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HomeMy WebLinkAbout11 Conflit of interest code Agenda Item # 11 TRUCKEE Public Utility District ACTION To: Board of Directors From: Michael D. Holley Date: February 18, 2009 Subject: Adopt Revisions to the District's Conflict of Interest Code 1. WHY THIS MATTER IS BEFORE THE BOARD The Political Reform Act requires every district to review its conflict-of-interest code biennially. 2. HISTORY The District's conflict-of-interest code was reviewed as part of District Code Title 2, Administration in a workshop held on August 6, 2008. A Public Hearing to receive comments on the proposed revisions to the District conflict-of-interest code was held on September 17, 2008. A resolution to adopt District Code Title 2 revisions which included the conflict-of- interest code was adopted on October 1, 2008. The revised conflict-of-interest code was submitted to the Fair Political Practices Commission (FPPC). 3. NEW INFORMATION The FPPC is working with districts and agencies to standardize the conflict-of-interest format. The District needs to use this new format. The District is not required to hold another public hearing before we adopt the amended resolution for the revisions to the conflict-of-interest code. Conflict-of-interest code revisions are: • Remove Executive Secretary and Human Recourses Administrator from reporting as the positions only ministerial functions • Add the Contract Administrator as this position appears to participate in making governmental decisions that could have a material financial effect on the decision maker • Add wording for utility companies that supply power in regards to solar and renewable power 4. FISCAL IMPACT There is no fiscal impact with this matter. 5. RECOMMENDATION Adopt the resolution amending the District's conflict-of-interest code. o Michael D. Holley General Manager -,. Public Utility I District P� Resolution No. 2009 - XX ADOPTING AMENDMENTS TO THE DISTRICT'S CONFLICT OF INTEREST CODE WHEREAS, the Board of Directors of the Truckee Donner Public Utility District wishes to amend the District conflict-of-interest code; and WHEREAS, the Truckee Donner Public Utility District has had, for a number of years, a conflict-of-interest code, which it adopted as required by the Political Reform Act of 1974, Government Code Section 81000, et. seq.; and WHEREAS, the conflict-of-interest code which must be reviewed bi-annually and includes a list of directors, officers, employees and consultants who must disclose certain financial interests and a list of those interests that must be disclosed; and WHEREAS, a workshop was held on August 6, 2008 for the Board to review and comment on the proposed changes to the conflict-of-interest code; and WHEREAS, a Public Hearing was held on September 17, 2008 to consider public input on the proposed changes to the conflict-of-interest code; and. WHEREAS, a resolution was adopted on October 1, 2008 to accept the proposed changes to the C conflict-of-interest code; and. WHEREAS, the Fair Political Practices Commission has asked the District to use a standard format which makes substantial changes to the newly revised conflict-of- interest code; and WHEREAS, the designated positions have been revised to remove the Executive Secretary and Human Resources Administrator; the Contract Administrator has been added; and disclosure categories reworded to clarify reporting of interests; and WHEREAS, the District has available at its offices all the information upon which the proposed amendments to the conflict-of-interest code are based; and NOW THEREFORE, BE IT RESOLVED, that the Board of Directors does hereby adopt the amended conflict-of-interest code. 1 Resolution 2009-XX, Conflict of Interest PASSED AND ADOPTED by the Board of Directors of the Truckee Donner Public Utility District in a meeting duly called and held within said District on the 18th day of February 2009 by the following roll call vote: AYES: ABSTAIN: NOES: ABSENT: TRUCKEE DONNER PUBLIC UTILITY DISTRICT By J. Ron Hemig, President ATTEST: Michael D. Holley, Clerk of the Board 2 Resolution 2009-XX, Conflict of Interest California Fair Political Practices Commission -- Adopting a Conflict of Interest Code Page 1 of 2 algae g. s Adopting a Conflict of Interest Code Under the Political Reform Act(the "Act"), all public agencies are required to adopt a conflict of interest code (code). A code FPPC Home Page designates positions required to file Statements of Economic Interests (Form 700), and assigns disclosure categories specifying Commission the types of interests to be reported. The Form 700 is a public document intended to alert public officials and members of the Agendas public to the types of financial interests that may create conflicts of interests. j#wFPPC Regulations The Political Reform Three Components Act :Candidates and Each code must contain the following: Committees