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Attachment 2 <br />LOCAL GOVERNMENT FINANCIAL TEST AND LOCAL <br />GOVERNMENTiRESPONSE <br />COMMENTS <br />l 1 1. <br />Commentor #1— City of Watsonville <br />The commentor proposes modifying the unqualified independent certified public accountant <br />opinion requirement by allowing a qualified opinion for a fixed asset exception. The commenter <br />indicates that while an unqualified opinion is the preferred opinion for governmental audits, <br />some local governments including the City of Watsonville have not maintained a sufficiently <br />detailed fixed asset ledger to obtain such an opinion. <br />Response #1— City of Watsonville <br />Staff concurs with EPA's analysis of and its final criteria for the Local Government Financial <br />Test. The requirement for the unqualified independent certified public accountant opinion adds <br />greater assurance that governments using the test can appropriately manage the assured landfill <br />costs. An unqualified independent certified public accountant opinion is also required for the <br />Financial Means Test, a financial assurance mechanism available to private operators. This <br />comment was noted but not accommodated. No modification was made to the regulations. <br />