Legislature(2011 - 2012)BARNES 124

04/12/2011 04:15 PM LABOR & COMMERCE

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04:24:10 PM Start
04:24:26 PM SB23
05:00:01 PM Adjourn
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Heard & Held
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                    ALASKA STATE LEGISLATURE                                                                                  
          HOUSE LABOR AND COMMERCE STANDING COMMITTEE                                                                         
                         April 12, 2011                                                                                         
                           4:24 p.m.                                                                                            
MEMBERS PRESENT                                                                                                               
Representative Kurt Olson, Chair                                                                                                
Representative Craig Johnson, Vice Chair                                                                                        
Representative Mike Chenault                                                                                                    
Representative Dan Saddler                                                                                                      
Representative Steve Thompson                                                                                                   
Representative Lindsey Holmes                                                                                                   
Representative Bob Miller                                                                                                       
MEMBERS ABSENT                                                                                                                
All members present                                                                                                             
OTHER LEGISLATORS PRESENT                                                                                                     
Representative Chris Tuck                                                                                                       
COMMITTEE CALENDAR                                                                                                            
COMMITTEE SUBSTITUTE FOR SENATE BILL NO. 23(FIN)                                                                                
"An Act relating to transferable  film production tax credits and                                                               
film   production   tax   credit  certificates;   requiring   the                                                               
legislative audit  division to audit  the Alaska  film production                                                               
incentive  program;  and  providing  for  an  effective  date  by                                                               
amending  the effective  dates  of secs.  3 and  4,  ch. 63,  SLA                                                               
     - HEARD & HELD                                                                                                             
PREVIOUS COMMITTEE ACTION                                                                                                     
BILL: SB 23                                                                                                                   
SHORT TITLE: FILM PRODUCTION TAX CREDIT/AUDITS                                                                                  
SPONSOR(s): SENATOR(s) ELLIS                                                                                                    
01/19/11       (S)       PREFILE RELEASED 1/7/11                                                                                
01/19/11       (S)       READ THE FIRST TIME - REFERRALS                                                                        
01/19/11       (S)       L&C, FIN                                                                                               
02/17/11       (S)       L&C AT 1:30 PM BELTZ 105 (TSBldg)                                                                      
02/17/11       (S)       Heard & Held                                                                                           
02/17/11       (S)       MINUTE(L&C)                                                                                            
02/22/11       (S)       L&C AT 1:30 PM BELTZ 105 (TSBldg)                                                                      
02/22/11       (S)       Moved SB 23 Out of Committee                                                                           
02/22/11       (S)       MINUTE(L&C)                                                                                            
02/23/11       (S)       L&C RPT  4DP 1NR                                                                                       
02/23/11       (S)       DP: EGAN, DAVIS, PASKVAN, MENARD                                                                       
02/23/11       (S)       NR: GIESSEL                                                                                            
03/21/11       (S)       FIN AT 9:00 AM SENATE FINANCE 532                                                                      
03/21/11       (S)       Heard & Held                                                                                           
03/21/11       (S)       MINUTE(FIN)                                                                                            
04/04/11       (S)       FIN RPT CS 7DP    NEW TITLE                                                                            
04/04/11       (S)       DP: HOFFMAN, STEDMAN, THOMAS, EGAN,                                                                    
                         MCGUIRE, OLSON, ELLIS                                                                                  
04/04/11       (S)       FIN AT 9:00 AM SENATE FINANCE 532                                                                      
04/04/11       (S)       Moved CSSB 23(FIN) Out of Committee                                                                    
04/04/11       (S)       MINUTE(FIN)                                                                                            
04/06/11       (S)       TRANSMITTED TO (H)                                                                                     
04/06/11       (S)       VERSION: CSSB 23(FIN)                                                                                  
04/07/11       (H)       READ THE FIRST TIME - REFERRALS                                                                        
04/07/11       (H)       L&C, FIN                                                                                               
04/08/11       (H)       L&C AT 3:15 PM CAPITOL 106                                                                             
04/08/11       (H)       Heard & Held                                                                                           
04/08/11       (H)       MINUTE(L&C)                                                                                            
04/10/11       (H)       L&C AT 3:15 PM BARNES 124                                                                              
04/10/11       (H)       -- MEETING CANCELED --                                                                                 
04/11/11       (H)       L&C AT 3:15 PM BARNES 124                                                                              
04/11/11       (H)       Heard & Held                                                                                           
04/11/11       (H)       MINUTE(L&C)                                                                                            
04/12/11       (H)       L&C AT 4:15 PM BARNES 124                                                                              
WITNESS REGISTER                                                                                                                
