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CITY OF PALO ALTO OFFICE OF THE CITY ATTORNEY
November 5, 2012
The Honorable City Council
Palo Alto, California
Adoption of Form 806, as Required by the California Fair Political
Practices Commission, to Provide for Reporting of Election of City
Council Members to Stipended Positions, such as Mayor and Vice-
Mayor
Recommendation
Adopt Form 806, as required by the Fair Political Practices Commission (FPPC), for the purpose
of reporting appointments of Council Members to stipended positions such as Mayor and Vice-
Mayor and direct the City Clerk to post the form on the City’s website.
The form will be blank at this time, as there are no City Council Members currently appointed
to positions that receive a stipend. After adopting and posting the form, all Council Members
will be able to participate in the election of Mayor and Vice-Mayor in January 2013. As part of
electing new officers in January, Council should direct the Clerk to amend the posted Form 806
to indicate the Council Members elected as Mayor and Vice-Mayor.
Background
The Palo Alto Charter requires the City Council, at its first meeting in January, to elect one of its
members to serve as Mayor and one as Vice-Mayor, for one-year terms. Charter, Sec. 8.
Council policy provides that the Mayor receive a stipend of $150 per month and the Vice-Mayor
receive $100 per month to defray the additional expenses of these offices. See Compensation
Plan for Management and Professional Personnel and Council Appointees, Sec. P; City Council
and Boards and Commissions Policy for Travel and Miscellaneous Expense Reimbursement, p. 5.
The California Political Reform Act, Govt. Code §§ 81000 et seq. (the Act), prohibits
governmental conflicts of interest. The Fair Political Practice Commission (FPPC) is charged
with interpreting and administering the Act. The FFPC adopts regulations to fill in gaps in the
statutory scheme. 2 Cal. Code Regs. §§ 18110 et seq. When requested by local officials, the
FFPC issues informal assistance letters that provide guidance regarding the FPPC’s
interpretation of the Act. FPPC advice letters are public documents, but are not widely
publicized.
Section 87100 of the Act prohibits public officials from making, participating in making, or using
an official position to influence a governmental decision in which the official has a financial
interest. Income is one type of financial interest that is subject to the Act. The Act excludes
Updated: 10/31/2012 11:14 AM by Sharon Hanks A Page 2
governmental salary and reimbursement from the types of income that create a conflict of
interest: “’Income’ does not include: Salary and reimbursements for expenses or per diem . . .
received from a state, local, or federal government agency.” § 82030(b)(2). The FPPC
regulations confirm a broad definition of government salary: “’Salary’ from a state, local or
federal government agency means any and all payments made by a government agency to a
public official, or accrued to the benefit of a public official, as consideration for the public
official’s services to the government agency.” Reg. 18232.
In addition to income, however, the Act also states that a financial interest sufficient to trigger a
conflict of interest can be formed by “an economic interest in [the official’s] personal finances.”
§ 87103. This rule is commonly referred to as the “personal financial effects” rule. The FPPC
set a materiality threshold for this type of financial interest of at least $250 in any 12-month
period. Reg. 18705.5(a).
Discussion
For many years, most city attorneys and city officials believed that the appointment of City
Council Members to special positions with stipends (such as mayor and vice-mayor, as well as
delegates to other regional planning and regulatory bodies) did not create a prohibited conflict
of interest because the Act excludes government salary and reimbursement from income that
creates a conflict of interest. As a result, it was common for all members of a body to
participate in the selection of members to stipended positions, including those interested in
and nominated to the positions.
In January of 2012, it came to the attention of Bay Area city attorneys that the FPPC had issued
a series of advice letters, including one in October 2011, advising that a City Council Member
could not make or participate in making a decision to appoint him or herself to a position that
provided a stipend of more than $250 annually. The FPPC based its interpretation on the
personal financial effects rule, rather than on the rule exempting governmental salary from
income that creates a conflict of interest.
