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california legislation > AB 506

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SENATE GOVERNANCE & FINANCE COMMITTEE
Senator Lois Wolk, Chair


BILL NO: AB 506 HEARING: 7/6/11
AUTHOR: Wieckowski FISCAL: Yes
VERSION: 6/29/11 TAX LEVY: No
CONSULTANT: Weinberger

LOCAL GOVERNMENT BANKRUPTCY


Prohibits a local agency from petitioning for bankruptcy
protection unless it starts a neutral evaluation process
and meets other conditions.


Background and Existing Law

Federal bankruptcy law for public agencies (Chapter 9)
gives government debtors time to come up with repayment
plans, providing them a breathing spell from creditors'
collection efforts. Only a municipality, which federal law
defines as a political subdivision, public agency, or
instrumentality of a state, can initiate a Chapter 9
proceeding. The municipality must be insolvent and desire
to effect a plan to adjust its debts. To qualify as
insolvent, a municipality must demonstrate that it:
Has obtained the agreement of creditors holding
at least a majority of the amount of the claims of
each class that such entity intends to impair under
a plan in a case under Chapter 9; or ,
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; or ,
Is unable to negotiate with creditors because
negotiation is impracticable; or ,
Reasonably believes that a creditor may attempt
to obtain a transfer that is avoidable under federal
bankruptcy law.

Unlike private bankruptcy law (Chapter 11), municipal
bankruptcy law must respect the states' sovereign powers.
Consequently, the states can control their local agencies'
access to federal bankruptcy protection. Like 11 other
states, California grants its local public agencies the




AB 506 - 6/2911 -- Page 2



broadest possible access to federal bankruptcy available.
The state statutes broadly authorizing bankruptcy filings
by local governments were first enacted in 1939 (SB 338,
Phillips, 1939) and codified in 1949 (SB 768, Cunningham,
1949). In 2001, after studying the state statutes
authorizing bankruptcy filings by local public entities,
the California Law Revision Commission recommended
revisions to conform the statutes to changes in federal
bankruptcy law and to reaffirm the intent of the statute to
provide the broadest possible access to municipal debt
relief under federal law. Legislators approved the
Commission's recommendations the following year (SB 1323,
Ackerman, 2002).

Because one municipality's bankruptcy may have a negative
effect on other local governments' borrowing power, some
states limit or prohibit their local governments to access
federal protections. Local governments in 22 states do not
have access to municipal bankruptcy, while 16 other states
impose some conditions on municipal bankruptcy filings.
The conditions imposed by other states range from a
requirement that a local entity's legislative body must
pass an ordinance or resolution before filing for
bankruptcy to a requirement that a state commission grant
approval before a local government may file for bankruptcy.

After the 1994 Orange County bankruptcy, the Legislature
tried to establish state oversight for municipal bankruptcy
filings. The bill passed, but Governor Pete Wilson vetoed
it (SB 349, Kopp, 1996). The Law Revision Commission's
2001 study also considered proposals to require prefiling
approval by the Governor or a governmental committee, but
did not recommend any substantive reforms. Last year, AB
155 (Mendoza, 2010) would have required either the approval
of a state commission or the completion of a state audit
before a local public entity could file for bankruptcy.
That bill died on the Senate Floor.

The California Debt and Investment Advisory Commission
provides information, education, and technical assistance
on debt issuance and public fund investments to local
public agencies. The Bureau of State Audits conducts
performance, financial, and compliance audits that are
either mandated by statute or requested by the Legislature
through the Joint Legislative Audit Committee. Information
relating to any audit conducted by the Bureau of State





AB 506 - 6/2911 -- Page 3



Audits cannot be released to the public until the audit is
completed.

In 2008, the City of Vallejo filed a Chapter 9 bankruptcy
petition. The City subsequently asked the bankruptcy court
for permission to reject collective bargaining agreements
with four unions representing city employees. After more
than three years, Vallejo remains under the bankruptcy
court's protection, although it may emerge from bankruptcy
soon.

In response to the length, cost, and consequences of
Vallejo's bankruptcy and the potential for additional
municipal bankruptcy filings, labor unions and others want
local officials to participate in a neutral alternative
dispute resolution process before filing for bankruptcy.






Proposed Law
Assembly Bill 506 prohibits a local public entity from
filing a petition and exercising powers under federal
bankruptcy law unless it participates in a neutral
evaluation process, and meets certain conditions.

