BILL ANALYSIS Ó SB 11 SENATE COMMITTEE ON ENVIRONMENTAL QUALITY Senator Jerry Hill, Chair 2013-2014 Regular Session BILL NO: SB 11 AUTHOR: Pavley AMENDED: As Introduced FISCAL: Yes HEARING DATE: April 3, 2013 URGENCY: Yes CONSULTANT: Rebecca Newhouse SUBJECT : ALTERNATIVE FUELS SUMMARY : Existing law : 1) Authorizes local air district boards to adopt a $2 surcharge on vehicle registration, subject to certain requirements, to be used to implement emission reduction programs from vehicular sources or off-road engines, including for projects eligible under the Carl Moyer Program, and other specified projects until January 1, 2015 (Health and Safety Code §§41081 & 44225). 2) Under the California Alternative and Renewable Fuel, Vehicle Technology, Clean Air, and Carbon Reduction Act of 2007 (HSC §43865 et seq.), requires the State Energy Resources Conservation and Development Commission (CEC) to implement the Alternative and Renewable Fuels and Vehicle Technology Program (ARFVTP) to provide funding measures to specified entities to develop and deploy technologies and alternative and renewable fuels in the marketplace, without adopting any one preferred fuel or technology, to help attain the state's climate change policies. The CEC is required to develop an investment plan for the program in consultation with an advisory committee, pursuant to specified requirements. An evaluation of the efforts funded by the ARFVTP that includes research, development, and deployment efforts funded by this program is required every two years, beginning in 2011. 3) Creates the Air Quality Improvement Program (AQIP), to be administered by the California Air Resources Board (ARB) in consultation with local air districts, to fund air quality SB 11 Page 2 improvement projects (HSC §44274). 4) Creates the Enhanced Fleet Modernization Subaccount to implement an Enhanced Fleet Modernization program (EFMP) developed by ARB, in consultation with the Bureau of Automotive Repair, to commence on January 1, 2010, that allows for the voluntary retirement of high polluting passenger vehicles and light-duty and medium-duty trucks (HSC §44125). 5) Requires that ARB, no later than July 1, 2008, develop regulations to apply following a year after a 12-month period where the hydrogen fuel dispensed in California for transportation purposes exceeds 3,500 metric tons. The regulations are required to ensure the following (HSC §43868 et seq.): a) That the hydrogen produced or dispensed in state be made from at least 33% renewable resources, as defined, on a statewide basis; b) That "well-to-wheels" greenhouse gas (GHG) emissions for an average hydrogen powered car in state are at least 30% less than an average new gasoline-powered vehicle's GHG emissions; c) That "well-to-tank" emissions of nitrogen oxides (NOx) and reactive organic gases are at least 50% lower for all hydrogen fuel dispensed in state than for the average motor gasoline sold in state on an energy equivalent basis. d) That "well-to-tank" emissions of relevant toxic air contaminants from hydrogen fuel produced or dispensed in California be reduced to the maximum extent feasible at each site when compared to well-to-tank emissions of toxic air contaminants of the average motor gasoline fuel on an energy equivalent basis. 6) Under the California Global Warming Solutions Act of 2006, requires the ARB to determine the 1990 statewide greenhouse gas (GHG) emissions level and approve a statewide GHG emissions limit that is equivalent to that level, to be SB 11 Page 3 achieved by 2020, and sets various requirements to meet this requirement (HSC §38500 et seq.). 7) Under the Alternative Fuels Law (HSC §38500 et seq.), requires the CEC, in partnership with the ARB, and in consultation with specified state agencies, to develop and adopt a state plan to increase the use of alternative fuels on or before June 30, 2007. 8) Requires the CEC to adopt and transmit an Integrated Energy Policy Report (IEPR) every two years on trends and issues (Public Resources Code §25300). 9) Establishes the Carl Moyer Program, administered by ARB, to fund the incremental cost of cleaner-than-required vehicles, engines, and equipment and authorizes the funding of projects reducing NOx, particulate matter (PM) and reactive organic gasses emissions under the Carl Moyer Program until January 1, 2015, after which date, only the reduction of NOx emission reduction projects will be eligible for funding (HSC §44275). 10)Establishes certain vehicle and vessel related surcharges and fees, until January 1, 2016, including an $8 fee increase in smog abatement, a $3 fee increase in the annual vehicle registration fee, a $5 fee increase for special identification plates, and a $10-20 fee increase for vessel registration, to fund the AQIP and the ARFVT and EFM programs (HSC §44060.5 and Vehicle Code §§9250.1, 9261.1, & 9853.6). 