BILL ANALYSIS                                                                                                                                                                                                    �




                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  AB 2567                     HEARING:  6/13/12
          AUTHOR:  Carter                       FISCAL:  No
          VERSION:  3/26/12                     TAX LEVY:  No
          CONSULTANT:  Weinberger               

                             PROPERTY-RELATED FEES
          

          Allows a local wastewater service provider to adopt a 
          schedule of fees authorizing automatic adjustments for 
          increases in wholesale wastewater treatment charges.


                           Background and Existing Law  

          Proposition 218 (1996) defines a property-related fee or 
          charge as, any levy other than an ad valorem tax, a special 
          tax, or an assessment, imposed by an agency upon a parcel 
          or upon a person as an incident of property ownership, 
          including a user fee or charge for a property-related 
          service.

          Before a local government can charge a new property-related 
          fee, or increase an existing one, Proposition 218 requires 
          local officials to:
                 Identify the parcels to be charged.
                 Calculate the fee for each parcel.
                 Notify the parcels' owners in writing about the 
               fees and the hearing.
                 Hold a public hearing to consider and count 
               protests.
                 Abandon the fees if a majority of the parcels' 
               owners protest.
          Property-related fees for sewer, water, or refuse 
          collection services are exempt from the additional 
          requirement that registered voters or property owners must 
          vote to approve property-related fees.

          The 2006 Supreme Court decision in Bighorn Desert-View 
          Water Agency v. Verjil found that a water agency's charges 
          for on-going water delivery are property-related fees that 
          are subject to Proposition 218's notice, protest, and 
          hearing requirements.  The Bighorn decision created 
          uncertainty among some local agencies about how to comply 




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          with some of Proposition 218's property-related fee 
          provisions.  In response, the Legislature passed new laws 
          governing how a public agency should provide notice and 
          tabulate written protests for new or increased 
          property-related fees or charges (AB 1260, Caballero, 
          2007).  

          The Legislature also allowed an agency providing water, 
          sewer, or refuse collection service to adopt a schedule of 
          fees or charges for a property-related service for a period 
          not to exceed five years pursuant to statutory notice and 
          protest requirements (AB 3030, Brownley, 2008).  The 
          schedule of fees or charges can include a schedule of 
          adjustments, including a clearly defined formula to adjust 
          for inflation.  The schedule of fees or charges for an 
          agency that purchases wholesale water from a public agency 
          can provide for automatic adjustments that pass through the 
          adopted increases or decreases in the wholesale charges for 
          water established by the other agency.

          The Ross Valley Sanitary District (Marin County) provides 
          wastewater collection and conveyance services to residents 
          and businesses in:  Fairfax, San Anselmo, Ross, Larkspur, 
          Bon Air, Sleepy Hollow, Kentfield, Kent Woodlands, Oak 
          Manor, Greenbrae, Murray Park, and San Quentin Prison.  The 
          District operates and maintains approximately 200 miles of 
          collection sewer lines and 20 pumping stations which 
          collect, pump, and transport approximately five million 
          gallons of wastewater per day to the Central Marin 
          Sanitation Agency (CMSA) for treatment.  District officials 
          want to be able to adopt a five year schedule of wastewater 
          fees that pass through adjustments in CMSA's wholesale 
          charges for wastewater treatment or adjustments for 
          inflation.


                                   Proposed Law  

          Assembly Bill 2567 allows an agency providing wastewater 
          service to adopt a schedule of fees or charges authorizing 
          automatic adjustments that pass through increases in 
          wholesale charges for wastewater treatment or adjustments 
          for inflation, if it complies with all of the following: 
                 The agency adopts the schedule of fees or charges 
               for a property-related service for a period not to 
               exceed five years pursuant to state law. 





          AB 2567 -- 3/26/12 -- Page 3



                 The schedule of fees or charges may include a 
               schedule of adjustments, including a clearly defined 
               formula for adjusting for inflation. Any inflation 
               adjustment to a fee or charge for a property-related 
               service cannot exceed the cost of providing that 
               service. 
                 The schedule of fees or charges for an agency that 
               purchases wholesale wastewater treatment  from a 
               public agency may provide for automatic adjustments 
               that pass through the adopted increases or decreases 
               in the wholesale charges for wastewater treatment  
               established by the other agency. 
                 Notice of any adjustment pursuant to the schedule 
               must be given pursuant to state law, not less than 30 
               days before the effective date of the adjustment.


                               State Revenue Impact
           
          No estimate.


                                     Comments  

          1.   Purpose of the bill  .  Public agencies that provide 
          wastewater collection services must go through a new 
          rate-approval process every time they adjust their 
          property-related fees in response to unanticipated 
          inflationary costs, such as increases in the wholesale cost 
          of wholesale wastewater treatment.  Requiring frequent 
          rate-approval proceedings can cause delays, produce 
          additional costs to ratepayers, and complicate long-term 
          financial planning.  By allowing local wastewater agencies 
          to adopt five-year fee schedules that pass through 
          adjustments in inflation and wholesale costs, AB 2567 
          grants local wastewater agencies the same authority that AB 
          3030 (Brownley, 2008) granted to local water agencies.  The 
          bill simplifies the process of adjusting wastewater service 
          rates in response to inflation or wholesale cost increases 
          while maintaining the fundamental rate-payer protections of 
          Proposition 218.  As a result, agencies that provide 
          wastewater collection services will benefit from lower 
          costs and greater revenue predictability.

          2.   Let's be clear  .  The statute enacted by the 2008 
          Brownley bill refers to agencies that provide water, sewer, 





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          or refuse collection services.  AB 2567 would allow 
          agencies that provide wastewater services to adopt fee 
          schedules that pass through wholesale costs for wastewater 
          treatment, but does not make any reference to wholesale 
          costs for sewer treatment.  This omission may generate some 
          confusion by implying that agencies that provide "sewer" 
          services, as opposed to "wastewater" services, cannot pass 
          through their wholesale costs.  To avoid this confusion, 
          the Committee may wish to consider amending AB 2567 to 
          include references to "sewage treatment" in addition to the 
          references to "wastewater treatment" that the bill adds to 
          the current statute.  


                                 Assembly Actions  

          Assembly Local Government Committee:   8-0
          Assembly Floor:                    74-1


                         Support and Opposition  (6/7/12)

           Support  :  Ross Valley Sanitary District; Association of 
          California Water Agencies.

           Opposition  :  Unknown.