The quarterly CAEZ board meeting was yesterday in Sacramento. There wasn’t too much activity except for a substantive report from HCD.

So far, only four of the 23 zones conditionally designated at the beginning of 2007 have received their final designation. With the exception of Arvin, all of the others continue to function under the “gap language” in AB 1550. What became clear at yesterday’s meeting was that at least some of this delay seems to be stemming from the zones themselves and is not necessarily a function of HCD’s legendary backlog. The question now becomes how long will such delays be tolerated before some of these conditional designation are taken away. The problem is, however, that there doesn’t seem to be any formal rules on how long this process can be allowed to go on. We should expect to see a final designation for Pasadena within the next few weeks and others will drag on throughout the year.

On the other hand, as a result of SB 341, the final designation process for the most recent eight zones could be done before the final designations of the last zones.

The next round of new zone applications will kick off in late April or early May.  There are four zones expiring in 2009 and the applications will be due some time next January.

HCD is undertaking a concerted effort to update and correct the zone street ranges published to their website.  Since FTB uses those as their primary source and will generally ignore or dismiss other sources of information, this is an important endeavor.  My concern is that street range listings are inherently problematic and notoriously difficult to maintain accurately.  HCD needs to make it clear to FTB that the street ranges are only guidelines and are likely not to be perfect; they should not be considered an exclusive and conclusive description of a zone.

HCD is still working on approving the W4 as a TEA supporting document.  The plan is to allow it as soon as the HCD legal department give a thumbs up, then move into a regulatory amendment process that will ultimately result in removing the I9 and adding the W4.  They are also working on guidelines for the acceptance of electronic I9s and W4s.

We should also expect to see about five more voucher appeals resolved and posted to the website within the next few weeks.  So far only one has been posted and that was on 8/28/07.