BILL ANALYSIS                                                                                                                                                                                                    

                                                                    AB 2243

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          Date of Hearing:  April 21, 2016


                           Sebastian Ridley-Thomas, Chair

          AB 2243  
          (Wood) - As Introduced February 18, 2016

                              RECONSIDERATION/VOTE ONLY

          2/3 vote.  Fiscal committee.

          SUBJECT:  Medical cannabis:  taxation:  cannabis production and  
          environment mitigation

          SUMMARY:  Enacts the Medical Cannabis Tax Law (MCTL).   
          Specifically, this bill:  

          1)Imposes, for the privilege of distributing "medical cannabis  
            flowers", "medical cannabis leaves", and "immature medical  
            cannabis plants", a tax upon all "licensed cultivators" at the  
            following rates:

             a)   $9.25 per ounce of "medical cannabis flowers";


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             b)   $2.75 per ounce of "medical cannabis leaves"; and, 

             c)   $1.25 per "immature medical cannabis plant".  

          2)Specifies that the "licensed distributor" shall collect the  
            tax from the "licensed cultivator" and separately state the  
            amount of tax imposed on the purchase order, which shall be  
            given by the "licensed distributor" to the "licensed  
            cultivator" at the time of sale.  

          3)Exempts from the tax sales by a "licensed cultivator" that the  
            state is prohibited from taxing under the Constitution or laws  
            of the United States (U.S.) or the Constitution of this state.  
             Any claim for exemption from the tax shall be made to the  
            State Board of Equalization (BOE) in the manner prescribed by  
            the BOE.  

          4)Requires the Legislative Analyst's Office to review regularly  
            the tax levels established by this bill, at a minimum of every  
            other year, beginning in 2018, and to make recommendations to  
            the Legislature on appropriate adjustments that would further  
            the goals of addressing public safety and the environmental  
            impacts caused by the proliferation of cannabis cultivation.  

          5)Defines "medical cannabis flowers" as the flowers of a  
            cannabis plant, excluding the leaves and stems, that are  
            intended to be sold for use by medical cannabis patients in  
            California under the Compassionate Use Act of 1996  
            (Proposition 215), found in Health and Safety Code Section  

          6)Defines "medical cannabis leaves" as all parts of a cannabis  
            plant, other than cannabis flowers, that are intended to be  


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            sold for use by medical cannabis patients in California under  
            Proposition 215.  

          7)Defines an "immature medical cannabis plant" as a cannabis  
            plant with no observable flowers or buds, that is intended to  
            be sold for use by medical cannabis patients in California  
            under Proposition 215.  

          8)Defines a "licensed cultivator" as a person licensed as a  
            cultivator under the Medical Marijuana Regulation and Safety  
            Act (MMRSA), found in Business and Professions Code (B&PC)  
            Section 19300 et seq.  

          9)Defines a "licensed distributor" as a "distributor" under B&PC  
            Section 19300.5.  

          10)Charges the BOE with administering and collecting the new tax  
            under the Fee Collection Procedures Law, found in Revenue and  
            Taxation Code (R&TC) Section 55001 et seq.  

          11)Specifies that a licensed cultivator is liable for the tax  
            until it has been paid to the state, except that payment to  
            the licensed distributor relieves the licensed cultivator from  
            further liability for the tax.  

          12)Authorizes the BOE to prescribe, adopt, and enforce  
            regulations relating to the implementation, administration,  
            and enforcement of the MCTL, including applicant requirements,  
            collections, reporting, refunds, and appeals.  

          13)Authorizes the BOE to prescribe, adopt, and enforce any  
            emergency regulations as necessary to implement the MCTL.  


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          14)Provides that the tax is due and payable to the BOE quarterly  
            on or before the last day of the month following each calendar  

          15)Requires a return for the preceding calendar quarter to be  
            filed with the BOE on or before the last day of the month  
            following each calendar quarter.  Returns shall be  
            authenticated in a form or pursuant to methods as the BOE  

          16)Establishes the Cannabis Production and Environment  
            Mitigation Fund (Fund) in the State Treasury.  All taxes,  
            interest, penalties, and other amounts collected and paid to  
            the BOE, less payments of refunds and costs of administration,  
            shall be deposited in the Fund.

