BILL ANALYSIS                                                                                                                                                                                                    Ó






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: ab 1411
          SENATOR MARK DESAULNIER, CHAIRMAN              AUTHOR:  V.M. PÉrez
                                                         VERSION: 6/28/11
          Analysis by:  Mark Stivers                     FISCAL:  Yes
          Hearing date:  July 5, 2011



          SUBJECT:

          Enterprise zones

          DESCRIPTION:

          This bill makes various changes to the zone selection and 
          administrative provisions of the enterprise zone program.

          ANALYSIS:

          Under existing law, the Department of Housing and Community 
          Development (HCD) can designate up to 42 enterprise zones.  Each 
          designation lasts for 15 years.  Within an enterprise zone, 
          cities and counties can relax regulatory controls such as 
          permits and development fees, provide tax incentives, expand 
          infrastructure, and target federal grants for education, health 
          and welfare, economic development, vocational education, 
          transportation, and housing.  The state provides a number of tax 
          credits and deductions for businesses in the zone, including 
          credits for sales and use tax paid on manufacturing equipment 
          purchased, hiring credits for qualified employees, 100% net 
          operating loss carryover for losses associated with operations 
          within the enterprise zone, deduction of interest earned by 
          lenders who loan money to enterprise zone businesses, and 
          election to expense rather than amortize equipment used within 
          the enterprise zone.  In order to claim a hiring credit, a 
          business must obtain a voucher from the enterprise zone.

          To be eligible for designation, a proposed enterprise zone area 
          must meet either of the following:

          1. Fulfill at least one of the following criteria:

                 Meet the criteria for the now-defunct Urban Development 
               Action Grant (UDAG) program of the United States Department 
               of Housing and Urban Development.
                 Meet criteria of economic distress related to those used 




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               in determining eligibility under the UDAG program.
                 Have experienced plant closures within the past two 
               years affecting more than 100 workers.
                 Have a history of gang-related activity, whether or not 
               crimes of violence have been committed.

          1.Fulfill at least two of the following criteria:

                 Have an unemployment rate not less than 3 percentage 
               points above the statewide average.
                 Be in a county where more than 70 percent of the 
               children participate in the federal free lunch program.
                 Be a low-income area.

          HCD selects enterprise zones through a competitive process based 
          on the appropriateness of the applicant's proposed economic 
          development strategy and implementation plan.  HCD awards bonus 
          points to proposed zones that meet at least two of the following 
          criteria:

                 Have at least 17.5 percent of households below the 
               poverty level.
                 Have an average unemployment rate that is not less than 
               five percentage points above the statewide average.
                 Have a unique distress factor affecting long-term 
               economic development, such as resource depletion, plant 
               closure, industry recession, natural disaster, or military 
               base closure.

          After receiving a designation, an enterprise zone biennially 
          must report to HCD on the zone's progress relative to its goals, 
          objectives, and commitments set forth in its memorandum of 
          understanding with HCD.  In addition, HCD may audit a zone at 
          any time and must audit each zone at least once every five 
          years.  If a zone receives a failing grade, it must enter into a 
          written agreement to remedy the deficiencies.  Ultimately, if a 
          zone fails to remedy the deficiencies, HCD must de-designate the 
          zone.

          HCD is required to report to the Legislature every five years 
          evaluating the effect of the program on employment, investment, 
          incomes, and state and local tax revenues in enterprise zones.  
          The report must also review the progress and effectiveness of 
          each zone.  

           This bill  makes various changes to the zone selection and 




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          administrative provisions of the enterprise zone program.  
          Specifically, the bill:

          Zone designation

           Alters the eligibility criteria for a proposed zone such that 
            a proposed zone must be located solely in low-income census 
            tracts and meet one of the following criteria:

                 Have an unemployment rate not less than 3 percentage 
               points above the statewide average.
                 Be served by schools in which at least 70 percent of the 
               students participate in the federal free lunch program.
                 Have experienced significant distress factors that HCD 
               may define but must include significant gang activity, high 
               crime rates, and a significant number of plant or business 
               closures.

           Deletes the provision prohibiting zone applicants from drawing 
            boundaries to include larger stable businesses to the 
            detriment of areas that are truly economically depressed.
           Allows an applicant's economic development strategy and 
            implementation plan to identify local resources that the 
            jurisdiction will utilize to implement its strategy and plan 
            and explain how these resources will leverage enterprise zone 
            benefits.
           Adds redevelopment tax increment, federal Workforce Investment 
            Act, federal Community Development Block Grant, CalWORKS, and 
            local educational funds to the list of local resources that 
            applicants may commit to the program. 
           Deletes from the list of scoring bonus criteria unique 
            distress factors affecting long-term development.

          Agency responsibilities

           Requires enterprise zones to include in their biennial report 
            to HCD the financial value of local incentives and other 
            resources benefiting zone and various voucher-related data.
           Requires enterprise zones to provide information HCD needs to 
            prepare its report to the Legislature.
           Requires HCD to submit a report to the Legislature on the 
            enterprise zone program every six years, as opposed to every 
            five years, and requires the report to include an evaluation 
            of the program's effects on retaining and increasing 
            employment among specified target populations. 
           Requires HCD to serve as a liaison between the state and 




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            enterprise zone residents, businesses, workers, non-profit 
            organizations, and local governments.  
           Requires state agencies, consistent with their statutory 
            duties, to respond to requests made by and on behalf of an 
            enterprise zone.
           Requires state agencies to consider harmonizing their programs 
            with the enterprise zone program to maximize the benefits to 
            workers and businesses.
           Requires the Employment Development Department to provide 
            letters certifying an unemployed jobseeker's eligibility for a 
            hiring tax credit due to eligibility under the Workforce 
            Investment Act.
           Requires local educational entities that administer student 
            work permits to consider how hiring credits could be used to 
            benefit lower-income students who apply for work permits.

