BILL ANALYSIS                                                                                                                                                                                                    Ó




                                                                  SB 1021
                                                                  Page A
          Date of Hearing:   June 25, 2014


                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

                      SB 1021 (Wolk) - As Amended:  June 2, 2014

           
           Majority vote.  Non-fiscal.
           
          SENATE VOTE  :   21-15
           
          SUBJECT  :   School districts:  parcel taxes

           SUMMARY  :   Allows a school district to impose a parcel tax at  
          different rates by classifying property as commercial,  
          industrial, single-family residential or multifamily  
          residential, provided that the same rate of tax is levied on all  
          properties within the same classification.  Specifically,  this  
          bill  : 

          1)Specifies that the phrase "special taxes that apply uniformly"  
            to all taxpayers or all real property within the school  
            district means any special tax imposed in accordance with one  
            or more of the following:

             a)   On a per parcel basis;

             b)   According to the square footage of a parcel or the  
               square footage of improvements on a parcel;

             c)   According to the commercial, industrial, single family  
               residential, or multifamily residential classification of a  
               parcel, so long as the same rate of tax is levied on all  
               properties of the same classification; or,

             d)   At a lower rate on unimproved property. 

          2)Provides that, in no event, the rate that the school district  
            imposes on property within the commercial or industrial  
            classification be more than two times the rate imposed on  
            property within the single family residential classification.

          3)Authorizes a school district to treat multiple parcels of real  









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            property as one parcel of real property for purposes of a  
            qualified special tax where the parcels are contiguous, under  
            common ownership, and constitute one economic unit, meaning  
            that the multiple parcels of real property have the same  
            primary purpose and are not separate and distinct properties  
            that may be independently developed and sold. 

          4)States that no inference shall be drawn from the enactment of  
            this bill with respect to the meaning of the term "uniformly"  
            for purposes of special taxes imposed by school districts  
            pursuant to the authorization in Government Code (GC) Section  
            50079 as it existed prior to the enactment of this act. 

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

          3)Does not allow cities, counties, or special districts to  
            impose an ad valorem tax on real property or a transactions  
            tax or sales tax on the sale of real property within that  
            city, county, or special district. 

          4)Prohibits school districts from imposing general taxes, but  
            allows school districts, community college districts, and  
            county offices of education to issue bonded indebtedness for  
            school facilities with 55% approval.  (Proposition 39;  
            November 7, 2000 General Election.)  

          5)Authorizes school districts to impose qualified special taxes,  
            in accordance with specified procedures, including the  
            approval of two-thirds of the voters in the district.

          6)Provides that "qualified special taxes" must apply uniformly  
            to all taxpayers or all real property within the school  
            district and do not include special taxes imposed on a  
            particular class of property or taxpayers.  

          7)Authorizes a school district to exempt from a "qualified  
            special tax" person 65 years of age or older, persons  









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            receiving Supplemental Security Income (SSI) for a disability,  
            regardless of age, or low-income persons receiving Social  
            Security Disability Insurance (SSDI) benefits, regardless of  
            age.

           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

           1)The Author's Statement  .  The author has provided the following  
            statement in support of this bill:

          "Under the recent court decision, school districts can no longer  
            apply higher or lower rates to parcels based on commercial,  
            industrial, or residential classification of the parcel.   
            Districts cannot even tax an empty property at a lower rate  
            than an oil refinery or a research and development campus.  SB  
            1021 restores this needed local control by allowing school  
            district boards to structure its tax according to local values  
            and priorities.  Because these taxes must be approved by 2/3  
            vote of local voters, school district boards must forge a  
            communitywide consensus to ensure voters approve the tax,  
            evident by the high approval rates in parcel tax elections.   
            The bill simply returns local control to its state before the  
            court case, and conforms the school district law to 15 other  
            laws that allow local agencies to impose parcel taxes.  The  
            bill does not grant any additional powers to districts they  
            did not have before the case.  The choice SB 1021 presents is  
            clear: the Legislature can decide who should and should not  
            pay local taxes, or local voters can choose at the ballot box  
            whether the tax placed on the ballot by the locally elected  
            school board after a full, public process is worth it."  
           
           2)Arguments in Support  .  The proponents state that this bill  
            addresses an issue that "arose through the decision in Borikas  
            v. Alameda Unified School District" and is needed to clarify  
            "troublesome ambiguities in existing law resulting from the  
            Borikas decision."  By explicitly providing that school  
            districts may levy parcel taxes based on square footage, "the  
            bill removes the prospect that future courts could interpret  
            the Borikas decision narrowly and raise questions regarding  
            those types of taxes."  Furthermore, the proponents argue  
            that, absent this bill, "Borikas could have the unintended  
            effects of requiring double taxation of owners of contiguous  
            parcels and imposing disproportionate taxes on owners of  









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            unimproved parcels." 

