As set out in the majority opinion, the County of Alameda and its agents and agencies (collectively, the county) have appealed a writ of mandate issued at the behest of several residents of Alameda County who are recipients of general assistance (GA). The writ directs the county to discontinue the time limitation of GA benefits to otherwise qualified persons who are unemployable for reasons other than physical, mental or emotional incapacity, or their age. The appeal questions the meaning of an “employable individual” as that term is used in Welfare and Institutions Code 1 section 17001.5, subdivision (a)(4). In my view, the trial court correctly determined *351that “employable” is not synonymous with “able-bodied and mentally competent” and that the term must be construed “fairly and equitably based upon practical employability factors.” In upholding the county’s artificial definition of employability, defensible only as a means of reducing the county’s welfare costs, the majority approves a definition that is at odds with the entire scheme of GA and with innumerable decisions of the courts of this state. While section 17001.5 authorizes counties to place certain restrictions on GA benefits, these restrictions are themselves limited. As part of a series of provisions designed to force welfare recipients to engage in job training and to seek employment, subdivision (a)(4) permits counties to impose time limits on GA benefits to persons who are “employable.” The statute does not authorize counties to withhold relief from persons who, despite their best efforts, cannot obtain employment, by the simple expedient of calling “employable” people who no employer will employ.
At a time of widespread unemployment throughout the nation and California and Alameda County in particular,2 the majority permits the county to terminate the last vestige of relief to thousands of indigents who cannot find work and have no other source of sustenance. This decision is unsupported by any indication that the Legislature intended such a draconian consequence, and is unnecessary to accomplish the Legislature’s objective of compelling GA recipients to seek employment. In numerous prior situations in which counties have attempted to avoid their mandatory duty to provide aid for their indigent and dependent poor because of fiscal concerns, our Supreme Court has concluded that these “burdens were not so grievous as to permit indigents, in the midst of plenty, to go hungry, cold and naked, without fault.” (City and County of San Francisco v. Superior Court (1976) 57 Cal.App.3d 44, 47 [128 Cal.Rptr. 712].) There is no reason for this court to do so now.
Background
In November 2007, the Alameda County Social Services Agency amended its GA regulations to provide that, effective January 1, 2008, “all GA applicants and recipients determined to be employable will be limited to a total of six months of assistance as an employable within any 12 month *352period.” (Alameda County General Assistance Regs., § 9-2-5.)3 “Unemployable clients are not subject to time limits.” (Regs., § 9-2-5.212.) The regulation defines unemployable applicants or recipients as persons meeting one of three conditions, in essence that they have a physical, mental or emotional incapacity, either permanent or temporary, that prevents them from working, or that they are 64 years of age or older.4 The regulations were adopted by the agency pursuant to authority conferred by the Alameda County Board of Supervisors, as reflected in the Alameda County General Ordinance Code (ACGO).5
On June 6, 2008, prior to the termination of GA benefits to a large number of recipients that would have occurred under these regulations starting on July l,6 respondents filed a petition for a writ of mandate. The cause of action relevant to this appeal asserts that the county’s classification of persons who are employable is overbroad and contrary to several provisions of the Welfare and Institutions Code. The petition alleges, “Section 11000 mandates that the provisions of law pertaining to the GA program, including section 17001.5(a)(4) authorizing time limits only for an ‘employable individual,’ be ‘fairly and equitably’ construed to effectuate the objectives and purposes of the GA program. A fair and equitable construction of ‘employable individual’ is that the individual be actually, not theoretically, employable and that, in determining employability, such factors as the individual’s education, skill level, work history, advanced age, and opportunity to obtain employment in the relevant labor market, be considered by the [ajgency.”
*353The trial court ultimately issued a thoughtful statement of decision in which it concluded that the county’s method of classifying GA recipients as employable constitutes an abuse of discretion. According to the trial court: “[The county] claim[s] the prerogative to define ‘employable’ as synonymous with ‘able-bodied and mentally competent.’ It is undisputed that, in assessing employability for purposes of the time limits, [the county does] not consider such factors as education, lack of skills and experience, illiteracy, or language barriers. The principles in Mooney [v. Pickett (1971) 4 Cal.3d 669 [94 Cal.Rptr. 279, 483 P.2d 1231]], Hunt [v. Superior Court (1999) 21 Cal.4th 984 [90 Cal.Rptr.2d 236, 987 P.2d 705]], Alford [v. County of San Diego (2007) 151 Cal.App.4th 16 [59 Cal.Rptr.3d 596]] and others in this fine of cases all dictate that the [county] may not merely substitute for ‘employability’ a wholly different concept like ‘able-bodied and mentally competent,’ because to do so excludes people who are not employable by virtue of their lack of skills, lack of experience, lack of language fluency, age or other factors. (Cf. Mooney, supra, 4 Cal.3d at pp. 679-680.) By so doing, [the county has] abused [its] discretion.” The court issued a writ of mandate, directing the county “to comply with [its] duty to construe the term ‘employability’ or ‘employable individual’ in Welfare and Institutions Code Section 17001.5(a) fairly and equitably based upon practical employability factors, as required by the state’s interest in providing General Assistance benefits to indigents.”
