BILL ANALYSIS                                                                                                                                                                                                    �






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: sB 867
          SENATOR MARK DESAULNIER, CHAIRMAN              AUTHOR:  padilla
                                                         VERSION: 2/18/11
          Analysis by:  Art Bauer                        FISCAL:  yes
          Hearing date:  January 10, 2012

          SUBJECT:

          Build California Bonds

          DESCRIPTION:

          This bill permits the California Transportation Financing 
          Authority to issue nonrefundable tax credit bonds, which would 
          be available to California income taxpayers, to fund the 
          construction of local transportation projects.

          ANALYSIS:

          AB 798 (Nava), Chapter 474, Statutes of 2009, established the 
          California Transportation Financing Authority within the State 
          Treasurer's office to assist local agencies finance 
          transportation projects.  AB 798:

             1.   Specifies the revenue sources that may be pledged as 
               security for revenue bonds the Authority issues to include 
               local transportation funds, fuel taxes, local 
               transportation sales taxes, state revenues approved for 
               this purpose by the Legislature or by initiative, developer 
               fees, and tolls.

             2.   Specifies the requirements that a project must meet in 
               order to be financed or refinanced by the authority to 
               include: 
                     The project complies with all relevant statutes 
                 applicable to the planning, programming, and construction 
                 of transportation projects.
                     The project is contained in the constrained portion 
                 of a conforming regional transportation plan that is 
                 consistent with the greenhouse gas reduction targets 
                 assigned by the Air Resources Board.
                     For highway projects, the project sponsor has 
                 secured the support of the Department of Transportation 
                 (Caltrans) and the project is consistent with the needs 
                 and requirements of the state's highway system.
                     The project is financially and technically feasible.




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                     The project meets or exceeds environmental 
                 requirements and has all necessary permits approved.
                     The project sponsor has developed performance 
                 measures for the project to monitor its progress.
                     That a project has community support, which shall be 
                 demonstrated through a public review and comment process.
                     For toll financed highway projects, the project 
                 sponsor submits to the California Transportation 
                 Commission (CTC) a plan that demonstrates how transit 
                 service or alternative modes of transportation will be 
                 enhanced in the corridor concurrent with the operation of 
                 a toll facility.

           This bill  :

             1.   Makes findings and declarations that it is in the public 
               interest to implement the Build California Bonds as soon as 
               possible to ensure the funding of high priority public 
               transportation projects. 

             2.   Defines "transportation project" as all or a part of the 
               planning, design, development, financing, construction, 
               reconstruction, rehabilitation, improvement, or acquisition 
               of a highway, street, rail line, bus line, or related 
               facilities supplemental to or improvements upon existing 
               facilities currently owned and operated by a transportation 
               agency, so long as the project life is at least as long as 
               the term of the bonds financing it. 

             3.   Authorizes the Authority to enter into financing 
               agreements with local transportation agencies to finance or 
               refinance transportation projects.  At least 95 percent of 
               the financing proceeds from the Build California Bonds must 
               be for the financing or re-financing of transportation 
               capital expenditures.  No outstanding bonds previously 
               issued may be re-financed with the proceeds of Build 
               California Bonds.

             4.   Authorizes the State Treasurer through the Authority to 
               issue up to $5 billion of Build California Bonds, with a 
               maturity not to exceed thirty years, for the purpose of 
               financing and re-financing the cost of transportation 
               projects.

             5.   Defines the Build California Bonds as "tax credit" bonds 
               and allows a bond holder to claim a nonrefundable tax 




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               credit at the time the individual or the corporation files 
               a state tax return.  The tax credit is in lieu of interest 
               payments, and the state is not obligated to make any cash 
               payments with respect to the tax credit.

