HomeMy WebLinkAbout07 RESOLUTION MAKING FINDINGS FOR COMPLIANCE WITH AB 361 DocuSign Envelope ID:454E6C71-B770-49D5-9377-069E6227353B
AGENDA REPORT Agenda Item
DS
Reviewed:
City Manager
Finance Director N
MEETING DATE: OCTOBER 5, 2021
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: MATTHEW S. WEST, CITY MANAGER
SUBJECT: RESOLUTION MAKING FINDINGS REQUIRED FOR THE USE OF
TELECONFERENCING IN COMPLIANCE WITH ASSEMBLY BILL 361 FOR
MEETINGS OF THE TUSTIN CITY COUNCIL.
SUMMARY:
Consider adoption of Resolution 21-89 to make findings that would be required for the City
Council, or individual members of the City Council, to use teleconferencing during Council
meetings, as required by recently enacted Assembly Bill 361 .
RECOMMENDATION:
Adopt Resolution No. 21-89 Making Findings Required For the Use of Teleconferencing as
Defined and In Compliance With Assembly Bill 361 For Meetings of the Tustin City Council.
FINANCIAL IMPACT:
None. The City plans to continue to stream and allow public access to the City Council
meetings via Zoom, so the electronic systems necessary to comply with AB 361 will continue
to operate whether or not one or more City Council members participate from remote
locations.
BACKGROUND AND DISCUSSION:
Assembly Bill 361 was signed into law by the Governor on September 16, 2021 . A portion
of AB 361 enacted amendments to California Government Code section 54953 regarding
teleconference meetings. (The relevant amendments to section 54953 that are in effect
today are attached hereto as Attachment 1).
Those amendments authorize local agencies like the City to continue to conduct meetings
by teleconference during a Governor-proclaimed state of emergencyl provided that certain
1 For purposes of AB 361 "...'state of emergency' means a state of emergency proclaimed pursuant to
Section 8625 of the California Emergency Services Act..." Cal. Gov't Code sec. 54953(e)(4). Section 8625 of
CESA in turn refers to a state of emergency proclaimed by the Governor.
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findings are made by the legislative body, and provided that certain procedural requirements
are met regarding public access to the meetings.
A "teleconference" will occur whenever one or more members of the City Council connect to
a Council meeting via electronic means.2 Thus, even if four members of the Council meet in
person, if the fifth joins the meeting via Zoom, the meeting will be a teleconference meeting
that must be conducted in accordance with the requirements of AB 361 .
A new requirement in AB 361 requires particular findings be made by the City Council, and
requires that the new findings must be reaffirmed at least every thirty (30) days thereafter in
order to continue to use teleconferencing.
The Required Findings
The teleconference provisions in AB 361 may only be utilized as long as a Governor-
proclaimed state of emergency remains active, or while state or local officials have
recommended measures to promote social distancing.
When either of those is the case (both are true at this time), then in order to continue to
teleconference using the new provisions of AB 361 , the City Council must make the following
findings by majority vote every 30 days:
(A) City Council has reconsidered the circumstances of the state of emergency; and
(B) Either of the following circumstances exist:
(i) The state of emergency continues to directly impact the ability of the members
to meet safely in person; or
(ii) State or local officials continue to impose or recommend measures to promote
social distancing.3
To comply with that requirement, the proposed Resolution 21-89 (Attachment 2) would find
each of the following:
1 . The City Council has reconsidered the circumstances of the state of emergency;
and
2. At the time this Resolution is adopted, a state of emergency proclaimed by
California's Governor due to the COVID-19 pandemic continues to exist; and
3. At the time that this Resolution is adopted, both the County of Orange and State
health officials continue to recommend measures to promote social distancing to
slow the spread of COVID-19.
2 "Teleconference means a meeting of a legislative body, the members of which are in different
locations, connected by electronic means, through either audio or video, or both." Cal. Gov't Code sec.
54953(b)(4).
3 Cal. Gov't Code sec. 54953(e)(3).
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The "Every 30 Days Thereafter" Requirement:
As noted above, AB 361 findings must be made "not later than 30 days after teleconferencing
for the first time pursuant to [AB 361], and every 30 days thereafter..."
