BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2529
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          ASSEMBLY THIRD READING
          AB 2529 (Fuentes)
          As Amended  May 28, 2010
          Majority vote

           BUSINESS & PROFESSIONS   8-2    APPROPRIATIONS      17-0        
           
           ----------------------------------------------------------------- 
          |Ayes:|Hayashi, Emmerson,        |Ayes:|Fuentes, Conway, Ammiano, |
          |     |Conway, Hernandez, Hill,  |     |                          |
          |     |Ma, Niello, Smyth         |     |Bradford, Charles         |
          |     |                          |     |Calderon, Coto,           |
          |     |                          |     |Davis, Harkey, Miller,    |
          |     |                          |     |Monning,                  |
          |     |                          |     |Nielsen, Norby, Ruskin,   |
          |     |                          |     |Skinner,                  |
          |     |                          |     |Solorio, Torlakson,       |
          |     |                          |     |Torrico                   |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Nava, Ruskin              |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 

           SUMMARY  :  Establishes a peer review process for specified  
          agencies with regards to a proposed action for a major proposed  
          regulation (MPR).  Specifically,  this bill  :  

          1)Requires the State Air Resources Board, the Energy Commission,  
            the Department of Fish and Game and the Department of Housing  
            and Community Development (agency) to complete and include a  
            related economic impacts analysis within the notice of  
            proposed action for a MPR.

          2)Requires the agency to enter into an agreement with the  
            National Bureau of Economic Research, the University of  
            California, the California State University, or a group of  
            economists of comparable stature and qualifications to conduct  
            an external peer review of the related economic impacts  
            analysis of the MPR if each of the following conditions occur:  


             a)   Within 15 days of the public disclosure of the notice of  
               proposed action, as specified, a person submits, in the  
               manner prescribed by the agency, a request for the agency  








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               to submit the related economic impacts analysis for  
               external peer review pursuant to this bill;

             b)   The requester pays an administrative fee to the agency  
               to cover the costs of processing the request.  The  
               administrative fee shall be in an amount determined by the  
               agency, not to exceed the costs of processing the requests,  
               and in no event to exceed $500; and,

             c)   The requester and the agency, within 30 calendar days of  
               the date that the request is submitted, enter into a  
               contract whereby the requester shall be required to fully  
               reimburse the agency for the nonadministrative costs  
               incurred by the agency to obtain the completed peer review  
               from the peer review entity (PRE).

          3)Requires the agency to select external peer reviewers (EPR)  
            using existing legal processes.

          4)Prohibits a person from serving as an EPR if that person  
            participated in the development of the related economic  
            impacts analysis of the MPR, or if that person has a financial  
            interest in an entity or person that would be subject to the  
            MPR, or has any other conflict of interest.

          5)Prohibits the person who requests the external peer review, a  
            person affiliated with that requester, and personnel of the  
            adopting agency from participating in the selection of the  
            individual EPR, or contacting or communicating with the  
            individual EPR during the peer review. 

          6)Permits the agency to contact or communicate with an EPR for  
            the purpose of entering into the contract with the reviewer  
            and to provide information, as specified.

          7)Requires the identity of individual EPRs to remain  
            confidential until the EPR submits the written report to the  
            specified department or commission.

          8)Requires the agency to meet the following conditions, after  
            the requirements of 1) are met, before taking action to adopt  
            the final version of an MPR:

             a)   The agency submits to the EPR the text of the MPR, the  








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               related economic impacts analysis for the MPR, and other  
               appropriate materials on which the related economic impacts  
               analysis is based;

             b)   The external PRE prepares a written report that contains  
               an evaluation of the related economic impacts analysis  
               within a timeframe determined by the agency.  If the  
               external PRE finds that the related economic impacts  
               analysis prepared by the agency is not based upon sound  
               economic knowledge, methods, or practices, the report shall  
               state that finding and the reasons supporting that finding;

             c)   The agency accepts the findings of the external PRE, in  
               whole or in part, and revises the MPR accordingly, or  
               rejects the finding.  If the agency disagrees with any  
               aspect of the findings of the external PRE, it shall  
               explain, and include as part of the rulemaking record, its  
               basis for the disagreement, including support for its  
               determination that the related economic impacts analysis is  
               based on sound economic knowledge, methods, and practices;  
               and,  

             d)   A public hearing is conducted to provide opportunity for  
               public comment on the written report prepared by the  
               external PRE or, as appropriate, the agency explanation  
               relating to its disagreement with the written report.  The  
               public hearing shall be in addition to any public hearing  
               for purposes of adopting the final version of the MPR.  The  
               agency shall not issue notice of a public hearing on  
               adoption of the final version of the MPR until the public  
               hearing has concluded.

