HomeMy WebLinkAbout2015_0622_Minutes Open_APPROVEDCOUNTY OF KAUAI
Minutes of Meeting
OPEN SESSION
Approved as circulated 7/27/15
Board /Committee:
CHARTER REVIEW COMMISSION Meeting Date
June 22, 2015
Location
Mo'ikeha Building, Meeting Room 2A /213 Start of Meeting: 4:04 pm
End of Meeting: 5:17 pm
Present
Chair Jan TenBruggencate; Vice Chair Joel Guy. Members: Allan Parachini; Patrick Stack; Cheryl Stiglmeier
Also: Deputy County Attorney Philip Dureza; Boards & Commissions Office Staff. Support Clerk Barbara Davis; Administrator Jay
Furfaro; County Clerk Jade Fountain - Tanigawa
Excused
Member Ed Justus
Absent
SUBJECT
DISCUSSION
ACTION
Call To Order
Chair TenBruggencate called the meeting to
order at 4:04 pm with 5 Commissioners present
Approval of
Regular Open Session Minutes of May 18, 2015
Mr. Guy moved to approve the minutes as
Minutes
circulated. Mr. Parachini seconded the motion.
Motion carried 5:0
Business
CRC 2014 -06 Discussion and possible decision - making on whether there is a
need to define what a charter amendment is
b. Discussion and possible decision - making on defining what a petition
initiated charter amendment is as outlined in the Charter
Amendment Proposal for Article XXIV, revised 5/18/15
Chair TenBruggencate asked if the Commission had any changes to the
proposed language before them.
Mr. Parachini said the version before them does not tinker with the
signature requirement percentage to which the Chair noted that is part of
item d. on the agenda.
Mr. Parachini moved that the Commission
approve the proposed language pertaining to
item b. Mr. Stack seconded the motion.
Mr. Guy expressed his concern with the 51h paragraph which puts the onus
on the county to seek a declaratory ruling. Mr. Parachini said it says "may
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seek ", it does not compel the clerk to do that. Chair TenBruggencate asked
if it was the understanding of the Commission that the way this is set up
now if a petition is filed with the county clerk and the county clerk checks
with the county attorney and the county attorney says it is not a charter
amendment, or not a valid charter amendment, then the county clerk would
still have to get a declaratory ruling, or could the county clerk based on that
advice invalidate it. The Chair was not sure the Commission had made this
clear enough and would create a problem if it is not clarified whether that
authority is in the hands of the county clerk; they can choose to get a
declaratory ruling or they have to get a declaratory ruling because they
don't have that authority themselves. Mr. Parachini said the way it is
worded now it unquestionably says that it is a decision the cleric could
make, but is not compelled to do. Mr. Guy said not the declaratory ruling,
but the actual decision of whether it is or is not a charter amendment
because that will trigger the next step. If the county attorney says it is not a
charter amendment can the clerk stop it right there, or in order to stop it
does the clerk have to go to court? Mr. Parachini said the way he reads it
the clerk could stop it. Chair TenBruggencate said if it is not clear there
will be debates later so they should say if the county clerk concludes the
measure is not a valid charter amendment, the county clerk may so certify
or may seek a declaratory ruling.
Attorney Dureza said based on the reading of the language it gives authority
to the county clerk to stop the process from going forward even without
going to court. The discussion the Commission had last month was that
was something they did not want to do. Where it says upon filing of such
petition [with the council], the county clerk shall examine it to see whether
it is a valid charter amendment followed by if the county clerk concludes
the measure is a valid charter amendment, the clerk shall then examine it to
see whether it contains a sufficient number, etc. The inverse of that
suggests that if the county clerk does not conclude that the measure is a
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valid charter amendment the clerk does not have to go to the next step of
checking to see whether or not there are enough signatures. Chair
TenBruggencate said if you go to the next sentence it is intriguing in that if'
it is not a valid charter amendment they may seek a declaratory ruling,
which suggests you can make the argument that the clerk does not have the
authority, they can go to court — why would that be there? Attorney
Dureza said if they want to be really clear about it they should address it. It
is a reasonable interpretation either way, but to be clear they should specify
that it is not supposed to stop the process. Mr. Parachim said the insertion
of the three words "so certify or" as suggested by the Chairman would fix
it. Chair TenBruggencate added it would make it very clear that the clerk
has the authority, and if the clerk chooses not to exercise the authority they
can ask the court to exercise the authority. Attorney Dureza disagreed; if
you are using the word "may" then it is optional for the clerk whether or not
the clerk certifies it. If the Commission wants to make sure that happens
they should use "shall ". Chair TenBruggencate said Attorney Dureza was
suggesting the clerk has the authority. If the clerk has that authority why is
that next line in there, why give them the right to seek a declaratory ruling?
