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September 9, 2025
ITEM TITLE
Campaign Contributions: Adopt Comprehensive Updates to Chula Vista Municipal Code Chapter 2.52 Regarding Various Provisions of the Campaign Contribution Ordinance Report Number: 25-0213
Location: No specific geographic location
Department: City Clerk & City Attorney
G.C. § 84308 Regulations Apply: No
Environmental Notice: The activity is not a “Project” as defined under Section 15378 of the California Environmental Quality Act State Guidelines. Therefore, pursuant to State Guidelines Section 15060(c)(3) no environmental review is required.
Recommended Action
Place one of the following ordinances on first reading:
A) Ordinance amending Chula Vista Municipal Code Chapter 2.52 to comprehensively update the City’s Campaign Contribution Ordinance, including provisions on contribution limits, permissible sources, acceptance periods, outstanding loans and debt, complaint processing, and removal of duplicative provisions. (First Reading)
OR
B) Ordinance amending Chula Vista Municipal Code Chapter 2.52 to comprehensively update the City’s Campaign Contribution Ordinance, including provisions on contribution limits, permissible sources, acceptance periods, outstanding loans and debt, complaint processing, removal of duplicative provisions, and basing individual contribution limits on a percentage of the State Senate limits. (First Reading)
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SUMMARY
This report presents two alternative ordinances that would comprehensively amend the City’s Campaign Contribution Ordinance (CVMC Chapter 2.52) to reflect City Council direction, City Attorney and City Clerk recommendations, and updates for clarity and consistency with the City Charter. Both ordinances incorporate identical revisions, including changes to contribution limits, allowable sources of contributions, the time period for accepting contributions, rules for outstanding loans and debt, complaint processing, and removal of duplicative provisions. The sole difference is how individual contribution limits are set: Ordinance A uses fixed dollar amounts with biennial adjustments by the City Clerk . Ordinance B ties the limits to a percentage of the State Senate contribution limits, which are automatically adjusted for inflation by the FPPC.
ENVIRONMENTAL REVIEW
The Director of Development Services has reviewed the proposed activity for compliance with the California Environmental Quality Act (CEQA) and has determined that the activity is not a “Project” as defined under Section 15378 of the State CEQA Guidelines because it will not result in a physical change in the environment.
Therefore, pursuant to Section 15060(c)(3) of the State CEQA Guidelines, the activity is not subject to CEQA.
BOARD/COMMISSION/COMMITTEE RECOMMENDATION
The Board of Ethics heard a presentation on the substantial elements of the proposed ordinance on 4/16/2025.
DISCUSSION
In accordance with City Charter Section 905, it is the City’s policy to avoid the potential for undue or improper influence over Elected Officials resulting from excessive campaign contributions. To further this purpose, the Charter requires the City Council to adopt reasona ble regulations governing campaign contributions, to be codified in the Municipal Code.
The City’s campaign contribution ordinance seeks to prevent corruption, ensure transparency, promote fairness, encourage accountability, foster public trust, and promote ethical behavior in the political process.
In 1989, the City adopted Chula Vista Municipal Code (CVMC) Chapter 2.52, “Campaign Contributions,” in compliance with these Charter requirements.
The City Council has received presentations and discussed the Campaign Contribution Ordinance provisions at recent public meetings, including February 14, 2023, May 13, 2025, and August 5, 2025. On August 5, 2025, the City Attorney and City Clerk presented draft provisions based on prior City Council direction. At tha t meeting, a majority of the City Council expressed consensus to revise the ordinance as follows:
1. General updates – Accept recommended clarifications, remove duplicative provisions, update terminology following the 2022 City Charter update (Measure K), and reorganize for clarity.
2. Individual Contribution Limit – District Seats – Set the contribution limit for City Council district seats at $800 per person, per election contest.
3. Individual Contribution Limit – Citywide Seats – Set the contribution limit for citywide seats (Mayor and City Attorney) at $1,200 per person, per election contest.
