BILL ANALYSIS                                                                                                                                                                                                    



                                                                SB 413
                                                                       

                      SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                        Senator S. Joseph Simitian, Chairman
                              2009-2010 Regular Session
                                           
           BILL NO:    SB 413
           AUTHOR:     Ducheny           
           AMENDED:    April 20, 2009
           FISCAL:     Yes               HEARING DATE:     April 27, 2009
           URGENCY:    No                CONSULTANT:       Caroll  
           Mortensen
            
           SUBJECT  :    WASTE DISCHARGE FEES

            SUMMARY  :    
           
            Existing law  :

           1) Pursuant to both the Federal Clean Water Act (CWA) and the  
              State Porter-Cologne Water Quality Act (Porter-Cologne)  
              requires completion of basin plans.

           2) Under the Porter-Cologne Water Quality Control Act,  
              establishes the State Water Resources Control Board (SWRCB)  
              and regional water quality control boards (RWQCBs) in the  
              California Environmental Protection Agency, which must be  
              "the principal state agencies with primary responsibility  
              for the coordination and control of water quality" (Water  
              Code 13000 et seq.).

              a)    Requires the nine Regional Water Quality Control  
                 Boards to adopt water quality control plans (basin  
                 plans) for watersheds within each region.

              b)    Provides that these basin plans shall become part of  
                 the California Water Plan when such plans have been  
                 reported to the Legislature (Water Code 13141).

              c)    Requires each regional board to establish water  
                 quality objectives in its basin plan to ensure the  
                 reasonable protection of beneficial uses and the  
                 prevention of nuisances.

              d)    Requires each basin plan to include a program of  









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                 implementation for achieving those objectives, including  
                 necessary actions to achieve water quality objectives,  
                 time schedules for the actions, and a description of  
                 surveillance to determine compliance with objectives.

              e)    Authorizes the assessment of Waste Discharge  
                 Requirement (WDR) fees annually for the allowance of  
                 discharging wastes pursuant to a WDR order that may  
                 affect California's surface and ground water (Water Code  
                  13260).

              f)    Authorizes the assessment of an annual fee to  
                 permittees for each WDR they hold.  The total WDR fee  
                 revenue supports the majority of the costs of SWRCB and  
                 the RWQCBs' regulatory programs.

              g)    Provides that the total amount of annual fees  
                 collected must equal the amount necessary to cover  
                 expenses related to the issuance, administration,  
                 reviewing, monitoring and enforcement of WDRs and  
                 waivers of WDRs.

              h)    Provides that the WDR fees are deposited in the WDR  
                 Permit Fund and are for the purposes of carrying out the  
                 requirements of the Act.

            This bill  :

           1) Amends the definition of "recoverable costs" for purposes  
              of WDR fees, to specify that it includes costs incurred by  
              the RWQCB's to prepare basin plans.

           2) States that the portion of the fee calculated for  
              recovering the costs for preparing basin plans shall be  
              calculated in a manner than ensures that fee payers are not  
              paying disproportionately more than their impacts or  
              benefits justify.

            COMMENTS  :

            1) Purpose of Bill  .  According to the author, reforms or  
              improvement at the state and regional water boards has been  
              one of her priorities.  To that end, one of the issues that  









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              was raised in the Little Hoover Commission Report "Clearer  
              Structure, Cleaner Water:  Improving Performance and  
              Outcomes at the State Water Boards", was the fact that  
              outdated basin plans undermine the credibility of water  
              quality throughout the different regions.  These plans are  
              the basis for all water quality plans and some are more  
              than a decade old.
            
           2) Little Hoover Commission Report  .  In January of this year,  
              the Little Hoover Commission release a reporting entitled,  
              "Cleaner Structure, Cleaner Water:  Improving Performance  
              and Outcomes at the State Water Boards".  This document  
              recommends extensive changes and updates to the way the  
              SWRCB and the regional boards do business.  They indicate  
              that the current structure and system needs major reform to  
              help protect and improve water quality.  Among dozens of  
              recommendations, one related to the sorely outdated,  
              under-staffed and under-funded efforts regarding the  
              preparation and updates to basin plans.

