BILL ANALYSIS                                                                                                                                                                                                    �




                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  AB 2194                     HEARING:  6/11/14
          AUTHOR:  Mullin                       FISCAL:  No
          VERSION:  2/20/14                     TAX LEVY:  No
          CONSULTANT:  Urquiza                  

                 MELLO-ROOS FINANCING FOR STORMWATER MANAGMENT
          

          Expands the services that may be financed with Mello-Roos  
          special taxes to include storm water management.


                           Background and Existing Law
           
          The Mello-Roos Community Facilities Act allows counties,  
          cities, special districts, and school districts to levy  
          special taxes (parcel taxes) to finance a wide variety of  
          public works, including parks, recreation centers, schools,  
          libraries, child care facilities, and utility  
          infrastructure.  A Mello-Roos Community Facilities District  
          (CFD) issues bonds against these special taxes to finance  
          the public works projects.  Like all special taxes,  
          Mello-Roos Act special taxes require 2/3-voter approval.   
          If there are fewer than 12 registered voters, the affected  
          landowners vote.

          In addition to financing public or governmental capital  
          facilities, Mello-Roos act special taxes can fund a limited  
          list of public services: police services, fire protection,  
          recreation programs, library services, museum operations,  
          park maintenance, flood and storm protection, hazardous  
          waste cleanup, street and road maintenance, lighting of  
          parks, parkways, streets, roads, and open space, plowing  
          and removal of snow, and graffiti management and removal.

          The Mello-Roos Act is an important feature of the local  
          fiscal landscape, providing local officials with a key tool  
          for accumulating the public capital needed to pay for the  
          public works projects that make new residential development  
          possible.  Mello-Roos is an attractive financial tool  
          because it provides more flexibility that can be used to  
          finance facilities that are not located in the district.  
          Additionally, there is no requirement that the special tax  
          is apportioned on the basis of benefit to the property.




          AB 2194 -- 2/20/14 -- Page 2



           
           The federal Clean Water Act requires states to reduce  
          pollution from urban storm water runoff.  In California,  
          the State Water Resources Control Board (SWRCB) and the  
          Regional Water Quality Control Boards (RWQCBs) are pushing  
          counties, cities, and special districts to reduce urban  
          runoff and storm water discharges.  RWQCBs issue National  
          Pollutant Discharge Elimination System General Permits  
          (NPDES) for medium and large municipalities that require  
          public education and outreach, illicit discharge detection  
          and elimination, construction and post-construction, and  
          good housekeeping for municipal operations.  Compliance  
          with permits sometimes requires comprehensive solutions to  
          urban runoff including low impact development, catchments,  
          water treatment, and other costly activities.  In 2013,  
          SWRCB also adopted permits for smaller municipalities,  
          including military bases, public campuses, prisons and  
          hospital complexes.  Local governments continue to struggle  
          to comply with permit requirements and want to be able to  
          use Mello-Roos taxes to help finance storm water  
          management. 

           
                                    Proposed Law  

          Assembly Bill 2194 adds to the list of services that a  
          Mello-Roos Community Facilities Districts can finance,  
          storm water management services, including, but not limited  
          to, compliance with state and federal storm water permit  
          requirements. 


                               State Revenue Impact
           
          No estimate. 


                                     Comments  

          1.   Purpose of the bill  .  Numerous local governments  
          throughout California are facing increasingly high costs  
          associated with compliance with federal and state storm  
          water permit requirements.  To comply with storm water  
          permits, cities need to fund projects that may cost  
          millions and even billions of dollars over the next ten  
          years.  AB 2194 establishes an additional funding mechanism  





          AB 2194 -- 2/20/14 -- Page 3



          to help local governments comply with storm water permit  
          requirements.  

          2.   Growing disparities  .  Current law authorizes counties  
          and cities to impose special taxes, benefit assessments,  
          and property-related fees in order to fund water pollution  
          prevention and storm water services.  By adding storm water  
          management to the list of services that may be financed  
          through Mello-Roos special taxes, AB 2194 allows  
          communities to finance those services through a single  
          mechanism.  The Committee may wish to consider whether  
          expanding the list of services financed by Mello-Roos  
          special taxes may widen disparities between services  
          supported by tax revenues from property owners within CFDs  
          and those not in CFDs. 

          3.   Services but not Facilities  ?  AB 2194 authorizes  
          Mello-Roos financing for storm water management services,  
          but does not explicitly add facilities for the purposes of  
          storm water management to the list of facilities and  
          services that CFDs can finance.  As a result, cities would  
          be able to finance services related to storm water permit  
          requirements, such as public education and outreach, but  
          not tangible infrastructure related to storm water  
          management, such as permeable concrete.  The committee may  
          wish to consider amending the bill to ensure facilities for  
          the purposes of storm water management may be financed by  
          Mello-Roos.

          4.   Public and private facilities  .  The Mello Roos Act  
          authorizes a CFD to finance a wide range of public  
          facilities, as well as the construction, expansion,  
          improvement, or rehabilitation of a limited type of  
          privately owned facilities.  If the bill is amended to add  
          facilities for stormwater management, and given that the  
          goal of AB 2194 is to help cities comply with municipal  
          storm water permits, the committee may wish consider  
          restricting the acquisition, improvement, rehabilitation,  
          or maintenance of any real or other tangible property to  
          only publicly-owned property. 

          5.   Let's be clear  .  State and federal law requires many  
          storm water permits in addition to municipal ones,  
          including those for stormwater discharge associated with  
          industrial activity and permits and construction projects.  
          To reflect the author's intent, the committee may wish to  





          AB 2194 -- 2/20/14 -- Page 4



          consider amending the bill to specify that Mello-Roos  
          special taxes may be used only for local agency's  
          compliance with state and federal stormwater permits. 

          6.   Related Legislation  .  Several bills address the issue  
          of financing storm water management this legislative  
          session: 
                 AB 2403 (Rendon, 2014) expands the definition of  
               "water" in the Proposition 218 Implementation Act to  
               add storm water. 
                 AB 418 (Mullin, 2014) authorizes the City/County  
               Association of Government of San Mateo County to  
               impose a special tax or property-related fee to fund  
               stormwater management programs. 
           
           
                                 Assembly Actions  

          Assembly Local Government:        9-0
          Assembly Floor:                  75-1



                         Support and Opposition  (6/5/14)

           Support  : California Building Industry Association;  
          California Special Districts Association; City/County  
          Association of Governments of San Mateo County.

           Opposition  : Unknown.