The challenged electoral system, under which none but owners of commercial property may vote on the imposition of special benefit assessments to finance rail rapid transit stations, violates the equal protection guarantee of the Fourteenth Amendment of the United States Constitution. Because the construction of rapid transit stations is a matter of concern to all residents of the area surrounding the sites of the proposed stations, and because the *682burden of the assessments will be passed on to other members of the community in the form of higher rents and higher prices for goods and services, the right to vote on a financing mechanism for the stations may not be restricted to owners of commercial property. The contrary conclusion reached by the majority is based on a faulty analysis derived from a misreading of the applicable decisions of the United States Supreme Court.
I
The Legislature established the Southern California Rapid Transit District (hereafter the SCRTD) to construct, operate, and maintain “a comprehensive mass rapid transit system in the southern California area, and particularly in Los Angeles County.” (Pub. Util. Code, § 30001, subd. (a).) The governing body of the SCRTD is its board of directors (hereafter the Board). (Id., § 30200.)
Recognizing that “rail rapid transit facilities and services provide special benefits to parcels of land, and improvements thereon, in the vicinity of rail rapid transit stations” (Pub. Util. Code, § 33000, subd. (b)), the Legislature authorized the SCRTD to identify the area around each transit station that would be specially benefited by the station, to designate this area a benefit assessment district (or a zone within a benefit assessment district), and to levy special benefit assessments on property so designated (id., §§ 33000, subd. (a), 33001). Imposition of the special benefit assessments is “for the purpose of financing, in whole or in part, the acquisition, construction, development, joint development, operation, maintenance, or repair of one or more rail transit stations and rail transit related facilities located within the benefit districts.” (Id., § 33001, subd. (a).) Revenue derived from a special benefit assessment, or from bonds secured by such assessment, may be used only for financing the facility for which it was levied. (Id., § 33002, subd. (d).)
The Board may establish the benefit districts and impose the assessments without an election (Pub. Util. Code, § 33002.1) unless presented with a petition for election “signed by the owners of at least 25 percent of the assessed value of real property within the benefit district.” (Id., § 33002.2.) If a petition with the required signatures is presented, the SCRTD holds an election at which only owners of assessed property may vote and each such property owner “may cast one vote for each one thousand dollars ($1,000), or fraction thereof, worth of land or improvements owned by the voter in the benefit district as is shown on the most recent equalized assessment roll.” (Id., § 33002.3, subd. (b).)
Using its statutory authority, the Board established two benefit districts (one of which contains four zones) consisting of land surrounding proposed *683rail rapid transit stations. Although the Legislature had not expressly authorized the exemption of residential property from assessment, such property was exempted and the Board levied the assessment only on commercial property. The lawsuit now before this court challenges the electoral features of the existing scheme, under which only owners of commercial property can petition for and vote in an election on the benefit assessments.
II
Under the Fourteenth Amendment to the federal Constitution, no state may “deny to any person within its jurisdiction the equal protection of the laws.” In the context of state and local voting systems, this guarantee means that the government may not impose a voting restriction other than residence, age, or citizenship, in elections of general interest, unless it can demonstrate that the restriction is necessary to promote a compelling state interest. (Hill v. Stone (1975) 421 U.S. 289, 297 [44 L.Ed.2d 172, 178-179, 95 S.Ct. 1637].) The SCRTD does not contend that the voting restriction at issue here, which limits the franchise to owners of commercial property, can withstand this strict scrutiny. The primary question to be answered, therefore, is whether an election on the imposition of special benefit assessments to finance rail rapid transit stations is an election of general or special interest.
To support its conclusion that the restrictions at issue here are constitutionally permissible, the majority relies heavily on Salyer Land Co. v. Tulare Water District (1973) 410 U.S. 719 [35 L.Ed.2d 659, 93 S.Ct. 1224] (hereafter Salyer), and Ball v. James (1981) 451 U.S. 355 [68 L.Ed.2d 150, 101 S.Ct. 1811] (hereafter Ball). As I will explain, these cases are of limited relevance because they concern elections to select representatives rather than, as here, elections to decide discrete issues. To the extent these cases are relevant, they support the conclusion that voting restrictions in elections conducted by the SCRTD are not exempt from strict scrutiny.
