HomeMy WebLinkAbout20 ORD BANNING GIFTS 08-01-94? ENDA; ....
NO. 20
8-1-94
Inter-eom
DATE: July 12, 1994
TO:
FROM:
SUBJEC~
WILLIAM A. HUSTON, CITY MANAGER
CITY ATTORNEY
ORDINANCE BANNING GIFTS OF $250
OR MORE
Enclosed for the consideration of the City Council is a
proposed ordinance banning the acceptance of gifts aggregating $250
or more. The ordinance is similar to restrictions on state
officers. The amount of the limit is designed to coincide with
existing provisions of state law affecting local officials. Under
the Political Reform Act, gifts of $250 or more are permissible,
but a City officer or designated employee may not participate in
making or in any way attempt to use their official position to
influence a governmental decision in which there will be a material
financial effect on any donor, intermediary or agent for a donor of
gifts, aggregating $250 or more. The concept of the proposed
ordinance is that if you don't accept such gifts you won't ever be
in a position of potentially participating in a decision involving
a gift donor.
We have suggested alternate wording for your consideration:
either a ban on gifts of $250 or more or a ban on gifts up to $249.
The point is that once you hit $250 you are in the red zone, but up
to $249, gifts are permitted. The Council should decide which
wording it prefers.
The proposed ordinance is similar to but not identical to the
Levine Act, found in Government Code section 84308. That section
applies to appointed officials and specifically addresses campaign
contributions of more than $250. I have enclosed a copy of that
section for the City Council's information in case they wish to
incorporate any of its provisions into this ordinance.
Additionally, we have attached two pages from a Fair Political
Practices Commission Bulletin that describes gift prohibitions of
state law that will become effective January 1, 1995. The $270
limit will be adjusted in January of 1995 to reflect changes in the
Consumer Price Index. If the Council still wishes to proceed with
its owen ordinance, we recommend staying with a $250 limit because
it coincides better with other provisions of the Political Reform
Act.
Lois E. Oeff~,~y' ~' 0
L~J:p~/ca$ :D: 07/12/94: (~7)
Enclosures
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ORDINANCE NO. 1129
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY
OF TUSTIN, CALIFORNIA, REGARDING RESTRICTIONS
ON GIFTS
The City Council of the City of Tustin hereby ordains as
follows:
Section 1. Part 3 entitled "Restrictions on Gifts" is
hereby added to Chapter 2 of Article 1 of the Tustin City Code, to
read as follows:
PART 3 RESTRICTIONS ON GIFTS
1230 PURPOSE
The City Council finds that the receipt of excessive amounts
of gifts by public officials from persons who may do business with
the City erodes public confidence in the impartiality of decisions
made by those officials. The purpose of this Ordinance is to
prohibit the receipt of gifts, valued individually or cumulatively
at $250 or more, thereby eliminating, to the extent possible, suc}
loss of confidence.
1231 DEFINITIONS
Except as otherwise defined, the terms used in this Part 3
including the definition of "gift" shall have the same meaning as
defined in the California Political Reform Act (Title 9 of the
California Government Code) and regulations issued by the Fair
Political Practices Commission pursuant to the authority of the
Political Reform Act, as the Act and regulations shall be, from
time to time, amended.
For the purposes of this part:
(a) "City" means the City of Tustin.
(b)
"City Officer" means every person who is elected or
appointed to an office in the City which is specified in
Section 87200 of the California Government code.
(c)
"Designated Employee" means every employee of the City
who is designated in the City's Conflict of Interest Code
to file a Statement of Economic Interest and every member
of a board or commission under the jurisdiction of the
City Council required to file such a statement.
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Ordinance No. 1129
Page 2
1232 PROHIBITION
(a)
No City Officer or Designated Employee shall accept gifts
from any single source in any calendar year with a total
value, either individually or cumulatively, of two
hundred fifty dollars ($250) or more. [alternate wording
up to two hundred forty-nine dollars ($249)]
(b)
Gifts which are not subject to limitation under state law
and are not required to be disclosed on a Statement of
Economic Interest, pursuant to the Political Reform Act
and regulations of the Fair Political Practices
Commission, are not included within the prohibition of
1232(a) above.
1233 PENALTIES
(a)
Any City Officer or Designated Employee who violates the
provisions of Section 1232 shall be guilty of a
misdemeanor.
(b)
Any Designated Employee who violates the provisions of
Section 1232 may be subject to discipline for such
violation, including termination of employment, or
removal from office in the case of members of City boards
or commissions.
