BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 804
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          Date of Hearing:   April 14, 2009

                   ASSEMBLY COMMITTEE ON WATER, PARKS AND WILDLIFE
                            Jared William Huffman, Chair
                  AB 804 (Hall) - As Introduced:  February 26, 2009
           
          SUBJECT  :   Invasive Aquatic Species:  Mussels

           SUMMARY :   Provides that an operator of water delivery and  
          storage facilities who has prepared and implemented a plan to  
          control and eradicate dreissenid mussels in accordance with  
          existing law is immune from civil or criminal liability for  
          introduction of mussels as a result of operation of those  
          facilities, and exempts such operators from prohibitions on  
          possession, importation, shipment or transport of mussels and  
          other requirements.  Specifically,  this bill  :

          1)Provides that if the operator of water delivery or storage  
            facilities for public water supply purposes prepares and  
            implements a plan to control and eradicate dreissenid mussels  
            in accordance with provisions of existing law, the following  
            requirements would not apply to the operation of those  
            facilities:
               a)     The requirement that a person shall not possess,  
                 import, ship, or transport in the state or cause to be  
                 placed or planted in any water within the state,  
                 dreissenid mussels, 
               b)     Provisions authorizing the director of the  
                 Department of Fish and Game (DFG) to conduct inspections,  
                 order closures or quarantines, or restrict access to  
                 waters or facilities.

          2)Provides that if DFG requires the operator of a facility to  
            update its plan for control and eradication of dreissenid  
            mussels, and the plan is not updated as required, the above  
            requirements referenced under 1) shall apply until the  
            operator updates or revises the plan.

          3)Provides that the operator of water delivery or storage  
            facilities for public water supply purposes that prepares and  
            implements a plan to control and eradicate mussels in  
            accordance with existing law shall be immune from civil or  
            criminal liability for introduction of mussels as a result of  
            operation of those facilities.









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          4)Requires DFG, in conjunction with the Department of Water  
            Resources (DWR), to conduct a study on quagga mussels. 

          5)Makes various legislative findings and declarations regarding  
            quagga mussels and the need to protect water agencies from  
            liability.

           EXISTING LAW  :  Makes it unlawful to possess, import, ship,  
          transport, or place dreissenid mussels in any water within the  
          state, and authorizes DFG to conduct inspections of conveyances,  
          waters, and water facilities that may contain mussels, and to  
          order closures, quarantines and disinfections if mussels are  
          detected.  Prohibits a closure or quarantine from being imposed  
          by the DFG director without the concurrence of the Secretary of  
          Resources. Requires water supply agencies to cooperate with DFG  
          to implement measures to avoid infestation and to control or  
          eradicate any infestations that occur.  Requires water supply  
          system operators, if mussels are detected, to prepare and  
          implement plans to control or eradicate mussels, and to update  
          the plans as required by DFG.

           FISCAL EFFECT  :   Unknown costs to DFG and DWR to conduct a  
          study.

           COMMENTS  :   Dreissenid mussels, which include quagga and zebra  
          mussels, are highly invasive species that were first discovered  
          in the United States in the Great Lakes region in 1988, where  
          they have caused billions of dollars in damage control costs to  
          public agencies and private industry.   Quagga mussels were  
          first discovered in California in January of 2007 in Lake  
          Havasu, and have since spread through the Colorado River  
          Aqueduct to reach several southern California reservoirs.  Zebra  
          mussels were first detected in California in January of 2008 in  
          Hollister's San Justo Reservoir in San Benito County.  The San  
          Justo Reservoir gets its water from the San Luis Reservoir which  
          is used jointly by the federal Central Valley Project and the  
          California State Water Project.  Both of these invasive species  
          reproduce rapidly and in large numbers, and can severely hinder  
          water delivery systems due to their capacity to clog pipes,  
          pumps and other water intake structures.  They are also harmful  
          to aquatic ecosystems by consuming plankton and other nutrients  
          that form the primary base of the food chain. 

          Based on the billions of dollars in damages caused by dreissenid  
          mussels in the Great Lakes region, these invasive species could  








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          seriously threaten California's entire irrigation network, and  
          the canal system that transports drinking water for millions of  
          Southern California residents.  According to the state's Aquatic  
          Invasive Species plan, if a mussel invasion is not prevented,  
          the economic and social consequences to California may be  
          incalculable.  In addition to the state's natural ecosystems and  
          water conveyance systems, a mussel invasion threatens other  
          valuable state resources, including commercial and sport  
          fisheries.

