BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:  May 11, 2009

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                             Charles M. Calderon, Chair

                ACA 10 (Torlakson) - As Introduced:  February 11, 2009

          2/3 vote.

           SUBJECT  :  Taxation:  education finance district:  special tax.

           SUMMARY  :  Amends the California Constitution to lower the  
          constitutional vote requirement for approval of a special tax to  
          be levied by an education finance district from two-thirds to a  
          majority of the district voters.  Specifically,  this bill  :  

          1)Modifies Section 2(d) of Article XIII C of the California  
            Constitution to authorize an education finance district,  
            formed pursuant to statute, to impose, extend, or increase a  
            special tax within its jurisdiction by a majority of the  
            voters voting on the proposition. 

          2)Specifies that a special tax imposed by an education finance  
            district is not deemed to have been increased if it is imposed  
            at a rate not higher than the maximum rate so approved. 

          3)Makes clarifying, non-substantive changes to Section 4 of  
            Article XIII A, Section 2 of Article XIII C, and Section 3 of  
            Article XIII D of the California Constitution. 

           EXISTING LAW  :

          1)Authorizes cities, counties, and special districts to impose a  
            general tax for general governmental purposes with the  
            approval of a majority of the voters.

          2)Prohibits special purpose districts and agencies, including  
            schools districts, from levying a general tax.  

          3)Authorizes cities, counties, and special districts to impose a  
            special tax for specified purposes with the approval of  
            two-thirds of the voters. 

          4)Does not allow cities, counties, or special districts to  
            impose an ad valorem tax on real property or a transactions  








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            tax or sales tax on the sale of real property within that  
            city, county, or special district. 

          5)Allows school districts, community college districts, and  
            county offices of education to issue bonded indebtedness for  
            school facilities with 55% approval. 

           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

          1)The author states that, "California's budget crisis must be  
            resolved without breaking the state's commitment to education.  
             Local revenue generation and local control for our schools  
            must be a component to how we get ourselves out of this budget  
            mess.  The lower school bond threshold has been instrumental  
            in reviving California's school facilities.  A majority vote  
            for local education finance districts promises to similarly  
            rebuild the education of our children."

          2)The proponents argue that local communities should be able to  
            explore local resources to meet local priorities and that the  
            two-thirds vote requirement allows a minority of voters to  
            thwart the will of the majority.  They assert that ACA 10, in  
            partnership with AB 267, would give education finance  
            districts the tools necessary to navigate these uncertain  
            economic times, by addressing their needs at the local level  
            and relying less on the timely passage of a state budget.  ACA  
            10 provides an important option for local schools and their  
            communities to work together to raise desperately needed  
            revenues by a simple majority of the voters, rather than the  
            current constitutional requirement of two-thirds vote.   
            Further, the proponents believe that ACA 10 presents an  
            example of direct democracy, in that it would give voters an  
            opportunity to decide the appropriate vote requirement for a  
            special tax imposed by an education finance district.  

          3)The opponents argue that the voters of California have clearly  
            stated that special taxes should only be approved by a  
            two-thirds vote and that ACA 10 runs counter to the expressed  
            views of Californians.  The opponents are also concerned that  
            expanding the tax authority to education finance districts  
            could cause duplicative and/or increased taxation.  The  
            opponents believe that a two-thirds vote requirement ensures  
            that tax increases are a last resort and argue that  








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            long-standing taxpayer protections should not be thwarted  
            based on the need for revenue.

          4)Committee staff notes all of the following:

              a)   Background  . Constitutional requirements for voter  
               approval of local taxes were initiated with the passage of  
               Proposition 13 in 1978, followed by Proposition 62, which  
               was approved by voters in 1986.  Proposition 62 guaranteed  
               that all local tax increases be approved by voters.  After  
               Proposition 62, local government resorted to the use of  
               fees and assessments, which did not require voter approval,  
               to fill the void.  Ten years later, in 1996, the passage of  
               Proposition 218 added Articles XIII C and XIII D, providing  
               voters with control over taxes regardless of whether they  
               were called assessments, fees, or charges.  Proposition 218  
               also included a provision requiring that special taxes  
               receive thirds approval of the electorate.  In 2000,  
               however, Proposition 39 provided a narrow exception to the  
               two-thirds vote requirement for special taxes by  
               authorizing the passage of local school construction bond  
               measures by approval of 55% of voters. 

