Item 3a Staff Report Authorize Request for Amicus Participation in City of Santa Monica Petition Before the State Board of Equalization, Case No. 255567, at no Cost to the TownMEETING DATE: 8/16/04
AGENDA ITEM:
COUNCIL AGENDA REPORT
DATE: August 9, 2004
TO: MAYOR AND TOWN COUNCIL
FROM: ORRY P. KORB, TOWN ATTORNEY
SUBJECT: AUTHORIZE REQUEST FOR AMICUS PARTICIPATION IN CITY OF
SANTA MONICA PETITION BEFORE THE STATE BOARD OF
EQUALIZATION, CASE NO. 255567, AT NO COST TO THE TOWN
RECOMMENDATION:
Approve joining the amicus brief of the City of Brisbane, et al., in support of the petition of the City
of Santa Monica, Case No. 255567, at no cost to the Town.
BACKGROUND:
The State Board of Equalization ("SBE") distributes local sales taxes based on where sales
transactions occur. Determining the sales tax situs can be complex and occasionally controversial
undertaking, particularly where sales operations involve facilities located in multiple jurisdictions.
The recent advent of internet based sales operations has further complicated the question, in part
because staff of the SBE believes that internet based sales do not involve human interaction, a
component which has long been considered necessary in determining where a sales transaction
occurs
Agreeing that internet sales do not involve a human component, a SBE hearing officer in the above
case determined that the City of Santa Monica should not be credited with sales taxes generated by
internet based sales by E-Toys, a one time Santa Monica based corporation. In that case, the hearing
officer determined that the first human involvement occurred at the warehouse where sales orders
were filled. Because E-Toys' warehouse operations were located outside Santa Monica, the hearing
officer determined that the City was not entitled to the tax revenues. Also, because E-Toys did not
PREPARED BY: ORRY P. KORB, TOWN ATTORNEY
OPK:LMB/wp [N:1ATY\Sales-Tax..AM1.TCR.wpd]
Reviewed by: Town Manager �33 Assistant Town Manager Clerk
Finance Community Development
Rev: 8/9/04 8:15 am
Reformatted: 7/19/99
File# 301-05
PAGE 2
MAYOR AND TOWN COUNCIL
SUBJECT: AUTHORIZE REQUEST FOR AMICUS PARTICIPATION IN CITY OF SANTA
MONICA PETITION BEFORE THE STATE BOARD OF EQUALIZATION,
CASE NO. 255567, AT NO COST TO THE TOWN
August 9, 2004
own its warehouse operation, the hearing officer further determined that the sales taxes should go
to a statewide fund.
DISCUSSION:
The above decision has been appealed to the full Board. A number of cities with significant internet
based sales tax producers within their jurisdictions have joined in a brief supporting Santa Monica's
petition. Because the Town receives significant sales tax revenues from internet based sales by
Netflix, Inc., it has been invited to join the brief.
The Town has been a leader in arguing that there is significant human involvement in internet based
sales. For example, in recent correspondence with the SBE, the Town asserted that internet
transactions do not occur without direct human involvement in the decisions regarding terms of sale
for products, software programing and system maintenance. It therefore follows that the Town has
an interest in the above matter and should lend its support to an amicus brief.
Distribution: Robert Cendejas, Esq., 1725 North Juliet Court, Brea, CA 92821
MEETING DATE: 8/16/04
AGENDA ITEM: b
COUNCIL AGENDA REPORT
DATE: August 12, 2004
TO: MAYOR AND TOWN COUNCIL
FROM: ORRY P. KORB, TOWN ATTORNEY()V
SUBJECT: AUTHORIZE REQUEST FOR AMICUS PARTICIPATION IN SUPPORT OF
PETITION FOR REVIEW IN ZACK, ET AL. v. MARINEMERGENCYRADIO
AUTHORITY, CASE NO. S125094, AT NO COST TO THE TOWN
RECOMMENDATION:
Approve preparation of letter of support for review by the California Supreme Court of the decision
in Zack et al. v. Marin Emergency Radio Authority, case number S125094, at no cost to the Town.
BACKGROUND:
A number of Marin County agencies came together in 1998 to create the Marin Emergency Radio
Authority ("MERA"), a joint powers agency ("JPA") formed for the purpose of upgrading Marin
County's emergency communication system. MERA then applied to the Town of Tiburon for permit
allowing the construction of a radio facility, including a 72 foot tall tower, microwave dishes and
related accessory structures. The application was denied based on Tiburon's land use regulations
that prohibit such facilities in residential neighborhoods unless there are no feasible alternatives.
