Staff Report - Sacramento Ethics Commission Recommendation - Modernize the City of Sacramento Lobbyist Registration and Reporting Code — Law and Legislation Committee, May 16, 2023

City of Sacramento
Law and Legislation Committee Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2023-00560 5/16/2023 Discussion Item 5.

Sacramento Ethics Commission Recommendation - Modernize the City of Sacramento Lobbyist Registration and Reporting Code
File ID: 2023-00560
Location: Citywide
Recommendation: Review the Sacramento Ethics Commission five recommendations and pass a Motion either 1) directing the Sacramento Ethics Commission conduct further review and come back to the Law and Legislation Committee with additional analysis; 2) directing the City Clerk and/or City Attorney to come back to the Law and Legislation Committee with more information regarding the proposed recommendation; 3) directing the City Clerk and/or City Attorney to bring back to the Law and Legislation Committee draft amendments to ordinance(s) per committee direction; or 4) dismissing the recommendation(s).

Contact: Mindy Cuppy, MMC, City Clerk, (916) 808-5442, [email protected], Office of the City Clerk
Presenter: Sacramento Ethics Commissioners Liz Gomez and Linda Ng.

Attachments:
1-Description/Analysis
2-October 24, 2022 Ethics Commission staff report
3-Memorandum from Consultant
4-Sacramento City Code Section 2.15, The City of Sacramento Lobbyist Registration and Reporting Code
5-Sacramento City Code Section 2.112, Ethics Commission Additional Description/Analysis
Issue Detail: At the October 24, 2022 meeting, the Sacramento Ethics Commission recommended updates to the Lobbyist Registration and Reporting Code (Sacramento City Code Chapter 2.15).

Below is a summary of the recommended updates:

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File ID: 2023-00560 5/16/2023 Discussion Item 5.

Recommendation 1: Lobbyist registration thresholds should provide sufficient disclosure of activity to the public.

Change lobbying registration thresholds to:
· In-house lobbyist to 15 hours per 3 month period
· Contract lobbyist to $1,500 per 3 month period
Recommendation 2: Disclosure of information in lobbying reports (by what entities, and frequency of reporting) should support transparency.

Similar to state reporting requirements, require City quarterly lobbying reports to indicate:
· How much lobbying firms are receiving from clients and how much lobbyist employers are paying lobbying firms.
· Any gifts, campaign contributions, and behested payments made to city officials by a lobbying firm, lobbyist, or lobbyist employer.

Recommendation 3: Make relevant data more accessible to the public and media online.

Improve the City’s onlinelobbying data collection and disclosure system to permit:
· Searching lobbying filings by lobbyist employer
· Searching by item being lobbied on (e.g., if there is a permit # or resolution #) · Allow system to filter and sort reports by the amount of money spent lobbying (e.g., permit the system to only display lobbyist employers who spent more than $10,000 lobbying in a year) Recommendation 4: Lobbyist activities that create a risk of undue influence, or appearance thereof, should be regulated.

Follow state law where lobbyists and lobbying firms are limited to gifts of less than $10/month to elected officials, and are prohibited from directly contributing to campaigns of elected officials they lobby.

Recommendation 5: Consistent with the Ethics Commission’s scope and mission, clarify the Ethics Commission’s authority to enforce the Lobbying Ordinance.

Amend the City Municipal Code to expressly extend the Ethics Commission’s enforcement authority to include lobbyists, lobbying firms, and lobbyist employers. Amend the Lobbying Ordinance to reference the availability of these administrative penalties.

Policy Considerations: Sacramento City Code Section 2.15, The City of Sacramento Lobbyist Registration and Reporting Code and Sacramento City Code Section 2.112, Ethics Commission.

Economic Impacts: Not applicable.

Environmental Considerations: This action is not a project subject to CEQA because it involves only general policy and procedure making and does not have the potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment. (CEQA Guidelines, §§ 15002(d), 15378(b)(2), 15061(b)(3).)
Sustainability: Not applicable.

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File ID: 2023-00560 5/16/2023 Discussion Item 5.

Commission/Committee Action: On October 24, 2022 the Sacramento Ethics Commission passed a Motion forwarding the attached recommendation to the Personnel and Public Employees Committee for review and deliberation. On April 18, 2023 the Personnel and Public Employees Committee reviewed and provided direction on the Sacramento Ethics Commission recommendation and directing staff to forward the recommendation to the Law and Legislation Committee for deliberation.

Rationale for Recommendation: Not applicable.

Financial Considerations: Not applicable.

Local Business Enterprise (LBE): Not applicable.

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City of Sacramento
Ethics Commission Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2022-01852 10/24/2022 Discussion Item 04.

Sacramento Ethics Commission Lobbyist Registration and Reporting Code Ad Hoc Committee Update (Continued from September 26, 2022)
File ID: 2021-01852
Location: Citywide
Recommendation: 1) Receive and file activities of the Sacramento Ethics Commission Lobbyist Registration and Reporting Code Ad Hoc Committee, and 2) pass a Motion forwarding the recommendations to the City Council.

Contact: Mindy Cuppy, MMC, City Clerk, (916) 808-5442, [email protected], Office of the City Clerk
Presenters: Commissioners Gomez and Ng.

Attachments:
1-Description/Analysis
2-Sacramento City Code Chapter 2.15 - Lobbyist Registration and Reporting Code 3-October 12, 2022 Letter from the Ad Hoc Committee
Description/Analysis
Issue Detail: On May 23, 2022, the Sacramento Ethics Commission established the Lobbyist Registration and Reporting Code Ad Hoc Committee and appointed Commissioners Gomez and Ng.

On September 26, 2022 the Ad Hoc Committee presented an update to the commission and was directed to come back to the commission with an update requesting an action to forward recommendations to the city council for consideration.

The purpose of the Lobbyist Registration and Reporting Code (Sacramento City Code chapter 2.15; the “Sacramento Lobbyist Code”) is to maintain a fair and open decision-making process in city government and to ensure that the public and city officials have full knowledge of lobbying activities that have been brought to bear on any legislative or administrative action. To that end, the Sacramento Lobbyist Code states that-
· the people of Sacramento have the need and right to know the identity of lobbyists who

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File ID: 2022-01852 10/24/2022 Discussion Item 04.
attempt to influence the decisions of city government and the means employed by them to advance their interests;
· full disclosure of lobbying activities of such persons and the identity of their employers, will contribute to public confidence in the integrity of local government; and · full disclosure is also necessary to ensure that city officials are kept informed about the identity of persons whose interests the lobbyists represent. (Sac. City Code, § 2.15.020.) The attached letter is the Ad Hoc Committee’s recommendation for modernizing the Sacramento City’s Lobbying Ordinance.

