my name is jury with the san francisco land-use coalition. i support the proposed resolution to oppose bill 50 unless there is an amendment to include transportation mitigation provisions. san francisco has 865,000 people living in 47 square miles or 18,440 people per square mile. we have the second highest number of residents per square mile in the united states. san francisco has twice the population density of los angeles and three times the density of san jose. it is much more difficult and costly to build and maintain infrastructure in a very dense city. bill 50 needs to be modified to address the existing disparity in population density between san francisco, san jose, and los angeles, and allow for transportation mitigation. san francisco's current public

transit infrastructure is unable to support the current population density, let alone the proposed higher densification. sfmta has the second oldest and the highest mileage public transit fleet in the united states. this is a bay area problem. oakland and fremont are also on the worst city list. the m.t.a. has a serious staffing problem. as was mentioned, not enough drivers and not enough skilled workers to maintain aging equipment. thank you. >> thank you. next speaker, please and if we can return the overhead. thank you. >> good morning, transit authority, i am a tenant in district eight. i am a munimobile writer. i take the jay line, the 49, every line. i have been in this city almost 50 years so i've familiar with

the transit, which is in a sorry state. the proposed state senate bill 50, the more homes act, links housing density and the proximity to transit. the bill 50 would enable developers to build higher and more dems housing along transit corridors with the highest percentage of the units being market rate housing. it makes perfect sense there be a provision for transportation infrastructure to support the growth policies for transit rich areas because we need to have plans for complete communities. and therefore, i support the resolution to oppose the bill 50 unless it is amended unless there is companion legislation that specifically would provide sufficient new funding for community planning to ensure local jurisdictions can evaluate transportation service and infrastructure needs resulting from s.p. -- from bill 50 provide sufficient funding to

the local jurisdictions to deliver the additional transportation infrastructure and services to support the housing development enabled under bill 50, which could include supporting existing and new grants programs. and provide unlimited exemption from ceqa analysis for public transportation projects such that the changes inland use regulations resulting from the project aren't considered significant. please support this bill. thank you. >> thank you. next speaker, please. >> good morning, commissioners. first of all, i want to welcome our new supervisor, supervisor preston. we are just elated to have you here. and thank you to commissioner marr for introducing this resolution that is very much shedding the light on the sham

that bill 50 is. commissioners, how could we possibly increase population? let's not talk about density, just population. when the entire transit system in the city of san francisco is broken? chair peskin, you brought up the pin issue. that is an absolute embarrassment. we are bringing in a new fleet of cars, nobody has even quality assured them, and almost a year into this, we realize these are grave, serious problems. so are we transit rich? i daresay not. here is the report that came out from our late mayor that commissioned this and it came out in 2018. this is not too long ago. according to the report, overhead, police. the city of san francisco is $22 billion, that is not an m., it is be, billion dollars in their red. by 2045, because of the

deficiencies, the deficit in the funding that we have for transit this is a report out -- that was commissioned by the city. this is not a made up report by, the public or god forbid, the nimbys or that faction. we are not doing anything about it. there is no source, a single source identified to close this gap in 25 years. secondly, this whole thing about transit rich, here is how transit rich, district four is. fifty minutes from there to their. that is how transit rich we are. >> thank you. next speaker, please. >> good morning. thank you for listening to all of this information.

i support supervisor more's resolution to bill 50 because it was well thought out and includes funding. that is the most important part. let's make our city better than it is now. thank you. >> thank you. >> i am with van ness neighbours i actually had the interesting experience the other day. i went, for the first time to the bart station in oakland. for the first time, i saw an area that seems like it was ripe for affordable housing. it was covered and surrounded by hundreds and hundreds of acres of deteriorated and closed factories. it would probably be possible to put maybe 10,000 units of new housing there and has a major bart station and major bus station.

let's be positive this works. what would it take? it would take increased funding for bart, increased funding for a.c. transit, increased funding for s.f. munimobile because you have to connect the workers to get to the station, to get into the city and get to work, i think the most -- i think affordable housing is actually more possible than transit. i think the transit has to come first to be able to get people to work, which is the -- and into school and it is one of the most important things we have to do. we can't just plunk down any kind of housing without connections. we know that another important thing is we must have a new tunnel. we are maxed out with everything to do with bart. put transit first and do support these amendments. thank you.