Mr. Guy said the clerk would never have to go to court if they were the one
making the decision. Attorney Dureza said he was not saying their
interpretation was necessarily something that would be unacceptable or not
reasonable; if they are going to use that language those two things are
inconsistent with each other so if they want a clear amendment they want to
address that. If they are going to leave it at that people will litigate what
this means. Mr. Parachini asked if that could be addressed by changing
"may" to "shall" in the 5th paragraph saying the county clerk shall so certify
or seek a declaratory ruling. Mr. Guy said if the clerk is the decision
maker there is no reason to ever have a declaratory ruling if they can
determine it is not a valid charter amendment as said in the 41h paragraph.
What would impel the clerk to seek a declaratory ruling; they are the ruler
already. Ms. Stiglmeier asked if it would make more sense to say that "the
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county clerk shall certify that it is not a valid charter amendment" and take
out "and may seek the declaratory ruling ". Chair TenBruggencate said he
would agree with that. Mr. Guy said that is where they start losing his
support. Attorney Dureza asked what happens after the county clerk
certifies it is not a valid charter amendment. Both Chair TenBruggencate
and Ms. Stiglmeier responded it stops. Attorney Dureza apologized saying
he misunderstood their intent. Chair TenBruggencate said one of the
reasons they are talking about this is in the most recent (proposed
amendment) it was not clear who had the authority to say it was not a
charter amendment, and it defaulted to the county council to make that
decision. It is this Commission's job to make it clear so it does not default
anywhere. At the previous meeting Mr. Justus' wanted to put the onus on
the county rather than on the person who is creating the petition. The
position of the other Commissioners was to have the petitioners create a
declaratory ruling, which is their absolute right. Chair TenBruggencate
asked Mr. Guy if he had a problem with the language Ms. Stiglmeier was
proposing to which Mr. Guy said no, but he does caution putting it all on
the county clerk as the final say all.
Mr. Guy thought that Mr. Justus' position was if the petitioners got the
signatures it had to go on the ballot, and if the county did not like that they
had to seek the declaratory ruling. The intention initially was to define
what a charter amendment is so it seems clearer for the people who are
trying to get it done. Mr. Parachini noted that the minutes of the last
meeting indicate that Mr. Justus ultimately agreed that was not a wise
decision; there needed to be some determination and the conversation
included the county attorney or the county clerk. If the proposal is in
conflict of §24.01 then the onus passes to the proposers.
Mr. Stack asked if they should discuss the possibility of having an
independent council empowered with the notion that it is valid or invalid.
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The 4th paragraph says the clerk shall examine it; in any examination there
is a hunt and the hunt is for something. What exactly is the clerk hunting
for? Chair TenBruggencate said the position of county clerk is one of some
authority, and if they misuse the authority the courts are there to cover it.
One of the issues that comes up is timing. If when a petition comes in you
have to empanel a group to see whether the petition is sufficient then you
start running into deadlines that make it difficult to get things onto agendas.
If someone does not like that then they can go to the courts, but this adds
another piece. As the proposal now reads there would be a concurrence of
the county clerk and the county attorney, and that should be sufficient.
Chair TenBruggencate pointed out they have not been in the habit of
dumping legitimate petitions, only one has ever been turned down and not
by them. Mr. Stack asked if it was more than possible that some erstwhile
citizen is going to challenge it in court so they have to anticipate any course
they take is going to be challenged by some member of the public of
whoever validated or invalidated the amendment. Mr. Parachim said the
clerk would be reaching a conclusion about whether a proposal meets the
defining standard in §24.01. If a proponent does not agree with that
interpretation it goes without saying that the proponent has the right to
challenge that, and it does not necessarily need to be said because it is
already so. Ms. Stiglmeier asked if they need to clarify what examination
(by the clerk) means, and what the resources are and have that as part of the
language. Also do they need to clarify that if the county clerk is going to
certify that it is not a valid charter amendment what is the reasoning behind
the conclusion the county clerk made. Chair TenBruggencate wanted to
correct something he said earlier in that this language does not require the
county clerk to check with the county attorney. Mr. Guy asked why do they
fall on the county clerk and not the county attorney to which the Chair said
they could fall on the county attorney, but the county attorney's office is not
in the habit of making these kinds of calls. This is a sufficiency of
document. Are there situations in which the county attorney makes those
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kinds of judgments or does the county attorney simply advise other arms of
government? Attorney Dureza said they are the attorney for the entire
county and that would include the county clerk, and he doubts the county
clerk would move forward without consulting the county attorney's office.
