BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:  April 19, 2016


                           ASSEMBLY COMMITTEE ON JUDICIARY


                                  Mark Stone, Chair


          AB 2446  
          (Gordon) - As Amended March 17, 2016


          SUBJECT:  State Water Resources Control Board:  judicial review


          KEY ISSUE:  Should the statutes governing challenges to orders  
          and decisions of state AND REGIONAL water Boards be clarified in  
          order to prevent persons subject to such orders from delaying  
          proceedings or seeking judicial review prior to the exhaustion  
          of admInistrative remedies? 

                                      SYNOPSIS


          Under California's Porter-Cologne Water Quality Act, the State  
          Water Resources Control Board (State Board) and nine regional  
          water boards are charged with protecting the quality of the  
          state's waters.  Enacted in 1969, the Porter-Cologne Act has not  
          only been important in protecting California waters, but the  
          general approach, and even specific provisions, of the  
          Porter-Cologne Act became a model for the federal Clean Water  
          Act of 1972.  The most important tools that state and regional  
          boards use to protect water quality include issuing (or refusing  
          to issue) discharge permits, issuing clean up and abatement  
          orders to any person who causes or permits waste to be  
          discharged into state water, and issuing cease and desist orders  
          to address violations, or threatened violations, of waste  
          discharges.  According to the author, this measure will enhance  








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          the ability of the water boards to protect water supplies and  
          mitigate environmental damage by addressing ambiguities in  
          existing law that have been used to delay or prematurely  
          challenge water board proceedings, decisions, and orders.  AB  
          2446 does so by amending provisions that establish rules and  
          procedures for challenging the decisions of the state and  
          regional water boards.  The author contends that the bill is  
          primarily a clarification of existing law, insofar as it  
          requires the exhaustion of administrative remedies before a  
          party can go to court for a writ of mandate, seeking to undo a  
          board decision.  The bill is sponsored by the State Water Board  
          and supported by the Sierra Club.  It is opposed (or opposed  
          unless amended) by a coalition of farm groups, the Association  
          of California Water Agencies, and two district water agencies.   
          What the author and sponsor see as changes that eliminate delay  
          and allow the administrative process to proceed, the opponents  
          see as a denial of due process and their right to seek judicial  
          remedies.  Both the author and some of the opponents have  
          indicated to the Committee that there may be areas of compromise  
          on some points, especially on those related to the intersection  
          of state and federal law.  However, these issues were raised too  
          late for the Committee to fully analyze the issues and consider  
          possible amendments.  The Committee may wish to encourage the  
          author, if the bill moves out of this Committee, to continue  
          working with all interested parties: farm groups, water  
          agencies, and environmentalists. 


          SUMMARY:  Seeks to expand the authority of the State Water  
          Resources Control Board (State Water Board), and to a lesser  
          extent regional water boards, to issue or not issue a stay  
          pending board proceedings, prohibit certain judicial challenges  
          to water board decisions until after the administrative process  
          has run its course, and clarify two specified evidentiary  
          requirements.  Specifically, this bill:  


          1)Expands a provision of existing law that authorizes the State  
            Water Board, in response to a petition to review an order of a  








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            regional water board, to stay the effect of a decision or  
            order of a state or regional water board, to additionally  
            allow the State Water Board to stay an order or decision  
            issued under authority delegated to an officer or employee of  
            the State Water Board, as specified.  Authorizes an aggrieved  
            party, within 30 days of any order of the State Board issuing  
            or denying a stay, to file with the superior court a petition  
            for writ of mandate.  Specifies that if the State Water Board  
            or the superior court grants a stay, the stay shall be made  
            effective as of the effective date of the decision or order.


          2)Provides that no legal or equitable process shall issue in any  
            proceeding in any court against the State Water Board, a  
            regional board, or any officer of a state or regional board,  
            to review, prevent, or enjoin any adjudicative proceeding  
            under the Porter-Cologne Act.  Except for a petition for writ  
            of mandate, as authorized in Water Code Section 13321, no  
            legal or equitable process shall issue in any proceeding in  
            any court against the state board or regional board to review,  
            prevent, or enjoin a decision or order by a state or regional  
            water board before a decision or order has been issued and the  
            procedures for administrative review of that decision or order  
            have been exhausted. 


