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california legislation > AB 506

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Date of Hearing: May 4, 2011

ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
Cameron Smyth, Chair
AB 506 (Wieckowski) - As Amended: March 31, 2011

SUBJECT
: Local government: bankruptcy: mediation

SUMMARY : Establishes a process for mediation to be administered
by the California Debt and Investment Advisory Commission, and
prohibits a local public entity from exercising powers pursuant
to applicable federal bankruptcy law unless the local public
entity has participated in mediation proceedings and specified
criteria have been met through those mediation proceedings.
Specifically, this bill :

1)Prohibits a local public entity, as defined, from filing a
petition and exercising powers applicable to federal
bankruptcy law unless the local public entity has participated
in mediation and received a good faith certification from the
mediator, and requires one of the following to apply:

a) The local public entity has reached an out-of-court
agreement with all interested parties regarding a plan of
adjustment pursuant to provisions of this bill;

b) The local public entity and the interested parties were
unable to reach an out-of-court agreement and the mediator
has certified in writing that the parties have participated
in mediation in good faith pursuant to provisions of this
bill; or,

c) The local public entity initiated the mediation
proceeding and interested parties did not participate in
the mediation as specified in provisions of this bill.

2)Prohibits the local public entity from filing a petition and
exercising powers under 1) above
if either of the following occur:

a) The mediator determines that solvency or effective debt
restructuring can be achieved through settlement with all
interested parties and that a settlement can be reached
through further mediation; and,









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b) The mediator determines that a local public entity has
failed to participate in good faith mediation, which
includes, but is not limited to, the failure to provide
accurate and essential financial information, the failure
to attempt to reach a settlement with all interested
parties to avert bankruptcy, or evidence of manipulation to
delay and obstruct a timely agreement.

3)Requires the California Debt and Investment Advisory
Commission (CDIAC) to adopt mediation guidelines relating to
local public entity bankruptcy and specifies that CDIAC may
consult with Judicial Arbitration and Mediation Services, the
Executive Office for U.S. Trustees, retired bankruptcy judges,
or other appropriate entities in adopting the guidelines.

4)Allows a local public entity to initiate a mediation when the
local public entity is or is likely to become unable to meet
its financial obligations when those obligations are due or
become due and owing.

5)Provides that mediation will be conducted through an
alternative dispute resolution program within the state and in
accordance with mediation guidelines adopted by CDIAC.

6)Provides that the role of the mediator shall be to assist all
interested parties in reaching an equitable settlement to
avert a Chapter 9 filing.

7)Provides that the mediator may consult with the Judicial
Arbitration and Mediation Services, the Executive Office for
U.S. Trustees, retired bankruptcy judges, or other appropriate
entities in establishing and administering the mediation.

8)Requires a mediator to meet all of the following
qualifications:

a) At least 10 years of high level business or legal
practice involving bankruptcy;

b) Experience in conflict resolution; and,

c) Completion of a mandatory training program in municipal
organization, municipal debt restructuring, Chapter 9
bankruptcy, public finance, taxation, California
constitutional law, California labor law, federal labor








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law, and municipal finance dispute resolution, provided
through an alternative dispute resolution program within
the state.

9)States that the mediator shall be impartial, objective,
independent, and free from prejudice, and shall not act with
partiality or prejudice based on any participant's personal
characteristic, background, values or beliefs, or performance
during mediation.

10)Requires the mediator to avoid a conflict of interest or the
appearance of a conflict of interest during and after a
mediation and requires the mediator to make a reasonable
inquiry to determine whether there are any facts that a
reasonable individual would consider likely to create a
potential or actual conflict of interest.


11)Requires, prior to mediation, that the mediator shall not
establish another relationship with any of the parties in a
manner that would raise questions about the integrity of the
mediation, except that the mediator may conduct further
mediations regarding other potential local public entities
that may involve some of the same or similar constituents to a
prior mediation.


12)Requires the mediator to conduct the mediation in a manner
that promotes voluntary, uncoerced decisionmaking in which
each party makes free and informed choices regarding the
process and outcome.


13)Prohibits the mediator from imposing a settlement on the
parties and requires the mediator to use his or her best
efforts to assist the parties to reach a satisfactory
resolution of their disputes


14)Allows, subject to the discretion of the mediator, the
mediator may make oral or written recommendations for
settlement or plan of readjustment to a party privately or, if
the parties agree, to all parties jointly.










