BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                              Senator Wieckowski, Chair
                                2015 - 2016  Regular 
           
          Bill No:            AB 1550
           ----------------------------------------------------------------- 
          |Author:    |Gomez                                                |
           ----------------------------------------------------------------- 
          |-----------+-----------------------+-------------+----------------|
          |Version:   |5/31/2016              |Hearing      |6/29/2016       |
          |           |                       |Date:        |                |
          |-----------+-----------------------+-------------+----------------|
          |Urgency:   |No                     |Fiscal:      |Yes             |
           ------------------------------------------------------------------ 
           ----------------------------------------------------------------- 
          |Consultant:|Rebecca Newhouse                                     |
          |           |                                                     |
           ----------------------------------------------------------------- 
          
          SUBJECT:  Greenhouse gases:  investment plan:  disadvantaged  
          communities.

            ANALYSIS:
          
          Existing law:  
          
          1) Under the California Global Warming Solutions Act of 2006,  
             requires the California Air Resources Board (ARB) to  
             determine the 1990 statewide greenhouse gas (GHG) emissions  
             level, to approve a statewide GHG emissions limit equivalent  
             to that level that will be achieved by 2020, and to adopt GHG  
             emissions reductions measures by regulation.  ARB is  
             authorized to include the use of market-based mechanisms to  
             comply with the regulations.  (Health and Safety Code (HSC)  
             §38500 et seq.)

          2) Establishes the Greenhouse Gas Reduction Fund (GGRF) as a  
             special fund in the State Treasury; requires that all moneys,  
             except for fines and penalties, collected pursuant to a  
             market-based mechanism be deposited in the fund; and requires  
             the Department of Finance, in consultation with the state  
             board and any other relevant state agency, to develop, as  
             specified, a three-year investment plan for the moneys  
             deposited in the GGRF.  (Government Code §16428.8)

          3) Requires that GGRF moneys be used to facilitate the  
             achievement of reductions of GHG emissions in the state  
             consistent with the Global Warming Solutions Act of 2006.   
             Appropriations of the GGRF funds in the annual budget are  







          AB 1550 (Gomez)                                         Page 2  
          of ?
          
          
             required to be consistent with the three-year investment  
             plan.  (HSC §39712)

          4) Under the GGRF Investment Plan and Communities Revitalization  
             Act, requires the California Environmental Protection Agency  
             (CalEPA) to identify disadvantaged communities for investment  
             opportunities related to the Act.  (HSC §39711)

          5) Requires the GGRF investment plan to allocate a minimum of  
             25% of the funds to projects that benefit disadvantaged  
             communities and to allocate 10% of the funds to projects  
             located within disadvantaged communities.  (HSC §39713)

          6) Requires the California Environmental Protection Agency  
             (CalEPA) to identify disadvantaged communities for GGRF  
             investment opportunities and requires those communities be  
             identified based on geographic, socioeconomic, public health,  
             and environmental hazard criteria. (HSC §39711)

          7) Requires the ARB, in consultation with the California  
             Environmental Protection Agency (CalEPA), to develop funding  
             guidelines for administering agencies receiving allocations  
             of GGRF funds that include a component for how agencies  
             should maximize benefits to disadvantaged communities.  (HSC  
             §39715)

          This bill:  

          1) Revises the requirement that 25% of the GGRF be expended to  
             benefit disadvantaged communities to require that the funding  
             be allocated for projects located within the boundaries of,  
             and benefiting individuals in, disadvantaged communities. 

          2) Requires that an additional 20% of the GGRF be allocated for  
             projects that benefit low-income households. 

          3) Defines "low-income household" as those with household  
             incomes at or below 80% of the statewide median income or  
             with household incomes at or below the threshold designated  
             as low income by the Department of Housing and Community  
             Development's list of state income limits.

          4) Requires that, to the extent feasible, a "fair share" of the  
             moneys allocated to benefit low-income households target  








          AB 1550 (Gomez)                                         Page 3  
          of ?
          
          
             households with incomes at or below 200% of the federal  
             poverty level.  

            Background
          
          1) Cap-and-trade auction revenue.  Since November 2012, ARB has  
             conducted 15 cap-and-trade auctions, generating over $4  
             billion in proceeds to the state.  

