BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1102
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          ASSEMBLY THIRD READING
          AB 1102 (Allen and Quirk-Silva)
          As Amended  January 17, 2014
          Majority vote 

           NATURAL RESOURCES   7-0         APPROPRIATIONS      16-0        
           
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          |Ayes:|Chesbro, Jones, Bigelow,  |Ayes:|Gatto, Bigelow, Allen,    |
          |     |Garcia, Patterson, Stone, |     |Bocanegra, Bradford, Ian  |
          |     |Williams                  |     |Calderon, Campos, Eggman, |
          |     |                          |     |Gomez, Holden, Linder,    |
          |     |                          |     |Pan, Quirk,               |
          |     |                          |     |Ridley-Thomas, Wagner,    |
          |     |                          |     |Weber                     |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Delays open burning rules restricting the use or  
          location of a beach fire ring until an approved coastal  
          development permit (CDP) is implemented.  Specifically,  this  
          bill  :

          1)Delays any rule adopted by the Southern California Air Quality  
            Management District (SCAQMD) on open burning that restricts  
            the use or location of a beach fire ring until the public  
            agency with jurisdiction over that area obtains and implements  
            an approved CDP consistent with the Coastal Act.

          2)Requires the affected public agency to obtain the CDP no more  
            than two years after the enactment of the open burning rule  
            adopted by SCAQMD.

          3)Requires restrictions on beach fire rings to be subject to the  
            provisions of this bill notwithstanding existing law that  
            limits the Coastal Act's jurisdiction over a city or county  
            authority to declare, prohibit, and abate nuisance.

          4)Requires an application for a CDP to remove or restrict the  
            use of a beach fire ring to include an analysis of  
            alternatives and mitigation measures that would avoid or  
            minimize the need to remove or restrict the use of a beach  
            fire ring. 









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          5)Declares that it is the state's preference to avoid the net  
            loss of beach fire rings within a city's jurisdiction.

          6)Defines a beach fire ring as a device in which recreational or  
            ceremonial burning occurs that is located on a beach in the  
            coastal zone.

          7)Applies the provisions of the bill retroactively to March 1,  
            2014.

          EXISTING LAW  :  

          1)Pursuant to the Coastal Act:

             a)   Requires a person wishing to perform a development in  
               the coastal zone to first obtain a CDP from the Coastal  
               Commission (Commission) or a local government with a  
               Commission-certified local coastal program.  

             b)   In carrying out the California Constitution's protection  
               of coastal access, requires maximum access and recreational  
               opportunities to be provided for all the people consistent  
               with public safety needs and the need to protect public  
               rights, rights of private property owners, and natural  
               resource areas from over use.  

             c)   Requires lower cost visitor and recreational facilities  
               to be protected, encouraged, and, where feasible, provided.  
                Declares a preference for developments providing public  
               recreational opportunities.  

             d)   Requires, wherever appropriate and feasible, public  
               facilities, including parking areas or facilities, to be  
               distributed throughout an area so as to mitigate against  
               the impacts, social and otherwise, of overcrowding or  
               overuse by the public of any single area.

          2)Pursuant to SCAQMD's open burning regulations:

             a)   Effective March 1, 2014, prohibits beach burning,  
               unless:

               i)     Particulate matter 2.5 air quality index value of  
                 100 or less has been forecast for the coastal source  








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                 receptor area; and

               ii)    Beach burning occurs in devices that are:

                  (1)       At least 700 feet from the nearest residence; 

                  (2)       At least 100 feet apart from one another; or

                  (3)       At least 50 feet apart from one another, if  
                    there are no more than 15 devices per contiguous beach  
                    area within the city's boundaries.

             b)   Explains that beach burning devices may not be made  
               available by a state or local authority if a city or county  
               has declared, pursuant to existing authority, that  
               designated beach burning devices within its boundaries  
               cause a nuisance, as defined by existing law, due to wood  
               smoke exposure.

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee:

          1)Unknown increased costs to the state for reimbursing local  
            governments mandated to obtain a CDP prior to complying with  
            Rule 444 likely in the range of several hundred thousand  
            dollars. 

          2)Unknown additional costs to the Commission for CDP approval  
            for activities including burning restrictions based on poor  
            air quality conditions.
           
          COMMENTS  :

           Background  .  There are approximately 765 beach fire rings in Los  
          Angeles and Orange counties with the overwhelming majority  
          (approximately 90%) along the Orange County coastline.  In the  
          City of Newport Beach (City), the beach fire rings have been a  
          part of the recreational experience since the late 1940s or  
          early 1950s and are recognized as a lower cost visitor and  
          recreational facility.

          In recent years, the City has been the epicenter of a highly  
          publicized debate over whether fire rings should be protected  
          because of their recreational value or strictly regulated  








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          because, among other things, the hazards of wood smoke.  

