BILL ANALYSIS                                                                                                                                                                                                    Ó




                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  SB 1121                     HEARING:  4/24/14
          AUTHOR:  De Leon                      FISCAL:  Yes
          VERSION:  4/10/14                     TAX LEVY:  No
          CONSULTANT:  Grinnell                 

                           CALIFORNIA GREEN BANK ACT
          

            Enacts the California Green Bank Act, which creates the  
                             California Green Bank.


                           Background and Existing Law  

          When public agencies issue bonds, they essentially borrow  
          money from investors, who provide cash in exchange for the  
          agencies' commitment to repay the principal amount of the  
          bond plus interest in the future.  Bonds are usually either  
          revenue bonds, which repay investors out of revenue  
          generated from the project the agency finances with bond  
          proceeds, like a parking garage, or general-obligation  
          bonds, which the public agency pays out of general revenues  
          and is guaranteed by its full faith and credit.    State  
          law authorizes several authorities within the State  
          Treasurer's Office to issue conduit bonds, whereby a public  
          agency sells a bond, then loans the proceeds to a  
          nongovernmental borrower, such as a hospital or factory.   
          Only the nongovernmental borrower's loan repayments secure  
          the bond.  

          In addition to the above, the state authorizes the  
          California Infrastructure and Economic Development Bank  
          (I-Bank) to support economic development and public and  
          private infrastructure investments through its authority to  
          issue bonds, make loans and, provide credit enhancements.  

          The I-Bank manages several programs, including:
                 The Infrastructure State Revolving Fund Program  
               (ISRF) provides low-cost financing to local agencies  
               for public infrastructure projects.
                 The Industrial Development Bond Program (IDB)  
               provides tax-exempt revenue bond financing for  
               eligible manufacturing and processing companies.
                 The 501(c) (3) Revenue Bond Program offers  




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               tax-exempt revenue bond financing for certain  
               nonprofit, public benefit corporations.
                 The Exempt Facility Bond Program provides  
               tax-exempt financing for projects that are  
               government-owned or consist of private improvements  
               within publicly-owned facilities, such as private  
               airline improvements at publicly owned airports. 
                 The Public Agency Revenue Bond Program provides  
               tax-exempt and taxable bond financing to specified  
               programs for state and local governmental agencies.

          Housed in the office of the State Treasurer, the California  
          Alternative Energy and Advanced Transportation Financing  
          Authority (CAEATFA) provides financing through conduit or  
          revenue bonds, loan guarantees, loan loss reserves and a  
          sales and use tax exemption for facilities that use  
          alternative energy sources and technologies.   While the  
          Legislature created CAEATFA in 1980, it didn't do much  
          until 2008, when Governor Arnold Schwarzenegger and State  
          Treasurer Bill Lockyer announced that CAEATFA would use its  
          existing authority to grant sales and use tax exemption for  
          normally taxable manufacturing equipment purchased by Tesla  
          Motors under a sale-leaseback agreement.  Subsequently, the  
          Legislature directed CAEATFA to administer three new  
          programs, in addition to its conduit bond authority:
                 A $10 million loan loss reserve program that  
               directs the state to reimburse the original mortgage  
               lender for the costs associated with the Property  
               Assessed Clean Energy program assessments during a  
               foreclosure (SB 96, Committee on Budget and Fiscal  
               Review, 2013).
                 A $25 million loan loss reserve program to backstop  
               loans made by participating financial institutions for  
               energy efficiency improvements and distributed  
               generation technology (ABx1 14, Skinner, 2011). 
                 Sales and use tax exemptions for manufacturers of  
               renewable technology (SB 71, Padilla, 2010), and  
               advanced manufacturing (SB 1128, Padilla, 2012).

          Also housed in the office of the State Treasurer, the  
          California Pollution Control Financing Authority deploys  
          federal funds for commercial PACE projects, and a  
          collateral support program for business loans.

                                   Proposed Law
                                         





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          Senate Bill 1121 enacts the Green Bank Act, to provide  
          financial assistance to:
                 Otherwise commercially viable projects, which are  
               not currently able to obtain financing in capital  
               markets at reasonable cost with a reasonable rate of  
               return to a clean energy project developer, and
                 Evaluate and coordinate support for innovative  
               energy technology projects not currently able to  
               obtain financing to achieve commercialization.

