BILL ANALYSIS                                                                                                                                                                                                    






                         SENATE COMMITTEE ON EDUCATION
                              Gloria Romero, Chair
                           2009-2010 Regular Session
                                        

          BILL NO:       SB 592
          AUTHOR:        Romero
          AMENDED:       April 16, 2009
          FISCAL COMM:   Yes            HEARING DATE:  April 29, 2009
          URGENCY:       No             CONSULTANT:  Kathleen Chavira

           SUBJECT  :  Charter School Facilities
          
           SUMMARY  

          This bill authorizes a local government entity, including  
          but not limited to, a county board of education, a city or  
          a county, and authorizes a charter school to hold title to  
          a facility constructed with state bond funds under the  
          School Facility Program.  The bill also requires a district  
          currently holding title to such facilities to transfer  
          title to these entities upon the request of the charter  
          school, unless the school district has contributed at least  
          50 percent of the local matching share or provided the land  
          for the project.

           BACKGROUND  

          Current law establishes the School Facility Program (SFP)  
          under which the state provides general obligation bond  
          funding for various school new construction and  
          modernization projects.  In 2002, Proposition 47 authorized  
          $11.4 billion dollars in general obligation bonds.  Among  
          other things, it created the Charter Schools Facilities  
          Program (CSFP) and provided $100 million in funding for  
          this purpose.  In 2004, Proposition 55 authorized $10  
          billion in general obligation bonds and provided an  
          additional $300 million for the new construction of  
          facilities for charter schools. Most recently, Proposition  
          1D made several changes and further expanded the CSFP,  
          providing an additional $500 million for charter school  
          facilities.  

          Current law requires that a school district hold title, in  
          trust, for the benefit of the state public school system,  
          to any project facilities constructed with state bond  




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          funds.  Current law also provides for the continued use of  
          a charter school facility by another charter, or the school  
          district if the charter school funded under the CSFP ceases  
          to use the facility for a charter school purpose.  If the  
          district declines to take possession of the facility or it  
          is no longer needed for public school purposes, the  
          district is authorized to dispose of the facility in a  
          manner applicable to the disposal of surplus public school  
          sites. 

           ANALYSIS
           
           This bill  authorizes a local government entity, including  
          but not limited to, a county board of education, a city or  
          a county, and authorizes a charter school to hold title to  
          a facility constructed with state bond funds under the  
          School Facility Program.  More specifically it:

          1)   Creates new conditions which must be met prior to the  
               release of funds for a school facility project under  
               the Charter School Facility Program (CSFP) by  
               requiring that an applicant for these funds provide  
               one of the following:

                    a)             Documentary evidence that a school  
                    district in which the facility is to be  
                    physically located holds title to the project  
                    facilities.

                    b)             Documentary evidence that a local  
                    governmental entity, including but not limited  
                    to, a county board of education, a city or a  
                    county holds title to the facilities in trust for  
                    the benefit of the state public school system.

                    c)             A request that the charter school  
                    be authorized to hold fee simple title to the  
                    property, to be submitted with a statement  
                    outlining the reasons that ownership of the  
                    facilities cannot be vested with the district or  
                    local governmental entity.

          2)   Prohibits a local governmental entity that holds title  
               to a project facility from exercising any control over  
               the operation of the charter school and requires  
               compliance with CSFP adopted regulations.




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          3)   Requires a charter school requesting authority to hold  
               title to a project facility to record a lien in favor  
               of the State Allocation Board for the total amount of  
               funds allocated under the CSFP.

          4)   Requires a school district which entered into an  
               agreement to hold title to a charter school facilities  
               project prior to January 1, 2010, to transfer title to  
               a local government entity or the charter school, upon  
               the request of the charter school unless the district:

                    a)             Contributed no less than 50  
                    percent of the local matching share, as  
                    specified.

                    b)             Purchased and retains ownership,  
                    in whole, of the site upon which the charter  
                    school facility project is located.  

          5)   Authorizes, the titleholder, rather than the school  
               district, to dispose of the facilities in a manner  
               otherwise applicable to the disposal of surplus public  
               school sites, if a district declines to use the  
               facility as a school site or it is no longer needed  
               for public school purposes.

          6)   Makes other conforming changes.




           STAFF COMMENTS  

           1)   What is the problem  ?  In order to participate in the  
               Charter School Facility Program (CSFP), the California  
               School Finance Authority (Authority) requires three  
               agreements: the Memorandum of Understanding (MOU),  
               which outlines the roles and responsibilities of all  
               parties involved in the CSFP project; the Funding  
               Agreement, which sets forth the repayment terms of the  
               local matching share amount (templates for these  
               agreements were adopted by the State Allocation Board  
               (SAB) in January 2007); and the Use Agreement, which  
               is negotiated and entered into by the school district  
               and charter school.  As titleholders for facilities  




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               constructed under the CSFP, school districts must sign  
               both the MOU and the Use Agreements.  All three  
               agreements must be executed prior to any fund release.  
                

               Charter schools contend that the time involved in  
               negotiating the Use Agreements is excessive, resulting  
               in delays in initiating projects or acquiring land.   
               In addition, charters have expressed concern that  
               school districts have placed "onerous" conditions upon  
               them in these agreements and have extracted  
               unreasonable concessions such as rights for parking,  
               use rights for adult school programs or other  
               non-charter programs, and that they have been required  
               to waive all rights to request any other property from  
               the district for the term of the lease.  This bill  
               attempts to address this issue by authorizing both  
               local government entities and charter schools to be  
               eligible to hold title to the facilities.  The  
               committee may want to explore further whether they  
               concur that the conditions imposed by districts are  
               "onerous."
           