          3)Specifies that in any civil action brought pursuant to the  
            Porter-Cologne Act in which a regional water board or the  
            State Water Board seeks an injunction or restraining order, it  
            shall not be necessary to allege or prove that irreparable  
            harm will occur should the temporary restraining order,  
            preliminary injunction, or permanent injunction not be issued.  
             


          4)Provides that for any order or decision of the State Water  
            Board under the Safe Water Drinking Act, if no aggrieved party  
            petitions for a writ of mandate within the 30-day period  
            authorized by the Act, the decision or order of the State  








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            Water Board is not subject to review by any court.  Specifies  
            that in every case that comes before the court under this  
            provision, the court shall exercise its independent judgment  
            on the evidence. 


          EXISTING LAW:  


          1)Provides, under the Porter-Cologne Water Quality Control Act,  
            that within 30 days of any action or failure to act by a  
            regional water board, an aggrieved person may petition the  
            State Water Board to review that action or failure to act.   
            Authorizes the State Water Board, in the case of such review  
            and upon notice and hearing, if hearing is requested, to stay  
            in whole or in part the effect of the decision and order of a  
            regional board of the State Water Board.  (Water Code Sections  
            13320 and 13321.)


          2)Authorizes an aggrieved party, not later than 30 days from  
            service of a copy of a decision or order issued by the State  
            Water Board, to file in superior court a petition for a writ  
            of mandate for review of the decision or order.  Specifies  
            that an aggrieved party must file a petition for  
            reconsideration with the State Water Board to exhaust that  
            party's administrative remedies only if the initial decision  
            or order is issued under authority delegated to an officer or  
            employee of the State Water Board and the State Water Board by  
            regulation has authorized a petition for reconsideration.   
            Specifies that the party aggrieved by the decision of the  
            State Water Board may obtain a review of the decision or order  
            of a regional water board by filing in superior court a  
            petition for writ of mandate not later than 30 days from the  
            date on which the State Water Board denies review.  (Water  
            Code Section 13330 (a)-(b).)


          3)Provides that if no aggrieved party petitions for a writ of  








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            mandate within the time provided by 2) above, a decision or  
            order of the state board shall not be subject to review by any  
            court.  (Water Code Section 13330 (d).) 


          4)Provides that every civil action brought under the provisions  
            of the Porter-Cologne Water Quality Control Act at the request  
            of the regional board or the state board shall be brought by  
            the Attorney General in the name of the people of the state of  
            California and any of those actions relating to the same  
            discharge may be joined or consolidated.  (Water Code Section  
            13361 (a).)


          5)Provides that in any civil action brought under the provisions  
            of the Porter-Cologne Water Quality Control Act, for an  
            injunction or temporary restraining order, it shall not be  
            necessary to allege or prove that irreparable harm will occur  
            if the injunction or restraining order is issued.  (Water Code  
            Section 13361 (c).)  


          6)Requires the State Water Board, under the California Safe  
            Water Drinking Act, to administer provisions in the Health &  
            Safety Code that regulate drinking water.  To carry out this  
            responsibility, existing law requires the State Water Board to  
            appoint a deputy director to oversee issuance and enforcement  
            of public water system permits and authorizes the deputy  
            director to issue orders directing corrective actions if the  
            conditions of any permit, regulation, or standard is violated.  
             Authorizes a party aggrieved by any order, within 30 day  
            after service of a copy of the order, to file in superior  
            court a petition for a writ of mandate to review the order.   
            Specifies, however, that failure to file an action shall not  
            preclude a party from challenging the reasonableness or  
            validity of a decision or order in any judicial proceeding  
            brought to enforce the decision or order.  (Health & Safety  
            Code Section 116700 (a).) 









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          7)Provides that in any action challenging an order or decision,  
            the evidence before the court shall consist of all relevant  
            evidence that, in the judgment of the court, should be  
            considered to effectuate and implement the provisions of the  
            Safe Drinking Water Act.  In every case, the court shall  
            exercise its independent judgment on the evidence.  (Health &  
            Safety Code Section 116700 (b).) 


          FISCAL EFFECT:  As currently in print this bill is keyed fiscal.  



