BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 580
                                                                  Page 1

          Date of Hearing:   April 14, 2009

           ASSEMBLY COMMITTEE ON ENVIRONMENTAL SAFETY AND TOXIC MATERIALS
                                Wesley Chesbro, Chair
                  AB 580 (Huber) - As Introduced:  February 25, 2009
                              As Proposed To Be Amended
           
          SUBJECT  :   Onsite Waste Treatment Systems.

           SUMMARY  :   Provides that the State Water Resources Control Board  
          (SWRCB) shall establish exemptions criteria from the statewide  
          standards for Onsite Waste Treatment Systems (OWTS).

           EXISTING LAW:
           
             1)    Under the Porter-Cologne Water Quality Control Act,  
               creates the SWRCB and Regional Water Quality Control Boards  
               (RWQCBs) and provides these entities with various  
               responsibilities relating to water quality.

             2)   Authorizes the RWQCBs to prohibit the discharge of waste  
               from onsite systems.  Generally, local health officers are  
               charged with protecting the health of members of the  
               public.  Regional boards are charged with protecting the  
               beneficial uses of the resources.

             3)   Under the provisions of AB 885 (Jackson) Chapter 781,  
               Statutes of 2000, requires the SWQCB to provide statewide  
               minimum requirements related to the permitting and  
               operation of OWTS.  The minimum requirements include  
               exemption criteria to be established by the RWQCBs.

           FISCAL EFFECT  :  None known

           COMMENTS  :

           Assembly Bill 885 (Jackson) 2000
           
          According to the SWRCB, the current practice of regulating OWTS  
          has led to inconsistencies among the various RWQCBs and among  
          the numerous local agencies in California's 58 counties.  For  
          example, although most counties have some type of minimum  
          performance requirements and siting and design requirements  
          specifically for OWTS and such requirements vary greatly from  
          one jurisdiction to another.  California is one of only two  








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          states that do not have statewide OWTS regulations.  The  
          inconsistency in regional and local OWTS requirements and  
          related lack of statewide regulations, along with the public  
          health and environmental issues and related incidents, are the  
          primary reasons why AB 885 was introduced by Assembly member  
          Hannah Beth Jackson in February 1999 and passed by the  
          California Legislature and signed into law in 2000 (Chapter 781,  
          Statutes of 2000).

          The provisions of AB 885 provide direction from the legislature  
          to the SWRCB to provide statewide minimum requirements related  
          to the permitting and operation of OWTS.  Typically, RWQCBs have  
          adopted minimum requirements for OWTS in their water quality  
          control plans and have worked with local agencies (counties,  
          cities, and special districts) through a formal or informal  
          agreement.  When a RWQCB and local agency enter into such an  
          agreement, the local agency commits to implement basin plan  
          requirements for OWTS at the local level.
           Assembly Bill 885 and the Development of Statewide OWTS  
          Regulations  .
               
          AB 885 requires the SWRCB to develop statewide OWTS regulations  
          in consultation with Department of Public Health, the Coalition  
          of California Directors of Environmental Health, the California  
          Coastal Commission, counties, cities, and other interested  
          parties.  AB 885 also requires the regulations to include, at a  
          minimum, these seven types of requirements (often referred to as  
          AB 885's "seven points"):

             1)   Minimum operating requirements that may include siting,  
               construction and performance requirements;

             2)   Requirements for OWTS adjacent to waters listed as  
               impaired under Section 303(d) of the Clean Water Act;

             3)   Requirements authorizing local agency implementation;

             4)   Corrective action requirements;

             5)   Minimum monitoring requirements;

             6)   Exemption criteria; and

             7)   Requirements for determining when an existing OWTS is  
               subject to major repair.








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          AB 885 requires the Regional Water Boards to incorporate the new  
          statewide regulations into their basin plans.  Neither the  
          legislation nor the proposed OWTS regulations preempt the  
          ability of the Regional Water Boards or any local agency to  
          adopt or retain performance requirements for OWTS that are more  
          protective of public health or the environment than the new  
          statewide regulations.

           The Proposed OWTS Regulations.
           
          The SWRCB officially submitted regulations in response to the  
          requirements of AB 885 on 11/7/09 and made them available for  
          public comments along with a Draft Environmental Impact Report.   
          The key elements of the proposed regulations included:

             1)   Owners must have their septic tanks inspected for solids  
               accumulations every five years by a qualified service  
               provider.

             2)   Owners with an onsite domestic well on their property  
               must have a state certified analytical laboratory analyze  
               well water (groundwater) for specified constituents once  
               every five years and report the results electronically to  
               the SWRCB.

             3)   Owners whose existing septic systems are within 600 feet  
               of a surface water body that does not meet water quality  
               standards (impaired water body) will be subject to special  
               requirements. 

             4)   Owners will have to keep documentation to show that they  
               are adhering to the regulations.

             5)   Where existing septic systems have been identified by a  
               RWQCB to be contributing to the water quality impairment  
               (pollution) of specific surface water bodies, owners of  
               septic systems within 600 feet of the impaired surface  
               water body will be required to have a qualified  
               professional determine whether the septic system is  
               contributing to the impairment.  If so, retrofit the septic  
               system with supplemental treatment.

           SWRCB Plans Review of OWTS Regulations.
           








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          On February 23, 2009, the SWRCB closed the public comment period  
          for draft regulations regarding OTWS.  According to the SWRCB,  
          during the comment period the SWRCB received more than 2,500  
          e-mail comments and hundreds of comments from 12 public  
          workshops held throughout the state.  Based on the public input  
          on the proposed regulations, the SWRCB is formulating  
          substantial changes to the regulations.  Those revised  
          regulations are anticipated to be developed by August of 2009.

           Committee Recommendations

           In light of the SWRCB's recent review of the proposed OWTS  
          regulations, it may be premature of the committee to modify the  
          underlying provisions of AB 885 until the SWRCB review has been  
          completed and the proposed regulations have been revised.

          The Committee may wish to approve a bill while recognize that  
          regulatory action will be take place in the next 2 to 4 months.   
          The legislation should be providing general direction on the  
          OTWS regulatory action, but the committee may wish to  
          re-evaluate the need for a bill after the upcoming review of the  
          regulations has been completed.

          The general elements of a bill would be to modify the provisions  
          of AB 885 (Water Code Section 13291) to provide:

             1)   Requirements that recognize the varying degrees of  
               public health or environmental risk posed by OWTS; and

             2)   Local agencies to implement the SWRCB's regulations or  
               standards for OWTS.  The local agencies would certify their  
               ability to oversee the new OWTS requirements and RWQCBs  
               would review the certification.

          RELATED LEGISLATION  :

             1)   AB 268 (Gaines) Relating to On Site Sewage Treatment  
               Systems.  Repeals the requirements of AB 885(Jackson) that  
               require the SWRCB to adopt regulations on the operations  
               and siting of OWTS.

             2)   AB 916(Logue) Relating to On Site Sewage Treatment  
               Systems.  Provides that the SWRCB actions shall be limited  
               to recommended standards rather than establishing  
               enforceable regulations.








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           REGISTERED SUPPORT / OPPOSITION  :

           Support
           
          None received

           Opposition
           
          Heal the Bay
           

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