BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 145
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          ASSEMBLY THIRD READING
          AB 145 (Perea and Rendon)
          As Amended  April 24, 2013
          Majority vote 

           WATER, PARKS & WILDLIFE       9-2                    
          ENVIRONMENTAL SAFETY     5-2
           
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          |Ayes:|Rendon, Blumenfield,      |Ayes:|Alejo, Bloom, Lowenthal,  |
          |     |Bocanegra, Fong, Frazier, |     |Stone, Ting               |
          |     |Gatto, Gray, Yamada,      |     |                          |
          |     |Bloom                     |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Dahle, Beth Gaines        |Nays:|Dahle, Donnelly           |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           APPROPRIATIONS      16-1                                        
           
           --------------------------------------------------------------------------------------------------------- 
          |Ayes:|Gatto, Harkey, Bocanegra,        |     |                          |     |                          |
          |     |Bradford, Ian Calderon, Campos,  |     |                          |     |                          |
          |     |Donnelly, Eggman, Gomez, Hall,   |     |                          |     |                          |
          |     |Ammiano, Linder, Pan, Quirk,     |     |                          |     |                          |
          |     |Wagner, Weber                    |     |                          |     |                          |
          |     |                                 |     |                          |     |                          |
           --------------------------------------------------------------------------------------------------------- 
           -------------------------------------------------------------------------------------- 
          |Nays:|Bigelow     |     |                            |     |                          |
          |     |            |     |                            |     |                          |
           -------------------------------------------------------------------------------------- 

           SUMMARY  :   Transfers, during the 2014- 2015 fiscal year, the  
          duties and responsibilities related to the regulation and  
          oversight of drinking water, including the authority to  
          administer the Safe Drinking Water State Revolving Fund  
          (SDWSRF), from the Department of Public Health (DPH), which is  
          under the California Health and Human Services Agency (CHHSA),  
          to the State Water Resources Control Board (SWRCB), which is  
          within the California Environmental Protection Agency (Cal/EPA).  
           Specifically,  this bill  :

          1)Makes findings that include, but are not limited to, the  








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            public nature of, and human need for, water; the effects of  
            groundwater contamination, especially upon communities that  
            lack the financial resources to resolve their drinking water  
            problems; and, the Legislature's attempts at addressing safe  
            drinking water access.

          2)Asserts that the state needs a consolidated and comprehensive  
            system to ensure safe drinking water for all, including  
            protecting groundwater for drinking water, and that  
            consolidating all water quality programs into the SWRCB, the  
            one state agency whose primary mission relates to water  
            quality, will yield numerous benefits.

          3)States the Legislature's intent to use a process with broad  
            public participation from affected stakeholders and agencies  
            in order to craft the most effective management structure for  
            achieving a comprehensive strategy for protecting drinking  
            water quality.

          4)Makes codified findings and declarations, including that it is  
            the Legislature's intent to effectively use California's  
            limited water and financial resources to ensure that all  
            communities enjoy access to safe drinking water and that this  
            2013 reorganization of the State's Drinking Water Program  
            (DWP) will maximize efficiencies of drinking water,  
            groundwater, and water quality programs by creating a  
            comprehensive water quality program under one state agency  
            that addresses water quality at all stages of the hydrologic  
            cycle.

          5)Creates a new Division of Drinking Water Quality at the SWRCB  
            that succeeds to and is vested with all of the authority,  
            duties, powers, purposes, responsibilities, and jurisdiction  
            of DPH for the purposes of the both the DWP and the SDWSRF.   
            Requires the reorganization to be implemented during the  
            2014-15 fiscal year.

           EXISTING LAW  :

          1)Authorizes, pursuant to the federal Safe Drinking Water Act  
            (SDWA), the United States Environmental Protection Agency  
            (USEPA) to set standards for drinking water quality and to  
            oversee the states, localities, and water suppliers who  
            implement those standards.  Under the State Water Drinking Act  








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            (SDWA) Amendments of 1996, establishes the Safe Drinking Water  
            State Revolving Fund (SDWSRF) program, which authorizes the  
            USEPA to award capitalization grants to states and authorizes  
            the states to, in turn, provide low-cost loans and other types  
            of assistance to public water systems to finance the costs of  
            infrastructure projects needed to achieve or maintain  
            compliance with federal SDWA requirements.

