SCO
Santa Cruz Flood Control District
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CITY OF SANTA CRUZ
Audit Report
FLOOD CONTROL SUBVENTIONS PROGRAM
San Lorenzo River Flood Control Project
March 28, 2018, through December 15, 2022
M M. C
ALIA OHEN
C
ALIFORNIA
S
TATE
C
ONTROLLER
August 2025
MALIA M. COHEN
CALIFORNIA STATE CONTROLLER
August 22, 2025
Mr. Jeremy Arrich, P.E., Manager
Division of Flood Planning and Improvements
Department of Water Resources
3310 El Camino Avenue, Suite 120
Sacramento, CA 95821
Dear Mr. Arrich:
The State Controller’s Office audited Flood Control Subventions Program claims submitted by
the City of Santa Cruz (the city) to the Department of Water Resources (DWR) for the San
Lorenzo River Flood Control (SLOR) Project. Our audit pertained to Project Claim Numbers
SLOR 40 through SLOR 42 for the period of March 28, 2018, through December 15, 2022.
The city claimed $2,003,119 for the aforementioned project during the audit period. Our audit
found that $1,920,980 is allowable and $82,139 is unallowable. The costs are unallowable
because the city failed to follow the DWR’s Guidelines for State Reimbursement on Flood
Control Projects to ensure that all claimed costs were allowable.
The State’s share of allowable costs is $1,344,686. The DWR reimbursed the city $1,261,965
during the audit period; therefore, the city is owed the remaining balance of $82,721.
If you have any questions regarding this report, please contact Efren Loste, Chief, Local
Government Audits Bureau, by telephone at 916-324-7226 or email at eloste@sco.ca.gov. Thank
you.
Sincerely,
Original signed by
Kimberly A. Tarvin, CPA
Chief, Division of Audits
KAT/rs
MAILING ADDRESS P.O. Box 942850, Sacramento, CA 94250
SACRAMENTO 3301 C Street, Suite 700, Sacramento, CA 95816 | 916.324.8907
LOS ANGELES 901 Corporate Center Drive, Suite 200, Monterey Park, CA 91754 | 323.981.6802
Mr. Jeremy Arrich
August 22, 2025
Page 2 of 2
Copy: Marisela Pavlenko, P.E., Program Manager
Division of Flood Planning and Improvements
Department of Water Resources
Matt Huffaker, City Manager
City of Santa Cruz
The Honorable Fred Keeley, Mayor
City of Santa Cruz
MAILING ADDRESS P.O. Box 942850, Sacramento, CA 94250
SACRAMENTO 3301 C Street, Suite 700, Sacramento, CA 95816 | 916.324.8907
LOS ANGELES 901 Corporate Center Drive, Suite 200, Monterey Park, CA 91754 | 323.981.6802
City of Santa Cruz Flood Control Subventions Program
Contents
Audit Report
Summary ............................................................................................................................ 1
Background ........................................................................................................................ 1
Audit Authority.................................................................................................................. 1
Objective, Scope, and Methodology ................................................................................. 1
Conclusion .......................................................................................................................... 3
Follow-up on Prior Audit Findings .................................................................................. 3
Views of Responsible Officials .......................................................................................... 3
Restricted Use .................................................................................................................... 3
Schedule—Total Project Costs ............................................................................................. 4
Finding and Recommendation .............................................................................................. 5
City of Santa Cruz Flood Control Subventions Program
Audit Report
Summary The State Controller’s Office (SCO) audited Flood Control Subventions
Program claims submitted by the City of Santa Cruz (the city) to the
Department of Water Resources (DWR) for the San Lorenzo River Flood
Control (SLOR) Project. Our audit pertained to Project Claim
Numbers SLOR 40 through SLOR 42, for the period of March 28, 2018,
through December 15, 2022.
The city claimed $2,003,119 for the aforementioned project during the
audit period. Our audit found that $1,920,980 is allowable and $82,139 is
unallowable. The costs are unallowable because the city failed to follow
the DWR’s Guidelines for State Reimbursement on Flood Control
Projects (Flood Control Guidelines) to ensure that all claimed costs were
allowable.
Water Code stipulates the percentage of state funding by project cost
category. Pursuant to Water Code section 12832, the DWR reimbursed the
city 90 percent of eligible costs claimed, with the remaining 10 percent to
be released subject to the completion of this audit. Based on our audit, the
State’s share of allowable project costs is $1,344,686. The DWR
reimbursed the city $1,261,965 during the audit period; therefore, the city
is owed the remaining balance of $82,721.