11)Establishes the California Tire Recycling Fee, which imposes a $1.75 surcharge on new tires, where $1 is directed to the Department of Resources Recycling and Recovery (DRRR), and $0.75 is directed to the Air Pollution Control Fund to be allocated by the ARB to local air districts for programs and projects that mitigate mobile source air pollution, until January 1, 2015, at which point the tire fee is reduced to $0.75 and retained by DRRR (PRC §42885). This bill : 1) Extends the authorization for local air district boards to adopt a two-dollar surcharge on vehicle registration, to be SB 11 Page 4 used to implement emission reduction programs from vehicular sources or off-road engines, until January 1, 2024. 2) Defines "publicly owned hydrogen fueling station" to mean equipment used to store and dispense hydrogen fuel to vehicles according to industry codes and standards that is open to the public. 3) Prohibits the ARB from enforcing any element of its existing clean fuels outlet regulation or of any regulation that requires that any person construct, operate or provide funding for the construction or operation of any publicly available hydrogen fueling station until January 1, 2024. 4) Requires the ARB to make the number of vehicles that automobile manufacturers project to be sold or leased available to the public. 5) Requires the CEC to allocate $20 million each fiscal year from July 1, 2013 through June 30, 2016, and up to $20 million for each fiscal year thereafter not to exceed 20% of the funds from the ARFVT Fund, until January 1, 2024, for purposes of achieving a hydrogen fueling network sufficient to provide convenient fueling to vehicles owners, and expand that network as necessary to support a growing market for fuel-cell vehicles, until there are at least 100 publically available hydrogen fuel stations. 6) Authorizes the CEC to defer allocation of the money described above for purposes of matching fuel station number to vehicle fueling needs. 7) Authorizes the CEC, in consultation with the ARB, to discontinue funding for hydrogen fueling stations if they establish that the private sector is establishing public hydrogen fueling stations without need for government support. 8) Requires the CEC and ARB, on or before December 31, 2015, and annually thereafter, to jointly review and report on progress toward establishing a hydrogen fueling network that provides coverage and capacity to fuel cell vehicles in the state. The CEC and ARB are required, at a minimum, to SB 11 Page 5 consider the following: a) The available plans of automobile manufacturers to deploy fuel cell vehicles in California and their progress toward achieving those plans; b) The rate of hydrogen fuel cell deployment; c) The length of time required to permit and construct hydrogen fueling stations; d) The coverage and capacity of the existing hydrogen fueling station network; and e) The amount and timing of growth in the fueling network to ensure fuel is available to these vehicles. 9) Authorizes the CEC to design grants, loan incentive programs and other forms of financial assistance to assist in deployment of hydrogen fueling infrastructure as rapidly as possible. 10)Specifies that the funds appropriated for hydrogen infrastructure shall be available for encumbrance by the commission for up to four years from the date of appropriation and available for liquidation up to four years after the encumbrance expiration. 11)Requires the ARB, in consultation with air districts, to convene working groups to evaluate the policies and goals of the Carl Moyer Program, no later than July 1, 2013. 12)Directs ARB and CEC to update the economic analysis used to develop and review ARB's regulations to include a range of petroleum and alternative fuel prices to more accurately assess the future costs of petroleum-based and alternative fuels by November 1, 2014. 13)Beginning November 1, 2015, and every two years thereafter, SB 11 Page 6 requires CEC, in consultation with ARB and as a part of its IEPR, to provide a status of the state's alternative transportation fuel use, including: a) An evaluation of how new and existing investment programs could help to increase the state's alternative fuels use; and, b) An evaluation of how federal fuel policies and existing state policies will help increase the use of alternative fuels in the state. 14)Requires ARB, when developing new and amended regulations, to include a finding on the effect of the proposed regulations on the state's alternative transportation fuels use. 15)Provides that this bill does not preempt AB 32 and that the bill be implemented consistent with environmental, public health, and sustainability considerations articulated in AB 32, clean fuels and vehicle funding statutes. 16)Requires ARB and CEC, when studying the state's alternative transportation fuel use, to measure: a) In-state job creation through the continued development of an alternative fuels industry in the state; b) Economic vulnerability of residents to future petroleum fuel price spikes by the use of either petroleum fuels or alternative fuels and vehicles; c) Alternative fuel market penetration in nonattainment areas; and, d) Increase access to the supply of alternative fuels and alternative fuel vehicles for all residents, including barriers to supply. SB 11 Page 7 17) Extends the authorization to fund projects reducing NOx, PM and reactive organic gasses under the Carl Moyer Program, until January 1, 2024. 