             State law specifies that the auction revenues must be used to  
             facilitate the achievement of GHG emissions reductions and  
             outlines various categories of allowable expenditures.   
             Statute further requires the Department of Finance, in  
             consultation with ARB and any other relevant state agency, to  
             develop a three-year investment plan for the auction  
             proceeds, which are deposited in the GGRF.  

             SB 535 (de León, Chapter 830, Statutes of 2012) requires the  
             Department of Finance, in the investment plan, to allocate at  
             least 25% of available moneys in the GGRF to projects that  
             provide benefits to disadvantaged communities, and at least  
             10% to projects located within disadvantaged communities.  

             Additionally, SB 862 (Committee on Budget and Fiscal Review,  
             Chapter 36, Statutes of 2014) requires ARB to develop  
             guidelines on maximizing benefits for disadvantaged  
             communities by agencies administering GGRF funds, and  
             guidance for administering agencies on GHG emissions  
             reduction reporting and quantification methods. 

             Legal consideration of cap-and-trade auction revenues.  The  
             2012-13 Budget analysis of cap-and-trade auction revenue by  
             the Legislative Analyst's Office noted that, based on an  
             opinion from the Office of Legislative Counsel, the auction  
             revenues should be considered mitigation fee revenues, and  
             their use requires that a clear nexus exist between an  
             activity for which a mitigation fee is used and the adverse  
             effects related to the activity on which that fee is levied.   
             Therefore, in order for their use to be valid as mitigation  
             fees, revenues from the cap-and-trade auction must be used to  
             mitigate GHG emissions or the harms caused by GHG emissions. 

             In 2012, the California Chamber of Commerce filed a lawsuit  
             against the ARB claiming that cap-and-trade auction revenues  








          AB 1550 (Gomez)                                         Page 4  
          of ?
          
          
             constitute illegal tax revenue.  In November 2013, the  
             superior court ruling declined to hold the auction a tax,  
             concluding that it is more akin to a regulatory fee.  The  
             plaintiffs filed an appeal with the 3rd District Court of  
             Appeal in Sacramento in February of 2014, and that case is  
             pending.

             Budget allocations.  SB 862 (Committee on Budget and Fiscal  
             Review, Chapter 36, Statutes of 2014), a budget trailer bill,  
             established a long-term cap-and-trade expenditure plan by  
             continuously appropriating portions of the funds for  
             designated programs or purposes.  The legislation  
             appropriates 25% for the state's high-speed rail project, 20%  
             for affordable housing and sustainable communities grants,  
             10% to the Transit and Intercity Rail Capital Program, and 5%  
             for low-carbon transit operations.  The remaining 40% is  
             available for annual appropriation by the Legislature.  

             The Governor's 2016-17 proposed budget appropriates over $3  
             billion to a variety of programs and projects in the  
             transportation, energy, natural resources, and waste  
             diversion sectors.
            
          2) CalEnviroScreen and disadvantaged communities.  
             CalEnviroScreen was developed by OEHHA, at the request of  
             CalEPA and pursuant to the GGRF Investment Plan and  
             Communities Revitalization Act (SB 535, de León, Chapter 830,  
             Statutes of 2012), to determine a list of disadvantaged  
             communities in California that are the most vulnerable and  
             pollution-burdened.  The tool is used to help direct those  
             GGRF investments targeted for disadvantaged communities, as  
             well as to guide CalEPA in administering its Environmental  
             Justice Small Grants Program and prioritizing resources for  
             cleanup and abatement projects and outreach efforts by the  
             Agency. 

             Using CalEnviroScreen, CalEPA determined a list of  
             disadvantaged communities throughout California in October  
             2014.  According to CalEPA, the current version incorporates  
             19 indicators, including those for exposures, environmental  
             effects, sensitive populations, and socioeconomic factors. 

             Census tracts in the top 25th percentile of cumulative  
             CalEnviroScreen scores have been designated disadvantaged  








          AB 1550 (Gomez)                                         Page 5  
          of ?
          
          
             communities for the purposes of SB 535 (de León).

             The areas where the majority of disadvantaged communities  
             were identified included the San Joaquin Valley, parts of Los  
             Angeles and the Inland Empire, and large portions of the  
             Coachella Valley and Mojave Desert, in addition to  
             communities located near industrial areas and major roadways.

             Update. OEHHA intends to update CalEnviroScreen this year to  
             incorporate the most current information available.  Other  
             improvements are also expected to be part of this update.   
             The proposed changes will be released in a draft version of  
             the tool this summer.

