In Erlich v. City of Culver City (1996) 12 Cal.4th 854, the court concluded there was no rough proportionality between a $280,000 mitigation fee imposed by the city on the owner of a private recreational facility. The city assessed the fee in connection with permitting a change to a nonrecreational use to compensate it for the loss of much needed recreational space. The Erlich court concluded the fee was disproportionate to the extent of the impact because it required the owner to pay for public recreations facilities, when what was being lost was private, commercial recreational facilities. (Id. at p. 883.)