HomeMy WebLinkAboutAgenda Statement 1980/06/17 Item 08
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COUNCIL AGENDA STATEMENT
Item 8'
Meeting Date 6/17/80
ITEM TITLE: Resolution Idlerl Adopting Conflict of Interest Code
SUBMITTED BY: City Attorney (4/5ths Vote: Yes
A Conflict of Interest Code has been prepared for various commis-
sions and employees of the City of Chula Vista, as required by the
Political Reform Act of the State of California, which in effect
incorporates by reference the model code prepared by the Fair
Political Practices Commission.
No~)
RECOMMENDATION:
That the City Council adopt the Conflict of Interest Code as
attached hereto.
BOARD/COMMISSION RECOMMENDATION: N/A
DISCUSSION:
The City Council had earlier considered a Conflict of Interest
Code for boards and commissions and certain employees of the City
of Chula Vista. At the time of the public hearing on said Code,
it was determined that the Fair Political Practices Commission
(FPPC) of the State of California was attempting to put together a
model code that would fully satisfy state standards and would be
less onerous and complex than the code prepared by the City
Attorney. Such a model code has now been prepared and a public
hearing was conducted by the City Manager wherein no complaints
from employees affected were received.
However, the City Attorney was approached by employees who were
concerned that the Statement of Economic Interests requiring the
disclosure of investments in real property include the principal
residence of the filer and that business income disclosures would
include personal savings accounts. It should be noted that the
code specifically exempts the principal residence of the filer
from disclosure and the City Attorney does not feel that any of
the provisions of the code require the disclosure of personal
savings accounts; however, on the latter point, a clarification
will be requested from the FPPC.
One of the primary changes from the previously considered code has
been the elimination of the Planning Commission and the City
Manager from the requirements of the local Conflict of Interest
Code. Their reporting requirements are now co . .
Political Reform Act.
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by t e City Council of
Chula Vista, C<llifornia
For/A9/3 YLv.
11 /79)
Dated
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EXHIBITS
Agreement_ Resolution~ Ordinance_ Plat_ Notification List
Other
ENVIRONMENTAL DOCUMENT: Attached
Submitted on
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APPENDIX A
position
Disclosure Categories
ADMINISTRATION
Assistant City Manager
Deputy City Manager/Development Services
Administrator
Director of Policy Analysis & Program
Evaluation
1, 2
1, 2, 3, 4
1, 2
Building and Housing
Director of Building & Housing
Chief Building Inspector
Zoning Enforcement Officer
Plan Checker II
1, 2
1, 2
1, 2
1, 2
Community Development
Director of Community Development
Principal Community Development Specialist
Housing Coordinator
Redevelopment Coordinator
1, 2, 3, 4
1, 2, 3, 4
1, 2, 3, 4
1, 2, 3, 4
Engineering
City Engineer
Senior Civil Engineer
Right of Way Agent
1, 2
1, 3
3, 6, 7
Finance
Director of Finance
Chief Accountant.
Business License Inspector
Purchasing Agent
1, 2
1, 3
1, 3
1, 2, 6
Fire and Police
Director of Public Safety
Fire Marshal
Battalion Chief
Police Captain
1, 2
1, 3
3, 6
1, 3
Library
City Librarian
1, 2
Parks and Recreation
Director of Parks and Recreation
Park Superintendent
Principal Analyst
1, 3, 6
3, 6, 7
3, 6, 7
Personnel
Director of Personnel
1, 3, 6
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Planning
Director .of Planning 1, 2, 3, 4
Senior Planner 1, 2, 3, 4
Current Planning Supervisor 1, 2, 3, 4
Environmental Review Coordinator 1, 2, 3, 4
CITY ATTORNEY I S OFFICE
Ci ty Attorney 1, 2
Assistant City Attorney 1, 2
CITY CLERK'S OFFICE
City Clerk 1, 2
Deputy City Clerk 1, 3
BOARD OF APPEALS MEMBERS 3, 6
BOARD OF ETHICS MEMBERS 3, 6
CONSULTANTS 1, 2
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APPENDIX B
General provisions
When a designated employee is required to disclose investments
and sources of income, he need only disclose investments in business
entities and sources of income which do business in the jurisdiction,
plan to do business in the jurisdiction or have done business in the
jurisdiction within the past two years. In addition to other activities,
a business entity is doing business within the jurisdiction if it owns
real property within the jurisdiction. When a designated employee is
required to disclose interests in real property, he need only disclose
real property which is located in whole or in part within or not more
than two miles outside the boundaries of the jurisdiction or within
two miles of any land owned or used by the local government agency.