          17)Provides that, notwithstanding Government Code Section 13340,  
            all moneys deposited in the Fund are to be continuously  
            appropriated, without regard to fiscal year, in the following  

             a)   30% to an unspecified entity for disbursement for local  
               law enforcement-related activities pertaining to illegal  
               cannabis cultivation.  Such funds shall be allocated on a  
               competitive grant application process administered by the  
               unspecified entity;

             b)   30% to the Natural Resources Agency to fund a  
               competitive grant program for environmental cleanup  
               restoration and protection of public and private lands that  
               have been damaged by illegal cannabis cultivation, as  
               specified.  Such funds shall be prioritized to restoration  


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               and cleanup projects, on public or private lands, based on  
               the level of damages that have occurred.  At least 35% of  
               the funds shall be used for these purposes related to  
               public lands, including parks managed by the California  
               Department of Parks and Recreation, and at least 20% of the  
               funds shall be used for these purposes related to private  

             c)   30% to the multiagency task force, the Department of  
               Fish and Wildlife and State Water Resources Control Board,  
               to address the environmental impacts of cannabis  
               cultivation on public and private lands in California and  
               fund other state enforcement-related activities pertaining  
               to illegal cannabis cultivation; and,

             d)   10% to the Bureau of Medical Marijuana Regulations, and  
               other state agencies or departments that the bureau  
               determines are appropriate, to conduct ongoing studies of  
               areas that may create challenges to compliance of the  
               MMRSA, including financial transactions, allowable tax  
               deductions, and the public safety implications of a cash  
               industry.  The bureau or other state agencies or  
               departments shall prepare reports on the results of those  
               studies and submit those reports to the Legislature on or  
               before January 1, 2020, and on or before January 1, every  
               two years thereafter.  

          18)Requires the BOE to submit a report to the Legislature on the  
            total amount of revenue that was collected for the two-year  
            period beginning on this tax's operative date.  The report  
            shall be due on or before the last day of the month commencing  
            180 days after the two-year period.  

          19)Provides that this act shall become operative on or after  
            [sic] the first day of the first calendar quarter commencing  


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            more than 270 days after adequate funding has been received by  
            the BOE to implement and administer this bill.  The BOE shall  
            post a notice on its Internet Web site when this condition has  
            been satisfied.  

          20)Specifies that funds for the establishment and support of the  
            activities required under this bill shall be advanced as a  
            General Fund or special fund loan, and shall be repaid by the  
            BOE from the initial proceeds from taxes collected, no later  
            than six months after the bill's operative date.  

          EXISTING FEDERAL LAW prohibits the manufacture, possession,  
          sale, or distribution of marijuana.  [21 United States Code  
          Section 841 et seq.]      


          1)Imposes a sales tax on retailers for the privilege of selling  
            tangible personal property (TPP), absent a specific exemption.  
             The tax is based upon the retailer's gross receipts from TPP  
            sales in this state.

          2)Imposes a complimentary use tax on the storage, use, or other  
            consumption of TPP purchased out-of-state and brought into  
            California.  The use tax is imposed on the purchaser, and  
            unless the purchaser pays the use tax to an out-of-state  
            retailer registered to collect California's use tax, the  
            purchaser remains liable for the tax.  The use tax is set at  
            the same rate as the state's sales tax and must generally be  
            remitted to the BOE.

          3)Applies the sales and use tax (SUT) to retail sales of  
            marijuana, including medical marijuana, to the same extent as  
            any other retail sale of TPP. 


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          4)Provides a SUT exemption for medicines, when the medicines  

             a)   Prescribed by an authorized person and dispensed on a  
               prescription filled by a pharmacist;

             b)   Furnished by a licensed physician to his or her own  
               patient; or,

             c)   Furnished by a health facility for treatment pursuant to  
               a licensed physician's order, or sold to a licensed  
               physician.  [R&TC Section 6369]   

          5)Defines "cannabis" as all parts of the plant Cannabis sativa  
            Linnaeus, Cannabis indica, or Cannabis ruderalis, whether  
            growing or not;  the seeds thereof;  the resin, whether crude  
            or purified, extracted from any part of the plant;  and every  
            compound, manufacture, salt, derivative, mixture, or  
            preparation of the plant, its seeds, or resin.  [B&PC Section  

          6)Defines "distribution" as the procurement, sale, and transport  
            of medical cannabis and medical cannabis products between  
            licensed entities.  [B&PC Section 19300.5]   

          FISCAL EFFECT:  The BOE estimates that this bill's new tax would  
          generate roughly $77 million in revenues annually.   
          Additionally, BOE staff estimates that this bill would generate  
          roughly $6.3 million in state and local SUT revenues annually.   
          Committee staff notes, however, that these estimates assume a  
          100% compliance rate.  


