 \n 43 \n 43 \n 31 \n 24 \n 25 \n 56 \n 58 \n 62 \n 48 \n 60 \n 2 \n 2 \n 2 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0 \n 6 \n 2 \n 0 \n 0 \n 5 \n 4 \n 6 \n 6 \n 5 \n 5 \n 6 \n 6 \n 12 \n 20 \n 22 \n 24 \n 23 \n 40 \n 44 \n 40 \n 34 \n 23 \n 28 \n 24 \n 18 \n 30 \n 39 \n 40 \n 43 \n 44 \n 100 \n 99 \n 101 \n 95 \n 83 \n 86 \n 77 \n 75 \n 85 \n 116 \n 110 \n 110 \n 114 \n 281 \n 281 \n 264 \n 263 \n 259 \n 281 \n 301 \n 274 \n 293 \n 264 \n 288 \n 265 \n 262 \n 281 \n 281 \n 264 \n 263 \n 259 \n 281 \n 301 \n 274 \n 293 \n 264 \n 288 \n 265 \n 262 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 129 of 176 \n Generated 9/9/2010 4:42:44 PM \n 101 \n 75 \n 83 \n 76 \n 62 \n 83 \n 63 \n 64 \n 97 \n 68 \n 105 \n 83 \n 75 \n 153 \n 153 \n 163 \n 162 \n 167 \n 170 \n 166 \n 169 \n 159 \n 173 \n 172 \n 168 \n 177 \n 254 \n 228 \n 246 \n 238 \n 229 \n 253 \n 229 \n 233 \n 256 \n 241 \n 277 \n 251 \n 252 \n 229 \n 188 \n 199 \n 193 \n 156 \n 164 \n 144 \n 676 \n 631 \n 646 \n 639 \n 652 \n 665 \n 645 \n 905 \n 819 \n 845 \n 832 \n 808 \n 829 \n 789 \n 86 \n 83 \n 90 \n 85 \n 87 \n 94 \n 89 \n 93 \n 95 \n 85 \n 89 \n 86 \n 78 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 90 \n 315 \n 340 \n 380 \n 342 \n 374 \n 374 \n 380 \n 386 \n 392 \n 392 \n 376 \n 383 \n 390 \n 244 \n 241 \n 245 \n 236 \n 238 \n 238 \n 237 \n 231 \n 235 \n 237 \n 241 \n 232 \n 233 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 256 \n 57 \n 64 \n 63 \n 60 \n 52 \n 54 \n 54 \n 64 \n 57 \n 63 \n 63 \n 64 \n 65 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 74 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 250 \n 246 \n 258 \n 257 \n 248 \n 255 \n 259 \n 249 \n 261 \n 248 \n 270 \n 266 \n 276 \n 365 \n 352 \n 358 \n 363 \n 370 \n 355 \n 347 \n 368 \n 361 \n 356 \n 342 \n 341 \n 343 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 384 \n 672 \n 662 \n 679 \n 680 \n 670 \n 664 \n 660 \n 681 \n 679 \n 667 \n 675 \n 671 \n 684 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n 458 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 130 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 13 \n 14 \n 13 \n 18 \n 18 \n 10 \n 12 \n 11 \n 6 \n 15 \n 10 \n 0 \n 15 \n 25 \n 18 \n 15 \n 6 \n 10 \n 40 \n 21 \n 17 \n 15 \n 5 \n 8 \n 0 \n 22 \n 26 \n 30 \n 27 \n 18 \n 18 \n 23 \n 17 \n 20 \n 30 \n 26 \n 17 \n 0 \n 13 \n 10 \n 15 \n 15 \n 13 \n 12 \n 17 \n 12 \n 13 \n 14 \n 13 \n 21 \n 0 \n 132 \n 105 \n 116 \n 81 \n 111 \n 119 \n 100 \n 143 \n 154 \n 159 \n 142 \n 98 \n 0.00 \n 8.52 \n 9.09 \n 9.31 \n 8.10 \n 7.75 \n 8.59 \n 8.55 \n 10.25 \n 12.98 \n 10.11 \n 9.74 \n 8.90 \n 0 \n 249 \n 266 \n 272 \n 235 \n 234 \n 261 \n 261 \n 316 \n 377 \n 295 \n 279 \n 257 \n 32 \n 35 \n 36 \n 30 \n 21 \n 34 \n 22 \n 32 \n 42 \n 43 \n 59 \n 51 \n 55 \n 92 \n 89 \n 95 \n 93 \n 94 \n 93 \n 89 \n 91 \n 87 \n 99 \n 98 \n 97 \n 98 \n 124 \n 124 \n 131 \n 123 \n 115 \n 127 \n 111 \n 123 \n 129 \n 142 \n 157 \n 148 \n 153 \n 10 \n 13 \n 12 \n 14 \n 17 \n 13 \n 15 \n 15 \n 11 \n 15 \n 11 \n 16 \n 16 \n 32 \n 32 \n 26 \n 26 \n 24 \n 22 \n 23 \n 23 \n 24 \n 27 \n 29 \n 25 \n 24 \n 42 \n 45 \n 38 \n 40 \n 41 \n 35 \n 38 \n 38 \n 35 \n 42 \n 40 \n 41 \n 40 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 261 \n 257 \n 256 \n 256 \n 255 \n 255 \n 254 \n 253 \n 256 \n 255 \n 257 \n 253 \n 258 \n 261 \n 257 \n 256 \n 256 \n 255 \n 255 \n 254 \n 253 \n 256 \n 255 \n 257 \n 253 \n 258 \n 23 \n 36 \n 63 \n 65 \n 68 \n 73 \n 56 \n 34 \n 44 \n 56 \n 82 \n 59 \n 56 \n 80 \n 76 \n 102 \n 100 \n 106 \n 102 \n 112 \n 125 \n 113 \n 106 \n 104 \n 103 \n 115 \n 106 \n 102 \n 224 \n 165 \n 174 \n 175 \n 168 \n 159 \n 157 \n 162 \n 186 \n 162 \n 171 \n 186 \n 178 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 131 of 176 \n Generated 9/9/2010 4:42:44 PM \n 24 \n 26 \n 18 \n 22 \n 15 \n 16 \n 16 \n 23 \n 16 \n 24 \n 16 \n 15 \n 18 \n 20 \n 26 \n 22 \n 29 \n 17 \n 13 \n 20 \n 17 \n 10 \n 18 \n 18 \n 24 \n 19 \n 5 \n 2 \n 4 \n 3 \n 4 \n 3 \n 1 \n 4 \n 7 \n 3 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 34 \n 38 \n 33 \n 33 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 3 \n 0 \n 1 \n 0 \n 1.10 \n 1.47 \n 1.20 \n 1.40 \n 1.07 \n 0.86 \n 0.99 \n 1.18 \n 0.88 \n 1.27 \n 0.93 \n 1.22 \n 1.21 \n 32 \n 43 \n 35 \n 41 \n 31 \n 26 \n 30 \n 36 \n 27 \n 37 \n 27 \n 35 \n 35 \n 1 \n 1 \n 0 \n 5 \n 2 \n 1 \n 0 \n 2 \n 2 \n 0 \n 1 \n 2 \n 4 \n 2.17 \n 2.22 \n 2.32 \n 2.70 \n 2.41 \n 2.22 \n 2.24 \n 2.16 \n 2.34 \n 2.55 \n 1.99 \n 2.37 \n 2.18 \n 63 \n 65 \n 68 \n 79 \n 70 \n 67 \n 68 \n 66 \n 72 \n 74 \n 58 \n 68 \n 63 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 2 \n 1 \n 3 \n 5 \n 0 \n 2 \n 3 \n 0 \n 59 \n 87 \n 79 \n 84 \n 68 \n 84 \n 71 \n 111 \n 162 \n 71 \n 78 \n 103 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 132 of 176 \n Generated 9/9/2010 4:42:44 PM \n 3 \n 5 \n 4 \n 9 \n 6 \n 1 \n 6 \n 2 \n 3 \n 2 \n 1 \n 5 \n 5 \n 7 \n 5 \n 9 \n 9 \n 5 \n 5 \n 6 \n 5 \n 3 \n 8 \n 7 \n 4 \n 1 \n 6 \n 2 \n 2 \n 0 \n 1 \n 1 \n 1 \n 1 \n 5 \n 2 \n 2 \n 1 \n 3 \n 13 \n 7 \n 11 \n 9 \n 6 \n 6 \n 7 \n 6 \n 8 \n 10 \n 9 \n 5 \n 4 \n 3 \n 1 \n 0 \n 3 \n 4 \n 3 \n 3 \n 7 \n 4 \n 7 \n 3 \n 3 \n 4 \n 11 \n 14 \n 10 \n 14 \n 12 \n 11 \n 11 \n 15 \n 11 \n 14 \n 11 \n 11 \n 19 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 11 \n 14 \n 10 \n 15 \n 14 \n 11 \n 11 \n 16 \n 11 \n 14 \n 12 \n 12 \n 19 \n 0 \n 0 \n 1 \n 2 \n 3 \n 1 \n 1 \n 0 \n 4 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 4 \n 0 \n 1 \n 0 \n 0 \n 2 \n 2 \n 0 \n 2 \n 1 \n 2 \n 0 \n 6 \n 6 \n 3 \n 1 \n 0 \n 0 \n 5 \n 6 \n 4 \n 3 \n 0 \n 1 \n 5 \n 0 \n 6 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 0 \n 3 \n 1 \n 5 \n 12 \n 6 \n 5 \n 1 \n 0 \n 10 \n 9 \n 8 \n 6 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 8 \n 2 \n 3 \n 4 \n 3 \n 1 \n 2 \n 5 \n 6 \n 2 \n 6 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 2 \n 0 \n 3 \n 3 \n 1 \n 1 \n 5 \n 1 \n 4 \n 3 \n 0 \n 2 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 133 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 12 \n 18 \n 20 \n 33 \n 56 \n 76 \n 2,905 \n 2,923 \n 2,927 \n 2,922 \n 2,903 \n 3,021 \n 3,037 \n 3,039 \n 3,065 \n 2,884 \n 2,884 \n 2,808 \n 2,813 \n 9 \n 8 \n 9 \n 7 \n 6 \n 4 \n 7 \n 4 \n 5 \n 8 \n 8 \n 10 \n 12 \n 5 \n 10 \n 7 \n 9 \n 3 \n 13 \n 6 \n 6 \n 37 \n 35 \n 18 \n 9 \n 6 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 2 \n 0 \n 2 \n 1 \n 2 \n 1 \n 4 \n 1 \n 0 \n 0 \n 1 \n 0 \n 6 \n 7 \n 12 \n 14 \n 14 \n 19 \n 15 \n 10 \n 12 \n 11 \n 6 \n 15 \n 10 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 4 \n 8 \n 5 \n 6 \n 6 \n 4 \n 7 \n 12 \n 9 \n 11 \n 3 \n 7 \n 3 \n 5 \n 7 \n 5 \n 3 \n 5 \n 7 \n 10 \n 8 \n 9 \n 2 \n 4 \n 2 \n 5 \n 2 \n 2 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 1 \n 1 \n 1 \n 1 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 1 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 134 of 176 \n Generated 9/9/2010 4:42:44 PM \n 20 \n 13 \n 22 \n 26 \n 29 \n 29 \n 32 \n 54 \n 28 \n 22 \n 22 \n 37 \n 33 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 5 \n 7 \n 10 \n 8 \n 3 \n 4 \n 6 \n 4 \n 6 \n 0 \n 7 \n 7 \n 4 \n 4 \n 4 \n 5 \n 6 \n 12 \n 9 \n 14 \n 0 \n 3 \n 4 \n 8 \n 5 \n 23 \n 27 \n 22 \n 28 \n 34 \n 25 \n 58 \n 37 \n 17 \n 11 \n 18 \n 23 \n 33 \n 0 \n 3 \n 3 \n 2 \n 4 \n 3 \n 4 \n 0 \n 3 \n 0 \n 2 \n 2 \n 4 \n 6 \n 6 \n 10 \n 7 \n 8 \n 7 \n 11 \n 12 \n 7 \n 8 \n 3 \n 4 \n 8 \n 11 \n 7 \n 15 \n 10 \n 13 \n 14 \n 13 \n 11 \n 3 \n 2 \n 6 \n 6 \n 5 \n 14 \n 20 \n 10 \n 16 \n 22 \n 24 \n 24 \n 24 \n 9 \n 9 \n 11 \n 14 \n 17 \n 3.89 \n 3.76 \n 4.24 \n 5.13 \n 5.65 \n 5.33 \n 6.62 \n 6.72 \n 3.05 \n 2.86 \n 2.85 \n 10.47 \n 12.25 \n 4 \n 0 \n 1 \n 1 \n 1 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 2 \n 7 \n 10 \n 8 \n 8 \n 12 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 6 \n 1 \n 392 \n 501 \n 314 \n 440 \n 446 \n 370 \n 265 \n 448 \n 440 \n 379 \n 343 \n 326 \n 461 \n 113 \n 110 \n 124 \n 150 \n 164 \n 161 \n 201 \n 205 \n 94 \n 83 \n 83 \n 300 \n 354 \n 505 \n 611 \n 438 \n 590 \n 610 \n 531 \n 466 \n 653 \n 534 \n 462 \n 426 \n 626 \n 815 \n 6 \n 7 \n 12 \n 14 \n 14 \n 19 \n 15 \n 10 \n 12 \n 11 \n 6 \n 15 \n 10 \n 6 \n 3 \n 8 \n 4 \n 2 \n 7 \n 2 \n 3 \n 2 \n 6 \n 2 \n 1 \n 6 \n 6 \n 7 \n 12 \n 14 \n 16 \n 18 \n 18 \n 10 \n 12 \n 11 \n 6 \n 15 \n 10 \n 6 \n 6 \n 9 \n 9 \n 7 \n 10 \n 7 \n 5 \n 7 \n 9 \n 3 \n 11 \n 8 \n 6 \n 6 \n 9 \n 9 \n 7 \n 11 \n 7 \n 5 \n 8 \n 10 \n 4 \n 12 \n 8 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 135 of 176 \n Generated 9/9/2010 4:42:44 PM \n 135 \n 108 \n 0 \n 162 \n 162 \n 162 \n 159 \n 162 \n 162 \n 162 \n 29.57 % \n 29.68 % \n 17.29 % \n 51.85 % \n 44.07 % \n 0.00 % \n 0.00 % \n 87.96 % \n 94.91 % \n 95.77 % \n 97.22 % \n100.00 %\n 95.37 % \n 236 \n 184 \n 111 \n 126 \n 119 \n 0 \n 0 \n 190 \n 205 \n 204 \n 210 \n 216 \n 206 \n 798 \n 620 \n 642 \n 243 \n 270 \n 0 \n 216 \n 216 \n 216 \n 213 \n 216 \n 216 \n 216 \n 0.00 \n 0.00 \n 9.12 \n 3.67 \n 7.75 \n 10.85 \n 7.85 \n 5.06 \n 12.15 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 10 \n 0 \n 0 \n 1 \n 0 \n 0 \n 78 \n 65 \n 27 \n 0 \n 46 \n 26 \n 9 \n 13 \n 16 \n 22 \n 18 \n 11 \n 14 \n 47 \n 45 \n 33 \n 0 \n 40 \n 26 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 69 \n 10 \n 59 \n 24 \n 137 \n 10 \n 34 \n 0 \n 0 \n 277 \n 112 \n 239 \n 315 \n 229 \n 145 \n 351 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 346 \n 122 \n 298 \n 339 \n 366 \n 155 \n 385 \n 1 \n 1 \n 2 \n 1 \n 1 \n 3 \n 2 \n 3 \n 4 \n 0 \n 4 \n 1 \n 2 \n 0 \n 1 \n 0 \n 0 \n 172 \n 202 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 4 \n 3 \n 5 \n 7 \n 5 \n 8 \n 6 \n 5 \n 0 \n 5 \n 3 \n 8 \n 3 \n 0 \n 4 \n 4 \n 1 \n 3 \n 4 \n 7 \n 1 \n 2 \n 0 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 4 \n 2 \n 3 \n 4 \n 3 \n 1 \n 2 \n 1 \n 5 \n 7 \n 4 \n 0 \n 2 \n 3 \n 8 \n 5 \n 3 \n 10 \n 2 \n 3 \n 1 \n 2 \n 11 \n 14 \n 11 \n 10 \n 20 \n 15 \n 18 \n 14 \n 10 \n 3 \n 8 \n 1 \n 5 \n 5 \n 6 \n 8 \n 8 \n 9 \n 5 \n 7 \n 10 \n 8 \n 6 \n 7 \n 5 \n 9 \n 4 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 136 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 10 \n 0 \n 1 \n 0 \n 0 \n 0 \n 2 \n 4 \n 5 \n 1 \n 4 \n 4 \n 44 \n 38 \n 27 \n 32 \n 10 \n 0 \n 328 \n 304 \n 285 \n 291 \n 249 \n 221 \n 221 \n 17 \n 7 \n 0 \n 168 \n 157 \n 149 \n 161 \n 136 \n 131 \n 115 \n 472 \n 14 \n 607 \n 93 \n 865 \n 1,009 \n 1 \n 0 \n 377 \n 1,855 \n 1,039 \n 1,909 \n 2,039 \n 245 \n 2,350 \n 1,786 \n 15 \n 1,801 \n 1,731 \n 1,905 \n 150 \n 124 \n 0 \n 3,662 \n 1,522 \n 2,498 \n 2,077 \n 1,333 \n 849 \n 1,891 \n 2,408 \n 1,824 \n 2,770 \n 1,159 \n 125 \n 0 \n 4,039 \n 3,377 \n 3,537 \n 3,986 \n 3,372 \n 1,094 \n 4,241 \n 8,039 \n 5,658 \n 2,569 \n 9,533 \n 4,070 \n 0 \n 14,375 \n 8,737 \n 12,877 \n 18,025 \n 17,179 \n 18,849 \n 18,983 \n 136 \n 45 \n 0 \n 148 \n 122 \n 152 \n 154 \n 147 \n 153 \n 209 \n 36.11 % \n 31.48 % \n 0.00 % \n 0.00 % \n 83.33 % \n 90.74 % \n 94.44 % \n 98.15 % \n100.00 %\n 98.15 % \n 39 \n 51 \n 0 \n 0 \n 45 \n 49 \n 51 \n 53 \n 54 \n 53 \n 108 \n 162 \n 0 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 64.44 % \n 62.96 % \n 0.00 % \n 0.00 % \n 89.51 % \n 96.30 % \n 96.23 % \n 96.91 % \n100.00 %\n 94.44 % \n 87 \n 68 \n 0 \n 0 \n 145 \n 156 \n 153 \n 157 \n 162 \n 153 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 137 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 162 \n 162 \n 162 \n 162 \n 162 \n 162 \n 162 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 116 \n 99 \n 99 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 120 \n 120 \n 120 \n 120 \n 0 \n 0 \n 0 \n 240 \n 240 \n 240 \n 234 \n 234 \n 240 \n 239 \n 0 \n 0 \n 0 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 52 \n 54 \n 56 \n 80 \n 59 \n 0 \n 245 \n 339 \n 332 \n 358 \n 346 \n 270 \n 331 \n 22 \n 27 \n 25 \n 136 \n 119 \n 0 \n 327 \n 470 \n 480 \n 447 \n 452 \n 444 \n 464 \n 0.0 \n 5.1 \n 5.0 \n 5.1 \n 5.1 \n 5.1 \n 5.1 \n 5.1 \n 5.2 \n 5.2 \n 5.2 \n 650 \n 650 \n 657 \n 210 \n 210 \n 210 \n 245 \n 245 \n 245 \n 245 \n 245 \n 245 \n 245 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 0 \n 0 \n 8 \n 0 \n 1 \n 6 \n 7 \n 10 \n 2 \n 8 \n 1 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 138 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 103 \n 103 \n 105 \n 108 \n 106 \n 106 \n 260 \n 260 \n 260 \n 260 \n 260 \n 260 \n 260 \n 0 \n 0 \n 0 \n 43 \n 15 \n 0 \n 277 \n 789 \n 262 \n 240 \n 212 \n 226 \n 219 \n 21 \n 10 \n 0 \n 184 \n 181 \n 169 \n 164 \n 167 \n 118 \n 137 \n 77 \n 52 \n 0 \n 527 \n 110 \n 169 \n 28 \n 0 \n 165 \n 376 \n 724 \n 835 \n 721 \n 150 \n 1,057 \n 115 \n 0 \n 115 \n 495 \n 1,947 \n 141 \n 7 \n 0 \n 741 \n 1,052 \n 1,084 \n 1,652 \n 826 \n 488 \n 231 \n 115 \n 1,021 \n 2,057 \n 310 \n 35 \n 0 \n 906 \n 1,428 \n 1,808 \n 2,487 \n 1,547 \n 638 \n 1,288 \n 5,720 \n 6,461 \n 4,372 \n 5,164 \n 4,450 \n 0 \n 5,828 \n 3,357 \n 4,266 \n 5,746 \n 6,461 \n 6,271 \n 7,846 \n 53 \n 49 \n 0 \n 60 \n 47 \n 51 \n 49 \n 55 \n 51 \n 86 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 95.06 % \n 97.53 % \n 75.31 % \n 85.19 % \n 0.00 % \n 0.00 % \n 90.12 % \n 95.06 % \n 96.30 % \n 97.53 % \n 96.30 % \n 97.53 % \n 96.30 % \n 77 \n 79 \n 61 \n 69 \n 0 \n 0 \n 73 \n 77 \n 78 \n 79 \n 78 \n 79 \n 78 \n 81 \n 81 \n 81 \n 81 \n 81 \n 0 \n 81 \n 81 \n 81 \n 81 \n 81 \n 81 \n 81 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 139 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,988 \n 1,921 \n 1,986 \n 1,625 \n 1,596 \n 1,486 \n 1,487 \n 1,487 \n 1,455 \n 1,455 \n 1,457 \n 1,459 \n 1,465 \n 1,988 \n 1,921 \n 1,986 \n 1,625 \n 1,596 \n 1,486 \n 1,487 \n 1,487 \n 1,455 \n 1,455 \n 1,457 \n 1,459 \n 1,465 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 6 \n 6 \n 5 \n 1 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 140 of 176 \n Generated 9/9/2010 4:42:44 PM \n 3,434 \n 4,447 \n 4,834 \n 3,866 \n 4,456 \n 4,848 \n 3,238 \n 2,731 \n 2,348 \n 2,864 \n 2,746 \n 2,205 \n 612 \n 315 \n 6,173 \n 2,068 \n 504 \n 1,107 \n 610 \n 1,330 \n 1,226 \n 877 \n 519 \n 463 \n 283 \n 307 \n 491 \n 87 \n 318 \n 118 \n 180 \n 255 \n 17 \n 340 \n 173 \n 202 \n 248 \n 950 \n 655 \n 602 \n 204 \n 470 \n 644 \n 692 \n 668 \n 1,070 \n 903 \n 973 \n 1,037 \n 899 \n 1,275 \n 1,351 \n 1,379 \n 3,018 \n 1,267 \n 218 \n 226 \n 2,767 \n 6,664 \n 471 \n 1,930 \n 299 \n 160 \n 1,162 \n 732 \n 6,221 \n 13,929 \n 8,957 \n 5,350 \n 6,661 \n 9,148 \n 12,318 \n 5,671 \n 6,301 \n 4,921 \n 4,516 \n 5,875 \n 3,656 \n 81.75 % \n 82.54 % \n 75.40 % \n 74.60 % \n 74.60 % \n 76.19 % \n 77.78 % \n 80.16 % \n 83.08 % \n 76.15 % \n 78.46 % \n 78.46 % \n 82.31 % \n 103 \n 104 \n 95 \n 94 \n 94 \n 96 \n 98 \n 101 \n 108 \n 99 \n 102 \n 102 \n 107 \n 126 \n 126 \n 126 \n 126 \n 126 \n 126 \n 126 \n 126 \n 130 \n 130 \n 130 \n 130 \n 130 \n 908 \n 969 \n 1,030 \n 893 \n 850 \n 945 \n 893 \n 940 \n 939 \n 734 \n 745 \n 720 \n 804 \n 982 \n 955 \n 983 \n 977 \n 964 \n 1,267 \n 891 \n 956 \n 779 \n 779 \n 747 \n 762 \n 795 \n 4 \n 3 \n 4 \n 2 \n 5 \n 9 \n 5 \n 3 \n 5 \n 10 \n 7 \n 7 \n 12 \n 986 \n 958 \n 987 \n 979 \n 969 \n 1,276 \n 896 \n 959 \n 784 \n 789 \n 754 \n 769 \n 807 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 61.72 % \n 65.17 % \n 60.07 % \n 68.98 % \n 70.80 % \n 63.80 % \n 89.85 % \n 61.72 % \n 65.17 % \n 60.07 % \n 68.98 % \n 70.80 % \n 63.80 % \n 89.85 % \n 88.77 % \n 94.23 % \n 97.11 % \n 94.10 % \n 97.74 % \n 94.81 % \n 761 \n 669 \n 793 \n 504 \n 466 \n 538 \n 151 \n 167 \n 84 \n 42 \n 86 \n 33 \n 76 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,227 \n 1,252 \n 1,193 \n 1,121 \n 1,130 \n 948 \n 1,336 \n 1,320 \n 1,371 \n 1,413 \n 1,371 \n 1,426 \n 1,389 \n 1,227 \n 1,252 \n 1,193 \n 1,121 \n 1,130 \n 948 \n 1,336 \n 1,320 \n 1,371 \n 1,413 \n 1,371 \n 1,426 \n 1,389 \n 2,251 \n 2,282 \n 2,283 \n 2,292 \n 2,281 \n 2,365 \n 2,387 \n 2,433 \n 2,421 \n 2,280 \n 2,262 \n 2,266 \n 2,289 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 141 of 176 \n Generated 9/9/2010 4:42:44 PM \n 81 \n 92 \n 118 \n 19 \n 21 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 7 \n 4 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 8 \n 11 \n 11 \n 8 \n 11 \n 9 \n 11 \n 17 \n 14 \n 45 \n 0 \n 0 \n 5 \n 5 \n 7 \n 7 \n 5 \n 7 \n 6 \n 7 \n 11 \n 7 \n 15 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 2,394 \n 3,276 \n 4,212 \n 5,040 \n 3,308 \n 3,318 \n 2,223 \n 6,384 \n 6,288 \n 6,630 \n 5,723 \n 6,786 \n 4,992 \n 76 \n 91 \n 104 \n 140 \n 105 \n 158 \n 78 \n 112 \n 131 \n 130 \n 109 \n 116 \n 104 \n 21 \n 24 \n 27 \n 24 \n 21 \n 14 \n 19 \n 38 \n 32 \n 34 \n 35 \n 39 \n 32 \n 11,070 \n 10,449 \n 11,933 \n 19,160 \n 12,423 \n 8,246 \n 1,470 \n 23,364 \n 14,242 \n 19,602 \n 19,912 \n 24,278 \n 16,142 \n 164 \n 162 \n 185 \n 241 \n 202 \n 239 \n 49 \n 236 \n 211 \n 198 \n 225 \n 249 \n 211 \n 45 \n 43 \n 43 \n 53 \n 41 \n 23 \n 20 \n 66 \n 45 \n 66 \n 59 \n 65 \n 51 \n 15,740 \n 15,665 \n 17,100 \n 24,268 \n 15,779 \n 11,575 \n 3,702 \n 29,759 \n 20,547 \n 26,246 \n 25,680 \n 31,064 \n 21,134 \n 326 \n 350 \n 414 \n 407 \n 333 \n 404 \n 133 \n 355 \n 353 \n 335 \n 349 \n 365 \n 315 \n 73 \n 75 \n 75 \n 80 \n 64 \n 38 \n 40 \n 105 \n 78 \n 101 \n 96 \n 104 \n 83 \n 26 \n 26 \n 26 \n 26 \n 26 \n 26 \n 26 \n 26 \n 25 \n 25 \n 24 \n 22 \n 22 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 142 of 176 \n Generated 9/9/2010 4:42:44 PM \n 40 \n 38 \n 40 \n 40 \n 40 \n 39 \n 39 \n 39 \n 39 \n 39 \n 40 \n 40 \n 41 \n 0.0 \n -1.8 \n 0.0 \n 0.0 \n -0.1 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -0.5 \n 1.0 \n 0.9 \n 1.0 \n 40 \n 40 \n 40 \n 40 \n 40 \n 39 \n 39 \n 39 \n 39 \n 39 \n 39 \n 39 \n 40 \n 22 \n 20 \n 27 \n 24 \n 26 \n 25 \n 42 \n 39 \n 23 \n 24 \n 13 \n 21 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 5 \n 9 \n 8 \n 8 \n 6 \n 5 \n 5 \n 6 \n 4 \n 5 \n 4 \n 3 \n 3 \n 2 \n 44 \n 32 \n 27 \n 22 \n 31 \n 35 \n 29 \n 17 \n 15 \n 23 \n 3 \n 18 \n 33 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 3 \n 2 \n 0 \n 2 \n 1 \n 2 \n 14 \n 13 \n 11 \n 15 \n 16 \n 12 \n 17 \n 12 \n 21 \n 15 \n 26 \n 15 \n 17 \n 957 \n 971 \n 978 \n 979 \n 969 \n 978 \n 973 \n 990 \n 992 \n 987 \n 996 \n 989 \n 993 \n 1,015 \n 1,016 \n 1,016 \n 1,016 \n 1,016 \n 1,025 \n 1,023 \n 1,022 \n 1,029 \n 1,024 \n 1,027 \n 1,022 \n 1,045 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 2.0 \n 0.0 \n -5.9 \n 0.0 \n -5.2 \n 3.0 \n -2.8 \n 11.0 \n 1,015 \n 1,016 \n 1,016 \n 1,016 \n 1,016 \n 1,023 \n 1,023 \n 1,028 \n 1,029 \n 1,029 \n 1,024 \n 1,025 \n 1,034 \n 1,649 \n 1,658 \n 1,667 \n 1,679 \n 1,672 \n 1,672 \n 1,669 \n 1,692 \n 1,690 \n 1,679 \n 1,675 \n 1,671 \n 1,688 \n -3,716 \n 162,346 \n 69,486 \n-139,885\n-327,767\n-385,826\n-401,193\n-401,193\n-437,828\n-437,828\n-458,914\n-601,613\n-601,613\n 0 \n2,739,749\n2,600,924\n2,600,924\n2,600,924\n2,526,887\n2,526,887\n2,526,887\n2,526,887\n2,526,887\n2,526,887\n2,317,560\n2,317,560\n -587,799\n-17,283,428\n-17,324,522\n-17,051,970\n-16,998,649\n-21,372,277\n-19,599,705\n-19,096,075\n-17,990,705\n-16,337,763\n-14,337,763\n-11,276,506\n-11,276,506\n 0 \n117,357,359\n118,220,638\n118,220,638\n118,220,638\n119,969,980\n119,969,980\n119,969,980\n119,969,979\n119,969,980\n119,969,980\n124,902,793\n124,902,793\n 2,268 \n 1,932 \n 944 \n 57 \n 40 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 143 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 28 \n 30 \n 28 \n 17 \n 33 \n 38 \n 38 \n 26 \n 23 \n 22 \n 11 \n 5 \n 17 \n 5 \n 6 \n 7 \n 6 \n 8 \n 4 \n 6 \n 5 \n 5 \n 4 \n 5 \n 5 \n 5 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 2 \n 331 \n 326 \n 326 \n 339 \n 335 \n 331 \n 329 \n 331 \n 334 \n 334 \n 327 \n 323 \n 331 \n 364 \n 363 \n 362 \n 363 \n 377 \n 372 \n 372 \n 361 \n 361 \n 361 \n 343 \n 333 \n 354 \n 0.0 \n 0.0 \n 0.0 \n 2.0 \n 19.0 \n 17.0 \n 17.0 \n 8.0 \n 8.0 \n 8.0 \n -1.0 \n -1.0 \n 0.0 \n 364 \n 363 \n 362 \n 361 \n 358 \n 355 \n 355 \n 353 \n 353 \n 353 \n 344 \n 334 \n 354 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 4 \n 7 \n 7 \n 3 \n 2 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 17 \n 16 \n 16 \n 16 \n 20 \n 21 \n 21 \n 22 \n 22 \n 22 \n 22 \n 22 \n 22 \n 18 \n 20 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 24 \n 0.0 \n -3.2 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 18 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 23 \n 24 \n 3 \n 2 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n -1 \n 0 \n 1 \n 0 \n 1 \n 1 \n 2 \n 2 \n 1 \n 3 \n 2 \n 3 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 35 \n 39 \n 40 \n 39 \n 39 \n 38 \n 38 \n 37 \n 38 \n 38 \n 38 \n 38 \n 38 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 144 of 176 \n Generated 9/9/2010 4:42:44 PM \n 15 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 5 \n 5 \n 4 \n 4 \n 6 \n 5 \n 4 \n 12 \n 12 \n 5 \n 2 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 119 \n 116 \n 117 \n 117 \n 116 \n 115 \n 116 \n 118 \n 110 \n 108 \n 106 \n 109 \n 111 \n 122 \n 122 \n 123 \n 122 \n 120 \n 121 \n 122 \n 122 \n 122 \n 120 \n 111 \n 111 \n 121 \n 0.0 \n 0.0 \n 1.0 \n 0.0 \n -0.4 \n -0.4 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 122 \n 122 \n 122 \n 122 \n 120 \n 121 \n 122 \n 122 \n 122 \n 120 \n 111 \n 111 \n 121 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 2 \n 1 \n 2 \n 2 \n 2 \n 3 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 16 \n 17 \n 20 \n 18 \n 22 \n 17 \n 16 \n 20 \n 10 \n 14 \n 6 \n 10 \n 3 \n 3 \n 4 \n 3 \n 3 \n 1 \n 2 \n 1 \n 1 \n 5 \n 3 \n 5 \n 7 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 181 \n 180 \n 179 \n 177 \n 180 \n 178 \n 180 \n 182 \n 182 \n 178 \n 173 \n 177 \n 180 \n 198 \n 199 \n 199 \n 199 \n 200 \n 200 \n 198 \n 198 \n 202 \n 192 \n 190 \n 189 \n 199 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 2.0 \n 0.0 \n 0.0 \n 4.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 198 \n 199 \n 199 \n 199 \n 200 \n 198 \n 198 \n 198 \n 198 \n 192 \n 190 \n 189 \n 199 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 2 \n 2 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 145 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,758 \n 1,691 \n 1,500 \n 1,712 \n 1,559 \n 1,709 \n 1,659 \n 1,827 \n 1,311 \n 1,439 \n 1,402 \n 1,792 \n 1,824 \n 57 \n 48 \n 63 \n 142 \n 156 \n 140 \n 136 \n 78 \n 91 \n 195 \n 16 \n 110 \n 107 \n 4,676 \n 4,807 \n 5,053 \n 4,899 \n 5,076 \n 5,552 \n 5,235 \n 5,272 \n 4,908 \n 5,447 \n 5,968 \n 5,719 \n 6,409 \n 499 \n 648 \n 459 \n 596 \n 436 \n 571 \n 398 \n 501 \n 347 \n 484 \n 572 \n 441 \n 476 \n 104 \n 72 \n 114 \n 100 \n 112 \n 151 \n 76 \n 144 \n 104 \n 157 \n 424 \n 120 \n 152 \n 5,335 \n 5,575 \n 5,688 \n 5,736 \n 5,780 \n 6,413 \n 5,844 \n 5,994 \n 5,449 \n 6,282 \n 6,980 \n 6,389 \n 7,144 \n 5 \n 5 \n 5 \n 5 \n 5 \n 6 \n 5 \n 6 \n 5 \n 6 \n 6 \n 6 \n 6 \n 8,224 \n 8,684 \n 8,492 \n 8,829 \n 8,950 \n 9,673 \n 8,994 \n 9,832 \n 8,499 \n 9,569 \n 9,996 \n 9,479 \n 10,464 \n 4,763 \n 3,630 \n 5,152 \n 4,207 \n 3,769 \n 4,132 \n 4,905 \n 3,505 \n 3,423 \n 3,824 \n 4,767 \n 4,451 \n 3,440 \n 1,144 \n 1,095 \n 1,047 \n 1,071 \n 1,323 \n 1,419 \n 2,027 \n 1,889 \n 2,112 \n 1,221 \n 1,130 \n 955 \n 1,082 \n 0 \n 0 \n 26 \n 10 \n 0 \n 64 \n 74 \n 52 \n 8 \n 0 \n 0 \n 0 \n 0 \n 12,939 \n 8,167 \n 15,700 \n 7,166 \n 10,340 \n 10,711 \n 13,965 \n 14,281 \n 11,909 \n 12,138 \n 12,563 \n 15,483 \n 12,871 \n 2,543 \n 1,845 \n 2,190 \n 1,339 \n 2,105 \n 1,648 \n 1,732 \n 2,037 \n 2,840 \n 2,216 \n 2,059 \n 2,926 \n 2,733 \n 809 \n 681 \n 861 \n 108 \n 469 \n 460 \n 928 \n 654 \n 963 \n 815 \n 670 \n 656 \n 720 \n 16,291 \n 10,693 \n 18,776 \n 8,623 \n 12,914 \n 12,883 \n 16,699 \n 17,024 \n 15,719 \n 15,169 \n 15,291 \n 19,066 \n 16,324 \n 13 \n 9 \n 15 \n 8 \n 11 \n 11 \n 14 \n 13 \n 13 \n 12 \n 13 \n 15 \n 12 \n 22,198 \n 15,418 \n 24,975 \n 13,901 \n 18,006 \n 18,434 \n 23,631 \n 22,418 \n 21,255 \n 20,214 \n 21,188 \n 24,471 \n 20,846 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 2 \n 1 \n 0 \n 1 \n 2 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 10 \n 11 \n 12 \n 13 \n 13 \n 12 \n 12 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 15 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 146 of 176 \n Generated 9/9/2010 4:42:44 PM \n 379 \n 310 \n 212 \n 330 \n 197 \n 159 \n 142 \n 226 \n 483 \n 305 \n 225 \n 293 \n 351 \n 8 \n 8 \n 0 \n 32 \n 0 \n 9 \n 0 \n 40 \n 14 \n 19 \n 0 \n 19 \n 32 \n 599 \n 261 \n 292 \n 232 \n 280 \n 166 \n 123 \n 171 \n 168 \n 273 \n 228 \n 301 \n 195 \n 80 \n 0 \n 0 \n 48 \n 13 \n 19 \n 16 \n 0 \n 64 \n 31 \n 200 \n 64 \n 8 \n 19 \n 8 \n 75 \n 34 \n 31 \n 37 \n 16 \n 16 \n 40 \n 88 \n 16 \n 8 \n 160 \n 706 \n 277 \n 367 \n 346 \n 324 \n 231 \n 155 \n 227 \n 286 \n 410 \n 444 \n 392 \n 395 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1,817 \n 1,086 \n 1,044 \n 1,015 \n 1,027 \n 716 \n 686 \n 1,125 \n 1,329 \n 1,448 \n 1,064 \n 1,392 \n 1,125 \n 744 \n 688 \n 1,052 \n 891 \n 1,183 \n 968 \n 1,213 \n 1,197 \n 1,120 \n 1,163 \n 1,201 \n 753 \n 583 \n 290 \n 604 \n 545 \n 695 \n 582 \n 424 \n 690 \n 464 \n 681 \n 546 \n 318 \n 276 \n 441 \n 0 \n 0 \n 0 \n 32 \n 0 \n 0 \n 104 \n 24 \n 145 \n 0 \n 0 \n 8 \n 32 \n 873 \n 294 \n 1,142 \n 716 \n 600 \n 856 \n 167 \n 1,417 \n 867 \n 1,089 \n 547 \n 982 \n 539 \n 28 \n 0 \n 32 \n 78 \n 0 \n 0 \n 0 \n 120 \n 101 \n 24 \n 55 \n 48 \n 0 \n 19 \n 8 \n 33 \n 0 \n 0 \n 0 \n 0 \n 152 \n 0 \n 0 \n 0 \n 0 \n 0 \n 920 \n 302 \n 1,207 \n 826 \n 600 \n 856 \n 271 \n 1,713 \n 1,113 \n 1,113 \n 602 \n 1,038 \n 571 \n 1 \n 1 \n 2 \n 1 \n 1 \n 1 \n 1 \n 2 \n 2 \n 2 \n 1 \n 1 \n 1 \n 1,954 \n 1,594 \n 2,803 \n 2,412 \n 2,364 \n 2,248 \n 2,174 \n 3,373 \n 2,913 \n 2,822 \n 2,122 \n 2,067 \n 1,595 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 4 \n 4 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 2 \n 1 \n 1 \n 2 \n 0 \n 0 \n 1 \n 0 \n 3 \n 2 \n 1,131 \n 1,419 \n 1,305 \n 1,382 \n 1,611 \n 1,551 \n 1,492 \n 2,011 \n 1,739 \n 1,848 \n 1,615 \n 1,298 \n 1,497 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 147 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 91 \n 65 \n 69 \n 61 \n 59 \n 26 \n 18 \n 1 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 92 \n 65 \n 70 \n 62 \n 60 \n 26 \n 18 \n 17.95 \n 4.01 \n 2.62 \n 1.81 \n 1.66 \n 1.37 \n 3.65 \n 5.11 \n 5.14 \n 3.36 \n 4.05 \n 3.41 \n 3.35 \n 118 \n 26 \n 17 \n 12 \n 11 \n 9 \n 24 \n 34 \n 34 \n 22 \n 26 \n 22 \n 22 \n 10.39 \n 7.13 \n 7.66 \n 8.35 \n 7.04 \n 3.15 \n 2.77 \n 9.64 \n 6.51 \n 7.71 \n 6.29 \n 5.55 \n 7.37 \n 103 \n 72 \n 78 \n 85 \n 71 \n 32 \n 28 \n 99 \n 67 \n 79 \n 65 \n 57 \n 76 \n 12 \n 33 \n 10 \n 22 \n 7 \n 28 \n 17 \n 5 \n 21 \n 8 \n 5 \n 13 \n 14 \n 6 \n 4 \n 8 \n 6 \n 4 \n 6 \n 6 \n 5 \n 11 \n 8 \n 11 \n 6 \n 1 \n 4 \n 4 \n 7 \n 4 \n 6 \n 10 \n 3 \n 5 \n 8 \n 7 \n 2 \n 2 \n 1 \n 2.74 \n 3.09 \n 2.62 \n 2.57 \n 2.56 \n 1.83 \n 2.59 \n 2.40 \n 2.72 \n 1.83 \n 1.40 \n 2.02 \n 2.43 \n 18 \n 20 \n 17 \n 17 \n 17 \n 12 \n 17 \n 16 \n 18 \n 12 \n 9 \n 13 \n 16 \n 15 \n 32 \n 15 \n 20 \n 7 \n 34 \n 11 \n 13 \n 18 \n 14 \n 12 \n 16 \n 30 \n 15 \n 15 \n 7 \n 10 \n 9 \n 7 \n 11 \n 8 \n 8 \n 10 \n 15 \n 13 \n 7 \n 1 \n 2 \n 8 \n 5 \n 15 \n 13 \n 6 \n 3 \n 5 \n 9 \n 8 \n 9 \n 5 \n 4.54 \n 4.75 \n 3.34 \n 3.24 \n 4.17 \n 3.64 \n 3.46 \n 3.60 \n 4.08 \n 3.91 \n 3.97 \n 3.90 \n 3.49 \n 45 \n 48 \n 34 \n 33 \n 42 \n 37 \n 35 \n 37 \n 42 \n 40 \n 41 \n 40 \n 36 \n 732 \n 499 \n 466 \n 340 \n 507 \n 327 \n 389 \n 672 \n 560 \n 734 \n 395 \n 708 \n 380 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 148 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n -2,782 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3,034 \n 2,308 \n 0 \n 0 \n 2.14 \n 1.64 \n 2.13 \n 0.73 \n 1.18 \n 2.40 \n 2.05 \n 0.63 \n 0.51 \n 0.38 \n 0.00 \n 0.02 \n 0.07 \n 0.12 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 0.00 \n 3.29 \n 2.53 \n 2.72 \n 2.02 \n 2.12 \n 1.00 \n 0.63 \n 709 \n 535 \n 694 \n 248 \n 396 \n 792 \n 675 \n 206 \n 165 \n 124 \n 0 \n 8 \n 24 \n 40 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3,128 \n 2,557 \n 2,756 \n 1,994 \n 2,093 \n 1,016 \n 642 \n 136 \n 0 \n 0 \n 64 \n 48 \n 0 \n 0 \n 0 \n 0 \n 16 \n 0 \n 0 \n 0 \n 0 \n 3,264 \n 2,557 \n 2,772 \n 2,058 \n 2,141 \n 1,016 \n 642 \n 14 \n 13 \n 16 \n 10 \n 7 \n 10 \n 9 \n 4 \n 5 \n 6 \n 0 \n 1 \n 2 \n 1 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 149 of 176 \n Generated 9/9/2010 4:42:44 PM \n 2 \n 2 \n 3 \n 4 \n 4 \n 4 \n 2 \n 3 \n 0 \n 1 \n 7 \n 6 \n 2 \n 0 \n 0 \n 0 \n 3 \n 2 \n 1 \n 2 \n 2 \n 1 \n 0 \n 1 \n 2 \n 2 \n 3 \n 4 \n 6 \n 4 \n 6 \n 7 \n 3 \n 9 \n 0 \n 4 \n 8 \n 5 \n 2 \n 0.06 \n 0.30 \n 0.12 \n 0.42 \n 0.60 \n 0.00 \n 0.42 \n 0.06 \n 0.12 \n 0.30 \n 0.30 \n 0.18 \n 0.77 \n 1 \n 5 \n 2 \n 7 \n 10 \n 0 \n 7 \n 1 \n 2 \n 5 \n 5 \n 3 \n 13 \n 6 \n 0 \n 1 \n 0 \n 1 \n 5 \n 2 \n 2 \n 0 \n 1 \n 1 \n 4 \n 3 \n 2 \n 6 \n 2 \n 4 \n 2 \n 9 \n 4 \n 0 \n 0 \n 1 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.49 \n 0.36 \n 0.18 \n 0.24 \n 0.18 \n 0.84 \n 0.36 \n 0.12 \n 0.00 \n 0.12 \n 0.06 \n 0.36 \n 0.18 \n 8 \n 6 \n 3 \n 4 \n 3 \n 14 \n 6 \n 2 \n 0 \n 2 \n 1 \n 6 \n 3 \n 23 % \n 14 % \n 26 % \n 30 % \n 24 % \n 23 % \n 10 % \n 8 % \n 10 % \n 12 % \n 7 % \n 9 % \n 9 % \n 0 \n 6 \n 4 \n 4 \n 6 \n 12 \n 14 \n 1 \n 36 \n 7 \n 20 \n 11 \n 13 \n 0 \n 0 \n 4 \n 4 \n 6 \n 12 \n 14 \n 1 \n 36 \n 7 \n 20 \n 11 \n 13 \n 400 \n 359 \n 730 \n 805 \n 846 \n 603 \n 742 \n 896 \n 699 \n 687 \n 704 \n 577 \n 749 \n 498 \n 413 \n 821 \n 944 \n 958 \n 723 \n 799 \n 883 \n 663 \n 801 \n 731 \n 685 \n 824 \n 915 \n 1,008 \n 1,017 \n 1,039 \n 815 \n 760 \n 914 \n 752 \n 1,054 \n 1,078 \n 713 \n 782 \n 803 \n 1,119 \n 1,314 \n 1,338 \n 1,226 \n 1,060 \n 934 \n 1,109 \n 921 \n 1,266 \n 1,272 \n 878 \n 964 \n 995 \n 108 \n 65 \n 143 \n 167 \n 161 \n 196 \n 179 \n 213 \n 170 \n 229 \n 160 \n 183 \n 201 \n 99 \n 70 \n 143 \n 167 \n 161 \n 196 \n 179 \n 213 \n 170 \n 229 \n 160 \n 183 \n 201 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 150 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1 \n 1 \n 0 \n 1 \n 1 \n 0 \n 1 \n 0 \n 1 \n 0 \n 6 \n 0 \n 0 \n 0.36 \n 0.12 \n 0.06 \n 0.24 \n 0.24 \n 0.12 \n 0.66 \n 0.18 \n 0.18 \n 0.30 \n 0.78 \n 0.30 \n 0.30 \n 6 \n 2 \n 1 \n 4 \n 4 \n 2 \n 11 \n 3 \n 3 \n 5 \n 13 \n 5 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 2 \n 3 \n 4 \n 3 \n 4 \n 7 \n 6 \n 7 \n 8 \n 5 \n 4 \n 6 \n 8 \n 0 \n 0 \n 1 \n 3 \n 3 \n 0 \n 1 \n 2 \n 3 \n 0 \n 3 \n 1 \n 0 \n 10 \n 11 \n 11 \n 11 \n 12 \n 13 \n 10 \n 9 \n 8 \n 12 \n 13 \n 12 \n 10 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 3 \n 1 \n 3 \n 1 \n 1 \n 0 \n 4 \n 1 \n 0 \n 0 \n 1 \n 1 \n 1 \n 3 \n 4 \n 0 \n 1 \n 1 \n 0 \n 0 \n 5 \n 0 \n 0 \n 1 \n 0 \n 1 \n 3 \n 1 \n 3 \n 0 \n 1 \n 0 \n 4 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 3 \n 1 \n 4 \n 1 \n 0 \n 0 \n 4 \n 1 \n 0 \n 0 \n 0.00 \n 0.06 \n 0.06 \n 0.18 \n 0.24 \n 0.00 \n 0.06 \n 0.00 \n 0.00 \n 0.00 \n 0.36 \n 0.06 \n 0.00 \n 0 \n 1 \n 1 \n 3 \n 4 \n 0 \n 1 \n 0 \n 0 \n 0 \n 6 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 4 \n 9 \n 10 \n 10 \n 11 \n 11 \n 8 \n 11 \n 6 \n 6 \n 8 \n 8 \n 9 \n 6 \n 2 \n 2 \n 4 \n 9 \n 1 \n 7 \n 2 \n 3 \n 15 \n 3 \n 9 \n 2 \n 26 \n 31 \n 29 \n 29 \n 26 \n 39 \n 28 \n 25 \n 23 \n 24 \n 34 \n 34 \n 38 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 2 \n 2 \n 2 \n 3 \n 3 \n 4 \n 4 \n 3 \n 3 \n 0 \n 1 \n 7 \n 5 \n 2 \n 2 \n 1 \n 2 \n 4 \n 5 \n 0 \n 4 \n 1 \n 0 \n 2 \n 4 \n 3 \n 12 