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4. Organizational & political party committee limits – Set the contribution limit for organizations and political party committees per election contest at one-half of the limit established for members of the State Senate under Government Code Section 85301(a), as adjusted for inflation b y the Fair Political Practices Commission (FPPC) pursuant to Government Code Section 83124. The current State Senate limit is $5,900 through December 31, 2026; therefore, the applicable limit for City candidates would be $2,950 per election contest.
5. Candidate personal loan limit – Limit personal loans from a candidate to their own campaign to $10,000 per election contest.
6. Loan and debt repayment – Require repayment of loans and debts within 11 months after the election.
7. Penalty for false complaints – Increase the maximum penalty for intentionally filing a false complaint to $2,500.
All of these revisions are included in both of the draft ordinances presented for consideration. The only difference between the two is the method for setting and adjusting individual contribution limits, as described below.
Ordinance Options
Two draft ordinances are presented for City Council consideration:
Ordinance A – Implements the revisions approved in concept by the City Council on August 5, 2025, with fixed dollar amounts for individual contribution limits. The City Clerk would continue to adjust these amounts every two years to account for inflation. Attachment 1 is a redline version that shows the changes made by Ordinance A.
Ordinance B – Identical to Ordinance A except that individual contribution limits are tied to a percentage of the State Senate contribution limits, which are automatic ally adjusted for inflation by the FPPC. This approach mirrors the City Council-directed limits on contributions from organizations and political party committees. Attachment 2 is a redline version that shows the changes made by Ordinance B.
The primary difference between Ordinance A and Ordinance B is how individual contribution limits are set and adjusted. All other provisions are the same. Attachment 3 is a redline version that shows the differences between Ordinance A and Ordinance B.
Table 1 – Comparison of Ordinance A and Ordinance B
Provision Ordinance A Ordinance B
General updates (clarifications, removal of
duplicative provisions, updated terminology,
reorganization)
✔ ✔
Individual Contribution Limit – District
Seats
$800 per person, per
election contest
15% of State Senate limit
(currently $885)
Individual Contribution Limit – Citywide
Seats
$1,200 per person, per
election contest
20% of State Senate limit
(currently $1,180)
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Provision Ordinance A Ordinance B
Organizational & political party committee
limit
50% of State Senate limit
(currently $2,950)
50% of State Senate limit
(currently $2,950)
Candidate personal loan limit $10,000 per election
contest
$10,000 per election
contest
Loan & debt repayment deadline 11 months after election 11 months after election Penalty for intentionally filing a false
complaint
Up to $2,500 Up to $2,500
Individual contribution limit adjustments
for inflation
Requires City Clerk
adjustment every 2 years
Automatically adjusts with
State Senate limits, no City
Clerk adjustment needed
Adopting either ordinance would modernize the City’s Campaign Contribution Ordinance, ensure compliance with City Charter requirements, and strengthen transparency and accountability in local elections. The choice between Ordinance A and Ordinance B centers on the preferred method for setting and adjusting individual contribution limits, either fixed amounts with periodic adjustments by the City Clerk or an automatic adjustment mechanism tied to State Senate limits. Staff recommends that the City Council place its preferred ordinance on first reading.
DECISION-MAKER CONFLICT
Staff has reviewed the decision contemplated by this action and has determined that it is not site-specific and consequently, the real property holdings of the City Councilmembers do not create a disqualifying real property-related financial conflict of interest under the Political Reform Act (Cal. Gov't Code § 87100, et seq.).
Staff is not independently aware, and has not been informed by any City Councilmember, of any other fact that may constitute a basis for a decision-maker conflict of interest in this matter.
CURRENT-YEAR FISCAL IMPACT
There is no current-year fiscal impact.
ONGOING FISCAL IMPACT
There is no ongoing fiscal impact
ATTACHMENTS
1. Changes to CVMC 2.52 in redline format for Ordinance A
2. Changes to CVMC 2.52 in redline format for Ordinance B
3. Comparison of Ordinances A and B in redline format
Staff Contacts: Marco Verdugo, City Attorney, and Kerry Bigelow, City Clerk