BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    AB 2153


                                                                    Page  1





          Date of Hearing:  June 2, 2016


           ASSEMBLY COMMITTEE ON ENVIRONMENTAL SAFETY AND TOXIC MATERIALS


                                  Luis Alejo, Chair


          AB 2153  
          (Cristina Garcia) - As Amended June 1, 2016


          SUBJECT:  The Lead-Acid Battery Recycling Act of 2016


          SUMMARY:  Establishes new fees on lead-acid batteries to fund  
          lead contamination cleanup.  Specifically, this bill:  


          1)Repeals and amends Article 10.5 of Chapter 6.5 of the Health &  
            Safety Code regarding the management of lead-acid batteries. 


          2)Requires a replacement lead-acid battery dealer to accept from  
            a consumer a used lead-acid battery without regard to the  
            brand or original dealer of the used battery for recycling.  
            Cap the number of batteries that can be returned by a consumer  
            at six lead-acid batteries per day. 


          3)Authorizes consumers to be refunded the deposit if the  
            lead-acid battery is returned within 45 days after purchase. 


          4)Requires a lead-acid battery dealer to conspicuously post a  
            written notice stating that the dealer is required by law to  
            accept used lead-acid batteries and charge a fee on all  
            replacement lead-acid battery sold. 








                                                                    AB 2153


                                                                    Page  2







          5)Requires a lead-acid battery dealer to charge a refundable  
            deposit (unspecified dollar amount) plus a non-refundable $1  
            California Battery Fee on each lead-acid battery sold to a  
            person buying a replacement lead-acid battery. 


          6)Requires all replacement lead-acid batteries to have a widely  
            understood recycling symbol.


          7)Requires a lead-acid battery dealer to collect the California  
            Battery Fee at the time of sale and authorize the dealer to  
            retain 1.5-percent of the fee as reimbursement for any costs  
            associated with the collection of the fee.  Require the  
            remainder of the fee be remitted to the State Board of  
            Equalization (BOE).


          8)Requires each manufacturer to remit to the BOE a $1  
            Manufacturer Battery Fee for each lead-acid battery sold at  
            retail to a person in California. 


          9)Requires all California Battery Fee and Manufacturer Battery  
            Fee revenues to be deposited into the Lead-Acid Battery  
            Cleanup Fund. 


          10)Requires DTSC and BOE to be reimbursed for the costs of  
            collection, auditing, and administration of funds. Cap  
            administrative costs at 3-percent. 


          11)Authorizes a wholesaler of lead-acid batteries to assume  
            responsibility of paying the Manufacturer Battery Fee at the  
            behest of the manufacturer. Require the wholesaler to notify  
            BOE, DTSC, and the manufacturer of its intention to pay the  








                                                                    AB 2153


                                                                    Page  3





            Manufacturer Battery Fee. 


          12)Authorizes any manufacturer exempted from its obligations to  
            pay the Manufacturer Battery Fee to voluntarily submit an  
            additional $1 Manufacturer Battery Fee per lead-acid battery.  
            Prohibit the manufacturer from passing along the costs to the  
            wholesaler or consumers. 


          13)Continuously appropriates all funds in the Lead-Acid Battery  
            Cleanup Fund to DTSC to fund the following activities:  
            investigation, site evaluation, cleanup, abatement, remedy,  
            removal, monitoring, or other response actions at any site in  
            California investigated because of concerns about lead  
            releases from a lead-acid battery recycling facility (from  
            hereto referred to as eligible lead-related activities), and  
            repayment of General Fund loans for lead contamination  
            cleanup.


          14)Requires any funds spent by DTSC for any eligible  
            lead-related activities to be drawn from the Lead-Acid Battery  
            Cleanup Fund before drawing from any other fund source.  


          15)Requires DTSC, prior to seeking to recover any moneys spent  
            on eligible lead-related activities from any person who has  
            remitted any amount of Manufacturer Battery Fees, other than  
            persons who are or were the owners or operators, or legal  
            successors to owners or operators, of a site at which such  
            activity occurred, to draw from and deplete the funds in the  
            Lead-Acid Battery Cleanup Fund, and exhaust efforts to recover  
            any funds expended for any eligible lead-related activity from  
            the owners or operators, or legal successors to owners or  
            operators, of the site at which such activity occurred.  


