BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          SB 555
          Senator Kehoe
          As Amended April 13, 2009
          Hearing Date: April 21, 2009
          Code of Civil Procedure
          BCP:jd
                    

                                        SUBJECT
                                           
                       Eminent Domain: Conservation Easements

                                      DESCRIPTION  

          This bill would prohibit a person authorized to acquire property  
          for a particular use by eminent domain from exercising that  
          power to acquire property that is subject to a conservation  
          easement, except as provided.  Specifically, this bill would  
          require:
                 notice to the holder of the conservation easement, an  
               opportunity for that holder to comment, and a response to  
               those comments; and
           notice to the public entity that provided funds for the  
            purchase of the easement, or that required the easement as a  
            condition of project approval.

          This bill would prohibit a person from initiating eminent domain  
          proceedings against property subject to a conservation easement  
          unless: (1) the location was not chosen based primarily on the  
          lower cost of the property; and (2) that there is no other land  
          in the vicinity on which it is reasonably feasible to locate the  
          public improvement.

          This bill would further state that the holder of a conservation  
          easement is an owner of property entitled to compensation if  
          that property is taken, and define compensation.

          This bill would additionally state that "property appropriated  
          to public use" includes a conservation easement, thus triggering  
          the application of specific requirements that apply when a  
          person seeks to acquire property already appropriated for public  
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          use.

                                      BACKGROUND  

          In 1979, the Legislature declared that the preservation of land  
          in its natural, scenic, agricultural, historical, forested, or  
          open-space condition is among the most important environmental  
          assets of California.  In conjunction with that declaration, the  
          Legislature broadly defined a "conservation easement," and  
          codified that those easements are an interest in real property,  
          perpetual in duration, not personal in nature, and having the  
          characteristics granted or specified in the instrument created  
          in the easement.  

          Generally speaking, a conservation easement is a legal contract  
          between a property owner and a third party (often a land trust)  
          that restricts the use of the land for the purpose of  
          conservation (retaining the land predominantly in its natural,  
          scenic, historical, agricultural, forested, or open-space  
          condition).   Those easements typically restrict development and  
          subdivision of the property, run with the land (ie. bind the  
          original and subsequent owners), and are recorded with the  
          county recorder to provide public notice of the easement.  Since  
          the property owner retains ownership of the property,  
          conservation easements also represent a less expensive  
          alternative to outright purchase of the property for nonprofits  
          seeking to protect land, and may result in a tax advantage to  
          the property owner.  The easement itself is held by the third  
          party (nonprofit 501(c)(3), Native American Tribe, or government  
          entity, as specified).  The sponsor, California Council of Land  
          Trusts, provides the following two examples of recent  
          conservation easement donations to the Land Trust of Santa  
          Barbara County:

            [The first donation was] a 195-acre avocado farm that  
            protects farmland, wildlife habitat and a creek, and  
            provides scenic views from a public trail.  The second  
            donation was appraised at $42 million on a 3,100-acre  
            property.  It contains extensive watershed lands and  
            farmland, and because the property abuts a very popular  
            public hiking trail, it also provides scenic views to the  
            public.  

          In response to prior concerns about the condemnation of  
          conservation easements, AB 910 (Wayne, Chapter 863, Statutes of  
          2001) prohibited a governmental entity from condemning wildlife  
                                                                      



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          conservation easements acquired by a state agency, or the  
          property under those easements, unless certain procedures were  
          complied with, including giving notice of the proposed  
          condemnation to the holder of the easement, and allowing that  
          holder to state its objections and to receive a response.  (Fish  
          & G. Code Sec. 1348.3.)  The sponsor of that bill, the  
          California Waterfowl Association, argued that the ease with  
          which conservation easements could be condemned under California  
          law, at that time, "threaten[ed] to undermine one of  
          California's most successful and economically prudent natural  
          resource conservation strategies."

          This bill, sponsored by the California Council of Land Trusts,  
          similarly seeks to restrict the ability of a person to condemn a  
          conservation easement by imposing additional notices, responses,  
          findings, and clarifying the compensation to be paid if land is  
          taken.