          3) ARB Guidance on GGRF. In 2014, ARB published interim guidance  
             for meeting the requirements associated with GGRF  
             appropriations, as well as maximizing benefits to  
             disadvantaged communities, for agencies appropriated GGRF  
             moneys. This guidance was finalized and released in late  
             2015.

             In meeting the SB 535 requirement, the guidance states that  
             agencies should first assess whether projects will be located  
             within a disadvantaged community, as identified through  
             CalEnviroScreen, and whether the project will provide direct  
             benefits to that community, consistent with specific criteria  
             in the guidance document for each program type. If  
             investments meet this requirement, then the guidance  
             specifies that the projects and administrative funds count  
             towards both the 10% and 25% requirements for GGRF  
             investments within, and providing benefits to, disadvantaged  
             communities.  

             If the project is not within the disadvantaged community, the  
             guidance directs agencies to evaluate whether the project  
             provides direct, meaningful, and assured benefits in  
             accordance with specified criteria for each project type.   
             Projects within a half-mile of a disadvantaged community and  
             that provide increased service or access to those  
             communities, or projects that result in at least 25% of  
             project work hours performed by residents of disadvantaged  
             communities, may count towards the SB 535 mandate requiring a  
             minimum of 25% of GGRF money benefit disadvantaged  
             communities.  








          AB 1550 (Gomez)                                         Page 6  
          of ?
          
          

          4) GGRF benefits report. AB 1532 (Pérez, Chapter 807, Statutes  
             of 2012) requires the Department of Finance (DOF) to submit  
             an annual report to the Legislature on the status and  
             outcomes of projects funded from the GGRF. The 2016 Annual  
             Report describes the status of funded programs and lists the  
             projects funded and also provides estimates of the GHG  
             reductions expected from project investments and statistics  
             on benefits to disadvantaged communities, demand for funding,  
             and leveraging of funds.  Specifically, the report states  
             that for implemented projects funded through GGRF, 51% of  
             investments provided benefits to disadvantaged communities,  
             with 39% of GGRF investments directed within disadvantaged  
             communities. 

             According to the Annual Report, "CALFIRE's urban forestry  
             program is planting trees in disadvantaged communities  
             throughout the State, providing community shading and  
             reducing energy demand while improving active transportation  
             and recreational opportunities for these residents. Caltrans'  
             Low Carbon Transit Operations Program is supporting new and  
             expanded services and facilities that improve mobility for  
             disadvantaged communities and low-income residents in these  
             communities. The Department of Community Services and  
             Development's (CSD) Low-Income Weatherization Program is  
             helping low-income residents in disadvantaged communities  
             reduce their energy use and energy costs.  The current  
             appropriations will easily meet and exceed the SB 535  
             disadvantaged community targets without including High Speed  
             Rail. However, the High Speed Rail Project is expected to  
             greatly benefit disadvantaged communities throughout the  
             State by creating thousands of direct construction-related  
             jobs as well as indirect jobs and related economic  
             development benefits in communities of the Central Valley,  
             which has some of the highest unemployment rates in the  
             country."



            Comments
          
          1) Purpose of Bill.  According to the author, "Low-income  
             communities and communities of color are and will continue to  
             be disproportionately impacted by the effects of our changing  








          AB 1550 (Gomez)                                         Page 7  
          of ?
          
          
             climate.  As we think about how to structure our state's  
             climate programs - as we discuss percentages and parameters -  
             this is a reality we cannot ignore and must strive to remedy.  
             AB 1550 builds on the successes of our climate equity efforts  
             to date by ensuring a greater investment in California's  
             environmentally and socioeconomically disadvantaged  
             populations.  The bill requires that at least 25% of  
             cap-and-trade funds be spent on projects located directly  
             within disadvantaged communities, as identified by the  
             state's environmental health screening tool, to ensure that  
             the level of investment in DACs equals their share of the  
             population.  The bill also requires an additional 20% of  
             funds to benefit low-income households.

             "While CalEnviroScreen is a valuable tool for capturing  
             cumulative impacts in communities, it is widely recognized  
             that there are poor and working-class households that lie  
             outside of DACs - but that struggle to make ends meet and  
             spend a large portion of their incomes on necessitates - such  
             as energy, water, housing, and transportation.  If we wish to  
             foster a shared, statewide commitment to tackling pressing  
             environmental issues, we must take advantage of opportunities  
             to reduce greenhouse gas emissions and build sustainable  
             communities while lifting poor and working Californians out  
             of poverty.

