HomeMy WebLinkAbout2008/03/18 Item 4
CITY COUNCIL
AGENDA STATEMENT
~!~ CITYOF
.~ CHULA VISTA
MARCH 18,2008, ItemL
SUBMITTED BY:
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA OPPOSING STATE PROPOSITION 98
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA SUPPORTING STATE PROPOSITION 99
ERIC CROCKETT, ASSISTANT DIRECTOR
REDEVELOPMENT AND HOUSING~
KEN LEE, PRINCIPAL PROJECT COORDINATOR~ .c=..D,.J)
LORI ANNE PEOPLES, SENIO DEPUTY CITY CLE~(}J\
CITY MANAGER
4/5THS VOTE: YES D NO ~
ITEM TITLE:
REVIEWED BY:
SUMMARY
At the June 2008 ballot, voters will have the choice between two initiatives on the
controversial topic of eminent domain. The Howard Jarvis Taxpayers Association, the
California Farm Bureau Federation, and the California Alliance to Protect Private Property
Rights gathered signatures to place Proposition 98 on the ballot, which would not only make
major changes to the law of eminent domain, but also take on much broader private property
rights issues, including rent control, open space conservation, and local land use regulation.
Proposition 98 closely resembles Proposition 90, which failed in 2006. To provide voters a
simpler and much more straight-forward alternative for homeowner protection, the League
of California Cities this year led the formation of Eminent Domain Reform Now, a coalition
working to support responsible eminent domain reform. The coalition successfully qualified
Proposition 99 for the June 2008 ballot. Proposition 99, entitled the Homeowners Protection
Act, would very simply prohibit governments from taking an owner-occupied home to
transfer it to a private party. This is consistent with this City's historical policies on the use
of eminent domain by the Redevelopment Agency on properties that are both residentially
zoned and used for residential purposes. Adoption of the first resolution opposes
Proposition 98 and the second supports Proposition 99.
ENVIRONMENTAL REVIEW
The Environmental Review Coordinator has reviewed the proposed activity for
compliance with the California Environmental Quality Act (CEQA) and has determined
that the activity is not a "Project" as defmed under Section 15378 of the State CEQA
Guidelines; therefore, pursuant to Section 15060(c)(3) of the State CEQA Guidelines the
activity is not subject to CEQA. Thus, no environmental review is necessary.
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RECOMMENDATION
Council adopt the resolutions.
BOARDS/COMMISSION RECOMMENDATION
Not applicable.
DISCUSSION
The League of California Cities has asked cities to support their efforts to oppose
Proposition 98 and support Proposition 99. The following discussion provides a
summary of each proposition.
Proposition 98: California Property Owners and Farmland Protection Act
In addition to Proposition 98's proposed changes- to eminent domain law, opponents
believe that there is a major hidden agenda in the measure's other provisions affecting
rent control, open space conservation, and land use regulation. The initiative's major
provisions are summarized below.
1. Property mav not be taken and then transferred to a private partv. For over 50
years, State and Federal Courts have held that the use of eminent domain by
redevelopment agencies to eliminate conditions of blight is a public use. The
initiative would end the use of eminent domain by redevelopment agencies
except for public works projects, and would prevent the use by other public
agencies in public/private partnerships for facilities.
2. New definition of Just Compensation. Existing law requires the payment of
just compensation to the owner of property taken by eminent domain and is
defined as "fair market value." A body of well-established law interprets the
meaning and allows both public agencies and property owners to be
reasonably certain about the value of property to be acquired. The initiative
would add a constitutional definition of "just compensation" that would
prevail over the settled body of law, possibly resulting in the need to have
more frequent recourse to the courts to settle disputes over the meaning of
"just compensation." Other changes that the initiative would make are:
a. Just compensation would include an award of the property owner's
attorney's fees if the jury awards one dollar more than the amount
offered by the public agency. It is unclear which offer to purchase this
provision refers to.
b. Just compensation would include elements not currently recognized such
as temporary business losses. Relocation and other business re-
establishment costs would also be elevated to constitutional status,
thereby perhaps abrogating existing statutes which place limits on the
type and amount
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MARCH 18, 2008, Item~
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3. Acquiring "immediate possession" of property made more complicated.
Under existing law, after depositing with the court the estimated just
compensation, a public agency can obtain possession of the property prior to a
fmal judgment based on a showing of an overriding need for the condenmor to
take possession prior to final judgment. If the property owner withdraws the
deposit, he or she waives their right to contest whether the taking is for public
use, but may still contest the amount. The initiative changes the balanced
approach to prejudgment possession by permitting the property owner to
contest both public use and just compensation after withdrawing the deposit.