AB 361 was enacted on September 16, 2021 , and the City Council conducted a public
hearing in connection with the district election process via teleconference the next day, on
September 17, 2021 . Out of an abundance of caution, if the Council wishes to preserve the
option for the Council or individual Council members to meet via teleconference in the future,
the City Attorney recommends that the Council adopt the required findings on or before
Sunday, October 17th to eliminate any doubt whether the Council has complied with the new
requirement.
In addition, the Council should be aware that, in order to preserve the option for the Council
or individual members of the Council to participate in meetings via teleconference in the
future, the Council will have to adopt the required findings at least every 30 days. From time
to time this may require the Council to meet for a special meeting when the Council's regular
meetings would otherwise be scheduled more than 30 days apart. These meetings may
themselves be conducted via teleconference, provided the requirements of AB 361 have
been previously addressed.
Potential Consequence of Not Making the Findings Every 30 Days
AB 361 does not expressly state what happens if a legislative body fails to make the required
findings "every 30 days." However, it expressly requires the timely reapproval of the findings
"in order to continue to teleconference" in the manner that AB 361 authorizes.
As a result, if the Council does not adopt the required findings every 30 days, then the Council
could be precluded from continuing to teleconference thereafter, perhaps even if the Council
was later willing to adopt the findings at a later date. For this reason, the City Attorney
recommends that the City Council adopt the findings at this time and at least every 30 days
thereafter, unless the Council decides as a permanent matter that it will no longer permit
teleconferencing at all.
Procedural Requirements for The Conduct of Teleconference Meetings
AB 361 contains several modest new requirements for the conduct of teleconference
meetings with which the City Council has already been complying. Specifically, the City
Council must:
1 . Allow members of the public to attend and comment at the meeting via call-in option
or internet-based service option;
2. Protect the statutory and constitutional rights of the parties and the public appearing
before the legislative body;
3. In the event of disruption which prevents broadcasting the meeting or which
prevents members of the public from offering public comments via the call-in or
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internet-based option, the Council must take no further action until the disrupted
public access is restored;
4. The City may not require public comments to be submitted in advance, and must
offer the opportunity for the public to offer comments "in real time" during the
meeting; and
5. The public must be allowed "a reasonable amount of time per agenda item to allow
members of the public to provide public comment, including time for members of
the public to register [to log into the teleconference], or otherwise be recognized for
the purpose of providing public comment."
CONCLUSION:
For the reasons summarized above, it is recommended that the City Council approve
Resolution 21-89 (Attachment 2)
ATTACHMENT:
1 . Excerpt of AB 361 —Amendments to Government Code section 54953 in effect now.
2. Proposed Resolution 21-89
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ATTACHMENT 1
Excerpts of AB 361 —Amendments to Government Code section 54953
54953.
(a) All meetings of the legislative body of a local agency shall be open and public, and all persons
shall be permitted to attend any meeting of the legislative body of a local agency, except as
otherwise provided in this chapter.
(b) (1) Notwithstanding any other provision of law, the legislative body of a local agency may
use teleconferencing for the benefit of the public and the legislative body of a local agency
in connection with any meeting or proceeding authorized by law. The teleconferenced
meeting or proceeding shall comply with all otherwise applicable requirements of this
chapter and all otherwise applicable provisions of law relating to a specific type of meeting
or proceeding.
(2) Teleconferencing, as authorized by this section, may be used for all purposes in
connection with any meeting within the subject matter jurisdiction of the legislative body.
All votes taken during a teleconferenced meeting shall be by rollcall.
(3) If the legislative body of a local agency elects to use teleconferencing, it shall post
agendas at all teleconference locations and conduct teleconference meetings in a manner
that protects the statutory and constitutional rights of the parties or the public appearing
before the legislative body of a local agency. Each teleconference location shall be
identified in the notice and agenda of the meeting or proceeding, and each teleconference
location shall be accessible to the public. During the teleconference, at least a quorum of
the members of the legislative body shall participate from locations within the boundaries
of the territory over which the local agency exercises jurisdiction, except as provided in
subdivisions (d) and (e). The agenda shall provide an opportunity for members of the
public to address the legislative body directly pursuant to Section 54954.3 at each
teleconference location.
(4) For the purposes of this section, "teleconference" means a meeting of a legislative
body, the members of which are in different locations, connected by electronic means,
through either audio or video, or both. Nothing in this section shall prohibit a local agency
from providing the public with additional teleconference locations.
