BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 126
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          Date of Hearing:   June 28, 2011

              ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER 
                                     PROTECTION
                                 Mary Hayashi, Chair
                SB 126 (Steinberg) - As Introduced:  January 27, 2011

           SENATE VOTE  :   39-0
           
          SUBJECT  :   California Transportation Commission: guidelines.

           SUMMARY  :   Establishes a process for the adoption of guidelines 
          by the California Transportation Commission (CTC), starting 
          January 1, 2012, and exempts the adoption of these guidelines 
          from the requirements of the Administrative Procedure Act (APA). 
           Specifically,  this bill  :

          1)Exempts, regardless of any other law, the adoption of 
            guidelines by CTC from the rulemaking provisions of the APA.  

          2)Exempts the State Transportation Improvement Program (STIP) 
            guidelines, as specified, from the provisions of this bill.

          3)Requires CTC's legal counsel to review the proposed guidelines 
            for necessity, authority, clarity, consistency, reference, and 
            redundancy and recommend any changes to CTC commissioners.

          4)Provides that the comments and recommendations made by CTC's 
            legal counsel are subject to the attorney-client privilege, 
            unless otherwise waived.  

          5)Requires the CTC Executive Director to distribute the 
            recommendations and communications to all commissioners.

          6)Requires program or policy guidelines to be presented first at 
            a CTC hearing for purposes of receiving public comment.

          7)Requires that the proposed or draft guidelines be sent to any 
            person who has requested CTC meeting notices at least 45 days 
            beforehand, and be made available to the public in an 
            electronic format.

          8)Requires that the proposed or draft guidelines include notice 
            a of the right of the public to comment orally on the proposed 
            or draft guideline during the public meeting, or to comment in 








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            writing at any time prior to the meeting to within 7 business 
            days following the meeting, at which time the written comment 
            period shall be closed.

          9)Requires CTC staff to review all written and oral comments 
            following the close of the written comment period, prepare a 
            summary of the objections and recommendations made in those 
            comments and provide an explanation of how the guideline is 
            proposed to be changed to accommodate the objections or 
            recommendations, or the reason or reasons for proposing no 
            changes.

          10)Requires CTC staff to make the recommendations and summary 
            publicly available at least 15 days prior to a subsequent 
            regular meeting of the CTC.  At that subsequent public 
            meeting, CTC shall consider the staff recommendations and any 
            additional public comment made at the meeting prior to voting 
            on the adoption of the proposed guideline. 

          11)Specifies that a program or policy guideline adopted by CTC 
            shall be adopted by an affirmative vote of a majority of the 
            CTC membership.

          12)Requires CTC to maintain a guideline adoption file containing 
            the public notice, public comments, minutes of the public 
            meeting, including the action taken by CTC, and a letter from 
            the CTC's legal counsel confirming that he or she reviewed the 
            proposed guidelines for compliance, as specified.

          13)Requires the guideline adoption file to contain a summary of 
            each objection or recommendation made and an explanation of 
            who the proposed guideline was changed to accommodate each 
            objection or recommendation, or the reason or reasons for 
            making no change.

          14)Requires CTC to include in its annual report to the 
            Legislature, a summary of its activities related to the 
            adoption of program or policy guidelines during the previous 
            calendar year, including a summary of the proposed guidelines 
            considered by CTC, a description of the actions taken by CTC, 
            and the votes of the CTC on matters it considered.

          15)Makes legislative findings and declarations.










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           EXISTING LAW  :

          1)Provides for programming and allocation of state and federal 
            funds available for transportation capital improvement 
            projects by the CTC, as specified, and authorizes CTC, in 
            certain cases, to adopt guidelines relative to its programming 
            and allocation policies and procedures.

          2)Governs the procedure for the adoption, amendment, or repeal 
            of regulations by state agencies and for the review of those 
            regulatory actions by the Office of Administrative Law (OAL) 
            under the APA, exempting state agencies from these 
            requirements under certain circumstances.

           FISCAL EFFECT  :   Unknown

           COMMENTS  : 

           Purpose of this bill  .  According to the author's office, "The 
          CTC adopts guidelines for the administration of various 
          transportation programs it oversees.  CTC's responsibilities in 
          this area grew immensely with the passage of Proposition 1B, The 
          Highway Safety, Traffic Reduction, Air Quality, and Port 
          Security Bond Act of 2006 (Prop 1B).  Generally, CTC's 
          guideline-adoption process has not been subject to the APA 
          process conducted by OAL.  In fact, the CTC has not submitted a 
          guideline to the OAL for approval in over 30 years.  On some 
          occasions, the Legislature has specifically exempted CTC 
          guidelines from the APA.   

          "In some instances, the CTC has attempted to adopt guidelines 
          with little or no public process.  This was most evident in 
          2007, when CTC attempted to adopt guidelines for the Corridor 
          Mobility Improvement Account program without releasing the draft 
          guidelines in advance of the public meeting at which a vote to 
          adopt the program was to occur.  The public went ballistic.  
          More recently, the CTC was close to adopting guidelines for its 
          public-private partnership guidelines without sufficient 
          opportunity for public review and comment.  In this latter case, 
          the CTC ultimately did the right thing and delayed guideline 
          adoption, but the process was close to another calamity.

          "SB 126 agrees with the premise that CTC should be able to adopt 
          program guidelines without going through the long APA process; 
          however, this bill does establish a statutory public process for 








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          CTC to follow to adopt program guidelines."

          Background  .  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.  The CTC 
          programs and allocates funds for the construction of highway, 
          passenger rail, and transit improvements throughout California. 

          Existing law authorizes the 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 STIP and regional 
          transportation planning process.  The passage of Prop 1B 
          mandated the issuance of several new guidelines such as the 
          Corridor Mobility Improvement Account, State Route 99 Corridor 
          Program, the Trade Corridors Improvement Fund, the Public 
          Transportation Modernization, Improvement, and Service 
          Enhancement Account and the Highway-Railroad Crossing Safety 
          Account. 

          This bill is identical to SB 1348 (Steinberg) of 2010, which was 
          vetoed.

           Previous legislation  .  SB 1348 (Steinberg) of 2010, provides a 
          procedure for the CTC to adopt legislatively mandated policy 
          guidelines.  SB 1348 was vetoed with the following message: 
          "This bill would establish specified procedures that the CTC 
          would be required to use when adopting guidelines.  This bill is 
          unnecessary as it establishes a formal process which is very 
          similar to the process already used by the CTC."

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          None on file.
           
            Opposition 
           
          None on file.








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           Analysis Prepared by  :    Rebecca May / B.,P. & C.P. / (916) 
          319-3301