I. Requirements for seeking bankruptcy protection .
Specifically, AB 506 prohibits a local public entity from
filing for bankruptcy protection unless it participates in
a neutral evaluation process, receives a good faith
certification from the neutral evaluator, and:
Reaches an out-of-court agreement with all
interested parties regarding a plan of adjustment; or ,
Is unable to reach an out-of-court agreement and
the neutral evaluator certifies in writing that the
parties have participated in the neutral evaluation
process in good faith; or ,
Interested parties did not participate in the
neutral evaluation process.

AB 506 prohibits a local public entity from filing a
petition and exercising powers under federal bankruptcy law
if the neutral evaluator determines that the local entity
failed to participate in the neutral evaluation process in





AB 506 - 6/2911 -- Page 4



good faith. Failure to participate in good faith includes
the failure to provide accurate and essential financial
information, the failure to attempt to reach settlement
with all interested parties to avert bankruptcy, or
evidence of manipulation to delay and obstruct a timely
agreement. See 3 of the bill.]

Alternatively, AB 506 allows a local public entity to file
a petition and exercise powers under federal bankruptcy
laws if:
The State Auditor determines that the local public
entity is insolvent, as defined in federal law; and ,
The local public entity has been participating in a
neutral evaluation with interested parties for at
least 90 days.
ݧ12]

For these purposes, AB 506 states that the term "local
public entity" does not include a school district. ݧ3]


II. Neutral evaluation process . When a local public
entity is or likely will become unable to meet its
financial obligations when those obligations are due or
become due, AB 506 allows a local public entity to initiate
a neutral evaluation process. The neutral evaluation must
be conducted through an alternative dispute resolution
program within the state and in accordance with state law.
ݧ5]

AB 506 requires each interested party to provide at least
one representative to attend all neutral evaluation
conferences. Each party's representative must have
authority to settle and resolve disputes or be in a
position to present any proposed settlement or plan of
readjustment to the governing body or membership for
approval and implementation. The local public entity must
provide a representative who must represent the local
public entity's interest and who must be in a position to
propose any settlement or plan of readjustment to the local
public entity's governing body. AB 506 allows an
interested party to be represented by legal counsel, but
requires it to inform all parties of the representation.
ݧ9]

AB 506 requires the parties to maintain the confidentiality





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of the neutral evaluation process and prohibits them from
disclosing statements made, information disclosed, or
documents prepared or produced, during the neutral
evaluation process unless all parties consent in writing to
the disclosure. The confidentiality requirement does not
apply to documents that were not confidential before the
start of the neutral evaluation process. ݧ9]

AB 506 requires the parties to a neutral evaluation process
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 neutral
evaluator. The neutral evaluator may request the
submission or exchange of memoranda on issues, including
the underlying interests, and the history of the parties'
prior negotiations. Information that a party wishes to
keep confidential may be sent to the neutral evaluator in a
separate communication clearly marked "CONFIDENTIAL." ݧ8]

AB 506 requires the neutral evaluation process to end if:
The parties execute an agreement of settlement.
The parties reach an agreement or proposed plan
of readjustment that requires the approval of a
bankruptcy judge.
The neutral evaluator certifies that one or
more of the parties has not participated in good
faith, that no resolution has been reached, and that
further efforts at the neutral evaluation process
would not contribute to a resolution of the parties'
dispute.
The neutral evaluator certifies that the
parties have participated in good faith, but the
parties have reached an impasse and further efforts
at the neutral evaluation process would not
contribute to a resolution of disputes.
The neutral evaluator certifies that a neutral
evaluation was initiated by the local public entity
but that no interested parties participated.
ݧ10]


III. Neutral evaluator selection and removal . AB 506
requires the parties to a neutral evaluation process to
select a neutral evaluator through a mutually agreed upon
process. If at any time during the neutral evaluation





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process, the public entity and a majority of interested
parties wish to have the neutral evaluator replaced, AB 506
allows the public entity or a member of the interested
parties to request that the neutral evaluator be removed.
If the public entity and the majority of the interested
parties agree that the neutral evaluator should be removed,
then a new neutral evaluator must be selected in a mutually
agreed upon selection process. ݧ7]