          1)The author has provided the following statement in support of  


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            this bill:

               We are seeing unpermitted land grading and road  
               construction, illegal stream diversions, discharge of  
               sediments, and pollutants into waterways, as well as  
               contamination of water and soil by pesticides,  
               rodenticides, fertilizers and fuels.  Mammals, birds and  
               fish are dying horrible deaths from poisons used to protect  
               crops and left behind long after the growers leave an area.  
                These toxins seep into our water supply.

               Water is being held from traditional agriculture to ensure  
               there is water in the streams for endangered fish, but  
               instead it is being pumped onto illegal marijuana farms and  
               poisoned by chemicals.  Last year, Sproul Creek, in  
               Humboldt County, ran dry for the first time and officials  
               believe it was due in large part to illegal diversions of  
               water for marijuana.

               The Medical Marijuana Regulation Safety Act, specifically  
               AB 243, created an environmental regulatory structure to  
               address many of these environmental damages, such as the  
               establishment of a permanent and statewide Watershed  
               Enforcement Team (WET), but the funding component was  
               removed in AB 243 before the bill reached the Governor's  


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               AB 2243 reestablishes an excise tax for medical marijuana  
               that is charged to a licensed medical cannabis cultivator  
               and collected by a licensed medical marijuana distributor.   
               The funds collected will pay for environmental remediation,  
               local law enforcement, and the WET program to address  
               illegal marijuana related activities.

          2)This bill is supported by the California Association of  
            Professional Scientists, which notes the following:  

               The Legislature recently passed, and the Governor signed,  
               the Medical Marijuana Regulation and Safety Act (the Act),  
               which created a state regulatory licensing structure for  
               medical marijuana.  The Act brings sensible regulation,  
               oversight and environmental protections to California's  
               medical marijuana industry.  Irresponsible marijuana  
               cultivation is threatening California's environment; it is  
               threatening the state's water supply, the state's water  
               quality and the lives and habitat of endangered and other  
               sensitive species.  In an effort to protect the  
               environment, the State Water Resources Control Board and  
               the California Department of Fish and Wildlife requested  
               funding from the Governor to create a taskforce to address  
               the damages to natural resources from marijuana  
               cultivation.  [. . .]

               The Act will help ensure that watersheds and wildlife  
               habitat throughout the state will be protected and, while  
               proposed funding is helpful, there are still gaps that need  
               to be addressed to fully protect the environment.  

               The Act did not include environmental remediation funding  
               to combat illegal marijuana activities and there is a dire  
               need for another funding mechanism focused on illegal  


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               marijuana activities.  AB 2243 will address that oversight  
               and provide that funding.  

          3)This bill is opposed by California NORML, which notes the  

               We urge the committee to reject AB 2243 (Wood), which would  
               impose a new $9.75/ounce tax on the cultivation of  
               medical-only marijuana.  At current wholesale prices of  4  
               $1,500 / lb, this is tantamount to a 10% tax on the value  
               of marijuana.  This would be in addition to the current  
               7.5+% sales tax plus various local business taxes imposed  
               by some localities.  

               The proposed tax is unreasonably high and burdensome to  
               low-income patients who need marijuana for medicine.  No  
               other state has a comparably high tax on medical (only)  

               The proposed tax will also likely be counterproductive  
               insofar as it will encourage the diversion of marijuana to  
               the untaxed, unregulated adult-use market.  

               [. . .]

