BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 1
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          Date of Hearing:  August 14, 2013

                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
                           K.H. "Katcho" Achadjian, Chair
                    SB 1 (Steinberg) - As Amended:  August 5, 2013

           SENATE VOTE  :  27-11
           
          SUBJECT  :  Sustainable Communities Investment Authority.

           SUMMARY  :  Allows local governments to establish a Sustainable  
          Communities Investment Authority to finance specified activities  
          within a Sustainable Communities Investment Area.  Specifically,  
           this bill  :   

          1)Allows a Sustainable Communities Investment Authority  
            (Authority) to be formed and specifies that it must comply  
            with the provisions of the Community Redevelopment Law (CRL),  
            with certain exceptions, and the provisions contained in the  
            bill.

          2)Requires an Authority to adopt a plan for a sustainable  
            communities investment area.

          3)Requires a sustainable communities investment plan to  
            terminate on a specified date not to exceed 30 years from the  
            date of the first issuance of bond indebtedness by the  
            Authority.

          4)Provides that the Authority shall be deemed to be an "agency"  
            as defined in the CRL and shall have all the rights,  
            responsibilities, and obligations of an agency.

          5)Provides that an Authority is not required to make a finding  
            of blight or conduct a survey of blight in a project area, but  
            can rely upon the legislative findings in the bill to  
            establish blight. 

          6)Prohibits an Authority from being formed under the bill's  
            provisions by either of the following:

             a)   A city or county that created a redevelopment agency  
               (RDA) that was dissolved, as specified, unless the  
               successor agency or designated local authority for the  
               former RDA has received a finding of completion from the  








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               Department of Finance; or,

             b)   A city, county, city and county, or special district  
               that has declared a fiscal emergency, unless the city,  
               county, city and county, or special district subsequently  
               declares that the fiscal emergency has been resolved.

          7)Allows an Authority to be created in the following ways:

             a)   A city, county, city and county, or special district may  
               create an Authority by entering into a joint powers  
               agreement, as specified.   A joint powers agreement shall  
               establish a governing board and designate the Sustainable  
               Communities Investment Area;

             b)   A city may create an Authority, appoint the Authority  
               governing board, designate a Sustainable Communities  
               Investment Area within the city's incorporated area, and  
               establish the parameters of the proposed economic  
               development within a proposed Sustainable Communities  
               Investment Area with county approval of the economic  
               development parameters and the Sustainable Communities  
               Investment Plan, including any amendments to the plan;

             c)   A city and county may create an Authority and appoint  
               the authority governing board, which shall be comprised of  
               two members appointed by the city and two members by the  
               county.  A fifth member shall be appointed by the two city  
               and the two county members.  The governing board shall  
               designate the Sustainable Communities Investment Area.  A  
               Sustainable Communities Investment Plan, including any  
               amendments to it, shall be approved by both the city and  
               the county.  The Sustainable Communities Investment Area  
               may include an incorporated area or both an incorporated  
               area and an unincorporated area; 

             d)   If the Sustainable Communities Investment Area is within  
               an unincorporated area, the board of supervisors of a  
               county may create an Authority and appoint the authority  
               governing board; and,

             e)   A city may create an Authority, which shall constitute a  
               legally distinct entity from that city, and appoint the  
               authority governing board, which may designate a  
               Sustainable Communities Investment Area only within the  








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               incorporated limits of that city.

          8)Provides that the governing board of the Authority shall  
            consist of five members, and that members shall be appointed  
            for four-year terms and shall only be removed by the  
            appointing authority for cause, and provides that the initial  
            appointees to the governing board shall serve either two-year  
            or four-year terms and shall draw their terms by lot.

          9)Deems an Authority a public body subject to the Ralph A. Brown  
            Act, California Public Records Act, Meyers-Milias-Brown Act,  
            and the Political Reform Act. 

          10)Requires a city or county approving participation in an  
            Authority, the governing board, or a sustainable communities  
            investment area to do so through a resolution. 

          11)Excludes a school district from participating in an  
            Authority. 

