BILL ANALYSIS Ó SB 380 Page A Date of Hearing: February 22, 2016 ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE Mike Gatto, Chair SB 380 (Pavley) - As Amended February 16, 2016 SENATE VOTE: 40-0 SUBJECT: Natural gas storage: moratorium SUMMARY: Places a moratorium on injecting natural gas into the Aliso Canyon gas storage facility and establishes requirements for resuming natural gas injections at the Aliso Canyon gas storage facility, as specified. Specifically, this bill: 1)Codifies a moratorium on injections of natural gas into any well at the Aliso Canyon storage facility until each well has been tested and evaluated for integrity and risks posed by well failure with particular emphasis on wells drilled prior to 2006. 2)Specifies the moratorium shall continue until each Aliso Canyon well has been evaluated using state-of-the-art technology as determined by the Department of Conservation's Division of Oil, Gas, and Geothermal Resources (DOGGR) with input from independent experts. SB 380 Page B 3)Requires at least one public meeting and that DOGGR shall request that the independent experts develop objective criteria for assessing the overall risk of the facility that DOGGR can then make public. 4)Specifies that any well posing an enhanced risk of failure is to be repaired or plugged and abandoned. 5)Specifies that the Supervisor of DOGGR is to determine the overall risk from well failure satisfies the supervisor's duty to prevent damage to life, health, property, and natural resources and other requirements; and requires the California Public Utilities Commission (CPUC) and the California Energy Commission (CEC) concur with the supervisor's determination. 6)Allows production of natural gas by any well drilled earlier than 1954 at the Aliso Canyon storage facility when necessary to either respond to the uncontrolled leak of natural gas from the "Standard Sesnon 25" well or maintain regional energy reliability, at the written direction of the commissions. 7)Requires the CPUC, in consultation with the CEC, DOGGR, and the California Independent System Operators (Cal ISO), to determine the feasibility of minimizing or eliminating use of the Aliso Canyon natural gas storage facility while still maintaining energy reliability for the region. 8)Includes an urgency clause for the statute to take effect immediately in order to mitigate ongoing harm from the gas leak at the Aliso Canyon storage facility and evaluate the integrity and risks associated with older wells at that facility. SB 380 Page C EXISTING LAW: 1)Authorizes the CPUC to regulate private corporations that own, operate, control, or manage a line, plant, or system for the transportation or the production, generation, transmission, or furnishing of heat, power, or storage directly or indirectly to or for the public, (California Constitution, Article XII, Section 3) 2)Authorizes the CPUC to regulate gas corporations, including underground storage. (Public Utilities Code Sections 216(a), 221, 222, 227, and 228) 3)Authorizes the CPUC to require that utility charges are just and reasonable and requires utilities to maintain facilities as necessary to promote safety, health, comfort, and convenience of patrons, employees, and the public. (Public Utilities Code Section 451) 4)Authorizes the CPUC to do all things, whether specifically designated in this part or in addition thereto, which are necessary and convenient in the exercise of such power and jurisdiction. (Public Utilities Code Section 701) 5)Establishes that the CPUC is responsible for regulating and enforcing intrastate gas pipeline transportation and pipeline facilities pursuant to Chapter 601 (commencing with Section 60101) of Subtitle VIII of Title 49 of the United States Code, including the development, submission, and administration of a state pipeline safety program certification for natural gas pipelines pursuant to Section 60105 of that chapter. (Public Utilities Code Section 955(b)) SB 380 Page D 6)Requires gas storage facilities to receive a Certificate of Public Convenience and Necessity (CPCN) before constructing a gas storage facility. Requires that the CPUC grant a CPCN on the grounds that the present or future public convenience and necessity requires or will require the gas storage facility. (Public Utilities Code Section 1001, et seq.) 7)Authorizes the CPUC to investigate, as part of the rate proceeding for any gas corporation, impediments to the in-state production and storage of natural gas and encourage in-state production or storage of natural gas unless the CPUC finds it likely that it will result in consequences adverse to the interests of gas customers. (Public Utilities Code Section 1001, et seq.) 1)Directs the Department of Conservation to: b) Supervise the drilling, operation, maintenance, and abandonment of wells and the operation, maintenance, and removal or abandonment of tanks and facilities attendant to oil and gas production so as to prevent, as far as possible, damage to life, health, property, and natural resources; damage to underground oil and gas deposits from infiltrating water and other causes; loss