1. To help improve the effectiveness of its sustainability policy, the Authority should revise the policy by May 2019 to more clearly differentiate between construction and operation phases of the high-speed rail system. Further, it should ensure that each objective in each section of the policy is associated with quantifiable metrics for evaluating implementation.
| Response: | |
| The Authority concurs with this recommendation. The Authority will revise its Sustainability Policy to more clearly differentiate between construction and operations. Since the end of audit fieldwork, the Authority has revised the implementation plan to match each existing policy objective with a quantitative metric, posted here: | ⑦ |
| Planned completion date: The Policy will be updated by May 2019. |
2. To allow it to evaluate the sustainability of the high-speed rail system's construction, the Authority should perform and document a review of its compliance with its existing quality controls related to ensuring the validity and completeness of contractor-reported data by May 2019. The Authority should also establish a formal process to perform such reviews periodically.
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| Response: The Authority concurs with this recommendation. The Authority improved its environmental and sustainability data gathering and analysis system in July 2017. As an additional improvement, the Authority will develop a quality assurance process to perform periodic reviews of its compliance with the quality controls related to validity and completeness of contractor-reported data. |
| The updated system has a data field validation feature, which is a quality control measure that involves a cross check at the data entry level, next level review and confirmation of data by PCMs, and a final data quality review and acceptance by the Authority. This process is enforced by the system and is ongoing and continuous. The recommended periodic reviews will verify that the above-described controls are functioning as expected. Planned completion date: May 2019 |
3. To help ensure it meets its sustainability goals, the Authority should comprehensively compare the three construction project's performance to their construction contractors' original baseline estimates on a quarterly basis by May 2019.
| Response: The Authority concurs with this recommendation. Since 2015, the Authority has collected and organized data which it uses to analyze construction activities related to air quality and greenhouse gas emissions. The Authority then compares that to the contractually identified baseline estimates; this comparison is done on a quarterly basis. The Authority compares the contractor's required performance for waste, absolute targets for recycling of concrete and steel and a percentage target for remaining nonhazardous waste, as recycling records are submitted. Other sustainability performance tracking, related to fuel usage, water usage, and recycling, had previously been analyzed and compared to baseline estimates on an annual basis. The Authority will begin comparison of these performance areas on a quarterly basis and will adjust the analysis to include the relationship to construction progress. | |
| Planned completion date: May 2019 |
4. To help ensure that its contractors proposed environmental impacts are reasonable and to measure the progress of its sustainable construction efforts over time, the Authority should, by November 2019, identify and track standardized measure - such as project miles - that will allow it to compare construction impacts across the high-speed rail system's different construction projects.
Response:
The Authority concurs with this recommendation. Currently, the Authority has a model that assesses program environmental impacts using standardized metrics, including tons of CO2e, kgCO2e/kg, kgCO2e/gallon, kgCO2e/kWh, normalized by miles and construction typology. The Authority is in the process of updating this model to incorporate refined project lengths and infrastructure typologies adopted in the Baseline and to incorporate relevant, validated data (e.g., tons of CO2e and environmental product declarations for actual materials installed) tracked on each construction package. This updated model will allow comparison across construction projects and support establishing targets for future construction contracts.
Planned completion date: November 2019
5. To increase the transparency of its reporting, the Authority should, by May 2019, expand its quarterly small business, DBVE, and DBE utilization reporting to account for the total value of all its contracts and to identify the reasons it has exempted specific contracts.
Response:
The Authority concurs with this recommendation. In an effort to increase transparency, the Authority will post the total value of all current contracts within the Small Business Program section of the Authority's website. The Authority will also post the total value of any contracts that require small business, DVBE and/or disadvantaged business, which will appropriately reflect the Authority's utilization percentages per state and federal guidelines.
While the Authority reports utilization on a quarterly basis for federally funded contracts, the state process, administered by the Department of General Services, only requires an annual report from all state agencies/departments. However, the Authority will create an internal process to closely align the state timeline to the federal quarterly process. In addition, a policy will be created that will clearly specify what contracts are exempt from small business, DVBE and/or disadvantaged business according to state and/or federal regulations, policies, and guidelines.
Planned completion date: May 2019
Again, we appreciate the opportunity to provide a response to our plans to implement the California State Auditor's recommendations. If you have any questions, please contact Paula Rivera, Chief Auditor, at paula.rivera@hsr.ca.gov or (916) 403-2679