Policy Considerations : The purpose of the Sacramento Ethics Commission is to review and consider complaints against elected and appointed city officials, as further described in Sacramento City Code section 2.112.030, to ensure those city officials are conforming their conduct to the city’s laws and policies. The commission may make recommendations to the City Council regarding the subjects of its purview as described in Sacramento City Code section 2.112.030 (A)(1).

Economic Impacts: Not applicable.

Environment Considerations: Not applicable.

Sustainability: Not applicable.

Commission/Committee Action: Not applicable.

Rationale for Recommendation: Not applicable.

Financial Considerations: Not applicable.

Local Business Enterprise (LBE): Not applicable.

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Sacramento City Code
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Title 2 ADMINISTRATION AND PERSONNEL
Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE Article I. Findings and Purpose

2.15.010 Title.

This chapter shall be known as the city of Sacramento Lobbyist Registration and Reporting Code, hereafter “the lobbyist code.” (Ord. 2003-034 § 1)

2.15.020 Findings and declarations.

The city council of the city of Sacramento finds and declares as follows:

A. The people of Sacramento have the need and right to know the identity of lobbyists who attempt to influence the decisions of city government and the means employed by them to advance their interests; and B. Full disclosure of lobbying activities of such persons and the identity of their employers, will contribute to public confidence in the integrity of local government; and C. Full disclosure is also necessary to ensure that city officials are kept informed about the identity of persons whose interests the lobbyists represent. (Ord. 2003-034 § 1)

2.15.030 Purpose.

The purpose of this chapter is to maintain a fair and open decision-making process in city government and to ensure that the public and city officials have full knowledge of lobbying activities that have been brought to bear on any legislative or administrative action. (Ord. 2003-034 § 1)

Article II. Interpretation and Definitions

2.15.040 Interpretation.

Unless the term is specifically defined in this lobbyist code or the contrary is stated or clearly appears from the context, the definitions set forth in Government Code Sections 81000, et seq., shall govern the interpretation of this chapter. Any term herein expressed in the plural may also apply to the singular. (Ord. 2003-034 § 1)

2.15.050 Definitions.

The following definitions apply in this chapter:
“Activity expense” means any payment made by a lobbyist to or directly benefiting any city official, city official-elect or member of their immediate family. Activity expenses include gifts, honoraria, consulting fees, salaries and any other form of compensation, but do not include campaign contributions. “Administrative action” means the proposal, drafting, development, consideration, advocacy, or recommendation of any rule, regulation, agreement or contract, permit, license or hiring action. “City official” means any person who participates in the consideration of any legislative or administrative action other than in a purely clerical, secretarial, or ministerial capacity. City official includes the mayor and mayor-elect; any councilmember and councilmember-elect; any member of a city board, committee, or commission; any city employee; any city representative to any joint powers authority to which the city is a party; and any consultant to the city.
“Consultant” means an individual who, pursuant to a contract with the city:

A. Makes a governmental decision whether to:

1. Approve a rate, rule, or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the city to enter into, modify, or renew a contract provided it is the type of contract which requires city approval;

5. Grant city approval to a contract which requires city approval and in which the city is a party or to the specifications or scope of work for such a contract;

6. Grant city approval to a plan, design, report, study or similar item;

7. Adopt or grant city approval of policies, standards or guidelines for the city, or for any subdivision thereof.

B. Serves in a staff capacity with the city and in that capacity performs the same or substantially all the same duties for the city that would otherwise be performed by an individual holding a position specified in the city’s conflict of interest code.
“Client” means a person who is represented by a lobbyist. “Compensation” means, but is not limited to, money of any denomination or origin; goods or services or anything of value, delivered, or rendered; or promises to perform or provide services or contractual arrangements or awards.
“Gift” means gift as defined in the California Political Reform Act, Government Code section § 81000, et seq., as amended from time to time.
“Influence” or “influencing” means the purposeful communication, either directly or through agents, promoting, supporting, modifying, opposing, causing the delay or abandonment of conduct, or otherwise intentionally affecting the behavior of a city of Sacramento official or official-elect, by any means, including, but not limited to, providing or using persuasion, information, incentives, statistics, studies or analyses; excepted from this definition is communication made as a part of a noticed governmental public meeting. “Legislative action” means the drafting, introduction, consideration, modification, enactment or defeat of any motion, resolution, ordinance, amendment thereto, report, nomination, or other action of the mayor, city council, any committee of the city council, any entity for which the city council is the governing body, any joint powers authority of which the city is a party, or any city board, commission, or committee. “Lobbying” is the influencing or attempting to influence a legislative or administrative action of the city of Sacramento.
“Lobbyist”, unless exempt under subsection D hereunder, means:

B. Business or Organization Lobbyist. Any business or organization, whose owners, officers, or employees carry out lobbying on its behalf, in an aggregate amount of 100 hours or more within any three- month period, whether or not such officers or employees are specifically compensated to engage in lobbying; provided that the activities of officers shall be considered lobbying only if those officers receive compensation by the business or organization beyond reimbursement for their reasonable, travel, meals or incidental expenses; or
C. Expenditure Lobbyist. A person who makes payments or incurs expenditures of $5,000 or more during any calendar year in connection with carrying out public relations, advertising or similar activities with the intent of soliciting or urging, directly or indirectly, other persons to communicate directly with any city official in order to attempt to influence legislative or administrative action. The $5,000 threshold does not include:

1. Compensation paid to contract lobbyists or employees for lobbying; or

2. Dues payments, donations, or other economic consideration paid to an organization, regardless of whether the dues payments, donations or other economic consideration are used in whole or in part to lobby.