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nSAC\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 151 of 176 \n Generated 9/9/2010 4:42:44 PM \n 223 \n 166 \n 161 \n 167 \n 141 \n 141 \n 129 \n 163 \n 186 \n 206 \n 174 \n 86 \n 87 \n 2,818 \n 2,301 \n 2,326 \n 2,345 \n 2,332 \n 2,310 \n 2,330 \n 2,248 \n 2,252 \n 2,267 \n 2,245 \n 2,016 \n 2,170 \n 0.00 % \n 38.23 % \n 33.22 % \n 28.40 % \n 20.74 % \n 21.26 % \n 9.01 % \n 9.45 % \n 10.93 % \n 11.35 % \n 14.32 % \n 23.15 % \n 9.43 % \n 23 \n 47 \n 43 \n 37 \n 28 \n 28 \n 0 \n 0 \n 216 \n 191 \n 167 \n 118 \n 118 \n 51 \n 52 \n 60 \n 64 \n 63 \n 178 \n 88 \n 0 \n 565 \n 575 \n 588 \n 569 \n 555 \n 566 \n 550 \n 549 \n 564 \n 440 \n 769 \n 933 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 2 \n 17 \n 13 \n 17 \n 7 \n 11 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7.32 % \n 7.46 % \n 8.27 % \n 9.52 % \n 8.26 % \n 7.35 % \n 10.81 % \n 10.80 % \n 8.65 % \n 8.04 % \n 8.30 % \n 9.62 % \n 7.97 % \n 0 \n 0 \n 2 \n 0 \n 3 \n 4 \n 0 \n 15 \n 17 \n 21 \n 20 \n 18 \n 18 \n 24 \n 27 \n 23 \n 23 \n 24 \n 28 \n 24 \n 205 \n 228 \n 254 \n 210 \n 218 \n 245 \n 222 \n 250 \n 266 \n 286 \n 289 \n 291 \n 301 \n 94.29 % \n 96.68 % \n 94.83 % \n 97.22 % \n 96.94 % \n 96.94 % \n 96.14 % \n 92.84 % \n 93.55 % \n 95.48 % \n 88.52 % \n 88.69 % \n 97.17 % \n 3,666 \n 3,759 \n 3,797 \n 3,780 \n 3,769 \n 3,769 \n 3,786 \n 3,656 \n 3,684 \n 3,760 \n 3,585 \n 3,692 \n 4,045 \n 3,888 \n 3,888 \n 4,004 \n 3,888 \n 3,888 \n 3,888 \n 3,938 \n 3,938 \n 3,938 \n 3,938 \n 4,050 \n 4,163 \n 4,163 \n 242 \n 248 \n 249 \n 246 \n 254 \n 248 \n 246 \n 244 \n 248 \n 248 \n 255 \n 249 \n 250 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1,443 \n 1,503 \n 1,505 \n 1,528 \n 1,502 \n 1,489 \n 1,503 \n 1,399 \n 1,414 \n 1,442 \n 1,345 \n 1,419 \n 1,604 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,986 \n 2,013 \n 2,047 \n 2,011 \n 2,016 \n 2,036 \n 2,038 \n 2,019 \n 2,027 \n 2,072 \n 1,987 \n 2,032 \n 2,197 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nOut of Level IV Assignments\nLevel IV\n% of Out of Level Assignments\nOut of Level III Endorsed and \nAwaiting (Pending) Transfer\nOut of Level III Assignments\nLevel III\n% of Out of Level Assignments\nOut of Level II Endorsed and \nAwaiting (Pending) Transfer\nOut of Level II Assignments\nLevel II\n% of Out of Level Assignments\nOut of Level I Endorsed and \nAwaiting (Pending) Transfer\nOut of Level I Assignments\nLevel I\nInmate Custody Level\n% Inst. Filled to Budgeted Capacity\nInmate Count\nBudgeted Capacity\nMedical Beds\nTemporary Beds (Family \nVisiting/Tank Beds)\nOvercrowding Beds\nNon-Traditional Beds\nDesign Beds\nContract Beds\nTotal Bed Capacity\nCustody Operations\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 152 of 176 \n Generated 9/9/2010 4:42:44 PM \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 439 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 335 \n 300 \n 294 \n 291 \n 292 \n 283 \n 282 \n 272 \n 270 \n 277 \n 275 \n 273 \n 275 \n 1,309 \n 1,310 \n 1,302 \n 1,295 \n 1,287 \n 1,293 \n 1,292 \n 253 \n 253 \n 270 \n 304 \n 376 \n 452 \n 205 \n 228 \n 254 \n 210 \n 218 \n 245 \n 222 \n 250 \n 266 \n 286 \n 289 \n 291 \n 301 \n 250 \n 250 \n 250 \n 250 \n 250 \n 250 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 300 \n 953 \n 966 \n 965 \n 961 \n 960 \n 954 \n 960 \n 959 \n 954 \n 944 \n 1,394 \n 1,726 \n 1,905 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 950 \n 1,900 \n 180 \n 175 \n 179 \n 182 \n 180 \n 178 \n 180 \n 174 \n 175 \n 178 \n 187 \n 183 \n 184 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 1,682 \n 1,722 \n 1,755 \n 1,787 \n 1,759 \n 1,731 \n 1,756 \n 1,662 \n 1,670 \n 1,709 \n 1,102 \n 872 \n 1,012 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,804 \n 1,926 \n 2,043 \n 1,093 \n 3,020 \n 3,091 \n 3,153 \n 3,140 \n 3,117 \n 3,108 \n 3,118 \n 3,045 \n 3,065 \n 3,117 \n 2,972 \n 3,072 \n 3,402 \n 3,196 \n 3,196 \n 3,196 \n 3,196 \n 3,196 \n 3,196 \n 3,246 \n 3,246 \n 3,246 \n 3,246 \n 3,368 \n 3,485 \n 3,485 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7.91 % \n 7.21 % \n 6.92 % \n 7.12 % \n 6.05 % \n 6.10 % \n 5.54 % \n 7.25 % \n 8.26 % \n 9.09 % \n 7.75 % \n 4.27 % \n 4.01 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nBudgeted Capacity\nAdministrative Segregation \n(ASU)\nActual Population\nBudgeted Capacity\nReception Center\nLife (Without Possibility of Parole) \n(LWOP)\nLife (With Possibility of Parole)\nLife Sentenced Inmates\nActual Population\nBudgeted Capacity\nMinimum Support Facility\nActual Population\nBudgeted Capacity\nSensitive Needs Yard\nActual Population\nBudgeted Capacity\nEnhanced Outpatient Program\nActual Population\nBudgeted Capacity\nGeneral Population\nActual Population\nBudgeted Capacity\nGeneral Population Summary\nCamps\n% of Out of Level Assignments\nOut of Level IV Endorsed and \nAwaiting (Pending) Transfer\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 153 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,214 \n 1,183 \n 1,189 \n 1,167 \n 1,132 \n 1,096 \n 1,068 \n 1,019 \n 995 \n 1,000 \n 1,036 \n 1,104 \n 1,209 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 1,299 \n 97 \n 99 \n 101 \n 100 \n 94 \n 102 \n 101 \n 97 \n 105 \n 114 \n 120 \n 152 \n 146 \n 249 \n 334 \n 245 \n 242 \n 253 \n 247 \n 358 \n 267 \n 259 \n 255 \n 216 \n 245 \n 282 \n 346 \n 433 \n 346 \n 342 \n 347 \n 349 \n 459 \n 364 \n 364 \n 369 \n 336 \n 397 \n 428 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 120 \n 120 \n 110 \n 90 \n 120 \n 120 \n 120 \n 120 \n 35 \n 0 \n 0 \n 0 \n 8 \n 8 \n 12 \n 12 \n 12 \n 13 \n 9 \n 10 \n 17 \n 14 \n 0 \n 0 \n 0 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 27 \n 76 \n 86 \n 73 \n 72 \n 189 \n 61 \n 57 \n 51 \n 52 \n 55 \n 62 \n 60 \n 50 \n 14 \n 59 \n 54 \n 0 \n 2 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 11 \n 11 \n 13 \n 9 \n 9 \n 14 \n 16 \n 15 \n 11 \n 14 \n 28 \n 18 \n 9 \n 134 \n 50 \n 49 \n 39 \n 62 \n 50 \n 41 \n 41 \n 37 \n 61 \n 64 \n 480 \n 15 \n 163 \n 41 \n 37 \n 37 \n 36 \n 49 \n 37 \n 55 \n 33 \n 29 \n 38 \n 8 \n 6 \n 310 \n 102 \n 99 \n 85 \n 107 \n 113 \n 94 \n 111 \n 81 \n 104 \n 130 \n 506 \n 30 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 6 \n 5 \n 8 \n 8 \n 8 \n 8 \n 7 \n 6 \n 6 \n 8 \n 10 \n 9 \n 5 \n 37 \n 40 \n 40 \n 37 \n 35 \n 36 \n 28 \n 24 \n 26 \n 43 \n 46 \n 34 \n 29 \n 99 \n 98 \n 98 \n 104 \n 105 \n 101 \n 96 \n 100 \n 99 \n 110 \n 104 \n 98 \n 91 \n 418 \n 479 \n 449 \n 394 \n 400 \n 419 \n 422 \n 367 \n 371 \n 395 \n 358 \n 369 \n 393 \n 404 \n 420 \n 395 \n 394 \n 398 \n 411 \n 422 \n 367 \n 371 \n 395 \n 358 \n 369 \n 393 \nActual Population\nTreatment Capacity\nCorrectional Clinical Case \nManagement Services (CCCMS)\nNon-Impacting\nImpacting\nActual Population\nAmerican with Disabilities Act\nNumber of Completions\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nBehavior Management Unit\nActual Population\nASU EOP Hub\nActual Population\nASU Overflow\nASU Endorsed for PSU\nASU Endorsed for SHU\nASU Endorsed for SNY\nASU Endorsed for GP\nTotal ASU Endorsed Inmates\nStays Exceeding 800 days\nStays Exceeding 400 days\nStays Exceeding 200 days\nAverage Length of Stay\nActual Population (With Overflow)\nActual Population (Excluding \nOverflow)\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 154 of 176 \n Generated 9/9/2010 4:42:44 PM \n 100 \n 15 \n 13 \n 0 \n 4 \n 0 \n 3 \n 5 \n 5 \n 7 \n 5 \n 5 \n 10 \n 98 \n 133 \n 115 \n 81 \n 119 \n 108 \n 123 \n 51 \n 115 \n 113 \n 106 \n 164 \n 131 \n 198 \n 148 \n 128 \n 81 \n 123 \n 108 \n 126 \n 56 \n 120 \n 120 \n 111 \n 169 \n 141 \n 149 \n 63 \n 60 \n 20 \n 38 \n 24 \n 26 \n 217 \n 255 \n 241 \n 207 \n 247 \n 244 \n 257 \n 366 \n 318 \n 301 \n 227 \n 285 \n 268 \n 283 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 75 \n 78 \n 69 \n 70 \n 49 \n 53 \n 55 \n 55 \n 54 \n 56 \n 59 \n 57 \n 52 \n 72 \n 72 \n 72 \n 72 \n 72 \n 72 \n 72 \n 72 \n 72 \n 72 \n 45 \n 45 \n 45 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 103 \n 94 \n 84 \n 146 \n 146 \n 132 \n 119 \n 104 \n 92 \n 81 \n 68 \n 43 \n 21 \n 173 \n 166 \n 170 \n 172 \n 172 \n 167 \n 173 \n 167 \n 163 \n 166 \n 176 \n 176 \n 176 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 192 \n 352 \n 338 \n 323 \n 388 \n 367 \n 352 \n 347 \n 326 \n 309 \n 303 \n 303 \n 277 \n 252 \n 264 \n 264 \n 264 \n 264 \n 264 \n 264 \n 264 \n 264 \n 264 \n 264 \n 237 \n 237 \n 237 \n \nGP without S-Suffix\nGP with S-Suffix\nTotal General Population (GP)\nSummary without S-Suffix\nSummary with S-Suffix\nSingle Cell Inmate Summary\nSingle Cell Inmates\nActual Population\nBudgeted Capacity\nSecurity Housing Unit\nAverage Length of Stay\nActual Population\nBudgeted Capacity\nPsychiatric Services Unit\nActual Population\nBudgeted Capacity\nEOP-ASU\nActual Population\nBudgeted Capacity\nEOP-SNY\nActual Population\nEOP Other Housing Programs\nActual Population\nBudgeted Capacity\nEOP-GP (GP Housing Program)\nActual Population\nBudgeted Capacity\nTotal EOP Populations\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 155 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 9 \n 10 \n 17 \n 4 \n 18 \n 11 \n 4 \n 11 \n 12 \n 6 \n 12 \n 7 \n 6 \n 27 \n 18 \n 19 \n 25 \n 27 \n 23 \n 21 \n 26 \n 15 \n 16 \n 8 \n 17 \n 9 \n 17 \n 27 \n 82 \n 15 \n 12 \n 26 \n 20 \n 21 \n 12 \n 17 \n 15 \n 10 \n 17 \n 5 \n 8 \n 10 \n 11 \n 6 \n 7 \n 10 \n 11 \n 7 \n 9 \n 15 \n 18 \n 9 \n 93 \n 146 \n 88 \n 118 \n 101 \n 78 \n 87 \n 102 \n 56 \n 107 \n 69 \n 119 \n 99 \n 8.57 \n 8.01 \n 8.64 \n 8.44 \n 7.85 \n 5.70 \n 7.16 \n 10.07 \n 4.40 \n 7.45 \n 4.94 \n 6.04 \n 5.19 \n 314 \n 301 \n 328 \n 319 \n 296 \n 215 \n 271 \n 368 \n 162 \n 280 \n 177 \n 223 \n 210 \n 16 \n 15 \n 13 \n 6 \n 9 \n 4 \n 3 \n 5 \n 5 \n 5 \n 4 \n 4 \n 5 \n 46 \n 45 \n 43 \n 44 \n 46 \n 50 \n 55 \n 51 \n 53 \n 48 \n 52 \n 50 \n 63 \n 62 \n 60 \n 56 \n 50 \n 55 \n 54 \n 58 \n 56 \n 58 \n 53 \n 56 \n 54 \n 68 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 0 \n 29 \n 33 \n 34 \n 14 \n 25 \n 20 \n 20 \n 8 \n 15 \n 17 \n 30 \n 26 \n 34 \n 73 \n 77 \n 83 \n 82 \n 82 \n 86 \n 79 \n 69 \n 64 \n 71 \n 76 \n 82 \n 84 \n 106 \n 110 \n 117 \n 96 \n 107 \n 106 \n 99 \n 77 \n 79 \n 88 \n 106 \n 108 \n 118 \nIHP Refusals / Failure to Comply\nIndecent Exposure (IEX)\nStimulants and Sedatives\nBatteries on Inmates\nBatteries on Staff\nConduct\nPer 100 inmates\nTotal\nInmate Disciplinaries\nEOP without S-Suffix\nEOP with S-Suffix\nTotal Enhanced Outpatient Program \n(EOP)\nSHU without S-Suffix\nSHU with S-Suffix\n7RWDO\u00036HFXULW\\\u0003+RXVLQJ\u00038QLW\u0003\u000b6+8\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nPSU without S-Suffix\nPSU with S-Suffix\n7RWDO\u00033V\\FKLDWULF\u00036HUYLFHV\u00038QLW\u0003\u000b368\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nASU EOP without S-Suffix\nASU EOP with S-Suffix\nASU without S-Suffix\nASU with S-Suffix\n7RWDO\u0003$GPLQLVWUDWLYH\u00036HJUHJDWLRQ\n8QLW\u0003\u000b$68\f\n6LQJOH\u0003&HOO\u0003,QPDWHV\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 156 of 176 \n Generated 9/9/2010 4:42:44 PM \n 7 \n 4 \n 10 \n 14 \n 6 \n 11 \n 14 \n 6 \n 4 \n 6 \n 12 \n 14 \n 13 \n 37 \n 24 \n 23 \n 42 \n 26 \n 25 \n 34 \n 29 \n 19 \n 34 \n 31 \n 38 \n 36 \n 7 \n 9 \n 8 \n 9 \n 9 \n 14 \n 9 \n 7 \n 12 \n 8 \n 8 \n 8 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 5 \n 10 \n 2 \n 4 \n 3 \n 4 \n 9 \n 42 \n 49 \n 59 \n 74 \n 72 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 1 \n 0 \n 1.17 \n 0.72 \n 0.76 \n 1.46 \n 0.82 \n 0.90 \n 1.08 \n 1.01 \n 0.54 \n 0.98 \n 1.00 \n 1.16 \n 1.06 \n 43 \n 27 \n 29 \n 55 \n 31 \n 34 \n 41 \n 37 \n 20 \n 37 \n 36 \n 43 \n 43 \n 2 \n 1 \n 1 \n 2 \n 2 \n 0 \n 1 \n 0 \n 0 \n 2 \n 0 \n 1 \n 2 \n 2.15 \n 1.65 \n 1.82 \n 2.25 \n 2.15 \n 1.62 \n 1.74 \n 1.91 \n 1.52 \n 1.84 \n 2.01 \n 2.03 \n 1.73 \n 79 \n 62 \n 69 \n 85 \n 81 \n 61 \n 66 \n 70 \n 56 \n 69 \n 72 \n 75 \n 70 \n 4 \n 8 \n 3 \n 5 \n 4 \n 0 \n 0 \n 2 \n 0 \n 0 \n 2 \n 3 \n 4 \n 113 \n 92 \n 112 \n 145 \n 132 \n 70 \n 129 \n 197 \n 60 \n 124 \n 58 \n 52 \n 70 \n 1 \n 6 \n 20 \n 0 \n 23 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n2. Physical Force\n1. OC\nType of Force\nLockdown/Modified Programs\nTotal Number of Overdue UOF \nReviews - 90 Days\nTotal Number of Overdue UOF \nReviews - 30 Days\nDepartmental Executive Use of Force \nReview\nPer 100 inmates\nTotal Number of Documented Force\nNumber of Voided Incident Reports\nPer 100 inmates\nNumber of Incidents\nNumber of Incidents\nSerious 115's Lost to time \nconstraints\nOther\nMurder or Attempted Murder\nWeapon\nRESISTING STAFF\nRiot/Disturbance Control\nPossession of Cell Phone/s\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0003RYHU\n&\u0005\u00036WDWXV\n5HVWULFWHG\u0003+RXVLQJ\u0003,QPDWHV\u0003,+3\n5HIXVDOV\n5HVXOWLQJ\u0003LQ\u00033ULYLOHJH\u0003*URXS\u0003\u0005&\u0005\n6WDWXV\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 157 of 176 \n Generated 9/9/2010 4:42:44 PM \n 4 \n 2 \n 1 \n 2 \n 6 \n 1 \n 0 \n 2 \n 1 \n 3 \n 6 \n 6 \n 3 \n 15 \n 7 \n 6 \n 7 \n 6 \n 11 \n 10 \n 17 \n 6 \n 13 \n 9 \n 7 \n 10 \n 0 \n 0 \n 2 \n 3 \n 0 \n 3 \n 2 \n 0 \n 2 \n 2 \n 3 \n 0 \n 4 \n 15 \n 7 \n 8 \n 10 \n 6 \n 14 \n 12 \n 17 \n 8 \n 15 \n 12 \n 7 \n 14 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 3 \n 5 \n 5 \n 11 \n 7 \n 6 \n 5 \n 8 \n 7 \n 7 \n 12 \n 12 \n 9 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 3 \n 5 \n 5 \n 11 \n 7 \n 6 \n 5 \n 8 \n 7 \n 7 \n 13 \n 13 \n 9 \n 0 \n 4 \n 2 \n 0 \n 1 \n 3 \n 3 \n 3 \n 0 \n 1 \n 0 \n 2 \n 3 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 3 \n 2 \n 2 \n 6 \n 2 \n 2 \n 2 \n 1 \n 1 \n 0 \n 2 \n 1 \n 1 \n 3 \n 5 \n 4 \n 7 \n 3 \n 5 \n 1 \n 2 \n 4 \n 0 \n 2 \n 1 \n 5 \n 0 \n 3 \n 1 \n 2 \n 1 \n 1 \n 2 \n 0 \n 2 \n 2 \n 0 \n 1 \n 12 \n 8 \n 9 \n 6 \n 12 \n 5 \n 10 \n 9 \n 2 \n 5 \n 2 \n 5 \n 3 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 8 \n 8 \n 3 \n 4 \n 3 \n 7 \n 4 \n 8 \n 3 \n 4 \n 3 \n 1 \n 0 \n 8 \n 0 \n 4 \n 5 \n 4 \n 0 \n 1 \n 5 \n 0 \n 3 \n 0 \n 1 \n 0 \n 1 \n 3 \n 1 \n 1 \n 2 \n 3 \n 8 \n 3 \n 5 \n 2 \n 1 \nCELL EXTRACTIONS\nWithout Weapon - Causing Serious \nBodily Injury (SBI)\nWith Weapon\nBATTERY ON INMATE\nAggravated Battery\nWithout Weapon\nWith Weapon\nBATTERY ON STAFF\nDrug Paraphernalia/Other\nMorphine\nCodeine\nBarbiturates\nAmphetamine\nCocaine\nHeroin\nMarijuana\nMethamphetamine\nCONTROLLED SUBSTANCE \nINVOLVED/U.A.\nIncidents\n9. Other\n8. Hydro-Force Water Restraint \nSystem\n7. Mini 14 - Warning Shots\n6. Mini 14 - Shots\n5. 37 mm/40 mm\n4. CN\n3. Baton\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 158 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 2 \n 2 \n 6 \n 5 \n 3,666 \n 3,759 \n 3,797 \n 3,780 \n 3,769 \n 3,769 \n 3,785 \n 3,656 \n 3,683 \n 3,758 \n 3,583 \n 3,686 \n 4,040 \n 14 \n 8 \n 11 \n 11 \n 4 \n 9 \n 13 \n 3 \n 9 \n 10 \n 8 \n 11 \n 8 \n 23 \n 44 \n 47 \n 43 \n 57 \n 17 \n 30 \n 19 \n 4 \n 16 \n 22 \n 12 \n 49 \n 1 \n 3 \n 0 \n 0 \n 2 \n 0 \n 2 \n 0 \n 1 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 4 \n 1 \n 1 \n 8 \n 6 \n 3 \n 3 \n 3 \n 1 \n 3 \n 4 \n 4 \n 4 \n 9 \n 10 \n 17 \n 3 \n 17 \n 9 \n 3 \n 9 \n 13 \n 5 \n 13 \n 7 \n 6 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 5 \n 4 \n 11 \n 6 \n 8 \n 6 \n 2 \n 2 \n 2 \n 4 \n 11 \n 10 \n 2 \n 5 \n 4 \n 4 \n 5 \n 4 \n 7 \n 4 \n 4 \n 5 \n 3 \n 0 \n 3 \n 0 \n 2 \n 3 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n7KDW\u0003$UH\u0003WKH\u00035HVXOW\u0003RI\u0003WKH\u0003,+3\n1XPEHU\u0003RI\u0003,Q\u0003&HOO\u00039LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u0003'LIIHUHQW\u00035DFH\f\n1XPEHU\u0003RI\u0003\u0005,Q\u0003&HOO\u0005\n9LROHQFH\u0012,QFLGHQWV\n\u000b%HWZHHQ\u0003,QPDWHV\u0003RI\u00036DPH\u00035DFH\f\nIn Cell Violence/Incidents\nTotal Number Non IHP Coded \nInmates\nTotal Number IHP Coded Inmates\nIntegrated Housing Program \n(IHP)\nMISCELLANEOUS\nContraband Cell Phone Discoveries\nTotal Number of Deaths\nUnexpected Death\nHomicide\nExpected Death\nSuicide\nAttempted Suicide\nSEXUAL MISCONDUCT\nTHREATENING STAFF\nRESISTING STAFF\nPOSSESSION OF A WEAPON\nMELEE/RIOT\nATTEMPTED ESCAPES\nESCAPES - Number of Inmates \nInvolved\nESCAPES\nCELL EXTRACTIONS (KEYHEA)\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 159 of 176 \n Generated 9/9/2010 4:42:44 PM \n 38 \n 43 \n 29 \n 30 \n 36 \n 37 \n 33 \n 52 \n 54 \n 62 \n 46 \n 29 \n 46 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 29 \n 13 \n 18 \n 22 \n 14 \n 27 \n 18 \n 28 \n 29 \n 26 \n 27 \n 59 \n 65 \n 16 \n 17 \n 10 \n 14 \n 12 \n 10 \n 7 \n 14 \n 8 \n 10 \n 12 \n 9 \n 9 \n 45 \n 44 \n 43 \n 43 \n 47 \n 43 \n 32 \n 53 \n 55 \n 52 \n 48 \n 33 \n 71 \n 1 \n 1 \n 1 \n 4 \n 2 \n 5 \n 2 \n 3 \n 4 \n 2 \n 2 \n 2 \n 4 \n 11 \n 4 \n 11 \n 17 \n 19 \n 11 \n 12 \n 10 \n 13 \n 6 \n 7 \n 11 \n 15 \n 16 \n 21 \n 14 \n 8 \n 14 \n 14 \n 10 \n 17 \n 21 \n 15 \n 16 \n 17 \n 29 \n 23 \n 17 \n 19 \n 25 \n 25 \n 25 \n 12 \n 14 \n 21 \n 34 \n 32 \n 20 \n 28 \n 8.70 \n 9.02 \n 7.95 \n 8.70 \n 8.52 \n 8.78 \n 6.68 \n 10.59 \n 17.78 \n 15.85 \n 17.15 \n 16.90 \n 17.85 \n 0 \n 1 \n 1 \n 0 \n 1 \n 2 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 4 \n 4 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 0 \n 0 \n 12 \n 1 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 5 \n 3 \n 17 \n 14 \n 4 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 3 \n 0 \n 0 \n 4 \n 171 \n 160 \n 120 \n 115 \n 153 \n 179 \n 108 \n 159 \n 156 \n 174 \n 184 \n 192 \n 72 \n 319 \n 339 \n 302 \n 329 \n 321 \n 331 \n 253 \n 387 \n 655 \n 596 \n 615 \n 624 \n 722 \n 490 \n 499 \n 422 \n 444 \n 474 \n 510 \n 361 \n 546 \n 811 \n 770 \n 799 \n 816 \n 794 \n 10 \n 10 \n 17 \n 3 \n 17 \n 9 \n 3 \n 9 \n 13 \n 5 \n 13 \n 7 \n 6 \n 10 \n 7 \n 14 \n 2 \n 4 \n 9 \n 0 \n 6 \n 5 \n 4 \n 7 \n 6 \n 4 \n 9 \n 10 \n 17 \n 3 \n 17 \n 9 \n 2 \n 8 \n 13 \n 5 \n 12 \n 7 \n 6 \n 9 \n 8 \n 16 \n 2 \n 6 \n 8 \n 0 \n 5 \n 10 \n 3 \n 8 \n 3 \n 6 \n 9 \n 8 \n 16 \n 3 \n 7 \n 8 \n 0 \n 6 \n 10 \n 4 \n 8 \n 4 \n 6 \n \nLiving Conditions\nStaff Complaints - Medical\nStaff Complaints\nCase Records\nPersonal Property\nVisiting\nMail\nCustody/Classification\nDisciplinary\nInmate Appeal Breakdown\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)\nOverdue Appeals (Monthly \nCumulative)\nOverdue Appeals (Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Appeals\nNumber of Sexual Misconduct \nReports completed (employee)\nTotal number of victims\nNumber of documented mental \nhealth referrals (inmates)\nNumber of D.A. Referrals\nTotal number of incidents (first time \nand repeat offenders)\nIndecent Exposure Incidents\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 160 of 176 \n Generated 9/9/2010 4:42:44 PM \n 313 \n 295 \n 270 \n 270 \n 297 \n 297 \n 297 \n 297 \n 297 \n 297 \n 78.01 % \n 80.41 % \n 73.97 % \n100.00 %\n100.00 %\n 77.04 % \n 77.41 % \n 86.53 % \n 90.91 % \n 91.92 % \n 94.28 % \n 94.28 % \n 95.29 % \n 454 \n 468 \n 466 \n 313 \n 295 \n 208 \n 209 \n 257 \n 270 \n 273 \n 280 \n 280 \n 283 \n 582 \n 582 \n 630 \n 313 \n 295 \n 270 \n 270 \n 297 \n 297 \n 297 \n 297 \n 297 \n 297 \n 0.00 \n 0.00 \n 6.87 \n 5.96 \n 5.67 \n 5.19 \n 6.69 \n 5.93 \n 5.09 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 21 \n 21 \n 1 \n 1 \n 1 \n 0 \n 1 \n 55 \n 64 \n 117 \n 127 \n 103 \n 101 \n 106 \n 79 \n 76 \n 57 \n 91 \n 56 \n 54 \n 55 \n 64 \n 117 \n 127 \n 103 \n 101 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 72 \n 90 \n 103 \n 103 \n 85 \n 115 \n 92 \n 0 \n 0 \n 260 \n 218 \n 209 \n 195 \n 240 \n 219 \n 206 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 332 \n 308 \n 312 \n 298 \n 325 \n 334 \n 298 \n 66 \n 90 \n 89 \n 77 \n 82 \n 104 \n 76 \n 73 \n 69 \n 95 \n 96 \n 162 \n 156 \n 55 \n 292 \n 195 \n 240 \n 219 \n 206 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 5 \n 11 \n 9 \n 6 \n 5 \n 6 \n 5 \n 7 \n 8 \n 8 \n 8 \n 17 \n 19 \n 16 \n 13 \n 10 \n 9 \n 10 \n 8 \n 9 \n 13 \n 12 \n 18 \n 16 \n 9 \n 12 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 15 \n 16 \n 18 \n 20 \n 16 \n 10 \n 16 \n 18 \n 11 \n 13 \n 10 \n 11 \n 5 \n 8 \n 2 \n 5 \n 4 \n 1 \n 2 \n 1 \n 1 \n 4 \n 8 \n 5 \n 4 \n 27 \n 37 \n 20 \n 37 \n 20 \n 16 \n 13 \n 15 \n 35 \n 42 \n 26 \n 13 \n 30 \n 8 \n 5 \n 9 \n 13 \n 11 \n 8 \n 9 \n 16 \n 14 \n 16 \n 18 \n 9 \n 17 \nInmate Quota\nAcademic Programs - Full Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nAcademic Programs - Total\nPrograms\nAppeals Per 100 Inmates\nTotal Modification Orders Issued\nOverdue Appeals (ADA)(Medical)\nOverdue Appeals - Medical Related \n(Monthly Cumulative)\nOverdue Appeals - Medical Related \n(Point-in-time)\nTotal Screen Outs\nTotal Appeals Issued a Log Number\nTotal Appeals received by the \nAppeals Office\nInmate Medical Appeals\nADA (1824's)\nMedical\nOther\nFunds\nTransfer\nRe-Entry\nWork Incentive\nSegregation Hearings\nProgram\nLegal\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 161 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 3 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 4 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 3 \n 1 \n 3 \n 65 \n 46 \n 21 \n 74 \n 24 \n 275 \n 265 \n 247 \n 217 \n 186 \n 176 \n 198 \n 250 \n 30 \n 16 \n 151 \n 141 \n 133 \n 122 \n 110 \n 102 \n 119 \n 146 \n 336 \n 73 \n 1,435 \n 1,407 \n 2,397 \n 1,048 \n 921 \n 1,879 \n 2,308 \n 1,106 \n 1,770 \n 2,375 \n 2,578 \n 2,689 \n 3,160 \n 6,649 \n 35 \n 6,684 \n 7,110 \n 8,118 \n 6,199 \n 7,193 \n 9,688 \n 10,682 \n 10,054 \n 11,795 \n 17,970 \n 19,906 \n 15,498 \n 16,079 \n 8,118 \n 8,517 \n 10,515 \n 7,247 \n 8,114 \n 11,567 \n 12,990 \n 11,159 \n 13,565 \n 20,345 \n 22,484 \n 18,186 \n 19,239 \n 5,757 \n 12,386 \n 8,176 \n 6,119 \n 6,044 \n 1,528 \n 5,705 \n 5,157 \n 7,461 \n 9,300 \n 7,638 \n 11,313 \n 12,027 \n 128 \n 126 \n 24 \n 58 \n 72 \n 82 \n 80 \n 65 \n 87 \n 132 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 100.00 %\n100.00 %\n 77.04 % \n 77.41 % \n 86.53 % \n 90.91 % \n 91.92 % \n 94.28 % \n 94.28 % \n 95.29 % \n 313 \n 295 \n 208 \n 209 \n 257 \n 270 \n 273 \n 280 \n 280 \n 283 \nAdult Basic Education (ABE) 3\nAdult Basic Education (ABE) 2\nAdult Basic Education (ABE) 1\nEnglish Language Development \n(ELD)\nNumber of Program Completions\nAcademic Programs - Outcomes \nand Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S Time Non-Education (S-Time \nCustody)\nTotal S Time Non Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal Hours S-Time\nTotal Hours X-Time\nAverage Daily Attendance\nAcademic Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Quota\nAcademic Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 162 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 108 \n 108 \n 108 \n 108 \n 108 \n 108 \n 108 \n 0 \n 0 \n 96 \n 96 \n 116 \n 162 \n 158 \n 179 \n 179 \n 158 \n 0 \n 0 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 240 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 19 \n 11 \n 33 \n 40 \n 41 \n 60 \n 55 \n 58 \n 0 \n 0 \n 0 \n 313 \n 0 \n 317 \n 366 \n 450 \n 433 \n 461 \n 466 \n 478 \n 493 \n 8.0 \n 5.2 \n 5.2 \n 5.2 \n 5.2 \n 5.2 \n 5.2 \n 5.2 \n 5.1 \n 5.1 \n 5.1 \n 170 \n 99 \n 99 \n 210 \n 210 \n 399 \n 399 \n 443 \n 423 \n 423 \n 427 \n 450 \n 580 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 3 \n 6 \n 0 \n 0 \n 0 \nVocational Programs - Full Time\nNumber of AA Degrees Earned\nNumber of Course Completions in \nTrade Schools\nCompletions\nEnrollment\nIncarcerated Individuals \nProgram (IIP)\nInmate Enrollment\nInmate Quota (PY Driven)\nBridging Programs\nStudents Enrolled\nStudent Quota\nDistance Learning Students\nStudents Enrolled\nStudent Quota\nIndependent Study Students\nInmates (Students Reading Level > \n9.0)\nInmates (Students Reading Level < \n9.0)\nAverage TABE (Overall) Level of \nInmates\nAverage Reading Level of Inmates \n(Students)\nAcademic Programs - \nProgramming Eligible Inmate \nPopulation\nNumber of Inmates on Academic \nWaiting List\nHigh School Diploma\nGED Certificate Completion\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 163 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 232 \n 204 \n 172 \n 146 \n 162 \n 142 \n 122 \n 0 \n 0 \n 0 \n 131 \n 119 \n 108 \n 95 \n 105 \n 95 \n 85 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 124 \n 696 \n 176 \n 694 \n 462 \n 884 \n 442 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 297 \n 861 \n 556 \n 1,006 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 124 \n 696 \n 176 \n 991 \n 1,323 \n 1,440 \n 1,448 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1,476 \n 2,470 \n 3,577 \n 4,189 \n 4,034 \n 4,374 \n 3,786 \n 0 \n 0 \n 0 \n 15 \n 35 \n 39 \n 36 \n 34 \n 34 \n 42 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 48.15 % \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 26 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \n 54 \nTotal Number of Component \nCompletions (Include NCCER amd \nNon-NCCER)\nStudent Achievements\nNumber of inmates on VOC Waiting \nList\nVocational Programs - \nOutcomes and Completions\nAvg. Length of Time in Assignment \n(LTA)\nAverage # Days in School (DIS)\nTotal A-Time\nTotal E-Time\nTotal S-Time Education\nTotal S-Time Non-Education (S-Time \nCustody)\nTotal S-Time Non-Education (S-Time \nMedical)\nTotal S-Time Non-Education\nTotal S-Time\nTotal X-Time\nAverage Daily Attendance\nVocational Programs - \nAttendance Tracking\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nVocational Programs - Half Time\n% of Total Capacity Enrolled\nInmate Enrollment\nInmate Capacity\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 164 of 176 \n Generated 9/9/2010 4:42:44 PM \n 4 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 16 \n 12 \n 1,765 \n 1,748 \n 1,748 \n 1,568 \n 1,568 \n 1,314 \n 1,560 \n 1,649 \n 1,699 \n 1,699 \n 1,690 \n 1,686 \n 1,670 \n 1,769 \n 1,764 \n 1,764 \n 1,584 \n 1,584 \n 1,330 \n 1,576 \n 1,665 \n 1,715 \n 1,715 \n 1,706 \n 1,702 \n 1,682 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n \nHalf Time\nFull Time\nAvailable Assignments\nInmate Work Assignments\nProgram Utilization Rate (AB900 \nBenchmark 5)\nProgram Utilization XSEA Total\nProgram Utilization X-Time\nNumber of Program Completions\nWaiting List of Potential SAP \nParticipants\n% of SAP Beds Filled\nSAP Beds Filled\nSAP Beds\nOffice of Substance Abuse and \nTreatment Services (OSATS)\nProfessional Licenses\nIndustry Certifications\nProgram Completions\nCourse Completions\nNon - NCCER's\nProgram Completion\nComponent Completion\nNational Center for \nConstruction, Education, and \nResearch (NCCER's)\nTotal Number of Industry \nCertifications (Include NCCER and \nNon-NCCER)\nTotal Number of Program \nCompletions (Include NCCER amd \nNon-NCCER)\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 165 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n 0.00 % \n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n100.00 %\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 9 \n 9 \n 10 \n 11 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 9 \n 9 \n 9 \n 10 \n 11 \n 16 \n 1,014 \n 1,201 \n 1,353 \n 1,470 \n 1,456 \n 1,705 \n 1,414 \n 1,304 \n 1,191 \n 1,131 \n 1,093 \n 1,212 \n 1,603 \n 1,044 \n 1,234 \n 1,353 \n 1,488 \n 1,462 \n 1,702 \n 1,414 \n 1,298 \n 1,181 \n 1,122 \n 1,082 \n 1,231 \n 1,617 \n 13 \n 6 \n 7 \n 6 \n 10 \n 10 \n 13 \n 17 \n 17 \n 19 \n 19 \n 18 \n 27 \n 1,057 \n 1,240 \n 1,360 \n 1,494 \n 1,472 \n 1,712 \n 1,427 \n 1,315 \n 1,198 \n 1,141 \n 1,101 \n 1,249 \n 1,644 \n100.00 %\n 25.00 % \n 43.75 % \n 62.50 % \n 50.00 % \n 50.00 % \n 50.00 % \n 93.09 % \n 96.28 % \n 96.74 % \n 99.04 % \n 99.04 % \n 99.62 % \n 96.54 % \n 93.10 % \n 95.63 % \n 96.26 % \n 98.67 % \n 98.55 % \n 99.02 % \n 96.07 % \n 96.10 % \n 97.26 % \n 97.84 % \n 98.24 % \n 99.18 % \n101.19 %\n 122 \n 77 \n 66 \n 21 \n 23 \n 13 \n 62 \n 65 \n 47 \n 37 \n 30 \n 14 \n -20 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 4 \n 7 \n 10 \n 8 \n 8 \n 8 \n 9 \n 12 \n 12 \n 11 \n 7 \n 0 \n 4 \n 4 \n 7 \n 10 \n 8 \n 8 \n 8 \n 9 \n 12 \n 12 \n 11 \n 7 \n 0 \n 1,643 \n 1,683 \n 1,691 \n 1,553 \n 1,553 \n 1,309 \n 1,506 \n 1,591 \n 1,656 \n 1,666 \n 1,665 \n 1,681 \n 1,702 \n 1,647 \n 1,687 \n 1,698 \n 1,563 \n 1,561 \n 1,317 \n 1,514 \n 1,600 \n 1,668 \n 1,678 \n 1,676 \n 1,688 \n 1,702 \n 3,205 \n 3,303 \n 3,407 \n 3,379 \n 3,363 \n 3,340 \n 3,308 \n 3,250 \n 3,300 \n 3,356 \n 3,189 \n 3,339 \n 3,650 \nNumber of Inmates Enrolled in \nCollege Courses\nCollege Programs (unfunded)\n(Vacant) PIA Lost Hours\n(Other) PIA Lost Hours\n(Industry Related) PIA Lost Hours\n(Ducats) PIA Lost Hours\n(Custody) PIA Lost Hours\nPIA Lost Hours\n% of PIA Assignments Filled\nPIA Assignments Filled\nPIA Assignments\nPrison Industry Authority\nInmates on Waiting List\nInvoluntary\nVoluntary\nInmates Unassigned\nPercentage of Filled Work \nAssignments - Half-Time\nPercent of Filled Work Assignments - \nFull Time\nPercent of Filled Work Assignments\nVacant Work Assignments\nTwo Half Time Assignments\nOne Half Time Assignment\nHalf Time\nFull Time\nInmates Assigned\nEligible Inmates\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 166 of 176 \n Generated 9/9/2010 4:42:44 PM \n 53 \n 69 \n 22 \n 0 \n 0 \n 23 \n 196 \n 89 \n 182 \n 339 \n 257 \n 216 \n 178 \n 3 \n 6 \n 4 \n 0 \n 0 \n 3 \n 12 \n 6 \n 10 \n 31 \n 21 \n 17 \n 16 \n 150 \n 45 \n 0 \n 0 \n 0 \n 250 \n 735 \n 140 \n 500 \n 260 \n 425 \n 25 \n 140 \n 20 \n 9 \n 0 \n 0 \n 0 \n 20 \n 42 \n 14 \n 40 \n 26 \n 37 \n 10 \n 28 \n 3 \n 2 \n 0 \n 0 \n 0 \n 5 \n 7 \n 4 \n 5 \n 4 \n 5 \n 1 \n 2 \n 1,470 \n 1,035 \n 2,040 \n 3,925 \n 337 \n 230 \n 5,307 \n 3,465 \n 2,520 \n 7,962 \n 8,250 \n 6,467 \n 2,275 \n 84 \n 69 \n 102 \n 157 \n 45 \n 46 \n 193 \n 154 \n 126 \n 245 \n 220 \n 199 \n 130 \n 7 \n 6 \n 8 \n 10 \n 3 \n 2 \n 11 \n 9 \n 8 \n 13 \n 15 \n 13 \n 7 \n 1,940 \n 1,452 \n 3,795 \n 5,340 \n 580 \n 937 \n 10,667 \n 2,250 \n 1,635 \n 6,900 \n 2,860 \n 6,757 \n 2,240 \n 97 \n 83 \n 138 \n 178 \n 58 \n 75 \n 251 \n 90 \n 109 \n 230 \n 143 \n 159 \n 128 \n 8 \n 7 \n 11 \n 12 \n 4 \n 5 \n 17 \n 10 \n 6 \n 12 \n 8 \n 17 \n 7 \n 4,620 \n 3,304 \n 5,950 \n 9,265 \n 917 \n 1,589 \n 18,472 \n 6,382 \n 16,374 \n 33,581 \n 20,437 \n 19,073 \n 11,775 \n 254 \n 230 \n 262 \n 335 \n 103 \n 164 \n 682 \n 347 \n 457 \n 840 \n 657 \n 584 \n 464 \n 21 \n 21 \n 23 \n 22 \n 7 \n 15 \n 47 \n 29 \n 29 \n 60 \n 49 \n 48 \n 32 \n 31 \n 21 \n 28 \n 22 \n 7 \n 15 \n 47 \n 29 \n 29 \n 20 \n 49 \n 48 \n 3 \n \nTotal Number of Attendees\nTotal Number of Meetings Held\nAll Other ILTAG's\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nVeteran's Groups\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nNarcotics Anonymous (NA)\nContact Hours\nTotal Number of Attendees\nTotal Number of Meetings Held\nAlcoholics Anonymous (AA)\nTotal Number of Contact Hours (for \nall meetings held)\nTotal Number of Attendees (for all \nmeetings held)\nTotal Number of Meetings Held\nTotal Number of ILTAG Groups\nInmate Leisure Time Activity \nGroups (ILTAG's)\nNo. of College Course Assessments\nNo. of Master Degrees\nNo. of Bachelor Degrees\nNo. of Associate Degrees\nNo. of Units/Credits Earned (total)\nCourse Completions\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 167 of 176 \n Generated 9/9/2010 4:42:44 PM \n 45 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 45 \n 45 \n 45 \n 47 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n 0.0 \n 45 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 46 \n 45 \n 45 \n 47 \n 24 \n 24 \n 23 \n 21 \n 20 \n 20 \n 16 \n 8 \n 22 \n 22 \n 20 \n 21 \n 19 \n 2 \n 3 \n 2 \n 2 \n 1 \n 3 \n 3 \n 4 \n 4 \n 4 \n 4 \n 4 \n 7 \n 3 \n 0 \n 0 \n 59 \n 58 \n 58 \n 60 \n 61 \n 64 \n 9 \n 17 \n 18 \n 14 \n 55 \n 61 \n 54 \n 108 \n 109 \n 101 \n 106 \n 105 \n 99 \n 97 \n 58 \n 55 \n 115 \n 0 \n 0 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 909 \n 903 \n 921 \n 867 \n 867 \n 870 \n 871 \n 879 \n 883 \n 884 \n 860 \n 864 \n 878 \n 964 \n 964 \n 976 \n 976 \n 977 \n 971 \n 977 \n 984 \n 982 \n 981 \n 920 \n 920 \n 994 \n 0.0 \n -6.6 \n 0.0 \n 0.0 \n 0.0 \n -5.8 \n -1.8 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 10.7 \n 964 \n 970 \n 976 \n 976 \n 977 \n 977 \n 978 \n 984 \n 982 \n 981 \n 920 \n 920 \n 983 \n 1,501 \n 1,499 \n 1,516 \n 1,463 \n 1,463 \n 1,465 \n 1,466 \n 1,469 \n 1,476 \n 1,459 \n 1,415 \n 1,418 \n 1,471 \n -6,017 \n 509,646 \n 364,957 \n 177,726 \n 411,669 \n-106,012\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n3,004,723\n2,864,259\n2,864,259\n 286,425 \n2,415,563\n2,415,563\n2,415,563\n2,415,563\n2,415,563\n2,628,632\n2,628,632\n2,628,632\n -960,249\n-17,430,945\n-17,489,367\n-16,620,315\n-15,817,839\n-16,813,237\n-13,512,147\n-13,512,147\n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n103,897,687\n103,948,837\n103,948,837\n103,948,837\n105,657,259\n105,657,259\n105,657,259\n105,657,259\n105,657,259\n109,303,477\n109,303,477\n109,303,477\n 1,060 \n 772 \n 115 \n 0 \n 0 \n 172 \n 1,763 \n 527 \n 11,719 \n 18,459 \n 8,902 \n 5,824 \n 7,120 \nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\n2WKHU\u0003&XVWRG\\\n5HPDLQLQJ\u0003&RGHV\u0003RI\u00035\u0013\u0019\u000f\u00036\u0013\u0019\u000f\n8\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nNumber of \"Other\" Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations\nBudgeted Positions\n&XVWRG\\\n&RGHV\u0003\u001c\u0019\u0019\u0015\u000f\u0003\u001c\u0019\u0018\u001c\u000f\u0003DQG\u0003\u001c\u0019\u0018\u0019\u0003RI\n5\u0013\u0019\u000f\u00036\u0013\u0019\u000f\u00038\u0013\u0019\u0003DQG\u0003(\u0013\u0019\nTotal of all personnel in filled \npositions.