Public agencies would still be at risk of being prohibited from taking the
property rather than simply paying more for it.
4. Balance of power between Legislature and Courts shifted. Current law provides
that findings made by a public agency in connection with the taking of property
by eminent domain are entitled to strong presumptions of validity, and courts
will overturn those findings only where the property owner is able to
demonstrate a gross abuse of discretion such as bribery or fraud. The initiative
would change this balance, providing that a court must exercise its independent
judgment and give no deference to the finding of a public agency. The court's
inquiry would also not be limited to the administrative record, so the property
owner could introduce evidence of value and other matters not before the
condemning agency at the time the decision to condenm was made.
5. Governmental Regulations Affecting Price. The initiative would also define a
regulation of property that limits the price a private owner could charge another
person to purchase, occupy or use his or her real property as a prohibited taking
for a private use. This would prohibit rent control ordinances (units as of
January 1, 2007 would be grandfathered as long as at least one of the tenants
continued to live in the unit) and make unconstitutional inclusionary housing
ordinances adopted in many California cornmunities, which require new housing
development to include affordable units for low and moderate income buyers or
renters. The effect on the inclusionary housing provisions of the Community
Redevelopment Law is difficult to predict. Redevelopment agencies might still
be able to bargain for the provision of affordable units as a condition of agency
assistance, but they would not be able to impose such requirements as a matter
oflaw.
6. Limitation on Use of Eminent Domain for Consumption of Natural Resources.
The initiative would prohibit the use of eminent domain to "transfer the
ownership, occupancy or use of private property... to a public agency for the
consumption of natural resources..." This provision can be read to prohibit the
use of eminent domain by a city to acquire new drinking water resources, and
would also prohibit the use of eminent domain if the public agency would use
the property for "the same or substantially similar use as that made by the private
owner." It would likely eliminate eminent domain as a tool to acquire
conservation and open space easements.
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7. Regulation of Land Use. The initiative requires a public agency to pay "just
compensation" when it regulates the use of land, if the regulation transfers an
economic benefit from the person who owns the land to another person.
Existing law allows public agencies to use their police power to enact
regulations governing the use of privately owned real property. These
regulations range from traditional zoning to nuisance regulations and include
conditions imposed on the new development of property, and most have an
economic impact. Some properties will be benefited while others will be
burdened, and read literally, this provision would make unconstitutional virtually
all regulation of land use unless just compensation is paid.
Proposition 99: Homeowners Protection Act
The Eminent Domain Reform Now coalition consists of a broad mix of stakeholders,
including seniors, homeowners, business, labor, environmentalists, affordable housing
advocates, public safety leaders, and local governments. The coalition's intent behind
Proposition 99 is to address homeowners' common fears about eminent domain, mainly
its use on single-family homes. To address those fears and promote the responsible and
appropriate use of eminent domain for "public use," including health and safety,
Proposition 99 would prohibit governments from using eminent domain to take a single-
family, owner-occupied home (including a condominium) for the purpose of transferring
it to another private party (e.g., person, business, association). This policy stance is
closely aligned with Chula Vista's local policies, including those contained in its
redevelopment plans. The redevelopment plan for the Merged Chula Vista Project Area
specifically provides that the Redevelopment Agency is prohibited from using eminent
domain on any property that is both residentially zoned and used for residential purposes.
DECISION MAKER CONFLICT
Staff has reviewed the decisions contemplated by this action and has determined that it is
not site specific and consequently the 500 foot rule found in California Code of
Regulations section I 8704.2(a)(I) is not applicable to this decision.
FISCAL IMPACT
No fiscal impact as a result of taking formal action to oppose Proposition 98 or support
Proposition 99.
ATTACHMENTS
A. Summary of California Property Owners and Farmland Protection Act (Prop 98)
B. Summary of Homeowners Protection Act (Prop 99)
Prepared by: Lori Anne Peoples. Senior Deputy City Clerk, City Manager's Office
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ATTACHMENT A
Proposition 98
Government Acquisition, Regulation of Private Property.
Constitutional Amendment.
BACKGROUND
Government Actions to Take Property-"Eminent Domain"
Every year, California state and local governments buy hundreds of millions of
dollars of property from private owners. Government uses most of this property for
purposes such as roads, schools, and public utilities. In other cases, government buys
property for different purposes, such as to transfer it to (1) private owners to develop
new businesses or (2) nonprofit organizations to provide affordable housing.
