BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                              Senator Wieckowski, Chair
                                2015 - 2016  Regular 
           
          Bill No:            AB 2564
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          |Author:    |Cooper                                               |
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          |Version:   |4/20/2016              |Hearing      | 6/29/2016      |
          |           |                       |Date:        |                |
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          |Urgency:   |No                     |Fiscal:      |Yes             |
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          |Consultant:|Rebecca Newhouse                                     |
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          SUBJECT:  Air Quality Improvement Program:  Clean Vehicle Rebate  
          Project.

            ANALYSIS:
          
          Existing law:  
          
          1) Establishes the Air Quality Improvement Program (AQIP), to be  
             administered by the California Air Resources Board (ARB) in  
             consultation with local air districts, to provide competitive  
             grants to fund projects to reduce criteria air pollutants,  
             improve air quality, and support research to improve the air  
             quality impacts of alternative fuels and vehicles, vessels,  
             and equipment technologies. (Health and Safety Code (HSC)  
             §44274).

          2) Establishes the Charge Ahead Initiative administered by ARB  
             with the goals of reaching at least one million zero-emission  
             and near-zero-emission vehicles by January 1, 2023, and  
             increasing accessibility for disadvantaged, low-income, and  
             moderate-income communities. ARB is required to establish  
             programs that further increase access to and direct benefits  
             for disadvantaged, low-income, and moderate-income  
             communities and consumers from electric transportation. (HSC  
             §44258 et seq.)

          3) Under the California Global Warming Solutions Act of 2006  
             (also known as AB 32), requires ARB to determine the 1990  
             statewide greenhouse gas (GHG) emissions level and approve a  
             statewide GHG emissions limit that is equivalent to that  







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             level, to 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  
             these regulations.  (HSC §38500 et seq.) 

          4) Establishes the Greenhouse Gas Reduction Fund (GGRF) in the  
             State Treasury, requires all moneys, except for fines and  
             penalties, collected pursuant to a market-based mechanism be  
             deposited in the fund.  (Government Code §16428.8)

          5) Prohibits the state from approving allocations for a measure  
             or program using GGRF moneys except after determining that  
             the use of those moneys furthers the regulatory purposes of  
             AB 32, and requires moneys from the GGRF be used to  
             facilitate the achievement of reductions of GHG emissions in  
             California.  (HSC §39712)

          This bill requires ARB, in consultation with the California  
          Energy Resources Conservation and Development Commission (CEC),  
          local air districts and the public, to adopt regulations for the  
          Clean Vehicle Rebate Project (CVRP), adopted pursuant to AQIP,  
          that do the following: 

          1) Lower CVRP income limits to $125,000 for single filers,  
             $170,000 for heads of households, and $250,000 for joint  
             filers, as specified, for all eligible vehicles except fuel  
             cell electric vehicles. 

          2) Prioritize rebate payments for low-income consumers.

          3) Increase rebate amounts by $500 per rebate for consumers with  
             household incomes less than or equal to 300% of the federal  
             poverty level for all eligible vehicles. 

          4) Include outreach to low-income households. 


            Background
          
          1) Background on Clean Vehicle Rebate Project. AB 118 (Núñez,  
             Chapter 750, Statutes of 2007) established the Alternative  
             and Renewable Fuels and Vehicle Technology (ARFVT) program,  
             the Enhanced Fleet Modernization Program (EFMP), and the Air  
             Quality Improvement Program (AQIP).  The three programs are  








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             intended to promote vehicle and fuel technology that reduces  
             air pollution and GHG emissions statewide. AB 118 provides  
             funding to the programs through surcharges on vehicle and  
             vessel registrations, which was extended by AB 8 (Perea,  
             Chapter 401, Statutes of 2013) until 2023.

             The primary purpose of the AQIP, administered by ARB in  
             consultation with local air districts, is to fund projects to  
             reduce criteria air pollutants, improve air quality, and  
             provide funding for research on air quality impacts of  
             alternative fuels and vehicles.  

             Pursuant to their authority under AQIP, ARB developed the  
             Clean Vehicle Rebate Project (CVRP), administered by ARB's  
             contractor, the California Center for Sustainable Energy. The  
             CVRP is intended to encourage and accelerate zero- and  
             near-zero emission, on-road light-duty vehicle deployment and  
             technology innovation. CVRP provides rebates for purchasing  
             or leasing a new battery electric vehicle (BEV) of up to  
             $4,000, up to $3,000 for a plug-in hybrid electric vehicle,  
             and up to $6,000 for a hydrogen fuel cell electric vehicle  
             (FCEV).