          COMMENTS:  Under the Porter-Cologne Water Quality Control Act,  
          the State Water Resources Control Board (State Water Board) has  
          ultimate authority to regulate water quality in the state.   
          Porter-Cologne also established nine regional water boards to  
          oversee water quality on a day-to-day and regional basis.  Among  
          the key tools available to the state and regional water boards  
          are the power to issue or deny water discharge permits, issue  
          clean-up and cease and desist orders to polluters, and issue  
          stays against harmful conduct and discharges while a matter is  
          pending before the board.   This bill deals primarily with the  
          ability of persons subject to such orders to challenge those  
          orders. Existing law sets out prescribed procedures and  
          timelines that the state and regional water boards must conform  
          to, including noticing hearings, making decisions, and issuing  
          orders designed to protect water quality.  Existing law also  
          sets forth procedures and timelines that persons aggrieved by an  
          order or decision must conform to when challenging those orders  
          and decisions.   


          According to the author and sponsor, most of the changes  
          proposed in this bill are clarifying in nature.  The author, for  
          example, contends that this bill will mainly address  
          "ambiguities" in existing law that have allowed "dischargers . .  
          . to impede or delay hearings on proposed pollution control  








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          actions by going to court before the State Water Board or a  
          Regional Water Board has actually taken an action," and in some  
          cases dischargers have allegedly obtained injunctions that  
          prohibit the water boards from even holding hearings. 


          Exhausting Administrative Remedies or Denying Due Process?   
          According to background material provided by the author and  
          sponsor, one of the more vexing problems water boards sometimes  
          face is the efforts of dischargers and polluters to delay board  
          proceedings, both state and regional, and to seek injunctions  
          and court orders overturning or staying a board order even  
          before the administrative process runs its course.  That is,  
          under existing law, a state or regional water board has the  
          authority to issue or deny waste discharge permits and to take  
          actions against those who violate the conditions of the permit  
          or other laws or regulations.  For example, if a regional water  
          board issues an order to halt a permittee from discharging  
          waste, the person aggrieved - the person subject to the order -  
          may file a petition with the State Water Board for  
          "reconsideration" of a board's decision.  Only after the  
          administrative process is complete, would the aggrieved party be  
          permitted to seek a court order.  However, the sponsor, the  
          State Water Board, contends that some dischargers have exploited  
          "ambiguities" in existing law to seek injunctions that delay  
          board proceedings or seek judicial review to overturn a board  
          decision.  


          This bill would clarify what is seemingly implied in existing  
          law, and is generally true of most administrative actions: a  
          party who is unhappy with a board decision must wait for the  
          board to actually take action before attempting to challenge the  
          board's decision by recourse to any available administrative  
          proceeding, such as a petition for review, reconsideration, a  
          hearing, and other administrative adjudication that is necessary  
          before going to the courts for relief.  For the author and  
          sponsor, these administrative procedures were established for a  
          reason: to seek a resolution before resorting to the courts and  








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          to ensure that any potentially harmful conduct is stayed during  
          the administrative process.  Opponents, on the other hand,  
          accuse the bill of "circumscribing judicial review."  However,  
          it should be noted that none of the provisions eliminate  
          anyone's right to judicial review.  Rather, the bill simply  
          requires what is usually the case in administrative law: all  
          administrative remedies must be exhausted before a party may  
          turn to the courts.  If the allegations of the author and  
          sponsor are correct, some aggrieved dischargers are turning to  
          the courts even before a board has issued an order or decision,  
          let alone using the administrative process to challenge the  
          order or decision.  In at least one case, according to the  
          sponsor, a discharger sought to obtain an injunction to prevent  
          the board from even holding a hearing. 



          "Shall Not be Subject to Review":  One example of the  
          disagreement between the sponsor and opponents of the bill  
          concerns the novelty, or lack of thereof, of the language the  
          bill would add to the California Safe Drinking Water Act (Health  
          & Safety Code Section 116700) stating that if no aggrieved party  
          petitions for a writ of mandate within the prescribed 30-day  
          period, the decision or order "shall not be subject to review by  
          any court."  Opponents of the bill suggest that this amounts to  
          a denial of due process by precluding anyone who has not filed a  
          petition for a writ of mandate from obtaining judicial review.   
          The sponsors, on the other hand, contend that this is not a new  
          restriction, but merely a simple clarification of what is  
          necessarily implied in the provision that authorizes an  
          aggrieved party to file a petition for writ of mandate within 30  
          days of service of the order.  The 30-day time limit would have  
          no meaning if the aggrieved party could seek judicial review of  
          the board's decision or order after that time period.  Moreover,  
          the sponsor correctly points to a parallel provision in the  
          Porter-Cologne Act that contains both a requirement that the  
          petition for writ be filed within 30 days of service and the  
          express language that says if the petition is not filed within  
          the prescribed time period the decision or order "shall not be  








