HomeMy WebLinkAboutstewardshipDecember 9, 2010
Members of the
Butte County Board of Supervisors
25 County Center Drive
Oroville, CA 95965
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Stewardship
COUCICI~
Dear Honorable Members of the Board ,
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The Pacific Forest and Watershed Lands Stewardship Council {Stewardship Council) is a private,
nonprofit foundation responsible far overseeing the development and implementation of a plan for the
permanent protection of aver 140,000 acres of watershed lands currently owned by Pacific Gas and
Electric (PG&E} and located`in 22 different counties in California.
The Stewardship Counci[ anticipates recommending the donation of a substantial portion ofi these
watershed lands to public entities or qualified non-profit conservation organizations subject to the
requirements of the PG&E Settlement Agreementand Stipulation that established the Stewardship
Council. One of these requirements is that the totality of dispositions in each affected county be "tax
neutral." with respect to property faxes.
To facilitate the achievement of tax neutrality, the Stewardship Council has prepared draft guidelines
that establish a standard methodology for addressing property tax neutrality on the watershed lands,
and communicate the general principles and approach regarding the achievement of property tax
neutrality. On December 2, 2010, the Stewardship Counci[ Board of Directors requested that staff issue
these draft guidelines far public review and comment.
Accordingly, we would greatly appreciate your county's review and comment on these draft guidelines.
A copy ofi these draft guidelines is enclosed, and can also be found, along with additional information
about the Stewardship Council's Land Conservation Commitment, on our website at
www.st~wardshipcouncil.arcl.
To comment on the draft guidelines, please send us your comments electronically or by regular mail no
later than January 31, 2D11. Please send all a-mails pertaining fo this matter to the following address:
comments3Ca7_stewardshipcouricil.org.
Thank you for your time and interest.
Sincerely,
J ~ el Wagner
~irector of Finance
Enclosure
I5 N. Ellsworth Avenue
Suite 140
G 5~ ateo, C~,
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Phone (650 344 9072
Fox (650) 401 2140
www. stewardshipcouncil.org
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Council
GUIDELINES FOR ACHIEVING PROPERTY TAX NEUTRALITY
FOR PUBtlC REVIFWAND COMMENT
INTRODUCT[ON
The Settlement Agreement) and Stipulation2 that established the Land:Conservation
Commitment require that the Land Conservation Plan being developed by the Stewardship
Council provide property tax revenue, other equivalent revenue source,, or a lump sum payment,
so that the totality of dispositions in each affected county will:be "tax neutral" for each county.
Section 4.3 of Volume I of the Land Conservation Plan (~LCP) adopted b~-the Stewardship
Council in November 2007 described the Stewardship Council's potential strategies and
anticipated approach to achieving property tax neutrality at a programmatic level;;..
More recently, on September 17, 2009, the Stewardslup`Council adopted a funding policy. This
policy further clarified the Stewardship Council's approach to property tax neutrality and
identified the following potential vehicles to achieving this rEquirement:
• Voluntary payment of property taxes by the new landowner:.
• Lump-sum payment in satisfaction `of future tax revenues
• Establishment of an endowment to fund a negotiated share of annual payments
• Other in-lieu carnpens,ation as negotiated by tfie parties
• Payment by PG&E:per theterms articulated in the Stipulation
• Other consideration or benefit as negotiated by the parties
BACKGROUND. _ ___.
The watershed lands identified ~n tlie',Land.Canservatian Caznrnitment are subject to a valuation
process conducted by the California'StateBoord of Equalization (SBE), rather than local county
assessors. The SBE sets the taxation value of alI property owned or used by public utilities.