          The proponents assert that parcel taxes are "a stable funding  
            source for public schools" and argue that this bill is an  
            important measure necessary to provide the "needed clarity,  
            authority, and flexibility for districts to structure taxes ?  
            that meet community needs and comply with long-standing equal  
            protection principles."  The proponents note that this bill  
            "does not change the existing 2/3 vote requirement for local  
            communities to pass parcel taxes."  Finally, the proponents  
            argue that this bill "would restore local control and  
            discretion to school districts prior to the court ruling in  
            Borikas... and would bring parity to the law by providing  
            school districts similar legal authority to impose parcel  
            taxes as fifteen other local agencies."  All in all, this bill  
            would "give school districts and their respective community  
            much needed flexibility to structure their parcel tax  
            according to local values, needs and priorities."

           3)Arguments in Opposition .  The opponents argue that this bill  
            would "overturn the Borikas decision for the over one thousand  
            school districts across California, allowing them to impose  
            non-uniform parcel taxes," which could result in "a jumble of  
            different tax rates depending on the type of property in a  
            community, leading to confusion for home and business owners."  
             The opponents assert that pursuant to this bill's "wholly  
            volatile and very random parcel tax regime," school districts  
            would have "nearly unlimited discretion to decide who pays  
            what tax"; would be allowed to impose a different tax rate on  
            unimproved parcels; and would be permitted to "aggregate  
            multiple, smaller parcels owned by one owner to capture all  
            the properties under a square footage parcel."  The opponents  
            also state that this bill could be "detrimental to residential  
            homeowners who may be forced to pay higher parcel taxes  
            depending on how a particular tax is imposed."  Finally, the  
            opponents claim that one of the "most regrettable unintended  
            consequences of [this bill] is its potentially negative social  
            equity implications, specifically on equal [and fair] access  
            to education."  According to the opponents, while "per-pupil  
            funding disparities among school districts currently exist  
            because certain school districts levy illegal non-uniform  
            parcel taxes, SB 1021 would undermine Serrano and exacerbate  
            the problem by allowing school districts to impose even more  
            exaggerated nonuniform parcel taxes, bringing back  
            wealth-related taxes that are extremely unequal and  









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            nonuniform."  
           
           4)Background  .  Prior to 1970, the state's K-12 schools largely  
            relied on local property taxes levied at different rates and  
            yielding different amounts per pupil in more than 1,000  
            California schools districts.  State court rulings in the  
            Serrano v. Priest equalization cases forced the state to  
            revise basic school finance and establish the revenue limit  
            system.  [Serrano v. Priest (1971) 5 Cal.3d 584; Serrano v.  
            Priest (1976) 18 Cal.3d 728; Serrano v. Priest (1977) 20 Cal.  
            3d 25).]  In order to conform to the court's decision and  
            reduce the differences in per-pupil amounts, the state created  
            the revenue limit system that combines local property tax  
            revenues with state general aid and allows the state to  
            control the two revenue sources on a per pupil basis.  The  
            state does not fund basic aid districts, where local property  
            taxes meet or exceed the revenue limit.  

            In 1978, Proposition 13 limited both the tax rates and  
            assessments, thus significantly reducing property tax revenues  
            and forcing the state to replace the lost revenues in district  
            revenue limits.  Proposition 13 also eliminated the ability of  
            school districts to levy an incremental ad valorem tax on real  
            property.  Local governments and special districts may,  
            however, levy non-ad valorem taxes, subject to voter approval.  
             Since schools and special districts have no plenary taxing  
            powers, the Legislature had provided general authority for all  
            local agencies to levy special taxes, subject to 2/3 voter  
            approval.  [SB 785 (Foran) 1979.]  However, in 1986, another  
            proposition - Proposition 62 - was placed on the statewide  
            ballot, requiring the Legislature to grant specific power to  
            local agencies to impose taxes.  In response, the Legislature  
            authorized school and community college districts to impose  
            qualified special taxes.  [AB 1440 (Hanningan) 1988.]  Thus,  
            under existing law, a school district may impose a qualified  
            special tax within that district, as long as the special tax  
            applies uniformly to all taxpayers (other than persons over  
            the age of 65 or persons receiving SSI or SSDI] or real  
            property within the district, and is approved by a two-thirds  
            vote of the qualified electors of the district. In 1991, the  
            Legislature additionally authorized 15 other types of local  
            agencies to impose similar taxes, allowing local agencies to  
            tax unimproved property at a lower rate than improved  
            property.  [SB 158 (Committee on Local Government) 1991.]