BARBARA HUFF TUCKNESS, Director                                                                                                 
Governmental and Legislative Affairs                                                                                            
Teamsters Local 959                                                                                                             
Anchorage, Alaska                                                                                                               
POSITION STATEMENT:  Testified in support of SB 23.                                                                           
WANETTA AYERS, Director                                                                                                         
Anchorage Office                                                                                                                
Economic Development Section                                                                                                    
Department of Commerce, Community & Economic Development (DCCED)                                                                
Anchorage, Alaska                                                                                                               
POSITION STATEMENT:  Testified and answered questions during the                                                              
discussion of SB 23.                                                                                                            
JOHANNA BALES, Acting Director                                                                                                  
Tax Division                                                                                                                    
Anchorage Office                                                                                                                
Department of Revenue (DOR)                                                                                                     
Anchorage, Alaska                                                                                                               
POSITION STATEMENT:  Testified and  answered questions during the                                                             
discussion of SB 23.                                                                                                            
KONRAD JACKSON, Staff                                                                                                           
Representative Kurt Olson                                                                                                       
Alaska State Legislature                                                                                                        
Juneau, Alaska                                                                                                                  
POSITION STATEMENT:  Explained potential amendments to SB 23.                                                                 
KATE TESAR, Director of Business Development                                                                                    
Evergreen Films                                                                                                                 
Anchorage, Alaska                                                                                                               
POSITION STATEMENT:  Testified during the discussion of SB 23.                                                                
ACTION NARRATIVE                                                                                                              
4:24:10 PM                                                                                                                    
CHAIR KURT  OLSON called  the House  Labor and  Commerce Standing                                                             
Committee meeting  to order at  4:24 p.m.  Representatives Olson,                                                               
Thompson,  Holmes, Miller,  Chenault, Johnson,  and Saddler  were                                                               
present at the call to order.                                                                                                   
            SB 23-FILM PRODUCTION TAX CREDIT/AUDITS                                                                         
4:24:26 PM                                                                                                                    
CHAIR OLSON  announced that the  only order of business  would be                                                               
SENATE  BILL  NO.  23,  "An Act  relating  to  transferable  film                                                               
production tax  credits; and providing  for an effective  date by                                                               
amending  the effective  dates  of secs.  3 and  4,  ch. 63,  SLA                                                               
4:24:59 PM                                                                                                                    
BARBARA  HUFF TUCKNESS,  Director,  Governmental and  Legislative                                                               
Affairs, Teamsters  Local 959 (Teamsters)  referred members  to a                                                               
letter of  support that  outlines the  reasons for  the Teamsters                                                               
Local 959's support for SB 23.   She stated that her organization                                                               
has observed firsthand a significant  increase in employment with                                                               
the  passage  of the  bill  several  years  ago.   She  expressed                                                               
excitement  over the  proposed extension  of the  film production                                                               
tax credits.   She said  the Teamsters look forward  to potential                                                               
training,  since a  limited number  of Alaskans  have the  skills                                                               
needed.  She  commented that the Teamsters Local  959 is "behind"                                                               
anything  with "wheels"  pertaining to  the film  industry.   She                                                               
hoped the bill would pass out today.                                                                                            
4:27:01 PM                                                                                                                    
WANETTA AYERS,  Director, Anchorage Office,  Economic Development                                                               
Section,   Department   of   Commerce,   Community   &   Economic                                                               
Development  (DCCED), stated  the department  has vetted  some of                                                               
the changes in the current  committee substitute and has provided                                                               
comments.  She offered to answer questions.                                                                                     
4:27:37 PM                                                                                                                    
CHAIR  OLSON,  after first  determining  no  one else  wished  to                                                               
testify, closed public testimony on SB 23.                                                                                      
CHAIR  OLSON  removed his  objection.    There being  no  further                                                               
objection, Version G was before the committee.                                                                                  
The committee took an at-ease from 4:28 p.m. to 4:30 p.m.                                                                       
