BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1333
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          ASSEMBLY THIRD READING
          AB 1333 (Frommer)
          As Amended May 4, 2005
          Majority vote 

           ENVIRONMENTAL SAFETY           5-1                  PUBLIC  
          SAFETY              6-0         
           
           ----------------------------------------------------------------- 
          |Ayes:|Ruskin, Chu, De La Torre, |Ayes:|Leno, Benoit, Cohn,       |
          |     |Goldberg, Jerome Horton   |     |Dymally, Goldberg,        |
          |     |                          |     |Spitzer                   |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Strickland                |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 

           APPROPRIATIONS      13-5                                        
           
           ----------------------------------------------------------------- 
          |Ayes:|Chu, Bass, Berg,          |     |                          |
          |     |Calderon, Mullin,         |     |                          |
          |     |Karnette, Klehs, Leno,    |     |                          |
          |     |Nation, Oropeza,          |     |                          |
          |     |Ridley-Thomas, Saldana,   |     |                          |
          |     |Yee                       |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Sharon Runner, Emmerson,  |     |                          |
          |     |Haynes, Nakanishi,        |     |                          |
          |     |Walters                   |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Makes it a misdemeanor criminal offense to improperly  
          discard grease.   Specifically,  this bill  :

          1)Prohibits any grease hauler from reinserting into a grease  
            trap, grease interceptor, manhole, cleanout, sanitary sewer  
            facility or any other place not authorized to receive them,  
            any materials that the hauler has removed from the grease trap  
            or grease interceptor.  

          2)Defines, for purposes of the Penal Code "grease waste hauler"  
            to be "an individual or business who removes grease and  








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            accompanying materials from a grease trap or a grease  
            interceptor and transports the materials to another location.   
            It does not include a hauler of grease from grease traps  
            serving industrial processes that principally contain  
            petroleum hydrocarbons.

          3)Makes it unlawful for any person to manage or dispose of  
            grease removed from a grease trap or grease interceptor into a  
            land treatment unit.  For purposes of the Penal Code, "land  
            treatment unit" or "land farm" is "a facility or part of a  
            facility at which waste is applied onto or incorporated into  
            the soil surface so that constituents are degraded,  
            transformed, or immobilized with the treatment zone."

          4)Provides that any person who violates these provisions shall  
            be guilty of a misdemeanor punishable, on the first offense,  
            by imprisonment in a county jail for not more than six months,  
            or by a fine of up to $10,000, or both.  Upon a subsequent  
            offense, that person is subject to imprisonment of up to one  
            year in a county jail, or a fine of up to $25,000, or both.

          5)Apportions the fines paid pursuant to this section as follows:

             a)   50% shall be deposited in the Environmental Enforcement  
               and Training Account (ETTA), which is used to help fund  
               statewide training for local environmental enforcement  
               officials; 

             b)   25% shall be distributed pursuant to the customary  
               method for apportioning fines between the city and the  
               county in which the crime occurred; and,

             c)   25% to the local health officer or other local public  
               officer or agency that investigated the matter which lead  
               to bringing the action.

          6)Authorizes the court to bar the violating individual or  
            business from engaging in the business of grease hauling for a  
            period not to exceed five years if it finds that the violator  
            has engaged in a practice or pattern of violation, consisting  
            of two or more convictions.

          7)Permits the court to require, in addition to any fine imposed  
            upon conviction, as a condition of probation, that a person  








                                                                  AB 1333
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            convicted under this section remove, or pay the cost of  
            removing any materials which the convicted person dumped in  
            violation of this section.

           EXISTING LAW  , under the Food and Agricultural Code, generally  
          regulates haulers of grease under the chapter governing  
          Horsemeat and Pet Food.

          1)Authorizes any registered transporter or licensed renderer of  
            inedible kitchen grease to deliver any inedible kitchen grease  
            to a licensed renderer or collection center for processing or  
            recycling into usable products.  As used in this section,  
            "usable products" includes, but is not limited to, biofuels,  
            lubricants, and animal feed, provided the uses for animal feed  
            are permitted by the rules and regulations adopted by the  
            United States Food and Drug Administration. 

          2)Requires the California Department of Food and Agriculture  
            (CDFA) to issue licenses to individuals who operate rendering  
            plants and collection centers.  

          3)Makes it unlawful to maliciously discharge any substance  
            capable of causing substantial damage or harm to the operation  
            of a public sewer sanitary facility, or to deposit in  
            commercial quantities, any other substance, into a manhole,  
            cleanout, or other sanitary sewer facility,  not intended for  
            use as a point of deposit for sewage, which is connected to a  
            public sanitary sewer system, without possessing a written  
            authorization.  A first violation is a misdemeanor, punishable  
            by imprisonment in the county jail for not more than one year,  
            or by a fine of up to $25,000, or by both a fine and  
            imprisonment.  A subsequent violation, is an alternate  
            felony-misdemeanor, punishable by imprisonment in the county  
            jail for not more than one year, or imprisonment in the state  
            prison for 16, 20, or 24 months, and by a fine of not less  
            than $5,000 or more than $25,000.

          4)Establishes the Environmental Circuit Prosecutor Project as  
            part of the Local Environmental Enforcement and Training  
            Program.  This program is meant to assist local enforcement  
            personnel in the investigation and enforcement of all  
            environmental laws.

