BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



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                                    THIRD READING


          Bill No:  SB 1203
          Author:   Jackson (D), et al.
          Amended:  5/22/14
          Vote:     21

           
           SENATE GOVERNANCE & FINANCE COMMITTEE  :  5-0, 4/24/14
          AYES:  Wolk, Beall, DeSaulnier, Hernandez, Liu
          NO VOTE RECORDED:  Knight, Walters


            SUBJECT  :    Property taxation:  welfare exemption:  rental  
                      housing and related facilities:   
                      payment-in-lieu-of-taxes agreement

           SOURCE  :     Author


          DIGEST  :    This bill prohibits local agencies from imposing a  
          charge or fee on a low-income housing project which is eligible  
          for the property tax welfare exemption unless the charge or fee  
          meets specified conditions.
           
           Senate Floor Amendments  of 5/22/14 modify the conditions that  
          apply to local agencies' fees and charges on some rental housing  
          development projects.

           ANALYSIS  :    The California Constitution provides that all  
          property is taxable unless explicitly exempted by the  
          Constitution or federal law, but also allows the Legislature to  
          exempt property used for charitable purposes owned by nonprofit  
          entities organized and operated for charitable purposes, such as  
          universities, hospitals, and libraries.  The Legislature enacted  
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          this exemption, commonly known as the "welfare exemption."   
          According to the Legislative Analyst's Office, local agencies  
          statewide forego $3 billion annually in revenues from welfare  
          exempt properties.  

          Local agencies can impose dedications or fees under their  
          general police power; however, two U.S. Supreme Court cases  
          require local agencies to meet "nexus" (Nollan v. Coastal  
          Commission, 1987) and "rough proportionality" tests (Dolan v.  
          City of Tigard, 1994).  The "nexus" test requires a government  
          to establish the link between the exaction and the interest  
          being advanced by that exaction, while "rough proportionality"  
          requires a connection between proposed exactions and the  
          projected impacts that the exactions are intended to allay.   
          State law allows local agencies to impose fees in accordance  
          with the two cases under the MFA, Subdivision Map Act, and  
          Quimby Act, among others.

          Some local agencies impose "payment in lieu of tax" agreements,  
          or PILOTs, to compensate them for the services it provides the  
          property, but is not paid for in taxes due to the exemption.   
          Local agencies generally calculate PILOTs to equal the share of  
          countywide property tax revenues that agency would have received  
          from the property.  

          This bill, not withstanding any other law, as of January 1,  
          2015, bars local agencies from imposing a charge or fee on a  
          low-income housing described under the exemption from property  
          tax unless the charge or fee meets one of the following  
          conditions:

          1.The fee or charge meets both of the following criteria:

             A.   The charge or fee is imposed pursuant to the MFA.

             B.   The charge or fee imposed on specified housing  
               development projects under the MFA must not prohibit or  
               discriminate against the housing development project  
               because of any of the following:  

               (1)    The method of financing the development;

               (2)    The development is intended for occupancy by persons  
                 and families of very low, low, or moderate income, as  

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                 defined in state law, or persons and families of middle  
                 income; or 

               (3)    The development is subsidized, financed, insured, or  
                 otherwise assisted by the federal or state government or  
                 by a local public entity.   

          1.The charge or fee is for a specific service or product  
            provided directly to the housing development project, the  
            service or product is not provided to those not charged, and  
            the charge or fee does not exceed the actual cost of providing  
            the service.

          This bill adopts legislative findings applying its provisions to  
          charter cities.

          This bill deletes the requirement that the property owner must  
          certify that the funds that would have been used to pay property  
          taxes are used to maintain the affordability of the units or  
          reduce rents to be eligible for the exemption.  This bill also  
          bars assessors from levying future escape or supplemental  
          assessments resulting from the requirement, and cancels any  
          outstanding tax, interest, or penalty levied between January 1,  
          2012 and January 1, 2015 resulting from the requirement.   
          However, this bill does not provide for any refunds of taxes.

          This bill adds a definition of "related facilities" into the  
          welfare exemption.  This bill makes legislative findings and  
          declarations supporting its purposes, including "no inference"  
          language to ensure that any authority adjudicating a challenge  
          to the legality of current PILOTs does not consider this bill to  
          ensure these disputes are determined using the law in place at  
          the time the local agency imposed the PILOT.  This bill also  
          makes conforming changes.

           Background
           
          In June, 2012, Ventura County Assessor Dan Goodwin revoked the  
          welfare exemption, and issued escape assessments for penalty,  
          interest, and taxes for four previous years, for affordable  
          housing projects with PILOT agreements with cities.  Goodwin  
          argues that because the property owner pays PILOT fees, he/she  
          cannot demonstrate that the property tax savings maintains the  
          affordability of the project or reduces rents, a necessary  

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          condition for the exemption.  Given that the project owners and  
          developers do not have sufficient cash to pay the assessments,  
          they want the Legislature to erase the taxes, and provide  
          guidance regarding which fees municipalities can charge  
          low-income housing developments.

           Comments
           
          According to the author, "As a condition of project approval,  
          some local governments have required affordable housing  
          developers to agree to annual PILOT payments, often equal to the  
          share of the jurisdiction's share of the property tax.  Most  
          recently, some county assessors are threatening certain  
          affordable housing projects that make PILOT payments with the  
          cancellation of their welfare exemption and the imposition of  
          back taxes for past years when PILOT payments were made.  Back  
          taxes on PILOT agreements are often in the hundreds of thousands  
          of dollars.  These assessments threaten to bankrupt the  
          affordable housing developments, which would result in the loss  
          of precious affordable housing.  Affordable housing developments  
          provide critical opportunities for our low-income residents.  
          Often, these units can be their last resort before becoming  
          homeless.  As confirmed by Legislative Counsel in 2012, there is  
          no legal authority to charge these PILOT fees.  Affordable  
          housing developments should be protected by the welfare  
          exemption, not burdened by local governments requiring PILOT  
          fees."

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No   Local:  
           No

           SUPPORT  :   (Verified  5/23/14)

          Board of Equalization, 4th District
          BRIDGE Housing Corporation
          Cabrillo Economic Development Corporation
          California Housing Consortium
          California Infill Builders Federation
          LeadingAge California
          The Arc of Ventura County
          Ventura County Assessor
          Western Center on Law and Poverty

           OPPOSITION  :    (Verified  5/23/14)

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          City of San Marcos


          AB:k  5/23/14   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

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