4:30:14 PM                                                                                                                    
REPRESENTATIVE  JOHNSON asked  for  clarification  on the  letter                                                               
from the Department of Revenue (DOR) dated April 12, 2011.                                                                      
JOHANNA BALES,  Acting Director, Tax Division,  Anchorage Office,                                                               
Department of  Revenue (DOR) expressed concern  that the proposed                                                               
committee substitute  would allow the  film credit to  be applied                                                               
to all the other tax types  administered by the DOR.  She brought                                                               
up  that the  language in  Version G  may create  some unintended                                                               
consequences  which  could   affect  municipal  revenue  sharing,                                                               
dedicated funds, and  other programs.  In some  programs, such as                                                               
the cigarette taxes, specific tax  revenue has been identified to                                                               
fund different activities  within the state.   She suggested that                                                               
the committee  may wish to consider  that opening the bill  up to                                                               
other tax types may have some unintended consequences.                                                                          
4:31:54 PM                                                                                                                    
REPRESENTATIVE JOHNSON asked whether  taxpayers could buy the tax                                                               
credits  for  cigarette taxes  and  not  deposit money  into  the                                                               
education fund as required under the tax laws.                                                                                  
MS.  BALES  related  her understanding  that  taxpayers  who  owe                                                               
cigarette taxes could purchase film  tax credits and reduce their                                                               
cigarette tax  liability.  A  portion of the cigarette  taxes are                                                               
designated to the  school fund and the remaining  is deposited in                                                               
the  state's  general  fund.    She was  unsure  if  any  of  the                                                               
reduction as a result of the  film credit would affect the amount                                                               
of the  school fund since  the taxpayer could  potentially reduce                                                               
its  entire  liability  for  cigarette   taxes.    She  suspected                                                               
provisions in the bill would  affect the school fund and probably                                                               
the general  fund, too.  She  pointed out that these  are some of                                                               
the  DOR's  questions with  the  bill.    The cruise  ship  taxes                                                               
present another example.   Currently, the department participates                                                               
in revenue  sharing with the first  seven ports of call,  and the                                                               
remaining  amounts are  designated  to  the Commercial  Passenger                                                               
Vessel  Tax Account  (CPVTA), which  is required  to be  used for                                                               
harbor  improvements  to  facilitate  cruise ship  tourism.    If                                                               
taxpayers  used  the  tax credits,  the  department  could  still                                                               
revenue share since  the taxes are based on $5  per port of call.                                                               
However,  it is  possible  insufficient revenue  would remain  to                                                               
deposit  to the  CPVTA.   Thus, funds  may not  be available  for                                                               
harbor improvements.                                                                                                            
4:34:06 PM                                                                                                                    
REPRESENTATIVE  JOHNSON asked  for  a list  of dedicated  revenue                                                               
MS.  BALES  responded  that taxpayers  could  purchase  the  film                                                               
credits.   In the event all  of the taxpayers for  gambling taxes                                                               
opted  for  film  credits,  revenue would  not  be  available  to                                                               
deposit into  the specific  account, she said.     The department                                                               
has  specific programs  that could  be affected  with respect  to                                                               
specific  sub-accounts within  the general  fund.   She indicated                                                               
that 50  percent of the  alcoholic beverage tax is  designated to                                                               
the  Department of  Health and  Social Services  to fund  alcohol                                                               
cessation programs.   It  is possible  the program  could receive                                                               
less  revenue unless  a  specific,  additional appropriation  was                                                               
made.   She remarked that  the list  of taxes is  actually fairly                                                               
long  since  rarely  are  100  percent  of  the  taxes  collected                                                               
deposited to the state's general fund.                                                                                          
4:35:59 PM                                                                                                                    
REPRESENTATIVE CHENAULT  asked whether the film  tax credit would                                                               
also apply to motor fuel taxes collected in the state.                                                                          
MS.  BALES answered  yes.    All motor  fuel  taxes collected  on                                                               
behalf of the  state are deposited into  separate sub-accounts in                                                               
the general  fund.  However,  the aviation fuel tax  collected is                                                               
deposited  to the  Aviation Fuel  Account, which  is shared  with                                                               
local   municipalities   that   own   the   municipal   airports.                                                               
Additionally, the  bill would  apply to  the highway  fuel taxes,                                                               
which are deposited to a special Highway Use Account, she said.                                                                 
REPRESENTATIVE  CHENAULT  related   his  understanding  that  the                                                               
