BILL ANALYSIS                                                                                                                                                                                                    





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          |                                                                 |
          |         SENATE COMMITTEE ON NATURAL RESOURCES AND WATER         |
          |                   Senator Fran Pavley, Chair                    |
          |                    2009-2010 Regular Session                    |
          |                                                                 |
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          BILL NO: AB 2598                   HEARING DATE: June 29, 2010  
          AUTHOR: Brownley                   URGENCY:   No
          VERSION: June 16, 2010             CONSULTANT: Marie Liu  
          DUAL REFERRAL: No                  FISCAL: Yes  
          SUBJECT: Tidelands and submerged lands: sea level action plan.  
          
          BACKGROUND AND EXISTING LAW
          The State Lands Commission (Commission) is charged with managing  
          and protecting the state's tide and submerged lands for the  
          public trust. With legislative approval, the Commission may  
          grant state tidelands to local governments for their use and  
          maintenance. The Legislature has transferred certain sovereign  
          lands in trust to 85 cities, counties, and harbor districts.  
          These "granted" lands include the ports of Los Angeles, Long  
          Beach, San Diego, San Francisco, Oakland, Richmond, Benicia, and  
          Eureka. The Commission has oversight responsibilities over the  
          trustees to ensure compliance with the grant terms, California  
          law, and the Public Trust Doctrine. 

          Report on Sea Level Rise Preparedness: In December 2009, the  
          Commission released a Report on Sea Level Rise Preparedness  
          which summarized the efforts of state agencies, federal  
          agencies, and other coastal states to address sea level rise.  
          The report also contained the results of a survey to the state's  
          major lessees and grantees to assess the extent which they have  
          considered the potential impacts of seal level rise on  
          facilities on granted lands. The survey revealed that, "the  
          majority of survey respondents have not yet begun to  
          comprehensively consider the impacts of sea level rise." The  
          report also made 16 recommendations for Commission consideration  
          including:
           Require all new coastal development projects to consider the  
            implications of and include adaptation strategies for  
            projected sea level rises of 16" and 55", depending on the  
            life of the project.
           Adopt engineering design standards that would require major  
            facilities to withstand a defined storm event, such as a  
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            100-year storm, taking into account sea level rise.
           Evaluate structures subject to the ocean environment (wharves,  
            docks, levees, piers, etc.) for structural integrity and  
            potential hazards as sea level rises.

          California Climate Adaptation Strategy: In December 2009, the  
          Resources Agency released the California Climate Adaptation  
          Strategy (CAS), pursuant to Executive Order S-13-2008, which  
          directed the Resources Agency to identify how state agencies can  
          respond to rising temperatures, changing precipitation patterns,  
          sea level rise, and extreme natural events. The report noted  
          that climate change is already affecting California with  
          increased average temperatures, more extreme hot days, fewer  
          cold nights, shifts in the water cycle, and the lengthening of  
          the growing season. Not addressing these changes can cause  
          significant economic damages to the state in the trillions of  
          dollars. The report argues that the state must address climate  
          change challenges with both climate adaptation and mitigation.  
          The report made a number of preliminary recommendations  
          including: 
           Preparation of agency-specific adaptation plans for sea-level  
            rise.
           Considering project alternatives that avoid significant new  
            development in areas that cannot be adequately protected from  
            climate change impacts.
           Amending general plans and local coastal plans to assess  
            climate change impacts, identify areas most vulnerable to  
            those impacts, and develop reasonable and rational risk  
            reduction strategies.

          PROPOSED LAW
          This bill would require a local trustee of granted public trust  
          lands to prepare a sea level action plan, by July 1, 2011, that  
          shall be transmitted to the Natural Resources Agency, the  
          Governor's Office of Planning and Research, and the State Lands  
          Commission. The plan shall include the following:
           An assessment of sea level rise impacts on the granted lands.
           Maps indicating the areas affected by predicted sea level rise  
            in the years 2050 and 2100.
           Estimates of the fiscal costs of sea level rise on granted  
            lands, including repair costs, lose of use costs, and  
            anticipated mitigation costs.
           Strategies to prevent or mitigate damage to existing  
            development and infrastructure and to protect and enhance  
            undeveloped shorelines. Grantees shall consider, where  
            feasible, using nonengineered measures in accomplishing these  
            strategies.
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           Design standards that would avoid impacts to new development  
            and infrastructure. 
           Implementation measures and timetables.
          The State Lands Commission may exempt a trustee from these plan  
          requirements or allow the trustee to submit a modified plan if  
          (1) none of the trustee's granted lands are subject to sea level  
          rise by 2100, (2) the cost of preparing the plan substantially  
          outweighs the economic and environmental benefits that the plan  
          would bring in respect to sea level rise on their granted lands,  
          and (3) revenues derived from the granted tidelands and outside  
          funding are insufficient to pay for the cost of developing the  
          plan.

          The bill also makes a number of findings regarding  
          responsibilities of trustees of granted lands, the trustee's  
          fiduciary duties to the control and preservation of the granted  
          lands, and the impacts of climate change and sea level rise to  
          the state and port activities specifically.

          ARGUMENTS IN SUPPORT
          The State Controller John Chiang, the sponsor of this bill,  
          states, "[This] measure will improve the State's overall  
          understanding of sea level rise readiness and yield valuable  
          input from local granted lands stakeholders on how the State, as  
          a whole, should address this pressing climate issue.  
          Specifically, the bill would require all trustees to estimate  
          the cost, prepare maps, identify strategies, and provide  
          timelines to implement sea level rise action plans. The risks of  
          sea level rise must be assessed as soon as possible. With  
          projected increases of 16" in 2050 and 55" by 2100, it won't be  
          long before sea level rise will threaten entire communities.  
          Furthermore, inaction puts the State and nation at grave  
          economic risk. California's coast is crucial to the state and  
          national economy, producing more than a half million jobs in  
          California [and] 2 million jobs nationally. Port activities in  
          California generate an estimated $7 billion annually in state  
          and local tax revenues."