18) Extends the sunset date of various vehicle and vessel-related fees, including an $8 fee increase in smog abatement, a $3 fee increase in the annual vehicle registration fee, a $5 fee increase for special identification plates, and a $10 fee increase for vessel registration, to fund the ARFVT, AQIP and EFM programs, until January 1, 2024. 19) Extends the sunset date of the $0.75 fee increase on tire sales to fund the Carl Moyer Program, until January 1, 2024. COMMENTS : 1) Purpose of Bill . The author notes that in order to address major health and environmental risks, stringent air quality and climate requirements, and chronic under-investments in clean transportation solutions, SB 11 provides incentives that address two overarching challenges, including the legacy mobile source fleet and the acceleration of next-generation technologies. According to the author, the former will reduce near-term particulate pollution and NOx by accelerating the turnover of older, dirtier vehicles and off-road engines; provide assistance for on- and off-road users to upgrade equipment prior to regulatory requirements and help prevent the loss of federal highway funds by accelerating progress toward meeting state and federal air quality health standards. The author states that accelerating next-generation technologies will reduce the cost of clean, next-generation cars and trucks through research and development as well as direct purchase incentives; help meet AB 32, zero-emission vehicle mandates, and clean air goals; ensure widespread availability of alternative fuels by providing infrastructure for hydrogen, electricity, natural gas, biofuels, and other clean fuels which move us towards clean air and energy independence; SB 11 Page 8 facilitate roll-out of zero-emission hydrogen fuel cell electric vehicles which are crucial to achieving California's long-term air quality and climate goals and expand California's manufacturing capacity for advanced technology vehicles, fuels, and components, providing in-state jobs. 2) Background . AB 118 : AB 118 (Núñez), Chapter 750, Statutes of 2007, created the ARFVT program, AQIP and the EFMP. AB 118 provides, upon appropriation by the Legislature, approximately $180 million annually until 2016 for these programs. These funds primarily come from additional fees on vehicle registrations and vessel registrations. The extension of the vehicle registration fees, trailer fees, tire fees, and boat registration fees in this bill will result in approximately $180 million per year for an additional eight years for the AB 118 programs. Carl Moyer Program/AB 923 : AB 1571 (Villaraigosa), Chapter 923, Statutes of 1999, established the Carl Moyer Memorial Air Quality Standards Attainment Program through which ARB provides grants to offset the incremental costs of purchasing or retrofitting engines in order to reduce specified air emissions. The Carl Moyer Program originally received General Fund appropriations. AB 923 (Firebaugh), Chapter 707, Statutes of 2004, expanded the Carl Moyer Program to cover additional pollutants and engines, imposed a 75-cent fee on tire sales to fund the Carl Moyer Program, and authorized local air districts to levy a surcharge on vehicle registrations to fund certain emission reduction programs, including eligible projects under the Carl Moyer Program. The fee for the Carl Moyer Program and the authorization for the surcharge are set to expire on January 1, 2015. Clean Fuels Outlet . ARB adopted its Clean Fuels Outlet (CFO) Regulation to provide fueling stations for fuel to meet the needs of those driving clean, alternative fuel vehicles. When it first began work on the regulation in 1990, ARB planned to use it as a tool to provide methanol, ethanol, and compressed natural gas fueling stations once a certain number of vehicles using those fuels were certified in California. Those vehicles were not forthcoming, and ARB last updated the SB 11 Page 9 regulation in 2000. In January 2012, ARB considered and passed amendments to the regulation to require major refiners and importers of gasoline to provide alternative fuel fueling stations when the number of vehicles using a particular alternative fuel reaches 10,000 within an air basin or 20,000 statewide with specified adjustments. Refiners and importers of gasoline would provide these alternative fueling stations in proportion to their market share but would not provide fueling stations for electric vehicles. This update to the CFO Regulation arose as part of ARB's work to meet California's air quality and greenhouse gas emission reduction goals but has not been finalized by the Office of Administrative Law as required by state law. ZEVs . ARB's zero emission vehicle (ZEV) regulation requires that by 2025 about 15% of new car sales will be zero emission and requires automakers to produce and sell ZEVs, which include plug-in electric vehicles (PEVs) and fuel cell vehicles (FCVs), in order to achieve this