BILL ANALYSIS �
AB 2398
Page 1
Date of Hearing: April 24, 2012
ASSEMBLY COMMITTEE ON ENVIRONMENTAL SAFETY AND TOXIC MATERIALS
Bob Wieckowski, Chair
AB 2398 (Hueso) - As Amended: April 16, 2012
SUBJECT : Recycled Water Discharge Permitting.
SUMMARY : Establishes regulatory authority for the permitting
of the discharge of recycled water produced from municipal waste
water.
Abolishes the existing authority of the State Water Resources
Control Board (SWRCB) and Regional Water Quality Control Boards
(RWQCBs) under the California Porter Cologne Water Quality Act
(Porter-Cologne) to regulate the discharge of treated waste
water that is recycled and creates new permitting authority of
the SWRCB, RWQCBs the Department of Public Health (DPH) in a new
division of the Water Code entitled the Water Recycling Act of
2012 (WRA).
Adds new definitions and other new requirements to recycled
water permitting. Specifies that the Department of Public
Health (DPH) shall permit advanced treated purified water (ATPW)
for potable uses and adds a new section to the Health and Safety
Code regulating ATPW.
Specifies that the SWRCB and RWQCBs shall permit recycled water
for non-potable uses. Specifically, this bill :
1) Defines ATPW as wastewater treated with a method at least as
effective as membrane filtration, reverse osmosis, advanced
oxidation, disinfection and that includes engineered
reliability features or other suitable treatment approved by
DPH.
2) Defines "recycled water" as municipal wastewater that is
treated to a disinfected tertiary level or greater, including
ATPW. Creates a regulatory scheme where recycled water is
not deemed a waste discharge, ATPW projects are permitted by
DPH, and recycled water that is not ATPW is permitted by the
Water Boards under the WRA.
3) Specifies all other water reuse besides ATPW and recycled
water shall permitted as a waste discharge by the Water
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Boards under the existing statutory scheme in the
Porter-Cologne.
4) Allows government agencies to charge fees for permitting and
other services required by the SWRCB and the RWQCBs pursuant
to the WRA.
5) Repeals the Water Recycling in Landscaping Act and
integrates specific portions of that Act into Chapter 5,
Article 3 of the WRA
6) Amends the Health and Safety Code to:
a) Exempt recycled water that is being used in accordance
with the WRA from classification as a waste discharge.
b) Add recycled water to the existing exemption for waste
discharges permitted by the Water Boards.
c) Declare ATPW, as defined, is being used for groundwater
recharge.
d) Declare that the planned introduction of ATPW into a raw
water (i.e. water for a potable use prior to drinking water
treatment) can help meet the State's recycled water goals
and that rigorous safety review and clear permitting
authority for such uses is needed.
e) Reference the definitions of ATPW, potable reuse, raw
water, raw water augmentation, treated water augmentation,
and uniform drinking water criteria found in the WRA.
f) Specify that recycled water is a source of supply and,
as such, no change to the method of treatment or
distribution can be made unless first authorized by DPH.
Distinguishes recycled water from wastewater that would be
subject to the permitting jurisdiction of the Water Boards.
g) Set out the specific criteria DPH must meet in
permitting raw water augmentation project ("Augmentation
Project") using recycled water, including an engineering
evaluation, establishment of drinking water criteria under
the WRA, consultation with the Water Boards regarding any
relevant water quality control plan or other applicable
plan or policy, and a public hearing. Allows case-by-case
permitting of Augmentation Projects prior to DPH's
establishment of drinking water criteria but requires DPH
consider current and potential future public health
consequences of the project prior to permitting.
h) Allow DPH to charge fees necessary to recoup regulatory
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costs for issuing Augmentation Project permits and requires
those funds be placed in the Augmentation Permit Fund.
i) Require holders of both DPH permits for Augmentation
Projects and Water Board permits for recycled water to pay
an annual fee to DPH to support investigations,
inspections, adjudications of permits, and consultations
between DPH and the Water Boards. Requires annual fees be
placed in the Augmentation Permit Fund.
7) Repeals the Health and Safety Code requirement that all
recycled water be conveyed via purple pipes and inserts
language regarding the use of purple pipes for recycled water
into WRA section 18140.
8) Makes technical conforming changes to the Public Utilities
Code and Water Code to redefine "reclaimed water" as
"recycled water," and "wastewater recycling" as "water
recycling," respectively.