          2)   Who should hold title  ?  This bill authorizes cities  
               and counties to hold title to CSFP facilities in trust  
               for the state public school system and prohibits them  
               from controlling the operation of the charter school.   
               Is this sufficient to ensure that assets that derive  
               from funds provided by voters for the purpose of  
               constructing school facilities serve this purpose?   
               Could/should the local entities' financial interest in  
               these facilities be used to underwrite other local  
               government priorities?  What happens if a city or  
               county declares bankruptcy? Would/should the facility  
               be available as an asset to satisfy a city or county's  
               debt obligations?  Should titleholders be restricted  
               to those who can grant charters, i.e. districts,  
               county offices of education and the State Board of  
               Education? 

           3)   Just ask  ?  As drafted, the bill appears to require a  
               simple request from a charter to hold title as  
               sufficient documentary evidence to release funds for a  
               charter school facility project.  Staff recommends the  
               bill be amended to clarify that the SAB has reviewed  
               and approved such a request prior to any fund release.  




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           4)   New role for SAB  ?   This bill requires a charter that  
               requests to hold title to submit a statement outlining  
               the reasons ownership is not vested in a district or  
               other local entity.  Presumably, this would occur when  
               there is a lack of consensus around a Use Agreement  
               between the two entities.  Is it the intent that the  
               SAB assess the "reasonableness" of each party's  
               conditions/concerns? Is this "arbiter" function over  
               Use Agreements an appropriate role for the State  
               Allocation Board (SAB)? 
           
          1)   Surplus property  .  This bill authorizes the  
               "titleholder" to dispose of the facilities if a  
               district declines to use the facility as a school site  
               or it is no longer needed for public school purposes.   
               What happens to the proceeds from the sale?  Does a  
               school district retain any excess proceeds if the  
               property is sold or can a charter school or other  
               local government entity retain the proceeds? What  
               assurance is there that proceeds from the sale of  
               assets constructed with funds authorized for public  
               school facility purposes will be used to meet voters'  
               original intent?  Staff recommends the bill be amended  
               to clarify that the excess proceeds from the sale of  
               any charter school facility shall be transferred to  
               and retained by the school district in which the  
               charter facility is located, or that granted the  
               charter, to be used for capital facilities purposes of  
               a school district.  
           
          1)   Gift of public funds  ?  This bill also requires that a  
               district transfer title to a charter school upon  
               request of the charter, unless a district contributed  
               at least 50 percent of the local match or land for the  
               project.  Should a school district's resources, in any  
               amount, be transferred to a charter?  Does this  
               constitute a gift of public funds to the charter?   
               Staff recommends the bill be amended to require that  
               the charter school reimburse the school district for  
               any funds or the value of land provided by the  
               district prior to transfer of title in order to avoid  
               any possibility of a gift of public funds. 
           
          2)   Abrogate a contract  ?  Currently, districts hold title  




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               to charter facilities funded under the Charter School  
               Facility Program (CSFP) and enter into Use Agreements  
               with charters for use of these facilities.  This bill  
               proposes to invalidate existing agreements by  
               requiring a district to comply with a charter school's  
               request to have title transferred to a local  
               government entity or to the charter school itself, in  
               essence, abrogating a contract entered into by a  
               school district.  Arguably, it may be within the  
               State's authority to abrogate or modify any contract  
               which its political subdivision or agency, the  
               district, has entered into on the State's behalf.  But  
               is it prudent for the State to unilaterally overturn  
               the local district's authority in this regard?   
               Shouldn't the district retain some discretion?  Who is  
               responsible for the related transaction costs to  
               transfer title?  Staff recommends the bill be amended  
               to apply to contracts entered into prior to January 1,  
               2010 only if mutually agreed to by the district and  
               the charter school facility.

           3)   Protection of the state's interests  .  This bill  
               authorizes a charter school to hold title to  
               facilities constructed with state bond dollars and  
               requires that the charter hold "fee simple title" and  
               record a lien against the property by the SAB for the  
               total amount of funds allocated. 

               Does "fee simple title" provide the best protection  
               for the state?  Are other methods or conditions for  
               holding title more appropriate?  Staff recommends the  
               bill be amended to ensure that the charter holding  
               title is conditioned upon the continued use of the  
               facility for school purposes and automatically ends  
               the charter's interest in the property if that  
               condition is not met.

               Is a lien against the property for the total amount of  
               funds  allocated  sufficient protection of the state's  
               interest in the property?  Are the state's interest  
               ensured if they have a lien against only half a  
               building?  What risk or liability does the state incur  
               if it holds a lien against the title?  Under the Lease  
               Purchase Program (LPP), which preceded the current  
               School Facility Program, the state held lease to  
               property constructed with state bond funds and  




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               districts purchased the property from the state over  
               time.  The LPP contained various provisions of law to  
               protect the State Allocation Board from any liability  
               actions or damages arising from district construction  
               related contracts and to ensure that the state's  
               interest in properties and equipment purchased with  
               state bond funds was assured.  Staff recommends the  
               bill be amended to require a lien for the full value  
               of the building.  Staff further recommends the bill be  
               amended to add language patterned after Education Code  
               Sections 17029.5 and 17030, which applied to the LPP,  
               in order to provide these same protections of the  
               state's interest in Charter School Facility Program  
               projects. 

           SUPPORT  

          California Charter School Association
          Department of General Services
          EdVoice
          Green Dot Public Schools
          Los Angeles Unified School District

           OPPOSITION

           None received.