In Salyer, supra, 410 U.S. 719, and Ball, supra, 451 U.S. 355, the issue before the United States Supreme Court was the validity, under the Fourteenth Amendment’s equal protection guarantee, of a law limiting to property owners the right to vote in elections of the governing body of a water district. In upholding the property ownership restrictions, the high court explained that a water district, in the discharge of its primary function, does not exercise traditional governmental powers. Noting that a water district exists to acquire, store, and distribute water, the court commented that the district at issue in Salyer provided “no other general public services such as schools, housing, transportation, utilities, roads, or anything else of the type *684ordinarily financed by a municipal body. . . . and it does not have a fire department, police, buses, or trains.” (Salyer, supra, at pp. 728-729 [35 L.Ed.2d at pp. 666-667], italics added.) Although the district at issue in Ball did provide a “general public service” by producing and distributing electrical power, this activity was merely incidental to its primary purpose and thus, the court concluded, the provision of this utility service could not change the district’s character. (Ball, supra, at pp. 368-369 [68 L.Ed.2d at pp. 161-162].)
The United States Supreme Court also emphasized that the actions of water districts disproportionately affect landowners because district costs are assessed against landowners in proportion to the benefits received, with delinquencies becoming a lien on the land. (Salyer, supra, 410 U.S. 719,729 [35 L.Ed.2d at p. 667].) Although the district at issue in Ball provided much of its water for nonagricultural uses, the court explained that the “constitutionally relevant fact” was that all of its water was distributed according to land ownership. (Ball, supra, 451 U.S. 355, 367 [68 L.Ed.2d at pp. 160-161].) The court concluded that the districts “remain essentially business enterprises, created by and chiefly benefiting a specific group of landowners.” (Id. at p. 368 [68 L.Ed.2d at p. 161].)
The SCRTD’s primary purpose and manner of operation contrast sharply with those of the water districts discussed in Salyer, supra, 410 U.S. 719, and Ball, supra, 451 U.S. 355. The SCRTD’s primary purpose is to establish and operate an urban rail mass transit system. Providing urban mass transportation is a task traditionally performed by local government, as the United States Supreme Court recognized when it included transportation among the “general public services” that local governments have historically provided to their citizens. (Salyer, supra, at pp. 728-729 [35 L.Ed.2d at pp. 666-667]; see also, Cunningham v. Municipality of Metropolitan Seattle (W.D.Wash. 1990) 751 F.Supp. 885, 890 [applying one-person, one-vote principle to special district providing mass transit and water pollution abatement].)
If a public entity’s primary purpose is to provide even a single traditional governmental service, the federal Constitution may require strict scrutiny of voting restrictions in elections of its governing body. (See, e.g„ Hadley v. Junior College District (1970) 397 U.S. 50 [25 L.Ed.2d 45, 90 S.Ct. 791] [applying one-person, one-vote principle to election for school board members]; Fumarolo v. Chicago Bd. of Educ. (1990) 142 Ill.2d 54 [566 N.E.2d 1283, 1295].) The transportation service that the SCRTD provides is not distributed according to land ownership but is available to all who choose to ride its trains. Although the building of a rail mass transit system provides special benefits to some landowners, these benefits are incidental to the rapid *685transit district’s primary purpose. The chief beneficiaries of the transit system are those who use it for transportation, a class unrelated to land ownership. Finally, only a small portion of the SCRTD’s revenues will be derived from assessments on land. Its primary sources of funding are grants from the federal and state governments and the fares to be collected from transit patrons. Given these many significant differences between the SCRTD and the water districts considered by the United States Supreme Court in Salyer, supra, 410 U.S. 719, and Ball, supra, 451 U.S. 355, this case is not controlled by the decisions in those two cases.