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          subject to review by any court."  The sponsor contends that this  
          brings consistency to the parallel provisions in Health & Safety  
          Code and Water Code, so that both say that failure to file a  
          petition for writ of mandate to review an action of the State  
          Water Board within the prescribed period means that the order or  
          decision will not be subject to court review.  This express  
          reinforcement is necessary, the sponsor contends, in order to  
          clear up any ambiguity in that section of the Health & Safety  
          Code and avoid the potential that someone will challenge an  
          earlier permitting decision during a subsequent enforcement  
          proceeding for violations of that permit.  


          Concerns about "401 Certificates" and the Interaction of Federal  
          and State Law:  The water boards (state and regional) regulate  
          all pollutants and discharges that may affect the quality of  
          either surface water or groundwater.  Any person proposing to  
          discharge waste within a region must file a report of waste  
          discharge with the appropriate regional board.  No discharge may  
          take place until the regional board issues either "waste  
          discharge requirements" (i.e. a permit and any conditions  
          attached to it), or a waiver of those requirements.  Under the  
          auspices of the U.S. Environmental Protection Agency, the State  
          Water Board and regional water boards also grant National  
          Pollutant Discharge Elimination System (NPDES) permits required  
          by the federal Clean Water Act for "point-source" discharges.   
          (A "point source" discharge means any confined conveyance, such  
          as pipe, ditch, or other conduit, from which pollutants may  
          enter into a stream or other body of water; it is distinct from  
          storm water discharges and return flows from irrigated  
          agriculture.)  The state and regional water boards, therefore,  
          issue NPDES permits for "point-source" discharges, and "water  
          discharge requirement" permits for all other discharges.


          Adding a further layer of state-federal complexity, the Federal  
          Energy Regulation Commission (FERC) cannot issue a new license  
          for a hydroelectric project pursuant to Section 401 of the  
          federal Clean Water Act until a state water board issues a "401  








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          certificate" affirming that the new license will comply with the  
          state's water quality requirements.  The interaction between  
          state and federal permitting requirements, and the changes  
          proposed by this bill, has caused concern for some regional  
          water agencies.  For example, the Association of California  
          Water Agencies (ACWA) and a regional water agency argue that  
          applicants for hydroelectric plants could be adversely and  
          unintentionally affected by the provisions of this bill.  The  
          certificates often require plants to take actions - such as  
          creating fish passages at dams or maintaining streamflow for  
          whitewater recreation - that are not directly or significantly  
          related to issues of water quality.  Because state law allows  
          the State Water Board to issue a 401 certificate for a  
          hydroelectric project without a public proceeding, the only way  
          that a licensee may obtain public consideration of a certificate  
          occurs is if the State Water Board considers a petition for  
          reconsideration, but existing law does not set any time limit  
          for the State Water Board to act on a petition for  
          reconsideration.  These agencies contend that limiting their  
          ability to petition and obtain a timely decision from the State  
          Water Board may limit their ability to comply with FERC  
          requirements.  As the ACWA puts it, "a hydroelectric licensee  
          needs the opportunity to go to court immediately upon receiving  
          a [401 certificate] so that it can seek to maintain the status  
          quo pending reconsideration."  These agencies, therefore, would  
          prefer an amendment creating a carve-out for hydroelectric  
          projects and 401 certificates. 


          However, the issue of the "401 certificates" was raised too late  
          for the Committee to fully consider the need for, or likely  
          effect of, such an amendment.  Nor is it entirely clear to the  
          Committee counsel if this is a concern with existing law or with  
          the specific amendments proposed by this bill, or if the  
          provisions of this bill will make an existing problem worse.  
          However, the author, sponsor, and the ACWA have all indicated to  
          the Committee that there may be a compromise that could address  
          everyone's respective concerns, but there was not time to work  
          out those amendments in time for this hearing. 