9) Repeals the Water Reuse Law of 1974, which calls for studies
to promote the use of reclaimed water, and incorporates it
into WRA sections 18110-18111.
10)Deletes master recycling permits from Porter Cologne and
establishes water recycling permits will be issued under the
WRA.
11)Specifies existing permits to use recycled water issued
before December 31, 2012, including master permits, will
remain valid until expiration or modification.
12)Deletes chapters 7 ("Water Reclamation"), 7.3 ("Direct and
Indirect Potable Reuse"), and 7.5 ("Water Recycling Act of
1991") from Porter-Cologne and makes conforming changes to
Porter-Cologne to delete references to Chapters 7, 7.3, 7.5,
and recycled water permitting.
13) Amends language regarding the prohibition on waste wells
back in to Porter-Cologne chapter 7, but excludes groundwater
recharge using recycled water from the waste well definition.
14)Amends the Water Code to create the WRA (Division 8, ��
18000 and seq.), which replicates much, but not all, of the
language from deleted Porter-Cologne chapters 7, 7.3, and 7.5
and consolidates, reorganizes, and revises that language.
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15)Makes findings regarding the safety, necessity, societal and
environmental value of using recycled water to help meet
California's future water needs. States water that is
recycled, supplied, stored and used in accordance with the
WRA is not a discharge of waste or sewage or a nuisance,
except as provided in the WRA.
16)Incorporates the State Board's Recycled Water Policy, but
converts it into the numeric goals of recycling 1.5 million
acre-feet of water per year by 2020 and 2.5 million acre-feet
by 2030. States that the relevant public agencies shall use
their authorities to encourage the use of recycled water and
that such use under the WRA counts towards meeting the goals.
17)States that actions authorized pursuant to the WRA shall be
consistent, to the extent applicable; with the federal Clean
Water Act and the federal Safe Drinking Water Act and that
nothing in the WRA shall alter or affect any existing water
rights.
18)Authorizes the State Board and DPH to adopt regulations to
carry out the act. Allows DPH to accept public or private
funds from any source and to expend those funds, upon
appropriation by the Legislature, for the purposes of the
WRA.
19)Requires DPH to establish and maintain uniform water
recycling criteria for each varying type of nonpotable use
where the water use requires protection of public health.
20)Requires DPH to investigate, develop, maintain appropriate
criteria for, and report to the legislature on, potable reuse
projects, including treated water augmentation and raw water
augmentation, as defined by the WRA.
a) Requires, by December 31, 2013, that DPH to adopt
drinking water criteria for groundwater projects utilizing
recycled water.
b) Requires, by December 31, 2016, that DPH to adopt
drinking water criteria for projects that augment raw water
supplies with ATPW.
c) Requires, by December 31, 2016, that DPH report to the
Legislature on the feasibility of developing drinking water
criteria for direct potable reuse including, but not
limited to, the treatments and technologies necessary to
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ensure the protection of public health.
d) Requires that criteria for proposed raw water
augmentation projects and direct potable reuse be submitted
to an expert panel for a review as to whether criteria
adequately protect public health, which is consistent with
existing law.
e) Makes mandatory existing discretionary requirement for
DPH to appoint a task force of stakeholders, including
industry and environmental interests, to advise DPH
regarding the development of drinking water criteria for
potable reuse projects.
f) Models these requirements on Porter-Cologne sections
13560, 13562, 13563, 13566.
21)Declares that the use of potable domestic water for
nonpotable uses including, but not limited to, toilet
flushing, landscape irrigation, cooling towers or air
conditioning devices, is a waste or unreasonable use of water
in accordance with the California Constitution if recycled
water, as specified, is available and requires that the SWRCB
or the RWQCB must determine:
a) Recycled water of adequate specified quality and
comparable cost is available;
b) The use of recycled water from the proposed source will
not be detrimental to the public health and DPH concurs;
and
c) The use recycled water will not adversely affect
downstream water rights, will not degrade water quality,
except in accordance with the applicable water quality
control plan, and will not be injurious to plant life,
fish, and wildlife.
