BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 914
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          Date of Hearing:  April 27, 2009

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                     AB 914 (Logue) - As Amended: April 23, 2009
                                           
                                   PROPOSED CONSENT
                                           
          SUBJECT  :  MANDATORY MINIMUM CIVIL PENALTIES (MMPs): PUBLICLY  
          OWNED TREATMENT WORKS

           KEY ISSUE  :  SHOULD THE SIZE AND TYPE OF SMALL COMMUNITY  
          FACILITIES THAT ARE ALLOWED ALTERNATIVES TO MANDATORY MINIMUM  
          PENALTIES (MMPs) BE INCREASED, AND SHOULD A LESSER PENALTY THAN  
          THE MMP BE ALLOWED IN CERTAIN SPECIFIED CASES?

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

                                      SYNOPSIS
          
          This non-controversial bill was approved by the Environmental  
          Safety and Toxic Materials Committee on April 21, 2009, by a  
          vote of 7-0.  The bill as amended merely increases the size and  
          type of small community facilities that are allowed to use  
          alternatives to mandatory minimum civil penalties (MMPs) for  
          remediation of Water Code violations and provides an additional  
          alternative to MMPs.  Existing law imposes a mandatory minimum  
          penalty of $3,000 for each serious waste discharge violation, or  
          for certain other violations if they occur four or more times in  
          any period of six months.  Existing law also authorizes the  
          state board or a regional board to elect, in lieu of assessing  
          the MMP against a "publicly owned treatment works serving a  
          small community" (POTW), defined as a publicly owned treatment  
          works that serves a population of 10,000 or fewer, to require  
          the POTW to spend an equivalent amount toward completion of a  
          compliance project proposed by that POTW if certain requirements  
          are met.  This bill would expand the definition of a POTW  
          serving a small community, so that it includes treatment works  
          or drinking water systems serving a population of 20,000 or  
          fewer.  This bill would also authorize the state board or a  
          regional board to assess a penalty against a POTW serving a  
          small community that is less than the MMP, if the amount of the  
          alternative penalty reflects a consideration of the size of the  
          community being served by the POTW, the affordability of the  
          penalty, and the impact of the water quality violation.  The  








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          bill is supported by Nevada County and has no known opposition.

           SUMMARY  :  Expands the definition of a publicly owned treatment  
          works (POTW) serving a small community, and provides an  
          additional alternative to imposition of MMPs on those POTWs.    
          Specifically,  this bill  :  

          1)Authorizes the state board or a regional board to assess a  
            penalty against a publicly owned treatment works (POTW)  
            serving a small community that is  less  than the mandatory  
            minimum penalty, if the amount of the alternative penalty  
            reflects the following: 

             a)   A consideration of the size of the community being  
               served by the POTW;
             b)   The affordability of the penalty; and 
             c)   The impact of the water quality violation.

          2)Expands the definition of a "publicly owned treatment works  
            serving a small community" to include treatment works or  
            drinking water systems serving a population of 20,000 or  
            fewer.

           EXISTING LAW  :

          1)Authorizes the State Water Resources Control Board (SWRCB) and  
            the California regional water quality control boards (RWQCBs)  
            to prescribe waste discharge requirements in accordance with  
            the federal Clean Water Act.  (Water Code section 13385(a).)

          2)Imposes a mandatory minimum penalty, with certain exceptions,  
            of $3,000 for each serious waste discharge violation, as  
            defined, or for certain other described violations if those  
            violations occur four or more times in any period of 6  
            consecutive months.  (Water Code section 13385(h).)

          3)Authorizes the state board or a regional board to elect to  
            require a "publicly owned treatment works (POTW) serving a  
            small community," in lieu of assessing the MMP against that  
            POTW, to spend an equivalent amount toward completion of a  
            compliance project proposed by that POTW if certain  
            requirements are met.  (Water Code section 13385(k).)

          4)Defines a "publicly owned treatment works serving a small  
            community" as a publicly owned treatment works that serves a  








                                                                  AB 914
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            population of 10,000 or fewer.  (Water Code section  
            13385(k)(2).)

           COMMENTS  :  According to the author, this non-controversial bill  
          is necessary because, "In many instances, fees and penalties for  
          some small community waste water treatment plants are so severe  
          that they represent a substantial impediment to achieving  
          compliance.  AB 914 is meant to lessen the burden on smaller  
          communities that do not have the resources to afford such  
          regulations."  The legislation was introduced in response to  
          water discharge violations that occurred at Cascade Shores, Lake  
          Wildwood, and Lake of the Pines in Nevada County.

          Mandatory minimum penalties (MMPs) were established in 1999 in  
          response to concerns over the SWRCB and RWQCB failing to take  
          enforcement actions against Water Code violations.  This bill  
          would merely expand the definition of a POTW serving a small  
          community to include drinking water as well as water treatment  
          works, and to include POTWs serving populations of 20,000 or  
          fewer rather than 10,000 or fewer.  Moreover, the bill will  
          allow those POTWs to be assessed a penalty lower than the MMP  
          only under certain limited circumstances.  Existing law already  
          provides an alternative to MMPs for POTWs serving small  
          communities, by allowing them to spend an equivalent amount  
          toward completion of a compliance project proposed by the POTW  
          if certain requirements are met.  This bill would provide an  
          additional alternative to MMPs by allowing a lesser amount to be  
          imposed if the penalty reflects the size of the community being  
          served, the affordability of the penalty, and the impact of the  
          violation.  The author states that this bill is necessary to  
          ensure that POTWs serving smaller communities are not unduly  
          burdened by MMPs.

           Prior Related Legislation  .  AB 2900 (La Malfa), 2008: Water  
          quality: civil penalties.  This bill would have required the  
          State Water Resources Control Board or a regional water quality  
          control board to expeditiously take appropriate action to assess  
          any mandatory minimum penalty for each serious waste discharge  
          violation of the federal Clean Water Act and the Porter-Cologne  
          Water Quality Control Act.  The bill died in the Assembly  
          Committee on Environmental Safety and Toxic Materials.

          SB 390 (Alpert), Chapter 686, 1999:  Liability: waste discharge.  
           Revised the authority of regional water quality control boards  
          to waive waste discharge requirements of the Porter-Cologne  








                                                                  AB 914
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          Water Quality Control Act as to a specific discharge if the  
          waiver is not against the public interest and is not for a  
          period to exceed five years; required regional boards and the  
          State Water Resources Control Board to enforce the conditions  
          under which a waiver was granted;  required the regional boards,  
          prior to renewing any waiver, to review the terms of the waiver  
          at a public hearing; and revised liability provisions where a  
          person violates prescribed orders or discharges waste in  
          violation of a waste discharge requirement or other order or  
          prohibition to include waivers or conditions.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Nevada County (sponsor)

           Opposition 
           
          None on file

           Analysis Prepared by  :  Drew Liebert and Rachel Anderson / JUD. /  
          (916) 319-2334