Alameda County’s Expansive Definition of “Employable” Distorts and Defeats the Intention of the Legislature
“Section 17000 imposes upon counties a mandatory duty to ‘relieve and support all incompetent, poor, indigent persons, and those incapacitated by age, disease, or accident,’ when those persons are not relieved and supported by some other means.[7] [Citation.] In the last several decades many specialized relief programs have been enacted to support indigent individuals, but section 17000 ‘creates “the residual fund” to sustain indigents “who cannot qualify . . . under any specialized aid programs.” [Citations.]’ [Citation.] . . . [1] Section 17001 requires each county to ‘adopt standards of aid and care for the indigent and dependent poor.’[8] Although this provision confers upon a county broad discretion to determine eligibility for—and the types of— indigent relief, this discretion must be exercised in a manner that is consistent *354with—and that furthers the objectives of—state statutes. [Citations.] These objectives are ‘to provide for protection, care, and assistance to the people of the state in need thereof, ... to promote the welfare and happiness of all of the people of the state by providing appropriate aid and services to all of its needy and distressed,’ and to administer such aid and services ‘promptly and humanely.’ [Citation.] Furthermore, ‘[t]he provisions of law relating to a public assistance program shall be fairly and equitably construed to effect the stated objects and purposes of the program.’ [Citation.] ‘County standards that fail to carry out section 17000’s objectives “are void and no protestations that they are merely an exercise of administrative discretion can sanctify them.” [Citation.] Courts, which have “ ‘final responsibility for the interpretation of the law,’ ” must strike them down. [Citation.] Indeed, despite the counties’ statutory discretion, ’’courts have consistently invalidated . .. county welfare regulations that fail to meet statutory requirements.” ’ ” (Hunt v. Superior Court, supra, 21 Cal.4th at pp. 991-992 (Hunt); see also, e.g., Alford v. County of San Diego, supra, 151 Cal.App.4th at pp. 28-29 (Alford); Arenas v. San Diego County Bd. of Supervisors (2001) 93 Cal.App.4th 210, 215 [112 Cal.Rptr.2d 845]; Nelson v. Board of Supervisors (1987) 190 Cal.App.3d 25, 29-30 [235 Cal.Rptr. 305].)
Although “ ‘case law . . . has recognized that section 17001 confers broad discretion upon the counties in performing their statutory duty to provide general assistance benefits to needy residents[,] there are ‘clear-cut limits’ to this discretion. [Citation.] The counties may exercise their discretion ‘only within fixed boundaries. In administering General Assistance relief the county acts as an agent of the state. [Citation.] When a statute confers upon a state agency the authority to adopt regulations to implement, interpret, make specific or otherwise carry out its provisions, the agency’s regulations must be consistent, not in conflict with the statute, and reasonably necessary to effectuate its purpose.’ ” (County of San Diego v. State of California (1997) 15 Cal.4th 68, 100 [61 Cal.Rptr.2d 134, 931 P.2d 312], citation omitted; see Alford, supra, 151 Cal.App.4th atp. 29; Nelson v. Board of Supervisors, supra, 190 Cal.App.3d at pp. 29-30.)
Section 17001.5, subdivision (a) provides authorization for counties to place various restrictions on the amount of and conditions for GA that it provides. The section begins, “Notwithstanding any other provision of law, including, but not limited to, Section 17000.5, the board of supervisors of each county, or the agency authorized by the county charter, may do any of the following . ...” In subdivision (a)(4) the statute authorizes the county to “[p]rohibit an employable individual from receiving aid under this part for more than three months in any 12-month period, whether or not the months are consecutive. This paragraph shall apply to aid received on or after the *355effective date of this paragraph. This paragraph shall apply only to those individuals who have been offered an opportunity to attend job skills or job training sessions.” The county implicitly acknowledges that the time limitation it has imposed on GA benefits contravenes state law unless the limitation is authorized by subdivision (a)(4). (See Mooney v. Pickett, supra, 4 Cal.3d 669 (Mooney).)
The county argues that section 17001.5, subdivision (a)(4) authorizes the time limitation it has imposed because section 17001.5 states explicitly that its provisions apply “[njotwithstanding any other provision of law.” The county devotes the greater portion of its briefs on appeal to its argument that “the plain language of the phrase ‘notwithstanding any other provision of law’ means what it says” and the majority seems to attach some weight to this argument. However, the county’s extended argument misses the point. Neither respondents nor the trial court (nor I) question that if section 17001.5, subdivision (a)(4) does in fact authorize the time limitation on those persons who the county considers to be employable, the restriction would be valid despite any more general provisions of the Welfare and Institutions Code to the contrary. The controversy concerns whether subdivision (a)(4) does in fact authorize such a limitation, which in turn depends on the meaning to be ascribed to the term “employable” as it appears in that provision.