D. Exemptions to “lobbyist” are:

1. Any public official acting in their official capacity or acting within the scope of their employment or appointment;

2. The media, when limiting its action to the ordinary course of news gathering or editorial activity, as carried out by members of the press. “Media” means newspapers or any other published periodical, radio or television station or network or information published on the Internet. This exemption also applies to neighborhood newsletters, flyers, or gazettes;

3. Persons reimbursed for only their reasonable travel, meals or incidental expenses, including but not limited to, uncompensated members or directors of non- profit organizations such as chambers of commerce;

4. Persons whose communications regarding any legislative or administrative action are limited to appearing or submitting testimony at any public meeting held by the city or any of its agencies, offices, or departments, as long as the communications are public records available for public review. Notwithstanding the foregoing, persons who otherwise qualify as lobbyists must register and disclose their lobbying activities directed toward city officials, in the same manner and to the same extent such registration and disclosure is required of all other lobbyists;

5. Persons submitting bids or responding to requests for proposals, provided the provision of such information is limited to direct conversation or correspondence with the official or department specifically designated to receive such information;

7. Persons whose communications relate to:
a. The establishment, amendment, administration, implementation or interpretation of a collective bargaining agreement or a memorandum of understanding between the city and a recognized employee association.
b. Management decisions as to the working conditions of represented employees that clearly relate to the terms of a collective bargaining agreement or memorandum of understanding between the city and a recognized employee association.
c. Proceedings before the City of Sacramento Civil Service Board. “Organization” means any person that is not an individual.
“Person” means any individual, domestic or foreign corporation, for-profit or non- profit entity, firm, association, syndicate, union, chamber of commerce, joint-stock company, partnership of any kind, limited liability company, common-law trust, society, or any other group of persons acting in concert. (Ord. 2021-0001 § 1; Ord. 2003-034 § 1)

Article III. Registration of Lobbyists

2.15.060 Registration.

Lobbyists shall register with the city clerk within 15 calendar days after qualifying as a lobbyist under section 2.15.050. (Ord. 2021-0001 § 2; Ord. 2003-034 § 1)

2.15.070 Annual registration renewal.

A lobbyist shall renew their registration by January 15 of each year unless they have terminated their status as a lobbyist pursuant to section 2.15.080 by such date. (Ord. 2021-0001 § 3; Ord. 2003-034 § 1)

2.15.080 Termination of lobbyist status.

After initial registration, annual registration renewals and quarterly registration reports are not required if a termination report attesting to the termination of lobbying services within the city has been filed with the city clerk. (Ord. 2021-0001 § 4; Ord. 2003-034 § 1)

2.15.090 Active status.

All registrations, renewals and terminations will be deemed filed on the date received by the city clerk. A lobbyist shall be deemed active for the duration of the year of registration ending December 31, unless a declaration attesting to termination of lobbying services within the city is filed. (Ord. 2003-034 § 1)

2.15.100 Penalty for failing to register or report.

Any person subject to the registration and reporting requirements of this chapter who fails to register or report is subject to a non-registration or late-reporting penalty of $25 per day, up to a maximum of $500, from the date of written notification of non-compliance until the date of compliance. (Ord. 2021-0001 § 5; Ord. 2003- 034 § 1)

2.15.110 Required registration information.

Registration statements shall contain the information set forth in Section 2.15.120. (Ord. 2003-034 § 1)

Article IV. Disclosure of Lobbying Activities

2.15.120 Disclosure.

Any business or organization registering under this chapter shall also briefly describe the nature of its business or organization. In addition to this information, the report shall contain the following:

A. Contract Lobbyist. The name, business address, telephone number, and email address of each client, the nature of each client’s business and the item of legislative or administrative action the lobbyist is seeking to influence on behalf of the client; and the name of each person employed or retained by the lobbyist to lobby on behalf of each client.

B. Business or Organization Lobbyist. The names of owners, officers or employees conducting lobbying activities and the item of legislative or administrative action the lobbyist is seeking to influence.

C. Expenditure Lobbyists. The item of legislative or administrative action the lobbyist is seeking to influence.

D. All campaign contributions by a lobbyist or a client at the lobbyist’s behest, to any city official, identified by name and by office, to a controlled committee, office holder’s fund or legal expense fund, given personally or through an intermediary, totaling $100 or more, made during the calendar quarter.

E. Payment received by the reporting lobbyist for services as a consultant or in any other capacity for services rendered to a city agency, any city official or their controlled committees, any officeholder committee, or ballot measure committee. The dates of payment and name of each payer shall be included.

2.15.130 Subsequent disclosures.

For each calendar quarter following the quarter in which the lobbyist was required to register, the lobbyist must file a quarterly report with the city clerk not later than 15 calendar days after the end of the qualifying quarter whether or not any lobbying activities have occurred during such period. Reporting must be completed electronically according to the process established by the city clerk. Each quarterly report shall contain the same information as required to be disclosed in the initial registration, for those activities occurring in that quarter. If a lobbyist has terminated all lobbying activities during such quarter, the lobbyist may file a declaration of termination with the quarterly report. The final quarterly report shall include disclosure of any lobbying activities during the quarter of termination. (Ord. 2021-0001 § 7; Ord. 2003-034 § 1)

2.15.140 Quarterly reports.

Quarterly reports are to be filed by April 15, July 15, October 15, and January 15, for the prior calendar quarter, and are delinquent thereafter. Reporting must be completed electronically according to the process established by the city clerk. (Ord. 2021-0001 § 8; Ord. 2003-034 § 1)

2.15.150 Records retention.

Copies of the records pertaining to the above-required reports shall be preserved by the lobbyist for inspection and audit for a period of four years from date of production. (Ord. 2003-034 § 1)

2.15.160 Lobbyist identification.

When appearing in a lobbying capacity at a public meeting of the city council or other city board, commission, or committee, a contract lobbyist shall identify themselves and the client on whose behalf they are appearing, and a business or organization lobbyist shall identify themselves and the business or organization they represent. (Ord. 2021-0001 § 9; Ord. 2003-034 § 1)

Article V. Prohibitions

2.15.170 Prohibitions.

It shall be unlawful for any lobbyist to commit any one of the following acts:

A. Deception. Deceiving or attempting to deceive any city official with regard to any material fact pertaining to any pending or proposed legislative or administrative action.

C. Fictitious Persons. Contacting any officer of the city in the name of any non-existent person or in the name of any existing person, except with the consent of such existing person.

D. Indirect Violations. Attempting to evade the requirements of this ordinance through indirect efforts or through the use of agents, associates, intermediaries or employees.

