ETHICS SAN MATEO
DEDICATED TO TRUTH, TRANSPARENCY AND ETHICAL CONDUCT IN CITY GOVERNMENT Ethics San Mateo - A California Nonprofit Public Benefit Corporation www.EthicsSanMateo.com
July 28, 2025
Honorable Mayor and Council Members,
I am writing on behalf of Ethics San Mateo, a California Nonprofit Public Benefit Corporation, regarding the July 28, 2025, Special City Council Meeting, Agenda Item #6, City Council Rules and Procedures – Updates.
Ethics San Mateo wants to recognize the efforts by the City Council and Staff which has resulted in improvements to how our city leaders govern themselves. Adopting a set of Rules that include a Code of Conduct which is enforceable and contains consequences for violations is a long-sought accomplishment. This will be the legacy of this city council.
We would like to comment on two items, the staff discussion about Public Participation and the rules regarding Conflicts of Interest rules which were not changed in the current document.
Public Participation – Chapter 7:
Ethics San Mateo recognizes that there have been incidents where Public Comment had become quite lengthy and repetitive in content. Staff is requesting clarifications regarding Organized Presentations, along with some recommended rules. These new rules would include a mandate that all members of the group be listed and present during the presentation. We strongly oppose this potential blanket provision, for the following reasons:
• The City has held that there is no requirement for anyone to identify themselves to make a Public Comment and to require it has been presumed as a violation of law by city staff.
• “Groups” may be legal entities, with many members, e.g.: HLC, Samaritan House, SVBC, Ethics San Mateo, HAC. To expect all members of these organizations to be present is simply unrealistic. How would verification be accomplished?
• Would remote attendance satisfy the proposed requirement? If, yes, how would verification be accomplished.
• If the authorized representative of a Corporation, or other form of a legal entity, requests the allowance of an Organized Presentation, will it be required to identify all members of the entity? Doing so may violate privacy agreements.