department's concern  is by establishing  the film tax  credit in                                                               
Title 43  might short  fund municipalities  on airports  and road                                                               
projects based on fuel tax credits alone.                                                                                       
MS. BALES  agreed.   She suggested the  committee review  each of                                                               
the tax types  to ensure that the state  provides the appropriate                                                               
mechanism to ensure the historical  level of funding for programs                                                               
could be maintained.                                                                                                            
REPRESENTATIVE CHENAULT  pointed out  that the  legislature could                                                               
always "backfill"  the account with general  fund provided excess                                                               
general funds existed.                                                                                                          
MS. BALES answered yes.                                                                                                         
4:39:27 PM                                                                                                                    
The committee took an at-ease from 4:39 p.m. to 4:45 p.m.                                                                       
4:45:49 PM                                                                                                                    
KONRAD JACKSON,  Staff, Representative  Kurt Olson,  Alaska State                                                               
Legislature, on behalf  of the House Labor  and Commerce Standing                                                               
Committee  chaired  by  Representative  Olson,  related  that  he                                                               
planned  to  describe  four potential  amendments  the  committee                                                               
could consider to  address issues discovered after  Version G was                                                               
prepared.   He  referred  to proposed  Amendment  1, labeled  27-                                                               
LS0252\G.1, Bullock, 4/12/11, which read:                                                                                       
     Page 6, line 10, following "accountant":                                                                                   
          Insert ", licensed in the state and"                                                                              
     Page 6, line 11, following "office":                                                                                       
          Insert ","                                                                                                        
MR. JACKSON explained that the  intent of proposed Amendment 1 is                                                               
to ensure  that the  certified public  accountants used  to audit                                                               
the film production tax credit  program are licensed by the state                                                               
to operate in Alaska.                                                                                                           
4:46:42 PM                                                                                                                    
MR. JACKSON referred to Amendment 2, labeled 27-LS0252\G.2,                                                                     
Bullock, 4/12/11, which read:                                                                                                   
     Page 7, line 11, following "(10)":                                                                                         
          Insert "subject to the limitation in (c) of this                                                                  
     Page 7, following line 27:                                                                                                 
          Insert a new bill section to read:                                                                                    
       "* Sec. 19. AS 44.33.236 is amended by adding new                                                                    
     subsections to read:                                                                                                       
          (c)  The qualified expenditures described in                                                                          
     (a)(10) of this section may not exceed                                                                                     
               (1)  15 percent of the total production                                                                          
     budget after June 30, 2013, and before July 1, 2016;                                                                       
               (2)  12 percent of the total production                                                                          
      budget after June 30, 2016, and before July 1, 2018;                                                                      
               (3)  10 percent of the total production                                                                          
     budget after June 30, 2018.                                                                                                
          (d)  For the purposes of (c) of this section,                                                                         
     "total production  budget" means  the sum of  the total                                                                    
     qualified expenditures and  the total expenditures that                                                                    
     are  not qualified  expenditures that  are incurred  by                                                                    
     the  producer  in  connection with  a  film  production                                                                    
     approved by the film office."                                                                                              
     Renumber the following bill sections accordingly.                                                                          
MR.  JACKSON explained  that  proposed Amendment  2  would be  to                                                               
limit  some of  the  above the  line  expenses and  expenditures.                                                               
This  process is  a stepped  process  that would  go into  effect                                                               
beginning in 2013, 2016, and 2018, he said.                                                                                     
4:47:29 PM                                                                                                                    
MR. JACKSON referred to proposed Amendment 3, labeled 27-                                                                       
LS0252\G.3, Bullock, 4/12/11, which read:                                                                                       
     Page 8, line 30:                                                                                                           
          Delete "2024"                                                                                                     
          Insert "2029"                                                                                                     
     Page 8, line 31:                                                                                                           
          Delete "one year"                                                                                                     
