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HomeMy WebLinkAboutagenda.council.worksession.20240318AGENDA CITY COUNCIL WORK SESSION March 18, 2024 4:00 PM, City Council Chambers 427 Rio Grande Place, Aspen I.Work Session I.A Open Meetings and Open Records / Council Emails I.B Boards and Commissions Expectations I.C City Manager Board Reports - CAST, Airport Advisory Board Zoom Meeting Instructions Join from a PC, Mac, iPad, iPhone or Android device: Please click this URL to join: https://us06web.zoom.us/j/87246631168? pwd=a7X9CvKbdMmVkUg0xAiMRXceHmzbms.1 Passcode: 81611 Or join by phone: Dial: US: +1 346 248 7799 Webinar ID: 872 4663 1168 Passcode: 81611 International numbers available: https://us06web.zoom.us/u/kgourkbhv Council Memo - Open Meetings and Open Records.docx Aspen 3-18-24 Final.pdf Council Memo - Boards and Commissions.docx CML handbook-boards (002).pdf 2024a_House Bill 1168_01.pdf Boards and Commission Spreadsheet.pdf 1 1 MEMORANDUM TO:Mayor and City Council FROM:Jenn Ooton, Senior Project Manager THROUGH:Sara Ott, City Manager MEMO DATE:March 6, 2024 MEETING DATE:March 18, 2024 RE:Open Meetings and Open Records Laws Email Transparency REQUEST OF COUNCIL: This work session will cover a range of topics related to open meetings, open records, and the expectations that Council has for its advisory boards. SUMMARY AND BACKGROUND: This work session will cover three major topic areas: A presentation regarding open meetings and open records laws by CIRSA, information about email transparency, and a conversation regarding Boards and Commissions. This staff memo provides information related to the first two topics. A second memo provides additional information related to boards and commissions. CIRSA presentation The first part of the work session will focus on open meetings and open records laws. Sam Light, general counsel for CIRSA (Colorado Intergovernmental Risk Sharing Agency), will provide a training and opportunity for Council to ask questions about requirements for local government transparency, individual liability as an elected official, social media, public meetings/accessibility bill and law enforcement liability. Council Email Transparency The second topic for the work session is a discussion around Council email transparency. The Colorado Open Records Act (CORA) ensures that emails sent to and from public officials are public documents that are open to inspection, with only limited exceptions. According to the City Attorney’s office, the city receives an average of five CORA’s a year where staff have had to reach out to Council and ask for forwarded communications in response to a CORA request. Often these are related to topics of wide community interest. To provide some examples: Question 2A in fall 2022 STR Tax question in fall 2022 Comments about the Aspen Times 2022 Communications concerning the lease to Aspen Mountain Tots and Playgroup Aspen - 2021 West End Traffic issues – fall 2021 Moratorium in Dec. of 2021 (ordinance 27) Adam Frisch information 2023 Lumberyard – 2023 2 Several elected community boards in Colorado provide a platform to display email messages that are considered public records with user-friendly interfaces that make accessing these records much easier for the public. These systems increase transparency and allow for people to access information without needing to file a CORA request. Providing a public portal for Council emails could also ensure that the public is able to access to all emails that would be responsive to a specific request. City staff have researched an email transparency and archiving system that would allow for public posting of Council emails for the City of Aspen through a public portal. The system utilizes an initial screening of emails through a set of rules, automatically flagging emails that meet certain criteria and excluding them from being displayed on the public portal. For example, emails to or from the city attorney would be screened out to ensure confidentiality. In Fort Collins, the City Attorney’s office reviews three to four days of recent emails stored in the system at a time and then another team member does a “quality control” check. The attorney’s office scans the subject lines of all the emails that were not already automatically restricted, looking for any that should be kept out of the public folder because they contain information of a sensitive or confidential nature that was perhaps not intended to be released. These are flagged as restricted, and a notation is made for each as to why it was restricted. All the unrestricted messages are then placed in a folder where the public can access them. This process on average takes about one hour of staff time per week. Information and access to the portal for Fort Collins is available at this weblink: https://www.fcgov.com/council/email-transparency.php FINANCIAL IMPACTS: The city received a proposal from the vendor that provides this software solution to other jurisdictions for approximately $5,000 annually. The final cost for these services would be based on all of the elements of the service. Staff anticipates a cost savings through streamlining the review and publishing process. CITY MANAGER COMMENTS: ATTACHMENTS CIRSA/Sam Light Slides 3 Presented by: Sam Light, CIRSA Deputy Executive Director/General Counsel Elected Official Presentation City of Aspen • March 18, 2024 4 2 Introduction •Suggestions for best practices that will enhance your effectiveness and success as municipal officials – which in turn will reduce risk for the City and you individually. Topics we will touch on include: •The role of public official •Transparency topics •Organizational structure & liability •Concluding thoughts – Q & A •Presentation is a training resource only; is not intended to address or provide legal advice on any specific, pending issues. 5 3 Commit to the Role of Public Official •Being a local elected official means your role has changed: •Citizen → government official (24/7!) •Outsider → insider •Critic/proponent → representative-ambassador-steward-fiduciary of the City as an entity and of the City Council as an institution. •In the eyes of the community, you are always a public official! 6 4 The Role of Public Official •As local government officials, part of your role is delivering good governance which, at root, is based both practically and legally on a few core concepts: •Openness & Transparency (open meetings/records laws); •Fundamental Fairness (due process); •Predictability & Evenhandedness (equal protection, certiorari claims, etc.); and •Civility & Mutuality of Respect 7 5 Commit to Transparency •Honor the “openness” requirement of the Open Meetings Law (OML). Applies when 3 or more members of governing body “meet” to discuss “public business”. •A “meeting” is any kind of gathering convened to discuss public business, in person, by phone, electronically, or by other means of communication. •The “openness” rule is a “rule of three”, so what about one-on-one meetings? •Using email, etc.? Be cognizant of OML and Open Records Act (CORA) requirements. •Using social media? Be cognizant of risks and impacts; see https://www.cirsa.org/wp- content/uploads/2019/06/Social-Media-Use-by-Elected-Officials.pdf. 8 6 Transparency – Meeting Best Practices •Great meetings don’t happen by happenstance. Individually and collectively, commit to meeting best practices that build faith and trust in the governing body as an institution. •Have consistent procedures for handling common meeting items, such as public comment periods, procedures for Council deliberations, and the process for identifying future agenda items. •Use and embrace civility and mutuality of respect, no matter how difficult the circumstances. Recognize that tone and temperament matter, particularly for public officials in public settings. •Adopt and use simple rules of procedure—for example, Bob’s Rules as an alternative to Robert’s Rules—that will help facilitate, rather than debilitate, getting work done. 9 7 Organizational Structure & Liability •Another important risk management principle for everyone within the organization is to recognize and honor their role—it is important that everyone “swim in their lane” to avoid risks of liability, including the risk of personal liability! •You have protection from personal liability under Colorado Governmental Immunity Act (CGIA) if you are “within the scope of employment” and not acting “willfully and wantonly.” •Means everyone needs to know and respect their “job description.” •Conduct that is “outside the scope” or “willful and wanton” can result in a loss of governmental immunity and create liability, including the potential of personal liability for you. 10 8 Organizational Structure & Liability •Can also result in potential loss of insurance coverage. Public official liability (POL) policies follow “course and scope” and “willful and wanton” concepts. That is, they extend coverage to elected officials “in their capacity as such” (or similar) and have provisions excluding coverage where liability is based on willful & wanton conduct, etc. •The CGIA provides a form of qualified immunity, but it is not an absolute shield. Similarly, a federal form of qualified immunity protects government officials from liability for civil damages “insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” •Recognize that certain liability risks—in particular civil rights claims—can be exacerbated by “bad facts” that suggest (or are perceived to be based upon) retaliatory or reactive conduct. 11 9 Organizational Structure & Liability •Tips to support the structure and avoid concerns around “role discipline” and “scope”: •Respect the delegations of authority already made via your charter, ordinances and organizational structure. Those allocations work to serve and protect the City and the Council and its members, if honored. •Your role is a group role; if you are thinking of acting individually, ask whether you have authority to act (and if you don’t, don’t do it). •Recognize elected officials—”the legislative and governing body”—act primarily as a group and exercise responsibilities mainly by voting in a public meeting. •Therefore, think “We” ... not “I”! If you find yourself about to act in terms of “I” rather than “we” ...that’s a red flag. 12 10 Organizational Structure & Liability Where Does the City Council Focus its Efforts? Ownership | Governance | Management | Supervision | Front Line Employment Legislative and Corporate Governance is: •Policy-setting, big picture, and forward-looking, rather than dealing with day-to-day, and rather than making reactive, case-by-case decisions as issues arise, or after- the-fact. •Examples: General ordinances, annual budget, decisions regarding corporate assets, appointment of Council reports, corporate and quasi-judicial matters reserved to the Council. •The governing body should: •Have longest time horizon—looks down the road. •Have broad interests in mind. •Work together in their fiduciary role to protect the City as an entity and the Council as an institution. 13 11 Organizational Structure & Liability •From a risk management perspective, role discipline is particularly important in the areas of employee relations and administrative matters assigned to staff. Except for the Council’s direct reports, elected and appointed officials are not employee supervisors. Thus, •Don’t get individually and improperly involved in personnel issues, or in administrative matters, that have been assigned to staff. (Remember your Charter: Section 6.5 - Relationship of Council to Administrative Service.). •Such activities undermine your organizational structure, weaken the Council as an institution, impact morale, and can create risks for the City and for you individually. •Use your City Manager as your resource and point of contact. Support good “information flow” and as a Council commit to speak with one voice to your manager and other Council direct reports. 14 12 Organizational Structure & Liability •Commit to personnel conduct that strengths the WE - the governing body as an institution. This sometimes requires personal sacrifices, such as: •Setting aside a personal interest or agenda when there is lack of support. •Accepting “the Council has spoken” though one preferred a different outcome. •Accepting when “Our work is done”; i.e., the hand-off from Council → staff. •Recognizing that individual efforts—e.g., liaison and representative roles—are in service of the entity and governing body (the WE). •Avoiding perceptions (internal or external) of “getting ahead” of or “speaking for” the voice of Council where Council has not yet spoken. 15 13 Elected Official & Governing Body Liability Risks •Where do liability risks lie for elected officials and elected governing bodies? •Civil rights claims (e.g., First Amendment, Due Process, Equal Protection) •Employment practices – e.g. harassment, discrimination, retaliation •Alleged “willful & wanton” conduct (state law intentional torts) •Breach of ethics and/or fiduciary duty •Open meetings/open records laws •C.R.C.P. 106(a)(4) challenges to a “quasi-judicial” action of Council •Declaratory or injunctive relief claims arising from Council action; e.g., challenging an ordinance or some other action •Contract and quasi-contract claims •Takings and regulatory takings claims 16 14 Concluding Thoughts •While there are many aspects of risk management that municipalities and their elected officials cannot fully control—e.g., public perceptions, the actions of claimants, the inclinations of judges, the enactments of federal and state legislatures, etc.