22)Allows any state, local or public agency, if there will be
no loss or diminution of existing water rights, to require
the use of recycled water for:
a) Residential landscaping if proper irrigations systems
are constructed.
b) Cooling if the new or retrofitted structure is approved
by DPH to use recycled water and, if there could be public
exposure to mists, mist mitigation or mist control is
provided.
c) Toilet and urinal flushing, except in a mental facility,
if the public agency has prepared an engineering report, as
specified. For condominiums adds additional requirements
regarding notice and consistency with recycled water laws
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and regulations.
23)Exempts the retrofit of an existing plumbing system to
accommodate the use of recycled water from the California
Environmental Quality Act (CEQA). Models this exemption on
multiple existing statutory and categorical exemptions.
24)Incorporates existing language recognizing the use of sea
water to flush urinals and toilets is corrosive and allows a
state or local public agency, where there is a separate
distribution system for the sea water, to use recycled if it
meets DPH criteria.
25)Allows a recycled water producer, wholesaler, or supplier
(collectively "recycled water entity") to provide notice to
the Department of Transportation (DOT) and the Department of
General Services (DGS) that, within 10 years , the recycled
water entity will provide recycled water that meets all
necessary standards for use for state landscape irrigation.
Thereafter, DOT and DGS must install dual piping ("purple
pipe") that meets applicable requirements.
26)Requires a local land use agency to adopt a recycled water
ordinance, as specified, if it is notified by a recycled
water entity that recycled water will be provided within the
boundaries of the local land use agency within 10 years.
Requires, if relevant criteria are met, that new industrial,
commercial or residential subdivisions include a separate
plumbing system to apply recycled water to nonpotable uses.
27)Allows any local public agency or private company supplying
or storing water, or a mutual water company, to acquire,
store, provide, sell, and deliver recycled water if the water
is used in accordance with the uniform water recycling
criteria and regulations established pursuant to the WRA or
the drinking water criteria developed for ATPW by DPH.
28)States those retailer water suppliers shall, and recycled
water producers and wholesalers may assist in, identifying
potential uses for recycled water and potential customers.
Allows cooperation on groundwater replenishment feasibility
studies. Mandates that a recycled water supplier shall
provide recycled water to a requesting customer. Restricts a
customer to receiving recycled water from the local service
area retail water supplier unless otherwise permitted by that
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supplier.
29)Requires the use of separate purple pipe systems for
recycled water, with specified exceptions.
30)Specifies that ATPW, other than ATPW blended with recycled
water, shall be regulated by DPH as a source of drinking
water supply in consultation with the Regional Boards and
accordance with the new requirements and procedures added to
the Health and Safety Code by this bill.
31)Requires permits for recycled groundwater recharge projects
using soil aquifer treated purified water to implement the
drinking water criteria adopted by DPH.
32)Specifies that raw water augmentation projects not subject
to drinking water criteria, and using other than ATPW, shall
be permitted on a case-by-case basis in consultation with
DPH.
33)Requires DPH to review reports of intent to recycle water
and make any recommendations for the proposed recycled water
projects to the state board and regional boards as
appropriate for the protection of public health.
34)Specifies that permits for non-potable use must include
requirements to:
a) Assure compliance with uniform water recycling criteria;
b) Submit an annual report summarizing the recycled water
use;
c) Create a program of oversight and compliance with the
uniform water recycling criteria;
d) Comply with the program described in the permittee's
report of intent to recycle water, and,
e) Implement the DPH recommendations protective of public
health.
35)Specifies that where water recycling occurs within an area
covered by a municipal separate storm sewer system (MS4)
permit issued pursuant to the federal National Pollutant
Discharge Elimination System (NPDES), the Water Boards shall
regulate incidental runoff as a low threat nonstorm water
discharge under the MS4.
36)Specifies that the Water Boards shall regulate the filling
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and storm-induced overflow of nonpotable surface water
augmentation reservoirs and other nonpotable impoundments on
a case-by-case basis as necessary to avoid or minimize
adverse impacts relating to the individual impoundment that
are not addressed by uniform water recycling criteria.
37)In lieu of issuing water recycling permits for nonpotable
reuse to a recycling entity, allows the SWRCB to issue
general permits to that entity.