          Insert "six years [ONE YEAR]"                                                                                     
MR. JACKSON  referred to page 7,  line 29-30 of Version  G, which                                                               
changes  the   dates  of  the   "look  back"  period   for  legal                                                               
proceedings from  one year  to six years  for recovery  of funds.                                                               
Proposed Amendment 3  would change one of the dates  from July 1,                                                               
2024  to July  1, 2029.   The  date was  inadvertently missed  in                                                               
proposed Section 24 of Version G, he said.                                                                                      
4:48:21 PM                                                                                                                    
MR.  JACKSON  referred  to  proposed  Amendment  4,  labeled  27-                                                               
LS0252\G.4, Bullock, 4/12/11, which read:                                                                                       
     Page 3, line 9:                                                                                                            
          Delete "this title"                                                                                               
          Insert "AS 21.09.210, AS 21.66.110, AS 43.20,                                                                     
     AS 43.55, AS 43.56, AS 43.65, AS 43.75, and AS 43.77"                                                                  
MR. JACKSON  indicated that proposed  Amendment 4 is  specific to                                                               
the Department of  Revenue.  This proposed  amendment would scale                                                               
back the  potential credit or a  portion of the credit  to offset                                                               
taxes imposed from all taxes to  some specific taxes in Title 43,                                                               
which is based on the current  Alaska education tax program.  The                                                               
programs  that would  qualify would  be  Alaska Corporate  Income                                                               
Tax,  the Fisheries  Business Tax,  the Fishery  Resource Landing                                                               
Tax, the  Title Insurance  Premium Tax,  the Mining  License Tax,                                                               
Oil and  Gas Production and  Transportation Tax, and the  Oil and                                                               
Gas Property Tax.   He reiterated that the intent  of Amendment 4                                                               
would be  to make the credits  more salable and more  valuable to                                                               
enhance the film program.                                                                                                       
4:50:31 PM                                                                                                                    
MS. BALES clarified she could not  speak to insurance taxes.  She                                                               
related her  understanding that the Alaska  Corporate Income Tax,                                                               
the Mining License Tax, and  Oil and Gas Production are deposited                                                               
to the state's general fund so  they seem fine.  However, the way                                                               
the Fishery  Resource Landing Taxes  are shared, any  tax credits                                                               
would   reduce   revenue   sharing   to   those   municipalities.                                                               
Currently,  there  are  some  other credits  that  can  be  taken                                                               
against the  Fisheries Business Tax and  Fishery Resource Landing                                                               
Tax but  specific language exists that  indicates revenue sharing                                                               
happens  before  the  credit  are  taken.    She  said  that  the                                                               
committee  would need  similar  language to  ensure that  revenue                                                               
sharing to municipalities would not be affected.                                                                                
CHAIR  OLSON  asked for  written  comments  to  hand out  to  the                                                               
MS. BALES agreed to do so.                                                                                                      
4:52:08 PM                                                                                                                    
REPRESENTATIVE JOHNSON asked for  clarification on the percentage                                                               
of  the  tax  credit  on  the  dollar.    He  asked  whether  the                                                               
department has any ideas on the amount.                                                                                         
MS. BALES  responded that  the department is  not privy  to those                                                               
types of transactions  and are only asked to  transfer the credit                                                               
at its face value.                                                                                                              
REPRESENTATIVE  JOHNSON asked  whether the  tax credits  could be                                                               
purchased for  ten cents  on the  dollar and  could substantially                                                               
reduce the taxes.                                                                                                               
MS. BALES stated that while the  taxpayer could buy the credit at                                                               
ten cents  on the dollar, it  would not affect the  face value of                                                               
the credit  and what  can be applied  against the  tax liability.                                                               
She related a scenario in which  the DOR would issue a tax credit                                                               
for $1  million, and if  the tax  credits sold for  $100,000, the                                                               
department would still apply $1 million in tax credits.                                                                         
4:53:27 PM                                                                                                                    
REPRESENTATIVE  CHENAULT   recalled  prior  legislation   on  tax                                                               
credits.  He decided he would research the legislation himself.                                                                 
MS. AYERS  stated that anecdotally  the department has  heard the                                                               
tax credits market value ranges from  75 to 80 percent at the low                                                               
end.  She stated that  someone holding the tax credit certificate                                                               
has the incentive  to try to sell the tax  credit for the highest                                                               
price possible.   She offered her belief that  parties would take                                                               
