HomeMy WebLinkAbout03.a. Review draft Position Paper to adopt Resolution No. 2024-xxx approving biennial updates to the District's Conflict of Interest codePage 1 of 20
Item 3.a.
CDrrEN1 RAL SAN BOARD OF •'
CENTRAL CONTRA COSTA SANITARY DISTRICT POSITION PAPER
DRAFT i
MEETING DATE: NOVEMBER 5, 2024
SUBJECT: REVIEW DRAFT POSITION PAPER TO ADOPT RESOLUTION NO. 2024-
XXX APPROVING BIENNIAL UPDATES TO THE DISTRICT'S CONFLICT
OF INTEREST CODE AND DIRECTING THE SECRETARY OF THE
DISTRICT TO SUBMIT THE UPDATED 2024 CONFLICT OF INTEREST
CODE TO THE CONTRA COSTA COUNTY BOARD OF SUPERVISORS FOR
APPROVAL
SUBMITTED BY:
INITIATING DEPARTMENT:
KATIE YOUNG, SECRETARY OF THE SECRETARYOF THE DISTRICT
DISTRICT
REVIEWED BY: LEAH CASTELLA, DISTRICT COUNSEL
ROGER S. BAILEY, GENERAL MANAGER
ISSUE
The Government Code requires the District to review and update its local Conflict of Interest Code every
two years. As part of this year's review process, District staff identified the need for a complete review
and update of the Code for clarity and consistency with the Political Practices Commission ("FPPC")
practices.
BACKGROUND
The Political Reform Act requires certain public officials to file a Statement of Economic Interests
(otherwise known as a Form 700), disclosing financial interests such as investments in business entities,
interests in real property, sources of income and sources of gifts. (Gov. Code § 87200.) Officials and
employees not specified in the Political Reform Act must disclose those interests set forth in their
agencies' local Conflict of Interest ("COI") codes. (Gov. Code § 87302(b).) In other words, the Political
Reform Act governs disclosure requirements for certain public agency officials, and the local COI Code
requires other employees, not covered by State law, to disclose specific financial interests based on their
duties.
The principles governing disclosure of economic interests are the same for all agencies. However, each
agency's code is a unique document that must be tailored to the reporting requirements applicable to the
type of decisions each designated employee makes on behalf of the agency. Each COI Code must
contain the following:
November 5, 2024 Regular ADM IN Committee Meeting Agenda Packet - Page 3 of 63
Page 2 of 20
(1) the provisions for disclosing financial interests and the disqualification procedures;
(2) designated positions that make or participate in making decisions that are subject to the disclosure
and disqualification requirements of the COI Code; and
(3) disclosure categories that list the types of assets and income to be disclosed by those individuals
holding the designated positions.
The FPPC recommends public agencies adopt Regulation 18730 by reference to satisfy the
requirements of Element 1. Regulation 18730 sets forth provisions regarding disclosure of financial
interests, when Form 700s are due, and disqualification. The COI Code's appendix makes it specific to
that local agency. Generally, the appendix is split into two parts. The first identifies the Designated
Employees, whose duties "involve the making or participation in the making of decisions which may
foreseeably have a material effect on any financial interest." (Gov. Code § 87302(a).) A financial interest
is an interest in an investment, business position, interest in real property, and sources of income and is
reportable when the interest "may foreseeably be affected materially by any decision made or participated
in by the designated employee by virtue of the designated employee's position." (Id.)
The second part of the appendix provides disclosure categories, i.e., an explanation of which financial
interests each Designated Employee must disclose. Required disclosures depend on the duties and
responsibilities of the position. For example, the general manager should most likely be assigned full
disclosure (all investments, interests in real property, sources of income, and business positions) because
the general manager makes decisions that would affect a wide range of interests. Alternatively, an
administrative assistant whose decision -making is limited to the purchase of office supplies should only be
assigned disclosure of investments, sources of income, and business positions in entities that provide
office supplies, equipment, or merchandise of the type used by the local agency.