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15)Specifies that the mediator has a duty to instruct and inform
the local public entity and all parties of the limitations of
Chapter 9 relative to other chapters of the bankruptcy codes
and requires that this instruction highlight the limited
authority of United States bankruptcy judges in Chapter 9 such
as the lack of flexibility available to judges to reduce or
cram down debt repayments and similar efforts not available to
reorganize the operations of the city, that may be available
to a corporate entity.


16)Requires the mediator to request from the parties
documentation and other information that the mediator believes
may be helpful in assisting the parties to address the
obligations between them.


17)Allows, in the event a complete settlement of all or some
issues in dispute is not achieved within the scheduled
mediation session or sessions, the mediator to, at the
mediator's discretion, continue to communicate with the
parties in an ongoing effort to facilitate a complete
settlement in order to avoid a Chapter 9 filing.


18)Requires the mediator to provide council and guidance to all
parties and shall not be a legal representative of any party
and shall not have a fiduciary duty to any party.


19)Allows, in the event of a settlement with all interested
parties, the mediator to assist the parties in negotiating a
prepetition, preagreed plan of readjustment in connection with
a potential Chapter 9 filing.


20)Requires the mediator to maintain the confidentiality of all
the information obtained by the mediator in mediation, unless
otherwise agreed to by the parties.

21)Requires parties to exchange all documents including current
financial information and projections addressing future
financial obligations affecting the local public entity or
that may hinder a resolution of the issues before the
mediator, and allows the mediator to request the submission or








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exchange of memoranda on issues, including the underlying
interests, and the history of the parties' prior negotiations.

22)Allows information that a party wishes to keep confidential
to be sent to the mediator in a separate communication clearly
marked "CONFIDENTIAL."

23)Requires each interested party to provide at least one
representative to attend all mediation conferences, and states
that each party's representative shall have authority to
settle and resolve disputes or shall be in a position to
present any proposed settlement or plan of readjustment to the
governing body or membership for approval and implementation.

24)Requires the local public entity to provide a representative
who shall represent the local public entity's interest in the
mediation and who shall propose any settlement or plan of
readjustment to the governing body of the local public entity.

25)Allows an interested party to be represented by legal
counsel, but must inform all parties of the representation.

26)Requires the parties to participate in the mediation in good
faith, and allows the mediator to request that a substitute
representative be appointed, if the mediator determines that a
representative of one or more of the parties is not
participating in good faith.

27)Requires the parties to maintain the confidentiality of the
mediation and prohibits the parties from disclosing statements
made, information disclosed, or documents prepared or produced
during the mediation process as specified in provisions of the
Evidence Code related to mediation, unless all parties consent
in writing to the disclosure.

28)Requires mediation to end if any of the following occur:

a) The parties execute an agreement of settlement;

b) The parties reach an agreement or proposed plan of
readjustment that requires the approval of a bankruptcy
judge;

c) The mediator certifies in writing that one or more of
the parties has not participated in good faith, that no








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resolution has been reached, and that further efforts at
mediation would not contribute a resolution of the parties'
dispute;

d) The mediator certifies in writing that the parties have
participated in good faith but the parties have reached an
impasse and further efforts at mediation would not
contribute to a resolution of disputes; or,

e) The mediator certifies in writing that a mediation was
initiated by the local public entity, but that no
interested parties participated.

29)Adds a new section that defines terms related to provisions
of the bill.

30)States that the Legislature finds and declares that certain
sections contained in the bill impose a limitation on the
public's right of access to the meetings of public bodies or
the writings of public officials and agencies pursuant to
Section 3 of Article I of the California Constitution, and
provides that the reason to demonstrate the interest protected
by this limitation and the need for protecting that interest
is to facilitate the process to avoid municipal bankruptcy;
therefore, it is necessary to provide for secure documents.

31)Makes other legislative findings and declarations.

EXISTING LAW :

1)Allows a local public entity in California to file a petition
and exercise powers pursuant to applicable federal bankruptcy
law, without any statewide approval or pre-conditions.