E. Creation of Obligations. Performing or sponsoring any act with the purpose and intent of placing any city official under personal obligation to the lobbyist. (Ord. 2003-034 § 1)

Article VI. Responsibility

2.15.180 The city clerk.

The city clerk shall:

A. Oversee compliance with this chapter, including creation of all forms and explanatory materials.

B. Maintain an electronic filing system for submission of registrations and reports, and publish them on the City’s website.

Accept all required filings under articles III and IV of this chapter. (Ord. 2021-0001 § 10; Ord. 2003-034 § 1)

Article VII. Enforcement

2.15.190 Criminal penalties.

Any person who knowingly or willfully violates or causes any other person to violate any provision of Article III, IV or V of this chapter is guilty of a misdemeanor. Any person who knowingly or willfully causes any other person to violate any provision of this chapter is guilty of a misdemeanor. (Ord. 2003-034 § 1)

2.15.200 Injunction.

The city attorney may seek injunctive relief in the courts to enjoin violations of or to compel compliance with the provisions of this chapter. (Ord. 2003-034 § 1)

2.15.210 Practice restrictions.

No person convicted of a violation of this chapter may act as a lobbyist or otherwise attempt to influence municipal legislation for compensation for one year after such conviction. (Ord. 2003-034 § 1)

2.15.220 Limitation of actions.

Prosecution for violation of any provision of this chapter shall be commenced within four years after the date on which the violation occurred. (Ord. 2003-034 § 1)

2.15.230 Cost of litigation.

The court may award costs of litigation including reasonable attorney’s fees to the prevailing party in any action to compel compliance with the provisions of this chapter. (Ord. 2003-034 § 1)

Article VIII. Effective Date

2.15.240 Effective date.

The registration, reporting and other requirements of this chapter shall apply to lobbying occurring on or after October 1, 2003. Lobbying that occurs prior to October 1, 2003, and payment for lobbying services rendered prior to October 1, 2003, whether made prior to or after October 1, 2003, shall not be considered for purposes of the registration, reporting and other requirements of this chapter. (Ord. 2003-034 § 1)

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October 12, 2022

Sacramento City Council Sacramento
City Hall 915 I St.

Sacramento, CA 95814

RE: Modernizing Sacramento City’s Lobbying Ordinance

Dear Mayor Steinberg and Members of the City Council:

In 2003, the City of Sacramento adopted a Lobbying Ordinance (2.15.020) to provide more transparent information on how interest groups attempt to influence policy in our City. It begins by powerfully declaring:

“A. The people of Sacramento have the need and right to know the identity of lobbyists who attempt to influence the decisions of city government and the means employed by them to advance their interests; and
B. Full disclosure of lobbying activities of such persons and the identity of their employers, will contribute to public confidence in the integrity of local government; and C. Full disclosure is also necessary to ensure that city officials are kept informed about the identity of persons whose interests the lobbyists represent.”

These words are as true today as they were in 2003. However, in those intervening 19 years, technology, the prevalence of money in politics, and our City have all changed dramatically. Yet, the Lobbying Ordinance has never been amended. It is past time for the Ordinance to be modernized in order to provide the same level of “sunshine” over lobbying activities as our peer jurisdictions, and to reflect government transparency as a core value of our City.

At the suggestion of good governance groups, including California Common Cause and the League of Women Voters of Sacramento County, the Sacramento Ethics Commission voted in 2021 to review the City’s Lobbying Ordinance. In May 2022, the Ethics Commission established a temporary Ad Hoc Committee to lead this review, consisting of Commissioners Liz Gomez and Linda Ng, Paula Lee and Charlene Jones with the League of Women Voters of Sacramento County, and Nicolas Heidorn with the Sacramento Policy Analysis Network.

After reviewing how well the Ordinance achieves the City’s stated goals and comparing Sacramento’s Ordinance with state law and other California city lobbying ordinances, the Sacramento Ethics Commission is pleased to recommend several amendments to update and improve the Ordinance. If adopted, these changes will provide greater transparency around lobbying and bring Sacramento more in-line with the reformist practices of peer municipalities.

We respectfully urge the City Council to refer these recommendations to its Law & Legislation Committee for review, and request the Committee bring forward draft ordinance language for the Council to consider and adopt. Below are proposed changes to the current Lobbying Ordinance.

Lobbyist registration thresholds should provide sufficient disclosure of activity to the public

Recommendation #1: Change lobbying registration thresholds to:
● In-house lobbyist to 15 hours per 3 month period
● Contract Lobbyist to $1,500 per 3 month period

Description of Recommendation #1: Sacramento has fallen far behind other California cities in lobbying disclosure and regulations. The disclosure requirements of the Lobbying Ordinance only kick in once a person has engaged in enough compensated activity to qualify as lobbying. However, the Ordinance’s lobbyist registration thresholds are far below that of peer jurisdictions, making it so that much of the lobbying activity, including potentially significant lobbying spending, is not transparent and thus not subject to public scrutiny. Mindful of the City’s commitment to build public confidence in the integrity of local government, the lobbyist registration thresholds should be adjusted to be on par with peer jurisdictions.

SMC 2.15.050 sets high thresholds for who is required to register as a lobbyist, particularly for an in-house (“Business or Organization”) lobbyist, in which means that far fewer people and firms are required to register and report lobbying activities in Sacramento than in other cities. For example, to qualify as an in- house lobbyist under the Ordinance, an employee would have to spend more than 100 hours in a 3-month period engaged in lobbying activities. That is equivalent to nearly two-and-a-half weeks of lobbying full- time, an improbably high standard to achieve. By contrast, thresholds are much lower in Long Beach (50 hours), Los Angeles (30 hours), and San Jose (10 hours). San Francisco, San Diego, and Oakland use a stricter “number of contacts” basis to trigger lobbying registration, rather than an hourly approach. We recommend that the threshold be set at 15 hours in a 3 month period, which distinguishes between businesses that have incidental contact with City Hall and those that are more actively lobbying for a particular city action.

The contract lobbyist threshold of a $3,200 contract, while matching Long Beach’s, is also one of the highest in the state. Berkeley, Oakland, San Jose, and Anaheim, for example, all set their threshold at $1,000 or lower, and other major cities like Fresno and San Diego have no lower limit trigger at all. We recommend that the threshold be set at $1,500 per 3 month period.

Disclosure of information in lobbying reports (by what entities, and frequency of reporting) should support transparency.

