BILL ANALYSIS Ó
SENATE COMMITTEE ON ENERGY, UTILITIES AND COMMUNICATIONS
Senator Ben Hueso, Chair
2015 - 2016 Regular
Bill No: SB 350 Hearing Date: 4/7/2015
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|Author: |De León |
|-----------+-----------------------------------------------------|
|Version: |2/24/2015 As Introduced |
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|Urgency: |No |Fiscal: |Yes |
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|Consultant:|Jay Dickenson |
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SUBJECT: Clean Energy and Pollution Reduction Act of 2015.
DIGEST: This bill enacts the Clean Energy and Pollution
Reduction Act of 2015, which creates or expands three related
clean-energy goals to be achieved by 2030: (1) a 50 percent
reduction in petroleum used in motor vehicles; (2) a doubling of
the energy efficiency of existing buildings; and (3) generating
50 percent of total retail sales of electricity from renewable
resources.
ANALYSIS:
Existing law:
1. Provides the California Air Resources Board (ARB) with
primary responsibility for control of mobile source air
pollution, including adoption of rules for reducing vehicle
emissions and the specification of vehicular fuel
composition. (Health and Safety Code §39000 et seq. and
§39500 et seq.)
2. Directs ARB to implement motor vehicle emission
standards, in-use performance standards, and motor vehicle
fuel specifications for the control of air contaminants and
sources of air pollution that ARB finds to be necessary,
cost effective, and technologically feasible, unless
preempted by federal law. (Health and Safety Code §43013 et
seq.)
3. Directs the California Energy Commission (CEC) to
SB 350 (De León) PageB of?
continually assess energy consumption trends and to analyze
the social, economic, and environmental consequences of
these trends; carry out, energy conservation measures; and
recommend to the Governor and the Legislature new and
expanded energy conservation measures. (Public Resources
Code §25200 et seq.)
4. Requires the CEC to develop and implement a
comprehensive program to achieve greater energy savings in
California's existing residential and nonresidential
building stock. (Public Resources Code §25943 et seq.)
5. Establishes the Electric Program Investment Charge
(EPIC) Fund, to fund projects that benefit electricity
ratepayers and lead to technological advancement and
breakthroughs to overcome the barriers that prevent the
achievement of the state's statutory energy goals. (Public
Utilities Code §25710 et seq.)
6. Requires retail sellers of electricity - investor-owned
utilities (IOU), community choice aggregators (CCAs), and
energy service providers (ESPs) - and publicly-owned
utilities (POU) to increase purchases of renewable energy
such that at least 33 percent of retail sales are procured
from renewable energy resources by December 31, 2020. This
is known as the Renewable Portfolio Standard (RPS). The
California Public Utilities Commission (CPUC) establishes
the RPS for retail sellers and ensures they progress in
achieving it, and levies penalties for failure. The
governing board of each POU establishes its own RPS. The
CEC may issue a notice of violation against a POU for
failure the adequately progress in meeting RPS targets and
refer the POU to the ARB, which may assess penalties
against it. The RPS provides numerous cost containment
provisions and exceptions to compliance obligations.
(Public Utilities Code §399.11 et seq.)
7. Requires all renewable electricity products to meet the
requirements of a "loading order" that mandates minimum and
maximum quantities of three product categories (or
"buckets"), which includes renewable resources directly
connected to a California balancing authority (CBA) or
provided in real time without substitution from another
energy source, energy not connected or delivered in real
time yet still delivering electricity, and unbundled
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renewable energy credits (RECs). (Public Utilities Code
§399.16.)
This bill:
This bill enacts the Clean Energy and Pollution Reduction Act of
2015, which creates or expands three related clean-energy goals
to be achieved by 2030: (1) a 50 percent reduction in petroleum
used in motor vehicles; (2) generating 50 percent of total
retail sales of electricity from renewable resources; and (3) a
doubling of the energy efficiency of existing buildings.
Specific to the petroleum reduction goal, this bill directs the
ARB to adopt and implement motor vehicle emissions standards,
in-use performance standards, and motor vehicle fuel
specifications in furtherance of achieving a 50 percent
reduction in petroleum use in motor vehicles by January 1, 2030.
Specific to the energy efficiency goal, this bill directs the
CEC, by January 1, 2017, and at least once every three years
thereafter, to adopt and update its comprehensive program to
achieve greater energy savings in California's existing
residential and nonresidential building stock - known as the
California Existing Buildings Energy Efficiency Action Plan - in
order to achieve a doubling of the energy efficiency of existing
buildings by January 1, 2030.