             "A greater investment in California's environmentally and  
             socioeconomically disadvantaged populations has the potential  
             to yield significant climate, public health, and cost  
             benefits while helping bridge the 'green divide'."

          2) Amending SB 535.  AB 1550 amends requirements put in place  
             through SB 535 (de León, Chapter 830, Statutes of 2012) for  
             spending cap-and-trade auction proceeds in disadvantaged  
             communities and adds additional requirements for minimum  
             spending for low-income households. Specifically, SB 535  
             requires a minimum of 25% of GGRF moneys benefit  
             disadvantaged communities and 10% be spent within those  
             communities.  AB 1550 eliminates the distinction created in  
             SB 535, where appropriating funds to "benefit" a  
             disadvantaged community do not necessarily have to be spent  
             within the disadvantaged community, and instead requires a  
             minimum of 25% GGRF moneys be spent to benefit disadvantaged  
             communities within those communities. Additionally, AB 1550  








          AB 1550 (Gomez)                                         Page 8  
          of ?
          
          
             requires a minimum of 20% of GGRF moneys be directed to  
             benefit "low-income households," as defined, and does not  
             allow investments toward disadvantaged communities to count  
             toward the minimum percentage required to benefit low-income  
             households, or the reverse. 

          3) Benefiting low-income households. The bill requires a minimum  
             of 20% of GGRF be spent to benefit "low-income households."  
             AB 1550 defines these households as those at or below 80% of  
             the statewide median income, or as households designated as  
             low-income based on area-wide median incomes, based on  
             figures from the Department of Housing and Community  
             Development (DHCD). The area-wide "low-income" income  
             thresholds better account for high cost of living and rent  
             burdens in various regions across the state.

             Some of the current programs funded through GGRF, like  
             weatherization programs and car retirement and replacement  
             programs, may be counted as benefiting a household. However,  
             it is difficult to ascribe benefits specifically to  
             individual households for a number of other GGRF programs,  
             including transportation projects that provide enhanced or  
             improved public transit (i.e., the Low Carbon Transit  
             Operations program or the Transit and Intercity Rail Capital  
             program, which both receive continuous GGRF appropriation)  
             and, urban forestry and greening projects. In this way, the  
             20% requirement for benefiting low-income households may be  
             1) difficult to measure, 2) limit access of low-income  
             households to a variety of other GGRF programs with more  
             community-wide impacts, and 3) create implementation  
             challenges, since funding for the subset of programs directly  
             benefiting households may not be sufficient to meet the  
             bill's 20% requirement. 

             To address this issue, amendments are needed to require 20%  
             of GGRF moneys be directed to "low-income households" or  
             "low-income communities," and to define a "low-income  
             community" as a census tract with a median household income  
             at or below 80% of the statewide median income or with a  
             median household income at or below the threshold designated  
             as low-income by the Department of Housing and Community  
             Development.

          4) Smaller pot. As the cap for the state's cap-and-trade program  








          AB 1550 (Gomez)                                         Page 9  
          of ?
          
          
             is reduced, so are allowances that are offered for sale. As  
             it is the sale of these allowances at auctions that generate  
             cap-and-trade proceeds, this revenue source will continue to  
             shrink. Additionally, only 2% of the state allowances sold at  
             the auction in May, and resulted in the state receiving only  
             $10 million in proceeds where up to $500 million was  
             projected. 

             A larger fraction of moneys for disadvantaged communities and  
             low-income households, as prescribed in AB 1550, of a  
             shrinking pot of GGRF moneys may result in a significantly  
             reduced fraction of money from GGRF for emissions reduction  
             projects in the rest of the state. 

          5) More constraints on funding. As larger amounts of GGRF are  
             set aside to benefit various groups, flexibility for  
             allocating those funds is reduced. For example, a project  
             that does not rank as high may be funded over a project  
             ranked more highly in order to satisfy a requirement that a  
             certain percentage of funds be spent to benefit a particular  
             group. In situations where a tradeoff is required, policy  
             goals of providing benefits to vulnerable populations may  
             outweigh other policy goals for the GGRF, including funding  
             only the most highly ranked project. However, the more these  
             constraints are added to the fund, the more frequently these  
             policy tradeoffs will arise.  