If a neutral evaluator is informed of the existence of any
facts that a reasonable individual would consider likely to
create a potential or actual conflict of interest, AB 506
requires the neutral evaluator to disclose those facts to
the local public entity and all interested parties involved
in the neutral evaluation. If any party to the neutral
evaluation objects to the neutral evaluator, that party
must notify all other parties, including the neutral
evaluator, within 15 days of receiving the notice from the
neutral evaluator. The neutral evaluator must withdraw and
a new neutral evaluator must be selected. ݧ6]


IV. Neutral evaluator requirements . AB 506 requires a
neutral evaluator to oversee the neutral evaluation
process, and facilitate the following requirements:
The local public entity must completely disclose of
all documentation necessary to clearly demonstrate
whether the local public entity is solvent, including
financial reports, expenditures, assets, and any other
relevant documentation.
The local public entity and any interested party
must present information to each other, including the
status of funds of the local public entity that
clearly distinguishes between general funds and
special funds.
The local public entity and any interested party
must present its proposed plan of readjustment.
The local public entity and any interested party
must negotiate in good faith.
ݧ4]

AB 506 requires a neutral evaluator to assist all
interested parties in reaching an equitable settlement to
avert a Chapter 9 filing. The neutral evaluator must also
assist the parties in identifying the anticipated legal
costs associated with a Chapter 9 filing relative to the





AB 506 - 6/2911 -- Page 7



local public entity's budget shortfall. The neutral
evaluator may consult with alternate dispute resolution
service providers, the California Debt and Investment
Advisory Commission, the California State Mediation and
Conciliation Service, the Executive Office for U.S.
Trustees, retired bankruptcy judges, or other appropriate
entities in establishing and administering the neutral
evaluation regarding issues that are not confidential. ݧ5]

AB 506 requires the California Debt and Investment Advisory
Commission, when requested by a local public agency or a
neutral evaluator, to serve as a neutral third party to
provide technical assistance in any neutral evaluation
process conducted pursuant to state law governing municipal
bankruptcy. ݧ2]

AB 506 requires a neutral evaluator to meet all of the
following qualifications:
At least 10 years of high level business or legal
practice involving bankruptcy.
Experience and training in conflict resolution and
alternative dispute resolution.
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 law, and municipal finance dispute
resolution, provided through an alternative dispute
resolution program within the state.
ݧ6]

AB 506 provides that a neutral evaluator:
Must be impartial, objective, independent, and
free from prejudice.
May not act with partiality or prejudice based
on any participant's personal characteristics,
background, values or beliefs, or performance during
the neutral evaluation process.
Must avoid a conflict of interest or the
appearance of a conflict of interest during the
neutral evaluation process and must 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.
May not, before the neutral evaluation process,





AB 506 - 6/2911 -- Page 8



establish another relationship with any of the
parties in a manner that would raise questions about
the integrity of the neutral evaluation, except that
the neutral evaluator may conduct further neutral
evaluations regarding other potential local public
entities that may involve some of the same or
similar constituents to a prior mediation.
Must conduct the neutral evaluation process in
a manner that promotes voluntary, uncoerced
decisionmaking in which each party makes free and
informed choices regarding the process and outcome.
May not impose a settlement on the parties.
Must use his or her best efforts to assist the
parties to reach a satisfactory resolution of their
disputes. The neutral evaluator may make oral or
written recommendations for settlement or plan of
readjustment to a party privately or to all parties
jointly.
Must instruct and inform the local public
entity and all parties of the limitations of Chapter
9 relative to other chapters of the bankruptcy
codes. This instruction must 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.
May request documentation and other information
from the parties that the neutral evaluator believes
may be helpful in assisting the parties to address
the obligations between them.
Must provide counsel and guidance to all
parties and is prohibited from being a legal
representative of any party or having a fiduciary
duty to any party.
Must maintain the confidentiality of all the
information he or she obtained in the neutral
evaluation process, unless otherwise agreed to by
the parties.
ݧ6]

If a complete settlement of all or some issues in dispute
is not achieved within the scheduled neutral evaluation
sessions, the neutral evaluator may continue to communicate
with the parties in an ongoing effort to facilitate a





AB 506 - 6/2911 -- Page 9



complete settlement in order to avoid a Chapter 9 filing.
ݧ6]

In the event of a settlement with all interested parties,
the neutral evaluator may assist the parties in negotiating
a prepetition, preagreed plan of readjustment in connection
with a potential Chapter 9 filing. ݧ6]


