I&E Plan Requirements

The State Water Board Evaluation staff reviews the CUPA's I&E plan as part of the evaluation process, focusing on sections related to the UST program. Any discrepancies or inconsistencies with UST regulations or the HSC may be noted in the summary of findings.

Common issues found CUPA's I&E Plan:

• Incorrect UST Regulations and HSC cited
• Incorrect penalty amount cited
• Use of the word "suspension" in reference to the UST operating permit
• Language in the I&E plan is less stringent than UST regulations or HSC

Additional guidance documents for the I&E plan are available on the CalEPA Inspection and Enforcement Resources for Unified Program Agencies page.

Note: With the Chapter 16 rewrite, new requirements for the I&E plan will be outlined in 2026. Once the proposed rewrite is finalized, this webpage will be updated to reflect those requirements. Information on the proposed Chapter 16 rewrite can be found on the Proposed Chapter 16 Rewrite Regulations page.