             6.   Limits the total amount of bonds issued to $5 billion, 
               provided that no more than $1 billion may be issued in one 
               year and any unused proportion of the annual authorization 
               may be rolled over to be issued in a subsequent year.  In 
               addition, the bill requires the Authority to determine 
               prior to the issuance of any Build California Bonds that 
               the aggregate amount of state tax credits granted to all 
               taxpayers holding bonds previously issued and new bonds 
               being issued does not exceed $250 million for any fiscal 
               year.  

             7.   Establishes two tests for capping the amount of state 
               tax credit associated with any issuance of the bonds: 

                     Limits the amount of state tax credit associated 
                 with any issuance of Build California Bonds to not exceed 
                 the greater of (1) five percent of the face amount of 
                 bonds outstanding or (2) the yield required to market the 
                 bonds to investors at a price or par.  
                     Limits the amount of tax credit in any calendar year 
                 with respect to any Build California Bond to an amount 
                 that is equal to the principal amount of the bonds times 
                 the percentage rate specified in the above.

             1.   Provides that Build California Bonds are not a debt or 
               liability of the state. 




          COMMENTS:

              1.   Purpose  .  The purpose of this bill is to add a state 
               component to Metro's debt financing strategy.  According to 
               the author, if a local transportation agency desires to 
               accelerate the construction of projects, the cost of 
               accelerating financing, however, would be a substantial 
               cost to the agency.  By creating a state tax credit bond, 
               the cost to the local agency is reduced.  This, the author 
               argues, will accelerate construction of transportation 
               projects, and provide the economic benefits forecasted by 




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               the LAEDC.  While the author emphasizes the advantage of 
               this bill for developing transit projects in Los Angeles 
               County, the tax credit bonds may be used to assist in the 
               financing of highway projects as well in all eligible 
               counties.

              2.   Background  .  The sponsor of this bill is the Los Angeles 
               County Metropolitan Transportation Authority (Metro).  
               Metro has adopted a transportation financing strategy for 
               constructing twelve mass transportation projects throughout 
               Los Angeles County in ten years rather than the usual 
               thirty years when relying upon the conventional grant 
               funding approach. 

               This strategy referred to as the 30/10 Initiative relies 
               upon using the revenue from the local, voter-approved 
               Measure R transportation sales tax as collateral for 
               long-term bonds and federal loans.  Metro believes this 
               will allow it to achieve its ambitious construction 
               timeline and will also result in substantial construction 
               cost savings.  Successful implementation of the 30/10 
               Initiative is expected to deliver immediate economic 
               benefits.  According to the Los Angeles Economic 
               Development Corporation (LAEDC), the $12.6 billion 30/10 
               Initiative, which anticipates $10.8 billion in direct 
               construction expenditures will generate $23.3 billion of 
               regional economic output, 137,000 jobs, $8.7 billion of 
               direct income to project workers, and federal, state and 
               local taxes of $962 million during the ten years of the 
               program.

              3.   State assumes new transportation funding responsibility  . 
                This bill involves the state in a new funding scheme for 
               financing transportation investments, the use of state 
               income tax credits in lieu of interest payments for local 
               transportation debt.  The tax credit is nonrefundable.  (A 
               nonrefundable tax credit prohibits the taxpayer from 
               seeking a cash refund in the event there is no tax 
               obligation from which to deduct the credit.)  This bill 
               allows unused tax credits to be rolled over for up to ten 
               years.  At a minimum, it appears that the tax credit is at 
               least five percent but may be higher.  This bill provides 
               that the total tax credits for any fiscal year cannot 
               exceed $250 million.  The total amount of bonds issued that 
               would be entitled to tax credits is $5 billion.  No more 
               than $1 billion of bonds can be issued per fiscal year. 




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              4.   Back to the general fund for transportation funding  .  
               Essentially, after the Legislature extricated 
               transportation funding from the general fund last year with 
               the gas tax swap, this bill puts transportation back into 
               the general fund through the use of tax credits.  As a 
               result of the swap, the debt service on general obligation 
               bonds financing highway improvements is funded from the gas 
               tax.  State general obligation bonds that fund mass 
               transportation projects, such as high-speed rail remain an 
               obligation of the general fund.