(c) (1) No legislative body shall take action by secret ballot, whether preliminary or final.
(2) The legislative body of a local agency shall publicly report any action taken and the
vote or abstention on that action of each member present for the action.
(3) Prior to taking final action, the legislative body shall orally report a summary of a
recommendation for a final action on the salaries, salary schedules, or compensation paid
in the form of fringe benefits of a local agency executive, as defined in subdivision (d) of
Section 3511.1, during the open meeting in which the final action is to be taken. This
paragraph shall not affect the public's right under the California Public Records Act
(Chapter 3.5 (commencing with Section 6250) of Division 7 of Title 1) to inspect or copy
records created or received in the process of developing the recommendation.
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(d) (1) Notwithstanding the provisions relating to a quorum in paragraph (3) of subdivision (b),
if a health authority conducts a teleconference meeting, members who are outside the
jurisdiction of the authority may be counted toward the establishment of a quorum when
participating in the teleconference if at least 50 percent of the number of members that
would establish a quorum are present within the boundaries of the territory over which the
authority exercises jurisdiction, and the health authority provides a teleconference
number, and associated access codes, if any, that allows any person to call in to
participate in the meeting and the number and access codes are identified in the notice
and agenda of the meeting.
(2) Nothing in this subdivision shall be construed as discouraging health authority
members from regularly meeting at a common physical site within the jurisdiction of the
authority or from using teleconference locations within or near the jurisdiction of the
authority. A teleconference meeting for which a quorum is established pursuant to this
subdivision shall be subject to all other requirements of this section.
(3) For purposes of this subdivision, a health authority means any entity created pursuant
to Sections 14018.7, 14087.31, 14087.35, 14087.36, 14087.38, and 14087.9605 of the
Welfare and Institutions Code, any joint powers authority created pursuant to Article 1
(commencing with Section 6500) of Chapter 5 of Division 7 for the purpose of contracting
pursuant to Section 14087.3 of the Welfare and Institutions Code, and any advisory
committee to a county-sponsored health plan licensed pursuant to Chapter 2.2
(commencing with Section 1340) of Division 2 of the Health and Safety Code if the
advisory committee has 12 or more members.
(e) (1) A local agency may use teleconferencing without complying with the requirements of
paragraph (3) of subdivision (b) if the legislative body complies with the requirements of
paragraph (2) of this subdivision in any of the following circumstances:
(A) The legislative body holds a meeting during a proclaimed state of emergency,
and state or local officials have imposed or recommended measures to promote
social distancing.
(B) The legislative body holds a meeting during a proclaimed state of emergency
for the purpose of determining, by majority vote, whether as a result of the
emergency, meeting in person would present imminent risks to the health or safety
of attendees.
(C) The legislative body holds a meeting during a proclaimed state of emergency
and has determined, by majority vote, pursuant to subparagraph (B), that, as a
result of the emergency, meeting in person would present imminent risks to the
health or safety of attendees.
(2) A legislative body that holds a meeting pursuant to this subdivision shall do all of the
following:
(A) The legislative body shall give notice of the meeting and post agendas as
otherwise required by this chapter.
(B) The legislative body shall allow members of the public to access the meeting
and the agenda shall provide an opportunity for members of the public to address
the legislative body directly pursuant to Section 54954.3. In each instance in which
notice of the time of the teleconferenced meeting is otherwise given or the agenda
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for the meeting is otherwise posted, the legislative body shall also give notice of
the means by which members of the public may access the meeting and offer
public comment. The agenda shall identify and include an opportunity for all
persons to attend via a call-in option or an internet-based service option. This
subparagraph shall not be construed to require the legislative body to provide a
physical location from which the public may attend or comment.
(C) The legislative body shall conduct teleconference meetings in a manner that
protects the statutory and constitutional rights of the parties and the public
appearing before the legislative body of a local agency.
(D) In the event of a disruption which prevents the public agency from broadcasting
the meeting to members of the public using the call-in option or internet-based
service option, or in the event of a disruption within the local agency's control which
prevents members of the public from offering public comments using the call-in
option or internet-based service option, the body shall take no further action on
items appearing on the meeting agenda until public access to the meeting via the
call-in option or internet-based service option is restored. Actions taken on agenda
items during a disruption which prevents the public agency from broadcasting the
meeting may be challenged pursuant to Section 54960.1.
