On behalf of Tulare County Board of Supervisors, I am writing to discuss Assembly Bill 1737 (AB 1737) by Assembly Member Holden, which we must regretfully oppose. Currently, the State Public Health Officer regulates and establishes minimum standards for "organized camps." AB 1737 would expand current law to make all provisions related to "organized camps" applicable to "children's camps" as well. The resulting expansion of current law would therefore serve to limit children's camps and learning opportunities in Tulare County and would furthermore add significant workload to existing Environmental Health staff, which we believe should be offset by direct payment by the State. We therefore must regretfully oppose AB 1737 without changes to the legislation that would address these concerns.
Tulare County currently permits approximately ten (10) organized camps in Tulare County, annually inspecting them for safe housing accommodations, sanitation, adequate vector controls, safe food service, health supervision (i.e., allergies and immunizations, etc.), adequate emergency plans, and proper supervision and oversight of swimming pool facilities. The associated cost of the regulatory oversight services provided by Tulare County Environmental Health Services (EHS) is recovered by several current annual permit fees set for the organized camp program that include plan review, campground review, food, and swimming pools permit ranges between $1,035-$1,910 based on non-profit or for-profit status. Current revenue for this program is approximately between $10,000-$11,000. All current permitted camps are non-profit organizations.
This bill would require local implementation of a new regulatory, inspection and enforcement program for daytime camps for 5 days or more during one or more seasons of the year, significantly expanding the children's summer programs that would be subject to permitting and inspections.
This would include, but not limited to: City Parks and Recreation programs, sports camps, arts and ceramics camps, theatre camps, horseback riding camps, STEAM camps, library programs, sign language camps, and hundreds more. It is estimated that there are more than 40 of such camps routinely advertised in Tulare County, excluding many faith-based organization camps that will not be exempted from this legislation.
The additional requirement to require children's camps to register at least 90 days prior to commencing operations, prepare a comprehensive operating plan as required by Sec. 600004, obtain a health permit, hire a full-time adult health supervisor, and be subject to penalties for not registering, will serve to limit the available children's camps and learning opportunities in Tulare County for those parents and children least likely to afford these daytime camp opportunities already. A reduction in daytime camps for working households will further increase the disparity of economic opportunity in Tulare County.
Based on the estimated workload, the cost for the County to implement a children's camp regulatory program will be between $80,000-170,000, requiring an additional 1.0-2.0 FTE staff, and program implementation costs, including database updates, reporting to the State Department of Public Health, at least two inspections at each camp, and mandated enforcement by the County for those not registered. These costs, in addition to labor requirements for each children's daytime camp, will substantially increase the cost of children's daytime camps in the community. The other alternative is that these camps will no longer be offered for five (5) or more days.
While it is important to ensure health and safety standards are maintained to protect child participants at daytime or overnight camps, it is recommended that this bill be OPPOSED UNLESS AMENDED in the following areas (as an unfunded State mandate):
Substantial cost increase to County for program implementation and resulting in severe limiting of daytime children's camp opportunities in Tulare County and elsewhere in the State. It is for these reasons that the Tulare County Board of Supervisors must regretfully oppose AB 1737.
Sincerely,
Eddie Valero, Chairman
Tulare County Board of Supervisors
cc: Assembly Member Wood, Tulare State Delegation, Paul Yoder, Shaw Yoder Antwih Schmelzer & Lange