             As the bill already specifically targets low-income  
             households with a significant fraction of the GGRF, the  
             committee may wish to consider removing the requirement in  
             the bill that a "fair share" of GGRF moneys target households  
             with incomes at or below 200% of the federal poverty level  
             "to the maximum extent feasible." 

          6) How will this change the way GGRF moneys are appropriated? It  
             is not clear how agencies will implement an increased  
             requirement for spending within disadvantaged communities,  
             and an additional mandate for spending to benefit low-income  
             households.  

             According to the annual DOF report on GGRF benefits and  
             funded projects to date, about 39% of GGRF has been spent  
             within disadvantaged communities-14% over the AB 1550  
             requirement. Assuming that the majority of those  








          AB 1550 (Gomez)                                         Page 10  
          of ?
          
          
             disadvantaged communities would also qualify as low-income  
             under the bill, that 14% of GGRF investment over the 25%  
             mandate could potentially count toward the 20% requirement  
             for low-income households or communities, leaving only 6%  
             more directed toward low-income households to meet the new  
             requirements under AB 1550. Under this scenario, there may  
             not be significant change in the way current GGRF investments  
             are made. However, as the author would like to capture a  
             distinct population from disadvantaged communities by  
             requiring a minimum investment for "low-income households,"  
             agencies may work to implement the intent of the legislation  
             by specifically directing expenditures to low-income  
             communities that are not also disadvantaged communities.  
             Therefore, it is not clear to what extent low-income  
             populations that are not identified as disadvantaged  
             communities according to CalEnviroScreen, will benefit from  
             the additional set-aside in AB 1550.   

          7) Targeting disadvantaged communities. SB 535 requires  
             disadvantaged communities for GGRF investment opportunities  
             be identified based on geographic, socioeconomic, public  
                                                                                     health, and environmental hazard criteria. The resulting  
             tools uses socioeconomic and environmental pollution  
             indicators throughout the state to evaluate those vulnerable  
             populations experiencing cumulative pollution burdens and  
             specifically targets them for GGRF investment.  The analysis  
             is complex, relying on 19 different indicators for an  
             aggregate score to identify disadvantaged communities for  
             targeted GGRF investment. 

             AB 1550 does not alter the methodology behind how  
             disadvantaged communities are identified, but further expands  
             investments to those communities as well as requiring 20% of  
             GGRF moneys be directed toward low-income households. In  
             contrast to CalEnviroScreen, this criterion is a relatively  
             simple method for targeting vulnerable populations. 

             In this way, the bill seems to establish an inconsistent  
             policy for identifying vulnerable or distressed populations  
             for GGRF investments-on one hand relying on a complex  
             analysis to assess aggregate socioeconomic factors and  
             environmental burdens, and on the other hand, simply  
             directing moneys to communities or households based on a  
             single economic metric.








          AB 1550 (Gomez)                                         Page 11  
          of ?
          
          

             This also raises questions surrounding the original policy  
             goals of SB 535 in requiring CalEPA identify disadvantaged  
             communities based on a variety of criteria. Does singling out  
             an additional population for investment based on a single  
             measure fit within the original policy goals of SB 535?
            

          SOURCE:                    Author  

           SUPPORT:               

          Alameda County Board of Supervisors 
          Amigos de los Rios
          Asian Pacific Environmental Network
          Asian Pacific Policy and Planning Council
          California Association of Local Conservation Corps
          California Bicycle Coalition
          California Black Health Network 
          California Black Health Network
          California Center for Public Health Advocacy
          California Environmental Justice Alliance
          California Environmental Justice Alliance
          California Housing Partnership Corporation
          California League of Conservation Voters
          California ReLeaf
          California Urban Forests Council
          California Vanpool Authority
          California Voices for Progress
          Canopy
          Catholic Charities
          Catholic Charities, Diocese of Stockton
          Center for Community Action and Environmental Justice
          Center on Race, Poverty and the Environment 
          Central California Asthma Collaborative
          Central Coast Alliance United for a Sustainable Economy 
          Central Coast Energy Services
          City Project
          Coalition for Clean Air
          Communities for a Better Environment 
          Community Action to Fight Asthma 
          Community Health for Asian Americans
          Defenders of Wildlife
          Energy Solidarity Cooperative








          AB 1550 (Gomez)                                         Page 12  
          of ?
          
