BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 504
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 504 (Williams)
          As Amended  July 6, 2011
          Majority vote
           
           ----------------------------------------------------------------- 
          |ASSEMBLY:  |75-0 |(May 26,  2011) |SENATE: |36-0 |(July 14,      |
          |           |     |                |        |     |2011)          |
           ----------------------------------------------------------------- 
            
           Original Committee Reference:    REV. & TAX.  

           SUMMARY  :  Authorizes any newly unified school district in the 
          County of Santa Barbara (SB) to continue the collection of the 
          parcel taxes originally imposed and collected in former school 
          districts.  

           The Senate amendments  authorize the Santa Barbara Unified School 
          District to impose a new parcel tax within the boundaries of the 
          former Santa Barbara Elementary School District, provided that 
          specified conditions are met. 

           AS PASSED BY THE ASSEMBLY  , this bill:  

          1)Provided that, when any school district in the County of SB 
            was merged with one or more school districts so as to form a 
            single district, the newly unified district may do all of the 
            following:

             a)   Continue to impose any qualified special taxes imposed 
               in any former school district, as defined by Education Code 
               (EC) Section 35516, provided that the revenues derived from 
               those taxes remain segregated on a geographical basis 
               conforming to the former boundaries of the school districts 
               prior to unification; 

             b)   Impose a new special tax pursuant to the procedures 
               established in Government Code (GC) Article 3.5 (commencing 
               with Section 50075); and, 

             c)   Allows a segregation of revenues derived from the 
               imposition of the new tax on a geographical basis 
               conforming to the former boundaries of the school districts 
               prior to unification. 









                                                                  AB 504
                                                                  Page  2

          2)Declared that a special law was needed to allow school 
            districts in the County of SB that have merged to form a 
            unified school district to continue to impose qualified 
            special taxes that used to be imposed in any of the former 
            school districts, as defined by EC Section 35516, in order to 
            provide critical program support in the unified school 
            district in areas such as music, art, mathematics, and 
            technology.  

           FISCAL EFFECT  :  Unknown, but the Assembly Revenue and Taxation 
          Committee staff estimates no revenue impact on the General Fund. 


           COMMENTS  :   

           Author's statement  .  The author states that, "Assembly Bill 504 
          is clarifying legislation that allows Santa Barbara School 
          Districts to maintain existing parcel tax revenue allotments 
          once their elementary and high school districts unify.  AB 504 
          would also allow the unified Santa Barbara School District to 
          continue to levy future parcel taxes as they do now so that 
          residents are allowed to continue paying for the schools which 
          serve their community.

          "The author wishes to stress that the proposed legislation is a 
          continuation of the status quo in all respects except one.  Now 
          there will be one district instead of two.  The justification 
          for applying this legislation to a single local entity is based 
          upon the unique configuration of the Santa Barbara School 
          Districts, who are one of only a handful of districts statewide 
          that are made up on non-coterminous districts, and the only 
          known such district that is seeking to unify with existing 
          separate outstanding parcel taxes in place." 

           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 schools 
          districts in California.  State court rulings in the Serrano v. 
          Priest equalization cases forced the state to revise basic 
          school finance and established 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, California created the revenue 
          limit system that combines local property tax revenues with 








                                                                  AB 504
                                                                  Page  3

          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 met or exceeded 
          the revenue limit.  In 1978, Proposition 13 limited both the tax 
          rates and assessments, thus, significantly reducing property tax 
          revenues, eliminating the ability of school districts to levy an 
          incremental ad valorem tax on real property and forcing the 
          state to replace the lost revenues in district revenue limits.  
          School districts still have limited authority to generate local 
          revenues from qualified special taxes, but most school funding 
          is either received from the state or federal governments, or 
          controlled by the state through revenue limits required to 
          equalize per-pupil funding. 

           What is a "qualified special tax"  ?  Under existing law, a school 
          district may impose a qualified special tax within that 
          district; however, the special tax must apply uniformly to all 
          taxpayers (other than persons over the age of 65) or real 
          property within the district and must be approved by a 
          two-thirds vote of the qualified electors of the district.  
          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].  School districts and special districts are 
          prohibited from imposing general taxes (Proposition 218) and 
          thus, by definition, any tax levied by a school district or 
          community school district is considered to be a special tax 
          subject to a two-thirds voter approval.  Furthermore, school 
          districts are not allowed to impose a special tax that is 
          imposed on a particular class of property or taxpayers.  
          Therefore, thus far, school districts have only imposed 
          "qualified special taxes," under Government Code Section 50079, 
          in the form of a parcel tax.  

           Parcel tax  .  A parcel tax 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 








                                                                  AB 504
                                                                  Page  4

          same dollar amount of tax is 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 as compared to 
          owners of larger parcels of land.  Some districts levy a rate at 
          a fixed amount per square foot of taxable land, and many include 
          an annual inflation adjustment.  
             