The county defends its interpretation of “employable,” which as correctly characterized by the trial court essentially equates the term with “able-bodied and mentally competent,”9 by reference to the dictionary. In its appellate brief, it states that “[d]uring oral argument [in the trial court], the county presented a definition of ‘employable’ found in the oft-cited Webster’s New World Collegiate Dictionary: ‘physically or mentally fit to be hired for work.’ ” Respondents point out that this definition is incomplete. The complete definition in the fourth edition of Webster’s New World Diet. (4th college ed. 2001) is “that can be employed; specif., a) physically or mentally fit to be hired for work b) meeting the minimum requirements for a specified position of work or position of employment.”10 Webster’s New Collegiate Dictionary (1979) defines the term simply as “capable of being employed,” as does the more recent Merriam-Webster’s Collegiate Dictionary (11th ed. 2003). From these various dictionary definitions, one can conclude at most that the term is reasonably susceptible to more than one interpretation. One linguistically acceptable use of the term may be to refer to persons *356who are physically and mentally capable of performing work. Another equally acceptable use of the term is to refer to persons who are not simply able-bodied but who in fact employers are willing to employ. (See, e.g., Mumford, The Condition of Man (1944) p. 209 [“[T]he artist, who was the most courted figure of the fifteenth century, became ultimately the chronic unemployable of the nineteenth century.”]; Gallagher et al., State General Assistance Programs 1998 (Urban Inst. 1999) p. 25 [“Persons with disabilities, elderly persons, and other unemployable persons are the most likely to be eligible for General Assistance.” (italics added)].) In this sense, a healthy individual who speaks only a foreign language and has no job skills may not be employable, especially during periods of economic downturn and reduced employment.11
Recognizing that the term “employable” is linguistically susceptible to the interpretation that the county has given it does not end the inquiry, despite the discretion that the county exercises in administering the welfare statutes. The question is not what interpretation the language will bear, but what meaning was intended by the Legislature. That is a question that ultimately must be determined by the courts. (Whitcomb Hotel, Inc. v. California Employment Com. (1944) 24 Cal.2d 753, 757 [151 P.2d 233].) In County of San Diego v. State of California, supra, 15 Cal.4th at pages 100-104, for example, the Supreme Court refused to accept a definition of “indigent persons” that limited those entitled to GA benefits more strictly than contemplated by the statutory scheme. The Supreme Court explicitly disapproved of a Court of Appeal statement “that a county’s responsibility under section 17000 extends only to indigents as defined by the county’s board of supervisors.” (Id. at p. 101, fn. 23; see Alford, supra, 151 Cal.App.4th at pp. 33-34.) For the same reason, the fact that other counties may have adopted a similar definition of employable individuals subject to time limitations on their receipt of GA benefits is not determinative of what the Legislature has intended.12 “Again and again our courts have voided county ordinances which have attempted to redefine eligibility standards set by state *357statute.” (Washington v. Board of Supervisors (1993) 18 Cal.App.4th 981, 985 [22 Cal.Rptr.2d 852]; cf. Rojas v. Woods (1981) 127 Cal.App.3d 286, 290 [179 Cal.Rptr. 420] [invalidating State Department of Social Services regulation that disqualified AFDC (Aid for Dependent Children) applicants from receiving benefits for 30 days if they left employment without good cause; the department “had no power to impose a mode of pressure [to obtain employment] that the Legislature had not elected to adopt”].)
There are numerous reasons to conclude that “employable individual^]” as used in section 17001.5, subdivision (a)(4) was not intended by the Legislature to refer to able-bodied persons who are unable to obtain employment— because they lack the necessary skills, language ability or other qualifications deemed necessary by employers for employment or simply because economic conditions are such that there is no employment available. Excluding such persons from coverage would be at odds with the entire scheme and purpose of the GA statutes. As the courts have repeatedly pointed out, GA “is a program of last resort.” (E.g., County of San Diego v. State of California, supra, 15 Cal.4th at p. 92.) Section 17000 creates a “residual fund” to sustain indigents who have no other means of support and cannot qualify for benefits under any other specialized aid program. Limiting the right to more than three or six months of GA to those who are unable to work because of physical or mental incapacity limits that right to persons most likely to be entitled to welfare benefits under other federal and state programs (see, e.g., 42 *358U.S.C. § 1381 et seq. [Supplemental Security Income for Aged, Blind, and Disabled]; Welf. & Inst. Code, § 12000 et seq. [State Supplementary Program for Aged, Blind and Disabled]), and thus to persons who are not entitled to GA in the first place. (Hunt, supra, 21 Cal.4th at p. 991 [“section 17000 ‘creates “the residual fund” to sustain indigents “who cannot qualify . . . under any specialized aid programs” ’ ”].) However, if despite all diligent efforts a physically fit indigent person cannot obtain employment, deeming the person employable and limiting or denying GA on that basis is contrary to the fundamental purpose of providing GA to those who have no other source of relief.