Chair TenBruggencate asked if they should put language in the proposal
that suggests a consultation. Attorney Dureza said that is for the
Commission to determine.
Mr. Furfaro reminded the Commission that the county clerk is in fact
advised by the county attorney's office. The county attorney's office
represents all subdivisions of the political subdivision called the County of
Kauai. It is the appropriate consideration that all the council members
have access to the county attorney. Mr. Furfaro does not believe there
would be anything that is given a legal interpretation without asking for that
interpretation from the clerk to the county attorney. Chair TenBruggencate
said Mr. Furfaro was suggesting they would not have to put it in the charter,
it would happen automatically. Mr. Furfaro said it is understood.
Mr. Parachini asked Ms. Stiglmeier to clarify that she thinks it would be a
good idea that the clerk be required to indicate why. Ms. Stiglmeier said
that was her thinking that if there is clarification to the petitioner as to why
something is not valid they would hopefully get it, and understand why it is
not something they could move forward with. Mr. Parachini thought that
was reasonable. The Chair asked what language would be used to
accomplish that. Mr. Guy suggested to say the clerk provides a written
response within 30 days or 60 days of filing assuming there are deadlines
they have to make. Chair TenBruggencate said if the county clerk explains
their reasoning does that put the county in any stronger or weaker position
if the decision is challenged. Attorney Dureza said they try to make
decisions in good faith so it is not necessarily something negative to put
forth the reasons why something was rejected. It is not something of a
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confidential nature. Mr. Guy said if it is determined it is not a valid charter
amendment and give the reasons why, you are spelling out the case to the
opposing attorney to know where the county is at; it seems it would be
sketchy from the county's perspective. Attorney Dureza said it may give the
other side more advantages in terms of litigation, but if we are operating on
good faith it is not something we ought to be afraid of.
Mr. Furfaro wanted to remind everyone that the request for a county
attorney privilege that would come from the clerk's office would be
between the clerk and the county attorney, and would be considered a
privileged document. It would then need to go to the full council for the
council to make an interpretation if they agree to release that. The question
from Mr. Guy is it would be dependent upon the fact that what is disclosed
as public information could be used.......... Chair TenBruggencate thought
what they were talking about was whether the county clerk would be
required to provide a public description of why they made the decision. Mr.
Furfaro said he understood that is where the question goes, but he would
think the clerk would like to have the benefit of having a legal response to
how they came to the conclusion of that interpretation. It would then be
voted on to release it and dependent on how strong that case is they are also
exposing themselves to the other side should there be litigation. Chair
TenBruggencate asked the county clerk if she would like to weigh in on this
subject.
Ms. Fountain - Tanigawa said she understands what Mr. Furfaro was
discussing about the privilege between the county attorney and the county
clerk. It has been their practice if they were to reject or return anything to
an organization or an individual they would provide some type of rationale,
but she has not seen the language the Commission is working from. From
previous instances they have issued a rationale from the county clerk's
office. Aside from that she would like to have the Commission think about
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is the time frame. When the information and signatures are provided to the
county clerk as soon as they receive it they have to verify everything. If
there is a signature they cannot read they want to give the organization time
to obtain the additional information required. The timeline the clerk's
office is up against is pretty tight and is something to consider, so if the
Commission can craft language to address that the clerk's office would very
much appreciate it. Mr. Guy asked if Ms. Fountain - Tanigawa was asking to
increase the timeline that currently is in place or to create one. Ms.
Fountain - Tanigawa said it would be good to clarify that it needs to be
turned in by "X" date, but because they give the organization the
opportunity to provide additional information, and acting in good faith, they
would need extra time. She did not know if it would be helpful to turn the
signatures over to the clerk earlier. Chair TenBruggencate said those
decisions, the timing of when a petition is required, are not in the charter.