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          Evidentiary Changes Proposed by this Bill:  Finally, this bill  
          potentially proposes two evidentiary changes, both of which,  
          according to the sponsor, are largely clarifying in nature, but  
          one of which opponents see as substantive.  First, under an  
          existing provision of the Safe Drinking Water Act, when a review  
          of the State Water Board action comes before the court, "the  
          evidence before the court shall consist of all relevant evidence  
          that, in the judgment of the court, should be considered to  
          effectuate and implement the provisions [of the Safe Drinking  
          Water Act].  In every case, the court shall exercise its  
          independent judgment on the evidence."  (Health & Safety Code  
          Section 116700 (b).)  This bill would delete everything except  
          the final sentence: "In every case, the court shall exercise its  
          independent judgment on the evidence."  The so-called  
          "independent judgment" standard of review, which is both the  
          existing standard and the standard proposed by this bill, is  
          usually contrasted with the "substantial evidence" standard of  
          judicial review when a court considers a petition for a writ of  
          administrative mandate.  Generally speaking, under the  
                "substantial evidence" rule, the court is more deferential to  
          the findings of the agency, asking only if the decision was  
          reasonable in light of the evidence before it.  However, the  
          "independent judgment" rule is much less deferential to the  
          agency, allowing the court to use its "independent judgement on  
          the evidence."  (See e.g. Code of Civil Procedure 1094.5 (c).)  


          This bill makes it clear that the independent judgment rule is  
          the appropriate standard with a clear simple statement.  It  
          should be noted that the sponsor is adopting a standard which is  
          contrary to its interest.  As an agency subject to review by the  
          courts, it would naturally prefer the more deferential  
          "substantial evidence" standard.  Thus, the opposition's  
          criticism of this amendment, as though it were some sort of  
          power play to enhance the State Water Board's authority, is  
          curious to say the least.  The farm group coalition letter  
          claims that by eliminating the reference to "all relevant  








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          evidence" this will have the effect of "restricting the court's  
          review to what the state administrative agencies alone deem  
          relevant."  But this is precisely what the "independent  
          judgment" rule does not allow. 


          The impact of the other evidentiary change also depends upon  
          whether one sees it as a clarification or a departure from  
          existing law.  As a general rule, a key requirement for  
          obtaining an injunction is to show that without the injunction,  
          the party seeking the injunction will suffer "irreparable harm."  
           However, the Porter-Cologne Act creates an exception to this  
          general rule, providing that in any civil action brought under  
          the Act in which a temporary restraining order or an injunction  
          is sought, "it shall not be necessary to allege or prove at any  
          stage of the proceeding that irreparable damage will occur  
          should the temporary restraining order, preliminary injunction,  
          or permanent injunction not be issued."  (Water Code Section  
          13361 (c).)  Although the passive construction of the language  
          in this provision does not make it who does not need to prove  
          irreparable harm, the sponsor contends that this section was  
          intended and has been construed to mean that the water boards do  
          not need to show irreparable harm when they enjoin a harmful or  
          potentially harmful contamination of the water supply.  But the  
          sponsor contends that "due to ambiguities in existing law," this  
          section "could be misinterpreted to provide that a party seeking  
          an injunction against the Water Boards need not prove  
          irreparable harm."  This bill would clarify that only when "a  
          regional board or the state water board" seeks an injunction is  
          a showing of irreparable harm not required.  Because the sponsor  
          states that this could be so interpreted, it is not entirely  
          clear if it ever has been so interpreted.  The Committee counsel  
          could not find any case law bearing on the question of whether  
          the exemption from showing irreparable harm belonged only to the  
          water boards, or to any party who sought an injunction or  
          restraining order under the Act.  However, it is certainly quite  
          reasonable to assume that the existing law intended to only  
          excuse the boards from the irreparable harm requirement.  The  
          boards, after all, are charged with protecting the state's water  








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          from harm by preventing contamination; to require the boards to  
          prove irreparable harm before it could issue an injunction to  
          prevent harm would make no sense. 

          Considerations Should the Bill Move Forward:  As noted, the  
          letters of opposition on this measure arrived late to the  
          Committee and, as such, the opposition concerns may not have  
          received as much consideration as would otherwise have been the  
          case.  Nonetheless, some of the points raised by opponents and  
          groups expressing concern may be worthy of consideration.  Most  
          notably, the ACWA and some of its member water agencies have  
          concerns about the bill's impact on the ability of hydroelectric  
          projects to obtain necessary "401 certificates" to comply with  
          federal laws and regulations.  It appears that the author,  
          sponsor, and ACWA, and at least one regional agency have engaged  
          in discussions about how this issue may be addressed.  