          16)Requires the balance of a judgment against any manufacturer  








                                                                    AB 2153


                                                                    Page  4





            who has remitted any amount of Manufacturer Battery Fees to be  
            reduced by the amount the manufacturer has remitted to the  
            state.


          17)States that nothing in this bill shall be construed to limit  
            or otherwise affect any cause of action that may exist under  
            any law that the state may bring against the owners or  
            operators, or legal successors to owners or operators, of a  
            site at which any described eligible lead-related activity.


          18)Requires any funds spent from the Lead-Acid Battery Cleanup  
            Fund that are subsequently recovered from any person to be  
            deposited into the Lead-Acid Battery Cleanup Fund.


          19)Prohibits funds from the Lead-Acid Battery Cleanup Fund from  
            funding Green Chemistry as it relates to lead-acid batteries. 


          20)Precludes lead-acid batteries from consideration for  
            inclusion on a list of Priority Products under DTSC's Safer  
            Consumer Products Program as long as the national recycling  
            rate for lead in batteries determined by the methodology  
            accepted by the US Environmental Protection Agency (US EPA)  
            employed in the Battery Council International's National  
            Recycling Rate Study exceeds a to be determined percentage. 


          21)States that this shall not preclude a study of the impacts  
            and benefits of manufacture and recycling of lead-acid  
            batteries pursuant to the Governor's May Revise proposal.   


          22)Requires DTSC to report annually to the Governor and to the  
            Legislature on the status of the Lead-Acid Battery Cleanup  
            Fund and on DTSC's progress on implementation. 









                                                                    AB 2153


                                                                    Page  5






          23)Requires any manufacturer who has remitted any amount of fees  
            and who is held responsible by any authority under the  
            California Hazardous Substances Account Act or any other law  
            for the payment or reimbursement of any moneys to the state or  
            a regional board for an eligible lead-related activity to have  
            its responsibility for such payment or reimbursement reduced  
            by the amounts that manufacturer remitted.


          24)Authorizes the state to bring an action against a  
            manufacturer who has remitted any amount of fees for the  
            payment or reimbursement of any moneys to the State or a  
            regional board for any of the eligible lead-related activities  
            if the state has a reasonable basis to believe that the  
            manufacturer ultimately would be held responsible for amounts  
            in excess of the amount the manufacturer has remitted. 


          25)Requires the state to notify the manufacturer of the state's  
            intent to bring an action and meet and confer with the  
            manufacturer to reach an agreement by which the manufacture  
            voluntarily resolves the state's claim.   


          26)States that nothing shall be construed to create a private  
            cause of action against a manufacturer, affect any cause of  
            action that may exist under other law or reduce the amount of  
            damages for which the manufacturer is held liable in any civil  
            action for personal injury or wrongful death.  


          27)States that nothing shall be construed to limit or otherwise  
            affect a claim the state may assert against the owners or  
            operators, or legal successors to owners or operators, of a  
            site at which any eligible lead-related activity.


          28)Prohibits any administrative order or judicial relief from  








                                                                    AB 2153


                                                                    Page  6





            being sought to compel any person who has remitted fees to  
            take any eligible lead-related activity at a site unless the  
            Lead-Acid Battery Cleanup Fund has been exhausted by the  
            state.


          29)Authorizes DTSC to impose civil administrative penalties not  
            to exceed $1,000 per day on any person who is in violation.  
            Requires all penalties to be deposited into the Lead-Acid  
            Battery Cleanup Fund. 


          30)Establishes this as an urgency act in order to increase the  
            cleanup of toxic materials and prevent additional toxic  
            pollution at the earliest possible time.


          31)Establishes the effective date as January 1, 2017. 


          EXISTING LAW:


          1)Prohibits the disposal of a lead-acid battery at a solid waste  
            facility, or on or in any land, surface waters, watercourses,  
            or marine waters. (Health and Safety Code (H&S) § 25215.2)


          2)Requires retailers to accept the trade-in of a spent lead-acid  
            battery by a consumer upon purchase of a new one. (H&S §  
            25215.3)


          3)Governs the management of used lead-acid batteries.  
            (California Code of Regulations, Title 22, § 66266.80 and  
            66266.81)


          4)Requires all lead-acid batteries purchased by any state agency  








                                                                    AB 2153


                                                                    Page  7





            for, and, at the next required installation of a battery in,  
            an automobile or light truck owned or operated by the state  
            agency, to be a recycled lead-acid battery, to the extent that  
            all existing stock of nonrecycled batteries have been  
            utilized. (Public Resources Code (PRC) § 42442)


          FISCAL EFFECT:  Unknown. The Assembly Appropriations Committee  
          analyzed a previous version of the bill, which may render that  
          estimated fiscal impact irrelevant to the current version of the  
          bill.  