Most of the time, government buys property from willing sellers. Sometimes,
however, property owners do not want to sell their property or do not agree on a sales
price. In these cases, California law allows government to take property from a private
owner provided that government:
. Uses the property for a "public use" (a term that has been broadly interpreted
to mean a variety of public purposes).
. Pays the property owner "just compensation" (generally, the property's fair
market value) and relocation costs (including some business losses).
This government power to take property for a public use is called "eminent domain."
(The nearby box provides additional information about its use.)
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Eminent Domain Challenges. Property owners are not required to accept the amount
of compensation government offers. Instead, they may make a counteroffer or challenge
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the amount in court. Under the State Constitution, property owners are entitled to have
the amount of compensation determined by a jury. While property owners also may
challenge government's right to take a property, these challenges are more difficult. In
part, this is because courts give significant weight to government's findings and
perspectives when ruling on disputes as to whether an eminent domain action is for
public use.
Programs to Promote Affordable Housing
Rent Control. Over a dozen California cities have some form of rent control law.
These cities include Los Angeles, San Francisco, Oakland, Berkeley, Santa Monica, and
San Jose. In addition, about 100 citi~s and counties have laws limiting the rent mobile
home park owners may charge people who lease space in their park. Altogether, about
one million California households live in rent-controlled apartments or mobile home
parks. While the provisions of these rent control laws vary, they typically restrict the
amount of money by which a landlord (or park owner) may increase a tenant's rent
each year. If a tenant moves out of a housing unit or mobile home park, property
owners may reset rents to market rates. Once the unit or space is rented again, however,
rent control laws restrict the rate of future rent increases.
Other Housing Programs and Laws. About one-third of California cities and
counties have laws referred to as "inclusionary housing." These laws (which can be
mandatory or voluntary in nature) have the goal of providing lower-cost housing units
in new developments. Mandatory inclusionary laws require developers to construct
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affordable housing on part of their land or contribute funds to develop such housing.
Voluntary laws offer developers incentives to provide affordable housing. (For
example, a city might permit a developer to build an increased number of housing units
if some of them are affordable to lower-income households.) In addition, many
California cities have ordinances requiring apartment owners to provide relocation
benefits to tenants if they convert their property into condominiums.
PROPOSAL
This measure amends the State Constitution to (1) constrain state and local
governments' authority to take private property and (2) phase out rent control. The
measure also might constrain government's authority to implement certain other
programs and laws, such as mandatory inclusionary housing programs and tenant
relocation benefits. The measure's provisions apply to all governmental agencies.
Taking Property
The measure prohibits government from taking ownership of property to transfer it
to a private party-such as a person, business, or nonprofit organization. In addition,
government could not take property to use it for (1) a purpose substantially similar to
how the private owner used it (such as public operation of a water or electricity
delivery system formerly owned by a private company) or (2) the purpose of
consuming its natural resources (such as its oil or minerals). These restrictions on
government's authority to take property also would apply to cases when government
transfers the right to use or occupy property (but does not take ownership of it). None
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of these restrictions would apply, however, if government was addressing a public
nuisance or criminal activity or as part of a state of emergency declared by the
Governor.
Under the measure, government could continue to take property for facilities that it
would own and use, such as new schools, roads, parks, and public facilities.
Government could not take property for one purpose, however, and then use it for a
different purpose unless it offered to sell the property back to its previous owner.
Property Owner Challenges. If a property owner challenged government's authority
to use eminent domain, the measure directs the court to exercise its independent
judgment and not defer to the findings of the government agency. In addition, property
owners could challenge government's right to take the property even if they accepted
funds that government deposited as part of an accelerated eminent domain action.
Property Owner Compensation. The measure contains provisions that would
increase the amount of compensation provided to property owners. For example,
property owners would be entitled to reimbursement for all business relocation costs,
which could exceed the maximum amounts specified under current law. In addition,
property owners would be entitled to compensation for their attorney costs if the
property owner was successful in an eminent domain challenge.
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Rent Control
The measure generally prohibits government from limiting the price property
owners may charge others to purchase, occupy, or use their land or buildings. This
provision would affect local rent control measures. Specifically, government could not
enact new rent control measures, and any rent control measure enacted after January 1,
2007 would end. Other rent control measures (those enacted before January 1, 2007)
would be phased out on a unit-by-unit basis after an apartment unit or mobile home
park space is vacated. Once a tenant left an apartment or mobile home space, property
owners could charge market rate rents, and that apartment unit or mobile home space
would not be subject to rent control again.