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           5)What is a "Qualified Special Tax"  ?  As discussed, school  
            districts have limited authority to generate local revenues  
            from qualified special taxes, even though most school funding  
            is either received from the state or federal government, or  
            controlled by the state through revenue limits required to  
            equalize per-pupil funding.  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.]  

          Since school districts are prohibited from imposing general  
            taxes, any tax levied by a school district, by definition, is  
            considered to be a special tax subject to a two-thirds voter  
            approval.  School districts may only to impose "qualified"  
            special taxes, i.e. taxes that are applied uniformly to all  
            taxpayers or real property within the district.  Therefore,  
            thus far, school districts have only imposed "qualified  
            special taxes", under Government Code Section 50079, in the  
            form of a parcel tax.

           6)A Parcel Tax  . The California Constitution specifies that only  
            two types of taxes may be imposed upon a parcel of property:   
            an ad valorem property tax and a special tax receiving  
            two-thirds voter approval pursuant to Section 4 of Article  
            XIIIA (or a parcel tax). A parcel tax is a special tax and may  
            not be based on the property's value (it is non-ad valorem).   
            Instead, it 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 generally 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.  To address the  
            issue of regressivity, some districts decided to levy a rate  
            at a fixed amount per square foot of taxable land, and many  









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            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, in 2014, 13  
            school parcel tax propositions were placed on the ballots in  
            13 school districts, all of which were approved, ranging from  
            $660 per unit in El Dorado County to $84 per parcel in Santa  
            Clara County, with terms as short as four years and as long as  
            eight years.  According to the California School Boards  
            Association, ten school districts have enacted parcel tax  
            measures that utilize various tax rates, based on square  
            footage or certain property classification.  There is no  
            current limitation on how the special tax proceeds may be  
            spent and, therefore, a local government or a special district  
            may specify in the ballot measure how the funds will be used.   
            Districts can use revenues in almost any way that serves local  
            needs, such as ongoing expenses, programs, or buildings.   
            Generally, local parcel taxes provide secure funding for  
            teacher salaries, books, materials and supplies, computers,  
            and art, music and sports programs. 

           7)The "Uniformity" Requirement and the Borikas Decision  .   
            Existing law authorizes school districts to impose "qualified"  
            special taxes only if the taxes apply uniformly to all  
            taxpayers or real property within the district.  (GC Section  
            50079.)  Some school districts have interpreted the term  
            "uniformly" to require a uniform treatment of taxpayers and  
            property within a tax classification of property or taxpayers.  
             Consequently, those school districts have utilized, with the  
            voters' permission, variable parcel tax rates depending on a  
            property's use and/or size.  For example, in 2008 the Alameda  
            Unified School District's voters approved Measure H, which  
            imposed different rates of parcel taxes.  A parcel tax of $120  
            per parcel was levied on residential parcels as well as  
            commercial and industrial parcels under 2,000 square feet.   
            However, larger commercial and industrial properties were  
            subject to a tax of $0.15 per square foot, not to exceed the  
            overall limit of $9,500 per parcel per year.  In 2013, Mr.  
            Borikas challenged the validity of the variable tax rates in  
            Measure H, arguing that GC Section 50079 never authorized  
            differential tax rates nor property classification in a school  
            funding measure.  [Borikas v. Alameda Unified School District  
            (2013) 214 Cal.App.4th 135.]  The Alameda School District  









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            argued that the statutory language of GC Section 50079  
            reflected long-established equal protection principles that  
            allow a governmental entity to create reasonable tax  
            classification so long as all taxpayers within a  
            classification are treated the same.  (Id., p. 140.)  The  
            Court of Appeal agreed with the plaintiff and concluded that  
            the statutory language in question was intended to be "a  
            constraint on the extent of the taxing authority delegated to  
            the local governmental entities."  (Ibid.)  In other words,  
            the uniformity provision is "language of limitation and does  
            not, itself, authorize local districts to classify and  
            differentially tax taxpayers or property."  (Id., p. 151.)   
            The Court concluded that if the Legislature "had intended to  
            delegate the school districts the broadest taxing authority  
            allowed by law - that is, taxing authority bounded only by  
            equal protection principles - it needed only to have  
            authorized school districts to impose special taxes, or in  
            other words, it needed only to have enacted section 50079,  
            subdivision (a)."  (Ibid.)