          COMMENTS:  


          Need for the bill: According to the author, "AB 2153 will create  
          a state mandated Lead-Acid (Car) Battery fee that will serve as  
          a funding mechanism for clean-up of areas contaminated by  
          lead-acid batteries. Consumers will be charged a $1 fee per car  
          battery at point of sale. Manufacturers will pay a $1 fee on all  
          batteries sold in the state. The money from the fee can go to  
          re-pay the Governor's 176.6 million dollar loan, and will be  
          used to clean up areas of the state that have been contaminated  
          by the production and recycling of lead acid batteries."


          The problem with lead:  Lead has been listed under California's  
          Proposition 65 since 1987 as a substance that can cause  
          reproductive damage and birth defects and has been on the list  
          of chemicals known to cause cancer since 1992.  According to the  
          Office of Environmental Health Hazard Assessment, lead has  
          multiple toxic effects on the human body. 


          Lead-acid batteries:  According to the U.S. Geological Survey,  
          the lead-acid battery industry accounted for about 90% of  
          reported U.S. lead consumption during 2015. 









                                                                    AB 2153


                                                                    Page  8






          According to the California Board of Equalization's estimates,  
          based on 2012 Census data, lead-acid car battery sales in  
          California are approximately $1.6 billion.  That is based on an  
          estimate of roughly 16 million batteries sold at an average cost  
          of $100.


          Under current law, any dealer of lead-acid batteries is required  
          to accept a lead-acid battery from a consumer, regardless of  
          type and size of the battery. AB 2153, as amended, narrows the  
          requirement for retailers to take back virtually any lead acid  
          battery and authorizes retailers to reject a lead-acid battery  
          if it is not the same "type and size" that is sold by that  
          retailer. 


          The author may wish to consider restoring current law, which  
          affords more flexibility to consumers to return their spent  
          lead-acid batteries for recycling. 


          Exide Technologies:  The Exide Technologies (Exide) battery  
          recycling facility in Vernon, California, recycled lead from  
          used automotive batteries and other sources.  The facility could  
          process about 25,000 automotive and industrial batteries a day,  
          providing a source of lead for new batteries.  Over the course  
          of decades of operation, the facility polluted the soil beneath  
          it with high levels of lead, arsenic, cadmium and other toxic  
          metals.  It also has contaminated groundwater, released battery  
          acid onto roads and contaminated homes and yards in surrounding  
          communities with lead emissions.  In March, 2015, Exide was  
          forced to close the facility for good and, under a state  
          agreement with DTSC, set aside $7.7 million to test homes and  
          other structures around the facility for pollution resulting  
          from the facility. 


          DTSC estimates homes between 1.3 and 1.7 miles away from the  








                                                                    AB 2153


                                                                    Page  9





          facility may potentially be affected by Exide's lead  
          contamination - that equates to somewhere between 5,000 - 10,000  
          residential properties.  Cleaning each home costs about $45,000,  
          according to DTSC.  If the cleanup grows to thousands of  
          properties, it could cost hundreds of millions of dollars.   
          Removing lead-contaminated soil from thousands of homes  
          surrounding Exide could result in the most extensive cleanup of  
          its kind in California and will be among the largest cleanup  
          ever conducted in the nation.  At the end of the day, the cost  
          of cleanup in and around the Exide facility is expected to top  
          $500 million dollars. 


          On April 20, 2016, the Governor signed AB 118 (Santiago),  
          Chapter 10, Statutes of 2016 and SB 93 (De Léon), Chapter 9,  
          Statutes of 2016, appropriating a $176.6 million loan from the  
          Toxic Substances Control Account to enable DTSC to test the  
          remaining properties, schools, daycare centers, and parks in the  
          1.7 mile radius and remove contaminated soil at the properties  
          that have the highest lead levels and greatest potential  
          exposure to residents.