The incongruence of the county’s interpretation and the fundamental purpose of the statute is brought into sharp contrast by the decision in Mooney. There, prior to the enactment of section 17001.5, San Mateo County attempted to limit GA benefits pursuant to section 17000 by adopting the so-called “employable single man” rule, under which nonemergency GA benefits were denied to employable single men. (Mooney, supra, 4 Cal.3d at pp. 671, 672-673.) “The term ‘employability’ . . . [was] used by the county to denote merely that a man is physically and mentally fit for work; it [did] not signify that a job awaits him.” (Id. at pp. 679-680.) In voiding the county’s regulation the Supreme Court observed: “Even in time of full employment a person may be physically and mentally fit, but lack necessary skills to obtain a job; in periods, such as the present, of substantial unemployment, even the skilled and experienced worker may be unable to obtain work. To the man who cannot obtain employment his theoretical employability is a barren resource; it is inedible; it provides neither shelter nor any other necessity of life. Until he can get a job, he does not differ in economic resources from the man whose unemployment stems from more personal disabilities.” (Id. at p. 680.) In enacting subdivision (a)(4) of section 17001.5, there is no reason to believe that the Legislature intended to embrace a definition of employability so forcefully discredited by the Supreme Court in the oft-cited Mooney opinion. (See, e.g., People v. Superior Court (Zamudio) (2000) 23 Cal.4th 183, 199 [96 Cal.Rptr.2d 463, 999 P.2d 686] [“We do not presume that the Legislature intends, when it enacts a statute, to overthrow long-established principles of law unless such intention is clearly expressed or necessarily implied.”]; see also, e.g., Ohio Casualty Ins. Group v. Superior Court (1994) 30 Cal.App.4th 444, 449 [35 Cal.Rptr.2d 771].)
Nor is there reason to believe the Legislature intended to use the term “employable” in a sense that so far departs from its common understanding in the marketplace. According to the declaration of former Secretary of Labor Robert B. Reich, which is included in the record, the phrase “able bodied and mentally competent” is “typically used to describe a person without serious *359physical impairments or mental/psychological disorders such as a developmental disability or mental illness. It is used to evaluate whether a person is capable of performing the functions necessary to daily living, not whether the person is capable of getting employment. A person who is ‘able bodied and mentally competent’ is not necessarily ‘employable’ because he or she may not be capable of becoming employed. In my view, ‘employable’ means that a person can reasonably compete for employment in the local labor market. Physical and/or mental disabilities are, of course, relevant but they do not alone determine whether a person is ‘employable’ in this practical sense, [f] . . . [I]n a weak job market, persons with disabilities, few job skills and no employment history are not likely to be capable of obtaining jobs. Hence, they are not, practically speaking, ‘employable.’ ”
This understanding is confirmed throughout the record. (E.g., declaration of Dr. Gerald Belchick, a vocational expert who commonly testifies before the Social Security Administration [“Various factors must be considered in evaluating employability. These factors include physical and mental disabilities and limitations, but also include age, education, work experience, or lack thereof, and literacy.”].) It is also confirmed in the literature. (E.g., Holzer, What Employers Want: Job Prospects for Less-Educated Workers (1996) pp. 62-66, p. 132 [“for the least-skilled, least-educated, and least-experienced members of our society there appear to be a very limited number of jobs available in the short term”].) The Dictionary of Business Terms, published online by AllBusiness.com, defines “unemployable” as “those who are not employable because of their lack of skills, education, and experience.” (<http://www.allbusiness.com/glossaries/unemployable/4944054-1 .html> [as of Sept. 3, 2009].)
Another generally recognized category of individuals who cannot obtain employment is persons who are providing necessary childcare or daily home care for disabled relatives and have no other means of providing such care to those who are dependent upon them. (See, e.g., Goldberg & Collins, Washington’s New Poor Law: Welfare “reform” and the roads not taken, 1935 to the present (2001) pp. 247-249; Maynard, Subsidized Employment and Non-Labor Market Alternatives for Welfare Recipients in The Work Alternative: Welfare Reform and the Realities of the Job Market (Nightingale & Haveman edits., 1995) pp. 113, 119-120; see also L.A. County Gen. Assistance Relief Regs., § 41-202(b), (e).) Had the Legislature intended to authorize a new limitation on GA to such persons, one can only assume that the Legislature would have made such an intention clear. (Cf., e.g., Franzosi v. Santa Monica Community College Dist. (2004) 118 Cal.App.4th 442, 450 [13 Cal.Rptr.3d 25] [“Looking to the whole system of law related to employees in the Education Code, we find the Legislature *360knows how to specify the ‘date of the approval of the disability allowance’ when it desires to designate that date.”]; De Anza Santa Cruz Mobile Estates Homeowners Assn. v. De Anza Santa Cruz Mobile Estates (2001) 94 Cal.App.4th 890, 911 [114 Cal.Rptr.2d 708] [“one can infer that the Legislature, if it intends a stated remedy to be nonexclusive or cumulative, knows how to express such a concept, and its silence on the subject therefore indicates a contrary intent”].) There is nothing in the history leading to the adoption of section 17001.5 or any of its subdivisions to justify the assumption that the Legislature intended to permit counties, by deeming such caretakers “employable,” to limit to three months of the year essential relief to indigents who cannot accept employment because of their need to care for others.