               At this time when providers already face burdensome new  
               costs and regulations under MMRSA, it is unwise and unfair  
               to impose further costs on those trying to comply with the  
               law.  It is unfair to tax the minority of law-abiding,  
               medical-only suppliers for all of the costs due to illicit,  
               black-market recreational use traffickers.  And it is  
               unfair to the many low-income patients who have legitimate  
               medical need for marijuana to impose such a tax on their  


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          4)The BOE notes the following in its staff analysis of this  

              a)   Proposed tax is complicated  :  "This bill proposes a  
               complicated tax scheme that departs from other  
               distributor-level tax structures administered by the BOE.   
               [. . .]  The MCTL requires a licensed distributor to issue  
               a purchase order to document the tax imposed. However, a  
               purchase order is simply a merchandise order and not  
               documentation of a sale or distribution. This method could  
               be problematic when the distributor does not purchase the  
               quantity specified on the purchase order. Further, it is  
               unclear how a distributor, who makes the payment rather  
               than receives a payment, can collect the tax. Does the  
               distributor "short" his or her payment to the cultivator by  
               the tax amount? 

               BOE staff suggests imposing the tax on the "first sale" or  
               "distribution" of flowers, leaves, and immature plants in  
               this state. The taxpayer in this case would be defined as  
               the person who makes the first sale or distribution of  
               cannabis flowers, leaves, and immature plants in this  
               state.  A sale from a cultivator to a distributor would be  
               excluded from the definition of sale or distribution thus  
               imposing the tax on the distributor's sale or distribution.  
                This mechanism closely follows the imposition of the  
               cigarette and tobacco products tax.  In addition to the  
               suggested revisions to the proposed tax, BOE staff also  
               suggests revising the MCTL's definitions to conform to the  
               imposition and collection change." 

              b)   Lack of license should not exclude tax liability  : "This  
               bill imposes the medical cannabis tax upon a cultivator.   


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               The bill defines licensed cultivator to mean: a person that  
               is  licensed  as a cultivator under the MMRSA.  The bill  
               requires tax collection by a  licensed  distributor.  Does a  
               cultivator or distributor escape the tax if they do not  
               comply with the MMRSA's licensing requirements? (Emphasis  
               in original)"

              c)   Do cultivators always sell to distributors  ?  "Under the  
               MMRSA, [B&PC] Section 19326 specifies certain restrictions  
               on medical cannabis.  For example, the statute requires a  
               licensed cultivator or licensed manufacturer "to send" all  
               medical cannabis to a distributor for quality assurance,  
               inspection, and batch testing prior to distribution to a  
               dispensary.  Accordingly, the MMRSA allows a cultivator to  
               sell medical cannabis directly to a manufacturer.  That  
               manufacturer must send the finished product to a  
               distributor prior to distribution to a dispensary.  Since  
               the MMRSA does not require a cultivator to sell to a  
               distributor, how would the tax be imposed and collected if  
               a cultivator sells directly to a manufacturer or if the  
               cultivator "sends" (does not sell) the medical cannabis to  
               the distributor for testing?" 

              d)   Proposed tax is subject to sales tax  :  "The total retail  
               sales price of [TPP] is subject to the sales or use tax,  
               unless specifically exempted or excluded by law.

               To be reimbursed for the proposed new tax, a distributor  
               would likely incorporate the additional tax into the sales  
               price of the medical cannabis. The sales tax applies to the  
               entire sales price of medical cannabis, including any  
               increase in the retail sales price to the consumer due to  
               the prior imposition of the medical cannabis tax."  

              e)   Future track and trace tax program  :  "The bill requires  


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               a licensed distributor to collect and remit the tax and a  
               return to the BOE quarterly.  The bill does not  
               specifically allow tax payment through the use of stamps,  
               other markings capable of encrypting certain tax  
               information, or track and trace technology.  

               BOE staff suggests amending the bill to provide the BOE  
               authority to prescribe by regulation a method and manner  
               for the medical cannabis tax payment.  This suggestion  
               builds upon existing requirements for the BOE to adopt a  
               track and trace system ([R&TC] Section 31020) and for the  
               CDFA to establish a unique identifier program ([B&PC]  
               Section 19335)."

              f)   Suggested technical amendments  :  "The BOE staff  
               recommends the following amendments: 

               i)     The bill specifies two distinct points of tax  
                 imposition: sale and distribution. The bill should  
                 specify only one point of taxation to eliminate  

               ii)    The bill should require licensed distributors to  
                 file electronic returns, consistent with other  
                 BOE-administered tax programs. 