          The bill creates two divisions within the California Green  
          Bank:
                 The clean energy division which oversees all clean  
               energy projects, and
                 The innovative energy technology division, which  
               oversees the innovative energy technology project.  

          I.   Financial Instruments.  The Green Bank can issue  
          bonds, including structured, subordinated bonds or other  
          securities, loans, notes (including revenue, grant, and tax  
          anticipation notes), commercial paper, floating rate and  
          variable maturity securities, and any other evidences of  
          indebtedness or ownership, such as asset backed  
          certificates, lease-purchase or installment purchase  
          agreements, or certificates of participation, for clean  
          agriculture projects, clean energy infrastructure projects,  
          clean energy projects, demand response projects, energy  
          efficiency projects, innovative energy technology projects,  
          low-carbon transportation projects, renewable energy  
          projects, and system efficiency projects, as defined.

          Bonds can be in any form, denomination, or interest rate  
          the Bank determines, but cannot have a maturity of more  
          than 50 years.  Bond repayment is solely the responsibility  
          of the bank, and is not backed by the full faith and credit  
          of the state.  Each bond must have on its face a notice to  
          that effect, in addition to the aggregate face amount.  The  
          Bank must issue bonds according to a competitive bidding  
          process that encourages aggressive bidding.

          The Bank must establish a competitive program for loans,  
          loan guarantees, securitization, insurance, portfolio  
          insurance, and other financial assistance, for clean energy  
          projects.  As part of the process, the Board may set  
          lending guidelines such as maturities and interest rates.   
          Any public or private entity can apply, and the Board shall  





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          establish guidelines and criteria to choose projects for  
          financial support that comply with the following criteria:
                 Maximizing economic, environmental, and public  
               health benefits to the state,
                 Fostering job creation by promoting the reduction  
               of greenhouse gas emissions by California workers and  
               businesses,
                 Complementing efforts to improve air quality,
                 Directing investment toward the most disadvantaged  
               communities and households in the state,
                 Providing opportunities for business, public  
               agencies, nonprofits, and other community institutions  
               to participate in and benefit from statewide efforts  
               to reduce greenhouse gas emissions,
                 Lessening the impacts and effects of climate change  
               on the state's communities, economy, and environment,
                 Funding to reduce greenhouse gas emissions through  
               energy efficiency, clean and renewable energy  
               generation, clean and renewable energy generation,  
               distributed renewable energy generation, energy  
               transmission and storage,
                 Funding to reduce greenhouse gas emissions through  
               the development of state-of-the-art systems to move  
               goods and freight, advanced technology vehicles and  
               vehicle infrastructure, advanced biofuels, and  
               low-carbon and efficient public transportation,
                  Funding to reduce greenhouse gas emissions  
               associated with water use and supply, land, and  
               natural resource conservation and management,  
               forestry, and sustainable agriculture,
                 Funding to reduce greenhouse gas emissions through  
               strategic planning and development of sustainable  
               infrastructure projects, including, but not limited  
               to, transportation and housing,
                 Funding to reduce greenhouse gas emissions through  
               increased diversion of municipal solid waste from  
               disposal through waste reduction, diversion, and  
               reuse,
                 Funding to reduce greenhouse gas emissions through  
               investments in programs implemented by local and  
               regional agencies, local and regional collaboratives,  
               and nonprofit organizations coordinating with local  
               governments,
                  Funding in research, development, and deployment  
               of innovative technologies, measures, and practices  
               related to programs and projects funded pursuant to  





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               this part,
                 Creating robust private markets for low-carbon  
               technologies.

          The Bank shall only provide financial assistance if the  
          project is:
                 Located inside the state, 
                 Can support a commercial rate of debt adjusted for  
               the bank's lower costs (except in the case of an  
               innovative energy technology project), 
                 The requested financing support is secured as the  
               chief executive officer of the bank determines  
               appropriate for the sector and the project, 
                 The project satisfied the terms of the Greenhouse  
               Gas Reduction Fund Investment Plan and Communities  
               Revitalization Act, and
                 The project is consistent with any criteria,  
               priorities, and guidelines issued by the bank.