—embracing wise leadership in the areas we can control will support your success and reduce your risks. Some examples: •Committing to a “no surprises” approach. •Dealing honestly and effectively with discord. •Committing always to civility & mutuality of respect and to avoiding and/or effectively addressing “high conflict.” •Touting your governing body’s, your organization’s, and your staff’s successes—builds faith and trust that your government is getting good things done! •Committing to service of the City as an entity and the governing body as an institution, and embracing the fiduciary, stewardship, and “We” responsibilities of Council membership. 17 15 Resources CIRSA Elected Officials Handbook: https://www.cirsa.org/wp- content/uploads/2019/06/EthicsLiabilityBestPra cticesHandbookForElectedOfficials.pdf CIRSA Executive Director Tami Tanoue’s Webinar on Ethics, Liability, and Best Practices for Elected Officials: https://www.cirsa.org/wp- content/uploads/2020/05/Ethics-Liability-and- Best-Practices-Webinar-2020.mp4 CIRSA “Law of Civility” Presentation: https://www.cirsa.org/wp- content/uploads/2022/06/The-Law-of-Civility- Sam-Light.pdf. Other CIRSA elected and appointed officials’ resources: https://www.cirsa.org/safety- training/elected-officials/. 18 16 About the Colorado Intergovernmental Risk Sharing Agency (CIRSA) •Public entity self-insurance pool for property, liability, and workers’ compensation coverages. •Formed by in 1982 by 18 municipalities pursuant to CML study committee recommendations. •Not an insurance company, but an entity created by intergovernmental agreement of our members. •Total membership today stands at 287 member municipalities and affiliated legal entities •Member-owned, member-governed organization. •No profit motive – sole motive is to serve our members effectively and responsibly. •CIRSA Board made up entirely of municipal officials. •Seek to be continually responsive to the liability-related needs of our membership – coverages and associated risk management services, sample publications, training, and consultation services, as well as specialty services such as home rule charter review. •We have the largest concentration of liability-related experience and knowledge directly applicable to Colorado municipalities. 19 17 Speaker Bio Sam Light is Deputy Executive Director / General Counsel for the Colorado Intergovernmental Risk Sharing Agency (CIRSA). Previously, Mr. Light was a partner with the Denver law firm of Light | Kelly, P.C., specializing in municipal and other public entity law, insurance law and defense of public entities and elected officials. Sam is a frequent speaker on public entity risk issues and municipal law and has practiced in Colorado since 1993. 20 MEMORANDUM TO:Mayor and City Council FROM:Jenn Ooton, Senior Project Manager THROUGH:Sara Ott, City Manager MEMO DATE:March 5, 2024 MEETING DATE:March 18, 2024 RE:Boards and Commissions Expectations REQUEST OF COUNCIL: The March 18 work session will cover a range of topics related to open meetings, open records, and the expectations that Council has for its boards. SUMMARY AND BACKGROUND: This work session will cover three major topic areas: A presentation regarding Open Meetings and Open Records Laws by CIRSA, information about email transparency, and a conversation regarding Boards and Commissions. Boards and Commissions Expectations The third topic is a review of Council’s expectations for its advisory boards and commissions. City Council appoints local boards, commissions, task forces, and committees to advise on a wide range of policy issues. Boards and commissions provide in-depth examination of issues and a communication channel between elected officials and the community, bringing a broad range of ideas and expertise to public decision-making, assisting in the resolution of conflicts, and providing training for new leaders. Aspen's charter requires permanent boards and commissions, including advisory and appeal boards, to be created by ordinance, which also creates the policies and duties delegated to those boards and commissions. Temporary, ad hoc committees may be created by resolution. The Charter says that no member of the City Council, the mayor, any city employee, nor any appointed city official shall serve on any permanent board or commission heretofore established or hereafter established by council during his or her tenure as councilman, mayor, city employee, or appointed official. The city charter also specifies that a permanent board or commission member be a resident of the city for at least one year and be a qualified elector. It also provides a different term of residency — 2 years in Aspen or Pitkin County — for the board of appeals. The Aspen City Council creates new boards and commissions, fills vacancies, reappoints board and commission members, eliminates boards and commissions, and removes members of any board or commissions. There are currently 15 boards and commissions that are appointed by the Aspen City Council or with seats appointed by City Council. Of those, the majority are wholly appointed by Council. Considerations for Council: This work session is intended to gather direction from Council related to the ongoing work of boards and commissions, including on the topic of hybrid meetings, communication with and from these boards, and general best practices in governance for boards and commissions. 21 Governance There is not a single document that provides guidance for boards and commissions or their staff liaisons that addresses best practices for operating these boards. There are requirements for boards and commissions in their enacting ordinances, the municipal code, the city charter, and state Sunshine Law requirements. Quasi-judicial boards and commissions are governed by language in the Municipal Code and others are governed by ordinances, which do not appear in the code. These ordinances identify scope, number of board members, terms, membership criteria, requirements for a quorum, etc. A few of the boards and commissions also have bylaws or an operating charter that provide guidance for the way in which business is conducted. Staff believes that it is important to streamline information regarding board and commission guidance and to have a uniform set of guidance for the operation of these public bodies. Additionally, the city has created boards outside the governance of the city charter – by making boards non-permanent to allow for different rules for individual boards/commissions. Potential options for streamlining these procedures include: Creating an additional section of the municipal code that provides information regarding boards and commissions regarding the following: o Record keeping, noticing and other open meeting requirements – making it clear that Section 2.04.030 of the Municipal Code applies to these boards/public bodies regarding open meetings, notes and minutes; o Organization (including board duties, elections and terms of office); and, o Membership requirements (including residency requirements) This would allow for one-stop information for people looking for information about boards and commissions. Currently, only those boards that have a quasi-judicial function have this information codified. Staff has added the enacting ordinances for these boards and commissions onto the Aspen.gov website pages for the majority of the boards to make accessing information easier for the public. Establishing a uniform set of bylaws that would address order of business, clarify parliamentary procedures, election expectations for board officer positions, and public comment procedures. In addition, staff would recommend that bylaws address guidance for hybrid meetings if Council wants to provide specific direction on this topic. Currently this decision is at the discretion of the board chair in consultation with the staff liaison. Staff recommends that these bylaws provide guidance on whether there should be limits for the number of times per year any one board member may appear via online attendance and whether in-person attendance is expected for the chair of the meeting. Staff strongly recommends that the chair of the board be in person for quasi-judicial proceedings. Posing a city charter cleanup question to voters to modernize the governing document to represent the ways in which the city operates today. For example, the charter does not allow board members to sit on multiple boards, which is one reason that some boards have been established as “non-permanent”. Additional changes could be made, including allowing term limits, not requiring board members to be qualified electors or be residents of Aspen, and allowing staff to sit on boards. (For a time, members of staff were seated on the non-permanent grants steering committee). The Clerk’s Office reviewed its records and show that the following committees have members who live outside of Aspen: Grants Steering – 1 CCLC – 1 Kids First – 2 Wheeler – 6 ARC – 1 Communication and General Expectations 22 Council has not established direction regarding consistency in communication from boards and commissions, especially those that do not have specific decision-making authority and procedures outlined in the Municipal Code or the board is not appointed wholly by the Council. Council members at a recent Council work session indicated their deep appreciation for the many volunteers who serve on boards and commissions. During that discussion, it was also noted that feedback from these boards and commissions might not be making its way to Council members. Staff sent a questionnaire to board chairs for the city’s boards and commissions asking about communications, trainings and resources that the boards are lacking. Regarding ideas for better communication with Council, staff received the following comments: I think a regular cadence of info memos, with the option of council calling something up for a work session if they'd like to provide alternatives or formal direction. Perhaps having a Council member sit in on one of our meetings. Staff does an excellent job. It is also valuable to have committee members at council meetings when our business is discussed. Regular newsletter or email. They would benefit from understanding how to communicate with council and proper protocol Joint meetings I think our communication is good as is. The current arrangement works well. Having an occasional check in with the City Council might be beneficial. It's not always clear what information or recommendations are needed by Council. Similarly, it's not always clear what information is being brought back to council. If my board could have a better understanding of when Council is going to be discussing issues pertinent to [the specific board], we could provide more timely feedback. Regarding the question about resources or support that would enhance the effectiveness of boards and commissions, comments included a request for a clearer defined path for two-way communication with Council, additional training on Robert’s Rules of Order, and a general discussion of ethics. In January, Council started a new practice of having the Council members who represent the City of Aspen on the Aspen Pitkin County Housing Authority lead a discussion at the Council table to share what is happening at APCHA. This practice is expected to be ongoing. The Wheeler Board also presented to Council during a work session in early February. During this March 18 work session, staff would like to hear from Council what expectations it has regarding communication to and from these boards. Council could choose to have more meetings like these two examples above. Other options include holding a single meeting each year to hear from each board or commission chair about the work they are doing and to go over the work plan for the following year or for boards to provide regular written communication about their work to Council on an established basis. Additionally, there might be a mismatch of the work that some boards and commissions are focused on relative to the expressed written duties or expectations of Council. At the January 22, 2024, work session Council gave direction to decommission the Next Generation Advisory Commission. Are there other boards that Council would like to evaluate for decommissioning? Hybrid Meetings At the end of 2023, Council requested that staff provide information regarding hybrid meetings. Currently, only a few a few boards and commissions offer hybrid meetings, including the Kids First Advisory Board and the Wheeler Opera House Board. 