           FISCAL EFFECT  :  According to the Assembly Appropriations  








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          Committee analysis, potential moderate statewide revenue  
          generated by fines imposed for the new grease-related crimes and  
          moderate reallocation of fine revenue to the EETA and local  
          health officers.

           COMMENTS  :   The author seeks to make the most egregious  
          violators of statutes governing the proper handling and disposal  
          of grease removed from grease traps subject to misdemeanor  
          penalties.

          1)The sponsor of this measure, the California District Attorneys  
            Association (CDAA), explains that under current law  
            prosecutions are often hampered because the prosecutors must  
            actually catch illegal dumpers in the act and must have  
            accurate discharge measurements in order to prove the dumpers  
            are exceeding discharge limits or the extent of harm to the  
            environment.  CDAA asserts that this bill takes a simpler and  
            more sensible approach by making the act of disposal to an  
            unauthorized place illegal in and of itself as a strict  
            liability misdemeanor crime.  This change should better deter  
            cheaters that are taking advantage of businesses that think  
            their grease is being properly disposed.

          2)CDAA states that "brown grease" is a major problem because it  
            threatens our natural resources, our health, and the  
            remediation cost dissipates precious tax dollars.  District  
            Attorneys have prosecuted waste haulers in the past few years,  
            all of whom were filling our sewers and creeks with grease  
            that had been taken out of legitimate restaurant grease traps  
            and interceptors.  Currently, grease cases are complicated to  
            prosecute because various practices are not expressly illegal.  
             California's Water and Fish and Game Codes do not provide  
            prosecutors with the tools required to address this serious  
            problem.  Prosecutors need legislation to provide strict  
            penalties for the mishandling of brown grease.  

          3)Studies by local governments of sewer blockages demonstrate  
            that blockages due to buildup of fats, oil, and grease are a  
            major cause of sewage overflow.  Forty-one percent of the 682  
            sewage spills occurring during 2001 in Los Angeles were the  
            result of grease buildup in the sewer system.  In Sacramento,  
            grease blockages accounted for 44% of annual mainline  
            blockages between 1996 and 2000, and sewage spills caused by  
            grease blockages cost an average of $235,000 during the  








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            four-year period.  Six specific mainline stoppages directly  
            attributable to restaurant-generated grease cost the  
            Sacramento County Sanitation District over $1.4 million in  
            flooded structure claims.  Orange County beaches were closed  
            more than 2,000 days between 1987 and 2000 as a result of  
            bacterial contamination due to sewage spills, many of which  
            were caused by grease clogs. Sewage spills caused by pipeline  
            blockages and pipeline breaks were responsible for the  
            majority (70%) of the ocean and bay water closures in Orange  
            County from 1987-2004.  Grease blockage was directly  
            attributable for 28% of the sewer pipeline blockages that  
            resulted in ocean and bay closures in Orange County from  
            1999-2004. 

          4)The membership of the California Grain and Feed Association  
            (CGFA) includes most of the California rendering companies  
            engaged in servicing grease interceptors and the hauling and  
            disposal of interceptor grease.  They support "most of the  
            provisions of the bill including those regarding disposal of  
            interceptor grease at land treatment units as well as the  
            penalty provisions of the bill.  We think these provisions  
            will assist in preventing the improper disposal of grease."

          5)However, in a hearing at of the Environmental Safety  
            Committee, CGFA urged the author to permit the use of mobile  
            separator units.  CGFA states, "While we do support the  
            concept of removing all grease, solids and water from  
            interceptor units, the bill does not recognize that some  
            interceptor service companies now have equipment on their  
            pumping trucks that separate the grey water from the solids  
            and grease.  They can then pump the grey water back into the  
            interceptor unit which actually makes the unit operate more  
            effectively and prevents some grease from escaping into the  
            sewer system."  They contend that permitting the use of such  
            equipment eliminates the need to haul the water long distances  
            and also reduces the number of dumping trips at sanitation  
            district facilities.  In addition, particularly in remote and  
            rural areas, they think that mobile separator units are more  
            efficient where there are long distances between the food  
            facility and a treatment plant.  CGFA would like to permit the  
            "separated water" be returned to the inlet chamber of the  
            interceptor unit if equipment capable of separating the water  
            is used and if this practice is permitted by the local  
            sanitation district.








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          6)While the concept of how a mobile separator unit might work is  
            relatively straightforward, there appears to be some question  
            as to how it would work in fact.  According to the author's  
            office, several cities have banned the use of mobile separator  
            units including Huston and Baton Rouge.  There is concern that  
            such an amendment might undermine the effectiveness of the  
            straightforward ban currently in this bill on the disposal of  
            removed material back into the filter input or down the drain.  
             It could make it very difficult for local authorities to  
            determine what kind of waste the transporter is pumping back  
            into the interceptor and would require the enforcing authority  
            to quantify how much grease is contained within the effluent  
            entering back into the grease interceptor.

           Related legislation  :  AB 1065 (Agriculture Committee) authorizes  
          CDFA to establish a system to document and track the  
          transportation of inedible kitchen grease in order to better  
          ensure the proper disposal or recycling of the grease.  This  
          bill is on the Assembly Floor.
          .

           Analysis Prepared by  :    Michael Endicott / E.S. & T.M. / (916)  
          319-3965 


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