BILL ANALYSIS                                                                                                                                                                                                    �




                   Senate Appropriations Committee Fiscal Summary
                            Senator Kevin de Le�n, Chair


          AB 1102 (Allen) - Beach fire rings: coastal development permit.
          
          Amended: July 1, 2014           Policy Vote: EQ 4-2, NR&W 7-0
          Urgency: No                     Mandate: Yes (see staff  
          comments)
          Hearing Date: August 11, 2014                     Consultant:  
          Marie Liu     
          
          This bill does not meet the criteria for referral to the  
          Suspense File.
          
          
          Bill Summary: AB 1102 would specify that the removal or  
          restriction of the use of a beach fire ring is subject to the  
          Coastal Act and that an application for a coastal development  
          permit (CDP) regarding the removal or use restriction of a beach  
          fire ring must include an analysis of alternatives and  
          mitigation measures that would avoid or minimize the need to  
          remove or restrict the use of those rings. 

          Fiscal Impact: Minor state costs, if any, to the General Fund to  
          the Coastal Commission for the review of a CDP regarding the  
          removal or restriction of use of beach fire rings.

          Background: The Coastal Act requires any person (including a  
          local agency) wishing to perform a development in the coastal  
          zone to first obtain a CDP from the Coastal Commission  
          (commission) or from the local government, if that local  
          government has a commission-certified local coastal program.  
          What constitutes a "development" in the coastal zone is broadly  
          defined under the Coastal Act and includes activities that  
          change the intensity of use of land or public access to coastal  
          waters. 

          Section 30005 of the Public Resources Code states that the  
          Coastal Act does not limit a local government's ability to  
          declare, prohibit, and abate nuisances.

          The Coastal Act also states that Air Resources Board and the air  
          pollution control districts are the principal public agencies  
          responsible for the establishment of ambient air quality and  
          emission standards and air pollution control programs. The  








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          Coastal Act does not authorize the commission or any local  
          government to establish or modify any air quality standard,  
          emission standard, or air pollution control program that has  
          been established by the ARB or an air pollution control  
          district. (PRC �30414)

          Proposed Law: This bill would specify that the removal or  
          restriction of use of a beach fire ring is subject to the  
          Coastal Act even if the city or county is attempting to remove  
          or restrict the use under nuisance ordinances.

          This bill would specify that the application include an analysis  
          of alternatives that would avoid or minimize the need for  
          changing the use of fire rings. 

          Staff Comments: The Coastal Commission contends that the Coastal  
          Act currently applies to the removal or restriction of use of a  
          beach fire ring. Under this assertion, there are no costs to the  
          bill as this bill would only specify that the CDP include an  
          analysis of alternatives, which would minimally change the staff  
          time necessary to review the application, if at all. Other costs  
          associated with the submission of the permit would be existing  
          and would occur irrespective of this bill.

          However, if it is found that the Coastal Act does not currently  
          require a CDP for the removal or restriction of use of a beach  
          fire ring, than the permit obligation of this bill is new, and  
          the commission's costs to consider such a permit would be  
          attributable to this bill. Staff believes that this bill will  
          only likely trigger one permit. Changes to fire ring use are  
          being currently being sought in Southern California as a result  
          of South Coast Air Quality Management District's (SCAQMD's) Rule  
          444, which imposes various conditions on beach burning. No other  
          air district has taken actions indicating interest in enacting a  
          similar rule. Within in SCAQMD's jurisdiction, there are several  
          municipalities who have fire rings, but all of them have  
          approved local coastal development plans except the City of  
          Newport Beach. Thus, the only permit that would come to the  
          commission, and therefore have state costs to review, would be a  
          permit from Newport Beach. Much of the staff work necessary to  
          review an application from Newport Beach has already been  
          completed as a result of a local debate on this issue that has  
          spanned over two years and included a CDP application that was  
          later withdrawn. As such, the Coastal Commission estimates that  








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          the staff time to review a new CDP application for the removal  
          or use restriction of a beach fire ring from Newport Beach would  
          be between $25,000 and $35,000 in one-time costs. Again, these  
          costs are only attributable to this bill under the assumption  
          that the Coastal Act does not currently require a CDP for fire  
          rings.

          Staff notes that Newport Beach applied for a CDP application in  
          late July for its pilot program which prohibits the burning of  
          wood in the fire rings and instead requires the use of charcoal.  
          If this application is approved before this bill's effective  
          date (January 1, 2015), should it be signed into law, there will  
          be no additional state costs associated with the bill. 

          This bill is tagged as a state mandated local-program; however,  
          staff believes that there is no mandate because there is nothing  
          in this bill that would require a local agency to remove or  
          restrict the use of a fire ring. Thus, if a local agency incurs  
          costs with submitting a CDP application regarding fire rings, it  
          is a result of a discretionary action. In the case of Newport  
          Beach and SCAQMD, Newport Beach is being required to modify the  
          use of the fire rings, but this requirement is the result of the  
          SCAQMD's action, not this bill. Therefore, staff believes that  
          there are no state mandate costs associated with this bill.