There are other indications that the Legislature did not intend to equate “employability” with being able-bodied and mentally competent. Prior to the enactment of subdivision (a)(4) of section 17001.5, former subdivision (a)(3) authorized counties to discontinue GA benefits for up to 180 days to “able-bodied and mentally competent” recipients failing without good cause to participate in a qualified job training program or failing to engage in certain other conduct that might affect their ability to obtain employment. (Stats. 1992, ch. 719, § 14, p. 3330.) At the same time that the Legislature added subdivision (a)(4) to the statute, it amended subdivision (a)(3) by replacing the phrase “able-bodied and mentally competent” with the word “employable.” (Stats. 1996, ch. 6, § 9, p. 29.) The clear inference is that the Legislature did not consider the terms to be synonymous, and that by an “employable individual” something other than able-bodied and mentally competent was intended. This inference is confirmed by the Department of Finance Enrolled Bill Report on the proposed amendments contained in Senate Bill No. 681 (1995-1996 Reg. Sess.), which states, “This bill would alter the criterion of ‘able-bodie[d] and mentally competent’ by changing it to ‘employ[able].’ Counties believe the current criteria are too restrictive and that it is difficult to get many recipients into job training.”13 Yet, the county has now interpreted “employable” to be the equivalent of the very language for which this qualifier was substituted when the Legislature amended the statute.
Amicus curiae, the California State Association of Counties, argues that by expanding the scope of those to whom section 17001.5, subdivision (a)(3) applies, the Legislature restricted the population entitled to non-time-limited GA cash benefits, presumably indicating that subdivision (a)(4) should also *361be interpreted in a manner to achieve such a restriction. However, the modification that was made to subdivision (a)(3) reflects the acknowledgement that the ability to obtain employment is not determined exclusively by one’s physical and mental health. In some cases a person with physical or mental disabilities may be employable, and in other cases a person without such disabilities may nonetheless be unable to obtain employment.
Amicus curiae also argues that various amendments made to the GA statutes in 1991, 1992, and 1996, including the addition of subdivision (a)(4) to section 17001.5, were all intended to reduce assistance costs to the counties in recognition of “the fiscal tightrope that counties must walk in order to meet the general mandate to provide Section 17000 aid while also providing other vital county services.” We are told “the Legislature focused on protection, at the expense of the indigent population, of both its coffers and the coffers of local government.” While the Legislature may indeed have authorized various reductions and restrictions because of fiscal pressures, the resulting statutory provisions are not to be interpreted simply with the aim of minimizing the financial burden on the counties. The statute still mandates that its provisions “be fairly and equitably construed to effect the stated objects and purposes of the [GA] program.” (§ 11000; see Hunt, supra, 21 Cal.4th at pp. 1005-1006; Alford, supra, 151 Cal.App.4th at pp. 27-29; Oberlander v. County of Contra Costa (1992) 11 Cal.App.4th 535, 538-539, 543-545 [15 Cal.Rptr.2d 182].)
The amendments made to the GA statutes during the 1990’s to which amicus curiae refers, described more fully in the majority opinion (at pp. 332-335, ante), authorize counties to impose various conditions and restrictions on GA benefits that had not previously been authorized. These measures were designed to permit counties to structure their programs to reduce GA expenditures and to encourage greater efforts by those on welfare to seek employment, consistent with the nationwide attempt at the time to move unemployed persons from “welfare to work.” (See generally Harvey, supra, 21 Berkeley J. Emp. & Lab. L., pp. 687-689 & fn. 21, 747, fn. 221; Quigley, Backwards into the Future: How Welfare Changes in the Millennium Resemble English Poor Law of the Middle Ages (1998) 9 Stan. L. & Pol’y Rev. 101, 104 [“Like the earliest English Poor Laws, forcing poor people to work is the core theme of the 1996 welfare changes.”]; Wilson, When Work Disappears: The World of the New Urban Poor (1996) pp. 164, 168; Burtless, Employment Prospects of Welfare Recipients in The Work Alternative: Welfare Reform and the Realities of the Job Market (Nightingale & Haveman edits., 1995) pp. 73-75.) However, these restrictions were defined and limited; none permit counties to abandon their responsibility to provide minimal assistance to indigents who, despite their best efforts, are unable to obtain employment.