V. Confidentiality requirements . AB 506 requires the
neutral evaluation process to meet extensive
confidentiality requirements. ݧ13] Specifically, the bill
requires that:
No evidence of anything said or any admission made
for the purpose of, in the course of, or pursuant to,
a neutral evaluation is admissible or subject to
discovery, and disclosure of the evidence cannot be
compelled, in any arbitration, administrative
adjudication, civil action, or other noncriminal
proceeding in which testimony can be compelled to be
given.
No writing, as defined in state law, that is
prepared for the purpose of, in the course of, or
pursuant to a neutral evaluation is admissible or
subject to discovery, and disclosure of the writing
cannot be compelled, in any arbitration,
administrative adjudication, civil action, or other
noncriminal proceeding in which testimony can be
compelled to be given.
All communications, negotiations, or settlement
discussions by and between participants in the course
of a neutral evaluation must remain confidential.
Evidence otherwise admissible or subject to
discovery outside of a neutral evaluation cannot be
inadmissible or protected from disclosure solely by
reason of its introduction or use in a neutral
evaluation.
Neither a neutral evaluator nor anyone else may
submit to a court or other adjudicative body, and a
court or other adjudicative body may not consider, any
report, assessment, evaluation, recommendation, or
finding of any kind by the neutral evaluator
concerning a neutral evaluation conducted by the
neutral evaluator, unless the information is deemed
necessary by a judge presiding over a Chapter 9
bankruptcy proceeding to determine eligibility of a





AB 506 - 6/2911 -- Page 10



municipality to proceed with a Chapter 9 case or
unless all parties to the neutral evaluation expressly
agree otherwise.
A communication or a writing, as defined in state
law, that is made or prepared for the purpose of, or
in the course of, or pursuant to a neutral evaluation
is not made inadmissible, or protected from
disclosure, by provisions of this chapter if either:
o All persons who conduct or otherwise
participate in the neutral evaluation expressly
agree in writing, or orally, to disclosure of the
communication, document, or writing.
o The communication, document, or writing
was prepared by or on behalf of fewer than all
the neutral evaluation participants, those
participants expressly agree to its disclosure,
and the communication, document, or writing does
not disclose anything said or done or any
admission made in the course of the neutral
evaluation.
A written settlement agreement prepared in the
course of, or pursuant to, a neutral evaluation, is
not made inadmissible, or protected from disclosure,
if the agreement is signed by the settling parties and
any of the following conditions are satisfied:
o The agreement provides that it is
admissible or subject to disclosure, or words to
that effect.
o The agreement provides that it is
enforceable or binding or words to that effect.
o All parties to the agreement expressly
agree to its disclosure.
o The agreement is used to show fraud,
duress, or illegality that is relevant to an
issue in dispute.
An oral agreement made in the course of, or
pursuant to, a neutral evaluator is not made
inadmissible, or protected from disclosure, if any of
the following conditions are satisfied:
o The oral agreement is recorded by a court
reporter or reliable means of audio recording.
o The terms of the oral agreement are
recited on the record in the presence of the
parties and the mediator, and the parties express
on the record that they agree to the terms
recited.





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o The parties to the oral agreement
expressly state on the record that the agreement
is enforceable or binding, or words to that
effect.
o The recording is reduced to writing and
the writing is signed by the parties within 72
hours after it is recorded.
o The agreement is used to show fraud,
duress, or illegality that is relevant to an
issue in dispute.
Anything said, any admission made, or any writing
that is inadmissible, protected from disclosure, and
confidential before a neutral evaluation ends, must
remain inadmissible, protected from disclosure, and
confidential to the same extent after the neutral
evaluation ends.
If a person subpoenas or otherwise seeks to compel
a neutral evaluator to testify or produce a writing,
as defined in state law, and the court or other
adjudicative body determines that the testimony or
writing is inadmissible under this section, or
protected from disclosure under this section, the
court or adjudicative body making the determination
must award reasonable attorney's fees and costs to the
neutral evaluator against the person seeking the
testimony or writing.
Any reference to a neutral evaluation during any
subsequent trial is an irregularity in the proceedings
of the trial for the purposes of state law. Any
reference to a neutral evaluation during any other
subsequent noncriminal proceeding is grounds for
vacating or modifying the decision in that proceeding
and granting a new or further hearing on all or part
of the issues, if the reference materially affected
the substantial rights of the party requesting relief.