Specific to the renewable energy goal, this bill:
Directs the CPUC and the CEC to implement the RPS to
obtain the target of generating 50 percent of total retail
electricity sales from renewable energy resources by
December 31, 2030.
Establishes the following RPS compliance periods and
renewable energy goals for retail sellers and POUs: January
1, 2021, to December 31, 2024 - 40 percent; January 1,
2025, to December 31, 2027 - 45 percent; and January 1,
2028, to December 31, 2030 - 50 percent.
Directs the CPUC to require all retail sellers of
electricity to annually prepare renewable energy
procurement plans and, for each IOU procurement plan,
require the IOU to include a strategy for procuring a
diverse portfolio of resources that provide a reliable
electricity supply, including renewable energy integration
needs, using zero carbon-emitting resources to the maximum
SB 350 (De León) PageD of?
extent reasonable, the net capacity costs of which shall be
allocated on a nonbypassable basis.
Requires retail sellers and POUs to ensure that, for
each compliance period after 2020, at least 75 percent of
the incremental renewable energy procurement is from
generation either (1) directly connected to a CBA, or, (2)
connected to another balancing authority and providing
power to a CBA via dynamic transfers or by scheduling power
from the facility into a CBA on an hourly basis.
Limits to 10 percent, for each compliance period after
2020, the incremental renewable power a retail seller or a
POU may receive from unbundled RECs from generators not
directly connected to a CBA.
Directs the CPUC to establish limitations for each IOU
on procurement expenditures for RPS compliance at a level
that prevents disproportionate rate impacts and deletes
provisions of existing law requiring the CPUC to report to
the Legislature, by January 1, 2016, on the ability of each
IOU to meet and maintain the 33 percent 2020 target within
existing cost limitations.
Authorizes the CPUC to assess penalties against a retail
seller, and the CEC to assess penalties against a POU, for
noncompliance with an RPS interim goal and, in the case of
an IOU, prohibits the IOU from collecting the cost of the
penalties in rates.
Directs penalties collected from a retail seller or a
POU to the EPIC Fund, to be used for renewable energy
programs and research, development, and demonstration
programs.
Directs the CPUC and the CEC to consider the benefits of
distributed generation; allow for consideration of costs
and benefits of grid integration in RPS proceedings;
minimize system power and fossil fuel purchases; recommend
how to better align state incentive programs with the
state's clean energy and pollution reduction goals and
provide benefits to disadvantaged communities; and give
preference to the manufacture and deployment of clean
energy and pollution reduction technologies that create
jobs and investment in the state.
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Background
State Efforts to Address Environmental Effects of Energy Use . In
California, the energy sector, broadly defined, accounts for
more than 85 percent of greenhouse gas emissions. The two
largest sources of California's greenhouse gases are
transportation, at 39 percent, and electricity production, at 21
percent.<1> Accordingly, the state's existing clean energy and
climate change programs focus on the energy sector in general
and the transportation and electricity sectors specifically.
Principal among those programs are the California Global Warming
Solutions Act of 2006 (more commonly known as "AB 32"), which
requires a reduction of the state's greenhouse gas emissions to
1990 levels by 2020, and the RPS, which requires the 33 percent
of the state's electricity come from renewable resources by
2020. AB 32 tasks the ARB with developing a plan of measures
that reduce greenhouse gas emission levels, to be updated every
five years. To that end, ARB, in 2008, adopted a scoping plan
that includes regulatory and market-based measures applicable to
the state's major economic sectors. Among the regulatory
measures included in the initial scoping plan were numerous
energy efficiency measures, measures to encourage the
development and adoption of alternative fuels, and a 33 percent
RPS. In 2014, ARB released an update to its scoping plan. The
ARB approved its first update to the scoping plan in May of
2014. The state has reduced its overall emissions of greenhouse
gases since passage of AB 32, as shown below:
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|Overall Greenhouse Gas Emission Decline Since Passage of AB 32 |
| |
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|--------------------------------------+----------------------+------|
| | | |
| Sector | 2006 | 2012 |
| | | |
|--------------------------------------+----------------------+------|
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<1> 2013 Integrated Energy Policy Report
(http://www.energy.ca.gov/2013publications/CEC-100-2013-001/CEC-1
00-2013-001-CMF.pdf)
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| Electricity Generation (In-state)| 50.05444|51.180|
| | | 08|