1234 NO CONFLICT WITH STATE LAW INTENDED
Nothing contained within this Part 3 is intended to conflict
with provisions of the California Political Reform Act or the
regulations adopted thereto by the Fair Political Practices
Commission, except that this Part 3 is intended to impose a
limitation on the acceptance of gifts not found in state law.
PASSED AND ADOPTED, at a regular meeting of the City Council
for the City of Tustin on this day of , 1994.
THOMAS R. SALTARELLI, Mayor
MARY E. WYNN, City Clerk
{3) The name, street address, ~.nd c~t) of the si ' ' '
· ' ' Slj~e~ the cammittee i' the contr~but on
mailer organization as required by paragraph y~d~e~d~.~ ~r~uired ~ file
the notice required by para.apb (2) may appe~on ~~ry: Ad'ed by ~u. 1979, Cb.
samy.~l~t (,[sur[a~.e,o[an m~erL.. --,. / ., . ~lercn.. at the urn. ofpublicaaon (.e pace
has paid Lo up.ar in the slate mailer is desi~a~d by ~,u,~: 2C.I.C~d~of~gs.~c~son 18421.]
an *. Any candidate or ballot measure ~t has, not ~id Eniurcement
W up~a~ in the sla~ mailer is not desi~a~d b~an *. Decismns: John Fur~k 90~0 (1992)
~ y , , I ~OlC~e ~65~1986)
legibility u~ is used for the name of~e candidate br ~e Bill Pre~n ~e~ Offshore CommJJack
ballot measure name or numar and ~siLion adv~d
w which the * desi~ation applies except that in no ~se .....
shall the * be required to be larger than ]0-point {~307. Commmg~g~Personal Funds.
~)ldfuce t~,po. The desi~ation sha immediately ~o11~ · No contribution shall.be commingled with the
the namc'~}f thc cundida~, or the name or number an~ ~rsonal funds of the recipient or any other per~n.
~sition advocated on the ballot measure whe;e ~ Hi,wry: Add~byS~.1979. Ch. 779.
measures Ir there is no sla~ listing, the desi~ation ~.
~hall 9pp~ur. ut I~ust once m at least 8-~mt ~l~uce ~ ~ciso~
type, ~mmed~u~}~ following the name of the ~ndidate, ~- -
or the name or number and ~sition advo~d on the [ Appointed Boards or Commissions;f ~
bullotmeusurc. /~ {~308. Contributions to Members o
(5) Thc name o[ any candidate appearing in the ~ Disqualification.
~a} 'I'Ve Oelmitmns set Iorth in this subdivision
slate mailer who is a member of a political party
differing l'r~m th~. political party which the mailer
appears by representation or indicia to represent is
accompunlcd, imn~ediate]y below the name, by the
party designation sit the candidate, in no less than 9-
point ruma~ typo which shall be in a color or print that
construsts with the background so as Lo be easily
legible. The designation shall not be required in the
case o/candidates lot nonpartisan office.
(b) For purposes of the designations required by
paragraph 141 of subdivision (al. the payment of any
sum made reportable by subdivision (c) of Section 84219
by or at thc. behest of a candidate or committee, whose
name ur pusithm appears in the mailer, to the slate
mailer' urguni~tion, shah constitute a payment to
appear requiring the * designation. The payment shall
also be deemed to constitute authorization to appear in
the mailer.
Jcl A slate mailer that complies with this section
shall hc deemed LO satisfy the requirements of Sections
] 1703 and ] 1704 of the E~ections Code.
§ 843(h5. Contributions Received by Agents of
Candidates or Committees.
All contributions received by u parson acting as an
agent of a candidate shall be reported promptly to the
candidate or uny of his or her designated agents. Ail
contribuLim,.~ received by a person acting as an agent of
u committee shall be reported promptly Lo the
cummittuc'.~ treasurer or any of his or her designated
agents. "Promptly" as used in this section means not
later tha~ the closing date of any campaign statement
shall govern the interpretation of this section.
(I) "Party" means any person who tiles an
application for, or is the subject of a proceeding
involving a license, permit, or other entitlement for use.
(2) "Participant" means any person who is not a
party but who actively supports or opposes a particular
decision in a proceeding involving a license, permit, or
other entitlement for use and who has a financial
interest in the decision, as described in Article I
(commencing with Section 87100) of Chapter 7. A
.person actively supports or opposes a particular decision
in a proceeding if he or she lobbies in person the o z~cers
or employees of the agency, tesLLfies in person before the
agency, or otherwise acts to influence o£1'icers of thc.
agency.
