BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 300
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          Date of Hearing:  May 13, 2013

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

                     AB 300 (Perea) - As Amended:  April 16, 2013
                                           
           2/3 vote.  Urgency.  Fiscal committee.  
           
          SUBJECT  :  Telecommunications:  prepaid mobile telephony  
          services:  state surcharges and fees:  local charges collection

           SUMMARY  :  Establishes a new point of sale system for collecting  
          and remitting specified fees, surcharges, and taxes applicable  
          to prepaid mobile telephony services (MTS).  Specifically,  this  
          bill :

          1)Contains the following legislative findings and declarations:

             a)   Providers of end-use communications services, including  
               providers of mobile voice telecommunications services,  
               which the Federal Communications Commission (FCC) terms  
               MTS, are required to collect and remit communications  
               taxes, fees, and surcharges on various types of  
               communication service revenues, as provided by existing  
               state or local law.  

             b)   Consumers purchase prepaid MTS at a wide variety of  
               retail locations and other distribution channels, as well  
               as through service providers.  

             c)   Prepaid MTS are an important and growing segment of the  
               communications industry.  Such services are often the only  
               means by which persons with low incomes can obtain limited  
               access to the telecommunications system.  

             d)   To ensure equitable contributions from end-use consumers  
               of postpaid and prepaid MTS in this state, there should be  
               standardization with respect to the method used to collect  
               communications taxes, fees, and surcharges from end-use  
               consumers of prepaid MTS.  

             e)   Prepaid MTS are frequently sold by a third-party  
               retailer that is not the provider of MTS, and collecting  








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               taxes, fees, and surcharges from prepaid consumers of MTS  
               at the time of the retail transaction is necessary and the  
               most efficient and competitively neutral means of  
               collection.  

             f)   An equitable distribution mechanism is necessary to  
               ensure that utility user taxes (UUTs) and other  
               telecommunication charges are collected on behalf of cities  
               and counties and are properly distributed to those  
               jurisdictions.  

          2)Enacts the Prepaid MTS Surcharge and Collection Act.

          3)Imposes, on and after January 1, 2015, a "prepaid MTS  
            surcharge" on each prepaid consumer.  Sellers shall collect  
            the surcharge from prepaid consumers at the time of each  
            retail transaction for prepaid MTS in the state.   

          4)Specifies that the "prepaid MTS surcharge" shall be collected  
            as a percentage of the amount of each retail transaction that  
            occurs in this state.  

          5)Provides that the "prepaid MTS surcharge" shall be in lieu of  
            any charges imposed under the Emergency Telephone Users  
            Surcharge Act and the "Public Utilities Commission (PUC)  
            surcharges" for prepaid MTS.   

          6)Defines the "prepaid MTS surcharge" as a unitary surcharge  
            consisting of the emergency telephone users surcharge and the  
            "PUC surcharges", as specified.    

          7)Defines the "PUC surcharges" to include:

             a)   The California High-Cost Fund-A Administrative Committee  
               Fund program surcharge;

             b)   The California High-Cost Fund-B Administrative Committee  
               Fund program surcharge;

             c)   The Deaf and Disabled Telecommunications Program  
               Administrative Committee Fund surcharge;

             d)   The California Teleconnect Fund Administrative Committee  
               Fund program surcharge;









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             e)   The California Advanced Services Fund program surcharge;  


             f)   The Moore Universal Telephone Service Act; and, 

             g)   PUC reimbursement fees.  

          8)Requires the PUC to compute annually, by October 1 of each  
            year beginning on October 1, 2014, the following:

             a)   A reimbursement fee as a percentage of the sales price  
               for prepaid MTS, to be effective on January 1 of the  
               following year and to be collected and remitted pursuant to  
               this bill; and, 

             b)   The cumulative of the telecommunications universal  
               service surcharges as a percentage of the sales price for  
               prepaid MTS, to be effective on January 1 of the following  
               year and to be collected and remitted pursuant to this  
               bill.  

