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HomeMy WebLinkAboutAgenda Report - May 1, 2013 C-26AGENDA ITEM Co .0Z1+ CITY OF LODI COUNCIL COMMUNICATION • TM AGENDA TITLE: Authorize the Mayor, on Behalf of the City Council, to Send a Letter of Support for AB 1229 (Atkins) and a Letter of Opposition to AB 325 (Alejo) MEETING DATE: May 1, 2013 PREPARED BY: City Clerk RECOMMENDED ACTION: Authorize the Mayor, on behalf of the City Council, to send a letter of support for AB 1229 (Atkins) and a letter of opposition to AB 325 (Alejo). BACKGROUND INFORMATION: On April 18, 2013, the City received a request from the League of California Cities to support AB 1229 (Atkins) and oppose AB 325 (Alejo). In regards to AB 1229, the Planning and Zoning Law authorizes the legislative body of any city or county to adopt ordinances regulating zoning within its jurisdiction. This bill would additionally authorize the legislative body of any city or county to adopt ordinances to establish, as a condition of development, inclusionary housing requirements and would declare the intent of the Legislature in adding this provision. In regards to AB 325, the Planning and Zoning Law requires an action or proceeding against local zoning and planning decisions of a legislative body to be commenced and the legislative body to be served within a one year of accrual of the cause of action. When the action or proceeding is brought in connection with the development of housing increasing the community's supply of affordable housing, a cause of action accrues 60 days after notice is filed or the legislative body takes a final action in response to the notice, whichever occurs first. This bill would authorize the notice to be filed any time within 3 years after a specified action pursuant to existing law. For the reasons stated above and in the attached draft correspondence, it is recommended that the City Council authorize the execution and delivery of the proposed correspondence. FISCAL IMPACT: Not applicable at this time. FUNDING AVAILABLE: Not applicable at this time. Randi Joh City Clerk 0I1"D Bartlam, City Manager Randi Johl From: Randi Johl Sent: Monday, April 22, 2013 02:38 PM To: Randi Johl Subject: FW: Letters needed Attachments: AB 325 (Alejo) Action Alert 041513 (2).pdf; AB 325 Sample Letter.doc; AB 1229 (Atkins) Action Alert 041113b.docx; AB 1229 Sample support letter-FINAL.doc A use AB 325 (Alejo) AB 325 Sample AB 1229 (Atkins) AB 1229 Sample Action Alert 04... Letter.doc (31 K... Action Alert ... support letter-... -----Original Message ----- From: Stephen R. Qualls (mailto:squalls@cacities.org] Sent: Thursday, April 18, 2013 09:44 AM Subject: Letters needed Attached you will please find letters concerning AB 325 and AB 1229. AB 325 (oppose), extends the statute of limitation for challenging certain housing or planning decisions. The current statute of limitations of 1 year and 150 days already exceeds the 90 days allowed for other planning decisions. AB 1229 (support), returns the decision making process for inclusionary housing to local government. But this shouldn't be of concern only to those cities that have inclusionary housing elements. This should concern every city as it is a conduit to return local control to local government. Something that has been eroded lately by the Legislature in Sacramento. These both need to be sent as soon as possible because AB 1229 is to be heard on May 17th and AB 325 on May 30th. Please cc me when you send the letters. Thank you for your support, Stephen Qualls Central Valley Regional Public Affairs Manager League of California Cities 209-614-0118 Fax 209-883-0653 squalls@cacities.org<mailto:squalls@cacities.org> To expand and protect local control for cities through education and advocacy in order to enhance the quality of life for all Californians. <http://www.cacities.org/AC> PLEASE DO NOT distribute political campaign advocacy information from public (city hall) computers, on city time, or using public resources, even if it's from your personal email account. If in doubt, check with your city attorney. ***Disclaimer***Please Note: Please take the following precautions if this email is about a CITIPAC event. Though it is not illegal for you to receive this notice via a city e- mail address, you should not respond to it or forward it using public resources. You may however forward this message to your non-public e-mail account for distribution on non- public time. If you have questions about the event or need additional information, please contact Mike Egan at (916) 658-8271 or egan@cacities.org 1 CITY COUNCIL ALAN NAKANISHI, Mayor PHIL KATZAKIAN, Mayor Pro Tempore LARRY D. HANSEN BOB JOHNSON JOANNE MOUNCE May 1, 2013 CITY OF LODI CITY HALL, 221 WEST PINE STREET P.O. BOX 3006 LODI, CALIFORNIA 95241-1910 (209) 333-6702 / FAX (209) 333-6807 www.lodi.gov citvclerk aalodi.gov The Honorable Norma Torres Chair, Housing and Community