2)Defines a "local public entity" as a county, city, district,
public authority, public agency, or other entity, without
limitation, that is a municipality as defined in paragraph
(40) of Section 101 of Title 11 of the United States Code, or
that qualifies as a debtor under any other federal bankruptcy
law applicable to local public entities.

3)Allows a legislative body authorized to conduct a proceeding
pursuant to this chapter (Government Code 59125) to file a
petition and exercise powers under applicable federal
bankruptcy law as provided by Section 53760.








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4)Defines the term "municipality" as a political subdivision or
public agency or instrumentality of a state, in federal law
(11 U.S.C. § 101 (40)).

5)Allows the Superintendent of Public Instruction to assume
control of a school district that becomes insolvent to ensure
the district's return to fiscal solvency.

FISCAL EFFECT : Unknown

COMMENTS :

MUNICIPAL BANKRUPTCY UNDER FEDERAL LAW

1)The list of eligibility requirements for a "municipal debtor"
in federal law under chapter 9 is contained in 11 U.S.C §
Section 109(c) and specifies the following:

First, an entity may be a debtor under Chapter 9 only if such
entity:

a) Is a municipality;

b) Is specifically authorized, in its capacity as a
municipality or by name, to be a debtor under such chapter
by state law, or by a governmental officer or organization
empowered by state law to authorize such entity to be a
debtor;

c) Is insolvent;

d) Desires to effect a plan to adjust such debts; and,

e) Has obtained the agreement of creditors holding at least
a majority in amount of the claims of each class that such
entity intends to impair under a plan in case under such
chapter:

i) Has negotiated in good faith with creditors and it
has obtained the agreement of creditors holding at least
a majority in amount of the claims of each class that the
municipality intends to impair under a plan of adjustment
of claims;









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ii) Is unable to negotiate with creditors because such
negotiation is impracticable; or,

iii) Reasonably believes that a creditor may attempt to
obtain a transfer that is avoidable under section 547 of
this title.

A municipality must meet all of these conditions for the
bankruptcy petition to be accepted by the court.

1)According to the U.S. Courts, "the purpose of Chapter 9 is to
provide a financially-distressed municipality protection from
its creditors while it develops and negotiates a plan for
adjusting its debts. Reorganization of the debts of a
municipality is typically accomplished either by extending
debt maturities, reducing the amount of principal or interest,
or refinancing the debt by obtaining a new loan."

Chapter 9 provides a municipal debtor with two primary
benefits: a) a breathing spell with the automatic stay; and,
b) the power to readjust debts through a bankruptcy plan
process. The process enables municipalities to continue to
provide essential public services while allowing them to
adjust their debts.

2)Federal law regarding municipal bankruptcy rose out of the
financial crises of the 1930s.
Chapter 9 federal law was created in 1934 and after several
revisions, was made a permanent part of the Bankruptcy Act in
1946, and incorporated into the new Bankruptcy Code in 1978.
In 1994, Congress amended the Bankruptcy Code to require that
municipalities be "specifically authorized" under state law to
file a petition under chapter 9 - this was an express
invitation to the states to revisit the types of local
agencies that could seek federal relief. SB 1323 (Ackerman),
Chapter 94, Statutes of 2002, sponsored by the California Law
Revision Commission (CLRC), accomplished this by bringing
state law in line with the "specific authorization" as
required under federal law.

CALIFORNIA'S RESPONSE TO CHAPTER 9

3)In response to the federal creation of Chapter 9, the
California Legislature enacted bankruptcy authorization for
municipalities in 1934. The general state statutes








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authorizing bankruptcy filings by local governments were
codified in 1949 and those provisions were not amended until
SB 1323 became law in 2002.

There were several attempts in the 1990s to streamline
California law with federal law requiring specific
authorization:

a) SB 1274 (Killea, 1995-1996) and AB X2 2 (Caldera,
1995-1996) would have granted the broadest authority
permissible under federal law by adopting the federal
definition of "municipality;"

b) AB X2 29 (Archie-Hudson, 1995-1996) would have provided
authority for a municipality as defined by federal law to
file "with specific statutory approval of the Legislature"
and required the plan for adjustment of debts under
Bankruptcy Code Section 941 to be "submitted to the
appropriate policy committees of the Legislature prior to
being submitted to the United States Bankruptcy Code;" and,

c) SB 349 (Kopp, 1995-1996) would have modernized the
obsolete references and adopted the "municipality"
definition language in federal law. The bill would have
established a Local Agency Bankruptcy Committee" to
determine whether to permit a municipality to file a
Chapter 9 petition, and the committee would have contained
the Treasurer, Controller and Director of Finance. The
bill passed the Legislature, but was vetoed by
then-Governor Wilson.