          9)Requires the State Board of Equalization (BOE) to calculate  
            annually the prepaid MTS surcharge by November 1 of each year  
            beginning on November 1, 2014, by adding the following:

             a)   The emergency telephone users surcharge rate established  
               for intrastate telephone communication service, multiplied  
               by the inverse of the interstate wireless safe harbor  
               percentage established by the FCC for federal universal  
               service contribution purposes; and, 

             b)   The PUC surcharges, multiplied by the inverse of the  
               interstate wireless safe harbor percentage established by  
               the FCC for federal universal service contribution  
               purposes.  

          10)Permits sellers to deduct and retain 3% of the amounts  
            collected from prepaid consumers for the prepaid MTS surcharge  
            and local charges.  

          11)Requires the BOE to administer the prepaid MTS surcharge  
            pursuant to the Fee Collection Procedures Law.  

          12)Establishes the Prepaid MTS Surcharge Fund (Fund) in the  
            State Treasury.  The Fund shall consist of all surcharges,  








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            interest, penalties, and other amounts collected and paid to  
            the BOE, less a deduction "in an amount not to exceed" 2% of  
            the collected amounts to reimburse the BOE for administrative  
            expenses incurred.

          13)Enacts the Local Prepaid MTS Collection Act.

          14)Requires any local agency that has enacted "local charges" to  
            provide the BOE with notice of the charges applicable to  
            prepaid MTS, expressed as a percentage of the sales price of  
            prepaid MTS, on or before October 15, beginning on October 15,  
            2014.  

          15)Provides that on and after January 1, 2015, and before an  
            unspecified date, a "local charge" imposed on the consumption  
            of prepaid MTS shall be collected from prepaid consumers in  
            the same manner as the prepaid MTS surcharge is collected, in  
            lieu of collection of those local charges by the city, county,  
            or city and county.

          16)Defines "local charge" as UUTs, as specified, and charges for  
            access to communication services or to local "911" emergency  
            telephone systems, as specified.   

          17)Suspends, on and after January 1, 2015, and before an  
            unspecified date, the authority of any city, county, or city  
            and county to impose a UUT rate on the consumption of prepaid  
            MTS at the rate specified by ordinance.  States that it is the  
            Legislature's intent to create a "tiered method" for  
            collection of the UUT rate.   

          18)Suspends, on and after January 1, 2015, and before an  
            unspecified date, the authority of any city, county, or city  
            and county to impose a charge applicable to prepaid MTS for  
            access to communication services or to local "911" emergency  
            telephone systems at the rate specified by ordinance.   
            Provides, instead, for a simplified but currently unspecified  
            rate structure.  

          19)Requires the amount of the combined prepaid MTS surcharge and  
            local charges to be separately stated on the invoice provided  
            to the prepaid consumer at the time of the retail transaction.

          20)Authorizes the BOE to make software available to sellers to  
            enable sellers to match the location of a retail transaction  








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            to the applicable prepaid MTS surcharge amount and local  
            charges.

          21)Provides that a seller that relies in good faith on  
            information provided by the BOE to match the location of a  
            point-of-sale transaction to the applicable prepaid MTS  
            surcharge amount and local charges, collects that amount from  
            the prepaid consumer, and remits the amount to the BOE, shall  
            not be liable for any additional MTS surcharge or local  
            charges and shall not be required to refund any amounts  
            collected and paid to the BOE or to the prepaid consumer.

          22)Provides that the prepaid MTS surcharge and local charges are  
            imposed on the prepaid consumer and not on the seller or on  
            any prepaid MTS provider, except that the seller shall collect  
            and remit the charges.

          23)Provides that this is an urgency statute necessary for the  
            immediate preservation of the public peace, health or safety.   
                        

           EXISTING LAW  :

          1)Imposes a surcharge, under the Emergency Telephone Users  
            Surcharge Act, on amounts paid for intrastate telephone  
            service.  These surcharges provide revenues sufficient to fund  
            "911" emergency telephone system costs.  Upon collection,  
            amounts are paid to the BOE on a monthly basis by the  
            telephone service supplier. 

          2)Grants the PUC regulatory authority over public utilities,  
            including telephone corporations.  Specifically, the PUC is  
            authorized to fix just and reasonable rates and charges for  
            services provided by public utilities.  

