BILL ANALYSIS                                                                                                                                                                                                    Ķ



                                                                SB 497
                                                                       

                      SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                              Senator Jerry Hill, Chair
                              2013-2014 Regular Session
                                           
           BILL NO:    SB 497
           AUTHOR:     Walters
           AMENDED:    April 15, 2013
           FISCAL:     Yes               HEARING DATE:   May 1, 2013
           URGENCY:    No                CONSULTANT:      Rebecca  
           Newhouse
            
           SUBJECT  :    CALIFORNIA GLOBAL WARMING SOLUTIONS ACT

            SUMMARY  :    
           
            Existing law  , under the California Global Warming Solutions  
           Act of 2006 (CGWSA): 

           1) Requires the California Air Resources Board (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 achieved by 2020, and to  
              adopt GHG emission reduction measures by regulation, and  
              sets certain requirements in adopting the regulations.  ARB  
              may include the use of market-based mechanisms to comply  
              with these regulations. (Health and Safety Code §38500 et  
              seq.).

           2) Requires ARB to prepare and approve a scoping plan by  
              January 1, 2009, for achieving the maximum technologically  
              feasible and cost-effective reductions in GHG emissions  
              from sources or categories of sources of GHGs by 2020.  ARB  
              must evaluate the total potential costs and total potential  
              economic and noneconomic benefits of the plan for reducing  
              GHGs to the state's economy and public health, using the  
              best economic models, emission estimation techniques, and  
              other scientific methods.  The plan must be updated at  
              least once every five years. (§38561).

           3) Authorizes ARB to adopt a schedule of fees to be paid by  
              GHG emission sources regulated under CGWSA, to be deposited  
              into the Air Pollution Control Fund and available upon  
              appropriation by the Legislature for carrying out the  









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              CGWSA. (§38597).

           4) Establishes the Cost of Implementation Account (account)  
              within the Air Pollution Control Fund (fund), and requires  
              that revenue collected pursuant to #3 above be deposited in  
              the account and be maintained separately from all other  
              funds in the fund (Government Code §16428.95).  

           5) Creates the University of California as a public trust, to  
              be administered by the UC Regents, with full powers of  
              organization and government (California Constitution,  
              Article IX).

            This bill  :  

           1) Requires the ARB to freely allocate GHG allowances to the  
              California State University (CSU), the University of  
              California (UC), and private colleges and universities, for  
              any market-based compliance mechanism adopted by the ARB. 

           2) Prohibits the ARB from assessing a fee on CSU, UC and  
              private colleges and universities, for purposes of any  
              program or regulation adopted pursuant to the GWSA.

            COMMENTS  :

            1) Purpose of Bill  .  According to the author, "The bill seeks  
              to provide necessary relief to [UCs] and [CSUs].  Five UC  
              campuses and one medical center are currently subject to AB  
              32 reporting requirements: UCLA, UC San Diego, UC Irvine,  
              UC San Francisco, UC Santa Cruz and UC Davis. In the CSU  
              system, three campuses are expected to be impacted: San  
              Diego, San Jose and Channel Islands.  These campuses are  
              not on target to meet the requirements outlined in AB 32.   
              Instead, they must increase compliance actions which are  
              costly and will reduce the level of resources available for  
              more direct educational activities.  The cost of compliance  
              will ultimately place an undue burden on California's  
              public postsecondary education.  Student tuitions are  
              already high and college costs continue to rise."

            2) Brief background on cap-and-trade  .  Pursuant to authority  
              under AB 32 (Nuņez) Statutes of 2006, Chapter 488, the ARB  









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              adopted cap-and-trade regulations and those regulations  
              were approved on December 13, 2011. Beginning on January 1,  
              2013, the cap-and-trade regulation sets a firm, declining  
              cap on total GHG emissions from sources that make up  
              approximately 85% of all statewide GHG emissions.  Sources  
              included under the cap are termed "covered" entities.  The  
              cap is enforced by requiring each covered entity to  
              surrender one "compliance instrument" for every metric ton  
              of carbon dioxide equivalent (MTCO2e) that it emits at the  
              end of a compliance period.  Over time, the cap declines,  
              resulting in GHG emission reductions. Compliance  
              instruments include allowances and offsets, where  
              allowances are generated by the state in an amount equal to  
              the cap, and offsets result from emission reductions  
              achieved in an uncapped sector, generated pursuant to an  
              approved protocol adopted by ARB.  Offsets may be used to  
              satisfy up to 8% of a covered entities compliance  
              obligation.  

               Initially, 90% of all allowances will be allocated freely  
              to covered entities.  A small percentage of the remaining  
              allowances are set aside for an allowance price-containment  
              reserve, and the rest are sold at quarterly auctions.  
              Initially most allowances will be freely distributed to  
              entities, however that fraction will decline over time and  
              entities must either reduce emissions or purchase a greater  
              number of allowances at auction.  The program authorizes  
              entities to buy or sell their allowances, creating a market  
              that is intended by ARB to minimize the cost of compliance  
              and encourage entities to invest in GHG emissions  
              reductions.  
            
              For the first two years, the program will cover electricity  
              generation, and large industrial sources and processes with  
              annual GHG emissions at or above 25,000 MTCO2e.  The  
              program will expand in 2015 to include fuel distributors to  
              address emissions from combustion of transportation fuels  
              and combustion of natural gas and propane at sources not  
              covered in the first phase of the program. 

