DATE: September 2, 2026
TO: Honorable Mayor and City Councilmembers
FROM: City Attorney's Office
TITLE: ADOPTION OF RESOLUTIONS AMENDING THE LOCAL CONFLICT OF INTEREST CODES FOR THE CITY OF OCEANSIDE, OCEANSIDE SMALL CRAFT HARBOR DISTRICT AND OCEANSIDE COMMUNITY DEVELOPMENT COMMISSION
RECOMMENDATION
title
The City Attorney recommends as follows:
1. The City Council adopt a resolution approving amendments to the City of Oceanside’s local conflict of interest code and adopting the Appendix.
2. The Harbor District Board of Directors adopt the resolution approving amendments to the City of Oceanside local conflict of interest code as the local conflict of interest code for the District and adopting the Appendix.
3. The Community Development Commission adopt the resolution approving amendments to the City of Oceanside local conflict of interest code as the local conflict of interest code for the Commission and adopting the Appendix.
body
BACKGROUND AND ANALYSIS
The Political Reform Act of 1974 requires local agencies to adopt local conflict of interest codes and to update those codes periodically to reflect changes to the employment positions within the agencies. The local conflict of interest codes must be consistent with the statute and with regulations adopted by the Fair Political Practices Commission (“FPPC”).
Sections 2.61 - 2.69 of the Oceanside City Code establish the local conflict of interest code for the City. As authorized by state law, the City Council has adopted the provisions of Title 2 California Code of Regulations section 18730 (a standardized local conflict of interest code) along with certain supplemental provisions as the local code for the City. City Code section 2.62 requires the City Council to adopt a resolution indicating the employee positions and members of boards, commissions and committees subject to conflict of interest disclosure requirements.
The City’s local conflict of interest code references an appendix that sets forth the various City employment positions and members of boards, commissions and committees (often referred to as “designated positions/employees”) along with the categories and disclosure requirements for those positions. The proposed resolutions would update the appendix for the City as required by Government Code section 87360.5.
The Community Development Commission and the Small Craft Harbor District are also required to have local conflict of interest codes. In order to formalize their reliance on the City’s local conflict of interest code, staff recommends that both the Commission and the District adopt resolutions adopting the City’s local conflict of interest code and code appendix.
Government Code section 87306.5 requires each local agency to review its local conflict of interest code in even-numbered years and to make such amendments as may be necessary as a result of that review. The review has been accomplished by the City Attorney (and Commission General Counsel and Harbor Attorney). In light of that review, a revised Local Conflict of Interest Code Appendix, List of Designated Positions/Employees, and Disclosure Requirements has been prepared (hereinafter called “Appendix”).
The revised Appendix makes changes to the previous disclosure list and requirements by adding new positions created within the City that did not exist the last time the conflict of interest code was amended as well as positions whose job descriptions warrant inclusion. Those additions can be found in Attachment 1 underlined in blue text, and are listed below for reference:
Additions To Designated Positions
Asset Management Administrator
Assistant Public Works Director
Assistant Water Utilities Director
Chief Assistant City Attorney
Coastal Zone Manager
Communication and Engagement Manager
Crimes and Intelligence Manager
Deputy Fire Marshal I
Deputy Fire Marshal II
Forensics and Evidence Manager
Geographic Information Systems Supervisor
Housing/Neighborhood Services Director
Information Technology Director
Laboratory Supervisor
Meter Services Supervisor
Parking Enforcement Supervisor
Parks and Recreation Programs Administrator
Parks and Recreation Director
Parks and Recreation Division Manager
Plant Maintenance Supervisor
Procurement and Accounts Payable Supervisor
Revenue Operations Supervisor
Risk Analyst I
Senior Electrical/Traffic Maintenance Supervisor
Senior Employee Relations Analyst
Senior Parks and Beaches Supervisor
Special Events Administrator
Urban Forestry/Landscape Supervisor
Water Distribution Supervisor
Water Efficiency Program Manager
Water Engineering Manager
Water Treatment Superintendent
Water Treatment Supervisor
Water/Wastewater Plant Supervisor
Water/Wastewater Treatment Superintendent
Watershed Protection Program Manager
Zero Waste Program Manager
Members of the City Council, the Planning Commission, the City Manager, the City Attorney and the City Treasurer are required by statute to file FPPC form 700 disclosure statements and to disclose financial interests pursuant to state law. These positions are excluded from the list of positions contained in the Appendix. The Harbor District finance director is designated by the Appendix as a position responsible for the management of public investments and is also required to disclose investments on the 700 form.
CITY ATTORNEY ANALYSIS
The referenced documents have been reviewed and approved as to form.
end
Prepared by: T. Steven Burke, Jr., City Attorney
Reviewed by: Robert O’Brien, Deputy City Manager
Submitted by: Jonathan Borrego, City Manager
ATTACHMENTS:
1. Conflict of Interest - Appendix
2. Council Resolution
3. CDC Resolution
4. Harbor Resolution