                                CHANGES TO EXISTING LAW
           
           Existing federal law  provides that "private property [shall not]  
          be taken for public use, without just compensation." (U.S.  
          Const. Am. V.)

           Existing state law  provides that private property "may be taken  
          or damaged for public use only when just compensation,  
          ascertained by a jury unless waived, has first been paid to, or  
          into court for, the owner."  (Cal. Const. art. I, Sec. 19.)   
          Existing state law defines "just compensation" as a property's  
          fair market value "as determined by any method of valuation that  
          is just and equitable."  (Code Civ. Proc. Secs.  
          1263.310-1263.320.)

           Existing law  further provides that the power of eminent domain  
          may be exercised to acquire property only for a public use, and  
          only if all of the following are established: (1) the public  
          interest and necessity require the project; (2) the project is  
          planned or located in the manner that will be most compatible  
          with the greatest public good and the least private injury; and  
          (3) the property sought to be acquired is necessary for the  
          project.  (Code Civ. Proc. Secs.1240.010, 1240.030.)

           Existing law  states that any person authorized to acquire  
          property for a particular use by eminent domain may exercise the  
          power of eminent domain to acquire property appropriated to  
          public use: (1) if the proposed use will not unreasonably  
                                                                      



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          interfere with or impair the continuance of the public use as it  
          then exists or may reasonably be expected to exist in the  
          future; or (2) if the use for which the property is sought to be  
          taken is a more necessary public use than the use to which the  
          property is appropriated. (Code Civ. Proc. Secs. 1240.510,  
          1240.610.)

           Existing law  finds and declares that the preservation of land in  
          its natural, scenic, agricultural, historical, forested, or  
          open-space condition is one of the most important environmental  
          assets of California, and states that it is to be the public  
          policy and in the public interest of this state to encourage the  
          voluntary conveyance of conservation easements to qualified  
          nonprofit organizations.  (Civ. Code Sec. 815.)  

           Existing law  defines a "conservation easement" as any limitation  
          in a deed, will, or other instrument in the form of an easement,  
          restriction, covenant, or condition, which is or has been  
          executed by or on behalf of the owner of the land subject to  
          such easement and is binding upon successive orders of such  
          land, and the purpose of which is to retain land predominantly  
          in its natural, scenic, historical, agricultural, forested, or  
          open-space condition.  (Civ. Code Sec. 815.1.)  A conservation  
          easement has the following characteristics:  
           voluntarily created interest in real property that is freely  
            transferable;
           perpetual in duration;
           not deemed to be personal in nature, but shall constitute an  
            interest in real property; and
           the particular characteristics shall be those granted or  
            specified in the instrument creating or transferring the  
            easement. (Civ. Code Sec. 815.2.)

          Existing law  only allows the following entities or organizations  
          to acquire and hold conservation easements: (a) tax-exempt  
          nonprofit 501(c)(3) organizations with a primary purpose of  
          preserving, protecting, or enhancing land in its natural,  
          scenic, historical, agricultural, forested, or open-space  
          condition or use; (b) the state or any city, county,  city and  
          county, district, or other state or local government entity, as  
          specified; and (c) a California Native American tribe, as  
          specified.  (Civ. Code Sec. 815.3.)  Existing law also requires  
          the recordation of instruments creating, assigning, or otherwise  
          transferring conservation easements, and provides for the  
          creation of a conservation easement registry.  (Civ. Code Sec.  
          815.5; Pub. Res. Code Sec. 5096.520.)
                                                                      



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           Existing law  provides that no governmental entity may condemn  
          any wildlife conservation easement, as defined, unless, prior to  
          the initiation of condemnation proceedings by a governmental  
          entity, the entity: (a) gives notice to the holder of the  
          easement; (b) provides an opportunity for the holder of the  
          easement to consult with the governmental agency; and (c)  
          provides a response to objections.  In the condemnation  
          proceedings, the condemning governmental entity shall be  
          required to prove by clear and convincing evidence that its  
          proposed use satisfies specified requirements under the Eminent  
          Domain Law.  (Fish & G. Code Sec. 1348.3; Code Civ. Proc. Sec.  
          1240.610 et seq.) 