           8)What Does This Bill Do  ?  This bill would prospectively  
            overturn the Borikas decision, allowing school districts to  
            use property classifications - commercial, industrial,  
            single-family residential and multifamily residential - to  
            levy different parcel tax rates within the classification.   
            The rate of tax imposed on commercial or industrial properties  
            may not be more than two times the rate of the parcel tax  
            imposed on single-family residential properties.  School  
            districts would also be allowed to tax unimproved property at  
            a lower rate.  In addition, districts would be able to choose  
            the method of calculating a parcel tax based on any the  
            following: a per-parcel, per-square foot of the parcel, or  
            per-square foot of the improvements basis.  Finally, this bill  
            would allow districts to combine multiple parcels into one if  
            they are commonly owned and constitute one economic unit.  
           
           9)The Balancing Act  .  While this bill provides school districts  
            with more control and flexibility over their parcel tax  
            measures, it may, at the same time, lead to a patchwork of  
            complex parcel tax regimes in different parts of the state.   
            Under Borikas, school districts can only impose a tax applying  
            the same rate to all parcels, regardless of their sizes or  
            use.  In contrast, if this bill were to become law, school  
            districts may choose to tax commercial property based on  
            square footage but multifamily properties on a per-parcel  









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            basis; they may decide to treat multiple parcels as one parcel  
            and tax those as one at a higher rate.  Different parcel tax  
            regimes in different school districts will certainly  
            complicate the tax compliance for some property owners,  
            especially business owners, and may lead to wide disparities  
            in the amount of revenues raised by various school districts. 

          On the other hand, the Borikas "one-size-fits-all" approach  
            presupposes that all school districts have the same needs and  
            the same ability to raise needed revenues.  Parcel taxes are  
            intended as a local source of funding for local programs; they  
            are subject to rigorous public discussions and a voter  
            approval.  Local residents must decide whether the proposed  
            tax is a fair price to pay to fund certain programs and  
            services.  However, parcel taxes are inherently regressive  
            since they are not based on one's ability to pay or the value  
            of the property.  Voters may be questioning this truly  
            "uniform" but regressive tax structure and may be less willing  
            to vote for the new parcel taxes.  

          In essence, this bill highlights the inherent problem with the  
            existing parcel tax structure, as well as the  
            acquisition-based property tax system in California.  The  
            Committee may wish to consider whether the benefits of  
            allowing a school district to impose a parcel tax at  
            differential rates would outweigh the burdens of creating a  
            myriad of complicated parcel tax regimes in the state.  The  
            Committee may also wish to consider whether a broader  
            discussion of California's property tax system and its current  
            structure is warranted. 

           10)Who Bears the Burden of a Parcel Tax  ?  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.]  Generally, nonresident landowners are not registered  
            voters and are not included among the voters voting on the  
            proposed parcel tax.  On the other hand, some registered  
            voters who do not own real property 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).  In  
            addition, districts may exempt taxpayers 65 years or older or  









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            those who receive SSI or SSDI, creating another class of  
            voters who do not bear the incidence of the tax. This bill  
            would allow school districts to levy a parcel tax on  
            commercial and industrial properties at a higher rate than the  
            tax imposed on residential properties.  The Committee may wish  
            to consider whether this bill would encourage residents within  
            the school district to enact a parcel tax where the greater  
            incidence of the tax burden is shifted to commercial and  
            industrial properties, especially in light of the fact that  
            many of those properties are owned by non-residents who do not  
            have the right to vote in the district and do not generally  
            use the services and programs funded by the parcel taxes. 

           11)Parcel Taxes and Income Tax Deductions  .  Some critics of this  
            bill have argued that the proposed non-uniform parcel tax  
            structure may cause homeowners to lose their income tax  
            deductions for the parcel tax.  However, it is unclear whether  
            a parcel tax imposed as a flat tax on every parcel in the  
            district is currently deductible for income tax purposes.   
            Generally, to be deductible for both state and federal income  
            tax purposes, real property taxes must be levied for the  
            general public welfare at "a like rate against all property"  
            in the taxing authority's jurisdiction.  [Treasury  
            Regulations, Section 1.164-4(a).]  Non-ad valorem assessments  
            may be deductible only if they are levied "for the general  
            welfare by a property taxing authority at a like rate on  
            owners of all properties in the taxing authority's  
            jurisdiction, and if the assessments are not for local  
            benefits (unless for maintenance or interest charges)."<1>   
            While the phrase "a like rate" is not defined in either the  
            Internal Revenue Code or the Treasury Regulations, a  
            memorandum issued by the Office of Chief Counsel of the IRS  
            states that this term "requires that the rate must uniformly  
            apply based upon an independent variable, such as property  
            value or parcel or structure size, to be considered similar or  
            'like.' "<2>  With respect to the Fire Prevention Fee, the  
            memorandum concluded that a "charge of $150 against each  
            structure no matter how large or small is not levied at a  
            'like' rate."  This interpretation of a "like rate" appears to  
            be based on the assumption that a rate could be "a like rate"  
          ---------------------------
          <1> Internal Revenue Service Information Letter 2012-0018A  
          (March 30, 2012). 
          <2> Real Property Tax Deduction for Fire Prevention Fees, Office  
          of Chief Counsel of the Internal Revenue Service Memorandum,  
          Number 201310029, January 14, 2013, page 5. 








