At a time when schools and other public service providers are coping with major funding cuts and next year’s budget remains uncertain, yet another threat looms on the horizon — this one courtesy of the State Water Resources Control Board (SWRCB). The agency is proceeding with a rule-making that would cost school districts, cities, counties and small businesses hundreds of millions of dollars without first conducting a thorough analysis of its water quality benefits, its costs and whether there are less costly alternative strategies.
We need to continue improving water quality in California, but we need to proceed intelligently to ensure that regulations provide measurable environmental benefits and that we clearly understand their costs before approving them, and carefully consider any additional costs imposed during this difficult economic time.
That’s why the Coalition for Adequate School Housing (CASH) — representing 500 school districts serving 92% of California’s school children — has joined with the WATER Coalition (Workable Approach to Environmental Regulation) in opposition to SWRCB’s newest proposal to regulate storm water runoff.
Thousands of California school districts (along with local governments, recycling facilities, truckers, manufacturers and other businesses) currently comply with an Industrial General Storm Water Permit that requires them to manage storm water runoff through best management practices. The State Water Resources Control Board has proposed a revised storm water permit that would require that these public agencies and businesses comply with several new requirements that are over and above what the US Environmental Protection Agency mandates and will result in hundreds of millions of dollars in additional costs with no proven environmental benefits.
These new requirements would impact 220 school bus maintenance facilities (operated by school districts). We estimate the annual cost of compliance with the proposed inspection and monitoring requirements of the SWRCB proposal to be a minimum of approximately $30,000 per facility and as high as $130,000 (or more) per facility. In addition, though more difficult to quantify but no less real, cost of complying with the new requirements for other agencies and businesses that we work with will also be passed on to schools.
Like our WATER Coalition allies, school districts have been willing partners in the effort to improve water quality. We support continued progress on this front; however it needs to be accomplished without bankrupting public and private entities. This requires the State Water Resources Control Board to pay attention to the concerns being voiced. We are specifically concerned about the “sector-specific” approach, the use of numeric limits without sound science backing them up, the elimination of cost-effective group monitoring, and the lack of an economic impact study to inform policy development.
It is well-known that K-12 schools in California are dealing with draconian funding reductions at every level. However, here are a few specific relevant statistics: Since 2007-08, K-12 education funding has been cut by 20%. The Governor’s 2011-12 proposed State Budget would reduce K-12 funding by $2 billion more (a reduction of $330 per pupil). This represents the best-case scenario for schools. (The reduction could be a much as $4.8 billion for the next fiscal year.) All this while state funding to maintain schools has essentially been eliminated for five years, and the Governor’s proposed budget would extend this situation for two more years. Finally, the funding for the Emergency Repair Program which funds schools’ immediate health and safety facility and maintenance issues has been completely eliminated in the Governor’s proposed 2011-12 State Budget.
Put simply, every dollar that goes to meeting non-educational requirements is a dollar that does not go to educate California’s children. For this reason, C.A.S.H. strongly urges the SWRCB to be measured and reasonable in moving forward. The proposal on the table now is just the opposite.