These bills were introduced mainly in response to the Orange
County bankruptcy filing in 1994. According to a study done
by the Public Policy Institute of California on the Orange
County bankruptcy, "the financial difficulties leading to the
bankruptcy were the direct result of an enormous gamble with
public funds taken by a county treasurer who was seriously
under-qualified to deal in the kinds of investments he chose."
At that time, Orange County and its investment pool - which
suffered nearly $1.7 billion in investment losses - filed for
bankruptcy protection on December 6 in two separate cases.
The bankruptcy judge ruled that only the county, and not the
investment pool, could file for bankruptcy.

The California Law Revision Commission (CLRC) studied








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California's municipal bankruptcy statute and released their
report in 2001. CLRC recommended that the Legislature revise
the state law to conform to the federal provisions and what
resulted was SB 1323 by Senator Ackerman. However, the CLRC's
report only suggested that California law be updated to
provide explicit authority for municipalities, per the federal
statute requiring states to have explicit authorization. The
report did not recommend any other substantive policy changes
or pre-conditions, or "gate-keeping" in order to access the
federal bankruptcy process, and instead, the report noted that
"there does not appear to be any general agreement on the best
approach to reform, or even as to the need for additional
protections or controls."

The California State Legislature has a long history, dating
back to the Orange County bankruptcy filing in 1994, of
debating access to federal municipal bankruptcy laws every few
years (see Comments under 3) and 4) above, and ultimately in
2002, made the decision to seek the broadest authority for
municipal bankruptcies that exists under federal law.

4)Currently, California state law authorizes federal bankruptcy
filing by a "local public entity" - "a county, city, district,
public authority, public agency, or other entity, without
limitation, that is a municipality as defined in paragraph
(40) of Section 101 of Title 11 of the United States Code, or
that qualifies as a debtor under any other federal bankruptcy
law applicable to local public entities". As referenced,
federal law defines "municipality" as a political subdivision
or public agency or instrumentality of a state (11 U.S.C. §
101 (40)). However, the California Law Revision Commission
notes that the definitions in state and federal law create
some ambiguity as to what exactly falls under the definition
of "municipality" and can therefore seek financial relief
through the Chapter 9 bankruptcy process.

There is some debate about how broad the definition of
"municipality" and "local public entity" is - it may be that
the definition includes anything from library districts,
parking districts, public cemetery districts, community
service districts and the like. The Legislature may wish to
discuss whether there is a legitimate statewide interest in
preventing these small local government entities from filing
for bankruptcy.









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BANKRUPTCY PRACTICES IN OTHER STATES

5)The 10th amendment to the United States Constitution says that
"the powers not delegated to the United States by the
Constitution, nor prohibited by it to the states, are reserved
to the states respectively, or to the people," otherwise known
as the sovereign rights of the states. In the context of
municipal bankruptcy filing, it is up to each state to decide
whether to empower its municipalities to utilize federal
bankruptcy laws.

Other states approach authorization for municipalities in
various ways - some explicitly authorize municipalities and
provide unlimited access, or explicitly authorize certain
types of municipalities, some states are silent, one state
expressly prohibits municipalities from filing, and yet others
have their own state pre-conditions, processes or
"gate-keeping" requirements.

Those states comparable to California in terms of population,
like Texas and Florida, provide explicit authorization for
municipalities in their state statutes. The state of New York
allows a municipality or its emergency financial control board
to file any petition within any United States district court
or court of bankruptcy and explicitly notes in the statute
that "nothing contained in this title shall be construed to
limit the authorization granted by this section İfor
municipalities to file a petition under federal bankruptcy
law]."