               iii)   The bill should allow licensed distributors to remit  
                 the medical cannabis tax by means other than an  
                 electronic funds transfer (EFT) when they are unable to  
                 obtain a bank account.  Under the law [citation omitted],  
                 certain reporting requirements are imposed on tax and  
                 feepayers that have substantial tax or fee liabilities.  
                 Specifically, tax and feepayers with monthly tax  
                 liabilities that average $20,000 or more must remit their  


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                 tax and fee payments via an EFT under BOE-prescribed  

          5)Committee staff comments:

              a)   An overview of federal law :  Federal law prohibits the  
               manufacture, possession, sale, or distribution of  
               marijuana.  Congress enacted the Controlled Substances Act  
               (CSA) as part of the Comprehensive Drug Abuse Prevention  
               and Control Act of 1970.  The CSA sets forth five  
               "schedules" of specified drugs and other substances  
               designated "controlled substances."  For a drug or other  
               substance to be designated as a "Schedule I" controlled  
               substance, it must be found that the substance "has a high  
               potential for abuse", and has "no currently accepted  
                                                         medical use in treatment in the United States".  Federal  
               law lists marijuana as a Schedule I controlled substance,  
               deemed to have no accepted medical use.

                i)     The Cole Memo  :  On August 29, 2013, the U.S.  
                 Department of Justice issued guidance to federal  
                 prosecutors regarding cannabis enforcement under the CSA  
                 (referred to as the "Cole Memo").  The Cole Memo  
                 reiterated the Department's commitment to enforcing the  
                 CSA consistent with Congress' determination that cannabis  
                 is a dangerous drug that provides a significant source of  
                 revenue to large-scale criminal enterprises, gangs, and  
                 cartels.  In furtherance of these objectives, the Cole  
                 Memo instructed Department attorneys and law enforcement  
                 officials to focus on the following eight enforcement  

                  (1)       Preventing the distribution of marijuana to  


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                  (2)       Preventing revenue from marijuana sales from  
                    going to criminal enterprises, gangs, and cartels;

                  (3)       Preventing the diversion of marijuana from  
                    states where it is legal under state law in some form  
                    to other states;

                  (4)       Preventing state-authorized marijuana activity  
                    from being used as a cover or pretext for the  
                    trafficking of other illegal drugs or other illegal  

                  (5)       Preventing violence and the use of firearms in  
                    the cultivation and distribution of marijuana;

                  (6)       Preventing drugged driving and the  
                    exacerbation of other adverse public health  
                    consequences associated with marijuana use;

                  (7)       Preventing the growing of marijuana on public  
                    lands and the attendant public safety and  
                    environmental dangers posed by marijuana production on  
                    public lands; and,

                  (8)       Preventing marijuana possession or use on  
                    federal property.  

                 Under the Cole Memo, these priorities will guide the  
                 Department's enforcement of the CSA against  
                 marijuana-related conduct.  While the Cole Memo's  
                 guidance was issued in response to recent marijuana  


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                 legalization initiatives in other states, it applies to  
                 all Departmental marijuana enforcement nationwide.  

                ii)    Public Law 113-235  :  Operative December 16, 2014,  
                 Public Law 113-235 prohibits the U.S. Department of  
                 Justice from using funds to prevent specified states,  
                 including California, from implementing laws that  
                 authorize the use, distribution, possession, or  
                 cultivation of medical marijuana.  

              b)   An overview of state law  :  The California Uniform  
               Controlled Substances Act prohibits, except as authorized,  
               the possession, cultivation, transportation, and sale of  
               marijuana and marijuana derivatives.  Under Proposition  
               215, however, existing law does authorize a patient (or the  
               patient's primary caregiver) to cultivate or possess  
               marijuana for the patient's medical use when recommended by  
               a physician, as specified.

                i)     SB 420  :  SB 420 (Vasconcellos), Chapter 875,  
                 Statutes of 2003, established statewide guidelines for  
                 Proposition 215 enforcement.  Specifically, SB 420 called  
                 for the establishment of a voluntary program for the  
                 issuance of identification cards to qualified patients.   
                 SB 420 further specified that no patient or primary  
                 caregiver in possession of a valid identification card  
                 shall be subject to arrest for possession,  
                 transportation, delivery, or cultivation of medical  
                 marijuana, as specified.    

                ii)    Medical Marijuana Regulation and Safety Act  :  In  
                 2015, the Legislature enacted the MMRSA through a package  
                 of bills establishing a comprehensive licensing and  
                 regulatory framework for medical marijuana.   
                 Specifically, the MMRSA consists of three bills:  (1) SB  


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                 643 (McGuire), Chapter 719, Statutes of 2015; (2) AB 243  
                 (Wood), Chapter 688, Statutes of 2015; and, (3) AB 266  
                 (Bonta), Chapter 689, Statutes of 2015.  

