Brown Act Updates
SB 707 Open Meeting Law Amendments
March 10, 2026 Teresa Stricker, City Attorney
Dina Manis, City Clerk
New Rules Applicable to All Brown Act Bodies
Additional Remote Option Council May Adopt for Certain Limited Advisory Bodies
New Requirements SB 707 Imposes on City Council Meetings Only as of July 1, 2026
Direction Needed.
Today’s Presentation
New Rules Applicable to All
Brown Act Bodies –
Effective January 1, 2026
3 A copy of the Brown Act and list of meeting locations must be provided to:
All elected officials
All appointed officials serving on legislative bodies Social Media Communication provision updated to
remove 2026 sunset.
Miscellaneous
SB 707 – Effective January 1, 2026
5Miscellaneous
SB 707 – Effective January 1, 2026
Staff recommends amendments to City Council Manual of Procedures and Protocols related to removal procedures.
Updated Disruptive Behavior Language
• Explicitly Applies to virtual attendees too.
Expanded Prohibition on Special
Meetings for Executive Compensation
• Now Includes Council Compensation
6Reasonable Accommodation
SB 707 – Effective January 1, 2026
Member of Council or Board/Commission may participate
remotely as a reasonable accommodation for a qualifying disability.
Staff recommends adoption of Reasonable Accommodation Policy for Council and Boards/Commission Members and amendments to
SRCC 1-10.070 regarding related minute requirements.
Traditional Teleconferencing Rules are Unchanged
New Remote Public Comment requirement for Council - eff.
July 1 - (discussed later)
Alternate teleconferencing framework under “Just Cause” Streamlined into single framework
• Personal emergency circumstances are now part of “just cause.” No need for motion for personal emergency circumstances 7Teleconferencing Rules
SB 707 – Effective January 1, 2026
Staff recommends amendment to SRCC 1-10.070 regarding related minutes requirements.
Caregiving needs for qualifying family members
Contagious illness
Physical or mental condition (non-ADA)
Official business travel
New: Care for immunocompromised family member
New: Physical or family medical emergency
New: Military service preventing attendance
8 Just Cause Applies to
• Requires Council and the subsidiary body to authorize every 6 months based on certain findings made by Council
• Limited application to certain purely advisory bodies • Bic/Ped. Adv. Bd., Com., Bd. Parks & Rec., Waterways Adv. Com. • Does not apply to Council subcommittees: Electeds cannot participate remotely under this provision.
• A staffed physical location for meeting must be provided open to public
• Requires camera on for remote member, subject to exceptions. • Requires remote public participation option:
• 2-way audio-visual (public comment OK by audio only), or • 2-way telephonic and live webcasting.
9Eligible Subsidiary Bodies –
Option to allow 100% remote
If an approved subsidiary body requests opportunity to present its recommendations to Council:
• Council must hold a discussion about the recommendations at a regular meeting within 60 days
• Discussion item may not be on consent calendar
• Council may not take any action on recommendation sooner than the next regular meeting;
action requires two Council meetings.
10Eligible Subsidiary Bodies –
Ongoing Requirements
Staff recommends no action -- not approving use of this optional teleconferencing mechanism for “Eligible Subsidiary Bodies”.
Council-Specific Provisions
Effective July 1, 2026
11 STARTING JULY 1
12Council Meetings Only: Mandatory
Remote Public Participation Opportunity
Staff recommends amendments to City Council Manual of Procedures, Protocols related to public comment time, repeal of outdated CP 000-34, and SRCC.
Council Meetings Only: Disruptions of
Internet/Telephonic Service
• Procedure Requirement If Disruption in
Internet/Telephone Service Occurs:
• Council must recess open session for at least 1
hour while staff attempts to restore service.
• If service is not restored, Council may
reconvene and proceed with meeting but only
after making specific findings, by motion, that
there is good cause to proceed.
13 14
Direction Needed: Policy for Disruption
of Telephonic/Internet Service
Does Council want to create an exception Spanish Interpreter requirements in SRCC in the case of an internet disruption which may result in no Spanish interpretation in chambers?
1. No action. Council will not be able to use the Brown Act provisions permitting Council meetings to continue with its meeting during internet/telephone service disruption following unsuccessful efforts to restore and make appropriate findings by Council. This is because an internet disruption disables the City’s ability to provide Spanish interpretation. Interruptions in internet services in those situations could result in lengthy recesses, continued meetings, and no ability for Council to move forward with time-sensitive items.
OR
15Direction Needed: Policy for Disruption of
Telephonic/Internet Service
2. Amend SRCC 1-10.030: Create an exception to the City’s current Spanish interpretation requirement for Council meetings to allow Council discretion to move forward with a Council meeting, or with certain specific items on the agenda, without Spanish interpretation where Council makes findings similar to those required by the Brown Act when there is an internet/telephone disruption.