          12)States that a sustainable communities investment area shall  
            include only the following:

             a)   Transit priority areas that meet the following  
               parameters:

               i)     A transit priority project including a high-speed  
                 rail station. The transit stop or corridor must be  
                 completed within the planning horizon established by  
                 specified federal regulations. The transit priority area  
                 may include a military base reuse plan that meets the  
                 definition of a transit priority area and it may include  
                 a contaminated site within a transit priority area;

               ii)    It is within the geographic boundaries of a  
                 metropolitan planning organization (MPO) with an approved  
                 sustainable communities strategy (SCS). 

             a)   Areas that are small walkable communities, as defined,  
               except that small walkable communities may also be  
               designated in a city that is within the area of an MPO.   
               Specifies that no more than one small walkable community  
               project area shall be designated within a city; and,

             b)   Sites that have land use approvals, covenants,  








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               conditions and restrictions, or other effective controls  
               restricting the sites to clean energy manufacturing, and  
               that are consistent with the use, designation, density,  
               building intensity, and applicable policies specified for  
               the sustainable communities investment area in the SCS, if  
               those sites are within the geographic boundaries of an MPO.  
                Specifies that clean energy manufacturing shall consist of  
               the manufacturing of any of the following:

               i)     Components, parts, or materials for the generation  
                 of renewable energy resources;

               ii)    Equipment designed to make buildings more energy  
                 efficient or the component parts thereof;

               iii)   Public transit vehicles or the component parts  
                 thereof;  or,

               iv)    Alternative fuel vehicles or the component parts  
                 thereof.

          12)Allows a sustainable communities investment plan for an  
            sustainable communities investment area to include a provision  
            for the receipt of tax increment funds providing that the  
            local government with land use jurisdiction has adopted all of  
            the following:

             a)   A sustainable parking standards ordinance that restricts  
               parking in transit priority project areas to encourage  
               transit use to the greatest extent feasible;

             b)   An ordinance creating a jobs plan.  Specifies that all  
               entities receiving financial support from the Authority  
               shall, at a minimum, require that any and all agreements  
               approved by the Authority include a jobs plan, which shall  
               describe how the project will further create construction  
               careers that pay prevailing wages, living wage permanent  
               jobs, and create a program for community outreach, local  
               hire, and job training.  Specifies that the plan shall also  
               describe the project developer's commitment to offer jobs  
               to disadvantaged California residents, including veterans  
               of the Iraq and Afghanistan wars, people with a history in  
               the criminal justice system, and single-parent families;

             c)   For transit priority areas and small walkable  








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               communities within an MPO, a plan consistent with the use  
               designation, density, building intensity, and applicable  
               policies specified for the sustainable communities  
               investment area density of at least 20 dwelling units per  
               net acre and for nonresidential uses, provides a minimum  
               floor area ratio of 0.75; 

             d)   Within small walkable communities outside of an MPO, a  
               plan for new residential construction that provides a  
               density of at least 20 dwelling units per net acre and, for  
               nonresidential uses, provides a minimum floor area ratio of  
               0.75; and

             e)   An ordinance that prohibits the number of housing units  
               for extremely low-, very low- and low-income households in  
               the sustainable communities investment area from being  
               reduced during the effective period of the sustainable  
               communities investment plan.  And requires the replacement  
               of these housing units within two years of their  
               displacement.

          13)Requires the county auditor controller to allocate to an  
            Authority the tax increment as specified in a an sustainable  
            communities investment plan in proportion to the  levied taxes  
            for the city and or county in excess of the amount specified  
            in Health and Safety Code Section 33670 (a).    

          14)Provides that the auditor-controller may only allocate tax  
            increment revenues to an Authority if the taxing agency whose  
            tax increment would be allocated adopts a resolution  
            authorizing the allocation. 

          15)Provides that the adoption of a resolution to allow tax  
            increment to go to the Authority does not prohibit an  
            auditor-controller's authority to revoke the allocation if it  
            conflicts with requirements to pay existing obligations  
            secured by tax increment revenues.

          16)Provides that if an sustainable communities investment area  
            includes in whole or in part a former redevelopment area and  
            the sustainable communities investment plan includes a  
            provision for receipt of tax increment revenues then it shall  
            include a provision that tax increment amounts collected and  
            received by the Authority are subordinate to existing  
            enforceable obligations. 








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          17)Defines "net available revenue" as periodic distributions to  
            the city or county from the Redevelopment Property Tax Trust  
            Fund once all enforceable obligations are paid.