Behested Payments Form 801 1. Terms of the code ;;Form 802 Independent The terms of the code comprise the main body of a code and include such provisions as the manner to report financial interests, Expenditures the disqualification procedures, etc. The FPPC recommends that agencies incorporate FPPC Regulation 18730 by reference Interested Persons' because the type of information required to be in the main body of the code is quite complex and Regulation 18730 contains all of 11 Meetings these provisions. The FPPC will amend the regulation to include legislative and regulatory changes that affect the main body of ijoLobbyists the code; therefore, this component of an agency's code is automatically in compliance with the Act. To view FPPC Regulation ;,Restrictions on 18730, click here. Government Officials and Employees 2. Designated positions Ethics Orientation for State Officials The code must specifically list positions that make or participate in making decisions. Typically, positions that involve voting on Conflicts of Interest/ matters, negotiating contracts, or making recommendations on purchases without substantive review must be included in codes. Form 700/COI Codes Positions listed in Government Code Section 87200 (i.e. City Councilmembers, Planning Commissioners, Members of the Board Farm 700 of Supervisors, etc.)are not required to be included, because these positions automatically file Form 700. „Section 1090 Study ,Can I Vote?Overview of An agency may review duty statements or enlist the assistance of department or division managers to determine which positions the Conflicts Laws should be included. ;, Notification Guidelines for Form 700 Filing Officers SEI/Conflict Training/Code Review Seminars and 3. Disclosure Categories Workshops gency conflict-of- A primary purpose of the code is to require disclosure of those types of investments, interests in real property, sources of income Interest Code Biennial and business positions that designated positions may affect in their decision-making. For example, the manager of an agency Notice P 9 P Y 9• P 9 9 Y Where to Find Copies of should be assigned full disclosure (all investments, interests in real property, sources of income and business positions) because Form 700 Filed by Public the manager makes decisions that affect a wide range of interests. Alternatively, a purchasing agent whose decision-making is Officials limited to the purchase of office supplies should only be assigned disclosure of investments, sources of income and business dopting a Conflict of Interest Code positions in entities that provide office supplies, equipment or merchandise of the type used by the agency. http://www.fppc.ca.gov/index.html?id=228 2/12/2009 California Fair Political Practices Commission -- Adopting a Conflict of Interest Code Page 2 of 2 *Your Duty to File: The FPPC has developed model disclosure categories to assist state agencies in drafting or amending their conflict-of-interest Economic Disclosure for codes. To view model categories, click here. Public Officials g Holding Two Positions (updated 12/19/03) Code Approval �opConflict of Interest Training/Slide Show ;,;Exemptions from Codes are not effective until they have been approved by an agency's code reviewing body(section 87303). The code reviewing Coverage by Conflict-of- body for city agencies is the city council. The code reviewing body for an agency wholly within a count Is the count board of Interest Code Y Y 9 Y 9 Y g Y Y Y Y :How To Get More Help supervisors. The code reviewing body for multi-county and state agencies is the FPPC. Contact the specific code reviewing body CAB 1234 Ethics or the FPPC for further guidance regarding code adoption procedures. Training for Local Officials Enforcement (Revised 5/03) Audit Program Workshops &Seminars sLitigation Mailing Lists Links Contacting the FPPC .................. Copyright 2009 State of California FPPC. All rights reserved. http://www.fppc.ca.gov/index.html?id=228 2/12/2009 CHAPTER 2.52 CONFLICT OF INTEREST Deleted: Sections: Deleted: Deleted:which 2.52.005 Financial Interests of Employees Deleted: 2.52.010 District's Conflict of Interest Code i Deleted: 2.52.015 Officials Who Manage Public Investments Deleted:it 2.52.020 Disclosure Categories and Designated Positions Deleted:¶ 2.52.005 Financial Interests of Employees - It is the policy of the Board that Deleted:T no employee of the District shall have any financial interest in any activity outside ;' Deleted:employees the Truckee Donner Public Utility District which does business for profit with the �,;'!; Deleted:categories Truckee Donner Public Utility District(District). Deleted:C 2.52.010 District's Conflict of Interest Code - The Political Reform Act ji';; ;;; Deleted: (Government Code Section 87100, et seq.) requires state and local government (i'';-ii;i; Deleted` I a encies to adopt and promulgate conflict- f nterest