\nPersonnel Vacancies (Category)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 45)\nSurplus/Deficit\nAllotment\nBudget Allotment (Program 25)\nAdministration\nContact Hours\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 168 of 176 \n Generated 9/9/2010 4:42:44 PM \n 10 \n 10 \n 9 \n 10 \n 8 \n 8 \n 10 \n 10 \n 9 \n 8 \n 8 \n 8 \n 7 \n 34 \n 26 \n 26 \n 25 \n 29 \n 27 \n 28 \n 30 \n 31 \n 22 \n -3 \n -6 \n 22 \n 7 \n 7 \n 6 \n 8 \n 9 \n 9 \n 10 \n 11 \n 10 \n 20 \n 15 \n 14 \n 15 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 192 \n 192 \n 190 \n 189 \n 184 \n 186 \n 184 \n 181 \n 181 \n 173 \n 167 \n 170 \n 186 \n 233 \n 225 \n 222 \n 222 \n 222 \n 222 \n 222 \n 222 \n 222 \n 215 \n 178 \n 178 \n 222 \n 0.0 \n 2.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 233 \n 223 \n 222 \n 222 \n 222 \n 222 \n 222 \n 222 \n 222 \n 215 \n 178 \n 178 \n 222 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n -1 \n 4 \n 4 \n 4 \n 0 \n 0 \n -1 \n -1 \n -1 \n -1 \n -7 \n 1 \n 7 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 20 \n 19 \n 19 \n 19 \n 23 \n 23 \n 24 \n 24 \n 24 \n 23 \n 21 \n 21 \n 23 \n 20 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 23 \n 15 \n 22 \n 30 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -6.0 \n 0.0 \n 0.0 \n 20 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 24 \n 23 \n 21 \n 22 \n 30 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 0 \n 1 \n 2 \n 1 \n 1 \n 1 \n 2 \n 1 \n 1 \n 2 \n 1 \n 1 \n 2 \n 2 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 44 \n 43 \n 44 \n 44 \n 44 \n 43 \n 44 \n 44 \n 44 \n 42 \n 43 \n 43 \n 44 \n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nMedical Positions (16, 17, 18, \n19, 20; R, S, M, U and E)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nEducation Positions (M03, R03, \nS03, U03, E03)\nNumber of “Other” Type of Leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 169 of 176 \n Generated 9/9/2010 4:42:44 PM \n 15 \n 15 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 15 \n 0 \n 0 \n 5 \n 2 \n 2 \n 1 \n 3 \n 1 \n 5 \n 5 \n 5 \n 6 \n 4 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 6 \n 4 \n 3 \n 2 \n 4 \n 5 \n 5 \n 5 \n 6 \n 6 \n 3 \n 8 \n 10 \n 1 \n 1 \n 1 \n 3 \n 2 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 134 \n 137 \n 137 \n 138 \n 137 \n 137 \n 137 \n 137 \n 137 \n 137 \n 131 \n 126 \n 133 \n 142 \n 142 \n 142 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 134 \n 134 \n 143 \n 0.0 \n 0.0 \n -0.3 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 142 \n 142 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 143 \n 134 \n 134 \n 143 \n 2 \n 2 \n 4 \n 2 \n 4 \n 2 \n 6 \n 6 \n 10 \n 8 \n 9 \n 9 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 16 \n 17 \n 16 \n 19 \n 15 \n 18 \n 15 \n 17 \n 16 \n 16 \n 13 \n 14 \n 11 \n 1 \n 1 \n 1 \n 0 \n 1 \n 0 \n 2 \n 2 \n 0 \n 1 \n 1 \n 1 \n 5 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 189 \n 192 \n 193 \n 192 \n 194 \n 192 \n 192 \n 190 \n 193 \n 187 \n 181 \n 181 \n 194 \n 206 \n 209 \n 210 \n 210 \n 209 \n 209 \n 208 \n 208 \n 208 \n 204 \n 195 \n 196 \n 210 \n 0.0 \n -1.5 \n -0.5 \n 0.0 \n 0.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n -1.0 \n 0.0 \n 0.0 \n 206 \n 211 \n 210 \n 210 \n 209 \n 208 \n 208 \n 208 \n 208 \n 204 \n 196 \n 196 \n 210 \n 3 \n 3 \n 6 \n 3 \n 6 \n 2 \n 4 \n 9 \n 9 \n 9 \n 2 \n 3 \n 3 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \nBudgeted Positions\nManagement (M01, M06, E99, \nS02)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nTrades (12, 13, 15; R, S, U, and \nE)\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nBudgeted Positions\nSupport Staff (01, 04, 09, 10, \n11; R, S, U, and E; E97)\nNumber on other type of leave\n916 Blanket\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 170 of 176 \n Generated 9/9/2010 4:42:44 PM \n 1,403 \n 1,905 \n 1,626 \n 1,562 \n 1,890 \n 1,650 \n 1,653 \n 1,610 \n 990 \n 1,823 \n 1,641 \n 1,746 \n 1,832 \n 231 \n 157 \n 76 \n 152 \n 203 \n 235 \n 115 \n 209 \n 216 \n 279 \n 130 \n 177 \n 92 \n 5,293 \n 5,352 \n 5,350 \n 5,223 \n 4,639 \n 4,958 \n 5,081 \n 5,063 \n 5,389 \n 5,597 \n 5,362 \n 5,722 \n 5,980 \n 565 \n 421 \n 595 \n 476 \n 651 \n 482 \n 495 \n 614 \n 521 \n 571 \n 494 \n 696 \n 769 \n 194 \n 150 \n 93 \n 136 \n 138 \n 120 \n 144 \n 191 \n 287 \n 182 \n 116 \n 111 \n 108 \n 6,283 \n 6,079 \n 6,114 \n 5,987 \n 5,630 \n 5,795 \n 5,834 \n 6,076 \n 6,413 \n 6,629 \n 6,102 \n 6,705 \n 6,949 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 6 \n 5 \n 6 \n 6 \n 6 \n 6 \n 8,891 \n 9,003 \n 8,849 \n 8,561 \n 8,794 \n 8,431 \n 8,387 \n 8,251 \n 7,842 \n 9,428 \n 8,651 \n 9,199 \n 9,460 \n 1,880 \n 1,896 \n 2,229 \n 1,607 \n 1,858 \n 1,744 \n 2,652 \n 1,655 \n 2,514 \n 1,820 \n 2,002 \n 2,540 \n 1,956 \n 1,567 \n 1,309 \n 1,143 \n 1,144 \n 1,093 \n 772 \n 1,328 \n 891 \n 1,104 \n 1,060 \n 1,505 \n 1,408 \n 2,019 \n 116 \n 28 \n 70 \n 22 \n 25 \n 25 \n 52 \n 14 \n 30 \n 36 \n 28 \n 123 \n 80 \n 17,079 \n 13,180 \n 18,619 \n 10,349 \n 11,862 \n 12,701 \n 15,865 \n 13,017 \n 15,665 \n 18,248 \n 18,681 \n 20,653 \n 23,405 \n 2,581 \n 2,298 \n 1,947 \n 1,234 \n 1,361 \n 1,953 \n 4,404 \n 2,334 \n 2,632 \n 2,279 \n 2,069 \n 2,627 \n 2,141 \n 566 \n 603 \n 437 \n 263 \n 303 \n 278 \n 1,157 \n 844 \n 737 \n 487 \n 775 \n 552 \n 477 \n 20,341 \n 16,109 \n 21,073 \n 11,867 \n 13,551 \n 14,957 \n 21,478 \n 16,209 \n 19,064 \n 21,049 \n 21,553 \n 23,955 \n 26,103 \n 16 \n 13 \n 16 \n 10 \n 11 \n 12 \n 17 \n 13 \n 15 \n 16 \n 18 \n 20 \n 20 \n 23,788 \n 19,315 \n 24,445 \n 14,618 \n 16,502 \n 17,473 \n 25,458 \n 18,754 \n 22,681 \n 23,929 \n 25,059 \n 27,903 \n 30,078 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 2 \n 2 \n 0 \n 0 \n -1 \n -1 \n -1 \n -1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 13 \n 14 \n 12 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 13 \n 13 \n 13 \n 14 \n 15 \n 16 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 14 \n 15 \n 0.0 \n 1.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \n 0.0 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nSick Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal\nOver Time\nNumber on other type of leave\n916 Blanket\n902 Blanket\nTrue Vacancy Total\n918 Blanket\n920 Blanket\nFilled Budgeted Positions\nAdjusted Budgeted Total\nActivations (+) / Deactivations (-)\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 171 of 176 \n Generated 9/9/2010 4:42:44 PM \n 410 \n 371 \n 214 \n 144 \n 301 \n 519 \n 359 \n 514 \n 373 \n 352 \n 323 \n 164 \n 500 \n 37 \n 66 \n 8 \n 1 \n 30 \n 13 \n 18 \n 32 \n 88 \n 35 \n 8 \n 22 \n 0 \n 75 \n 160 \n 96 \n 65 \n 69 \n 82 \n 92 \n 88 \n 48 \n 73 \n 67 \n 90 \n 88 \n 76 \n 64 \n 40 \n 66 \n 36 \n 88 \n 104 \n 48 \n 59 \n 21 \n 40 \n 52 \n 69 \n 16 \n 8 \n 16 \n 0 \n 32 \n 0 \n 54 \n 24 \n 20 \n 8 \n 16 \n 0 \n 8 \n 204 \n 298 \n 160 \n 131 \n 167 \n 183 \n 269 \n 192 \n 215 \n 137 \n 131 \n 164 \n 165 \n 1 \n 1 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 759 \n 821 \n 651 \n 455 \n 683 \n 745 \n 745 \n 723 \n 677 \n 611 \n 525 \n 389 \n 693 \n 93 \n 16 \n 82 \n 82 \n 46 \n 60 \n 42 \n 91 \n 60 \n 135 \n 82 \n 61 \n 45 \n 361 \n 369 \n 203 \n 259 \n 360 \n 314 \n 258 \n 117 \n 55 \n 263 \n 213 \n 122 \n 330 \n 0 \n 217 \n 121 \n 0 \n 245 \n 13 \n 0 \n 32 \n 8 \n 11 \n 8 \n 0 \n 0 \n 495 \n 204 \n 232 \n 252 \n 145 \n 222 \n 169 \n 77 \n 48 \n 144 \n 87 \n 302 \n 104 \n 16 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 135 \n 69 \n 16 \n 8 \n 16 \n 0 \n 32 \n 8 \n 54 \n 16 \n 16 \n 8 \n 16 \n 0 \n 8 \n 527 \n 429 \n 369 \n 252 \n 422 \n 243 \n 223 \n 125 \n 72 \n 163 \n 111 \n 436 \n 181 \n 1 \n 1 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 980 \n 814 \n 654 \n 593 \n 828 \n 617 \n 523 \n 332 \n 187 \n 560 \n 406 \n 618 \n 556 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 11 \n 0 \n 3 \n 0 \n 2 \n 2 \n 4 \n 2 \n 0 \n 3 \n 0 \n 0 \n 0 \n 1,205 \n 1,019 \n 1,110 \n 1,013 \n 1,274 \n 985 \n 900 \n 564 \n 439 \n 976 \n 908 \n 747 \n 680 \nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nAnnual Leave\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody\nAVG Hours Per Staff\nTotal Hours\nIn-Lieu of Sick Leave\nStaff Exceeding Trigger Point\n$GYHUVH\u0003$FWLRQV\u0003IRU\u00036LFN\u0003/HDYH\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0015QG\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\n/HWWHU\u0003RI\u0003,QVWUXFWLRQ\u0003\u0010\u00036LFN\u0003/HDYH\n\u000b\u0014VW\u0003/HWWHU\u0003\f\n\u000b5\u0013\u0019\u0003DQG\u00036\u0013\u0019\u00036WDII\u00032QO\\\f\nSick Leave Management\nMedical\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 172 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 67 \n 50 \n 47 \n 58 \n 47 \n 28 \n 37 \n 6 \n 3 \n 0 \n 0 \n 2 \n 4 \n 5 \n 3 \n 1 \n 1 \n 3 \n 1 \n 0 \n 1 \n 76 \n 55 \n 48 \n 62 \n 50 \n 32 \n 43 \n 0.00 \n 0.00 \n 0.73 \n 0.72 \n 0.36 \n 0.54 \n 1.82 \n 1.10 \n 3.28 \n 1.13 \n 0.78 \n 1.76 \n 1.09 \n 0 \n 0 \n 4 \n 4 \n 2 \n 3 \n 10 \n 6 \n 18 \n 6 \n 4 \n 9 \n 6 \n 0.00 \n 0.00 \n 2.69 \n 2.74 \n 3.84 \n 2.85 \n 3.28 \n 1.19 \n 1.73 \n 1.62 \n 1.66 \n 1.76 \n 0.54 \n 0 \n 0 \n 26 \n 25 \n 35 \n 26 \n 30 \n 11 \n 16 \n 15 \n 15 \n 16 \n 5 \n 12 \n 6 \n 4 \n 24 \n 13 \n 19 \n 13 \n 6 \n 9 \n 7 \n 4 \n 9 \n 14 \n 5 \n 10 \n 5 \n 12 \n 6 \n 5 \n 3 \n 5 \n 4 \n 7 \n 6 \n 4 \n 3 \n 0 \n 2 \n 2 \n 3 \n 3 \n 3 \n 3 \n 1 \n 4 \n 6 \n 3 \n 3 \n 2 \n 2.37 \n 2.53 \n 1.81 \n 1.99 \n 0.91 \n 0.72 \n 2.36 \n 1.47 \n 1.82 \n 2.44 \n 2.15 \n 1.57 \n 1.46 \n 13 \n 14 \n 10 \n 11 \n 5 \n 4 \n 13 \n 8 \n 10 \n 13 \n 11 \n 8 \n 8 \n 5 \n 7 \n 6 \n 31 \n 14 \n 26 \n 10 \n 9 \n 7 \n 12 \n 7 \n 19 \n 22 \n 8 \n 12 \n 8 \n 7 \n 9 \n 6 \n 10 \n 3 \n 5 \n 9 \n 6 \n 12 \n 2 \n 4 \n 1 \n 1 \n 2 \n 4 \n 2 \n 9 \n 1 \n 3 \n 7 \n 1 \n 5 \n 2 \n 1.68 \n 1.80 \n 1.66 \n 1.43 \n 0.88 \n 0.88 \n 1.42 \n 1.73 \n 1.51 \n 1.51 \n 1.44 \n 1.10 \n 0.76 \n 16 \n 17 \n 16 \n 13 \n 8 \n 8 \n 13 \n 16 \n 14 \n 14 \n 13 \n 10 \n 7 \n 145 \n 152 \n 276 \n 180 \n 215 \n 43 \n 118 \n 16 \n 90 \n 123 \n 71 \n 61 \n 28 \nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of Staff off Work \ndue to FMLA\nFMLA\nOff Work Rate (Per 100 Staff)\nNon-Custody - Number of Staff off \nWork due to non-work related \nillness/injuries.\nOff Work Rate (Per 100 Staff)\nCustody - Number of Staff off Work \ndue to non-work related \nillness/injuries.\nNDI/SDI - (FMLA Moved Jan \n2010)\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nNon-Custody -- Number of Staff off \nWork due to accepted and pending \nclaims.\nClosed Claims\nNew Claims\nPending/Open Claims\nOff Work Rate (Per 100 Staff)\nCustody -- Number of Staff off Work \ndue to accepted and pending claims.\nWorkers' Compensation\nMedical\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 173 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 135 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 852 \n 0 \n 911 \n 227 \n 5 \n 56 \n 112 \n 0 \n 342 \n 0 \n 268 \n 0 \n 0 \n 789 \n 0 \n 0 \n 1,753 \n 1,542 \n 4,185 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 109 \n 48 \n 90 \n 13 \n 4 \n 131 \n 81 \n 0 \n 0 \n 17 \n 1.34 \n 0.42 \n 1.09 \n 0.72 \n 0.94 \n 0.90 \n 0.00 \n 0.64 \n 0.54 \n 0.42 \n 0.09 \n 0.11 \n 0.00 \n 0.46 \n 0.00 \n 0.93 \n 0.00 \n 0.55 \n 0.00 \n 0.00 \n 0.00 \n 3.47 \n 2.87 \n 2.16 \n 3.20 \n 2.36 \n 1.29 \n 1.83 \n 256 \n 80 \n 208 \n 136 \n 173 \n 168 \n 0 \n 226 \n 197 \n 152 \n 32 \n 40 \n 0 \n 168 \n 0 \n 40 \n 0 \n 24 \n 0 \n 0 \n 0 \n 2,860 \n 2,388 \n 2,074 \n 2,599 \n 2,071 \n 992 \n 1,407 \n 208 \n 224 \n 0 \n 0 \n 57 \n 184 \n 228 \n 239 \n 64 \n 8 \n 296 \n 24 \n 0 \n 40 \n 3,307 \n 2,716 \n 2,082 \n 2,919 \n 2,152 \n 1,176 \n 1,675 \n 3 \n 2 \n 2 \n 2 \n 2 \n 1 \n 0 \n 4 \n 2 \n 3 \n 2 \n 1 \n 0 \n 2 \n \nWork Orders\nDollar Amount ($)\nNumber of Penalties\nRegulatory Citations Cal OSHA\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nRAO Accounting Penalties ($ \nAmounts)\nMedical (Program 50) ($)\nEducation (Program 45) ($)\nInstitutions (Program 25) ($)\nAccounting Penalties ($ \nAmounts)\nMedical\nNon-Custody\nOther Custody\nCustody - Average Number of FMLA \nHours Used by Staff\nMedical\nNon-Custody\nOther Custody\nOfficers\nSergeants\nLieutenants\nCustody - Number of FMLA Hours \nUsed by Staff\nMedical\nNon-Custody\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 174 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 3 \n 1 \n 2 \n 2 \n 1 \n 6 \n 0 \n 5 \n 3 \n 4 \n 5 \n 3 \n 0 \n 0 \n 4 \n 0 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 1 \n 0 \n 1 \n 4 \n 2 \n 0 \n 2 \n 2 \n 12 \n 2 \n 7 \n 4 \n 10 \n 7 \n 3 \n 0.60 \n 0.13 \n 0.33 \n 0.62 \n 0.34 \n 0.61 \n 0.68 \n 0.89 \n 0.27 \n 0.34 \n 0.28 \n 0.78 \n 0.61 \n 9 \n 2 \n 5 \n 9 \n 5 \n 9 \n 10 \n 13 \n 4 \n 5 \n 4 \n 11 \n 9 \n 0 \n 0 \n 0 \n 0 \n 1 \n 2 \n 0 \n 0 \n 2 \n 2 \n 2 \n 0 \n 0 \n 2 \n 0 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 145 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 7 \n 0 \n 0 \n 0.13 \n 0.00 \n 0.13 \n 0.00 \n 0.07 \n 0.14 \n 0.00 \n 0.00 \n 0.14 \n 10.08 \n 0.78 \n 0.00 \n 0.00 \n 2 \n 0 \n 2 \n 0 \n 1 \n 2 \n 0 \n 0 \n 2 \n 147 \n 11 \n 0 \n 0 \n 32 % \n 35 % \n 20 % \n 30 % \n 32 % \n 28 % \n 26 % \n 22 % \n 46 % \n 32 % \n 30 % \n 57 % \n 40 % \n 0 \n 1 \n 4 \n 9 \n 3 \n 2 \n 2 \n 1 \n 3 \n 0 \n 2 \n 8 \n 9 \n 0 \n 1 \n 2 \n 7 \n 10 \n 1 \n 2 \n 1 \n 1 \n 0 \n 2 \n 0 \n 7 \n 707 \n 887 \n 691 \n 787 \n 983 \n 982 \n 1,165 \n 1,074 \n 1,181 \n 1,384 \n 910 \n 1,025 \n 1,165 \n 713 \n 679 \n 828 \n 713 \n 890 \n 878 \n 985 \n 959 \n 1,134 \n 1,317 \n 1,107 \n 1,150 \n 1,122 \n 1,307 \n 1,973 \n 1,244 \n 1,834 \n 2,078 \n 1,525 \n 1,296 \n 1,363 \n 1,377 \n 1,682 \n 2,130 \n 2,150 \n 1,800 \n 1,441 \n 2,305 \n 1,652 \n 1,797 \n 2,640 \n 1,845 \n 1,220 \n 1,373 \n 965 \n 1,584 \n 2,471 \n 1,475 \n 1,539 \n 406 \n 569 \n 503 \n 581 \n 575 \n 441 \n 508 \n 452 \n 490 \n 556 \n 435 \n 441 \n 479 \n 469 \n 545 \n 484 \n 629 \n 555 \n 441 \n 514 \n 460 \n 440 \n 541 \n 454 \n 472 \n 434 \nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nStaff Investigations\nE.E.O\nConditions of Work\nHealth & Safety\nPer 100 Staff\nTotal\nEmployee Grievances and Staff \nComplaints\n% of personnel hours spent on \npreventative maintenance\nNumber of project Work Orders \n(priority 5) completed\nNumber of project Work Orders \n(priority 5) received/submitted\nNumber of corrective Work Orders \n(priority 3 and 4) completed\nNumber of corrective Work Orders \n(priority 3 and 4) received/submitted\nNumber of preventative \nmaintenance Work Orders (priority \n2) completed\nNumber of preventative \nmaintenance Work Orders (priority \n2) received/submitted\nNumber of Emergency Work Orders \n(priority 1) completed\nNumber of Emergency Work Orders \n(priority 1) received/submitted\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 175 of 176 \n Generated 9/9/2010 4:42:44 PM \n 0 \n 1 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0.47 \n 0.13 \n 0.46 \n 0.07 \n 0.14 \n 0.14 \n 0.07 \n 0.07 \n 0.14 \n 0.27 \n 0.07 \n 0.00 \n 0.07 \n 7 \n 2 \n 7 \n 1 \n 2 \n 2 \n 1 \n 1 \n 2 \n 4 \n 1 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 4 \n 4 \n 3 \n 2 \n 5 \n 5 \n 4 \n 4 \n 3 \n 2 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 2 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 0 \n 0 \n 1 \n 1 \n 0 \n 0 \n 0 \n 0.13 \n 0.07 \n 0.13 \n 0.00 \n 0.00 \n 0.07 \n 0.00 \n 0.07 \n 0.00 \n 0.00 \n 0.14 \n 0.07 \n 0.00 \n 2 \n 1 \n 2 \n 0 \n 0 \n 1 \n 0 \n 1 \n 0 \n 0 \n 2 \n 1 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 8 \n 10 \n 0 \n 2 \n 7 \n 0 \n 0 \n 0 \n 3 \n 3 \n 0 \n 1 \n 4 \n 23 \n 10 \n 19 \n 4 \n 27 \n 27 \n 43 \n 39 \n 30 \n 35 \n 37 \n 33 \n 34 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 0 \n 1 \n 0 \n 0 \n 3 \n 1 \n 2 \n 2 \n 1 \n 6 \n 0 \n 5 \n 3 \n 5 \n 5 \n 3 \n 3 \n 2 \n 3 \n 3 \n 5 \n 5 \n 4 \n 7 \n 3 \n 4 \n 3 \n 7 \n 6 \nDismissals\nPer 100 Staff\nTotal\nAdverse Actions\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nCentral Intake Requests Approved \nfor Direct Action\nCentral Intake Requests Rejected\nCentral Intake Requests Accepted\nPer 100 Staff\nTotal Central Intake Requests\nMedical Staff Investigations\nInvestigations exceeding the Statute \nof Limitations\nInvestigations exceeding 180 \ncalendar days\nNumber of Closed Investigations\nNumber of Open Investigations\nDirect Action Requests Rejected\nDirect Action Requests Accepted\nTotal Direct Action Requests \nSubmitted\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n COMPSTAT DAI Statistical Report - 13 Month\n'DWD\u0003$QDO\\VLV\u0003\u0014\u0016\u00030RQWK\u0003DV\u0003RI\u0003\u0013\u001c\u0010\u0013\u001c\u0010\u0015\u0013\u0014\u0013\n/RFDWLRQ\u000bV\f\u001d\u0003\u0003\u0003\u0003&&,\u000f\u0003\u0003\u0003&25\u000f\u0003\u0003\u0003+'63\u000f\u0003\u0003\u0003.963\u000f\u0003\u0003\u00033%63\u000f\u0003\u0003\u00036$&\u000f\u0003\u0003\u00036963\nCOMPSTAT DAI Statistical Report - 13 Month\n Page 176 of 176 \n Generated 9/9/2010 4:42:44 PM \n 64 \n 65 \n 68 \n 65 \n 70 \n 69 \n 53 \n 60 \n 63 \n 62 \n 63 \n 61 \n 63 \n \nDMH (ASH, CSH, PSH) Actual \nPopulation\nUnique Populations\nGen. Pop. III & IV\nSVSP\nJul\nJun\nMay\nApr\nMar\nFeb\nJan\nDec\nNov\nOct\nSep\nAug\nJul\n2010\n2009\n"
} |
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"pdf_file": "AJXUPPG2S5WLMN76I434ABJTFQFTSFSO.pdf",
"text": " REAL ESTATE BOARD \n \nAGENDA \n \nThursday, May 14, 2009 - 9:00 a.m. \n2nd Floor \nDepartment of Professional and Occupational Regulation \n9960 Mayland Drive \nRichmond, Virginia 23233 \n(804) 367-8526 \n \nI. CALL TO ORDER \n \nII. PUBLIC COMMENT PERIOD ** \n III. ADMINISTRATIVE MATTERS \n \n1 Approval of Agenda \n \n2. Approval of Minutes: \n \nA. March 12, 2009, Informal Fact-Finding Conference \nB. March 19, 2009, (Licensing) Info rmal Fact-Finding Conference \nC. March 19, 2009, (Disciplinary) Informal Fact-Finding Conference \nD. March 19, 2009, (Licensing) Info rmal Fact-Finding Conference \nE. March 25, 2009, Informal Fact-Finding Conference \nF. March 26, 2009, Real Estate Board Meeting \nG. March 26, 2009, Informal Fact-Finding Conference \nH. April 1, 2009, Informal Fact-Finding Conference \nI. April 9, 2009, Informal Fact-Finding Conference \nJ. April 16, 2009, Informal Fact-Finding Conference \nK. April 16, 2009, (Recovery Fund) In formal Fact-Finding Conference \nL. April 23, 2009, Informal Fact-Finding Conference \n \nIV. FAIR HOUSING REPORTS \n \n3. Fair Housing Administrator’s Report \n \n4. Fair Housing Sub-Committee Minutes – March 26, 2009 \n \nV. CASES \n \n5. File Number 2009-0290 8 – Kathleen Farrar \nIFF by Brigil – Licensing \n6. File Number 2009-0251 8 – Steven Falkowitz \nIFF by Brigil – Licensing 2 7. File Number 2009-03 179 – Sheila Haun \nIFF by Brigil – Licensing \nAppointment – Sheila Haun, Applicant \n8. File Number 2009-02 992 – Ramon Smith \nIFF by Brigil – Licensing \n9. File Number 2009-02 991 – David McClung \nIFF by Brigil – Licensing Appointment – David McClung, Applicant \n10. File Number 2009-01231 – David Reutershan \nIFF by Oglesby – Licensing \n \n11. File Number 2008-02925 – Teresa M. Menendez v. Melinda E. Poirier \nIFF by Oglesby – Recovery Fund \n \n12. File Number 2008-0344 9 – Marie Ann Schulte \nIFF by Oglesby – Disciplinary \n \n13. File Number 2009-0185 5 – Frank M. Worrell \nPre-IFF Consent Order by Oglesby – Disciplinary \n \n 14. File Number 2009- 00093 – Linda Mather \nPost-IFF Consent Order by Oglesby – Disciplinary \n \n15. File Number 2009-00652 – Vicki Holmes \nIFF by Oglesby – Disciplinary \n 16. File Number 2008-01 319 – Meredith L. Minter \n IFF by Oglesby – Disciplinary \n17. File Number 2008-03 716 – Mondana Nicksolat \n Post-IFF Consent Order by Oglesby & Daniels – Disciplinary \n \n 18. File Number 2009-01 775 – James C. Black, Jr. \n Pre-IFF Consent Order by Johns on & Oglesby – Disciplinary \n 19. File Number 2008- 00035 – Dionetta Boone \n IFF by Johnson – Disciplinary \n 20. File Number 2008- 04305 – Dionetta Boone \n IFF by Johnson – Disciplinary \n21. File Number 2009-00 150 – Kelley W. Randolph \n Pre-IFF Consent Order by Johnson – Disciplinary \n 3 22. File Number 2009-02 201 – Charles G. Smith \nPre-IFF Consent Order by Johnson – Disciplinary \n \n23. File Number 200 9-02541 – Joseph C. Foster \nPre-IFF Consent Order by Johnson - Disciplinary \n 24. File Number 200 9-01191 – Tani R. Haggerty \n IFF by Gaeser – Disciplinary 25. File Number 2008-03 236 – Nancy G. Heflin \n IFF by Gaeser – Disciplinary 26. File Number 2009-0127 8 – Sandra R. Wilkinson \n Pre-IFF Consent Order by Taylor – Disciplinary \n 27. File Number 200 9-00797 – Gloria L. Brown \nPre-IFF Consent Order by Taylor – Disciplinary \n \n28. File Number 20 09-01454 – Darlene M. Harris \nPre-IFF Consent Order by Clarke – Disciplinary \n \n29. File Number 2009-01042 – Lo renzo Gamez \nPre-IFF Consent Order – Disciplinary \n \n30. File Number 2008- 04889 – Patricia Ford Copper \nPre-IFF Consent Order – Disciplinary \n \n31. File Number 2009- 00604 – Anne S. Overington \nPre-IFF Consent Order – Disciplinary \n \n32. File Number 2009-02077 – Keith L. Hartke \nPre-IFF Consent Order – Disciplinary \n VI. ADMINISTRATIVE ISSUES \n• NOIRA – Fair Hous ing Regulations \n• Residential Property Di sclosure Statement \n \nVII. EDUCATION \n \n• May 13, 2009, Education Committee Report \n \nVIII. OLD BUSINESS \n \nIX. NEW BUSINESS \n 4 X. ADJOURNMENT \n \nNEXT MEETING SCHEDULED FOR THURSDAY, JULY 9, 2009 \n \n** 5-minute public comment, per person, on those items not included on the agenda with the exception of any open disciplinary \nfiles. No other public comment will be accepted by the Board during the meeting. \n \nPersons desiring to participate in the meeting and requiring speci al accommodations or interpretive services should contact the \nDepartment at (804) 367-8552 at least ten days prior to the meeting so that suitable arrangements can be made for an appropriate accommodation. The Department fully co mplies with the Americans with Disabilities Act. "
} |
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] | {
"pdf_file": "JBHIRIZUQZPQ57WERXLX567KMHIZQQG7.pdf",
"text": "Standing for Veterans\n \nCongressman Rooney meets with American Legion representatives from \n \nFlorida to discuss TRICARE fees and reducing the VA claims backlog.\n \n \nAs an Army veteran and a member of the House Appropriations Subcommittee on Veterans\nAffairs, Congressman Rooney is dedicated to ensuring our service members and veterans\n 1 / 5 Standing for Veterans\nreceive the benefits they have earned and deserve. \n \nCongressman Rooney has been a tireless advocate bringing awareness to the growing number\nof troops and veterans with post-traumatic stress disorder, traumatic brain injury, depression,\nand other invisible wounds. He has worked to improve mental health services, increase funding\nfor treatment, and expand access to licensed mental health professionals for TRICARE\nbeneficiaries. He has stood firm against increases in TRICARE fees for veterans and military\nfamilies, and has worked across the aisle to combat veteran homelessness.\n \nOne of Congressman Rooney’s top priorities for improving services for America’s veterans\nreducing the disability claims backlog at the Department of Veterans Affairs (VA). Despite more\nthan four years of promises from the Obama Administration to eliminate the backlog, the\nsituation has only grown worse. The number of unprocessed claims will soon reach one million,\nand nearly all claims are still processed on paper, rather than online. Congressman Rooney\nfirmly believes this is unacceptable. He helped lead a bipartisan group of veterans in Congress\nin writing a letter to President Obama urging him to take immediate action to reduce the\nbacklog and improve VA services.\n \nCongressman Rooney firmly believes we have a moral obligation to care for those who served.\nHe will continue holding the VA accountable for providing the very best services possible for our\nreturning war fighters, their families and veterans.\n \nIf you are a veteran and you need assistance with you benefits, please contact our office or\nvisit our Veterans Services webpage by clicking \nhere\n.\n \nLatest Veterans News:\n \nApril 25, 2013 Rooney Writes Obama on VA Claims Backlog: Our Veterans Deserve Better\n \nApril 12, 2013 - Rooney Opposes TRICARE Fee Hikes\n 2 / 5 Standing for Veterans\n \nMarch 7, 2013 - Pascrell, Rooney to Chair Brain Injury Task Force\n \nFebruary 27, 2013 - Rooney, Hunter, Murphy Bill Blocks Pentagon from Ranking Drone\nMedal above Purple Heart\n \n \n All fields marked with an * are required\nE-mail Address: *\n Are you a veteran, active-duty service member or family member? \n \n Yes\n \n No\n Do you support or oppose President Obama’s proposal to hike TRICARE fees? \n \n Support\n \n Oppose\n Do you think VA is on the right track or wrong track in its efforts to reduce the disability claims backlog? \n \n Right Track\n \n 3 / 5 Standing for Veterans\n Wrong Track\n \n \n *By answering this survey, you are subscribing to my newsletter.\n \n \n \n \nHelpful links for Veterans and Families\n \nThe following information is for veterans. Please contact my office for assistance with any\nquestions or problems you may have.\n \n - How can I contact the Department of Veterans Affairs? \n - How can I get education benefits under the Montgomery GI Bill? \n - How can I get medical benefits? \n - How can I get information on suicide prevention? \n - How can I get a home loan? \n - How can I get life insurance? \n - How can I get vocational rehabilitation and employment benefits? \n - How can I get survivor benefits? \n - What drug benefits are available? \n - How can I get a copy of my military records? \n - How can I apply for a medal, award, or decoration that I earned while in the service? \n - What other services are available to me? \n \n Veterans’ facilities in and around the 17th district\n \n - Port Charlotte VA Primary Care Clinic \n 4 / 5 Standing for Veterans\n - Sarasota VA Primary Care Clinic \n - Sarasota Vet Center \n - Fort Myers OPC \n - Ft. Myers Vet Center \n - Okeechobee CBOC \n - Bay Pines 3A Southeast Regional Offices \n - Lake City VAMC NF/SGVHS Lake City FL VAMC \n - West Palm Beach VAMC West Palm Beach FL VAMC \n - Viera OPC Viera FL OPC \n - Bradenton Community-Based Outpatient Clinic Bradenton FL CBOC \n - Lakeland CBOC Lakeland FL CBOC \n - Port Charlotte Community-Based Outpatient Clinic Port Charlotte FL CBOC \n - Sebring Community-Based Outpatient Clinic Sebring FL CBOC \n \n More information and help\n \n - Where can I get more information on Federal benefits for veterans? \n - Where can I get more information on Florida benefits for veterans? \n - Where can I get help getting my veterans benefits? \n \n 5 / 5"
} |
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"pdf_file": "65UHUSAELNKVXUYGUXKY2JQLAKWINVC2.pdf",
"text": "CITY OF FARGO\nFARGODOME\nState Investment Board\nBalance Sheet\nAs of 12/31/2005\nAs of As of\n12-31-05 6-30-05\nASSETS:INVESTMENTS (AT MARKET) DOMESTIC EQUITIES $ 4,364,436 $ 3,679,529 DOMESTIC FIXED INCOME 4,126,358 3,557,205 \n INVESTED CASH (NOTE 1) 83,462 72,825 \n TOTAL INVESTMENTS 8,574,256 7,309,559 RECEIVABLES\n DIVIDEND/INTEREST RECEIVABLE 12,651 11,525 \nTOTAL ASSETS $ 8,586,907 $ 7,321,084 \nLIABILITIES:\n ACCOUNTS PAYABLE 4,960 4,708 \n TOTAL LIABILITIES 4,960 4,708 NET ASSETS AVAILABLE:\n NET ASSETS AVAILABLE BEGIN OF YEAR 7,316,376 5,863,757 CASH IN DURING YEAR (NOTE 4) 1,000,000 1,000,000 CASH OUT DURING YEAR (NOTE 5) 0 0 NET INCREASE (DECREASE) 265,571 452,619 \n NET ASSETS AVAILABLE END OF PERIOD 8,581,947 7,316,376 \nTOTAL LIABILITIES & NET ASSETS AVAILABLE $ 8,586,907 $ 7,321,084 CITY OF FARGO\nFARGODOME\nState Investment Board\nProfit and Loss Statement\nFor the Month Ended 12/31/2005\nMonth Ended\n12-31-05 Year-to-Date\nINVESTMENT INCOME INTEREST/DIVIDEND INCOME $ 21,868 $ 113,732 SECURITIES LENDING INCOME 4,111 23,041 \n25,979 136,773 \n GAIN ON SALE OF INVESTMENTS 216,604 582,727 \n LOSS ON SALE OF INVESTMENTS 48,201 319,219 \n NET GAINS (LOSSES) INVESTMENTS 168,403 263,508 INVESTMENT EXPENSES 1,580 10,056 \n SECURITIES LENDING EXPENSES 3,969 21,890 \n NET INVESTMENT INCOME 188,833 368,335 NET APPREC (DEPREC) MARKET VALUE (129,282) (104,293)\n MISCELLANEOUS INCOME/(EXPENSE) 0 1,529 \nTOTAL INVESTMENT INCOME 59,551 265,571 \nNET INCREASE (DECREASE) $ 59,551 $ 265,571 CITY OF FARGO\nFARGODOME\nNotes to Financial Statements\nDecember 31, 2005\nThe following notes to financial statements are intended to provide general descriptions of line\nitems in the financial statements.\nNOTE 1 INVESTED CASH\nCash invested in a money market demand account at the Bank of North Dakota.\nNOTE 2 DUE FROM OTHER AGENCIES\nAmounts paid in anticipation of the allocation of administrative expenses of RIO.\nNOTE 3 DUE TO OTHER AGENCIES\nAmounts owed to RIO for administrative and direct costs charged.\nNOTE 4 CASH IN DURING YEAR\nCash transferred into investment accounts at The Northern Trust during the\ncurrent fiscal year.\nNOTE 5 CASH OUT DURING YEAR\nCash transferred out of investment accounts at The Northern Trust during the\ncurrent fiscal year."