          18)Allows a city or county forming the Authority to dedicate any  
            portion of its net available revenue to the Authority through  
            the sustainable communities investment plan which shall  
            include the date upon which the Authority will cease to  
            receive the net available revenue. 

          19)Provides that an Authority that collects tax increment  
            revenues must dedicate no less than 25% of the allocated tax  
            increment for affordable housing purposes.

          20)Requires a sustainable communities investment plan to include  
            the following, in addition to what is required for a  
            redevelopment plan in the CRL:

             a)   A fiscal analysis of the projected receipt of tax  
               increment and other revenue and the projected expenses over  
               five-year planning horizons for the life of the Authority;

             b)   A statement of the principal goals and objectives of the  
               plan with findings of the public purposes and uses that  
               will be achieved;

             c)   A statement of how the sustainable communities  
               investment plan will relieve blight as follows:

               i)     How it will implement the goals of a SCS if the re  
                 sustainable communities investment area is within an MPO;

               ii)    How it will contribute to a more efficient  
                 transportation;

               iii)   How it will contribute to and reduce cost for the  
                 combined costs of housing and transportation;

               iv)    How it will contribute to improved public health;

               v)     How it will promote more efficient water  
                 consumption;

               vi)    How it will avoid loss of prime farmland;








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               vii)   How it will reduce air pollution, energy consumption  
                 and greenhouse gas emissions by reducing vehicle miles  
                 traveled; and,

               viii)  How it will ensure compliance with the affordable  
                 housing maintenance and preservation requirements.

             d)   A statement of how the plan will implement the  
               sustainable parking standards; and,

             e)   A statement of how the plan will implement the jobs  
               plan.

          21)Provides a sustainable communities investment plan, in  
            addition to meeting the housing provisions of the CRL, may  
            include, to the extent applicable to the sustainable  
            communities investment area, the following:

             a)   Affordable and farmworker housing;

             b)   Transitional and supportive housing for, including but  
               not limited to, former foster youth, persons with mental  
               health treatment needs, persons with substance use disorder  
               treatment needs, offender populations. 

             c)   Health and safety related infrastructure investments in  
               disadvantaged rural communities; and,

             d)   Infrastructure to support country wide services. 

          22)Requires, if a city, county, city and county, or special  
            district that has entered into an agreement to allocate a  
            portion of its tax increment to an Authority and subsequently  
            declares a fiscal emergency, that city, county, or city and  
            county, or special district to develop a plan for how the  
            county auditor-controller shall reduce the amount of the tax  
            increment revenue allocated to the authority during the period  
            of time of the fiscal emergency.

          23)Requires an Authority to contract for an independent and  
            financial audit every five years, conducted by guidelines  
            established by the Controller, and submit it to the  
            Controller, Director of Department of Finance, and the Joint  
            Legislative Budget Committee. 








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          24)Requires the audit to determine compliance with the  
            affordable housing maintenance and replacement requirement  
            including provisions to ensure that the replacement  
            requirements are met within the five year period covered by  
            the audit. 

          25)Provides that if the Authority fails to meet the maintenance  
            and replacement requirement for affordable housing it must  
            adopt and submit to a plan with the audit to show how it will  
            comply with those provisions within two years. 

          26)Require the controller to review and approve an Authority's  
            plan to meet the replacement housing requirements and ensure  
            that the plan includes one or more of the following means of  
            achieving compliance:

             a)   Expenditure of an additional 10% of gross tax increment  
               revenue on increasing, preserving, or improving the supply  
               of low-income housing;

             b)   An increase in the production by an additional 10% of  
               housing for very low-income households as required under  
               the CRL housing production requirements; and/or 

             c)   The targeting of expenditures from the Low- and Moderate  
               -Income Housing Fund toward rental housing affordable to  
               and occupied by person of very low and extremely low  
               income. 

          27)Requires the Authority to approve any bond financing.

          28)Specifies that school district property taxes cannot be  
            pledged for the repayment of bonds issued by an Authority.  

          29)Specifies, in the event a tax increment financing provision  
            is included as part of an sustainable communities investment  
            area, and for the purposes of collecting tax increment under  
            Section 16 of Article XVI of the California Constitution, that  
            the terms "district" and "affected taxing entity" shall  
            exclude a school district and special districts.

          30)Permits a state or local pension fund system to invest  
            capital in the public infrastructure projects and private  
            commercial residential developments undertaken by an  








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            Authority.

