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In Georgia-Pacific Corporation V. California Coastal Commission, 132 Cal. App. 3d 678, 699 (1982), the court stated: "A regulatory body may constitutionally require a dedication of property. in the interest of the general welfare as a condition of preventing land development. It does not act in eminent domain when it does this, and the validity of the dedication requirement is not dependent on a factual showing that the development has created the need for it." However, the statute itself as in the School Facilities Act (S5 659702 et seg.) can create a more direct nexus (see McLain Western No. 1 v. County of San tl Diego, 146 Cal. App. 3d 772 (1983)). d A good review of the legal relationship needed in subdivision or other type of land use exactions was set forth by the federal appellate court in Parks v. Watson, 716 F.2d 646 (9th Cir. ) (1983) , wherein the court stated: A city allows a developer to subdivide land in return for a contribution, typically of land for streets within the subdivision or for a park or school. Developer then challenged the requirement as a taking without just compensation. At one extreme, the older Illinois rule "permits an exac- tion only if the 'need' for the facility being financied is 'specifically and uniquely attribu- table' to the subdivider's developer." Ellickson, Suburban Growth Controls: An Economic and Legal Analysis, 86 EAL L.J. 385, Ul 82 (1§T7) f Pioneer Trust and Savings Bank v. Villa a of Mt. PProos22ct, �1. 2d 375, 1�.E. 79 62 (19 l� ) . But see Plote, Inc. v. Minnesota Alden Co., 96 Ill. At t ie other extreme, Cali orn a requires only that the exaction have some relationship to the needs of the subdivision or to the increased needs of the city', caused by the additional popula- tion brought by the subdivision. Associated Home Builders v. City of Walnut Creek, 4 Ca1.3d 640-641, 484 P.2d 606, 611-613 (1971). But there is agreement among the states "thc,: the dedication should have some reasonable relationship to the needs created by the subdivision." Hall v. Cit of West Jordan, 606 P.2d 217, 220 (Uta-i 1� Footnote omitted). The latest case stressing the rule that there only be an indirect relationship between a prorosed exaction and 2A11 code references are to the Government Code of tie State of California unless otherwise noted. -9-