              a)   General tax v. special tax.   While Proposition 13 did  
               not define the term "special tax," the courts, over time,  
               have opined that a tax is a "special tax" whenever  
               expenditure of its revenues is limited to specific  
               purposes, i.e. the proceeds of the tax are earmarked or  
               dedicated in some manner to a specific project or projects.  
                In contrast, a tax is a "general tax" only when its  
               revenues are placed into the general fund and are available  
               for expenditure for any and all governmental purposes. [Bay  
               Area Cellular Telephone Co. v. City of Union City (2008)  
               162 Cal. App.4th 686; Howard Jarvis Taxpayers Assn. v. City  
               of Roseville (2003) 106 Cal.App.4th 1178].  School  
               districts and special districts are prohibited from  
               imposing general taxes (Proposition 218), and thus, by  
               definition, any tax levied by a school district or  
               community school district is considered to be a special tax  
               subject to a two-thirds voter approval.  Furthermore,  
               school districts are not allowed to impose a special tax  
               that is imposed on a particular class of property or  
               taxpayers.  Therefore, thus far, school districts have only  
               imposed "qualified special taxes," under Government Code  
               Section 50079, in the form of a parcel tax.  








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              a)   Parcel Tax.   Under existing law, a school district may  
               impose a qualified special tax within that district;  
               however, the special tax must apply uniformly to all  
               taxpayers (other than persons over the age of 65) or real  
               property within the district and must be approved by a  
               two-thirds vote of the qualified electors of the district.   
               A parcel tax is a flat fee imposed by a city, county, or  
               special district on each parcel, residential as well as  
               commercial, rather than on the assessed value of property,  
               located within the local entity's jurisdiction.  Because  
               the same dollar amount of tax is assessed on each parcel of  
               property, whether the parcel is one acre or 100 acres,  
               parcel taxes are generally regressive, which means owners  
               of smaller parcels of land pay a larger percentage of tax  
               compared to owners of larger parcels of land.  

             Some districts levy a rate at a fixed amount per square foot  
               of taxable land, and many include an annual inflation  
               adjustment.  Existing law does not prescribe a maximum rate  
               of tax nor does it limit the period within which the  
               qualified special tax may be imposed.   Therefore, the rate  
               of tax varies significantly among different school  
               districts.  For example, EdSource reports that, in 2008, 21  
               school parcel tax propositions were placed on the November  
               4, 2008 ballot in 21 school districts. Seventeen of those  
               parcel tax propositions were approved, ranging from $23 per  
               parcel in Santa Barbara County to $193 per parcel in Marin  
               County, with terms as short as three years, and as long as  
               nine years.  A number of school districts have adopted  
               permanent parcel taxes. Existing law does not limit how the  
               special tax proceeds may be spent, and therefore, a local  
               school board can specify in the ballot measure how the  
               funds will be used.  Generally, local parcel taxes provide  
               secure funding for teacher salaries, books, materials and  
               supplies, computers, and art, music and sports programs. 

             As a special tax, a parcel tax levied by a school district  
               requires approval at an election of at least two-thirds of  
               the qualified electors of such district.  Court have  
               interpreted the phrase "qualified electors of such  
               district" to mean the registered voters voting in the  
               election concerning the proposed tax.  [Neilson v. City of  
               California City (2005) 133 Cal. App.4th 1296, 1312].   
               Nonresident landowners are not registered voters and are  








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               not included among the voters voting on the proposed parcel  
               tax.  On the other hand, some registered voters who do not  
               own land within the district's boundaries are able to vote  
               on the parcel tax even though they will not be paying that  
               tax (at least not directly).  

              b)   A lower voter threshold for education finance districts  ?  
                ACA 10 would amend the California Constitution to remove  
               the two-thirds vote requirement for special taxes imposed,  
               extended, or increased by an education finance district,  
               which is being created by a companion measure, AB 267, and  
               would replace it with a majority vote requirement.  The  
               author maintains that local school districts lost  
               substantial control over their own finances with the  
               passage of Proposition 13 in 1978.  The author argues that  
               ACA 10 and AB 267, together, would broaden opportunities  
               for local school districts to raise local revenues through  
               a majority vote.  According to Ed Source, between 1983 and  
               November 2006, voters voted on 414 parcel tax proposals.   
               Out of 414 elections, voters approved 211 parcel taxes and  
               166 proposals received a majority vote but not the  
               necessary two-thirds vote approval.  The author asserts  
               that, under a majority vote scenario, those 166 proposed  
               taxes would have been approved, bringing the success rate  
               of local tax approval rate to over 90%. 

              c)   But what about regular school districts  ?  If both this  
               measure and AB 267 are enacted, and ACA 10 is approved by  
               the voters, then an education finance district would be  
               able to levy qualified special taxes with only a majority  
               vote of its electorate. However, a special tax levied by a  
               regular school district will still be subject to a  
               two-thirds vote requirement of the electorate; that is  
               except for the San Francisco Unified School District  
               (SFUSD).  Founded in 1851, SFUSD educates approximately  
               55,000 of San Francisco's pre-school, elementary, middle,  
               and high school students at 34 preschools, 102 K-12  
               schools, 8 county/court schools, and 9 charter schools.  It  
               is a relatively large and diverse district.  Because SFUSD  
               is a school district in the county that contains only one  
               school district, it will be allowed, under AB 267, this  
               measure's companion, to form an education finance district.  
                Once the education finance district is formed, it will be  
               able to impose a special tax with only a majority vote of  
               the electorate approving the tax.  The Committee may wish  