} |
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] | {
"pdf_file": "RVF6AZOJLCDEWLY2UNGVFQ4PSVEQYAUH.pdf",
"text": "Rural Housing Preservation Grants\nRural Housing Preservation Grants\n \n \nOn May 9, 2012 the U.S. Department of Agriculture Rural Development announced the\navailability of funding for the Rural Housing Preservation Grants (Catalog for Federal Domestic\nAssistance number 10.433). \nThe purpose of this program is to install or improve plumbing, provide access to individuals with\ndisabilities, weatherize and repair homes in rural communities. The grants are then distributed\nto qualified homeowners or owners of multi-family rental properties or cooperative dwellings\nwho rent to low- and very-low-income residents. USDA does not provide funding directly to\nhomeowners under this program. \nThe application deadline is June 25, 2012\n. \nEligible applicants include town or county governments, public agencies, federally recognized\nIndian Tribes, and non-profit and faith-based organizations\n. To request an application package, visit \nwww.grants.gov\n. For further information contact, Bonnie Edwards-Jackson, Finance and Loan Analyst,\nMulti-Family Housing Preservation and Direct Loan Division, Rural Housing Service, United\nStates Department of Agriculture, Stop 0781, 1400 Independence Avenue SW, Washington,\nDC, 20250-0781, \nbonnie.edwards@wdc.usda.gov\n.\n \n 1 / 1"
} |
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"pdf_file": "Z2ABHWIEHLGHKMQDUVUCEL3EH7SEXCIT.pdf",
"text": "CONGRESSMAN BACHUS: REPEAL GOVERNMENT HEALTH CARE MANDATE\nWASHINGTON (June 15)– Congressman Spencer Bachus (AL-6) today voted to repeal a\nmandate in the federal health care takeover that will require Americans to buy\ngovernment-approved health insurance. \n \n However, the measure failed on the House floor when the Democrat majority led by\nSpeaker Nancy Pelosi rejected it in a procedural vote. \n \n Congressman Bachus said, “From the beginning, I have said that this mandate is both\nunwise and unconstitutional. The federal government has no right telling Americans what kind\nof health insurance they must buy, especially when a plan requires coverage of abortion. It is\nmy intention to fight this radical change to our health care system, and I will continue to\nadvocate a reasoned approached of ‘repeal and replace’.”\n \n Bachus had earlier announced his support for a lawsuit filed by Alabama and 19 other\nstates challenging the individual mandate as unconstitutional. \n \n To view the floor statement that Congressman Bachus delivered during the House\ndebate on the health care bill, click here.\n \n \n \n 1 / 1"
} |
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"pdf_file": "LXW732IC7XIG4SH67A3LN3OF3LUOAWIV.pdf",
"text": "MEDIA ADVISORY \n9-11 Commission to Release Final Report\nin Washington, D.C., on Thursday, July 22 \nJuly 19, 2004 —The National Commission on Terrorist Attacks Upon the United States \n(also known as the 9-11 Commission) will release its final report at 11:30 a.m. on Thursday, July 22, in Washington, D.C. \nThomas H. Kean, Chair of the Commission, and Lee H. Hamilton, Vice Chair, will \npresent the report at a live, televised event at 11:30 a.m. on July 22. Opening remarks by the Chairs will be followed by a press conference with all ten Commissioners. The report will be available online on the Commission’s Web site when the presentation begins. The report will also be available for purchase in bookstores nationwide and from the Government Printing Office on Thursday. \n“For the past 20 months, the Commission has worked to fulfill its mandate, preparing for \nthe Congress, the President, and the American people an authoritative account of the terrorist attacks of September 11, 2001, and recommendations to help avert future attacks,” said Kean. “We are honored to present our findings and recommendations to the American people this week.” \n“The terrorist threat to the United States has not disappeared since September 11,” said \nHamilton. “Future attacks are expected. We hope that the President and the Congress study our recommendations with care and act on them quickly.” \nWorking press wishing to attend this event must register on the Commission’s Web site, \nwww.9-11\ncommission .gov. Only those members of the media whose attendance has been \nconfirmed in writing by the Commission will be granted entry. Information about access to the event and further press guidelines also may be found on the Commission’s Web site.\nAll media requests to interview Commissioners should be directed to Craig Brownstein at \n(202) 326-1799 or by email at requests@9-11\ncommission .gov.\nBefore July 22, press inquiries, not including interview requests, should be directed to \nAl Felzenberg, Deputy for Communications, at (202) 401-1725 or (202) 236-4878, or by email at afelzenberg@9-11\ncommission .gov.\nOn July 22 and 23, all press inquiries should be directed to (202) 326-1711. ### "
} |
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] | {
"pdf_file": "DVKZAQ3CUXGDY2H4OVKPJHXM4IDHXP4M.pdf",
"text": " PartnersPartners\nGov’s Office of Energy Mgmt and Cons.Gov’s Office of Energy Mgmt and Cons.\nSTEPP FoundationSTEPP Foundation\nTown of SnowmassTown of Snowmass\nCommunity Office for Resource EfficiencyCommunity Office for Resource Efficiency\nHoly Cross EnergyHoly Cross Energy\nAspen REMP FundAspen REMP Fund\nCanyon IndustriesCanyon Industries Power OutputPower Output\n115 115 kwkwturbineturbine\n250,000 250,000 kwhkwhannuallyannually\n$10$10--$15k annual return$15k annual return\nEnough for 40 homes year roundEnough for 40 homes year round\nKeeps half a million pounds of pollutants out Keeps half a million pounds of pollutants out \nof the air annuallyof the air annually\nA model for any ski resort with snowmaking A model for any ski resort with snowmaking \nsystemsystem\nAn onAn on --slope educational resource. slope educational resource. "
} |
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"pdf_file": "DLCK2ZINQX5GZHWTO7CREF3XKDUSMXRQ.pdf",
"text": "Published on United States Botanic Garden (http://www.usbg.gov )\nHome > Grow > Gardening Tips > Cultivating Carnivorous Plants\nCultivating Carnivorous Plants\nCarnivorous plants fascinate with how they lure, catch, kill and digest insects. There are more than 720 species of carnivorous plants, many with \nastounding adaptations to inhospitable habitats. Popular carnivorous plants by genera include Byblis (rainbow plant), Cephalotus (Australian pitcher \nplant), Darlingtonia (cobra lily), Dionaea (Venus flytrap), Drosera (sundews), Nepenthes (tropical pitcher plants), Pinguicula (butterworts), Sarracenia\n(American pitcher plants) and Utricularia (bladderworts). With this kind of variety, there is no one way to grow carnivorous plants, but here are some \ngeneral tips to get you started:\nLight. Most carnivorous plants prefer bright light, and many, such as Sarracenia spp., are best with direct sunlight. Flourescent or other cool \ntemperature grow lights can be used for indoor cultivation of smaller species. A terrarium of smaller carnivorous plants under such lights can \nmake a great starter set-up.\nHumidity . Almost all carnivorous plants require high humidity. An indoor terrarium or an outdoor bog garden in humid regions will meet this \nrequirement.\nWater. Do not use tap water or mineral water on carnivorous plants. Rainwater, melted snow or distilled water are ideal. Most carnivorous \nplants require moist to wet soil in the warmer months and less moisture in winter.\nSoils. Garden soil is not suitable for carnivorous plants. The preferred media for most are live sphagnum moss, dried long-fiber sphagnum \nmoss or a mix of about three parts peat moss to one part clean, sharp sand. Nepenthes prefer a more \"open\" mix, such as long-fiber \nsphagnum mixed with horticultural charcoal, perlite, vermiculite or other porous aggregate.\nTemperature . Temperature requirements vary with specis and some require a distinct cool dormancy period.\nFeeding. When insects are not available, a one-quarter strength organic fertilizer will benefit plants when actively growing, especieally \nNepenthes . Do not feed any with actual meat, aas they are incapable of digesting complex proteins!\nYou can find out much more about carnivorous plants through the International Carnivorous Plant Society .\nSource URL: http://www.usbg.gov/cultivating-carnivorous-plants"
} |
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"pdf_file": "BUDP7F2VA32OORAA4TZ5OYZRYYLZGMDK.pdf",
"text": "Bulletin 35 11/14/03 Page 1 of 3Department of Development and Environmental Services (DDES)\n900 Oakesdale Avenue Southwest ● Renton, Washington 98055-1219 ● 206-296-6600 ● TTY 206-296-7217\nPermits For Relocating\na BuildingDDES Customer\nInformation Bulletin #\n35\n● FREQUENTLY ASKED QUESTIONS ●\nVisit the DDES Web site at\nwww.metrokc.gov/ddes\nfor more information\nAlternative formats available upon request\nBuilding Relocation Permits For Residential and Commercial Structures\nThis bulletin outlines what is required to obtain a permit to relocate a building that will be used\nfor residential or commercial purposes. Two separate permits are needed for buildingrelocation: The first permit, a Relocation Investigation Permit, provides for inspection of thebuilding to be relocated. If the building is determined to be eligible for relocation, then thesecond permit, a Building Relocation Permit, may be obtained.\nAll building relocation permits must comply with the following State and King County codes and\nregulations:\n1) Uniform Building Code;\n2) Uniform Mechanical Code;\n3) Uniform Fire Code;\n4) King County Code [Title 21A of the King County Code (KCC)];5) King County Critical Areas Ordinance and Administrative Rules [Chapter 21A.24 of the \nKing County Code (KCC)];\n6) King County Surface Water Design Manual;\n7) King County Road Standards;\n8) Washington State Energy Code and Ventilation and Indoor Air Quality Code;9) Shoreline Management Act;10) Other King County Ordinances and Regulations; and11) Other Washington State Ordinances and Regulations.\nBuilding Relocation Investigation Permits\nIf customers are planning to relocate a building in King County, an assessment of that buildingand the prospective site for relocation is required before applying for a building permit. Thisassessment is accomplished through a Relocation Investigation Permit.\nCustomers may apply for a Relocation Investigation Permit at the Permit Center of the King\nCounty Department of Development and Environmental Services (DDES) offices in Renton,\nWashington, or at one of our satellite offices. For the locations and operating hours of satellite\noffices, call 206-296-6600. To schedule an appointment to apply for a Relocation InvestigationPermit, please call the Permit Center Appointment Desk at 206-296-6797.\nKing County DDES has created customer information bulletins to inform\nthe general public about the effect of codes and regulations on their\nprojects. These bulletins are not in tended to be complete statements of\nall laws and rules and should not be used as substitutes for them. If\nconflicts and questions arise, curr ent codes and regulations are final\nauthority. Because the codes and regulations may be revised or\namended at any time, consult King County staff to be sure you\nunderstand all requirements before beginning work. It is the applicants\nresponsibility to ensure that the project meets all requirements of\napplicable codes and re gulations. Permits For Relocating a Building Bulletin 35\nBulletin 35 11/14/03 Page 2 of 3To apply for a Relocation Investigation Permit, customers must provide the following\ninformation:\n▪The current address, Parcel Number and location of the building to be relocated;\n▪The legal description or Parcel Number of the site where the building is to be relocated;\n▪An Affidavit of Application; and\n▪A site plan of the site, showing the current location of the building.\nAn inspection report regarding the proposed building relocation will be prepared and given to\nthe project applicant.\nBuilding Relocation Permits\nIf the relocation investigation indicates that a proposed building is eligible for relocation,\ncustomers may then apply for a Building Relocation Permit. This permit will be processed andreviewed in the same way as a permit for a new residential or commercial project and will be\nsubject to any code reviews and restrictions applicable to the new site. These reviews and\nrestrictions may include SEPA, critical areas, shorelines, drainage, traffic, noise, etc.\nTo apply for a Building Relocation Permit, please call 206-296-6797 to schedule a permit\napplication appointment. When coming for an appointment, be sure to bring a copy of the\nRelocation Investigation Permit Report. In addition, customers must provide all the information\nrequired for a complete permit application. (See Bulletin 9, Obtaining a Residential Building\nPermit , for complete application requirements for single-family residential projects, and see\nBulletin 8, Commercial and Multi-family Building Permits , for complete application requirements\nfor commercial and multi-family projects.)\nThe Relocation Investigation Report requires either a Full Plans Submittal for the building, or, if\nonly minimal or no changes to the building are required, a Limited Plans Submittal. A Full PlansSubmittal for the foundation and site is required in all circumstances.\nWhat Resource Information Is Available?\nKing County Information Bulletins, Affidavit of Application Forms, and Owners Affidavit Forms\nare all available at the King CountyDDES Permit Center at the Renton office location and at\nsatellite offices. Forms are also available via the DDES Web site at www.metrokc.gov/ddes, theDDES Customer Information Line at 206-296-6600 and in the DDES Permit Center in Renton,Washington.\nIf customers have a question regarding a building relocation project that was not answered by\nthis bulletin, or if additional information is needed, please contact the Permit Center of DDES at206-296-6600. Permits For Relocating a Building Bulletin 35\nBe sure to visit our Web site at:\nwww.metrokc.gov/ddes\nBulletin 35 11/14/03 Page 3 of 3\nKing County complies with the Americans with Disabilities Act (ADA). If\nyou require an accommodation to attend a meeting (two weeks' notice)or require this information in Bra ille, audiocassette, or large print, please\ncall 206-296-6600 or TTY 206-296-7217.Other Bulletins and Telephone Numbers That May Be Helpful\nBulletin 1 Building and Development Permit Telephone Numbers\nBulletin 6 Working With Contractors\nBulletin 8 Commercial/Multi-Family Building PermitsBulletin 9 Obtaining a Residential Building PermitBulletin 10 Residential Building On or Near WaterfrontBulletin 12 The Residential Building Permit ProcessBulletin 21 Critical Area Review\nBulletin 29 Drainage Review\nBulletin 40 Financial Guarantees\nThese and other DDES bulletins are available via the department Web site at\nwww.metrokc.gov/ddes.\n206-296-6600 DDES Information\n206-296-6797 DDES Appointment Desk206-296-6630 Building Inspection Services206-296-6635 24-Hour Inspection Request Line"
} |
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"pdf_file": "BOH4KJMMRAVVCOH7QURXB6OI54ZHSFSX.pdf",
"text": "Telephone Town Hall Sign-Up - June 29th 2010 at 6:30PM PST\nWritten by Mike Honda\n \n 1 / 1"
} |
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"pdf_file": "EB46IVVKTIHXKYY42XWKUM64HY2USGTZ.pdf",
"text": "Fireworks Safety\nSince 1994, fireworks-related injuries have decreased by about one-third. In\n1998, the estimated number of people treated in U.S. hospital emergency roomsfor these injuries was 8,500, according to a recent study by staff at the U.S.Consumer Product Safety Commission (CPSC).\n1This is in contrast to an \nestimated 12,500 fireworks-related injuries in 1994.\nSpecial Study\nEach year, in addition to its year-round injury data collection, CPSC staff con-ducts a special study of fireworks injuries that occur around the Fourth of Julyholiday.\nAbout 60% to 75% of fireworks-related injuries occur during this period.\nThe special fireworks study focuses more closely on the kinds of injuries associated with fireworks and the types of fireworks involved. \nFor the 1998 study, CPSC staff examined fireworks-related injuries treated in\nNEISS hospital emergency rooms between June 23 and July 23, 1998.\n2Victims\nwere asked to identify the fireworks type from illustrations shown to them at theemergency room.\nInjury Data\nAccording to the data collected in the special study, children suffered a signifi-cant number of fireworks-related injuries. In 1998, about 40% of the fireworks-related injuries in the special study occurred to children under age 15. This issimilar to the data in CPSC’s 1997 special study, where children sustained about38% of these injuries.\nIn 1998, according to the special study, those 15 to 24 years old incurred\nabout 35% of fireworks-related injuries. The year before, this age group sufferedabout 26% of these injuries.\nMales incurred a significantly higher percentage of fireworks-related injuries\nthan females. In 1998, males suffered about 75% of the injuries. This was thesame as reported in 1997.\nAccording to the 1998 special study, the highest percentage of fireworks-relat-\ned injuries occurred to people’s hands, followed by eye injuries and head andface injuries. In 1998, hand injuries accounted for 35% of the total fireworks-re-lated injuries; eye injuries for 20%; and head and face injuries for 20%. In 1997,hand injuries comprised 35% of the fireworks-related injuries; head injuries for22%; and eye injuries for 18%.\nOver half of the injuries in 1998 involved burns. Eye injuries, however, typi-\ncally involved contusions or lacerations. This is similar to the pattern of injuriesin 1997.\nContinued on page 2CONSUMER PRODUCT\nSAFETY REVIEWSPRING 1999\nVOL. 3, NO. 4\nU.S. Consumer\nProduct Safety\nCommission\nAnn Brown, Chairman\nMary Sheila Gall, Commissioner\nThomas H. Moore, Commissioner\nIN THIS ISSUE\nFireworks .........................1\nChild Care Settings ...........3\nECOSA Conference ...........3\nCPSC Report Form............7MECAP News..................8CPSC Recalls.................10NHTSA Recalls...............11\nIncludes \nrecalls from theNational \nHighway Traffic Safety Administration 2The type of firework involved in injuries in 1998 also\nwas similar to 1997. Firecrackers were the leading causeof injury, followed by rockets and sparklers. About 15%of the injuries were related to illegal fireworks.\nFireworks Regulations\nCPSC enforces a number of fireworks regulations.These include fuse burn time limits, a 50-milligram pow-der limit on firecrackers, requirements to preventtipover and blowout of devices, and requirements forspecific cautionary labeling. Other regulations affectcertain reloadable tube aerial shell fireworks and stabili-ty requirements for multiple tube devices.\nMillennium Celebration\nTo highlight the importance of fireworks safety, CPSChas spearheaded a national public awareness campaignto promote fireworks safety during the millennium cele-brations and is an official partner of the White HouseMillennium Council. CPSC is working cooperativelywith a broad range of national, state, and local organiza-tions to disseminate information about fireworks safety.(See Millennium Fireworks Tips. ) The campaign will run\nfrom July 4, 1999 through New Year’s Day 2001.\n— Michael A. Greene, Ph.D, Directorate for Epidemiology and\nHealth Sciences\nReferences:\n11998 fireworks-related injuries: a study of fireworks-related in-\njuries treated in hospital emergency rooms between June 23 andJuly 23, 1998. Washington, DC: CPSC, 1999.\n2CPSC. National Electronic Injury Surveillance System (NEISS).\nNEISS is a statistical sample of hospitals nationwide that haveemergency departments. Each day, NEISS hospitals report to CPSC all emergency room-treated injuries associated with consumer products and related activities.Consumer Product Safety Review Spring 1999\nMillennium Fireworks Tips\nFireworks can be dangerous, causing serious burn\nand eye injuries. That’s why CPSC and its nationaland state partners strongly recommend that youleave fireworks to the professionals. \nBut if fireworks are legal where you live and you de-\ncide to set them off on your own, be sure to followthese important safety tips:\nnNever allow children to play with or ignite fire-\nworks.\nnRead and follow all warnings and instructions.\nnBe sure other people are out of range before\nlighting fireworks.\nnOnly light fireworks on a smooth, flat surface\naway from the house, dry leaves, and flammablematerials.\nnNever try to relight fireworks that have not fully\nfunctioned.\nnKeep a bucket of water handy in case of a mal-\nfunction or fire.\nFor more information about fireworks safety, visit\nCPSC’s website at: www.cpsc.gov/cpscpub/pubs/july4/4thjuly.html.\nFor More Information\nFor a complete copy of the report, 1998 Fireworks-\nRelated Injuries, please contact: \nOffice of the Secretary\nU.S. Consumer Product Safety CommissionWashington, DC 20207\n301-504-0800 \nor visit CPSC’s website at www.cpsc.gov. Consumer Product Safety Review Spring 1999\n3CPSC staff recently conducted a national study that\nidentified potential safety hazards at child care settingsacross the country. The staff found at least one of thetargeted safety hazards at two-thirds of the 220 licensedchild care settings visited.\n1\nCPSC staff looked at eight product areas with poten-\ntial safety hazards. These included: cribs, soft bedding,playground surfacing, playground surfacing mainte-nance, child safety gates, window blind cords, draw-strings in children’s clothing, and recalled children’sproducts.\nThese potential hazard areas were chosen because\nthey are a source of injury to children in and aroundtheir homes and could be equally hazardous in childcare settings. \nSome of the targeted hazards were more obvious\nones, like problems with used cribs or playground sur-facing. For example, more babies (about 40 to 50 eachyear) die in incidents involving cribs than any otherpiece of nursery equipment. Since 1990, at least ninechildren have died in crib-related incidents in child caresettings.\n2\nFor young children, playground-related injuries ac-\ncount for more visits to U.S. hospital emergency roomsthan any other child care-related injury. For example, in1997, about 60,000 children under 5 were treated inhospital emergency rooms for all playground-related in-juries. About 8,000 of these injuries occurred in childcare/school settings.\n3Other potential hazards, like soft bedding or window\nblind cords, were selected because caregivers might notbe aware of potential dangers. CPSC recently issued newguidelines on soft bedding in cribs, urging that all softbedding be removed from cribs when babies are putdown to sleep. (See Soft Bedding, page 5.)\nAbout one child a month strangles in window cover-\ning cords. These deaths have occurred both at homeand in child care settings.\nBackground Data\nCPSC has reports of at least 56 children who have diedin child care settings since 1990. At least 28 of these chil-dren died from suffocation and/or asphyxia related tonursery equipment or soft bedding.\nAbout 31,000 children, 4 years old and younger, were\ntreated in U.S. hospital emergency rooms for injuries atchild care/school settings in 1997. The playground-re-lated injuries (8,000 in 1997) were the largest singlecause.\nThere are 21 million children under age 6 in this\ncountry; almost 13 million of them are placed in non-parental child care during some portion of the day.About 29% of these children are in center-based care,including child care centers, Head Start programs, andnursery schools. The other 71% of these children are innon-center-based care, including family child care, in-home care, and care by a relative.\nECOSA Conference\nFor the first time, CPSC will co-sponsor theInternational Conference on Product Safety Researchwith the European Consumer Safety Association(ECOSA). This seventh annual international conferencewill be held on September 30 and October 1, 1999 nearWashington, DC in Bethesda, MD.\nThe 1999 conference will focus on such topics as new\nconsumer product safety issues; benefits of protectivesafety equipment; fire hazards and effective interventionstrategies; children’s hazards; and costs and benefits ofproduct safety improvements.\nThe conference is especially designed for those from\nconsumer safety agencies and injury control organiza-tions, consumer groups, national and international stan-dardization bodies, testing laboratories, consumer prod-\nuct manufacturers and designers, the research commu-nity, and trade associations.\nLast year, the ECOSA-sponsored conference was held\nin Amsterdam. ECOSA is a non-profit organization con-cerned with the safe design of consumer products.\nFor more information about the 1999 conference,\nvisit www.ecosa.org and click on “news.” Or, contact:ECOSA Secretariat, P.O. 75169, NL-1070 ADAmsterdam, The Netherlands (e-mail: R.Molenaar@con-safe.nl or S.Geldhof@consafe.nl at ECOSA or akirshn-er@cpsc.gov at CPSC).Continued on page 4Safety at Child Care Settings Consumer Product Safety Review Spring 1999\n4There are about 99,000 licensed child care centers in\nthe U.S. In addition, there are about 283,000 regulatedor licensed family child care providers. In CPSC’s staffreview of state licensing requirements for child care,however, most of the hazards included in this child carestudy were not addressed. \nFor example, although cribs are covered by both fed-\neral regulations and voluntary safety standards, manystates did not require child care centers to use cribs thatmet all of these standards. Although virtually all childcare settings use nursery equipment, like high chairsand strollers, none of the states reviewed had require-ments for addressing recalled nursery equipment.\nDescription of Study\nTo conduct the study, CPSC staff visited four differenttypes of child care settings. These included: 23Government Services Administration (GSA)-managedchild care centers (sponsored by Cabinet-level and inde-pendent federal government agencies); 77 non-profitcenters; 68 in-home settings; and 52 for-profit centers.\nThese child care settings were spread across the\ncountry. These included 73 child care settings in theeast, 76 in the west, and 71 in the central part of thecountry. Within each region, about 10% of the childcare settings were GSA-sponsored; 40% were non-profit;30% were in-home; and 20% were for-profit.\nWhere possible, participating child care settings were\nselected randomly from regional or national lists of li-censed child care providers. When such lists were notavailable, selections were made from a variety of othersources, including Internet sites and local yellow pages.\nCPSC staff used a prepared checklist to observe con-\nditions related to the eight product areas. Informationfrom the checklists was entered into a database for fur-ther analysis.Results of the Study \nMany child care settings provide safe environments foryoung children. Yet CPSC staff found the following re-sults at the child care settings included in this study.\nn8% of the child care settings had cribs that did not\nmeet current safety standards.\nn19% of the child care settings had cribs that contained\nsoft bedding.\nn24% of the child care settings did not have safe play-\nground surfacing.\nn27% of the child care settings did not keep the play-\nground surfacing well-maintained.\nn13% of the child care settings did not use child safety\ngates where necessary.\nn26% of the child care settings had loops on the win-\ndow blind cords.\nn38% of the child care settings had children wearing\nclothing with drawstrings at the neck.\nn5% of the child care settings had products that had\nbeen recalled by CPSC.\nPreventing Injuries\nCPSC staff found that most (two-thirds) of the child caresettings in the study had at least one safety hazard,putting children in these settings at risk of possible in-jury or death. CPSC staff’s review of state licensing re-quirements indicated that most of the hazards includedin the study were not adequately addressed in these re-quirements.\nTo help prevent deaths and injuries at child care set-\ntings, CPSC released a Child Care Safety Checklist for par-\nents and child care providers. (See page 6.) \nThis checklist is intended to help adults easily identi-\nfy potential safety hazards both at child care settings andat home. CPSC staff is sending the checklist to nationalchild care groups, state licensing authorities, and otherchild care providers and organizations. Many of thesegroups are reprinting and distributing the checklist.\n— Carol Cave, Directorate for Field Operations, and Debra\nSweet, Directorate for Epidemiology and Health SciencesChild Care Safety: First Lady Speaks Out\nFirst Lady Hillary Rodham Clinton joined CPSC\nChairman Ann Brown to kick off a national cam-paign to alert parents and caregivers to safety haz-ards in child care settings. On April 12, 1999, at achild care center in downtown Washington, DC, theFirst Lady and Chairman Brown announced the re-sults of the CPSC staff’s study and the availability ofthe CPSC child care safety checklist. Consumer Product Safety Review Spring 1999\n5Soft Bedding\nDr. N.J. Scheers, Project Manager of the Infant\nSuffocation Project, discusses the new recommenda-tions for soft bedding in cribs and the association ofsoft bedding with sudden infant death syndrome(SIDS).\nWhat’s new about how babies should be placed to sleep?We’re recommending that when you put a baby down\nto sleep, be sure all soft bedding — like comforters,quilts, pillows, sheepskins, and pillow-like toys — is re-moved from the crib. \nHow is this new recommendation on soft bedding different\nfrom the old one?\nFor years, we recommended that soft bedding not be\nplaced underneath babies. That’s because babies, in-cluding those correctly placed to sleep on their backs,can roll over, and the bedding can become moldedaround the infant’s face, nose, and mouth. Based onfurther research, we’re now recommending, in addi-tion, that no comforters or heavy quilts be used tocover the baby.\nOne critical recommendation that remains un-\nchanged is that babies should be put down to sleepon their backs, on a firm, tight-fitting mattress, in acrib that meets all current safety standards.\nWhat research findings led to this new recommendation on\nsoft bedding?\nResearch found that babies are at increased risk for\nSIDS if they get their heads covered by soft beddingwhile sleeping. The research showed that this can oc-cur even when they’re sleeping on their backs orsides. \nHow is soft bedding related to SIDS?\nSince the Back-to-Sleep campaign, deaths from SIDS\nhave dropped dramatically, by over 2,000 a year.However, about 3,000 babies still die of SIDS eachyear, and past studies suggest that some may have suf-focated when placed to sleep on top of soft bedding.If comforters or quilts are not recommended to keep babies\nwarm, what can be used?\nConsider putting the baby in a sleeper. If you must\nuse a blanket, use a thinone. Place the baby withhis or her feet at the footof the crib. Then tuckthe blanket around thecrib mattress, extendingthe blanket only as far asthe baby’s chest. (Seepicture at left.)\nFor what ages do these rec-\nommendations apply?\nWe recommend that all\nsoft bedding be removedfrom cribs of childrenunder 12 months. \nIs it safe to put babies down to sleep in places other than\ncribs?\nWe recommend that babies not be placed to sleep on\nsoft surfaces like waterbeds, sofas, soft mattresses, andpillows. There’s always the possibility of suffocation ifthe soft surface molds around the baby’s face.\nDo pediatricians agree with these new recommendations\non soft bedding?\nThe American Academy of Pediatrics, along with the\nNational Institute of Child Health and HumanDevelopment, joined CPSC in issuing a recent safetyalert that warned against placing babies to sleep in anenvironment with soft bedding.\n 6Consumer Product Safety Review Spring 1999\nHere are some safety tips for parents and child care\nproviders to use at child care settings. For a completeversion of the checklist (in English or Spanish), visitCPSC’s website at www.cpsc.gov or send a postcard to: \nChild Care Safety Checklist\nCPSCWashington, DC 20207\nlCRIBS\nMake sure cribs meet current national safety stan-dards and are in good condition. Look for a certifica-tion safety seal. Older cribs may not meet currentstandards. Crib slats should be no more than 2 3/8”apart, and mattresses should fit snugly.\nlSOFT BEDDING\nBe sure that no pillows, soft bedding, or comfortersare used when you put babies to sleep. Babies shouldbe put to sleep on their backs in a crib with a firm,flat mattress. \nlPLAYGROUND SURFACING\nLook for safe surfacing on outdoor playgrounds — atleast 12 inches of wood chips, mulch, sand or peagravel, or mats made of safety-tested rubber or rub-ber-like materials. References:\n1CPSC staff study of safety hazards in child care settings.\nWashington, DC: CPSC, April 1999.\n2CPSC. Medical Examiners and Coroners Alert Project (MECAP).\nMECAP is a national voluntary reporting system for 2,500 coro-ners and medical examiners nationwide to report consumer prod-uct-related deaths to CPSC. CPSC also purchases deathcertificates from 50 states and the District of Columbia for deathsrelated to consumer products.\n3CPSC. National Electronic Injury Surveillance System (NEISS).\nlPLAYGROUND MAINTENANCE\nCheck playground surfacing and equipment regularlyto make sure they are maintained in good condition. \nlSAFETY GATES\nBe sure that safety gates are used to keep childrenaway from potentially dangerous areas, especiallystairs. \nlWINDOW BLIND AND CURTAIN CORDS\nBe sure mini-blinds and venetian blinds do not havelooped cords. Check that vertical blinds, continuouslooped blinds, and drapery cords have tension or tie-down devices to hold the cords tight. \nlCLOTHING DRAWSTRINGS\nBe sure there are no drawstrings around the hoodand neck of children’s outerwear clothing. Othertypes of clothing fasteners, like snaps, zippers, orhook and loop fasteners (such as Velcro), should beused. \nlRECALLED PRODUCTS\nCheck that no recalled products are being used andthat a current list of recalled children’s products isreadily visible.For More Information\nFor a copy of the complete CPSC Staff Study of\nSafety Hazards in Child Care Settings, please visit\nCPSC’s website at www.cpsc.gov or contact: Officeof the Secretary, U.S. Consumer Product SafetyCommission, Washington, DC 20207, 301-504-0800.\nTo get all CPSC product recall information\nfaxed directly to you (or to a child care facility),send a fax with your name and fax number to 301-504-0399. To receive recall information by e-mail,send an e-mail message to listproc@cpsc.gov and,in the message area, enter: Join CPSCINFO-L.\nChild Care Safety Checklist \n 7Consumer Product Safety Review Spring 1999\nConsumer Product Incident Report\nPlease contact us about any injury or death involving consumer products. Call us toll free at: 1-800-638-8095 .\nVisit our website at www.cpsc.gov . Or, fill out the form below. Send it to: U.S. Consumer Product Safety\nCommission/EHDS, Washington, DC 20207 or fax it to: 1-800-809-0924 . We may contact you for further\ndetails. Please provide as much information as possible. Thank you.