           This bill  would similarly provide that a person authorized to  
          acquire property for a particular use by eminent domain shall  
          not exercise that power to acquire for public use property that  
          is subject to a conservation easement, except as specified. 

           This bill  would state that when it appears that property subject  
          to a conservation easement may be required for a public use, the  
          person seeking to acquire the property shall, not less than 30  
          days prior to the date it intends to initiate eminent domain  
          proceedings, provide written notice to the entity or  
          organization that holds the conservation easement of its  
          intention to initiate eminent domain proceedings to acquire  
          property that is subject to a conservation easement.  That  
          notice shall provide:
           a general description of the property subject to a  
            conservation easement that is proposed for acquisition;
           a description of the public use or improvement that the person  
            is considering for the property; and 
           provide an opportunity for the holder of the conservation  
            easement to consult with the person seeking to acquire the  
            property prior to commencement of eminent domain proceedings.

           This bill  would provide that the person intending to acquire the  
          property subject to a conservation easement shall, within 30  
          days after receipt of comments from the holder of the  
          conservation easement, respond in writing to the comments.

           This bill  would provide that if a conservation easement was  
          purchased with state or local public funds or if a public entity  
          required the conservation easement as a condition of project  
          approval, the easement holder upon receipt of the above notice  
          shall inform the person intending to initiate eminent domain  
                                                                      



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          proceedings of the name and address of any public entity that  
          provided funds for the purchase of the easement or required it  
          as a condition of approval.  The easement holder shall provide  
          to the public entity that provided funds or required the  
          easement the same notice and the public entity shall have 30  
          days after receipt of the notice from the easement holder to  
          state in writing its objections to the acquisition.  This  
          requirement shall not apply if there are no recorded documents  
          that evidence, and the easement holder has no record or  
          independent knowledge of, the identity of the public entity that  
          provided funds to purchase the conservation easement or that  
          required the conservation easement as a condition of approval.

           This bill  would provide that in any eminent domain proceeding to  
          acquire property subject to a conservation easement, that:
           provisions in existing law regarding the characteristics of  
            conservation easements shall apply; and
           the holder of the easement be named as a defendant, and have  
            all the same rights and obligations as any other defendant in  
            the eminent domain proceeding;

           This bill  would further state that no person shall initiate  
          eminent domain proceedings against property subject to a  
          conservation easement unless the following findings are made:
           the location is not based primarily on a consideration of the  
            lower cost of acquiring the property; and
           there is no other land within the vicinity on which it is  
            reasonably feasible to locate the public improvement.

           This bill  would state that "property appropriated to public use"  
          as used in Article 6 (commencing with Section 1240.510) and  
          Article 7 (commencing with Section 1240.610) includes a  
          conservation easement, and define "person" and "conservation  
          easement."

           This bill  would provide that the holder of a conservation  
          easement is an owner of property entitled to compensation if  
          that property is taken.  Compensation for the taking of all  
          interests in the property subject to a conservation easement  
          shall be no less than the compensation paid for the property if  
          it were unencumbered by that conservation easement.

                                        COMMENT
           
          1.    Stated need for the bill  

                                                                      



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          According to the author:

            Tremendous public and charitable assets have been invested  
            in the acquisition of conservation easements in California.   
             Yet, with the narrow exception created for a relatively  
            small number of easements in Fish and Game Code section  
            1348.3, conservation easements are as vulnerable to  
            condemnation as any other property in private ownership.   
            The fact that a conservation easement exists, that sometimes  
            millions of dollars in public dollars have been expended to  
            conserve it, or that a public agency has said that the  
            property's conservation advances certain public goals are  
            all irrelevant to a potential condemnation proceeding.  In  
            spite of the implicit recognition of the public value of  
            conservation easements as evidenced in law and public  
            funding, they are not recognized as having any public use  
            for the purposes of eminent domain law.

            Further, the easement holder - who holds a real property  
            interest - does not have to be notified of the proposed  
            condemnation.  Nonprofit easement holders report that  
            governmental entities with the power of eminent domain often  
            fail to recognize a conservation easement as a separate and  
            distinct property right.  In numerous instances, the entity  
            has refused to acknowledge the easement holder until the  
            holder of the fee title land refuses to talk with the entity  
            about the condemnation without the easement holder or the  
            easement holder has retained counsel to force discussion.