            3) Basin Plans  .  Basin plans, or formally titled, water  
              quality control plans, provide the basis for protecting  
              water quality in California.  They are the cornerstone for  
              enforcement and planning and absolutely critical for the  
              SWRCB and the regional board to carry out their mandates.   
              Each plan must contain water quality objectives, which in  
              the judgment of the SWRCB and regional boards will ensure  
              the protection of beneficial uses and the prevention of  
              nuisance, and a program of implementation for achieving  
              those objectives, including a description of the nature of  
              actions that are necessary to achieve the objectives, time  
              schedules for the actions to be taken, and a description of  
              surveillance to be undertaken to determine compliance with  
              objectives. 

              Basin plans provide for a definitive program of actions  
              designed to preserve and enhance water quality and to  
              protect beneficial uses of water.  They are used as a  
              regulatory tool for the regional boards.  Enforcement  
              orders cite the basin plan's water quality standards and  
              prohibitions applicable to a particular discharge.  The  
              basin plan is also used by other agencies in their  
              permitting and resource management activities.  It also  









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              serves as an educational and reference document for  
              dischargers and members of the public.

            4) Lack of Data and Scientific Research  . One of the main  
              issues facing the SWRCB and the regional boards is a lack  
              of data and scientific research.  Data collection is also a  
              problem.  According to the Little Hoover Report, water  
              quality monitoring is sporadic throughout the state,  
              leaving SWRCB and the regional boards to regulate on the  
              basis of incomplete information.  A 2004 report noted that  
              as much as 75 percent of the state's rivers, streams, lakes  
              and reservoirs were unmonitored. 

              The SWRCB and the regional boards struggle to organize what  
              data they do have, however.  One analysis of the water  
              boards' program to protect and enhance wetlands was  
              hampered because more than 40 percent of the files for the  
              program could not be located.  And while the SWRCB and the  
              regional boards conduct and fund scientific research, they  
              have done a poor job of coordinating or consolidating that  
              research or working to infuse it into regulatory programs.

            5) Basin Plans Out-of-Date  .  The Little Hoover Report also  
              points out that the lack of data and science mean that  
              basin plans are often decades out-of-date. As basin plans  
              guide virtually all regulations in each region, this  
              undermines the legitimacy of the state's regulatory  
              efforts.  Basin plans list the uses of water bodies and the  
              limits on contaminants in each of the water bodies to  
              support those uses.  Despite this, the state has not  
              committed the resources to update them.  According to the  
              report, less than 3 percent of the SWRCB and the regional  
              board's nearly 1,600 employees are dedicated to updating  
              basin plans.  The SWRCB's funding structure, which relies  
              mostly on fees to support specific permitting programs and  
              almost no General Fund dollars, leaves little money  
              available for this critical task.  The state must give this  
              task higher priority, commensurate with the role the plans  
              play in ensuring and protecting water quality.

            6)Step in the Right Direction  .  As the Little Hoover report  
             indicates, there is much work to be done in this policy  
             area.  Providing adequate funding for the SWRCB and the  









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             regional boards to implement the Act is key to improving and  
             preserving water quality in this state.  The Legislative  
             Analyst's Office has recommended a look toward a  
             comprehensive water quality fee based on the "polluter pays"  
             principle.  However, until an effort that addresses the  
             overarching resource needs, this bill makes a step in the  
             direction of providing a funding source for basin plans.

            7)Amendment Needed  .  This bill contains a provision that  
             requires the SWRCB to calculate any increase to the  
             discharge fee  " . . . in a manner than ensures that fee  
             payers are not paying disproportionately more than their  
             impacts or benefits justify."  This raises two points.  One  
             raised in the Little Hoover Commission Report was the SWRCB  
             needs to have flexibility to match resources to priorities.   
             The second is that this calculation would be difficult to  
             quantify.  Thus, the bill should be amended remove the  
             requirement for the calculation.  

            SOURCE  :        Senator Ducheny
            
           SUPPORT  :       None on file  

           OPPOSITION  :    None on file