          31)Allows an Authority to exercise the powers granted under the  
            Mello-Roos Act. 

          32)Allows an Authority to implement local transaction and use  
            tax, except that the resolution authorizing the tax may  
            designate the use of the tax.

          33)Establishes a process to prequalify developers for  
            construction contracts in excess of $1,000,000.

          34)Requires the Department of Industrial Relations to monitor  
            and enforce compliance with prevailing wage requirements for  
            projects that include funds from an Authority and shall charge  
            each awarding body or developer for the reasonable and  
            directly related costs of monitoring and enforcing compliance  
            with the prevailing wage requirements of each project.

          35)Defines, for the purpose of exempting small walkable  
            communities from the California Environmental Quality Act  
            (CEQA), the following terms:

             a)   "Floor area  ratio" as the ratio of gross building area  
               of development, exclusive of structured parking areas,  
               proposed for the project divided by the total net lot area;  
                
             b)   "Gross building area" as the sum of all finished areas  
               of all floors of a building included within the outside  
               faces of its exterior walls; and, 

             c)   "Net lot area" means the area of a lot excluding  
               publicly dedicated land, private streets that meet local  
               standards, and other public use areas as determined by the  
               local land use authority. 

          36)Makes legislative findings and declarations.

           EXISTING LAW  :

          1)Dissolves redevelopment agencies as of February 1, 2012.

          2)Establishes the Community Redevelopment Law, which governs the  
            authority to establish a redevelopment agency and the  
            authority for a redevelopment agency to function as an agency  








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            and to adopt and implement a redevelopment plan.

          3)Defines a "small walkable community project" as a project that  
            is in an incorporated city that is not within the boundaries  
            of an MPO and that satisfies the following requirements:

             a)   Has a project area of approximately one-quarter mile  
               diameter of contiguous land completely within the existing  
               incorporated boundaries of the city;

             b)   Has a project area that includes a residential area  
               adjacent to a downtown retail area; and,

             c)   The project has a density of at least eight dwelling  
               units per acre or a floor area ratio for retail or  
               commercial uses of not less than 0.50. 

          4)Specifies that a "transit priority project" shall a) contain  
            at least 50% residential use, 
          based on total building square footage and, if the project  
            contains between 26% and 50% nonresidential uses, a floor area  
            ratio of not less than 0.75; b) provide a minimum net density  
            of at least 20 dwelling units per acre; and, c) be within  
            one-half mile of a major transit stop or high-quality transit  
            corridor included in a regional transportation plan.  A major  
            transit stop is as defined in Section 21064.3, except that,  
            for purposes of this section, it also includes major transit  
            stops that are included in the applicable regional  
            transportation plan.  For purposes of this section, a  
            high-quality transit corridor means a corridor with  
            fixed-route bus service with 
          service intervals no longer than 15 minutes during peak commute  
            hours.  A project shall be considered to be within one-half  
            mile of a major transit stop or high-quality transit corridor  
            if all parcels within the project have no more than 25% of  
            their area farther than one-half mile from the stop or  
            corridor and if not more than 10% of the residential units or  
            100 units, whichever is less, in the project are farther than  
            one-half mile from the stop or corridor.

          5)Requires, under the provisions of SB 375 (Steinberg), Chapter  
            728, Statutes of 2008, a regional transportation plan to  
            include a sustainable communities strategy designed to achieve  
            the targets for greenhouse gas emission reductions.









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           FISCAL EFFECT  :   This bill is keyed fiscal.


           COMMENTS  :   

          1)This bill authorizes cities and counties to establish  
            Sustainable Communities Investment Authorities to help develop  
            transit priority areas, clean manufacturing districts and  
            small walkable communities.  This bill is author-sponsored.

            According to the author, this bill has been developed "to give  
            local governments economic development tools following the  
            elimination of redevelopment. The key policy advanced by SB 1  
            is that it would replace the historical standard of blight  
            remediation with the new objective of encouraging  
            transit-oriented, infill development, and compliance with SB  
            375."

          2)In 2011, the Legislature approved and the Governor signed two  
            measures, ABX1 26 and ABX1 27 that together dissolved  
            redevelopment agencies as they existed at the time and created  
            a voluntary redevelopment program on a smaller scale.  In  
            response, the California Redevelopment Association, League of  
            California Cities, along with other parties, filed suit  
            challenging the two measures.  The Supreme Court denied the  
            petition for peremptory writ 
          of mandate with respect to ABX1 26.  However, the Court did  
                                                 grant CRA's petition with respect to ABX1 27.  As a result,  
            all redevelopment agencies were required to dissolve as 
          of February 1, 2012.    

