I dissent. I am unpersuaded by the majority’s strained effort to bring special taxes within the purview of Government Code section 65995, subdivision (a),1 which neither comports with a reasonable interpretation of the statutory language nor finds support in any evidence of legislative intent.
Preliminarily, I disagree in at least one critical respect with the majority’s historical survey. In enacting section 65995, the Legislature did not broadly *924“reenter[] the field of school financing . . . (Maj. opn., ante, at p. 917.) Rather, it more narrowly focused its concern on “the subject of financing school facilities with development fees” (§ 65995, subd. (e), italics added), i.e., the funding of these educational needs through regulatory police powers, a matter separate and distinct from raising revenue by taxation. Indeed, all the pertinent materials digesting the various provisions of the legislative package speak almost exclusively in terms of fees (see, e.g., Legis. Counsel’s Dig., Assem. Bill No. 2926 (1985-1986 Reg. Sess.) p. 2; Conf. Com., Analysis of Assem. Bill No. 2926 (1985-1986 Reg. Sess.) p. 2); the few references to special taxes exclude them from consideration.2 (E.g., § 65995, subd. (f).)
I also question the majority’s postulation of legislative intent. Their initial claim that “section 65995 was an integral part of the Legislature’s comprehensive revision of the subject of school financing in 1986” (maj. opn., ante, at p. 919) overstates the record considerably. As discussed above, the Legislature limited its attention to a particular method of funding school facilities—development fees. To the extent special taxes require two-thirds voter approval (Cal. Const., art. XIII A, § 4), the Legislature may well have considered that alternative revenue source sufficiently constrained without additional statutory restrictions.
The further claim that section 65995 and its companion legislation “restored” a “balance” “between each district’s need to fund school construction caused by residential development and the community’s need to ensure an adequate supply of affordable housing” (maj. opn., ante, at p. 919) appears made of whole cloth. As evidenced by the majority’s lack of citation to authority, this proposition finds no support in either the statutory language or its history.3
Moreover, the majority’s discussion of the Legislature’s purported goals puts the cart before the horse. While the aim of statutory construction is to effectuate legislative intent, the analysis should begin with the terms of the *925enactment itself, which then may be considered in light of any clarifying evidence of such intent. (See Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1386-1387 [241 Cal.Rptr. 67, 743 P.2d 1323].)
Turning to the language of section 65995, subdivision (a), I note the singularly illuminating fact that the Legislature failed to specify “special tax” in an otherwise inclusive listing of preempted exactions. While not dispositive, this omission is significant and requires a convincing explanation to overcome the compelling implication that section 65995 does not affect the validity of special taxes imposed on new developments.
The argument that “charge” or “other requirement” includes special taxes is unsatisfactory for a variety of reasons. First, I find nothing from which to infer the Legislature intended to accomplish indirectly and obliquely what it could easily have done directly and expediently. (See Peralta Community College Dist. v. Fair Employment & Housing Com. (1990) 52 Cal.3d 40, 51 [276 Cal.Rptr. 114, 801 P.2d 357].) I disagree with the implication that our decision in Associated Homebuilders v. City of Livermore (1961) 56 Cal.2d 847 [17 Cal.Rptr. 5, 366 P.2d 448] somehow equated “charge” with “tax” as a matter of law. (Maj. opn., ante, at pp. 919-920.) At best, “charge” is a generic term the precise meaning of which can only be contextual. Here, the statutory scheme focuses on regulatory impositions intended to mitigate the increased burden on facilities caused by new development. (Cf. § 66001.) Taxes, intended solely to raise revenue, perform a distinctly different function. (See Ingels v. Riley (1936) 5 Cal.2d 154, 159 [53 P.2d 939, 103 A.L.R. 1].) Thus, I find no basis in this case for finding “special tax” subsumed by the statutory reference to “charge.”
Second, under the interpretive principle of ejusdem generis, “other requirement” does not reasonably include “special tax” either. This doctrine provides that “ ‘where general words follow the enumeration of particular classes of persons or things, the general words will be construed as applicable only to persons or things of the same general nature or class as those enumerated. The rule is based on the obvious reason that if the Legislature had intended the general words to be used in their unrestricted sense, it would not have mentioned the particular things or classes of things which would in that event become mere surplusage.’ [Citations.]” (Sears, Roebuck & Co. v. San Diego County Dist. Council of Carpenters (1979) 25 Cal.3d 317, 331, fn. 10 [158 Cal.Rptr. 370, 599 P.2d 676].)