          2)Requires, pursuant to California's parallel SDWA statute, DPH  
            to regulate drinking water and to enforce the federal SDWA and  
            other related regulations.

          3)Continuously appropriates the SDWSRF to DPH and requires DPH  
            to undertake specified actions to implement the SDWSRF  
            pursuant to the federal SDWA, including providing grants or  
            revolving fund loans for the design and construction of  
            projects for public water systems that will enable suppliers  
            to meet safe drinking water standards.

          4)Regulates, pursuant to the federal Clean Water Act (CWA), also  
            administered by the USEPA, discharges of pollutants into the  
            waters of the United States and regulates quality standards  
            for surface waters.  Under the CWA Amendments of 1987,  
            establishes the Clean Water State Revolving Fund (CWSRF)  
            program to fund water quality projects, including nonpoint  
            source, watershed protection or restoration; estuary  
            management projects; and municipal wastewater treatment  
            projects.  Authorizes USEPA to award capitalization grants to  
            and authorizes states to, in turn, make loans to communities,  
            individuals, and others for water quality activities to  
            further the provisions and requirements of the CWA.

          5)Establishes, pursuant to the Porter-Cologne Water Quality  
            Control Act (Porter-Cologne), California's statute that  
            predates the CWA and upon which some sections of the CWA are  
            modeled, the SWRCB and the regional water quality control  
            boards and provides that the SWRCB and the regional water  
            quality control boards are the principal state agencies with  
            authority over matters relating to water quality and  
            implementation of the CWA.  Requires the SWRCB to administer  
            the CWSRF.

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, there are unknown administrative costs for  








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          transferring the program, likely in the hundreds of thousands of  
          dollars, which are potentially offset by future efficiencies.
           
          COMMENTS  :  Both federal environmental regulatory statutes that  
          govern water quality issues, the CWA and the SDWA, are  
          administered under one federal agency:  USEPA.  

          In California, water quality regulation is bifurcated.  The  
          SWRCB, which is housed in Cal/EPA, administers the CWA,  
          Porter-Cologne, and the CWSRF.  Then DPH, which is housed within  
          the CHHSA, administers the SDWA, the State's parallel statute to  
          the SDWA, and the SDWSRF.  In essence, this means that the SWRCB  
          and the regional water quality control boards are responsible  
          for the quality of a water source before the water is pumped.   
          But, once the water is pumped from a drinking water well or  
          surface-water intake point, then DPH becomes responsible.

          The missions and the mandates of the SWRCB and DPH, while  
          overlapping with regard to water, are different.  The SWRCB  
          provides comprehensive protection for California's waters by  
          exercising authority over both water allocation and water  
          quality, with the exception of drinking water quality.  DPH  
          manages programs for a broad range of health-related activities,  
          such as chronic disease prevention, communicable disease  
          control, family health and planning, health care quality  
          (including the regulation of health care facilities and  
          professionals and laboratories), but also drinking water  
          quality.  

          DPH's DWP regulates over 8,000 public water systems (PWS), which  
          are defined as privately or publicly owned water systems that  
          serve more than 15 service connections or 25 people.  Regulation  
          includes inspecting the systems, issuing permits, taking  
          enforcements actions, and implementing new requirements due to  
          changes in federal or state law or regulations.  For small PWS  
          serving less than 200 service connections, DPH has delegated  
          regulatory authority to 34 California counties.  The delegated  
          counties regulate approximately 4,600 small PWSs that are  
          usually owned by schools, churches and small businesses, like  
          restaurants and hotels.  Other functions of the DWP have  
          included responding to emergencies, providing technical support,  
          and, providing financial assistance for water system  
          improvements, including funding under Proposition 50 (2002),  
          Proposition 84 (2006), and the SDWSRF.








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          Prior legislation has made several attempts to address safe  
          drinking water.  AB 2222 (Caballero), Chapter 670, Statutes of  
          2008 required the SWRCB to, among other actions, identify the  
          communities that rely on contaminated groundwater as a primary  
          source of drinking water.  In response to AB 2222 the SWRCB  
          identified 682 such communities serving nearly 21 million  
          people.  SB 1 X2 (Perata), Chapter 1, Statutes of 2007-08 Second  
          Extraordinary Session required the SWRCB, in consultation with  
          other agencies, to prepare a report to the Legislature that  
          would improve understanding of the causes of nitrate groundwater  
          contamination and identify potential remediation solutions and  
          funding sources to recover costs expended by the state.  AB 685  
          (Eng), Chapter 524, Statutes of 2012 declared it is state policy  
          that every human being has the right to clean, affordable, and  
          accessible water adequate for human consumption, cooking and  
          sanitary purposes.  However, the findings from both the AB 2222  
          and SB 1 X2 reports suggest that drinking water contamination in  
          California disproportionally affects small, rural and low-income  
          communities that depend mostly on groundwater as their drinking  
          water source.  