             CVRP supplemented by GGRF. The demand for CVRP has steadily  
             increased over time and surpassed funding available through  
             AB 118. Originally the funding gap was covered with loans  
             from various funds. In the 2014-15 Budget Act, $200 million  
             was appropriated to AQIP from the Greenhouse Gas Reduction  
             Fund (GGRF). Last year, CVRP was one of the few  
             non-continuously appropriated programs to receive an  
             appropriation from GGRF ($90 million for low carbon  
             transportation investments, with ARB approving $75 million of  
             that for CVRP). To date, CVRP has spent $320 million ($178  
             million from GGRF) to provide over 150,000 rebates. ARB  
             proposes to spend an additional $230 million on CVRP from the  
             $500 million requested appropriation for low carbon  
             transportation and fuels in the Governor's 2016-17 fiscal  
             year budget. Funding for CVRP is currently exhausted, and all  
             applications for rebates submitted after June 10, 2016 are  
             being placed on a rebate waitlist.

          2) CVRP statistics. Survey data compiled by the Center for  
             Sustainable Energy reveals that 77% of the survey respondents  
             have household incomes of over $100,000/year, with about half  








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             of those consumers at household incomes over $200,000. The  
             data also shows that three quarters of the CVRP rebate  
             recipients are men, and that 83% of all survey respondents  
             are college graduates. Of the 150,000 rebates, about 9,300 or  
             6%, have gone to residents of disadvantaged communities.  
             Approximately 22,000 rebates ($56 million) were used on  
             vehicles whose prices range from $70,000 to over $100,000.

          3) 1.5 million clean cars by 2025. In 2012, The Governor's  
             Executive Order B-16-2012 set milestones for zero-emission  
             vehicles, including a target of over 1.5 million  
             zero-emission vehicles will be on California roads by 2025.  
             Additionally, SB 1275 (de Leon, Chapter 530, Statutes of  
             2014), through the Charge Ahead Initiative established a goal  
             of one million zero and near-zero emission vehicles by 2023.   
             Currently, Californians have purchased around 200,000 of  
             these vehicles. 

          4) SB 1275 and income cap. Amidst concerns that the CVRP was  
             primarily benefiting wealthy car buyers who would have likely  
             bought an alternative vehicle regardless of the rebate,  
             legislation was introduced in 2014 to address issues of  
             equity and cost effectiveness in the program. SB 1275 (de  
             León, Chapter 530, Statutes of 2014) requires ARB to increase  
             access to zero-emission and near-zero emission vehicles for  
             lower and moderate income Californians and disadvantaged  
             communities.  SB 1275 also required eligibility to be limited  
             based on income.  In response, ARB, on March 28, 2016, set an  
             income cap of $250,000 for single filers, $340,000 for  
             head-of-household filers, and c) $500,000 for joint filers.   
             According to ARB, these income eligibility limits are  
             consistent with Proposition 30, approved by California voters  
             in 2012.  

             Additionally, ARB modified the program to increase rebates by  
             $1,500 for consumers with household incomes less than or  
             equal to 300% of the federal poverty level (about $73,000 for  
             a family of four).

             According to ARB's approved funding plan that proposed the  
             income eligibility limits, "The income eligibility limit  
             should support continued growth of the ZEV market to meet the  
             broader SB 1275 goals to deploy 1 million ZEVs by 2023 and  
             establish a self-sustaining market and the Governor's goal of  








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             1.5 million ZEVs by 2025. To meet this principle, staff is  
             striving to establish income eligibility for the project in a  
             way that targets incentives towards those likely to value the  
             rebate most in deciding to make a ZEV purchase." In response  
             to stakeholders recommending lower income eligibility limits  
             for CVRP rebates, the plan states, "[Staff] is concerned that  
             if the limit is set too low it would limit growth of the ZEV  
             market at this key early stage thereby impacting California's  
             ability to meet the ZEV deployment targets established by SB  
             1275 and the Governor."

             This bill reduces the current CVRP income eligibility caps by  
             half, and increases the rebate for those at or below 300% of  
             the federal poverty level by $500. 
            
          Comments
          
          1) Purpose of Bill.  According to the author, "AB 2564 aims to  
             make clean vehicles more accessible to California drivers  
             living in communities with poor air quality by limiting  
             eligibility by income, increasing rebates levels for  
             lower-income consumers and improving outreach."