(3) "Agency" means an agency as defined in Section
82003 except t~ut it does not include the courts or any
agency in the judicial branch of government, local
governmental agencies whose members are directly
elected by the voters, the Legislature, the Board of
Bqualiza~.ion, or constitutional officers, llowever, this
section applies to any person who is a member of an
exempted agency but is acting as a voting member of
another agency.
(4) "Officer" means any elected or appointed o~ccr
of an agency, uny alternate to an elected or app~inted
~fficer of an agency, and uny candidate for elective uti]ce
(5) "l.icense, permit, or other entitlement fro' u~e"
means all business, professional, trade and land use
licenses and permits and all other entitlements for use.
including all entitlements for land use, all contracts
(other than competitively bid, labor, or personal
employment contracts), and all franchises.
//' ) Contribution includes contributions tu~"~
%candidates and committees in federal, state, or h,cal/
~elecLiuns.
r(bl No officer of an agency shall accept, solicil, or
ect a contribution o_f more than~ two hun~tr_e_~__fi~)£
39
dulJars ($250J from any party, or his or her agent, or
from un)' parDc~pant, 67 ~s-~3~-F-h'~u~g~nt, whilc
pr,ceeding involving a license, permit, or o:her
entitlement for use is pending before the agency und for
three months following the date a final decision is
rendered in the proceeding if the officer knows or has
reason to know that the participant has u financiul
re.rarest, .us that term is used in Article I (commencing
w~th S~ctaun 87100) of Chapter 7. This prohibition shall
apply regurdless of whether the officer accepts, solicits,
or direct~ the contribution for himself or herself, or on
behalf of any other officer, or on behalf of any candidate
for office or on behalf of any committee..
(c) Prior to renderin~ any decision in a proceeding
involving s license, permit or other entitlement for use
pending before an agency, each officer of the agency who
received u contribution within the preceding ] 2 months
in an umuunt of more than two hundred i~ffty dollars
15250} from a party or from any participant sh?.]]
disclose that fact on the record of the proceeding. No
ofl~cer of un agency shah make, participate in making,
or m any wuy attempt to use his or her official posit.ion
to influence the decision in a proceeding involving a
license, permit, or other entitlement for use pending
before the agency if the officer has willfully or
knowingly received a contribution in an amount of more
than two hundred fifty dollars ($250) within the
preceding 12 months from a party or his or her agent, or
from any participant, or his or her agent Lc the officer
knows or has reason to know that the participant has a
finuncial interest in 'the decision, as that term is
described with respect Lo public officiuls in ArLic e
Icommencing with Section 87l 00) of Chapter 7.
If an officer receives a contribution which would
-therwise require disqualification under this section,
ruLurns the contribution within 30 days from the time
be or she knuws, or should have known, about the
cuntribuLiun and the proceeding involving a license,
permit, ur uther entitlement for use, he or she shall be
permitted to participute in the proceeding.
Idl A party to a proceeding before an agency
involving a license, permit, or other entitlement for use
shall disclose on the record of the proceeding any
cuntribution in an amount, of more than two hundred
fifty dollars ($250) made within the preceding 12
munths by the party, or his or her agent, to any officer or
the agency. No party, or his or her agent, to a
proceeding involving u license, permit, or other
untttlumun! fur use pending before uny agency und nu
participant or his ur her ugenL, in the proceeding shull
make a contribution uf more than two hundred fifty
dollars ($250) to any officer u£ that agency during the
proceeding and for three months following the dote u
final decision is rendered by the agency in the
pruceeding When a closed corporation is a party to, or u
participant in, u proceeding invo ring a license, permit.
or other entitlement for use pending before an agency,
the majority shureholder is subject to the disclosure
prohibiLiun' requirements specified in subdivisions (bt
lc), and this subdivision.
lei Nothing in this section shall be construed tu
imply that any contribution subject to being reported
under this title shall not be so reported.