38)Specifies that the SWRCB and RWQCBs may issue a recycled
water groundwater recharge permit to a recycled water entity,
an entity responsible for groundwater replenishment, or both,
for a project using soil aquifer treated purified water, with
or without ATPW, if that permit implements the
recommendations of DPH to protect public health and includes:
a) Requirements to assure compliance with drinking water
criteria for recycled water groundwater recharge projects,
including source control requirements;
b) Monitoring and reporting in order to demonstrate
compliance with the permit;
c) Technical specifications with regard to buffer zones,
travel times, diluent ratios and groundwater retention
requirements, as recommended by DPH; and,
d) A requirement to comply with the permittee's intent to
recycle water.
39)Requires recycled water producers, wholesalers, and
suppliers of recycled water for non-potable purposes for
which uniform water recycling criteria have been established
to file a report of intent to recycle water with the
appropriate RWQCB that incorporates:
a) An engineering report which includes, but is not limited
to:
i. information required by DPH in accordance Title 22
of the California Code of Regulations;
ii. methods of treatment;
iii. system installation, operation, maintenance and
emergency backup systems;
iv. recycled water use areas; and,
v. a monitoring and reporting program to demonstrate
compliance with permit terms.
b) An implementation plan for demonstrating that the
recycled water use will not cause the receiving water to
exceed any water quality objective specified for the
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receiving water in the applicable water quality control
plan, except a salinity standard in the basin plan. Allows
that where a salt and nutrient management plan is in place
for the basin or sub basin, the implementation plan may
consist of the implementation provisions of that plan.
c) As applicable, the recycled water entity's established
rules or general rules or regulations as approved by DPH
for recycled water entities in accordance with the uniform
water recycling criteria.
40)Exempts the filing of a report where a producing,
manufacturing or processing operation recycles water solely
for its own use.
41) Requires any person proposing a groundwater recharge
project to file a report of intent to recycle water that
includes:
a) An engineering report containing relevant technical
information;
b) An implementation plan demonstrating that the use of
recycled water will not cause the underlying groundwater to
exceed any water quality objective specified in the
applicable water quality control plan, except as allowed
with regard to salinity. Where a salt/nutrient plan is in
place, the implementation plan may consist of the
implementation provisions of the salt/nutrient plan.
42)Mandates that if there is any material change or proposed
change in the character of recycled water or its use, the
recycled water entity must file a report with the appropriate
Regional Board.
43)Specifies that all reports of intent to recycle water and
reports of changes are sworn statements submitted under
penalty of perjury.
44)Requires a Regional Board to determine the adequacy of a
report of intent to recycle water within the time frames set
out in the Permit Streamlining Act.
45)If the RWQCB fails to act within the statutory period,
allows the applicant to recycle water until the Regional
Board acts to adopt a water recycling permit or recycled
water groundwater recharge permit.
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46)Further requires the SWRCB and RWQCBs, in issuing a water
recycling permit, to:
a) Consult with, and receive the recommendations of DPH;
b) Provide notice and a minimum of 30 days to comment; and,
c) Hold a public hearing.
47)Requires a permit filing fee when a report of intent to
recycle water is filed and states the payment of fees may
deem the application complete. Requires the payment of
annual fees. Allows the Board to adjust fees periodically, as
appropriate, after notice and hearing. Limits what costs are
recoverable through fees.
48)Allows any aggrieved person to petition the State Board to
review any action or failure to act, of a Regional Board in
the same manner as provided in Porter-Cologne.
49)Allows any person aggrieved by a decision or order to obtain
review of that decision in superior court in the same manner
as provided in Porter-Cologne.
50)Requires immediate notification to the Board, as soon as
practicable, for the discharge of 1,000 gallons or more of
tertiary recycled water in or on, or projected to be in or
on, waters of the state.
51)States storm-induced overflow, as defined, is not an
unauthorized release.
52)Establishes the Water Recycling Research Fund. Sets out
fines for the unauthorized release of water. Requires any
fines to be deposited into the Water Recycling Research Fund.
53)Prohibits the use of recycled water without a permit for any
purpose for which uniform water recycling criteria or
drinking water were established. Imposes a misdemeanor fine
for each day the recycled water is distributed. Allows the
SWRCB and RWQCBs to impose administrative liability, taking
into account the nature, circumstances, extent and gravity of
violations. Requires fines to be deposited in the Water
Recycling Research Funds. Allows funds to be used for
environmentally beneficial projects. Does not include strict
liability.
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54)Allows for the issuance of cease and desist orders directly
by the State Board, after notice and hearing. Allows civil
penalties. Requires funds be deposited in the State Water
Pollution Cleanup and Abatement Account.