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            only if applied within a certain property classification.  The  
            issue of whether a particular parcel tax is deductible for  
            income tax purposes is a question of facts and circumstances.   
            However, it appears that per-parcel flat taxes are not  
            currently deductible for federal or state income tax purposes  
            anyway, and this bill, if nothing else, will bring California  
            parcel taxes one step closer to being deductible by satisfying  
            the federal definition of a "like rate." 

           12)Related Legislation  .  AB 59 (Bonta) would have provided that  
            the "uniform application of taxes" provision shall not be  
            construed as limiting a school district from assessing taxes  
            in accordance with rational classifications among taxpayers or  
            types of property within the school district. AB 59 would have  
            applied to transactions predating the Borikas decision.  AB 59  
            was amended out of this Committee's jurisdiction.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Alameda Unified School District
          Albany Unified School District Board of Education
          Association of California School Administrators
          California Association of School Business Officials
          California Labor Federation 
          California School Boards Association
          California School Employees Association
          California Teachers Association
          San Diego Unified School District
          Tom Torlakson, State Superintendent of Public
            Instruction
          Wiseburn School District
           
            Opposition 
           Air Conditioning Trade Association
          Air Logistics Corporation
          American Resort Development Association
          Apartment Association, California Southern Cities
          Apartment Association of Greater Los Angeles
          Associated Builders and Contractors of California
          Associated Builders and Contractors of California -
            San Diego Chapter
          Associated General Contractors of California
          BayBio









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          Biocom
          Building Owners and Managers Association of
            California
          California Apartment Association
          California Association of Realtors
          California Attractions and Parks Association
          California Bankers Association
          California Beer and Beverage Distributors
          California Building Industry Association
          California Business Properties Association
          California Cable and Telecommunications
            Association
          California Chamber of Commerce
          California Grocers Association
          California Healthcare Institute
          California Hotel and Lodging Association
          California Independent Oil Marketers
            Association
          California Independent Petroleum Association
          California Manufacturers and Technology
            Association
          California Mortgage Bankers Association
          California New Car Dealers Association
          California Railroad Industry
          California Restaurant Association
          California Retailers Association
          California Tank Lines, Inc.
          California Taxpayers Association
          California Travel Association
          Caterpiller, Inc.
          Chamber of Commerce Mountain View
          Chamber of Commerce Alliance of Ventura and
            Santa Barbara Counties
          Chemical Transfer Company, Inc.
          Contra Costa Taxpayers Association
          Council on State Taxation
          East Bay Rental Housing Association
          Extra Space Storage, Inc.
          El Dorado Land Holdings, LLC
          Family Business Association
          Family Winemakers of California
          Greater San Fernando Valley Chamber of
            Commerce
          Howard Jarvis Taxpayers Association
          International Council of Shopping Centers









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          Kern County Taxpayers Association
          Lake Tahoe South Shore Chamber of Commerce
          Lucy Lofrumento, Esq., LMA Law, LLP
          NAIOP of California, the Commercial Real
            Estate Development Association
          National Association of Real Estate 
            Investment Trusts
          National Federation of Independent
            Business
          NorCal Rental Property Association
          Orange County Business Council
          Orange County Taxpayers Association
          Pacific Life Insurance Co.
          PhRMA
          Plumbing-Heating-Cooling Contractors
            Association of California
          Redondo Beach Chamber of Commerce
          Regional Economic Association Leaders of California
          San Diego County Apartment Association
          San Jose Silicon Valley Chamber of
            Commerce
          San Mateo County Economic Development
            Association
          Santa Barbara Rental Property Association
          Silicon Valley Leadership Group
          Simi Valley Chamber of Commerce
          Solar Turbines, Incorporated
          Superior Tank Wash, Inc.
          TechAmerica
          TechNet
          Tenet Healthcare Corporation
          United Hospital Association
          West Coast Leasing, LLC
          West Coast Lumber and Building Material
            Association
          Western Electrical Contractors Association
          Western Manufactured Housing Communities
            Association
          Western States Petroleum Association
          Wine Institute

          Analysis Prepared by  :    Oksana Jaffe / REV. & TAX. / (916)  
          319-2098 











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