\nYOUR NAME\nYOUR ADDRESS\nCITY STATE ZIP\nYOUR TELEPHONE\nNAME OF VICTIM (IF DIFFERENT FROM ABOVE)\nADDRESS\nCITY STATE ZIP\nTELEPHONE\nDESCRIBE THE INCIDENT OR HAZARD, INCLUDING DESCRIPTION OF INJURIES\nVICTIM’S AGE SEX DATE OF INCIDENT\nDESCRIBE PRODUCT INVOLVEDPRODUCT BRAND NAME/MANUFACTURERIS PRODUCT INVOLVED STILL AVAILABLE? l YES l NO PRODUCT MODEL AND SERIAL NUMBER\nWHEN WAS THE PRODUCT PURCHASED?\nThis information is collected by authority of 15 U.S.C. 2054 and may be shared with product manufacturers, distributors, or ret ailers. \nNo names or other personal information, however, will be disclosed without explicit permission.\nU.S. Consumer Product Safety Commission\nWashington, DC 20207\nTC-49\nPLEASE DUPLICATE THIS FORM FOR FUTURE USE. CPSC FORM 175A (6/96) OMB CLEARANCE NO. 3041-0029\n 8*A male, 3, was playing in his yard\non playground climbing equipmentwhen his scarf caught on the climb-ing apparatus. His mother foundhim hanging from the playgroundequipment. The cause of death wasasphyxia. \n(Delores Jones-Butler for Carolyn\nRivercomb, M.D., Medical Examiner,Philadelphia, PA)\nA male, 5 months was found\nwedged between a mattress and themetal grating at the foot of an adultbed. The victim was taken to the hos-pital, where he died. The cause ofdeath was mechanical asphyxia. \n(D. Jones for John Jofko, M.D.,\nMedical Examiner and WilliamMassello, III, M.D., Pathologist,Western District, Roanoke, VA)\nA male, 3 months, was placed face\ndown on a soft adult pillow inside hisbassinet to sleep. He was found unre-sponsive. The cause of death was po-sitional asphyxia. \n(Manfred C. Borges, Jr., M.D.,\nAssociate Medical Examiner, CollierCounty, Naples, FL)\n*A male, 7 months, was gagging\non a piece of balloon, when his fa-ther found him. The father alsofound several balloons lying on thefloor. The cause of death was asphyx-ia and upper airway obstruction. \n(Antoinette J. Tibbs for L.\nSathyavagiswaran, M.D., ChiefMedical Examiner, Los AngelesCounty, Los Angeles, CA)\nA female, 7 months, was placed\non an adult-size bed to sleep. She wasfound wedged between the head-board and the mattress of the bed.The cause of death was positional as-phyxia. \n(Rebecca Bluedorn, RN, for\nTheodore Soboslay, M.D., Coroner,Trunbull County, Warren, OH)During the months of January, February\nand March 1999, 1,013 cases were reported to CPSC. Included here are samples of cases to illustrate the type andnature of the reported incidents.\nASPHYXIATIONS/\nSUFFOCATIONS\n*A male, 3 months, was found\ntrapped between the mattress andthe side of his crib by his mother.The child’s father attempted CPR.The cause of death was positionalasphyxia. \n(Drew Toler for Thomas Young,\nM.D., Pathologist, Jackson County,Kansas City, MO)\n*A female, 8 months, was swing-\ning in an infant swing. She caughther neck on the shoulder harnessstrap of the swing and died. Thecause of death was accidental hang-ing. \n(Mary Coffman for Jeffrey Barnard,\nM.D., Medical Examiner, DallasCounty, Dallas, TX)\nA female, 1, was placed in a\ndaybed to sleep. She was later foundby her mother with her head be-tween the metal rails of the head-board and her body resting on themetal mattress frame of the bed.The cause of death was asphyxia. \n(Terry Browne, Deputy Coroner for\nCyril H. Wecht, M.D., J.D., Coroner,Allegheny County, Pittsburgh, PA)Consumer Product Safety Review Spring 1999\nMECAP\nNEWS\nMedical Examiners and\nCoroners Alert Project andEmergency PhysiciansReporting System\nThe MECAP-EPRS Project is\ndesigned to collect timelyinformation on deaths andinjuries involving consumerproducts. Please contact uswhenever you encounter adeath or situation that youbelieve should be consideredduring a safety evaluation ofa product.\nTo report a case or ask for\ninformation about MECAP,please call our toll-freenumber, 1-800-638-8095,or our toll-free fax number, 1-800-809-0924, or send amessage via Internet toAMCDONAL@CPSC.GOV.\n*Indicates cases selected for\nCPSC follow-up investigations.Cases reported but notselected for follow-up alsoare important to CPSC. EveryMECAP report is included inCPSC’s injury data base andwill be used to assess thehazards associated withconsumer products. 9Consumer Product Safety Review Spring 1999\n*A female, 24 weeks, was seated\nin an infant swing. She slid down inthe seat and was strangled by thewaist strap. The swing’s lap belt,which went between the infant’s legs,was missing. The cause of death wasasphyxia. \n(Butch M. Houston, M.D., Medical\nExaminer, Milwaukee, WI)\nPOISONINGS\nA male, 68, used a propane\nheater to warm an unvented camp-ing trailer during cold weather. Hewas found dead by his son. Thecause of death was carbon monoxidepoisoning. \n(Michael S. Birchmeyer for Mary\nJumbelic, M.D., Chief MedicalExaminer, Onondaga County,Syracuse, NY)\n*Two males, 47 and 52, were\nfound dead in their home. The gasfurnace had malfunctioned. Thecause of death was carbon monoxidepoisoning. \n(Venus Azar, M.D., Medical\nExaminer, Richmond, VA)\nDROWNINGS\nA female, 2, went to an apartment\ncomplex playground with her 8-and10-year-old cousins. The victim disap-peared. She was found floating faceup in the apartment complex pool.The victim gained access to the poolthrough an open gate. The cause ofdeath was drowning. \n(Parviz Pakdaman, M.D., Medical\nExaminer, Santa Clara County, SanJose, CA)*A male, 39, was scuba diving. He\ncalled to his girl friend that he washaving trouble with the regulator onhis equipment and then sank belowthe water’s surface. He was recov-ered, and CPR was attempted. Thecause of death was drowning. \n(Gary G. Bluemink, M.D., Medical\nExaminer, Norfolk, VA)\nFIRES\nA male, 86, died in a house fire\ncaused by a faulty electric heater.The cause of death was burns to75% total body surface. \n(Samantha L. Wetzler, M.D.,\nMedical Examiner, Richmond, VA)\nA male, 18, died in a house fire.\nHis mother had poured gasolinefrom one container to another in autility room. A gas water heater inthe room ignited fumes from thegasoline. The cause of death wassmoke inhalation. \n(Susan Haddak for William R. Bell,\nM.D., Medical Examiner and GaryD. Cumberland, M.D., ChiefMedical Examiner, Pensacola, FL)\nA female, 55, died in a house fire\ncaused by a faulty electrical outlet.The cause of death was smoke in-halation. \n(Nancy Moore for John Butts, M.D.,\nChief Medical Examiner, ChapelHill, NC)*A male, 88, died in a house\nfire caused by a faulty heater con-trol on an electric blanket. Thecause of death was thermal burns. \n(Nancy Moore for John Butts,\nM.D., Chief Medical Examiner,Chapel Hill, NC)\nELECTROCUTIONS\nA male, 31, was installing an ice-\nmaker at a friend’s house. He washolding a water pipe in one handand using cutters with the otherhand. He cut a live 220 volt electri-cal conduit. The cause of deathwas electrocution. \n(Nancy Moore for John Butts,\nM.D., Chief Medical Examiner,Chapel Hill, NC)\nA female, 82, died while using a\nhedge trimmer. Her gold metalnecklace made contact with aloosely-connected electrical plugin the hedge trimmer. The causeof death was electrocution. \n(Eroston A. Price, M.D., Medical\nExaminer, Ft. Lauderdale, FL)\nMISCELLANEOUS\nA male, 2, hugged a 64-pound\nTV while watching his favoritecharacter on a TV show. The TVwas on a particleboard stand. TheTV fell off the stand onto thechild. The cause of death wasblunt force trauma of the head. \n(Terry Browne, Deputy Coroner\nfor Cyril H. Wecht, M.D., J.D.,Allegheny County, Pittsburgh, PA)\n— Suzanne Newman, Directorate for\nEpidemiology and Health Sciences 10Consumer Product Safety Review Spring 1999\nCPSC Recalls\nThe following product recalls were conducted by firms in cooperation with\nCPSC. For more information about recalls, visit CPSC’s website atwww.cpsc.gov. \nProduct: About 78,000 power mowers by Toro Co. The mowers\nare Lawn-Boy Silver Series, Four Cycle, walk-behind 21-inch mow-ers. The model numbers are: 10200, 10202, 10212, 10236, 10302,10307 (with serial number ranges 7900001-7999999); 10249(8900001-8999999); 10313, 10321 (7900001-8999999). The modelnumber and serial number are printed on a decal on the rightrear of the mower. Lawn-Boy dealers and mass merchant retailoutlets, including Sears, Lowe’s and Home Depot, sold thesemowers from January 1997 through November 1998 for between$280 and $400.Problem: Interference with the mower’s mulching fan can cause\nthe mower blade to crack and break off. Broken pieces of theblade can be propelled from under the mower, possibly injuringsomeone. One consumer was struck on the ankle while mowing,resulting in a bruised tendon.What to do: Stop using the mowers until they are repaired.\nContact Lawn-Boy at 1-800-444-8676 between 7:30 a.m. and 4:30\np.m. CDT M-F or at www.lawnboy.com to locate the nearest Lawn-Boy service dealer for free repair or for more information.\nProduct: About 274,000 battery-powered children’s riding vehicles\nby Peg Perego. The vehicles run on 12 volts, powered by two 6-voltbatteries and were manufactured before December 1997. Theplastic vehicles have the following model names: Corral 270,Diablo, Dragon, Gaucho, Gaucho Grande, Gaucho High Torque,Gaucho Sport, Magica, Magnum, Ranger GT, Thunderbolt,Thundercat, and Tornado. The model name and Peg Perego ap-pear on each vehicle. Peg Perego vehicles are intended for chil-dren from 3 to 8 years old and have speed ranges from 2.5 to 5mph. Toy stores and retail catalogs sold the vehicles nationwidefrom 1990 through 1997 for about $100 to $550. Vehicles madesince 1998 and 6-volt, single battery vehicles are not recalled.Problem: The pedals can stick and electrical components can\noverheat, presenting fire and injury hazards to children. Therehave been about 320 reports of electrical components overheat-ing or pedals sticking. Thirty fires have been reported, resultingin one child suffering second-degree burns to his hand and atleast $55,000 in property damage. One child suffered a concus-sion and six children were bruised when accelerator pedals stuckand the vehicles hit trees, fences, walls, or parked automobiles.What to do: Remove the vehicles’ batteries right away and don’t\nlet children use them until repairs are made. Contact Peg Peregoat 1-888-893-7903 between 8 a.m. and 8 p.m. EST M-F or atwww.perego.com/recall1.htm to order a free repair kit that canbe installed by consumers or by an authorized Peg Perego servicecenter. Service centers will not have repair kits. \nProduct: About 1,000,000 carbon monoxide alarms distributed by\nKidde Safety, including 650,000 Nighthawks and 350,000Lifesavers. The Nighthawk models were made between November8, 1998 and March 9, 1999. The manufacturing date is on theback of the unit as year, month, day. “NIGHTHAWK” and“Carbon Monoxide Alarm” are on the front of the unit. If“Carbon Monoxide Detector” is on the front, the unit is not part\nof the recall. The Lifesaver units being recalled are models 9CO-1and 9CO-1C made between June 1, 1997 and January 31, 1998.The manufacturing date is on the back of the unit as the first sixnumbers in the serial number, located above the UPC code. Thedate is written as day, month, year. “LIFESAVER” and “CarbonMonoxide Alarm” are on the front of the unit. Hardware andmass merchandise stores nationwide sold the alarms beginning in1998 for about $20 to $50.Problem: The Lifesaver models could alarm late or not at all, and\nthe Nighthawk models could alarm late. The alarms are used todetect carbon monoxide (CO) leaking from fuel burning appli-ances. When they don’t work, consumers can be unknowingly ex-posed to hazardous levels of CO and suffer injury or death. KiddeSafety and CPSC are not aware of any injuries involving theseproducts.What to do: Visit the Kidde Safety recall web site at\nwww.nhawk.com and follow the instructions or call 1-888-543-\n3346 between 8 a.m. and 8 p.m. EST M-S for help identifying re-\ncalled units and to get a postage-paid envelope to return thealarm. Lifesaver models will be repaired; Nighthawk models willbe tested, and repaired if needed. All returned alarms will be re-certified to UL-2034. Kidde says it will return consumers’ alarmswithin 30 days.\nProduct: About 424,000 GE Spacemaker radio cassette players dis-\ntributed by Thomson Consumer Electronics. The model numberis 7-4285 and is located on the top of the unit. It may or may notbe followed by a letter. The player is designed for under-the-cabi-net use. Each has an AM/FM stereo cassette player, a light, and aprogrammable appliance outlet with timer. The outlet is on theleft side of the unit. “GE Spacemaker...AM/FM Stereo CassettePlayer...Programmable Appliance Outlet” is on the front of theunit. Department, electronic and discount stores nationwide soldthe radio cassette players from January 1992 through December1995 for about $50 to $80.Problem: The player has an appliance outlet that can overheat,\npresenting a fire hazard. Thomson Consumer Electronics has re-ceived three reports of the appliance outlets overheating andcatching fire, causing minor property damage. No injuries werereported.What to do: Unplug the units and call Thomson at 1-800-464-7022\nanytime for instructions and a free replacement unit or contactThomson at www.home-electronics.net/recall or write ThomsonConsumer Electronics, Spacemaker Recall, INH 950, P.O. Box6127, Indianapolis, IN 46206-6127\n— Marc Schoem and Terri Rogers, Office of Compliance\n 11Consumer Product Safety Review Spring 1999\nNHTSA Recalls\nThe National Highway Traffic Safety Administration (NHTSA) is the gov-\nernment agency responsible for improving safety on our Nation’s highways.As part of its efforts to achieve this goal, NHTSA is authorized to ordermanufacturers to recall and repair vehicles or items of motor vehicle equip-ment (including air bags, tires, and child safety seats).\nThe following safety recall campaigns are being conducted in coopera-\ntion with NHTSA. For more information about NHTSA recall activities,you can access NHTSA on the Internet at http://www.nhtsa.dot.gov or bycalling the NHTSA Auto Safety Hotline at 1-888-DASH-2-DOT (1-888-327-4236).\nAmTran Corporation\nAmTran is recalling 8,217 1993-1999 Genesis, FE, 1996-1999 RE,\n1997-1999 Conventional, and 1993-1997 Volunteer school buses\nequipped with flip seats at the emergency exits. The seat cushionhinge on the combination flip seat is located in such a manner thatit is within easy reach of the passenger sitting in the seat located be-hind the combo flip seat. The hinges on the combo flip seat canpinch or sever fingers, resulting in personal injury. [NHTSA RecallNo. 99V061/ AmTran Recall No. 99-303]\nBayerische Motoren Werke\nBMW is recalling 32,500 1999 BMW 323i and 328i vehicles built\nwith a side air bag system consisting of door-mounted thorax airbags (rear door air bags are optional), a Head Protection System(HPS) for front occupants, a central electronic sensor and diagnos-tic system, left and right satellite impact sensors, and associatedwiring, manufactured from June 1998 through March 1999. Thissystem is unduly sensitive to certain non-crash impacts, such as con-tacting large potholes or curbs at substantial speed. This couldcause the side air bag and HPS to deploy without an actual sidecrash. Owners who do not receive the free remedy within a reason-able time should contact BMW at 1-800-831-1117. [NHTSA RecallNo. 99V063]\nDaimlerChrysler \nChrysler is recalling 263,000 1995-1997 Dodge Ram van and wagon\nmodel vehicles manufactured from August 1994 through August1997. If water/road salt gets on the interior floor of the vehicle inthe proximity of the air bag electronic control module (AECM),the AECM can corrode. The resulting corrosion can cause the dri-ver side air bag to deploy inadvertently. Deployment of the air bagwithout warning could cause a driver to lose vehicle control, in-creasing the risk of a crash and personal injury. Owners who donot receive the free remedy within a reasonable time should con-tact Chrysler at 1-800-992-1997. [NHTSA Recall No.99V023/Chrysler Recall No. 815]\nFord Motor Company \nFord is recalling 757,000 1992-1997 Ford Aerostar Mini Vans man-\nufactured from August 1991 through August 1997. These vehicleswere produced with a higher than specified electrical load throughthe accessory power feed circuit that connects to the A2 (accesso-ry) terminal within the ignition switch. As a result, during startup,electrical arcing of the A2 terminal to the terminal bridge couldpotentially cause pitting of the bridge. This condition, over time,could create a short circuit and allow current to flow through theground wiring, causing overheating and the potential for a vehiclefire. Owners who do not receive the free remedy within a reason-able time should contact Ford at 1-800-392-3673. [NHTSA RecallNo. 99V029/Ford Recall No. 99S02]\nFord will also recall 895,000 certain 1997-1999 RHD Explorer\nequipped with 4.0L OHV/SOHC engines and speed control builtfrom May 29, 1996 through March 4, 1999; 1998-1999\nExplorer/Mountaineers equipped with 4.0L OHV/SOHC or 5.0L\nengines or 1998-1999 Rangers equipped with 2.5L, 3.0L FFV/EFI\nor 4.0L engines and speed control built from January 5, 1998through March 4, 1999; 1998-1999 Mustangs equipped with 3.8L,\n4.6L 2-valve or 4-valve engines and speed control built from March2, 1998 through March 4, 1999; 1999 F250/F350/F450/F550 (over\n8,500 lbs.) trucks equipped with 5.4L or 6.8L engines and speedcontrol built from March 2, 1998 through March 4, 1999; and1999 F-53 stripped chassis equipped with 5.4L or 6.8L engines and\nspeed control built from March 2, 1998 through March 4, 1999.The speed control cable can interfere with the speed control servopulley and not allow the throttle to return to idle when disengag-ing the speed control. If the speed control is used and this condi-tion is present, a stuck throttle could result, increasing thepotential for a crash. Owners who do not receive the free remedywithin a reasonable time should contact Ford at 1-800-392-3673.[NHTSA Recall No. 99V062/Ford Recall No. 99S09]\nHarley-Davidson Motor Company\nHarley-Davidson is recalling 14,211 1999 FLHT, FLHTC, FL-\nHTCUI, FLHTCI, FLHTPI, FLTR, FLTRI, FLHR, FLHPI,FLHP, FLHRCI, FXDL, FXDWG, FXDS CONV, FXD, and FXDXmotorcycles manufactured from February 1998 through January1999. The engine cam bolt can lose its clamp load and/or break.This condition can cause the engine to quit running with or withoutprior warning. In some instances, the engine could run erraticallybefore quitting. Owners who do not receive the free remedy within areasonable time should contact Harley-Davidson at 1-414-342-4680.[NHTSA Recall No. 99V003/Harley-Davidson Recall No. 095]\nGeneral Motors Corporation\nGM is recalling 2,090 1996-1998 Chevrolet Astro and GMC Safari\nminivans equipped with integrated child seats and manufactured\nfrom May 1996 through September 1997. Some of these vehiclesmay be missing a seat belt retractor clutch spring and/or pawlspring in the child seat. If the clutch spring was missing, the seatbelt would lock in the retracted position and could not be used. Ifthe pawl spring was missing, the seat belt restraint would continu-ally play out and not lock. These conditions could increase the oc-cupant’s risk of injury in the event of a vehicle crash. Dealers willinspect the seat belts on the child seats, and if necessary, replacethe child seat. Owners who do not receive the free remedy withina reasonable time should contact Chevrolet at 1-800-222-1020 orGMC at 1-800-462-8782. [NHTSA Recall No. 99V009/GM RecallNo. 98071]GM is also recalling 988,587 1994 Chevrolet C10, C20, C30,\nC3500, Suburban, GMC C15, C25, C35, C3500, and Suburban ve-hicles manufactured from March 1993 through September 1994.\nThese vehicles were built with the polarity of the wiring for thebrake switch reversed from what was specified on the switch draw-ing. With the reversed polarity, the contacts in the brake switchcan wear out prematurely. The brake switch will perform normal-ly until the brake switch contacts wear out, resulting in loss of thebrake lamps without any warning to the driver. This would fail towarn a following driver that the vehicle is braking and could leadto a crash. Owners who do not receive the free remedy within areasonable time should contact Chevrolet at 1-800-222-1020 orGMC at 1-800-462-8782. [NHTSA Recall No. 99V025/GM RecallNo. 98065] United States Government\nInformation\nOrder Processing Code: *5822\nCredit card orders are welcome!\nFax your orders (202) 512-2250Phone your orders (202) 512-1800\nlYES, please send ____ subscriptions to:\nConsumer Product Safety Review (SAFRE) at $10.00 a\nyear ($12.50 foreign).\nThe total cost of my order is $ ______________.\nPrice includes regular shipping & handling and is subject to change.\nCompany or personal name (Please print or type)\nAdditional address/attention line\nStreet address\nCity, State, Zip code\nDaytime phone including area code\nPuchase order number (optional)Don’t miss a single issue of the quarterly Consumer Product Safety Review . \nComplete the subscription form below or visit CPSC’s web site at http://www.cpsc.gov.\nFor privacy protection, check box below:\nlDo not make my name available to other mailers\nCheck method of payment:\nlCheck payable to: Superintendent of Documents\nlGPO Deposit Account lllllll–l\nlVISA lMastercard\nllllllllllllllllllll\nExpiration date llll\nAuthorizing signature 5/96\nMail to: \nSuperintendent of Documents P.O. Box 371954 Pittsburgh, PA 15250-7954\nImportant: Please include this completed order form with\nyour remittance. \nThank you for your order!\nConsumer Product Safety Review is published quarterly by the U.S.\nConsumer Product Safety Commission, Washington, DC 20207. For subscription inquiries, contact:Superintendent of Documents (see above). For editorial correspondence, contact:Nancy Sachs, CPSC, nsachs@cpsc.gov Phone: 301-504-0554/Fax: 301-504-0407. For marketing inquiries, contact:Lynn Barclay, CPSC, lbarclay@cpsc.govLola Springer, CPSC Phone: 301-504-0106/Fax: 301-713-0047.To report consumer product-related injuries or for information on prod-\nuct safety, including recalls, contact CPSC by:Toll-free Hotline: 1-800-638-2772\nWorld Wide Web: http://www.cpsc.gov\nInternet Gopher: cpsc.gov\nE-mail address: info@cpsc.gov\nFax-on-demand service: call 301-504-0051 from the handset of a fax \nmachineTTY for hearing and speech-impaired: 1-800-638-8270$\nU.S. CONSUMER PRODUCT SAFETY COMMISSION\nWASHINGTON, D.C. 20207\nOFFICIAL BUSINESS\nPENALTY FOR PRIVATE USE, $300\nAn Equal Opportunity EmployerComments?\nPlease\ncontact us!"
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"pdf_file": "I6S22V76FRG6WXENYBFTYLUPZEYTE7CE.pdf",
"text": "Attention FDA\n~450~~y‘%~h;~~ight tosignaItcametomyattention thattheFDAisbeingaskedtotaeaa\nmedicalwaiverbeforepurchasing ahearingaid.InsteadIwouldbeforcedtohave\namedicalexamorhearingtest.Here’smyviewsand/orexperiences onseveral\nrelatedquestions?\n1.ShouldIbeforcedtohaveamedicalexamand/orhearingtestbeforepurchasing\nahearingaid?Ifso,shouldtheFDApayfortheexam?\n2.Somepeoplearephysically unabletodrivetoadoctororhearingspecialist, or\nhavehadbadexperiences theydon’twanttorepeat.Forinstance .,:.\nJ/G%V-&+\n~&d;:y7./@%i&~. #-z$=-z?)G’%9&%%#7+\nAd\nmP~tqL\n3.ShouldtheFDAtakeawaymyConstitutional Right,affi-rned bytheSupreme\nCourt,todecideformyselfmymedicalexamsandtreatment?\n4.ShouldIbeallowedtopurchase hearingaidsbymailasIchoose?\nJf4.4?,\n(-- .\n----!\n... ..II.-\n....,..“.\n❑NEWADDRESS-.-.’\nEXCEL Hearing Solutions\n105NFirstSt,Dept.B11\nPOBOX586\nDeKalb. IL60115-0586\nMARZ12008\nltllllllllllllllllllllllllllIlIllllllllllIlllllllllllll!'l'lll\n....-"
} |
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] | {
"pdf_file": "SSC5AFOSRRYRFIB7FNROD3UUH2WQL5DV.pdf",
"text": " \nPage 1 of 1 164.355 Repealed, 1988. \nCatchline at repeal: Agriculture and mechanic arts departments at Kentucky State \nUniversity -- Feder al fund. \nHistory: Repealed 1988 Ky. Acts ch. 257, sec. 7, effective July 15, 1988. -- Created \n1952 Ky. Acts ch. 41, sec. 9. "
} |
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"pdf_file": "YBADYKBNS5RN7M3CAMP75XV6Y2DQH2U6.pdf",
"text": "Virginia Quality \nImprovement Program (QIP)\nPresentation to:\nThe Joint Commission on Health Care\nTerry Smith\nDivision DirectorDivision of Long-Term Care Department of Medical Assistance ServicesOctober 17, 2007\n2Presentation Outline\nBackground \nCivil Money Penalty (CMP) Funds\nQIP Advisory Committee\nCommittee Discussions \nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion 3Background\nHouse Bill 2290 of the Virginia General Assembly required \nthe Director of DMAS to:\n¾Establish a Nursing Facility (NF) Quality \nImprovement Program; and,\n¾Provide a strategic plan and progress report to the \nGovernor, Chairmen of the House Committees on \nHealth, Welfare and Institutions, and Appropriations; the Senate Committees on \nEducation and Health, and Finance; and the Joint \nCommission on Health Care by October 1, 2007.\n4Presentation Outline\nBackground \nCivil Money Pena lty (QIP) Funds \nQIP Advisory Committee\nCommittee Discussions \nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion 5Civil Money Penalty (CMP) Funds \nFederal and State law dictate certain quality \nstandards for NFs that are enforced through \nperiodic surveys conducted by the Virginia Department of Health and the Centers for Medicare and Medicaid Services (CMS).\nSeveral remedies exist to address quality issues raised during the survey process including imposition of civil money penalties for NF out of compliance.\n6Civil Money Penalty (CMP) Funds \nCMS gives states broad latitude in using \nCMP funds.\nNationally, states use CMP funds for:\n1) survey and certification activities, such as \ntemporary management, relocation, or consulting; and, \n2) special projects.\nNotes : Annual unduplicated enrollment in the Virginia Medicaid program 7Civil Money Penalty (CMP) Funds\nCMP funds are collected when quality \ndeficiencies are discovered during \nperiodic on-site surveys.\nVDH conducts the on-site surveys and assesses the fines.\nThe amount of a fine assessed depends \nupon three deficiency categories.\n8Civil Money Penalty (CMP) Funds\nCategory 1 Deficiency - typically remedied by a \nplan of correction, state monitoring, and/or \ndirected in-service training.\nCategory 2 Deficiency – resolution includes \ndenial of payment by CMS for new admissions \nfor all residents, and/or CMPs of $50 to $3,000 \nper day; or, a single instance of $1,000 to \n$10,000 9Civil Money Penalty (CMP) Funds\nCategory 3 Deficiencies (most serious)\nDeficiencies in Category 3 directly affect \nresident behavior, nursing practices, quality of life, and quality of care. Remedies involve temporary management or termination of the provider agreement.\n10Presentation Outline\nBackground \nCivil Money Penalty (CMP) Funds\nQIP Advisory Committee\nCommittee Discussions\nA Culture of Caring and Better Jobs Better Care\nThe Strategic Plan\nConclusion 11QIP Advisory Committee\nThe Alzheimer’s Association \nState Long-Term Care Ombudsman \nVirginia Association for Home Care and Hospice\nVirginia Coalition for the Aging\nVirginia Health Care Association \nVirginia Association of Non-Profit Homes for the \nAging\nState Agencies (VDA, VDH, DMHMRSAS, VDSS, Health Professions, DMAS)\nOther advocates and stakeholders\n12Presentation Outline\nBackground \nCivil Money Penalty (CMP) Funds\nQIP Advisory Committee\nCommittee Discussions\nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion 13Committee Discussions\nQIP programs were researched in other \nstates and considered for replication in Virginia\nAreas of committee discussions included: \n1) health care worker shortage and high rates \nof turnover; 2) recruitment and retention of direct care staff; 3) consumer satisfaction; 4) clinical outcomes; 5) quality of life for residents.\n14Committee Discussions\nSummary of Committee Discussions:\nFor the foreseeable future, the need to attract \nand retain an adequate and stable number of well-qualified and motivated direct care \nworkers will continue to be a shared\nconcern \nof employers, employees, consumers, families, and public payors . 15Committee Discussions\nQuality Improvement Programs in other \nstates were reviewed by the committee.\nEvaluation of programs focused primarily on 1) improving efficiency and \nquality of resident se rvices, and 2) ability \nto enhance nursing staff’s ability to \nperform their jobs with knowledge and \nrespect. \n16Committee Discussions\nSummary\nBased upon discussions and review of \nexisting QIPs, the committee endorsed building on voluntary models\nthat would \nrefocus facility culture, operations, and \noutcomes without increasing costs. 17Presentation Outline\nBackground \nCivil Money Penalty Funds (CMP) Funds\nQIP Advisory Committee\nCommittee Discussions\nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion\n18A Culture of Caring\nNothing has greater impact on the quality of care \nthan having adequate numbers of well trained \nand motivated staff to provide care for residents. \nSuccessful models have in common certain \nbasic philosophies and principles and \noperational methods that, if implemented, would lead to significant improvements in long-term care quality. 19A Culture of Caring\nNorth Carolina’s Program, Better Jobs \nBetter Care , a voluntary program builds a \nculture of caring within nursing facilities and is a proven model for quality care.\nOf all the programs reviewed, Better Jobs \nBetter Care of North Carolina seemed to \nbest match the committee’s vision for enhancing the lives of Virginia’s nursing facility residents.\n20Better Jobs Better Care\nBetter Jobs Better Care began as a pilot \nprogram limited to 60 providers.\nNorth Carolina expanded the successful pilot \nprogram statewide with the intent of making it \na meaningful and voluntary “raise-the-bar”\nprogram pertaining to nurse recruitment and \nretention in long-term care. 21Better Jobs Better Care\nProgram’s 4 Domains:\nSupportive Workplaces (peer \nmonitoring, coaching supervision, supportive management)\nBalanced Workloads\nTraining\nCareer Opportunities\n22Better Jobs Better Care\nParticipating NFs:\nAttend an orientation meeting\nWork toward implementing the program \nrequirements with the expectation of submitting an application to become a designated facility, which will be publicized as a positive achievement for the NF\nProvide feedback as requested to program administration 23Better Jobs Better Care\nA key component is a special two year \nlicensure designation, “ New Organization \nVision Aware” (NOVA), using a statewide, \nuniform set of criteria and expectations . \nProviders voluntarily submit evidence for \nconsideration - On-site visits and desk reviews are conducted.\nEligibility for enhanced funding or \nreimbursement may follow NOVA \ndesignation. \n24Better Jobs Better Care\nBENEFITS TO WORKERS – Improved job \nsatisfaction, workplace environment, \ncommunication and professional growth\nBENEFITS TO PROVIDERS – Voluntary nature \nof program, retention of quality direct care \nstaff, availability of special licensure\nBENEFITS TO CONSUMERS – More stable, \nqualified direct care staff supporting the \nphilosophy of “culture of caring” 25Presentation Outline\nBackground \nCivil Money Penalty (CMP) Funds\nQIP Advisory Committee\nCommittee Discussions\nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion\n26The Strategic Plan\nThe Mission\nThe Virginia Quality Improvement Program \nAdvisory Committee seeks to ensure an adequate supply of nursing staff in Virginia’s \nNFs through innovative recruitment and \nretention practices to meet the current and future need for care of one of the Commonwealth’s most vulnerable populations. 27The Strategic Plan\nGoal One\nPromote culture change in NFs by \nencouraging NFs to adopt proven operational practices and innovative strategies that \nstrengthen the performance of nursing staff \nand improve the quality of care based on the “Better Jobs Better Care” demonstration project.\n28The Strategic Plan\nGoal One, Objective One\nImprove the quality of Virginia’s NFs by \nexamining the potential use of CMP funds to develop a voluntary incentive-\ndriven program to promote “culture \nchange.” 29The Strategic Plan\nGoal One, Objective Two\nDevelop and maintain online resources \noffering technical assistance to NFs on nursing recruitment and retention efforts. \nInclude information on staff career \nadvancement, mentoring, and trends.\n30The Strategic Plan\nGoal Two\nUsing the “Better Jobs Better Care” model, \ndirect a portion of CMP funds specifically towards recruitment and retention efforts of \nnursing staff in NFs, particularly of nursing \nassistants, that would provide positive inducements for NFs to voluntarily implement practices to improve workforce stability and care quality. 31The Strategic Plan\nGoal Two, Objective One\nDevelop, pilot, and implement a uniform set \nof criteria and expectations for statewide use, on a voluntary basis, for NFs that address \nfactors affecting the recruitment, retention, \nand job satisfaction of direct care staff. Consideration should be given to the reason why nursing staff leave their jobs as demonstrated in long-term care research.\n32The Strategic Plan\nGoal Two, Objective Two\nConsider the “raise-the-bar” program \npertaining to direct care staff recruitment and retention based on job practices known to \ncontribute the high turnover and, by \nextension, workplace cultures where there is low turnover and high job satisfaction (supportive workplaces, balanced workloads, training, and career opportunities). 33The Strategic Plan\nGoal Two, Objective Three\nOutline eligibility requirements for participation \nas a pilot site and criteria for attaining a special designation indicating that the NF is a \nparticipating facility. The program should \nallow for creative, innovative, and cost-effective approaches to achievement of identified measurable objectives based on sound culture change principles.\n34The Strategic Plan: Funding\nDMAS could use existing CMP funds to \nbegin the development and \nimplementation of the QIP project. 35The Strategic Plan: Funding\nThe Advisory Committee may consider \nsetting aside a base funding amount of \n$500,000 to offset co sts of relocation of \nresidents, main tenance of ope ration of a \nNF pending correction of deficiencies or \nclosure.\n36The Strategic Plan: Funding\nFunding Suggestion\nWhile the Advisory Committee did not \ndiscuss the Pay-for-Performance (P4P) initiative, the QIP should be a complementary \nprogram. It may be appropriate to use a \nsmall portion of the CMP funds to “jump start”the P4P project. Funding could be continued on a yearly basis in an amount determined by the Advisory Committee. 37Presentation Outline\nBackground \nCivil Money Penalty Funds\nQIP Advisory Committee\nCommittee Discussions\nA Culture of Caring/Better Jobs Better Care\nThe Strategic Plan\nConclusion\n38Conclusion: Next Steps\nDMAS will reconvene an advisory committee \nto develop program criteria and implement \nthe QIP strategic plan.\nAdvisory committee decisions will include \ndeveloping parameters for a pilot QIP, \nrecommending a funding amount, defining measurable outcomes and marketing strategies.\nMeetings will be quarterly. 39Conclusion\nThe Virginia QIP Advisory Committee \nexamined many programs and identified \nthe best-practice model for the basis of \nquality improvement program in the Commonwealth. \nInvolvement of all of our long-term care \npartners is critical to successful \ndevelopment of Virginia’s future QIP."