23 Notably, there have been requests for a virtual option for the Planning & Zoning Commission (P&Z) and the Historic Preservation Commission (HPC). Pursuant to the City’s Land Use Code, both P&Z and HPC have the power to review and approve a number of development applications, including relocation of historic buildings, variances to design standards, and dimensional variances. Unlike advisory boards, these two boards in particular have decision-making authority. Consequently, projects before these boards often garner public attention, and, in some circumstances, generate both oral and written comments from members of the public. Requests for hybrid meetings have come from both members of the boards and members of the public wishing to provide public comment during meetings virtually. Because HPC and P&Z have final decision-making powers, in some instances an appeal of the decision may be filed directly with district court. If an appeal is taken, the City is required to produce a record of the proceedings, including a transcript of the proceedings if available. During COVID-19, many boards and commissions held all meetings virtually, and IT staff were present during those meetings to troubleshoot technical problems for both commissioners and public attendees. IT staff ensured that meetings were not disrupted, muting attendees speaking out of turn or who had background noise. IT staff also assisted with identifying members of the public calling in from a phone, ensuring staff were aware of who they were for purposes of providing public comment, and maintaining an accurate record of the names of those providing comments. Coming out of the pandemic both P&Z and HPC were given the option to continue with virtual meetings or return to in-person meetings. Hybrid meetings were not an option because IT staff was no longer available to provide assistance, and planning staff could not facilitate the meeting and provide IT assistance, manage background noise and disruption online, and assure that the Commissioners were visible on camera when speaking. Staff found that a dedicated and IT trained staff member was needed to monitor the Zoom room, troubleshoot technological issues with the physical meeting room and virtual platform, and ensure that all individuals and Commissioners were heard. Because an open Zoom meeting is vulnerable to “zoom bombing” where someone takes over the meeting picture and sound to disturb the proceedings, Zoom meetings for public meetings need to be held as webinars with only some of the virtual participants being allowed to share their screen and camera. This also requires a staff member to assist in moderation of the meeting, including allowing public comment for attendees who are not panelists. Accessibility New House Bill 24-1168 would require any public meetings of local public bodies to be accessible in real time through live streaming video or audio. It would also require the posting of any documents that would be distributed or discussed 24 hours before the meeting or as soon as practicable before the meeting. If the documents are not available to the public until distributed, they would need to be posted in real time during the public meeting. The legislation also requires that a public body provide any auxiliary aids to access the meeting for those who request them. Auxiliary aids or services are an aid or service that is used to provide information to an individual with cognitive, development, intellectual, neurological, or physical disability. This bill is expected to be heard in committee at the Legislature on March 20. Considerations for Hybrid Meetings For City Council meetings, an IT staff member arrives early to ensure that staff members who need to present their screen are in the meeting as panelists and staff throughout the meeting to ensure continuity of the meeting. 24 Staff recommends that additional staff be hired to support hybrid meetings. Specifically, P&Z and HPC meet an average of 4 hours a month with each meeting being two hours. In the case of these land use related meetings, additional support would be needed to conduct the meetings. Hiring for the mid-point of the salary range with benefits for an additional IT Support Technician would add $108,360 to the city’s budget. Staff would not recommend that Grassroots broadcast other boards and commission meetings due to the expense. Grassroots broadcasts City Council meetings and switches the cameras in the room to ensure that at home viewers are able to see who is speaking. The contract for Grassroots is $70,270 and is based upon 24 regular meetings and 72 work sessions – up to 4 hours each, gavel to gavel. Additional meetings are charged based on a fee schedule. DISCUSSION: This work session is intended to hear from Council related to priorities for boards and commissions. Staff recommends the following: As a first step, directing staff to develop consistent bylaws for all boards and commissions. That Council establish the expectations of boards and commissions communication with Council based on the options presented. Council determine whether all boards and commissions hold hybrid meetings. (Note: If the legislature passes HB 24-1168 as introduced, local governments would be required to ensure that the accessibility requirements are implemented by July 1, 2025.) FINANCIAL IMPACTS: The specific financial impacts will depend on additional staff members are needed to provide hybrid meetings and any needed software and hardware changes to allow for the hosting of hybrid meetings. Additionally, if Council chose to broadcast meetings through Grassroots, there would be additional costs associated with that support. CITY MANAGER COMMENTS: ATTACHMENTS CML Boards and Commissions Handbook HB 24-1168 Boards and Commissions information 25 BOARDS & COMMISSIONS HANDBOOK September 2018 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 26 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 27 TABLE OF CONTENTS Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 Scope of this handbook . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 Municipal Government Structure: An Overview . . . . . . . . . . . . . . . . . . . . . .3 The democratic heritage of municipal government . . . . . . . . . . . . . . .3 The role of the governing body . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 The role of the manager or administrator . . . . . . . . . . . . . . . . . . . . . . .3 The role of boards and commissions . . . . . . . . . . . . . . . . . . . . . . . . . .3 The role of the staff liaison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 Meeting Procedure Basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 General and legal requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 Rules of procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 Agenda . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 Conducting the meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 Involving the public . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9 Colorado’s Open Meetings Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Scope of the Open Meetings Law - “Local public bodies” and “meetings” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Providing notice of the meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 Minutes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 Executive sessions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 Penalties for violation of Open Meetings Law . . . . . . . . . . . . . . . . . .15 Ethics and Local Officials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Overview of state laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Amendment 41 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 Other issues and considerations regarding ethics . . . . . . . . . . . . . . .19 Sticky situations - Questions to ask . . . . . . . . . . . . . . . . . . . . . . . . . .20 Quisi-Judicial Decisions and Ex Parte Contact . . . . . . . . . . . . . . . . . . . . .22 What is an ex parte contact? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 Some Final Guideposts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 28 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 29 COLORADO MUNICIPAL LEAGUE 1 INTRODUCTION Congratulations! Your appointment to a board or commission in your city or town provides you with a valuable opportunity for public service, and your time and effort are appreciated. Although the specific duties assigned to the board or commission you serve on may vary, the information contained in this handbook will serve as a general guide to your new role . Scope of this handbook This handbook cannot address every subject that appointed board and commission members may face . Nor does this handbook claim there is any one best way for appointed board and commission members to perform their jobs . Instead, it is a compilation of the ideas and experiences of a large number of municipal officials from Colorado and other states, assembled here with the hope that it may offer both veteran and newly appointed officials the benefit of this perspective and experience. State statutes provide considerable detail on what municipalities can and cannot do . While this book does more than merely outline legal matters, much of the content is based on pertinent provisions of the state statute . This text is not intended as a substitute for study of the statutes or for competent legal counsel . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 30 2 BOARDS & COMMISSIONS This page intentionally left blank. Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 31 COLORADO MUNICIPAL LEAGUE 3 MUNICIPAL GOVERNMENT STRUCTURE: AN OVERVIEW The democratic heritage of municipal government Municipal officials, unlike their counterparts in federal and state offices, are in direct contact with the citizens they serve on a continuing basis . Citizens hold their local officials responsible for everything from the state of the local economy to whether the potholes in the streets need repairing . This is municipal government in action: a living demonstration that people who live together in a community can and want to solve their own problems . Colorado is home to 272 separate municipalities that range in population from fewer than 20 residents to more than 600,000 . Colorado cities and towns operate under provisions of Colorado state statutes (and are referred to as “statutory” cities and towns) unless voters adopt a municipal charter to become a “home rule” city or town . Home rule is based on the concept that the citizens of a municipality have the right to decide how their local government should be organized and how their local problems should be solved . Municipal home rule derives its authority directly from the Colorado Constitution . Home rule governance affords residents freedom from the need for state-enabling legislation and protection from state interference in both local and municipal matters . The role of the governing body Local governing bodies in Colorado may be in the form of an elected city council or board of trustees. Elected officials become caretakers of their community’s public life . The job of the municipal governing body is often stated simply: set public policy . The governing body sets the vision that reflects what they believe best represents their constituency’s interests and sets priorities for the municipality in order to develop this vision . One of the most important ways the governing body does this is through the adoption of an annual budget . The role of manager or administrator The city (or town) manager is the chief administrative officer of the city and is responsible directly to the city council for the performance of his or her duties .1 The manager directs the work of staff in implementing the vision set by the governing body . The role of boards and commissions Boards, commissions, and citizen committees provide the governing body with a great deal of assistance by recommending public policy and transforming policy decisions into action . Some boards or commissions are required or permitted by statute, while others are created by ordinance, resolution, or motion . Some are empowered to make administrative 1 C .R .S . § 31-4-211 . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 32 4 BOARDS & COMMISSIONS decisions, others can only make recommendations to the governing body, and still others are primarily fact-finding bodies. Some boards and commissions are permanently established, while others are established for a limited time to accomplish a single purpose and cease to exist once their functions are completed . Boards and commissions give the municipality an opportunity to leverage the talents of local specialists in certain fields and permit community members with special interests to serve the community in an area of personal concern . The first step to understanding a board or commission’s role in its municipality is to look at the original authority for the creation of the board or commission . This is found in a variety of places, such as the home rule charter or in ordinances or resolutions . In some cases (such as planning commissions), the authority is derived from state statute . The second step to understanding the role of a board or commission is to identify whether it is an advisory body or a decision-making body . Again, this information can be found in the enabling authority of the board or commission. Decision-making boards are those that have specific authority to rule on policy decisions . Some examples of this type of boards and commissions are planning commissions,2 liquor licensing authorities,3 and zoning boards of adjustment .4 Your municipal attorney is also a resource for clarifying your roles and responsibilities . The role of staff liaison Staff support is available to boards and commissions through the various staff members assigned as liaisons to help each group . The staff liaison may handle meeting logistics such as scheduling, setup, and public notification, as well as agenda preparation and distribution . The staff liaison is a great resource for any questions you may have . 2 C .R .S . § 31-23-202 .3 C .R .S . § 12-47-201, et seq .4 C .R .S . § 31-23-307 . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 33 COLORADO MUNICIPAL LEAGUE 5 MEETING PROCEDURE BASICS This section is an overview of the methods for conducting meetings of city and town boards and commissions . Please consult with your city or town staff for specific guidelines that may apply to the board or commission on which you serve . Legal considerations for conducting meetings under the Open Meetings Law are discussed later in this manual . General and legal requirements Regular, required meetings Regular meetings are those meetings of a municipal governing body, such as the city council or town board, that occur at fixed or established intervals . The statutes do not require either city or town boards or commissions to meet at regular intervals . However, a municipal code might set meeting requirements for certain or all boards and commissions . Attendance expectations and requirements vary and may be outlined in your municipality’s code or resolutions . For persons serving on boards and commissions, you may be interested in attending the regular meetings of your governing body in order to understand the policies and processes on which you are making recommendations and/or taking action . Your board or commission may also be asked to present your recommendations at a regular meeting of the governing body . Special meetings A special meeting of a municipal governing body is a separate session that is held at a time different from that of the regular meeting . Special meetings are convened most often to consider only one or two items of business that require the immediate action of the board or commission prior to the next regular meeting . The method for calling a special meeting, if permitted for a board or commission, is often prescribed by local ordinance . Rules of procedure Each board and commission should adopt a set of rules by which to operate . These rules can incorporate Robert’s Rules of Order5 or any other set of prepared rules, or simply be established by the governing body . Such rules guide the board or commission, make the process more stable and predictable, and reduce disputes concerning correct procedure . Meeting routine Most agenda formats may be divided into two categories: (1) procedural items of business that occur at most meetings (including the roll call, opening ceremonies, reading and approval of minutes, etc .) and (2) nonprocedural items of business that may vary from meeting to meeting . 5 Henry M . Robert, et al ., Robert’s Rules of Order Newly Revised (10th ed ., 1981) [hereinafter Roberts Rules of Order] . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 34 6 BOARDS & COMMISSIONS There is no “correct” organization or ordering of business, and state law requires no particular order be followed . Many cities and towns, however, have prescribed a local ordering of business, either by charter, ordinance, resolution, or the body’s rules of procedure . While variations on the order of business abound, a fairly common order might look like this: • Call to order • Roll call • Reading and approval of minutes • Public comments • Reports from officers or municipal staff • Public hearings, final reading and voting • Unfinished business • New business • Extended public hearings • Adjournment Agenda A meeting’s agenda is the statement of the purpose for the meeting and the basis of all other planning . A written copy of the agenda often is prepared and distributed to board or commission members and other interested persons to inform them of the specific items of business that will be considered at a meeting . While the municipal staff often prepares the agenda, this responsibility varies from municipality to municipality and is usually set by the governing body . Agenda analysis (Are meetings too long?) An agenda should include only as many items of business as can be considered in the time allotted for the meeting . If there are 32 items on the agenda and each item is estimated to take “only” 10 minutes, the board or commission is in store for a six-hour meeting . Reducing the number of items placed on the agenda is often a difficult task. Some ideas to eliminate or consolidate agenda items are: • A specific type of decision may be handled by staff with a brief summary report being made to the board or commission from time to time . • The board or commission may establish policies to handle reoccurring decisions, then direct staff members to follow the policy . • The board or commission may evaluate whether items are being postponed to future meetings when they could be dealt with at the present meeting . While decisions should not be made in a casual or hasty manner, board and commission members should resist postponing items in the hope that, at the next meeting, a whole new set of facts will surface and make the decision easier . Delay, when Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 35 COLORADO MUNICIPAL LEAGUE 7 it results in a better decision, is commendable; but delay, so that an official does not have to act on a sticky question, may be inefficient and irresponsible . • The board or commission may set definite times for the meeting to come to order and to adjourn . Few board or commission meetings achieve much of value after four hours, and two hours is usually enough time to allocate for most meetings . Time limits also may be set for special hearings that are not required by law, for citizen participation periods and for the debate by board and commission members . Conducting the meeting Quorum Before a body, such as a board or commission, may proceed to its first item of business, the presiding officer must determine that a quorum is present. A quorum is a majority of all the members of the body and it is a number that, if present, is sufficient to transact most government business. In the absence of a quorum, any business transacted and actions taken by the body will be null and void . In fact, the only action that may be taken by a board or commission in the absence of a quorum is a motion to adjourn . The presiding officer The presiding officer, often referred to as “the chair,” is the director and leader of any meeting of the municipal body. It is the presiding officer’s responsibility to see that the meeting moves forward in an orderly fashion, that discussion is guided and controlled, and that the meeting runs as smoothly as possible. For a board or commission, a similar presiding officer is necessary to lead the smooth process of business . The success of presiding officers may depend upon their ability to remain impartial and to keep business moving . Frequent displays of partisanship or favoritism risk destroying members’ and citizens’ respect for the presiding officer. Agenda item discussion While there are several approaches to agenda item discussion and no single “right” way to conduct the discussion, one possible format follows: 1. The presiding officer should announce the agenda item and briefly describe the subject to be discussed . 2. The presiding officer should invite the appropriate people to report on the item and provide recommendations . The report may come from a member of the board or commission, municipal staff, or a member of the public invited by the board or commission to provide information on the item . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 36 8 BOARDS & COMMISSIONS 3. The presiding officer should then open the agenda item to the board or commission to ask questions . 4. If appropriate, the presiding officer may invite public comments after the board or commission has had the opportunity to ask their questions about the agenda item . More information on involving the public is available in the section, “Involving the public .” 5 . Once the public comment period (if applicable) is over, the presiding officer can request a motion to be made from a member of the board or commission . A second is typically required to ensure that more than one person on the board or commission is in agreement with the motion before the question is posed to the rest of the body for a vote. The presiding officer may wish to announce who made the motion and the second for purposes of meeting minutes . 6. Once the motion has been made and seconded, the presiding officer can entertain debate from the board or commission . If little or no discussion takes place, the presiding officer can proceed directly to the vote. If the discussion is lengthier, the presiding officer may wish to restate the motion to be sure that everyone understands the question before them prior to taking a vote . 7. After closing the discussion, the presiding officer calls for a vote. The vote typically involves asking for the “ayes” and then the “nays .” Unless specific legal provisions require a super majority, a simple majority is all that is needed to pass a motion. The presiding officer announces the results of the vote and may note the dissenting votes for the purpose of meeting minutes . Motions in a nutshell Motions are vehicles for decision-making . There are three basic types of motions: • The basic motion. The basic motion is the one that puts forward a decision for consideration . A basic motion might be: “I move that we create a five-member committee to plan our annual fundraiser.” • The motion to amend. If a member wants to change a basic motion under discussion, he or she would move to amend it . A motion to amend might be: “I move that we amend the motion to have a 10-member committee .” • The substitute motion. If a member wants to completely do away with the basic motion under discussion and put a new motion before the governing body, that member would “move a substitute motion .” A substitute motion might be: “I move a substitute motion that we cancel the annual fundraiser this year .” Other types of motions Beyond the basic motions listed above, there are other types of motions that are used on occasion during meetings . For more information about the types Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 37 COLORADO MUNICIPAL LEAGUE 9 of motions and examples, please refer to Robert’s Rules of Order, Newly Revised . Involving the public Each board or commission may afford members of the public an opportunity to speak to any matter coming within the purview of the board or commission . The board or commission may impose time limitations on such public input as necessary to conduct the business of the meeting in a timely and efficient manner. The method by which citizens are allowed to speak at a board or commission meeting varies from community to community, and the procedures may be established by ordinance, resolution, rule, or tradition . It is important to ensure that the ground rules of the meeting are known to all, not just the chair . Remember that some of the public participants are first-time visitors and some may have never participated in a professional meeting before . Methods of allowing public comment include: • Allowing the public to comment at any time throughout the meeting as long as their comments are restricted to the agenda item currently under consideration . • Allowing a specific period during which the public is invited to speak on matters listed on the agenda . • Allowing a specific period during which the public is invited to speak on any matter other than those listed on the agenda . This method is often used in combination with one of the two previous methods . When a board or commission holds a public comment period, it must consider certain issues: How quickly will the commission or board respond to a citizen’s request? Will any discussion be allowed? For example, if a citizen brings a request for a drainage improvement on his or her property, will discussion of this concern occur? Public hearings A public hearing is any meeting or portion of a meeting of a body, such as the town board or commission, at which members of the public are given the opportunity to speak on specific matters on the agenda for hearing. As such, public hearings are distinguished from citizen participation or public comment . Some public hearings are required by law . The board or commission cannot make a decision until it has concluded public hearing on the matter . No public hearing can be successful unless the people attending the hearing understand the issues to be discussed . The following recommendations can promote orderly public participation during a public hearing . • Establish rules of procedure before the hearing and read them at the beginning of the hearing so that everyone understands how the hearing will be conducted . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 38 10 BOARDS & COMMISSIONS • Announce that issues will be considered in the order listed on the agenda . • Ask anyone who wishes to speak at the hearing to register or otherwise sign-up to help keep track of comments and the persons making those comments for the public record . • Set time limits on how long speakers can talk and apply the limits on every person who speaks . • Allow each person who wishes to speak a chance to do so before allowing a second round of comments . • To clarify for the audience and the public record, ask each speaker to begin by stating his or her name and address, any group being represented, if any, and how many people he or she represents . • Establish ahead of time whether board or commission members or other participants at the hearing will be allowed to ask questions of a speaker after his or her presentation . • State that disruptive behavior will not be tolerated . When a large number of citizens attend a meeting to speak about an issue, there are a number of strategies to ensure that everyone’s opinion is heard without unduly lengthening the meeting. The presiding officer can ask the citizens to sign in either “for” or “against” the particular issue at hand, and then request a representative from each group to speak on behalf of the others . The body may also simply ask members in the audience who are in agreement with the speaker to stand and acknowledge that fact in lieu of speaking. Additionally, the presiding officer can set shorter time limits per speaker . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 39 COLORADO MUNICIPAL LEAGUE 11 COLORADO’S OPEN MEETINGS LAW All 50 states, as well as the federal government, have enacted a variation of a “Sunshine Law,” requiring certain proceedings of government agencies to be open to the public . This section will answer the most common questions concerning the requirements of Colorado’s Open Meetings Law: • Who is covered? • What is a “meeting”? • When are “executive sessions” permitted? • What advance notice of a meeting is required? • What exemptions are there? • What happens to those who violate the law? Scope of the Open Meetings Law — “Local public bodies” and “meetings” Put simply, the Open Meetings Law declares that whenever three or more members (or a quorum of the members, if fewer than three) of the “local public body” get together and public business is discussed or formal action may be taken, the gathering is a “meeting” and must be open to the public .6 What is a “local public body”? The Open Meetings Law defines a “local public body” to include political subdivisions of the state, such as municipalities, and any other formally constituted body of the political subdivision that performs an advisory, policymaking, or rulemaking role .7 This definition, by its terms, includes boards, committees, commissions and authorities of the municipality . However, “persons on the administrative staff” of a local public body are specifically excluded.8 What constitutes a “meeting”? The statute broadly defines a “meeting” as “any kind of gathering, convened to discuss public business, in person, by telephone, electronically, or by other means of communication .”9 Conversely, chance meetings of public officials, or social gatherings at which discussion of public business is not the “central purpose,” are not subject to the provisions of the Open Meetings Law .10 However, be aware that a chance meeting may develop into a problem if you have a quorum of the body in attendance and the conversation turns to official matters. 6 C .R .S . § 24-6-402(2)(b) .7 C .R .S . § 24-6-402(1)(a)(i) .8 C .R .S . § 24-6-402(1)(a)(i) .9 C .R .S . § 24-6-402(1)(b) .10 C .R .S .§ 24-6-402(2)(e) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 40 12 BOARDS & COMMISSIONS Meetings conducted by “telephone, electronically, or by other means of communication” The General Assembly has included electronic, as well as “other means” of communication under the statutory definition of “meeting.”11 The Open Meetings Law now explicitly subjects the e-mail communication of elected officials to the statutory requirements if it includes discussion of pending legislation or other public business .12 What this means is that the open meetings requirements apply to your board and commission, regardless of the manner in which the meeting is held . For example, if a discussion of official matters unfolds over email and a quorum of the body is included on the email, the open public meetings requirements apply .13 Retreats Under the expansive definition of “meeting” in the statute, “any kind of gathering” that is held to discuss public business may qualify . Thus, if the retreat is attended by three or more members of the local public body, or by a quorum of the body (if fewer than three), and public business is discussed, the retreat qualifies as an open meeting to which requirements for notice apply .14 Of course, an unlimited number of administrative staff members may attend the retreat, due to the specific exclusion of administrative staff from the “local public body” definition.15 Providing notice of the meeting The public cannot exercise its right to attend open meetings unless given sufficient notice. Therefore, the Open Meetings Law requires that the public receive “full and timely notice” of any meeting held, and the posting shall include specific agenda information where possible.16 “Full and timely” notice The statute does not explicitly specify or limit what may constitute “full and timely notice .” The statute does, however, indicate that a meeting notice must be posted in the designated public place no less than twenty-four hours before the meeting .17 The courts have found that the notice provisions of the Open Meetings Law establish a “flexible standard,” the requirements 11 C .R .S . § 24-6-402(1)(b) A meeting is also described in the context of email communications, is presumed by many municipal attorneys to imply that such email communications must occur in a “chat room” format or otherwise be contemporaneous, in order to constitute a “meeting .” At this writing, however, no Colorado court decision had adopted this presumption .12 C .R .S . § 24-6-402(2)(d)(III) This requirement presents numerous potential practical problems for local government officials seeking to comply with the openness, notice, and other requirements of the Open Meetings Law, in the email context . Close consultation with the municipal attorney is advised .13 However, electronic mail communication among elected officials that does not relate to pending legislation or other public business is not considered a meeting . C .R .S . § 24-6-402(2)(d)(III) .14 C .R .S . § 24-6-402(2)(c) .15 C .R .S .§ 24-6-402(1)(a) .16 C .R .S . § 24-6-402(2)(c),17 C .R .S . § 24-6-402(2)(c) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 41 COLORADO MUNICIPAL LEAGUE 13 of which may vary depending on the particular type of meeting involved .18 However, the statute requires the local public body to designate the public place where the body will post notice at its first regular meeting each year.19 Emergency meetings Unlike similar statutes from other states, the Colorado Open Meetings Law contains no reference to emergency meetings, which by their very nature present a challenge in terms of public notice . The Colorado Court of Appeals has recognized the need for municipalities to hold emergency meetings on occasion, and has upheld an ordinance providing for such meetings without prior public notice, where action taken would be ratified at a subsequent public meeting for which full and timely notice is provided .20 The court defined an emergency as “an unforeseen combination of circumstances or the resulting state that calls for immediate action,”21 and acknowledged that the notice requirement may be affected by the type of meeting involved .22 While this decision finds no conflict between a local emergency meeting ordinance and the Open Meetings Law, officials should remain mindful of the law’s intent and give as much notice as possible under the circumstances . Direct notification requirements The Open Meetings Law contains a provision requiring the clerk to maintain a list of persons who have requested, within the previous two years, direct notification of meetings, whether the request be for all meetings or only when certain specified policies will be discussed.23 The clerk is required to provide these persons with “reasonable advance notice” of such meetings, but the statute does not specify what sort of notice or what time frame will be considered reasonable .24 Further, unintentional failure to give this direct notification will not invalidate actions taken at an otherwise properly published meeting .25 Minutes The clerk, or other official in the clerk’s absence, must take the minutes of any meeting of the local body “at which the adoption of any proposed policy, position, resolution, rule, regulation, or formal action occurs or could occur .”26 After the meeting, the minutes must be promptly recorded and are considered a public record open to inspection .27 18 Town of Marble v. Darien, 181 P .3d 1148 (Colo . 2008) (citing Benson v . McCormick , 578 P .2d 651, 653 (Colo . 1978)); VanAlstyne v. Housing Auth. of the City of Pueblo, 985 P .2d 97, 100 (Colo . App . 1999) .19 C .R .S . § 24-6-402(2)(c) .20 Lewis v. Town of Nederland, 934 P .2d 848 (Colo . App . 1997); but see VanAlstyne v. Housing Auth. of the City of Pueblo, as to the limits of subsequent ratification of action taken in prior non-emergency meeting held without proper notice .21 Lewis v. Town of Nederland, 934 P .2d 848, 851 (Colo . App . 1997) (quoting Webster’s Third New International Dictionary 741 (1986)) .22 Lewis v. Town of Nederland, 934 P .2d 848, 851 (Colo . App . 1997) .23 C .R .S . § 24-6-402(7) .24 C .R .S . § 24-6-402(7) .25 C .R .S . § 24-6-402(7) .26 C .R .S . § 24-6-402(2)(d)(II) .27 C .R .S . § 24-6-402(2)(d)(II) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 42 14 BOARDS & COMMISSIONS Executive sessions Because the underlying principle of the Open Meetings Law is that the formation of public policy is public business, and therefore cannot be conducted in secret, the exceptions provided by statute are limited and strictly tailored to situations where the General Assembly has determined that public discussion could be contrary to the public interest . Topics of executive sessions The statutes limit these private meetings, referred to as “executive sessions,” to the following situations: • the purchase, sale, or lease of real and personal property; • attorney conferences; • confidential matters under state or federal law; • security arrangements or investigations; • negotiations; • personnel matters; and • documents protected under Open Records Act . Procedure for calling an executive session Local government bodies may only call an executive session at a regular or special meeting .28 While the Open Meetings Law requires “full and timely notice” of the regular or special meeting, there is no notice requirement that would impair the body from spontaneously calling an executive session during one of its meetings . The local government body must first announce the topic of discussion, including the specific citation to the Open Meetings Law that authorizes consideration of the announced topic in executive session, as well as identify the particular matter to be discussed in as much detail as possible without compromising the purpose for which the executive session is authorized, and then vote on whether to hold the session for the purpose of discussing only the topic announced . Two-thirds of the quorum present must vote affirmatively before the local government body can close the meeting to the public .29 The local government body cannot utilize the open meeting to simply “rubber stamp” the position adopted by it while in executive session .30 The public cannot “participate in a public meeting if [it] witnesses only the final recorded vote .”31 28 C .R .S . § 24-6-402(4) .29 C .R .S . § 24-6-402(4) .30 Littleton Educ, Ass’n v. Arapahoe Cty Sch. Dist . No . 6, 553 P .2d 793, 798 (Colo . 1976); Bagby v . Sch . Dist . No . 1, 528 P .2d 1299, 1302 (Colo . 1974); Hudspeth v. Bd. of Cty. Comm’rs of Routt Cty ., 667 P .2d 775 (Colo . App . 1983) .31 Bagby v. Sch. Dist. No.1, Denver, 528 P .2d 1299, 1302 (Colo . 1974) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 43 COLORADO MUNICIPAL LEAGUE 15 The executive session record The Open Meetings Law requires that an electronic record be made of an executive session of a local public body,32 unless the attorney representing the local public body (who must be in attendance) determines that the attorney-client privilege applies to the executive session .33 The law requires that executive session records reflect the “actual contents” of the discussion during the session, as well as the citation to the specific provision of the Open Meetings Law that authorizes the session . If a written record is used, the record must include a signed statement by the person presiding over the session attesting that the minutes “substantially reflect the substance” of the discussion that took place . The executive session record must be retained for at least 90 days following the date of the executive session .34 Penalties for violation of Open Meetings Law The underlying goal of the Open Meetings Law is to create an atmosphere of openness in public matters, not to “punish” those who violate the provisions . In keeping with this prevailing philosophy, the Colorado law contains no criminal sanctions for noncompliance . Although members of governing bodies do not risk criminal punishment for transgressions, there are other consequences: • Any action taken at a meeting that does not comply with the Open Meetings Law requirements is void .35 • If the court finds that a public body has violated the Open Meetings Law, it must award the prevailing citizen or citizens costs and reasonable attorney fees .36 • There is also the potential for a serious loss of confidence in the government when official actions are invalidated because laws aimed at assuring open government are violated . 32 C .R .S . § 24-6-402(2)(d .5)(II)(A) .33 C .R .S . § 24-6-402(2)(d .5)(II)(B) . There is also an exception for electronic recordings of executive sessions discussing individual students . C .R .S . § 24-6-402(2)(d .5)(II)(A), C .R .S . § 24-6-402(4)(h) .34 C .R .S . § 24-6-402(2)(d .5)(II)(E) .35 C .R .S . § 24-6-402(8); See Gray v. City of Manitou Springs, 598 P .2d 527, 529 (Colo . App . 1979) .36 C .R .S . § 24-72-204(5 .5) . Furthermore, this award does not require that the violation be “knowing and intentional .” Zubeck v. El Paso Cty. Retirement Plan, 961 P .2d 597, 601-602 (Colo . App . 