               Having removed transportation funding from the general 
               fund, the principle sources of state revenue for 
               transportation programs include the 35.3 cents per gallon 
               excise tax on gasoline for highways, a 6.62 percent sales 
               tax on diesel fuel for mass transportation, and proceeds of 
               general obligation bonds.  At the local level, a  percent 
               of the local sales tax in each county is designated 
               primarily for public mass transportation.  In addition, 
               eighteen counties have voter approved local transportation 
               sales taxes.  Most of the voter approved sales taxes have a 
               sunset date.  Los Angeles County has two permanent  
               percent sales taxes, and a third, referred to as Measure R 
               passed by the voters in 2008, that will sunset in forty 
               years.  In addition, four transit districts have permanent 
                percent sales taxes. 

               This bill authorizes the State Treasurer, acting through 
               the Authority, to issue the debt for local transportation 
               projects.  The principal is the obligation of the borrower, 
               in this case Metro or another eligible local agency.  
               Therefore, should a default occur, it is the obligation of 
               the borrower and not the state.  To be sure, the state is 
               not directly financing a project.  The state is, however, 
               reducing the cost of debt to the local agency by removing 
               interest costs and substituting a tax credit against state 
               income tax owed by taxpayers.  This is a cost shift to the 
               state general fund.

               The State Treasurer's office, in conversations with the 
               committee staff, indicated that there are not a sufficient 
               number of California taxpayers to take advantage of the tax 
               credit.  In addition, high wealth taxpayers typically tax 
               planning horizon is about five years not the longer time 
               horizon associated with bonds.  Finally, the Treasures 




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               office indicated that it is unlikely that there would be a 
               secondary market for the bonds. 
           
             5.   Tax credits not offset by 30/10 Initiative  .  This bill 
               caps the annual tax credit at $250 million per year.  Over 
               thirty years this would be a potential cost of up to $7.5 
               billons to the general fund.  According to the LAEDC's 
               analysis, the 30/10 Initiative over the ten year 
               construction period would generate $962 million in total 
               taxes including, state, local, and federal.  This analysis 
               suggests that the economic activity generated by the 30/10 
               Initiative will not make the state whole.
           
             6.   Modeled on Build America Bonds  .  Congress included the 
               Build America Bonds (BABs) in the American Recovery and 
               Reinvestment Act of 2009.  In general, there were two types 
               of BABs: interest rate subsidy bonds and a tax credit bond 
               equal to 35 percent of the interest payable by the issuer.  
               Public agencies preferred the interest rate subsidy option. 
                Unlike municipal bonds, the interest was taxable and 
               equivalent to corporate bond interest rates, but the 
               Federal government paid the issuer 35 percent of the 
               interest cost when due.  For example, California sold $5.2 
               billion of BABs at 7.4 percent, but with the 35 percent 
               subsidy the effective interest rate paid by the state is 
               4.8 percent.  The bonds were popular with institutions and 
               individuals, especially pension funds and foreign 
               investors, as they do not pay federal taxes.  The tax 
               credit option was not used.  BABs sunseted on December 31, 
               2010. 

              7.   Previous hearing  .  The committee heard, but did not 
               vote, on this bill on April 26, 2011. In the interim, the 
               committee held two informational hearings on the subject 
               matter of this bill.  The first hearing was held in Los 
               Angeles where the committee learned about the types of 
               transportation projects that might be financed by the Build 
               California Bonds.  A second hearing was heard on the 
               financial issues associated with this bill in Sacramento. 

              8.   Doubled Referred  .  This bill is also referred to the 
               Governance and Finance Committee because of the tax credit 
               features of the bill.

          POSITIONS:  (Communicated to the committee before noon on 
          Wednesday,




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                     January 4, 2012)

               SUPPORT:  Los Angeles County Metropolitan Transportation 
          Authority (Sponsor)
                         Associated General Contractors
                         

          
               OPPOSED:  None received.