BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2153
                                                                  Page  1

          Date of Hearing:   May 14, 2008 

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mark Leno, Chair

                  AB 2153 (Krekorian) - As Amended:  April 8, 2008 

          Policy Committee:                              Natural Resources  
                       Vote:                            5-3

          Urgency:     No                   State Mandated Local Program:  
          Yes    Reimbursable:              No

           SUMMARY  

          This bill establishes a process by which developers of  
          residential and commercial buildings must mitigate the projected  
          increase in water consumption from these buildings by taking  
          measures to equally reduce water consumption elsewhere in the  
          same hydrologic region.  

           FISCAL EFFECT  

          Potentially substantial costs, in the millions of dollars  
          annually statewide starting in 2008-09, to cities and counties  
          and other local lead agencies under CEQA to review and approve  
          project mitigation measures and to enforce the mitigation  
          process.  These costs are covered by revenue generated by  
          CEQA-related fees imposed on project developers.  

           SUMMARY CONTINUED
           
          Specifically, this bill:

          1)Requires new residential and commercial construction projects  
            subject to the California Environmental Quality Act (CEQA) to  
            implement all feasible & cost-effective water efficiency  
            measures.

          2)Requires these projects, after efficiency measures are  
            implemented, to mitigate any increase in the projected annual  
            increase in water consumption within the same hydrologic  
            region by doing any of the following:

             a)   Water efficiency measures.








                                                                  AB 2153
                                                                  Page  2

             b)   Infrastructure rehabilitation to reduce water leaks.
             c)   Recycled water facilities.
             d)   Groundwater remediation and treatment facilities.
             e)   Stormwater capture facilities.

          3)Makes the mitigation measures specified in #2 above subject to  
            review and approval by the city or county or other lead  
            agency, but does not require them to be so reviewed and  
            approved.

          4)Requires the mitigation measures specified in #2 above to meet  
            all the following criteria:

             a)   40% (of water consumption reduction) must be  
               accomplished by projects serving disadvantaged communities  
               within the same hydrologic region.
             b)   Project and programs must be "real", have a lifespan of  
               at least 20 years, and have quantifiable results that  
               produce an amount of water equal to the new residential or  
               commercial building project's projected water use.
             c)   Projects or programs, if feasible, must minimize  
               greenhouse gas (GHG) emissions and environmental impact,  
               reduce contaminated runoff, and provide environmental  
               benefits.

          5)Requires affordable housing projects to implement all feasible  
            and cost-effective water efficiency measures, but exempts them  
            from the mitigation requirements.

           COMMENTS  

           1)Rationale  .  The author contends that developers of new  
            residential and commercial buildings should be primarily  
            responsible for making sure that overall water consumption in  
            the hydrologic region does not increase as a result of the new  
            buildings.  This essentially translates to a "no growth"  
            policy with regard to water consumption within each hydrologic  
            region of the state.  The author also believes that efforts to  
            "hold the line" on regional water consumption should benefit  
            disadvantaged communities that often lack adequate water  
            infrastructure to efficiently deliver water supplies.  The  
            author exempts the developers of public buildings from these  
            requirements to avoid incurring any major state or local  
            agency costs.









                                                                  AB 2153
                                                                  Page  3

           2)Background  .  California has long been challenged by the need  
            to provide adequate water supplies to an ever-increasing  
            population.  Possible solutions involve increasing the state's  
            overall water supply by creating new reservoirs, increasing  
            the capacity of existing reservoirs, building desalination  
            recycled water facilities, fixing leaks in the water delivery  
            system, and/or treating contaminated groundwater basins, or  
            decreasing or slowing water demand in the state by increasing  
            water conservation and efficiency measures, reducing the  
            demands of landscaping, encouraging the infill construction of  
            multi-unit housing in urban areas, and/or limiting population  
            growth in more problematic hydrologic regions.

            While local agencies are currently required to ensure adequate  
            water supplies are available to support the additional water  
            demands resulting from new major residential subdivision  
            development, this bill attempts to make sure that total water  
            consumption in individual hydrologic regions will not increase  
            due to the construction and use of new residential and  
            commercial buildings.  By establishing a ceiling on water  
            consumption in each hydrologic region, the bill provides  
            substantial benefit to the existing residential and commercial  
            inventory in the region, especially those homes and buildings  
            in disadvantaged communities, and would make it easier for  
            local water suppliers to comply with the 20% per capital water  
            consumption reduction by 2020 called for the governor earlier  
            this year and proposed to be codified by AB 2175 (Laird).

           3)What is Net Effect on Water Consumption  ?  This bill's  
            co-sponsors, the Planning and Conservation League and the  
            Environmental Justice Coalition for Water, contend the  
            proposed mitigation requirements are intended to completely  
            offset any projected increase in water consumption resulting  
            from the use of a new residential or commercial building, with  
            measures that reduce water consumption or expand water supply  
            by the same amount.  For example, if a new 500-home  
            subdivision, even after being fitted with all feasible and  
            cost-effective water efficiency devices and systems, is  
            projected to increase annual water consumption by 250  
            acre-feet (or 82 million gallons), the developer must mitigate  
            that increased water consumption by taking measures that  
            reduce water consumption or increase water supply in the same  
            hydrologic region by 250 acre-feet, of which 100 acre-feet  
            must be in disadvantaged communities.