>> thank you. edward mason. the m.t.a. and the sfcta should participate with the planning department to acquire development funds. growth must fund growth and not rely on state funding. the nexus study for development and transportation study resulted in this transit sustainability fee being reduced by 75%. in essence, growth was not funding growth and there should be more reliance on the developers paying the fee. this is an article for the valley transportation authority in santa clara county. on the 208th of december, they will restructure their transit lines. bottom line is, they will escape probably most of the

requirements of bill 50 by having service upgraded to 15 minutes from 30 minutes and a lot of lines are going to go that way. however, you the transit stations, they will have anywhere from 30 to 238 buses in our. indirectly, senate bill 50 has rezoned that area around those centres. this is in direct. my concern is growth must fund growth and don't go to the state piggy bank for funding because the state piggy bank has been funded with our tax dollars that go in there. the developers should be responsible for any type of development funds that are required on that. and also, keep in mind what happens when transportation is driving the planning results as it winds its way through senate bill 50.

thank you. >> thank you. next speaker, please. >> hello. i'm with the san francisco transit riders. i am here to support supervisor mark's resolution. it is not to like there are a ton of m.t.c. his on munimobile buses and trains waiting to whisk everybody along. through the mayor -- do the work on the mayor's task force, we have gotten clear on how far behind munimobile is on staffing and maintenance and how much -- how far it has to go to catch up to current demand, nevermi the mode shift we need to achieve and nevermind future populations if we really prioritize transit to serve new development, then we would have had the 16th street project, the new fair landing and the t6 before the chase center opened and not after. and makes sense for us to tie the streamlining of approvals and funding for transit to

increase development and increase housing. thank you very much. >> thank you. next speaker, please. >> good morning, commissioners. welcome to supervisor preston. looking forward to working with all of you. i'm the council of community housing organization -- we were not aware this is coming. this is very smart to support the resolution before you. i know this is coupled with the resolution the full board of supervisors will be considering with a different frame. this makes public policy transit-oriented development together. we really do that and so you are doing the right things. you are you're talking about pieces of the puzzle. this is not to say -- i think it is important for everyone listening. do not up zone, do not plan, do not grow, do not develop. all these things need to happen, but you need to think about them carefully. we need to think about them carefully and do it right. there's nothing wrong with saying when used to be done

right to grow and plan and develop. i also suggest we stepped back from the details of this resolution and consider that we are in a historic time. this is absolutely a transformative change after decades and decades in the region, in california and nationally of suburban sprawl. that is how we accommodate population growth as a nation and as a region. we are reversing that. what that does is it presents massive challenges to tackle. it is not something for simple, a wand waving solutions. that will not fix it. i really believe that san francisco is built as a place to figure out how to do it and do it right. all of you as electeds are doing excellent jobs as leaders. we have the democracy to do it in this jurisdiction. we have the advocacy committee, folks who are experts in this field and we have dedicated activists on the ground. let's figure out how to do this

right. thank you for sending the message about how to get it right and grow right. thank you. >> thank you. are there any other members of this public -- of the public for item number 11? we will close public comment. would we liked to make a motion to adopt the resolution? >> yes. >> moved by commissioner mar is there a second? come seconded by commissioner preston. is there any discussion? seeing none, same house, same call, the matter is finally approved. please call item 12 through 14 together. >> item from the personnel committee. item 12 is recommend adoption of a real program manager job classification and revised organization chart. item 13 is evaluation of public employee performance and recommend approval of performance objectives for 2020. i do 14, recommended option of the revised salary structure amendment of the existing employment agreement and setting