(E) The legislative body shall not require public comments to be submitted in
advance of the meeting and must provide an opportunity for the public to address
the legislative body and offer comment in real time. This subparagraph shall not
be construed to require the legislative body to provide a physical location from
which the public may attend or comment.
(F) Notwithstanding Section 54953.3, an individual desiring to provide public
comment through the use of an internet website, or other online platform, not under
the control of the local legislative body, that requires registration to log in to a
teleconference may be required to register as required by the third-party internet
website or online platform to participate.
(G) (i) A legislative body that provides a timed public comment period for each
agenda item shall not close the public comment period for the agenda item,
or the opportunity to register, pursuant to subparagraph (F), to provide
public comment until that timed public comment period has elapsed.
(ii) A legislative body that does not provide a timed public comment period,
but takes public comment separately on each agenda item, shall allow a
reasonable amount of time per agenda item to allow public members the
opportunity to provide public comment, including time for members of the
public to register pursuant to subparagraph (F), or otherwise be recognized
for the purpose of providing public comment.
(iii) A legislative body that provides a timed general public comment period
that does not correspond to a specific agenda item shall not close the public
comment period or the opportunity to register, pursuant to subparagraph
(F), until the timed general public comment period has elapsed.
(3) If a state of emergency remains active, or state or local officials have imposed or
recommended measures to promote social distancing, in order to continue to
teleconference without compliance with paragraph (3) of subdivision (b), the legislative
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body shall, not later than 30 days after teleconferencing for the first time pursuant to
subparagraph (A), (B), or (C) of paragraph (1), and every 30 days thereafter, make the
following findings by majority vote:
(A) The legislative body has reconsidered the circumstances of the state of
emergency.
(B) Any of the following circumstances exist:
(i) The state of emergency continues to directly impact the ability of the
members to meet safely in person.
(ii) State or local officials continue to impose or recommend measures to
promote social distancing.
(4) For the purposes of this subdivision, "state of emergency" means a state of
emergency proclaimed pursuant to Section 8625 of the California Emergency
Services Act (Article 1 (commencing with Section 8550) of Chapter 7 of Division 1
of Title 2).
(f) This section shall remain in effect only until January 1, 2024, and as of that date is repealed.
DocuSign Envelope ID:454E6C71-B770-49D5-9377-069E6227353B
RESOLUTION NO. 21-89
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN,
CALIFORNIA, MAKING FINDINGS REQUIRED FOR THE USE OF
TELECONFERENCING AS DEFINED AND IN COMPLIANCE WITH
ASSEMBLY BILL 361 FOR MEETINGS OF THE TUSTIN CITY COUNCIL.
WHEREAS, existing California law, the Ralph M. Brown Act("Brown Act") requires,
with specified exceptions, that all meetings of a legislative body of a local agency, as
those terms are defined, be open and public, that a physical location for such meetings
be provided, and that the public be permitted to provide public comment during the
meetings; and
WHEREAS, on March 4, 2020, California Governor Newsom declared a State of
Emergency in response to the COVID-19 pandemic; and
WHEREAS, on March 12, 2020, to address the impacts of COVID-19, Governor
Newsom issued Executive Orders that required, among other things, residents of
California to follow orders and guidance of local public health officials, including social
distancing and masking requirements; and
WHEREAS, Governor Newsom's Executive Orders suspended certain
teleconferencing provisions of the Brown Act as they applied to members of a legislative
body to provide local agencies with greater flexibility to hold meetings via teleconferencing
in recognition that such public gatherings could accelerate the spread of COVID-19; and
WHEREAS, pursuant to the Emergency Services Act (Government Code sections
8550 et seq.), and Chapter 2 of Article 5 of the Tustin City Code, the City Council of the
proclaimed the continued existence of a local emergency resulting from the COVID-19
pandemic; and
WHEREAS, as of September 30, 2021 , the Governor's Executive Order
suspending the Brown Act's teleconferencing requirements expired; and
WHEREAS, on September 16, 2021 , Governor Newsom signed Assembly Bill 361,
which authorizes a local agency to use teleconferencing without complying with certain
teleconferencing requirements imposed by the Brown Act when: (1) the legislative body
of a local agency holds a meeting during a declared state of emergency; (2) when state
or local health officials have imposed or recommended measures to promote social
distancing; and/or (3) when a local agency has determined that meeting in person would
present imminent risks to the health or safety of attendees; and
WHEREAS, both Orange County and state health officials continue to recommend
social distancing due to recent increases in COVID-19 cases including those caused by
the so-called Delta Variant; and
1625386.1
DocuSign Envelope ID:454E6C71-B770-49D5-9377-069E6227353B
Resolution No. 2021-89
WHEREAS, the Tustin City Council must approve a Resolution reaffirming that the
requirements set forth in Assembly Bill 361 exist at least every 30 days in order to allow
members of the City Council to utilize the provisions of Assembly Bill 361 when attending
public meetings via teleconferencing; and
WHEREAS, notwithstanding that the City's legislative bodies, as defined by the
Brown Act, may hold some of their public meetings in person, there may be situations in
which a member of one of these legislative bodies decides not to attend in person due to
a particular health or safety risk posed by such attendance and as such, it is the City
Council's desire to permit members of its legislative bodies to attend by way of
teleconference due to health and safety concerns associated with COVID-19.