          2) Regulations.  AB 118 requires ARB to administer AQIP, in  
             consultation with local air districts, and to develop  
             guidelines to implement the program. AB 118 specifies that  
             prior to adoption of the guidelines, ARB is required to hold  
             at least one public hearing, and to hold at least three  
             public workshops in different regions of the state. The  
             Office of Administrative Law (OAL) approved regulations  
             implementing AQIP in 2009. 

             The CVRP program, adopted pursuant to authority under AQIP,  
             is not currently implemented through a regulatory process.  
             Instead, each fiscal year, ARB adopts a funding plan for  
             programs funded through AQIP, including CVRP.  The 2015-16 FY  
             plan for AQIP adjusted income level eligibility for CVRP  
             rebates and increased rebate levels for low-income consumers.  


             AB 2564 would require ARB to adjust CVRP income eligibility  
             levels and increase rebates for low-income consumers through  
             a regulatory process, which entails following the  
             administrative procedures act, and final approval by OAL. As  








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             regulatory processes can be lengthy, the changes required in  
             this bill may not take effect until 2018. 

          3) Income limits. As noted in the background, ARB recently  
             established income eligibility limits for CVRP rebates. In  
             setting these thresholds, ARB staff noted the goal of better  
             targeting those consumers who are influenced in their  
             decision to buy a ZEV by the availability of rebate.  AB 2564  
             sets income eligibility levels that reduce ARB's income  
             thresholds by half. 

             Although income limits at reasonable levels is a simple, and  
             potentially effective method of targeting low and  
             middle-income consumers who place greater weight on  
             availability of clean vehicles when making decisions to buy a  
             zero-emission or near-zero emission vehicles, setting these  
             income limits at a level that is too low may impede market  
             adoption in certain areas.  Consumers with an income that  
             would make them high-income earners in some areas of the  
             state might be middle-income earners in high cost of living  
             areas, such as Santa Clara and Marin counties, and therefore  
             may place more weight on rebates when deciding what type of  
             car to buy.  ARB staff, in the AQIP investment plan for FY  
             2016-17, expressed concern that lowering CVRP income limits  
             beyond their recommendations ($250,000 for single filers,  
             $500,000 for joint filers) could negatively impact ZEV market  
             development in the state. 

          4) Premature?  As ARB just recently established income caps at  
             the end of March for CVRP-a little over two months prior to  
             the depletion of CVRP funds-this measure may be premature. 

             Additionally, AB 2654, by setting CVRP limits in statute,  
             removes ARB's discretion to adjust income limits based on  
             market developments or any other factors.

             If the committee believes this measure is necessary, an  
             amendment is needed to allow ARB to increase the income  
             limits if ARB finds that the income caps pursuant to this  
             measure are negatively impacting the goals of the program.
            Related/Prior Legislation
          
            AB 1851 (Gray) creates and expands a broad array of incentive  
          programs to increase the sales and use of certain clean air  








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          vehicles. The bill was held on the Assembly Appropriations  
          suspense file.

          AB 1710 (Calderon), requires ARB, in coordination with CEC, on  
          or before    January 1, 2019, to develop and implement a  
          comprehensive program to promote advanced-technology light-duty  
          vehicle deployment in the state to drastically increase the use  
          of ZEVs to meet the state's emissions reduction goals.  The bill  
          was held on the Assembly Appropriations suspense file.
          
          SOURCE:                    Author  

           SUPPORT:               

          Rural County Representatives of California
           
           OPPOSITION:    

          California Electric Transportation Coalition
          The Alliance of Automobile Manufacturers  

           ARGUMENTS IN  
          SUPPORT:    The Rural County Representatives of California
          state that the bill improves equity of the CVRP by improving  
                         outreach efforts in 
          all eligible low-income households and not limiting it to  
                         disadvantaged
          communities. They also note this will encourage applications for  
                         eligible low-
          income households in an additional 29 counties. 
           
           ARGUMENTS IN  
          OPPOSITION:    The Alliance of Automobile Manufacturers 
          opposes the bill because they argue the income eligibility  
                         threshold for ZEV 
          rebates were recently enacted by the ARB and that those  
                         thresholds use voter-
          approved figures to determine high-income. They also state that  
                         reducing 
          maximum income thresholds do not make ZEVs more affordable for  
                         middle or 
          lower income consumers, and further note that in the last two  
                         years, ZEV sales
          have stagnated at approximately 3%, and requirement under this  








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                         bill will make the
          15% requirement for ZEV sales by 2025 considerably more  
                         challenging to meet.  
           
           
                                          
                                      -- END --