annual compensation for the director for 2020. they are all action items. >> thank you, colleagues. the personnel committee consisting of myself, the vice chair and personnel committee member commissioner ronen met earlier today. we have recommendations for you, but if any member of the body would like to meet in closed session, we can do so. if not, if there is no motion to meet in closed session, the item has been called. i would be happy to share with you what the personnel committee recommends to this body. seeing no motion to meet in closed session, the personnel committee met to discuss the performance evaluation and recommend approval of our executive director for the performance objectives for the

coming year and found her work during the 2019 year to be exceptionally good. we took action in closed session , which i reported out to recommend a revised salary structure range, which is a 15% increase in the range, but not in salary to a new range between 217 dollars is a minimum to $304,000 as a maximum. we also recommend to you the amendment of the employment contract for an additional three years so this would be the third three-year contract which would commence on the last day of this month and last until 2022, and finally, the personnel committee recommends an annual compensation for the 2020 year with a 5% increase, which is in line with data that the committee reviewed for other similar positions for a total

salary of $267,417, and we recommended that the unspent $15,000 for employee development , which missed chang did not spend in 2019 because she has been incredibly busy and working her behind off, they spent in 20204 things that will help enhance her job performance missed chang, we are delighted to have you. we hold you in the highest of esteem. colleagues, are there any questions or comments? are there any members of the public would like to comment on items 12 or 14 in so far as we are not reading in closed session? public comment is closed. is there a motion to move the personnel committee's recommendations? made by commissioner mar and seconded by commissioner yee. we have the same house, same call. those items are adopted. is there any general public comment?

>> thank you, supervisors. i would like to talk about the five m. building. the reason i am addressing you is that i have contacted multiple people throughout these five years. i want to ensure that there are no encroachments for the width of the street, which is the width of 30 feet. the reason i'm requesting this, i know some of you have been briefed. there is another alignment with the lying, it is on the alignment -- it has been on the table for eight years and as we discussed during the first personnel committee, the same individual that was responsible

what happened -- and by the way, the procurement as the caltrain railcar. if they are also responsible for ignoring that alignment. i want to give you some updates on this. i have worked -- walked this alignment with engineers who have done something similar the last few years. and they basically agreed that it works. however, what you are trying to do is the equivalent of climbing mount everest with bare feet. i will make you another offer. i will not take my shoes and my socks off. i am willing to volunteer my time between now and the appointment of the new rail manager pro bono to the city and the county. i'm not asking for a salary, i'm not asking for benefits. the only thing i would ask for his assistance with housing because -- [indiscernible]

it is out there on the table. i will leave it up to you. thank you for your consideration merry christmas and happy new year. >> thank you for that generous offer which you are welcome to take up with staff. do want you to know that they went up part of mount everest, barefoot. next speaker, please. >> good afternoon. i like to provide a commuter bus update, especially at 24th and church. we now have 100 authorized private commuter buses, plus several other buses that have been going on since before thanksgiving that i have been recording on a daily basis. part of the real problem is with 100 buses in four hours, there is a peak period between 7:00 a.m. and 8:30 a.m. and the consequence is you have simultaneous arrivals.

there is only two dedicated flight zones that have been set aside for the commuter buses. the problem is you then have buses three, four, and five that are backing up in the street between church and sanchez. that causes all kinds of congestion. so as a consequence, you know, it is just getting to the point where 24th street is a neighborhood street that has been designated as a minor arterial. it is accommodating inner-city over the highway. you put that into the mix with an occasional fire truck or an ambulance or police car, whatever, and all the congestion that you have a 24th and church. i think it really boils down to we need to reevaluate the whole commuter bus program and consider revisiting the hub

study because if you work 50 miles from where you work, you will be inconvenienced one way or another. and the detriment is now on the neighborhood. it is something i think that needs to be revisited because having 100 buses coming down your neighborhood, that means there's 100 buses in the evening so there's over 200 buses, plus you have buses that are idling at 205th and castro to initiate a run. it needs consideration. thank you. >> thank you. thank you for the data that you constantly procure for the city and county of san francisco and we have thank you for that before and i think we all get your e-mails. i very much would encourage you to speak with ramos after this meeting. if we have to revisit the commuter shuttle battles, both old because you have that many

buses backing up, the system, it sounds -- it may not be working as intended, so i encourage you to get with the sfmta so we don't have to fix it, but if the sfmta doesn't, we can. with that, are there any other members of the public for this item? seeing none, general public comment is closed. i will wish everybody a very happy, healthy, prosperous new year and we are adjourned. .

