BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 632
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          SENATE THIRD READING
          SB 632 (Alan Lowenthal)
          As Amended  August 18, 2010
          Majority vote

           SENATE VOTE:    Vote not relevant
            
           TRANSPORTATION                  APPROPRIATIONS                  
               (vote not relevant)                (vote not relevant)

           SUMMARY  :  Allow the South Coast Air Quality Management District  
          (SCAQMD) and the Sacramento Metropolitan Air Quality management  
          District (SMAQMD) to levy vehicle registration renewal fees of  
          up to $3 to fund emission control projects.  Specifically,  this  
          bill  :  

          1)Allows SCAQMD and the SMAQMD to levy a fee of up to $3 upon  
            motor vehicles registered within their respective districts.  

          2)Requires any such fees to be paid to and collected by the  
            Department or Motor Vehicles (DMV) upon registration renewal.   


          3)Exempts from this fee any vehicle that does not pay  
            registration fees or that meets the standards of a  
            zero-emission vehicle.  

          4)Requires DMV to distribute to SCAQMD and SMAQMD the revenues  
            from this fee, less DMV's own costs.  

          5)Requires SCAQMD and the SMAQMD to use the revenues for  
            projects to reduce nitrogen oxides (NOx) or volatile organic  
            compound (VOC) emissions from motor vehicles.  

          6)Prohibits SCAQMD and SMAQMD from using more than 5% of the  
            revenues for their own administrative costs.  

          7)Prohibits the SCAQMD and the SMAQMD from using the revenues to  
            fund projects required by local, state or federal mandates  
            unless the project funding is awarded before the compliance  
            dates of those mandates.  

          8)Allows SCAQMD and SMAQMD to use the revenues to fund projects  
            even if the State Implementation Plan (SIP) already assumes  
            that the emission reductions from those projects will occur.  








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           EXISTING LAW  :  

          1)Requires a vehicle registration fee of $31 to be paid for the  
            registration of every motor vehicle, except those expressly  
            exempt.  

          2)Authorizes a variety of additional fees that are related to  
            the operation of motor vehicles to be paid with the  
            registration, most particularly to address certain air quality  
            and law enforcement issues.  These fees support, among other  
            things, service authorities for freeway emergencies,  
            California Highway Patrol staffing, and fingerprint  
            identification programs.  

          3)Authorizes an air pollution control district designated by the  
            Air Resources Board (ARB) as a state non-attainment area for  
            any pollutant emitted by motor vehicles to levy a fee up to $6  
            on motor vehicles registered within an air district.  

          4)Authorizes the San Joaquin Valley Unified Air Pollution  
            Control District to increase the motor vehicle registration  
            fee to up to, but not exceeding, $30 for incentive-based  
            programs to achieve surplus emission reductions.  

           FISCAL EFFECT  :  Unknown

           COMMENTS  :  Section 185 of the Federal Clean Air Act (CAA)  
          requires areas that are designated as Severe or Extreme  
          Nonattainment of the National Ambient Air Quality Standards  
          (NAAQS) for ozone to develop, as a revision to the SIP, a fee  
          collection rule to be implemented in the event that an area  
          fails to attain the ozone standards by the required attainment  
          date.  

          The theory behind the now more than 30 year old requirement is  
          that the fee would act as a deterrent to emissions and result in  
          additional pollution control.  Failure to adopt a Section 185  
          approvable rule will result in sanctions that may include higher  
          emission offset ratios and loss of highway funding.   
          Additionally, the California Environmental Protection Agency  
          (EPA) would be required to adopt a federal rule to implement  
          Section 185 and would collect the fee plus substantial penalties  
          directly.  









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          Although the one-hour ozone standard has been revoked and major  
          stationary sources contribute less than 10% to the emissions  
          inventory, "major stationary sources" are still required to pay  
          the fee.  This requirement places an extreme economic burden on  
          some stationary sources because such sources in California are  
          required to have maximum feasible controls and already pay  
          administrative fees.  In contrast, according to SCAQMD, mobile  
          sources including motor vehicles, locomotives, ships and  
          off-road equipment have not reduced their fair share of  
          emissions.  The current Section 185 fee is over $8,000 per ton,  
          and exceeds $30 million in aggregate in the SCAQMD  
          jurisdictional area alone and potentially millions more in the  
          SMAQMD.  

