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Updated Travel Policy Input

From: domainremoved <Lynne>
Date: Mon, 11 Feb 2019 14:17:07 -0800

Hello Council,

I’m writing here with input regarding the updated travel policy.
Unfortunately, I will also need to miss Tuesday's Council meeting but will
watch it later!

High-Level Suggestions

· Can we add a section for Activities Not Considered Reimbursable?
Palo Alto’s City Council Protocols and Procedures Handbook lists the
following examples:

o Voluntary attendance at any conference or meeting, not representing the

o Meetings of social or service organizations

o Meetings of voter groups or with individual citizens concerns with
agenda items

o Election campaign activities

o Alcohol and entertainment expenses

o Personal portion of the trip and other non-mileage automobile expenses

· Reports to Council. Can we add some details that would convey
general expectations for these brief, verbal updates, such as:

o Where went/how many days

o Cost to City (aka taxpayers)

o Meetings attended (public and private)

o How trip served the public’s business (giving specifics not

· Travel Paid for by Third Parties

o Would you consider prohibiting this entirely?

o I’d like to see: Generally, you may not accept payments for travel or
travel-related expenses from sources other than the City.”

o Is this kind of travel necessary or beneficial to MP when so many of
our most serious current problems (housing, traffic, road infrastructure)
need regional solutions?

o Other than visits related to Sister City Relationships, how does
foreign travel by Council members *directly* benefit the residents of Menlo
Park? To me, these kinds of trips convey personal benefits on those

Detailed Input

Page 1 of Travel, Meal and Lodging Policy (Findings)

· Instead of “Findings” seems that a better title would be
“Introduction.” I would start with a brief overview as to the purpose of
the Policy, and then a brief summary of each major section along with the
relevant page numbers for the section. The word "Findings" makes it seem
like these are new discoveries and surely all the items cannot be
considered that.

· I would also tighten the content, use more precise language and
add some definitions. For example the term “substantial benefit” needs
defining. The section on meals comes too early and it’s odd in that most of
the document doesn’t focus on meals. There is also no content related to
lodging, despite the document’s name.

· Instead of pointing the reader to Gov. Code sections 53232.2 and
53233.3, I would give some details as to what they will find in those

· The report refers to Gov. Code sections 53232.2 and 53233.3 but
these codes pertain to reimbursement requirements. However, these codes do
not specify what constitutes official agency business. I would also add a
reference to FPPC Regulation 18950.1 and use some of its examples to better
define what constitutes official agency business activities that warrants
reimbursable expenses.

· The contents somewhat overlap with what’s in Resolution NO. 6485,
provided at the end of the staff report.

Page 2: Travel, Meal and Lodging Policy (Authorized Expenses)

· I would use the label “Eligible Activities” and use language
taken directly from FPPC language in Regulation 18950.1.

· Page seems unnecessarily detailed with the inclusion of the types
of U.S. organizations that host seminars etc. Is the list necessary? Then,
I suspect that most of us are concerned about the foreign trips and not the
U.S. ones!

· Section mixes items regulated by law with others that may not be
regulated, such as taking an employee out to a meal. It would be helpful to
add references to relevant regulations, as appropriate.

· Can you add some specifics related to employee travel and meals
out? In other words, how often can they go? Which classifications of
employees get to go? Are these opportunities fairly distributed? What
reporting expectations do employees have post trip? How often are employees
treated to meals or possibly retirement parties? More context would help.

· Misuse of Public Resources. I appreciate your adding that “City
equipment, titles and staff time must only be used for authorized City
business. However, the point may be missed without a few more details such
as those found in Cal Gov Code Title 2, Chapter 5, 8314.

 Page 3: Travel, Meal and Lodging Policy

· Travel Paid for By Third Parties.

o I think it would be best to prohibit accepting travel paid for by third
parties while working for the City or why serving as an elected official
for the City.

o We cannot be sure that a foreign entity is accurately representing
itself as a non-profit.

o A supposed non-profit (501c3) may instead be a front for a foreign
government or perhaps even a spying agency. As anyone following world news
knows, some foreign governments act in ways contrary to U.S. interests.

o How can our local Council members, not typically experienced in
diplomacy or privy to State Department briefings, avoid possible traps?

o Even if the FPPC pre-authorizes the trip, the trip may still be
problematic. The FPPC has limited staffing and it miss some foreign
entities who have disguised who they really represent.

· Enforcement and Cost Control.

o I consider this inadequate, especially given the experience of other
cities who have “in-house” oversight for their ethical lapses.

o A better oversight would be complete transparency by posting details at
the MP website. Let the public see the cumulative totals of these kinds of
trips. I would like to see a quarterly list of who traveled, where, costs,
who paid, purpose of trip and how exactly it benefited MP. Posting this
information may even be a FPPC requirement.

Lynne Bramlett
Received on Mon Feb 11 2019 - 14:14:20 PST

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