BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2259
                                                                  Page  1

          Date of Hearing:  April 9, 2014

                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
                           K.H. "Katcho" Achadjian, Chair
                 AB 2259 (Ridley-Thomas) - As Amended:  April 1, 2014
          
          SUBJECT  :  Water replenishment: assessment.

           SUMMARY  :  Requires actions to challenge to a replenishment  
          assessment for the Water Replenishment District of Southern  
          California to be commenced within 120 days of the adoption of  
          the resolution or motion to levy the replenishment assessment.   
          Specifically,  this bill  :  

          1)Requires a judicial action or proceeding to attack, review,  
            set aside, void, or annul a resolution or motion levying a  
            replenishment assessment for the Water Replenishment District  
            of Southern California to be commenced within 120 days of the  
            adoption of the resolution or motion.  

          2)Requires that an action by a local agency or interested person  
            regarding the replenishment assessment be brought pursuant to  
            the chapter in the Code of Civil Procedure related to  
            "Validating Proceedings."

           EXISTING LAW  :

          1)Provides, under the Water Replenishment District Act, for the  
            formation of a water replenishment district and grants  
            authority to a water replenishment district relating to the  
            replenishment, protection, and preservation of groundwater  
            supplies within that district.

          2)Requires, if the Board of WRD determines that a replenishment  
            assessment shall be levied upon the production of groundwater  
            from groundwater supplies within the district during the  
            ensuing fiscal year immediately following the making of that  
            determination, the Board to levy a replenishment assessment on  
            the production of groundwater from the groundwater supplies  
            within the district during the fiscal year commencing on July  
            1st next.

          3)Specifies that the replenishment assessment shall be fixed by  
            the Board at a uniform rate per acre-foot of groundwater so  
            produced.








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          4)Requires the producers of the groundwater to pay the  
            replenishment assessment to the District at the times and in  
            the manner provided.

          5)Provides for validating proceedings in the Code of Civil  
            Procedure.

           FISCAL EFFECT  :  None

           COMMENTS  :   

           1)Purpose of this bill  .  This bill establishes a 120-day period  
            by which actions challenging the replenishment assessment must  
            be brought.  The 120-day period would begin on the date upon  
            which the board made the determination to impose the  
            replenishment assessment.  The bill is sponsored by the Water  
            Replenishment District of Southern California.

           2)Background  .  The Water Replenishment District of Southern  
            California, which was established by voters in Los Angeles  
            County in 1959, is the state's only water replenishment  
            district. The District was established while the Los Angeles  
            County court proceeded through adjudication of groundwater  
            rights in the Central Basin and West Coast Basin aquifers.   
            The main function of the District is to recharge water into  
            groundwater basins for later withdrawal by water purveyors,  
            and the District has certain legal authorities to accomplish  
            this purpose.  The District earns revenue by charging water  
            replenishment assessments to the agencies, utilities, and  
            companies that pump groundwater.  The District also gets  
            property tax revenues from its share of the 1% property tax  
            rate.  Funds are used to buy surface water that then  
            percolates into the groundwater basin.

           3)Author's statement  .  According to the author, "The Water  
            Replenishment District Act does not specify a time period for  
            legal challenges to the replenishment assessment.  This bill  
            would establish a 120-day period by which actions challenging  
            the replenishment assessment must be brought; the 120-day  
            period would begin on the date upon which the board made the  
            determination to impose the replenishment assessment."

            "The bill provides that any such challenge must be in the form  
            of validation action of a writ of mandamus.  The latter option  








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            is provided as Code of Civil Procedure Section 860 is not  
            always allowed as a mechanism by which a person can seek  
            judicial invalidation of a public agency's action.  For  
            example, one line of case law holds that such a lawsuit is  
            available only in bonds and other similar financing  
            transactions.  Accordingly, a person challenging an agency's  
            actions will file a petition for writ of mandamus."

            The author also points to a number of statutes and case law  
            that recognize a short statute of limitations whereby a party  
            can challenge the adoption of a local agency public utility  
            tax, assessment, rate, fee or charge. This includes the  
            Mitigation Fee Act (contained in the Government Code),  
            Irrigation District Law, Municipal Water District Law, Water  
            Conservation District Law, and statutes regarding the  
            liability of public entities to pay for public utility capital  
            facilities fees.  The author notes that "the purpose of such a  
            short statute of limitations is to enhance the budgetary  
            stability of public utilities by promptly informing them of  
            any challenges to their ability to charge and collect fees."

           4)Related legislation  .  SB 620 (Wright), Chapter 638, Statutes  
            of 2013, repealed a limitation on the expenditure of the Water  
            Replenishment District of Southern California's annual reserve  
            fund for a five-year period and requires the District to  
            establish a budget advisory committee for purposes of  
            reviewing a replenishment assessment and the District's annual  
            operating budget.  The District would then be required to  
            consult with that advisory committee and would be required to  
            maintain records regarding the recommendations of the budget  
            advisory committee and the final decisions made by the board  
            of the District.  Provisions related the budget advisory  
            committee become inoperative on June 30, 2019, and are  
            repealed as of January 1, 2020.  
             
             Provisions in the SB 620 also increase the penalty that may be  
            imposed for the failure of the owner of a water-producing  
            facility to file certain reports.  Additionally, the bill  
            provides that the court shall direct that the District or  
            operator of a water-producing facility be awarded the  
            reasonable attorney's fees and costs relating to a motion  
            seeking injunctive relief whenever the District or operator of  
            a water-producing facility prevails on a petition or  
            complaint.  SB 620 was sponsored by the Water Replenishment  
            District of Southern California.








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            AB 2189 (Garcia, 2014) is currently pending in this Committee.  
             AB 2189 would incorporate into the Water Replenishment  
            District of Southern California's Act the procedures and  
            substantive requirements of Proposition 218.

           5)Arguments in support  .  The sponsor argues that over 70% of the  
            revenue collected by the Water Replenishment District is  
            expended in the fiscal year in which the assessment is imposed  
            to purchase or produce replenishment water and that the lack  
            of a statute of limitations for legal challenges for the  
            assessment jeopardizes the financial security of the District  
            as well as the duty to replenish groundwater basins that serve  
            over 10% of California's population.

           6)Arguments in opposition  .  None on file.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Water Replenishment District of Southern California [SPONSOR]

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Debbie Michel / L. GOV. / (916)  
          319-3958