The proposed amendments (Attachment 1) to the District's COI Code restructure the Code to more
clearly incorporate Regulation 18730, followed by Part 1 of the Appendix setting forth the Designated
Employees, then Part 2 of the Appendix providing for the Disclosure Categories. The amended COI
Code also removes various provisions that are not necessary in local COI Codes, such as references to
officials whose financial disclosures are governed by the Political Reform Act, which are outside the scope
of a local agency's code. Moreover, to streamline the system, the proposed amended Code requires all
filers to submit Form 700s with the County, through its NetFile system.
The amended Code maintains the existing Code's organization of disclosure categories to group
disclosure groups by the type of decision being made, but clarifies Categories 1, 2, 3, and 4 to require
disclosure of only those interests which can reasonably be affected by District actions.
Category 1 - the broadest disclosure category, is reserved for high-level decisionmakers such as the
general manager, department heads, and other employees who make or participate in making broad
purchasing or policy choices for Central San. The proposed COI Code specifies that a business
entity is "located or doing business in the jurisdiction of District" if the entity does business or plans
to do business within the boundaries of the District, or if the entity owned or leased facilities within the
District, or has done business within the District, in the past two years. The amendments provide
further clarity that only interests in real property located within the boundaries or within two miles of
the boundaries of the District or land owned by the District must be disclosed. These two
qualifications for disclosure provide more tailored disclosure requirements to require disclosure of
only those interests that could be reasonably affected by a District decision.
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 4 of 63
Page 3 of 20
Category 2 - relating to employees or official who participate in contracting or purchasing, includes
employees who have Procurement Cards ("P-Cards") and can make purchases or enter contracts
using District funds. This category requires disclosure of investments, positions in business entities,
and income from sources that provide goods or services to the District and might include anyone
from an administrative assistant who purchases office supplies to the District's Contracts and
Procurement Administrator. Staff has reviewed the current purchasing practices in the District and
has determined that employees who make purchases on behalf of the District amounting to
$1,500/month or $18,000/year could reasonably have financial conflicts, and therefore, should be
required to make certain financial disclosures.
Category 3 - applies to officials and employees whose decisions may affect real property interests.
Similar to our revisions to Category 1, we clarified that only those real properties within the District,
within two miles of the District, or within two miles of land owned or used by the District must be
reported.
• Category 4 -applies to designated employees with regulatory powers. In other words, employees
who make decisions relating to permitting and licensing on behalf of the District must disclose all
investments, business positions, and income from sources that are subject to the District's regulatory
authority or that have an application for a license or permit pending with the District.
ALTERNATIVES/CONSIDERATIONS
The FPPC provides clear language regarding criterion that constitutes a conflict of interest, appropriate
behavior of elected officials and staff and disclosure requirements. The updated policy reflects these
requirements. The Board may consider alternative reporting requirements for Procurement Card holders,
with the caveat that reporting requirements for individuals with purchasing power for the District may have
significant conflicts of interest arising from District activity, so some level of disclosure is recommended.
FINANCIAL IMPACTS
None related to this action.
COMMITTEE RECOMMENDATION
This matter was reviewed at the November 5, 2024 Administration Committee meeting and recommended
that
RECOMMENDED BOARD ACTION
Adopt a proposed resolution approving the recommended changes to the District's Conflict of Interest
Code and directing the Secretary of the District to complete the 2024 Conflict of Interest Code Biennial
Notice and submit it to the Contra Costa County Board of Supervisors for approval.