1998) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 44 16 BOARDS & COMMISSIONS ETHICS AND LOCAL OFFICIALS Overview of state laws The Colorado Constitution, state statutes, and oftentimes local charters and ordinances have provisions relating to ethical principles and conflicts of interest . While this section provides an orientation to laws governing ethics, the state conflict of interest statutes are subject to varied interpretations and particular applications, depending on the facts of the situation . For home-rule municipalities with local provisions that may conflict with state provisions, a legal question may arise over which law controls . If you believe your conduct may be affected by any of the state laws we describe, your best course of action is to seek the guidance of your municipal attorney . Ethics laws that apply to local government officials, including members of boards and commissions, can be found in three separate sections of the Colorado Revised Statutes37 as well in Article 29 of the State Constitution (sometimes referred to as Amendment 41) . Colorado “Code of Ethics” The Colorado Code of Ethics38 identifies several rules of conduct for local government officials, which includes boards and commissions, as well as local government employees . The following are explicitly prohibited: • using confidential information for personal benefit; • accepting gifts or economic benefits as rewards or inducements; • transacting business with those one supervises or inspects; • acting to benefit one’s business or client; and • taking a personal or business interest in municipal contracts . Exclusions from the Colorado “Code of Ethics” The code provides that it is not a breach of fiduciary duty or the public trust for a local government official or employee to: • use local government facilities or equipment to communicate with constituents, family members or business associates, (as long as the use of these facilities is not otherwise prohibited, such as for campaign purposes), or • accept or receive benefits as an indirect consequence of transacting local government business .39 37 C .R .S . §24-18-101, et seq .; C .R .S . § 31-4-404; C .R .S . § 18-8-308 .38 C .R .S . § 24-18-101, et seq .39 C .R .S . § 24-18-109(4) . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 45 COLORADO MUNICIPAL LEAGUE 17 The municipal “disclosure and abstention” statute The disclosure of conflicts of interest and abstention from voting rules are found at C .R .S . § 31-4-404(2) and (3) . These statutory provisions require that a member of the governing body of a city or town who has a “personal or private” interest in any matter proposed or pending before the governing body shall: • disclose such interest to the governing body, • not vote, and • not attempt to influence the votes of other members of the governing body .40 However, a member of the governing body may vote notwithstanding his or her personal or private interest if: • the member’s participation is necessary to achieve a quorum or otherwise enable the body to act, and • disclosure prior to official activity is made pursuant to the voluntary disclosure provision of the Code of Ethics .41 Board and commission members should avoid voting on matters in which they may have a conflict of interest, as well as avoid attempting to influence other members on those matters. Such conflicts should be properly disclosed . If a situation like this arises, consult with your municipal attorney . Colorado Criminal Code The Colorado Criminal Code contains additional disclosure requirements affecting local government officials and employees. The disclosure requirement is triggered when a local government official has a “known potential conflicting interest” affected by an impending exercise of a “substantially discretionary function with respect to a government contract, purchase, payment, or other pecuniary transaction .”42 The code provision requires disclosure in writing to the Secretary of State 72 hours before any action is taken . Voluntary disclosure Section 24-18-110 provides for voluntary disclosure by a local government official or employee of the “nature of his private interest” prior to acting in a manner that may impinge upon fiduciary duty and the public trust. The statute provides that such disclosure will be a defense for the local official in any civil or criminal action, or against “any sanction .” Note that this defense is for the individual; it does not protect the official action tainted by a conflict from being voided, if otherwise voidable . 40 C .R .S . § 31-4-404(2) .41 C .R .S . § 31-4-404(3) .42 C .R .S . § 18-8-308 . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 46 18 BOARDS & COMMISSIONS Proper disclosure requires the disclosure to be in writing and delivered to the Secretary of State . Disclosure should include the following elements: • amount of financial interest, if any; • purpose and duration of services rendered, if any; • compensation received for services; or • “such other information as is necessary to describe” the interest . If the act is then performed, the official or employee shall state for the record the fact and nature of the interest involved . Amendment 41 At the statewide general election in November 2006, the voters of Colorado adopted Amendment 41, which added a new Article (XXIX) to the state Constitution . The amendment’s language, which is couched in very broad terms, limits receipt of gifts exceeding $50 (subject to inflation; the 2018 amount is $59)43 from any particular donor in a given year by municipal municipal employees and officials, among others. This broad language has spawned efforts within the legislature and the courts to define the practical reach of Amendment 41 . Amendment 41 provides for creation of an Independent Ethics Commission (IEC) and empowers the IEC to issue “advisory opinions” on ethics issues arising under the Amendment . The Commission has provided guidance on gifts that would not qualify as having substantial value, including: • Unsolicited gifts of trivial value; • Gifts valued less than $59 (and not given by a lobbyist); • Gifts from relatives and friends for special occasions; • Inheritances; • Expense reimbursements; • Campaign contributions; • Scholarships; • Honoraria for public speaking engagements; and • Prizes, raffles, lotteries, etc. The IEC’s position statement clarifying acceptable gifts is available on the its website at www.colorado.gov/pacific/sites/default/files/ PositionStatement_08-01_IEC.pdf . As a reminder, the guidelines presented here are those declared by the IEC; your municipality may have local regulations prohibiting certain gifts for board and commission members . 43 The gift limit was originally $50, adjusted every four years for inflation and is $59 as of the date of this publication . However, $53 is the amount listed in the implementing statute because it has not yet been updated . See Colorado Independent Ethics Commission, Ethics Handbook (2016), www.colorado.gov/pacific/sites/default/files/IEC_Ethics_Handbook_2016.pdf. Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 47 COLORADO MUNICIPAL LEAGUE 19 Other issues and considerations regarding ethics In addition to legal requirements, a number of other laws, principles, and related issues involve ethics for municipal officials. Nonbinding ethical “principles” in the Colorado State Statutes Colorado statute44 provides “ethical principles” that are intended to provide supplemental guidance for ethical behavior . The statute provides: The principles in this section are intended as guides to conduct and do not constitute violations as such of the public trust of office or employment in state or local government . A public officer, a local government official, or an employee should not acquire or hold an interest in any business or undertaking which he has reason to believe may be directly and substantially affected to its economic benefit by official action to be taken by an agency over which he has substantive authority . A public officer, a local government official, or an employee should not, within six months following the termination of his office or employment, obtain employment in which he will take direct advantage, unavailable to others, of matters with which he was directly involved during his term of employment . These matters include rules, other than rules of general application, which he actively helped to formulate, and applications, claims, or contested cases in the consideration of which he was an active participant . A public officer, a local government official, or an employee should not perform an official act directly and substantially affecting a business or other undertaking to its economic detriment when he has a substantial financial interest in a competing firm or undertaking. Nepotism and cronyism Nepotism is commonly defined as “favoritism (as in appointment to a job) based on kinship .” Cronyism is “partiality to cronies especially as evidenced in the appointment of political hangers-on to office without regard to their qualifications.” While neither cronyism nor nepotism is specifically prohibited by Colorado law, some local governments in Colorado have taken the initiative to pass their own anti-nepotism ordinances . However, even absent express prohibitions on cronyism or nepotism, municipal officials should be aware that there may be times when disclosure and abstention from voting on matters that directly concern their relations, close friends, or financial or political supporters may be desirable . Board and commission members at times excuse themselves from votes regarding these matters to avoid the potential appearance of impropriety . If a situation like this arises, consult with your municipal attorney . 44 C .R .S . § 24-18-105 . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 48 20 BOARDS & COMMISSIONS Expectations of your community It is important to note that laws are limited in their ability to provide guidance for every situation you encounter . While an action may be legal, it may not necessarily be ethical or viewed by the public as ethical behavior . As many popular references suggest, laws should be regarded as a floor for ethical behavior, not a ceiling . The public may not be aware of all the laws that apply to your position as a public official; nonetheless they will have expectations of your behavior and will hold you to a high standard— regardless of the law . What the public expects from public officials: • honesty; • decisions that put the community first, rather than the interests of the individual public official; • an open, impartial and fair decision-making process; • respect for individual rights and community rights; • accountability; • forthrightness; • decorum and professionalism; and • personal character and lawful personal behavior . Sticky situations — Questions to ask Unfortunately, not all of our questions involving ethics are black and white or addressed clearly in the laws. When you are faced with a difficult ethical question, it may be helpful to ask yourself the following questions: 1. What does the law require in this situation? The law should be considered a minimum standard for ethical conduct . It can and should be a starting point for your decisions . 2. What does our own municipal ethics code require in this situation? If your city or town has a locally adopted ethics code, make sure you understand it and apply it to your decisions . Like state laws, local ethics codes always should be considered a floor for your decisions, not a ceiling . 3. Is this a right vs. wrong situation? Is the issue simply that doing the “right” thing involves significant personal cost? Remember, your responsibility is to do the right thing for your community, regardless of personal cost . Ethics and the associated legal requirements are written to avoid improper conduct, not to serve as an excuse for avoiding politically difficult decisions. 4. Would I be embarrassed to read about my actions in the local newspaper? This is a simple “self-test,” but can be very useful in clarifying a sticky situation! Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 49 COLORADO MUNICIPAL LEAGUE 21 5. Which decision will build or preserve the most public confidence in our municipality and the leadership of this governing body? The public expects you to base your conduct on the highest standards — even the appearance or perception of unethical behavior can test the public’s confidence in your leadership. 6. Which decision is most consistent with my values? Is it fair? Compassionate? Respectful of all parties involved? Am I keeping my word? 7. Does this decision represent the interests of everyone in my community? Are there other stakeholders or members of the public who should be heard before this decision is made? Keeping your procedures open and accessible to the public not only ensures that everyone has an opportunity to be heard, but also that you make the best decisions for your community . 8. Does this decision involve conflicting values? If so, what are the facts? Is there a decision that best reflects my responsibility to the community as a whole? Does this decision do more good than harm? Is there something we can do to make this decision more fair and equitable? Sometimes, no matter what you do, there will be someone in your community who disagrees with your decision . However, if you have carefully thought through all of these considerations, you can be assured that you have done everything possible to ensure a fair — and ethical — decision . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 50 22 BOARDS & COMMISSIONS QUASI-JUDICIAL DECISIONS AND EX PARTE CONTACT A quasi-judicial decision occurs when a non-judicial body interprets the law to make a decision . Boards and commissions do not always make quasi- judicial decisions, but in certain circumstances they may . Quasi-judicial decisions involve the implementation of a previously adopted policy, rather than the declaration of new policy . When a board acts as a quasi-judicial body, it is important for the board’s members to avoid ex parte contact . What is an ex parte contact? Broadly defined, an ex parte contact is any written or verbal communication initiated outside of a regularly noticed public hearing between an official with decision-making authority and one or more of the parties, but not all of the parties, concerning a particular subject matter that is under, or that is about to become under, consideration by that official, and that seeks either to influence, or present information relating to, that matter which is the subject of the decision . The term is usually used in a courtroom context: the judge cannot discuss a case with either party or their attorney without the other party and the attorney being present . The term is equally applicable to any quasi-judicial matter pending before a local governmental body; including a board or commission with quasi-judicial authority . An ex parte contact includes discussing an upcoming hearing or decision with the applicant or the party protesting the application . Why are ex parte contacts before making a quasi-judicial decision improper? • All parties are entitled to have the matter heard by an impartial person or body . At the very least, ex parte contacts, whether the contacting person is an applicant or a protestant, call into question the impartiality of the decision maker . • Every quasi-judicial decision must be supported by findings of fact, and the findings of fact must be based solely upon the evidence as it appears in the record of the proceeding . The record of the proceedings consists only of matters presented at the hearing, not anything presented before or after the hearing . Therefore, to have a defensible record, only evidence presented during the hearing, on the record of the hearing, may be relied upon in reaching the body’s decision . • In some instances, the parties have the right of cross-examination of the opposing side . They cannot cross-examine an ex parte contact . • In the event one party challenges the final decision, you can be sure any ex parte communications will be included as one of the grounds for reversing the decision . What do I do if someone attempts to contact me before a hearing? • Stop the person . If it is a verbal contact, advise the person that you are sitting as a judge in the matter and you cannot listen to or review anything about the issue prior to the hearing . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 51 COLORADO MUNICIPAL LEAGUE 23 • Disclose the contact . At the next public meeting or prior to the hearing on the public record, advise the remaining members of the board and the parties regarding the contact, your response, and whether or not you think you can make an impartial decision based on the evidence presented at the hearing despite the contact . • Consider whether the ex parte contact requires abstention . An ex parte contact, by itself, is usually not enough to reverse the final decision or require you to abstain from voting on the issue . Each individual contact must be reviewed to determine whether it affects your impartiality or ability to consider the matter fairly, whether it creates an appearance of impropriety, whether it creates a conflict such that you cannot participate in the decision-making process, or whether it otherwise affects the rights of the parties seeking the decision to “fundamental fairness” or due process in the decision- making proceedings . • Consider adopting formal procedures. It is difficult to tell a neighbor or a constituent that you cannot talk to them about an issue that may be very important to them . Very often constituents are unable to understand why they cannot speak about particular issues to those that have been elected or appointed to represent those constituents . It may help to have specific procedures that the governing body or the planning commission has adopted that you can point to as the reason you cannot handle a quasi-judicial issue in the same manner as you do other legislative or administrative issues . This will also help to make sure all board members handle ex parte contacts in the same manner . At the very least, ex parte contact can give the appearance of impropriety . At worst, ex parte contact may be grounds for reversal of a decision, a lawsuit, charges of undue influence or coercion, or bribery. Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 52 24 BOARDS & COMMISSIONS SOME FINAL GUIDEPOSTS Municipal government is a team operation . There are many sources of information about municipal government available to members of boards and commissions . The publications, information, and services of the Colorado Municipal League, meetings, institutes and conferences for municipal officials, and journals of the various professional associations of municipal officers and employees all provide basic information about the many problems and activities of municipal government . In addition, there are specialists and professional consultants who can help with technical problems . Remember, however, that these persons are advisers and that the policy decisions should be left to the board or commission member . No state law, handbook or any other guide can adequately outline the board or commission member’s role in the governmental process . Yet, members of boards and commissions have a real responsibility to the citizens . Members of boards and commissions are the trustees and custodians of the privilege of local self-government in this country, and the individual member, regardless of the size of the municipality, is engaged in the vital process of making American democracy work . Resources Acknowledgements Many thanks to the City of Commerce City and the City of Fort Collins for providing their Boards and Commissions Manuals as sources of information for this handbook . CML also thanks former Aurora Deputy City Clerk Karen Goldman for her valuable feedback and edits . Related CML publications Colorado Municipal Government: An Introduction Open Meetings, Open Records Ethics Handbook Handbook for Municipal Elected Officials Municipal Candidates Guide Public Officials Liability Handbook Visit www.cml.org to learn more or to order . Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 53 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 54 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 55 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 56 Sara Ott / City of Aspen Order # 62231 / Order Date: 1/9/2024 Copyright by CML 57 Second Regular Session Seventy-fourth General Assembly STATE OF COLORADO INTRODUCED LLS NO. 24-0541.01 Nicole Myers x4326 HOUSE BILL 24-1168 House Committees Senate Committees Transportation, Housing & Local Government A BILL FOR AN ACT CONCERNING EQUAL ACCESS TO PUBLIC MEETINGS.101 Bill Summary (Note: This summary applies to this bill as introduced and does not reflect any amendments that may be subsequently adopted. If this bill passes third reading in the house of introduction, a bill summary that applies to the reengrossed version of this bill will be available at http://leg.colorado.gov.) The bill requires state and local public bodies (public bodies) to ensure that the following accessibility requirements are implemented by July 1, 2025: !Any public meeting at which public business is discussed, formal action may be taken, or recommendations to the governing body of the public body may be discussed (meeting) held by a public body is required to be accessible in real time by live streaming video or audio that is HOUSE SPONSORSHIP Froelich and Rutinel, SENATE SPONSORSHIP Hinrichsen, Shading denotes HOUSE amendment. Double underlining denotes SENATE amendment. Capital letters or bold & italic numbers indicate new material to be added to existing law. Dashes through the words or numbers indicate deletions from existing law. 58 recorded and accessible to individuals with disabilities; !A public body is required to post on its website, at least 24 hours before a meeting, any documents that will be distributed during the meeting; !For any meeting of a public body during which public testimony will be heard, the public body is required to allow any individual to participate in the meeting and offer public testimony by using a video conferencing platform unless the meeting occurs in a geographic location that lacks broadband internet service; and !A public body is required to provide any auxiliary aids or services requested in time for the meeting for which they were requested. A public body may require that a request for auxiliary aids or services to attend a meeting of the public body with the use of the video conferencing platform be made up to 7 days before the date of the meeting. Nothing in the bill prohibits a public body from promulgating rules for the administration of public testimony so long as the rules apply to both in-person and remote testimony, and nothing in the bill requires a public body to provide hardware or software or internet or phone access at an individual's home. The failure of any public body to comply with the applicable requirements of the bill constitutes discrimination on the basis of disability. Any individual who is subjected to a violation is entitled to seek relief as currently provided in law. Be it enacted by the General Assembly of the State of Colorado:1 SECTION 1. Legislative declaration. (1) The general assembly2 hereby finds and declares that:3 (a) The federal "Americans with Disabilities Act of 1990" has4 been law for over three decades;5 (b) The federal "Americans with Disabilities Act of 1990"6 mandates equal access to everyday activities for individuals with7 disabilities;8 (c) Many places of public business continue to be inaccessible to9 individuals with disabilities; and10 HB24-1168-2- 59 (d) It is the right of every individual to participate in public1 discourse and it is imperative to a healthy and functional democracy that2 all citizens have access to their government.3 (2) The general assembly further finds and declares that it is4 necessary to codify the right to accessible and transparent governance to5 protect access and promote greater equity.6 SECTION 2. In Colorado Revised Statutes, add part 17 to article7 1 of title 29 as follows:8 PART 179 ACCESSIBILITY OF LOCAL GOVERNMENT10 29-1-1701. Local public bodies - meetings - accessibility -11 definitions. (1) AS USED IN THIS PART 17, UNLESS THE CONTEXT12 OTHERWISE REQUIRES:13 (a) "AUXILIARY AIDS OR SERVICES" MEANS AN AID OR SERVICE14 THAT IS USED TO PROVIDE INFORMATION TO AN INDIVIDUAL WITH A15 COGNITIVE, DEVELOPMENTAL, INTELLECTUAL, NEUROLOGICAL, OR16 PHYSICAL DISABILITY, AND IS AVAILABLE IN A FORMAT OR MANNER THAT17 ALLOWS THE INDIVIDUAL TO BETTER UNDERSTAND THE INFORMATION.18 (b) (I) "LOCAL PUBLIC BODY" MEANS ANY BOARD, COMMITTEE,19 COMMISSION, AUTHORITY, OR OTHER ADVISORY, POLICY-MAKING,20 RULE-MAKING, OR FORMALLY CONSTITUTED BODY OF ANY POLITICAL21 SUBDIVISION OF THE STATE AND ANY PUBLIC OR PRIVATE ENTITY TO WHICH22 A POLITICAL SUBDIVISION, OR AN OFFICIAL THEREOF, HAS DELEGATED A23 GOVERNMENTAL DECISION-MAKING FUNCTION BUT DOES NOT INCLUDE24 INDIVIDUALS ON THE ADMINISTRATIVE STAFF OF THE LOCAL PUBLIC BODY.25 (II) NOTWITHSTANDING THE PROVISIONS OF SUBSECTION (1)(b)(I)26 OF THIS SECTION, TO ASSURE SCHOOL BOARD TRANSPARENCY, "LOCAL27 HB24-1168-3- 60 PUBLIC BODY" INCLUDES MEMBERS OF A BOARD OF EDUCATION, SCHOOL1 ADMINISTRATION PERSONNEL, OR A COMBINATION THEREOF WHO ARE2 INVOLVED IN A MEETING WITH A REPRESENTATIVE OF EMPLOYEES AT3 WHICH A COLLECTIVE BARGAINING AGREEMENT IS DISCUSSED.4 (III) NOTWITHSTANDING THE PROVISIONS OF SUBSECTION (1)(b)(I)5 OF THIS SECTION, "LOCAL PUBLIC BODY" INCLUDES THE GOVERNING BOARD6 OF AN INSTITUTE CHARTER SCHOOL THAT IS AUTHORIZED PURSUANT TO7 PART 5 OF ARTICLE 30.5 OF TITLE 22.8 (c) "PUBLIC MEETING" MEANS ANY MEETING HELD BY A LOCAL9 PUBLIC BODY AT WHICH PUBLIC BUSINESS IS DISCUSSED, FORMAL ACTION10 MAY BE TAKEN, OR RECOMMENDATIONS THAT MAY BE MADE TO THE11 GOVERNING BODY OF A LOCAL PUBLIC BODY MAY BE DISCUSSED.12 (2) EACH LOCAL PUBLIC BODY SHALL ENSURE THAT THE13 ACCESSIBILITY REQUIREMENTS SPECIFIED IN THIS PART 17 ARE14 IMPLEMENTED BY JULY 1, 2025, TO ENSURE THE FULL AND EQUAL15 ENJOYMENT OF THE LOCAL PUBLIC BODY BY INDIVIDUALS IN PROTECTED16 CLASSES, INCLUDING INDIVIDUALS WITH DISABILITIES, AS REQUIRED BY17 SECTIONS 24-34-601 AND 24-34-802.18 (3) (a) ANY PUBLIC MEETING MUST BE ACCESSIBLE IN REAL TIME19 BY LIVE STREAMING VIDEO OR AUDIO THAT IS RECORDED AND ACCESSIBLE20 TO INDIVIDUALS WITH DISABILITIES.21 (b) A LOCAL PUBLIC BODY MUST POST ON ITS WEBSITE ANY22 DOCUMENTS THAT WILL BE DISTRIBUTED OR DISCUSSED DURING A PUBLIC23 MEETING. A LOCAL PUBLIC BODY MUST POST SUCH DOCUMENTS AT LEAST24 TWENTY-FOUR HOURS BEFORE THE PUBLIC MEETING OR, IF POSTING THE25 DOCUMENTS TWENTY-FOUR HOURS BEFORE THE PUBLIC MEETING IS NOT26 POSSIBLE, AS SOON AS PRACTICABLE BEFORE THE PUBLIC MEETING; EXCEPT27 HB24-1168-4- 61 THAT, IF THE DOCUMENTS ARE CONFIDENTIAL OR PRIVILEGED, NOT1 AVAILABLE TO THE PUBLIC UNTIL DISTRIBUTED OR DISCUSSED, OR NOT IN2 THE LOCAL PUBLIC BODY'S POSSESSION BEFORE THE MEETING, A LOCAL3 PUBLIC BODY MUST POST THE DOCUMENTS IN REAL TIME DURING THE4 PUBLIC MEETING. ANY DOCUMENTS THAT A LOCAL PUBLIC BODY POSTS5 PURSUANT TO THIS SUBSECTION (3)(b) MUST MEET CURRENT PREVAILING6 DOCUMENT AND INTERNET ACCESSIBILITY STANDARDS AND MUST REMAIN7 AVAILABLE TO THE PUBLIC ON THE LOCAL PUBLIC BODY'S WEBSITE FOR8 ON-DEMAND USE IN THE SAME MANNER IN WHICH THE LOCAL PUBLIC BODY9 MAKES THE WRITTEN RECORD OF THE MEETING AVAILABLE TO THE PUBLIC.10 (c) A LOCAL PUBLIC BODY MAY, IN ITS DISCRETION, MAKE THE11 VIDEO OR AUDIO RECORDING OF ANY PUBLIC MEETING AVAILABLE TO THE12 PUBLIC FOR ON-DEMAND USE.13 (4) (a) EXCEPT AS OTHERWISE PROVIDED IN SUBSECTION (4)(b) OF14 THIS SECTION, FOR ANY PUBLIC MEETING DURING WHICH THE LOCAL15 PUBLIC BODY WILL HEAR PUBLIC TESTIMONY, THE LOCAL PUBLIC BODY16 MUST ALLOW ANY INDIVIDUAL TO PARTICIPATE IN THE PUBLIC MEETING17 AND OFFER PUBLIC TESTIMONY BY USING A VIDEO CONFERENCING18 PLATFORM. THE LOCAL PUBLIC BODY MUST ENSURE THAT ANY INDIVIDUAL19 SEEKING THE USE OF A VIDEO CONFERENCING PLATFORM TO PARTICIPATE20 IN THE PUBLIC MEETING IS PROVIDED ACCESS TO THE PUBLIC MEETING BY21 USE OF THE VIDEO CONFERENCING PLATFORM AT THE SAME TIMES AND22 UPON THE SAME TERMS AS INDIVIDUALS WHO APPEAR AT THE PUBLIC23 MEETING IN PERSON. IT IS IN A LOCAL PUBLIC BODY'S DISCRETION TO24 DETERMINE WHICH VIDEO CONFERENCING PLATFORM WILL BE USED FOR25 SUCH PARTICIPATION SO