RECENT LEGISLATION

6)The Legislature saw two municipal bankruptcy bills in the
2009-10 legislative session,
AB 155 (Mendoza) and SB 88 (DeSaulnier), following on the heels
of the City of Vallejo bankruptcy filing in May of 2008. Both
bills would have prohibited a local public entity from
exercising its rights under applicable federal bankruptcy law
unless granted approval by CDIAC, and would have specified
procedures in which the local public entity could override a
decision of denial by CDIAC. AB 155 died on the Senate Third
Reading File and SB 88 was chaptered with other provisions not
relating to municipal bankruptcy.

7)For both AB 155 and SB 88, the authors argued that a municipal








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bankruptcy filing has repercussions in terms of credit rating
and spillover effects that will raise borrowing costs for
other California municipalities and the state. Arguably, a
municipal bankruptcy, depending on the size of the entity,
could potentially affect other local agencies and the state as
a whole.

PROPOSED LAW


8)AB 506 places conditions on how and when a municipality could
seek Chapter 9 relief under federal bankruptcy law. Current
law authorizes municipalities to file a petition under the
federal bankruptcy process without any prior state approval or
pre-conditions to filing. Instead of full and unfettered
access, this bill requires that a local government go through
a mediation process first, and that local government can only
file a petition for Chapter 9 if certain conditions are met.
First, the local public entity would need to participate in
mediation proceedings and receive a good faith certification
from the mediator. Second, the local public entity would need
to have one of the following happen: a) Reach an out-of-court
agreement with all interested parties regarding a plan of
adjustment; b) Be unable to reach an out-of-court agreement
but have the mediator certify that all parties acted in good
faith; or,
c) The local public entity would need to initiate the mediation
proceeding but have interested parties not participate in the
mediation.

The bill also prohibits a local public entity from filing a
petition for Chapter 9 if either of the following occurs: a)
The mediator determines that solvency or effective debt
restructuring can be achieved through settlement with all
interested parties and that a settlement can be reached
through further mediation; or b) The mediator determines that
a local public entity has failed to participate in good faith
mediation.

Additionally the bill requires CDIAC to administer the
mediation process and adopt guidelines for mediation. The
provisions of the bill allow a local public entity to initiate
a mediation when the local public entity is or is likely to
become unable to meet its financial obligations, and provides
that the mediation shall be conducted through an alternative
dispute resolution program within the state and in accordance








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with mediation guidelines adopted by CDIAC.
9)The author argues that the state has a vested interest in
protecting taxpayers from the effects of an ill-advised
bankruptcy and believes that this bill will help local public
entities and elected officials make the most responsible
decisions for the communities they represent. Additionally,
the author notes that "in the absence of clear standards or
oversight, local elected officials considering bankruptcy and
the communities impacted by such a bankruptcy have little
guidance about whether İthe bankruptcy] is merited or
necessary." The author argues that under current law, there
is nothing to prevent a frivolous bankruptcy petition or one
that is politically motivated.

10)In order for a bankruptcy petition to be accepted by the
court for a Chapter 9 filing, certain conditions must be met
by the local public entity (see Comment #1). The local public
entity must be insolvent, have the desire to effect a plan to
adjust debts, and must attempt to negotiate in good faith with
creditors, as long as such negotiation is not impracticable.
In situations where the local public entity has not met these
conditions, the court can reject the bankruptcy petition.

The Committee may wish to consider whether the bill's
mediation process is duplicative of what is already required
for local governments before they can file a bankruptcy
petition for Chapter 9 protection.

11)According to Judicial Arbitration and Mediation Services
(JAMS), "mediation" is defined as "a process wherein the
parties meet with a mutually selected impartial and neutral
person who assists them in the negotiation of their
differences." JAMS specifies the following about the role of
the mediator:

"Mediation leaves the decision power totally and strictly with
the parties. The mediator does not decide what is 'fair' or
'right,' does not assess blame nor render an opinion on the
merits or chances of success if the case were litigated.
Rather, the mediator acts as a catalyst between opposing
interests attempting to bring them together by defining issues
and eliminating obstacles to communication, while moderating
and guiding the process to avoid confrontation and ill will.
The mediator will, however, seek concessions from each side
during the mediation process."








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While this bill requires mediation for a local public entity
and interested parties in order to "assist all interested
parties in reaching an equitable settlement to avert a Chapter
9 filing," it is important to note that mediators are not
usually responsible for making determinations.

