HomeMy WebLinkAboutStaff Report 2410-3619CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, February 10, 2025
Council Chambers & Hybrid
5:30 PM
Agenda Item
11.Adoption of a Resolution Amending the Conflict of Interest Code for Designated City
Officers and Employees as Required by the Political Reform Act and Regulations of the
Fair Political Practices Commission and Repealing Resolution Number 9937. CEQA
Status -- Not a Project
City Council
Staff Report
From: City Clerk
Report Type: CONSENT CALENDAR
Lead Department: City Clerk
Meeting Date: February 10, 2025
Report #:2410-3619
TITLE
Adoption of a Resolution Amending the Conflict of Interest Code for Designated City Officers
and Employees as Required by the Political Reform Act and Regulations of the Fair Political
Practices Commission and Repealing Resolution Number 9937. CEQA Status -- Not a Project
RECOMMENDATION
It is recommended that Council adopt a resolution amending the City’s Conflict of Interest Code
of Non-Elected Officials and Designated employees, repealing Resolution 9937.
BACKGROUND
California law requires public officials, both elected and non-elected, to disclose their financial
interests to the public. This includes elected officials like Councilmembers and non-elected
officials like the City Manager and City Treasurer, as outlined by Government Code Section
87200. Other non-elected officials, such as management staff and consultants, are designated
by the agency’s Conflict of Interest Code and must disclose if they have financial decision-
making authority.
These disclosures, filed through Form 700, alert the public to any personal financial interests
that may be impacted by the official’s duties. Form 700 is filed when taking office, annually, and
upon leaving office.
On January 11, 2021, City Council adopted Resolution 9937 amending the Conflict of Interest
Code designated for City Officers and Employees as required by the Political Reform Act and
Regulations of the Fair Political Practices Commission and repealed Resolution No. 9800.
ANALYSIS
The Political Reform Act requires the City review its Conflict of Interest Code every two years.
Chapter 2.09 of the Palo Alto Municipal Code and the Political Reform Act require the City to
adopt a list of designated positions and disclosure responsibilities for each position subject to
the Conflict of Interest Code for Designated Employees. Disclosure statements from designated
positions are due annually each April and within 30 days of a person either assuming or leaving
a designated position. The attached Resolution amends the City’s Conflict of Interest Code to
update the list of designated positions to reflect administrative changes, including title changes
and positions added or deleted from the Table of Organization. The attached Resolution
(Attachment A) includes the Disclosure Categories and Definitions in Appendix B and resources
for Statement of Economic Interests filers in Appendix C.
The last review and update of the Conflict of Interest Code occurred in January 2021.
Accordingly, the City Council is required to approve an update to the code. The following is a
summary of the proposed updates, based upon review by City staff:
Addition of positions and/or divisions that will be involved in financial decision making:
HUMAN RESOURCES
•Human Resources Representative
•Manager, Recruitment Division
INFORMATION TECHNOLOGY
•Assistant Director, Information Technology
PLANNING & DEVELOPMENT SERVICES
•Supervisor of Code Enforcement
•Senior Building Inspector
PUBLIC WORKS
Administration Division
•Assistant Director of Climate Action and Sustainability
•Management Analyst
Office of Sustainability (additional division)
•Sustainability Programs Administrator
OFFICE OF TRANSPORTATION
•Coordinator Transportation Systems Management
UTILITIES
Administration
•Principal Utilities Program Manager
•Utilities Safety Officer
•Utilities Systems Analyst
Engineering Division to Electric Engineering & Operating Division (revision)
•Manager Electric Operations
Water-Gas-Wastewater Engineering & Operations Division (additional division)
•Assistant Director Utilities W-G-W
•Manager Utilities Operations W-G-W
•Engineering Manager W-G-W
•Senior Project Engineer
•Utilities Supervisor
Palo Alto Fiber (additional division)
•Assistant Director Fiber
•Manager, Telecommunications
•Manager, Information Technology
Revision of Titles:
FIRE DEPARTMENT
•Deputy Chief/Fire Marshal to Fire Marshal
LIBRARY DEPARTMENT
•Assistant Director, Libraries Services to Division Head, Operations
UTILITIES DEPARTMENT
Resource Management Division
•Asst Dir Ut/Res Mgmt to Assistant Director, Resource Management
Electric Engineering & Operating Division
•Assistant Director Utilities Engineering to Assistant Director, Utilities, Electric, and Fiber
•Senior Engineer – U (Senior Project Engineer) to Utilities Supervisor
Deletion of positions and/or divisions:
CITY ATTORNEY
•Management Specialist (Attorney)
UTILITIES
Electric Engineering & Operating Division
•Engineering Manager Water Gas Wastewater
•Manager, Utilities Telecommunications
•Supervising Electric Project Engineer
Operations Division (deletion of division)
There are no updates to the disclosure categories.
Appendix C Resources was updated with new electronic filing system (eFile) information as well
as links to the FPPC reference pamphlet and Form 700 Disclosure FAQs.
FISCAL/RESOURCE IMPACT
There are no significant Fiscal/Resource impacts related to this item. The law mandates that
every local government agency review its Conflict of Interest Code every two years to
determine if any amendments are needed. The cost related to processing the Statements of
Economic Interests are part of the City Clerk Department budget.
STAKEHOLDER ENGAGEMENT
Staff collaborated with Human Resources Department on the proposed changes and the
attached update to the Conflict of Interest Code was circulated to department heads for
confirmation of changes. Updates and edits are reflected in the attached draft resolution.
ENVIRONMENTAL REVIEW
This action is not a project under section 15378 (b)(25) of the California Environmental Quality
Act Guidelines (administrative activities that will not result in direct or indirect physical change
in the environment).
ATTACHMENTS
Attachment A: Resolution approving an update of Conflict of Interest Code and Appendix "A"
Designating Positions Red-Lined
Attachment B: Local Agency Biennial Notice
APPROVED BY:
Mahealani Ah Yun, City Clerk