Development Committee California State Assembly State Capitol Building, Room 2179 Sacramento, California 95814 Via Facsimile: (916) 319-2152 SUBJECT: Limitations. NOTICE OF Dear Assembly Member Torres: The City of Lodi has taken a position of oppose on of limitations to file suit against a city's housing ele KONRADT BARTLAM, City Manager RANDI JOHL, City Clerk D. STEPHEN SCHWABAUER City Attorney would expan.,''the statute Jr years. Government Code Section 65009 state that legal action adit"s a city or county "has a chilling effect on the confidence with which j5t6 11 owners an l ocgJ,°governments can w proceed with projects. In addition, The purpos o wthts section i§A provide certainty for property owners and local governments regarding decxsOOns, meld pursuant to this division. Expanding the statute of limitations goes again sttheve rypurpose of this section with which this bill seeks to amend 4,°"'*"�- �.:.:s..., Q AB 325 is an attem`ktt`4expand the current statute of>limitations without regard to whether a city's housing element follows the;lettter of the law�ar a jurisdiction fails to adopt a housing element entirely Our city hasiNorked hac to mtieet the state s statutory housing requirements The pS�bility oaulawsuit looirttng over our head for over four years would have a tatingeffect Qn dei , opment and our local economy. For#hese4 easons, the CiW.,," a. Lodi his an oppose position on AB 325. Sincerely, Alan Nakanishi Mayor C: Anya Lawler, Consultant, Assembly Housing and Community Development Committee (916-319-3182) William Weber, Consultant, Assembly Republican Caucus (916-319-3902) Kirstin Kolpitcke, League of California Cities Stephen Qualls, League of California Cities CITY COUNCIL ALAN NAKANISHI, Mayor PHIL KATZAKIAN, Mayor Pro Tempore LARRY D. HANSEN BOBJOHNSON JOANNE MOUNCE May 1, 2013 CITY OF LODI CITY HALL, 221 WEST PINE STREET P.O. BOX 3006 LODI, CALIFORNIA 95241-1910 (209) 333-6702 / FAX (209) 333-6807 www.lodi.gov cityc[erk@lodi.gov The Honorable Toni G. Atkins Member, California State Assembly State Capitol Building, Room 319 Sacramento, California 95814 Via Facsimile: (916) 319-2178 SUBJECT: AB 1229 (Atkins). Lanc NOTICE OF SUPPORT Dear Assembly Member Atkins: The City of Lodi is pleased to support your authority for inclusionary housing. In the appellate court decision, Palmer Angeles, 175 Cal. App. 4th 1396 (2009) 1 Costa -Hawkins Act and its application or inclusionary housing ordinances with reg preempted by the Costa -Hawkins Act. C of rent control, not precJuceCett,restrictit Inclusionary housirfg`j homes for working far to be severely-.diminis For thes6 reasons, Alan Nakanishi Mayor ms qre an impo uld restore KONRADT BARTLAM, City Manager RAND[ JOHL, City Clerk D. STEPHEN SCHWABAUER City Attorney zoning Street Prope�`te�s L.P. v. City of Los ,ourts took a ve .,road interpretation of the lupnary housingxartlinances, opining that to �rynitalMousing conflicted with and were r-Hawkinsves intended to restrict systems n inclusionary housing. in the production of affordable new affordable housing stock continues of Lbdi,.surrworts AB 1229. C: Anya Lawler, Consultant, Assembly Housing and Community Development Committee (916-319-3182) William Weber, Consultant, Assembly Republican Caucus (916-319-3902) Kirstin Kolpitcke, League of California Cities Stephen Qualls, League of California Cities CALIFORNIA LEGISLATURE -2013-14 REGULAR SESSION ASSEMBLY BILL No. 325 Introduced by Assembly Member Alejo February 13, 2013 An act to amend Sections 65009, 65589.3, and 65755 of the Government Code, relating to land use. LEGISLATIVE COUNSEL'S DIGEST AB 325, as introduced, Alejo. Land use and planning: cause of actions: time limitations. (1) The Planning and Zoning Law requires an action or proceeding against local zoning and planning decisions of a legislative body to be commenced and the legislative body to be served within a year of accrual of the cause of action, if it meets certain requirements. Where the action or proceeding is brought in support of or to encourage or facilitate the development of housing that would increase the community's supply of affordable housing, a cause of action accrues 60 days after notice is filed or the legislative body takes a final action in response to the notice, whichever occurs first. This bill would authorize the notice to be filed any time within 3 years after a specified action pursuant to existing law. The bill would declare the intent of the Legislature that its provisions modify a specified court opinion. The bill would also provide that in that specified action or proceeding, no remedy pursuant to specified provisions of law abrogate, impair, or otherwise interfere with the full exercise of the rights and protections granted to a tentative map application or a developer, as prescribed. (2) The Planning and Zoning Law establishes a rebuttable presumption, in any action filed on or after January 