                 Among its provisions, the MMRSA established the Bureau of  
                 Medical Marijuana Regulation within the Department of  
                 Consumer Affairs to oversee and enforce the state's  
                 medical marijuana regulations, in collaboration with the  
                 California Department of Public Health and the California  
                 Department of Food and Agriculture (CDFA).  Additionally,  
                 the law established categories of licenses for various  
                 medical marijuana activities, such as cultivation,  
                 manufacturing, distribution, transportation, and sale.   
                 AB 266 also added R&TC Section 31020 to require the BOE,  
                 in consultation with the CDFA, to adopt a system to  
                 report commercial cannabis and cannabis product movement  
                 throughout the distribution chain (i.e., "track and  
                 trace").  The adopted system must employ secure packaging  
                 and provide information to the BOE.  Section 31020 also  
                 requires the system to capture, at a minimum, all of the  

                  (1)       The amount of tax due by the designated  

                  (2)       The name, address, and license number of the  
                    designated entity that remitted the tax;  

                  (3)       The name, address, and license number of the  
                    succeeding entity receiving the product;

                  (4)       The transaction date; and, 


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                  (5)       Any other information the BOE deems necessary  
                    for the taxation and regulation of marijuana and  
                    marijuana products.  

              c)   What would this bill do  ?  This bill would impose, for  
               the privilege of distributing medical cannabis flowers,  
               medical cannabis leaves, and immature medical cannabis  
               plants, a tax on all licensed cultivators of cannabis.   
               Specifically, this bill would require 

              licensed distributors to collect the tax from licensed  
               cultivators, and separately state the amount of tax imposed  
               on each purchase order.  Funds generated from the new tax  
               would be used for, among other things, both  
               cannabis-related law enforcement activities and efforts to  
               address the environmental impacts of cannabis cultivation  
               on public and private lands in California.  
              d)   How does this bill fit in with the changing legal  
               landscape  ?  There is at least one marijuana legalization  
               initiative currently being circulated for signatures.   
               Specifically, Proposed Initiative 1762 would legalize both  
               marijuana and hemp under state law.  The initiative would  
               also impose a state excise tax on retail sales of marijuana  
               equal to 15% of the sales price, along with state  
               cultivation taxes on marijuana of $9.25 per ounce of  
               flowers and $2.75 per ounce of leaves.  In addition, the  
               proposed initiative would exempt medical marijuana from  
               some taxation.  As such, it is unclear to Committee staff  
               how the present bill's tax regime would be impacted by the  
               enactment of a subsequent initiative establishing a new tax  
               regime for cannabis in California.  

              e)   Related legislation  :  SB 987 (McGuire), of the current  


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               Legislative Session, would impose a 15% tax on medical  
               marijuana purchased from a retailer of medical marijuana,  
               beginning January 1, 2018.  SB 987 would only become  
               operative, however, if Proposed Initiative 1762 referenced  
               above is not approved by the voters at the November 8, 2016  
               statewide general election.  

              f)   Suggested technical amendments  :  Committee staff  
               recommends the following technical amendments be adopted:

               i)     On page 7, in line 9, strike "is" and insert "are"; 

               ii)    On page 7, in line 10, strike "of" and insert  

               iii)   On page 7, in line 16, strike "report" and insert  
                 "reports"; and, 

               iv)    On page 7, in line 34, strike "or" and insert "and".  



          California Association of Professional Scientists 

          California Cattlemen's Association


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          California League of Conservation Voters

          California Trout

          Central Coast Forest Association

          The Trust for Public Land


          Americans for Safe Access

          California NORML

          Consortium Management Group

          UCBA Trade Association

          Analysis Prepared by:M. David  Ruff / REV. & TAX. / (916)  


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