Background The State of California provides financial assistance to local agencies
participating in the construction of federal flood control projects. Under
the Flood Control Subventions Program (Water Code, Division 6, Part 6,
Chapters 1 through 4), the DWR pays a portion of the local agency’s share
of flood control project costs, including the costs of rights of way,
relocation, and recreation and fish and wildlife enhancements.
In accordance with Water Code section 12585.5, the DWR reimburses the
district for 70 percent of eligible costs associated with non-federal
expenditures, land acquisition, and relocations.
The DWR’s Flood Control Guidelines describe the compliance
requirements for local agencies seeking reimbursement for the State’s
share of federal flood control projects.
Audit We conducted this performance audit in accordance with Water Code
Authority section 12832, which requires the SCO to perform audits of flood control
projects. In addition, Government Code section 12410 provides the SCO
with general authority to audit the disbursement of state money for
correctness, legality, and sufficient provisions of law for payment.
Objective, Scope, Our audit objective was to determine whether the costs claimed by the city,
as presented in the Schedule, were allowable and in compliance with the
and Methodology
DWR’s Flood Control Guidelines. Our audit pertained to Project Claim
-1-
City of Santa Cruz Flood Control Subventions Program
Numbers SLOR 40 through SLOR 42 for the period of March 28, 2018,
through December 15, 2022.
To achieve our objective, we performed the following procedures:
• We gained an understanding of the city’s internal controls that are
significant to the audit objective by interviewing key personnel, by
completing an internal control questionnaire, and by reviewing the
city’s organization chart.
• We evaluated and assessed control activities for the claim preparation
process by inspecting documents and records, and by inquiring with
key personnel.
• We assessed the reliability of computer-processed data by reviewing
existing information about the data and the system that produced it; by
interviewing city officials knowledgeable about the data; and by
tracing data to source documents, based on auditor judgment and non-
statistical sampling. We determined that the data was sufficiently
reliable for the purposes of achieving our audit objective.
• We conducted a risk assessment to determine the nature, timing, and
extent of substantive testing.
• We reviewed the city’s prior SCO and single audit reports.
• We reviewed DWR’s engineering reports and/or claim evaluations
pertaining to the city’s claims.
• We determined whether the city received revenues that should have
been offset against the flood program expenditures.
• We reviewed the city’s claim detail for any condemnation interest, and
asked the city whether it had received interest on condemnation
deposits.
• We determined whether the city received from the DWR advances on
its flood control project expenditures.
• We verified through sampling that the claimed costs were supported
by proper documentation and eligible in accordance with the
applicable criteria. Based on our risk assessment, we tested all items
that were equal to or greater than the significant item amount
(calculated based on materiality threshold). We also tested additional
items that were valued less than the individual significant item
amount, based on auditor judgment and non-statistical sampling.
Based on errors identified in the selected sample, we expanded our
testing.
We tested the following expenditures:
o Labor – We tested all $50,513 in labor costs.
o Services and supplies – We tested $1,577,729 of $1,952,606 in
services and supplies costs.
For the selected sample, errors found were not projected to the
intended (total) population.
-2-
City of Santa Cruz Flood Control Subventions Program
We did not audit the city’s financial statements. We limited our audit scope
to planning and performing audit procedures necessary to obtain
reasonable assurance that claimed costs are allowable for reimbursement.
We conducted the audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objective. We
believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objective.
Conclusion The city claimed $2,003,119 in project costs for the period of March 28,
2018, through December 15, 2022.
Our audit found that $1,920,980 is allowable and $82,139 is unallowable.
The costs are unallowable because the city failed to follow the DWR’s
Flood Control Guidelines to ensure that all costs claimed were allowable.
Based on our audit, the State’s share of allowable project costs is
$1,344,686. The DWR reimbursed the city $1,261,965 during the audit
period; therefore, the city is owed the remaining balance of $82,721.
Follow-up on Our prior audit report on the city for the period of January 25, 2013,
through August 8, 2019, issued on September 28, 2022, disclosed no
Prior Audit
findings.
Findings
Views of We discussed our audit results with the city’s representatives during an
exit conference conducted on May 30, 2025. At the exit conference, the
Responsible
city’s representatives agreed with the audit results.