Utility awned property is reassessed by the SBE every four years; therefore, the lands owned by
PG&E are generally at or near their current market value.3
In California, property taxes are allocated among several different agencies and districts
according to the subject"-property's Tax Rate Area (TRA). Typically, only a portion of the annual
tax payments go to the county general fund, with the majority of taxes distributed to the county's
~ Opinion Mod~ing the Proposed Settlement Agreement of Pacific Gas & Electric Company, PGc~rE' Corporation
and the Commission Staff, and Approving the Modified Settlement Agreement, December 18, 2003:
http: //tivww. stewardshipcouncil. org/documents/Settlement_ 4 ~reement. pdf
z Stipulation Resolving Issues Regarding the Land Conservation Commitment, September 25, 2003:
httn://www.stewardshipcourrcil.org/documents/Stipulation flQreement.odf
3 Stewardship Council Land Conservation Plan, November 28, 2007
DRAFT Guidelines For Achieving
Property Tax Neutrality Page 1 of 6 9?J13/2090
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special districts (e.g., water and fire districts, school districts, libraries, and resource conservation
districts).
The SBE classifies real property owned by public utilities as either "unitary" or "non-unitary."
Unitary property is defined as property necessary for an assessee's primary function. Non-
unitaryproperty is property awned by the assessee, but not used as part of its primary function.
The SBE generally assesses both unitary and non-unitary land using typical appraisal methods,
such as comparable sales.
PG&E is expected to retain the majority of lands and improvements' necessary for the future
generation of power (i.e., unitary property). However, in some instances, PG&E may donate
lands classified as unitary. Table 1 below lists the acreage and'annual'taxes for the watershed
lands by county as presented in Volume T of the LCP. The`estiiriated total:tax;~iability that would
be subject to tax neutrality will depend upon the total acreage transferred, and-the types of
organization receiving lands.
Table 1 -Property Taxes From Land Available for Donation3
_Codnty - Lands•
Available #o~
Donation Unitary
~ faxes
~ (Annual) ~ Non Unitary
Taxes
Annual Total-Taxes
(Anndal
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AI ine 1,028 , $21;000 € $11,300 !' $32,300
Arnador 2,851 $'f:8,000 °$23,100
_^ .: $41,100
Butte 6,843 $49;700, $23;7,00';. ' $65,400
Calaveras _ , 1 ~ $1,900'- $300 $2,200
EI Dorado ~..:,<:,;.9 $1,10U:. $0 $1,100
Fresno 335 $17,200; $8,300 $25,500
Kern .443 $1,500 $0 $1,500
Lake 3;390 '"$37,OOQ;; ' $2,500 $39,500
Lassen 1 $33;800 $0 $33,800
Madera ~ ~- 70. $62,500 $116,600 $179,100
Mariposa ~ 0 <:;.' $100 $0 $100
Mendocino 1,823 ';;:` $25,000 $200 $25,200
Merced::::.. D $400 $D $400
Nevada`? " 4,095 $34,800 $41,600 $76,400
Placer ~ 4,693 $106,600 $176,800 $283,400
Plumas 5,329 $278,200 $98,300 $376,500
San Luis Obispo` .;~ `' 654 $D $2,800 $2,800
Shasta 37,127 $107,900 $138,500 $246,400
Tehama 1,412 $3,300 $7,600 $10,900
Tulare 29 $500 $2,000 $2,500
Tuolumne 1,337 $4,800 $16,900 ~ $21,700
Yuba ~ 59 $D $200 $200
Others 2,431
Total 74,593 $797,300 $670,700 $1,468,000
a This acreage includes lands within parcels that cross county boundaries
DRAFT Guidelines For Achieving
Property Tax Neutrality Page Z of G 12/13/2070
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PURPOSE OF PR~PQSED
GUIDELINES
The purpose of these guidelines is to establish a standard methodology for addressing property
tax neutrality an lands located across 22 affected counties that are subject to the Land
Conservation Commitment; and to communicate the general principles and approach regarding
the achievement of property tax neutrality.
Tlie Stewardship Council is seeking public input on the proposed`-guidelines from affected
counties, special districts, and other interested stakeholders. -
Following the completion of these guidelines, the Stew. air"dsl~uip' Council will develop a more
specific methodology concerning other elements of property tax neutrality such:as: ,.