          Hiring tax credit vouchers

           Requires that hiring credit vouchers be approved or denied 
            based upon the regulations and administrative memoranda in 
            effect on the date of application.
           Provides that administrative memoranda are binding on all 
            parties unless modified or repealed in writing.
           Requires HCD to maintain on its website a catalog of 
            administrative memoranda in effect and update the website 
            within 10 business days of the publication, modification, or 
            repeal of a memorandum.
           Requires HCD to post enterprise zone and targeted employment 
            area boundaries and changes thereto on its website within 10 
            business days.

          Zone audits

           Requires HCD to consider progress report findings as a basis 
            for conducting an audit.
           Requires HCD to audit zones that fail to submit a biennial 
            report.
           Deems as superior an enterprise zone that, according to an HCD 
            audit, meets 90 percent of its goals, objectives, or 
            commitments, as opposed to 100 percent.
           Requires HCD to provide technical assistance and training to 
            address inadequacies identified in an audit.
          COMMENTS:

           1.Purpose of the bill  .  According to the author, one of the most 
            important things state government can do during difficult 




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            economic times is to help keep people employed.  When 
            Californians have jobs, local and state governments have the 
            necessary resources to fund local priorities such as 
            education, public safety, and community services.  At the same 
            time, it is essential that scarce state resources are put to 
            good use for economic recovery.  The enterprise zone program 
            is an economic development program that encourages businesses, 
            through tax and other incentives, to locate and create jobs in 
            targeted, economically distressed communities.  Beginning in 
            2009, the Assembly Jobs, Economic Development, and the Economy 
            Committee initiated a series of oversight hearings on the 
            enterprise zone program to ensure that it has been meeting its 
            economic development goals.  The reforms in this bill are 
            based on this examination, which spanned two years of 
            oversight hearings, working group meetings, stakeholder 
            engagement, and a comparative review of other states' 
            programs.  While more comprehensive reforms have been proposed 
            this session in AB 231 (V.M. Pérez), this bill advances only 
            those recommendations that relate to increased accountability 
            and program transparency.

           2.Voucher rules  .  In order to claim a hiring credit, a business 
            must obtain a voucher from the enterprise zone administrator.  
            An employer may appeal a zone administrator decision to HCD. 
            This bill requires that hiring credit vouchers be approved or 
            denied based upon the regulations and administrative memoranda 
            in effect on the date of application.  While this seems to 
            make sense on its face, the language may be overly broad and 
            include actions taken by the Franchise Tax Board (FTB).  
            Recent Board of Equalization (BOE) and court cases have 
            challenged the ability of the Franchise Tax Board (FTB) to 
            determine the appropriateness of a voucher issued by a zone 
            administrator.  The BOE affirmed FTB's role in The Appeal of 
            Deluxe (Dec. 12, 2006, No. 297128) 2006 Cal. Tax Lexis 432, 
            but the Second Court of Appeal subsequently weakened FTB's 
            authority in Dicon Fiberoptics v. Franchise Tax Board (Case 
            B202997, 2009) by stating that while FTB is legally authorized 
            to audit hiring credits, the voucher constitutes prima facie 
            evidence that the taxpayer is entitled to the credit.  So if 
            FTB looks behind a voucher, discovers some practice it deems 
            illegal, and writes a memorandum clarifying its illegality, 
            would the bill prohibit FTB from rejecting vouchers issued 
            prior to the memorandum?  The committee may wish to consider 
            deleting this provision from the bill until its ramifications 
            are more clearly understood.





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           3.Increasing zone sizes  .  Over the last decade, the average size 
            of an enterprise zone has increased almost 500%.  Most of this 
            increase is driven by the expansion or combination of zones 
            when they apply for re-designation at the end of their 
            original 15 year lifespan.  Of the 28 enterprise zones that 
            HCD has re-designated, 12 grew in area by more than 15 
            percent.  The San Joaquin County zone grew 19 times in size.  
            Los Angeles, Sacramento, and San Diego aggregated 
            previously-designated zones.  Los Angeles went from five to 
            two zones, Sacramento from three to one zone, and San Diego 
            from two to one zone.  Expanding and aggregating zones is akin 
            to increasing the cap on the number of zones without 
            legislative authorization.  The committee may wish to consider 
            capping the amount that a zone may increase upon 
            re-designation.  
          



           4.Technical amendments  .

                 On page 5, lines 11-13 strike "Sections 7073 and 7073.3 
               that include an eligible area and a qualifying commercial 
               or industrial area, or both, as defined by the department" 
               and insert "Section 7073"
                 On page 5, line 18 after "zone" insert ", a 
               Manufacturing Enhancement Area, a targeted tax area,"
                 On page 7, line 5 strike "Except as provided in (e), 
               any" and insert "Any"
                 On page 11, line 37 after "zone" insert "or 
               manufacturing enhancement area"
                 On page 17, lines 23-26 strike "The Franchise Tax Board 
               shall make available to the department and the Legislature 
               aggregate information on the dollar value of enterprise 
               zone tax credits that are claimed each year by businesses 
               pursuant to Section 7085.5."
          
          Assembly votes are not relevant

          POSITIONS:  (Communicated to the Committee before noon on 
          Wednesday,                                             June 29, 
          2011)

               SUPPORT:  None received.

          




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               OPPOSED:  None received.