>> december 20 of 2019. we'll take roll call. commissioner lee is absent today. agenda item number 2, public comment on those items not appearing on the agenda. >> good afternoon. thank you, commissioners. my name is ellen. i have my name tag here. i am a public employee. i am a union delegate for government employees. i am also the director of public relations for california for the grand jury for the san francisco

chapter. i have been coming to you at the commissions with other government employees, many times. in 2016, 2017, 2018 and 2019. the last time i was here was november 15, 2019, which is last month. i came before you demanding as a commission to investigate corruption within the commission department. between april 2017 to july 2017, six public employees reported bribery, extortion and retaliation with the ethics commission department, but no record was found, and they never got back to us. i was one of the eight candidates for mayor, june 2018 election. i just finished my mayor run for the november election. i was one of the six mayor candidates for the last month's

election. i was bullied by democrats and democratic leaders from city hall and from different departments and different leaderships from different communities. many of my billboards and posters were illegally removed because i am a conservative republican. i am a conservative republican, and i am for the people. i have been coming out to you about possible corruption with electoral officials and election fraud. in 2018, san francisco payers, taxpayers, paid $4.16 million in matching funds to support government scam. the government has been running a scam for election fraud to empower democrats only. for the last 45 years, no other party other than democrats. it is a public scam created by

democrats. november 19, $6 million bond for 2800 housing units is also a violation for equality for all. the united states constitution article 6 and the supreme court which stated that united states constitution is the supreme law of the land, the state and city violate the constitution. it's called treason. recreational cannabis is also a violation of federal law. it is a government race to raise a lot of money to do drug rehabs because the illegal drugs support it and pay for our taxpayers. you as ethics commission, i believe you have the duty to investigate many of the

complaints that i am bringing to you -- before you today. we the people have been facing a tyranny government for the last many years. we lost our quality of life in san francisco. we are worse than a third world country in san francisco. so today i'm here again because you ethics commissioners to restore law and order to protect san francisco for the way you sign up for. thank you. and for public record, my packet. thank you. >> thank you. any other public comment on agenda item number 2? moving onto consent calendar items to consider number 3, draft minutes for the ethics commission november 15, 2019, regular meeting, agenda item 4, the proposed stipulation, decision and order in the matter of the coalition for san francisco neighborhoods, complaint number 16/17-056.

and agenda item 5 the proposed stipulation decision and order in the matter of affordable housing for all, yes on d, complaint number 1718-134a. call for public comment on all three of these items? seeing no public comment, i'll move the items. >> i second. >> all in favor. >> aye. >> so the agenda items 3, 4, and 5 are unanimously approved. agenda item 6, discussion and possible action on proposed amendments to regulations related to article i chapter i of the campaign and governmental conduct code. >> thank you. good afternoon, commissioners. i'm pat ford, senior policy and legislative affairs counsel. this agenda item contains a set of regulations or i should say amendments to the regulations

that support article i chapter i of the campaign of governmental conduct code, which we call cfro because it's the campaign finance reform ordinance. the amendments represent updates that are part of two separate projects. i've condensed those into one document so that essentially for convenience that you can act on it if you choose to do so at one time. two different projects are the campaign financing review project, phase 2. this would update regulations to match the statutory changes. and secondly, the regulation amendments also address changes to the code brought about by proposition f, which was passed in the last election and the

same idea, brought changes to the code so we need to update the regulations to follow that and especially in this case to provide guidance about these new laws, because these are new provisions of law, don't provide all the details someone would need to comply with them. so this is to help fill in the blanks. what i would like to do is briefly go over at a high level what these regulation amendments are. and i would like to suggest to you five different amendments that were requested by stakeholders. i think all five of them make sense. and i will explain what they are. and i will also read the text of them where you don't already have it. i provided you with he mails from -- e-mails from these folks so you have that. these are also on the table for the public. so in some cases you have the amendments in writing. in other cases they were proposed to me in concept-form

