BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: SB 425
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  simitian
                                                         VERSION: 4/16/09
          Analysis by:  Jennifer Gress                   FISCAL:  yes
          Hearing date:  April 28, 2009









          SUBJECT:

          Parking cash-out program:  tax credits and deductions

          DESCRIPTION:

          This bill specifies that an employer subject to the requirement  
          to provide a parking cash-out program may not deduct the cost of  
          providing parking subsidies from its gross income unless it is  
          in compliance with the requirement.  This bill also provides a  
          tax credit to small businesses in an amount equal to 80 percent  
          of costs incurred for qualified commute reduction expenditures.

          ANALYSIS:

          Existing law allows a business to deduct from its gross income  
          "all ordinary and necessary expenses" incurred in carrying out  
          any trade or business, which includes the provision of free or  
          subsidized parking.

          Existing law also allows an employer to take a deduction from  
          its gross income for expenses paid or incurred for any of the  
          following ridesharing arrangements:

                 Subsidizing employees commuting in vanpools.

                 Subsidizing employees commuting in private commuter  
               buses or buspools.

                 Subsidizing monthly transit passes for its employees or  
               for use by the employees' dependents.





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                 Subsidizing employees commuting in subscription  
               taxipools.

                 Subsidizing employees commuting in a carpool.

                 Offering a cash equivalent to employees who do not  
               require parking, including a parking cash-out program.

                 Providing free or preferential parking to carpools,  
               vanpools, or any other vehicle used in a ridesharing  
               arrangement.

                 Making facility improvements to encourage employees, for  
               the purpose of commuting from their homes, to participate  
               in ridesharing arrangements, to use bicycles, or to walk.  

                 Providing company commuter van or bus service to its  
               employees and to others for commuting from their homes.

                 Providing to employees transportation services which are  
               required as part of the employer's business activities.

          Existing law provides that an individual's gross income does not  
          include compensation or the fair market value of any benefit  
          received for participation in any ridesharing arrangement,  
          including the following:

                 Commuting in a vanpool. 

                 Commuting in a private commuter bus or buspool.

                 A transit pass for use by the employee or his or her  
               dependents.

                 Commuting in a subscription taxipool.

                 Commuting in a carpool.

                 Free or subsidized parking.

                 Bicycling to or from the employee's place of employment.

                 Commuting by ferry.

                 The use of an alternative transportation method, other  
               than a method otherwise specified in this subdivision, that  




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               reduces the use of a motor vehicle by a single occupant to  
               travel to or from that individual's place of employment.

                 Travel to or from a telecommuting facility.

           Parking Cash-Out Program
           Existing law requires certain employers that provide a parking  
          subsidy to employees to provide a cash allowance to an employee  
          who does not use the parking space an amount equivalent to the  
          amount the employer would otherwise pay to provide that employee  
          a parking space.  This law is known as the Parking Cash-Out  
          program.  

          The program is administered by the California Air Resources  
          Board (ARB).   An employer must comply with the program by  
          offering a cash-out option if it has the following  
          characteristics:

                 Employs at least 50 persons, regardless of the number of  
               work sites.

                 Is located in an air basin designated nonattainment for  
               any state air quality standard.  (Practically speaking,  
               this means every county except Lake County.)

                 Provides free or subsidizes employee parking on  leased  
                spaces (i.e., on spaces the employer does not own).

                 Can calculate the expense of the parking subsidy, which  
               means the parking is leased separately from the building or  
               office space. 

                 Is able to reduce the number of leased parking spaces  
               without financial penalty.
           
          This bill  :  

          1.Prohibits an employer that is subject to the Parking Cash-Out  
            law from deducting from its gross income subsidies paid for  
            employee parking spaces unless the employer is in compliance  
            with that law.

          2.Provides a tax credit to businesses that have a maximum of 20  
            employees in an amount equal to 80 percent of costs incurred  
            for the following commute reduction expenditures:





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                 Subsidizing employees commuting in vanpools.

                 Subsidizing employees commuting in private commuter  
               buses or buspools.

                 Subsidizing monthly transit passes for its employees or  
               for use by the employee's dependents.

                 Subsidizing employees commuting in subscription  
               taxipools.

                 Subsidizing employees commuting in a carpool.

                 Subsidizing employees commuting in a ferry.

                 Providing free or subsidized parking to carpools,  
               vanpools, or any other vehicle used in a ridesharing  
               arrangement.