*362Section 17000.5, enacted in 1991, permits counties to include the value of in-kind aid, including a portion of the actuarial value of medical care, in establishing their GA standard of aid. However, the statute establishes a firm minimum standard. Moreover, when an appellate court held that a county could satisfy its obligation under section 17000 to furnish health care to indigent residents by merely providing the GA standard of aid specified in section 17000.5, this view was quickly repudiated by both the Supreme Court and the Legislature, the Supreme Court emphasizing the continuing vitality of “the objectives of the statutory scheme governing indigent relief—to provide for the protection, care, and assistance of all the needy and distressed people of the state, and to administer appropriate aid and services promptly and humanely. (§ 10000.)” (Hunt, supra, 21 Cal.4th at pp. 1005-1006, italics omitted.)14
Section 17001.5 authorizes several other restrictions that counties are authorized to adopt, but none without limitations. Subdivision (a)(1) permits counties to adopt residency requirements for the purpose of determining eligibility for GA, but the requirement “shall not exceed 15 days” and may not exclude homeless persons by requiring recipients to “have an address.” Subdivision (a)(2), as it now reads, again permits counties to establish special GA standards for those who share housing with unrelated persons. The subdivision prescribes limits on the amount by which benefits may be reduced to such persons (§ 17001.5, subd. (a)(2)(A)); in Oberlander, after again acknowledging the continuing obligation of the counties to provide GA to the indigent (Oberlander v. County of Contra Costa, supra, 11 Cal.App.4th at pp. 538-539), the court invalidated a county’s attempt to reduce the benefits to persons sharing housing to less than authorized by the statute. (Id. at pp. 543-545.)
Similarly, section 17001.5, subdivision (a)(4), the focus of the inquiry in this case, permits counties to limit GA benefits to three months in any 12-month period, but only with respect to employable individuals. As indicated by the explicit qualification in this subdivision that before a county may terminate benefits it must offer applicants the opportunity to attend job skills or job training sessions, the time limitation is intended to incentivize individuals to take the steps necessary to seek and obtain employment. GA may be discontinued if a physically fit individual fails to accept reasonable employment or fails to participate in a job training program. (E.g., § 17001.5, *363subd. (a)(3), (5).)15 The statutory purpose of encouraging diligent efforts to obtain employment is accomplished by enforcing these conditions, not by adopting the fiction that people who simply cannot get a job are nonetheless necessarily “employable.”16 Nowhere in the language or history of this provision is there a suggestion that persons who, despite their best efforts, are unable to obtain employment can nonetheless be deemed “employable” and denied minimal, last-resort, GA subsistence benefits for nine months of the year. Interpreting “an employable individual” as used in section 17001.5, subdivision (a)(4) in a manner that corresponds with workplace reality would not, as the majority asserts, read subdivision (a)(4) out of the statute; rather, it *364is the county’s artificial definition of “employable” that eviscerates the meaning of this statutory qualification as it relates to an untold number of individuals.
The county’s expansive interpretation of “employable” is not the means the Legislature has provided for a county to obtain relief if the GA obligations become greater than the county’s finances can bear. Rather, section 17000.6, first enacted in 1993 (Stats. 1993, ch. 72, § 1, p. 1059) and reenacted as part of the same legislation by which subdivision (a)(4) was added to section 17001.5 (Stats. 1996, ch. 6, §§ 8, 9, pp. 28, 29), permits a county to reduce the level of aid if the Commission on State Mandates makes a finding that meeting the standards in section 17000.5 would result in significant financial distress to the county. (§ 17000.6, subd. (a).) The availability of this escape mechanism emphasizes that defining the conditions of eligibility in a manner that does not comport with the basic purpose and structure of the GA program is not the means the Legislature intended to address whatever financial strain the mandate of sections 17000 and 17000.5 may place upon the county. (See Washington v. Board of Supervisors, supra, 18 Cal.App.4th at p. 986 [a county in financial extremes “may not meet its financial burdens by redefining state standards of eligibility”].)
The writ of mandate that the trial court issued here correctly recognizes the overbreadth of the manner in which the county has defined those whose GA benefits may be time limited because they are “employable individual[s].” (§ 17001.5, subd. (a)(4).) The writ does not improperly invade the province of the county. It would leave to local authorities the task of revising the governing regulations to comply with the statute, by delineating those who are unemployable in a manner that recognizes factors in addition to physical and mental capacity that may render an otherwise eligible person unable to obtain employment despite his or her best efforts to do so.17 By permitting the county to ignore the myriad of additional factors that may render a person incapable of obtaining employment, the majority sanctions what can only be characterized as throwing out the baby with the bath water. While section 17001.5, subdivision (a)(4) permits the county to time limit relief to persons *365who are employable, it does not permit the county to deny relief for up to nine months of the year to indigent persons who no one in the marketplace is willing to employ. I would affirm the judgment of the trial court.
Respondents’ petition for review by the Supreme Court was denied December 2, 2009, S177058. Moreno, J., was of the opinion that the petition should be granted.