NOW, THEREFORE, IT IS HEREBY RESOLVED by the City Council of the City
of Tustin as follows:
1 . The City Council has reconsidered the circumstances of the state of
emergency.
2. At the time this Resolution is adopted, a state of emergency proclaimed by
California's Governor due to the COVID-19 pandemic continues to exist.
3. At the time that this Resolution is adopted, both the County of Orange and
State health officials continue to recommend measures to promote social
distancing to slow the spread of COVID-19.
4. Members of the City Council may participate in meetings subject to the Brown
Act by way of teleconference until such teleconferences are no longer
permitted in accordance with AB 361 , and provided the City and the City
Council comply with the requirements of AB 361 .
5. That if a member of the City Council or another legislative body of the City of
Tustin teleconferences into a meeting subject to the Brown Act, the meeting
shall be held in accordance with the requirements of Government Code
section 54953(e) as modified by AB 361 by, among other things, providing
notice to the public how it can access the meeting and provide public
comment, providing an opportunity for the public to attend via a call-in or an
internet-based service option, conducting the meeting in a manner which
protects the statutory and constitutional rights of the public, and stopping the
meeting until public access is restored in the event of a service disruption.
6. The requirements of Government Code section 54953(e) as modified by AB
361 shall only apply to a meeting that is otherwise subject to the Brown Act
and shall only apply in the event that a member of the City Council or a
legislative body of the City of Tustin desires to attend that meeting by way of
teleconference.
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Resolution No. 2021-89
IT IS FURTHER RESOLVED that this Resolution is effective immediately upon its
adoption date but the findings required by Government Code section 54953(e)(3) must
be made at least every 30 days in order for the provisions of Assembly Bill 361 to continue
to apply to teleconferencing by members the City Council. Future findings may be made
with or without a Resolution of the Council.
IT IS FURTHER RESOLVED that the legislative bodies of the City of Tustin are
authorized to consider and reconsider the circumstances of the state of emergency and
whether to adopt the findings required by Government Code section 54953(e)(3).
IT IS FURTHER RESOLVED that this Resolution shall expire and be of no further
force or effect upon the expiration or revocation of the requirements of Government Code
section 54953(e).
PASSED, APPROVED AND ADOPTED this 5t" day of October, 2021 .
LETITIA CLARK,
Mayor
ATTEST:
ERICA N. YASUDA,
City Clerk
DocuSign Envelope ID:454E6C71-B770-49D5-9377-069E6227353B
Resolution No. 2021-89
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) SS
CITY OF TUSTIN )
I, Erica N. Yasuda, City Clerk and ex-officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council is five;
that the above and foregoing Resolution No. 21-89 was duly and regularly passed and
adopted at a regular meeting of the City Council held on the 5t" day of October, 2021 by the
following vote:
COUNCILPERSONS AYES:
COUNCILPERSONS NOES:
COUNCILPERSONS ABSTAINED:
COUNCILPERSONS ABSENT:
ERICA N. YASUDA,
City Clerk