            Over the last sixty years, redevelopment agencies used tax  
            increment to finance affordable housing, community  
            development, and economic development projects.  The  
            dissolution 
            of redevelopment agencies has created a void and an effort to  
            create new tools that would support community and economic  
            development activities.  SB 1 would allow a city or county to  
            establish a Sustainable Communities Investment Authority to  
            use tax increment financing, on a limited scale, along with  
            other financing tools to support the goals of SB 375. 

          3)SB 375 created a new procedure for land use planning that  
            would require local governments to plan in a way that would  
            accomplish the greenhouse gas reduction goals of AB 32 (the  








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            California Global Greenhouse Gas Reduction Act of 2006).  SB  
            375 required MPOs to adopt an SCS in their regional  
            transportation plans for the purpose of reducing greenhouse  
            gas emissions, required the alignment of planning for  
            transportation and housing, and created specified incentives  
            for the implementation of those strategies. 

            This bill would authorize the use of tax increment as well as  
            other funding sources to finance some of the projects - small  
            walkable communities, transit priority areas and clean energy  
            manufacturing - that would be part of the SCS. 

          4)This bill relies upon tax increment financing, in addition to  
            several other potential funding sources, including Mello Roos,  
            capital investment from public pensions, and local transaction  
            and use taxes, to support the development of transit priority  
            areas, small walkable communities, and clean energy  
            manufacturing.  One of the challenges of using tax increment  
            as a financing tool for community and economic development in  
            the post-redevelopment world is carving out the schools  
            portion of the tax increment.  Section 16 of Article XVI of  
            the California Constitution gives authority to reapportion  
            property taxes among a city, city and county, and district or  
            other public corporation (otherwise known as taxing agencies)  
            for the purpose of redevelopment.  SB 1 excludes school  
            district and special district from "district" and "affected  
            taxing entity" for purposes of tax increment financing.  

          5)Post-World War II, redevelopment was created as a tool to  
            combat urban decay and eradicate blight.  Redevelopment  
            agencies were given fundamental tools including the ability to  
            acquire property through the power of eminent domain, the  
            authority to finance their activities by issuing bonds and  
            taking on debt, and the authority and obligation to relocate  
            people who have interests in the property acquired by an  
            agency.  To establish redevelopment project areas, a  
            redevelopment agency was required to identify both physical  
            and economic blight in the project area that could not be  
            mitigated without the use tax increment.  SB 1 would allow  
            sustainable communities investment authority to establish a  
            sustainable communities investment area without making a  
            finding of blight.  In order to eradicate blight,  
            redevelopment agencies had authority to use eminent domain. SB  
            1 would permit a sustainable communities investment authority  
            to use eminent domain without a finding of blight. 








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            The California Farm Bureau Federation, in their opposition  
            letter, write that SB 1 "would replace this specific statutory  
            definition [of blight] and many years of well-defined case law  
            created by hundreds of court challenges over many decades,  
            with a definition of blight that is so vague that it is  
            essentially meaningless. 'Inefficient land use patterns' and  
            'inefficient transportation infrastructure' are the essential  
            triggers for a determination of blight that could result in  
            the taking of someone's home, business, or family farm for the  
            lease or sale to another private party for a private use."

          6)Redevelopment agencies were required to set aside 20% of tax  
            increment generated in redevelopment project areas for the  
            creation, improvement, and preservation of affordable housing.  
             This bill increases the set aside to 25%. In addition, the  
            bill requires that a host city or county pass an ordinance  
            ensuring that housing affordable to and occupied by extremely  
            low-, very low-, and low-income households within an area do  
            not decrease during the life of the plan.  The bill also  
            requires that ordinance to ensure an authority provide  
            replacement housing in two rather than four years.  These  
            provisions represent an agreement between the author and the  
            advocates of affordable housing. 