codes. The Fair Political r Deleted:C 9 P P 9 - Practices Commission has adopted a regulation (2 Cal. Code of Regs. 18730) Deleted:- hat contains the terms of a standard conflict7;pfjnterest code, which can be a Deleted:Designated employees incorporated by reference in an agency's code. After public notice and hearing Deleted:Truckee Donner Pubic the standard code maybe amended by_the Fair Political Practices Commission ; utility to conform to amendments in the Political Reform Act. Therefore,1he terms of 2 ,' ;, Deleted: California Code of Regulations Section 18730 and any amendments to it duly tt;;;:' Deletes:employees adopted b the Fair Political Practices Commission are hereby adopted and ,t!, Deleted:TDPUD P Y Y P �' �,' incorporated by reference. This regulation and Sections 2.52.015 — 2.52.020 14 i, Deleted:¶ designating officials and,positions and establishing disclosure Mguirements shall , Deleted:2.52.010.2 Investments constitute the (gpnflict.�pf jnterest Bode for the Truckee Donner Public Utility ` and business positions in any District District`` business and sources of income 1 listed in Column II are disclosable if:¶ 2.52.010.1 Place of Filing — Individuals holding designated positions shall file +,;", Mich the investment The business entity in F ,��' which the investment or business their statements with the District, which will make the statements available for , position is held or the source of income is of the type which within the p ublic insp ection and reproduction Gov. Code §81008 tatements for all last two years has contracted with the designated,positions will be retained by the istrict. , 1, District;or¶ c_ ----- ------- -------------.-----„-----__-__ _-_-. ..-_.--.... ...-. .._ ___ -- --------- ------- - _1 2.52.010.2(B) The business entity in 2.52.015 Officials Who Manage Public Investments The following positions which the investment or business position is held or the source of are not covered by this conflict-of-interest code because those individuals holding income is of the type which within the these positions must file under Government Code Section 87200. These last two years has contracted to positions are listed for information al purposes only: furnishsubcontractors supplies any contract as subcontractors in any contract with • Members of the Board of Directors the District.¶ • General Manager 2.52.010.3 Interests in real property • District Treasurer are disclosable by a designated employee if listed in Column II on the • Assistant Treasure line applicable to his or her position.¶ • Consultants(Those that invest public funds.) Deleted:No public official of the District,as specified in Formatted:Bullets and Numbering 1 An individual holding one of the above-listed positions may contact the Fair Political Practices Commission for assistance or written advice regarding their filing obligations if they believe that their position has been categorized incorrectiv. The Fair Political Practices Commission makes the final determination whether a position is covered by Government Code Section 87200. Deleted:, ,2.52.020 Designated Positions and Disclosure Categories„ Deleted: Shall make,participate in j making or in any way attempt to use The following positions are in Disclosure Category I: l', his or her official position to influence A, esi Hated Positions a government decision in which he or Administrative Services Manager `{ she knows or has reason to know he or she has a financial interest in Assistant General Manager P; accordance with the Political Reform Attorney Act.Public officials who manage Electric Utility Manager/Power Supply Engineer/GIS ±'(, public investments shall file a Public Information and Conservation Manager statement of economic interest to disclose his or her financial interest in Water Utility Manager accordance with the Political Reform Consultants Act.It has been determined that the positions listed below manage public investments and will file a statement The following positions are in Disclosure Category 11: of economic interest pursuant to Government code Section 87200:(1) Buyer/Clerk Directors,(2)General Manager,(3) Contract Administrator District Treasurer and(4)Assistant Customer Services Manager Treasurer.¶ Finance and Accounting Manager ' ¶ Geographic Information System Coordinator Deleted:and Senior Accountant Analyst Deleted:Designated Positions Technical Program Administrator Deleted:category l The following positions are in Disclosure Category III: Formatted:Font:Bold Conservation Program Administrator Electric Engineer Electric Superintendent Electric System Engineer Water Engineer Formatted:Font:11 pt Water Superintendent Deleted: 1.Disclosure Categories. Water System Engineer. Persons occupying positions in Category I shall disclose all investments,interests in real *Consultants shall be included in the list of designated employees and shall property,sources of income and disclose pursuant to the pisclosure Requirements in the Code,subject to the business positions held in business -- entities located in or doing business following limitations. The General Manager may determine, in writing, that a within the jurisdiction of the District.