and i have texts for you that i will read. >> before we proceed, i would like to ask the city attorney, is it okay for us to consider these amendments? >> yes. >> okay. thank you. >> so i'll start by going over what's actually in this agenda item first and then move on to the amendments. so the way that i structured this is in the actual attachment to this which has the regulation amendments that are ordered by regulation number. so on the public financing-related amendments are combined in with the prop f amendments. i can tell you that the vast majority of what is in here is really prop f. the public financing amendments are very, very minor. so we'll talk about those first i think just to kind of get them out of the way. so really the only thing in the regulations that needs to be updated because of the changes to the code from the public

financing phase two ordinance is basically just update the initial iec amounts, the individual expenditure ceiling, the limit that each candidate must agree to. the ordinance changed where that starts. it used to start at $250,000 for supervisor candidates and at $1,475,000 for mayor candidates. it will change $300,000 and $1.7 million. the places where those need to change are called out here in the amendments. so in regulation 1.140-2, which is if you are looking at the attachment with the amendments, that's on page 8. you can see that's changed once

for each number in that regulation. then on the next page, regulation 1.143-1, it's changed there and in regulation 1.142-2 it's changed throughout. i had to do a little bit more updating in regulation 1.143-2 than just changing the initial iec levels, because this regulation consists of a set of examples to explain the mechanics of the iec adjustment process. so i had to go through and make sure they still made sense, given the new levels. some of the numbers just didn't work out. so i kept the mechanics the same, the concepts are all the same. but you'll see there are a number of changes throughout. it should basically keep the spirit of these as is. i did the same thing with phase 1 ordinance that changed the increments of the adjustment, made the increments larger. i had to do the same thing back

then, going through the examples and updating them to make sure they still made sense and showed the new regime. so this is the same idea, going through the examples, making sure they add up and now reflect the new law. so that's all for the public financing-related changes. maybe i'll stop here and ask if there are any questions about those set of changes before moving on. >> the only question i have relates to the change in the matching ratio. that was done in the ordinance itself so it's not required to be addressed here in the regulations l. >> surprisingly there was nothing in the regulations that talks about the matching ratio. i was surprised myself to find the only things that needed to be updated pertain to the initial iec level. there's nothing in the regulations about the matching ratio, nothing about what portion of a contribution can be matched, which went down from the full 500 down to 150.

those things weren't in the regulars. the regulars i would describe as being more about process of how the financing program is administered and how the different mechanics work, not so much about the goal posts or the actual parameters of it. those are just set forth in the code, and the regs, i would assume didn't see the need to elaborate on those because they were just very clear in the statute. >> okay. thank you. any other questions from commissioners? >> no. >> okay. i'll move on to the prop f-related changes, which are a lot more substantive and may be have more room for discussion. and this is where the amendments are. so i think maybe i'll start by giving a quick overview of what is actual in prop f. i know commissioner ambrose asked about that the last meeting. so i included some bullet points

here. and i'll roll through those quickly so you are all primed with what is in this ballot measure. so this is on page 3 of this agenda item. starting at the top of the page, the first thing that is in prop f is that it expands the prohibition on corporate contributions, which is currently construed narrowly, it could apply to just corporations. it expands it to cover llps and llcs. and i would presume that the intent behind this was that it doesn't matter what form of entity you choose, that these are business entities, they are for profit, they should be treated the same way. >> i'm just curious. was there any date that showed -- data that showed how limited partnerships and limited liability companies were not being picked up by the prior

prohibition of a 100 contributions were 95 coming from llps and llcs therefore we needed to address this issue? >> i'm not aware of any kind of data like that. the only thing that i'm aware of that i can speak to is actually addressed in the regs, which is that the regs used to address when llcs might be actually captured by the rule and it was based on how the l.l.c.s had elected to be taxed. i found the taxation principles to be complicated, and i am not familiar with an actual application of that regulation to an entity, so i can't tell you too much about how it worked. but that's the only thing i saw in here about non-corporation business entities making contributions. and i really couldn't tell you how common that was, only that we didn't get any advice questions that ever came to me

