BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: ab 2406
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  blakeslee
                                                         VERSION: 4/28/10
          Analysis by: Carrie Cornwell                   FISCAL:  no
          Hearing date: June 29, 2010





          SUBJECT:

          Redevelopment: pooled housing funds

          DESCRIPTION:

          This bill allows redevelopment agencies in adjoining cities to  
          pool their low and moderate income housing funds to construct,  
          rehabilitate, and preserve housing for extremely low-income  
          persons.

          ANALYSIS:

          The Community Redevelopment Law allows local governments to  
          establish redevelopment areas and capture all of the increase in  
          property taxes that is generated within the area (referred to as  
          "tax increment"). The law requires redevelopment agencies to  
          deposit 20 percent of tax increment funds into a Low & Moderate  
          Income Housing Fund (L&M Fund) to be used to increase, improve,  
          and preserve the community's supply of low and moderate income  
          housing at affordable housing cost. 

          Existing law sets income limits for persons and families  
          (adjusted for family size) of low and moderate-income based on  
          countywide median incomes:

               Moderate income           <  120%
               Low income               <  80%
               Very low income          <  50%
               Extremely low income<  30%

          L&M funds can be spent on housing anywhere in the jurisdiction  
          (i.e., within the city limits) upon the agency making a general  
          finding of benefit to the project areas within that  
          jurisdiction, but not outside of the jurisdiction. 





          AB 2406 (BLAKESLEE)                                       Page 2

                                                                       


          AB 2041 (Dutra), Chapter 552, Statutes of 2000, gave  
          redevelopment agencies in contiguous cities authority, until  
          January 1, 2010, to pool their L&M funds to build affordable  
          housing for low- and very low-income households in one of the  
          city's redevelopment project areas. The redevelopment agencies  
          could exercise this authority by creating a Joint Powers  
          Authority (JPA), provided that the agencies had met specified  
          standards including that each city must have met 50 percent of  
          its regional housing needs for very low and low income, that the  
          proposed use of pooled funds would not exacerbate racial  
          segregation, and that each city had an Department of Housing and  
          Community Development (HCD)-approved housing element.  

          AB 2041 required redevelopment agencies that pooled funds to  
          report to HCD on how many housing units were produced.   
          According to HCD, no agencies submitted a report indicating that  
          they had used this authority. 

           This bill  :

          1.Finds that the transfer of L&M funds to a JPA and the use of  
            pooled L&M funds within the housing market area of the  
            participating redevelopment agencies is of benefit to the  
            redevelopment project area that produced the tax increment.

          2.Permits redevelopment agencies located within adjoining cities  
            within a single metropolitan statistical area to create and  
            participate in a JPA to pool their L&M funds for the direct  
            costs of constructing, substantially rehabilitating, and  
            preserving the affordability of housing units that are  
            affordable to extremely low income households. To participate:

                 An agency must make a finding based on substantial  
               evidence after a public hearing that the aggregation will  
               not cause or exacerbate racial, ethnic or economic  
               segregation. 

                 An agency must have met its requirement to replace  
               housing units its redevelopment activities have destroyed,  
               have deposited 20 percent of its tax increment funds into  
               its L&M Fund, and held a public hearing on the agreement to  
               pool funds at least 45 days before transferring L&M funds  
               to the JPA.

                 A JPA must spend or encumber the L&M funds it receives  
               within two years of receipt or return them to the agency  




          AB 2406 (BLAKESLEE)                                       Page 3

                                                                       


               from which they came, which would then face prescribed  
               penalties.

                 A JPA must also make a finding that the pooled funds  
               will not exacerbate racial or economic segregation.

                 A JPA must submit an annual report to HCD documenting  
               the amount of L&M funds its received and expended for  
               housing assistance. 

          1.Requires that participating communities have HCD-certified  
            housing elements and have met in the previous housing element  
            cycle at least 50 percent of the region's needs in the low-  
            and very low-income categories.

          2.Prohibits spending pooled funds to pay for planning and  
            administrative costs, offsite improvements, or development  
            fees. In addition, pooled funds may only be spent within a  
            project area.

          3.Sunsets the authority to create a new project under its  
            pooling authority on January 1, 2020.
          
          COMMENTS:

           1.Purpose  .  According to the author, the cities of Arroyo Grande  
            and Grover Beach are contiguous cities in San Luis Obispo  
            County that share many demographic similarities. The cities  
            are both small, with fewer within 20,000 residents at the time  
            of the last census, and they do not have adequate funding to  
            support the affordable housing projects they would like to  
            develop. This bill allows these cities flexibility to pursue a  
            qualified redevelopment project that will benefit both  
            communities with many appropriate safeguards, including that  
            each city is in compliance with the housing element  
            requirements in state law. The author believes that enabling  
            cities to pool funds for a regional project allows the  
            community to achieve a greater economy of scale and increases  
            the cities' ability to leverage capital from other public and  
            private sources both within and outside the individual cities.
           
          2.But will it be used  ? The Legislature and governor have several  
            times authorized the pooling of L&M funds among jurisdictions.  
            The broadest authorities for pooling included:

            For seven years from 1993 to 2000, redevelopment agencies had  




          AB 2406 (BLAKESLEE)                                       Page 4

                                                                       


            the authority to transfer L&M funds from one agency to another  
            under certain conditions.  No redevelopment agencies took  
            advantage of this law.  The one attempt to use the law was  
            when the City of Indian Wells offered to transfer some of its  
            housing funds to the City of Coachella.  This transfer was  
            eventually rejected by the Coachella City Council.

            From 2001 through 2010, under AB 2041 (Dutra), agencies had  
            the authority to pool their funds between adjoining cities  
            under essentially the same conditions as this bill provides.  
            Again, no cities took advantage of this law either. Except for  
            the one pair of cities for which the author introduced this  
            bill, it is unlikely that any cities would take advantage of  
            this law. 
          
           3.Spending tax increment outside its community of origin  . While  
            current law allows a redevelopment agency to spend L&M funds  
            outside of a project area but within the territorial limits of  
            the agency, it does not allow an agency to spend L&M funds  
            outside the agency's territorial jurisdiction, whether  
            directly or through a pooling or transfer agreement. Because  
            tax increment is derived from a given project area in a given  
            community, the use of those funds should benefit the same  
            community.  

           4.Over concentration  . Because this bill allows for agencies  
            across jurisdictions to pool their L&M funds without a  
            requirement that each agency fulfill some portion its  
            responsibility to provide housing affordable to extremely  
            low-income households, this bill could lead to an over  
            concentration in a single community of such housing.
          
          Assembly Votes:
               Floor:    74 - 0
               H&CD:   9 - 0

          POSITIONS:  (Communicated to the Committee before noon on  
          Wednesday,
                     June 23, 2010)

               SUPPORT:  None received.
          
               OPPOSED:  None received.