Designated employees shall disclose their financial interests
pursuant to the appropriate disclosure category as indicated in
Appendix A.
Disclosure Categories
CATEGORY 1:
CATEGORY 2:
CATEGORY 3:
CATEGORY 4:
CATEGORY 5:
CATEGORY 6:
CATEGORY 7:
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All Investments and sources of income.
All interests in real property.
All investments, interests in real property
and sources of income subject to the regula-
tory, permit or licensing authority of the
departmen t.
Investments in business entities and sources
of income which engage in land development,
construction or the acquisition or sale of
real property.
Interests in real property located within two
miles of any land owned by the City of Chula
Vista.
Investments in business entities and sources
of income of the type which, within the past
two years, have contracted with the City of
Chula Vista to provide services, supplies,
materials, machinery or equipment.
Investments in business entities and sources
of income of the type which, within the past
two years, have contracted with the designated
employee's department to provide services,
supplies, materials, machinery or equipment.
Commission (2 Cal. Adm. Code Sections 18100 et seq.), and
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any amendments to the Act or regulations, are incorporated
by reference into this Conflict of Interest Code.
(2 )
Section 2.
Designated Employees.
The persons holding positions listed in the Appendix
are designated employees.
It has been determined that these
persons make or participate in the making of decisions which
may foreseeably have a material effect on financial interests.
( 3 )
Section 3.
Disclosure Categories.
This Code does not establish any disclosure obli-
gation for those designated employees who are also specified
in Government Code Section 87200 if they are designated in
this Code in that same capacity or if the geographical juris-
diction of this agency is the same as or is wholly included
within the jurisdiction in which those persons must report
their financial interests pursuant to Article 2 of Chapter 7
of the Political Reform Act, Government Code Sections 87200,
et sea.l/ Such persons are covered by this Code for dis-
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qualification purposes only. With respect to all other
designated employees, the disclosure categories set forth in
l/ Designated employees who pre required to file
statements of economic interests under any other agency's
Conflict of Interest Code, or under Article 2 for a different
jurisdiction, may expand their statement of economic in-
terests to cover reportable interests in both jurisdictions,
and file copies of this expanded statement with both entities
in lieu of filing separate and distinct statements, provided
that each copy of such expanded statement filed in place of
an original is signed and verified by the designated employee
as if it were an original. See Government Code Section
81004.
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Regulations of the Fair Political Practices Commission
(Ti tle 2, Division 6 of the Cal Hornia Adm.in istra ti ve Code)
18730. provisions of Conflict of Interest Codes
(Gov. Code Sections 87300 - 87302)
(a) Incorporation by reference of the terms of
this regulation along with the designation of employees and
the formulation of disclosure categories in the Appendix
referred to below constitute the adoption and promulgation
of a Conflict of Interest Code within the meaning of Government
Code Section 87300 or the amendment of a Conflict of Interest
Code within the meaning of Government Code Section 87307 if
the terms of this regulation are substituted for terms of a
Conflict of Interest Code already in effect. A code so
amended or adopted and promulgated requires the reporting of
reportable items in a manner substantially equivalent to the
requirements of Article 2 of Chapter 7 of the Political
Reform Act, Government Code Sections 81000, et seq. The
requirements of a Conflict of Interest Code are in addition
to other requirements of the Political Reform Act, such as
the general prohibition against conflicts of interest con-
tained in Government Code Section 87100, and to other state
or local laws pertaining to conflicts of interest.
(b) The terms of a Conflict of Interest Code
amended or adopted and promulgated pursuant to this regulation
are as follows:
(1) Section 1. Definitions.
The definitions contained in the Political Reform
Act of 1974, regulations of the Fair Political Practices
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filing officer with respect to thes~ statements. Such state-
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ments shall be forwarded to the code reviewing body within
five days after the filing deadline or five days after receipt
in the case of statements filed late.
(B) All designated employees shall file statements
of economic interests with the agency, which shall make and
retain a copy and forward the originals to the code reviewing
body, which shall be the filing officer.
