BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                   AB 833|
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                                 THIRD READING


          Bill No:  AB 833
          Author:   Ruskin (D)
          Amended:  8/20/07 in Senate
          Vote:     21

           
           SENATE ENV. QUALITY COMMITTEE  :  5-2, 7/2/07
          AYES:  Simitian, Florez, Kuehl, Lowenthal, Steinberg
          NOES:  Runner, Aanestad

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8

           ASSEMBLY FLOOR  :  48-29, 6/6/07 - See last page for vote


           SUBJECT  :    California Toxic Release Inventory Program

           SOURCE  :     Author


           DIGEST  :    This bill enacts the California Toxic Release  
          Inventory Program Act of 2007 to require the Department of  
          Toxic Substances Control to develop and implement, by  
          January 1, 2009, the California Toxic Release Inventory  
          Program to require a facility to submit a toxic chemical  
          release form to the department, if the facility is not  
          required to submit a toxic chemical release form containing  
          that same information pursuant to the existing federal  
          regulations, as specified.

           ANALYSIS  :    

           Existing Law  
                                                           CONTINUED





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          1.Requires certain California industrial facilities that  
            use any of approximately 650 chemicals annually to  
            disclose information about releases to air, land, and  
            water to the US Environmental Protection Agency (US EPA)  
            for the dissemination of information in a publicly  
            accessible, on-line data base, referred to as the Toxics  
            Release Inventory or TRI, pursuant to the federal  
            Emergency Planning and Community Right to Know Act of  
            1986 (EPCRA, Chapter 116 of Title 42 of the United States  
            Code).

          2.Authorizes the California Environmental Protection Agency  
            (Cal EPA) to request any business to submit the  
            information required pursuant to EPCRA to also submit  
            such information to Cal EPA.

          3.Prohibits Cal EPA, however, from requiring the form from  
            certain businesses or in an amount lower than the  
            applicable threshold amount specified pursuant to EPCRA.

          This bill makes the following legislative findings and  
          declarations:

          1.That the people of California have the right to know the  
            hazards posed by toxic releases near their homes,  
            schools, and workplaces.  They have the right to know how  
            much pollution is being released into the water, air, and  
            soil.

          2.Since its inception in 1986, as part of the federal  
            Emergency Planning and Community Right-to-Know Act of  
            1986, (EPCRA; Chapter 116 (commencing with Section 11001)  
            of Title 42 of the United States Code), the Toxic Release  
            Inventory (TRI) has supplied this essential information  
            on toxic chemical releases to the public.  The goal of  
            the TRI is to empower citizens, through information, to  
            hold companies and local governments accountable for how  
            toxic chemicals are managed.

          3.States that it is the intent of the Legislature that  
            California citizens do not lose access to the information  
            necessary to understand the potential threats to public  
            health and safety and the environment that is available  







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            through the Toxic Release Inventory as it existed on  
            January 1, 2006, including the ease of accessibility.
           
          This bill:

          1.Requires the DTSC to develop and implement the California  
            Toxic Release Inventory Program which requires DTSC when  
            implementing the program to comply with the requirements  
            of the federal act with regard to ensuring that any  
            requirement imposed by this bill is no less stringent  
            than, not otherwise preempted by, any requirement imposed  
            pursuant to the federal act, including any changes to the  
            existing federal regulations that decrease the threshold  
            quantity or include additional toxic chemicals subject to  
            the federal act.

          2.Requires a facility to submit a toxic chemical release  
            form to the DTSC, in accordance with the existing federal  
            regulations, if the facility is not required by the  
            federal regulations to submit a toxic chemical release  
            form containing that same information.

          3.Provides that the program require that the information be  
            reported retroactively to the effective date of the  
            change in the federal act or the existing federal  
            regulations as to ensure no gap in data collection.

          4.Requires DTSC to evaluate California-specific reporting  
            requirements and determine if this information can  
            substitute, in whole or in part, for the information  
            required under the program, as specified.

          5.Requires DTSC to post a copy of each form received from  
            each facility that is subject to the program on the  
            department's publicly available Internet Web site.

          6.Authorizes the DTSC to adopt regulations to implement the  
            program as emergency regulations and requires the Office  
            of Administrative Law to deem these regulations to be  
            necessary for the immediate preservation of the public  
            peace, health, safety, and general welfare.

           Background
           







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           What is the Toxic Release Inventory (TRI)  ?  The TRI  
          constitutes a body of information on the release of toxics  
          at the community level as part of what was for many years  
          regarded as the nation's premier right-to-know law - EPCRA.  
            Established in 1986, TRI simply required certain  
          industrial facilities that manufacture, process, or use  
          significant amounts of certain toxic chemicals, to annually  
          report the amount of chemicals they release and dispose of  
          each year.

          The TRI report contains information about the types and  
          amounts of toxic chemicals that are released each year to  
          the air, water, and land.  Additionally, TRI provides  
          information on the quantities of toxic chemicals sent to  
          other facilities for disposal or treatment.

           Changes in Federal Regulatory Requirements  .  On September  
          21, 2005, the federal EPA announced its intention to roll  
          back reporting requirements for all chemicals under the  
          federal TRI.  The federal EPA proposal had two major  
          components (1) Increase the amount of chemical releases  
          that trigger detailed TRI reporting from 500 to 5,000  
          pounds per year, and (2) eliminate annual reporting and  
          replace it with reporting every other year.