          3)Establishes the PUC Utilities Reimbursement Account and  
            authorizes the PUC to determine annually a fee to be paid by  
            every public utility (except railroad corporations) providing  
            service directly to customers or subscribers and subject to  
            the PUC's jurisdiction.   

          4)Establishes the state's telecommunications universal service  
            programs and authorizes the PUC to impose charges to fund  
            those programs.  Pursuant to this authority, the PUC has  
            established six end-user surcharges to fund six universal  








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            service programs.         

           FISCAL EFFECT  :  Unknown.  The BOE's fiscal estimate for this  
          bill is pending.   

           COMMENTS  :

          1)The author has provided the following statement in support of  
            this bill:

               Everyone who uses phone services pays a small monthly fee  
               as part of their bill to help fund 911 and support other  
               important state and local programs.  However, for the  
               fastest growing segment of wireless users, prepaid wireless  
               services, there is no collection mechanism for them to pay  
               these fees.  Approximately 25% of all wireless customers  
               are now prepaid customers.  The current system leaves state  
               and local governments without a reliable, predicable means  
               for ensuring collection of these revenues, depriving state  
               911, local governments and other public purpose programs of  
               critical funding.

               By modernizing state [statutes] and implementing a method  
               of point-of-sale collection on prepaid wireless services,  
               AB 300 ensures revenue for 911 systems, local governments  
               and other public purpose programs.  It would modernize our  
               collection system to ensure that prepaid wireless customers  
               pay the same, existing taxes and fees that all other phone  
               customers are currently required to pay.  In doing so it  
               will ensure more funding to maintain effective and  
               efficient 911 systems, while also benefitting local  
               governments and other public purpose programs.   

          2)Proponents of this bill note the following:

               This legislation will create a fair and equitable method of  
               collecting end user fees from the consumers of prepaid  
               wireless services.  

               Prepaid wireless service's unique business model offers  
               excellent wireless service to consumers at a very  
               affordable rate, often less expensive than post paid  
               service.  Moreover, prepaid services are offered on a  
               "pay-as-you-go" basis with no required contracts, term or  
               volume commitments, early termination penalties, overage  








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               charges, or credit checks.  These important factors make  
               prepaid services available to those consumers to whom the  
               security and convenience of mobile telephone service would  
               not be available.  This business model offers reliable  
               service and affordable pricing.  However, the fact that the  
               service is not billed creates a challenge as to how to  
               collect end user fees to fund programs such as 911, and the  
               various public purpose programs administered by the  
               California Public Utilities Commission.  

               AB 300 would establish a uniform, statewide retail  
               point-of-sale collection for taxes and fees on prepaid  
               wireless services.  AB 300 will create a transparent and  
               predictable source of funding for critical 911 services.   
               AB 300 also promotes consumer equity and fairness by  
               ensuring that all wireless customers who use the same 911  
               services pay the same taxes and fees to fund those  
               services.  In fact, point of sale collection methods have  
               been successfully enacted and implemented in at least 26  
               states.  

          3)Opponents of this bill note the following:

               AB 300 will create significant harms for California's  
               low-income communities and communities of color.  Consumers  
               who purchase pre-paid wireless services are more likely to  
               be low-income and more likely to be people of color.  AB  
               300 would force those consumers to pay a higher portion of  
               telephone surcharges than consumers of postpaid services.   
               Additionally, AB 300 would unjustly enrich retailers of  
               prepaid wireless services at the expense of low-income  
               communities and communities of color.

               [ . . . ]

               [AB 300 also] provides for up to two percent of the  
               collected funds to be used to reimburse the Board of  
               Equalization for the actual costs of administering the  
               program.  Retailers are entitled to retain three percent of  
               the collected funds.  However, the funds retained by  
               retailers are not reimbursement for their actual costs of  
               administering the program.  Rather, these funds are,  
               according to the bill analysis, "vendor compensation" for  
               administering the program. 