            The conservation community is facing an increasing number of  
            condemnations of conservation easements, and it expects this  
            trend to increase as development pressure continues and  
            communities are built out.  The conservation community is  
            not trying to eliminate the power of eminent domain - it  
            recognizes that other societal needs will sometimes require  
            the condemnation of a conservation easement.  However, it is  
            seeking to ensure that easement holders receive notice and  
            have the right to object, and to create a high standard for  
            condemning easements to help ensure that public use and  
            investment is not lightly lost.

          The California Outdoor Heritage Alliance (COHA), in support,  
          notes that:

            . . . urban growth increasingly threatens easements in cases  
            where public agencies attempt to use their condemnation  
                                                                      



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            powers to construct roads and other infrastructure.  If  
            successful, this action not only compromises the wildlife  
            values of the conservation easement, but also wastes  
            valuable public funding that was typically used initially to  
            acquire the easement.  In addition, it threatens the future  
            use of easements as conservation tools by undermining the  
            landowner trust that easements, in fact, protect land in  
            perpetuity.

          2.    Requirements that must be satisfied prior to the initiation  
            of eminent domain proceedings  

          The sponsor states that this bill is the result of their study  
          of condemnation actions against conservation easements and lands  
          protected for conservation purposes and: "The lack of notice  
          provisions was identified as a common problem which this bill  
          would address.  Further, the fact that the conservation easement  
          had been created for public purposes and with public support was  
          not viewed by the condemning agencies as a public use of the  
          property that could conceivably outweigh the purpose for which  
          they wanted the property."

          This bill seeks to address those issues, by, among other things,  
          imposing detailed notice requirements and findings that must be  
          made prior to initiation of eminent domain proceedings on the  
          property for which there is a conservation easement.

            a)   Timing of notice  

            As noted above, AB 910 (Wayne, 2001) imposed notice  
            requirements prior to the condemnation of a wildlife  
            conservation easement that had been acquired by a state  
            agency.  While this bill would impose similar notice  
            requirements on a broader range of conservation easements,  
            this bill requires additional notices and specific timing  
            requirements (AB 910 did not specify timing in terms of days).  
             

            The sponsor notes that there is a problem in the proposed  
            timing requirements because those requirements do not provide  
            enough time between the initial notice and the filing of the  
            eminent domain proceeding.  Specifically, the detailed notice  
            would be required not less than 30 days prior to the date the  
            person intends to initiate eminent domain proceedings.  The  
            holder of the easement then has 30 days to state its  
            objections in writing - the person intending to acquire the  
                                                                      



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            property then has 30 days to respond in writing to the  
            comments.  As a result, the action could be filed well before  
            completion of the notice and comment requirements.

            In response to that timing issue, the sponsor suggests that  
            the original notice be provided not less than 90 days (instead  
            of 30) prior to the date the action is commenced.  That  
            modification to the timing requirement would ensure that all  
            communication takes places prior to the commencement of  
            proceedings, and would replace the word "intent" with  
            "initiate" in order to provide a firm timeframe.

                Amendments  :

               On page 2, lines 18 through 19, strike out "30 days prior  
               to the date it intends to initiate eminent domain  
               proceedings" and insert:

               90 days prior to the initiation of eminent domain  
               proceedings

            b)   Notice to public entity when public funds used to purchase  
            easement  

            To ensure that the public entity that expended funds, or  
            required the easement as a condition of project approval, is  
            aware of the eminent domain action, this bill would require  
            that those public entities receive notice of the action, as  
            specified, and have 30 days to respond.  

