The board identified four particular areas of concern.

The first was the belief that citizens may be confused when the bill arrives in the mail. Even though state and county officials attempted to educate the public, the board believes many citizens will remain confused and not accept the billing at face value. This will put a burden on the limited time local officials already have when the public approaches them for clarification.

The second item mentioned was concern about the accuracy of the billing. The board anticipates a significant number of property owners will seek documentation to support a request for redetermination. These requests will take time to process.

A third concern was that in rural Lassen County, not all residents have Internet access, which is a required component of the redetermination process. The board believes the 30-day deadline for submitting payment or filing a petition for redetermination to be insufficient time for citizens to get answers and gather the necessary documentation to support legitimate challenges to the fee calculations.

The fourth concern mentioned was the board felt the imposition of a 20 percent penalty was onerous and abusive to citizens who may not have financial resources to respond to this new and unexpected expense.

Based on these concerns, the board of supervisors requests the State Board of Equalization use its authority to suspend the imposition of all penalties provided for in the Public Resource Code for at least the 2012-2013 fiscal year. They also requested the period for payment or filing a petition for redetermination be extended to no less than 60 days.