As a result of the FPPC’s interpretation, Palo Alto’s 2012 Mayor and Vice-Mayor waived in
writing the stipend provided by local rule for Mayor and Vice-Mayor.
Immediately following the widespread appreciation of the FPPC’s interpretation, city attorneys
throughout the state encouraged the FPPC to revise its regulations to exclude stipended
government positions from the conflict of interest rules. The city attorneys argued that the
FPPC interpretation created an unworkable and potentially anti-democratic rule, and was
unnecessary to prevent financial self-dealing in these circumstances.
In March 2012, the FPPC responded by amending Regulation 18705.5 to provide that it is not a
conflict of interest for an elected official to participate in a decision to appoint him or herself to
a stipended government position, such as mayor or vice-mayor, provided that the appointment
is one that the body is required to make by state law, local law or a joint powers agreement,
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and provided that the body posts on its website certain information about the appointment on
a form provided by the Commission. Several months later, the FPPC issued Form 806 to
implement this regulation. The FPPC requires local bodies to adopt and post Form 806 in
advance of making any appointment to a stipended position. Upon appointment of any
individual to a stipended position, the local agency amends the form with the names and
specific appointment information.
We recommend that the Council adopt FPPC Form 806 for the purpose of reporting
appointments of Council Members to stipended positions such as Mayor and Vice-Mayor, and
direct the City Clerk to post the Form on the City’s website.
Resource Impact
There are no resource impacts related to this recommendation.
Environmental Review
Adoption of Form 806 is not a project subject to environmental review under the California
Environmental Quality Act (CEQA).
ATTACHMENTS:
Attachment A: FPPC Form 806 (PDF)
Attachment B: 2 Cal. Code Regs. § 18705.5 “Materiality Standard: Economic Interest in
Personal Finances” (PDF)
Department Head: Molly Stump, City Attorney
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Agency Report of:
Public Official Appointments A Public Document
California 806
Form
1. Agency Name
Division, Department, or Region (If Applicable) For Official Use Only
Designated Agency ontact (Name, Title)
Date Posted:
Area Code/Phone Number E-mail Page __ of __
(Month, Day, Year)
2. Appointments
Agency Boards and Name of Appointed Person Appt Date and Per Meeting/Annual Salary/Stipend Commlulons Length of Term
~ Per Meeting: $
~Name ~ _1 __ 1-
(Last, First) Appt Date ~ Estimated Annual:
Alternate, if any ~ 0$0-$1,000 0$2,001-$3,000
(Last First) Length of Term
0$1,001-$2,000 0
Other
~ Per Meeting: $
~Name ~ __ 1 __ 1_-
(Last, First) Appf Date
~ Estimated Annual:
Alternate, if any ~ 0$0-$1,000 0$2,001-$3,000
(Last, First) Length of Term
0$1,001-$2,000 0
Other
~Name ~ _1 __ 1_-~ Per Meeting: $
(Last, First) Appf Date
~ Estimated Annual:
Altemate, if any ~ 0$0-$1,000 0$2,001-$3,000 (Last, Firsf) Length of Term
0$1,001-$2,000 0
Other
~ Per Meeting: $ ~Name ~ _1_1-
(Last, First) ApptDate
~ Estimated Annual:
Alternate, if any ~ 0$0-$1,000 0$2,001-$3,000
(Last, First) Length of Term
0$1,001-$2,000 0
Other
3. Verification
I have read and understand FPPC Regulation 18706.6. I have verified that the appointment and information identified above is true to the best of my information and belief.
Signature of Agency Head or Designee Print Name Title (Month, Day, Year)
Comment ______________________________________ _
FPPC Form 806 (5/12)
FPPC Toll-Free Helpline: 866/ASK-FPPC (866/275-3772)
Agency Report of:
Public Official Appointments
Background
This form is used to report additional compensation that
officials receive when appointing themselves to positions
on committees, boards or commissions of a public agency,
special district, and joint powers agency or authority. For
example, a city councilmember may be appointed to serve as
the city's representative on a joint powers insurance authority
or a metropolitan planning organization or mayor. (Regulation
18705.5, amended 03.2012)
Each agency must post on its website a single Form 806 which
lists all the paid appointed positions. When there is a change in
compensation or a new appointment, the Form 806 is updated
to reflect the change. The form must be updated promptly as
changes occur.