            While the present language requires the easement holder to  
            notify the public entity themselves of the pending action, the  
            sponsor notes that that requirement is a drafting error, and  
            it should be the person who seeks to initiate eminent domain  
            proceedings who should provide notice to the public entity.   
            The following amendment is suggested to correct the drafting  
            problem:

                Amendments:

                1)  On page 3, line 29, strike out "easement holder" and  
               insert:

               person intending to initiate eminent domain proceedings

               2)  On page 3, line 32, strike out "easement holder" and  
                                                                      



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               insert:

               person intending to initiate eminent domain proceedings

            Furthermore, the notice to the public entity is conditioned  
            upon the easement holder knowing that they must inform the  
            person seeking to initiate eminent domain of the public  
            entity's involvement.  To ensure that the easement holder is  
            aware of that requirement, the initial notice to the easement  
            holder should include a statement that they are obligated to  
            provide information about the involvement of a public entity.   
            The following amendment is suggested to address this issue:

                Suggested amendment  :

               On page 3, line 11 after the period, insert:

               (D) Inform the easement holder that, upon receipt of the  
               notice, the easement holder shall inform the person  
               intending to initiate eminent domain proceedings of the  
               name and address of any public entity that provided funds  
               for the purchase of the easement or required it as a  
               condition of approval.

            The sponsor, in support of the above provisions, contends that  
            they are seeking to protect the public's investment in  
            conservation easements, and that it is reasonable that the  
            person seeking to condemn an easement should have certain  
            notice and consultation requirements.   

             c)   Findings prior to the initiation of eminent domain  
               proceedings - clarification needed  

            In order to further protect conservation easements and ensure  
            that the easement is not condemned merely because it is the  
            least expensive plot of land, this bill would require two  
                                         findings to be made prior to the initiation of proceedings.   
            The first required finding is that the location is not based  
            primarily on a consideration of the lower cost of acquiring  
            the property; second, that there is no other land in the  
            vicinity on which it is reasonably feasible to locate public  
            improvements.

            Although the bill would require those findings to be made  
            prior to the initiation of eminent domain proceedings, it is  
            unclear whether a separate action for declaratory relief must  
                                                                      



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            be brought prior to the initiation of proceedings, or even if  
            those findings must be made by a court.  The sponsor states  
            that the intent was to require those findings to be made by  
            the court prior to a plaintiff prevailing in the eminent  
            domain proceeding.  The following amendment is suggested to  
            clarify the findings provision:

                Suggested amendment:

                On page 4, line 7, strike out "initiate eminent domain  
               proceedings against" and insert:

               prevail in an eminent domain proceeding concerning

            d)   Application of restriction on condemning property  
            appropriated for public use  

            The Eminent Domain Law additionally contains procedures for  
            the condemnation of property already appropriated to public  
            use.  Under those provisions, a person may exercise their  
            power of eminent domain only if the proposed use will not  
            unreasonably interfere with or impair the public use as it  
            exists, or if the use for which the property is sought to be  
            taken is a more necessary public use than the use to which the  
            property is appropriated.  This bill would apply those  
            provisions to eminent domain actions that condemn a property  
            with a conservation easement.  It should be noted that  
            although those easements would be treated as a public use,  
            some may be held by non-profit organizations and Native  
            American tribes (neither of which are state entities), and  
            would not necessarily be accessible for use by the public.

            At the request of the Committee, the sponsor provided the  
            following response to this issue:

               Although some conservation easements are held by  
               nonprofit organizations and Native American tribes, they  
               were created to serve a public purpose(s).  Conservation  
               easements are fulfilling public uses recognized in local,  
               state and federal law and significant public funds are  
               expended in furtherance of these uses.  Public use does  
               not necessitate public access, and in fact, may preclude  
               public access in order to achieve the public use and  
               benefit.  For example, conservation easements have been  
               created to protect water quality and public access is not  
               allowed in order to achieve the public use and benefit.   
                                                                      



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               Further, this bill only declares that conservation  
               easements are property appropriated to public use; it  
               does  not  recognize conservation easements as enjoying the  
               presumption that they are the best and most necessary  
               public use of the land.     

          3.   Compensation requirements

           Pursuant to the federal and state Constitutions, property cannot  
          be taken for public use without just compensation.  The Eminent  
          Domain law further states that the owner of property acquired by  
          eminent domain is entitled to compensation, that compensation  
          shall be awarded for any property taken, and that the measure of  
          that compensation is fair market value, as specified.  This bill  
          would additionally provide that: (1) the holder of a  
          conservation easement is an owner entitled to compensation; and  
          (2) that compensation for the taking of all interests in the  
          property shall be no less than the compensation paid for the  
          property if it were unencumbered by that easement.