mandate. Automakers may also produce and sell vehicles that are partially zero emission or help transition to ZEVs in order to meet the mandate. This will ensure that there will be 1.5 million ZEVs on the road by 2025 as directed under Governor Brown's Executive Order B-16-2012. Hydrogen Highway . In 2004, Governor Schwarzenegger signed an executive order calling for the development of the California Hydrogen Highway Blueprint Plan (plan) that would expedite availability of hydrogen fueling stations. The plan outlined a path for 100 hydrogen-fueling stations and 2,000 hydrogen-fueled vehicles by 2010, to be followed by two more phases with increased deployment of FCVs and hydrogen fuel stations. As recommended by the plan, the 2005-06 Budget allocated $6.5 million for state-sponsored hydrogen demonstration projects and over $12 million was allocated in two subsequent budgets for the continued development of hydrogen stations. The CEC has awarded $18.2 million to date, and has $28.6 currently allocated for hydrogen infrastructure, and has $20 million proposed for the 2013-2014 draft ARFVTP investment plan. According to the California Fuel Cell Partnership (CaFCP), there are currently SB 11 Page 10 36 hydrogen-fueling stations, of which, eight are public, 15 are private or demonstration, and 13 are in development. In total, 25 stations received state funding, 14 of which are currently open. The CaFCP has published a document, the California Road Map, which describes the need for 68 hydrogen stations in state by 2016 to serve the thousands of FCV drivers expected in the early years of commercialization. Environmental impacts of hydrogen . An FCV is powered by the reaction of hydrogen and oxygen in a fuel cell to produce electricity and water vapor as the only tail pipe emission. The initial production of hydrogen may be associated with a range of GHG emissions depending on the production pathway. Electrolysis, where electricity is used to split water into oxygen and hydrogen, can produce hydrogen without GHG emissions if renewable electricity is used. Only a small fraction of hydrogen is produced in this manner, however, due to the high costs associated with electrolyzers and renewable energy. Currently, the most cost effective way to produce hydrogen on a large scale is to react natural gas with water to produce CO2 and hydrogen (termed steam reformation). Ninety-five percent of hydrogen is produced via steam reformation, primarily for industrial and refinery purposes. Estimates of "well-to-wheels" (WTW) GHG emissions for hydrogen produced in this manner reduce GHG emissions by half relative to current conventional gasoline vehicles, due in part to the increased efficiency of fuel cells compared to internal combustion engines. Steam reformation with biomethane as a feedstock could further decrease WTW GHG emissions for hydrogen production, although current supplies of biomethane available in the state are limited. New regulations and standards for landfill biomethane, as well as efforts to increase biomethane production in state, pursuant to AB 1900 (Gatto), Chapter 602, Statutes of 2012, may help increase in-state biomethane production. Current law requires the ARB, by July 1, 2008, to develop regulations that would, among other things, require that the hydrogen produced or dispensed in state be made from at least 33% renewable resources when dispensed hydrogen exceeds 3500 metric tons/year (which translates to roughly 10,000 FCVs). ARB has not yet drafted these regulations and last noticed a workshop for regulation development in 2010. SB 11 Page 11 3) Bundling of sunset extensions . SB 11 extends the sunset extensions on several disparate programs. Extension of several fees for several different programs in a single bill makes legislative oversight of each individual program more difficult. 4) Abrogating the CFO . This bill would override the ARB approved amendments to the CFO and prohibit the ARB from adopting a similar regulation for the next 12 years. It is unclear why this action is necessary, since the amendments to the regulation were never finalized and the authority to amend or withdraw them belongs to ARB. In addition to abrogating the CFO regulation, SB 11 prohibits, until 2024, the ARB from requiring "any person construct, operate or provide funding for the construction or operation of publicly available hydrogen fueling stations." Amendments to the CFO regulation, like other regulations, required significant stakeholder input at the agency level. Statutorily overriding regulations is the Legislature's prerogative, but undoing the stakeholder process should only be done when the Legislature believes there is adequate justification. 5) ARFVTP funded infrastructure . For infrastructure funded by the CEC's Alternative and Renewable Fuels and Vehicle Technology program, should a fraction of the cost of re-charging or re-fueling be directed to the state to help pay back the initial public investment? 