into account  the right amount  of holding time.   She reiterated                                                               
that  at this  point  the  department has  heard  that  75 to  80                                                               
percent  falls in  the  normal  range.   She  commented that  the                                                               
department does not have a mechanism to track that at this time.                                                                
4:55:12 PM                                                                                                                    
MS.  AYERS referred  to  proposed Amendment  2,  and related  the                                                               
department would  prefer time  to digest  the limitations  to the                                                               
qualified  expenditures.   She related  her understanding  of the                                                               
committee's desire to address the  limitation for "above the line                                                               
expenses" within film production and  how the credit would apply.                                                               
She expressed concern that going  from 100 percent to 15 percent,                                                               
that the possible  impact it could have  on productions currently                                                               
queued  up and  for the  future viability  of the  program.   She                                                               
questioned the  impact the bill  could have on the  viability for                                                               
Alaska script  writers who may  be compensated under  these terms                                                               
once the  industry matures.  These  types of terms could  be more                                                               
likely to benefit a production  without on-screen talent, such as                                                               
those films  that rely  largely on  scenic or  digital production                                                               
rather than  the types  of feature  film productions  that Alaska                                                               
hopes to attract.   The attraction of the feature  films would be                                                               
preferable due to the spin off ability for Alaska's businesses.                                                                 
CHAIR OLSON suggested the department  should provide its comments                                                               
as soon as possible.                                                                                                            
4:56:49 PM                                                                                                                    
KATE TESAR,  Director of  Business Development,  Evergreen Films,                                                               
stated  that Evergreen  Films is  currently in  negotiations with                                                               
parties and  has been considering  credits at  85 to 90  cents on                                                               
the dollar,  which is closer  to the  range the tax  credits have                                                               
been selling.   She noted  that the production companies  are not                                                               
likely  to give  away  the  commodity.   She  clarified that  the                                                               
company  definitely  wants  the   highest  rate  possible.    She                                                               
predicted that  as these tax  credits become more  available, the                                                               
prices will  rise.  The whole  point of the credit  is to provide                                                               
incentives  to attract  film productions  to come  to Alaska  and                                                               
make films.                                                                                                                     
CHAIR OLSON asked  whether she thought the  tax incentive credits                                                               
were working.                                                                                                                   
MS. TESAR answered  yes.  She clarified  that earlier discussions                                                               
the committee discussed, quoting  lower percentages is definitely                                                               
not something that Evergreen Films  would be interested in doing.                                                               
Evergreen Films  would not  consider selling  its credits  at the                                                               
rates mentioned.   In fact, if  the company did not  get the rate                                                               
it wanted from one buyer it would seek another buyer, she said.                                                                 
CHAIR OLSON asked whether proposed  Amendment 4 would assist film                                                               
production companies.                                                                                                           
MS. TESAR  responded that Evergreen  Films supports  the language                                                               
that mirrors the education tax  credits.  She shares the concerns                                                               
that Ms.  Bales expressed with  respect to revenue sharing.   She                                                               
elaborated  that some  discussions are  ensuing since  it is  not                                                               
Evergreen  Film's intent  to  adversely  affect any  communities.                                                               
She  related her  understanding that  the education  language has                                                               
been  in effect  for 25  years and  has not  impacted communities                                                               
thus  far.   The  intention of  the  bill is  to  expand the  tax                                                               
credits  for  companies  doing  business in  Alaska  but  not  to                                                               
adversely impact communities, she said.                                                                                         
[SB 23 was held over.]                                                                                                          
5:00:01 PM                                                                                                                    
There being no  further business before the  committee, the House                                                               
Labor and  Commerce Standing Committee  meeting was  adjourned at                                                               
5:00 p.m.                                                                                                                       

Document Name Date/Time Subjects
SB23 Draft Proposed Amendment G.1.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Draft Proposed Amendment G.2.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Draft Proposed Amendment G.3.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Draft Proposed Amendment G.4.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Opposing Documents - Email Jerry LaVine 4-12-2011.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Opposing Documents - Article LA Times Richard Verrier 1-23-2011.pdf HL&C 4/12/2011 4:15:00 PM
SB 23
SB23 Opposing Documents - Article FDNM Demot Cole 2-23-2011.pdf HL&C 4/12/2011 4:15:00 PM
SB 23