BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                            



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                                    THIRD READING


          Bill No:  SB 176
          Author:   Galgiani (D)
          Amended:  5/28/13 
          Vote:     21

           
           SENATE GOVERNMENTAL ORGANIZATION COMMITTEE  :  11-0, 4/9/13
          AYES:  Wright, Nielsen, Berryhill, Calderon, Cannella, Correa,  
            De León, Galgiani, Hernandez, Lieu, Padilla

           SENATE APPROPRIATIONS COMMITTEE  :  7-0, 5/23/13
          AYES:  De León, Walters, Gaines, Hill, Lara, Padilla, Steinberg


           SUBJECT  :    Administrative procedures 

           SOURCE  :     California Association of Realtors


           DIGEST  :    This bill requires a state agency proposing to adopt  
          regulations to involve parties that would be subject to those  
          regulations in public discussions prior to publishing the notice  
          without regard to the complexity or number of proposals.

           ANALYSIS  :    

          Existing law:

          1.Governs the procedure for the adoption, amendment, or repeal  
            of regulations by state agencies and for the review of those  
            regulatory actions by Office of Administrative Law (OAL).

          2.Specifies that, in order to increase public participation and  
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            improve the quality of regulations, state agencies proposing  
            to adopt complex or numerous regulations shall involve parties  
            who would be subject to the proposed regulations in public  
            discussions prior to publishing the official notice of  
            proposed regulations. 

          This bill requires a state agency proposing to adopt regulations  
          to involve parties that would be subject to those regulations in  
          public discussions prior to publishing the notice without regard  
          to the complexity or number of proposals.

           Background
           
          In a comprehensive review of the state's rulemaking process, the  
          Little Hoover Commission recently noted that "California's  
          process lacks any requirement to bring in the affected public  
          before a rule is released for public comment.  This prevents  
          parties who stand to be impacted by the regulation, regulated  
          and unregulated, from offering their expertise about real world  
          conditions or suggesting better approaches before a proposed  
          regulation is released for public comment."

          The Commission also noted that no section of the Administrative  
          Procedure Act specifically requires a department or agency to  
          consult with parties who may be affected by a proposed  
          regulation prior to issuing the official public notice, which is  
          published in the Register. 

           California Regulatory Notice Register (Register)  .  The OAL  
          maintains and publishes the Register.  It is published every  
          Friday in PDF format.  The Register contains all notices of  
          proposed regulatory actions by state regulatory agencies to  
          adopt, amend, or repeal regulations.  In addition, OAL publishes  
          an index to the Register that covers all state agency regulatory  
          actions taken over the past 12 months, sorted according to  
          agency name.

          Comments
           
          The author's office notes that, although state agencies must  
          publish notices of proposed adoption of regulations in the  
          Register, they are not required to publish notices of  
          informational hearings, workshops, reports and the like in the  
          Register.  Consequently, the affected public is not typically  

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          involved in the regulatory process until the rule is released  
          for public comment.  The author's office suggests that  
          California should adopt practices that more closely approximate  
          the federal rulemaking process, which requires federal agencies  
          to additionally publish all public notices of hearings,  
          workshops and the like in the Federal Register, not just notices  
          of proposed regulations. 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

          According to the Senate Appropriations Committee, likely minor  
          ongoing costs to over 200 state agencies to involve interested  
          parties in discussions prior to proposing regulations.  (General  
          Fund and Various Special Funds).

           SUPPORT  :   (Verified  5/28/13)

          California Association of Realtors (source) 
          American Council of Engineering Companies
          Apartment Association of Greater Los Angeles 
          California Apartment Association 
          California Building Industry Association
          California Business Properties Association 
          California Cement Manufactures Environmental Coalition
          California Chamber of Commerce
          California Independent Oil Marketers Association 
          California Land and Title Association
          California Manufactures and Technology Association 
          California New Car Dealers Association
          California Restaurant Association
          California Retailers Association 
          California Service Station and Auto Repair Association
          National Federation of Independent Business 
          San Diego County Apartment Association
          Santa Barbara Rental Property Association 
          USANA Health Sciences, Inc. 
          Western States Petroleum Association

           ARGUMENTS IN SUPPORT  :    The supporters and sponsor of the bill  
          note that since the adoption of the Administrative Procedure Act  
          in 1945, the process for developing regulations has evolved  
          substantially, and today a majority of regulations are developed  
          during the pre-rulemaking process.  They believe that this bill  

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          will greatly benefit state agencies when developing regulations  
          by encouraging citizen participation, and that this bill will  
          simplify the state's regulatory notice procedures by providing a  
          single source of information to state agencies' pre-rule making  
          process.

          MW:nl  5/29/13   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

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