55)Allows DPH to order contamination abated if the use of
recycled water contaminates potable supplies. Establishes a
presumption that the use of water in accordance with the
uniform water recycling criteria does not constitute
contamination.
56)Allows DWR to assist local agencies and public utilities in
applying for and receiving funding for cost-effective
recycled water projects. Authorizes the State Board to
provide loans for the development of recycled water projects
and mandates added consideration for water quality control
facilities providing optimum water recycling and recycled
water use.
EXISTING LAW
1)Pursuant to the Porter -Cologne Act the SWRCB has the ultimate
authority over State water rights and water quality policy.
The Porter-Cologne also establishes nine Regional Water
Quality Control Boards to oversee water quality on a
day-to-day basis at the local and regional level.
2)Requires the RWQCBs or the SWRCB to prepare and periodically
update Basin Plans (water quality control plans). Each Basin
Plan establishes:
a) Beneficial uses of water designated for each water body
to be protected;
b) Water quality standards, known as water quality
objectives, for both surface water and groundwater; and,
c) The actions necessary to maintain these standards in
order to control point sources (end of pipe discharges) and
non-point sources of pollution to the State's waters.
1)Mandates permits issued to control pollution (i.e.
waste-discharge requirements and NPDES permits) that implement
Basin Plan requirements (i.e. water quality standards), taking
into consideration beneficial uses to be protected.
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2)Requires any person proposing to discharge waste within any
region to file a report of waste discharge with the
appropriate RWQCB. No discharge may take place until the
RWQCB issues waste discharge requirements or a waiver of the
waste discharge requirements.
3)Empowers the SWRCB, under the auspices of the U.S.
Environmental Protection Agency, to grant Clean Water Act
NPDES permits for certain point-source discharges.
4)Requires any discretionary decision by a public agency with
the potential for significant impacts of the environment to
undergo environmental review pursuant to the CEQA, unless
otherwise exempt.
FISCAL EFFECT : Not Known
COMMENTS :
Need For This Bill . According to the author "Recycled water is
an important component of California's sustainable water future
and economic strength. This bill would expand the use of
recycled water in California by improving and streamlining the
existing regulatory and permitting process to reflect current
scientific study and advances in treatment technology. By
establishing a consistent and appropriate regulatory and
permitting framework for this important alternative water
supply, this bill will help secure California's water supply
reliability and provide the foundation for California's future
economic stability".
"Current statutes and regulations do not recognize the
significant advances in treatment technology that have been made
over the past two decades. Additionally, the current framework
establishes multiple recycled water permitting paths and
overlapping jurisdictions resulting in confusing, inconsistent
and often conflicting requirements. The disconnect between
recycled water science and the regulatory framework coupled with
inconsistent regulations results in project delays and added
costs as well as public confusion and mistrust."
Water Recycling in California . According to the California
Association of Water Agencies California is among the major
players worldwide in water recycling. There are over 250 water
recycling plants currently operating in the state. According to
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the California Department of Water Resources, the state recycles
anywhere from 450,000 acre-feet to 580,000 acre-feet of
wastewater annually, which is almost three times the amount
recycled in 1970. About two-thirds of the state's recycled
water is used for irrigation, with about 46% used for
agriculture and another 21% used for landscaping. About 14% is
used for groundwater recharge, while 19% goes to all other uses.
This bill is an ambitious undertaking that attempts to
substantially redraft a complex body of public health and water
quality. AB 2398 would leave the basic water quality planning
functions of the Porter-Cologne Act in place, but otherwise
seeks to excise water recycling from the Porter-Cologne Act and
instead provide for regulation of recycled water in a separate
division of the Water Code. Creating the separate division may
not contain the safeguards, processes, and resources provided by
the Porter-Cologne act. There are numerous outstanding issues
raised by the bill, some of which may be the result of drafting
oversights and many are questions about the change in program
operation. The Committee faces deadlines for action on the
Assembly bills that will make comprehensive action very
difficult.