          Cleanup costs initially incurred by the state will ultimately be  
          sought from the parties responsible for the lead contamination.   
          DTSC is looking for funds to pay for the work while it seeks  
          additional money from Exide and other responsible parties.


          After the $176.6 million is expended, DTSC will need additional  
          funds to do complete and thorough cleanup.  This bill is  
          intended to fill that gap while providing an ongoing source of  
          funds to address future lead contamination from lead-acid  
          batteries.  


          Use of proposed battery charge revenues:  This bill would  
          require a fee to be added to the purchase price of a replacement  
          lead-acid battery at the point of sale. A non-refundable $1  








                                                                    AB 2153


                                                                    Page  10





          Consumer Battery Fee would be paid by the consumer and $1  
          Manufacturer Battery Fee would be paid per lead-acid battery  
          manufacturer. An additional $1 per battery could be collected if  
          a wholesaler pays the Manufacturer Battery Fee on the  
          manufacturer's behest and the manufacturer voluntarily pays an  
          additional $1 fee. 


          The bill would authorize those fee revenues to be continuously  
          appropriated to DTSC for the investigation, site evaluation,  
          cleanup, abatement, remedy, removal, monitoring, or other  
          response actions at any site in California investigated because  
          of concerns about lead releases from a lead acid battery  
          recycling facility. In addition, AB 2153 would authorize funds  
          in the Lead-Acid Battery Cleanup Fund to be used towards  
          repaying the General Fund loan.  


          The April 14 version of the bill authorized use of the funds for  
           the cleanup of areas of the state that have been contaminated  
          by the production, recycling, or improper disposal of lead-acid  
          batteries and activities. 


          The author may wish to consider amending the bill to clarify  
          that the funds can be used beyond cleanup at recycling  
          facilities (of which there are only two in California) and be  
          used at any facility that may have lead contamination resulting  
          from the production, recycling, or improper disposal of  
          lead-acid batteries and activities. 


          Manufacturer credits: Under AB 2153, any funds spent by DTSC for  
          any eligible lead-related activities must be drawn from the Lead  
          Acid Battery Cleanup Fund before drawing from any other fund  
          source. The bill also requires the financial obligations of any  
          manufacturer found financially responsible for any lead-related  
          activity (site cleanup) to be reduced by the amount that the  
          manufacturer remitted in Manufacturer Battery Fee or voluntary  








                                                                    AB 2153


                                                                    Page  11





          fees. If a manufacturer is found responsible for site cleanup,  
          those fees act like a deposit on their cleanup costs. If a  
          manufacturer is never found responsible for site cleanup, those  
          remitted fees help to cover other manufacturer or recycler's  
          cleanup costs, which could be considered a way of mandating  
          corporate social responsibility. 


          Accounting correction: The bill requires DTSC to deplete all  
          funds in the Lead-Acid Battery Cleanup Fund before it can seek  
          to recover funds from a person who has remitted a Manufacturer  
          Battery Fee, unless that person is an owner or operator of a  
          contaminated site. 


          The bill also states that the balance of a judgment against any  
          person responsible for a contaminated site and who has remitted  
          any amount of Manufacturer Battery Fees shall be reduced by the  
          amount that person has remitted to the state.


          If the fees are remitted on a quarterly basis, the fund will  
          likely never be extinguished, which prevents DTSC from recouping  
          costs from an RP who is not an owner or operator or legal  
          successor of a site. Under current law, there is a statute of  
          limitations on when DTSC can recoup costs of removal or remedial  
          actions, which is within three years after completion of all  
          response or corrective actions have been certified by DTSC or a  
          regional water quality control board.


          The author may wish to consider correcting this provision to  
          eliminate any constraint on DTSC from recovering costs from an  
          RP. 


          Clarifying responsibility: A manufacturer could have more than  
          one wholesaler selling lead-acid batteries in California. The  
          bill does not determine any threshold at which the manufacturer  








                                                                    AB 2153


                                                                    Page  12





          is released from responsibility. The bill simply requires a  
          wholesaler to notify intent to pay the Manufacturer Battery Fee.  
          If a wholesaler who manages 20% of a manufacturer's battery  
          sales in California elects to pay the Manufacturer Battery Fee,  
          it's unclear if the manufacturer is off the hook for the fee for  
          the other 80% of its batteries sold in California. The author  
          may wish to consider clarifying the manufacturer's obligations  
          under the bill so that they are commensurate with the  
          wholesaler(s) paying the fee on that manufacturer's behalf, or  
          simply stating that any single wholesaler paying the  
          Manufacturer Battery Fee on behalf of a manufacturer shall  
          assume responsibility for the entirety of the manufacturer's  
          inventory sold in California. 