OR
3. Other option provided by Council.
New Brown Act Requirement:
Starting 7/1/26, Council Meeting agendas must be translated into languages that are:
Spoken by 20% or more of the City's population if at least 20% of those speaking the language speak English less than “very well” Up to 3 languages
Existing Santa Rosa City Code Exceeds New Brown Act Requirements! 16Council Meetings Only: Agenda
Translation Requirements
17Direction Needed:
Agenda Translation Requirements
1. Continue to translate City Council agendas as currently identified in SRCC, leaving open the possibility that the City may need to translate City Council agendas in more than 3 non-English languages should the population speaking each of those languages reach 5% of the City’s population; or
2. Retain the City’s current 5% population criteria for triggering the City’s obligation to provide a translated City Council agenda, but limit the number of non-English agendas to a maximum of 3 in alignment with Brown Act; or
3. Other direction provided by Council.
Effective 7/1/26, Brown Act requires reasonable access to translated agenda requests and interpretation assistance for City Council meetings
• May include arranging for sufficient space, extra time, use of personal equipment
• Does NOT require City to provide interpretation services Santa Rosa goes farther - SRCC 1-10.030(N)
• Provides interpretation services in Spanish at all regular Council meetings. • As matter of practice, staff accommodates language access requests whenever possible.
18Council Meetings Only:
Interpretation Assistance
Recommend no action as City Council is exceeding Brown Act Requirements 19 Outreach to Underrepresented and
Non-English-Speaking Communities
• Reasonable efforts to encourage
participation by groups that do not
traditionally participate in
meetings
• Broad Council discretion
• Only applies to City Council
agendas.
Outreach to Underrepresented and Non-
English Speaking Communities
20 1987
Adopted CP 000-20
Citizen Participation
2013
Formation of OG Task
Force
2020
Adoption of OG
Ordinance, CIRO Formed,
CE Director hired
2021
Amended OG SRCC
OG Implementation
21 Outreach to Underrepresented and
Non-English Speaking Communities
Community Type Number of
Events 2024
Number of Events
2025
Percentage
2024-2025
%
Elected Officials & CBOs 4 11
General Public 14 20 45
LGBTQ+ Community 1 1 3
Neighborhood 1 4 7
Older Adults 1 3
People with Disabilities 1 3
Small Business 2 1 4
Underserved
Communities 12 9 28
Underserved Youth 1 2 4
Unhoused 1 3
Total 38 37 100
Currently:
• Current Outreach Plan
• Council Policy 000-20 –
Outdated.
Staff recommends amendments
to CP 000-20 for modernization
and alignment with current
organizational structure.
Continue efforts as already
established in SRCC, Council
Policies, engagement plan.
Outreach to Underrepresented and
Non-English-Speaking Communities
• By 7/1/26, the City must provide a physical location near the City Council agenda posting site for the public to post translated City Council agendas
23Public Location for Council Agenda
Translations
City Clerk rendering (not a professional digital artist) Recommendation
• The City Clerk’s and City Attorney’s Offices present this study session to provide the Council with an overview of recent Brown Act changes adopted under Senate Bill 707 (2025).
Council will take no action except provide direction to staff.
This item has no impact on the current fiscal year budget. 24 25
100% Remote Participation
by Eligible Subsidiary Bodies
• Eligible Subsidiary Bodies =
Waterways Advisory Committee
Board of Parks and Recreation
Bicycle and Pedestrian Advisory Board
• Option requires Council to prioritize hearing recommendations of body within 60-days of request at a Council meeting without Council voting to add to agenda/workplan.
• Staff recommends no action. Affirm or provide different direction 26 Remote Public
Attendance/Comment
Amend CCMPP
• Section II. Agenda - to Update public comment time to "no less than 1 minute" in anticipation of increased number of public comments from online participants.
• Section IV. Addressing the Council - subsections B for removal of reference to CP 000-34 if repealed.
Amend SRCC 1-10.070 – Minutes, to simplify public comment summary requirements
Affirm or provide different direction.
27 Internet and Telephonic Service
Disruption Provisions
Does Council want exceptions to Interpreter requirements in SRCC?
1. No action. Council continues without language access exception due to interpretation service interruption, resulting in continuation of meetings;
2. Amend SRCC 1-10.030:
a. To provide exception to move forward with Council meeting without Spanish interpretation; or
b. Make certain good cause findings similar to those required in the internet and telephonic service disruption policy, to proceed with the meeting or limited items on the agenda.
3. Other option provided by Council
28 Language Access Requirements for
City Council Meetings
1. Continue to translate City Council agendas as currently identified in SRCC, leaving open the possibility that the City may need to translate City Council agendas in more than 3 non-English languages should the population speaking that language reach 5% of the City’s population (far exceeds Brown Act); or
2. Retain the City’s current 5% population criteria for triggering the City’s obligation to provide a translated City Council agenda, but limit the number of non-English agendas to a maximum of 3 in alignment with Brown Act; or
3. Other direction provided by Council.
Direction Needed.
29 Outreach Efforts
1. Update to CP 000-20
2. Continue outreach efforts as set forth in existing code, policies, engagement plan.
Affirm or provide different direction.
Questions?
30