6) ARFVTP benefits report . The December 2011 benefits report evaluated the first few years of funding from the ARFVT program. The report gave a range for estimated petroleum and diesel fuel displacement in years leading up to 2020 based on ARB's ZEV mandate, as well as surveys and feedback from grant awardees and auto manufacturers. The high and low projections are based on a variety of factors including uncertainties in the market, gas prices, extent of future utilization of funded technologies, consumer willingness to switch to alternative vehicles and infrastructure readiness. The report gives a high value for petroleum gallons displaced from FCVs, estimated to number 124,000 by 2020, of 4% of the total SB 11 Page 12 gallons displaced from alternative fuel and vehicle technologies in 2020 (estimated to be 1.184 billion). In contrast, petroleum displaced due to plug-in electric vehicles (PEVs) represents 21% of the total projected petroleum displaced for the high estimate in 2020. These numbers highlight the fact that FCVs will not result in a significant reduction of GHG emissions in the short run, but instead, will require vehicle market transformation where FCVs represent a large fraction of the vehicle fleet to realize significant GHG reductions. Although not insurmountable, the requirements for market transformation of FCVs, including creating a hydrogen fueling infrastructure network from scratch, distributing hydrogen fuel at competitive costs to dispersed fueling stations and high initial FCV costs in the early stages of a transition, represent significant challenges, especially considering the limited public funds available and the uncertainty surrounding when the hydrogen market will be self-sustaining and no longer require public subsidy. 7) CEC has the authority to allocate money for hydrogen infrastructure . Under the ARFVT program administered by the CEC, projects for hydrogen infrastructure can be and have already been awarded, but the author and proponents contend that the provisions requiring $20 million be awarded for hydrogen infrastructure for 3 years and up to $20 million in eight subsequent years are necessary to send a clear signal to auto manufacturers that there is a commitment to hydrogen infrastructure from the state and thus prompt a timely roll out of FCVs from the manufacturers beginning in 2015. However, this mandated allocation for hydrogen infrastructure funds could make the CEC less flexible in responding to changing market demand for hydrogen as well as other alternative fuel and infrastructure technological advancements, especially if there are significant technological leaps in various fields. 8) ARFVT program requirements and hydrogen allocation . SB 11 would allocate funds to construct a hydrogen infrastructure from ARFVTP funds, but it is not clearly stated in the bill that these awards would necessarily be subject to the statutory and regulatory requirements of the ARFVT program, including, among other things, life-cycle assessments, SB 11 Page 13 ensuring measurability of air emission reduction and benefits, and the establishment of a competitive process for the allocation of funds. The committee may wish to suggest that language that unambiguously subjects funds granted for hydrogen infrastructure to the existing ARFVT program requirements be included. 9) Broad provisions describing infrastructure spending . The CEC scores applications for ARFVT program funds based on a number of criteria, including, among other things, qualifications of the applicant team, market viability of the proposal, and economic benefits of the proposed station, given its location, expected performance, innovation and sustainability. However, the bill does not require the CEC to reference or produce an initial plan for constructing a hydrogen fueling network that minimizes public financial resources while maximizing user accessibility, but simply states that hydrogen fueling stations should provide "convenient fueling" and the network be expanded "as necessary," with at least 100 hydrogen fueling stations, although the CEC may defer funding. SB 11 requires the CEC and the ARB to conduct a thorough review of the progress toward achieving a hydrogen infrastructure network by the end of December 2015, but at this point, $60 million would already be appropriated, with the possibility that much of that allocated funding could already be awarded to recipients. Should there be an outlined strategy for the holistic and integrated placements of hydrogen fueling stations for various early FCV deployment scenarios, before any of the money is awarded to ensure the creation of a publicly subsidized hydrogen fueling network with maximum benefit and usability from the fewest stations and resources necessary? 