of oil, gas, or reservoir energy, and damage to underground and surface waters suitable for irrigation or domestic purposes by the infiltration of, or the addition of, detrimental substances. SB 380 Page E c) Supervise the drilling, operation, maintenance, and abandonment of wells so as to permit the owners or operators of the wells to utilize all methods and practices known to the oil industry for the purpose of increasing the ultimate recovery of underground hydrocarbons and which, in the opinion of the supervisor, are suitable for this purpose in each proposed case. d) Encourage the wise development of oil and gas resources to best meet oil and gas needs in this state. (Public Resources Code Section 3106) 1)Requires the Department of Conservation to maintain surveillance over underground gas storage facilities to insure that the original reserves are not lost, that drilling of new wells is conducted properly, and that no damage occurs to the environment by reason of injection and withdrawal of gas. (Public Resources Code Section 3403.5) FISCAL EFFECT: Unknown COMMENTS: 1)Author's Statement . "My constituents have been on the receiving end of a natural disaster for the last three plus months. The uncontrolled leak of natural gas from the Aliso Canyon facility is a public health and climate emergency. SB 380 Page F "SB 380 builds on the Governor's State of Emergency declaration, [DOGGR] proposed emergency gas storage regulations and statements by the CPUC and the [CEC], among others. It institutes a public, rigorous and transparent process to ensure the integrity of the gas storage wells. We have an obligation to the public to ensure that they have a formal voice in this process to ensure its credibility to them." 2)Background . A leak was discovered on October 23, 2015, at a natural gas well located at the Aliso Canyon storage facility, owned and operated by Southern California Gas Company (SoCalGas). SoCalGas made several unsuccessful well "kill" attempts. On December 4, 2015, SoCalGas began drilling a relief well to intercept and cap the leaking well near the bottom of the well. SoCalGas estimated the well could be capped by March 2016. Through November and December 2015 DOGGR and the CPUC issued orders establish a moratorium on natural gas injection at Aliso Canyon, to provide data, retain evidence, and track costs of the effort to plug the well. The Air Resources Board began collecting and publishing data on methane emissions caused by the leak. On January 6, 2016, the Governor issued a Proclamation<1> directing various state entities to oversee SoCalGas' actions to stop the leak, protect public safety, ensure accountability and strengthen oversight of natural gas storage facilities. Relevant to this bill, portions of the Governor's Proclamation: a) Ordered DOGGR to continue its prohibition against SoCalGas injecting any gas into the Aliso Canyon Storage Facility until a comprehensive review of the safety of the storage wells and the air quality of the surrounding -------------------------- <1> https://www.gov.ca.gov/news.php?id=19264 SB 380 Page G community utilizing independent experts is completed; and b) Tasked the CEC in coordination with CPUC to maintain energy reliability during this incident. On February 11, 2016, SoCalGas announced it had temporarily controlled the flow of natural gas at the leaking well and will continue to work in coordination with DOGGR and other agencies during the process of permanently sealing the well. 1)Reliability of California's energy system . One of the important questions is whether or not the moratorium specified in this bill impacts energy reliability. According to the CEC and the CPUC in a letter to the Governor on February 1st, "There is good reason to be concerned that reliability of supply may be critical for electric generators in the LA Basin, especially those serving [the Los Angeles Department of Water and Power]." The CEC and CPUC expect to complete their assessment of reliability for the summer of 2016 by April 1, 2016. The SoCalGas system consists of a pipeline system (Backbone Transmission System) and storage facilities. Most of SoCalGas' gas supply (90%) originates outside of California largely from production basins in Texas, New Mexico, and the Rocky Mountains. Gas from these regions is delivered via interstate pipelines into SoCalGas' Backbone Transmission System. Gas inventory in storage facilities is then used when demand exceeds the flowing supplies provided through the Backbone Transmission System. In Los Angeles County there are three natural gas storage facilities: ------------------------------------------------------------ |Field Name |Operator | Active | Working | Max Daily | | | | Well | Capacity | Delivery | | | | Count | (Mcf) | (Mcf) | |---------------+---------+--------+-----------+-------------| |Playa del Rey |SoCalGas | 22 | 2,400,000| 480,000| |---------------+---------+--------+-----------+-------------| SB 380 Page H |Aliso Canyon |SoCalGas | 92 | 86,000,000| 1,860,000| |---------------+---------+--------+-----------+-------------| |Honor Rancho |SoCalGas | 32 | 