          The sponsor maintains that it is necessary to specify that the  
          easement holder is entitled to compensation because situations  
          have arisen where public agencies have argued that no  
          compensation should be paid to the easement holder because the  
          property is actually worth less after the easement was put in  
          place.  Although conservation easements are negative rights (ie.  
          restrictions on the use of the property), significant funds may  
          have been expended to purchase that easement, and those  
          easements are arguably worth the amount the encumbrance  
          diminishes the value of the underlying parcel of land.  

          The second provision is intended to clarify how land that is  
          subject to a conservation easement is valued.  The sponsor  
          provides the following example:  If a property that has an  
          appraised value of $1 million dollars and the easement is valued  
          at $400,000, the condemning agency may want to use an appraisal  
          based on the encumbered value of the property, $600,000  
          ($1,000,000 - $400,000), and contend that that fee title holder  
          and easement holder should split the $600,000.  The sponsor  
          asserts that, instead, the compensation should reflect the total  
          unencumbered value of the property ($1,000,000), with the fee  
          title holder and easement holder splitting that amount according  
          to the relative values of their property rights.  Accordingly,  
          the bill seeks to ensure that, in the above situation, the  
          compensation would be $1,000,000, not $600,000.

                                                                      



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          4.   Additional requirements  

          The remaining provisions of this bill would, among other things,  
          require the holder of the easement to appear as a defendant and  
          have all the same rights and obligations as any other defendant  
          in the eminent domain proceedings.  That provision appears  
          consistent with existing law requiring the plaintiff to name  
          persons who have or claim an interest in the property described  
          in the complaint, and the allowance for any person who claims a  
          legal or equitable interest in the property to appear in the  
          proceeding.  (Code Civ. Proc. Secs. 1250.220, 1250.230.)

          5.   Opposition  

          The American Council of Engineering Companies of California,  
          California Business Properties Association, California Chamber  
          of Commerce, and California Forestry Association, in opposition,  
          contend that this bill "would be used to further block jobs and  
          construction of infrastructure projects in California."  Those  
          groups contend, among other things, that: (1) this bill would  
          greatly expand the scope of easements protected from  
          condemnation; (2) property could be immunized from condemnation  
          by having a conservation easement placed on it; and (3) "if SB  
          555 were to become law, conservation easements can be expected  
          to quickly become a favorite weapon in the arsenal of those  
          opposed to a particular condemnation effort or, more generally,  
          of those opposed to an infrastructure or other public project."   
          The Orange Chamber of Commerce raises similar concerns about the  
          bill.  While the above opposition was based on a prior version  
          of the bill, the Committee did not receive any letter removing  
          opposition by any of the above parties.  The author and sponsor  
          should continue to work with those parties, and committee staff,  
          to ensure that this bill's new protections are not abused.  

          The Orange County Taxpayers Association (OCTax), in opposition,  
          further contends that this bill would delay construction of  
          projects, and that the intent seems to be to delay the  
          completion of the SR-241 Toll Road.  The Orange County Board of  
          Supervisors similarly argues:

            SB 555 is intended to stop the ability of governmental  
            agencies to add and adjust conservation easement boundaries.  
             This measure interferes with state and local decision  
            making authority and the ability to protect the public  
            interest in the management of conservation easements by  
            creating new rights of action for parties to litigate  
                                                                      



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            against governmental entities.  Clearly, this bill is an  
            attempt to impede completion of the final segment of the  
            Foothill South toll road by eliminating exploration of any  
            and all potential routes and increasing construction costs.

          In addition, letters were submitted by individuals who contended  
          that this bill would add additional burdensome and costly  
          regulations.  It should be noted that if this bill were to be  
          approved by this Committee, it will be referred to the Senate  
          Appropriations Committee for evaluation of its fiscal effect.