All statutory references are to the Welfare and Institutions Code unless otherwise indicated.
According to data released by California’s Employment Development Department (EDD), unemployment in Alameda County rose from 6.5 percent, or 50,500 persons, in July 2008 (EDD Rep. 400 C (Mar. 5; 2009)) to 11.5 percent, or 90,000 persons, in July 2009. (EDD News Release No. 09-53 (Aug. 21, 2009) p. 4 [preliminary figures].) Unemployment in California rose from 7.3 percent in July 2008 to 11.9 percent in July 2009, a loss of between 760,200 and 798,000 jobs. (EDD News Release No. 09-53, supra, p. 1.) Nationwide unemployment in July 2009 was 9.4 percent of the workforce. (Ibid.)
All further regulation references are to the Alameda County General Assistance Regulations.
Regulation 9-2-5.211 provides: “Unemployable applicants or recipients are determined to meet one or more of the following conditions: [f] a. Have a physical, mental or emotional incapacity that prevents the person from working for 12 months or longer; this includes former SSI Drug & Alcohol persons who meet this criteria. H] b. Have a temporary physical, mental or emotional incapacity that prevents the person from working for a specified time period, which is less than 12 months. The period of incapacity does not include short term illnesses such as colds, flu, etc. that result in being unemployable for less than one calendar month. H] c. They are 64 years of age or older.”
ACGO section 7.08.060 provides that the agency shall administer an “employability program” under which, among other things, “[otherwise eligible employable recipients become ineligible to receive general assistance after receiving three months of benefits within any twelve (12) month period,” “a determination of unemployability shall be based on a written medical report as required by the agency,” and an employable recipient is defined as “a recipient who does not have a medical statement of unemployability on file with the agency.” (§ 7.08.060.A., E, B., G.) The statement of unemployability form used by the county (form 90-2) designates two categories of employable persons, those subject to no work restrictions and those subject to some work restrictions.
The record indicates that the county had designated 6,462, or more than 75 percent of its 8,510 GA recipients, as employable.
“Section 17000 states: ‘Every county and every city and county shall relieve and support all incompetent, poor, indigent persons, and those incapacitated by age, disease, or accident, lawfully resident therein, when such persons are not supported and relieved by their relatives or friends, by their own means, or by state hospitals or other state or private institutions.’ ”
“Section 17001 states: ‘The board of supervisors of each county, or the agency authorized by county charter, shall adopt standards of aid and care for the indigent and dependent poor of the county or city and county.’ ”
The only qualification to this characterization is that the county regulation also classifies as unemployable all persons 64 years of age or older.
What is missing from the county’s partial quotation of this dictionary definition is not only the second specific example of the use of the word, but the critical basic definition of the term: “that can be employed.”
See, e.g., Harvey, Combating Joblessness: An Analysis of the Principal Strategies that Have Influenced the Development of American Employment and Social Welfare Law During the 20th Century (2000) 21 Berkeley J. Emp. & Lab. L. 677, 709, footnote 112 (Harvey) (“[T]he line employers draw between ‘employable’ and ‘unemployable’ candidates varies depending on how many positions they need to fill relative to the available supply of labor. At the top of the business cycle and in geographic areas where aggregate demand is above average, employers find a larger portion of the labor force ‘employable’ as compared to other points in the business cycle and in geographic areas where aggregate demand is less robust. This is not surprising. When employers collectively need more workers, they lower their standards (and maybe give up some irrational biases) in order to hire the workers they need.”).
The county brought to the court’s attention GA regulations adopted in several other counties. Although some of these regulations are superficially comparable to the Alameda County regulations, none appear to be as extreme. The regulations adopted in Los Angeles County, for example, classify as unemployable not only individuals who are unemployable *357because of a physical incapacity or a mental disability, but those who are “[a]dministratively unemployable—individuals who are unemployable for reasons other than physical.” (L.A. County Gen. Assistance Relief Regs., § 41-301.5.) “This means,” the regulations further state, “there are reasons other than physical or mental incapacity which prevents the individual from finding, accepting or continuing existing employment.” (Id., § 41-201, original boldface.) These regulations then specify 13 different reasons for which a person may be deemed administratively unemployable, including being enrolled in a California Department of Rehabilitation training program, providing full-time care to an incapacitated family member when other arrangements cannot be made, providing necessary infant care, participation in a mandatory substance abuse recovery program when a court-ordered reunification plan for a child is in effect, and when the person is “determined administratively unemployable by the District Director/Deputy District Director.” (Id., § 41-202.) The regulations adopted in San Diego County include persons with limited English-speaking capability or literacy or limited job skills as able-bodied and thus presumptively employable, but provide further that “[t]hese persons may be eligible to receive extended aid if they have extenuating circumstances, have a verified course of action to address and/or correct the situation within a limited time, and are approved for a hardship waiver from time limits by the GR Program Manager.” (San Diego County Gen. Relief Selected Employability Regs., § C-l(3).) In Placer County, recipients are not classified as employable if they are “[njeeded in home or to care for a child or children age 3 and under when no other child care arrangements can be arranged.” (Resolution: Gen. Relief Program of Placer County, § 5(A)(1)(c).) In Mono County, the determination of employability is based upon either a job assessment and/or a mental health status evaluation. (Mono County Code, § 7.50.130(E).) In all events, whatever the situation may be in other counties, much less in other states under different statutes, the issue remains one for final determination by the courts.