          The Bank also must determine one or more of the following  
          to fund a project:
                 The bank's participation enables otherwise  
               creditworthy and commercially viable entities to  
               deploy clean energy projects at a reasonable cost with  
               a reasonable rate of return to the project developer.
                 The financing will facilitate deployment of a clean  
               energy project at an accelerated rate.
                 The financing support will stimulate, aid, or  
               otherwise support manufacturing of finished products  
               or component parts used in an innovative energy  
               technology project located within the state.
                 The financing support is necessary to create liquid  
               markets for energy securities.
                 The financing support otherwise addresses barriers  
               that have prevented adequate commercial financing of  
               clean energy projects.

          The Bank shall allocate between 15% and 30% of its capital  
          to fund innovative energy technology projects.  The bank  
          can provide convertible debt or warrants for these  
          projects, including nonvoting equity or membership interest  
          in projects or developers.  In the event of default, the  
          bank can complete, maintain, operate, lease, or otherwise  
          dispose of any property it acquires pursuant to a guarantee  
          or related agreement, and direct the sponsor or developer  
          to continue to pursue the purposes of the project if the  





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          bank determines it to be in the public interest.  The bank  
          may fix and collect insurance premiums and loan loss  
          reserve contributions adequate to cover the financial risks  
          associated with the bank's financing support programs.   

          The Bank must use clean energy development networks to  
          identify projects, including creating advisory committees  
          of public and private stakeholders.  The Bank will endeavor  
          to coordinate with existing clean energy research,  
          development, and deployment programs. The bank also can  
          facilitate financing transactions in the tax equity market.

          Any recipient of funds from the Bank shall certify that its  
          contractors are properly licensed, and apply for financial  
          assistance in the form and manner required by the board.  

          The bill exempts interest paid on bonds from state  
          taxation; however, federal taxes would still apply.

          II.  Bank Board.  SB 1121 creates the Green Bank Board,  
          composed of:
                 Three members appointed by the Governor,
                 One member appointed by the Senate Committee on  
               Rules,
                 One member appointed by the Speaker of Assembly,
                 One member appointed by the State Treasurer,
                 One member appointed by the Director of Finance,
                 One member appointed by the California Public  
               Utilities Commission,
                 One member appointed by the California Energy  
               Commission,
                 One member appointed by the State Air Resources  
               Board, 
                 One member appointed by the Department of Water  
               Resources,

          Members appointed by the Governor, Senate Committee on  
          Rules, and Assembly Speaker must have private sector  
          financial experience.  The measure directs the Bank to  
          stagger terms of two, three, and four years after the first  
          four-year term, provides that members can serve after their  
          terms expire under specified circumstances, and enacts  
          other provisions for appointments.  The bill applies the  
          Political Reform Act to board members.    

          III. General Powers.  SB 1121 creates the Green Bank as an  





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          independent entity within state government.  The measure  
          also creates the California Green Bank Fund within the  
          State Treasury, which is continuously appropriated to the  
          Bank, which can draw on it for the purposes of the bill.    
          Additionally, the bill allows the Board to:
                 Adopt and amend bylaws,
                 Adopt an official seal,
                 Establish committees and subcommittees,
                 Sue or be sued in its own name.
                 Purchase insurance for itself or its fiduciaries  
               for acts or omissions, so long as it allows recourse  
               against the fiduciary for breach of obligation. 
                 To receive a salary of an unspecified amount.

          The bill also allows the Chair to place an item pertaining  
          to the policies and procedures of the Bank on the agenda at  
          the request of any two board members.  Any item must be  
          discussed at a meeting of the board within 30 days of the  
          request.

          The bank also can receive charitable gifts, grants, and  
          other conveyances from a variety of sources, so long as the  
          money isn't donated to support any specific project or  
          category of projects.  The bank also can own or take  
          interest in property to the extent necessary to carry out  
          its activities.  Additionally, the bank must assess  
          reasonable fees to cover its reasonable costs.  
          