LONG AS THE PLATFORM IS ACCESSIBLE TO26 INDIVIDUALS WITH DISABILITIES.27 HB24-1168-5- 62 (b) NOTHING IN THIS PART 17 PROHIBITS A LOCAL PUBLIC BODY1 FROM PROMULGATING RULES FOR THE ADMINISTRATION OF PUBLIC2 TESTIMONY SO LONG AS THE RULES APPLY TO BOTH IN-PERSON AND3 REMOTE TESTIMONY.4 (c) THE REQUIREMENTS OF SUBSECTION (4)(a) OF THIS SECTION DO5 NOT APPLY WHEN A PUBLIC MEETING OCCURS IN A GEOGRAPHIC LOCATION6 THAT IS IN AN UNSERVED AREA OF THE STATE, AS DEFINED IN SECTION7 40-15-102 (32).8 (d) A LOCAL PUBLIC BODY THAT IS EXEMPT FROM THE9 REQUIREMENTS OF SUBSECTION (4)(a) OF THIS SECTION SHALL USE AN10 ALTERNATIVE TO A VIDEO CONFERENCING PLATFORM, SUCH AS A11 TELEPHONE CONFERENCE CALL, TO ALLOW PARTICIPATION IN A PUBLIC12 MEETING. THE ALTERNATIVE OPTION USED MUST BE ACCESSIBLE TO13 INDIVIDUALS WITH DISABILITIES.14 (5) (a) A LOCAL PUBLIC BODY MAY REQUIRE THAT A REQUEST FOR15 AUXILIARY AIDS OR SERVICES TO ATTEND A PUBLIC MEETING OF THE16 LOCAL PUBLIC BODY WITH THE USE OF THE VIDEO CONFERENCING17 PLATFORM SELECTED BY THE LOCAL PUBLIC BODY PURSUANT TO18 SUBSECTION (4)(a) OF THIS SECTION BE MADE UP TO SEVEN DAYS BEFORE19 THE DATE OF THE PUBLIC MEETING FOR WHICH THE AUXILIARY AIDS OR20 SERVICES ARE REQUESTED.21 (b) A LOCAL PUBLIC BODY SHALL PROVIDE ANY AUXILIARY AIDS22 OR SERVICES TIMELY REQUESTED PURSUANT TO SUBSECTION (5)(a) OF THIS23 SECTION IN TIME FOR THE PUBLIC MEETING FOR WHICH THE AUXILIARY24 AIDS OR SERVICES WERE REQUESTED WITHOUT REQUIRING OR REQUESTING25 AN EXPLANATION OF THE NEED FOR THE AUXILIARY AIDS OR SERVICES.26 (c) NOTHING IN THIS PART 17 REQUIRES A LOCAL PUBLIC BODY TO27 HB24-1168-6- 63 PROVIDE HARDWARE OR SOFTWARE OR INTERNET OR PHONE ACCESS AT AN1 INDIVIDUAL'S HOME.2 (6) NOTHING IN THIS PART 17 SUPERSEDES OR NEGATES THE3 REQUIREMENTS OF THE OPEN MEETINGS LAW, PART 4 OF ARTICLE 6 OF4 TITLE 24, OR THE "COLORADO OPEN RECORDS ACT", PART 2 OF ARTICLE5 72 OF TITLE 24.6 (7) THE FAILURE OF ANY LOCAL PUBLIC BODY TO COMPLY WITH7 THE REQUIREMENTS OF THIS PART 17 CONSTITUTES DISCRIMINATION ON8 THE BASIS OF DISABILITY IN VIOLATION OF SECTION 24-34-802. ANY9 INDIVIDUAL WHO IS SUBJECTED TO A VIOLATION OF THIS PART 17 IS10 ENTITLED TO SEEK ALL RELIEF PROVIDED IN SECTION 24-34-802.11 SECTION 3. In Colorado Revised Statutes, add part 14 to article12 82 of title 24 as follows:13 PART 1414 ACCESSIBILITY OF STATE GOVERNMENT15 24-82-1401. State public bodies - meetings - accessibility -16 definitions. (1) AS USED IN THIS PART 14, UNLESS THE CONTEXT17 OTHERWISE REQUIRES:18 (a) "AUXILIARY AIDS OR SERVICES" MEANS AN AID OR SERVICE19 THAT IS USED TO PROVIDE INFORMATION TO AN INDIVIDUAL WITH A20 COGNITIVE, DEVELOPMENTAL, INTELLECTUAL, NEUROLOGICAL, OR21 PHYSICAL DISABILITY, AND IS AVAILABLE IN A FORMAT OR MANNER THAT22 ALLOWS THE INDIVIDUAL TO BETTER UNDERSTAND THE INFORMATION.23 (b) "PUBLIC MEETING" MEANS ANY MEETING HELD BY A STATE24 PUBLIC BODY AT WHICH PUBLIC BUSINESS IS DISCUSSED, FORMAL ACTION25 MAY BE TAKEN, OR RECOMMENDATIONS THAT MAY BE MADE TO THE26 GOVERNING BODY OF A STATE PUBLIC BODY MAY BE DISCUSSED.27 HB24-1168-7- 64 (c) (I) "STATE PUBLIC BODY" MEANS ANY BOARD, COMMITTEE,1 COMMISSION, OR OTHER ADVISORY, POLICY-MAKING, RULE-MAKING,2 DECISION-MAKING, OR FORMALLY CONSTITUTED BODY OF ANY STATE3 AGENCY, STATE AUTHORITY, GOVERNING BOARD OF A STATE INSTITUTION4 OF HIGHER EDUCATION INCLUDING THE REGENTS OF THE UNIVERSITY OF5 COLORADO, A NONPROFIT CORPORATION INCORPORATED PURSUANT TO6 SECTION 23-5-121 (2), OR THE GENERAL ASSEMBLY, AND ANY PUBLIC OR7 PRIVATE ENTITY TO WHICH THE STATE, OR AN OFFICIAL THEREOF, HAS8 DELEGATED A GOVERNMENTAL DECISION-MAKING FUNCTION BUT DOES9 NOT INCLUDE INDIVIDUALS ON THE ADMINISTRATIVE STAFF OF THE STATE10 PUBLIC BODY.11 (II) NOTWITHSTANDING THE PROVISIONS OF SUBSECTION (1)(c)(I)12 OF THIS SECTION, "STATE PUBLIC BODY" DOES NOT INCLUDE THE13 GOVERNING BOARD OF AN INSTITUTE CHARTER SCHOOL THAT IS14 AUTHORIZED PURSUANT TO PART 5 OF ARTICLE 30.5 OF TITLE 22.15 (2) EACH STATE PUBLIC BODY SHALL ENSURE THAT THE16 ACCESSIBILITY REQUIREMENTS SPECIFIED IN THIS PART 14 ARE17 IMPLEMENTED BY JULY 1, 2025, TO ENSURE THE FULL AND EQUAL18 ENJOYMENT OF THE STATE PUBLIC BODY BY INDIVIDUALS IN PROTECTED19 CLASSES, INCLUDING INDIVIDUALS WITH DISABILITIES, AS REQUIRED BY20 SECTIONS 24-34-601 AND 24-34-802.21 (3) (a) ANY PUBLIC MEETING MUST BE ACCESSIBLE IN REAL TIME22 BY LIVE STREAMING VIDEO OR AUDIO THAT IS RECORDED AND ACCESSIBLE23 TO INDIVIDUALS WITH DISABILITIES.24 (b) A STATE PUBLIC BODY MUST POST ON ITS WEBSITE ANY25 DOCUMENTS THAT WILL BE DISTRIBUTED OR DISCUSSED DURING A PUBLIC26 MEETING. A STATE PUBLIC BODY MUST POST SUCH DOCUMENTS AT LEAST27 HB24-1168-8- 65 TWENTY-FOUR HOURS BEFORE THE PUBLIC MEETING OR, IF POSTING THE1 DOCUMENTS TWENTY-FOUR HOURS BEFORE THE MEETING IS NOT POSSIBLE,2 AS SOON AS PRACTICABLE BEFORE THE MEETING; EXCEPT THAT IF THE3 DOCUMENTS ARE CONFIDENTIAL OR PRIVILEGED, NOT AVAILABLE TO THE4 PUBLIC UNTIL DISTRIBUTED OR DISCUSSED, OR NOT IN THE STATE PUBLIC5 BODY'S POSSESSION BEFORE THE MEETING, THE STATE PUBLIC BODY MUST6 POST THE DOCUMENTS IN REAL TIME DURING THE PUBLIC MEETING. ANY7 DOCUMENTS THAT A STATE PUBLIC BODY POSTS PURSUANT TO THIS8 SUBSECTION (3)(b) MUST MEET CURRENT PREVAILING DOCUMENT AND9 INTERNET ACCESSIBILITY STANDARDS AND MUST REMAIN AVAILABLE TO10 THE PUBLIC ON THE STATE PUBLIC BODY'S WEBSITE FOR ON-DEMAND USE11 IN THE SAME MANNER IN WHICH THE LOCAL STATE BODY MAKES THE12 WRITTEN RECORD OF THE PUBLIC MEETING AVAILABLE TO THE PUBLIC.13 (c) A STATE PUBLIC BODY MAY, IN ITS DISCRETION, MAKE THE14 VIDEO OR AUDIO RECORDING OF ANY PUBLIC MEETING AVAILABLE TO THE15 PUBLIC FOR ON-DEMAND USE.16 (4) (a) EXCEPT AS OTHERWISE PROVIDED IN SUBSECTION (4)(b) OF17 THIS SECTION, FOR ANY PUBLIC MEETING DURING WHICH THE STATE PUBLIC18 BODY WILL HEAR PUBLIC TESTIMONY, THE STATE PUBLIC BODY MUST19 ALLOW ANY INDIVIDUAL TO PARTICIPATE IN THE PUBLIC MEETING AND20 OFFER PUBLIC TESTIMONY WITH THE USE OF A VIDEO CONFERENCING21 PLATFORM. THE STATE PUBLIC BODY MUST ENSURE THAT ANY INDIVIDUAL22 SEEKING THE USE OF A VIDEO CONFERENCING PLATFORM TO PARTICIPATE23 IN THE PUBLIC MEETING IS PROVIDED ACCESS TO THE PUBLIC MEETING BY24 USE OF THE VIDEO CONFERENCING PLATFORM AT THE SAME TIMES AND25 UPON THE SAME TERMS AS INDIVIDUALS WHO APPEAR AT THE MEETING IN26 PERSON. IT IS IN A STATE PUBLIC BODY'S DISCRETION TO DETERMINE WHICH27 HB24-1168-9- 66 VIDEO CONFERENCING PLATFORM WILL BE USED FOR SUCH PARTICIPATION1 SO LONG AS THE PLATFORM IS ACCESSIBLE TO INDIVIDUALS WITH2 DISABILITIES.3 (b) NOTHING IN THIS PART 14 PROHIBITS A STATE PUBLIC BODY4 FROM PROMULGATING RULES FOR THE ADMINISTRATION OF PUBLIC5 TESTIMONY SO LONG AS THE RULES APPLY TO BOTH IN-PERSON AND6 REMOTE TESTIMONY.7 (c) THE REQUIREMENTS OF SUBSECTION (4)(a) OF THIS SECTION DO8 NOT APPLY WHEN A PUBLIC MEETING OF A STATE PUBLIC BODY OCCURS IN9 A GEOGRAPHIC LOCATION THAT IS IN AN UNSERVED AREA OF THE STATE,10 AS DEFINED IN SECTION 40-15-102 (32).11 (d) A STATE PUBLIC BODY THAT IS EXEMPT FROM THE12 REQUIREMENTS OF SUBSECTION (4)(a) OF THIS SECTION SHALL USE AN13 ALTERNATIVE TO A VIDEO CONFERENCING PLATFORM, SUCH AS A14 TELEPHONE CONFERENCE CALL, TO ALLOW PARTICIPATION IN A PUBLIC15 MEETING. THE ALTERNATIVE OPTION USED MUST BE ACCESSIBLE TO16 INDIVIDUALS WITH DISABILITIES.17 (5) (a) A STATE PUBLIC BODY MAY REQUIRE THAT A REQUEST FOR18 AUXILIARY AIDS OR SERVICES TO ATTEND A PUBLIC MEETING WITH THE USE19 OF THE VIDEO CONFERENCING PLATFORM SELECTED BY THE STATE PUBLIC20 BODY PURSUANT TO SUBSECTION (4)(a) OF THIS SECTION, BE MADE UP TO21 SEVEN DAYS BEFORE THE DATE OF THE PUBLIC MEETING FOR WHICH THE22 AIDS OR SERVICES ARE REQUESTED.23 (b) A STATE PUBLIC BODY SHALL PROVIDE ANY AUXILIARY AIDS OR24 SERVICES TIMELY REQUESTED PURSUANT TO SUBSECTION (5)(a) OF THIS25 SECTION IN TIME FOR THE PUBLIC MEETING FOR WHICH THE AUXILIARY26 AIDS OR SERVICES WERE REQUESTED WITHOUT REQUIRING OR REQUESTING27 HB24-1168-10- 67 AN EXPLANATION OF THE NEED FOR THE AUXILIARY AIDS AND SERVICES.1 (c) NOTHING IN THIS PART 14 REQUIRES A STATE PUBLIC BODY TO2 PROVIDE HARDWARE OR SOFTWARE OR INTERNET OR PHONE ACCESS AT AN3 INDIVIDUAL'S HOME.4 (6) NOTHING IN THIS PART 14 SUPERSEDES OR NEGATES THE5 REQUIREMENTS OF THE OPEN MEETINGS LAW, PART 4 OF ARTICLE 6 OF THIS6 TITLE 24, OR THE "COLORADO OPEN RECORDS ACT", PART TWO OF7 ARTICLE 72 OF THIS TITLE 24.8 (7) THE FAILURE OF ANY STATE PUBLIC BODY TO COMPLY WITH9 THE REQUIREMENTS OF THIS PART 14 CONSTITUTES DISCRIMINATION ON10 THE BASIS OF DISABILITY IN VIOLATION OF SECTION 24-34-802. ANY11 INDIVIDUAL WHO IS SUBJECTED TO A VIOLATION OF THIS PART 14 IS12 ENTITLED TO SEEK ALL RELIEF PROVIDED IN SECTION 24-34-802.13 SECTION 4. Act subject to petition - effective date. This act14 takes effect at 12:01 a.m. on the day following the expiration of the15 ninety-day period after final adjournment of the general assembly; except16 that, if a referendum petition is filed pursuant to section 1 (3) of article V17 of the state constitution against this act or an item, section, or part of this18 act within such period, then the act, item, section, or part will not take19 effect unless approved by the people at the general election to be held in20 November 2024 and, in such case, will take effect on the date of the21 official declaration of the vote thereon by the governor.22 HB24-1168-11- 68 Board or Commission Permanent or Not Permanent Bylaws Term Limits Notes ARC Advisory Committee Status not stated in enacting documents No ARC Advisory Committee member eligibility requirements differ from those of a permanent board per the Charter (section 8.2). Four members appointed by SPARC, one member appointed by Aspen Youth Center, one member appointed by Council to represent swimming interests, one member appointed by Council to represent general interests. Aspen Animal Shelter Board Status not stated in enacting documents Yes No-members serve until successor is appointed Joint board between Pitkin County and City of Aspen. Member qualifications differ from those of a permanent board. Board of Adjustments Permanent No Ord. 41 series 2002 notes members must be qualified electors and have been residents of the City for at least one year and states that members cannot be members of the council, city- appointed officials, or city employees. These are the requirements of a permanent board (section 8.2 of the city charter). Board of Appeals Permanent, Other rules by City Charter No term limits Member qualifications specificed in Section 8.2 of the charter. Charter and Chapter 8.08 of the municipal code states that the members of the Board of Appeals must be qualified electors and residents of the City or County for at least two years, and members of City staff (Chief Building Official) serve as ex officio members. Comercial Core & Lodging Commission Unclear No Ord. 43 series 2007 notes no age or residency requirement shall be imposed on membership despite the whereas section noting the recommendation that it be a permanent board. Elections Commission Other rules by City Charter Not stated. Commission is established in the City Chater. Charter also notes membership requirements which are similar to those of a permanent board. Golf Advisory Board Yes No. Grants Steering Committee Not Permanent No bylaws but have Charter Yes- no members shall serve more than two consecutive full three-year terms. No age or residency requirements. Historic Preservation Commission Permanent No Ord. 41 series 2002 notes members must be qualified electors and have been residents of the City for at least one year and states that members cannot be members of the council, city- appointed officials, or city employees. These are the requirements of a permanent board (section 8.2 of the city charter). Housing Authority Yes No-members serve until successor is appointed Joint board with Pitkin County. IGA and Bylaws do not explicitly state that board is not permanent, but member qualifications differ from those of a permanent board. Kids First Advisory Board Not Permanent Yes No Overlapping 3-year terms. There are no age or residency requirements for membership. Candidates for appointment are not required to be qualified electors. Local Licensing Authority Permanent Yes. Cannot serve more than two consecutive terms. Ordinance 48-Series of 99 set for the member eligibility requirements differ from those of a permanent board. 4-year term, with a term limit unless qualfied replacement members are unavailable. According to the Municipal Code: Members of the Authority shall be qualified electors and residents of the City for at least one (1) year prior to appointment. In the event that any member is no longer a qualified elector or is convicted of a felony or an offense involving moral turpitude while in office, the City Council shall terminate the appointment of such person as a member of the Authority. Open Space and Trails Board Permanent Yes, Adopted August 26, 2004 Not stated.Ord. 31 series 2007 notes that staff and board recommend making it a permanent board Planning & Zoning Commission Permanent No Ord. 41 series 2002 notes members must be qualified electors and have been residents of the City for at least one year and states that members cannot be members of the council, city- appointed officials, or city employees. These are the requirements of a permanent board (section 8.2 of the city charter). Wheeler Opera House Not Permanent Yes. The Feb. 8, 2023, board bylaws specifically allow board members to attend by phone or other virtual method. Not stated. 3-year terms. The Board of Advisors is declared not to be a permanent board within the meaning of Section 8. 2 of the Charter of the City of Aspen and, therefore, there shall be imposed no age or residency requirement for membership on the Board of Advisors nor shall candidates for appointment be required to be qualified electors. 69