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               The three percent figure bears no apparent relation to  
               retailers' actual administrative costs.  Large retailers  
               will likely be able to take advantage of economies of  
               scale, and have administrative costs significantly lower  
               than the 3% set amount.  Those retailers will be able to  
               pocket the difference.  As a result, pre-paid subscribers  
               will be paying a surcharge that partially supports state  
               telecommunications programs, and partially lines the  
               pockets of retailers and shareholders.        

          4)Committee Staff Comments

              a)   Where the law and market trends collide  :  In the case of  
               traditional "postpaid" services, carriers know the personal  
               identities of their customers and generally collect  
               surcharges and fees by levying a certain percentage on top  
               of the cost of monthly services billed.  
                
                In the case of "prepaid" services, however, carriers often  
               do not know the identity of individual purchasers,  
               especially where services are provided through third-party  
               retailers.  This has rendered the "collection" and  
               "remittance" of surcharges for prepaid MTS a subject of  
               considerable controversy.  The PUC asserts that carriers  
               are already collecting and remitting state surcharges and  
               fees from both their postpaid and prepaid customers,  
               thereby rendering this bill unnecessary.  The wireless  
               telecommunications industry, on the other hand, asserts  
               that carriers are currently remitting the taxes, fees, and  
               surcharges with no standardized or feasible way to collect  
               them from prepaid customers. With the use of prepaid  
               services only expected to grow, carriers argue that it is  
               time to establish a uniform statewide method for collecting  
               and remitting fees and surcharges from prepaid consumers.    
                

              b)   What would this bill do?  :  This bill would establish a  
               new point of sale system for collecting and remitting  
               specified fees, surcharges, and taxes applicable to prepaid  
               MTS.  Beginning January 1, 2015, retailers would be  
               required to collect a unified "prepaid MTS surcharge" from  
               prepaid consumers at the time of sale.  This unified  
               surcharge would be collected as a percentage of the retail  
               sales price, and would be imposed in lieu of any 911  
               surcharge or PUC-administered surcharges imposed for  








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               prepaid MTS.  Retailers would be permitted to deduct and  
               retain 3% of the amounts collected as vendor compensation,  
               with the remainder paid to the BOE, which would be charged  
               with administering the new system.  The BOE, in turn, would  
               be authorized to deduct up to 2% of the collected amounts  
               to reimburse its administrative expenses.  
              
                Essentially, prepaid MTS providers would no longer be  
               required to remit surcharges and fees out of their existing  
               (largely wholesale) revenue streams.  Instead, carriers  
               would be able to keep their existing revenue streams whole,  
               by passing the surcharge and fee costs directly on to  
               prepaid MTS consumers.  

               This bill would also establish a new point of sale system  
               for collecting and remitting locally-imposed UUTs  
               applicable to prepaid MTS.  While this section of the bill  
               appears to be something of a "work in progress", the most  
               recent set of amendments proposed by the author would  
               establish a tiered rate structure for locally-imposed UUTs.  
                This tiered structure is designed to ameliorate the  
               administrative complexity that would necessarily be  
               involved in collecting the multiple rates imposed by the  
               roughly 90 to 100 jurisdictions with UUT ordinances  
               applicable to MTS.   

             c)   The policy arguments on both sides  :  On April 4, 2013,  
               the PUC voted unanimously to oppose AB 300.  The PUC bases  
               its opposition to this bill on four main policy objections.  
                The discussion below outlines these four points, and  
               summarizes the wireless telecommunication industry's  
               response to each argument:
              
               i)     The PUC argues that this bill is unnecessary  :   
                 Specifically, the PUC states that carriers are already  
                 collecting and remitting state surcharges and fees from  
                 both their postpaid and prepaid customers.  The PUC  
                 intentionally does not prescribe a MTS collection method,  
                 leaving carriers with discretion to implement the method  
                 that best meets their needs.  According to the PUC, there  
                 are multiple non-legislative remedies that would make  
                 prepaid collection methods more closely resemble postpaid  
                 methods.  For example, the PUC argues that carriers could  
                 modify their contractual arrangements with retailers, and  
                 deduct the requisite surcharges and fees from customers  








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                 at the time of credit activation.  The PUC argues that  
                 carriers could alternatively charge state-specific rates.  
                  The PUC acknowledges that such remedies put the onus on  
                 carriers to develop a more sophisticated collection  
                 system, which comes at a cost.  The PUC notes, "Carriers  
                 have made clear that their preferred alternative to  
                 assuming additional costs is to shift any and all prepaid  
                 collection expenses onto government, and, by extension,  
                 ratepayers and taxpayers."