Rather than pursue alternatives, MERA instead claimed immunity from local land use authority
based on the theory that a JPA is entitled to land use immunity that is otherwise applicable to any
of its member agencies, in this case the County of Marin. This theory was rejected by the trial court
but accepted by the California Court of Appeal. Tiburon has petitioned the California Supreme
Court to exercise its discretion to review the Court of Appeal decision.
DISCUSSION:
The issue presented by Tiburon's petition is whether section 6509 of the Government Code was
intended to extend local land use immunity to JPAs, where other land use immunity statutes have
PREPARED BY: ORRY P. KORB, TOWN ATTORNEY
Reviewed by:
Rev: 8/12/04 12:07pm
own Manager Assistant Town Manager
Finance Community Development
OPK/wp [N:1ATY1Tiburan.TCR.wpol
Clerk
Reformatted: 7/19/99
File# 301-05
PAGE 2
MAYOR AND TOWN COUNCIL
SUBJECT: AUTHORIZE REQUEST FOR AMICUS PARTICIPATION IN SUPPORT OF
PETITION FOR REVIEW IN ZACK, ET AL. v. MARIN EMERGENCY RADIO
AUTHORITY, CASE NO. S125094, AT NO COST TO THE TOWN
August 11, 2004
not done so. Tiburon's petition thus emphasizes the statewide proliferation of joint powers agencies,
currently estimated at 1,894, according to the records of the Secretary of State, and argues that the
potential for conflicts with local land use regulations is substantial and growing.
A problem posed by Tiburon's position is that many cities participate in and benefit from the
statutory powers conferred on JPAs. This conflict has kept the Legal Advocacy Committee of the
League of California Cities from supporting Tiburon's petition. Nevertheless, in light of the
emphasis placed on land use regulation, the Town of Los Gatos has generally asserted both in
litigation and in the legislative process that local land use control must be protected. Tiburon's
position in this litigation is consistent with protecting local land use control.
Attachments:
Distribution:
1. E-mail message from Mary Ellen Wetlesen dated August 1, 2004.
2. Proposed form of letter to the Supreme Court supporting Petition for Review.
Ann Danforth, Tiburon Town Attorney, 1505 Tiburon Boulevard, Tiburon, CA
94920
Town Attorney (External) - Importan' s Gatos Land Use Issue - Tiburon Needs "jry Help
Page 1
From: Mary Ellen Wetlesen <wetlesen@pacbell.net>
To: <slickman@losgatosca.gov>, <mwasserman@losgatosca.gov>,
<sdecker@losgatosca.gov>, <dmcnutt@losgatosca.gov>, <jpirzynski@losgatosca.gov>,
<manager@losgatosca.gov>, <attorney@town.los-gatos.ca.us>
Date: Sun, Aug 1, 2004 9:43 PM
Subject: Important Los Gatos Land Use Issue - Tiburon Needs Your Help
Dear Mayor Glickman, Vice -Mayor Wasserman, Council Members: Decker,
McNutt, Pirzynski, Town Manager Figone, and Town Attorney Kork:
The Town of Tiburon needs the help of Los Gatos in the form of an amicus
letter to help get the attention of the Supreme Court to rule on a very
important land use issue, that I believe could affect Los Gatos and all
California cities and towns. We need the Court to clarify whether a
Joint Power Authority (JPA) is immune from local land use regulations.
Tiburon takes its land use authority very seriously, and I know that Los
Gatos does, too. Other towns/cities have sent letters (e.g., Atherton,
Woodside and Los Altos Hills), but we believe that Los Gatos' voice
would be very helpful.
Time is of the essence because the Supreme Court is due to make its
decision at any time. Due to the time constraint, Atherton convened a
special council meeting last week to proceed with the amicus letter
because they felt that the ambiguous ruling on the power of a JPA could
conceivably allow a "real estate consortium" to skirt land use
regulations with adverse affects within its jurisdiction. I am sure
that Los Gatos feels the same way. Woodside and Los Altos Hills
provided letters with quick turnaround without convening a council
meeting.
I include a copy of the MEMO that Tiburon Town Attorney Ann Danforth
emailed to all city/town attorneys and a copy of the pro forma amicus
letter, so that it would be minimal effort for Town Attorney Orry Kork
to craft a letter to address Los Gatos' concerns. Even if you were to
merely print the form letter on your letterhead and send it to the
Court, it would help.