          
          Environment California 
          Environmental Defense Fund
          Environmental Health Coalition
          Fallbrook Land Conservancy
          Filipino/American Coalition for Environmental Solidarity
          Fresno Economic Opportunities Commission
          Fresno Interdenominational Refugee Ministries
          Friends Committee on Legislation of California
          Grayson Neighborhood Council
          Green Education, Inc.
          Green for All
          Greenlining Institute
          Greenspace-The Cambria Land Trust
          GRID Alternatives
          Growing Together
          Huntington Beach Tree Society, Inc.
          Liberty Hill Foundation
          Little Tokyo Service Center
          Los Angeles Conservation Corps
          Los Angeles Neighborhood Land Trust
          Move LA
          National Parks Conservation Association
          Pacific Asian Consortium in Employment (PACE)
          Pacoima Beautiful
          People Organizing to Demand Environmental and Economic Rights
          Physicians for Social Responsibility - Los Angeles
          Placer Land Trust
          Propel Fuels 
          Public Advocates
          Regional Asthma Management and Prevention
          Rising Sun Energy Center
          Rural County Representatives of California
          Sacramento Tree Foundation
          Safe Routes to School National Partnership
          Santa Clara Valley Open Space Authority 
          Save the Bay
          SCOPE
          Sierra Business Council 
          Sierra Climate Adaptation and Mitigation Partnership (Sierra  
                         CAMP)
          Sierra Club California
          Sierra Foothill Conservancy
          Solar-Oversight
          Stone Soup Fresno








          AB 1550 (Gomez)                                         Page 13  
          of ?
          
          
          Strategic Actions for a Just Economy
          Strategic Concepts in Organizing and Policy Education 
          The Nature Conservancy
          TransForm
          Tree Davis
          Tree San Diego
          Truckee Donner Land Trust
          Trust for Public Land
          TRUST South LA
          Union of Concerned Scientists
          Urban Releaf
          Valley Clean Air Now
          Watershed Conservation Authority 
                         
            OPPOSITION:    

          California Chamber of Commerce
          California Taxpayers Association
          Metropolitan Transportation Commission
           
           ARGUMENTS IN  
          SUPPORT:    

          Supporters state that, since CalEnviroScreen classifies a  
          quarter of the state's population as living in disadvantaged  
          communities, at least a quarter of GGRF proceeds should be  
          invested directly within the boundaries of disadvantaged  
          communities, which generally provides more assistance than  
          simply "benefiting" these communities. They further add that  
          this is a simple equity adjustment to the existing formula that  
          reflects the need to invest in these communities hit first and  
          worst by the adverse impacts of climate change. Additionally,  
          they state that some of the best GHG reduction strategies are  
          those that benefit low-income households whether they lie inside  
          or outside CalEnviroScreen-designated disadvantaged communities.  
          They further note that low-income Californians often lack  
          adequate and affordable transportation and housing choices,  
          access to green spaces, and spend a significant percentage of  
          their budget on necessities including fuel and energy, and for  
          those reasons, AB 1550 directs additional investments to  
          low-income households, communities and populations, as well. 
           
           ARGUMENTS IN OPPOSITION:
          








          AB 1550 (Gomez)                                         Page 14  
          of ?
          
          
          The Metropolitan Transportation Commission (MTC) states that, as  
          written, AB 1550 would expand the state's reliance upon a flawed  
          definition of disadvantaged communities that excludes many  
          communities characterized by poor socio-economic conditions, and  
          state that the CalEnviroScreen should not be relied upon  
          exclusively to target cap-and-trade funds to disadvantaged  
          communities.  They argue that CalEnviroScreen has the perverse  
          public health effect of encouraging growth and development in  
          locations where residents have greater exposure to environmental  
          harm. MTC states that they are opposed to the bill unless AB  
          1550 is amended to broaden the definition of disadvantaged  
          communities so that it includes communities with concentrations  
          of people living with poor socio-economic conditions-regardless  
          of their exposure to environmental hazards. California Chamber  
          of Commerce and California Taxpayers Association are opposed as  
          they argue that ARB lacks the authority to raise revenue through  
          auction of allowances.  
           
           
                                          
                                      -- END --