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               to examine the rationale for lowering a constitutional vote  
               requirement for only one regular school district, without  
               affording the same favorable treatment to other school  
               districts in the state. 

              d)   Voting (but not paying) and paying (but not voting).    
               This measure is designed to make it easier for voters to  
               approve parcel taxes, which are taxes on landowners.  Some  
               argue that allowing non-homeowners to vote on a tax they  
               will not need to pay is unfair.  On the other hand,  
               landowners who are non-resident are not allowed to vote in  
               the election, but must pay the tax, if the voters approve  
               the measure.  Finally, a district may exempt taxpayers 65  
               years or older, or disabled persons, thus creating another  
               class of voters who will not bear the tax burden but,  
               presumably, will benefit from living a community that has a  
               well-funded school system and a more educated workforce.   
               Is it equitable to lower the vote threshold for new parcel  
               taxes when many voters will not bear the costs and those  
               who bear the tax burden are precluded from voting?  The  
               Committee may also wish to consider whether the Legislature  
               or the voters of California should be given the opportunity  
               to answer this question.

              e)   Accountability.   Special taxes are subject to additional  
               oversight and accountability provisions.  Local agencies  
               must issue a statement indicating the specific purpose of  
               the tax and use the proceeds only for that purpose.  In  
               addition, the agencies must create an account in which the  
               deposit the proceeds.  Finally, they must issue an annual  
               report that includes the amount to money collected and  
               expended, along with the status of any project required or  
               authorized by the tax measure.  

              f)   Effective date.   If approved by the Legislature, this  
               measure would appear on the next statewide election ballot  
               and, if approved, would take effect as soon as the election  
               results are certified. 

              g)   Companion measure  .  The Committee will consider this  
               measure and AB 267 (Torlakson), a companion measure, at its  
               May 11, 2009 hearing.  AB 267 authorizes an education  
               finance district, as defined, to impose a qualified special  
               tax within the district. If both this measure and AB 267  
               are enacted, and ACA 10 is approved by the voters, then an  








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               education finance district would be able to levy qualified  
               special taxes with only a majority vote of its electorate.   
               If only AB 267 is enacted, then an education finance  
               district would still be able to impose those taxes but with  
               a two-thirds vote of the electorate.

           5)Related Legislation  . 

           ACA 9 (Huffman), introduced in the current Legislative Session,  
            makes changes to the voting requirements contained in the  
            California Constitution for special taxes and bonded  
            indebtedness for local government.  ACA 9 passed out of the  
            Assembly Local Government Committee with a vote of 5 - 2 and  
            was re-referred to this committee. 

          ACA 15 (Arambula), introduced in the current Legislative  
            Session, lowers the constitutional vote requirements for  
            approval of a special tax specifically for providing funding  
            for local transportation projects from two-thirds to a 55%  
            majority.  ACA 15 passed out of the Assembly Local Government  
            Committee with a 5 - 2 vote and was re-referred to the  
            Assembly Committee on Appropriations. 

           SCA 6 (Simitian), introduced in the current Legislative  
            Session, amends the California Constitution to authorize  
            school districts, community college districts, and county  
            offices of education to impose a parcel tax on real property  
            by a 55% vote of the voters in the district or county.  SCA 6  
            is set for a hearing on May 13, 2009, in the Senate Revenue  
            and Taxation Committee. 

          SB 1430 (Torlakson), introduced in the 2007-08 Legislative  
            Session, as amended on April 10, 2008, was identical to this  
            bill.  Its companion measure, SCA 18, also introduced in the  
            2007-08 Legislative Session, would have reduced the vote  
            threshold for special taxes levied by an education finance  
            district from two-thirds to a majority of the electorate.   
            Both SB 1430 and SCA 18 died in the Senate.

          SCA 8 (Simitian), introduced in the 2005-06 Legislative Session,  
            was identical to SCA 6 (Simitian).  SCA 8 died in the Senate. 

           
           REGISTERED SUPPORT / OPPOSITION  :   









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           Support 
           
          California Tax Reform Association
          Small School Districts' Association
          San Francisco Unified School District
          California School Employees Association
          California Federation of Teachers
          California Association of School Business Officials
          California Teachers Association 

           Opposition 
           
          California Association of Realtors
          California Taxpayers' Association
           
          Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916)  
          319-2098