24,200,000|1,000,000 | ------------------------------------------------------------ Concerns regarding energy reliability relate to all three of California's major uses for energy: a) Natural Gas . Natural gas is used for electric generation, home heating, water heating (residential, commercial), cooking (residential and commercial), and industrial processes. Natural gas supplies are critical for public health and safety. SoCalGas' system-wide demand for gas supplies is highest in the winter-reflecting gas needs for heating buildings, hot water and cooking. To some extent, California's natural gas storage facilities provide some financial benefits to ratepayers in that the presence of the stored gas avoids both real and perceived supply shortages in the event of a disruption of suppliers from non-state sources, which can ameliorate natural gas commodity price spikes. It is unclear the extent to which the supply of natural gas via pipelines into the Los Angeles region can meet 100% of demand for natural gas reliably. According to the CPUC, to minimize risks of curtailments to residential and small commercial customers and electric generators and to minimize the possibility of curtailment to core customers, the CPUC ordered SoCalGas not to reduce SB 380 Page I inventory levels at Aliso Canyon below 15 Billion cubic feet (Bcf) other than to meet unspecified reliability requirements. b) Electricity . Electricity is used by residential, commercial, industrial, and agricultural customers for a variety of uses (for example, lighting, cooling, financial transactions, entertainment, manufacturing, etc.). There are 18 natural gas power plants supplying baseload, peaking, and voltage support into the Los Angeles region. These power plants supply electricity customers of Los Angeles Department of Water and Power (LADWP), Southern California Edison (SCE), and publicly owned utilities serving customers in Long Beach, Glendale, Burbank, Pasadena, Anaheim, and Vernon. According to their 2014 Power Content Labels,<2> approximately one-fourth of the electricity is supplied via natural gas generation (see Table 1). Other sources of energy include: wind, solar, geothermal, bioenergy, hydroelectric, nuclear, and coal. It is unclear the extent to which the Los Angeles region can reliably provide electricity 100% of the time if the power plants were to rely solely on natural gas delivered via pipelines into the region. This information does not include self-generation (roof-top solar, fuel cells, energy storage). Table 1: Los Angeles Region Sources of Electricity (%) ----------------------------------------------------------- | Retail |Anahei|Burban|Glenda|LADWP |Pasade| SCE |Vernon | | Supplier | m | k | le | | na | | | ----------------------------------------------------------- --------------------------- <2> http://www.energy.ca.gov/sb1305/labels/index.html SB 380 Page J ------------------------------------------------------------- | Resource | % of electricity generation by type of resource | | Type | | | | | ------------------------------------------------------------- |----------+------+------+------+------+------+-----+-------| |Bioenergy | 15 | 16 | 15 | 5 | 19 | 1 | 12 | |----------+------+------+------+------+------+-----+-------| |Geothermal| 5 | 2 | 4 | 1 | 2 | 9 | 0 | | | | | | | | | | |----------+------+------+------+------+------+-----+-------| | Small | 1 | 3 | 3 | 1 | 0 | 0 | 0 | | Hydro | | | | | | | | |----------+------+------+------+------+------+-----+-------| | Solar | 0 | 2 | 1 | 1 | 0 | 4 | 0 | |----------+------+------+------+------+------+-----+-------| | Wind | 7 | 5 | 24 | 12 | 7 | 10 | 7 | |----------+------+------+------+------+------+-----+-------| | Subtotal | 28 | 28 | 46 | 20 | 28 | 20 | 19 | |Renewable | | | | | | | | |----------+------+------+------+------+------+-----+-------| | Coal | 41 | 37 | 10 | 40 | 48 | 0 | 0 | |----------+------+------+------+------+------+-----+-------| | Large | 2 | 2 | 6 | 2 | 4 | 3 | 2 | | Hydro | | | | | | | | |----------+------+------+------+------+------+-----+-------| | Natural | 24 | 25 | 31 | 22 | 8 | 27 | 59 | | Gas | | | | | | | | |----------+------+------+------+------+------+-----+-------| | Nuclear | 0 | 6 | 8 | 9 | 7 | 6 | 7 | ----------------------------------------------------------- | Other | 0 | 2 | 0 | 0 | 0 | 0 | 0 | |----------+------+------+------+------+------+-----+-------| |Unspecifie| 7 | 0 | 0 | 7 | 5 | 40 |13 | |d Sources | | | | | | | | | of Power | | | | | | | | ----------------------------------------------------------- SB 380 Page K According to the CPUC, Aliso Canyon is an integral part of the SoCalGas system and is essential for meeting demand in the Los Angeles Basin. The CPUC also states that limited use or loss of Aliso's storage capacity under normal conditions can be supplemented in the short term using increased flowing supply and, to a limited extent, the Honor Rancho storage facility. The CPUC adds that Aliso Canyon storage is the only source available to meet the gas supply needed for gas-fired electric generators in Los Angeles Basin during summer hot days when electric