*926As defined in section 66000, subdivision (b), a development “fee” expressly excludes “a tax or special assessment.”4 As discussed above, a “charge” is essentially synonymous with “fee” in this context, generally denoting a cost for services. (See Webster’s New World Diet. (3d college ed. 1988) p. 236.) A “dedication” “is the setting apart of land for the public use . . . .” (People v. County of Marin (1894) 103 Cal. 223, 227 [37 P. 203].) With respect to development projects, a dedication may be in lieu of the payment of other required fees. (See § 65974; see also § 66477.) Each of these specifics, having an underlying regulatory purpose and effect, is a form of exaction wholly dissimilar to an imposition intended principally to raise revenue. Therefore, under the rule of ejusdem generis special tax does not come within the general category of “other requirement.”
Third, at the time section 65995 was enacted, the significant distinction between regulatory development fees and special taxes had been well drawn by numerous Court of Appeal decisions (e.g., Trent Meredith, Inc. v. City of Oxnard (1981) 114 Cal.App.3d 317, 325-327 [170 Cal.Rptr. 685]); and we presume legislative awareness of such authority. More importantly, whatever “their relative rarity and novelty” (maj. opn., ante, at p. 921), some special taxes had been approved prior to the passage of section 65995. In fact, the Legislature had actual knowledge of Measure C exactions, having provided specific statutory authorization for their collection. (Ed. Code, § 43040 et seq.) In this circumstance, it would have been irrational for lawmakers to omit “special tax” from section 65995 on the assumption it would be construed as within “charge” or “other requirement.”
The majority’s citation to subdivisions (e) and (f) of section 65995 in support of their construction is unconvincing. Subdivision (e) states a legislative intent to occupy the subject of “development fees and other development requirements” respecting school construction. (Italics added.) Reliance on the emphasized language is misplaced for two reasons. First, it disregards legislative material indicating this reference most reasonably contemplates other regulatory impositions. For example, a Senate Conference Report on the legislation states, “School districts would not be able to use California Environmental Quality Act (CEQA) or their general police powers to extract additional fees.” (Conf. Com., Analysis of Assem. Bill No. 2926 (1985-1986 Reg. Sess.) p. 2, italics added.)
Second, it reflects a fundamental misapprehension of the distinction between taxes and regulatory fees as to their purpose and operation, a distinction this case aptly illustrates. Section 53080, subdivision (b), provides that *927no building permit may issue absent certification by the school district that the development project has complied with any fee requirements. By contrast, Measure C special taxes simply become “due and payable” at the time a building permit issues. The record contains no evidence the district or the city conditions issuance on payment. As with other tax indebtedness, it most likely results in a lien on the property. Thus, Measure C does not impose any “development requirements”; it merely attaches a tax surcharge to a particular enterprise or activity, collection of which coincides with regulatory approval.5 (See The Pines v. City of Santa Monica, supra, 29 Cal.3d at p. 663.)
As for subdivision (f) of section 65995, it provides, “Nothing in this section shall be interpreted to limit or prohibit the use of [the Mello-Roos Community Facilities Act, authorizing the imposition of certain special taxes,] to finance the construction or reconstruction of school facilities.” Accordingly, the majority conclude all other special taxes are preempted: “expressio unius est exclusio alterius.” I find nothing so dispositive in this lone reference. Again, the majority fail to explain why lawmakers would choose an indirect rather than direct means of expressing their intent. An equally likely explanation of subdivision (f) lies elsewhere. Under section 53313.5, Mello-Roos Act special taxes may be used to finance “elementary and secondary schoolsites and structures.” The Legislature may simply have sought to expressly conform section 65995 to section 53312, which provides that the Mello-Roos Act prevails over any other conflicting provisions of law.
The contention also disregards the Legislative Counsel’s opinion concluding that “[i]n view of the significant legal distinction between the terms ‘fee’ and ‘tax,’ ... if the Legislature had intended to include taxes within the scope of the restrictions set forth in Section 65995, that section would have made express reference to taxes.”6 (Ops. Cal. Legis. Counsel, No. 22732 (Sept. 26, 1986) School Facility Fees: Special Taxes, pp. 4-5.) While this *928opinion may not necessarily reflect the understanding of legislators when enacting the statute, it does considerably inform and illuminate their defeat shortly thereafter of an amendment that would have precluded the imposition of special taxes in excess of the limitations contained in section 65995, subdivision (b). (Assem. Bill No. 1929 (1986-1987 Reg. Sess.) § 4.)7 As this court has noted, “in some circumstances such legislative inaction may represent a reliable indicant of the intended scope of existing legislation . . . .” (Gay Law Students Assn. v. Pacific Tel. & Tel. Co. (1979) 24 Cal.3d 458, 480, fn. 13 [156 Cal.Rptr. 14, 595 P.2d 592]; see also 2A Sutherland, Statutory Construction (4th ed. 1984) §49.10.) In light of the view expressed by the Legislative Analyst directly addressing the precise issue so closely in time, the rejection reasonably implies the Legislature did not consider the originally enacted bill to preempt special taxes or desire to rectify the omission. (See Seibert v. Sears, Roebuck & Co. (1975) 45 Cal.App.3d 1, 19 [120 Cal.Rptr. 233].) The fact that the proposed amendment specifically included special taxes also suggests section 65995, subdivision (a), did not previously contemplate this type of imposition.