VI. State Auditor . After a local entity has initiated the
neutral evaluation process, to help ensure that a local
public entity meets the insolvency requirement in federal
law and to assist the local entity and the interested
parties in the neutral evaluation process, AB 506
authorizes a local public entity to submit information to
the State Auditor describing the public entity's current
financial position, including analyses of:
The local public entity's revenues and estimated





AB 506 - 6/2911 -- Page 12



revenues for the relevant time period.
The local public entity's anticipated ongoing
expenses.
The local public entity's proposed plan for
restoring the soundness of the local public entity's
financial position if they have one.
An itemized list of creditors that may be impaired
or may seek damages as a result of the proposed plan.
Any additional information the auditor deems
necessary to complete the audit in a timely manner.
ݧ13]

The State Auditor must audit the analyses and financial
position of the local public entity and must work with the
local public entity to establish a deadline for the audit
work. AB 506 requires that this audit must take precedent
over any pending audit requested by the Joint Legislative
Audit Committee. The auditor's report must become public
at the time of filing for bankruptcy or prior to filing, at
the public entity's discretion. ݧ13]

AB 506 requires, if a local public entity requests an
audit, that the State Controller must transfer sufficient
funds from the General Fund to the State Auditor to
reimburse the State Auditor for the audit activities. The
State Controller must use General Fund revenues that are
payable to the state from local public entities during the
fiscal year in which the audit is performed. AB 506
specifies that it does not create an additional fiscal
obligation to the local public entity. ݧ13]

AB 506 contains legislative findings declaring that the
duties of the State Auditor that arise under the bill's
provisions must be initially funded from the State Audit
Fund, pursuant to state law, which meets the requirements
of specified Legislative Joint Rules. ݧ15]

VII. Definitions . AB 506 defines numerous terms used in
the bill. ݧ14]


VIII. Findings and declarations . AB 506 contains
extensive legislative findings and declarations supporting
the need to establish a neutral evaluation process for
municipalities in fiscal distress. ݧ1] As
constitutionally required by Proposition 59 (2004), AB 506





AB 506 - 6/2911 -- Page 13



also includes legislative findings and declarations
regarding the necessity of maintaining the confidentiality
of neutral evaluation proceedings. ݧ16]


State Revenue Impact

No estimate.


Comments

1. Purpose of the bill . Because local and state finances
are inextricably linked, the state has a direct interest in
the fiscal health of its local governments. A municipal
bankruptcy can have statewide repercussions, including
higher borrowing costs for other local entities and the
state. The state also has a compelling interest in
ensuring the validity and enforceability of contracts
negotiated through the collective bargaining process, which
forms the foundation for positive and stable labor
relations. These state interests justify a state role in
prescribing conditions under which local entities may seek
Chapter 9 protection. The neutral evaluation authorized by
AB 506 helps local officials find alternative strategies to
address short-term fiscal challenges in ways that avoid the
broad and lasting spillover effects of municipal
bankruptcy. By providing an opportunity for good faith
negotiation over a restructuring plan, the neutral
evaluation process expedites the Chapter 9 process for
local entities that eventually file for bankruptcy. AB
506's state audit process produces an independent and
public assessment of a local entity's financial position,
which may either support the local entity's bankruptcy
claim or identify alternatives to bankruptcy. AB 506
offers municipalities facing financial distress a faster,
cheaper, better alternative to the path recently taken by
Vallejo and protects the interests of a broad coalition of
stakeholders who are affected by municipal bankruptcies.

2. Local control . By imposing conditions on a local
officials' access to bankruptcy protection, AB 506
critically undermines their discretion in responding to
fiscal crises. Local elected officials are directly
accountable to residents within communities affected by a
municipal bankruptcy. As a result, a decision to enter





AB 506 - 6/2911 -- Page 14



bankruptcy is a last resort that those officials do not
take lightly. High legal costs, damaged credit ratings,
and a lasting stigma that can deter investment and growth
in a community all weigh heavily against a decision to
petition for bankruptcy protection. The principal benefit
of federal bankruptcy is the automatic stay of financial
obligations which allows a local entity some breathing
space to formulate a debt readjustment plan that is
consistent with the fiscal interests and priorities of the
local community. The neutral evaluation process and
optional audit process proposed by AB 506 could delay a
local government's ability to obtain protection under the
stay of financial obligations. The Committee may wish to
consider whether AB 506 is an unjustified state intrusion
into local affairs.