(C) All designated employees shall file statements
of economic interests with the code reviewing body.
(5) Section 5. Statements of Economic Interests:
T~me of F~l~ng.
(A) Initial Statements. All designated employees
employed by the agency on the effective date of this Code,
as originally adopted, promulgated and approved by the code
reviewing body, shall file statements within thirty days
after the effective date of this Code. Thereafter, each
person already in a position when it is designated by an
amendment to this Code shall file an initial statement within
thirty days after the effective date of the amendment.
(B) _ Assuming Office Statements.
(i) All persons assuming designated positions
after the effective date of this Code which are
civil service or merit system positions shall file
statements within thirty days after assuming the
designated positions.
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'the Appendix specify which kinds of financial interests axe
reportable. Such a designated employee shall disclose in
his or her statement of economic interests those financial
interests he or she has which are of the kind described in
the disclosure categories to which he or she is assigned in
the Appendix. It has been determined that the financial
interests set forth in a designated employee's disclosure
categories are the kinds of financial interests which he or
she foreseeably can af~ect materially through the conduct of
his or her office.
(4) Section 4. Statements of Economic Interests:
Place of F1l1ng.
The code reviewing body shall instruct all desig-
nated employees required to file statements of economic
interests pursuant to this Conflict of Interest Code to file
in accordance with one of the following procedures:ll
(A) All designated employees shall file statements
of economic inter~sts with the agency. Upon receipt of the
statements of economic interests of the head of the agency
and members of boards or commissions not under a department
of state or local government, the agency shall make and
reta in a copy of each and forward the orig inals of these
statements to the code reviewing body, which shall be the
II See Government Code Section 81010 and 2 Cal.
Adm. Code Section 18115 for the duties of filing officers
and persons in agencies who make and retain copies of state-
ments and forward the originals to the filing officer.
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sh'all begin on the effective date of the Code or the'date of
assuming office whichever is later.
(D)
Contents of Leaving Office Statements.
Le av ing
office statements shall disclose reportable investments,
interests in real property, income and business positions
held or received during the period between the closing date
of the last statement filed and the date of leaving office.
(7 )
Section 7.
Manner of Reporting.
Statements of economic interests shall be made on
forms prescribed by the Fair Political Practices Commission
and supplied by the agency, and shall contain the following
information:
(A) Investment and Real Property Disclosure.
When an investment or an interest in real property21 is
required to be reported,il the statement shall contain the
following:
(i) A statement of the nature of the invest-
ment or interest;
21 For the purpose of disclosure only (not dis-
qualification), an interest in real property does not include
the principal residence of the filer.
il Investments and interests in real property
which have a fair market value of less than $1,000 are not
investments and interests in real property within the meaning
of the political Reform Act. However, investments or interests
in real property of an individual include those held by the
individual's spouse and dependent children as well as a
pro rata share of any investment or interest in real property
of any business entity or trust in which the individual,
spouse and dependent children own, in the aggregate, a direct,
indirect or beneficial interest of 10 percent or greater.
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(ii) All other persons appointed, promot'ed
or transferred to designated positions after the
effective date of the Code shall file statements
within ten days after assuming office, or if subject
to State Senate confirmation, ten days after being
nominated or appointed.
(C) Annual Statements. All designated employees
shall file statements no later than April 1.
(D) Leaving Office Statements. All persons who
leave designated positions shall file statements within
thirty days after leaving office.
(6) Section 6. Contents of and Period Covered by Statements
of EconomlC Interests.
(A) Contents of Initial Statements. Initial
statements shall disclose any reportable investments, interests
in real property and business positions held on the effective
date of the Code.
(B) Contents of Assuming Office Statements.
Assuming office statements shall disclose any reportable
investments, interests in real property and business positions
held on the date of assuming office or, if subject to State
Senate confirmation or appointment, on the date of nomination.
(C) Contents of Annual Statements. Annual state-
ments shall disclose any reportable investments, interests
in real property, income and business positions held or
received during the previous calendar year provided, however,
that the period covered by an employee's first annual statement
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. (i i)
A statement whether the aggregate value
of income from each source, or in the case of a
loan, the highest amount owed to each source, was
one thousand dollars ($1,000) or less, greater
than one thousand dollars ($1,000), or greater
than ten thousand dollars ($10,000);
(iii)
A description of the consideration, if
any, for which the income was received;
( iv)
In the case of a gift, the name, address
and business activity of the donor and any in-
termediary through which the gift was made; a
description of the gift; the amount or value of
the gift; and the date on which the gift was received.