This bill, however, gives a mediator involved in bankruptcy
mediation the ability to determine if solvency or effective
debt restructuring can be achieved through settlement with all
interested parties. This bill also gives the mediator the
power to determine whether the mediator thinks a settlement
can be reached through further mediation. The Committee may
wish to consider whether the authority given to mediators
under the provisions of the bill is too far-reaching and
changes the typical role a mediator would play.

12)This bill treats all forms of local governments - cities,
counties, and special districts - the same, even though there
is wide variation among these entities and how they are
funded, the services they provide, and the different ways that
they function and are governed.


According to the Urban Counties Caucus (UCC), in opposition to
the bill, counties provide many mandated programs on behalf of
the state or federal government. UCC raises the point that
counties often have fiscal issues related to payment deferrals
or a lack of payments from the state or federal government.
In a situation where there is a court case, run on the bank,
or decreased payments from the state or federal government,
the provisions of the bill do not allow for the types of
emergency situations that could occur for counties.

According to the California Special Districts Association
(CSDA) and the Association of California Healthcare Districts
(ACHD), in opposition, special districts have never entered
Chapter 9 because of a disputed labor contract. Rather,
certain types of special districts, like healthcare districts,
have typically used Chapter 9 because of low Medi-Cal
reimbursements or a court judgment that the district could not
afford. In these situations, going through a mediation
process does not make sense and prohibits districts from being
granted the automatic stay protection under Chapter 9.









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The Committee may wish to consider whether these types of
situations for local governments warrant the inclusion of
emergency process provisions in the bill to allow local
governments to have access to the automatic stay of protection
under Chapter 9 in cases where mediation will have little to
no impact.

13)The bill's provisions are silent on the following issues.
The Committee may wish to ask the author:

1) Who will appoint the mediator?

2) Who will pay for mediation?

3) How long will the mediation process take?

4) What happens if the local public entity or other
stakeholders involved in the mediation process want to
request a different mediator?

1)As noted in Governor Wilson's veto of SB 349 (Kopp) in 1996,
state interference in municipal bankruptcy "could raise
questions of the liability of the state to creditors of the
public agency if eligibility for bankruptcy is denied. State
denial of access to Chapter 9 may create the implication that
the state has assumed responsibility for the debts of the
distressed municipality." The Committee may wish to consider
this bill creates some sort of unintended state liability.

2)The California Professional Firefighters, writes that the
"2008 bankruptcy filing by the City of Vallejo has only
serviced to further devastate a struggling community,
including local businesses that were already feeling the
adverse impact of a stagnant economy." As well, "Upon
İVallejo's bankruptcy filing] the city's bond interest rates
converted to their maximums and the city's filing claimed a
deficit of approximately $12 million, and Vallejo's litigation
costs have escalated to over $9.5 million, thereby further
encumbering an already dried-up general fund budget."


3)Support arguments: According to the California Labor
Federation, in support, "in the absence of clear standards or
oversight, local elected officials considering bankruptcy and
the communities impacted by such a bankruptcy have little








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guidance about whether it is merited or necessary."
Additionally, "the state has a vested interest in protecting
taxpayers from the effects of an ill-advised bankruptcy, and
all major creditors, workers, retirees, and investors have a
stake in reaching a fair resolution without resorting to
bankruptcy, as do local elected officials."

Opposition arguments: The California Chamber of Commerce, in
opposition, writes that the "business community's concern is
three-fold: Debts and contracts remain unpaid as the local
government entity simply will not function or is dissolved;
the local entity will raise fees, assessments and taxes on the
community's residents and businesses at a time when jobs need
to be created and the economy stimulated; the state - already
facing a cash crisis and budget deficit - steps in to take
over the provision of services, putting further strain on the
budget that other Californians and businesses will have to pay
for.

REGISTERED SUPPORT / OPPOSITION :

Support

California Labor Federation
California Nurses Association
California Professional Firefighters

Opposition

Association of California Healthcare Districts
California Chamber of Commerce
California Special Districts Association
California State Association of Counties
Howard Jarvis Taxpayers Association
League of California Cities
Regional Council of Rural Counties
Urban Counties Caucus

Analysis Prepared by
: Debbie Michel / L. GOV. / (916)
319-3958