The report includes what apparently are two typographical errors. The report refers to “able-bodies” rather than “able-bodied” and to “employment” rather than “employable.” The corrected terms are the terms that appeared in the former statute (“able-bodied”) and in the amended statute (“employable”).
The Legislature, for its part, promptly enacted section 17000.51 to correct the appellate court’s misinterpretation of its intent and to clarify that, despite the potential cost savings, “a county’s discretion granted pursuant to Section 17000.5 . . . was not intended, and shall not be construed, to . . . [among other things] [][]... [s]atisfy, in whole or in part, the duty of a county ... to provide health care services to indigent and dependent poor persons under Section 17000.” (§ 17000.51, subd. (a)(1), as added by Stats. 1997, ch. 294, § 84.)
It is within the counties’ broad discretion to impose job training or work-related requirements on recipients that are classified as unemployable by virtue of circumstances unrelated to their physical or mental health. (See Pettye v. City and County of San Francisco (2004) 118 Cal.App.4th 233, 238 [12 Cal.Rptr.3d 798] [§ 17001 confers upon counties a broad discretion “ ‘ “to determine . . . conditions to be attached to indigent relief’ ’ ”]; § 17001; § 17200 [“Work may be required of an indigent, who is eligible to receive benefits under Section 17000, and who is not incapacitated by reason of age, disease, or accident, as a condition of relief.”].) Subdivision (a)(3) of section 17001.5 authorizes a county to sanction an “employable” recipient who, among other things, fails without good cause to participate in a required job training program or accept an offer of employment, but subdivision (a)(5) of section 17001.5 is broader and, “[n]otwithstanding paragraph (3),” authorizes a county to “discontinue aid to, or sanction, recipients for failure or refusal without good cause to follow program requirements.” Collectively, these subdivisions were enacted for the purpose of allowing “counties to discontinue aid for those recipients who refuse to participate in job training or accept an offer of employment.” (Dept, of Finance, Enrolled Bill Rep. on Assem. Bill No. 1012 (1991-1992 Reg. Sess.) Aug. 19, 1992, p. 2.) Although subdivision (a)(3) of section 17001.5 implies that job training and employment requirements will most often be imposed on “employable” recipients, subdivision (a)(5) nonetheless provides a mechanism for enforcing such requirements with respect to all physically fit recipients, whether employable or unemployable. Thus, the county’s limited and unrealistic construction of those who are unemployable is not necessary, as the majority asserts (at pp. 341-343, ante), to avoid the undesirable consequence of eliminating job training requirements for able-bodied persons who are unemployable because they lack English proficiency, job skills or other employment prerequisites.
Although respondents in this litigation have not attempted to show that the job skills and training sessions provided by Alameda County are insufficient to justify the imposition of time limits under section 17001.5, subdivision (a)(4), the record contains suggestions that these programs may be woefully inadequate. Improved general educational and job training programs, as well as programs designed to provide such support as childcare, will tend to reduce joblessness and dependence on welfare. (See, e.g., Goldberg & Collins, Washington’s New Poor Law: Welfare “reform” and the roads not taken, 1935 to the present, supra, at pp. 243-249; Holzer, What Employers Want: Job Prospects for Less-Educated Workers, supra, at pp. 45-70; Burtless, Employment Prospects of Welfare Recipients in The Work Alternative: Welfare Reform and the Realities of the Job Market, supra, at pp. 94-102.) The point for present purposes is that in order to achieve the legislative objectives, emphasis should be placed on providing improved training programs and job-seeking assistance and insisting that unemployed GA recipients utilize those services, rather than by defining the problem away by deeming persons who cannot obtain work nonetheless “employable.”
As indicated above (see fn. 12, ante), other counties have chosen diverse methods of defining those who are employable for the purpose of applying a time limit to GA benefits. Moreover, the record also reflects employability guides that have been adopted in California and in other jurisdictions to determine entitlement to benefits under the federal Temporary Assistance for Needy Families program, implemented in California as the CalWORKs program. (§ 11200 et seq.) According to the Director of Policy for the Alameda County Social Services Agency, the assessment criteria for this purpose include the participant’s work history, skills, knowledge and abilities, educational history and educational competency level, need for supportive services, as well as “an evaluation of the participant’s chances to get a job given his/her skills and the local job market.” The trial court’s order would leave to the county the discretion to draw from these or other sources in fashioning appropriate criteria of employability.