          IV.  Staff.  SB 1121 directs the Board to select a Chief  
          Executive Officer (CEO), who shall manage and conduct the  
          Bank's affairs at the direction of the Board.  The CEO must  
          have significant experience in management and  
          administration of a financial institution, or in the  
          financing and development of energy or infrastructure  
          projects.  However, the CEO cannot have any financial  
          interest in any project considered by the board, or an  
          interest in an investment institution or its affiliates  
          that seek or are likely to seek financial assistance from  
          the bank, unless the interest is placed in a blind trust.   
          Interests in institutions seeking or likely to seek  
          assistance must be placed into a blind trust for the tenure  
          of the CEO's service, plus two years.  The CEO shall be  
          compensated in an amount set by the Board commensurate with  
          private sector positions.

          The CEO shall select an executive vice president to serve  





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          as CEO during his or her absence or disability, or a  
          vacancy.  The CEO may appoint divisional vice presidents to  
          oversee each of its two divisions, and set compensation  
          amounts for the positions at amounts commensurate with  
          similar private sector financial positions.  The CEO also  
          may employ staff as he or she determines necessary, except  
          as the Board determines otherwise.

          The Bank may contract with banks, credit agencies, and  
          attorneys at customary commercial rates to provide  
          services, including administrative and operating functions,  
          consistent with the California Constitution's civil service  
          provisions. The Bank may compensate its employees at  
          prevailing rates of compensation for similar positions in  
          private industry.  However, no director, officer, attorney,  
          agent, or employee shall participate in the deliberation or  
          determination of any question affecting his or her personal  
          interest.  The bill doesn't apply these provisions to  
          persons or entities entering into contracts with the bank,  
          and also doesn't apply the Political Reform Act to its  
          staff.

          V.  Performance Measurement.  The CEO must:
                 Require any entity receiving financial assistance  
               to report quarterly on its use of support and its  
               progress fulfilling its objectives.  The CEO must make  
               these reports public.
                 Pursue a diversified portfolio of clean energy  
               projects,
                 Establish appropriate mechanisms to ensure  
               appropriate use and compliance with all terms of any  
               financing support made by the Bank, 
                 Create and maintain a fully searchable database  
               accessible on the bank's Internet Website at no cost  
               to the public that contains specific information,
                 Assist in and ensure the development of  
               underwriting standards for financing of clean energy  
               projects consistent with good industry practices for  
               public and private financial institutions, 
                 Establish a risk committee that develops and  
               publishes operational performance metrics including  
               operations, risk management, financial and market  
               metrics, and energy and environmental metrics.
                 Receive public comment.

          The CEO may:





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                 Establish additional reporting and informational  
               requirements of any recipient of financing,
                 Withdraw financing support made to entities that  
               demonstrate insufficient performance, or wasteful or  
               fraudulent spending as defined in advance.  The CEO  
               may award these funds competitively to a new or  
               existing project.  
                 Redact any information regarding applicants and  
               borrowers to protect confidential business  
               information.  

          On February 1st of each year, the Bank shall report to the  
          Governor and the Joint Legislative Budget Committee  
          regarding:
                 A listing of applications received,
                 A specification of bonds sold and the interest  
               rates thereon,
                 The amount of public and private funds leveraged by  
               the assistance provided,
                 A report of revenues and expenditures, including  
               all the bank's costs, with specified contents,
                 Projection of the bank's needs and requirements for  
               the coming year, and
                 Recommendations for changes in state law.

          An independent certified public accountant shall audit the  
          bank each year using generally accepted accounting  
          standards.  The Board also must commission independent  
          comprehensive biennial evaluations of the bank's  
          performance.  The evaluation shall assess the effectiveness  
          and cost-effectiveness of all the bank's activities.

          The measure changes the Greenhouse Gas Reduction Fund  
          Investment Plan and Communities Revitalization Act to allow  
          proceeds of regulatory fee revenues from auction of  
          greenhouse gas allowances required by the California Global  
          Warming Solutions Act of 2006 through the Green Bank (AB  
          32, Pavley).  The measure states legislative findings and  
          declarations to support its purposes, and sunsets its  
          provisions on January 1, 2036.  SB 1121 also states  
          legislative intent relative to redacting confidential  
          business information of purposes of Section 3 of Article 1  
          of the California Constitution.  


                               State Revenue Impact





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          No estimate.