I also include a copy of Tiburon's Petition to the Supreme Court. If
you skim this document you will understand the importance that this case
has to the future land use control of all California towns/cities and to
the future of all JPAs. At the end of the day, a town's/city's land use
control is extremely important...don't you agree?
I always thought that government agencies should be sterling examples of
open process and public participation...but the JPA in question has done
everything behind closed doors, with NO public participation and has
been a real bully. What happened to Tiburon could happen to Los Gatos
not only in the form of a transmission facilities but in the form of a
dog kennel, a half -way house, low-income housing...any form of JPA.
Tiburon's JPA, called Marin Emergency Radio Authority (MERA), believes
that it can legally construct an industrial grade communications
facility right in the middle of a residential neighborhood without any
permits from the Town of Tiburon. The facility includes a 72 foot
transmission tower, large microwave dishes, 500 gallon propane tank,
generator, out buildings, etc. It would be located only 60 feet from
ATTACHMENT 1.
Town Attorney (External) - Importan}
s Gatos Land Use Issue - Tiburon Needs Your Help Page 2
children's bedrooms, 20 feet from a child's play area and immediately
adjacent to the public hiking trail. (MERA readily admits that radio
frequency radiation would be transmitted through the children's bedrooms
24 hours a day/7days a week)
It began with MERA's "stealth EIR" (Environmental Impact Report),
whereby no one in the 500' noticing circle was notified. The JPA felt
that referring to a parcel number in the bowels of a county newspaper
constituted "proper notice". There were absolutely no comments from
Tiburon because we were purposely kept in the dark.
It continued when the JPA came to the Town of Tiburon for a conditional
use permit (CUP) in June 2000 ONLY after the time period in which to
legally contest the EIR had expired.
It culminated when Tiburon refused to grant a permit because it was an
inappropriate site, and the JPA proceeded to take the land via eminent
domain in less than 24 hours (again with no public notice) and brought
earth moving equipment to the site to begin excavation. Tiburon police
red -tagged the contractor claiming that it didn't matter who owned the
land, what mattered is that they did not have a permit to build. The
JPA then sued the Town of Tiburon, claiming that they did not need a
permit to build within its jurisdiction!!!
Tiburon prevailed in the hearing, but the JPA won in appeal. With two
courts having conflicting views, it is important that the Supreme Court
rule on this very important issue.
I hope that Tiburon can count on Los Gatos' support and assistance in
this commitment to local land use control for all our futures.
I plan to follow up this email with a phone call in the next day or so.
If you have any questions, and would like to contact me before then,
please do not hesitate to email me or call me (415) 435-1254. Or please
call Tiburon Town Attorney Ann Danforth at (415) 435-7373.
Sincerely yours,
Mary Ellen Wetlesen
LTown,Attorney (External) - Supreme ,urt amici letter, draft .doc
Page 1
June ,2004
Honorable Ronald M. George, Chief Justice
Honorable Associate Justices
Supreme Court of the State of California
350 McAllister Street
San Francisco, CA 94102
Re: Zack et al. v. Marin Emergency Radio Authority
Case No. S125094
Dear Honorable Justices:
The [City][Town] of , California urges the Court to grant review in the
referenced case. There are many thousands of joint powers agencies around the
State, all established for important purposes. Yet a serious question has now emerged
about the proper balance between those important joint purposes and the traditional
power of cities and towns to control land use within their borders. The recent decision
by the First District Court of Appeal in this case has exposed a worrisome uncertainty in
published case law about the proper balance between those interests. We urge this
Court to grant review and settle this important point of law.
The great majority of cities and towns in California either belong to an existing
joint powers arrangement ("JPA") or will be considering one or more new ones in the
near future. That is because the JPA format can be highly valuable in addressing
regional needs efficiently and cost effectively. But the First District's recent decision
exposes a serious problem with the JPA format — potentially serious enough to make
cities and towns hesitate before joining new JPAs and insist on changes in existing
ones. Unless and until this Court resolves this problem authoritatively, it will have the
unfortunate effect of making the JPA format less desirable and attainable than it ought
to be.