                 The wireless industry strongly objects to the assertion  
                 that carriers are already collecting and remitting state  
                 surcharges and fees from their prepaid customers.   
                 Specifically, the industry states:

                    Carriers are currently remitting the taxes, fees and  
                    surcharges with no standardized or feasible way to  
                    collect them from prepaid customers.  Over 70% of all  
                    prepaid wireless transactions occur through third  
                    party retail channels.  In such instances, prepaid  
                    products (i.e.: prepaid cards) are sold at wholesale  
                    and distributed to retail outlets across the country.   
                    At the time of the wholesale sale, the provider does  
                    not know where the prepaid products will ultimately be  
                    sold.  Since prepaid products could be sold in  
                    California or any other state, carriers do not know  
                    which states' taxes, fees and surcharges to collect at  
                    the time of the wholesale sale.  

                 The wireless industry also takes issue with the PUC's  
                 assertion that carriers could simply charge  
                 state-specific rates for their prepaid products.   
                 Carriers argue that such a solution could potentially  
                 result in increased prices by eliminating economies of  
                 scale associated with national pricing and distribution.   
                  
                  
                ii)    The PUC argues that this bill would harm California  
                 consumers  :  Specifically, the PUC argues that consumers  
                 will likely see smaller contributions to the PUC user  
                 fee, the universal service programs, and the state's 911  
                 fee.  Under the newly enacted Revenue and Taxation Code  
                 (R&TC) Section 42010(b)(2), the PUC-mandated surcharges  
                 would be applied to intrastate revenue defined as, "the  
                          inverse of the interstate wireless safe harbor percentage  








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                 established by the [FCC] . . . ."  The PUC notes:

                    Under current FCC law, the safe harbor for the  
                    intrastate/interstate allocation of revenue is  
                    62.9%/37.1%.  Staff is aware, however, that the  
                    largest prepaid MTS carrier, TracFone, has (and is  
                    currently remitting on) a "books and records"  
                    allocation of 84%/16%.  Thus, for that carrier, the  
                    bill shrinks the surcharge base by over 20% (the delta  
                    between 84% and 62.9% of total California revenue.)   
                    New [R&TC] Section 42010 (a) also apparently extends  
                    this 20% smaller surcharge base to carriers' online,  
                    telephonic, or other direct sales which do not involve  
                    a third party retailer (approximately 30% of total  
                    sales).  

                 All in all, the PUC estimates that revenues would drop by  
                 as much as $16.3 million, which would need to be made up  
                 for by raising fees and surcharges on all wireless  
                 customers.

                 The wireless industry rejects this estimate and points to  
                 evidence from other states suggesting that AB 300 will  
                 actually generate more money for the PUC programs.   
                 Specifically, the industry states:

                    At a minimum, all of the surcharges on the majority of  
                    prepaid services sold by third party retailers would  
                    be imposed at the retail price instead of at the  
                    wholesale price under current practice.  The PUC is  
                    not the only revenue-receiving stakeholder to benefit  
                    from [AB 300].  In fact, the PUC's opposition to the  
                    point-of-sale collection mechanism proposed in [AB  
                    300] threatens to jeopardize a proposal that will  
                    benefit the state's 911 program and about 100 local  
                    governments that have local utility user taxes that  
                    apply to prepaid wireless.  Without this point-of-sale  
                    solution, locals, who are actively working with the  
                    industry on a complicated mechanism to collect their  
                    utility user taxes from prepaid customers, will stand  
                    to be the biggest losers.       