|--------------------------------------+----------------------+------|
| Electricity Generation (Imports)| 54.76146|44.146|
| | | 77|
|--------------------------------------+----------------------+------|
| Industrial| 99.65204|100.67|
| | | 17|
|--------------------------------------+----------------------+------|
| Agricultural| 37.7503|37.863|
| | | 4|
|--------------------------------------+----------------------+------|
| Residential| 30.60681|31.587|
| | | 83|
|--------------------------------------+----------------------+------|
| Commercial| 17.34549|22.021|
| | | 16|
|--------------------------------------+----------------------+------|
| Transportation| 192.1233|171.00|
| | | 75|
|--------------------------------------+----------------------+------|
| Total Greenhouse Gas Emissions | 482.2939|458.47|
| (millions of metric tons of carbon | | 85|
| dioxide equivalent)| | |
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|Source: California Energy Commission. |
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The Legislature approved the statutory RPS program in 2011 with
the passage of SB 2 x1 (Simitian, Chapter 1). Statute directs
the CPUC to establish the RPS for retail sellers and ensure they
progress in achieving it, levying penalties for failure. The
governing board of each POU establishes its own RPS. The CEC may
issue a notice of violation against a POU for failure the
adequately progress in meeting RPS targets and refer the POU to
the ARB, which may assess penalties against it. The state's
electric utilities report they are on track to meet, or exceed,
the RPS goals. The following table shows the progress to date
of the state's largest electric utilities:
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|Progress of Major Electric Utilities Towards Meetings RPS Goals |
| |
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|--------------------+------------------------+---------------------|
| | | Percentage of RPS |
| | RPS Procurement | Procurement |
| | Percentages for the | Currently Under |
| | 2011-13 Procurement | Contract for 2020 |
| | Period | |
| | | |
|--------------------+------------------------+---------------------|
| | 23.8% | 31.3% |
| Pacific Gas and | | |
| Electric| | |
| | | |
|--------------------+------------------------+---------------------|
| | 21.6% | 23.5% |
|Southern California | | |
| Edison| | |
| | | |
|--------------------+------------------------+---------------------|
| | 23.6% | 38.8% |
| San Diego Gas and | | |
| Electric| | |
| | | |
|--------------------+------------------------+---------------------|
| | 20.1% | -- |
| Sacramento | | |
|Municipal Utilities | | |
| District| | |
| | | |
|--------------------+------------------------+---------------------|
| | 20.0% | -- |
| Los Angeles | | |
|Department of Water | | |
| and Power| | |
| | | |
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|IOU RPS procurement is as reported by the CPUC. See |
|http://www.cpuc.ca.gov/PUC/energy/Renewables/index.htm. |
| |
|The POUs report their own progress on the RPS to the CEC. See |
|http://www.energy.ca.gov/portfolio/pou_rulemaking/2013-RPS-01/POU_R|
|eported_2011-2013_RPS_Percentage_Table.pdf. |
| |
| |
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Regarding transportation, the state regulates vehicle emissions
and encourages the development of less carbon-intensive
alternative fuels. For example, the ARB regulates the
greenhouse gas tailpipe emissions of new passenger vehicles, as
well as smog-forming emissions. Acting under the authority
provided by AB 32, the ARB regulates the carbon content of
transportation fuels, via the Low Carbon Fuel Standard. In
addition, ARB provides rebates for the purchase of
alternative-fueled vehicles and funds the retirement of older,
higher-polluting vehicles, as well as funding alternative fuel
research, demonstration and workforce training. In a related
effort, the CEC provides nearly $100 million annually to fund
measures to develop and deploy innovative technologies that
transform California fuel and vehicle types to help attain the
state's climate change policies.
Other state programs directly address energy efficiency. The
state's loading order, established by the energy agencies in
2003, calls for meeting new electricity needs first with
efficiency and demand response, followed by renewable energy and
distributed generation, and then with fossil generation.<2>
Under statute guidelines, the CPUC authorizes IOU spending for
all available energy efficiency that is cost effective, reliable
and feasible. In recent years the CPUC has authorized close to
$1 billion per year in energy efficiency spending to meet this
mandate based on feasibility studies and the record developed in
CPUC's energy efficiency proceedings. Since 1977, the CEC,
acting under the broad authority provided to it under the
Warren-Alquist Act, has set energy efficiency standards for
appliances and new buildings; many credit these standards, in
part, with keeping California's per-capita electricity
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<2> 2003 Energy Action Plan
(http://www.energy.ca.gov/energy_action_plan/2003-05-08_ACTION_PL
AN.PDF).