Strategic Plan Tie -In
GOAL FOUR: Governance and Fiscal Responsibility
Strategy 1 - Promote and uphold ethical behavior, openness, and accessibility, Strategy 3 - Maintain financial stability
and sustainability
GOAL SEVEN: Innovation and Agility
Strategy 3 - Be adaptable, resilient and responsive
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 5 of 63
Page 4 of 20
ATTACHMENTS:
1. Conflict -of -Interest Code (Strikeout)
2. Conflict -of -Interest Code (Clean)
3. Resolution
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 6 of 63
Page 5 of 20
ATTACHMENT 1
CONFLICT OF INTEREST CODE
Adopted: November 15, 2012
Last Revised: September 9, 2023
CENTRAL CONTRA COSTA SANITARY DISTRICT
CONFLICT OF INTEREST CODE
A Incorporation of FPPC Denu iatmon by Deference
The Fair Political Practices Commission has adopted a regulation (2
Cal.Code Regs. 18730) which contains the terms of a standard conflict of
interest code which can be incorporated by reference in the agency's code. After
public notice and hearing it may be amended by the Fair Political Practices
Commission to conform to amendments in the Political Reform Act. Therefore,
the terms of 2 California Code of Regulations Section 18730 and any future
amendments to it duly adopted by the Fair Political Practices Commission are
hereby incorporated by reference. Such regulation, and the attached Appendix
designating officials and employees and establishing disclosure categories, shall
constitute the conflict -of -interest code of the Central Contra Costa Sanitary
District.
The desianated officials and emDlovees shall file statements of economic
interests with the County Clerk through its electronic NetFile system and shall
provide a courtesy copy of the statement of economic interests to the Secretary
of the District, who shall make a the statements available for public inspection
and reproduction. (Gov't Code 81008.) The original statements of the General
Manager, Secretary, General Counsel, Deputy General Managers, Director of
Engineering and Technical Services, Finance Manager and Directors shall be
forwarded to the Clerk of the Board of Supervisors for Contra Costa County.
Conies of the statements for all desianated officials and emDlovees will be
retained by the Central Contra Costa Sanitary District.
In addition to anv other reauirements of 2 California Code of Reaulations
Section 18730 and any amendments thereto, a candidate for the Board of
Directors of Central Contra Costa Sanitary District shall file, no later than the final
filing date of a declaration of candidacy, a statement of economic interests,
pursuant to Government Code section 87200 et seq. T41e
the California Code of RegulatiORs and any amendments to that regulatiOR
subsequently adopted by the Fair Dnli+inal Dron+iGes Commission (FPPC) are
hereby inGOrpOrated on this GonfliGt of interestConfloGt Of interest Gede by
rofo�Ge
4871-8616-3424 v4
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Page 6 of 20
APPENDIX
Disclosure Categories
Part I: Desi Hated Em to ees
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 2 of 7
Designated PositkmsEmplloyees
Category
1
1.
General Manager
Secretary of the District
General Counsel
Deputy General Manager — Administration
Deputy General Manager — Operations
Finance Manager
Capital Projects Division Manager
1
2.
Collection System Operations Division Manager
1
3.
Communication Services and Government Relations
Manager
1
4.
Environmental and Regulatory Compliance Division Manager
1
5.
Human Resources & Organizational Development Manager
1
6.
Information Technology Manager
1
7.
Internal Auditor/Diversity, E uit & Inclusion Officer
1
8.
Operations Optimization Manager
1
9.
Planning and Development Services Division Manager
1
10.
Plant Maintenance Division Manager
1
11.
Plant Operations Division Manager
1
12.
Resource Recovery Program Manager
1
Consultants and SiqeGial QapaGith&
1
13.
Consultant* (refeF to SeGtkN 4 belew)
14.
Employees or consultants hired as financial advisor or
underwriter
1
15.
Employees on the Deferred Compensation Advisory
Committee
1
All Other Annlinahle Staff Positions
16.
17.
-Accounting Supervisor
Associate Engineer
1
1
18.
Construction Inspector
2, 4
19
Contracts and Procurement Administrator
2
4871-8616-3424 A
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Page 7 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 3 of 7
now 21 2
Desi nated NT w-A�Em to ees
Category
4-9,20
Contracts and Procurement Specialist 1/11
2
2-0:21
Contracts Specialist
2
24,22
Development Services Supervisor
2,3
2-2,23
Environmental Compliance Inspector 1/11
2,4
23 24
Environmental Compliance Program Administrator
2, 4
2425
Laboratory Program Administrator
2, 4
2-526
Land Surveyor
2,3
26,27
Maintenance Planner
2
27,28
Maintenance Supervisor
2
2�29
Material Services Supervisor
2
29,30
Materials Specialist
2
3$31
Real Property Agent
2,3
3432
Risk Management Program Administrator
1
32:33
Senior Engineer
1
33-34
Senior Environmental Compliance Inspector
2,4
3435
Superintendent, Operation s/Ma i nte nan ce
2
3&36
Utility Systems Engineer
1
37.