                 As to the PUC's assertion that the surcharge base will  
                 shrink by applying the inverse of the FCC safe harbor  
                 percentage, the industry states, "The PUC itself has  








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                 sponsored the inverse approach and, in fact, argued  
                 vociferously that it was completely reasonable and  
                 acceptable to the PUC."  

                iii)   The PUC argues that AB 300 establishes unfair  
                 disparities between postpaid and prepaid consumers  :   
                 Specifically, the PUC notes that retailers would be  
                 allowed to keep 3% of surcharges and fees, while the BOE  
                 would be allowed to retain an additional 2% to cover its  
                 administrative costs.  The PUC notes:

                    If, under the new system, the surcharges for prepaid  
                    consumers are set at the same level as those set for  
                    postpaid consumers, the [PUC] will ultimately receive  
                    from prepaid consumers only 95% of the revenues  
                    necessary to fund existing universal services  
                    [programs].  To reach 100% of the required revenue,  
                    the [PUC] would need to set surcharges for prepaid  
                    consumers higher than those for postpaid consumers,  
                    which is fundamentally unfair.  By adding 5% in  
                    additional administrative expenses on top of the  
                    required program revenues, prepaid consumers will be  
                    burdened with paying for the additional and  
                    unnecessary administrative expenses associated with  
                    the bill.  

                 Further complicating the equities involved, the PUC  
                 points out that prepaid consumers are more likely than  
                 postpaid consumers to be low-income and from minority  
                 communities.

                 The wireless industry rejects the assertion that  
                 collection allowances for retailers and the BOE will  
                 result in a disparity between prepaid and postpaid  
                 customers.  The wireless industry instead argues that the  
                 current system is responsible for creating a disparity  
                 between prepaid and postpaid consumers.  Specifically,  
                 the industry notes, "Currently, no fees or surcharges are  
                 collected from prepaid wireless customers, while postpaid  
                 customers have the fees and surcharges collected on their  
                 monthly bills."  

                 In response to the PUC's assertion that AB 300's  
                 collection method would be unfair to low-income and  
                 minority consumers, the wireless industry notes that  








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                 prepaid services comprise the fastest growing segment of  
                 the market and that the demographics today are "far more  
                 mainstream than in the early days of the service."    

                iv)    The PUC asserts that AB 300 could interfere with  
                 current and future enforcement cases against carriers  :   
                 In 2009, the PUC initiated an enforcement proceeding  
                 against TracFone to address its alleged failure to  
                 collect and remit state surcharges and fees.  In  
                 D.12-02-032, the PUC determined that TracFone was, in  
                 fact, required to collect and remit universal service  
                 program surcharges and rejected TracFone's defense that  
                 collection was impossible.  The PUC notes that, while a  
                 subsequent lawsuit to overturn this decision was rejected  
                 by the courts, Phase II of the proceeding continues, and  
                 staff is currently seeking millions of dollars in unpaid  
                 surcharges and fees, along with interest and penalties.   
                 The PUC notes:

                    The strong implication (but not explicit statement) of  
                    this bill is that collection and remittance of  
                    surcharges is impossible at present, and would thus  
                    set up a possible defense for TracFone on appeal.  The  
                    bill could also vitiate or remove the [PUC's]  
                    authority to pursue such enforcement actions against  
                    other carriers in the future.

                 The wireless industry counters that nothing in AB 300  
                 will have any retroactive application that interferes  
                 with the PUC's investigation of past collections.   
                 Instead, the industry asserts that AB 300 simply  
                 establishes a prospective method for collecting fees and  
                 surcharges from prepaid customers.   
                  
              d)   Amendments suggested by Committee staff  :  The Committee  
               may wish to consider the following two amendments to this  
               bill:

                i)     On inferences and urgencies  :  This bill would go  
                 into immediate effect as an urgency statute "necessary  
                 for the immediate preservation of the public peace,  
                 health, or safety . . . ."  The bill states that this  
                 immediacy is needed to provide a standardized collection  
                 mechanism as soon as possible by which state and local  
                 charges can be collected from consumers of prepaid MTS.   