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consumption flat over the past three decades.<3> Further, CEC,
acting according to statutory mandate, recently released a draft
plan to achieve cost-effective energy savings in California's
existing residential and nonresidential buildings, which,
generally, are not subject to CEC's building efficiency
standards.<4>
Building Upon Existing Structure to Create New "Golden
Standards" . In his 2015 State-of-the-State speech, Governor
Brown announced three ambitious new energy goals that would take
state clean energy policy beyond 2020: (1) 50 percent of
California's electricity to come from renewable energy sources;
(2) reducing by 50 percent the amount of petroleum used in cars
and trucks; and (3) doubling the energy efficiency of existing
buildings, all by 2030. The author has described this bill as
an effort to execute on the Governor's "bold vision."
To a large extent, the bill builds upon existing state programs,
which the author describes as already making significant
progress to the three goals. In its current form, the bill
prescribes little for the achievement of the petroleum reduction
goal or the energy efficiency goal. Rather, the bill directs
the ARB and the CEC, respectively, to expand upon existing
authorities to achieve each goal.
Similarly, the bill builds upon existing statutory authority to
achieve the expanded RPS goal. As existing statute makes
extensive, specific requirements of the RPS program, so too does
the bill. Notably, the bill removes the prescriptive
cost-containment provisions of the RPS statute meant to ensure
the renewables mandate does not cost too much. Just as notable,
however, is that the cost-containment provisions have never been
used as the cost of compliance with the RPS statute has not been
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<3> See, for example,
http://switchboard.nrdc.org/blogs/mwaltner/energy_savings_on_the_
way_for.html.
<4> Existing Buildings Energy Efficiency Action Plan - Draft
(http://www.energy.ca.gov/ab758/).
SB 350 (De León) PageK of?
too burdensome.<5> This bill, instead, directs the CPUC to
establish a limitation for each IOU, at a level that prevents
disproportionate rate impacts. It will be important for the
Legislature to maintain oversight of the CPUC's implementation
of these looser cost-containment provisions. The author and
committee may wish to consider requiring the CPUC and the Office
of Ratepayer Advocate, as part of their annual reports to the
Legislature, to update the Legislature on the cost-containment
requirements the CPUC has made of each IOU.
What the Duck Is This ? The bill also adds language to the RPS
statute that directs the CEC and CPUC to:
Value distributed generation and the benefits it
provides, particularly in disadvantaged communities, and to
promote its use.
Allow for the costs of grid integration.
Adopt rules that, where feasible, minimize system power
and fossil fuel purchases, increase the use of energy
storage, demand response, and other low-emission and
zero-emission technologies to protect system reliability.
Ensure incentive programs are aligned with state policy
and benefit disadvantaged communities.
Give priority to opportunities to create jobs and
increase investment in the state.
Integration of renewables is a real challenge. Many renewable
resources, including solar and wind, are intermittent resources,
meaning they are available only as conditions allow them to be,
such as, when the sun is shining or the wind is blowing. This
intermittency complicates reliable management of the electrical
grid a challenge and has the potential to lead to situations in
which the state produces more power than it needs. Such a
scenario is depicted in the California Independent Service
Operator's now-infamous "duck" chart. Thus far, the state's
electrical system has responded to the challenge of
intermittency by, primarily, relying on natural-gas fired power
plants that can quickly ramp up and down in their generation of
power.
However, other solutions exist or may be developed. For
example, energy may be stored in batteries, pumped hydro, or
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<5> The CPUC's Energy Division estimates that the RPS has
increased electricity rates by four to five percent, a range
well within that contemplated by the Legislature during its
deliberation of SB 2 X1. See, for example, the Assembly
Appropriations Committee analysis of SB 2 X1, which referenced a
CPUC estimate that the 33 percent RPS might raise rates as much
as 7.7 percent.
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compressed air. So called demand response can be called upon to
better match electricity demand to electricity supply.
Distributed generation can be placed where it most benefits the
grid overall. Balancing markets can allow use of resources
across regions, so that local supply need less coincide with
local demand. And the state has programs and policies to
encourage these programs. For example, the CPUC requires the
IOUs to procure set amounts of storage capacity. And the IOUs
operate demand response programs, though, as the CEC notes,
growth in demand response in California is flat and lags other
parts of the country.<6> The author may want to consider, as
the bill moves forward, language that better ensures that the
CPUC, CEC and the retail sellers of electricity appropriately
value these zero-emission, grid-enabling opportunities.
