In a Budget Change Proposal (BCP) released earlier this month, the California Department of Pesticide Regulation asked for $5 million in Department of Pesticide Regulation Fund monies during the 2021-22 fiscal year to support “vendor procurement and initial analysis, design, and development of the California Pesticide Electronic Submission Tracking (CalPEST) project.” (Find this and other BCPs in the bids area of Techwire’s website.) Among the takeaways:
- CalPEST is a “fully integrated information and document management system” aimed at dramatically improving “the current pesticide product registration process for pesticide product and device companies,” according to the BCP. Pesticide products and some “structural pest control devices” must be registered by CDPR before they can be sold in the state. The department evaluates registered pesticide products to ensure those that endanger the environment or don’t perform as claimed are not used. Its Pesticide Registration Branch (PRB), the primary liaison to pesticide product and device companies, gets about 5,000 submissions annually and maintains registrations for about 1,500 different registrants and 13,500 pesticide products. The registration process is paper-based and managed manually “with some supporting technology” and because of that, submissions have to be worked on “sequentially rather than concurrently.” This makes it difficult for staff to locate information quickly, requires the handling of large volumes of paper and leads to registration delays. The long registration process can also “financially impact registrants by delaying their ability to sell products in California” — and impact CDPR’s revenue stream since assessment fees can’t be assessed until products are registered and sold.
- CDPR has been in the process of implementing an electronic registration system “for several years.” In 2015-16, the department received resources for CalPEST, formerly known as the Pesticide Registration Database Management System or PRDMS, that included $1.96 million from the DPR Fund, plus $1.96 million in 2016-17, $400,000 in 2017-18, and $163,000 in 2018-19 “and thereafter.” Delays prompted the reversion of about $3.4 million from 2015-16 and 2016-17 and increased the 2017-18 appropriation “to make the full balance of project costs available” for the approved project. Delays were due to “excessive material deviations in the project’s Request for Proposal responses” which extended procurement. In 2017-18, CDPR hired a system integration vendor to develop and implement CalPEST. During design, DPR and the vendor “mutually agreed to terminate any remaining obligations.” CDPR expects “approximately $2 million of the 2015-16 project appropriation will revert to the DPR Fund when the encumbrance period ends on June 30, 2021.” CDPR “has implemented lessons learned from the initial vendor procurement and contract,” and has refined and clarified system requirements, updated its estimated cost based on market research, and “changed the project management methodology to reduce project risk.”
“This will greatly increase the probability that the state obtains functional system components at each phase in a shorter timeframe than the previous approach to the CalPEST project,” according to the BCP. - CDPR received approval from the California Department of Technology (CDT) for the project’s first Special Project Report (SPR) in February 2018; total approved project cost was slightly more than $6.9 million. “Due to the project delays,” the department turned in a second SPR in December explaining the reasons for the project’s cost variance and schedule “as a result of the re-planning effort.” Projected total project cost rose to slightly more than $22.7 million. The main sources of the increase included “increased projected system integrator vendor costs” due to the release of a new RFI in December 2019; longer project duration due to replanning; the addition of “a dedicated project manager vendor” and project management support services; and “additional interdepartmental oversight costs from CDT.” Use of the funds requested in this BCP, CDPR said in the BCP, are contingent on CDT’s approval of the second SPR.
- According to the second SPR, the department estimates the CalPEST project will cost just more than $22.7 million. But it requests funding in 2021-22 to do “only the following activities,” including procuring a new vendor for system integration and a new dedicated project manager; beginning design, development and release of a minimum viable product; and “limited-term help” for the state project team. CDPR’s “paper-based, manual-intensive registration processes must be modernized to meet the needs of registrants, improve internal processes, and facilitate the public’s access to product information,” the BCP said. It indicated challenges have been accentuated by the pandemic with staff “required to telework to the greatest extent possible” but also needed to “physically work in the office on a regular basis to collect and process new documents and transfer completed work to the next step in the process.” This proposal, the department said, will let it contract for CalPEST development, enabling “electronic submission, payment, tracking, review, and approval of registration applications, supporting documentation, and renewal of currently registered pesticide products.”
- Benefits from the CalPEST implementation — and a “temporary increase in registration fees” — include faster processing times and real-time data validation with concurrent “scientific evaluation of submissions.” The new system is also expected to offer public-facing real-time access to registered pesticide labels, allowing residents to look up product labels without making a Public Records Act request; and better efficiency for state and local officials including CDPR enforcement branches and county agricultural commissioners. It will also offer for the first time the option of electronic payment in lieu of the existing paper-only option, and an expected reduction in paper usage and the costs to store paper documents. The rise in registration fees is necessitated by the current estimated cost of CalPEST, according to the BCP. CDPR will review that cost when the project wraps to ensure that fees don’t exceed program needs and are “appropriately supporting the ongoing work of the registration program.”
- CDPR recommends that the Legislature approve the BCP as submitted but suggested two less-costly options. Approving instead $5 million from the General Fund in one-time money for a new contract to develop CalPEST would let development continue and would not require a temporary fee increase — but would use General Fund money. Doing nothing would force CDPR to “face critical challenges as it continues to struggle to meet expected registration review timeframes” and it’s expected its legacy systems will become “increasingly difficult” to maintain and ensure security. The general public, enforcement officials and emergency responders, meanwhile, would continue to lack ready electronic access to pesticide labels. Approving the BCP as written would enable easier project tracking via the “four-year encumbrance period” but would use monies from the DPR fund and cause fees to rise.