demand increases to meet cooling needs (air conditioning, etc.). The CPUC states that analysis of the full impact on the electric system, if storage from Aliso Canyon is not available, is ongoing. However, they state that initial studies indicate that even with 15 Bcf in storage now, as the 15 Bcf is drawn down over the course of the summer, it will be increasingly difficult for SoCalGas to respond to increases in electric generation demand and therefore likely that electric generation in the Los Angeles Basin that relies on gas from Aliso Canyon will be curtailed. c) Petroleum Fuels . The Tesoro Refinery located near the Los Angeles Harbor is the largest refinery in Los Angeles County. The facility is capable of providing approximately 35% of the California's unique gasoline blend sold in the Los Angeles basin, 40% of the jet fuel for Los Angeles International Airport (LAX) and two million gallons per day of ultra-low sulfur diesel. Tesoro is also the majority owner of the Watson gas-fired cogeneration facility, which provides electricity to the Tesoro-Carson refinery. The Watson facility exports power to SCE customers through a SB 380 Page L power purchase agreement with SCE. Other larger refineries in the region include Chevron and ExxonMobil. For the most part, these refineries purchase their natural gas needs directly from gas suppliers and take delivery of their gas via the SoCalGas Backbone Transmission System. If these refineries were ordered to curtail their gas use in the event of peak demand for natural gas at the local power plants, there could be problems with maintaining sufficient inventories of petroleum fuels in the region (gasoline, diesel, aircraft fuels). Historically, fuel shortages have led to retail fuel price spikes. It is unclear whether this bill's moratorium would impact the reliability of transportation fuel supplies provided by refineries located in the region or whether this concern is to be addressed by the analysis that the CPUC and CEC will make available in April 2016. 2)Other similar gas storage facilities . This bill addresses operation of wells located in Aliso Canyon. However, there are six operators of 12 storage facilities in California with 343 active wells. Those other storage facilities are located in the following counties: Santa Barbara, Madera, Butte, Colusa, Contra Costa, San Joaquin, Solano, and Yolo. The Governor's proclamation addresses all storage facilities in California and specifically requires DOGGR to promulgate emergency regulations for gas storage facility operators throughout the state, requiring: at least daily inspection of gas storage well heads using gas leak detection technology such as infrared imaging; ongoing verification of the mechanical integrity of all gas storage wells; ongoing measurement of annular gas pressure or annular gas flow within wells; regular testing of all safety valves used in wells; SB 380 Page M minimum and maximum pressure limits for each gas storage facility in the state; a comprehensive risk management plan for each facility that evaluates and prepares for risks, including corrosion potential of pipes and equipment. At Aliso Canyon there are 39 pre-1954 wells and 98 pre-2006 wells (including the pre-1954 wells. Honor Rancho has no pre-1954 wells and 41 pre-2006 wells. La Goleta has 13 pre-1954 wells and 20 pre-2006 wells (including the pre-1954 wells). Playa del Rey has 41 pre-1954 wells and 51 pre-2006 wells (including the pre-1954 wells). Data on the age of wells at other natural gas storage facilities in California was not available. The Governor's proclamation orders DOGGR, the CPUC, California Air Resources Board (CARB), and the CEC to submit to the Governor's Office a report that assesses the long-term viability of natural gas storage facilities in California. This bill does not include this provision. 3)Two Moratoria - Similar but different . If enacted, this bill would codify a portion of the Governor's proclamation. The relevant portions of the Governor's proclamation are: Protecting Public Health and Safety: The state will: continue its prohibition against [SoCalGas] injecting any gas into the Aliso Canyon Storage Facility until a comprehensive review of the safety of the storage wells and the air quality of the surrounding community utilizing independent experts is completed; expand its real-time monitoring of emissions in the community; convene an independent panel of scientific and medical experts to review public health concerns; SB 380 Page N and take all actions necessary to ensure the continued reliability of natural gas and electricity supplies in the coming months. Strengthening Oversight: The state will promulgate emergency regulations for gas storage facility operators throughout the state, requiring: at least daily inspection of gas storage well heads using gas leak detection technology such as infrared imaging; ongoing verification of the mechanical integrity of all gas storage wells; ongoing measurement of annular gas pressure or annular gas flow within wells; regular testing of all safety valves used in wells; minimum and maximum pressure