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How is This New Sacramento EZ Supposed to Work?

I have been trying to figure out the technical ramifications of creating a new zone in Sacramento which includes the Northern Sacramento Zone designated in 2006 and which does not increase the total number of zones beyond 42. I think there are three possibilities:

1. The new 2009 Sacramento zone is really an expansion of the Northern Sacramento Zone. The difficulty with this is that the new geography would be limited to 15% of the territory of the 2006 zone.

2. The new area could be deemed a “boundary modification” of the 2006 zone. While some other zones have had boundary modifications, they have been done while the zone was still in its conditional phase. This would result in the new 2009 area becoming retroactively effective back to 2006 – very confusing.

3. The Northern Sacramento Zone could opt to give up its 2006 designation in favor of receiving a new, larger designation. Of the three, this is the most likely, but still presents potential for serious confusion, especially when it comes to apportionment.

I think, however, that I have come up with a new solution which would keep the total number of zones at 42, would allow Sacramento to operate two distinct zones (one with a 2006 designation and one with a 2009 designation), would eliminate confusion, and which is backed up by precedent. If anyone at HCD is interested in hearing the idea, give me a call.

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