} |
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"pdf_file": "VGYROI7GPRFUEH3N7Q6KKH6AVQRI2NYK.pdf",
"text": "16271 Federal Register / Vol. 66, No. 57 / Friday, March 23, 2001 / Notices\nActivities, National Cancer Institute, National\nInstitutes of Health, 6116 ExecutiveBoulevard, 8th Floor, Room 8050, Bethesda,MD 20852 –8328, (301) 496 –7930,\nmg85x@nih,gov.\nThis notice is being published less than 15\ndays prior to the meeting due to the timinglimitations imposed by the review andfunding cycle.\n(Catalogue of Federal Domestic Assistance\nProgram Nos. 93.392, Cancer Construction;93.393, Cancer Cause and PreventionResearch; 93.394, Cancer Detection andDiagnosis Research; 93.395, CancerTreatment Research; 93.396, Cancer BiologyResearch; 93.397, Cancer Centers Support;93.398, Cancer Research Manpower; 93.399,Center Control, National Institutes of Health,HHS)\nDated: March 15, 2001.\nLaVerne Y. Stringfield,Director, Office of Federal Advisory\nCommittee Policy.\n[FR Doc. 01 –7213 Filed 3 –22–01; 8:45 am]\nBILLING CODE 4140 –01–M\nDEPARTMENT OF HEALTH AND\nHUMAN SERVICES\nNational Institutes of HealthNational Cancer Institute; Notice of\nClosed Meeting\nPursuant to section 10(d) of the\nFederal Advisory Committee Act, asamended (5 U.S.C. Appendix 2), noticeis hereby given of the followingmeeting.\nThe meeting will be closed to the\npublic in accordance with theprovisions set forth in sections552b(c)(4) and 552b(c)(6), Title 5 U.S.C.,as amended. The grant applications andthe discussions could discloseconfidential trade secrets or commercialproperty such as patentable material,and personal information concerningindividuals associated with the grantapplications, the disclosure of whichwould constitute a clearly unwarrantedinvasion of personal privacy.\nName of Committee: National Cancer\nInstitute Initial Review Group, SubcommitteeE—Cancer Epidemiology, Prevention &\nControl.\nDate: April 4 –6, 2001.\nTime: 7 a.m. to 1 p.m.\nAgenda: To review and evaluate grant\napplications.\nPlace: Holiday Inn —Georgetown, 2101\nWisconsin Avenue, NW., Washington, DC20007.\nContact Person: Mary C Fletcher, PhD,\nScientific Review Administrator, GrantsReview Branch, Division of ExtramuralActivities, National Cancer Institute, NationalInstitutes of Health, 6116 ExecutiveBoulevard, Room 8115, Bethesda, MD 20892 –\n8328.\nThis notice is being published less than 15\ndays prior to the meeting due to the timinglimitations imposed by the review and\nfunding cycle.\n(Catalogue of Federal Domestic Assistance\nProgram Nos. 93.392, Cancer Construction;93.393, Cancer Cause and PreventionResearch; 93.394, Cancer Detection andDiagnosis Research; 93.395, CancerTreatment Research; 93.396, Cancer BiologyResearch; 93.397, Cancer Centers Support;93.398, Cancer Research Manpower; 93.399,Cancer Control, National Institutes of Health,HHD)\nDated: March 15, 2001.\nLaVerne Y. Stringfield,Director, Office of Federal Advisory\nCommittee Policy.\n[FR Doc. 01 –7214 Filed 3 –22–01; 8:45 am]\nBILLING CODE 4140 –01–M\nDEPARTMENT OF HEALTH AND\nHUMAN SERVICES\nNational Institutes of HealthNational Cancer Institute; Notice of\nClosed Meeting\nPursuant to section 10(d) of the\nFederal Advisory Committee Act, asamended (5 U.S.C. Appendix 2), noticeis hereby given of the followingmeeting.\nThe meeting will be closed to the\npublic in accordance with theprovisions set forth in sections552b(c)(4) and 552b(c)(6), Title 5 U.S.C.,as amended. The grant applications andthe discussions could discloseconfidential trade secrets or commercialproperty such as patentable material,and personal information concerningindividuals associated with the grantapplications, the disclosure of whichwould constitute a clearly unwarrantedinvasion of personal privacy.\nName of Committee: National Cancer\nInstitute Special Emphasis Panel, FlexibleSystem to Advance Innovative Research forCancer Drug Discovery by Small Business.\nDate: April 19, 2001.\nTime: 8 a.m. to 5 p.m.\nAgenda: To review and evaluate grant\napplications.\nPlace: National Cancer Institute, 6130\nExecutive Boulevard, EPN/Conference J,Rockville, MD 20852.\nContact Person: Timothy C. Meeker, MD,\nScientific Review Administrator, SpecialReview and Resources Branch, Division ofExtramural Activities, National CancerInstitute, 6116 Executive Boulevard, Room8088, Rockville, MD 20852, 301/594 –1279,\nmeekert@mail.nih.gov.\n(Catalogue of Federal Domestic Assistance\nProgram Nos. 93.392, Cancer Construction;93.393, Cancer Cause and PreventionResearch; 93.394, Cancer Detection andDiagnosis Research; 93.395, CancerTreatment Research; 93.396, Cancer BiologyResearch; 93.397, Cancer Centers Support;93.398, Cancer Research Manpower; 93.399,Cancer Control, National Institutes of Health,\nHHS)\nDated: March 15, 2001.\nLaVerne Y. Stringfield,Director, Office of Federal Advisory\nCommittee Policy.\n[FR Doc. 01 –7215 Filed 3 –22–01; 8:45 am]\nBILLING CODE 4140 –01–M\nDEPARTMENT OF HEALTH AND\nHUMAN SERVICES\nNational Institutes of HealthNational Cancer Institute; Notice of\nClosed Meeting\nPursuant to section 10(d) of the\nFederal Advisory Committee Act, asamended (5 U.S.C. Appendix 2), noticeis hereby given of the followingmeeting.\nThe meeting will be closed to the\npublic in accordance with theprovisions set forth in sections552b(c)(4) and 552b(c)(6), Title 5 U.S.C.,as amended. The grant applications andthe discussions could discloseconfidential trade secrets or commercialproperty such as patentable material,and personal information concerningindividuals associated with the grantapplications, the disclosure of whichwould constitute a clearly unwarrantedinvasion of personal privacy.\nName of Committee: National Cancer\nInstitute Initial Review Group, SubcommitteeC—Basic & Preclinical Basic and Preclinical\nStudies.\nDate: April 10 –11, 2001.\nTime: 7:30 pm to 6 pm.\nAgenda: To review and evaluate grant\napplications.\nPlace: Georgetown Holiday Inn, 2101\nWisconsin Avenue, NW., Washington, DC20007.\nContact Person: Michael B. Small, PhD,\nScientific Review Administrator, GrantsReview Branch, Division of ExtramuralActivities, National Cancer Institute, NationalInstitutes of Health, 6116 ExecutiveBoulevard, Room 8040, Bethesda, MD 20892,301/402 –0996.\n(Catalogue of Federal Domestic Assistance\nProgram Nos. 93.392, Cancer Construction;93.393, Cancer Cause and PreventionResearch; 93.394, Cancer Detection andDiagnosis Research; 93.395, CancerTreatment Research; 93.396, Cancer BiologyResearch; 93.397, Cancer Centers Support;93.398, Cancer Research Manpower; 93.399,Cancer Control, National Institutes of Health,HHS)\nDated: March 15, 2001.\nLaVerne Y. Stringfield,Director, Office of Federal Advisory\nCommittee Policy.\n[FR Doc. 01 –7216 Filed 3 –22–01; 8:45 am]\nBILLING CODE 4140 –01–M\nVerDate 11<MAY>2000 19:20 Mar 22, 2001 Jkt 194001 PO 00000 Frm 00100 Fmt 4703 Sfmt 4703 E:\\FR\\FM\\23MRN1.SGM pfrm01 PsN: 23MRN1"
} |
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"pdf_file": "PV2UUKY4MEWQFTITQRUFTBMJY6ONPUNW.pdf",
"text": "Fortenberry Comments on ‘Highly Complex and Dangerous’ Situation in Egypt\nWASHINGTON, D.C.--Congressman Jeff Fortenberry today issued the following statement\nconcerning today’s escalating clashes in Egypt:\n \n\"This is a highly complex and dangerous situation in the streets of Egypt.\n \n\"Egypt is the cultural and historic center of the Arab world and has provided a stabilizing\ninfluence in the volatile Middle East. This is a critical moment for the future of the country and\nthe region.\n \n\"People have the right to express their concerns with the government, and there must be space\nwithin Egyptian civil society for the highest aspirations of the people. Peaceful and pragmatic\ndialogue are necessary hallmarks of democratic change. Unfortunately, chaos and violence is\nthe current dynamic. It is important that the outcome addresses the sources of tension and\ndespair while preventing exploitation by violent extremists.\" \nCongressman Fortenberry, who has lived near Tahrir Square in Cairo, is a member of the\nHouse Foreign Affairs Committee.\n \n###\n \n 1 / 1"
} |
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"pdf_file": "EZ5GI4R7U4POAIDO2DOL6J3LIQLGQQRX.pdf",
"text": "Rep. Israel Joins Gold Star Mother Dorine Kenney, Founder of the Jacob's Light Foundation, to Announce the 400,000th Pound of Supplies Packed and Shipped from Long Island to our Armed Forces Overseas\n \nBrentwood, NY— On Monday, Rep. Steve Israel (D-Huntington) joined Gold Star Mother Dorine\nKenney to announce that her foundation, Jacob's Light, will pack and ship its 400,000th pound\nof supplies for our Armed Forces overseas. Kenney lost her son Jacob to a roadside bomb in\nIraq and started the Jacob's Light Foundation in his honor. \n“I have visited our troops in Afghanistan and Iraq eight times, and each time I see firsthand how\nimportant packages from home are to them. For seven years, Dorine Kenney has devoted\nherself to that cause, in honor of the son she lost in Iraq. This week, the Jacob’s Light\nFoundation will pack and ship the 400,000th pound of supplies. That's 400,000 pounds of good\nmorale and critical support for our warfighters,” said Rep. Israel. \n“Jacob's Light Foundation, Inc. packs and sends boxes with comforts and necessities for\ndeployed troops. We reach troops without support from home and helping those in remote\nbases, which do not have access to amenities. Our troops have come to rely upon us with 90\npercent of all requests coming from the troops themselves. We are making a huge impact on\nthe morale and comfort of our nation’s warriors,” Kenney said. \nKenney lost her only child, Spc. Jacob Fletcher, 173rd Airborne Brigade, on November 14th,\n2003 from a roadside bomb in Samarra, Iraq.\nThe Jacob’s Light Foundation packs boxes with toiletries, foods and snacks, reading and writing\nmaterials as well as bug wipes, sunscreen, batteries and other necessities for our troops.\nSpecial items are sent for the holidays. They also include letters from the public and letters and\npictures from children. And, they care for soldiers whose families cannot afford to send boxes to\ntheir loved ones.\nOn Tuesday, Jacob’s Light volunteers will meet and to pack supplies and reach the 400,000 lb\nmilestone.\n 1 / 1"
} |
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"text": " \nWireless Communication \nCollocation Site Plan \nType I Review \nHandout #74-C Revised: 1/8/09 \n \nWhat types of projects are subject to a Type I Review Process? \nCollocation of wireless communi cation facilities that are loca ted in Industrial or Forest \nzone districts in the Rural area or Commerci al districts in the Urban Growth Area are \nsubject to Type I Review re quirements. Type I projects are exempt from the State \nEnvironmental Policy Act (SEPA) review and subject to clear, objective and non-\ndiscretionary standards requiring professi onal judgement about technical issues. \n \nType I Site Plan reviews are “ministerial”, requi ring a review and decision by staff unless \nthey are exempt from the si te plan review process. \n When is a Fire Marshal review required? \nThe following list summarizes when it is necessa ry for the Fire Marshal’s office to review \na project. A “yes” answer to any one of thes e questions confirms that a Fire Marshal’s \nreview is necessary. Note: This review may be required even if Type I Site Plan review \nis not required. \n 1. Will there be a change in occupancy or use? 2. Is a building permit required, (other than for a single-family residence or a duplex)? \n3. Does the project involve a change in vehicular access to the site? \n4. Does the review involve fire flow r equirements? For example, will there be an \nincrease in height or interior floor area? \n5. Does the review involve ot her fire protection requirements such as fire sprinkler \nsystems, alarm systems, fire hydrants, etc.? \n6. Does the project include new constructi on involving review of building setbacks? \n7. Is the subject site within the Wildland Urban Interface/Intermix Area? \n8. Does the review involve any new building construction or review of limitations to a \nland use? \n9. Does the review involve hazardous proc esses per the Uniform Fire Code, Chapter \n80? (Such processes involve hazardous ma terials, flammable liquid or flammable \ngases.) \n \nIs a Pre-application Conference required? \nNo, however an applicant may reques t a pre-application conference. \n \nHow do I start the application process? \nThe first step is to submit a complete\n Type I Site Plan Application Form to the Permit \nServices Center along with t he application fees and the r equired number of copies for \nall submittal items. (See the atta ched Submittal Requirement list) Page 2 \nHandout #74-C \nWill I ever get to meet with the st aff members who review my project? \nYes. When you submit your applicati on, you will be given a date and time for a “Type I \nReview Conference”. At this conference you will get to personally meet with your \nPlanner and, depending upon the scope of your project, y ou may also meet with a staff \nengineer, a Public Works eng ineer, a Deputy Fire Marsha l, a Sheriff’s Deputy, a \nBuilding Inspector or Plans Examiner, or a staff member from the Southwest \nWashington Health District. \n As the applicant this conference affords you the opportunity to present your proposal \nand plans to the staff. For staff, the conf erence offers an opportunity to ask questions, \ngive guidance, and to ensure the applicant clearly understands the process and \nregulations, as they will be affecting them. \n By the end of the conference, you as the applicant will know whether your project will be approved, approved with c onditions, denied, OR, what additional information the staff \nwill need before they can make a decision. (Your project wi ll be placed on hold if \nadditional information is required.) \nHow does the Type I Site Plan review process work? \nThe County conducts two application checks to ensure that applications are complete \nbefore staff begins their development review pr ocess. Prior to accepting an application, \nthe Permit Services staff will conduct a “ Counter Complete\n“ review of the submittal \npackage. This initial Counter Complete review ensur es that all required submittal items are \ncontained within the package. If each item on the submitta l requirement list has been \nsubmitted, the application will be accepted for further review . To be Counter Complete, \nthe following items must be submitted: 1. Cover Sheet & Table of Contents 2. Application Form 3. Application Fee 4. Developer’s GIS Packet Information 5. Narrative 6. Authorization to use Site & Support Structure 7. Legal Lot Determination Information 8. Proposed Site Plan 9. Photographic Analysis 10. Preliminary Stormwater Design Report 11. Associated Applications 12. Submittal Copies Upon acceptance of t he application two things will h appen immediately. First, the \ncounter person will schedule a Ty pe I Conference for you. This conference will be held \nwithin 14 to 20 days from the date your application is counter complete. Second, the \ncounter staff will route the appl ication package (with the conference information) to the \nreview staff. Page 3 \nHandout #74-C Within 21 days (or the 14 to 20 days allotted before the Type I Conference) the review \nstaff will conduct a second completeness check, known as the “ Fully Complete “ \nreview. This detailed review ensures that all items submitted have the technical \ninformation required for staff to make a decision. \n If the application is “Fully Complete” the staff has until the Type I Conference date to review the application. The staff is then required to attend the Conference and explain \ntheir decision as well as expl ain any conditions of approval that the applicant may have \nto complete. The staff will then have up to 20 days to issue a written decision. If required technical information or items ar e missing, the planner will prepare a letter \nindicating the application is “ Not\n Fully Complete”, and deliv er it to you at the \nconference. It will indicate the additional it ems and/or information required to make the \nproject “Fully Complete”. If the requested information is not submitted within 30 days, staff will return the application and ref und a portion of the application fee. \n Once an application is “Fully Complete”, the review staff has 21 days to prepare a \nwritten decision that specifies the Conditions of Approval for your project to ensure \ncompliance with all applicable codes and laws. In all, the issuance of a decision may ta ke up to 42 calendar days from the date a \ncounter complete application is accepted by the Permit Serv ices Center, unless it is \nplaced on hold. \nCan I Request an Extension of Time to Submit Additional Information? \nYes. You can submit a written request to extend the decision deadline and submit \nadditional information for consider ation with or after the request. \n \nIf your application has been deemed “Not Fully Complete” you may also request \nadditional time to submit any information requested. \n \nWhat kind of public notice is provided? \nThere is no public notice required for Type I development proposals. \n Can the decision be appealed? \nThe staff’s decision may be appealed to the County Hearings Examiner by the applicant \nor any person or group. An appellant must submit an appeal application and the $1,166 \nfee within 14 calendar days af ter the written notice of the decision is mailed. \n \nHow long is my approval valid? \nA preliminary site plan approval shall be valid for a period of five (5) years after approval. \nDuring that time, a complete application for fi nal site plan review OR building permit must \nbe submitted. This time limit may be extended where there is an approved phased \ndevelopment or separate development agreements have been approved, (see Clark \nCounty Code, Section 40.500. 010(B) for more details). \n \nAfter the Preliminary Site Plan is approved, what is next? \nAfter receiving approval of the prelimin ary site plan, the applicant may submit \nengineering construction plans, the final site plan (if necessary), and building permits for \nreview. Page 4 \nHandout #74-C \nNote: Conditions of Approval must be met before you begin your project, \noccupy your building, or open for business. \n \nWhen can I apply for a building permit? \nSite plan approval is required prior to the issuance of building permits by the Building \nDivision. However, application for building permits may be made at the same time as \napplication for site plan review . Please note: Should the site plan review process require \nmodification to the site plan, you must revise and re-submit your building plans to reflect \nthose changes. Failure to make the appropriate change s may delay your building \ninspections or it may result in Code Enforcement actions for th e failure to co mply with the \nsite plan review conditions. Building permi t applications are filed with the Building \nDivision in the Permit Services Center. \n Please see “Engineering Cons truction Plan Review” info rmation handout for further \ninformation about the final engineering pl an and final site plan review process. \n \nTYPE I Wireless Communication Collocation \nSITE PLAN REVIEW \nFEES \n \nNon-Residential: $1,531 \nFire Marshal Review: $ 434 \nStormwater Review: $ 386 \nTransportation Review: $ 395 \nLot Determination Fee*: $ 200 + $75 / lot over 2 lots Page 5 \nHandout #74-C \nDEVELOPMENT REVIEW \nTYPE I SITE PLAN APPLICATION \nSUBMITTAL REQUIREMENTS \n \nThe following checklist identifies information required to be included with the Type I Site \nPlan Application. All items with a number followed by an underlined space (i.e., 1. ___ ) \nmust be submitted before the application will be considered “Cou nter Complete.” All \nitems with a check box (i.e., \u0000) must be complete for the application to be determined \n“Fully Complete.” \n1. __ COVER SHEET AND TABLE OF CONTENTS – Each application \nsubmittal packet shall cont ain a cover sheet that incl udes the applicant’s name, \naddress, e-mail address, an d phone number, along with the name of the proposed \nproject. A table of contents to prov ide assistance in locating the various \nrequirements shall follow the cover sheet. \n \n2. __ APPLICATION FORM - The application form shall be completed and the \napplicant shall sign at least one original copy in ink. \n \n3. __ APPLICATION FEE - The fee for a Type I Site Plan review shall accompany \nthe application. Checks are payable to \"Clark County Commu nity Development\". \n \n4. __ DEVELOPER’S GI S PACKET INFORMATION \nA copy of the “Developer’s GIS Packet” shall be submitted with the application. \nApplicants have the option of requesting their GIS Developer’s Packet in PDF \nformat on a CD or posted to one of our FTP sites. Applicants can request their \nDeveloper Packets either as paper copy or electronically for $40.00. Applicants \nmay request the digital version and add a paper copy for an additional $10.65 \nplus tax. The Developer’s Packet fee increase will take effect on September 1, \n2007. To order Developer’s Packets, please contact Linda Mattila by phone (360) \n397-2391 ext. 4641 or email at themapstore@clark.wa.gov . \n \nThe packet includes the following: \n• General Location Map; \n• Property Informa tion Fact Sheet; \n• Arterial Roadway, C-Tran Bus Routes, Parks and Trails Map; \n• Elevation Contours Map; \n• Photography Map; \n• Photography Map with Contours; \n• Zoning Map; \n• Comprehensive Plan Map; \n• Water, Sewer and Storm Systems Map; \n• Soil Type Map; \n• Environmental Cons traints Map; and, \n• Quarter Section Map. Page 6 \nHandout #74-C \n5. __ NARRATIVE \n A written narrative shall be submitte d that addresses the following: \n \n COLLOCATIONS : \n How the application meets or exceeds each of the applicable approval criteria \nand standards; \n How the proposed plan m eets the minimum area and dimensions of the base \nzone; \n How the issues identified in the pr e-application conference have been \naddressed, and generall y, how services will be provided to the site; \n A comprehensive description of the existing or proposed facility including the \ntechnical reasons for the design and co nfiguration of the facility, design and \ndimensional information, and antici pated coverage of the facility; \n If camouflage technology is proposed, the applicant shall provide a complete \ndescription of the suggested camouflage, including style and materials to be \nused, a photographic depict ion of the proposed facility, and a maintenance plan \ndetailing provisions for the contin ued effectiveness of the suggested \ncamouflage for the life of the facility; \n An analysis of the proposal area and discussion of factors influencing the \ndecision to target the proposed location. Such analysis shall include the good \nfaith efforts and measures taken to secure a higher priority location; how and why \nsuch efforts were unsuccessful; and how and why the proposed site is essential \nto meet service demands for the geographic service area; and, \n The frequency of vehicle trips the pr oposal could be expected to generate. \n \n6.__ AUTHORIZATION TO USE SITE & SUPPORT STRUCTURE \nDocumentation that establishes the applicant’s right to use the site shall be \nprovided at the time of application by a copy of the proposed lease agreement, \neasement agreement, license agreement or letter of authorization to use the \nfacility from the owner of the support structure. \n \n7.__ LEGAL LOT DETERM INATION INFORMATION \n If the lot is part of a plat, binding site plan, or subdivision, no lot information is \nrequired beyond that supplied in the GIS packe t. If the application is not part of a \nplat, binding site plan, or subdivision, the applicant is required to either: a) \ncomplete a legal lot determination, or b) submit a sales or transfer deed history \ndating back to 1969, to incl ude copies of recorded deeds and/or contracts verifying \nthe date of creation of the parcel in ch ronological order with each deed identified \nwith the Assessor’s lot number. \n \n8. __ PROPOSED SITE PLAN \n The proposed plan shall be drawn to a mi nimum engineer’s scale of 1” = 200’ \non a sheet no larger than 24\" x 36\". \n \n The following information shall be clear ly depicted on the proposed site plan: \n \n GENERAL INFORMATION \n Applicant’s name, mailing address and phone number; Page 7 \nHandout #74-C Owner’s name and mailing address; \n Contact person’s name, mailing address, and phone number; \n North arrow (orientated to the top, le ft or right of page ) scale and date; \n Proposed name of project; \n Vicinity map covering ¼ mile radius from the development site (not required for \nrural area plans); and, \n Area of the site in acres or square feet. \n \n COLLOCATIONS : \n \n Existing Conditions \n Show the entire parcel, drawn to scale, with property lines, north arrow \n(orientated to the top, left or right), footprint of existing structures and \ndriveways, parking spaces, abutting streets (name, centerline, curb & \nsidewalk), and existing fire hydrants; \n The location of existing wells & septic systems; \n Location and full width of existing ease ments for access, drainage , utilities, \netc.; \n The locations of any existing environm entally sensitive areas (e.g. wetlands, \nwater bodies, steep slopes etc.) on the si te, as indicated in the GIS materials; \n Indicate the existing surfacing and featur es on all portions of the site, such as \nasphalt, landscaping, lawn, gr avel, stormwater swale, et c; (as applicable); and, \n Elevation plans showing the existing ant ennae and the height of each as well \nas any lightning rods (as applicable). \n Proposed Improvements\n \n Show the location of all proposed stru ctures, driveways and roads, easements. \nnumber and layout of pro posed parking spaces; (as applicable) and proposed \nlocation of fire hydrants;; \n Landscape plan if landscapi ng is proposed; and, \n Elevation plans of proposed site and facili ty changes. \n \n9. __ PHOTOGRAPHIC ANALYSIS \n A photographic analysis of the proposed site shall be submitted, including a \nrepresentation of existing conditions and photographic simulations depicting \nviews of any new antennae, support structures or towers. \n \n10.__PRELIMINARY STORMWATER DESIGN REPORT \nIf the project involves the addition or re-development of 2,000-sq. ft. of \nimpervious surfacing in an Urban Growth Area or 5,000-sq. ft. of impervious \nsurfacing outside of an Urban Growth Area, stormwater review will be required for the project. \n \n11.__ASSOCIATED APPLICATIONS \nApplications associated with the project, to the extent applicable (e.g., floodplain, \nhabitat, shoreline, wetland, variances, etc.) must be submitted prior to or with this \napplication. Page 8 \nHandout #74-C \n12.__SUBMITTAL COPIES \n The applicant must select Option A or B below and proceed as follows: \n \nOption A : \nSubmit a CD in PDF format, with a paper copy of the full application package. \nAny special studies shall also be in cluded on the CD. The proposed plans \nsubmitted must be scanned to an enginee r's scale. The main CD application \nshall be organized as follows: A. The application submittal shall be organized in the same order as the table \nof contents, with a separate PDF document for each separate item. \n B. The PDF document must be organized into separate files. Each PDF file \nmust be labeled with a number fo llowed by a name (example): \n \n1. Cover Sheet and Table of Contents 2. Application Form 3. Developer’s GIS Packet Information 4. etc. \n \n Option B\n: \n ___ One copy of the main submittal with original signatures, bound by a \n Jumbo clip or rubber band, and \n ___ Five (5) copies of application pac kage with a full size set of plans. \n ___ Separately bound copy of any special studies (e.g., wetland, \n floodplain, etc) as identified below: \n 1 original and 3 copies - Traffic St udy and Road Modification requests \n 1 original and 2 copies of all other sp ecial studies or permits to include: \nCritical Aquifer Recharge Areas (CARA) floodplain, geo-hazard, habitat, \nshoreline, stormwater, erosion control plan, and wetland). \n___2 reduced copies of 11” x 17\" for a ll sheets larger th an 11” x 17.” \n \nStaff Notes: \n1. If any of the application materials exceed 11” x 17\" in size, please also provide a \nreduced copy no larger than 11” x 17”. Clark County cannot reproduce materials \nlarger than 11” x 17\". \n2. ________________________ _____________________ ______________________ \n3. ________________________ _____________________ ______________________ \n4. __________________ __________________ __________________ _____________ \n5. ________________________ _____________________ ______________________ \n6. ________________________ _____________________ ______________________ \n \n \nThis application was determined to be C ounter Complete on: ____/______/____ \n \nCommunity Development Specia list: ______________________ _________ \n \n \n \n \n* This fee is not required if a previous legal review has been comnpleted. \n \n \n \n \nPublic Service Center \nCommunity Development Department \n1300 Franklin Street \nP.O. Box 9810 \nVancouver, WA. 98666-9810 \nPhone: (360) 397-2375; Fax: (360) 397-2011 \nWeb Page at: http://www.clark.wa.gov \n \n \n \n ADA COMPLIANCE PROGRAM: \n For an alternate format, contact the Clark County ADA Compliance \n Office, V (360) 397-2375-2025; TTY (360) 397-2445; E-Mail: \n ADA@clark.wa.gov \n \n \n \nPage 9 \nHandout #74-C "
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"pdf_file": "2KH4X5DOMVDC44GAIAFOCYEKJMXGQH4T.pdf",
"text": "March 13, 2006 - New Study Reveals U.S. to Lose $785 Million, Canada $1.7 Billion Annually with WHTI\n New Study Reveals U.S. to Lose $785 Million, Canada $1.7 Billion Annually with WHTI \n Slaughter Repeats Call for Cost-Benefit Analysis of Passport Initiative\n \n \n \n Washington, DC - Rep. Louise M. Slaughter (D-NY-28), Ranking Member of the House Rules\nCommittee, today repeated her call for a cost-benefit analysis of the Department of Homeland\nSecurity's Western Hemisphere Travel Initiative (WHTI) following the release of a new study\nfrom the BESTT Coalition (Borders for Economic Security, Trade and Tourism). The study\nconcluded that the United States stands to lose $785 million annually if the WHTI is\nimplemented in its current form. \n \n \n \n "This new study is only more evidence that the Travel Initiative is deeply flawed\nand needs to be changed," Rep. Slaughter said. "If we don't conduct a\ncomprehensive economic analysis of this plan before ground is broken, we will simply\nbe writing off the economic security of millions of Americans and Canadians. And they\ndeserve better." \n \n \n \n Rep. Slaughter was today joined by 20 New York Members of Congress in requesting that the\nOffice of Management and Budget (OMB) oversee the proposed analysis. She had previously\nemployed an Executive Order in a further attempt to force the federal government to study the\neconomic impact of its plan. \n \n \n \n The Conference Board of Canada confirmed BESTT's findings. It concluded that the WHTI\nwould result in 3.5 million fewer nationwide crossings from Canada to the United States, and\n 1 / 2 March 13, 2006 - New Study Reveals U.S. to Lose $785 Million, Canada $1.7 Billion Annually with WHTI\nmore than twice this number from the U.S. to Canada. In addition to the $785 million annually\nlost by America, the Canadian economy would stand to lose $1.7 billion per year in revenue. \n \n \n \n The BESTT study used a Zogby International poll taken of individuals living in cities along the\nborder. The poll found that such citizens would be less likely to visit the United States if they\nwere required to use a passport or another secure document at the border, a requirement of the\nWHTI. The study also revealed that: \n \n \n \n - Vacation is the top reason why Americans and Canadians travel to Canada and the\nUnited States, respectively. Many poll respondents also said that they would not participate in a\nprogram requiring a new identification card for cross-border travel. \n - Most Canadian visitors to the United States travel more than 100 miles to get there. They\nare also two times as likely as American tourists to spend over $500 during their visit.\nConsequently, their trips contribute significantly not just to border economies, but to a broader\narray of communities in both countries. \n - A majority of the poll's respondents said that they supported an enhanced driver's license\nthat could combine a normal license with a border crossing ID card, and that such a document\nwould increase the likelihood that they would continue to cross the border. \n - Most poll respondents also said that they did not believe that new border-crossing\nrestrictions were necessary. \n \n 2 / 2"
} |
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"text": "Download spreadsheet version\nTable 2. Number of applications and denials, by type of agency and type of check, 1999 - 2008\n2008 1999-2008a\nPercent Percent\nType of checks conducted Applications Denials denied Applications Denials denied National total (FIST and FBI) 9,900,711 147,080 1.5 % 84,340,362 1,463,940 1.7 %\nFBI total 5,813,249 70,725 1.2 % 48,159,005 680,905 1.4 %\nState and local total (FIST)\nb4,087,462 76,355 1.9 % 36,181,357 783,035 2.2 %\nState agencies\n Total 3,551,936 63,051 1.8 % 30,974,930 668,222 2.2 %\n Instant checksc2,395,133 42,546 1.8 21,520,780 504,814 2.3\n Purchase permitsd361,373 9,648 2.7 3,202,911 75,936 2.4\n Exempt carry permitse323,722 6,053 1.9 2,098,762 43,426 2.1\n Other approvalsf471,708 4,804 1.0 4,152,477 44,046 1.1\nLocal agenciesg\nTotal 766,293 13,304 1.7 % 6,207,965 114,813 1.8 %\nPurchase permitsd367,719 7,930 2.2 3,824,049 81,436 2.1\nExempt carry permitse334,577 4,855 1.5 1,865,517 29,137 1.6\nOther approvalsf63,997 519 0.8 518,399 4,240 0.8\ngTotals were estimated. See Methodology for more detail.aTotals for the 10-year period include December 1998.\nbAgencies that conduct exempt carry permit checks in Arizona, Arkansas, Kentucky, Mississippi, North Dakota, South Carolina, Tex as, and Wyoming request an \nFBI background check, but the state agency makes the decision to approve or deny an applicant. Applications in these states are included in FBI checks but \ndenials are included in state and local checks, causing a reduction of FIST total applications by 230,767 in 2008 and by 1,001, 538 for 1999 to 2008.\ncInstant check requires a seller to transmit a buyer's application to a checking agency by telephone or computer; the agency is required to respond immediately \nor as soon as possible. \ndPurchase permit systems require a buyer to obtain, after a background check, a government-issued document such as a permit, lic ense, or identification card \nthat must be presented to a seller in order to receive a firearm.\neExempt carry permit is a state concealed weapons permit, issued after a background check, that exempts the holder from a new ch eck at the time of purchase \nunder an ATF ruling or state law. \nfOther approval systems require a seller to transmit an application to a checking agency, with transfers delayed until a waiting period expires or the agency \ncompletes a check. "
} |
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"pdf_file": "4JVIYSW2MHWPE5BXGXLAXTNMHGHJFPUP.pdf",
"text": "In a recent report to the Senate \nCommittee on Environment and \nPublic Works , the Government Ac-\ncountability Office (GAO) pre-sented the results of a survey con-\nducted among fifty wastewater ex-\nperts nationwide who were asked to answer the following questions: \n• Which wastewater assets are \nmost vulnerable to terrorist at-\ntacks? \n(See below) \n• What security enhancing actions \nare most deserving of federal support? \n (See page 2) \n• What criteria should be used for \ndetermining those utilities having \nthe highest priority for federal \nfunding to improve security? \n (See page 2) • What is the best method \nto distribute federal \nfunds? \n (See page 2) \nThe results of the survey \nare presented in the follow-\ning, starting immediately below and continuing on through page 2. \nThe Five Most Vulnerable Wastewater Assets \nFifty experts asked to identify \nwastewater assets \nthat are the most vulnerable to \nsecurity threats \npicked the following: 1 Collection system’s network of sewers (42 votes) \n2 Treatment chemicals (32 votes) 3 Key components of the treatment plant, such as the headworks (29 \nvotes) \n4 Supervisory Control and Data Ac quisition (SCADA ) systems (18) \n5 Pumping stations (16) IDAHO DEPARTMENT OF ENVIRONM ENTAL QUALITY, WASTEWATER PROGRAM WASTEWATER \nSECURITY FACT SHEET \nWastewater Security is Focus of GAO-05-165 Report \nHow can waste water security be \nenhanced? Who do you call in an \nemergency? See back page. \nTo get a copy of GAO-05-165, “Wastewater Facilities: Expert’s Views on How Federal Funds Should be Spent to Improve Security,” go to http://www.gao.gov/ and enter GAO-05-165 in the search box. \nThen click Go.\n \nThe Idaho National Laboratory (INL) maintains a SCADA test bed for conducting research aimed at enhancing utility infra-\nstructures, making systems less susceptible to attacks. For more information on the INL test bed, go to: \n \nhttp://www.inl.gov/nationalsecurity/capabilities/security/ 2006 Security-Enhancing Activities Deserving Federal Support \n1 Direct grants (34 votes) \n2 Clean Water State Revolving Fund \n(5 votes) \n3 Loans or loan guarantees (1 vote) When asked to rate the best \nmechanisms for distributing fed-\neral funds to be used to enhance \nwastewater security, the fifty ex-perts chose the following: How Should Federal Funds be Distributed? Who Should Get Federal Funds? \n1 Utilities serving critic al infrastructure (39 \nvotes) \n2 Utilities using large quantities of gaseous \nchemicals (26 votes) \n3 Utilities serving large populations (24 votes) When asked which utilities \nshould get top priority for fed-\neral funds to enhance the se-\ncurity of wastewater systems, the panel of fifty experts cited \nthe following criteria most fre-\nquently: When asked to pick those security-\nenhancing activities \nmost deserving of fed-eral support, the sur-\nvey of experts polled \nfor GAO-05-165 cited the following: 1 Replacing gaseous chemicals used in wastewater \ntreatment with less hazardous alternatives (29 votes) \n2 Improving local, state, and regional collaboration \nefforts (23 votes) \n3 Completing vulnerability assessments for individual \nwastewater systems (20 votes) \nTWENTY-NINE OF FIFTY EXPERTS SURVEYED RATED THE REPLACEMENT OF GASEOUS CHEMICALS WITH LESS HAZARDOUS \nALTERNATIVES TO BE THE HIGHEST PRIORITY FOR FEDERAL FUNDING. Page 2 WASTEWATER SECURI TY FACT SHEET \nHow do wastewater experts think \nsecurity can be enhanced and funded? Source: GAO-05-165. \nCWSRF Programs: \nMore than $40 Billion \nIn Low-Interest Loans \nEPA’s Clean Water State \nRevolving Fund (CWSRF) \nprogram has provided more than \n14,000 low-interest loans for “water quality protection projects \nfor wastewater treatment, \nnonpoint source pollution control, and watershed and estuary \nmanagement.” \n “CWSRFs offer: \n• Low interest rates, flexible \nterms \n• Significant funding for nonpoint source pollution \ncontrol and estuary \nprotection \n• Assistance to a variety of \nborrowers \n• Partnerships with other funding sources” \n \nFor additional information, see \nthe addresses below: \nhttp://www.epa.gov/owmitnet/cwfinance/cwsrf/index.htm \nFOR ADDITIONAL INFORMATION ON CONSTRUCTION LO ANS FOR PUBLIC WATER SYSTEMS IN IDAHO, SEE: \nHTTP://WWW.DEQ.IDAHO.GOV/WATER/ASSIST_BUSI NESS/PWWS/CONSTRUCTION_LOANS.CFM \nAccess EPA’s Water Security Web site at: http: //cfpub.epa.gov/safewater/w atersecurity/index.cfm EPA Resources \nVulnerability Assessment Tools \n• Vulnerability Self-Assessment Tools \n(VSAT) \n• National Environmental Training Center for Small Communities (NETCSC) guide to security for small water systems \n• A video on developing vulnerability assessments, prepared especially for small water systems. \n• Security Vulnerability Se lf-Assessment Guide for Very Small (<3,300) \nSystems \n• Risk Assessment Methodology fo r Water Utilities (RAM-W), developed \nby Sandia National Laboratory \n• Protecting Your Community's Asse ts: A Guide for Small Wastewater \nSystems \n. . .for more, see the address below: Evaluating your vulner-\nability is the first step in \nmaking your facility \nmore secure. EPA pro-vides links to resources \nthat can help utilities \nperform security vul-nerability assessments. \nAmong the resources \nthat can be accessed from the EPA site are the following: Basic Elements of \nVulnerability \nAssessments: \n1. Characterization of the water \nsystem, including mission and \nobjectives \n2. Identification and prioritization of \nadverse consequences \n3. Determination of critical assets \n4. Assessment of the likelihood of \nmalevolent acts \n5. Evaluation of existing \ncountermeasures \n6. Analysis of current risk and \ndevelopment of a prioritized plan for \nrisk reduction. \n \nFor additional information, see the \naddress below: Page 3 \nThe Environmental \nProtection Agency’s \nWater Security Web \nsite provides resources of interest to utilities \nand others involved in \nensuring security. Top-ics addressed on this site include: \n • Vulnerability assessments \n• Emergency/incident planning \n• Security enhancements, research, \nand technology \n• Legislation and directives, including \nlinks to Homeland Security Presiden-\ntial Directives and federal laws \n• Resources for small utilities \n• Resources for public involvement \n• Resources for information sharing \nEPA Vulnerability Assessment Fact Sheet \nhttp://www.epa.gov/safewater/waters ecurity/pubs/va_fact_sheet_12-19.pdf \nIn this wastewater fact sheet, the focus is on securi ty, starting with the findings of GAO-05-165 and continu-\ning through some other compelling wastewater security related suggestions and recommendations of merit. \nIn an era in which terrorism remains a major threat to the security of our country’s infrastructure, including \nwastewater systems, we are sure that you will find this information to be not only thought-provoking, but \nworthy of your attention. \nRichard Huddleston, DEQ Wa stewater Program Manager \nhttp://www.deq.idaho.gov/water/prog_ issues/waste_water/overview.cfm (208) 373-0561 \nRichard.Huddleston@deq.idaho.gov A Message from the Wastewater Program Manager Idaho Department of Environmental Quality \nWastewater Program 1410 N. Hilton \nBoise, Idaho 83706 \nph: (208) 373-0502 fx: (208) 373-0417 When to call \nConditions under which you \nshould call include the following: \n• When physical security has been compromised, or there is \nobvious evidence of accidental \nor malicious intrusion. \n• When there is evidence of van-dalism that suggests intrusion \nleading to added vulnerability of \nthe system—such as caused by \nholes in fences or gates, cuts in \nbarbed wire, or the removal or destruction of locksets. \n• When suspicious materials \n(discarded packaging, plastic \nbags, unlabeled and discarded \ncontainers) or evidence of intru-Who to call \nIf you suspect contamination of \nor intrusion into your wastewa-\nter system, first call your local \nlaw enforcement agency by \ndialing 911. Then call the \nIdaho Com Center (1-800-632-\n8000 ) to set up an emergency \ntelephone conference with \nstate and local officials, who \nwill advise you on what to do next. If you suspect contamination \nor intrusion, call your local law enforcement agency (911) and then the Idaho Com Center, 1-800-632-8000! sion (marks where devices \nhave been dragged across the \nground or vehicle tracks) have been discovered. \nWhen anonymous threats have \nbeen directed at a facility. \nWhat to do \nIf your concern meets any of the \ncircumstances described, call \nyour local law enforcement \nagency (911) and then the \nIdaho Com Center at 1-800-\n632-8000 . \nClearly indicate that your call \nconcerns a threat to a wastewa-\nter system. \n Emergencies: Who to call, wh en to call, and what to do \nIf you suspect contamination of or intrusion into your wastewater system, first call your local law enforcement \nagency by dialing 911. Then call the I daho Com Center (1-800-632-8000 ) to set up an emergency telephone \nconference with state and local officials, who will advise you on what to do next. \n"
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"pdf_file": "CM73W2TP2FDG5FFHRB6CQS526UNDQF7P.pdf",