The situation in Tiburon is hardly unique. Many JPAs desire to construct new
facilities or modify existing ones to pursue their various purposes. Until now, it was
widely assumed that any and all such projects are subject to the land use regulations of
the locality where the project is situated. Indeed, this Court suggested in Rider v. City
of San Diego (1998) 18 Ca1.4th 1035 that JPAs' ability to streamline their operations by
designating a lead agency was limited to procedural requirements, not substantive
ATTACHMENT 2
,j Town Attorney (External) - Supreme urt amici letter, draft .doc
Page 2
requirements like compliance with local land use regulations. Nevertheless, the First
District has held that virtually any JPA in California has the power to ignore and override
local land use regulations. All it need do, according to the First District's reasoning, is
designate a lead agency that has land use immunity for its own projects, and that
immunity automatically passes to the JPA.
Not every city and town may agree on the proper or most desirable resolution of
this issue. But no city or town can make intelligent decisions about existing or new
JPAs while the law remains uncertain on such a fundamental issue as the applicability
of local land use regulations to JPAs.
We therefore urge the Court to grant review and resolve this question.
Respectfully submitted,
Proof of service attached
, Town Attorney (External) - Supreme •urt amici letter, draft .doc Page 3
CERTIFICATE OF SERVICE BY MAIL
The undersigned declares:
I am over the age of 18 years and am not a party to or interested in the above entitled
cause. I caused to be served --
LETTER TO SUPREME COURT JUSTICES PURSUANT TO RULE OF COURT 28(g)
by enclosing true copies of said document in envelopes with proper postage prepaid
and addressed to --
Ann R. Danforth, Esq.
Town Attorney of Tiburon
1505 Tiburon Boulevard
Tiburon, CA 94920
Elliot L. Bien, Esq.
Bien & Summers LLP
23 Palomino Road
Novato, CA 94947
James M. Wagstaffe, Esq.
Kerr & Wagstaffe LLP
100 Spear Street, Suite 1800
San Francisco, CA 94105-1528
Attorney for Respondent
Town of Tiburon
Attorneys for Respondents
Howard Zack, et al.
Attorneys for Appellant,
Marin Emergency Radio Authority
and placing same for delivery by the United States Postal Service in my usual manner
on the date stated below.
The foregoing is true and correct. Executed under penalty of perjury at ---,
California, on June ---, 2004
Town Council Minutes
Redevelopment Agency
August 16, 2004
Los Gatos, California
TIME
ITEM
ACTION ON ITEM
7:07
CONSENT ITEMS
CONSENT ITEMS
ITEM 1
PAYROLL
RATIFICATION FOR
JULY 2004
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
ratify the check register for payroll of July 18, 2004 through July 31,
2004 paid on August 6, 2004 in the amount of $530,875.15. Carried
unanimously. (01.V)
ITEM 2
ACCOUNTS
PAYABLE FOR
JULY - AUGUST 2004
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
ratify the check register for accounts payable invoices paid on July 30,
2004 and August 6, 2004 in the amount of $1,124,964.03. Carried
unanimously. (02.V)
ITEM 3A
AMICUS BRIEF
STATE BOARD OF
EQUALIZATION
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
authorize joining the amicus brief of the City of Brisbane, et al, in
support of the petition of the City o f Santa Monica before the State
Board of Equalization, Case #255567, at no cost to the Town. Carried
unanimously. (03A. 28)
ITEM 3B
AMICUS BRIEF
EMERGENCY
RADIO AUTHORITY
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
authorize request for amicus participation in support of petition for
review in Zack, et al vs Marin Emergency Radio Authority before the
California Supreme Court , Case #S125094, at no cost to the Town.
Carried unanimously. (03B.28)
ITEM 4A
CIVIL GRAND
JURY REPORT
EVIDENCE ROOMS
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
approve response to Santa Clara County Civil Grand Jury report -
inquiry into Police evidence rooms in Santa Clara County. Carried
unanimously. (04A.28)
ITEM 4B
CIVIL GRAND
JURY REPORT
FINANCIAL AUDIT
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
accept and file report that this item was removed from agenda due to
word processing failure and will return to Council September 7, 2004.
Carried unanimously. (04B.28)
ITEM 5
BELOW MARKET
PRICE HOUSING
DEED
RESTRICTIONS
Resolution 2004-102
Motion by Mrs. Decker, seconded by Mr. Wasserman, that Council
adopt Resolution 2004-102 entitled, RESOLUTION OF TOWN OF
LOS GATOS ADOPTING A BELOW MARKET PRICE
HOUSING PROGRAM DEED RESTRICTION AGREEMENT
FOR OWNER -OCCUPIED UNITS AND RESCINDING
RESOLUTION 1988-80. Carried unanimously. (05.37)
Councilmember Decker praised staff for the work that was done on the
program and for the excellent report.
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