          According to the SCAQMD, the health effects from exposure to  
          household and neighborhood wood smoke have been studied  
          extensively. The greatest health effect from wood smoke exposure  
          originates from the fine particles that can cause health  
          problems ranging from minor irritations such as burning eyes and  
          runny noses to chronic illnesses such as bronchitis.

           The City steps into the ring .  On March 13, 2012, the City voted  
          unanimously "to direct staff to take the necessary steps to  
          remove the sixty (60) fire rings at Big Corona and the Balboa  
          Pier areas."  The City Council's staff report highlighted the  
          "health impacts to nearby residents and other beachgoers due to  
          smoke and particulate matter from the beach fires" and "safety  
          of fire ring users and other beachgoers when hot ash is not  
          doused or disposed of properly, or when individuals are injured  
          after falling near or in a fire ring."  

           The City goes to the Commission  .  On October 22, 2012, the City  
          filed a CDP application with the Commission to remove all fire  
          rings from the City's beaches.  This includes 33 fire rings near  
          the Balboa Pier and another 27 on a patch of Corona del Mar  
          State Beach known as Big Corona.  

           Commission staff recommended denial of the CDP "because removal  
          of the fire rings would deny the public access to this popular  
          form of lower cost public recreation."  In addition, the report  
          stated that removing these fire rings "would shift the already  
          high demand for fire rings to other coastal locations, creating  
          new access and recreational demands there."  

           Shortly before the March 6, 2013, Commission hearing on the CDP  
          application, the Commission was informed that the SCAQMD was  
          going to address fire rings through an amendment to its own  
          regulations.  In light of this information, the Commission took  
          no action at the hearing and continued the matter until the  
          SCAQMD's action is finalized.  
           
           SCAQMD regulates fire rings  .  Prior to July 2013, the SCAQMD's  
          regulation on open burning (Rule 444) specifically excluded from  
          its purview "recreational fire or ceremonial fires" and "open  
          burning of?untreated wood?for the purpose of?[g]enerating warmth  
          at a social gathering."








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           In March 2013, based on knowledge of wood smoke health effects,  
          the number of existing beach fire rings, proximity of those fire  
          rings to residences, and the extent of fire ring usage, SCAQMD  
          staff developed a proposal that would have prohibited beach  
          burning after January 1, 2015.  According to a SCAQMD staff  
          report, the proposal received significant public comment at a  
          March 28, 2013, public consultation meeting, as well as via  
          e-mail, direct mail, and telephone correspondence during the  
          subsequent public review period.  As a result, the proposal was  
          revised to essentially allow fire rings to remain if they are  
          "(I) at least 700 feet from the nearest residence; or (II) at  
          least 100 feet apart from one another; or (III) at least 50 feet  
          apart from one another, if there are no more than 15 devices per  
          contiguous beach area within the city's boundaries."  This  
          revised proposal, however, would allow a city or county to ban  
          fire rings by declaring that they cause a nuisance under  
          existing law.  

          On July 12, 2013, SCAQMD approved amending Rule 444 to reflect  
          the revised proposal.  The amendments will be effective  
          beginning on March 1, 2014.  SCAQMD also approved issuing a  
          request for bids to design and demonstrate up to 25 low-emission  
          fire rings fueled by sources other than wood such as propane or  
          natural gas.

          SCAQMD claims that fire rings at Dockweiler State Beach,  
          Huntington City Beach, and Bolsa Chica State Beach are not  
          expected to be affected by the distance criteria in the amended  
          Rule 444.  However, all 60 of the fire rings in the City "would  
          have to be better dispersed and/or moved to another beach in the  
          city to meet the rule's spacing requirements."  Additionally, "a  
          few dozen fire rings at Huntington State Beach and other beaches  
          would have to be dispersed at greater distances."

           The Main Problem  .  Although Rule 444 applies to all geographic  
          areas under the SCAQMD's jurisdiction, its impact (by design or  
          coincidence) appears to be focused on the City's fire rings.   
          Based on discussions with SCAQMD and Commission staff, it is  
          apparent that compliance with Rule 444 and the Coastal Act are  
          not mutually exclusive:  if the City spaces out its fire rings  
          at least 100 feet from each other, it has enough beach area to  
          keep all fire rings.  As such, the policy goals related to air  
          quality and lower cost visitor and recreational facilities could  








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          be achieved.
             
           The problem, however, is that the City has not yet submitted a  
          CDP to the Commission that would space the fire rings out 100  
          feet from each other.  With March 1, 2014, (the date Rule 444's  
          beach burning rule becomes effective) almost a month away, it  
          looks like the City will either be in violation of Rule 444 or  
          have to comply with Rule 444 without a CDP, which would likely  
          violate the Coastal Act.  

          This bill will delay Rule 444's effective date until the City  
          obtains and implements its CDP.  


           Analysis Prepared by  :  Mario DeBernardo / NAT. RES. / (916)  
          319-2092 


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