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An Audit of the Dam Safety Program at the Commission on Environmental Quality

July 2020

Summary Analysis

The Commission on Environmental Quality’s (Commission) implemented processes to identify the condition of dams it regulates and concentrated its efforts on the most hazardous dams in the state as required by statute. Specifically, the Commission:

  • Implemented processes that align with key requirements to identify the condition of dams it regulates through inspections.
  • Concentrated its efforts on the most hazardous dams in the state as required by statute, by focusing inspections on dams that have the potential to cause the greatest amount of loss and damage in the case of malfunction or failure.
  • Maintained accurate data for its regulated dams, including inspection data and records of emergency action plan submissions.

It completed 88 percent of inspections within the required time frame of five years, and during inspections it revisited deficiencies identified during previous inspections to determine if those were corrected by dam owners.

However, in responding to dam deficiencies, it did not consistently communicate with dam owners through dam inspection exit interviews and requests for corrective action plans, and it had not updated its enforcement policy to include current enforcement procedures. Additionally, the Commission did not have a complete and current emergency action plan for all dams required to have one.

 Jump to Overall Conclusion

The Commission implemented processes that align with key requirements to identify the condition of dams it regulates through inspections.

Jump to Chapter 1-A 

The Commission is not always meeting the five-year requirement for conducting inspections. The Commission performed timely inspections of 88 percent of all the high- and non-exempt significant-hazard dams identified in its records as of January 17, 2020. The Commission prioritized inspections of the most hazardous dams in the state as required by statute; however, the Commission should document its approach to prioritize inspections to ensure consistency and inspect certain dams within five years as required.

Jump to Chapter 1-B 

The Commission’s inspection process includes following up on prior deficiencies to determine if dam owners have addressed them.

Jump to Chapter 2-A 

In responding to dam deficiencies, the Commission did not consistently communicate with dam owners through dam inspection exit interviews and requests for corrective action plans, and it had not updated its enforcement policy to include current enforcement procedures.

Jump to Chapter 2-B 

The Commission did not have a complete and current emergency action plan for all dams that required them. As of January 17, 2020, the Commission had received submissions for emergency action plans (EAPs) for 77 percent of the high- and non-exempt significant-hazard dams that are required to have an EAP. Dam owners are not consistently updating their EAPs or conducting required reviews of their plans with local emergency management personnel.

Jump to Chapter 3 

For regulated dams, which the Commission has identified and documented in the Dam Safety Module (Module), it maintained dam and inspection data that is accurate and complete. The Commission also maintained accurate data on the EAPs associated with each dam. Additionally, the Commission has implemented controls over the Module to ensure data integrity is maintained and has processes in place to ensure the continuity of the Module.

Jump to Chapter 4 

Graphics, Media, Supporting documents

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