Recommendation #2: Similar to state reporting requirements, require City quarterly lobbying reports to indicate:
● How much lobbying firms are receiving from clients and how much lobbyist employers are paying lobbying firms.
● Any gifts, campaign contributions, and behested payments made to city officials by a lobbying firm, lobbyist, or lobbyist employer.

Description of Recommendation #2: Full disclosure of lobbying activities contributes to public confidence in the integrity of local government. However, compared with the state and many other cities’ reporting requirements, the City’s quarterly lobbyist filings provide little context of what type of lobbying activity is taking place in the City. The Ordinance requires disclosure of items that an interest group is lobbied on. However, the amount spent on that lobbying activity is not disclosed.

The current Ordinance does require that lobbyists disclose their campaign contributions to elected officials and any contracts with elected officials, but omits disclosure of behested payments or even direct gifts by lobbyist employers to elected officials. In addition, a lobbyist employer’s campaign contributions are not reportable on lobbying reports unless they were made at the lobbyist’s behest.

We recommend the Ordinance be amended to require the amount spent on lobbying (either the lobbying contract amount or value of an in-house employee’s time) be reported, as it is on State lobbying filings. The magnitude of lobbying spending, which can indicate how much pressure is being brought to bear on elected officials, is itself important for transparency and accountability. We also recommend the lobbying report include disclosure of gifts, campaign contributions, and behested payments made to elected officials by the lobbyist, lobbying firm, or lobbyist employer. Whenever an lobbying entity is providing a benefit to an elected official, that benefit should be disclosed. These disclosures are already required under state law, but the information is disaggregated and filed on different schedules, making it difficult to get a true picture of a lobbying firm or employer’s lobbying activity. Each report should be a full snapshot of an entity’s lobbying activity for that quarter; the state takes a similar view, requiring gifts and campaign contributions be reported in the same quarterly reports along with direct lobbying expenditures.

Make relevant data more accessible to the public and media online.

Recommendation #3: Improve the City’s online lobbying data collection and disclosure system to permit:
● Searching lobbying filings by lobbyist employer
● Searching by item being lobbied on (e.g., if there is a permit # or resolution #) ● Allow system to filter and sort reports by the amount of money spent lobbying (e.g., permit the system to only display lobbyist employers who spent more than $10,000 lobbying in a year)

Description of Recommendation #3: The Ethics Commission applauds the substantial improvements to the City’s Lobbying webpage and online disclosure system that were recently adopted by the City Clerk.

The new page is significantly more transparent and makes large strides towards making this data more readily available to the public. As of July 2022, the City’s lobbying webpage now includes a link to current registered lobbying firms and a link to a portal where the public can find firms’ quarterly reports. Prior to this change, it was very difficult for a member of the public to find these reports in the City’s general data portal.

Striving to make this information easy to read and easy to find by the public and press should be a continuous process and is vital to the success of the Lobbying Ordinance; it does not matter who files reports and what is contained in those reports if no one can find them or is aware of their existence.

As the new Lobbying portal is updated, we recommend the City consider a number of improvements on system usability. Most significantly, the system currently only enables users to search for lobbying information by lobbying firm. The system should also enable the public to search and find lobbying information based on the individual lobbyist, lobbyist employer, and items or topics being lobbed. It would also be helpful if there were other search filters to display how much lobbyist employers spend in a quarter.

Finally, the lobbying information database should be easier to find on the main webpage. Currently, the link Lobbying Employer
Reporting Category
California (Form 635 & 640) Sacramento
Lobbyist Employer -
Partners/Owners
Yes Yes
Lobbying Firms Hired Yes Yes
Bills or Agency Action lobbied
on
Yes Yes
Payments Made to Contract
Lobbyists
Yes No
Value of In-House Lobbyist’s
Time
Yes No
Other payments to influence
(advertising, consulting,
overhead)
Yes - total amount reported +
itemized for payments over
$2500.

No (except for $5k+
expenditure lobbying)
Gifts Made to Officials (plus
honoraria, salaries, etc.)
Yes No
$100+ Campaign
Contributions
Yes Yes, if at behest of lobbyist
Behested payments made No No
is located at the bottom of the page after substantial text; the City should explore ways to make this information easier to find for the public.

Lobbyist activities that create a risk of undue influence, or appearance thereof, should be regulated.

Recommendation #4: Follow state law where lobbyists and lobbying firms are limited to gifts of less than $10/month to elected officials, and are prohibited from directly contributing to campaigns of elected officials they lobby.

Description of Recommendation 4: The City must seek to ensure public trust in policymakers and political institutions by upholding ethical conduct by those under the purview of the Ethics Commission, which includes regulating lobbying practices. When lobbyists give direct gifts or maxed out campaign contributions to elected officials, it can create the appearance, or the risk, that these gifts or contributions are being made in exchange for promises to vote certain ways on permits or proposed legislation. For this reason, the state and many jurisdictions bar or restrict this practice.

Unlike the state and many peer jurisdiction ordinances, Sacramento’s Lobbying Ordinance imposes no upper limit on the amount registered lobbyists can gift to elected officials. That means lobbyists can give up to the generally applicable $520 limit that applies to all public officials, regardless of the source of the cotnribution. By comparison, at the state level, lobbyists are limited to gifts of less than $10/month to elected officials and are prohibited from directly contributing to the campaigns of state elected officials they lobby. Many cities go even further. For example, San Francisco prohibits lobbyists from giving gifts of any value or bundling campaign contributions. To avoid the risk or appearance of a quid pro quo, we recommend Sacramento exactly follow the state’s rules limiting gifts from lobbyists and lobbying firms to $10/month and prohibit lobbyist and lobbying firms from giving campaign contributions.

Consistent with the Ethics Commission’s scope and mission, clarify the Ethics Commission’s authority to enforce the Lobbying Ordinance.

Recommendation #5: Amend the City Municipal Code to expressly extend the Ethics Commission’s enforcement authority to include lobbyists, lobbying firms, and lobbyist employers. Amend the Lobbying Ordinance to reference the availability of these administrative penalties.

Description of recommendation 5: An overarching purpose of the Ethics Commission is to ensure ethics laws are followed and that City officials foster a culture of ethical decision-making. The Commission’s subject matter jurisdictions expressly include the City’s lobbying ordinance (SMC 2.112.030(A)(1)(d)), including the power to “review, investigate, and consider complaints alleging violations of” that ordinance.