10)Opposition concerns . The Automobile Club of Southern California objects to fees and taxes imposed on gasoline powered on-road vehicles being used to pay for environmental mitigation stemming from off-road equipment, heavy-duty vehicles and school buses. They also state that usage of fees and taxes appears to violate Article XIX of the California Constitution. The Sierra Club objects to language in SB 11 that abrogates the CFO, which they note was publicly vetted over a year ago. They also state that the CFO abrogation sets SB 11 Page 14 a dangerous precedent that undermines the integrity of the rulemaking process at the ARB. 11)Suggested Amendments : a) The Committee may wish to suggest that the regulation abrogation language be removed so that the CFO regulation can be amended or withdrawn with stakeholder input at the agency level (see Comment #4). b) The Committee may wish to suggest that the provisions prescribing how ARFVTP funds are spent on hydrogen be removed so that the CEC is able to adapt to technological developments and changing markets for alternative fuels, including hydrogen, and allocate limited public funds accordingly (see Comment #7). If the committee does not wish to remove those provisions, then the committee should amend the bill to require the CEC to produce or reference a guiding document for the strategic location of fueling stations that balances maximum user accessibility and cost-effectiveness (comment #9). 12)Technical Amendments . Per Senate Engrossing and Enrolling, the bill needs to be amended to address several technical errors in existing law. 13)Related legislation . SB 1455 (Kehoe) of 2011 included very similar provisions to SB 11. SB 1455 failed passage on the Senate floor on August 31, 2012 (25-10). 14)Double Referral to Senate Transportation and Housing Committee . If this measure is approved by this committee, the do pass motion must include the action to re-refer the bill to the Senate Transportation and Housing Committee. SOURCE : American Lung Association, California CALSTART California Air Pollution Control Officer's Association SUPPORT : Achates Power Aemetis, Inc. Alameda-Contra Costa Transit District SB 11 Page 15 Alliance of Automobile Manufacturers Associated General Contractors Association of Global Automakers Bay Area Air Quality Management District BIODICO Bioenergy Association of California Black Business Association Bosch Rexroth Americas California Air Resources Board California Association of Black Pastors California Association of School Transportation Officials California Association of Winegrape Growers California Biodiesel Alliance California Citrus Mutual California Cotton Ginners & Growers Association California Council for Environmental and Economic Balance California Dairies, Inc. California Electric Transportation Coalition California Energy Commission California Farm Bureau Federation California Grape and Tree Fruit League California Independent Oil Marketers Association California Industry Air Quality Coalition California Manufacturers & Technology Association California Municipal Utilities Association California Natural Gas Vehicle Coalition California Rice Industry Association California Service Station & Automotive Repair Association California Small Business Alliance California Thoracic Society California Transit Association California Trucking Association Carson Black Chamber of Commerce Caterpillar ChargePoint Clean Energy CleanWorld Coalition for Clean Air Coalition of Energy Users CODA Automotive SB 11 Page 16 Construction Industry Air Quality Coalition Contra Costa Council CR&R Incorporated Dow Kokam Eaton Vehicle Group Efficient Drivetrains, Inc. Electric Vehicles International, LLC Environmental Defense Fund Greater Corona Hispanic Chamber of Commerce Greenkraft, Inc. Harvest Power Honda North America, Inc. Hydrogenics Corporation Kern County Taxpayers Association Kings Canyon Unified Transportation Linde Los Angeles Area Chamber of Commerce Los Angeles County Medical Association Mission Motor Company Moreno Valley Black Chamber of Commerce Motiv Power Systems, Inc. Move LA Napa Valley Unified School District Transportation Natural Resources Defense Council Nisei Farmers League Odyne Systems, LLC Otto Construction Pacific Ethanol Physicians for Social Responsibility, Sacramento Chapter Physicians for Social Responsibility, SF-Bay Area Chapter Propel Fuels Proterra Public Health Institute Quallion Quantum Technologies Regional Asthma Management and Prevention Sacramento Black Chamber of Commerce Sacramento Metropolitan Air Quality Management District SB 11 Page 17 San Diego Gas & Electric San Diego Urban Economic Corporation San Francisco County Transportation Authority San Joaquin Valley Unified Air Pollution Control District Sempra Energy utilities Sierra Energy & Sierra Railroad Silicon Valley Leadership Group Slavic American Chamber of Commerce Smith Electric Vehicles South Bay Latino Chamber of Commerce Southern California Gas Company South Coast Air Quality Management District Synergex Technology Partners Tesla Motors The Grant Farm TransPower Total Transportation Services, Inc. United Parcel Service US Hybrid Corporation Vision Industries Corporation Ventura County Air Pollution Control Board Volvo Group North America Waste Management Western Agricultural Processors Association Western States Petroleum Association Yolo-Solano Air Quality Management District, Board of Directors OPPOSITION : Automobile Club of Southern California CRM Company of Rancho Dominguez Sierra Club California