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Carmel council asks staff to rewrite ticket-and-passes policy, favoring staff reporting over council exemptions
Summary
After a presentation on an FPPC-compliant ticket distribution policy that would let the city report complimentary tickets on a Form 802 instead of individual Form 700 filings, the Carmel-by-the-Sea City Council asked staff to revise the draft to limit the change to city employees and keep council reporting separate.
Nova, the city clerk, presented a draft policy and sample Form 802 that would let the city accept and distribute complimentary tickets and report those distributions centrally under Fair Political Practices Commission (FPPC) rules rather than requiring each official to report on a Form 700. "If they're distributed under the policy then as I just mentioned they wouldn't be subject to the FPPC's annual gift limit which currently is $630," Nova said, explaining how agency reporting differs from individual reporting.
Council members asked detailed questions about whether outside donors could earmark tickets for particular officials and how the city administrator would allocate passes. Nova and legal staff said the draft policy prohibits earmarking: tickets accepted by the city must be distributed at the city’s discretion and not designated for a specific official. "Tickets or passes shall be distributed under this policy at the sole discretion of the City pursuant to the policy," staff counsel noted while pointing to the draft's distribution language.
Several council members said the policy could reduce the reporting burden for staff and make it easier for employees to attend events. "We're volunteers and so to the extent that we don't have to report every guest pass... the staff can help us with that," one council member said in favor. Others said moving council reporting off Form 700 and onto Form 802 would be less transparent for elected officials and risk perceptions of favoritism if the city administrator were given allocation discretion.
In the exchange, council members proposed a bifurcated approach: allow the agency Form 802 process for city employees while council members continue to report gifts on their Form 700s. Several council members asked staff to return with edits and clarifications, including whether the policy can practically prioritize council members without violating FPPC guidance, and how the city will publish Form 802 disclosures for easier access. City Administrator Brandon was asked to work with the clerk and legal counsel on revisions.
No resolution was adopted at the meeting. Staff were directed to revise the draft policy to focus on employees (not elected officials), provide clearer distribution criteria and reporting/display options, and return with answers to the council's questions. Nova said she would post the Form 802s on the city website within the policy's posting requirements if the council ultimately adopts the policy.
Votes and procedural notes: the council handled the consent calendar and separately approved the related consent items that were not pulled; the ticket-and-passes policy discussion was taken as an action item and sent back to staff for revision. The council did not adopt Resolution 20 26 20 13 at this meeting.
What comes next: staff will revise the draft policy and return to the council with a version limited to city employees, clearer guidance on distribution procedures, and options for posting Form 802 disclosures so residents can subscribe or locate them more easily.