          ARGUMENTS IN OPPOSITION
          The California State Association of Counties (CSAC), in  
          opposition to the bill, states, "The impacts of sea level rise  
          have the potential to dramatically impact multiple aspects of  
          human life, including our environment, the economy and public  
          health and safety. While CSAC supports the development of local  
          strategies to protect our communities from sea level rise, we  
          are concerned that AB 2598 would impose additional planning  
          requirements on local agencies without providing any source or  
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          funding."

          A joint letter from the California Business Properties  
          Association, California Chamber of Commerce, California  
          Manufactures & Technology Association, and Western States  
          Petroleum Association also opposes the measure because "absent a  
          clear resolution of how issues such as sea level change will be  
          addressed under CEQA, as well as how the recently released  
          California Climate Adaptation Strategy document is implemented  
          over time, this bill appears likely to result in costly and  
          duplicative work for local governments, other trustees, and  
          lessees and other users of trust lands."

          COMMENTS 
           Funding for plans and hardship exemption:  Recent amendments to  
          this bill add findings language stating that it is the trustee's  
          financial responsibility to take reasonable steps to manage and  
          preserve the trust property. Furthermore, the bill declares that  
          evaluation of sea level rise impacts on granted lands is  
          directly related to the management of the trust property. Thus,  
          the bill finds that it is appropriate for the trustee to use any  
          revenues received from the trust lands and trust assets to  
          prepare a sea level rise plan. While opponents to the bill argue  
          that these revenues are already being utilized to protect the  
          public trust on the granted lands, the bill does provide a  
          "hardship provision" that allows the commission to exempt or  
          modify a local trustee's requirements should the trustee have  
          insufficient funds. The committee may wish to also allow the  
          commission to grant a deadline extension with the thought that  
          some trustees will be able to find sufficient funds if they are  
          given additional time. [see amendment 1]

          In further acknowledgement of the limited funds available for  
          plan preparation and in recognition of the workload involved in  
          preparing a sea level action plan, the committee may wish to  
          extend the deadline in this bill to July 1, 2012. [see amendment  
          2]

           What is the projected sea level change in 2050 and 2100?  There  
          is a range of predictions on sea level changes that California  
          may see in the future. Additionally, the extent of sea level  
          rise is still being studied, and projections are likely to be  
          modified with this additional information. While this bill does  
          not explicitly specify the increases that the trustees should  
          plan to, the bill does state that the plan should be developed  
          using relevant information contained in the 2009 California  
          Climate Adaptation Strategy and the Commission's Report on Sea  
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          Level Rise Prepardness. Both these documents site a paper by the  
          California Climate Change Center (sponsored by the California  
          Energy Commission, the Ocean Protection Council, and CalEPA)  
          which estimates sea level rises of 30-45cm/12-18in by 2050 and  
          50-140cm/20-55in by 2100. The committee may find that it is  
          valuable for all trustees to plan to approximately the same sea  
          level rise projections to create uniformity in plans. 

           Taking advantage of existing sea level rise maps  : Several  
          sources of maps of sea level rise currently exist, including  
          those produced by the San Francisco Bay Conservation and  
          Development Commission. The committee may wish to explicitly  
          allow trustees to meet the map requirements of the plan with  
          maps created by other sources that are included either in the  
          Resources Agency's Climate Adaptation Strategy or the  
          commissions' report on sea level rise prepardeness. [see  
          amendments 3 and 4]
           
          Other amendments  : This bill currently has an unnecessary  
          "notwithstanding" provision that the committee may find  
          desirable to delete. Also, the committee may wish to delete an  
          erroneous reference to beach replenishment as a nonengineered  
          measure to prevent and mitigate damage from sea level rise.  
          Lastly, the committee may wish to see the bill state the need  
          for design standards that would both avoid and mitigate impacts  
          to new development and infrastructure, similar to the  
          requirements for existing development and infrastructure.
          [see amendments 5, 6, and 7]

          SUGGESTED AMENDMENTS 
               AMENDMENT 1  
          On page 5, line 19, after "section" insert "grant a deadline  
          extension,"
               AMENDMENT 2 
          On page 4, line 20, delete "2011" and insert "2012"
               AMENDMENT 3 
          On page 4, line 24, delete "," and insert "and any subsequent  
          updates to this report," 
               AMENDMENT 4
          On page 4, line 30, after "events." insert: "A trustee may rely  
          on appropriate maps generated by other entities." 
               AMENDMENT 5
          On page 4, line 15, delete "Notwithstanding any other law"
               AMENDMENT 6 
          On page 5, line 3, delete "beach replenishment,"
               AMENDMENT 7 
          On page 5, line 5, after "avoid" insert "or mitigate"
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          SUPPORT
          California State Controller, John Chiang (sponsor)
          Sierra Club California

          Support to earlier versions of the bill:
          California Coastkeeper Alliance
          California State Lands Commission
          Global Green USA
          Heal the Bay
          Port of San Diego
          San Diego Coastkeeper
          Save the Bay

          OPPOSITION
          California State Association of Counties
          Delta Counties Coalition

          Opposition to the 4/15/2010 version of the bill:
          American Council of Engineering Companies of California 
          Automobile Aftermarket Industry Association 
          California Automobile Wholesalers' Association 
          California Business Properties Association 
          California Chamber of Commerce 
          California Manufactures & Technology Association 
          California Forestry Association
          California League of Food Processors
          California Manufactures & Technology Association
          California Metals Coalition
          Western States Petroleum Association  

















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