           Parcel taxes are flexible ways of raising revenues at the local 
          level, but are subject to certain requirements.  Parcel tax 
          elections must be held on "established election dates", which 
          means in March, April, or November of an even-numbered year, or 
          March, June, or November in an odd-numbered year.  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.  Interestingly, school districts in some areas 
          of the state seek to levy parcel taxes more so than other areas. 
           According to EdSource, only seven districts in southern 
          California imposed the tax, but 66 did in the San Francisco Bay 
          Area.  Districts imposing the tax generally serve fewer 
          low-income students than the typical California school district, 
          and are disproportionately smaller, with 66 (80%) of them 
          serving fewer than 10,000 students.   Existing law does not 
          limit how the special tax proceeds may be spent, and therefore, 
          a local school board can specify in the ballot measure how the 
          funds will be used.  Generally, local parcel taxes provide 
          secure funding for teacher salaries, books, materials and 
          supplies, computers, and art, music and sports programs.

          In 2006, the California voters rejected Proposition 88 that 
          would have amended the California Constitution to levy an annual 
          $50 real property tax on most parcels with the funds allocated 
          to specified K-12 education programs.   

           The need for special legislation:  The SB School Districts' 
          dilemma  .  SB School Districts are comprised of non-coterminous 
          elementary and high school districts.  The high school district 
          includes the territory of four separate "feeder" elementary 
          districts, in addition to the SB Elementary School district.  
          According to the author, the SB School Districts have made more 
          than $20 million in budget cuts over the last three years, and, 
          recently, have decided to unify their elementary and secondary 
          districts in order to save $6 million annually.  In fact, since 
          2004, those school districts have already acted as unified and 








                                                                  AB 504
                                                                  Page  5

          have been governed by a single board of education and 
          administration, even though they have maintained separate 
          revenue sources from two distinct parcel tax measures, Measure I 
          and Measure H, respectively.  Both measures were passed by the 
          voters in 2008, with over 70% approval, resulting in an annual 
          revenue gain for the districts of approximately $1.7 million.  
          The amount of parcel tax imposed by the SB High School District 
          is $23 per year (Measure H) and the amount of tax imposed by the 
          SB elementary school district is $27 per year (Measure I).  Both 
          measures provide for a senior exemption, whereby, an exemption 
          from the parcel tax is granted to any parcel owned by a senior 
          citizen 65 years of age or older, provided that the parcel is 
          used solely for owner-occupied, single-family residential 
          purposes.  The revenues generated from the imposition of the 
          parcel taxes have allowed the districts to maintain a reduced 
          junior high school math class size and elementary art and music 
          classes. 

          While existing law allows non-coterminous school districts to 
          merge, it does not expressly authorize the newly-created 
          district to either continue the collection of the already 
          approved parcel taxes, or utilize the revenues generated by 
          those special taxes.  In contrast, in the case of bonded 
          indebtedness, Education Code Section 35578 specifically provides 
          that a new district may sell unsold bonds and use the funds, but 
          only for the purposes for which the bonds were authorized 
          initially.  Furthermore, Education Code Section 35561 states 
          that the funds derived from bonds issued by the former district 
          may only be used in that district's territory, unless the new 
          district assumes the bonded indebtedness, in which case the 
          money can be used for any purpose for which the bonds were 
          originally issued.  

          If the SB school districts were to unify, it is doubtful that 
          the newly created district will be able to continue collecting 
          the parcel taxes originally approved by the voters in two 
          separate school districts.  There is no express statutory 
          authorization for a new unified district to continue the 
          imposition and collection of the voter approved parcel taxes 
          once the former districts are merged out of existence.  As 
          pointed out by the proponents of this bill, while the 
          unification of the SB school districts would generate 
          approximately $6 million in savings, it will essentially 
          terminate another source of revenue for the schools - the parcel 
          taxes originally approved by the voters in the former school 








                                                                  AB 504
                                                                  Page  6

          districts.  

           The proposed solution .  According to the author, the purpose of 
          this bill is to allow the two existing parcel tax measures, 
          which have been separately approved for each school district, to 
          continue after unification.  The high school parcel tax is 
          restricted to being used for junior and senior high school 
          purposes only, while the elementary school parcel tax is 
          restricted only to elementary school uses.  AB 504 would 
          authorize a newly unified SB school district to continue the 
          collection of the parcel taxes to ensure that the unification 
          does not result in a loss of the revenue stream used to support 
          various school programs.  This bill would permit the 
          continuation of parcel taxes following unification only if the 
          revenues derived from those taxes are segregated on a 
          geographical basis conforming to the boundaries of the former 
          school districts.  Thus, AB 504 is intended to ensure that the 
          revenues generated by the parcel taxes are allocated and used in 
          the way that the voters intended.  In this way, the residents of 
          the high school district who reside in separate elementary 
          "feeder" districts do not have to pay for SB elementary schools. 
           Following unification, there will be different amounts of taxes 
          paid depending on area of residence.  A lesser amount will be 
          paid by those who live in areas served by grades 7-12 only.  It 
          is a continuation of status quo in all respects except one - 
          there will be one district instead of two.  Absent this special 
          legislation, the continuation of the voter-approved parcel taxes 
          will be uncertain and subject to litigation.  Furthermore, AB 
          504 would authorize a newly created unified school district to 
          impose new "qualified special" taxes within the boundaries of 
          the former elementary school district.   
           
           
           Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916) 
          319-2098 



                                                                FN: 0001581