Examples of the outstanding policy issues that may be considered
in this bill include:
1) Fragmentation of Permitting Authority
2) Elimination of Requirement to Implement Water Quality
Objectives
3) Weakened Water Quality Enforcement Authority
4) Limiting Funding for Water Quality Control
5) Limiting Funding for Department of Public Health
6) Inadequate Enforcement authority for the Department of
Public Health
1) Fragmentation of Permitting Authority
Under existing law, recycled water projects are subject to two
types of permitting, waste discharge requirements and water
recycling requirements, administered by SWRCB. The requirements
of both permitting systems may be combined in a single master
recycling permit for a supplier or distributor of recycled
water. In place of the current system, AB 2398 substitutes a
system with three different types of permits, issued by
different agencies: (1) permits for advanced treated purified
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water, administered by the DPH; (2) permits for tertiary treated
recycled water, administered by the SWRCB; and (3) permits for
recycled water treated to a lesser level, administered by the
SWRCB. Having different permit systems issued by different
agencies increases the risk of duplication and overlap,
especially since waste treatment plants will need more than one
type of permit.
2) Elimination of Requirement to Implement Water Quality
Objectives
AB 2938 sets requirements that implement statewide criteria to
protect public health, and may not necessarily include limits
adequate to protect other beneficial uses. Moreover, statewide
criteria will not take into account water quality concerns
specific to the affected water bodies.
Under existing law, water quality objectives (standards) for
specific water bodies are set as part of the applicable Basin
Plan. When a discharge has the potential to adversely affect
water quality, the RWQCBs issue waste discharge requirements (or
master recycling requirements), which are required to implement
the applicable Basin Plan. Under AB 2398, the DPH would be
required to consult with the appropriate RWQCB, but the bill
does not require the permit to implement the applicable Basin
Plan. Nor does AB 2398 specifically require implementation of
the applicable basin plan in permits issued by the SWRCB or
RWQCBs.
3) Weakened Water Quality Enforcement Authority
Under the Porter-Cologne Act, the SWRCB and the RWQCBs have a
variety of enforcement tools. This authority would not apply to
the authority over water recycling under AB 2398, but instead
would be subject to separate enforcement provisions that are
patterned after some of the Porter-Cologne enforcement tools,
but omit many of those enforcement tools, and are generally
weaker than the enforcement sections of the Porter-Cologne Act.
4) Limiting Funding for Water Quality Control Boards
The Porter-Cologne Act establishes a fee supported program. AB
2398 exempts water recycling from those fees, and establishes a
new fee system to support the SWRCB and RWQCBs activities under
the new Division 8 of the Water Code. But unlike Porter-Cologne
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Act fees, these new fees cannot be used to pay for costs of
monitoring, modeling and planning, and cannot be used for water
quality activities under authority other than Division 8.
5) Limiting Funding for DPH
AB 2398 includes new fees in proposed Health and Safety Code ��
26304 and 26305 to support the new permit program to be
administered by the DPH. Because these sections do not specify
that they apply notwithstanding 6103 of the Government Code,
these fees will not apply to public agencies. Since almost all
of those who apply for, and obtain, permits from the DPH will be
public agencies, the result will be that the DPH's recycled
water program will not be adequately funded. The proposed fees,
if they could be collected, would not include the cost
associated with groundwater or surface monitoring outside a
specific permitted project.
6) Inadequate Enforcement Authority for the DPH
AB 2398 replaces the existing permitting requirements under the
Porter-Cologne Act for those wastewater projects involving the
discharge of advanced treated purified water and adds a new
section to the Health and Safety Code regulating ATPW. While
the existing Porter Cologne act provides a range of penalties
and enforcement procedures for violations of a permit condition
AB 2398 fails to provide any enforcement authority for the DPH
to respond to permit violations.
Dual-Referral : This bill was heard by the Assembly Water Parks
and Wildlife Committee on April 10, 2012, and passed with a 9 to
1 vote.
REGISTERED SUPPORT / OPPOSITION :
Support
BIOCOM
California Association of Sanitation Agencies
California Landscape Contractors
City of Santa Rosa
Delta Diablo Sanitation District
Dublin San Ramon Services District
Eastern Municipal Water District
El Dorado Irrigation District
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Irvine Ranch Water District
Las Virgenes Municipal Water District
Mesa Consolidated Water District
Metropolitan Water District of Southern California
San Diego County Water Authority
Sonoma County Water Agency
Three Valley Municipal Water District
Town of Winsor
Upper San Gabriel Valley Municipal Water District
WateReuse
West Basin Municipal Water District
Opposition
Russian Riverkeeper
Analysis Prepared by : Bob Fredenburg / E.S. & T.M. / (916)
319-3965