Those are in the Elections' regulations so that is in the clerk's court. Mr.
Guy said an earlier comment about why something wasn't a valid
amendment if it is not signatures how else can they invalidate it; do they
already have that mechanism to not take it? Ms. Fountain - Tanigawa said
any additional information they can provide and to be clear with the group
submitting the signatures; they do provide the rationale and it could be as
simple as the question presented is not clear enough — sometimes it is not
cut and dried. Sometimes we can't get a clear understanding from what we
are presented with. Mr. Parachim asked if Ms. Fountain - Tanigawa had seen
the language the Commission was considering to which she responded she
had not. Mr. Guy asked if the reason the clerk might invalidate an
amendment might be more structural and not so much the content. Ms.
Fountain - Tanigawa said it would be the content, but the structure of how it
is phrased is significant also. The meeting briefly recessed to allow Ms.
Fountain - Tanigawa an opportunity to review the proposed changes from the
Commission. Ms. Fountain - Tanigawa said her first concern is the language
where it states the county clerk would have to conclude that the measure is
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a valid charter amendment and that is where the issue comes up — is it a
charter amendment, is it something else. If they could clarify that point that
would be very helpful. Chair TenBruggencate said the first section, §24.01
at the top of the page, attempts to address that issue. Ms. Fountain -
Tanigawa thought that was much better than what is currently in the charter.
Mr. Stack asked Ms. Fountain - Tanigawa, in the capacity of a member of
the public, if she were empowered to give the responsibility of validation to
the county attorney or the county clerk, which would she choose? Ms.
Fountain - Tanigawa said the office of the county clerk just because the
county attorney's office provides legal advice and there would exist a
conflict should a conflict arise. Chair TenBruggencate said if they include
the line about the reasoning for a ruling he would suggest for the 5th
paragraph in the last half of the sentence following the comma to read the
county clerk shall so certify and provide the reasoning for that ruling.
Chair TenBruggencate then called for an amendment to the main motion.
Mr. Stack moved to amend the main motion
using the language cited by the Chair. Mr. Guy
seconded the motion.
Mr. Furfaro said his comments were on the role of the county attorney
advising the clerk, and the clerk's office has always responded many times
to these requests from the citizens without having to wait for a response
from the county attorney. Hearing the clerk's commentary he wanted to
make sure he was focusing only on the interaction between the clerk's
office and the county attorney.
Chair TenBruggencate said the current language they now have in this
amendment to the main motion allows the clerk the entire authority on how
much and when and whether to discuss it with the county attorney's office.
Motion to amend the main motion carried 5:0
Main motion as amended carried 5:0
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Proposed amendment to be sent to the County Attorney for review as to
form and legality once all agenda items are approved.
a. Add a preamble or an additional paragraph to section 1.01; (On-
going)
I ) Update on the preamble from the County Clerk's Office
Chair TenBruggencate explained this question comes from Commissioner
Justus, who is not present today, with respect to the preamble that was in
the original version of the charter approved in the 1968 election and does
not now appear in versions of the charter. Can it simply be reinserted, and
if it can, the Commission does not have to do anything further. Chair
TenBruggencate noted that Ms. Fountain - Tanigawa had been on her new
job for only a couple of weeks and has done a lot of work for the
Commission for which he thanked her.
Ms. Fountain - Tanigawa noted it took a lot of research on this question by
her office in which the staff feels it does not change the charter in
substance, however they would like to ask for a formal written opinion from
the County Attorney's Office on whether they can move ahead. Chair
TenBruggencate asked if that was something the County Clerk's Office was
prepared to ask for or is the Charter Commission being asked to do this.
Ms. Fountain - Tanigawa said her office will make the request to the County
Attorney. The most difficult thing the staff found was the fact they could
not locate the actual ballot from the 1968 special election, but did find the
results. Going off information handed out, information that was contained
in the Garden Island, reviewing minutes that was pulled from their office it
looks as if the preamble was inadvertently left out especially because of its
placement, but could not say that with 100% certainty because they have
not been able to locate the actual ballot for that year. Chair
TenBruggencate said presuming the Clerk's Office is prepared and willing
to proceed the Commission can receive this item and take no further action.
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Chair TenBruggencate thanked Ms. Fountain - Tanigawa for their work.