3. What's changed ? Local officials have used municipal
bankruptcy protection sparingly during the 70 years that it
has been available to local public entities in California.
Only three general purpose governments have filed for
municipal bankruptcy protection: Orange County (1994), the
City of Desert Hot Springs (2001), and the City of Vallejo
(2008). Since 1991, 24 local public entities have filed
for bankruptcy; more than half were small health care
districts. This recent average of fewer than two municipal
bankruptcy filings per year from among the thousands of
local public entities in California may reflect the
substantial, inherent disadvantages of resorting to
bankruptcy. Despite the Great Recession and additional
state-imposed burdens on local finances, the Sierra Kings
Health Care District is the only California local
government that has filed for bankruptcy protection in the
three years since Vallejo entered bankruptcy. Vallejo's
experience may serve as a cautionary example, encouraging
fiscally distressed local governments to find alternative
approaches to fiscal restructuring. The Committee may wish
to consider whether the recent frequency and purpose of
municipal bankruptcy filings justify the changes that AB
506 makes to the state's long-standing municipal bankruptcy
statute.

4. What happens next ? It is unclear what might happen if
a local entity that is participating in a neutral
evaluation process becomes unable to pay its obligations
before the process is completed. As mentioned in Governor
Wilson's veto of the 1996 Kopp bill, some opponents of





AB 506 - 6/2911 -- Page 15



state oversight of municipal bankruptcy argue that a denial
of eligibility for bankruptcy "could raise questions of
liability of the state to creditors of the public agency."
However, there is no evidence that this theoretical concern
has become a problem in the other states that block access
to municipal bankruptcy. Regardless of whether the state
may incur legal liability, it may face heightened political
pressure to provide fiscal assistance to a local entity
that can't seek bankruptcy protection because it has not
completed the neutral evaluation process. Legislators may
feel obligated to intervene to ensure that an insolvent
county, city, or district doesn't stop providing vital
public services. The Committee may wish to consider
whether the conditions imposed by AB 506 to protect limited
state interests could result in expanded state obligations
to struggling local entities.


Assembly Actions

Assembly Local Government Committee: 5-3
Assembly Appropriations Committee: 12-5
Assembly Floor: 48-27


Support and Opposition (6/30/11)

Support : California Professional Firefighters; California
Conference Board of The Amalgamated Transit Union;
California Conference of Machinists; California Dispute
Resolution Council; California Labor Federation; California
Official Court Reporters Association; California Nurses
Association; California Teamsters Public Affairs Council;
Estero Municipal Improvement District; International
Longshore and Warehouse Union; Police Officers Research
Association of California; Professional and Technical
Engineers; IFPTE Local 21; United Food and Commercial
Workers Region 8 States Council; Unite Here!; Utility
Workers Union of America, Local 132.

Opposition : Association of California Healthcare
Districts; California Chamber of Commerce; California
Contract Cities Association; California Special Districts
Association; California State Association of Counties;
Howard Jarvis Taxpayers Association; League of California
Cities; Long Beach Area Chamber of Commerce; Los Angeles





AB 506 - 6/2911 -- Page 16



County Business Federation; Marin County Council of Mayors
and Councilmembers; Regional Council of Rural Counties;
Urban Counties Caucus.
Cities of: American Canyon; Antioch; Apple Valley;
Atherton; Azusa; Bellflower; Beverly Hills; Burlingame;
Campbell; Ceres; Clayton; Cloverdale; Culver City;
Danville; Diamond Bar; Encinitas; Fontana; Foster City;
Fountain Valley; Fresno; Goleta; Gustine; Half Moon Bay;
Healdsburg; Hermosa Beach; Highland; Huron; Lakewood;
Lathrop; Livingston; Lodi; Long Beach; Los Altos Hills;
Madera; Merced; Monterey Park; Moreno Valley; Mountain
View; Murrieta; Newman; Norwalk; Pasadena; Pinole;
Placentia; Rancho Cucamonga; Red Bluff; Redding; Redwood
City; Santa Clara; Santa Rosa; Signal Hill; South San
Francisco; Stockton; Sunnyvale; Tracy; Tulare; Upland;
Vista; Wasco; West Hollywood; Whittier; Yucaipa.
Counties of: Monterey; Orange; Sacramento; Santa
Clara.