• Determination of allocations between counties and'special, drstricts
• Disbursement of funds after settlement amounts are calculated
• Subsequent changes in property tax allocations and effects; oa:the Stewardship Council's tax
neutrality payments
• Effects of inflation and future appreciation of value on property tax'neutrality payments
OVERARCHING ASSUMPTI(}NS
These guidelines are .based on tlxe ~'flllowing three overarching assumptions:
L Compensation for property taxes will be based on the current property faxes as paid by PG&E
of the time of transfer.
The Stewardship Council will address property tax neutrality based upon the most current
property taxes paid by PG&E on tlielands being transferred at the time of the actual transfer of
fee titli;`from PG&E to the selected donee.
Due to the uncertain nature of timber harvests and similar activities, the Stewardship Council's
commitment to`the:achievement of property tax neutrality does not extend to timber yield tax or
any other taxes associated with the conversion of natural resources to revenues by the future
landowner.
11. Property tax neufalify includes all property faxes assessed by fhe State Board of Egualizafion
and disfributed between the affected county and special disfricfs
The property taxes paid to counties are distributed among multiple agencies, including County
General Funds, School and Fire Districts, Regional Conservation and Water Districts, and other
special districts.
DRAFT Guidelines FwAchieving .
Property Tax Neutrality Page 3 of 6 12/13/2010
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The Stewardship Council's achievement of property tax neutrality applies to all property taxes
that would be distributed directly to County General Funds; School and Fire Districts, Regional
Conservation and Water Districts, and any other special districts as defined by the applicable Tax
Rate Area.
!!!. The Stewardship Councr"!'s tax neufrality commitment extends only to property tax revenues
that remain with locally contro!!ed entitles.
The Settlement and Stipulation direct the Stewardship Council to ensure that the effects of
distributions be made tax neutral for the affected counties. Therefore, the Stewardship Council's
property tax neutrality commitment will not apply to any portion `ofproperty tax payments that
are subject to apportionment by the State of California.
OPTIONS FOR FUNDING PROPERTY TAX NEUTRALITY PAYMENTS
The Stewardship Council is currently considering two options for making tax neutrality..
payments: (1) a one-time lump-sum payment; or {2) fuaiding of a~,.independent tn~st+re to
continue annual payments in lieu of taxes.
Lump-sum payments
Lump-sum payments in satisfaction of property tax neutrality would be calculated based upon
the net present value of the current taxes as.,paid by PG&E at the tirn~ fihat lands are removed
from the property tax rolls. The lump-sum pa~~aient would be calculated based upon the mast
current assessed value and tax rate at the time of property transfer: The discount rate would be
based upon reasonable rates of interest for long-term assets and liabilities.
Lump-sum paymentfi tiyould be allocated based upon the applicable Tax Rate Area at the time of
payment. The Stewai'dslup Council envisions makmg,these lump-sum payments as unrestricted
payments in lieu of property taxes. Counties and special districts vsrould be free to determine the
best use of the finds pursuant to tl~c needs;.of the county or special district.
Annual payments
The,$tewardship Council is researching the feasibility ofestablishing athird-party managed
endowment. account to makeannual payments to affected counties and special districts in lieu of
property taxes on donated lands. The endowment amount would be calculated based upon the net
present value of:tfie,current taxes as paid by PG&E at the time that lands are removed from the
property tax rolls; net of the, trustee's management and administrative fees.
As envisioned, annual'-payments out of the endowment account would be calculated as a
percentage of the account's value based upon a rolling average to be determined upon the
selection of an endowment manager. Please note, under this approach annual payments maybe
higher than the original tax payments in some years, and lower in others. Annual payments from
the trustee would be unrestricted.