Mr. Guy moved to receive the information on
the preamble. Ms. Stiglmeier seconded the
motion. Motion carried 5:0
C. Discussion and possible decision - making on the method for amending a
petition initiated charter amendment as outlined in the Charter Amendment
Proposal for Article XXIV, revised 5/18/15
Attorney Dureza thought this portion was covered during the previous
discussion for item a.
Mr. Stack moved to receive item c. Mr. Parachini
seconded the motion. Motion carried 5:0
d. Discussion and possible decision - making on the percentage of required
voters for petition initiated amendments (Article XXIV), initiative and
referendum (Article XXII) and recall (Article XXVM
Chair TenBruggencate asked Attorney Dureza if the Commission could
change the percentage requirements in all three Articles with a single
charter amendment. Attorney Dureza believed from the research he looked
at the answer is yes. Based on case law there have been other past
amendments that covered way more subjects than just two provisions in the
charter. Amendments can incorporate multiple areas of the charter being
amended. Some of the limitations in terms of the ballot question is it has to
be clear, not deceiving and the ballot question does not advocate for a
certain position nor misleads the voters it should be fine.
Chair TenBruggencate said on the table now is does the Commission want
to (change the percentages) and if so what those numbers ought to be.
Charter amendments now require a petition with 5 %, initiative, referendum
and recall require a petition with 20 %. Those numbers are different in part
because they weren't developed by the same people. The charter was
initially passed with initiative and referendum coming into the charter at a
later time with a higher standard. Does the Commission want to make those
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numbers the same or make them different in some way?
Mr. Stack said he is in favor of retaining the current percentages — 20 -20 -5
percent. This is a democracy and we who often craft the rules that people
play by have a different view, but we always have the fallback position that
the voters say yes or no to this issue. 5% is a low number by many other
standards, but it is one that has worked here since 1963 and it works just
fine. Mr. Parachini thought the problem was that it has not worked since
1963. The County's track record on initiative charter amendments is pretty
grim; two have been blown out by the courts and the one last year became a
very ugly process. Mr. Parachini respects the fact that the ballot box should
be accessible for the purpose of amending the charter, but if all you have to
get is 5% it does not create a dynamic in which the proponents need to
engage in a process of dialogue and compromise sufficient to get a large
enough proportion of the electorate to agree with them that something ought
to go on the ballot. 5 %, a very small group of people, could move forward
a charter amendment that would be stronger and more broadly accepted if it
had to undergo the process of political dialogue. Mr. Parachini did not
think it needed to be made 20% and would like to see the number get to
15% or 10% at the least.
Ms. Stiglmeier said the 5% has been in the charter since 1963 and has not
been changed since then. Looking at the most recent history the 5% has
made headlines across the nation and knowing the community has the
capability of being able to gather 5% of the voting population to be able to
try to change things. With recent history the public was able to get that 5 %,
but looking at history long term is has worked for us. Ms. Stiglmeier felt
they should leave the percentage where it is.
Mr. Guy said he has not supported the increase in the past. After deep
reflection and the financial implications to the County in court proceedings,
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he is a defendant of what is the price of democracy to get people involved
in government, and if it does not make it through the court but was an
incredible galvanizing experience then in the past he has leaned towards
that. More the financial ramifications of implementing the charter
amendment is what Mr. Guy gets nervous about keeping the number low.
The opportunity that the ramifications of these charter amendments have in
implementation throughout is something he was taught caution in creating
charter amendments. Mr. Guy would support the opportunity to lower the
initiative and have them both level out at 10 %.
Chair TenBruggencate explained that one of the reasons he has been a
proponent of doing something to shift it is the inherent difference in gravity
between a charter amendment, which changes the fundamental structure of
our government, and initiative and referendum dealing with ordinances,
which are the laws that operate under them. Rationally and in every other
county initiative and referendum are set at equal or lower than what it takes
to do a charter amendment. Chair TenBruggencate thought that one of the
reasons that the last initiative petition came in and failed is because they
used the charter amendment section to pass something which was
fundamentally not a charter amendment because it was a lower standard.
Perhaps the appropriate thing to do is to bring the numbers into balance or
make the initiative and referendum a lower bar than a charter amendment,
and he would be willing to drop initiative and referendum to 5% if they
could move charter amendments up to 10% or 15 %. Recall is a big step in
which you are trying to toss out people who have been elected by a majority
of the voters and that should probably stay at 20 %.