1, 1991, taken to 99 AB 325 —2— challenge 2 challenge the validity of a housing element, of the validity of a housing element or amendment if the Department of Housing and Community Development has found that the element or amendment substantially complies with specified provisions of existing law. This bill would provide in any action brought against a city, county, or city and county to challenge the adequacy of a housing element, if a court finds that the adopted housing element or amended housing element for the current planning period substantially complies with specified provisions, that the element or amendment be deemed to satisfy any condition of a state -administered housing grant program requiring a department finding of housing element compliance. Vote: majority. Appropriation: no. Fiscal committee: no. State -mandated local program: no. The people of the State of California do enact as follows: 1 SECTION 1. It is the intent of the Legislature in enacting 2 Section 2 of this act to modify the court's opinion in Urban Habitat 3 Program v. City of Pleasanton (2008)164 Ca1.App.4th 1561, with 4 respect to the interpretation of Section 65009 of the Government 5 Code. 6 SEC. 2. Section 65009 of the Government Code is amended 7 to read: 8 65009. (a) (1) The Legislature finds and declares that there 9 currently is a housing crisis in California and it is essential to 10 reduce delays and restraints upon expeditiously completing housing 11 projects. 12 (2) The Legislature further finds and declares that a legal action 13 or proceeding challenging a decision of a city, county, or city and 14 county has a chilling effect on the confidence with which property 15 owners and local governments can proceed with projects. Legal 16 actions or proceedings filed to attack, review, set aside, void, or 17 annul a decision of a city, county, or city and county pursuant to 18 this division, including, but not limited to, the implementation of 19 general plan goals and policies that provide incentives for 20 affordable housing, open -space and recreational opportunities, and 21 other related public benefits, can prevent the completion of needed 22 developments even though the projects have received required 23 governmental approvals. 99 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 — 3 — AB 325 (3) The purpose of this section is to provide certainty for property owners and local governments regarding decisions made pursuant to this division. (b) (1) In an action or proceeding to attack, review, set aside, void, or annul a finding, determination, or decision of a public agency made pursuant to this title at a properly noticed public hearing, the issues raised shall be limited to those raised in the public hearing or in written correspondence delivered to the public agency prior to, or at, the public hearing, except where the court finds either of the following: (A) The issue could not have been raised at the public hearing by persons exercising reasonable diligence. (B) The body conducting the public hearing prevented the issue from being raised at the public hearing. (2) If a public agency desires the provisions of this subdivision to apply to a matter, it shall include in any public notice issued pursuant to this title a notice substantially stating all of the following: "If you challenge the (nature of the proposed action) in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the (public entity conducting the hearing) at, or prior to, the public hearing." (3) The application of this subdivision to causes of action brought pursuant to subdivision (d) applies only to the final action taken in response to the notice to the city or clerk of the board of supervisors. If no final action is taken, then the issue raised in the cause of action brought pursuant to subdivision (d) shall be limited to those matters presented at a properly noticed public hearing or to those matters specified in the notice given to the city or clerk of the board of supervisors pursuant to subdivision (d), or both. (c) (1) Except as provided in subdivision (d), no action or proceeding shall be maintained in any of the following cases by any person unless the action or proceeding is commenced and service is made on the legislative body within 90 days after the legislative body's decision: (A) To attack, review, set aside, void, or annul the decision of a legislative body to adopt or amend a general or specific plan. This paragraph does not apply where an action is brought based upon the complete absence of a general plan or a mandatory 99 AB 325 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 —4— element thereof, but does apply to an action attacking a general plan or mandatory element thereof on the basis that it is inadequate. (B) To attack, review, set aside, void, or annul the decision of a legislative body to adopt or amend a zoning ordinance. (C) To determine the