I~gulat,a~: 2C, aI.C~deofR~g~ ~ectim~ 1843~ 2 Cal. Code ofl~gs l~ect~un ] 8438
~ C~ L ~e or ~. ~ction I N43~'o
2 ~t. C~e of ~gz. ~caun ]
2 6mi. ~e of~g~ ~ct~on 18438.G
2 Cat ~e of ~g~. ~ctmn 1
2 Cal. ~e of ~g~. ~ct~Un I &43~.~
~~417 ~1990~
na .87~16~ 19~8~
~ ~309. Transmittal of Campaig~
~tribufions ~ S~ O~ee Buildings. -
~) No ~rson shall receive or ~rsonally delivt~' n
er a eontributlon in the 5~ Capi~l,
o~ee building, or in any o~ce for which th
s~te the majority of the rent other/~hun
leash o~ce.
(b) r pur~ses of this ~cfion: d
(l) ersonully deliver" means eli~erv of
contr ~ in ~on or ~using a contri~utio~ tu
delivered ~y ~ agent or in~rme~iary.
(2) tcludes the receipt of u campaigr
contribution ~ in ~r~n.
~leregJces mt ~ ~ubli~on ~ page ~;:
§ 84400. Exer
NotwithsL
commission shall
inclqding uny.candida!
req
· ' of the luw. thc
corem.it.tee, from u'ny o£ the
s of this chap! (-r
Article ~tive Advertising.
§ 84~01-84514 ,epealed I
ISections 8d0l . 84514 ~euled by
Ch- ] 7 ], eff~e ~anuary l, ,~ .....
Ghap~r 5. ~fions o~ ribu tic ~ s.
A~icle 1. Appli~bilityand De tions.
/ 85]04
/ 2. Candidacy. t 85200.
~ 3. Con~ibu~on Limi~
85307
ical Practi, Commission
APRIL/MAY/JUNE 1994
Commission Amends New Legislation
Definition of "Consultant," Expands /
Defines "Other Public Officials Who Gift/Honoraria
Manage Public Investments" Prohibitions
r-~--1t meetings held earlier
this year, the Commission
finalized and adopted regula-
tions designed to clarify who
"consultants" and "other pub-
lic officials who manage public
investments" are for purposes
of the Political Reform Act.
Under the Political Reform
Act, certain private sector
"consultants" who contract
with public agencies can be-
come public officials governed
by provisions of the Act. If this
occurs, they must abide by the
conflict of interest rules for
California government officials
and may be required to file fi-
nancial disclosure statements.
In 1976 the Commission
adopted Regulation 18700 (lo-
cated in Title 2, Division 6 of
the California Code of Regula-
tions), which defined who was
a ':consultant" subject to the
provisions of the Act. Over the
In this issue..
Enforcement Actions ..... -~g 2
Conflict of Interest
Issues .................. Pg 5
Campaign Issues ......... Pg 6
Lobbying Issues .......... Pg 11
Commission Updates ..... Pg 12
Fortune 500 Listings ...... Pg 13
Advice Summaries ....... Pg 18
years, it became apparent that
this definition was difficult to
apply. In 1992, the Commission
staff began holding meetings
with interested parties in an at-
tempt to make this definition
more understandable. It was
an extremely difficult process
and involved numerous pre-
sentations to the Commission
for policy direction.
At its April 1994 meeting,
the Commission adopted
amendments to Regulation
18700 clarifying the definition
of consultant. Generally, the
definition includes only those
individuals who, pursuant to a
contract with a state or local
government agency, make final
government ~lecisions or per-
form substantially all the same
duties for an agency that would
otherwise be performed by an
individual holding a position
specified in the agency's con-
filet of interest code.
Government Code Sections
_87200-R72~ set .forth very spe-
cific financial disclosure re-
quirements for elected public
officials, such as State Senators,
and other high-ranking but
non-elected public officials,
such as county counsel. In 1989,
Section 87200 was amended to
include within its scope ~other
public officials who manage
public investments." While Sec-
tion 87200 includes, for examt
r~ ssembly Bill 1542 has been
signed by the Governor
and wilt go into effect January
1, 1995. (Chapter 36, Stats.
1994.)
Existing provisions of the Po-
litical Reform Act (the "Act") ira-
pose a $1,000 gift and honoraria
limit on local elected officehold-
ers. AB 1542, which amends
Government Code Section
89501:
· Lowers the gift limit to th~
same amount imposed
elected state officers and des
ignated employees of state
agencies. Currently, the Act
prohibits elected state officers
and state agency officials
from accepting gifts totaling
$270 per calendar year from a
single source. (The gift limit is
adjusted biennially to reflect
changes in the Consumer Price
Index. The limit will be ad-
justed in January 1995.)
Prohibits honoraria payments.