Officials
Restricted Use
This report is solely for the information and use of the city, the DWR, and
the SCO; it is not intended to be, and should not be, used by anyone other
than these specified parties. This restriction is not intended to limit
distribution of this report, which is a matter of public record and is
available on the SCO website at www.sco.ca.gov.
Original signed by
Kimberly A. Tarvin, CPA
Chief, Division of Audits
August 22, 2025
-3-
City of Santa Cruz Flood Control Subventions Program
Schedule—
Total Project Costs
March 28, 2018, through December 15, 2022
-4-
S
S
S
S
T
L
L
L
L
o
O
O
O
O
t
P r o je c
C la im
N u m b e
R 4 0
R 4 1
R 4 2
R 4 2
a l
t
r
C la im
C o s
$ 4 7
5 9
8 7
5
$ 2 ,0 0
e d
ts
8 ,6
6 ,2
7 ,7
0 ,5
3 ,1
5
0
5
1
1
0
0
6
3
9
A llo w a b le
C o s ts
$ -
-
-
-
$ -
A d ju s tm e n
to
C la im e d
C o s ts
$ ( 8 2 ,1 3 9
-
-
-
$ ( 8 2 ,1 3 9
t
)
)
S
S
ta
h a
7
7
7
7
te
r e
0 %
0 %
0 %
0 %
S ta te
S h a r e o f
C la im e d
C o s ts
$ 3 3 5 ,0
4 1 7 ,3
6 1 4 ,4
3 5 ,3
$ 1 ,4 0 2 ,1
5
4
2
5
8
5
0
9
9
3
S ta te
S h a r e o f
A llo w a b le
C o s ts
$ 2 7 7 ,5 5
4 1 7 ,3 4
6 1 4 ,4 2
3 5 ,3 5
$ 1 ,3 4 4 ,6 8
8
0
9
9
6
A d ju s tm e n t
to S ta te
S h a r e o f
C la im e d C o s ts
$ ( 5 7 ,4 9 7 )
-
-
-
$ ( 5 7 ,4 9 7 )
A m o
R e c e
b y th e
$ 3 0
3 7
5 5
3
$ 1 ,2 6
u
iv
C
1
5
2
1
1
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e d
ity
,5 5
,6 0
,9 8
,8 2
,9 6
0
6
6
3
5
A m o u n t
D u e th e C ity
P e n d in g A u d it
$ ( 2 3 ,9 9 2 )
4 1 ,7 3 4
6 1 ,4 4 3
3 ,5 3 6
$ 8 2 ,7 2 1
City of Santa Cruz Flood Control Subventions Program
Finding and Recommendation
The city claimed $2,003,119 in project costs for the SLOR Project during
the audit period. We tested $1,628,241 of these claimed costs, and
identified a total of $82,139 in unallowable costs.
This amount represents an accounts payable invoice accrual recorded on
June 30, 2020, and subsequently reversed on October 22, 2020. Therefore,
the expenditure was nulled, and no payment was due or issued to the
vendor. As a result, the State’s share of allowable costs should be reduced
by $57,497, as shown in the following table:
-5-
S
T
e
o
R
r v
t a
e
ic
l
im
C
e s
b
a
u r s
t e g
a n d
e
o
m
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S u
e
p
n
p
t
lie s
U
$
$
n a llo w a
C la im e
C o s t s
8 2 ,1
8 2 , 1
b
d
3
3
le
9
9
S
S
t
h
a
a
t e
r e
7 0 %
R
$
$
R e d u c t io n in
e im b u r s e m e
D u e t h e C it y
5 7 ,4 9
5 7 , 4 9
n
7
7
t
FINDING—
Unallowable
services and
supplies costs
Section VI, Part D.1 of the DWR’s Flood Control Guidelines states,
in part:
The local agency must keep and maintain a complete, accurate, and
itemized record of any cost for which state reimbursement is requested…
Until such time as the final audit is made, the local agency must maintain
its record of project expenditures. If the final review of project costs
indicates that previous payments require adjustment, the local agency
will be expected to reimburse the State for overpayments.
The city failed to follow the Flood Control Guidelines to ensure that all
claimed costs were allowable.
Recommendation
We recommend that DWR reduce the retention balance by the State’s
share of $57,497. In the future, the city should also ensure that claimed
costs are eligible for reimbursement under the Flood Control Guidelines.
State Controller’s Office
Division of Audits
Post Office Box 942850
Sacramento, CA 94250
www.sco.ca.gov
S25-FLC-0001