Mr. Parachini agreed with the Chairman, but as a practical matter if they
were to touch the signature requirements for any of the others that is an
amendment they would have to put on the ballot separately. Chair
TenBruggencate said they could put signature requirements from three
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different sections on the ballot in a yes or no question.
Mr. Stack said every commission member has at one time or another stated
they would be willing to tinker with the 5 %. The numbers that have come
up are all arbitrary and why should the Commission take that responsibility
when it can be passed along to the voters. Mr. Stack asked if it was
necessary to change the 5% to which he said no, nor did he find it desirable.
Mr. Stack said they should pass this along to the voters. Chair
TenBruggencate said that is what the Commission is doing. Mr. Stack said
if they are going to tinker with the 5% they either do it in Executive Session
or defer this to next month where more thought can be given to what
number is appropriate. Chair TenBruggencate stated no matter what the
Commission does it goes to the voters; the Commission cannot change the
charter. Mr. Stack thought they should not change any of the percentages.
Ms. Stiglmeier said if they try to lump everything together and the voters
agree with one percentage but not another one then nothing goes through.
If they break it out there is the possibility of making some changes. Mr.
Guy said then he feared they would all go to a higher rate, which is why he
likes putting them altogether. The value of the exercise is the dialogue
between a charter amendment, initiative and referendum, and recall in
which the definition of those is not crystal clear so in addition to improving
the charter there is the opportunity to educate the people and get them
involved in the process. Mr. Guy said the value in raising the charter
percentage is it engages more people, but he would like to see initiative and
referendum come down to 10 %, but would not touch recall. Mr. Guy
thought it would improve government and would get support among the
public to bring those percentages in line. Mr. Parachim said the people he
encountered in the heat of the moment who were adamant the proposal
should have been construed as a charter amendment no longer think so. Mr.
Guy also cautioned on changing the charter based off of one incident even
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though history proves there have been other instances. Chair
TenBruggencate went back to the charter amendment is something that has
some gravity and took judicial notice that the County Council is now
considering changing the form of county government to a county
management form of government — something this Commission chose not
to recommend 4 or 5 years ago. Chair TenBruggencate stated he felt the
change was both necessary and desirable that they fix the balance between
the number of signatures required for a charter amendment and the number
of signatures required for initiative and referendum because he feels it is not
working. Chair TenBruggencate said his original proposal was to take them
all to 20 %, but did not get much support for that proposal. Now he is
prepared to reduce the requirement for initiative and referendum as long as
they can keep the amount for charter at or above that level because it is the
Commission's job to fix this thing. Mr. Guy said hearing talk about
participation in the process, wanting to maintain that and retain that
opportunity for the voter is more why he supports it, and not because of the
errors that have been made. 10% gets more people involved; you have to
really do some work which gets more people involved in the democratic
process so Mr. Guy would support raising to 10 %.
Mr. Parachini moved to propose to the electorate
that they accept raising (sic) the signature
percentages for both initiative ordinances and
charter amendments to 10 %, which lowers it for
ordinances and raises it for charter amendments
and makes them equal but leaves recall alone. Mr.
Guy seconded the motion for discussion.
Mr. Guy said he is inclined to support that but they are not under the gun
and there are two more people not present that would have great
information and he would like to see this deferred.
Mr. Guy moved to defer this agenda item to the
July meeting. Ms. Stiglmeier seconded the
motion. Motion carried 4:1 (nay-Stack)
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Announcements
Next Meeting: Monday, July 27, 2015
Chair TenBruggencate noted he received a request from Mr. Parachim to
put something new on the agenda for next month which is whether to do
something about the issue that you can't recall County Councilmembers
because they only serve for two years.
Chair TenBruggencate also noted that Mia Ako has been approved as a
Commissioner by the County Council and will be sworn in at the beginning
of the next meeting. Mr. Guy and Ms. Stiglmeier announced that they
would not be present at the July meeting.
Adjournment
Mr. Guy moved to adjourn the meeting at 5:17
p.m. Mr. Stack seconded the motion. Motion
carried 5:0
Submitted by:
Barbara Davis, Support Clerk
O Approved as circulated.
() Approved with amendments. See minutes of
Reviewed and Approved by:
meeting.
Jan TenBruggencate, Chair