(v) In the case of a loan, the annual interest
rate and the security, if any, given for the loan.
(C) Business Entity Income Disclosure. When.
income of a business entity, including income of a sole
proprietorship, is required to be reported,~/ the statement
shall contain:
(i) The name, address, and a general description
of the business activity of the business entity;
~/ Income of a business entity is reportable if
the direct, indirect or beneficial interest of the filer and
the filer's spouse in the business entity aggregates a 10
percent or greater interest. In addition, the disclosure of
persons who are clients or customers of a business entity is
required only if the clients or customers are within one of
the disclosure categories of the filer.
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(ii) The name of the business entity in
which each investment is held, and a general description
of the business activity in which the business
entity is engaged;
.(iii) The address or other precise location
of the real property;
(iv) A statement whether the fair market
value of the investment or interest in real property
exceeds one thousand dollars ($1,000), exceeds ten
thousand dollars ($10,000), or exceeds one hundred
thousand dollars ($100,000).
(8) Personal Income Disclosure. When personal
income is required to be reported,2/ the statement shall
contain:
(i) The name and address of each source of
income aggregating two hundred fifty dollars ($250)
or more in value, or twenty-five dollars ($25) or
more in value if the income was a gift, and a
general description of the business activity, if
any, of each source.
2/ A designated employee's income includes his or
her community property interest in the income of his or her
spouse but does not include salary or reimbursement for
expenses received from a state, local or federal government
agency.
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(8)
Any real property in which the designated ..
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employee has a direct or indirect interest worth more than
one thousand dollars ($1,000);
(e) Any source of income, other than loans by a
commercial lending institution in the regular course of
business on terms available to the public without regard to
official status, aggregating two hundred fifty dollars ($250)
or more in value provided to, received by or promised to the
designated employee within twelve months prior to the time
when the decision is made; or
(D) Any business entity in which the designated
employee is a dir~ctor, officer, partner, trustee, employee,
or holds any position of management.
No designated employee shall be prevented from
making or participating in the making of any decision to the
extent his or her participation is legally required for the
decision to be made.
The fact that the vote of a designated
employee who is on a voting body is need~d to break a tie
does not make his or her participation legally required for
purposes of this section.
(9) Section 9.
Manner of Disqualification.
When a designated employee determines that he or
she should not make a governmental decision because he or
she has a financial interest in it, the. determination not to
act must be accompanied by disclosure of the financial interest.
In the case of a voting body, this determination and disclosure
shall be made part of the agency's official record; in the
case of a designated employee who is the head of an agency,
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(ii) The name of every person from whom the
business entity received payments if the filer's
pro rata share of gross receipts from such person
was equal to or greater than ten thousand dollars
($10,000).
(D) Business position Disclosure. When business
positions are required to be reported, a designated employee
shall list the name and address of each business entity in
which he or she is a director, officer, partner, trustee,
employee, or in which he or she holds any position of manage-
ment, a description of the business activity in which the
business entity is engaged, and the designated employee's
position with the business entity.
(E) Acquisition or Disposal During Reporting
Period. In the case of an annual or leaving office statement,
if an investment or an interest in real property was partially
or wholly acquired or disposed of during the period covered
by the statement, the statement shall contain the date of
acquisition or disposal.
(8) Section 8. Disqualification.
No designated employee shall make, participate in
making, or use his or her official positions to influence
the making of any governmental decision which will foreseeably
have a material financial effect, distinguishable from its
effect on the public generally, on:
(A) Any business entity in which the designated
employee has a direct or indirect investment worth more than
one thousand dollars ($1,000);
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'this' determination and disclosure shall be made in writing
to his or her ~ppointing authority; and in the case of other
designated employees, this determination and disclosure
shall be made in writing to the designated employee's
supervisor.
(10 )
Section 10. Assistance of the Commission and Counsel.
Any designated employee who is unsure of his or
her duties under this Code may request assistance from the
Fair political Practices Commission pursuant to Government
Code Section 83114 or from the attorney for his or her agency,
provided that nothing in this section requires the attorney
for the agency to issue any formal or informal opinion.
