It is difficult to imagine a more Byzantine interrelationship of statutory provisions than this case presents. However, I believe that the trial court correctly found its way through the maze and interpreted the provisions in a manner that conforms to the Legislature’s obvious intent and makes sense of the statutory scheme. The trial court construed the principal section in question in the same manner that every branch of government, including the Department of Social Services itself, had construed the section until the department’s last-minute and unexplained change of heart. The interpretation now urged by the Attorney General and adopted by the majority produces a result that is not required by the language of the controlling statute and is irreconcilable with any rational explanation of the purpose behind the statute. Hence, I respectfully dissent.
The key provision, as all agree, is Welfare and Institutions Code section 11453, subdivision (c)(3) (section 11453(c)(3) or the COLA statute), as the provision read in 1998 and as it remained in 2003-2004: “In any fiscal year commencing with the 2000-01 fiscal year to the 2003-04 fiscal year, inclusive, when there is any increase in tax relief pursuant to the applicable paragraph of subdivision (a) of Section 10754 of the Revenue and Taxation Code, then the increase pursuant to subdivision (a) of this section shall occur. In any fiscal year commencing with the 2000-01 fiscal year to the 2003-04 fiscal year, inclusive, when there is no increase in tax relief pursuant to the applicable paragraph of subdivision (a) of Section 10754 of the Revenue and Taxation Code, then any increase pursuant to subdivision (a) of this section shall be suspended.” (Stats. 1998, ch. 329, § 23, italics added.) The dispute centers on the italicized phrase, and the problem arises because Revenue and Taxation Code section 10754 (section 10754 or the VLF statute) was repeatedly amended in the manner described in the majority opinion, but section 11453(c)(3) remained unchanged.
There is no dispute over the basic proposition that what must be determined is what was intended by section 11453(c)(3) when it was enacted. “The words of a statute are to be interpreted in the sense in which they would have been understood at the time of enactment.” (People v. Cruz (1996) 13 Cal.4th 764, 775 [55 Cal.Rptr.2d 117, 919 P.2d 731].) When section 11453(c)(3) was enacted in 1998 (Stats. 1998, ch. 329, § 23), Revenue and Taxation Code section 10754 had just been changed to provide for an offset *950from the vehicle licensing fee (VLF) of at least 25 percent for every year from and after 1999, and it contained a series of provisions under which the amount of the offset might be increased to 35 percent, 46.5 percent, 55 percent or 67.5 percent in future years depending on the size of forecasted general fund revenue (Stats. 1998, ch. 322, § 2). The 25 percent reduction was considered to be “permanent.” (E.g., Assem. Floor Analysis, Conc. in Sen. Amends. to Assem. Bill No. 2797 (1997-1998 Reg. Sess.) as amended Aug. 10, 1998, p. 1; Assem. Floor Analysis, Conc. in Sen. Amends. to Assem. Bill No. 1121 (1999-2000 Reg. Sess.) as amended June 15, 1999, p. 1.) When section 11453(c)(3) referred to “any increase in tax relief pursuant to the applicable paragraph” (italics added) of Revenue and Taxation Code section 10754, it could only have been understood to refer to an increase over the base 25 percent offset. There would have been no point to a specific reference in section 11453(c)(3) to an increase over the base 25 percent because that is what Revenue and Taxation Code section 10754 already said explicitly. Indeed, it is not clear grammatically how or where this additional qualification could have been inserted.
Contrariwise, if the Legislature intended section 11453(c)(3) to require an increase over the tax relief provided in the preceding year, as the Attorney General argues and the majority now construes the provision, that is a qualification not included in Revenue and Taxation Code section 10754 that one would expect the Legislature to have stated explicitly in the COLA statute. The reasonableness of this expectation is emphasized by various statutes cited by respondent in which the Legislature did explicitly include such a qualification. (Ed. Code, § 41851, subd. (c) [school transportation allowances shall not exceed “the prior year’s approved home-to-school transportation costs, increased by the amount provided in the Budget Act”]; Fin. Code, § 17207, in certain years (Stats. 1996, ch. 670, § 1, p. 3720; Stats. 2005, ch. 257, § 2, eff. Jan. 1, 2010) [escrow license assessments “shall not increase by more than 25 percent over the amount assessed in the prior year”]; Gov. Code, § 54984.7 [authorization of “standby charges” for water and sewer services “shall not apply if the amount of the assessment is increased . . . compared to the prior year’s assessment”]; Lab. Code, § 4659, subd. (c) [average weekly earning limits for state disability insurance shall be increased “by an amount equal to the percentage increase in the ‘state average weekly wage’ as compared to the prior year”].) No such qualification or allusion to an increase over the prior year is to be found in section 11453(c)(3) or in any of its legislative history.