reasonableness, legality, or validity of any decision to adopt or amend any regulation attached to a specific plan. (D) To attack, review, set aside, void, or annul the decision of a legislative body to adopt, amend, or modify a development agreement. An action or proceeding to attack, review, set aside, void, or annul the decisions of a legislative body to adopt, amend, or modify a development agreement shall only extend to the specific portion of the development agreement that is the subject of the adoption, amendment, or modification. This paragraph applies to development agreements, amendments, and modifications adopted on or after January 1, 1996. (E) To attack, review, set aside, void, or annul any decision on the matters listed in Sections 65901 and 65903, or to determine the reasonableness, legality, or validity of any condition attached to a variance, conditional use permit, or any other permit. (F) Concerning any of the proceedings, acts, or determinations taken, done, or made prior to any of the decisions listed in subparagraphs (A), (B), (C), (D), and (E). (2) In the case of an action or proceeding challenging the adoption or revision of a housing element pursuant to this subdivision, the action or proceeding may, in addition, be maintained if it is commenced and service is made on the legislative body within 60 days following the date that the Department of Housing and Community Development reports its findings pursuant to subdivision (h) of Section 65585. (d) (1) An action or proceeding shall be commenced and the legislative body served within one year after the accrual of the cause of action as provided in thissubdivision,, subdivision if the action or proceeding meets both of the following requirements: ( It is brought in support of or to encourage or facilitate the development of housing that would increase the community's supply of housing affordable to persons and families with low or moderate incomes, as defined in Section 50079.5 of the Health and Safety Code, or with very low incomes, as defined in Section 99 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 — 5 — AB 325 50105 of the Health and Safety Code, or middle-income households, as defined in Section 65008 of this code. This subdivision is not intended to require that the action or proceeding be brought in support of or to encourage or facilitate a specific housing development project. (B) It is brought with respect to actions taken pursuant to Article 10.6 (commencing with Section 65580) of Chapter division, pursuant to 3, Section 6Jo� , 65863.6,–X5915,, or 66474.2 or pursuant to Chapter 4.2 (commencing with Section 65913). 65913), or to challenge the adequacy of an ordinance adopted pursuant to Section 65915. A (2) A cause of action brought pursuant to this subdivision shall not be maintained until 60 days have expired following notice to the city or clerk of the board of supervisors by the party bringing the cause of action, or his or her representative, specifying the deficiencies of the general plan, specific plan, or zoning ordinance. A cause of action brought pursuant to this subdivision shall accrue 60 days after notice is filed or the legislative body takes a final action in response to the notice, whichever occurs first. This notice may be filed at any time within three years after an action described in subparagraph (B) of paragraph (1). A notice or cause of action brought by one party pursuant to this subdivision shall not bar filing of a notice and initiation of a cause of action by any other parry. (3) After the adoption of a housing element covering the current planning period, no action shall be filed pursuant to this subdivision to challenge a housing element covering a prior planning period. (e) Upon the expiration of the time limits provided for in this section, all persons are barred from any further action or proceeding. (f) Notwithstanding Sections 65700 and 65803, or any other provision of law, this section shall apply to charter cities. (g) Except as provided in subdivision (d), this section shall not affect any law prescribing or authorizing a shorter period of limitation than that specified herein. (h) Except as provided in paragraph (4) of subdivision (c), this section shall be applicable to those decisions of the legislative 99 AB 325 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 —6— body of a city, county, or city and county made pursuant to this division on or after January 1, 1984. SEC. 3. Section 65589.3 of the Government Code is amended to read: 65589.3. (a) In any action filed on or after January 1, 1991, taken to challenge the validity of a housing element, there shall be a rebuttable presumption of the validity of the element or amendment if, pursuant to Section 65585, the department has found that the element or amendment substantially complies with the requirements of this article. (b) In any action brought against a city, county, or