¶ particular consultant, although a_°designated positions" had been hired to perform ¶ 2.Designated Positions¶ a range of duties that is limited in scope and thys is not required to fully comply a.Assistant General Manager¶ with the disclosure requirements described in this section. Such written `• b.consultants'¶ determination shall include a description of the consultant's duties, and based •`. .\ Deleted:broadest category upon that description, a statement of the extent of disclosure requirements. The Deleted:occupying General Manager's determination is a public record and shall be retained for Deleted:i public inspection in the same manner and location as the conflict,; f:jnterest Deleted:of the Code -code. _ _ _ _ Deleted:C Deleted: B. Disclosure Category I Deleted: I Deleted:C 2 Individuals holding designated positions in Disclosure Category I must report their Formatted:Bullets and Numbering interests in real property located within the jurisdiction or within two miles of the boundaries of the jurisdiction or within two miles of any land owned or used by the s Gated:¶ n agency: and investments and business positions in business entities, and income, 1.Disclosure Categories.Persons including loans,gifts, and travel payment,from all sources. occupying positions in Category u shall disclose any investments in, sources of income from,and business C. Disclosure Category II positions held in any business Individuals holding designated positions in Disclosure Category II must report their providing services,supplies, materials,or equipment of the type interests in real property located within the jurisdiction or within two miles of the utilized by the District,and located in boundaries of the jurisdiction or within two miles of any land owned or used by the r or doing business within the District. agency: investments and business positions in business entities, and income, including Types of businesses for which - disclosure is required include,but are loans,gifts, and travel payment,from sources,that: not limited to the following:¶ a. provide supplies, materials, machinery, equipment, or vehicles of the type• a.Construction and building utilized by the District, including, but not limited to: motor and specialty materials;¶ b.Office equipment and supplies;¶ vehicles and parts, petroleum products, construction and building materials c.Banks and savings and loan (e.g.transformers, poles, wire, cable, pipes), and solar and renewable energy institutions;¶ products; d.Public utilities;¶ e.Financial audit services;¶ b. are contractors providing services utilized by the District, including, but limited f.Insurance services;¶ to: educational and medical services, information technology, insurance, g•Printing,reproduction or photographic equipment,supplies engineering, energy pricing, legal, and billing and collection; and services;¶ c. are persons with a permit pending before the District; h.Chemical supplies and d. are utility companies or sources that supply power to the agency, including equipment¶ i.Motor vehicles and specialty solar and renewable power; vehicles,parts and supplies;¶ e. engage in the business of brokering, acquiring, leasing, marketing, disposing, 1.Petroleum products;¶ k.Measuring and calculating or owninq real property; equipment;¶ f. provide engineering, energy, or environmental assessment reports including I.Safety equipment and supplies;¶ those relating to pricing and demand; Or .m.Telephone and communication services and equipment;¶ q. provide consulting services, including, but not limited to: legal, financial, n.Pipes,valves,fittings,pumps, public relations, labor relations, and energy. tanks and similar materials;¶ o.Water quality testing equipment and services;¶ D. Disclosure Category III p.Cathodic protection equipment, Individuals holding designated positions in Disclosure Category III must report their services and supplies;¶ q.Engineering services;¶ investments and business positions in business entities, and income, including loans, j r.Employment and temporary help gifts, and travel payments, from sources, that provide services, supplies, materials, ! agencies;¶ machinery, equipment, or vehicles of the type utilized by the Department to which the s.General and specialty equipment rental;¶ filer has been assigned. t.Demolition,construction and maintenance services;¶ u.Real estate sales or investment firms,¶ v.Consulting services:legal, collection,energy and power, engineering,soils testing,water treatment,data processing, computers,financial,labor relations, employee training,advertising, communications,design,art work, audiovisual,movie production, planning,water pricing and demand, economics,auditing,desalination, architecture environmental,appraisal;¶ w.Information technology.