Initial Agency Posting
As soon as possible, each agency should prepare a Form
806 identifying all of the current paid appointments to other
governmental agencies. Thereafter, the form may be amended to
include the future appointments.
Instructions
This form must be posted prior to a vote (or consent item) to
appoint a governing board member to a paid position on another
agency.
Part 1. Agency Identification
Identify the agency name and information on who should be
contacted for information.
Part 2. Appointments
Identify the name of the other agency, board or commission. List
the name of the official, and an alternate, if any.
List the appointment date and the length of term the agency
official will serve. Disclose the stipend provided per meeting and
the estimated annual payment. The annual salary is an estimate
as it will likely vary depending on the number of meetings. It is
not necessary to revise the estimate at the end of the calendar
year.
Part 3. Verification
The agency head or his/her designee must sign the verification.
Frequently Asked Questions (FAQs)
1. When does an agency need to complete the Form 806?
A Form 806 is required when an agency's board members
vote on an appointment for a board member to serve on
another governmental agency and pay is provided.
2. The city council votes to serve as the city's housing authority,
a separate entity. Will the Form 806 be required?
If the council members receive an additional compensation
for serving on the housing authority, the Form 806 is required.
If there is no payment, the Form 806 is not required.
California 806
Form
A Public Document
3. Are appointments made by a governing board to aPPOint
one of its members to serve as an officer of that board for
additional pay (e.g. mayor) required to be disclosed on Form
806?
Yes. Regulation 18705.5 permits voting on your own
appointment to position of mayor as well as other boards and
commissions so long as proper disclosure on the Form 806 is
made. This exception and disclosure apply to agencies with
governing boards that are elected or appointed.
4. In determining the salary, must the agency include mileage
reimbursements, travel payments, health benefits, and other
compensation?
No. The FPPC regulation only requires the reporting of the
stipend or salary.
5. Which agency must post the Form 806?
The agency that is voting to appoint a public official must post
the Form 806 on its website. The agency that the official will
serve as a member is not required to post the Form 806. The
form is not sent to the FPPC.
6. When must the Form 806 be amended?
The Form 806 should be amended promptly upon any of
the following circumstances: (1) the number of scheduled
meetings is changed, (2) there is a change in the
compensation paid to the members, or (3) there is a change
in membership on the board or commission.
7. When a body meets irregularly, how should the annual
compensation be estimated?
The agency should estimate compensation using the highest
number of meetings.
8. In 2013 our agency will have a new appOintment to a new
agency. How is the Form 806 updated?
Before the agency votes on the appointment, the agency
should update the Form 806 and identify the other
governmental entity's name. If known, also include other
information such as the number of meetings and stipend.
As long as that information is posted prior to a vote of
the governing board on an appointment, the agency is in
compliance with Regulation 18705.5. Following the vote, the
agency must update the form to identify the individual that
will serve.
Privacy Information Notice
Information requested by the FPPC is used to administer and
enforce the Political Reform Act. Failure to provide information
may be a violation subject to penalties. All reports are public
records available for inspection and reproduction. Direct
questions to FPPC's General Counsel. Fair Political Practices
Commission, 428 J Street, Ste. 620, Sacramento, CA 95814.
FPPC Form 806 (5/12)
FPPC TolI·Free Helpline: 866/ASK·FPPC (866/275·3772)
(Regulations of the Fair Political Practices Commission, Title 2, Division 6, California Code of
Regulations)
§ 18705.5. Materiality Standard: Economic Interest in Personal Finances.