EHS Program Administrator
1
38.
Household Hazardous Waste Pro ram Administrator
1
39.
Asset Management Program Administrator
1
40.
Employees or consultants hired as financial or advisory
underwriter
1
41.
Employees on the Deferred Compensation Advisory
Committee
1
42.
Utility Worker
2
43.
Graphics Designer
2
44.
Vehicle E ui ment
2
45.
Senior HHW Tech
2
46.
Electrical Technician
2
47.
Instrumentation Tech
2
48.
Executive Assistant to the GM
2
49.
Admin Services Supervisor
2
50.
Admin Services Assistant
2
51.
Maintenance Technician
2
52.
Lead Maintenance Technician
2
53.
Deputy Secretary of the District
2
54.
Admin Assistant
2
55.
EHS Specialist
2
56.
Sr. Community Affairs Re2
2
57.
Chemist I, 11, III
2
58.
Supervising Chemist
2
59.
Community Affairs Rep
2
60.
Project Manager/Business Analyst
2
4871-8616-3424 v4
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Page 8 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 4 of 7
now 21 2
Desi nated Ros+fl@n-sEm to ees
Catecliory
61.
Electrical/Instrumentation Supervisor
2
62.
Machinist
2
63.
Pump Stations Operators I, II, III
2
*Consultants
Only those Consultants who fall within the criteria described below shall disclose
pursuant to the broadest disclosure category in the District's Conflict of Interest
Code, unless the General Manager determines, in writing, -that a less broad
category is appropriate.
For purposes of the District's Conflict of Interest Code, "Consultant" means an
individual who, pursuant to a contract with the District:
Makes a governmental decision whether to:
a. Approve a rate, rule, or regulation;
b. Adopt or enforce a law;
C. Issue, deny, suspend, or revoke any permit, license, application,
certificate, approval, order, or similar authorization or entitlement;
d. Authorize the agency to enter into, modify, or renew a contract
provided it is the type of contract that requires agency approval;
e. Grant agency approval to a contract that requires agency approval
and to which the agency is a party, or to the specifications for such
a contract;
f. Grant agency approval to a plan, design, report, study, or similar
item;
g. Adopt, or grant agency approval of, policies, standards, or
guidelines for the agency, or for any subdivision thereof; or
2. Serves in a staff capacity with the agency and in that capacity participates
in making governmental decisions as defined in FPPC Regulation 2 CCR
18700, et seq. or performs the same or substantially all the same duties
for the agency that would otherwise be performed by an individual holding
a designated position specified On the SeGtiens G and u above.
The General Manager shall make a determination in writing when a particular
Consultant falls within the above -described criteria requiring the Consultant to be
treated as a "designated position." The General Manager's determination is a public
record and shall be retained for public inspection in the same manner and location as
the Genfii„t of Interes Conflict -of -Interest Code.
Part II: Disclosure Categories
4871-8616-3424 v4
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Page 9 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 5 of 7
now 21__2�
These indoy0d eels listed in Qentiens Gd✓ I are Designated Employees
e u e en
required to file a statement of economic interests erg 700 as their job duties fall
under one, or more, of the following categories:
Category 1 — Officials and emnlo„ees Designated Employees whose
duties are broad and indefinable:
All investments and business positions in business entities, and income
(including loans, gifts and travel payments) from sources located in or
doing business in the District's jurisdiction. A business entity is "located or
doing business in the jurisdiction of District" if the business entity is doing
business or plans to do business within the boundaries of the District, or if
the business entity owned or leased any facilities within the boundaries of
the District, or has done business within the boundaries of the District, at
any time during the two years prior to the time that the disclosure
statement of the designated office/employee is filed.
