BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2595
                                                                  Page  1

          Date of Hearing:   May 19, 2010

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                Felipe Fuentes, Chair

                   AB 2595 (Huffman) - As Amended:  April 22, 2010 

          Policy Committee:                              Environmental  
          Safety and Toxic Materials                    Vote: 6-0
                       Agriculture                            7-1     

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

           SUMMARY  

          This bill requires a county agricultural commissioner to  
          withhold issuance of an operator identification number (OIN) for  
          pesticide use for an agricultural operator found to violate  
          certain water quality requirements.  Specifically, this bill:

          1)Codifies the existing regulatory requirement that an  
            agricultural operator obtain an OIN from a country  
            agricultural commissioner for each county in which pesticide  
            work is to be preformed for the production of an agricultural  
            commodity.

          2)Require the water boards to notify the Department of Pesticide  
            Regulation (DPR) and the agricultural commissioner if, after  
            exhausting all administrative proceedings and appeals, an  
            operator fails to:

             a)   Furnish pesticide use report to DPR and the county  
               agricultural commissioners, as required by current law. 

             b)   Enroll in the Irrigated Lands Conditional Waiver Program  
               (ILCWP), or obtain an individual or general waiver of waste  
               discharge requirements related to irrigated agriculture.

          3)Requires a county agricultural commissioner, with certain  
            exceptions, to withhold issuance of an OIN if the operator has  
            been found by a water board to be in violation of any of the  
            requirements described above.

          4)Authorizes a county agricultural commissioner to levy a civil  








                                                                  AB 2595
                                                                  Page  2

            penalty of up to $5,000 against an operator who fraudulently  
            obtains an OIN.

          5)Authorizes DPR to adopt regulations to carry out the bill's  
            provisions.

           FISCAL EFFECT  

          1)One-time costs to DPR, likely in the tens of thousands of  
            dollars, to adopt regulations and to develop a system to track  
            increased workload of county agricultural commissioners, which  
            DPR partially reimburses (Department of Pesticide Regulation  
            Fund (DPRF) or other special fund).  

          2)The water boards indicate minor, absorbable costs.  This is  
            because they anticipate administrative remedies, which the  
            bill requires the water boards to exhaust before reporting an  
            operator to a county agricultural commissioner, to result in  
            nearly all operators filing required reports and enrolling in  
            ILCWP.  The water boards conclude they would rarely resort to  
            reporting an operator's noncompliance to the country  
            agricultural commissioner. 

          3)Ongoing local costs of an unknown amount to the state's county  
            agricultural commissioners. The commissioners were unable to  
            estimate the range of potential costs because, they contend,  
            this bill involves them in an area that currently is outside  
            their experience and jurisdiction-water quality enforcement.

           COMMENTS  

           1)Rationale  .  The author intends this bill to encourage  
            agricultural operators to rapidly enroll in the Irrigated  
            Lands Conditional Waiver Program (ILCWP) for water quality  
            control.  The author contends delays in enrollment in the  
            program have compromised water quality and saddled the water  
            boards with the cost of tracking and enforcing enrollment.   
            The author additionally contends it unfair that some  
            agricultural operators have paid the ILCWP enrollment fee  
            while others have not.

          2)  Background .


              a)   State Regulation of Water Quality  .  The state's water  








                                                                  AB 2595
                                                                  Page  3

               boards-the State Water Resources Control Board (SWRCB) and  
               the nine semiautonomous regional boards-regulate water  
               quality. The regional boards-which are funded by the state  
               board and are under the state board's oversight-implement  
               water quality programs in accordance with policies, plans,  
               and standards developed by the state board.  
               In response to SB 390, Alpert (Chapter 686, Statutes of  
               1999), SWRCB developed the Irrigated Lands Regulatory  
               Program (ILRP) to prevent agricultural discharges from  
               polluting surface water. Under the program, the regional  
               water boards issue conditional waivers allowing  
               agricultural operators to discharge waste.  The waivers  
               include provisions requiring operators to monitor the  
               quality of waters receiving the discharge and to take  
               corrective actions when necessary.  Many agricultural  
               operators have not enrolled in the program or paid the  
               associated fee, despite a legal requirement to do so.  The  
               policy committee analysis indicates that enrollment has  
               increased more recently.


              b)   State Regulation of Pesticide Use  .  DPR administers  
               programs to protect the public health and the environment  
               from unsafe exposures to pesticides. The department (1)  
               evaluates the public health and environmental impact of  
               pesticides use; (2) regulates, monitors, and controls the  
               sale and use of pesticides in the state; and (3) develops  
               and promotes the use of reduced-risk practices for pest  
               management. The department is funded primarily by an  
               assessment on the sale of pesticides in the state (the mill  
               assessment).
               Existing regulation requires an agricultural operator  
               obtain an OIN from a country agricultural commissioner for  
               each county in which pesticide work is to be preformed for  
               the production of an agricultural commodity.  The operator  
               must provide the OIN to each pest control business applying  
               pesticides to the operator's property.


           3)Supporters  include several water quality and environmental  
            groups, including the Sierra Club, who contend the bill  
            provides consequences that will ensure agricultural operators  
            enroll in ILRP, thereby better protecting water quality.  

          4)Opponents  include numerous agricultural industry  








                                                                  AB 2595
                                                                  Page  4

            organizations, who argue the bill will add costs to  
            agricultural production and may prevent an agricultural  
            operator from practicing business, should an OIN be denied.   
            Additionally, the California Agricultural Commissioners and  
            Sealers Association opposes the bill because, the association  
            contends, the bill involves commissioners in a complex and  
            sometimes controversial activity-water quality  
            enforcement-that is well outside their current jurisdiction  
            and expertise.  The association reports that the authors and  
            proponents have not sought the commissioners input in  
            developing this bill.  

           
           Analysis Prepared by  :    Jay Dickenson / APPR. / (916) 319-2081