HomeMy WebLinkAboutMemo Mar 16, 2012 Attch 3(Page 309 of 315)
Mayor
Ron Morrison
Council Members
Alejandra 5otelo-Solis
Louis Natividad
Mona Rios
Rosalie Zarate
-0* CALIFORNIA
NATIONAL CITY
coaroa�ts�
Office of the City Attorney
MEMORANDUM
TO: Mayor and City Council
FROM: City Attorney
SUBJECT: Oversight Board Appointees and Vacancies
Attachment 3
CityAttorney
Claudia Gacitua Silva
Deprly City Attorney
Jennifer Knight
DATE; March 16, 2012
The City Council has asked the City Attorney to return with further information
regarding the appointment process applicable to the oversight board established pursuant to
ABx1 26. Specifically, the City Council asked for: 1) further information regarding what occurs
in the event of a vacancy to the oversight board; and, 2) further analysis regarding the ability to
appoint "back-up" members in the case of a vacancy. Both of these questions are limited to the
two appointments to the oversight board made by the Mayor. Lastly, the Council inquired into
the possibility of a policy to address the appointment process, lists of employees, vacancies,
alternates, and timelines.
I.
HEALTH AND SAFETY CODE SECTION 34179
GOVERNS THE OVERSIGHT BOARD APPOINTMENT PROCESS
A. Health and Safety Code Section 34179fa) Addresses the Composition of the Oversight
Board
ABx1 26, as part of the dissolution of redevelopment agencies, requires each successor
agency to "have an oversight beard composed of seven members." Health and Safety Code
section 34179(a). Two of the seven appointments are mayoral appointments. Health and Safety
Code sections 34179(a)(2) and 34179(a)(7). The appointment process was previously discussed
in a Memorandum to the Mayor and City Council, dated February 21, 2012,
B. Health and Safety Code Section 34179(b) Addresses Vacancies
Section 34179(b) states:
The Governor may appoint individuals to fill any oversight board
member position described in subdivision (a) that has not been filled
by January 15, 2012, or any member position that remains vacant for
more than 60 days.
1243 National City Boulevard; National City, California 91950-4301
Tel,: (619) 336.4220 Fax: (619) 336.4327
(Page 310 of 315)
The date of January 15, 2012 has now been moved to May 15, 2012, as a result of the
Supreme Court's ruling which extended deadline dates by four months. The deadline for the City
to make its appointments to the oversight board is May 1, 2012. The May 1st date fails to account
for actions which must be taken by the oversight board by April 15, 2012. Given that the
oversight board must take certain actions by April 15, 2012 to comply with other ABx 1 26
deadlines, the City appointments have already occurred so that the oversight board can be seated
as soon as a quorum is appointed`.
The statute provides that the Governor does not make an appointment to fill a subsequent
vacancy to the oversight board until 60 days have passed. Accordingly, should a vacancy occur
to the oversight board, the appointing body has 60 days to fill that vacancy. Should the vacancy
not be filled within that time frame, then the Governor may fill the appointment. Accordingly,
the Mayor will have 60 days to fill an appointment should one or both of its members vacate
their position.
A position can be vacated either by resignation or removal. A member serves at the
pleasure of the appointing entity. Health and Safety Code section 34179(g). There are not
defined teens for members of the oversight board.
C. `Back-up" Appointments to the Oversight Board
ABx1 26 neither contemplates nor authorizes "alternate" appointments. Thus, an alternate
member could not be appointed to serve on the oversight board in the manner alternate
appointments typically serve. The Council inquired as whether "back-up" appointments could be
made, should a vacancy occur, to avoid the loss of that appointment to the oversight board. There
is a 60 day window to fill vacancies, thus the appointment would not be immediately lost should
a vacancy occur. Thus, there is no direct advantage to malting "back up" appointments.
In the event the Mayor sought to pursue "back-up" appointments, it should be noted such
appointee would not have any authority to act or participate on the oversight board. They could
attend the meetings as a member of the public. In addition, a "backup" appointment would be
viewed more advisory in nature, because should a vacancy occur in the future, the Mayor and
Council sitting at the time of the vacancy have the power to appoint and approve, respectively.
Lastly, should "back up" appointments be sought, two such appointments would need to occur
(one for each mayoral appointee).
Overall, there is sufficient time to appoint a member to the oversight board in the event of
a vacancy. Appointing "back-up" members does not provide any greater opportunity to fill a
vacancy than already exists in the legislation.
As of the date of this Memorandum, the City has not yet been notified by the other appointing agencies about their
appointments. We anticipate the County to make its appointments on April 3, 2012. In addition, we await formal
notification of the appointments by the County Water Authority, the County Board of Education, and the Chancellor
of the California Community Colleges.
2 Oversight Board Appointees and Vacancies
March 20, 2012 Agenda Item
(Page 311 of 315)
D. Upcoming Deadlines
The Council asked staff to identify the most immediate deadlines regarding ABx126.
Below are the most immediate upcoming deadiines,•In addition, the previous presentation by
Financial Advisor Michael Busch provided an exhaustive list of deadlines.
April 1, 2012: deadline for Successor Agency to notify County Auditor -Controller if the
total amount available to the SA is insufficient to fund the specified payments in the six-month
fiscal period.
April 15 2012: last day for ROPS and Administrative Budget to be approved by
oversight board.
April 15, 2012: deadline to submit ROPS to the State Department of Finance, the State
Auditor -Controller, and the County Auditor; and to post ROPS on Successor Agency website.
May 1, 2012: deadline for all appointments to the oversight board
May I, 2012: deadline for Successor Agency to notify County Auditor -Controller if the
total amount available to the SA is insufficient to fund the specified payments for the next six-
month fiscal period.
E. A Policy Could Be Adopted to Address the Appointment Process as long as such Policy
Does Not Conflict with the Process Stated in ABx1 26 or Government Code section 40605
Council inquired whether a policy could be adopted which addresses the appointment
process for the oversight board. A policy could be adopted which supplements ABx1 26 and
Government Code section 40605 (addressing appoints, generally), but it cannot conflict or
contradict either provision. As ABx1 26 does address the vacancy issue, however, it does not
appear that a policy is needed to address such circumstance.
CONCLUSION
The provisions of ABx 1 26 provide a 60 day window for appointments to occur to fill
vacancies. If a vacancy is not filled in that time frame, then the Governor fills the vacancy. ABx1
26 does not provide for alternate members, thus alternates could not be appointed. Back-up
appoint?icnts for vacancies could occur and would be advisory in nature. Lastly, a policy that
does not conflict or contradict ABx1 26 or Government Code se tion 40605 could be adopted.
il
CL
City Attom
ILVA
2 In the event the oversight board does not have a quorum appointed and ready to meet, then the ROPS will need to
be sent in draft form to the other entities with an explanation of the status. In addition, while the Administrative
Budget does not have a stated deadline, it does need to be prepared in 6 month increments, thus it makes sense to
prepare and submit this budget with the ROPS.
3 Oversight Board Appointees and Vacancies
March 20, 2012 Agenda Item