          The SCAQMD's mission is to protect public health by reducing air  
          pollution including attainment of state and federal ambient air  
          quality standards.  SCAQMD, as the local air quality agency, has  
          primary jurisdiction over stationary sources of air pollution,  
          and limited authority over mobile sources.  Reducing emissions  
          from mobile sources is primarily the responsibility of state and  
          federal governments.  

          Great strides have been made in improving air quality; however,  
          areas under SCAQMD jurisdiction still do not meet the federal  
          standards for ozone summertime smog, although stationary sources  
          have achieved a control level upwards of 90%.  The reality is  
          that the federal clean air standards in South Coast Air Basin  
          (SCAB) cannot be achieved without significantly reducing  
          emissions from mobile sources beyond today's regulations.  The  
          Sacramento region also faces challenges of its own.   
          
          The CAA Section 185 fee is intended to be a penalty for major  
          stationary sources in areas that have not done all that they can  
          do to reduce emissions.  In reality, within SCAQMD, major  
          stationary sources have complied with the most stringent control  
          requirements anywhere and have invested a significant amount of  
          resources in air pollution controls.  Even with the elimination  
          of all stationary sources, the SCAB would not meet the federal  
          standards, without significant reduction of emissions from  
          mobile sources.  

          Approximately 350 businesses will be forced to pay Section 185  
          fees within SCAQMD, amounting to about $30 million in total.   
          Within SMAQMD, 15 businesses may collectively be forced to pay  
          close to $3 million in Section 185 fees.  Fees are based on  








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          emissions, at a rate of over $8,000 per ton, at this time.  As  
          an added burden, the baseline for calculating the penalty fees  
          is 2010, a time when most businesses are not operating at full  
          capacity due to the recession.  As the economy recovers, these  
          businesses will operate closer to normal, and could be forced to  
          pay even higher penalty fees.  Thus, the CAA Section 185 fee is  
          not only unfair, it may also delay the economic recovery for  
          certain businesses and force them to curtail operations or move  
          out of state.  

          On January 5, 2010, the United States Environmental Protection  
          Agency (USEPA) released guidance that provides for the use of  
          alternative programs to satisfy the CAA Section 185 fee  
          requirement provided it comports with the principles of CAA  
          Section 172(e).  One alternative specifically identified by  
          USEPA was a fee equivalent program.  Such a program must raise  
          at least as much revenue as otherwise required by the Section  
          185 fee program and the proceeds are expended to reduce  
          emissions of ozone-forming pollutants in the same geographic  
          area.  Under this concept, a program can be developed to shift  
          the fee burden from the specific set of major stationary sources  
          affected by the Section 185 fee to mobile sources which emit  
          about 80% of the pollutants that contribute to ozone formation  
          in the SCAB.  The large stationary sources emit less than 10% in  
          comparison.  

          Accordingly, the proponents of this bill contend that the state  
          should enact legislation authorizing SCAQMD and SMAQMD to levy a  
          motor vehicle fee up to $3 and allow such funds to be spent on  
          emission reduction projects consistent with the EPA guidance  
          referenced earlier.  The fee is a small percentage of the total  
          motor vehicle registration fee and would be relatively small  
          compared to similar fees authorized for other areas of  
          California.  

          Multitude of vehicle registration and license fee revenue bills:  
           There are a number of proposals being considered that would  
          raise either the vehicle registration or license fees for  
          various purposes, including funding state park maintenance,  
          regional blueprint greenhouse gas reduction planning, etc.    
          Should these proposals be considered on a broader, overarching  
          level rather than considered separately on a piecemeal basis in  
          determining the ultimate beneficiary or beneficiaries of the fee  
          revenues?  









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          Arguments in support:  According to the SMAQMD "Because of an  
          East Coast bias in federal law and regulation, Sacramento  
          employers will face harsh fines from the USEPA, with the moneys  
          from those fines going to Washington, D.C., unless the local air  
          district is able to generate alternative funds to achieve  
          emissions reductions required by the federal government.  
          Granting the local air district's board with authority to raise  
          DMV registration surcharges by no more than $3 would provide the  
          district with the means to implement projects and programs to  
          reduce pollution from motor vehicles, which are the largest  
          source of emissions.  Rather than impose fines upon employers  
          already hard-hit by the economic crisis, we believe minor  
          adjustments to motor vehicle registrations surcharges is by far  
          the fairer, wiser course of action."  

           
          Analysis Prepared by  :   Ed Imai / TRANS. / (916) 319-2093 FN:  
          0006216