( 11)
Section 11. Violations.
This Code has the force and effect of law.
Designated
employees violating any provision of this Code are subject
to the administrative, criminal and civil sanctions provided
in the Political Reform Act, Government Code Sections 81000 -
91014.
In addition, a decision in relation to which a violation
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of the disqualification provisions of this Code or of Government
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Code Section 87100 has occurred may be set aside as void
pursuant to Government Code Section 91003.
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INSTRUCTIONS FOR DESIGNATING EMPLOYEES'
,;ND FORMULATING DISCLOSURE CATEGORIES
A position should be designated if it involves the making
or participating in the making of decisions which could affect
private financial interests materially.
Such an effect could
come about because of the regulatory nature of the decision or
it could result because the decision is a contracting one of
such size that the recipient of the contract could be affected
materially by it.
By "making a decision" we mean that the official votes on
a matter, appoints a person to an office, obligates the agency
to a course of action or enters into a contractual agreement.
Of course, a decision not to do one of those things is also in-
cluded.
By "participating in a decision" we mean that a person,
without intervening substantive review, negotiates, with respect
to a decision or advises or makes recommendations to a decision-
maker by conducting research, making an investigation or preparing
or presenting any report, analysis or opinion which requires the
exercise of judgment and the purpose of which is to influence
the decision.1/ These standards, as well as a few exceptions,
are contained in one of the Commission's regulations, 2 Cal. Adm.
Code Section 18700.
1/ These terms do not include, however, appearances as a
member of the general public to represent oneself on matters
relating solely to one's personal interests.
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The private financial interests with which the Political
Reform Act is concerned are business entities operated for profit
in which one has an investment or an employment or management
position, interests in real property and sources of income, whether
such sources are persons, business entities, charitable institutions,
etc., excepting only state, local or federal government agencies.
If any decision made by your local government body or department,
including decisions relating only to your own administration such
as purchasing supplies or obtaining office space, could result in
a significant effect on any of these kinds of financial interests,
the persons who make or participate in making that decision should
be designated and the disclosure category for those persons should
include a description of the interests which could be so affected.
As a general rule, department heads and other high ranking
administrators, attorneys, and persons involved in planning should
have broad disclosure categories. In large or middle sized govern-
mental bodies, persons down through the level of division chief
generally should be designated. Some examples of how various kinds
of designated employees may be required ,to disclose financial
interests are set forth below in a sample Appendix A. This is
not intended to represent the list of employees for any particular
agency, but only to show you the format for listing designated
employees and to suggest the types of disclosure categories which
you might want to consider for a few kinds of employees. Following
it is a sample Appendix B listing the disclosure categories referred
to ~n Appendix A. The disclosure categories are also not necessarily
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intended to be adopted by cities, counties, districts and departments
in their present form, but have been included for the purpose of
providing examples of how disclosure categories should be drafted.
You are encouraged to create additional categories which apply to
the duties of specific employees of your agency.
In addition, we have attached model disclosure categories
and lists of designated employees for two of the mos.t common
kinds of special districts, water districts and school districts.
If your agency is a water district or a school district, you can
use these models as a beginning point for drafting your appendices
although you will of course have to review them to make sure they
are applicable to your district in their present form.
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June 6, 1980
SUBJECT:
Honorable Mayor and City Council
Lane F. Cole, City Manager (~
r.1anager's Hearing on the Conflict of Interest Code for the City
of Chula Vista
.
TO:
FROM:
This report will constitute as the minutes of the June 6, 1980 Conflict of
Interest public hearing.
In accordance with Resolution No. 10098, a public hearing was held in the City
Council Chambers, Public Services Building, 276 Fourth Avenue, on June 6, 1980,
at 9:00 a.m., with the following
City Manager Cole, City Clerk Fulasz, City Attorney Lindberg
and Associate Civil Engineer Hughes.
The purpose of the hearing was to hear testimony from all parties affected by
the proposed City of Chula Vista Conflict of Interest Code. All of the affected
parties received personal notice of the meeting.
~ The meeting was called to order by the City Manager at 9:00 a.m. No testimony,
oral or written, was received.
PRESENT:
The meeting was adjourned at 9:10 a.m.
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