BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 29 X1
                                                                  Page  1

          Date of Hearing:   February 22, 2001

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                               Ellen M. Corbett, Chair
                  AB 29 X1 (Kehoe) - As Amended:  February 20, 2001

          2/3 vote.  Urgency.  Fiscal committee.
           
          SUBJECT  :  Personal Income and Bank and Corporation Taxes:   
          Energy Conservation Tax Credit

           SUMMARY  :  Authorizes a 30% credit for the costs paid or incurred  
          to replace a commercial refrigeration unit with a more  
          energy-efficient model and authorizes several programs intended  
          to encourage small businesses to reduce their energy  
          consumption.  Specifically, the tax provisions of  this bill  :  

          1)Authorize a 30% credit for the costs paid or incurred by a  
            small business to replace a commercial refrigeration unit with  
            a more energy-efficient model.

          2)Cap the value of the credit at $2,000.

          3)Allow unused credits to be carried forward for up to five  
            years.

          4)Define the small businesses eligible for the credit by  
            reference to Section 14837 of the Government Code.  Under that  
            definition, the business must either be a manufacturer with  
            100 or fewer employees or must satisfy all of the following  
            criteria: independently owned and operated; not dominant in  
            its field of operation; have its principal office in  
            California; have its officers domiciled in California; have,  
            together with its affiliates, 100 or fewer employees; and have  
            averaged annual gross receipts of $10 million or less over the  
            previous three years. 

          5)Become operative for taxable years beginning on or after  
            January 1, 2002.

          6)Require the Franchise Tax Board (FTB) to report to the  
            Legislature annually beginning on or before January 1, 2003  
            regarding utilization of the tax credits authorized by the  
            bill.









                                                                  AB 29 X1
                                                                  Page  2

          7)Provide a gross income exclusion for the value of any grants  
            awarded pursuant to the bill's provisions.

           EXISTING LAW  does not offer any credits or other tax incentives  
          for the purchase or lease of energy-efficient refrigeration  
          units. 

           FISCAL EFFECT  :  Pending.  FTB estimated that an earlier version  
          of the bill which authorized the credit under the Personal  
          Income Tax Law but not the Bank and Corporation Tax Law would  
          result in revenue losses in the range of $5 to $10 million  
          annually beginning in 2002-03.  They commented that expanding  
          the credit by offering it under the Bank and Corporation Tax Law  
          would result in significant additional revenue losses.   
          Committee staff estimate that these revenue losses could  
          potentially be in the range of $50 to $100 million annually.

           COMMENTS  :   

          1)This bill has been double-referred to the Revenue and Taxation  
            Committee and Energy Costs and Availability Committee.  This  
            analysis will focus only on those parts of the bill which fall  
            under the jurisdiction of the Revenue and Taxation Committee.

          2)The author's office is currently working with Committee staff  
            and the Franchise Tax Board on amendments to address the  
            following policy and implementation concerns. 

             a)   As currently written, the bill fails to clarify whether  
               the $2,000 cap applies to the credit or to the cost against  
               which the credit may be claimed.

             b)   The bill lacks definitions for some of its terms,  
               including "cost of replacement" and "more  
               energy-efficient."  Definitions for these terms are  
               necessary for FTB to administer the bill.

             c)   The bill lacks a mechanism for allowing FTB to verify  
               the purchase and installation of a more energy-efficient  
               model. 

             d)   The credit is not restricted to commercial refrigeration  
               units that are placed in service in California.

             e)   The bill may pose constitutional concerns by requiring  








                                                                  AB 29 X1
                                                                  Page  3

               businesses to be domiciled in California in order to claim  
               the credit.

             f)   The bill lacks a sunset date.  

             g)   The bill requires FTB to report to the Legislature on or  
               before January 1, 2003 and each year thereafter regarding  
               utilization of the tax credit authorized by the bill.  If  
               the tax credit provisions of the bill are not operative  
               until the 2002 tax year, FTB will not have the data  
               necessary to report to the Legislature regarding credit  
               utilization until 2004. 

             h)   There is no mechanism for the state to recover the tax  
               credit if a taxpayer sells the commercial refrigeration  
               unit or fails to use it within a specified time period.

             i)   The language in the bill relating to a gross income  
               exclusion for the value of any grants awarded pursuant to  
               the bill's provisions does not achieve the author's intent.  
                Language providing for the gross income exclusion must be  
               added to the Revenue and Taxation Code in order to  
               accomplish what the author desires. 

          3)The tax provisions of this bill will become operative on  
            January 1, 2002, thereby failing to serve as an incentive for  
            businesses to purchase more energy-efficient commercial  
            refrigeration models during 2001. 

          4)Although Committee staff understand that it is the author's  
            intent to pay for the tax credit with a portion of the bill's  
            $200 million appropriation for replacing energy efficient  
            appliances, there is currently no language in the bill that  
            would achieve that intent.  As the bill is currently written,  
            the tax credit would result in General Fund revenue losses  
            unassociated with the bill's appropriations. 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Planning and Conservation League
          Michael Shames, of UCAN

           Opposition 








                                                                 AB 29 X1
                                                                  Page  4

          
          None on file.
           
          Analysis Prepared by  :    Eileen A. Roush / REV. & TAX. / (916)  
          319-2098