The majority opinion does not analyze the issue in these terms. Instead of comparing the water districts at issue in Salyer, supra, 410 U.S. 719, and Ball, supra, 451 U.S. 355, with the SCRTD, the majority compares them with the benefit assessment districts. This is fundamentally erroneous, and indeed senseless, because the SCRTD itself, not the benefit districts, imposes and collects the special benefit assessments and conducts any election that may be required. (Pub. Util. Code, § 33000 et seq.) Furthermore, although a rapid transit district and a benefit assessment district are both called “district,” only one of them—the rapid transit district—exists as a legal entity. A benefit assessment district is merely a geographical area within the SCRTD’s borders identified by the Board for the purpose of imposing the assessment. Such a “district” has no governing body, no employees, and no powers or responsibilities. It is not a public entity. (See Dawson v. Town of Los Altos Hills (1976) 16 Cal.3d 676, 683 [129 Cal.Rptr. 97, 547 P.2d 1377].) Because it is not a unit of government, a benefit assessment district, unlike the SCRTD itself, cannot be meaningfully compared to the water districts at issue in Salyer and Ball.
The conclusion to be drawn from Salyer, supra, 410 U.S. 719, and Ball, supra, 451 U.S. 355, is that the SCRTD is a governmental entity of general powers. If the election at issue were for the purpose of selecting the SCRTD’s governing body, it would be an election of general interest and restrictions on the franchise other than residence, age, or citizenship would therefore be subject to strict scrutiny. (Hill v. Stone, supra, 421 U.S. 289,297 [44 L.Ed.2d 172, 178-179].) But the scope of the election is narrower. Its purpose is to determine whether special benefit assessments shall be imposed. To decide whether such an election, conducted by a governmental entity of general powers, is an election of general interest, it is appropriate to consider decisions of the United States Supreme Court concerning similar limited-purpose elections.
As the high court has emphasized, the equal protection principles applicable to “an election involving the choice of legislative representatives” have *686only “limited relevance” in determining the validity of restrictions on the franchise in a “ ‘single-shot’ referendum.” (Lockport v. Citizens for Community Action (1977) 430 U.S. 259, 266 [51 L.Ed.2d 313, 321, 97 S.Ct. 1047].) Unlike an election of legislative representatives, a referendum “puts one discrete issue to the voters,” and the proposal can be analyzed “to determine whether its adoption or rejection will have a disproportionate impact on an identifiable group of voters.” (Ibid.) If adoption or rejection of the proposal that is the subject of the referendum would have such a disproportionate impact, “the question then is whether a State can recognize that impact either by limiting the franchise to those voters specially affected or by giving their votes a special weight.” (Ibid.)
Here, it cannot be questioned that the decision to impose a special benefit assessment will have a particular impact on an identifiable group of voters— owners of the property on which the assessment is imposed. But the existence of this special impact is not in itself sufficient to justify restriction of the franchise to the class specially affected in this manner. The relevant analysis is found in another United States Supreme Court decision, Phoenix v. Kolodziejski (1970) 399 U.S. 204 [26 L.Ed.2d 523, 90 S.Ct. 1990] (hereafter Phoenix).
The high court held in Phoenix, supra, 399 U.S. 204, that in an election to approve a municipality’s issuance of general obligation bonds, a state could not restrict the franchise to real property taxpayers, even though the municipality substantially relied on property taxes to service the bonds. The court concluded that “[t]he differences between the interests of property owners and the interests of nonproperty owners are not sufficiently substantial to justify excluding the latter from the franchise.” (Id. at p. 209 [26 L.Ed.2d at p. 527].)
The court gave three reasons for this conclusion. First, all municipal residents had a substantial interest in the facilities and services financed by the bonds. “Presumptively, when all citizens are affected in important ways by a governmental decision subject to a referendum, the Constitution does not permit weighted voting or the exclusion of otherwise qualified citizens from the franchise.” (Phoenix, supra, 399 U.S. 204, 209 [26 L.Ed.2d at p. 527].) Second, the municipality would not rely entirely on property taxes to service the bond debt, but would also rely in significant part on other local taxes paid by nonproperty owners. (Id. at pp. 209-210 [26 L.Ed.2d at pp. 527- 528].) Finally, the landowners could redistribute the property tax burden to others in the community in the form of higher rents and, in the case of commercial property, in the form of higher prices for goods and services produced or sold on the taxed property. (Id. at pp. 210-211 [26 L.Ed.2d at pp. 528- 529].)