Interests in real Drooerty located in the iurisdiction. includina Droaert
located in part or in while within the boundaries of the District, within two
miles thereof, or within two miles of land owned or used by the District.
Interests in real nreperty leGated in the iurisdis+inn insli ding nrenerty
e
within gale miles of the boundaries of the Distrint°s iurisdintion
• Category 2 — Officials and ernpleyees Designated Employees whose
duties involve contracting or purchasing equal to or exceeding $1,500 per
month or $18,000 per year for the District:
All investments and business positions in business entities, and income
(including gifts, loans and travel payments) from sources that provide
leased facilities, goods, equipment, vehicles, machinery or services,
including training or consulting services, of the type utilized by this District.
• Category 3 — Officials and employees Designated Employees whose
decisions may affect real property interests:
Interests in real property located in the jurisdiction, including property
located in part or in while within the boundaries of the District, within two
miles thereof, or within two miles of land owned or used by the District. of
the hoi -Rdaries of the Destrint
• Category 4 — Officials and empleyeesDesignated Employees with
regulatory powers:
All investments and business positions and income, including gifts, loans
and travel payments, from sources that are subject to the regulatory,
4871-8616-3424 v4
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Page 10 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 6 of 7
now 21 2
permit or licensing authority of, or have an application for a license or
permit pending before, the District.
-■
OStFOGt
Employees listed on SeGtion H belol.A.If shall file an OrigiRal Form .. with the
SeGretary of the DTXeiStFiGt. rVI ■
and shall retain the original state.m.ents.
4871-8616-3424 v4
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Page 11 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 7 of 7
now 21 2
..
W.
02.
r r
Deskinated DACI+oons
4 Member, rlBeard of irecters
Dusclosure ■ atecior\/
4-
%`onorol Manage
Secretary of the DmStrict
4-
4— GOURsoll for the Dictrinf
-
General Manager
-5-m-- Deputy
dm�,�nistt�ratll ,n 1
G
[� DG�e-rnr ra I 'cage i p
e rats O i S 41
DiFeGtGF Of ERginoorinn ani-I ToeGhnnTalrvervTG
4-
Finance Manager
4871-8616-3424 v4
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 13 of 63
Page 12 of 20
ATTACHMENT 2
CONFLICT OF INTEREST CODE
Adopted:
Last Revised:
CENTRAL CONTRA COSTA SANITARY DISTRICT
CONFLICT OF INTEREST CODE
The Fair Political Practices Commission has adopted a regulation (2 Cal.Code
Regs. § 18730) which contains the terms of a standard conflict of interest code which
can be incorporated by reference in the agency's code. After public notice and hearing
it may be amended by the Fair Political Practices Commission to conform to
amendments in the Political Reform Act. Therefore, the terms of 2 California Code of
Regulations Section 18730 and any future amendments to it duly adopted by the Fair
Political Practices Commission are hereby incorporated by reference. Such regulation,
and the attached Appendix designating officials and employees and establishing
disclosure categories, shall constitute the conflict -of -interest code of the Central Contra
Costa Sanitary District.
The designated officials and employees shall file statements of economic
interests with the County Clerk through its electronic NetFile system and shall provide a
courtesy copy of the statement of economic interests to the Secretary of the District,
who shall make a the statements available for public inspection and reproduction.
(Gov't Code § 81008.) The original statements of the General Manager, Secretary,
General Counsel, Deputy General Managers, Director of Engineering and Technical
Services, Finance Manager and Directors shall be forwarded to the Clerk of the Board
of Supervisors for Contra Costa County. Copies of the statements for all designated
officials and employees will be retained by the Central Contra Costa Sanitary District.
In addition to any other requirements of 2 California Code of Regulations Section
18730 and any amendments thereto, a candidate for the Board of Directors of Central
Contra Costa Sanitary District shall file, no later than the final filing date of a declaration
of candidacy, a statement of economic interests, pursuant to Government Code section
87200 et seq.