          The federal EPA offered no rationale for the proposal other  
          than its desire to ease the regulatory burden on business.   
          It was met with much opposition and prompted the federal  
          EPA to modify its proposal.  When the final rule was  
          published in December 2006, the proposal for alternate-year  
          reporting was gone, and the threshold for reporting  
          chemical use was raised not to 5,000 pounds, but 2,000  
          pounds.  However, raising the threshold by a factor of four  
          rather than a factor of 10 still will eliminate report of  
          millions of pounds of toxics chemicals nationwide.

           US EPA Science Advisory Board - Criticisms  .  On July 12,  
          2006 the US EPA Science Advisory Board wrote to the  
          Administrator of US EPA regarding their perspective on  
          proposed changes to federal law, "We are sufficiently  
          concerned about the potential negative impacts of these  
          changes on scientific research that we offer this  
          commentary."  The SAB then noted that they anticipated that  
          the proposed changes would affect the value of TRI data in  







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          the following two ways: First, it will obscure the extent  
          of facilities' releases of toxics chemicals; and second,  
          biennial reporting will make it impossible to track actual  
          emissions in communities (or by facilities) from year to  
          year (As noted above, the final change dropped the change  
          to biennial reporting).

           GAO - More Criticisms  .  In a review by the Government  
          Accountability Office (GAO) released in February of this  
          year, GAO concluded the following regarding the federal  
          changes:

            "We believe that the TRI reporting changes will likely  
            have a significant impact on information available to  
            the public about dozens of toxic chemicals?.We estimate  
            that 302 [facilities] in California would no longer  
            have to report any quantitative information to the  
            TRI?.and that California could have 33 percent fewer  
            chemical reports."

           Prior Legislation  .  

          AB 2490 (Ruskin), 2006-2007 Session a similar bill passed  
          the Senate Floor 21-13 on August 28, 2006, but was vetoed  
          by the Governor in September, 2006.  The veto message  
          stated, "This bill is overly broad, premature and  
          duplicative."  

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

           SUPPORT  :   (Verified  8/22/07)

          Breast Cancer Action
          Breast Cancer Fund
          Environmental Working Group
          League of Women Voters of California
          Planning and Conservation League
          Sierra Club California  
           
           OPPOSITION  :    (Verified  8/22/07)

          California Chamber of Commerce
          California Council for Environmental and Economic Reliance







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          California Manufacturers and Technology Association
          Silicon Valley Leadership Group

           ARGUMENTS IN SUPPORT  :    According to the author's office,  
          this bill ensures that Californians will always have access  
          to information regarding the hazards posed by toxic  
          releases near their homes, schools, and workplaces.  This  
          bill is in response to the recent federal regulations that  
          reduced information requirements for the federal act.  It  
          is also needed to ensure that separate from federal  
          administrative actions, California will maintain access to  
          information about chemical releases.

           ARGUMENTS IN OPPOSITION  :    According to the California  
          Chamber of Commerce, "The Environmental Protection Agency  
          (EPA) has recently finalized changes to the TRI program  
          that are intended to streamline the reporting process for  
          certain types of chemicals that are used in smaller  
          amounts.  Specifically, the new rules allow the use of a  
          simpler Form A instead of a more complicated Form R in  
          certain circumstances.  The Form A can be used under the  
          new rules if the chemical is not persistent,  
          bioaccumulative, and toxic (PBT).  The Form A can also be  
          used for certain PBT chemicals if there have been no  
          discharges and the PBT chemical is used under certain  
          amounts.  These changes simply allow for a more  
          cost-effective form of reporting under certain  
          circumstances.

          "The "trigger" for California creating a state TRI program  
          is very subjective.  Some may look at certain changes as  
          "less stringent", while others see those changes as a more  
          effective method of managing the program that indeed  
          reduces the use of some chemicals.  For example, the  
          federal TRI program website indicates that the changes  
          allow the use of Form A for PBT chemicals when there is no  
          discharge involved because they feel that this would in  
          fact reduce discharge and provide an incentive to use  
          preferred practices such as recycling or treatment.

          "AB 833 (Ruskin) would require California to create a  
          duplicative TRI program in the event that the federal  
          program is amended, repealed or in any way made less  
          stringent.  The federal TRI program has been in effect for  







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          years and has proven to be an effective tool for releasing  
          information to the public.  Creating a duplicative program  
          would be costly for the California economy and would  
          provide no additional public benefit."

           ASSEMBLY FLOOR  : 
          AYES:  Adams, Arambula, Bass, Beall, Berg, Brownley,  
            Caballero, Charles Calderon, Carter, Coto, Davis, De La  
            Torre, De Leon, DeSaulnier, Dymally, Eng, Evans, Feuer,  
            Fuentes, Hancock, Hayashi, Hernandez, Huffman, Jones,  
            Karnette, Krekorian, Laird, Leno, Levine, Lieber, Lieu,  
            Ma, Mendoza, Mullin, Nava, Parra, Portantino, Price,  
            Richardson, Ruskin, Salas, Saldana, Smyth, Solorio,  
            Swanson, Torrico, Wolk, Nunez
          NOES:  Aghazarian, Anderson, Benoit, Berryhill, Blakeslee,  
            DeVore, Duvall, Emmerson, Fuller, Gaines, Galgiani,  
            Garcia, Garrick, Horton, Houston, Huff, Keene, La Malfa,  
            Maze, Nakanishi, Niello, Plescia, Sharon Runner, Silva,  
            Spitzer, Strickland, Tran, Villines, Walters
          NO VOTE RECORDED:  Cook, Jeffries, Soto


          TSM:do  8/23/07   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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