"text": "House Passes Financial Rescue Plan\n \n For Immediate Release:\nOctober 3, 2008 Contact: Peter Karafotas\n(202) 226-6898\n \n HOUSE PASSES FINANCIAL RESCUE PLAN\n \n President Signs Bill into Law\n \n \nWashington, D.C.—U.S. Representative Jan Schakowsky (D-IL) today joined a bipartisan majority in voting for H.R. 1424, the Emergency Economic Stabilization Act. H.R. 1424, which passed the House by a vote of 263 to 171, will allow the Treasury Secretary to purchase troubled assets from financial institutions so banks can resume lending. The financial crisis on Wall Street has frozen the credit markets making it very difficult for Americans to get access to student loans, home loans, and car loans and for businesses to make payroll. The U.S. Senate passed this legislation on Wednesday evening and the President signed the bill into law shortly after today’s vote in the House of Representatives. \nCongresswoman Schakowsky released the following statement before the House voted on H.R. 1424.\nMadam Speaker,\nI rise in reluctant support of H.R. 1424, the Emergency Economic Stabilization Act. On Monday, the House failed to pass a rescue package, and the stock market dropped 777 points – the biggest one day point drop in U.S. history! The impact of that drop wasn’t just felt on Wall Street; it was also felt on Main Street. On Monday alone, Americans lost $1.2 trillion in the stock market. Almost 50 percent of Americans are invested in the stock market in some way, whether through retirement accounts or private investments, and they rely on credit and their investments to make ends meet. \nThis legislation is about protecting people’s retirement accounts and pension plans. In the last year, investments have declined by nearly 24 percent, putting the retirement security of millions at risk; I am worried that without this package, they will continue to the downward spiral. This legislation is about making sure that there is enough credit in order for students and families to take out loans to afford to go to college. It is about letting businesses make their payroll. It is about helping people stay in their homes. That is why dozens of groups representing educators, colleges, the homeless, pension managers, and others support this legislation. \nI want to make it very clear that I think this legislation is far from perfect – and, like many of my colleagues, I would have written a very different bill. However, I believe that Monday demonstrated that we had to act. Years of harmful Republican policies that pushed for deregulation and tolerated an almost total lack of enforcement, and a misguided philosophy that insisted that an unregulated market can heal all ills, have now led us to the brink of economic collapse. And I am deeply concerned – and hundreds of economists agree – that the failure to act could lead to a major economic depression. \nAgain, the rescue plan, while still imperfect, has come a long way from where we began. Instead of giving the President $700 billion with virtually no oversight or safeguards, we require Congressional review after the first $350 billion. And this legislation requires equity sharing, so taxpayers would benefit from future growth in the investments they have bought, and it contains provisions to ensure that Wall Street pays back the taxpayers for any losses. We are stopping forms of executive compensation that would encourage executives to take excessive risks, eliminating golden parachutes for executives who take part in the government program, and cracking down on excessive compensation practices for the fist time in history. And we include strong, independent oversight to protect the taxpayer, including two oversight boards to ensure that the Treasury Secretary is acting on good faith, as well as judicial review over the Secretary’s actions. \nWhile I would have liked to see the tax provisions paid for by rolling back some of the President’s tax cuts to the wealthiest Americans and closing corporate loopholes, there are also important tax fixes that will benefit millions of Americans and small businesses across the country. The legislation provides property tax relief to up to 30 million homeowners – extending a new $1,000 property tax deduction for non-itemizing couples through the end of 2009. It extends the qualified tuition deduction for low- and middle-income Americans. It extends the child tax credit, which will benefit millions of Americans with children age 17 and younger. It extends the Research and Development tax credit, which spurs innovation and job growth in the technology sector. And it extends critical renewable energy and energy efficiency tax credits to help the green economy take shape. \n This legislation also contains critical, comprehensive mental health parity legislation that will bring mental health insurance benefits in line with other medical benefits. I have not held a health care meeting in my district without the issue of access to mental health care being brought up my constituents who have faced discrimination or difficulty obtaining affordable care. I am proud that we are continuing Senator Paul Wellstone’s legacy by passing a bill that guarantees equal access to mental health and substance abuse treatment. I also want to thank Representatives Patrick Kennedy and Jim Ramstad for their persistence and passion in passing the Paul Wellstone Mental Health and Addiction Equity Act. \n 1 / 2 House Passes Financial Rescue Plan\nThere is so much more we should do. I am strongly committed to enacting a second stimulus package that will truly benefit the American people. Today the House enacted 7 weeks of extended benefits for workers who have exhausted regular unemployment compensation, with workers in high unemployment states eligible for an additional 13 weeks of benefits. However, I believe we also need to make investments in our highways, bridges, transit systems, and schools; we need increases in food stamps benefits; and we need a crucial temporary increase in Medicaid payments to states. Studies have shown that those are some of the quickest forms of economic stimulus because those benefits and investments are spent quickly\nThis bill represents unfinished business. I will fight my hardest to make sure that we rein in the excesses of corporate America in the next Congress, and to see to it that this crisis does not happen again.\n \n 2 / 2"
} |
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"pdf_file": "U23MNPFKWDU6QBI3PCJ5KCLGX3RO4LMN.pdf",
"text": "Dr. Burgess Weekly Video Address November 22, 201 3 \n“My Health Care Solutions ” \nHello, this is your c ongressman, Michael Burgess. I’ve been a doctor for over 25 years , and I \nknow that our health care system needs improvements. But before can we talk reform, \nAmericans need the opportunity to make their own health care decisions, and the president’s \npatched -up health c are law will not give Americans the health care they want – and it does \ncome at the expense of their freedom. \n \nThe Affordable Care Act was carel essly drafted behind closed doors. It included secret deals, \nloopholes, special interests, drafting errors, and allowed all federal agencies to be created \nwithout Congressional knowledge or oversight. The bottom line is the Affordable Care Act was \nnot mean ingful reform. There is no way that this law will improve your health or your health \ncare or reduce costs. In fact it’s going to cost you plenty. \n \nWith health care on so many people’s minds, I wanted t o share with you a few of my ideas for \nwhat we could do in health care . If we really want to help with cost, we need a series of changes \ninvolving specific problems which include the inequities in the tax code. We should give \nAmericans the ability to purchase health insurance across state lines to increase competition. \nAlso people should be allowed to use their Health Savings Acco unt to offset these very high \ndeductibles we’re seeing . \n \nFor better health care coverage, we should encourage and expand state solutions for people with \npre-existing conditions. Some medical liability reform would also be nice. All of this will \nmaintain a patient centered approach to health care and represent the meaningful type of reform that people have been seeking. \n If you are interested in learning more about my health care idea s, please visit my health caucus \nwebsite at health.burgess.house.gov. There you will be able to learn more about solutions and \nprescriptions for health care reform. Thank you for taking the time to listen. Ma y God bless you \nand your family, may you stay in good health, a nd as always, may God bless Texas. "
} |
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"pdf_file": "3IFL3YAHHYK5PMUEVWZZ2PHZ7TYPPTET.pdf",
"text": "738 47 CFR Ch. II (10–1–05 Edition) § 214.3 \n§ 214.3 Assumptions. \nWhen the provisions of this part be-\ncome operative, Presidential emer-gency authority, including Executive Order 12656, 12472, 12046 (3 CFR, 1966– 1970 Comp., p. 820), and other emer-gency plans regarding the allocation and use of national resources will be in effect. During an attack, and in a postattack period, the Director, OSTP, will have authority to make new or re-vised assignments of radio frequencies in accordance with authority delegated by the President. \n§ 214.4 Planned actions. \n(a) Whenever it is determined nec-\nessary to exercise, in whole or in part, the President’s emergency authority over telecommunications, the Director, OSTP, will exercise that authority as specified in Executive Order 12472 (49 FR 13471; 3 CFR, 1984 Comp., p. 193). \n(b) In this connection, and concur-\nrently with the war or national emer-gency proclamation by the President, the Director will: \n(1) Authorize the continuance of all \nfrequency authorizations issued by the National Telecommunications and In-formation Administration (NTIA) and the Federal Communications Commis-sion (FCC), except as they may other-wise be modified or revoked by the Di-rector, OSTP, in the national interest; \n(2) Redelegate to the Secretary of De-\nfense the authority necessary to con-trol the use of the radio spectrum in areas of active combat, where such control is necessary to the support of U.S. military operations; \n(3) Close all non-government radio \nstations in the international broad-casting service as defined in the FCC rules and regulations, except those car-rying or scheduled to carry U.S. Gov-ernment-controlled radio broadcasts. \n§ 214.5 Responsibilities. \n(a) The Director, OSTP, will issue \nsuch policy guidance, rules, regula-tions, procedures, and directives as \nmay be necessary to assure effective frequency usage during wartime emer-gency conditions. \n(b) The FCC, in coordination with \nNTIA, shall issue appropriate rules, regulations, orders, and instructions and take such other actions not incon-sistent with the actions of the Direc-\ntor, OSTP, and the NTIA Emergency Readiness Plan for Use of the Radio Spectrum as may be necessary to en-sure the effective use of those portions of the radio spectrum shared by Gov-ernment and non-governments users. \n(c) The FCC shall assist the Director \nin the preparation of emergency plans pursuant to section 3(h)(3) of Executive Order 12472. \n(d) Each Federal Government agency \nconcerned shall develop and be pre-pared to implement its own plans, and shall make necessary preemergency ar-rangements with non-government enti-ties for the provision of desired facili-ties or services, all subject to the guid-ance and control of the Director. \n§ 214.6 Postattack procedures and ac-\ntions. \n(a) The frequency management staff \nsupporting the Director, OSTP, com-prised of predesignated personnel from the frequency management staffs of the government user agencies, NTIA and the FCC, will have proceeded to the OSTP relocation site in accordance with alerting orders in force. \n(b) Government agencies having need \nfor new radio frequency assignments or for modification of existing assign-ments involving a change in the fre-quency usage pattern shall, unless oth-erwise provided, submit applications therefor to the Director, OSTP, by whatever means of communication are available and appropriate, together with a statement of any preapplication coordination accomplished. The Direc-tor, OSTP, will review such applica-tions accomplish the necessary addi-tional coordination insofar as prac-ticable, consider all pertinent views and comments, and grant or deny, as he shall determine, the assignment of such frequencies. All concerned will be informed promptly of his decisions. \n(c) Non-Government entities having \nneed for new radio frequency assign-ments or for modifications of existing assignments will continue to submit applications therefor to the FCC, or in accordance with FCC instructions. Such applications shall be coordinated with the Director, OSTP, and granted subject to the approval of the Director, OSTP, or his delegate. \nVerDate Aug<31>2005 13:23 Nov 08, 2005 Jkt 205199 PO 00000 Frm 00748 Fmt 8010 Sfmt 8010 Y:\\SGML\\205199.XXX 205199"
} |
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] | {
"pdf_file": "TYLWGSX5OYKE27DHTQXUJTBMKMHMKY3B.pdf",
"text": "Attachment 3 \n \nPWSs with a History of Significant Non-Compliance in Tennessee \nFY1997 – FY2000 \n \n \nPWSID Name Means of Achievement \n \n0000115 Clarksburg Utility District 3 TCR vi olations. DWS-0038 issued. RTC Oct 00. \n0000455 Middleton Utility District 3 TCR viol ations. CRM and LOA on 28 Jul 00. DWS-0037 \nissued 30 Nov 00. RTC Jan 01. \n0000572 Red Boiling Springs CO 93-0587 iss ued Dec 93 and DWS-0005 issued Feb 00, Plant \nre-designed; RTC 1 Nov 96. No SWTR violation in \nFY00. 2 violations were reported Dec 00. RTC May 01. \n0000745 White House Utility District Equipment r epaired, RTC 1 Mar 99. No SWTR violations. \nRTC Oct 00. \n0000848 Cumberland Mountain Retreat DWS-9931 issued De c 99, RTC 1 Mar 99. Nitrate violation in \nFY00. RTC May 2001. \n0000958 Wildwood Estates DWS-9702 issued 25 Jul 97; DWS-9906 \nissued 15 Apr 99; and DWS-9939 issued \n21 Dec 99, Board Final Order. 1 TCR violation and \nVOC violations in FY2000. RTC Jun 01. \n0000961 Acorn Village MHP (Gabbard’s) CO 96-0471 iss ued Feb 00, RTC 20 Jan 99. Deactivated. \n0000962 Decalogue Stone County (Elijah DWS-9901 issued 27 Jan 99, RTC 8 Feb 99. No more TCR \nGospel Mission) violations in FY 00. Viol in Nov 01. RTC Dec 01. \n0000963 Steeple Chase Apartments A SCM held wi th Mid-America Apt Communities (Steeple \n0000964 Hidden Creek Apartments Chase, Hidden, Cr, and Hamilton Pointe) on 17 Jul \n97, with an LOA was signed;all three RTC Dec 97. \n0000965 Hamilton Pointe Apartments No violations by any of the three in FY00. \n0008033 Cold Springs II WS 5 TCR violations. DWS-0003 issued 11 Feb 00. Deactivated \nJun 00. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nNote: TCR and operational violations may occur over several compliance periods. EPA consi ders a system as having RTC \nwhen a system successfully monitors TC the following period. \n "
} |
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"pdf_file": "FVIKHA7GEB6QLKRNAPQD63GXPARVH3KX.pdf",
"text": "Town of Alton \n \nBudget Committee Meeting \nMinutes \n \nAPPROVED \n \nNovember 28, 2006 \n \nPresent: Stephen Miller; William Curtin; Elizabeth Dominick; Virgil MacDonald; \nLaurie Boyce, Terri Noyes (ACS Board Rep.), \nPete Shibley (Selectmen’s Rep.); E. Ru ssell Bailey, Town Administrator; \nKrista Argiropolis, Secretary; Tom Hoopes, Planning Board \nMembers of the Public \n \n \nI. CALL TO ORDER \n \nMr. Miller called the meeting to order at 6:06pm. \n \n \nII. ROLL CALL \n \nT. Noyes and L. Boyce arrived at 6: 06pm. E. Dominick arrived at 6:12pm. \n(SM, VM, WC, ED, SMc, TN, LB) \n \n \nIII. APPROVAL OF MEETING MINUTES – November 16, 2006 \n \nW. Curtin motioned to approve the minutes of 11/16/06 and V. MacDonald seconded the motion. \nThe motion passed by a vote of three, with three abstaining and three absent. (SM, VM, WC / \nabsent - ED / abstain – PS, TN, LB) \n \n \nIV. CORRESPONDANCE \n \nThere was no correspondence. \n \n \nV. OLD BUSINESS \n \nThere was no old business. \n \n \nVI. CIP – Tom Hoopes, Vice Ch air, Alton Planning Board \n \nMr. Hoopes reported on the CIP Budget. He stat ed that the members of the Planning Board \nconsisted of Jeremy Dube – Chairman, Cris Blackstone - Ex-Officio Member, Robert Eddie, and \nLoring Carr – School Board Representative. Mr. Hoopes stated that he saw Mr. Carr in one \nmeeting for approximately five minutes and he didn’t know what happened. \n Alton Bu dget Committee \nMeetin g Min utes \nNovember 28, 2006 \nPage 2 o f 4 \nHe announced that under the school department, the “Land Purchase” line item had been \nchanged because there was no presentation made so it was changed to say “To The Appropriate \nSchool System Upgrade”. He stated that t he Building Expansion Project under the Police \nDepartment was for a study to be done for building upgrades later. Mr. Hoopes offered to share the book with backup documentation with the me mbers of the Budget Committee, if it was \nneeded. \n \nThe CIP Budget for the Highway was reviewed. Mr. Bailey noted that the Budget Committee was \nnot going to vote on CIP that night because t he Selectmen needed to vote on the items first. \nThere was discussion about the vehicles, chipper, etc. There were no questions. \n \nThe CIP Budget for the Fire Department was reviewed. There was discussion about funds for \nengines and other vehicles. Mr. Bailey stated that the Ambulance ($37,244) was in the articles \nthat includes all the ambulance fees and a spec ial fund, but it will be included in the special \nrevenue that will be paid for out of the ambulance revenue. The Ambulance fund can pay for the \nvehicles, wages, etc., but it will be redefined by t he Selectmen later this year to say that it will \ninclude fuel, training, and other materials needed to make it more self-sufficient. \n \nThere was discussion about the chief asking firemen to not go on ambulance calls. Mr. Miller \nasked if it was due to political reasons. Mr. Baile y stated it was due to budget restrictions and that \nthe chief had the final say in who could or could not go on calls. There was a discussion about the \nvehicles that are mentioned in the requests. \n \nMs. Noyes asked why the Committee was reviewing CIP prior to the Selectmen. Mr. Bailey responded that it was due to timing. Ms. Noyes asked Mr. Hoopes what the position of his \ndepartment was in CIP. Mr. Hoopes responded that CIP was given to the planning board to \nreview because it involved long term planning. He stated they did not make cuts or recommendations. He stated they reviewed it to make sure it was valid requests but they did not \nmake cuts. \n \nMr. Hoopes spoke about the request to have an ambulance stationed in East Alton, which would \nbe manned by students. He spoke about the insura nce rates of the town vs. personal insurance \nrates. He stated that if they did not have enou gh coverage in one part of town, the insurance \nrates would go up in those areas. He stated that having the students avail able and the volunteers \nwas a bonus to the town and that he fully supported the program. \n \nMr. Hoopes spoke about the growth in Alton. He announced that Laconia was the only town in the \nentire Lakes Region with more building permits at that time. He spoke about the possibility of \nhaving impact fees that would go to the schools or to emergency services. When new subdivisions come in there would be a fund for future growth items, such as to fund more \nclassrooms in the school to accommodate or o ffset the growth in the school. It can only fund \ncapitol – not operating budget. \n \nThe CIP Budget for the Solid Waste Department was reviewed. Mr. Bailey explained there was a \nfund to add to the capitol plan. The plans are being finished to redesign the re-cycling and site. It \nis a long term project and will take two to three phases. There will be six recycling containers for \nseparating waste. This will help to cut cost s. There was discussion about the improvements and \ncost savings that will result from the re-design. \n \nThe CIP Budget for Parks & Recreation wa s reviewed. Mr. Bailey explained that the \napproximately $13,000 in the budget was not enough to pay for the rebuilding of the green \nmonster, materials and labor. They were looking to get some volunteer assistance with rebuilding \nthe green monster. Mr. Bailey stated the Beach Committee was asking for a fund to purchase a Alton Bu dget Committee \nMeetin g Min utes \nNovember 28, 2006 \nPage 3 o f 4 \nbeach so that Alton could have a public beach. Mr. Hoopes stated that Alton has the greatest \nmileage on Lake Winnipesaukee but there is not much of a public beach available for swimming. \n \nThe CIP Budget for the Police Department was re viewed. Mr. Hoopes spoke about the requested \nnetwork file server and stated that it was an estimate. There were no other questions. \n \nThe CIP Budget for the School Department was reviewed. Mr. Miller asked what the upgrades \nwere for that were requested. Mr. Hoopes stated it was first stated as being for a land purchase \nbut that there was never any follow-up information or presentations given about it, so it was re-\nworded as being for upgrades. Mr. Bailey reminded the Committee that the School Board would word the warrant article. There was a discu ssion about the Fire Suppression System for the \nschool. Ms. Noyes stated that whether the build ing was renovated or not, the school still needed \nto implement the system and the money would ha ve to be used for it. Mr. Shibley explained that \nthe money could not be used for anything other than what it was requested for in a warrant \narticle. \n \nThe CIP Budget for the Administration budget. Mr. Bailey stated the line item for sidewalks was for new sidewalks or for maintaining current side walks. Mr. Bailey spoke about the line item for \nseptic and the possibility of implementing a town septic system. There were no other questions. \nMr. Miller thanked Mr. Hoopes for his presentation and comments. \n \nThe Committee reviewed and discussed the Special Warrant Articles. Mr. Bailey reviewed the \nbudgeted amounts for the previous year. The Co mmittee reviewed the new budgeted amounts. \nMr. Bailey noted there was a new program call ed CASA – Court Appointed Special Advocates. \nThere was a discussion about the various programs such as the VNA, Genesis, Medication \nBridges, Youth Service Bureau, etc. Mr. MacDon ald stated that Genesis came to the school to \noffer services. Ms. Noyes stated that Genesis, when it came to the school, that the students were \ntreated as patients and paid via insurance or as self -pay but were not there as a crisis treatment \nprovider to walk-ins. There was a discussion a bout the re-purchase of the Long lot. There were \nno other questions. \n \n \nXII. NEW BUSINESS \n \nMr. Miller suggested that COLA (Cost Of Li ving Allocation), which Alton pays about $66,000 a \nyear, and asked if the Committee thought it m ade sense to hand the money to the department \nheads to hand out as merit pay. Mr. Shibley stated they would have to do the policy over again if that was the case and t hat he, Mr. Miller, could not make that change. Mr. Shibley stated that he \ncould make that recommendation to the Selectmen but that it would be up to the Selectmen to \nconsider this. Mr. Miller noted he was not recommending this change for this year. \n \nThere was no other new business. \n \n \nXIII. PUBLIC INPUT \n \nThere was no public input. \n Alton Bu dget Committee \nMeetin g Min utes \nNovember 28, 2006 \nPage 4 o f 4 \n \nXIV. AJOURNMENT \n \nMrs. Boyce motioned to adjourn and Mr. Curtin seconded the motion. The motion passed \nunanimously. (SM, VM, WC, LB, ED, TN, PS) \n \nThe next meeting is scheduled November 30, 2006 at 6pm. \n \nThe meeting adjourned at approximately 7:43pm. \n \nRespectively Submitted, \n \n \n \nKrista A. Argiropolis \nKeeper and Transcriber of Minutes "
} |
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"pdf_file": "4RPOXAYQCNHNFQZMBDNNZAZUSVYDBPQJ.pdf",
"text": "Immunization Registry Progress in\nWisconsin\nNote: Unless otherwise stated, the information in this fact sheet was obtained from data and information submitted\nby the program manager or representative from the immunization program in Wisconsin. \nImmunization Coverage in Wisconsin\nAccording to National Immunization Survey (NIS) data for July 1997 to June 1998, the\npercentage of children 19-35 months of age who were up-to-date with 4 doses of diphtheria,\ntetanus, pertussis, 3 doses of poliomyelitis, and 1 dose of measles, mumps, rubella vaccine was\n78%.\nFacts about the Wisconsin Immunization Registry (WIR):\n WIR is very excited about the recent progress in registry development. Because of earlier\nsetbacks caused by the original software vendor QS Inc. being absorbed by HumanSoft\nand then HumanSoft going out of business, there was a great deal of pessimism by both\npublic and private providers concerning whether or not an immunization registry would\nbecome a reality. To date, WIR’s new software developer has been very cooperative and\nhas stayed on schedule. Pilot testing of the web-based system is set to begin in\nSeptember 1999.\n WIR is currently being developed under direction of the Immunization Program of the\nDivision of Public Health, and in cooperation with the Division of Health Care Finance,\nDepartment of Health and Family Services. Public and private providers will have direct\naccess to the central registry via the Internet and/or telephone modem. In addition to\ndirect access, software is also being developed to provide stand a alone provider\nimmunization registry that will be interfaced to and synchronized with the WIR Central\nRegistry. A standard interface for existing provider immunization registries will be\ndeveloped using the CDC recommended Health Level 7 (HL7) Standard for computer\nexchange of immunization data. Therefore, providers will have the option of a stand\nalone or web-based immunization registry, or they can continue to use their existing\nsystem. \nOther registry plans, accomplishments, and successes\n A significant accomplishment is WIR’s partnership with the Division of Health Care\nFinance (DHCF). The fiscal agent for the Medicaid Program is the vendor chosen to\ncomplete the project. The DHCF has a significant interest in the registry in that it will\nassist managed care agencies to gather data from non-affiliated providers and therefore\nsupport them in meeting immunization coverage requirements.\n WIR has created an Immunization Registry Advisory Workgroup made up of\nrepresentatives of public and private providers, managed care, DHCF and the Marshfield\nClinic. The Workgroup gives overall direction to registry development by reviewing\n“draft” documents and policies and procedures. WIR has maintained a close working relationship with the Marshfield Clinic. They have\ndeveloped the Regional Early Childhood Immunization Network (RECIN) which serves\ntheir numerous clinic sites in central and northern Wisconsin and also has linkages with\nmany public providers in their service area. An interface will exist between WIR and\nRECIN. \nSome challenges and barriers affecting registry progress\nWIR has not started the actual recruitment process to get private providers on board. However, t\nperiodic mailings have been sent out informing them of the status of registry development. In\naddition WIR has met with a number of major proprietary clinical services agencies to get their\ninput and share ideas. The Immunization Program as a whole is making a major effort to\nstrengthen the public/private partnership in regards to immunizations. The registry program has\ncreated the Wisconsin Council of Immunization Practices as an advisory group to the Program to\ngive direction on all aspects on vaccine delivery. Immunization Registry issues are a regular part\nof their meeting agenda. Any assistance regarding registry promotion would be most welcome.\nCurrent political or legislative factors affecting registry activity\nIt is the belief of WIR that the legislature is in support of the concept of Immunization Registry\ndevelopment. However, because of the delays in development, due in part to the demise of\nHumanSoft, they are taking a wait-and-see attitude regarding funding. WIR has sufficient funds\nfor registry development, but long term maintenance and support is not assured.\nHelpful immunization and immunization registry contacts in Wisconsin\nRegistry Contact Person:\nName: Dan Hopfensperger\nAddress: Wisconsin Division of Health\n1414 E. Washington Avenue, Room 251A\nP.O. Box 309\nMadison, WI 53701-0309\nPhone: 608.266.1339\nFax: 608.267.9493\nEmail: HOPFEDJ@dhfs.state.wi.us\nSuggestions for Mrs. Thompson’s involvement and support\nGeneral support of immunization issues and in particular registry development would be very\nhelpful."
} |
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"pdf_file": "3OHZBJVNLM4IAL6GLY3AKUQIVCNLPJLO.pdf",
"text": "page 1 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District for 2007-08\n Vocational and Educational Services for Individuals with Disabilities\nSpecial Education School District Data Profile for 2007-08\nThe Special Education School District Data Profile is prepared in accordance with the requirement of the Individuals with Disabilities Education Act (IDEA). Each State must have \na State Performance Plan (SPP) to evaluate the State's efforts to meet the requirements and purposes of the implementation of IDEA. The SPP is a six-year plan which describes \nNew York State's performance on 20 indicators. States must report annually to the public on the performance of the State in an Annual Performance Report (APR) and each \nschool district against the State's targets. New York State's SPP and the APR that describe these indicators in detail are available at \nhttp://www.vesid.nysed.gov/specialed/spp/home.html .\nThe following report reflects only quantifiable data collected by the State. Since performance of a school district in any indicator may be the result of unique circumstances within \na district, readers are encouraged to consider information provided by the district's administration in interpreting these data.\nEnrollment and Classification Rate\n 2007-08\nEnrollment of school-age students with disabilities on December 3 168\nDistrict enrollment (public and nonpublic school-age students - with and without disabilities) on the first Wednesday \nin October956\nSpecial education classification rate 17.6%\nEnrollment of preschool students with disabilities on December 1 5\nIndicator 1: Graduation Rate of Students with Disabilities\n 2007-08\n(2004 Total Cohort four years later as \nof June 30, 2008)2007-08\n(2003 Total Cohort five years later as \nof June 30, 2008)\nNumber of students with disabilities who first entered 9th grade anywhere (or \nif ungraded, became 17 years old) in 2004-0521 \nNumber of students with disabilities who first entered 9th grade anywhere (or \nif ungraded, became 17 years old) in 2003-04 12\nGraduation rate 23.8% 33.3%\nState target for 2007-08 38% or higher No State Target\nMeets State target? Not Applicable* Not Applicable\n* A graduation rate is provided only if at least 30 students with disabilities are reported in the first row. page 2 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 2: Drop-Out Rate of Students with Disabilities\n 2007-08\n(2004 Total Cohort as of June 30, 2008)\nNumber of students with disabilities who first entered 9th grade anywhere (or if ungraded, became 17 years old) in \n2004-05 school year21\nDrop-out rate after four years 0%\nState target for 2007-08 19% or lower\nMeets State target? Not Applicable*\n* A drop-out rate is provided only if at least 30 students with disabilities are reported in the first row.\nIndicator 3: State Assessments\nParticipation in State Assessments2007-08\nGrades\n3-8\nEnglish Language \nArts (ELA)Grades\n3-8\nMathHigh School\nEnglish Language \nArts (ELA)High School\nMath\nEnrollment of students with disabilities for participation rate 88 88 Less Than 40* Less Than 40*\nParticipation rate 99% 98% * *\nState target for 2007-08 95% 95% 95% 95%\nMeets State target? Yes Yes * *\n* Participation rate is provided only if at least 40 students with disabilities are reported in the first row.\nPerformance on State Assessments and Adequate Yearly Progress \n(AYP)2007-08\nGrades\n3-8\nEnglish Language \nArts (ELA)Grades\n3-8\nMathHigh School\nEnglish Language \nArts (ELA)High School\nMath\nEnrollment of students with disabilities for performance \naccountability87 86 Less Than 30** Less Than 30**\nScore on performance index 123 150 ** **\nState target for 2007-08 101 110 124 134\nMeets State target? Yes Yes ** **\nMade AYP? Yes Yes ** **\n** A performance index score is provided only if at least 30 students with disabilities are reported in the first row. page 3 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 4: Suspensions/Expulsions\nLong-term Suspension Rate 2007-08\nNumber of students with disabilities suspended out-of-school for more than 10 days 1\nNumber of students with disabilities enrolled on December 3 168\nPercent of students with disabilities suspended out-of-school for more than 10 days 0.6%\nState target for 2007-08 2.7% or lower\nMeets State target? Yes\nIndicator 5: School-age Least Restrictive Environment (LRE)\n 2007-2008\nNumber of students with disabilities ages \n6-21 on December 3162\n Percent of students with disabilities in general \neducation program for:In\nseparate\nschools / facilitiesIn\nOther\nSettings80% or\nmore of\nthe day40 to 79%\nof the dayLess than\n40% of\nthe day\nPercent of students ages 6-21 in each setting 77.8% 18.5% 3.7% 0% 0%\nState target for 2007-08 More than 53.1% No State Target Less than 24.6% Less than 6.8% No State Target\nMeets State target? YesNot Applicable Yes Yes Not Applicable\nIndicator 6: Preschool Least Restrictive Environment (LRE)\nThe data for this indicator are not presented because the LRE reporting categories for preschool children with disabilities are under review by the United States Department of \nEducation. page 4 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 7: Preschool Outcomes\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nPositive\nSocial - Emotional \nSkillsAcquisition and \nUse of Knowledge \n& SkillsUse of\nAppropriate Behaviors\nto Meet\ntheir Needs\nNumber of preschool students with disabilities evaluated for progress between entry into \npreschool special education and exit from preschool special education\nPercent of preschool students with disabilities who demonstrate improvement\nState target for 2007-08 To Be Established To Be Established To Be Established\nMeets State target?\nIndicator 8: Parental Involvement\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of completed parent surveys returned\nPercent of parents who reported that schools facilitated parent involvement to improve services and results for \nstudents with disabilities\nState target for 2007-08 87.5% or higher\nMeets State target?\nIndicator 9: Disproportionality - Identification for Special Education\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in special education and \nrelated services that was the result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable page 5 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 10A: Disproportionality in Specific Disability Categories\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in specific disability categories \nthat was the result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable\nIndicator 10B: Disproportionality in Special Education Placements\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in particular settings that was \nthe result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable\nIndicator 11: Timely Evaluations (Child Find)\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nPreschool School-age\nNumber of students for whom parental consent to evaluate was received (July 1, 2007 to June 30, 2008)\nNumber of students whose evaluations were completed within the State established timeline\nNumber of children whose evaluations were not completed within State established time lines, but for reasons that \nare considered to be in compliance with State requirements\nCompliance Rate [Line 2 divided by (Line 1 minus Line 3)*100]\nState target for 2007-08 100% 100%\nMeets State target? page 6 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 12: Early Childhood Transition\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of children who were served in Part C and referred to Part B for eligibility determination 0**\nNumber of those referred determined to be NOT eligible and whose eligibilities were determined prior to their third \nbirthday**\nNumber of those found eligible who had an IEP developed and implemented by their third birthday **\nNumber of children for whom delays in determination of eligibility or delays in implementing the IEP were caused by \nreasons that are in \"in compliance\" with State requirements**\nCompliance Rate [Line 3 divided by (Line 1 minus Line 2 minus Line 4) *100] **\nState target for 2007-08 100%\nMeets State target? **\n** 0 children referred from EI.\nIndicator 13: Secondary Transition\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of IEPs reviewed for students ages 15 and above\nPercent of IEPs of students ages 15 and above that include coordinated, measurable, annual IEP goals and transition \nservices that will reasonably enable the student to meet the post-secondary goals\nState target for 2007-08 100%\nMeets State target?\nDate the district reported correction of noncompliance for this indicator page 7 of 7 Sun May 02 00:24:42 EDT 2010 420807040000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nLafayette Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 14: Post-School Outcomes\nData for this indicator will be posted beginning June 2008, in accordance with the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html .\n 2007-08\nNumber of students interviewed to assess post-school outcomes one year after leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school AND have been competitively employed within one year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school within one year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and have been competitively employed within \none year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school, have been competitively employed, or both, within one year of leaving high school (sum of \nthe three percentages above)\nState target for 2007-08 92%\nMeets State target?"
} |
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"pdf_file": "DOKB26RKCSAF5APEDPO4JYXMHMUCLPRI.pdf",
"text": "u \nF r. \nUTERI S~~~TESGENERALACCOUY\\IT~NG OFFICE 1 REGIONAL OFFICE 1 \nROOM 201 413 FIRSTAVENLE NORTH \nMr. M. L. Rlaylock \nActing Regional Administrator \nGeneral Services Admxnistratlon \nGSA Center \nAuburn, Washington 98002 \nDear Mr, Blaylock: \nWe recently completed a survey of the procurement of automobile \nand truck parts by Federal agenues. The purpose of this letter is \nto bring to your attention an apparent opportunity for the Federal \nSupply Service to help agencies achieve savings through the \nconsolidation of prosurements. \nWe found that Federal agencies were purchasmg repax parts \nfrom a multitude of suppliers under various methods of procurement, \nThus resulted in substantially varying prices for the parts. Some \nprocuring actxvxties were attemptmng to ccnsofidate their require- \nments in order to achieve more favorable dzscounts, whzle others \nwere purchasing 8x1 an it=-by-item basis. In no cases, however, \ndid we find that activities were sonsolldating thexr volumes wath \nother actlvlties to negotiate better prices. As a result of this \nfra,Pnaented procurement, local agencies were not taking advantage of \nthe potential drscounts available through volume procurement. \nWe examined the prxces paid for automotive parts by two Forest \nServxe garages, the Atomic Energy Commission (AEC), Richland, \nWashington, and five agenczes in the Seattle/Tacoma area maintaining \nthe largest vehxle repair faejellties. The actgvitles included Fort \nLewxs9 General Services Admznistratxon (GSA) Hotor Pool, Seattle \nDistrict Postal Service, NcChord Air Force Base (AFB), and Puget \nSound Naval Shipyard (PSNS). At each location, we compared przces \nof replacement parts for general-purpose vehrcles manufactured by \nFord, Chrysler, General Motors9 American Motors, and International \nHarvester. , \nAutomotive replacement parts can be classzfied rnto two \ncategories--original eqaupment manufacturer's (OEM) parts and \nalternate parts. OHM parts are sold by the vehicle manufacturer \nand ats dealers. Alternate parts are sold under different brand \nnames and przce lists than those Identified with the vehule \nmanufacturer. Alternate parts are marketed przmarzly through auto \nparts stores rather than vehicle dealers. Examples of alternate \nparts brand names include Flagner, Monroe, Maremont, Echlin, Halley, \nCarter, and Borg Warner. \nWe compared the prices paid for OEM parts with the pruzes that \nwould have been pald had the part been purchased through nonmandatory \nFederal Supply Schedules. To provide a common basis for comparison, \nwe related the prices paid for alternate parts to the przces \navailable on the Federal Supply Schedule for an eqtivalent OEM part. \nAn index system was developed whereby the Federal Supply Schedule \nprice was set at a base of 180, \nThe followmng table compares the average prrces paid by the \nactlvrties vLszted. \nPrice indexes \nOEM Alternate \nparts parts \nForest Service (Note a) \nPSNS \nFort Lewis \nGSA Motor Pool \nAtomic Energy Commission \n(Note b) \nMcChord AFH \nPostal Service 132 128 \n118 114 \n112 91 \n107 91 \n101 96 \n(Note c) (Note c) \n103 63 \naAverage for two National Forest offices vislted. \nbAtfantic Richfield Hanford Company (AEC cost-epe contractor). \ncj%zChord AFi3 used a contractor-operated parts store (COPARS) \nmethod of parts supply. Since the contractor bid relatively \nlow on OHM parts and high on alternate parts, separate \nIndexes for OHM and alternate parts were not comparable. \nThe combined Index was 95, \n-2- Thus table shows that AX and the Postal Service obtained the \nlowest prices for OEX parts and that the Postal Service was charged \nthe lowest prices for alternate parts. We attribute these variances \nprLmarily to the agencies' selections of sources and methods of \nprocurement. \nThe followzng examples illustrate the wide variances in prices \nnoted during our survey. \nPSNS generally purchased its alternate parts through \nblanket purchase agreements, PSNS would have saved \n45 percent If these parts could have been purchased under \nthe Postal Sexplce's local term contract. As an example, \nPSNS purchased a Carter carburetor for a Dodge truck from \nan alternate parts supplier, who was not required to \ndeliver, at a cost of $31.08. This same part was available \nthrough the Postal Service's local contract at a cost of \n$23.38 dativered to the vehicle maintenance facility. \nA Forest Service garage normally purchased OEM part-s \nfrom a parts store under a blanket purchase agreement. \nThe supplier generally purchased the parts from OEM dealers \nand frequently resold them to the Forest Service at list \nprices. For example, m November 1973, the Forest Servace \ngarage purchased for stock two Chevrolet wheels from the \nparts store at a total list price of $70.70. Had this \npurchase been made from the General Motors warehouse, the \ntotal price would have been $31.18, a difference of $39.52. \nOEMPARTS \nThe following table compares the OEM price indexes for each \nactivity and the price indexes the Federal Supply Service, Auburn, \nWashington, achieved in procurements for the Army in Asia. \nPrice indexes for OEM parts \nProcurement General American International \nactivity Motors Ford Chrysler Motors Harvester \nForest Service 179 - 140 116 \nPSNS 132 96 116 139 100 \nFort Lewis 138 97 118 100 100 \nGSA Motor Pool 127 100 114 100 100 \nAEC 100 99 106 100 98 \nPostal Service 130 90 113 100 100 \nFederal Supply \nService 100 71 87 100 90 \n-3- The lowest prices for General. hotors parts were obtamed by \nusing the Federal Supply Schedule contractor as tie source of \nsuPPlY* Also, most agencies were able to obtain Federal Supply \nSchedule przces for Amencan tifotors parts from either the contractor \nat Portland, Oregon, or American Motors dealers. The lowest prices \nfor Ford, Chrysler, and International Harvester parts were attained \nby usmg term contracts as the pnnclpal method of purchase. Both \nthe Postal Service and Federal Supply Sernce used this method of \nprocurement. ABC used purchase orders while the other four agencies \nused blanket purchase agreements. \nAlthough substantial savings could be achieved by ordering \nGeneral Motors parts from the Federal, Supply Schedule contractor, \nnest agencies were reluctant to use this source of supply because \nof the relatively longer delavery times evolved. The prlnclpal \ncontractor supply point is located at Beaverton, Oregon. \nALTEWATE PARTS \nAs shown in the table at page 2, price mdexes for alternate \nparts ranged from a high of 128 for the Forest Servzce to a low of \n63 for the Postal Service. Average prices paid by flare agencies \nvzslted exceeded Postal Servlce prices by from 44 to 103 percent. \nWhile zhese fxve agencies use blanket purchase agreements or \nmtindual purchase orders (AX) as their predomnant method of \nprocurement, the Postal Servzce uses term contracts. \nOPPOR~ITY FOR SAVINGS \nWe believe the Government could achmve substantial savmgs \nthrough the use of competitively awarded term contracts to meet \nthe combined auto parts needs of agencies at field locations. \nWhzle centralized purchases or procurements m large quantxties \nshould result in the lowest possible prices, field ixastallatlons \nmust consrder both price and dellveml time as maJor factors UI \ndetermning the best method of procureneut. Prompt delivery precludes \nthe hxgh cost of muntainmg large inventories. \nBlanket purchase agreements Tath local concerns are an \neffective means of securmg parts promptly. However, as demonstrated \npreviously, they are not an effective moans for attaming low prices. \nRegulations covering the use of blanket purchase agreements do \nnot encourage eompetitlon, apparently in order to avoid the cost \nof securing quotations for small orders (under $250). For example, \nthe Armed Senrices Procurement Regulations state: \n-4- -_II-I -_1*11_-- -------.-I-LII)~ -- --.... -I --- I_--- I ---- -- - -- - --I \n\"3-60411 Purchases Not in Excess of $250. Small purchases \nnot exceeding $250 may be accomplrshed wrthout securrng \ncompetltrve quotations If the prices are consldered to be \nreasonable. Such purchases shall be dlstrlbuted equitably \namong quaIlfled suppllers. When practical, a quotation ~111 \nbe sollcz&ed from other than the previous supplier prior to \nplacing a repeat order. The admlnlstratlve cost of verlfylng \nthe reasonableness of the price of purchases not m excess \nof $250 may more than offset potentaal savings m detecting \nInstances of overprlclng; therefore, action to verify the \nreasonableness of the price need be taken only when the \nbuyer or contractmg officer suspects that, or has mforma- \ntlon to andlcate that, the price may not be reasonable, \ne g., comparison to previous price pazd, personal knowledge \nof the Itern involved H \nThzs regulation seems to Ignore the fact that mdlvldual orders \nunder $250, on a day-to-day basis, when considered over a period of time \n(a year) ~~11 amount to several thousand dollars and that prices can be \nestablished m advance so that the cost of obtalnlng competltron and \nestabllshlng prices need be incurred only once a year rather than every \nday or every week. \nNotwlthstandlng the apparent shortcomrngs UI the crted regulation, \nFederal Procurement Regulations provide a means of satlsfylng both price \nand prompt dellvery ObJectlves by encouraging cooperative use by one \nagency of the local term contracts of another agency. The regulations \nalso state \n\"In furtherance of the econormcal and other advantages to \nbe galned from cross utlllzatlon of local term contracts, \nwherever possible the requirements of several offices UI \nthe same community should be combined and Included In a \nszngle contract.\" \nThe Report of The Commlsslon on Government Procurement endorses the \nuse of lndeflnlte dellvery/quantlty type term contracts as an effective \nmeans of obtalnlng price advantages through consolidated purchasing \nwithout IncurrIng warehouslng costs and sxmpllfylng ordering by elz.mlnatlng \nlndlvldual purchases. \nAgencies we vlslted had not establlshed multiple-use local term \ncontracts to meet their combined needs for commercial vehrcle parts. \nWe belleve that neither the blanket purchase agreements nor the \nnonmandatory GSA Federal Supply Schedule 1s the best method of procurement \n-5- for all purchases by field mstallatmns, because they do not provide \noptmum prices. Further, with respect to the Federal Supply Schedules, \ndellvery periods are frequently unacceptable to the agencies \nThe table on page2 shows that the Postal Service purchased alternate \nparts at slgnlflcantly lower prices than the other agencies vlslted, and \nthe table on page 3 shows that the Federal Supply Service purchased OEM \nparts (Ford, Chrysler, and InternatIonal Harvester) at substantially \nlower prrces. We belleve that local term contracts consolidating the \nneeds for alternate parts at the local level would result In prices at \nleast as low as those obtamed by the Seattle Dlstrlct Postal Servmze. \nWhile OEM price Indexes equivalent to those experienced by the Federal \nSupply Service most likely could not be achieved for multiple-use term \ncontracts XL local areas (because the volume would be less than under \nthe Federal Supply Servxce term contracts), we belleve there are opportunltles \nfor lower prices. For example, the followrng price Indexes appear \nat talnable. General Motors--115, Ford--go, Chrysler--95, IHC--95. \nSmce General Motors parts can be purchased at substantially lower \nprices under the Federal Supply Schedule, we have encouraged agencies to \nuse it whenever feasible. However, because of dellvery problems, It \nappears agencies ~~11 continue to purchase a maJor share of General \nMotors parts needs locally. Accordingly, local term contracts should \nalso result m savmgs for the purchase of General Motors parts. \nAs a result of our survey, agencies are seeklng ways to obtain \nlower prrces for automotive parts, lncludlng the use of term contracts. \nBecause Region 10 1s asslgned contracting responslbllzty for the natlonal \nFederal Supply Schedule and has extenszve experience In the procurement \nof vehicle parts we belleve your offrce IS In a unique posltlon to take \na lead role za negotratlng multiple use term contracts with local \nsuppliers Several agency offlclals told us that they would be receptive \nto the use of such local term contracts \nRECOMMERDATION \nTo reduce the cost of automotive parts purchased locally by Federal \nagencies, we recommend that you consider, In consultation with other \nagencies, the feaslblllty of negotlatlng multiple use term contracts \nwith local suppliers \n-6- We would lrke to thank you and your staff for the excellent coopera- \ntlon and assistance your staff has provided to us durmg this survey. \nYour comments and advrce OR the foregomg matters ml1 be appreciated. \nSmcerely yours, \nhIlIp A, Bernstem \nManager \ncc: R. W. Gutmann, PSAD \nS. Wolm, PSAD/GP \nC. Janku, PSAD/GP \nD Llttleton, Area Mgr. PSAD/GP \nReports Ihstributlon Sactlon, OAPS~ \nJ. Hammond, Deputy Dxector, PSAD/GP \nT. Norris, Assmtant Comptroller \nGeneral \n-7- "
