BILL ANALYSIS                                                                                                                                                                                                    



                                                               AB 1981
                                                                       

                      SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                        Senator S. Joseph Simitian, Chairman
                              2009-2010 Regular Session
                                           
           BILL NO:    AB 1981
           AUTHOR:     Hill
           AMENDED:    May 28, 2010
           FISCAL:     Yes               HEARING DATE:     June 28, 2010
           URGENCY:    No                CONSULTANT:       Caroll  
           Mortensen
            
           SUBJECT  :    WASTE TIRE FEE

            SUMMARY  :    
           
            Existing law  , pursuant to the California Tire Recycling Act  
           (Public Resources Code 42860 et seq.), administered by the  
           Department of Resources Recycling and Recovery (DRRR):

           1)Requires retail sellers of new tires to collect a fee of  
             $1.75 per tire, of which $1.00 is deposited into the Tire  
             Management Fund (Fund) to promote recycling and other  
             alternatives to landfill disposal and stockpiling of waste  
             tires, and $0.75 is deposited in the Air Pollution Control  
             Fund (APCF) administered by the Air Resources Board (ARB)  
             for the mitigation of remediation of air pollution caused by  
             the decomposition of tires.  Beginning January 1, 2015,  
             reduces the fee to $.75 to be deposited into the Fund.  

           2)Allows sellers of new tires to keep 1 % of the fee to cover  
             their administrative costs related to collection of the fee.  


            This bill  :

           1)Adds an additional finding to the codified findings and  
             declarations regarding the management of waste tires that  
             states: "To mitigate the environmental impacts caused by  
             tires mounted on new and used vehicles on California roads,  
             and to ease compliance for new motor vehicle dealers and  
             their customers, collection of a fee for vehicles sold by  
             new motor vehicle dealers should be assessed on a per  
             vehicle, rather than a per tire, basis".









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           2)Exempts new tires sold with a new or used motor vehicle that  
             is sold by a new vehicle dealer from the definition of a new  
             tire for purposes of this bill and thereby exempts dealers  
             from collecting the tire fee for these tires.  

           3)Requires dealers to collect a "vehicle tire fee" of $10.50  
             for every new vehicle sold before January 1, 2015, and  
             reduces the fee to $5.50 on and after that date.  Exempts  
             used vehicles sold by dealers from this fee.  

           4)Specifies that the vehicle tire fee be listed separately  
             from the tire fee on the conditional sale or lease  
             agreement.  

           5)Specifies that $5.98 of the vehicle tire fee be deposited  
             into the Fund and $4.52 of the vehicle tire fee be deposited  
             into the APCF until December 31, 2014.  

           6)Requires, on or before January 1, 2012, the State Board of  
             Equalization, in consultation with the ARB and DRRR, to  
             report to the Legislature concerning the fiscal impacts of  
             imposing the vehicle tire fee.  

           7)Makes conforming changes to the Automobile Sales Finance  
             Act.

            COMMENTS:   

            1)Purpose of Bill  .  According to the author, in 1989, the  
             state created the Tire Recycling Program and the California  
             Tire Recycling Management Fund to deal with the millions of  
             used and waste tires generated annually by the state. The  
             current fee on each new individual tire sold at retail is  
             $1.75.

             The sponsor states that as dealers automate their  
             procedures, the collection of the fee has been increasingly  
             problematic.  Since only new tires are subject to the fee,  
             dealers must determine whether a new vehicle has a spare  
             tire and, on used vehicles, whether new tires were added to  
             the vehicle prior to sale.  Dealers also assert that they  
             faced significant problems in keeping track of the number of  









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             new tires installed on used vehicles and charging customers  
             accordingly.

             AB 1981 restructures the existing per tire fee for new  
             vehicle dealers only.  This bill would exempt used cars sold  
             by new car dealers from the tire fee and instead imposes a  
             $10.50 vehicle tire fee only on new cars.  The fee is  
             intended to be revenue neutral to the state. 

            2) Policy Concerns  .  This bill, while proposing a solution to  
              a small segment of fee payers, raises many concerns  
              regarding the solvency of the Tire Fund and creates an  
              equity issue for consumers.

            3) Counting Tires  .  AB 1981 proposes a flat fee on the sale of  
              new cars assessed at a level to cover the average number of  
              tires on a new car, plus an amount to cover the assumption  
              of the average number of new tires that may be sold on a  
              used car by a new car dealer.  The per-tire fee would no  
              longer be assessed on used cars sold by new car dealers. 

              The current structure of the assessment of the fee on a  
              per-tire basis has been in place since the waste tire  
              program and Fund were established in 2001.  While it works  
              for the rest of the fee payers in the program, this  
              approach addresses the issue of the variability of new  
              tires on new cars.  A new vehicle can have as few as two  
              new tires, for a motorcycle for example, or up to 18 for a  
              large truck or bus.  For used cars sold by dealers, it  
              requires them to keep track of the number of new tires, if  
              any, they place on a used car they sell so they can  
              accurately assess the fee.  