           Arguments in Support  :  The Association of California Water  
          Agencies (ACWA) has introduced this bill to limit water agency  
          liability for damages caused by dreissenid mussels.   ACWA  
          asserts that this bill is necessary to ensure that water system  
          operators and their employees, who are observing current legal  
          requirements to the best of their ability to control or  
          eradicate quagga mussels, are not subject to unwarranted civil  
          or criminal penalties.  They also note that even when a water  
          system operator diligently implements a sound plan, complete  
          eradication is not guaranteed or likely.  The legislative  
          findings in this bill further note that given the likely  
          impossibility of completely eradicating mussel infestations from  
          large water bodies, and the fact that water delivery systems are  
          essential to maintain public health and safety, implementation  
          of available measures to control and prevent the spread of  
          mussels to new water bodies is all that should reasonably be  
          required of water supply agencies.  For all these reasons, the  
          author and sponsor believe that criminal and civil penalties are  
          an inappropriate response to owners and operators who are  
          pursuing a control and eradication plan and who are in  
          compliance with the requirements of current law.        

          Immunity Provision:  This bill would provide absolute immunity  
          from civil or criminal liability to any operator of a water  
          delivery and storage facility for introduction of dreissenid  
          mussels as a result of those operations, if the operator has  
          prepared and implemented a plan to control or eradicate mussels  
          as required by existing law.   The committee may wish to  
          consider whether the immunity provision is adequately drafted to  
          ensure that it can not be construed to protect an operator from  
          immunity for intentionally or negligently introducing mussels  
          into a water body.  The author and sponsors believe that this  
          provision as currently worded would not immunize operators who  
          commit intentional or grossly negligent acts that result in  
          introduction of mussels, since it requires that the plan be  








                                                                  AB 804
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          prepared and implemented as required by law.  However, it is  
          unclear what would constitute "implementation" for the immunity  
          to apply.   For instance, if an operator has developed and  
          implemented the provisions of a plan, but then either  
          intentionally or negligently fails to diligently comply with all  
          of the control and monitoring methods called for in the plan,  
          resulting in the introduction of mussels, would the immunity  
          apply?  Due to the interconnected nature of many of California's  
          water systems, and the pathways through which mussels may be  
          transported from one water body to another, the failure of one  
          water facility to take adequate measures to prevent the spread  
          of mussels may pose significant threats to other water facility  
          operators, and to the state.  For these reasons, the state has  
          an interest in ensuring that protections from liability are  
          carefully crafted to ensure adequate incentives exist for all  
          water system operators to take concerted action to prevent and  
          control the spread of invasive mussels.  In light of the  
          significant state interests at stake, the committee may wish to  
          consider whether granting this kind of immunity would help or  
          hinder efforts to control invasive mussels.  Note:  This bill  
          has been double-referred to the Assembly Judiciary Committee  
          which will also be analyzing the immunity provision.

          In addition, if the immunity proposed in this bill is granted,  
          the state will in effect be relying on DFG's capacity to monitor  
          the development and implementation of the plans, which will  
          require that DFG have the resources to do so.  For this reason,  
          if the immunity is granted the committee may wish to consider  
          whether water operators should be required to pay a fee to cover  
          DFG's costs of planning, oversight and enforcement of the plan  
          requirements.

          Exemption from requirements relating to state inspections and  
          other restrictions:  This bill also exempts water facilities  
          that adopt and implement a plan from provisions authorizing DFG  
          to conduct inspections and order closures, quarantines,  
          disinfections and other controls to prevent the spread of  
          invasive mussels.  The committee may wish to consider whether  
          this provision is overly broad, since DFG may need to conduct  
          inspections in order to ensure that the plans are being followed  
          and updated as required by law.  Existing law also requires  
          concurrence of both the director of DFG and the Secretary of  
          Resources before any closure, quarantine or other restriction  
          can be ordered.  For these reasons, staff recommends the  
          committee adopt an amendment, on page 5, line 34, to limit the  








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          exemption to the requirements of subdivision (a)  (1)  .  
             
           REGISTERED SUPPORT / OPPOSITION  :  

           Support  
          Association of California Water Agencies (sponsor)
          California Central Valley Flood Control Association
          California Special Districts Association
          East Bay Municipal Utility District
          Eastern Municipal Water District
          El Dorado Irrigation District
          Friant Water Authority
          Las Virgenes Municipal Water District
          Metropolitan Water District
          Three Valleys Municipal Water District
          Valley Ag Water Coalition
          Western Municipal Water District

           Opposition  
          None on file.
           
          Analysis Prepared by  :    Diane Colborn / W., P. & W. / (916)  
          319-2096