city and county to challenge the adequacy of a housing element, if a court finds that the adopted housing element or amended housing element for the current planning period substantially complies with all of the requirements of this article, including, but not limited to, the requirements for public participation set forth in paragraph (7) of subdivision (c) of Section 65583, the element or amendment shall be deemed to satisfy any condition of a state -administered housing grant program requiring a department finding that the housing element substantially complies with the requirements of this article. SEC. 4. Section 65755 of the Government Code is amended to read: 65755. (a) The court shall include, in the order or judgment rendered pursuant to Section 65754, one or more of the following provisions for any or all types or classes of developments or any or all geographic segments of the city, county, or city and county until the city, county, or city and county has substantially complied with the requirements of Article 5 (commencing with Section 65300): (1) Suspend the authority of the city, county, or city and county pursuant to Division 13 (commencing with Section 179 10) of the Health and Safety Code, to issue building permits, or any category of building permits, and all other related permits, except that the city, county, or city and county shall continue to function as an enforcement agency for review of permit applications for appropriate codes and standards compliance, prior to the issuance of building permits and other related permits for residential housing for that city, county, or city and county. 99 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 '1— AB 325 (2) Suspend the authority of the city, county, or city and county, pursuant to Chapter 4 (commencing with Section 65800) to grant any and all categories of zoning changes, variances, or both. (3) Suspend the authority of the city, county, or city and county, pursuant to Division 2 (commencing with Section 66410), to grant subdivision map approvals for any and all categories of subdivision map approvals. (4) Mandate the approval of all applications for building permits, or other related construction permits, for residential housing where a final subdivision map, parcel map, or plot plan has been approved for the project, where the approval will not impact on the ability of the city, county, or city and county to properly adopt and implement an adequate housing element, and where the permit application conforms to all code requirements and other applicable provisions of law except those zoning laws held to be invalid by the final court order, and changes to the zoning ordinances adopted after such final court order which were enacted for the purpose of preventing the construction of a specific residential development. (5) Mandate the approval of any or all final subdivision maps for residential housing projects which have previously received a tentative map approval from the city, county, or city and county pursuant to Division 2 (commencing with Section 66410) when the final map conforms to the approved tentative map, the tentative map has not expired, and where approval will not impact on the ability of the city, county, or city and county to properly adopt and implement an adequate housing element. (6) Mandate that notwithstanding the provisions of Sections 66473.5 and 66474, any tentative subdivision map for a residential housing project shall be approved if all of the following requirements are met: (A) The approval of the map will not significantly impair the ability of the city, county, or city and county to adopt and implement those elements or portions thereof of the general plan which have been held to be inadequate. (B) The map complies with all of the provisions of Division 2 (commencing with Section 66410), except those parts which would require disapproval of the project due to the inadequacy of the general plan. 99 AB 325 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 8— (C) The approval of the map will not affect the ability of the city, county, or city and county to adopt and implement an adequate housing element. (D) The map is consistent with the portions of the general plan not found inadequate and the proposed revisions, if applicable, to the part of the plan held inadequate. (b) Any order or judgment of a court which includes the remedies described in paragraphs (1), (2), or (3) of subdivision (a) shall exclude from the operation of that order or judgment any action, program, or project required by law to be consistent with a general or specific plan if the court finds that the approval or undertaking of the action, program, or project complies with both of the following requirements: (1) That it will not significantly impair the ability of the city, county, or city and county to adopt or amend all or part of the applicable plan as may be