                                                                  AB 2153
                                                                  Page  4

            The net effect of the mitigation measure requirement, however,  
            may be to reduce overall consumption in the region beyond the  
            break-even point, depending on what water rights apply to the  
            land being developed into new residential and commercial  
            buildings, and how much water was being consumed on that land  
            before the development.  Going back to the example, if the  
            500-home subdivision is built on a 100-acre plot of land that  
            possessed water rights that allowed diversions of 500 acre  
            feet per year, the potential savings in water consumption in  
            the region from the mitigation measures required by this bill  
            is actually 750 acre feet of water annually.  If the 100-acre  
            plot of land was being actively used for agricultural purposes  
            using 400 acre-feet per year, while the new homes would  
            actually reduce water consumption on that land by 150 acre  
            feet per year, the developer would still have to take  
            mitigation measures to reduce water consumption or increase  
            water supply elsewhere in the hydrologic region by 250 acre  
            feet per year.

            According to this bill's co-sponsors, the potential or actual  
            prior water consumption of particular plots of land are not  
            considered when determining how much water consumption  
            reductions or water supply increases must be provided by the  
            developer.  In many cases, therefore, this bill will result in  
            a net benefit to a hydrologic region in terms of reduced water  
            consumption or increased water supply, or both.

           4)Hydrologic Regions  .  There are 10 major hydrologic regions in  
            California, as follows:

             a)   North Coast.
             b)   San Francisco Bay.
             c)   Central Coast.
             d)   South Coast.
             e)   Sacramento River.
             f)   San Joaquin River.
             g)   Tulare Lake.
             h)   North Lahontan (eastern slope of north Sierra Nevada  
               Mountains and Cascades.
             i)   South Lahontan (eastern slope of south Sierra Nevada  
               Mountains and Tehachapis.)
             j)   Colorado River.

            In addition, the San Joaquin-Sacramento Delta and the Sierra  
            Nevada mountain counties contain significant water resources.








                                                                  AB 2153
                                                                  Page  5


           5)Questions  .  There are several provisions and requirements open  
            to interpretation or do not clearly track with the author's or  
            co-sponsor's intent:

              a)   What projects are covered  ?  The mitigation measure  
               requirements apply to all new residential and commercial  
               building projects that are  subject  to CEQA.  All  
               significant projects beyond minor modifications to an  
               existing property are subject to CEQA.  The developers of  
               most of these projects are not required to develop full  
               environmental impact reports (EIRs), but are rather the  
               recipients of negative declarations made by the local or  
               state lead agency that mean the developer does not have to  
               go through the EIR process.  

              b)   Should this new process be in CEQA law  ?  CEQA requires a  
               lead agency and project developer to consider the potential  
               environmental impacts resulting from the construction and  
               use of the project.  This bill establishes a process to  
               control and reduce pressure on individual hydrologic  
               regions by reducing overall water consumption and/or  
               increasing overall water supply in the region.  Such a  
               statutory requirement should not be placed in CEQA law, but  
               rather should be placed in the Water Code.

              c)   Subject to lead agency review and approval are  
               mitigation measures only  ?  This bill specifies that the  
               mitigation measures a developer must carry out are subject  
               to review and approval by the appropriate lead agency.  The  
               appropriate lead agency could decide not to review and  
               approve these measures.  The appropriate provision, to  
               achieve the author's and co-sponsors' goal, would read "The  
               mitigation measures?must be reviewed and approved by the  
               lead agency."

              d)   What is real  ?  This bill requires mitigation measures,  
               among other things, to be "real."  This language appears to  
               be extraneous and rather subjective.

              e)   What produces water  ?  The mitigation measures a  
               developer must, among other things, "produce an amount of  
               water equal to the projected water usage of the project."   
               Many of the mitigation measures listed by this bill do not  
               produce water.  Water efficiency measures, such as water  








                                                                  AB 2153
                                                                  Page  6

               conservation and fixing leaky delivery pipes, while  
               stretching water supplies, do not produce water.

           6)Related Legislation  :

             a)   AB 2175 (Laird) establishes a process by which urban  
               water consumption, on a per capita basis, would have to be  
               reduced by 20% by the year 2020, and by which agricultural  
               water consumption would  have to be reduced substantially.   
               AB 2175 is on this committee's Suspense File.

             b)   AB 2751 (Wyland) - Chapter 194, Statutes of 2006  
               prohibits a local agency from imposing "fees" on developers  
               that include the "costs attributable to existing  
               deficiencies in public facilities."  While AB 2751 applies  
               to fees imposed by local agencies, there may be some  
               question as to whether the mitigation measures required by  
               AB 2153 amount to "fees." 

           Analysis Prepared by  :    Steve Archibald / APPR. / (916)  
          319-2081