about it. >> thank you. >> so the next bullet point, there's a new contribution prohibition now in section 1.127. and the basis of this rule is that the person who has a financial interest in a land use matter, as defined, may not make a contribution to any candidate or office holder of mayor supervisor or city attorney, so anybody currently holding the positions or running for them. and financial interest in land use matter are both defined terms in the code. and that's where a lot of the clarification in the regs focused on, what does it mean for something to be a land use matter, what exactly does that term encompass, and what does it mean to have a financial interest.

so the third bullet point is related to 1.127, to that contribution prohibition. and it essentially requires that certain departments post a description of this rule in their agenda materials and on their websites. and those departments are the same list of departments that is used in the definition of land use matter. so we are talking about the planning department, commission, board of appeals, essentially, any of the city departments that would be making decisions on land use matters. they have to put a notice that's publicly available that just tells people that the rule exists, that they should be aware of it. >> so just to clarify the prohibition on making contributions. so this is the $500 political contribution so that $500 is now going to zero?

>> correct. it's similar in its format to the contractor contribution prohibition, which says that if you are someone who is currently bidding on a city contract or who has had a city contract approved in the last 12 months, you can't give a contribution to an elected official who is considering that bid or approved that contract. this is loosely similar, saying that if you are someone who currently has a land use matter pending or a land use matter that was resolved within the last 12 months, you cannot make a contribution to a certain set of officials and candidates. it's not pegged in the same way as the contractor rule that you can't make a contribution literally to the officials who approved that land use matter. it instead takes a different approach and defines a fixed set of officials and candidates and says you can't make a distribution to that entire set of people, regardless of whether

they were actually involved in the land use matter. >> so if you are remodeling your house because of flood damage and you need to get permits, does that qualify as a land use matter and therefore that person would be prohibited from making a contribution? >> most likely not. there is an extension in the code for primary residence. that's carved out of the definition of land use matter. there's also a dollar threshold that's baked in. so you have to have a financial interest of $5 million or more in the project or in some cases the project has to have an estimated construction cost of $5 million or more. so depending on which type of financial interest applies, there's different ways you can have a financial interest. in each one of those ways, there's a $5 million threshold that's baked in. so that would probably exclude the scenario you were describing. >> thank you. >> so the one, two, three, four,

the fourth bullet point moves on to a different part of prop f. and the next few are all related. and it's about disclaimers. so the fourth bullet point refers to an existing requirement in state law, and it builds upon it. so state law requires that certain political advertisements contain disclaimers and that the disclaimers state who the committee paying for the advertisements top funders are. so if a committee pays for independent expenditure and they've received contributions of over a certain amount from other individuals or committees, they have to put the names of those individuals or committees on the advertisement. even before prop f was passed, san francisco law expanded on that and made it the top toledo

nowheres and lowered the thresh -- the top three donors and lowered the threshold. this lowered the threshold to $5,000. and it also requires that the dollar amount contributed by each of those people be included in the disclaimer. and further more it requires that if any of those major donors -- i shouldn't use the term major donor. that's something that's used elsewhere. top contributor, we'll say. if any of the top contributors are themselves political committees that have taken in political contributions that the disclaimer must additionally list the top two contributors to those contributors. so to phrase it differently, you could have a disclaimer that

says this ad paid for by abc committee, major committee funding from xyz committee, which is funded by these two people. additional funding provided by california voter committee with funding from these two people. so you could have up to, i guess it would be nine different funders listed in a disclaimer. and with each of them it would have a dollar amount that they contributed. and from what i saw in the voter information pamphlet talking about this measure, the idea is to put more information in front of viewers or readers who see political advertisements about who paid for the advertisement and who that person got their money from. so trying to give you a glimpse into the chain of funding. sometimes people talk about nested committees or gray money when committees give money to