4866-7811-1979 v4
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 14 of 63
Page 13 of 20
APPENDIX
Part I: Designated Employees
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 2 of 7
Designated Employee
Disclosure Category
Accounting Supervisor
1
Administrative Assistant
2
Administrative Services Assistant
2
Administrative Services Supervisor
2
Asset Management Program Administrator
1
Associate Engineer
1
Capital Projects Division Manager
1
Chemist I, 11, III
2
Collection System Operations Division Manager
1
Communication Services and Government Relations
Manager
1
Community Affairs Representative
2
Construction Inspector
2,4
Consultants*
1
Contracts and Procurement Administrator
2
Contracts and Procurement Specialist 1/II
2
Contracts Specialist
2
Deputy General Manager —Administration
1
4866-7811-1979 v4
November 5, 2024 Regular ADMIN Committee Meeting Agenda Packet - Page 15 of 63
Page 14 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 3 of 7
Deputy General Manager — Operations
1
Deputy Secretary of the District
1
Development Services Supervisor
2,3
EHS Program Administrator
1
EHS Specialist
2
Electrical Technician
2
Electrial/Instrumentation Supervisor
2
Employees on the Deferred Compensation Advisory
Committee
1
Employees or consultants hired as financial advisory or
underwriter
1
Environmental and Regulatory Compliance Division
Manager
1
Environmental Compliance Inspector 1/11
2,4
Environmental Compliance Program Administrator
2, 4
Executive Assistant to the GM
2
Finance Manager
1
General Counsel
1
General Manager
1
Graphics Designer
2
Household Hazardous Waste Program Administrator
1
Human Resources & Organizational Development
Manager
1
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Page 15 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 4 of 7
Information Technology Manager
1
Instrumentation Technician
2
Internal Auditor/Diversity, Equity & Inclusion Officer
1
Laboratory Program Administrator
2, 4
Land Surveyor
2,3
Lead Maintenance Technician
2
Machinist
2
Maintenance Planner
2
Maintenance Supervisor
2
Maintenance Technician
2
Material Services Supervisor
2
Materials Specialist
2
Operations Optimization Manager
1
Planning and Development Services Division Manager
1
Plant Maintenance Division Manager
1
Plant Operations Division Manager
1
Project Manager/Business Analyst
2
Pump Stations Operators, I, II, III
2
Real Property Agent
2,3
Resource Recovery Program Manager
1
Risk Management Program Administrator
1
Secretary of the District
1
Senior Engineer
1
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Page 16 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 5 of 7
Senior Environmental Compliance Inspector
2,4
Senior HHW Technician
2
Senior Community Affairs Representative
2
Superintendent, Operations/Maintenance
2
Supervising Chemist
2
Utility Systems Engineer
1
Utility Worker
2
Vehicle Equipment
2
*Cnnsultants
Only those Consultants who fall within the criteria described below shall disclose
pursuant to the broadest disclosure category in the District's Conflict of Interest Code,
unless the General Manager determines, in writing, that a less broad category is
appropriate.
For purposes of the District's Conflict of Interest Code, "Consultant" means an
individual who, pursuant to a contract with the District:
Makes a governmental decision whether to:
a. Approve a rate, rule, or regulation;
b. Adopt or enforce a law;
C. Issue, deny, suspend, or revoke any permit, license, application,
certificate, approval, order, or similar authorization or entitlement;
d. Authorize the agency to enter into, modify, or renew a contract
provided it is the type of contract that requires agency approval;
e. Grant agency approval to a contract that requires agency approval
and to which the agency is a party, or to the specifications for such
a contract;
f. Grant agency approval to a plan, design, report, study, or similar
item;
g. Adopt, or grant agency approval of, policies, standards, or
guidelines for the agency, or for any subdivision thereof; or
2. Serves in a staff capacity with the agency and in that capacity participates
in making governmental decisions as defined in FPPC Regulation 2 CCR
18700, et seq. or performs the same or substantially all the same duties
4866-7811-1979 v4
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Page 17 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 6 of 7
for the agency that would otherwise be performed by an individual holding
a designated position specified above.