limits for each gas storage facility in the state; a comprehensive risk management plan for each facility that evaluates and prepares for risks, including corrosion potential of pipes and equipment. Additionally, [DOGGR, CPUC, CARB and CEC] will submit to the Governor's Office a report that assesses the long-term viability of natural gas storage facilities in California. The significant differences between the Governor's moratorium and the moratorium proposed by this bill are as follows. The moratorium specified in this bill: Requires DOGGR to specifically address Aliso Canyon wells placed in service prior to 2006. Specifies that state-of-the-art technology must be used to assess well integrity. SB 380 Page O Specifies that the DOGGR supervisor's duty includes "other requirements." Requires the DOGGR supervisor to determine that overall risk from well failure is satisfied, with the concurrence of the CEC and CPUC. Prohibits the production of natural gas by any well drilled earlier than 1954 at the Aliso Canyon storage facility until after the integrity and risks have been evaluated unless the well(s) are needed to maintain regional energy reliability at the written direction of the CEC. Requires the CPUC to determine the feasibility of minimizing or eliminating use of the Aliso Canyon storage facility in consultation with DOGGR, CARB, the Cal ISO, and the CEC. The moratorium specified in the Governor's proclamation: Prohibits gas injection at Aliso Canyon until a comprehensive review of safety and air quality is completed and requires that all actions be taken as are necessary to ensure continued reliability of natural gas and electricity supplies. Requires actions to be taken by DOGGR to ensure safety at all natural gas storage facilities and requires a multi-agency assessment of the long-term viability of natural gas storage facilities in California. SB 380 Page P Requires convening of an independent panel of scientific and medical experts to review public health concerns; and take all actions necessary to ensure the continued reliability of natural gas and electricity supplies in the coming months. It is unclear whether having moratorium provisions in statute would enhance, inhibit, or present difficulties in implementing the Aliso Canyon activities underway as a result of the Governor's proclamation. While the Governor is able to take administrative actions in a relatively short amount of time, statutes are generally modified no more frequently than annually. If this bill included a sunset date on the provisions applicable to DOGGR it would ensure that the Legislature revisits the statute to verify that the work specified by this bill is actually completed. Further, this bill requires a multiagency assessment, led by the CPUC, of the feasibility of minimizing or eliminating the use of Aliso Canyon's natural gas storage facility. The author may wish to consider a date by which this assessment is to be completed and require the CPUC to also consult with local publicly owned utilities in preparing this assessment. 1)Support and Opposition . Supporters of this bill raise concerns regarding health and safety, climate change, and maintenance practices at the facility (with some supporters emphasizing concerns regarding aging infrastructure). In particular, local community supporters raise concerns about providing a safe environment for public education, worker compensation claims, and the safety of children and families. Opponents raise concerns, while also expressing support for safety and inspection requirements, regarding electric SB 380 Page Q reliability, adverse impact on the economy (some raise concern that the exception for energy reliability is vague and does not define the term or provide an exception to maintain gas production at Aliso Canyon in the event of near term natural gas needs). They express concern that this bill will disrupt business operations, negatively impact the local economy, and predict service outages and blackouts that are harmful to consumers and businesses. SB 380 Page R 2)Recommended amendments . The author may wish to consider the following amendments to this bill: Clarify that Public Resources Code Section 3217 applies specifically to gas storage wells. Clarify that Public Resources Code Section 3217(a)(3) "and other requirements" refers to those requirements in Public Resources Code Section 3106. Include a sunset date (January 1, 2021) to ensure that the Legislature will have an opportunity to verify that the state agencies have completed the tasks specified in Section 3217. Specify a date by which the CPUC is to complete its assessment of need for the Aliso Canyon natural gas storage facility (July 1, 2017) and include local publicly owned utilities among the entities the CPUC is required to consult with on this assessment. The specific amendments are as follows: SECTION 1. Section 3217 is added to the Public Resources Code, to read: 3217. (a) The supervisor shall immediately institute a moratorium on injections of natural gas into any gas storage wells located within and serving the Aliso Canyon storage facility