Board of Directors: Chair: Supervisor Federal Glover, Contra Costa County Vice Chair: Supervisor John Moorlach, Orange County Treasurer: Emily

Harrison, Finance Director, Santa Clara County Members: Supervisor Keith Carson, Alameda County; Supervisor Don Knabe, Los Angeles County; Supervisor

John J. Benoit, Riverside County; Supervisor Susan Peters, Sacramento County; Supervisor Josie Gonzales, San Bernardino County; Supervisor Dave Roberts, San

Diego County; Supervisor Eric Mar, San Francisco County; Supervisor Carole Groom, San Mateo County; Supervisor Ken Yeager, Santa Clara County; Supervisor

Kathy Long, Ventura County

1100 “K” Street, Suite 101/Sacramento, CA 95814/ (916) 327-7531 FAX (916) 491-4182/UCC@urbancounties.com

August 8, 2014 The Honorable Nora Campos Member of the State Assembly State Capitol, Room 3013 Sacramento, CA 95814

RE: Assembly Bill 194 (Campos) – OPPOSE UNLESS AMENDED - As Amended on July 1, 2014 Dear Assembly Member Campos: The Urban Counties Caucus (UCC), a coalition of California’s most populous counties, regrets to inform you that we have taken a position of Oppose Unless Amended to your bill, AB 194, which is currently pending on the Senate Floor. This bill would make changes to the public criticism and public comments sections of the Ralph M. Brown Act (Brown Act).

Under California’s Brown Act, county boards of supervisors must adhere to a variety of requirements including the allowance of individuals to provide public comment on items for consideration. This section of the Brown Act allows local agencies to establish reasonable rules to manage and conduct public comment. While the recent amendments to this bill help to provide further clarification to some of the references including the reference to staff and the ability of a Board to adopt reasonable regulations regarding public comment on a specific agenda item, our counties are still concerned that the bill does not provide any new tools to help manage and conduct meetings. Specifically, we are concerned that Section 54943.3 (B) provides that a legislative body cannot prohibit comments by a member of the public during presentation of an agenda item who has not provided notice of his or her desire to comment prior to consideration of the agenda item by the legislative body. This provision is troubling to our counties, who often receive hundreds of members of the public that attend meetings and want to comment. Without notice or letting the body know of their desire to speak there is the concern that this could result in the ability for the public to continue to ask to speak with no limitations allowed. UCC is in strong support of the Ralph M. Brown Act and we believe that our counties provide the public with several opportunities to comment on any specific issue item. If the bill was amended to address our ability to manage large audiences through proper notice to the legislative body, we could remove our opposition to the bill. We sincerely appreciate the willingness of your staff and the sponsors to hear our concerns, but at this time our Board could not remove our opposition when there is limited benefit to the changes in AB 194 and the possibility of unintended consequences remain in the bill. Sincerely,

Jolena L. Voorhis, Executive Director cc: Toby Ewing, Consultant, Senate Governance and Finance Committee Angela Mapp, Consultant, Assembly Local Government Committee

URBAN

COUNTIES

CAUCUS

Chair

Supervisor Federal Glover

Executive Director

Jolena L. Voorhis