          ARGUMENTS IN SUPPORT:  According to the State Water Board, the  
          sponsor, AB 2466 will "clarify the procedures for administrative  
          and judicial review of . . . actions taken by the State Water  
          Board and Regional Water Boards (collectively referred to as the  
          Water Boards.)"  The State Water Board argues that this measure  
          will "result in increased program efficiency by reducing  
          ambiguities in statute that result in premature legal challenges  
          and substantial delays in the Water Boards' abilities to take  
          necessary and appropriate actions to protect water quality."   
          The State Water Board also argues that the provisions of this  
          bill will clarify the intent of existing law.  For example, it  
          claims that a provision in existing law which provides that the  
          boards need not show irreparable harm in seeking an injunction  
          or a restraining order does not mean that a party seeking an  
          injunction against the boards is excused from showing  
          irreparable harm.  Finally, the State Water Board argues that  
          this will also clarify that a party wishing to challenge a board  
          cannot seek judicial review before a board has taken action and  
          the required administrative review process has been exhausted. 










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          The Sierra Club supports this bill because it will prohibit  
          "polluters from using the courts to get around Water Board stays  
          that stop pollution while the case is pending at the Water  
          Board."  According to Sierra Club, "when a polluter is found by  
          the Board, the Board's stay to prevent further problems can be  
          lifted by a court, allowing pollution to continue." 


          ARGUMENTS IN OPPOSITION:  A coalition of farm groups, including  
          the California Farm Bureau and the Western Growers Association,  
          oppose this bill because it "would significantly expand the  
          [State Water Board's] authority and discretion by circumscribing  
          judicial review of that authority."  Specifically, the  
          opposition points to the following provisions of the bill: (1)  
          the provision which says that "if no aggrieved party petitions a  
          writ of mandate within 30 days after service of a copy of an  
          order or decision by [the State Water Board]," then the decision  
          or order of the board shall not be subject to review by any  
          court; (2) the provision that would eliminate the requirement  
          that a court consider "all relevant evidence" relating to the  
          board's order; (3) the elimination of Water Code Section 13321  
          (c), which opponents contend would require a permittee to comply  
          with requirements of an administrative order "even though they  
          are being timely challenged through a judicial process;" (4) the  
          absence of a time limit for the State Water Board to make a  
          decision on an application for a stay; (5) and more generally  
          the provisions that would allow state and regional water boards  
          to delay a decision on a stay while preventing the applicant  
          from seeking a stay from the court, which the opponents believe  
          denies due process and "punishes the permittee by having to  
          comply with requirements despite a timely challenge that may be  
          successful." 


          The Association of California Water Agencies (ACWA) opposes this  
          bill primarily because it will adversely and unintentionally  
          affect water agency activities involving federal regulations.   
          In particular, ACWA notes that some of its member water agencies  
          are licensed by the Federal Energy Regulatory Commission (FERC)  








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          which requires a water quality certificate (a "401 certificate")  
          from the State Water Board in order to obtain a new or renew an  
          existing license to operate a hydroelectric project.  State law  
          allows the State Water Board to issue a 401 certificate for a  
          hydroelectric project without a public proceeding, thus the only  
          way that a licensee may obtain public consideration of a  
          certificate occurs if the State Water Board considers a petition  
          for reconsideration, but existing law does not set any time  
          limit for the State Water Board to act on a petition for  
          reconsideration.  "Therefore," ACWA contends, "a hydroelectric  
          licensee needs the opportunity to go to court immediately upon  
          receiving the Executive Director's Section 401 certificate so  
          that it can seek to maintain the status quo pending  
          reconsideration of that certificate by the State Water Board  
          itself."  The letter of "concern" submitted by the Yuba County  
          Water Agency raises the same issue.


          REGISTERED SUPPORT / OPPOSITION:




          Support


          State Water Resources Control Board (sponsor)


          Sierra Club




          Opposition


          Association of California Egg Farmers 









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          Association of California Water Agencies 


          California Farm Bureau Federation 


          California Grain & Feed Association 


          California Seed Association 


          El Dorado Irrigation District (unless amended)


          Western Growers Association 


          Concerns


          Yuba County Water Agency 




          Analysis Prepared by:Thomas Clark / JUD. / (916) 319-2334



















                                                                    AB 2446


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