Other Government Laws and Programs
The measure appears to limit government's authority to impose restrictions on the
"ownership, occupancy, or use of property" if the restrictions were imposed "in order
to transfer an economic benefit" from one property owner to other private persons. The
range of government laws and programs that would be affected by these provisions is
not clear and would be determined by the courts. Given the wording of the measure,
however, programs such as mandatory inclusionary housing and condominium
conversion relocation benefits might be prohibited.
Related Measure on Ballot. This ballot contains two measures related to eminent
domain: Proposition 98 (this measure) and Proposition 99. If this measure were
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approved by more votes than Proposition 99, the provisions of Proposition 99 probably
would not take effect.
FISCAL EFFECTS
Eminent Domain Changes
Much of the property state and local government acquires is bought from willing
sellers or is taken by eminent domain for purposes that would still be allowed under
the measure. In these cases, government could continue to acquire these properties, but
might need to pay somewhat more for them. This is because the measure increases the
amount of compensation provided for properties taken by eminent domain and willing
sellers are likely to demand similar increased amounts.
In some cases, the measure would prevent government from taking property by
eminent domain. This reduced ability to take property could apply to many
government plans for redevelopment, affordable housing, and public ownership of
water or electric utility services. As a result of this reduced authority to take property,
government might (1) buy fewer properties and have lower costs or (2) offer property
owners more to purchase their properties and thus have higher costs.
The net fiscal effect of these potential changes in the number and price of properties
acquired cannot be determined. Overall, we estimate that many governments would
have net increased costs to acquire property, but that the net statewide fiscal effect
probably would not be significant.
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Other Changes
It is difficult to estimate the fiscal impact of the measure's phase out of rent control
and limitation of other programs that transfer economic benefits from property owners
to private parties. In response to these provisions, governments might choose to change
their policies in ways that do not increase their costs. For example, a government might
repeal a mandatory inclusionary housing ordinance and not enact a replacement policy,
or repeal the ordinance and enact land-use regulations that encourage the construction
of lower-cost housing.
In other cases, conforming to the measure's provisions could result in new costs. For
example, a government could respond to the elimination of rent control by creating
publicly funded programs to subsidize affordable housing. Given the uncertainty
regarding some of the measure's provisions, some governments might be unaware that
their policies conflicted with the measure's provisions and be required to pay damages
to property owners.
The fiscal effect on state and local governments associated with these changes in rent
control and other policies is not possible to determine, but there probably would be
increased costs to many governments. The net statewide fiscal effect, however, probably
would not be significant.
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ATTACHMENT B
Proposition 99
Eminent Domain. Acquisition of Owner-Occupied Residence.
Constitutional Amendment.
Background
California state and local governments frequently acquire private property to build
public facilities (such as roads, parks, and schools) or to promote public objectives (such
as economic development and affordable housing).
Most of the time, government buys property from willing sellers. Sometimes,
however, property owners do not want to sell their property or do not agree on a sales
price. In these cases, California law allows government to take property from a private
owner provided that government:
. Uses the property for a "public use" (a term that has been broadly interpreted
to mean a variety of public purposes).
. Pays the property owner "just compensation" (generally, the property's fair
market value) and relocation costs (including certain business losses).
This government power to take property for a public use is called "eminent
domain." The nearby box provides additional information regarding the terms public
use, just compensation, and relocation costs.
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Proposal
This constitutional amendment limits state and local government's use of eminent
domain in certain circumstances. Specifically, the measure prohibits government from
using eminent domain to take a single-family home (including a condominium) for the
purpose of transferring it to another private party (such as a person, business, or
association).
This prohibition, however, would not apply if government was taking the home to:
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. Protect public health and safety.
. Prevent serious, repeated criminal activity.
. Respond to an emergency.
. Remedy environmental contamination that posed a threat to public health
and safety.
. Use the property for a public work, such as a toll road or airport operated by
a private party.
In addition, the prohibition would not apply if the property owner did not live in the
home or had lived there for less than a year.
Related Measure on Ballot. This ballot contains two measures related to eminent
domain: Proposition 99 (this measure) and Proposition 98. If this measure were
approved by more votes than Proposition 98, this measure provides that the provisions
of Proposition 98 would not take effect.