*687This analysis compels a similar conclusion here. As the United States Supreme Court recognized, a vote on a revenue measure cannot be divorced from the facilities and services to be financed by the revenue. Here, the issue addressed by the special benefit assessment election is not just the imposition of the assessment, but also the construction of the mass transit stations that the assessments will finance. The stations will generate an increase in commercial activity in the areas around the stations, as the majority acknowledges. This increase in commercial activity will make the areas more attractive for certain kinds of high volume businesses (e.g., fast-food outlets), and less attractive for other, more neighborhood-oriented businesses (e.g., laundromats). Inevitably, all residents of the benefit assessment area, not just the owners of commercial property, will be affected in important ways by the change in the commercial environment resulting from the location of the transit station.
The effects will not be confined to commercial activity. In most instances, residential property located near proposed rapid transit stations will increase in value in recognition of the convenience of ready access to the transit system.1 This increase in value will translate into higher rents for rented dwellings and higher sales prices for owner-occupied dwellings. These increases in housing costs will significantly affect the residents of the area immediately surrounding the proposed stations.
Because the construction of the transit stations affects all community residents in important ways, the exclusion of residents who own no commercial land is presumptively a violation of equal protection. Although the assessments will be levied initially on the owners of commercial property, they can redistribute the burden to other community residents. Rents charged to commercial tenants will certainly increase. Indeed, it is undisputed that most commercial leases in the benefit assessment areas contain “pass through” provisions under which the tenant assumes liability for any tax or assessment levied on the property. The occupant of the premises who pays the assessment, whether landowner or tenant, can recover the cost from consumers, many of whom will be local residents, by increases in the prices of goods and services produced or sold on the taxed property.
Under the test articulated in Phoenix, supra, 399 U.S. 204, which this court is required to employ, the election on the SCRTD’s special benefit *688assessments is an election of general interest, in which restrictions other than residence, age, and citizenship must be subjected to strict scrutiny. The restriction imposed, which limits the franchise to owners of commercial property, concededly cannot withstand such scrutiny. Accordingly, the existing system for the SCR.TD special benefit assessment elections, by disenfranchising all but owners of commercial property subject to assessment, violates the equal protection guarantee of the Fourteenth Amendment to the United States Constitution.
Ill
Like the other members of this court, I am reluctant to accept a conclusion that might impede the construction of needed public facilities, and the need for a modern and efficient rapid transit system in the greater Los Angeles area cannot be denied. Yet, as the United States Supreme Court has noted, restrictions on the franchise that violate equal protection cannot be justified “on exigencies of history or convenience.” (New York City Bd. of Estimate v. Morris (1989) 489 U.S. 688, 703, fn. 10 [103 L.Ed.2d 717, 733, 109 S.Ct. 1433].) Thus, like the Court of Appeal, I conclude that, under controlling federal precedent, the existing electoral system for the SCRTD’s special benefit assessments is invalid on its face.
Because the electoral system is invalid for the reasons I have stated, I find it unnecessary to consider the other bases on which that system has been challenged in this litigation. Having concluded that the existing electoral system violates the federal Constitution, I would affirm the judgment of the Court of Appeal.
Mosk, J., concurred.
Interveners’ petition for a rehearing was denied March 26, 1992. Mosk, J., and Kennard, J., were of the opinion that the petition should be granted.
There may be situations in which a rapid transit station would depress the value of adjacent residential property. For instance, this could occur in the unlikely event that the station were to be located in a neighborhood of expensive single-family residences. For present purposes, the essential point is that construction of a rapid transit station is virtually certain to have some effect, either positive or negative, on the value of nearby residential property.