The General Manager shall make a determination in writing when a particular
Consultant falls within the above -described criteria requiring the Consultant to be
treated as a "designated position." The General Manager's determination is a public
record and shall be retained for public inspection in the same manner and location as
the Conflict -of -Interest Code.
Part II: Disclosure Categories
Designated Employees are required to file a statement of economic interests as their
job duties fall under one, or more, of the following categories:
Category 1 — Designated Employees whose duties are broad and indefinable:
All investments and business positions in business entities, and income
(including loans, gifts and travel payments) from sources located in or
doing business in the District's jurisdiction. A business entity is "located or
doing business in the jurisdiction of District" if the business entity is doing
business or plans to do business within the boundaries of the District, or if
the business entity owned or leased any facilities within the boundaries of
the District, or has done business within the boundaries of the District, at
any time during the two years prior to the time that the disclosure
statement of the designated office/employee is filed.
Interests in real property located in the jurisdiction, including property
located in part or in while within the boundaries of the District, within two
miles thereof, or within two miles of land owned or used by the District.
• Category 2 — Designated Employees whose duties involve contracting or
purchasing equal to or exceeding $1,500 per month or $18,000 per year for the
District:
All investments and business positions in business entities, and income
(including gifts, loans and travel payments) from sources that provide
leased facilities, goods, equipment, vehicles, machinery or services,
including training or consulting services, of the type utilized by this District.
• Category 3 — Designated Employees whose decisions may affect real property
interests:
Interests in real property located in the jurisdiction, including property
located in part or in while within the boundaries of the District, within two
miles thereof, or within two miles of land owned or used by the District.
4866-7811-1979 v4
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Page 18 of 20
Central Contra Costa Sanitary District
Conflict of Interest Code — Page 7 of 7
• Category 4 — Designated Employees with regulatory powers:
All investments and business positions and income, including gifts, loans
and travel payments, from sources that are subject to the regulatory,
permit or licensing authority of, or have an application for a license or
permit pending before, the District.
4866-7811-1979 v4
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Page 19 of 20
ATTACHMENT 3
RESOLUTION NO. 2024 - XXX
A RESOLUTION OF THE CENTRAL CONTRA COSTA SANITARY
DISTRICT AMENDING ITS CONFLICT OF INTEREST CODE
WHEREAS, the Political Reform Act (California Government Code Section 81000, et
seq.) requires public agencies to adopt and promulgate a local conflict of interest code;
and
WHEREAS, the Fair Political Practices Commission has adopted a regulation (Title 2
California Code of Regulations Section 18730) that contains the terms of a standard
conflict of interest code which may be incorporated by reference in an agency's Conflict
of Interest Code; and
WHEREAS, the Political Reform Act, Government Code Section 87306.5, requires
government agencies to conduct biennial reviews of their adopted conflict of interest
code; and
WHEREAS, the Central Contra Costa Sanitary District has determined that revisions to
the Conflict of Interest Code are needed to reflect new and removed positions, to revise
the disclosure categories, and to reflect the structure of Conflict of Interest Codes
recommended by the Fair Political Practices Commission.
NOW THEREFORE, BE IT RESOLVED by the Board of Directors of District amends its
Conflict of Interest Code as set forth in Exhibit A, which is incorporated herein by
reference and attached to this Resolution.
PASSED AND ADOPTED this 21st day of November, 2024, by the Board of Directors of
the Central Contra Costa Sanitary District by the following vote:
AYES:
Members:
NOES:
Members
ABSENT:
Members:
Mariah N. Lauritzen
President of the Board of Directors
Central Contra Costa Sanitary District
County of Contra Costa, State of California
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Page 20 of 20
ATTACHMENT 3
COUNTERSIGNED:
Katie Young
Secretary of the Central Contra Costa Sanitary District
County of Contra Costa, State of California
Approved as to form:
Leah J. Castella
Counsel for the District
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