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                 As noted above, the PUC has raised concerns that this  
                 urgency clause might impact its ongoing litigation with  
                 TracFone by implicitly suggesting that, prior to this  
                 legislation, it was impossible for prepaid MTS providers  
                 to remit applicable fees and surcharges.  To address this  
                 specific issue, Committee staff suggests amending this  
                 bill to include a standard "no inference" clause.   
                 Specifically, this clause would provide that no inference  
                 shall be drawn from this legislation's passage with  
                 respect to the remittance obligations of prepaid MTS  
                 providers under the law as it read prior to this bill's  
                 enactment.  

                ii)    On operative dates  :  This bill's urgency clause  
                 raises a second and related issue.  If this bill were  
                 signed into law on October 1, 2013, its provisions would  
                 go into immediate effect.  Nevertheless, the prepaid MTS  
                 surcharge would only begin being imposed on January 1,  
                 2015.  Thus, it is not entirely clear what law would  
                 govern prepaid MTS sales during this 13-month transition  
                 period.  Would providers of prepaid MTS have to continue  
                 complying with prior law until the imposition of the new  
                 MTS surcharge on January 1, 2015?  If not, would fees and  
                 surcharge simply not apply to MTS services during this  
                 period?  Clearly, this later interpretation could have a  
                 significant and negative impact on fee and surcharge  
                 collections.  Thus, Committee staff suggests language  
                 requiring MTS providers to continue, until January 1,  
                 2015, complying with the law as it read prior to this  
                 bill's enactment.

              e)   Issues raised by the BOE  :  The BOE has raised a number  
               of policy and administrative concerns with this bill.  For  
               a comprehensive discussion of these concerns, please refer  
               to the BOE's staff analysis, which notes, among other  
               things:
              
                 While the state component language is challenging, the  
                 local component in its current form is impossible to  
                 administer  :  "BOE staff has several concerns regarding  
                 the bill, which are too numerous to list.  However, staff  
                 understands that the current version of the bill is a  
                 work-in-progress.  The BOE staff continues to participate  
                 in stakeholder meetings, provide technical assistance,  
                 meet with interested parties, and provide appropriate  








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                                                                  Page  15

                 amendments."  

                 "In part, BOE staff proposes to align the MTS state  
                 surcharge with the BOE-administered sales and use tax  
                 program to make the retailer's surcharge collection and  
                 reporting as convenient as possible, and reduce  
                 BOE-administrative costs."  

                 "This measure also enacts the Local Act, which is most  
                 problematic for the BOE.  Currently, certain cities and  
                 counties impose a utility user tax or 911 access charge  
                 on MTS pursuant to voter approved ordinances.  The Local  
                 Act suspends the rates specified in these ordinances with  
                 the intent to limit the number of rates imposed.   
                 However, the Local Act does not suspend the ordinances'  
                 imposition of taxes and charges on MTS, which can vary  
                 among each locality.  Accordingly, the local MTS  
                 surcharge would not be uniform, thus making  
                 administration of the Local Act problematic, if not  
                 impossible."

              f)   Amendments proposed by the author  :  The author has also  
               proposed an extensive set of amendments to be taken in this  
               Committee.  Among other things, these amendments:

               i)     Authorize a seller that has collected any amount of  
                 prepaid MTS surcharge and local charges in excess of the  
                 amount due to refund that amount to the prepaid consumer,  
                 even though the surcharge amount has already been paid  
                 over to the BOE and no corresponding credit or refund has  
                 yet been secured.  

               ii)    Provide that any local charge collected from a  
                 prepaid consumer that has not been remitted to the BOE  
                 shall be a debt owed jointly to the state and to the  
                 local jurisdiction imposing the local charge by the  
                 person required to collect and remit the local charge.

               iii)   Require any local agency that has enacted a local  
                 charge applicable to prepaid MTS, or that, in the future  
                 enacts a new or increased local charge, to provide the  
                 BOE with written notice of the amount of the local 911  
                 charge or the applicable tiered rate for the UUT, on or  
                 before December 1, commencing December 1, 2014, and for  
                 each year thereafter.