              Solid data of the number of used cars sold by new car data  
              is lacking.  Likewise for data that demonstrates how many  
              new tires those used cars may have been installed by a new  
              car dealer. 

            4) Tire and APCF Funds  .  As shown above, the variability of  
              the number of tires on new and used cars translates into  
              uncertainty when trying to apply a per car formula to deal  
              with new tires on both new and used cars to ensure the  
              total amount going into the funds is not changed.  The bill  









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              declares the intent that the fee changes be revenue  
              neutral.  Due to the uncertainty this is likely not to be  
              the case.  As a result, the bill may result in increased  
              annual revenue to the funds, or decreased annual revenue to  
              those funds, possibly in the millions of dollars.  For new  
              tires on new vehicles, the numbers and types of vehicles is  
              not constant.  For new tires on used cars, the direction  
              and magnitude of revenue change in a given year would  
              depend upon the ratio of new vehicle sales to used vehicle  
              sales and the ratio of used vehicles sold by new vehicle  
              dealers, which would not be subject to any fee, to used  
              vehicles sold by used vehicle dealers, which would still be  
              subject to the per tire fee.

            5) How Many New Tires on Used Cars  ?  The sponsor claims that  
              as they automate their procedures, the collection of the  
              tire fee is becoming increasingly problematic.  Most fees  
              and taxes assessed on the sale of a car are counted on a  
              per car basis.  As stated above, the tire fee is an  
              exception and is assessed on the actual number of new tires  
              on the new or used car.  According to the sponsor, this is  
              problematic and it is difficult for them to keep track,  
              especially for the used cars they sell.  However, when  
              researching used cars sold by new car dealers, much  
              maintenance and repair information, including installation  
              of tires, is available.   The popular "CARFAX" service  
              provided by some dealers, allows a consumer to see the  
              history of a car including what work has been performed.   
              These reports include a great level of detail.  For  
              example, you can see when a brake service or tune-up was  
              done, when wiper blades, belts or hoses were replaced.   
              Some even show when the car was washed.  It also includes  
              information about the installation of new tires.  Also, new  
              car dealers make available to their used car customers  
              copies of their "100 point" or similar inspections that  
              show that the car was examined and necessary repairs made.   
              It is assumed that this amount of information on a used car  
              shows its value and added to indicate to a customer that  
              the car is in tip-top condition.  They also include  
              information about installation of new tires.  With this  
              level of detail being supplied to customers about used  
              cars, it appears that developing a system to track the  
              number of new tires installed on used cars is possible.   









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              Sellers of new tires (including new vehicle dealers) are  
              allowed to retain 1% of the tire fees they collect to  
              cover their administrative costs.

            6) Sales Contracts  .  The sponsor has indicated that a number  
              of lawsuits have been filed against dealers for  
              overcharging consumers for fees and BOE has initiated  
              audits and levied fines against new car dealers for  
              improper collection.  The sales contract is a very long  
              form that is required to be completed with the sale of  
              every vehicle in California.  The long form contains a list  
              of mandated fees that must be listed and assessed as  
              applicable, including the tire fee.  If a fee is collected  
              incorrectly, it can nullify the contract. Also, BOE has  
              responsibility to audit the collection of the fee and does  
              have authority to levy fines and penalties if violations  
              are found.  Thus, accuracy is important and it can cost the  
              dealer through voided contracts, lawsuits and fines and  
              penalties. 

            7) Who's paying for the 'solution' proposed by AB 1981  ?  The  
              purchaser of a new vehicle will be paying for the  
              variability of the number of new tires on both new and used  
              vehicles.  They will be paying a flat fee regardless of  
              whether their new vehicle has two or eighteen tires.  Also,  
              the costs to implement and administer the per fee vehicle  
              must be borne by the funds (and fee payers).  The BOE who  
              collects the fee on behalf of DRRR, estimates one-time  
              costs of an unknown amount, but at least several hundred  
              thousand dollars, to develop a new California vehicle tire  
              fee program, applicable to new car sellers only, with  
              on-going costs of tens of thousand per year.  BOE's work  
              would include identifying affected vehicle dealers,  
              creating and revising forms and publications, and  
              developing or modifying computer programs.  The bill also  
              contains a one-time reporting requirement for BOE, with  
              DRRR and ARB, to evaluate the new per vehicle fee to  
              determine if there is any change in revenue and requires  
              BOE to recommend any needed adjustments.  The cost of this  
              report will be borne by the funds as well. 

            8) Policy Question  ?  Is AB 1981 viable given the uncertainty  
              it presents for the funds and the inequity posed to  









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              purchasers of new cars?  Also, the report and the increased  
              costs for BOE to ramp up, implement, and separately  
              administer the new per vehicle fee, payment must be borne  
              by the funds making less money available to implement both  
              of the tire recycling program and air pollution programs.   
              This is during a time when the Tire Fund is running at a  
              deficit and has outstanding loans to the General Fund. 

            SOURCE  :        California New Car Dealers Association  

           SUPPORT  :       None 

           OPPOSITION  :    California Air Pollution Control Officers  
                          Association
                          California Tire Dealers Association