¶ X.Computer hardware and software¶ 2.Designated Positions¶ a.Administrative Services Manager¶ b.Buyer/Clerk¶ c.Conservation Programs 1 3 Page 3:[1]Deleted Barbara 2/12/2009 5:41:00 PM B. Category II 1. Disclosure Categories. Persons occupying positions in Category II shall disclose any investments in, sources of income from, and business positions held in any business providing services, supplies, materials, or equipment of the type utilized by the District, and located in or doing business within the District. Types of businesses for which disclosure is required include, but are not limited to the following: a. Construction and building materials; b. Office equipment and supplies; c. Banks and savings and loan institutions; d. Public utilities; e. Financial audit services; f. Insurance services; g. Printing, reproduction or photographic equipment, supplies and services; h. Chemical supplies and equipment; i. Motor vehicles and specialty vehicles, parts and supplies; j. Petroleum products; k. Measuring and calculating equipment; I. Safety equipment and supplies; m. Telephone and communication services and equipment; n. Pipes, valves, fittings, pumps, tanks and similar materials; o. Water quality testing equipment and services; p. Cathodic protection equipment, services and supplies; q. Engineering services; r. Employment and temporary help agencies; s. General and specialty equipment rental; t. Demolition, construction and maintenance services; u. Real estate sales or investment firms; v. Consulting services: legal, collection, energy and power, engineering, soils testing, water treatment, data processing, computers, financial, labor relations, employee training, advertising, communications, design, art work, audiovisual, movie production, planning, water pricing and demand, economics, auditing, desalination, architecture environmental, appraisal; w. Information technology. x. Computer hardware and software 2. Designated Positions a. Administrative Services Manager b. Buyer/Clerk c. Conservation Programs Administrator d. Customer Services Manager e. Electric Utility Manager/Power Supply Manager f. Electric System Engineer g. Electric Engineer h. Electric Superintendent i. Finance & Accounting Manager j. Geographical Information Services Coordinator k. Human Resources Administrator I. Power Supply Engineer m. Public Information and Conservation Manager n. Senior Accountant Analyst o. Technical Program Administrator p. Water Utility Manager q. Water Superintendent r. Water System Engineer s. Water Engineer C. Category III 1. Disclosure Categories, Persons occupying positions in Category III shall disclose any investments in, sources of income from, and business positions held in any business providing services, supplies, materials, or equipment of the type utilized by the District, and located in or doing business within the District. Types of businesses for which disclosure is required include, but are not limited to the following: a. Office equipment and supplies; b. Printing, reproduction or photographic equipment, supplies and services; c. Employment and temporary help agencies 2. Designated Positions a. Executive Secretary b. Human Resources Administrator CHAPTER 2.52 CONFLICT OF INTEREST Sections: 2.52.005 Financial Interests of Employees 2.52.010 District's Conflict of Interest Code 2.52.015 Officials Who Manage Public Investments 2.52.020 Disclosure Categories and Designated Positions 2.52.005 Financial Interests of Employees - It is the policy of the Board that no employee of the District shall have any financial interest in any activity outside the Truckee Donner Public Utility District which does business for profit with the Truckee Donner Public Utility District (District). 2.52.010 District's Conflict of Interest Code - The Political Reform Act (Government Code Section 87100, et seq.) requires state and local government agencies to adopt and promulgate conflict-of-interest codes. The Fair Political Practices Commission has adopted a regulation (2 Cal. Code of Regs. 18730) that contains the terms of a standard conflict-of-interest code, which can be incorporated by reference in an agency's code. After public notice and hearing, the standard code may be amended by the Fair Political Practices Commission to conform to amendments in the Political Reform Act. Therefore, the terms of 2 California Code of Regulations Section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby adopted and incorporated by reference. This regulation and Sections 2.52.015 — 2.52.020 designating officials and positions and establishing disclosure requirements shall constitute the conflict-of-interest code for the Truckee Donner Public Utility District (District). 