located in the County of Los Angeles until all of the SB 380 Page S following conditions are met: (1) The integrity of each gas storage well has been quantitatively and objectively evaluated using state-of-the-art technology, as determined by the supervisor with input from independent experts, and the risks posed by gas storage well failure have been evaluated. (A) The age, history, and condition of each gas storage well shall be specifically addressed, with particular emphasis on gas storage wells drilled prior to 2006. (B) The technical methods and equipment used to evaluate gas storage well integrity and the risks posed by gas storage well failure shall be determined by the supervisor with input from independent experts and the public. (C) The division shall hold at least one public meeting concerning the technical methods and equipment. The division shall request the independent experts to also develop objective criteria to assess the overall risk of the Aliso Canyon natural gas storage facility. The division shall make the objective criteria available to the public. (2) Any well posing an enhanced risk of failure has been repaired to mitigate the enhanced risk or plugged and abandoned. (3) The supervisor determines that the overall risk from gas storage well failure satisfies the supervisor's duty pursuant to Section 3106 to prevent damage to life, health, property, and natural resources , and other requirements , as specified in Section 3106. (4) The Public Utilities Commission and the State Energy Resources Conservation and Development Commission concur with the supervisor's determination in paragraph (3). (b) The supervisor shall prohibit the production of natural gas by any gas storage well originally drilled earlier than 1954 at the Aliso Canyon storage facility located in the County of Los Angeles until after the integrity of and the risks associated with any of these gas storage wells have been evaluated and determinations by the supervisor, with the concurrence of the commissions, have been made pursuant to the process described in subdivision (a), except when necessary to do either of the following: SB 380 Page T (1) Respond to the uncontrolled leak of natural gas from the "Standard Sesnon 25" well (American Petroleum Institute identification number 03700776). (2) Maintain regional energy reliability, at the written direction of the commissions. (c) This section shall remain in effect only until January 1, 2021, and as of that date is repealed, unless a later enacted statute, that is enacted before January 1, 2021, deletes or extends that date. SEC. 2. Section 713 is added to the Public Utilities Code, to read: 713. The commission, no later than July 1, 2017, shall determine the feasibility of minimizing or eliminating use of the Aliso Canyon natural gas storage facility located in the County of Los Angeles while still maintaining energy reliability for the region. The commission shall consult with the State Energy Resources Conservation and Development Commission, the Independent System Operator, the local publicly owned utilities that rely on natural gas for electricity generation, the Division of Oil, Gas, and Geothermal Resources in the Department of Conservation, and other relevant government entities, in making its determination. REGISTERED SUPPORT / OPPOSITION: Support Lieu, Ted, Member of the United State House of Representatives Schmerelson, Scott, Member of the Los Angeles Unified School District Board of Education AZUL Asian Pacific Environmental Network California League of Conservation Voters SB 380 Page U California Public Interest Research Group (CALPIRG) Center on Race, Poverty & the Enviroment Clean Water Action Climate Action Campaign Dignity Health Environment California Environmental Defense Fund Environmental Working Group Friends Committee on Legislation in California Los Angeles, City of Los Angeles, County of National Parks Conservation Association People Demanding Action Porter Ranch Neighborhood Council Santa Susana Mountain Park Association Sierra Club California Ventura, County of Vote for Progress, California Office Opposition Foster, Bob Kelly, James Alhambra Chamber of Commerce CALASIAN Chamber of Commerce California Business Roundtable California League of Food Processors California Manufacturers & Technology Association (CMTA) California Retailers Association Central City Association (CCA) Congress of California Seniors Command Packaging DE Solutions Desert Valley Builders Association El Monte/South El Monte Chamber of Commerce Futureports Harris Ranch SB 380 Page V Industry Manufacturers Council Inland Empire Economic Partnership Keenan Farms Inc. Kern Economic Development Corporation Kheir Clinic Latino Chamber of Commerce Los Angeles Chamber of Commerce Los Angeles Latino Chamber of Commerce Orange County Business Council Pomona Chamber of Commerce San Gabriel Economic Partnership Southern California Leadership Council Sweetener Products Company Verdexchange Institute Western Milling Western States Petroleum Association (WSPA) WireTech, Inc. Analysis Prepared by:Sue Kateley / U. & C. / (916) 319-2083