(a) A reasonably foreseeable financial effect on a public official's or his or her immediate
family's personal finances is material ifit is at least $250 in any 12-month period. When
determining whether a governmental decision has a material financial effect on a public official's
economic interest in his or her personal finances, neither a financial effect on the value of real
property owned directly or indirectly by the official, nor a financial effect on the gross revenues,
expenses, or value of assets and liabilities of a business entity in which the official has a direct or
indirect investment interest shall be considered.
(b) The financial effects of a decision which affects only the salary, per diem, or
reimbursement for expenses the public official or a member of his or her immediate family
receives from a federal, state, or local government agency shall not be deemed material, unless
the decision is to appoint, hire, fire, promote, demote, suspend without payor otherwise take
disciplinary action with financial sanction against the official or a member of his or her
immediate family, or to set a salary for the official or a member of his or her immediate family
which is different from salaries paid to other employees of the government agency in the same
job classification or position, or when the member of the public official's immediate family is the
only person in the job classification or position.
(c) Notwithstanding subsection (b), pursuant to Section 82030(b)(2) and Regulation
18232, a public official may make, participate in making, or use his or her official position to
influence or attempt to influence, a government decision where all of the following conditions
are satisfied:
(1) The decision is on his or her appointment as an officer of the body of which he or she
is a member (e.g., mayor or deputy mayor), or to a committee, board, or commission of a public
agency, a special district, a joint powers agency or authority, a joint powers insurance agency or
authority, or a metropolitan planning organization.
(2) The appointment is one required to be made by the body of which the official is a
member pursuant to either state law, local law, or a joint powers agreement.
(3) The body making the appointment referred to in paragraph (1) adopts and posts on its
website, on a form provided by the Commission, a list that sets forth each appointed position for
which compensation is paid, the salary or stipend for each appointed position, the name of the
public official who has been appointed to the position and the name of the public official, if any,
who has been appointed as an alternate, and the term of the position.
COMMENT: Cross-references: For the definition of "immediate family," see Government Code
section 82029.
Note: Authority cited: Section 83112, Government Code. Reference: Sections 87100, 87102.5,
87102.6,87102.8 and 87103, Government Code.
HISTORY
1. New section filed 11-23-98; operative 11-23-98 pursuant to the 1974 version of Government
Code section 11380.2 and title 2, California Code of Regulations, section 18312( d) and (e)
(Register 98, No. 48).
2. Change without regulatory effect amending section heading filed 3-26-99 pursuant to section
100, title 1, California Code of Regulations (Register 99, No. 13).
3. Editorial correction of History 1 (Register 2000, No. 25).
4. Amendment of section heading and section filed 1-17-2001; operative 2-1-2001. Submitted to
OAL for filing pursuant to Fair Political Practices Commission v. Office of Administrative Law,
3 Civil C010924, California Court of Appeal, Third Appellate District, nonpublished decision,
April 27, 1992 (FPPC regulations only subject to 1974 Administrative Procedure Act rulemaking
requirements) (Register 2001, No.3).
5. Amendment of subsection (a) filed 1-16-2002; operative 2-15-2002 (Register 2002, No.3).
6. Amendment of subsection (b) filed 6-21-2005; operative 7-21-2005 (Register 2005, No. 25).
7. Amendment of subsection (a) filed 12-18-2006; operative 1-17-2007. Submitted to OAL for
filing pursuant to Fair Political Practices Commission v. Office of Administrative Law, 3 Civil
C010924, California Court of Appeal, Third Appellate District, nonpublished decision, April 27,
1992 (FPPC regulations only subject to 1974 Administrative Procedure Act rulemaking
requirements) (Register 2006, No. 51).
8. New subsections (c)-(c)(3) filed 4-23-2012; operative 5-23-2012. Submitted to OAL for filing
pursuant to Fair Political Practices Commission v. Office of Administrative Law, 3 Civil
C010924, California Court of Appeal, Third Appellate District, nonpublished decision, April 27,
1992 (FPPC regulations only subject to 1974 Administrative Procedure Act rulemaking
requirements and not subject to procedural or substantive review by OAL) (Register 2012,
No. 17).