                                     Comments  

          1.   Purpose of the bill  .  A publicly funded Green Bank  
          would provide low-cost, long-term financing to support  
          clean, low-carbon projects. And it would leverage the  
          public funds through the use of financial mechanisms to  
          attract private investment so that each public dollar  
          supports multiple dollars of private investment.  The  
          concept of a green bank is part of a long tradition of our  
          country supporting new energy transitions.  In the 1800s,  
          states rallied to help new businesses exploit their coal  
          resources.  In the early 1900s, tax and accounting benefits  
          helped to allow oil and gas development to proliferate.  In  
          the mid-20th century, government programs including  
          insurance guarantees put the nuclear power industry on the  
          map.  A California Green Bank can help low-carbon  
          industries get to scale, a critical point in a new  
          product's evolution. There are several "Valleys of Death" a  
          company has to survive before it produces its product at  
          scale. It has to get from concept to demonstration phase.   
          It has to get from demonstration to commercialization - the  
          ability to make not one but thousands of a product.  Then  
          it has to make that product at scale - being able to  
          manufacture product as the market demands, at a price  
          competitive with the traditional alternative.

          2.   Dangerous business  ?  SB 1121 would inject the State of  
          California into the banking business and authorize it to  
          issue myriad highly complex securities outside of the  
          Treasurer's Office, a significant expansion over its  
          current operations far from its core competency.   
          Additionally, the measure would require state bank  
          officials to invest state money not in traditional lines of  
          business, but into clean technology companies, where the  
          financial sector's investment results have been mixed to  
          date because it's hard to tell with certainty whether many  
          firms in the space will make money.  While wind and solar  
          energy finance is overflowing with capital, other clean  
          technology companies aren't there yet.  Joseph Dear, former  
                                                              CALPERS chief investment officer stated in 2013 that its  
          cleantech investments had not experienced the J-curve:  
          losses followed by steep gains. It's been "an L-curve, for  





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          'lose.  This had been a noble way to lose money.  Just  
          because it's a good idea doesn't make it a good  
          investment."  Consulting firm McKinsey notes the following:

               The sector has experienced a cycle of excitement  
               followed by high (and often inflated) expectations,  
               disillusionment, consolidation, and then stability as  
               survivors pick up the pieces. We've seen this before  
               with other once-emerging technologies, such as cars,  
               railroads, elevators, oil, and the Internet. Much of  
               cleantech is just leaving its disillusionment or  
               consolidation phase. For example, in transport, Tesla  
               Motors is looking good; Fisker Automotive went into  
               bankruptcy in 2013. In energy, SunPower is making  
               healthy margins and SolarCity raised $450 million in  
               2013, but over a hundred other solar companies are  
               gone. The shakeout is brutal-and typical. It has  
               weeded out weaker players, making the industry as a  
               whole more robust. Despite the rough patch, annual  
               growth is at double-digit rates.

          Should the state expand its footprint to grant credit to a  
          sector of the economy where it's notoriously hard to assess  
          risk, especially given the CALPERS's warning?  If so,  
          should they do so by issuing securities traditionally  
          reserved for sophisticated financial institutions and  
          investment banks, and allow issuance without the state  
          Treasurer, who usually serves as the state's intermediary  
          with capital markets?  The Committee may wish to consider  
          SB 1121's risks.

          3.   Overlap  ?  SB 1121 sets forth broad categories for  
          projects that the Green Bank should assist.  However, the  
          California Public Utilities Commission, California Energy  
          Commission, California Air Resources Board, the California  
          Alternative Energy and Alternative Transportation Finance  
          Authority also deploy financial assistance that overlaps  
          with the bill's direction.  These programs should be  
          consistent with each other, and advance the state's overall  
          goals.  If some of the projects envisioned by the bill can  
          be assisted through other programs, why set up a new state  
          agency?  While the bill also may be referred to the  
          Committee on Energy, Utilities, and Communication, the  
          Committee may wish to consider amending SB 1121 to select  
          an existing agency and grant it new powers, instead of  
          creating a new one.