Even if the majority were in any respect convincing in their interpretation of subdivisions (e) and (f), I would remain unpersuaded of their ultimate conclusion regarding the scope of section 65665, subdivision (a), considering the substantial body of legislative evidence from which I can discern no intent to preempt local special taxes. On the one hand, the majority’s construction of subdivision (a) is superficial and simplistic. On the other, it assumes that in establishing a regulatory scheme the Legislature either ignored or intended to obscure the settled distinction between development fees and related exactions imposed to regulate activity and special taxes enacted simply to raise revenue. (See The Pines v. City of Santa Monica, supra, 29 Cal.3d at p. 660.)
I cannot accept either the majority’s premise or their conclusions. Reading the plain statutory language in light of its history, I find the Legislature well understood the clear implications of omitting “special tax” from section 65995, subdivision (a), and intended that result.
Unless otherwise indicated, all statutory references are to the Government Code.
interestingly, a summary and analysis from the file of Assemblyman Stirling, the bill’s sponsor, dated shortly before its passage, states, “The financing package does not preclude the possibility of additional voter-approved taxes (such as Prop. 46, Mello-Roos, and Prop. 13 Special taxes) being levied in addition to the capped developer fee.”
However, even with legislative endorsement, the majority’s premise does not support their conclusion that a regulatory statutory scheme necessarily precludes concurrent taxation. In The Pines v. City of Santa Monica (1981) 29 Cal.3d 656 [175 Cal.Rptr. 336, 630 P.2d 521], the city taxed condominium conversions at the rate of $1,000 per unit. Rejecting the argument that the state had preempted the field under the Subdivision Map Act, this court stated, “That the state has preempted a field of statewide concern for purpose of regulation does not itself prevent local taxation of the person or activities regulated. [Citations.]” {Id., at p. 660.) The issues in that case similarly concerned a shortage of available housing and a state effort to regulate in an area subject to local taxation. I see no reason to preclude the exaction here when we allowed the earlier one under comparable circumstances.
The definitions contained in section 66000 apply to development fees collected pursuant to section 53080, which is incorporated by reference in section 65995. Since the statutes are thus in pari materia, the same interpretive provisions should govern throughout.
The majority also inaccurately imply that Measure C special taxes apply only to new residential development and that the revenue is used only to offset the burden generated by such development. (Maj. opn., ante, at p. 922.) On the contrary, all persons seeking building permits must pay, irrespective of whether the party is a large-scale developer or an owner-builder constructing a single residence. Moreover, expenditure of proceeds from Measure C is not limited to schools located in new developments but may accommodate the needs of students throughout the district.
Contrary to the majority’s claim, this distinction between fees and special taxes is anything but “abstract” (maj. opn., ante, at p. 922), as a wealth of court decisions attest. (See, e.g., Candid Enterprises, Inc. v. Grossmont Union High School Dist. (1985) 39 Cal.3d 878 [218 Cal.Rptr. 303, 705 P.2d 876]; Terminal Plaza Corp. v. City and County of San Francisco (1986) 177 Cal.App.3d 892 [223 Cal.Rptr. 379]; Beaumont Investors v. Beaumont-Cherry Valley Water Dist. (1985) 165 Cal.App.3d 227 [211 Cal.Rptr. 567]; J.W. Jones Companies v. *928City of San Diego (1984) 157 Cal.App.3d 745 [203 Cal.Rptr. 580]; Trent Meredith, Inc. v. City of Oxnard, supra, 114 Cal.App.3d 317; County of Fresno v. Malmstrom (1979) 94 Cal.App.3d 974 [156 Cal.Rptr. 777].)
Assembly Bill No. 1929 would have amended section 65995, subdivision (b), to read in part as follows: “In no event shall the amount of any fee, charge, dedication, or other form of requirement, . . . when combined with the amount of any special tax levied upon new construction for the purpose of funding the construction or reconstruction of school facilities . . . exceed [$1.50 per square foot of residential construction].”