Similarly, the author may want to consider language that ensures
regulators, retail sellers and POUs recognize the value of local
benefits that certain projects may provide.
Balancing the Balanced Portfolio . This bill leaves unchanged the
statutory requirement that retail sellers procure a "balanced
portfolio" of renewable energy resources. This bill, and the
existing RPS statute, define eligible renewable energy sources
as biomass, solar thermal, photovoltaic (PV), wind, geothermal,
fuel cells using renewable fuels, small hydroelectric
generation, digester gas, municipal solid waste conversion,
landfill gas, ocean wave, ocean thermal, or tidal current. An
examination of the IOU's RPS portfolios, however, shows an
increasing and predominant reliance on solar PV renewable energy
resources. This increasing reliance makes sense, in that the
cost of solar PV has decreased dramatically in recent years,
making electricity generated from solar PV nearly cost
competitive with electricity generated from natural gas, based
on the direct cost of generation. Yet, in calling for a
"balanced portfolio" of renewable resources, the Legislature
recognized that procurement of electricity from a variety of
renewable resources may have value not recognized by the price
of electricity generation.
This bill reaffirms and strengthens this recognition. The bill
newly requires each IOU to include in its RPS procurement plan a
strategy for procuring a diverse portfolio of resources that
provide specific, nonmonetary benefits: reliable electric
supply, including renewable energy integration needs, using
zero-carbon emitting resources to the maximum extent possible.
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<6> See 2013 IEPR, Chapter 2: Demand Response.
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The Legislature should expect this requirement to lead IOUs to
procure a more-diverse portfolio of renewable resources and to
rely less on natural gas-fired electricity generation to balance
the electrical system.
Not This Henhouse . The bill authorizes CEC to levy fines for
noncompliance with the RPS against POUs and directs monies from
any such fines to the EPIC Fund, as it does monies resulting
from fines levied by the CPUC against retail sellers. Existing
statute charges the CEC with administering monies in the EPIC
Fund and defines eligible projects as research, development, and
demonstration programs that benefit IOU electricity ratepayers.
In addition, the CPUC must approve CEC planned expenditures from
the fund. These requirements - CPUC approval and benefits to
IOU ratepayers - are appropriate for monies that come from IOU
electricity ratepayers. It seems inappropriate to apply these
requirements to monies from fines paid by the ratepayers of the
state's POUs. The author and committee may wish to establish a
fund, distinct from the EPIC Fund, to receive RPS penalties from
POUs, that funds similar projects as the main EPIC Fund, but
without the IOU-specific constraints statute places on monies in
the EPIC Fund.
Do As I Say (And Do) . The existing RPS does not apply to the
Department of Water Resources (DWR), though DWR is a major
purchaser of electric power. The Governor effectively described
the driving imperative of achieving our clean energy goals. If
the state is committed to meeting those clean energy goals - and
committed to obliging retail sellers and POUs and their
ratepayers as well, then it should apply those clean energy
goals to all energy users. The author and committee might want
to consider amending this bill to subject DWR to the RPS
requirements, though pursuant to a modified schedule that
acknowledges DWR's current fossil fuel-dependent energy
portfolio.
Decarbonizing the Electricity Sector: Another Way Forward ? As
described above, the bill expands upon the existing RPS
framework, largely as a strategy to reduce greenhouse gas
emissions. This makes sense: the strategy has worked.
California is on track to meet its renewable energy targets. As
the bill's author notes, renewable resources provide a number of
benefits beyond the production of electricity: minimizing local
air pollution effects, insulating ratepayers from fossil fuel
SB 350 (De León) PageN of?
market volatility, and encouraging technology innovation and a
decline in costs.
Some industry representatives, while expressing general support
for the state's clean energy goals, have suggested a "clean
energy standard" (CES) instead of an RPS. As described, under a
CES, the electricity generating sector would agree to a
sector-wide greenhouse gas emission cap. The particulars of how
the actors in the sector would achieve such a cap would be left
up to those actors, who, presumably, would choose the
least-costly greenhouse gas reduction measures needed to meet
the cap. Such measures might not include renewable energy
project or might not include the number and scale of renewable
energy projects that would be realized under the higher RPS.
The CES approach would have the advantage of being, potentially,
lower cost; however, it would also provide less benefit,
especially since it seems unlikely the lowest cost projects
would be those that would force innovation.