          Keeping score: In order to accurately determine how much a  
          person has remitted in Manufacture Battery Fees when determining  
          the amount of a judgment or settlement, DTSC will need to know  
          exactly which manufacturers and wholesalers have remitted fees  
          and how much each remitted. 


          The author may wish to add language requiring the BOE to keep  
          track of how much and from whom the fees were remitted, and  
          require the BOE to transmit that information to DTSC on a  
          regular basis. 


          Core battery charges:  According to a 2007 contracted report to  
          the California Integrated Waste Management Board (CIWMB, which  
          is now CalRecycle), Framework for Evaluating End-of-Life Product  
          Management Systems in California, the need to have disposal  
          options for lead-acid batteries lead to an industry response by  
          BCI to promote model legislation for states to enact.  That  
          resulted in a model that included a landfill ban, a mandatory  
          retailer-take back system, and mandatory collection of deposit  
          on the purchase of a new battery if an old battery is not  
          returned. California adopted a modified version of the model  
          legislation in 1989 with only two of those components:








                                                                    AB 2153


                                                                    Page  13







          1)Prohibit the disposal of a lead-acid battery at a solid waste  
            facility, or on or in any land, surface waters, watercourses,  
            or marine waters (H&S § 25215.2); and, 


          2)Require that retailers accept the trade-in of a spent  
            lead-acid battery by a consumer upon purchase of a new one.  
            (H&S § 25215.3)


          California's laws, therefore, do not identify that a deposit  
          should be added to the sale of batteries.  Despite the lack of a  
          deposit requirement, many retailers voluntarily charge a deposit  
          as an incentive to get the batteries returned, and the deposit  
          charge varies (usually between $15-$18).  If a used battery is  
          returned to the retailer at the time of purchase of a new  
          battery, the deposit is conditionally waived.  The deposit is  
          considered a "core" charge, or deposit. 


          Since it is illegal to dispose of lead-acid batteries in  
          California landfills, and all retailers that sell lead-acid  
          batteries must accept their return for disposal, the core charge  
          is supposed to give retailers a tool to comply with those laws  
          by incentivizing consumers to return their batteries. However,  
          the core charge is unevenly charged and refunded in the retail  
          industry, which has created an inconsistent implementation of  
          the core charge amongst California car battery dealers. 


          Establishing a state-mandated fee-for-recycling will compel all  
          lead-acid battery manufacturers and dealers to comply with the  
          requirements set forth in this bill and prevent an ongoing  
          patchwork of retailer participation, as is the case under the  
                                                 current core charges. 










                                                                    AB 2153


                                                                    Page  14





          Since AB 2153 is intending to replace the existing, voluntary  
          industry core charge with a statutory charge, the author may  
          wish to consider adding language to clarify the charge required  
          under this bill shall supplant any voluntary core charge  
          currently being charged to prevent a consumer from being charged  
          two times by a retailer.  


          Governor's Budget: The May Revise proposed an increase and two  
          positions for DTSC to evaluate listing lead-acid batteries as  
          "priority products" subject to DTSC's Safer Consumer Products  
          regulations. As part of DTSC's Hazardous Waste Reduction  
          Initiative, it will conduct research, engage with stakeholders,  
          evaluate options, and implement recommended actions to better  
          protect the people and environment of California from adverse  
          impacts related to the manufacture, use, recycling, and disposal  
          of lead acid batteries.


          AB 2153 would preclude lead-acid batteries from consideration  
          for inclusion in the Safer Consumer Products Regulations as long  
          as the national recycling rate for lead in batteries determined  
          by the methodology accepted by the US EPA employed in the BCI's  
          National Recycling Rate Study exceeds a to be determined  
          percentage. 


          While the bill is mindful of the Administration's budget  
          proposal, it is in conflict with the direction of that proposal.  
          According to the auto care industry, 99.6% of all lead-acid core  
          batteries are recycled in California. Supposing that statistic  
          is accurate for California, the author will have to consider  
          what percentage could be applied to the bill to render the  
          exemption meaningful. 