} |
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"pdf_file": "DLCKN67W6R4KMBYO4VLF2H7MTP665HIJ.pdf",
"text": "4725 Federal Register / Vol. 72, No. 21 / Thursday, February 1, 2007 / Notices \nunder Group No. 824, was accepted \nNovember 28, 2006. \nThese surveys were executed to meet \ncertain administrative needs of the Bureau of Land Management. \n2. The Plat of Survey of the following \ndescribed lands was officially filed at the Nevada State Office, Reno, Nevada, on December 12, 2006. \nThe plat representing the dependent \nresurvey of a portion of the subdivisional lines, the subdivision of section 16, and metes-and-bounds surveys in section 16, Township 35 North, Range 37 East, Mount Diablo Meridian, Nevada, under Group No. 835, was accepted December 8, 2006. \nThis survey was executed to meet \ncertain administrative needs of the Bureau of Land Management. \n3. The above-listed surveys are now \nthe basic record for describing the lands for all authorized purposes. These surveys have been placed in the open files in the BLM Nevada State Office and are available to the public as a matter of information. Copies of the surveys may be furnished to the public upon payment of the appropriate fees. \nDated: January 19, 2007. \nDavid D. Morlan, Chief Cadastral Surveyor, Nevada. [FR Doc. E7 –1574 Filed 1 –31–07; 8:45 am] \nBILLING CODE 4310 –HC–P \nDEPARTMENT OF THE INTERIOR \nNational Park Service Delaware Water Gap National \nRecreation Area Citizen Advisory Commission Meeting \nAGENCY : National Park Service; Interior. \nACTION : Notice of public meetings. \nSUMMARY : This notice announces two \npublic meetings of the Delaware Water Gap National Recreation Area Citizen Advisory Commission. Notice of these meetings is required under the Federal Advisory Committee Act, as amended (5 U.S.C. App. 2). \nDATES : Saturday, March 10, 2007, 9 a.m. \nADDRESSES : New Jersey District Office, \nWalpack, NJ 07881. \nThe agenda will include reports from \nCitizen Advisory Commission members including committees such as Natural Resources, Inter-Governmental, Cultural Resources, By-Laws, Special Projects, and Public Visitation and Tourism. Superintendent John J. Donahue will give a report on various park issues, including cultural resources, natural resources, construction projects, and partnership ventures. The agenda is set up to invite the public to bring issues of \ninterest before the Commission. \nDate: Saturday, March 10, 2007, 9 \na.m. \nAddresses: New Jersey District Office, \nWalpack, NJ 07881. \nThe agenda will include election of \nDelaware Water Gap National Recreation Area Citizen Advisory Commission officers for the 2007 –2008 \nterm. \nFOR FURTHER INFORMATION CONTACT : \nSuperintendent John J. Donahue, 570 – \n426–2418. \nSUPPLEMENTARY INFORMATION : The \nDelaware Water Gap National Recreation Area Citizen Advisory Commission was established by Public Law 100 –573 to advise the Secretary of \nthe Interior and the United States Congress on matters pertaining to the management and operation of the Delaware Water Gap National Recreation Area, as well as on other matters affecting the recreation area and its surrounding communities. \nDated: January 17, 2007. \nJohn J. Donahue, Superintendent. [FR Doc. 07 –432 Filed 1 –31–07; 8:45 am] \nBILLING CODE 4312 –JG–M \nINTERNATIONAL TRADE \nCOMMISSION \nGovernment in the Sunshine Act \nMeeting Notice; [USITC SE –07–001] \nAGENCY HOLDING THE MEETING : United \nStates International Trade Commission. \nTIME AND DATE : February 20, 2007 at 11 \na.m. \nPLACE : Room 101, 500 E Street SW., \nWashington, DC 20436, Telephone: (202) 205 –2000. \nSTATUS : Open to the public. \nMATTERS TO BE CONSIDERED \n1. Agenda for future meetings: none. 2. Minutes. 3. Ratification List. 4. Inv. No. 731 –TA–739 (Second \nReview)(Clad Steel Plate from Japan) — \nbriefing and vote. (The Commission is currently scheduled to transmit its determination and Commissioners ’ \nopinions to the Secretary of Commerce on or before March 1, 2007.) \n5. Inv. No. 731 –TA–895 \n(Review)(Pure Magnesium from China) —briefing and vote. (The \nCommission is currently scheduled to transmit its determination and Commissioners ’ opinions to the \nSecretary of Commerce on or before March 1, 2007.) \n6. Outstanding action jackets: none. In accordance with Commission \npolicy, subject matter listed above, not disposed of at the scheduled meeting, may be carried over to the agenda of the following meeting. \nBy order of the Commission. \nIssued: January 29, 2007. \nMarilyn R. Abbott, Secretary to the Commission. [FR Doc. 07 –462 Filed 1 –30–07; 2:17 pm] \nBILLING CODE 7020 –02–P \nDEPARTMENT OF JUSTICE \nNotice of Lodging of Consent Decree \nPursuant to the Comprehensive Environmental Response, Compensation, and Liability Act \nIn accordance with Departmental \npolicy, 28 CFR 50.7, and 42 U.S.C. 9622(d), notice is hereby given that a proposed consent decree in United \nStates v. Agere Systems, Inc., et al., Civil \nAction No. AMD –07–155, was lodged \nwith the United States Court for the District of Maryland on January 19, 2007. \nIn a complaint filed with the consent \ndecree, the United States seeks injunctive relief and reimbursement and a declaratory judgment for costs incurred and to be incurred in connection with the Spectron, Inc. Superfund Site ( ‘‘Site’’), located in \nElkton, Maryland, from 98 settling defendants pursuant to Sections 106 and 107 of the Comprehensive Environmental Response, Compensation, and Liability Act (‘‘CERCLA ’’) 42 U.S.C. 9606, 9607. \nThese 98 settling defendants agree to finance and perform the surface remedy selected for the Site and to pay $507,300 to natural resource trustees to resolve the federal and state natural resource damage claims relating to the Site. In addition, settling defendants agree to finance and perform a future, yet unknown, groundwater remedy, provided that the cost estimate of such OU2 selected remedy does not exceed $10 million. \nThe Department of Justice will \nreceive, for a period of thirty (30) days from the date of this publication, comments relating to the proposed consent decree. Comments should be addressed to the Assistant Attorney General for the Environment andNatural Resources Division, P.O. Box 7611, Department of Justice, Washington, DC 20044 –7611, and should refer to United \nStates v. Agere Systems, Inc., et al., DOJ \nRef. # 90 –11–2–482/3. \nThe proposed consent decree may be \nexamined at the office of the United \nVerDate Aug<31>2005 16:47 Jan 31, 2007 Jkt 211001 PO 00000 Frm 00046 Fmt 4703 Sfmt 4703 E:\\FR\\FM\\01FEN1.SGM 01FEN1rwilkins on PROD1PC63 with NOTICES"
} |
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"pdf_file": "64PJRWTXR43NVMTQCZGEFDUZA3JMJTD7.pdf",
"text": "ONTARIO INTL\nAIRPORTCABLE\nFIELDRIALTO \nAIRPORT63rd District59th District\n62nd District61st District\n66th District 71st DistrictSIERRA AVE\nCITRUS AVE\n4TH STCHERRY AVE\nSLOVER AVEVALLEY BLVDARCHIBALD AVEL YTLE CREEK RD\nJURUPA STBANYAN ST\nJURUPA AVEE 4TH STALDER AVE\nSAN BERNARDINO AVEEAST AVE\nN EUCLID AVE\nRAMONA AVEE HOLT BLVDW ARROW HWY\nMERRILL AVE\nW 8TH ST\nE PHILADELPHIA STSUMMIT AVEGLEN HELEN\nPKWY\nWILSON AVESAPPHIRE ST\nFONTANA AVE\nS MILLIKEN AVE\nW HOLT BLVD\nW PHILLIPS STN VINEYARD AVEW 16TH ST\nW MISSION BLVD\nARMSTRONG RDS ARCHIBALD AVEDEVORE RDKENWOOD AVE\nILEX STW 25TH ST\nW BASE LINE RD\nMULBERRY AVEW COAST BLVD\nS CENTRAL AVEALMOND STSHINN RD\nBOHNERT AVE\nN HAVEN AVETURQUOISE AVE\nMOUNTAIN LN\nW RIALTO AVEALDER STLOCUST AVE\nONTARIO AIRPORTAIR GUARD STASan Bernardino National ForestAngeles National Forest\nSan Bernardino National Forest\nOntarioFontana\nUplandRancho CucamongaRialto\nChinoGlen AvonBloomingtonSan Antonio Heights\nSunnyslopeGLEN HELEN\nREG PARK\nJURUPA\nPARKCUCAMONGA\nGUASTIREG PARK\nSOUTHRIDGE\nPARKVETERANS\nMEM\nPARK JUNIPER\nPARKNORTH\nHERITAGE\nPARK\nVILLAGE\nPARKCYPRESS\nPARK\nCREEKSIDE\nLAKEMILLER\nPARKWINDROWS\nPARK\nCATAWBA\nPARKSHADOW\nPARKSEVILLE\nPARK\nOAK PARKNORTH\nTAMARIND\nPARKCIRCLE\nPARK\nJUNIPER\nPARK303030\n60\n608383\n10\n1010\n1515\n6666\nS Etiwanda AveSan Bernardino AveN Etiwanda AveArrow Rte\nClaremont BlvdN Riverside Ave\nWhittram AveHighland AveSierra Ave\nBeech Ave\nFoothill BlvdDouglas Ave\nPhiladelphia St012\nMilesAssembly District 62\nWest Part\nMap 1 of 3\nRiverside\nSan DiegoSan Bernardino\nMEXICOOrange8065\n6634\n64\n73\n757470\n765467\nImperialLos Angeles\n7759\n7136\n63\n60\n7938\n62\n786144\n725743\n5556\n6849\n53\n6942\nPacific\nO\nc\ne\na\nnMapped\nAreaLegend\nAssembly Boundary\nState BoundaryCounty BoundaryCity BoundaryMajor HighwayOther HighwayOther RoadRailroadOutside DistrictMajor LandmarksInstitutions ST BERNARDINE\nMED. CNTR.\nPACIFIC\nH.S.MOUNTAIN VIEW\nCEMETERY\nPIONEER MEMORIALCEMSAN BERNARDINO\nH.S.\nSAN BERNARDINO\nCOMM. HOSP .ARROWHEAD\nCC\nEL RANCHOVERDE GCSHANDIN\nHILS GCCAL STATE UNIV\nSAN BERNARDINO\nNorton Air\nForce BaseSAN BERNARDINO\nCOUNTY HOSPWILDWOOD\nPARKLAKE GREGORY\nREG PARK\nPERRIS HILL\nPARKBLAIR\nPARK\nFRISBIE\nPARK\nNUNEZ\nPARKSECCOMBE\nLAKE REC AREAENCANTO\nPARKDEL VALLEJO\nPARKSWITZER\nPARK\nHUDSON\nPARK\nGUTIERREZ\nPARKSan Manuel\nReservationSan Bernardino National ForestSan Bernardino\nNational Forest\nSan Bernardino National Forest\nSAN BERNARDINO\nINTERNATIONAL\nAIRPORTSan Bernardino Highland\nRialtoCrestline\nMuscoyLake Arrowhead\nW Kendall Dr\n40 ST\nN California St\nPacific St\nAlabama StCable Creek Channel\nW 27th StJune St\nGolondrina DrN Flores StW 26th\nSt N MedicalCenter DrLytle Cajon\nCreek\n19th St\nRoberts StJune Pl\nCourt StN Elmwood RdAlamo StN Madison St\nBaseline StPasito St\nLeslie St\nDel\nRosaDrCajon Blvd\nCypress StMonte\nVista Dr \nWarm Creek\nTippecanoe AveLincoln DrMuscupiabe Dr59th District\n62nd District63rd District\n5TH ST\n3RD STN E STN H STN SIERRA WAY\nSTERLING AVEN STATE ST\nVICTORIA AVE\nRIALTO AVEROSA AVEHARRISON ST\nVALENCIA AVE\nW HIGHLAND AVEN WATERMAN AVE\nE RIALTO AVE6TH ST30TH ST\n5TH STPEPPER AVEARDEN AVE\n13TH STWATER DR\nW 27TH STUNIVERSITY PKWY\n4TH STN ARROWHEAD AVEN MOUNTAIN VIEW AVE\nCHURCH AVEMUSCOTT STBELMONT AVE\nPINE AVE\nFOOTHILL DR\n2ND STORANGE ST\nG STBASELINE RD\n3RD ST\nE STMOUNT VERNON AVE RIVERSIDE AVE215\n2153018138\n18173\n30\n30330189\n18MANZANITADRLAKEDRLAKEGREGORYDR\nRIVERSIDE AVE\n66NORTHPARK BLVDLITTLE\nM\nOUNTAIN\nDREL\nECTRIC\nAVEAssembly District 62\nNortheast Part\nMap 2 of 3\nLegend\nAssembly Boundary\nState BoundaryCounty BoundaryCity BoundaryMajor HighwayOther HighwayOther RoadRailroadOutside DistrictMajor LandmarksInstitutions\n01\nMiles2\nRiverside\nSan DiegoSan Bernardino\nMEXICOOrange8065\n6634\n64\n73\n757470\n765467\nImperialLos Angeles\n7759\n7136\n63\n60\n7938\n62\n786144\n725743\n5556\n6849\n53\n6942\nPacific\nO\nc\ne\na\nnMapped\nArea HERMOSA \nCEMETERY\nHILLSIDE\nCEMETERYAGUA MESA\nCEMETERYLOMA LINDA\nUNIVERSITYREDLANDS\nCOMMUNITY \nHOSPITALSAN BERNARDINO\nVALLEY COLLEGE\nLOMA LINDA\nCOMMUNITY\nHOSPITALLOMA LINDA\nUNIVERSITY MEDICALMONTECITO\nMEMORIAL PARKPALM MEADOWS\nGC\nUC\nRIVERSIDEVETERANS\nPARK\nVETERANS\nPARKWEST VALLEY\nPARK\nTERRACE\nHILLS PARKJENNIE DAVIS\nPARK\nBOX SPRINGS\nMOUNTAIN PARKREID\nPARK\nHUNTER\nPARK\nBORDWELL\nPARKISLANDER\nPARKHIGHLAND\nPARKColtonRedlands\nRiversideSan Bernardino\nLoma Linda\nMoreno ValleyGrand\nTerrace\nHighgroveRialto\nRialtoHighland\nI-10\nE Main StCooley Ave\nGould St\nRiversideCanalCoulston StHardt StS Richardson\nSt\nLa Crosse AveDavidson\nSt\nCanal St\nGrand Terrace RdBarton\nRdSanta Ana River\nIndustrial RdSAN BERNARDINO \nINTERNATIONAL\nAIRPORT\n63rd District\n64th District65th District\n65th DistrictBARTON RDW RIALTO AVE\nPIGEON\n PASS\n RDS CADENA DR\nCHICAGO\n AVEMAIN STS I ST\n3RD STCENTER STW MILL ST\nE MILL ST\nWATKINS\n DR PERRIS\n BLVDCHURCH\n ST\nCALIFORNIA\n STREDLANDS BLVDOLIVE ST\nUNIVERSITY AVEBEAUMONT AVE\nKANSAS\n AVEE M ST\nMANZANITA AVELUGONIA AVEN RANCHO AVE\nCENTER\n STN CADENA DR\nCYPRESS AVETIPPECANOE\n AVE\nSAN\n MATEO\n STSTATE\n HWY\n 38\nCOLTON AVE\nSPRUCE\nSTE F STFAIRWAY DR\nMOUNTAIN\n VIEW\n AVEARROWHEAD\n AVE\nANDERSON\n ST\nBROOKSIDE AVETENNESSEE\n ST\nCOLUMBIA\nAVE\nW BLAINE STLAKESIDE\n AVE\nS RIVERSIDE\n AVEINLAND CENTER DR\nSLOVER AVE\nLOCUST AVEHEACOCK\n ST SIERRA\n WAY\nFERNAVEPEPPER\n AVE\nS HUNTS\n LN\n14 TH STLA CADENA DRSERPENTINE\n DRSAN BERNADINO AVEALABAMA\n AVE\nUNIVERSITY ST\nMT\n VERNON\n AVES 3RD ST\nHIGH\n STS E STWATERMAN\n AVE\nE WASHINGTON\n ST\nSANTIMOTEOCANYONRDTE\nRRACI\nNAB\nLVDREC\nHEC\nANY\nO\nNRD\nBOXSPRINGSBLVDWAGUAMANSARDVALLEYBLVDAUTOPLAZADR62nd District\n60\n609110\n10\n215215215Assembly District 62\nSoutheast Part\nMap 3 of 3\n01\nMiles2\nRiverside\nSan DiegoSan Bernardino\nMEXICOOrange8065\n6634\n64\n73\n757470\n765467\nImperialLos Angeles\n7759\n7136\n63\n60\n7938\n62\n786144\n725743\n5556\n6849\n53\n6942\nPacific\nO\nc\ne\na\nnMapped\nAreaLegend\nAssembly Boundary\nState BoundaryCounty BoundaryCity BoundaryMajor HighwayOther HighwayOther RoadRailroadOutside DistrictMajor LandmarksInstitutions CALIFORNIA ASSEMBLY DISTRICTS\nAssembly Redistricting Plan (SB 802), September 13, 2001\nThe Honorable Robert M. Hertzberg, Speaker\nState Capitol\nRoom 219Sacramento, CA 95814\nThe California State Assembly Rules Committee\nThe Honorable Dennis Cardoza, Chair\nP .O. Box 942849\nSacramento, CA 94249-0001\nThe California State Assembly Committee on Elections, \n Reapportionment, and Constitutional AmendmentsThe Honorable John Longville, Chair\nP .O. Box 942849\nSacramento, CA 94249-0001\nProduced at California State University Northridge\nDr. Jolene Koester, President\nEugene Turner, Project Director\nDepartment of Geography\n18111 Nordhoff St.\nNorthridge, CA 91330\nwith\nRubyjane Domingo, Pat Jolley, Meredith Leonard\n2001About the Maps\nThese maps present specific information\nabout the features comprising the borders of the\nAssembly Districts of California that were cre-\nated after the 2000 Census. Each of the 80 dis-\ntricts are represented by one to ten maps with\nthe number depending on the size of the district\nand the complexity of the features followed by\nthe boundary. In general, the boundaries follow\ncounty lines, city limit lines, and roads, but\noccasionally canals, streams, and small roads\nare followed.\nThe Assembly boundary data were creat-\ned in digital form from Census 2000 TIGER\nfiles for California by Pactech Incorporated of\nPasadena, CA. The boundary files were released\nin two forms, as a file of district polygons and\nas a file of line segments used to create the\npolygons. Where these line segments were iden-\ntified, those identifiers were used to label the\nmap boundaries. In addition, place boundaries\nwere created from the TIGER files.Other map information such as roads,\nrailroads, coastlines, and landmarks were\nobtained from Geographic Data Technologies.\nDynamap 2000 files (v10.1). Government land\nownership information such as national forest\nboundaries was obtained from a government\nland ownership layer prepared by the California\nTeale Data Center.\nMaps were prepared from the digital\nfiles using Arcmap 8.1 software from\nEnvironmental Systems Research Incorporated.\nAn Albers equal area projection was used for\nthe maps with a central meridian of 120 degrees\nwest longitude and standard parallels of 30 and\n40 degrees of latitude. Coordinates are based on\nNAD83."
} |
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"text": " \nYouth Resource Connections \nU.S. Department of Labor, Division of Youth Services \n200 Constitution Avenue, NW, Washington, DC 20210 (202) 693-3036, \nhttp://www.doleta.gov/youth_services/ \n \n \nVolume 11, Number 11 November 30, 2011 \n \n \nHEADLINES \n \nThe Employment and Training Administration’s WIA Youth Program Hosts its first \nLive Chat . The Employment and Training Administration’s Division of Youth Services \nhosted a Live Chat entitled “WIA YOUTH TALK” on Tuesday, November 29th. The Live \nChat was designed to provide a real time di scussion forum for indi viduals interested in \ngeneral WIA youth issues, share promising prac tices, and hear about what other WIA youth \nprograms are doing around the countr y. To view a transcript of the LIVE CHAT and \nparticipate in future chats, visit the Youth Connections Community of Practice at: \nhttps://youth.workforce3one.org/ . \n \nThe Employment and Training Administration Issues Advisory Notice on the \nAvailability of Assistive Technology Resources for Persons with Disabilities . The \nEmployment and Training Administration released Training and Employment Notice (TEN) \n16-11 , which informs the public workforce system about Assistive Technology (AT) \nresources for persons with disab ilities. The TEN provides a de finition of AT , outlines the \ntypes of AT, and summarizes funding so urces. To view the TEN, visit: \nhttp://wdr.doleta.gov/directi ves/corr_doc.cfm?docn=3096 . \n \nThe Employment and Training Administration Publishes Guidance on Selective \nService Requirements for Workforce Investment Act and Wagner-Peyser-Funded \nprograms . The Employment and Training Administration has released Training and \nEmployment Guidance Letter (TEGL) 11-11 , which provides information on the Selective \nService registration requirements for Workforc e Investment Act-funded services established \nby the Workforce Investment Act (WIA) § 189(h), codified at 20 CFR 667.250, and the \nMilitary Selective Service Act (5 0 U.S.C. App. 453), codified at 32 CFR Part 1605. To view \nthe TEGL, visit: http://wdr.doleta.gov/directives/corr_doc.cfm?docn=9313 . \n \nU.S. Departments of Education and Defens e to Launch “Learning Registry” Tools \nand Community. The U.S. Departments of Education and Defense announced the launch \nof “Learning Registry,” an open source co mmunity and technology system designed to \nimprove the quality and availability of learning resources in education. The Learning \nRegistry is also a comm unication system that allows existing educational portals and online \nsystems to publish, consume and share importan t information about learning resources with \neach other and the public, while respecting the privacy of individual users. For further \ndetails about the Department of Education's involvement in Learning Registry and related \ninitiatives, contact the Department's Office of Education Technology. To obtain additional \ninformation, visit: http://www.learningregistr y.org/. To view the press release, visit: \nhttp://www.ed.gov/news/pres s-releases/departments-edu cation-and-defense-launch-\nlearning-registry-tools-and-community . \n \n \nYYoouutthh RReessoouurrccee CCoonnnneeccttiioonnss \nTTeecchhnniiccaall AAssssiissttaannccee UUppddaattee ffoorr NNoovveemmbbeerr 22001111 1 YYoouutthh RReessoouurrccee CCoonnnneeccttiioonnss \nTTeecchhnniiccaall AAssssiissttaannccee UUppddaattee ffoorr NNoovveemmbbeerr 22001111 2FUNDING ANNOUNCEMENTS \n \nU.S. Department of Education Awards TRIO Grants . The U.S. Department of \nEducation has awarded TRIO Educational Oppo rtunity Centers (EOC) program grants to 128 \ngrantees in 44 states and Puerto Rico. The grants will fund counseling services and \ninformation on college admissions to qualified individuals who want to enter, or continue a \nprogram of postsecondary education. To view the press release, visit: \nhttp://www2.ed.gov/progr ams/trioeoc/index.html . \n \n \nOPPORTUNITIES FOR YOUTH, YOUNG ADULTS, AND TEACHERS \n The Brown Rudnick Charitable Foundation Corp. Unveils New Grant Program Designed to Help Inner-City Educators. The Brown Rudnick Charitable Foundation \nCorp. is accepting applications for its Communi ty Grant Program. The program was created \nto support frontline educators and will subsidize small, concrete projects to improve inner-city education in Boston, Hartford, Providence, or New York City. Eligible applicants must \nbe a \"frontline educational worker\" who is involved in education or a related field in one of \nthe noted communities eligible for grants. To obtain additional information and an \napplication, visit: \nhttp://www.brownrudnickcenter.com/foundation/communitygrant.asp\n. \nDeadline: Rolling. \n \nThe Alliance for Young Artists & Writers Invites Entries for its Scholastic Art & \nWriting Awards . The Alliance for Young Artists & Writers is accepting entries from \ncreative teens for its 2012 Scholastic Art & Wr iting Awards. The awar ds are designed to \nrecognize talented teen artists and writers in the United States and Cana da. Applicants are \ninvited to submit work in twenty-eight categories of art and writing, including film and animation, video game design, sculpture, photography, fashio n design, poetry, journalism, \nhumor, dramatic script, and science fiction. Eligible applicants must be students in grades 7-12 in a public, private, parochial, home-sch ool, or out of school program in the U.S. or \nCanada, or in an American school abroad. Fifteen graduating high school seniors will be awarded with Portfolio Gold Medals, which include a $10,000 scholarship. To obtain \nadditional information and an application, visit: \nhttp://www.artandwriting.org/\n. Deadline: December 15; January 15, 2012. \n \nYouth Service America and Sodexo Foundatio n Invites Applications for its Sodexo \nYouth Grants. Youth Service America and Sodexo Fo undation are accepting applications \nfor its Sodexo Youth Grants. The grants are designed to recognize service projects that \nengage students' peers, friends, families , neighbors, Sodexo employees, and other \ncommunity members in creative youth-inspired so lutions to ending childhood hunger in their \ncommunities. Eligible applicants must be be tween the ages of 5 and 25. Awardees will \nreceive $500. To obtain additional information and an application, visit: \nhttp://www.ysa.org/gr ants/sodexoyouth/\n. Deadline: January 17, 2012. \n \n \n \n \n \n \n \n YYoouutthh RReessoouurrccee CCoonnnneeccttiioonnss \nTTeecchhnniiccaall AAssssiissttaannccee UUppddaattee ffoorr NNoovveemmbbeerr 22001111 3 \nPeyBack Foundation Accepting Applications for At-Risk Youth Programs in Indiana, \nLouisiana, and Tennessee. The PeyBack Foundation is accepting applications for its \n2012 PeyBack Foundation Grant. This grant is designed to recognize programs that have a \ndirect benefit to children through relationships and activities. Eligible applicants must be nonprofit 501(c)(3) organizations serving econ omically disadvantage d children between the \nages of 6 and 18 in Indiana, Tennessee, and the New Orleans metropolitan area. Awards \nwill range up to $15,000. To obtain addition al information and an application, visit: \nhttp://www.peytonmanning. com/2012-peyback-foundation-grant-application-now-\navailable.php . Deadline: February 1, 2012. \n \n \nPUBLICATIONS \n \nCareer Clusters: Forecasting Demand fo r High School through College Jobs, 2008-\n2018. This report developed by Anthony P. Carnevale, Nichole Smith, James R. Stone III, \nPradeep Kotamraju, Bruce Seuernagel, and Kimber ly A. Greeen, identifies 16 career clusters \nthat represent the full array of related occupational opportunities and education \nrequirements. Report findings indicate that fo r those with high school diplomas, decent jobs \nstill exist, but there are not en ough to go around. Only one in three of high school-level \njobs will pay wages of $35,000 or more; in some cases, with experience, these jobs can \nprovide wages up to $50,000. In addition to the full national repo rt, Career Clusters \ncontains an executive summary an d a state-level analysis of jobs by career cluster. All \nthree documents are available online at: http://cew.georgetown.edu/Clusters . \n \nFederal Education Tax Benefits: Who Re ceives Education Tax Benefits and the \nEffect These Benefits Have on th e Price of College Attendance? This report \ndeveloped by the U.S. Department of Education’s National Center for Education Statistics at \nthe Institute of Education Sciences, applies IRS rules and data to a nationally representative \nsample of 2007–08 undergraduates to estimate who received education tax benefits and \nlooks at the extent to which these benefits sh aped their price of college attendance. To \nview the report, visit: \nhttp://nces.ed.gov/pubsearch /pubsinfo.asp?pubid=2012212 . \n \nWho Enrolls in Dual Enrollment and Other Acceleration Programs in Florida High Schools? This study developed by Angela Estaci on, Bridget A. Cotner, Stephanie D’Souza, \nChrystal A.S. Smith, and Kath ryn M. Borman, examines dual en rollment programs in Florida \n(collaborative programs allowing high school students to enroll in college-level courses and \nearn credit toward both a high school diplom a and a college degree or a career preparatory \ncertificate) and compares them with other acceleration programs offered, such as Advanced Placement (AP), International Baccalaureate (IB), and Advanced International Certificate of \nEducation (AICE). The study also describes the number and characteristics of grade 11 and \n12 students enrolled in acceleration programs overall and by district during 2006/07 and it \nexamines dual enrollment part nerships between high schools and colleges in nine sample \nschool districts. To vi ew the study, visit: \nhttp://ies.ed.gov/ncee/edlabs/projects/project.asp?ProjectID=288\n. \n \n \n \n \n \n YYoouutthh RReessoouurrccee CCoonnnneeccttiioonnss \nTTeecchhnniiccaall AAssssiissttaannccee UUppddaattee ffoorr NNoovveemmbbeerr 22001111 4 \nPROGRAM RESOURCES \nOn November 29, the Bureau of Labor Statistics hosted a Webinar entitled: Overview of \nthe BLS National Longitudinal Surveys Program. This webinar featured the U.S. \nBureau of Labor Statistics National Longit udinal Surveys. Assistant Director Jay \nMeisenheimer pro vided an overview of the Bureau of Labor Statistics National Longitudinal \nSurveys program, the population groups that have been surveyed by BLS, and the types of \ninformation collected in the surveys. Other topics discussed included: Who uses NLS data?, \nexamples of the types of research questions that have been examined using NLS data, and \nhow to obtain NLS data and documentation. To view and listen to the archived Webinar, \nvisit: http://apdu.org/ . \n \nNational Center for Educational Statistic s Announces Release of High School \nCareer/Technical Education Participation Web Tables. The National Center for \nEducational Statistics (NCES) released a set of six tables that presents information on the \nparticipation of public high school gradua tes of the class of 2009 in career/technical \neducation (CTE). The tables also include the percentage of graduates who earned credits in \nCTE overall, as well as in various occupational areas within CT E, and the average number of \ncredits earned in CTE and in occupational area s. Three tables focus on graduates in 2009, \nand three tables look at participation trends from 1990 to 2009. To view the tables, visit: \nhttp://nces.ed.gov/surveys/ctes/tables/index.asp?LEVEL=SECONDARY . \n \nFederal Communications Commission Offe ring Low-Cost Broadband & Computers \nfor Students & Families. The Federal Communications Commission (FCC) will launch \n\"Connect to Compete,\" an initiative to brin g low-cost broadband and computers to millions \nof low-income Americans, in the spring of 2012. Under this initiative, families eligible for \nthe National School Lunch Program can receive discounted monthly broadband internet, a \ncomputer, and free digital litera cy training. To obtain additional information, visit: \nhttp://www.fcc.gov/blog/low-cost-broadband-and-computers-students-and-families . \n \n \nWEB SITE \n \nNational Center for Educational Statistic s Announces Release of New State-Level \nData on State Education Reforms Website. The National Center for Educational \nStatistics announced the release of new state- level data on open enrollment policies \navailable on the State Education Reforms website. The State Education Reforms website, \nwhich draws primarily on data collected by organizations other than NCES, compiles and \ndisseminates data on state-level education reform efforts in five areas: 1) Accountability; 2) Assessment and standards;3) Staff qualificat ions and development; 4) State support for \nschool choice and other options; and 5) Student readiness and progress through school. To \nview the Web site, visit: http://nces.ed.gov/programs/statereform/\n. \n \n \nCALENDAR OF EVENTS \n \nMarch 4-7 . Tampa, FL. University of South Florida 25th Annual Children’s Mental Health \nResearch & Policy Conference. To obtain additional information, visit: \nhttp://cmhtampaconference.com/ . \n \n \n NOTICE: \n \nThe Employment and Training Administration is interested in hearing about new \nand innovative approaches which bring employers, educators and workforce \nsystems professionals together to serve our communities’ youth. If you would like \n \nto share projects or programs in your area, please e-mail your information to the \nDivision of Youth Services at youth.services@dol.gov . \n Thank you. \n \n \nYouth Resource Connections (YRC). The Department of Labor (DOL), Employment and Training Administration (ETA) does \nnot take responsibility for non endorsed DOL/ETA resources included in the YRC. \n \nWe welcome your input . Please let us know how these updates might be impr oved to better serve your needs. If you have \ncomments contact the: Division of Youth Services at (202) 693-3030 or e-mail youth.services@dol.gov . \n \nSubscribe/Unsubscribe to Youth Resource Connections: http://www.doleta.gov/youth_services . Click on the “Subscribe \nto E-mail Updates” button to complete subscription. \nYYoouutthh RReessoouurrccee CCoonnnneeccttiioonnss \nTTeecchhnniiccaall AAssssiissttaannccee UUppddaattee ffoorr NNoovveemmbbeerr 22001111 5"
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] | {
"pdf_file": "2GFKZ3FSJWFKVKALUPEYHSLSHEJ3OGA6.pdf",
"text": "050100150200250CHAPTER 11 FILINGS\n1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004\nCALENDAR YEAR216\n178\n166\n134\n9790\n7988125\n103\n84CHAPTER 11 FILINGS IN CONNECTICUT\nCALENDAR YEARS 1994 -- 2004"
} |
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"pdf_file": "KMTEGGFKCFAJV3ICJRDK3YR2OAFQJ22Y.pdf",
"text": "page 1 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District for 2007-08\n Vocational and Educational Services for Individuals with Disabilities\nSpecial Education School District Data Profile for 2007-08\nThe Special Education School District Data Profile is prepared in accordance with the requirement of the Individuals with Disabilities Education Act (IDEA). Each State must have \na State Performance Plan (SPP) to evaluate the State's efforts to meet the requirements and purposes of the implementation of IDEA. The SPP is a six-year plan which describes \nNew York State's performance on 20 indicators. States must report annually to the public on the performance of the State in an Annual Performance Report (APR) and each \nschool district against the State's targets. New York State's SPP and the APR that describe these indicators in detail are available at \nhttp://www.vesid.nysed.gov/specialed/spp/home.html .\nThe following report reflects only quantifiable data collected by the State. Since performance of a school district in any indicator may be the result of unique circumstances within \na district, readers are encouraged to consider information provided by the district's administration in interpreting these data.\nEnrollment and Classification Rate\n 2007-08\nEnrollment of school-age students with disabilities on December 3 455\nDistrict enrollment (public and nonpublic school-age students - with and without disabilities) on the first Wednesday \nin October3,985\nSpecial education classification rate 11.4%\nEnrollment of preschool students with disabilities on December 1 69\nIndicator 1: Graduation Rate of Students with Disabilities\n 2007-08\n(2004 Total Cohort four years later as \nof June 30, 2008)2007-08\n(2003 Total Cohort five years later as \nof June 30, 2008)\nNumber of students with disabilities who first entered 9th grade anywhere (or \nif ungraded, became 17 years old) in 2004-0534 \nNumber of students with disabilities who first entered 9th grade anywhere (or \nif ungraded, became 17 years old) in 2003-04 44\nGraduation rate 76.5% 81.8%\nState target for 2007-08 38% or higher No State Target\nMeets State target? Yes Not Applicable page 2 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 2: Drop-Out Rate of Students with Disabilities\n 2007-08\n(2004 Total Cohort as of June 30, 2008)\nNumber of students with disabilities who first entered 9th grade anywhere (or if ungraded, became 17 years old) in \n2004-05 school year34\nDrop-out rate after four years 0%\nState target for 2007-08 19% or lower\nMeets State target? Yes\nIndicator 3: State Assessments\nParticipation in State Assessments2007-08\nGrades\n3-8\nEnglish Language \nArts (ELA)Grades\n3-8\nMathHigh School\nEnglish Language \nArts (ELA)High School\nMath\nEnrollment of students with disabilities for participation rate 221 221 Less Than 40* Less Than 40*\nParticipation rate 97% 97% * *\nState target for 2007-08 95% 95% 95% 95%\nMeets State target? Yes Yes * *\n* Participation rate is provided only if at least 40 students with disabilities are reported in the first row.\nPerformance on State Assessments and Adequate Yearly Progress \n(AYP)2007-08\nGrades\n3-8\nEnglish Language \nArts (ELA)Grades\n3-8\nMathHigh School\nEnglish Language \nArts (ELA)High School\nMath\nEnrollment of students with disabilities for performance \naccountability214 213 33 33\nScore on performance index 144 158 170 155\nState target for 2007-08 101 110 124 134\nMeets State target? Yes Yes Yes Yes\nMade AYP? Yes Yes Yes Yes page 3 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 4: Suspensions/Expulsions\nLong-term Suspension Rate 2007-08\nNumber of students with disabilities suspended out-of-school for more than 10 days 3\nNumber of students with disabilities enrolled on December 3 455\nPercent of students with disabilities suspended out-of-school for more than 10 days 0.7%\nState target for 2007-08 2.7% or lower\nMeets State target? Yes\nIndicator 5: School-age Least Restrictive Environment (LRE)\n 2007-2008\nNumber of students with disabilities ages \n6-21 on December 3422\n Percent of students with disabilities in general \neducation program for:In\nseparate\nschools / facilitiesIn\nOther\nSettings80% or\nmore of\nthe day40 to 79%\nof the dayLess than\n40% of\nthe day\nPercent of students ages 6-21 in each setting 68% 14.5% 11.1% 4% 2.4%\nState target for 2007-08 More than 53.1% No State Target Less than 24.6% Less than 6.8% No State Target\nMeets State target? YesNot Applicable Yes Yes Not Applicable\nIndicator 6: Preschool Least Restrictive Environment (LRE)\nThe data for this indicator are not presented because the LRE reporting categories for preschool children with disabilities are under review by the United States Department of \nEducation. page 4 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 7: Preschool Outcomes\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nPositive\nSocial - Emotional \nSkillsAcquisition and \nUse of Knowledge \n& SkillsUse of\nAppropriate Behaviors\nto Meet\ntheir Needs\nNumber of preschool students with disabilities evaluated for progress between entry into \npreschool special education and exit from preschool special education\nPercent of preschool students with disabilities who demonstrate improvement\nState target for 2007-08 To Be Established To Be Established To Be Established\nMeets State target?\nIndicator 8: Parental Involvement\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of completed parent surveys returned\nPercent of parents who reported that schools facilitated parent involvement to improve services and results for \nstudents with disabilities\nState target for 2007-08 87.5% or higher\nMeets State target?\nIndicator 9: Disproportionality - Identification for Special Education\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in special education and \nrelated services that was the result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable page 5 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 10A: Disproportionality in Specific Disability Categories\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in specific disability categories \nthat was the result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable\nIndicator 10B: Disproportionality in Special Education Placements\n 2007-08\nDid the school district have disproportionate representation of racial and ethnic groups in particular settings that was \nthe result of inappropriate policies, practices and procedures?No\nState target for 2007-08No school districts will have disproportionality \nthat is the result of inappropriate policies, \npractices and procedures.\nMeets State target? Yes\nDate the district reported correction of noncompliance for this indicator if it did not meet the State target Not Applicable\nIndicator 11: Timely Evaluations (Child Find)\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nPreschool School-age\nNumber of students for whom parental consent to evaluate was received (July 1, 2007 to June 30, 2008) 59 88\nNumber of students whose evaluations were completed within the State established timeline 45 72\nNumber of children whose evaluations were not completed within State established time lines, but for reasons that \nare considered to be in compliance with State requirements11 8\nCompliance Rate [Line 2 divided by (Line 1 minus Line 3)*100] 93.8% 90%\nState target for 2007-08 100% 100%\nMeets State target? No No page 6 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 12: Early Childhood Transition\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of children who were served in Part C and referred to Part B for eligibility determination\nNumber of those referred determined to be NOT eligible and whose eligibilities were determined prior to their third \nbirthday\nNumber of those found eligible who had an IEP developed and implemented by their third birthday\nNumber of children for whom delays in determination of eligibility or delays in implementing the IEP were caused by \nreasons that are in \"in compliance\" with State requirements\nCompliance Rate [Line 3 divided by (Line 1 minus Line 2 minus Line 4) *100]\nState target for 2007-08 100%\nMeets State target?\nIndicator 13: Secondary Transition\nIf data are not provided for this indicator, see the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html for the school year in which this school district will \nreport data for this indicator.\n 2007-08\nNumber of IEPs reviewed for students ages 15 and above\nPercent of IEPs of students ages 15 and above that include coordinated, measurable, annual IEP goals and transition \nservices that will reasonably enable the student to meet the post-secondary goals\nState target for 2007-08 100%\nMeets State target?\nDate the district reported correction of noncompliance for this indicator page 7 of 7 Sat Mar 20 11:47:41 EDT 2010 660501060000 New York State Education Department\nSpecial Education\nSchool District Data Profile for\nHarrison Central School District \n Vocational and Educational Services for Individuals with Disabilities\nIndicator 14: Post-School Outcomes\nData for this indicator will be posted beginning June 2008, in accordance with the schedule posted at http://www.vesid.nysed.gov/sedcar/sppschedule.html .\n 2007-08\nNumber of students interviewed to assess post-school outcomes one year after leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school AND have been competitively employed within one year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school within one year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and have been competitively employed within \none year of leaving high school\nPercent of students who had IEPs, are no longer in secondary school, and who have been enrolled in some type of \npost-secondary school, have been competitively employed, or both, within one year of leaving high school (sum of \nthe three percentages above)\nState target for 2007-08 92%\nMeets State target?"
} |
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"pdf_file": "FOCUMOSF3I3TKMLBTGIAMN4HZRA6OBPT.pdf",
"text": "VA Mileage Reimbursements Going Up, McNerney Announces\n \n \nJanuary 31, 2008\n \n \nWashington, D.C. – Today, Congressmen Jerry McNerney (CA-11) announced that, beginning tomorrow, veterans will see their mileage reimbursement for travel to VA medical facilities more than double.\n“In order to access the VA services they’ve earned, some veterans are forced to travel many miles,” Rep. McNerney said. “With gas prices as high as they are that can be a huge burden. Increasing the mileage reimbursement is long overdue and I am proud that we included funding for it in this year’s budget.”\nBeginning tomorrow, February 1, the beneficiary travel reimbursement rate will increase from 11 cents per mile to 28.5 cents per mile. This is the first mileage reimbursement increase in 30 years.\nFunding for the mileage reimbursement increase was included in the Consolidated Appropriations Act of 2008, H.R. 2764.\n \n \n 1 / 1"
} |