          Since November 2012, the Assembly Environmental Safety and Toxic  
          Materials Committee (ESTM) has held a series of oversight  
          hearings on the provision of safe, affordable, accessible  
          drinking water to all Californians, especially to those in  
          disadvantaged communities.  As part of those hearings, the  
          Legislative Analyst's Office (LAO) provided two analyses  
          relating to the DWP:  1) a comparison between DPH's management  
          of the SDWSRF and the SWRCB's management of the CWSRF, and; 2)  
          an evaluation of the transfer of the DWP from DPH to the SWRCB.   


          With regard to the SDWSRF, the LAO found that while there had  
          been some improvement in recent years, it still generally  
          performs less well than the CWSRF and performs significantly  
          below other states' SDWSRFs.  Thereafter, on April 19, 2013, the  
          USEPA issued a notice to DPH for non-compliance with the  
          requirements of the SDWA.  The USEPA notice stated that  
          California has the largest unliquidated obligation in the nation  
          and gave California 60 days to remedy specific instances of its  
          non-compliance or submit an acceptable corrective action plan.   
          If the state fails to do so, the USEPA may suspend payment to  
          the SDWSRF.  Additionally, the USEPA can take other enforcement  








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          actions such as withholding further grant funds, wholly or  
          partly suspending current awards, or wholly or partly  
          terminating current awards.

          The second LAO report regarding a potential transfer of the DWP  
          from SPH to the SWRCB concluded that transferring the DWP to the  
          SWRCB could have several advantages, including greater policy  
          integration on water issues; accelerated rulemaking; increased  
          efficiencies and administrative capacity; and heightened  
          transparency and greater public participation by utilizing a  
          board that meets in public.  The LAO's report also cautioned  
          that there could be potential disadvantages, including, loss of  
          some integration with public health programs; temporary  
          disruption in the program's capacity to perform regulatory  
          activities; and, potentially increased, mainly short-term,  
          administrative costs.  Ultimately, however, the LAO testified  
          that it would recommend transferring the DWP from DPH to the  
          SWRCB.

          The author states that the shift of an environmental health  
          program from a health based agency to an environmental  
          protection based agency is not a new trend.  At the federal  
          level, USEPA administers both clean water and safe drinking  
          water statutes and funds.  In California, Cal/EPA already has  
          several divisions that protect human health and the environment  
          at the same time, such as the California Air Resources Board and  
          the Department of Pesticide Regulation.  The author states that  
          placing the DWP under the SWRCB will strategically tie together  
          all water quality and water rights programs, thus enabling  
          California to better address future issues such as climate  
          change and increases in population.  Supporters state many  
          disadvantaged communities in California are regulated by DPH and  
          have lacked safe and reliable drinking water for numerous years.  
           They maintain that DPH's inability to help these communities  
          makes it clear that the administration of the DWP by DPH is a  
          barrier to achieving safe drinking water.  In contrast, they  
          state that the SWRCB has expertise in water quality and could  
          quickly and efficiently take on the additional responsibility.  

          Opponents however state that they provide safe drinking water to  
          millions of customers across the state, are regulated by DPH,  
          and that the State's DWP, including the permitting and  
          inspection functions, generally works well.  Opponents suggest  
          that the focus of this bill needs to be on targeted solutions  








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          that truly address the drinking water problems that  
          disadvantaged communities in unincorporated areas are facing.   
          Opponents maintain that they are concerned that moving the  
          entire DWP could negatively affect the parts of the program that  
          work and not solve the problems that do exist.  Other opponents  
          add that the transfer would create disruptions of vital division  
          functions; would inherently undermine human health functions;  
          and, could distract SWRCB from existing high profile priorities.


           Analysis Prepared by  :    Tina Cannon Leahy / W., P. & W. / (916)  
          319-2096 

                                                                 FN:  
                                                                 0000964