Fiscal Effects
Under current law and practice, government seldom uses eminent domain to take
single-family homes. Even when it does so, the acquisition often is for a purpose that is
permitted under the measure (such as construction of a road or school). Accordingly,
this measure would not change significantly current government land acquisition
practices.
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In a very limited number of cases, however, this measure might result in
government:
· Savings-because government could not acquire a home that the owner did
not wish to sell.
· Costs-because government might pay more to buy a home than would have
been the case if it could have taken the home using eminent domain.
The net fiscal effect of such actions would not be significant.
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RESOLUTION NO. 2008-
-
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA OPPOSING STATE PROPOSITION 98
WHEREAS, a constitutional amendment ballot measure, Proposition 98, will appear on
California's June 2008 ballot; and
WHEREAS, Proposition 98 proponents want voters to believe the initiative is about eminent
domain, but in fact the measure contains hidden agendas and flawed language which will eliminate
rent control and other renter protections, threaten development of public water proj ects, stymie local
land use planning and impair our ability to protect the environment; and
WHEREAS, the majority of the funding to qualifY this measure comes from wealthy
apartment and mobile home park owners who are attempting to trick voters into abolishing rent
control and other renter protections, thereby jeopardizing an important affordable housing tool to
protect working families, seniors, single-parent homes, veterans and others; and
WHEREAS, provisions in the initiative would also preclude the use of eminent domain to
acquire land or water to develop public water projects that are needed to provide our residents,
businesses, farmers and economy with a reliable and safe supply of water; and
WHEREAS, Proposition 98 is opposed by the Association of California Water Agencies
and the Western Growers Association, who warn the initiative will impair water projects to protect
water quality and supply; and
WHEREAS, language in the initiative will also prohibit the passage of regulations,
ordinances, land use and other zoning laws that enable local governments to plan and protect
communities; and
WHEREAS, the California Police Chiefs Association opposes the measure because it
threatens their ability to keep communities and the public safe; and
WHEREAS, leading environmental groups warn provisions in the measure would impair our
ability to enact environmental protections such as laws that control greenhouse gas emissions,
preserve open space, protect coastal areas, and regulate development; and
WHEREAS, the No on Proposition 98 campaign is represented by the League of California
Cities, California State Association of Counties, League of California Homeowners, California
League of Conservation Voters, California Alliance for Retired Americans and other leading state
and local associations who oppose Proposition 98.
NOW, THEREFORE, BE IT RESOLVED BY THE City Council of the City ofChula Vista
that we hereby oppose Proposition 98 on the June 2008 ballot.
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Resolution No. 2008-
Page 2
BE IT FURTHER RESOLVED that we authorize the use of our name by the No on
Proposition 98 campaign in opposition to Proposition 98, and direct staff to fax a copy of this
adopted resolution to 916.442.3510.
Submitted by
Approved as to form by
Ann Moore
City Clerk
David R. Garcia
City Manager
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RESOLUTION NO. 2008-
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CHULA VISTA IN SUPPORT OF STATE PROPOSITION 99
WHEREAS, in June of 2005 the US Supreme Court ruled in Kelo v. New London that
government could take a home through eminent domain to give to a private developer; and
WHEREAS, since that decision more than 40 states have reformed their eminent domain
laws; and
WHEREAS, California has failed to place a prohibition on the use of eminent domain to
take homes for private development; and
WHEREAS, Proposition 99, which will be on the June 2008 ballot, will prohibit
government from using eminent domain to take an owner-occupied home to transfer to another
private party; and
WHEREAS, the protections in Proposition 99 directly address the issues in the Kelo
decision and the measure does not contain any unrelated provisions that will result in unintended,
harmful consequences for California; and
WHEREAS, the League of California Homeowners supports this measure because it will
provide ironclad protections for California homeowners; and
WHEREAS, the Yes on Proposition 99 campaign is represented by a broad based
coalition, including the League of California Cities, California States Association of Counties,
League of California Homeowners, California League of Conservation Voters, California
Alliance for Retired Americans and other leading state and local associations who support
Proposition 99;
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City ofChula Vista
that we hereby support Proposition 99.
BE IT FURTHER RESOLVED that we authorize the use of our name by the Yes on
Proposition 99 campaign in support of Proposition 99, and hereby direct staff to fax a copy of
this adopted resolution to 916.442.3510.
Submitted by
Approved as to form by
David R. Garcia
City Manager
Ann Moore
City Attorney
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