          6.   Conflict with Fish and Game Code Section 1348.3 (enacted by  
          AB 910)
           
          As discussed above, existing Fish and Game Code Section 1348.3  
          imposes similar requirements with regards to wildlife  
          conservation easements acquired by a state agency.  While that  
          bill requires a higher burden of proof, this bill would apply to  
          all conservation easements (not just wildlife), to all easements  
          regardless of whether they were acquired by a state agency  
          (thus, including specified non-profits and Native American  
          tribes), and to all persons authorized to acquire property by  
          eminent domain (instead of governmental entities).  Although SB  
          555 imposes similar notice requirements, AB 910 did not specify  
          the timeframes that are included in this bill, thus making it  
          unclear which procedures must be complied with in actions to  
          condemn wildlife conservation easements.  (See Comment 2(a).)

          To resolve this conflict, the bill should be amended to,  
          instead, state that the requirements added by SB 555 shall apply  
          only if those contained in Fish and Game Code Section 1348.3 are  
          not applicable.  That amendment would preserve the steps  
          required under existing law for condemnation of wildlife  
          conservation easements, including the heightened burden of  
          proof.  

             Suggested amendment:  

            On page 4, line 19 after the period, insert:

            (h) This section shall not apply if the requirements of  
            Section 1348.3 of the Fish and Game Code apply.

          In addition, to provide conformity between sections, and reduce  
          confusion for the condemning entity, the author should continue  
          to work with committee staff to either amend the notice  
                                                                      



          SB 555 (Kehoe)
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          requirements of this bill to be consistent with AB 910, or, in  
          the alternative, amend the notice requirements of Fish and Game  
          Code Section 1348.3 to be consistent with those proposed by this  
          bill.  

          Furthermore, the following technical amendments are required to  
          improve the readability of proposed subdivision (b) of Section  
          1240.055 of the Code of Civil Procedure, and correct an  
          incorrect cross-reference.

             Suggested technical amendments:
             
            1)  On page 2, line 14, strike out "acquire for public use  
            property" and insert:

            acquire, for public use, property 

            2)  On page 2, line 10, strike out "410" and insert:

            510


           Support  :  California Outdoor Heritage Alliance; Planning and  
          Conservation League; California Coastal Coalition; Defenders of  
          Wildlife; California State Parks Foundation; Trust for Public  
          Land; CLCV; Sierra Club California; NRDC; Audubon California;  
          Trust for Public Land; American Land Conservancy; Peninsula Open  
          Space Trust; Sempervirens Fund; California Rangeland Trust;  
          Truckee Donner Land Trust; Big Sur Land Trust; Sequoia  
          Riverlands Trust; Land Trust of Napa County; Tri-Valley  
          Conservancy; Lassen Land & Trails Trust; Bay Area Open Space  
          Council; Mendocino Land Trust; Catalina Island Conservancy; Land  
          Trust of Santa Cruz County; Bolsa Chica Land Trust; Sierra  
          Foothill Conservancy; Feather River Land Trust; Placer Land  
          Trust; Marin Agricultural Land Trust; Eastern Sierra Land Trust;  
          Save Mt. Diablo; Muir Heritage Land Trust; Mountain Meadows  
          Conservancy; Solano Land Trust; Sierra-Cascade Land Trust  
          Council; Land Trust Council; Santa Barbara County; Shasta Land  
          Trust; Lake County Land Trust; Preserve Calavera; Sanctuary  
          Forest, Inc.; Sonoma Land Trust; Amigos de los Rios; San Joaquin  
          River Parkway and Conservation Trust; Land Conservancy of San  
          Luis Obispo County

           Opposition  :  American Council of Engineering Companies of  
          California; California Business Properties Association;  
          California Chamber of Commerce; California Forestry Association;  
                                                                      



          SB 555 (Kehoe)
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          Orange County Board of Supervisors, Orange County Taxpayers  
          Association (OCTax); Orange Chamber of Commerce; ten individuals

                                        HISTORY
           
           Source  :  California Council of Land Trusts

           Related Pending Legislation  :  None Known

           Prior Legislation  :

          AB 910 (Wayne, Chapter 863, Statutes of 2001), prohibited a  
          governmental entity from condemning any wildlife conservation  
          easement acquired by another state agency, except as provided.

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