          7)Last year this Committee heard SB 1156 (Steinberg) which is  
            substantially similar to this bill. Governor Brown vetoed SB  
            1156 with the following message:   

                 This bill would allow local governments to establish a  
            Sustainable Communities                                      
            Investment Authority to finance activities within a specified  
            area.  The planning and                                      
            investment that is envisioned by this bill would help to  
            develop and redevelop a                                      
            California that is sustainable and thriving.

                 I prefer to take a constructive look at implementing this  
            type of program once the winding down of redevelopment is  
            complete and General Fund savings are achieved.  At that time,  
            we will be in a much better position to consider new  
            investment authority.  I am committed to working with the  
            Legislature and interested parties on the important task of  
            revitalizing our communities.









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            The author notes that SB 1 contains provisions that require a  
            city or county to receive a finding of completion from the  
            Department of Finance certifying that they have met the legal  
            requirement of the RDA dissolution process before they can  
            participate in the creation of an Authority using the  
            provisions of SB 1, thereby addressing concerns raised in the  
            veto message.
          8)The California State Association of Counties (CSAC), in  
            support, writes that "the foundation of our support is  
            allowing counties a clear option whether or not to financially  
            participate in tax increment financing for economic  
            development purposes.  We believe an approach that encourages  
            collaboration between counties and cities will best serve  
            Californians.  This approach would not only allow counties  
            appropriate control over their own general funds, but  
            necessitates discussions about what kinds of development  
            benefits the community as a whole."

            Also in support, the California Special Districts Association  
            writes that "SB 1 protects core services, such as those  
            provided by special districts?any division of property taxes  
            away from local agencies would require the governing board of  
            each participating agency to adopt a resolution, or 'opt-in'.   
            This provision ensures accountability and local control over  
            local revenue; it also prevents the exchanging of one problem  
            for a new, worse local infrastructure problem.  Secondly, SB 1  
            promotes collaboration by empowering local agencies, including  
            special districts, with the ability to create an investment  
            authority by entering into a JPA?such a JPA would enable an  
            authority to best utilize the community's assets and meet its  
            needs."

           9)Support arguments  :  Supporters argue that this bill  
            establishes a new approach to local economic development and  
            housing policy that is focused on building sustainable  
            communities and creating high skill, high wage jobs, and that  
            the bill fosters collaboration between cities and counties on  
            local economic development efforts and mitigates the zero-sum  
            competition for scarce property tax revenues among cities,  
            counties, and school districts.

             Opposition arguments  :  Opponents object to the taxation,  
            bonding, and eminent domain powers that this bill confers to  
            the Authorities.  They are concerned about how high sales tax  
            rates could go up in the project areas and about how  








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            Authorities would structure the public votes for such sales  
            tax increases as well as for bonds.  The opponents are also  
            concerned that the imposition of sales taxes of varying levels  
            in many small areas throughout the state could result in  
            significant administrative challenges and compliance problems  
            for small businesses.  

          10)This bill was heard by the Assembly Housing and Community  
            Development Committee on July 3, 2013 and passed on a 5 - 2  
            vote.















           
          REGISTERED SUPPORT / OPPOSITION  :

           Support 
          
          Alameda-Contra Costa Transit District
          Alliance for Community Transit-Los Angeles
          California Association of REALTORS
          California Labor Federation
          California Transit Association
          California Special Districts Association
          California State Association of Counties
          California State Council on Developmental Disabilities
          Capacity Builders, Inc
          City of West Sacramento
          Counties of Alameda, Lassen
          East LA Community Corporation
          Emeryville Chamber of Commerce
          Green Technical Education and Employment
          Housing California








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          Los Angeles County Federation of Labor
          Los Angeles / Orange Counties Building and Construction Trades  
          Council
          Metropolitan Transportation Commission
          Mission Bay Development Group
          Natural Resources Defense Council
          Sacramento Area Council of Governments
          Sacramento Housing Alliance
          Southeast Asian Community Alliance
          State Building and Construction Trades Council
          Western Center on Law & Poverty
           
            Opposition 
           
          Air Conditioning Trade Association
          California Farm Bureau Federation
          California Right to Life Committee, Inc.
          CalTax
          Contra Costa Taxpayers Association
          Michelle Steel, Vice-Chair, Third District, State Board of  
          Equalization
          Plumbing-Heating-Cooling Contractors Association of California
          Western Electrical Contractors Association
          6 individuals

           Analysis Prepared by  :    Debbie Michel / L. GOV. / (916)  
          319-3958