          In addition, the proposed exemption for lead-acid batteries  
          would be precedent setting. The intent of the Safer Consumer  
          Product Program is to do a comprehensive analysis of products,  








                                                                    AB 2153


                                                                    Page  15





          chemicals, and exposure pathways, and prioritize the most  
          dangerous chemicals for regulation to protect public health and  
          limit Californians' exposure to hazardous chemicals. 


          Creating an exemption, which would likely be followed up with  
          future statutory exemptions, would weaken the intent of the  
          program and diminish the value the program serves the public. 


          Federal Toxic Substances Control Act (TSCA) reform: Congress is  
          actively working on legislation to update and reform TSCA, the  
          federal chemical policy. One of the versions being considered in  
          the US Senate (Chemical Safety for the 21st Century Act (S.  
          697)), however, contains preemption language that would  
          eliminate state authority to maintain or develop protections  
          against dangerous chemicals before compliance with new federal  
          rules is required; in other words, it would preempt state  
          chemical management laws, such as California's Safer Consumer  
          Products Program. 


          On September 30, 2015, Governor Jerry Brown sent a letter to the  
          Senate Majority Leader asking that the regulatory pause in S.  
          697 be eliminated. Matt Rodriguez, Secretary for Environmental  
          Protection at the California Environmental Protection Agency,  
          also sent a letter asking that S. 697's preemption provisions be  
          removed as it would prevent California from fully implementing  
          Safer Consumer Products program.


          The Administration's letters to Congress on this point  
          underscore the priority of the state to maintain the integrity  
          of the Safer Consumer Products Program.


          Additional issues for consideration: As this bill moves through  
          the Legislature, the author and the Legislature should consider  
          the following issues:








                                                                    AB 2153


                                                                    Page  16







          1)The baseline amount of the "deposit" portion of the fee. The  
            author acknowledges this is an issue to be worked out.  
            Statutorily establishing the core fee (the amount in addition  
            to the nonrefundable Consumer Battery Fee) will ensure  
            consumers pay the same fee statewide.  This is especially  
            important if the refund must be paid regardless of where the  
            battery is returned.
          2)Restoring current law under H&S § 25215.2 for returning  
            lead-acid batteries to a dealer to prevent any limitation on  
            consumer flexibility for returning spent batteries to a  
            dealer. 


          3)Clarification of the recycling symbol to be included on all  
            lead-acid batteries. 


          4)Expanding how the fee revenues in the Lead-Acid Battery  
            Cleanup Fund can be used to be more consistent with the April  
            14 version of the bill. 


          5)Correcting confusion over when DTSC can take action and when  
            the Lead-Acid Battery Cleanup Fund is extinguished to  
            eliminate any constraint on DTSC from recovering costs from an  
            RP. 

          6)Proportionality of wholesaler payment of the Manufacturer  
            Battery Fee and the total manufacturer's battery sales.   
          7)Requiring the BOE to keep track of how much and from whom the  
            fees were remitted, and requiring the BOE to transmit that  
            information to DTSC on a regular basis. 

          8)The differences between the Green Chemistry proposals in the  
            bill and the impacts on the Governor's proposed budget.
          9)To prevent obfuscating DTSC's budget processes for funding  
            hazardous waste cleanup, consider how language impacts DTSC's  








                                                                    AB 2153


                                                                    Page  17





            current process. 


          10)Eliminating prohibitions on loans to other programs. The  
            Legislature has used loans from state funds to balance the  
            budget, and restricting loans restricts the budgeting process  
            for future legislatures. 


          11)Clarifying the charge required under this bill shall supplant  
            any voluntary core charge currently being charged to prevent a  
            consumer from being charged two times by a retailer. 
             
          REGISTERED SUPPORT / OPPOSITION:




          Support


          Action Now


          Battery Council International


          California Communities Against Toxics


          California Labor Federation


          California Safe Schools 


          Coalition For A Safe Environment 










                                                                    AB 2153


                                                                    Page  18





          Del Amo Action Committee


          Desert Citizens Against Pollution


          Healthy Homes Collaborative


          Motor and Equipment Manufacturers Association


          Society for Positive Action




          Opposition


          None on file. 




          Analysis Prepared by:Paige Brokaw / E.S. & T.M. / (916) 319-3965