BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                   SB 126|
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                                 THIRD READING


          Bill No:  SB 126
          Author:   Steinberg (D)
          Amended:  As introduced
          Vote:     21

           
           SENATE TRANSPORTATION & HOUSING COMMITTEE :  9-0, 4/12/11
          AYES:  DeSaulnier, Gaines, Harman, Huff, Kehoe, Lowenthal, 
            Pavley, Rubio, Simitian

           SENATE APPROPRIATIONS COMMITTEE  :  9-0, 5/9/11
          AYES:  Kehoe, Walters, Alquist, Emmerson, Lieu, Pavley, 
            Price, Runner, Steinberg


           SUBJECT  :    California Transportation Commission:  
          guidelines

           SOURCE  :     Author


           DIGEST  :    This bill establishes a procedure for the 
          California Transportation Commission to adopt guidelines.

           ANALYSIS  :    Existing law authorizes the California 
          Transportation Committee (CTC) to adopt policy guidelines 
          for various transportation programs but provides little 
          direction on how the adoption process should proceed.  
          Among the programs for which the CTC adopts guidelines are 
          the State Transportation Improvement Program and regional 
          transportation planning processes.  The passage of the 
          Highway Safety, Traffic Reduction, Air Quality, and Port 
          Security Bond Act of 2006 (Proposition 1B) mandated the 
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          issuance of several new CTC guidelines, including 
          guidelines for the Corridor Mobility Improvement Account 
          (CMIA), the State Route 99 Corridor Program, the Trade 
          Corridors Improvement Fund, the Public Transportation 
          Modernization, Improvement, Service Enhancement Account, 
          and the Highway-Railroad Crossing Safety Account.

          Established in 1978, the CTC provides a single venue for 
          addressing transportation development and funding issues in 
          the state.  The CTC consists of eleven voting members and 
          two non-voting ex-officio members.  Of the eleven voting 
          members, the governor appoints nine, the Senate Rules 
          Committee appoints one, and the Speaker of the Assembly 
          appoints one.  The two ex-officio non-voting members are 
          the chairs of the transportation policy committees in each 
          house of the Legislature.  The CTC programs allocate funds 
          for the construction of highway, passenger rail, and 
          transit improvements throughout California.

          This bill:

          1. Makes legislative findings and declarations regarding 
             the need to ensure that the CTC's process for adopting 
             program guidelines is understandable, predictable, and 
             transparent and provides ample opportunity for public 
             review and comment on proposed guidelines. 

          2. Provides, notwithstanding any other provision, in 
             instances where the CTC adopts guidelines, the 
             guidelines will be exempt from the Administrative 
             Procedure Act.

          3. Sets forth a process governing the CTC's adoption of 
             guidelines after January 1, 2011, except for guidelines 
             adopted to implement the State Transportation 
             Improvement Program, as follows:

             A.    The CTC's legal counsel is required to review 
                the proposed guidelines for necessity, authority, 
                clarity, consistency, reference, and redundancy and 
                recommend any changes to the CTC commissioners.  
                Comments and recommendations made by legal counsel 
                will be subject to attorney-client privilege, 
                unless waived.  The CTC Executive Director is 

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                required to distribute the recommendations and 
                communications with legal counsel to all 
                commissioners.

             B.    Policy guidelines are to be first presented at a 
                CTC meeting for the purpose of receiving public 
                comment. 

             C.    Proposed guidelines must include a notice of the 
                right of the public comment on the guidelines.

             D.    At least 45 days prior to the adoption of the 
                guidelines, the CTC must distribute and make 
                available in electronic format copies of the 
                proposed guidelines for public review.

             E.    Following the proposed guideline review process, 
                the CTC staff must summarize all comments and 
                explain any recommended changes to the guidelines 
                in response to comments made.  Staff 
                recommendations and a summary must be made public 
                15 days prior to a regular CTC meeting.

             F.    Guidelines must be adopted by a majority of the 
                commission membership. 

          4. Requires the CTC to maintain complete files on guideline 
             adoption proceedings, including a summary of each 
             objection or recommendation made and an explanation of  
             how the proposed guidelines were changed to accommodate 
             each objection or recommendation or the reason no change 
             was made. 

          5. Requires the CTC to include in its annual report to the 
             Legislature an accounting of its activities related to 
             guideline adoption during the prior year. 

           Comment
           
          According to the author's office, with the increase in the 
          number of policy guidelines that the CTC is adopting, this 
          legislation is intended to systematize the process CTC uses 
          to adopt policy guidelines under its purview and to 
          increase the transparency of the process. 

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          Policy guidelines and regulations are two very distinct 
          administrative tools to manage state programs.  Regulations 
          are adopted according to the terms and conditions of the 
          Administrative Procedures Act.  According to counsel, 
          numerous court decisions have ruled that administrative 
          regulations are an extension of a statute and carry the 
          weight of law.  Policy guidelines, even when mandated by a 
          statute, are an elaboration of policy and do not have the 
          weight of law.  Typically, the guidelines are adopted 
          through a relatively informal process compared to 
          regulations. 

          Last year an identical bill, SB 1348 (Steinberg), passed on 
          Consent, 34-0, on August 26, 2010, unanimously passed the 
          Senate Transportation and Housing Committee and both houses 
          of the Legislature,  Governor Schwarzenegger vetoed the 
          bill.  In his veto message he wrote, "This bill is 
          unnecessary as it establishes a formal process which is 
          very similar to the process already used by the CTC."

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  No

          According to the Senate Appropriations Committee:

                          Fiscal Impact (in thousands)

           Major Provisions                2011-12     2012-13    
           2013-14   Fund  

          CTC legal review                        $50-$70   
          $50-$70Special*

          *State Highway Account

           SUPPORT  :   (Verified  5/10/11)

          Fresno Council of Governments



          JJA:do  5/10/11   Senate Floor Analyses 


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                         SUPPORT/OPPOSITION:  SEE ABOVE

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