necessary to make the plan substantially comply with the requirements of Article 5 (commencing with Section 65300) in the case of a general plan, or Article 8 (commencing with Section 65450) in the case of a specific plan. (2) That it is consistent with those portions of the plan challenged in the action or proceeding and found by the court to substantially comply with applicable provisions of law. The party seeking exclusion from any order or judgment of a court pursuant to this subdivision shall have the burden of showing that the action, program, or project complies with paragraphs (1) and (2). (c) Notwithstanding Section 65754.4 or subdivisions (a) and (b), in any action or proceeding brought pursuant to subdivision (d) of Section 65009, no remedy pursuant to this section or injunction pursuant to Section 65754.5 shall abrogate, impair, or otherwise interfere with the full exercise of the rights and protections granted to (1) an applicant for a tentative map pursuant to Section 664 74.2, or (2) a developer pursuant to Sections 65866 and 66498.1. 0 99 CALIFORNIA LEGISLATURE -2013-14 REGULAR SESSION ASSEMBLY BILL No. 1229 Introduced by Assembly Member Atkins (Principal coauthor: Assembly Member Mullin) (Principal coauthor: Senator Leno) February 22, 2013 An act to amend Section 65850 of the Government Code, relating to land use. LEGISLATIVE COUNSEL'S DIGEST AB 1229, as introduced, Atkins. Land use: zoning regulations. The Planning and Zoning Law authorizes the legislative body of any city or county to adopt ordinances regulating zoning within its jurisdiction, as specified. This bill would additionally authorize the legislative body of any city or county to adopt ordinances to establish, as a condition of development, inclusionary housing requirements, as specified, and would declare the intent of the Legislature in adding this provision. The bill would also make a technical, nonsubstantive change. Vote: majority. Appropriation: no. Fiscal committee: no. State -mandated local program: no. The people of the State of California do enact as follows: 1 SECTION 1. Section 65850 of the Government Code is 2 amended to read: 3 65850. The legislative body of any county or city may, pursuant 4 to this chapter, adopt ordinances that do any of the following: 99 AB 1229 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 —2— (a) Regulate the use of buildings, structures, and land as between industry, business, residences, open space, including agriculture, recreation, enjoyment of scenic beauty, use of natural resources, and other purposes. (b) Regulate signs and billboards. (c) Regulate all of the following: (1) The location, height, bulk, number of stories, and size of buildings and structures. (2) The size and use of lots, yards, courts, and other open spaces. (3) The percentage of a lot which may be occupied by a building or structure. (4) The intensity of land use. (d) Establish requirements for-e€€kfeet off-street parking and loading. (e) Establish and maintain building setback lines. (f) Create civic districts around civic centers, public parks, public buildings, or public grounds, and establish regulations for those civic districts. (g) Establish, as a condition of development, inclusionary housing requirements, which may require the provision of residential units affordable to, and occupied by, owners or tenants whose household incomes do not exceed the limits for lower income, very low income, or extremely low income households specified in Sections 50079.5, 50105, and 50106 of the Health and Safety Code. SEC. 2. The Legislature finds and declares all of the following: (a) Inclusionary housing ordinances have provided quality affordable housing to over 80,000 Californians, including the production of an estimated 30,000 units of affordable housing in the last decade alone. (b) Since the 1970s, over 170 jurisdictions have enacted inclusionary housing ordinances to meet their affordable housing needs. (c) While many of these local programs have been in place for decades, the recent decision in Palmer/Sixth Street Properties, L.P. v. City of Los Angeles (2009) 175 Cal.App.4th 1396, has created uncertainty and confusion for local governments regarding the future viability of this important local land use tool. (d) It is the intent of the Legislature to reaffirm the authority of local jurisdictions to enact and enforce these ordinances. 99 — 3 — AB 1229 1 (e) The Legislature declares its intent in adding subdivision (g) 2 to Section 65850 of the Government Code, pursuant to Section 1 3 of this act, to supersede any holding or dicta in Palmer/Sixth Street 4 Properties, L.P. v. City of Los Angeles (2009) 175 Cal.AppAth 5 1396, to the extent that the opinion in that case conflicts with that 6 subdivision. This act shall not otherwise be construed to enlarge 7 or diminish the authority of a jurisdiction beyond those powers 8 that existed as of July 21, 2009. 0 M