2.52.010.1 Place of Filing — Individuals holding designated positions shall file their statements with the District, which will make the statements available for public inspection and reproduction (Gov. Code §81008). Statements for all designated positions will be retained by the District. 2.52.015 Officials Who Manage Public Investments - The following positions are not covered by this conflict-of-interest code because those individuals holding these positions must file under Government Code Section 87200. These positions are listed for information al purposes only: • Members of the Board of Directors • General Manager • District Treasurer • Assistant Treasure • Consultants (Those that invest public funds.) 1 An individual holding one of the above-listed positions may contact the Fair Political Practices Commission for assistance or written advice regarding their filing obligations if they believe that their position has been categorized incorrectly. The Fair Political Practices Commission makes the final determination whether a position is covered by Government Code Section 87200. 2.52.020 Designated Positions and Disclosure Categories A. Designated Positions The following positions are in Disclosure Category I: Administrative Services Manager Assistant General Manager Attorney Electric Utility Manager/Power Supply Engineer/GIS Public Information and Conservation Manager Water Utility Manager Consultants* The following positions are in Disclosure Category II: Buyer/Clerk Contract Administrator Customer Services Manager Finance and Accounting Manager Geographic Information System Coordinator Senior Accountant Analyst Technical Program Administrator The following positions are in Disclosure Category III: Conservation Program Administrator Electric Engineer Electric Superintendent Electric System Engineer Water Engineer Water Superintendent Water System Engineer *Consultants shall be included in the list of designated employees and shall disclose pursuant to the Disclosure Requirements in the Code, subject to the following limitations. The General Manager may determine, in writing, that a particular consultant, although a "designated position," had been hired to perform a range of duties that is limited in scope and thus is not required to fully comply with the disclosure requirements described in this section. Such written determination shall include a description of the consultant's duties, and based upon that description, a statement of the extent of disclosure requirements. The General Manager's determination is a public record and shall be retained for public inspection in the same manner and location as the conflict-of-interest code. B. Disclosure Category 1 2 Individuals holding designated positions in Disclosure Category I must report their interests in real property located within the jurisdiction or within two miles of the boundaries of the jurisdiction or within two miles of any land owned or used by the agency; and investments and business positions in business entities, and income, including loans, gifts, and travel payment, from all sources. C. Disclosure Category II Individuals holding designated positions in Disclosure Category II must report their interests in real property located within the jurisdiction or within two miles of the boundaries of the jurisdiction or within two miles of any land owned or used by the agency; investments and business positions in business entities, and income, including loans, gifts, and travel payment, from sources, that: a. provide supplies, materials, machinery, equipment, or vehicles of the type utilized by the District, including, but not limited to: motor and specialty vehicles and parts, petroleum products, construction and building materials (e.g. transformers, poles, wire, cable, pipes), and solar and renewable energy products; b. are contractors providing services utilized by the District, including, but limited to: educational and medical services, information technology, insurance, engineering, energy pricing, legal, and billing and collection; c. are persons with a permit pending before the District; d. are utility companies or sources that supply power to the agency, including solar and renewable power; e. engage in the business of brokering, acquiring, leasing, marketing, disposing, or owning real property; f. provide engineering, energy, or environmental assessment reports including those relating to pricing and demand; or g. provide consulting services, including, but not limited to: legal, financial, public relations, labor relations, and energy. D. Disclosure Category III Individuals holding designated positions in Disclosure Category III must report their investments and business positions in business entities, and income, including loans, gifts, and travel payments, from sources, that provide services, supplies, materials, machinery, equipment, or vehicles of the type utilized by the Department to which the filer has been assigned. 3