However, due to an oversight, SMC 2.112.030(B) only gives the Commission the ability to enforce ethics laws against certain city officers, candidates, and campaign committees. It does not expressly mention lobbyists, lobbying firms, or lobbyist employers. We recommend this be amended to make clear the Commission’s enforcement powers extend to such lobbying entities. It would be illogical for the Commission not to have such authority. After all, the Ethics Commission is charged with enforcing the Ordinance, but other than lobbyists/lobbying firms there is no other entity regulated by the Ordinance.

Moreover, administrative enforcement of the Lobbying Ordinance is more likely to occur than, and is preferable to, criminal enforcement of reporting violations. Similarly, Article VII of the Lobbying Ordinance (2.15.190) only provides for criminal penalties or court injunction to punish violations of the law. Article VII should also be amended to reflect administrative penalties enforced by the Commission are a possibility.

Thank you for the City Council’s attention to this significant open governance issue. For the Council’s convenience, we have attached a chart of other cities’ lobbying practices, compiled in 2019, and updated in 2022. We look forward to engaging with the Law & Legislation Committee on this soon.

Sincerely,

Sacramento City Ethics Commission

Attachment A

Jurisdiction Contract Lobbyist Expenditure Lobbyist In-House Lobbyist

Person paid $3,200+ in 3 Person paid $5,000+ in 1 Person lobbying for 50+ hours in 3 Long Beach months to lobby year for public relations months on behalf of their employer LBMC 2.08.020(K) LBMC 2.08.020(K) LBMC 2.08.020(K)

Oakland Person paid $1,000+ in 1
month to lobby
Person whose “duties” include
lobbying
OMC Sec. 3.20.030(D)

OMC Sec.3.20.030(D)
Sacramento Person paid $3,200+ in 3 Person paid $5,000+ in 3 Person lobbies for 100+ hours in 3 months to lobby months for public
relations
months on behalf of their employer

SMC Sec. 2.15.050 SMC Sec. 2.15.050 SMC Sec. 2.15.050 Person paid any amount
to lobby
SDMC 27.4002
Person paid $5,000+ in 3
months for public relations
Person makes 10+ lobbying contacts
in 2 months on behalf of their
employer
San Diego
SDMC 27.4002
SDMC 27.4002

San
Francisco

Person makes 1+
lobbying contacts in 1
month on behalf of their
employer or makes 1+
contact on behalf of a
client
SF C&G 2.105
Person paid $2,500+ in 1
month to lobby

SF C&G Sec. 2.105
Person makes 5+ lobbying contacts
in 1 month on behalf of their
employer unless owning 20%+ of
the entity receives $300+ makes 5+
lobbying contacts in 1 month on
behalf of their employer
SF C&G Sec. 2.105

San Jose

Person paid $1,000+ in 3
months to lobby
SJMC Sec. 12.12.18(A)
Person paid $5,000+ in 1
year for public relations
SJMC Sec. 2.12.12(C)
Person lobbies for 10+ hours in 1
year
on behalf of their employer
SJMC Sec. 2.12.12(B)

Memorandum

To: Mindy Cuppy
From: Whitney Barazoto
Date: February 10, 2023
Subject: Sacramento Lobbyist Code – Review Staff Report File ID 2022-01852 (10/24/22)

Per your request, below are my comments about the staff report following my review.

Overall, the information in the staff report is generally accurate in describing the main lobbying concepts and comparisons to other jurisdictions. However, there was one item in the table that looked erroneous:

1. In the table on Attachment A , the San Francisco row at the In-House Lobbyist column states the following:
“Person makes 5+ lobbying contacts in 1 month on behalf of their employer unless owning 20%+ of the entity receives $300+ makes 5+ lobbying contacts in 1 month on behalf of their employer”

This is confusing, and I don’t see any reference to “receives $300+” anywhere in existing SF statutes or regulations; this is something I would check with the author about. In addition, the last part of this clause is repetitive . For both of these reasons, I would suggest deleting the entire part highlighted above in grey.

Further, like San Francisco, San Jose’s law also allows an exception for business owners with over 50% ownership interest, so perhaps you want to either leave off the 20% ownership exception in this column for San Francisco or add the same exception to the San Jose description for In-House Lobbyist to be consistent. There are many exceptions to lobbyist definitions across cities, and, while the business owner exception is not as common in all lobbyist ordinances, it’s also not something that is specifically relevant to the main amendments suggested in the proposal and could spark conversation unrelated to the suggested amendments, so my suggestion would be to remove it from the table.

In addition, there were a few places that could use some substantive clarification:

1. In the S an Francisco row for “Contract Lobbyist ,” I suggest distinguishing the “Contract Lobbyist” criteria from the “In -House Lobbyist” criteria by inserting “lobbyist services” after “employer or client.” SF’s definitions are a little different in that it uses the term “contact” (no “r”) to define a lobbyist, so this additional description will help to clarify the difference without going into un necessary detail about their laws . I also suggest deleting the repetitive clause after that so that the SF “Contract Lobbyist” criteria reads:
“Person makes 1+ lobbying contacts in 1 month on behalf of their employer or client for lobbyist services”

2 2. Looking at the table as a whole, and glancing down the “Expenditure Lobbyist” column, I suggest adding a bit more detail to the first example so it’s more clear to readers what this column is about in relation to the other two columns. Here’s what I recommend in that column for Long Beach, so it sets the stage for the other rows below it:
“Person paid $5,000+ in 1 year for public relations/advertisements with intent to solicit/urge others to influence legislative or administrative action”

Finally, two other ethics commissions , Long Beach and Los Angeles, are currently working to amend their lobbying ordinances, which may provide helpful background as the Sacramento EC carries this forward to Council.

1. The Long Beach Ethics Commission is drafting changes to its Lobbying Ordinance to reduce thresholds as follows:
a. Contract Lobbyist: reducing the threshold of $3,200+ in 3 months to $1,000 in 3 months.
b. Expenditure Lobbyist: reducing the $5,000 in 1 year threshold to $2,000 in 1 year. c. In-House Lobbyist: reduci ng the 50+ hours in 3 months threshold, and adding a number-of-contacts threshold, so lobbyist registration and reporting triggers at either 10+ hours OR 3+ contacts.