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          4.   Capitalization  ?  Banks make money when their net  
          interest margin, or the interest paid on its loans over its  
          cost of capital.  To generate net interest margin, it must  
          have access to capital to loan to individuals who will then  
          repay it over time with interest, price the interest rate  
          correctly, and avoid borrower defualt.  However, it's  
          unclear whether the current rules attached to the measure's  
          proposed bank capital, AB 32 allowance auction proceeds,  
          can be used to fund the bill's programs.  In a November,  
          2013 trial court opinion in  California Chamber of Commerce  
          v. California Air Resources Board (#34-2012-80001313)  , the  
          Court stated:

               "Under the unique circumstances of this case, the  
               court is not persuaded that the amounts charged for  
               allowances must be closely linked to the payers'  
               burdens on the specific regulatory programs that will  
               be funded by them. Rather, all that is required is a  
               reasonable relationship between the charges and the  
               covered entities' (collective) responsibility for the  
               harmful effects of GHG emissions."

          While the current standard set by the Courts is fairly  
          broad, appeals are expected and the standard could change  
          as higher courts consider the unique nature of AB 32  
          auction proceeds in the context of California's tax and fee  
          rules.  Should a higher court find that the auction  
          proceeds are regulatory fees, or even taxes, the  
          Legislature's spending flexibility will be sharply  
          curtailed.  The Committee may wish to consider whether it's  
          premature to direct AB 32 revenues towards uses without  
          resolution from the Courts regarding the use of the funds.

          5.   Other Issues  .  SB 1121 requires significant substantive  
          and technical amendments, including, among others:
                 The measure doesn't include consideration of the  
               bank's investment risk, return of capital, or return  
               on capital,
                 The measure doesn't provide a process for creditors  
               to repay it, and penalties or sanctions for failing to  
               do,
                 The proposed board includes representatives from  
               agencies (CPUC, DWR, CEC, CARB) when their Presidents  
               or Executive Directors generally serve on boards  
               instead of appointing individuals.  Additionally, the  





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               Governor appoints directors of these agencies that SB  
               1121 allows to appoint to the Green Bank Board,  
               creating a potential conflict.
                 It's unclear that DWR is an appropriate agency to  
               select a Green Bank board member given their separate  
               charges,
                 Some members must have private sector financial  
               experience, but no specific knowledge of risk  
               assessment, capital markets, venture capital funding  
               of clean energy firms, etc.
                 The process for the CEO placing both direct  
               interests and institutional investments into a blind  
               trust isn't clear.  Verification isn't required.   
               Additionally, direct investments can be removed from a  
               blind trust immediately after the CEO ceases working  
               for the Gren Bank, yet institutional investments  
               cannot be removed for two years, resulting in an  
               inconsistency.
                 It's unclear whether the bank's employees will be  
               state civil service.  The bill requires them to be  
               paid at industry prevailing rates, but doesn't say  
               whether the state will pay benefits, or whether the  
               employees will be subject to recent pension reforms,  
                 Conflict of interest provisions don't clearly apply  
               to all the bank's direct employees and contractors,
                 It's unclear why the Green Bank should issue tax or  
               revenue anticipation notes, floating rate and variable  
               rate securities, asset-backed certificates, bond  
               guarantees, securitization, loan warehousing, credit  
               enhancement, and other undefined financial instruments  
               given the risk involved and the understanding  
               necessary to accurately price these securities in  
               capital markets,
                 Provisions guarding the State's General Fund from  
               claims in case the Bank cannot pay its creditors  
               should be more robust, and more closely reflect  
               conduit bond authorities and the State Infrastructure  
               Bank,
                 The term "a competitive bidding process that  
               encourages aggressive bidding," is undefined, and it's  
               unclear what happens if the process is not  
               sufficiently competitive,
                 To exempt bond interest from income, the measure  
               needs a separate amendment so allowing in the Revenue  
               and Taxation Code, and it's unclear whether the bill  
               applies to capital gains from bond arbitrage.





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                         Support and Opposition  (4/21/14)

           Support  :  Agrion; Bernheim and Dean, Inc.; California Clean  
          Energy Fund; Clean TECH San Diego; Chargepoint; Coalition  
          for Green Capital Action Fund; DBL Investors; Environmental  
          Defense Fund; EV Communities Alliance; Natural Resources  
          Defense Council; Passive House Alliance US; Silicon Valley  
          Leadership Group; Strategy and Finance Center for Market  
          Innovation; Sungevity; SunRun.  

           Opposition  :  None received.