Double Referral . Should this bill be approved by the committee,
it will be re-referred to the Senate Committee on Environmental
Quality for its consideration.
Prior/Related Legislation
AB 758 (Skinner, Chapter 470, Statutes of 2009) requires the CEC
to develop and implement a comprehensive program to achieve
greater energy savings in California's existing residential and
nonresidential building stock.
SB 2 x1 (Simitian, Chapter 1, Statutes of 2011) requires retail
sellers of electricity and POUs to procure at least 33 percent
of their electricity from renewable resources by 2020.
FISCAL EFFECT: Appropriation: No Fiscal
Com.: Yes Local: Yes
ARGUMENTS IN SUPPORT: Supporters note the need to build upon the
success of the state's existing clean energy policies and note
many co-benefits, such as cleaner air, innovation forcing, and
energy supply diversity, provided by RPS.
ARGUMENTS IN OPPOSITION: The Western States Petroleum
Association (WSPA), in explaining its opposition to the bill's
SB 350 (De León) PageO of?
petroleum reduction goal, decries this approach, expressing
concern over how ARB would implement such a broad mandate. WSPA
recommends the bill, instead, spell out the regulatory
mechanisms ARB is to use to achieve the petroleum reduction
goal. Other opponents protest what they see as the excessive
cost of complying with the bill and the lack of flexibility.
SUPPORT:
American Lung Association - California
American Academy of Pediatrics - California
Asthma Coalition of Los Angeles County
Azul
Baz Allergy, Asthma and Sinus Center
Berkshire Hathaway Energy
Blattner Energy
Bonnie J. Adario Lung Cancer Foundation
Breathe California
BYD Motors, Inc.
California Black Health Network
California Conference of Directors of Environmental Health
California Energy Efficiency Industry Council
California League of Conservation Voters
California Pan-Ethnic Health Network
California Public Health Association - North
California Thoracic Society
California Wind Energy Association, if amended
Californians Against Waste
Center for Climate Change and Health; Public Health Institute
Central California Asthma Collaborative
Circulate San Diego
Clean Water Action
Clean Power Campaign
Cleveland National Forest Foundation
Coastal Environmental Rights Foundation
Doctors for Climate Health (8 Doctors)
Endangered Habitats League
Environment California
Environmental Defense Fund
EtaGen
First Solar
Friends of the River
Friends Committee on Legislation of California
Health Care Without Harm
Large-Scale Solar Association
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League of Women Voters of California
McCarthy Building Companies, Inc.
Medical Advocates for Healthy Air
Moms Clean Air Force
National Parks Conservation Association
Natural Resource Defense Council
NextGen Climate
NextTracker, Inc.
Office of Ratepayer Advocates
Physicians for Social Responsibility - Los Angeles
Physicians for Social Responsibility - San Francisco Bay Area
Chapter
Public Health Institute
Recurrent Energy
Regional Asthma Management and Prevention
Sequoia Riverlands Trust
Sierra Club California
Signal Energy, LLC
Solar Energy Industries Association
Southwest Wetlands Interpretive Association
SunEdison
The Utility Reform Network
TransForm
Trust for Public Lands
Union of Concerned Scientists
Wireless Advanced Vehicle Electrification
CONCERNS:
California Municipal Utilities Association
County of Los Angeles Public Health
OPPOSITION:
Association Builders and Contractors of California
BizFed (Los Angeles County Business Federation)
California Chamber of Commerce
California Construction Trucking Association
California Independent Oil Marketers Association
California Independent Petroleum Association
California Manufacturers & Technology Association
California Small Business Alliance
California Small Business Association
Coalition of Energy Users
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Fullerton Association of Concerned Taxpayers
Howard Jarvis Taxpayers Association
Independent Oil Producers Agency
International Warehouse Logistics Association
Kern Citizens of Energy
Kern Citizens for Sustainable Government
Kern County Taxpayers Association
Long Beach Area Chamber of Commerce
National Association of Royalty Owners - California
National Federation of Independent Business/California
Placer County Taxpayers Association
Regional Hispanic Chamber of Commerce
San Diego Tax Fighters
Santa Barbara County Taxpayers Association
Santa Barbara Technology and Industry Association
Small Business Action Committee
South Bay Association of Chamber of Commerce
Torrance Area Chamber of Commerce
Valley Industry & Commerce Association
Western States Petroleum Association
Wilmington Chamber of Commerce
-- END --