Because Long Beach is cited in the text in the middle of page 2 of the letter as the other highest threshold in the state, I think these currently proposed changes are important to note, even if just a footnote in the report. Also , Long Beach’s Lobbyist Ordinance was enacted in 2010 and appears to be identical in language to Sacramento’s law as it was adopted in 2003 ; thus, if they modeled their law after yours, they too see the need to reduce the same thresholds that your EC is recommending to amend. They also added registration fee language to the ordinance in 2011, FYI.

2. Los Angeles is not included in the table, but it’s important to note that the LA Ethics Commission also has proposed changes to its lobbying ordinance that result in an annual dollar amount just under what the Sacramento EC recommends . Currently (and since 2007), they define a lobbyist by the 30+ hours in 3 months that includes at least one communication with a City employee; however, due to difficulty enforcing (ie. tracking/proving how a lobbyist’s time was spent) and that current law fails to capture big money spent for small amounts of time, the LA EC now is proposing to return to a compensation-based definition as was in place there until 2007. It recommends defining lobbyist as an individual who becomes entitled to receive $5,000+ per year for lobbying on behalf of another person.

Let me know if you would like further information on these concurrent proposals, or if you wish to discuss any of the above.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 1/10 Sacramento, California City Code
Title 2 ADMINISTRATION AND PERSONNEL
Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST

REGISTRATION AND REPORTING CODE
Article I. Findings and Purpose

2.15.010 Title.

2.15.020 Findings and declarations.

2.15.030 Purpose.

Article II. Interpretation and Definitions

2.15.040 Interpretation.

2.15.050 Definitions.

Article III. Registration of Lobbyists

2.15.060 Registration.

2.15.070 Annual registration renewal.

2.15.080 Termination of lobbyist status.

2.15.090 Active status.

2.15.100 Penalty for failing to register or report.

2.15.110 Required registration information.

Article IV. Disclosure of Lobbying Activities

2.15.120 Disclosure.

2.15.130 Subsequent disclosures.

2.15.140 Quarterly reports.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 2/10

2.15.150 Records retention.

2.15.160 Lobbyist identification.

Article V. Prohibitions

2.15.170 Prohibitions.

Article VI. Responsibility

2.15.180 The city clerk.

Article VII. Enforcement

2.15.190 Criminal penalties.

2.15.200 Injunction.

2.15.210 Practice restrictions.

2.15.220 Limitation of actions.

2.15.230 Cost of litigation.

Article VIII. Effective Date

2.15.240 Effective date.

Article I. Findings and Purpose

2.15.010 Title.

This chapter shall be known as the city of Sacramento Lobbyist Registration and Reporting Code, hereafter “the lobbyist code.” (Ord. 2003-034 § 1)

2.15.020 Findings and declarations.

The city council of the city of Sacramento finds and declares as follows:

A. The people of Sacramento have the need and right to know the identity of lobbyists who attempt to influence the decisions of city government and the means employed by them to advance their interests; and
B. Full disclosure of lobbying activities of such persons and the identity of their employers, will contribute to public confidence in the integrity of local government; and 3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 3/10 C. Full disclosure is also necessary to ensure that city officials are kept informed about the identity of persons whose interests the lobbyists represent. (Ord. 2003-034 § 1)

2.15.030 Purpose.

2.15.040 Interpretation.

2.15.050 Definitions.

The following definitions apply in this chapter:
“Activity expense” means any payment made by a lobbyist to or directly benefiting any city official, city official-elect or member of their immediate family. Activity expenses include gifts, honoraria, consulting fees, salaries and any other form of compensation, but do not include campaign contributions. “Administrative action” means the proposal, drafting, development, consideration, advocacy, or recommendation of any rule, regulation, agreement or contract, permit, license or hiring action. “City official” means any person who participates in the consideration of any legislative or administrative action other than in a purely clerical, secretarial, or ministerial capacity. City official includes the mayor and mayor-elect; any councilmember and councilmember-elect; any member of a city board, committee, or commission; any city employee; any city representative to any joint powers authority to which the city is a party; and any consultant to the city. “Consultant” means an individual who, pursuant to a contract with the city:

A. Makes a governmental decision whether to:

1. Approve a rate, rule, or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the city to enter into, modify, or renew a contract provided it is the type of contract which requires city approval;
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 4/10

5. Grant city approval to a contract which requires city approval and in which the city is a party or to the specifications or scope of work for such a contract;

6. Grant city approval to a plan, design, report, study or similar item;

7. Adopt or grant city approval of policies, standards or guidelines for the city, or for any subdivision thereof.

B. Serves in a staff capacity with the city and in that capacity performs the same or substantially all the same duties for the city that would otherwise be performed by an individual holding a position specified in the city’s conflict of interest code.
“Client” means a person who is represented by a lobbyist. “Compensation” means, but is not limited to, money of any denomination or origin; goods or services or anything of value, delivered, or rendered; or promises to perform or provide services or contractual arrangements or awards.
“Gift” means gift as defined in the California Political Reform Act, Government Code section § 81000, et seq., as amended from time to time.
“Influence” or “influencing” means the purposeful communication, either directly or through agents, promoting, supporting, modifying, opposing, causing the delay or abandonment of conduct, or otherwise intentionally affecting the behavior of a city of Sacramento official or official-elect, by any means, including, but not limited to, providing or using persuasion, information, incentives, statistics, studies or analyses; excepted from this definition is communication made as a part of a noticed governmental public meeting.
“Legislative action” means the drafting, introduction, consideration, modification, enactment or defeat of any motion, resolution, ordinance, amendment thereto, report, nomination, or other action of the mayor, city council, any committee of the city council, any entity for which the city council is the governing body, any joint powers authority of which the city is a party, or any city board, commission, or committee.
“Lobbying” is the influencing or attempting to influence a legislative or administrative action of the city of Sacramento.
“Lobbyist”, unless exempt under subsection D hereunder, means:

A. Contract Lobbyist. A person who engages in lobbying on behalf of one or more clients (acting individually or through agents, associates, employees or contractors) and who has received or has entered into an agreement for compensation of $3,200 or more for engaging in lobbying during any consecutive three-month period.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 5/10 B. Business or Organization Lobbyist. Any business or organization, whose owners, officers, or employees carry out lobbying on its behalf, in an aggregate amount of 100 hours or more within any three-month period, whether or not such officers or employees are specifically compensated to engage in lobbying; provided that the activities of officers shall be considered lobbying only if those officers receive compensation by the business or organization beyond reimbursement for their reasonable, travel, meals or incidental expenses; or
C. Expenditure Lobbyist. A person who makes payments or incurs expenditures of $5,000 or more during any calendar year in connection with carrying out public relations, advertising or similar activities with the intent of soliciting or urging, directly or indirectly, other persons to communicate directly with any city official in order to attempt to influence legislative or administrative action. The $5,000 threshold does not include:

1. Compensation paid to contract lobbyists or employees for lobbying; or

D. Exemptions to “lobbyist” are:

1. Any public official acting in their official capacity or acting within the scope of their employment or appointment;

Notwithstanding the foregoing, persons who otherwise qualify as lobbyists must register and disclose their lobbying activities directed toward city officials, in the same manner and to the same extent such registration and disclosure is required of all other lobbyists;

6. Persons providing oral or written information pursuant to a subpoena or otherwise compelled by law or regulation, or in response to an official request provided that the request and response thereto are public records available for public review;
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 6/10

2.15.060 Registration.

Lobbyists shall register with the city clerk within 15 calendar days after qualifying as a lobbyist under section 2.15.050. (Ord. 2021-0001 § 2; Ord. 2003-034 § 1)

2.15.070 Annual registration renewal.

2.15.080 Termination of lobbyist status.

2.15.090 Active status.

All registrations, renewals and terminations will be deemed filed on the date received by the city clerk.

A lobbyist shall be deemed active for the duration of the year of registration ending December 31, unless a declaration attesting to termination of lobbying services within the city is filed. (Ord. 2003-034 § 1)

2.15.100 Penalty for failing to register or report.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 7/10 Any person subject to the registration and reporting requirements of this chapter who fails to register or report is subject to a non-registration or late-reporting penalty of $25 per day, up to a maximum of $500, from the date of written notification of non-compliance until the date of compliance. (Ord. 2021- 0001 § 5; Ord. 2003-034 § 1)

2.15.110 Required registration information.

Registration statements shall contain the information set forth in Section 2.15.120. (Ord. 2003-034 § 1)
Article IV. Disclosure of Lobbying Activities

2.15.120 Disclosure.

The initial registration shall contain the name, primary contact, business address, telephone number, and email address of all persons required to register pursuant to this chapter, including the names of all owners of sole proprietorships and partnerships of fewer than 10 persons. If the registrant is a corporation, it shall also include the names of the president, secretary, chief financial officer, and agent for service of process, if any. Any business or organization registering under this chapter shall also briefly describe the nature of its business or organization. In addition to this information, the report shall contain the following:

C. Expenditure Lobbyists. The item of legislative or administrative action the lobbyist is seeking to influence.

F. The name, address, title, telephone number, and email address of the person responsible for preparing the report, together with that individual’s signature attesting to the authority of the signatory and the accuracy and truthfulness of the information submitted. (Ord. 2021-0001 § 6; Ord. 2003-034 § 1) 3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 8/10

2.15.130 Subsequent disclosures.

2.15.140 Quarterly reports.

2.15.150 Records retention.

Copies of the records pertaining to the above-required reports shall be preserved by the lobbyist for inspection and audit for a period of four years from date of production. (Ord. 2003-034 § 1)

2.15.160 Lobbyist identification.

2.15.170 Prohibitions.

It shall be unlawful for any lobbyist to commit any one of the following acts:

A. Deception. Deceiving or attempting to deceive any city official with regard to any material fact pertaining to any pending or proposed legislative or administrative action.

B. Unauthorized Communications. Sending or causing any communication to be sent to any city official in the name of any non-existent person or in the name of an existing person without the express or implied consent of such person.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 9/10 C. Fictitious Persons. Contacting any officer of the city in the name of any non-existent person or in the name of any existing person, except with the consent of such existing person.

D. Indirect Violations. Attempting to evade the requirements of this ordinance through indirect efforts or through the use of agents, associates, intermediaries or employees.

E. Creation of Obligations. Performing or sponsoring any act with the purpose and intent of placing any city official under personal obligation to the lobbyist. (Ord. 2003-034 § 1) Article VI. Responsibility

2.15.180 The city clerk.

The city clerk shall:

A. Oversee compliance with this chapter, including creation of all forms and explanatory materials.

B. Maintain an electronic filing system for submission of registrations and reports, and publish them on the City’s website.

Accept all required filings under articles III and IV of this chapter. (Ord. 2021-0001 § 10; Ord. 2003- 034 § 1)
Article VII. Enforcement

2.15.190 Criminal penalties.

2.15.200 Injunction.

The city attorney may seek injunctive relief in the courts to enjoin violations of or to compel compliance with the provisions of this chapter. (Ord. 2003-034 § 1)

2.15.210 Practice restrictions.

2.15.220 Limitation of actions.

Prosecution for violation of any provision of this chapter shall be commenced within four years after the date on which the violation occurred. (Ord. 2003-034 § 1)

2.15.230 Cost of litigation.
3/5/23, 11:36 AM Chapter 2.15 THE CITY OF SACRAMENTO LOBBYIST REGISTRATION AND REPORTING CODE https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_15?view=all 10/10 The court may award costs of litigation including reasonable attorney’s fees to the prevailing party in any action to compel compliance with the provisions of this chapter. (Ord. 2003-034 § 1) Article VIII. Effective Date

2.15.240 Effective date.

City Clerk: 916-808-7200
Published by Quality Code Publishing, Seattle, WA. By using this site, you agree to the terms of use. 4/28/23, 3:44 PM Chapter 2.112 ETHICS COMMISSION
https://library.qcode.us/lib/sacramento_ca/pub/city_code/item/title_2-chapter_2_112 1/1 Sacramento, California City Code
Title 2 ADMINISTRATION AND PERSONNEL
Chapter 2.112 ETHICS COMMISSION

2.112.010 Commission established.

2.112.020 Purpose of commission.

2.112.030 Powers and duties of commission.

2.112.040 Appointment of members and qualification.

2.112.050 Term of office—Vacancy.

2.112.060 Conflict of interest and financial disclosure statements.

2.112.070 Chairperson and organization of the commission.

2.112.080 Commission meetings.

2.112.090 Quorum—Voting.

2.112.100 Compensation.

2.112.110 General requirements.

Contact:

City Clerk: 916-808-7200
Published by Quality Code Publishing, Seattle, WA. By using this site, you agree to the terms of use.

Law and Legislation CommitteeMay 16, 2023

Law and Legislation Committee
May 16, 2023