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                                                                  Page  16


               iv)    Allow any local agency to request the BOE to correct  
                 an error in the geocoding of a seller with a physical  
                 location within that local agency by submitting a written  
                 declaration of the correction, which is also signed by  
                 the local agency that is improperly receiving the local  
                 charge due to the error.

               v)     Establish the Local Charge for Prepaid MTS Fund in  
                 the State Treasury.  Further establish the UUT Account  
                 and the Local 911 Charges Account within that fund.

               vi)    Establish a detailed schedule of tiered UUT rates  
                 that shall apply in lieu of the rate specified by local  
                 ordinance.  Specifically, the schedule sets forth 9  
                 different rates, ranging between 0% and 9%.

               vii)   Provide that all local charges collected by the BOE  
                 shall be deposited in the Local Charges for Prepaid MTS  
                 Fund, and shall be held in trust for the local taxing  
                 jurisdiction.  Further provide that local charges shall  
                 consist of all taxes, charges, interest, penalties, and  
                 other amounts collected and paid to the BOE, less a  
                 deduction in an amount not to exceed 2% of the collected  
                 amounts to reimburse the BOE for administrative expenses.

               viii)  Authorize the BOE to contract with a third-party to,  
                 among other things:

                  (1)       Allocate collected local charges to the  
                    appropriate local jurisdiction;

                  (2)       Verify the applicability of a local ordinance  
                    to prepaid MTS and the applicable tiered rate;

                  (3)       Audit proper collection and remittance of the  
                    local charge, including correct geocoding of sellers;

                  (4)       Handle claims for refund, including exemption  
                    claims under the local ordinance; and, 

                  (5)       Respond to requests from sellers, customers,  
                    boards, and others regarding local charges.

               ix)    Provide that any city, county, or city and county  








                                                                  AB 300
                                                                  Page  17

                 that has adopted an ordinance to impose a charge  
                 applicable to prepaid MTS shall be solely responsible  
                 for:

                  (1)       Defending any claim regarding the validity of  
                    the ordinance in its application to prepaid MTS;

                  (2)       Interpreting any provision of the ordinance,  
                    except to the extent specifically superseded by this  
                    statute; and, 

                  (3)       Responding to refund claims, including claims  
                    of exemption under the ordinance.  
                   
              g)   Suggested technical amendments  :  Committee staff also  
               suggests the following technical amendments to this bill:  

               i)     On page 5, in line 26, insert "Services" after  
                 "Telephony";

               ii)    On page 5, in line 37, insert "Services" after  
                 "Telephony";

               iii)   On page 6, in line 6, strike "requires" and insert  
                 "require";

               iv)    On page 6, in line 34, insert "Services" after  
                 "Telephony";

               v)     On page 7, in line 27, insert "Services" after  
                 "Telephony";          

               vi)    On page 12, in line 24, strike "Prepaidmobile" and  
                 insert "Prepaid mobile";

               vii)   On page 15, in line 8, strike "the state" and insert  
                 "this state"; and

               viii)  On page 18, in line 34, strike "tax" and insert  
                 "charges". 

              h)   Double-referral :  This bill was double-referred to the  
               Assembly Committee on Utilities and Commerce, and passed  
               out of that Committee on a 14-0 vote on April 8, 2013.  For  
               additional discussion of this bill's provisions, please  








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                                                                  Page  18

               refer to that Committee's analysis.   

              i)   Related legislation  :  Committee staff notes the  
               following related bills:

               i)     AB 2545 (De La Torre), of the 2009-10 legislative  
                 session, would have required the PUC to conduct a public  
                 process to develop recommendations for an equitable and  
                 uniform method to collect state and local fees and  
                 surcharges from consumers of prepaid MTS.  AB 2545 died  
                 on the Senate inactive file.  

               ii)    AB 1050 (Ma), of the 2011-12 legislative session,  
                 would have imposed an MTS surcharge similar to this bill.  
                  AB 1050 died in the Senate Committee on Governance and  
                 Finance.          

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Boost
          California Communications Association
          Sprint
          T-Mobile
          TracFone Wireless, Inc. 
          Virgin Mobile

           Opposition 
           
          California Grocers Association
          California Public Utilities Commission
          Consumer Federation of California
          Greenlining Institute
          TURN
           
          Analysis Prepared by  :  M. David Ruff / REV. & TAX. / (916)  
          319-2098