               Allowance allocation and leakage  .  The ARB allocates free  
              allowances for the industrial sector based primarily on a  
              covered entity's risk of "leakage." Leakage refers to the  









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              shift of production outside California as a result of  
              facilities either leaving the state to operate (and  
              therefore generating GHG emissions elsewhere), or to  
              emission increases caused by out-of-state facilities  
              increasing production to meet new demand caused by  
              decreased production in state.  Industries at higher risk  
              for leakage (determined by the emissions intensity of an  
              entity's production process and their ability to pass costs  
              on to consumers) are allocated a larger percentage of their  
              allowances for free over the life of the program than  
              industries at low or negligible risk of leakage.  ARB also  
              includes, in their methodology for allowance allocation for  
              leakage-exposed covered industrial entities, emissions  
              efficiency benchmarks to account for previous investments  
              in energy efficiency and carbon reductions by those  
              entities. 

              Electrical distribution utilities receive 100% of their  
              allowances to meet their compliance obligation for free to  
              ensure that electricity ratepayers do not experience sudden  
              increases in their electricity bills due to cap-and-trade. 

            3) Covered universities  .  Ten universities in California (and  
              a UC medical center) are subject to the cap-and-trade  
              program, including five campuses of the University of  
              California (UC Los Angeles, UC San Diego, UC Irvine, UC San  
              Francisco, and UC Davis), three campuses of the California  
              State University system (San Diego State, San Jose State  
              and Channel Islands), California Institute of Technology,  
              and Loma Linda University. Under ARB's methodology for  
              determining allowance allocation, the universities are not  
              eligible for free allowances primarily because they are not  
              leakage-exposed entities.  To comply with current  
              cap-and-trade regulations, the universities must surrender  
              compliance instruments for all emissions in excess of  
              25,000 MTCO2e.  Based on 2011 emission data, ARB can  
              estimate a 2013 annual compliance cost for all CSUs and UCs  
              at approximately $8 million, using the allowance price of  
              $10.71.

              These campuses fall within the cap-and-trade program, in  
              part, because they operate on-site electrical generating  
              facilities.  Most of these electrical generating facilities  









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              are combined heat and power facilities (CHP), also known as  
              cogeneration (or cogen).

               Cost of implementation fee  .  AB 32 authorizes the ARB to  
              adopt a schedule of fees to be paid by sources of GHG  
              emissions to support the administration costs of  
              implementing AB 32.  These fees are based on the total  
              required revenue (implementation expenses plus loan  
              repayment) divided by the total statewide emissions covered  
              by the regulation. The AB 32 Cost of Implementation Fee  
              regulation does not require colleges or universities to pay  
              this fee.

            4) Combined Heat and Power  .  CHP is the production of  
              electricity and heat from a single fuel source.  Considered  
              highly efficient, CHP captures heat lost during the  
              production of electricity and converts it into useful  
              thermal energy, usually in the form of steam or hot water.   
              CHP systems are significantly more efficient than the  
              traditional power plant efficiency of approximately.  
              Increasing the use of CHP is identified as an energy  
              efficiency measure in the 2008 Scoping Plan to meet  
              California's 2020 GHG emission reduction goal. 

            5) ARB resolution  .  On September 20, 2012, the ARB issued a  
              resolution that recognizes that California universities  
              have taken early action by investing in GHG emission  
              reduction measures and further states that the  
              cap-and-trade program should award existing, and  
              incentivize new, efficient distributed electricity  
              generation technologies such as CHP.  The resolution  
              directs the executive officer to develop a methodology to  
              allocate allowances to California's universities that  
              recognizes early actions to reduce greenhouse gas  
              emissions, energy efficiency and combined heat and power  
              (CHP).  The resolution also directs the executive officer  
              to work with the California Public Utilities Commission and  
              the California Energy Commission to develop a methodology  
              that exempts the steam and waste heat emissions for all  
              facilities that are only covered under the cap-and-trade  
              program because of their investment in CHP.  The ARB has  
              noticed a public workshop on May 1, 2013, to present and  
              discuss the proposed methodologies. 









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            6) Prop 39  .  Proposition 39 passed on November 6, 2012, and  
              requires multistate businesses to pay income taxes based on  
              the percentage of their sales in California.  The measure  
              is expected to generate increased state revenues of $1  
              billion annually, with half of the revenues over the next  
              several years spent on energy efficiency projects.   
              Specifically, Prop 39 creates the Clean Energy Job Creation  
              Fund and provides that $550 million be transferred to the  
              Fund for five fiscal years, beginning in 2013, and be  
              available for, among other things, appropriation for the  
              purpose of funding energy efficiency retrofits, clean  
              energy installations, and other energy system improvements  
              to reduce costs and achieve energy and environmental  
              benefits for universities and colleges. The Governor's  
              2013-14 budget proposal allocates Prop 39 revenue to school  
              districts and community colleges.

            7) Is this bill premature  ?  ARB is currently working on a  
              methodology to fully exempt entities that fall under the  
              cap solely due to CHP usage, and to provide allowances for  
              California universities based on early action GHG  
              reductions, energy efficiency measures and use of CHP.   
              This proposal will likely reduce the compliance costs of  
              covered universities substantially.  Providing full  
              exemptions from the regulation invites other entities to  
              seek legislative exemptions, and should only be done when  
              solutions to legitimate policy concerns cannot or are not  
              being accomplished through regulation.  The bill should be  
              held pending the review of ARB's proposal, so that the  
              Committee may evaluate whether the proposed regulatory  
              amendments appropriately address the concern of rising  
              tuition costs as a result of the cap-and-trade regulation.  

           SOURCE  :        Senator Walters  

           SUPPORT  :       University of California 

           OPPOSITION  :    None on file  

            











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