DRAFT Gurdeiines ForAchieving
Property Tax Neutrality Fage 4 of 8 12/13/2010
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ACCEPTANCE OF PROPERTY TAX NEUTRALITY PAYMENTS
Prior to the disbursement of funding of property tax neutrality the Stewardship Council will ask
affected counties and special districts to execute an agreement stipulating that the Stewardship
Council's property tax neutrality has been fulfilled for each transaction. The Stewardship
Council will work with affected counties and special districts to determine the exact form of
acceptance that is acceptable to both parties.
PROPOSED GUIDELINES BY DONATION SCENARIO
The proposed guidelines described below are organized and presented'nndEr four different land
donation scenarios: donation oflands to counties, state agencies; federal agencies, and Native
American tribes and other tax-exempt organizations.
The Stewardship Council expects that any intended payments foie property tax neutrality will be a
consideration in the selection of donees for lands and in the development of transactional terms
related to the preservation and enhancement of beneficial public values.
SATISFACTION OF TAX NEUTRALITY WHEN LANDS ARE TRANSF~RRED.TO COUNTIES
Transfer of lands with no associated revenues:
• The value of the land interests donated will be considered "in lieu" payment of the
county's share ofproperty_,,taxes on the affected parcel;
• The Stewardship Council will .pay 1.00%`Of property tax neutrality related to special
districts andfother "non county" recipients
Transfer oflands -with .associated revenues'(i a existing leases and licenses, or Timber harvest
revenues):;
• The value of the land: interests donated will be considered "in lieu" payment of the
county's share of property taxes on the affected parcel
• The first use of revenues associated with the lands is to pay for special districts' share of
taxes ~~ `~
• If revenues afire not suf#`~cient to cover all property taxes due to special districts, the
Stewardship Council will pay for property tax neutrality related to special districts and
other "non-county" recipients.
• Any excess revenues after satisfaction of property tax neutrality will be available for
enhanced management and improvements on the subject property.
DRAFT Gulde!lnes ForAchleving
Property Tax Neufra!!ty Page 5 of 6 12/13/20!0
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SATISFACTION OF TAX NEUTRALITY WHEN LANDS ARE TRANSFERRED TO STATE AGENCIES
• The Stewardship Council will pay I00% of property tax neutrality related to counties,
special districts, and other "non-county" recipients when lands are transferred to state .
agencies, unless the recipient agency is expressly obligated to pay property taxes bylaw
and has a history of making such payments.
SATISFACTION OF TAX NI=UTRALITY WHEN LANDS ARE TRANSFERRED TO FEDERAL AGENCIES
• The Stewardship Council recognizes that lands transferred to federal agencies are
typically subject to various revenue sharing programs intended to help compensate local
governments for the provision of services on federal lands: Th® Stewardship Council's
analysis of these programs indicates that the annual payments under these programs
would yield only a fraction of the amount countiesand~special districts currently receive
in property taxes from 1'G&E.
• Therefore, the Stewardship Council will pay:1.00% of property tax neutrality related to
counties, special districts, and other "non.-county" recipients when lands are transferred to
federal agencies.
SATISFACTION OF TAX NEUTRALITY WHEN LANDS ARE TRANSFERRED TO NATIVE AMERICAN
TRIBES AND TAX-EXEMPT ORGANI~ATlONS'OTHER THAN COUNTIES AND STATE OR FEDERAL
AGENCIES
• The Stewardship Council will pay 100°!0 of property tax neutrality related to counties,
special districts, and other "non-county" recipients when-lands are transferred to tax-
exempt organizatioris.other than counties`and state or'federal agencies.
• With respect to Native American tribes that, would have been able to place lands into trust
but for the teims of the donation transaction;; the Stewardship Council will pay 100% of
property tax neutrality related to.counties, special districts, and other "non-county"
. ,::.
rec~p~ex~ts.
DRAFT Guidelines For Achieving - ~ '
Property Tax Neutrality Page 6 of 6 12/73/2010