Barajas

BACKGROUND

I. The Act

In 1987, the Legislature enacted the Act “ ‘in response to concerns among developers that local agencies were imposing development fees for purposes unrelated to development projects.’ ” (Ehrlich v. City of Culver City (1996) 12 Cal.4th 854, 864.) Although mostly “procedural in nature,” the Act “embodies a statutory standard against which monetary exactions by local governments subject to its provisions are measured.” (Id. at p. 865.) Section 66001, subdivision (a) sets forth certain requirements for “establishing, increasing, or imposing a fee as a condition of approval of a development project by a local agency . . . .” Among other things, the agency must determine how there is a “reasonable relationship” to the type of development project for both the use of the fee and the need for the public facility. (Id., subd. (a)(3)–(4).) The Act “thus codifies, as the statutory standard applicable by definition to nonpossessory monetary exactions, the ‘reasonable relationship’ standard employed in California and elsewhere to measure the validity of required dedications of land (or fees imposed in lieu of such dedications) that are challenged under the Fifth and…