                 Making facility improvements to encourage employees to  
               use bicycles to commute to work.

                 Making facility improvements to encourage employees to  
               use alternative methods of transportation, other than those  
               listed here, that reduce the use of a motor vehicle by a  
               single occupant traveling to or from his or her place of  
               employment.

                 Subsidizing employees who already use alternative  
               methods of transportation.

                 Subsidizing employees who travel to or from a  
               telecommuting facility.

          3.Provides that the tax credit is in lieu of any other deduction  
            that the employer may claim for qualified commute reduction  
            expenditures.

          4.Allows the tax credit to be carried over to reduce the  
            employer's net tax in the following and any succeeding taxable  
            years until the credit has been exhausted.

          5.Exempts the Franchise Tax Board (FTB), which is the entity  
            responsible for implementing the tax credit, from the  
            Administrative Procedures Act.
          




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          COMMENTS:

           1.Purpose  .  Certain employers have been required by law to  
            comply with the parking cash-out program since 1992, which  
            requires employers to offer their employees who do not drive  
            to work cash in lieu of free or subsidized parking.  "Free"  
            parking has significant social, economic and environmental  
            costs.

            Although ARB is the agency responsible for implementing the  
            parking cash-out program, existing law does not require ARB to  
            enforce or monitor the program; nor does it contain reporting  
            requirements for employers, which makes it difficult for ARB  
            to assess whether or not an employer is in compliance.  The  
            potential of parking cash-out to alleviate congestion and  
            reduce greenhouse gas emissions depends on assessing employer  
            compliance with the cash-out requirement.  
          
            By prohibiting an employer from deducting parking subsidies as  
            a qualified business expense unless the employer complies with  
            the cash-out law, this bill provides a clearer method of  
            enforcement for the parking cash-out requirement.   
            Furthermore, by providing a tax credit to small businesses,  
            this bill provides a direct incentive for and assistance in  
            implementing measures to reduce commute trips. 

           2.Effect of free parking on commute behavior  .  According to a  
            2002 report prepared by the Legislative Analyst's Office (LAO)  
            to examine California's Parking Cash-Out law, there is some  
            research to suggest that providing free parking encourages  
            employees to drive to work alone to work.  The report cited a  
            1990 study that found a 41 percent average reduction in solo  
            driving when employees had to pay to park.  The LAO also noted  
            a 2000 survey of Bay Area commuters, which found that while 77  
            percent of commuters drive alone to work when free parking is  
            available, only 39 percent do so when they have to pay to  
            park.

           3.Benefits of parking cash-out  .  The Parking Cash-Out program  
            was established by AB 2109 (Katz), Chapter 554, Statutes of  
            1992, in response to a number of studies indicating that  
            employees are more likely to rideshare, use transit, or  
            carpool when they have to pay the full cost of parking spaces.  
             Additionally, concerns were raised that employer-subsidized  
            parking distorts the free market and encourages  
            single-occupant auto trips, contributing to traffic congestion  




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            and air pollution.

            According to the 2002 LAO report, as well as a more recent  
            report by the RAND Corporation, the Parking Cash-Out program  
            is inexpensive to administer and offers numerous benefits,  
            including easing traffic congestion, improving air quality,  
            reducing greenhouse gas emissions, promoting social equity,  
            and supporting investments in other travel modes.

            Traffic congestion and vehicle emissions.  A 1997 study  
            conducted for ARB examining the impact of the parking cash-out  
            law on commute behavior found:

                 Solo driving dropped 17 percent, from 76 percent to 63  
               percent of employees.

                 Carpooling increased by 64 percent, from 14 percent to  
               23 percent of employees.

                 Transit use increased by 50 percent, from 6 percent to 9  
               percent.

                 Combined bicycling and walking increased 33 percent,  
               from 3 to 4 percent.

                 Vehicle miles traveled, along with their associated  
               emissions, decreased by 12 percent per employee per year.

                 Implementing parking cash-out resulted in "an average  
               reduction in carbon-dioxide emissions of 367 kg (or nearly  
               half a ton) per employee per year." 

            Equity:  When employers offer free or subsidized parking  
            without offering subsidies to employees for other travel  
            modes, employers reward driving over other modes and provide a  
            commute benefit to some employees but not others.  The LAO  
            report on the cash-out program concludes: "By providing  
            parking cash-out, the employee is rewarded equally, whether he  
            or she walks, bikes, takes transit, carpools, or drives alone  
            to work."