          9)Does not require an agency to comply with the above  
            requirements, and instead allow the agency to proceed with the  
            adoption of the final version of the MPR if the external PRE  
            fails to provide a written report to the agency by the  
            deadline.  

          10)Exempts emergency regulations, as specified, from this bill.

          11)Prohibits this bill from being construed to limit the  
            authority of an agency to adopt a regulation pursuant to the  
            requirements of any other law that authorizes or requires the  
            regulation's adoption. 








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          12)Does not require the agency to conduct additional peer  
            reviews after one external peer review of related economic  
            impacts analysis has been completed for a MPR. 

          13)Requires the office to notify the fiscal committees of each  
            house of the Legislature and the Joint Legislative Budget  
            Committee of each MPR that is approved or deemed approved by  
            the office, as specified.  The notification shall include the  
            text of the regulation, the related economic impacts analysis  
            conducted by the agency, and the written report, if any, of  
            the EPR.

          14)Sunsets on January 1, 2016. 

          15)Defines the following terms:

             a)   "Agency" means only the State Air Resources board, the  
               Energy Commission, the Department of Fish and Game, and the  
               Department of Housing and Community Development;

             b)   "MPR" means a proposed adoption, amendment, or repeal of  
               a regulation that will have an adverse economic impact on  
               California business enterprises and individuals in an  
               amount exceeding $10 million, as estimated by the agency in  
               the assessment required, as specified; and,

             c)   Related economic impacts analysis" means an analysis of  
               the reasonably identifiable and significant impacts of a  
               major proposed regulation, that are premised upon, or  
               derived from, empirical data or other scientific or  
               economic findings, conclusions, or assumptions, including,  
               but not limited to:

               i)     Short-term and long-term jobs within this state in  
                 individual sectors of the economy affected by the MPR;  
                 and,

               ii)    The revenues to the General Fund and special funds  
                 that result from changes in economic activity  
                 attributable to the MPR;

           EXISTING LAW  :









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          1)Establishes requirements for the adoption, publication,  
            review, and implementation of regulations by state agencies,  
            under the Administrative Procedure Act (APA).

          2)Requires a state agency to submit to the OAL an initial  
            statement of reasons for proposing the adoption, amendment,  
            repeal of a regulation that includes a description of  
            reasonable alternatives to the regulation.

           FISCAL EFFECT :  According to the Assembly Appropriations  
          Committee:

          1)Potential ongoing costs to the affected departments of an  
            unknown amount, but likely in the range of several hundred  
            thousand dollars, for the departments to contract with outside  
            entities for peer review of proposed major regulations.  The  
            departments' actual costs will depend upon the number of peer  
            reviews they must contract for and the cost of each peer  
            review.  In any case, the bill provides that the departments  
            will be reimbursed for these costs by the person requesting  
            the peer review.

          2)Potential ongoing costs to the departments to process  
            applications for peer review, fully covered by the processing  
            fee authorized by this bill. 

           COMMENTS  :   According to the author's office, "While an  
          assessment of the economic impact on California business  
          enterprises and individuals comprises part of the rulemaking  
          process, an agency's assessment is not reviewed by an  
          independent third party to ensure accuracy, and therefore could  
          result in regulations with significant adverse economic impacts  
          on Californians, impacts that may not have been the intent of  
          the legislature's original statute.  This bill remedies this  
          deficiency."

          The APA governs the adoption of regulations by state agencies  
          for purposes of ensuring that they are clear, necessary, legally  
          valid, and available to the public.  In seeking adoption of a  
          proposed regulation, state agencies must comply with procedural  
          requirements that include publishing the proposed regulation  
          along with supporting statement of reasons; mailing and  
          publishing a notice of the proposed action 45 days before a  
          hearing or before the close of the public comment  period; and  








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          submitting a final statement to OAL which summarizes and  
          responds to all objections, recommendations, and proposed  
          alternatives that were raised during the public comment period.   
          The OAL is then required to approve or reject the proposed  
          regulation within 30 days.
           
          More specifically related to this bill, the APA requires an  
          evaluation of the negative impact a proposed regulation would  
          have on businesses and reasonable alternatives that would  
          eliminate undue burdens.  The APA also requires state agencies  
          to justify their proposed regulations by evaluating the  
          technical and empirical evidence that supports the proposed  
          regulation in comparison to reasonable alternatives.

           
          Analysis Prepared by  :    Rebecca May / B.,P. & C.P. / (916)  
          319-3301 


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