BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1098
                                                                  Page 1


          ASSEMBLY THIRD READING
          AB 1098 (Saldana)
          As Amended April 16, 2007
          Majority vote 

           ENVIRONMENTAL SAFETY          7-0                   JUDICIARY    
          10-0                
           
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          |Ayes:| Huffman, Smyth, Eng,     |Ayes:|Jones, Tran, Adams,       |
          |     |Evans, Feuer, Jeffries,   |     |Evans, Feuer, Keene,      |
          |     |Nava                      |     |Krekorian, Laird, Levine, |
          |     |                          |     |Lieber                    |
           ----------------------------------------------------------------- 

           SUMMARY  :  Provides clarifying language to AB 2481 (Frommer),  
          Chapter 999, Statutes of 2002, regarding the imposition of  
          administrative and criminal penalties relating to the handling  
          and release of hazardous materials.  Specifically,  this bill  :  

          1)Deletes reference to "governing body" in the Business Plan  
            Administrative Enforcement Order (AEO) for setting  
            administrative penalties.

          2)Clarifies enforcement options by separating existing  
            enforcement options for administrative and criminal processes  
            into individual subsections.

           EXISTING LAW  :

          1)Requires the Secretary for the California Environmental  
            Protection Agency to adopt regulations and implement the  
            Unified Hazardous Waste and Hazardous Materials Management  
            Regulatory Program.  A city or local agency that meets  
            specified requirements can be authorized to assume enforcement  
            duties of the program as a Certified Unified Program Agency  
            (CUPA).

          2)Authorizes, under the CUPA program, local city and county  
            agencies to unify the administration and enforcement of six  
            environmental programs:  hazardous waste; aboveground and  
            underground storage tank; hazardous materials inventory;  
            extremely hazardous materials accidental release; and,  
            hazardous materials/fire code programs.  








                                                                  AB 1098
                                                                  Page 2



          3)Provides an administrative order/administrative penalty  
            program to enforce the corrective action order provisions of  
            the hazardous materials/waste laws. 

           FISCAL EFFECT :  Unknown

          COMMENTS:  Clean-up language to AB 2481:  According to the  
          sponsor, County of San Diego, prior to AB 2481, of the six  
          programs overseen by CUPA, four had different administrative  
          order procedures and two had none at all.  AB 2481 created a  
          single, uniform system of administrative actions (AEOs) for all  
          six CUPA programs.  However, AB 2481 failed to include a  
          revision needed to a previously existing provision for  
          imposition of penalties by a governing board in the hazardous  
          materials business plan program.  Because this resulted in  
          conflicting statutory provisions, this has been an obstacle in  
          implementing the AEO program for Business Plans.  This has  
          created inconsistency and confusion in the program for  
          regulators and the regulated.  The hearing process created by AB  
          2481 uses the Administrative Procedures Act in which the hearing  
          officer issues a decision, including the amount of the fine.

          The new AEO procedure requires the CUPA to follow the state  
          Administrative Procedures Act for issuing an enforcement order  
          or assessing an administrative penalty.  In creating the new  
          system, AB 2481 did not remove the clause that mandates the  
          governing board of the administrative agency to set the  
          administrative penalty.  AB 1098 clarifies that it is not the  
          local governing body but rather the CUPA or participating agency  
          that would set the penalty as it does for other CUPA programs.  


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


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