An ~honorarium" is a pay-
ment received in consider-
ation for making a speech,
publishing an article, or at-
tending a public or private
conference, convention,
meeting, social event, meal,
or like gathering.
Expands the gift limit and
honoraria prohibition to ¢- '-
er local elected officials,
ignated employees of Ioco,
(Continued on I~ge ~ 2)
a Commission meeting during
the FPPC to order at 9:14 a.m. scheduled for adoption at the the month of August. ~'he next
rf~gularly scheduled Commis-
in the Commission Hearing
* Room, 428 J Street, Sacra-
mento. In addition to Chair-
man Davidian, Commissioners
Richard Brandsma, Raquelle de
la ROcha, and Deborah Seller
were present. Commissioner
Rushford was absent.
The Commissioners adopted
Regulation 18940--Guide to
Gift Regulations, Regulation
18944.2--Gifts to an Agency,
and amendments to Regula-
tion 18726.7, to renumber to
· 18944.1--Recipient of the Gift:
Passes or Tickets Given to an
Agency. The Commissioners al-
so adopted amendments to
Regulation 18700--Public Offi-
~ cial Making or Participating in
Making a Governmental Deci-
sion (definition of "c -
tant"), onsul
The Commission approved a
fine of $92,000 in an enforce-
ment case against the
Yarmouth Group. Details of
the case are on page 4.
Chairman Davidian called
the May 5, 1994 meeting of the
FPPC to order at 9:10 a.m. in
the Commission Hearing Room,
428 j Street, Sacramento. In
addition to Chairman Davidian,
Commissioners Richard Brands-
ma, Raquelle de-la Rocha,
James Rushford, and Deborah
Seller were present.
Chairman David/an an-
nounced that there will b
~£ommission meeting in eAnu°-
J?ly meeting. The Commis-
sioners discussed the Glenn
vice letters (Nos.
A-92-3SBa) and directed Zhe
staff to prepare amendments
to Regulation 18703--Effect on
the Public Generally, for ~n order to provide more
prenoticed/scussioninJuly. L~_Jtimely information to
The Commissioner~ ap- those affected by the provi-
proved $53,000 in fines in three sions of the Political Reform
enforcement cases. Details of Act, the Commission will return
these cases may be found un-
der enforcement actions in this
bulletin.
Chairman Davidian called
the June 2, 1994 meeting of
the FPPC to order at 9:30 a.m.
in the Commission Hearin
Room, 428 J Street, Sacr
mento. In addition to Chair-
man Davidian, Commissioners
Richard Brandsma, Raquelle de
la Rocha, James Rushford, and
Deborah Seller were present.
The Commissioners rescind-
ed that portion of the
?_a~nchetti advice letter (No. 1-
91-301) which applied the lob-
byist contacts test to officers
eand_,employ, ees of a lobbyist
~p~oyer WhO meet with offi-
cials along with the employer's
paid registered lobbyist.
The Commissioners held
prenotice discussion of Re(
tion 18229--Definition
pendent Child. Additional
prenotice discussion will be
held at the July meeting.
The Commissioners a
proved $12,000 in fines in thr
s~on meetingwill be held Thurs-
day, September 1, 1994.
Bi-Monthly Bulletin
to bi-monthly publication of
the bulletin, the next publica-
tion will be July/August. You
should receive this issue during
the end of August. -
i$1ation (Continued from ~,age I,
government agencies, and
elected or appointed members
of the~overning boards of
special districts. ("Special dis-
tr!~" is defined as any agency
o? the state established for the
local performance of govern-
mental or propr etary func-
tions within mited bound-
anes. It includes a county ser-
vice area, a maintenance dis-
tr!ct area, an improvement dis-
tract or zone, an air pollution
control district, or a redevelop.
ment agency.)
There are exceptions to the
gift limit (e g., gifts from faro-
ily members) and honoraria
prohibition (e.g., earned in-
come received in connection
with a bona fide business). In
addition, payments received
for certain types of travel are
st. enforcement cases D**-:,- n~ot subject to the limit. See
~reTnho~icCe°~imissioners held ~jheerSe c, ases may b~ ,o~j~'~un. ~9°Sv0~r~n~fen' ,Code Sec/ion
. scussion of n . enTorcement a,~; . - -~ · you nave uesti
~-osea amendmentsto RegP~_ bulletin. --onsmth,s c,oncernlng the ,egqislatio°nns
L [ s~e_a,_se, con.tact the Commis:
I ,~,, ~ Lega! L)ivision