The majority opinion asserts that none of the legislative history supports the view that the Legislature wished to provide yearly cost of living adjustments (COLA’s) whenever state revenues were increasing. (Maj. opn., ante, p. 942.) But the trial court’s finding “that the Legislature’s intent in enacting Welfare and Institutions Code section 11453(c)(3) was to link *951provision of the COLA for CalWORKs recipients to increases in tax relief for car owners” is supported by the very language of the statute itself, which can sensibly be understood in no other way. Why else would the Legislature have tied the COLA relief to “any increase in tax relief pursuant to the applicable paragraph of subdivision (a) of section 10754”? The two measures—section 11453(c)(3) and the 1998 amendment of Revenue and Taxation Code section 10754—were enacted within one day of each other. And, in all events, the legislative analysis of the bill by which section 11453(c)(3) was enacted did state explicitly that the measure would “[l]ink the implementation of the CalWORKs COLA payment to implementation of’ the VLF provisions. (Assem. Floor Analysis, Conc. in Sen. Amends. to Assem. Bill No. 2779 (1997-1998 Reg. Sess.) as amended Aug. 10, 1998, p. 2.) As explained above, the VLF provisions provided for increases in the VLF offset, i.e., tax relief for car owners, as state revenues increased.
Still further, this is the interpretation that was placed on the measure by all agencies of government, including the agency entrusted with enforcement of the COLA provision, until the unexplained reversal of position that led to this litigation. For the calendar year 2000, the VLF offset was 35 percent, pursuant to an amendment to section 10754 that became effective July 7, 1999. (Stats. 1999, ch. 74, § 1.) A COLA was made on October 1, 2000. For 2001, the VLF offset was 67.5 percent, pursuant to the 1999 amendment of section 10754 and a measure that became effective July 10, 2000, adding to the 35 percent offset a rebate to bring the total offset to 67.5 percent. (Stats. 2001, ch. 106, § 1.1) A COLA was made on October 1, 2001. In 2002, the VLF offset remained at 67.5 percent, pursuant to a further amendment of section 10754 that raised the offset to 67.5 percent and eliminated the rebate. (Stats. 2001, ch. 5, § 5.) Despite the fact that the offset for 2002 did not increase over the 2001 offset, the offset was greater than 25 percent and a COLA was made on October 1, 2001.2 Thus, the Department of Social *952Services did not then interpret the COLA provision to require an increase in the VLF offset over the prior year’s offset in order to justify making a cost of living adjustment.
The 2001 and 2002 COLA’s were recommended by the Department of Finance, included in the Governor’s budget and approved by the Legislature. In neither year did anyone suggest that the COLA’s were unauthorized because the VLF offset had not increased from the offset the prior year. Similarly, for the 2002-2003 fiscal year, the Legislature enacted section 11453, subdivision (c)(4), which provided that “[njotwithstanding paragraph (3), an adjustment to the maximum aid payments . . . shall be made under this section . . . , but the adjustment shall become effective June 1, 2003.” (Stats. 2002, ch. 1022, § 42.) It is not clear from the text of this provision whether the “notwithstanding” clause was intended to indicate that section 11453(c)(3) would not otherwise have applied or merely that the effective date of the COLA was being moved back from October 1, as provided in section 11453, subdivision (a), to June of the next year. However, the legislative analyses in both the Senate and the Assembly indicate clearly that the provision was intended to “[d]elay[] the statutorily required cost-of-living adjustment for recipients of CalWORKs from October 1, 2002, to June 1, 2003.” (Assem. Floor Analysis, Conc. in Sen. Amends. to Assem. Bill No. 444 (2001-2002 Reg. Sess.) as amended June 29, 2002, p. 1; Sen. Rules Com., Off. of Sen. Floor Analyses, 3d reading analysis of Assem. Bill No. 444 (2001-2002 Reg. Sess.) as amended June 29, 2002, p. 4.) Thus, it was understood that the COLA was required for 2003 even though the VLF offset was to remain at 67.5 percent, the same as the preceding year.
And again, after Governor Schwarzenegger reinstated the VLF offset for 2003 following its termination under the prior administration, both the Legislative Analyst and the new administration itself indicated their understanding that the restoration would trigger a COLA for 2003, despite the fact that the offset would remain at the prior level of 67.5 percent. As stated by the Governor in seeking a legislative modification that was not adopted, “Current law requires a CalWORKs grant COLA when there is a reduction in the car tax. Because the car tax was increased for 2003-04, the October 2003 CalWORKs COLA was not provided. However, since the car tax is being rescinded, a CalWORKs COLA would be required by law.” (Governor’s Agenda to 5th Ex. Sess. (Nov. 2003 5th Ex. Sess.) p. 4.)