            Furthermore, women, minorities, and lower-income workers are  
            less likely to drive to work alone.  Parking cash-out corrects  
            this imbalance by providing for equivalent subsidies  
            regardless of the travel mode.





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            Supports transit and carpool lane investments:  The LAO notes  
            that the state and local governments invest hundreds of  
            millions of dollars on infrastructure intended to support  
            non-highway modes of travel, including new carpool lanes,  
            expanded and more frequent bus and rail service, and bicycle  
            and pedestrian facilities.  Parking cash-out, by reducing the  
            incentive to drive alone, reinforces investments in other  
            modes of travel.

            To the extent this bill will foster greater compliance with  
            the Parking Cash-Out program, this bill has the potential to  
            promote greater choice among alternative commute options and  
            help reduce congestion, improve air quality, and reduce  
            greenhouse gas emissions associated with driving to work.

           4.Implementation  .  The FTB publishes changes to the tax code  
            each year, which are widely distributed using a variety of  
            media.  These changes are distributed by the FTB in tax  
            booklets and published online, and are also distributed by  
            trade organizations and included in tax preparation software.   
            In other words, awareness of the cash-out requirement will  
            increase.  To the extent that the employer wants to claim a  
            deduction for parking subsidies, the employer will comply with  
            the requirement.   

           5.Facility improvements for ridesharing  .  Current law allows  
            employers to deduct the cost of making facility improvements  
            to encourage employees to participate in ridesharing  
            arrangements.  This bill does not include these expenditures  
            for purposes of calculating a tax credit. Because these  
            facilities may support the reduction in commute trips and are  
            consistent with deductions taken for such activities, the  
            author or committee may wish to consider an amendment to allow  
            expenditures for these facility improvements to be considered  
            in the calculation of a tax credit provided under this  
            measure.

           6.Author's amendment  .  The author intends to offer an amendment  
            in committee that would delete the provision of the bill that  
            exempts from the Administrative Procedures Act any rule or  
            regulation adopted by the FTB to implement the tax credit  
            established by this bill.  According to the author, the FTB  
            indicates it could implement the tax credit in accordance with  
            existing regulations.

           7.Technical amendments  .  The author or committee may also wish  




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            to make the following technical amendments:

                 Page 5, line 7 and Page 8, line11, which are identical,  
               strike "meaning" and insert "meanings" 

                 Subparagraphs (H) and (I) on pages 3 and 6, which are  
               identical, could be combined and written more clearly to  
               read: 

               (H) Making facility improvements to encourage employees to  
               use, or subsidizing employees who already use, an  
               alternative transportation method other than a  
               transportation method specified in this paragraph, that  
               reduces the use of a motor vehicle by a single occupant to  
               travel to or from that employee's place of employment.   
               Alternative transportation methods may include, but are not  
               limited to, walking and bicycling.

            In lieu of the above amendment, the author or committee may  
            wish to make the following amendments to subparagraphs (H) and  
            (I):

                 Page 3, line 15 and page 6, line 18, which are  
               identical, insert "use" after the second "to" 
                      
           8.Double-referral  .  This bill is double-referred to this  
            committee and the Senate Committee on Revenue and Taxation.   
            If the bill passes this committee, it will then be referred to  
            the Revenue and Taxation Committee.
          
          RELATED LEGISLATION

          SB 518 (Lowenthal) establishes incentives to reduce governmental  
          or government-mandated subsidies for parking and reveal the true  
          cost of parking to drivers as a means to reduce traffic  
          congestion and greenhouse gas emissions.  Passed this committee  
          on a 6-4 vote.  Set for hearing on April 29th in the Senate  
          Education Committee. 

          SB 728 (Lowenthal) allows cities, counties, and air districts to  
          ensure compliance with the state's Parking Cash-Out law.  Set  
          for hearing on May 4th in the Senate Environmental Quality  
          Committee.

          AB 1186 (Blumenfield) requires that lease agreements for  
          nonresidential buildings occupied by 50 or more persons that  




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          offer parking to tenants list separately the costs for parking  
          from other costs included in the lease.  In the Assembly  
          Transportation Committee.
          
           POSITIONS:  (Communicated to the Committee before noon on  
                     Wednesday,                              
                      April 22, 2009)

               SUPPORT:  None received.
          
               OPPOSED:  None received.