other committees. so the policy rationale here is to try to shed some light on that series of transactions that is behind a particular advertisement. and aside from the merits of that idea, it comes with some degree of confusion for people making advertisements. some of the regs try to provide people with guidance about how to put all that information -- because it is a lot of information, into a disclaimer that both complies with state formatting requirements, which say nothing about any of this material, the funders of the funders or the dollar amounts, and also something that looks readable and legible to people. so that's what the regs endeavor to do. i'll go over that in a moment. so the following bullet point,

prop f changes the font and format requirements for disclaimers. the highlight here is that it changes the font requirement to larger. it's now 14.5 for all disclaimers. so leaving the disclaimer world, the second-to-last bullet point prop f requires committees making independent expenditures to disclose separate cost associated with any independent expenditures during what we call the late reporting period, the 90 days before the election. so during that 90-day period, as you know, any time a committee makes an independent expenditure of $1,000 or more, they have to file a form 496, the late independent expenditure report, within 24 hours. what prop f says is not only must you file that form, which the form basically just says what expenditure did you make

and how much did it cost. additionally you need to disclose the separate costs associated with that communication, which the code says includes things like that photography, design, printing, postage, et cetera. so basically the different costs that the committee incurred in putting out that communication. that's not included right now on the 496. but prop f says you need to disclose this information as well. >> so just to make sure i understand, what is required to be disclosed right now is the aggregate cost, and this prop f is requiring a breakdown of those separate cost components? >> yeah, i think that's a good way to phrase it. the 496 requirement is aggregate. you typically would just put out literature supporting this candidate for supervisor's $10,000. >> now we need to know how much

the printing was, the photographer, the design? is there a policy rationale underlying this? >> i don't recall that this particular requirement was addressed in voter information pamphlet, which is usually where you go to look for legislative intent, what the voters were thinking when they approved this. i don't recall that this was addressed in those materials. i can tell you that a similar requirement already exists for candidate mass mailings. when candidates send out 200 or more pieces of identical mail, they have to file what's called an itemized disclosure statement that discloses the total cost of the mailing and breaks down the separate costs associated with the mailing. and essentially what prop f does is it duplicates that requirement for i.e.s.

so the final bullet point here, it's a good segue, i was just talking about candidate mass mailings. the final bullet point expands that disclosure requirement in mass mailing disclosure requirement, to i.e. committees. so this is kind of a technical thing, but the interaction between these final two bullet points is a little complex. but the way that it works is before the 90th day before an election, let's say 91 days or more before an election, if a committee incurs an independent expenditure, they will only have to make a filing, an immediate filing. they always have to do statements but they only have to do an immediate filing if the

i.e. is a mass mailing. so if they do a mass mailing, 200 or more identical pieces of mail, within five days they'll need to file the mass mailing form which breaks down the separate cost of the mass mailing, and they have to include a copy of the mass mailing. once they hit that 90th day before the election and they enter the late reporting period, now it doesn't matter what form the i.e. takes on. as long as it's $1,000 or more, they have to file a 496. and already under existing law, when you file a 496, you have to attach a copy of the ad. and as i was describing under prop f, when you file a 496, you also have to break down the separate costs. so i think the easiest way to think of it is the disclosures are now going to be the same no matter what, for i.e.s. whenever you do an i.e. that

requires immediate disclosure, you have to disclose a copy of the ad, you have to disclose the aggregate cost, you have to break down the separate cost related to the i.e. the difference between the late reporting period and prior to the late reporting period -- >> there's no distinction anymore. >> not in what you file but whether you have to file. so if you are before the late reporting period, you are 91 days or more out, you only have to do the immediate filing if it's a mass mailing. if it's not a mass mailing you don't need to file immediately. once you reach the 90-day late reporting period, than any i.e. of $1,000 or more triggers that immediate reporting. prosecution please stand -- [br-

>> what the conversation was that his public comment relates to is that eye reached out to a number of treasurers and political attorneys to get feedback. especially i wanted to hear