Thus, the position now advanced by the Attorney General and adopted in the majority opinion is that the understanding shared by all public officials *953since the enactment of section 11453(c)(3), and found to be correct by the trial court, was mistaken. This startling reinterpretation of the statute disregards the most obvious construction of its language and incorporates a qualification for which there is no support in either the text or the legislative history of the provision.
Moreover, while both sides argue that absurdity results from accepting the other’s interpretation of the statute, the respondents have the better argument. No one has suggested any reason why anyone would have thought the benefit of a COLA should be enjoyed by welfare recipients for the four years to which section 11453(c)(3) applies only if the state’s revenues increased gradually, each year exceeding the previous year, but not if California was fortunate enough to enjoy greater than anticipated revenues in the earlier years so that car owners would enjoy the maximum VLF reduction in each of those years. Yet, that is how the majority interprets the statute.3 The contrary argument that it would make no sense to regard an offset which is less than the offset in the prior year as an “increase” in tax relief is a play on words. There is no disagreement over the meaning of the word “increase” and there is no debate that an offset in one year of 67.5 percent would not be an increase in an offset the prior year of 67.5 percent. But that is not the question. When section 11453(c)(3) speaks of an increase in tax relief, the question is, an increase over what? The statute answers that question: an increase pursuant to section 10754, which means an increase over the 25 percent permanent offset provided in section 10754. There is nothing absurd about this commonsense reading of the statute. As the trial judge put it, “Every time an increase over and above the 25 percent was granted, regardless of what it was, the COLA statutes were triggered. ... I mean if the increase were 35 percent and stayed at 35 percent let’s say for all of these years .. . automobile owners would still get tax relief of 10 percent over and above that which is otherwise statutorily provided. And to say that automobile owners take a hit is really mischaracterizing it. They don’t—they don’t get as much of a break as they got the year before but they still get a break. And that’s the point of the statute. Every *954time automobile owners get a break, COLA increases kick in.” I see no absurdity in this conclusion. To the contrary, it is the only interpretation predicated on a rational explanation of what the Legislature was trying to accomplish by the unique COLA provision that it adopted for the four-year period ending with the 2003-2004 fiscal year that is in question.
I would affirm the decision of the trial court.
Respondents’ petition for review by the Supreme Court was denied June 13, 2007, S151347. Kennard, J., Chin, J., and Moreno, J., were of the opinion that the petition should be granted.
Revenue and Taxation Code section 10754.2 provided that for each VLF in 2001 or 2002 “for which the vehicle license fee offset required by section 10754 is less than 6IV2 percent, the Department of Motor Vehicles shall concurrently calculate an offset, in addition to the offset required by Section 10754, that is equal to the difference between the following: (A) A vehicle license fee offset of 67*/2 percent [and] (B) A vehicle license fee offset of the greater of 35 percent or that percentage required by section 10754.” It was intended that “[t]he taxpayer shall pay a fee based on a bill from the Department of Motor Vehicles containing the 35% offset, and then would receive a rebate check for the difference between 35% and 67.5%.” (Assem. Floor Analysis, Conc. in Sen. Amends. to Assem. Bill No. 858 (1999-2000 Reg. Sess.) as amended June 22, 2000, p. 1.)
It is arguable that the “offset” did increase from 2001 to 2002 because the total offset in 2001 consisted of 35 percent per section 10754 and the additional 32.5 percent rebate per Revenue and Taxation Code section 10754.2. However, viewed in this light, there was no increase between 2000, when the offset was 35 percent, and 2001 when the offset, not including the rebate, remained at 35 percent. A COLA was granted in both 2001 and 2002, so that however the matter is viewed, the Department of Social Services granted a COLA in each *952year in which the VLF offset exceeded 25 percent, including at least one year in which the VLF offset did not increase from the prior year.
Citing McLaughlin v. State Bd. of Education (1999) 75 Cal.App.4th 196, 222-223 [89 Cal.Rptr.2d 295] and Myers v. King (1969) 272 Cal.App.2d 571, 579 [77 Cal.Rptr. 625] and respondent also makes another valid point: “Under appellants’ interpretation of the COLA statute, ... no COLA was possible after October 2000, because the VLF was permanently set at 67.5% for 2001 and beyond. Yet the COLA statute links the COLA to VLF relief for three more years (through 2003-2004). Appellants’ interpretation, therefore, suggests that the Legislature’s amendment of the VLF statute effectively amended the COLA statute as well, to delete its ‘to the 2003-04 fiscal year’ language and render the link effective for a single year only. The implied amendment of one statute by the express amendment of another is strongly disfavored.”