HomeMy WebLinkAboutPlanning 2026-04-23 Item 8.1 - Procedures TrainingPlanning Commission Protocols:
Role of the PC, Open Public Meetings, & Public
Records
Nick Morton, Assistant City Attorney
GEDEN
MUR\PHY Tukwila Planning Commission
WALLACE
ATTORNEYS
Presentation Overview:
• Role of the Tukwila Planning Commission
• Tukwila Municipal Code (TMC) Chapter 2.36
• Planning Commission Bylaws
• Open Public Meetings Act (OPMA) Requirements
• Chapter 42.30 RCW
• Public Records Act (PRA) Requirements/Retention
• Chapter 42.56 RCW
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Planning Commission - TMC Chapter 2.36
• Pursuant to the authority conferred by RCW 35A.63, the Tukwila
Planning Commission ("Commission") is hereby established to serve
in an advisory capacity to the Mayor and City Council on matters
relating to land use, comprehensive planning and zoning. - TMC
§2.36.010
• The City Council delegates the Planning Commission's workload
either through:
• Outlining their responsibilities in the Zoning Code or
• Asking for a recommendation on a special topic
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Bylaws - Planning Commission
Objectives
1. To influence in a positive manner the major planning efforts and
projects that will affect the city.
2. To advocate consistency and integration among plans which provide a
future image and direction for the city as well as the means for
meeting more immediate needs.
3. To ensure that effective citizen participation, including opportunities
for timely public involvement, are part of the City's planning
processes.
4. To represent a whole -city viewpoint when evaluating proposed plans,
projects and issues.
5. To make recommendations which recognize the City's needs and
government's constraints as well as identified citizen viewpoints.
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Bylaws -Legislative Public Hearings
Article V, Section 1: Meetings
"The purpose of legislative public hearings is to obtain public input on
matters of policy. Such hearings do not involve the legal rights of specific,
private parties in a contested setting but rather affect a wider range of
citizens or perhaps the entire city. If challenged, the decision reached at a
legislative public hearing is only reviewed to determine if it is
constitutional or violates state law."
"The Commission may devote part or all of a meeting to an informational
work session during which no comments from the public will be
permitted, unless the Chairperson or a majority, on a case -by -case basis,
decides otherwise."
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Bylaws - Legislative Hearing Procedures
All legislative hearings held by the Commission shall use the following
procedures:
1. Chair — state the purpose of the legislative hearing and the action
the Commission may take.
2. Staff — present the staff report and take questions from the
Commission.
3. Chair — open the public hearing and receive public comment.
4. Chair — close the public hearing once all public comment is received.
5. Commission — make a motion on the topic at issue.
6. Commission — deliberate.
7. Chair — call for a vote on the motion.
NOTE — Commission Decisions and recommendations must be consistent
with the Comprehensive Plan and development regulations.
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Bylaws -Voting
Voting on all matters is by simple majority (except bylaw amendments):
• The Chair has one vote — same as all other Commissioners
• For matters considered to be of extreme importance, the Chair may call
for a roll call vote
• No matter may be voted upon unless:
a. All required notice procedures for that vote have been followed; and
b. The matter has been discussed at a previous meeting of the Commission, or
c. The matter has been placed on the agenda prior to the meeting by the
Secretary; or
d. A new legislative item, not on the agenda, and considered by a 2/ 3 vote of the
Commission to constitute an extreme emergency and that would thus warrant
an immediate decision, may be approved by a 2/ 3 vote, or
e. A new procedural item, not on the agenda, may be approved by a simple
majority vote.
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Bylaws - Receiving Public Comment and
Testimony
General, Non -Public Hearing Related Comments
• Public comment on general, nonpublic hearing related items is provided
for during all regular meetings.
• Must be written and provided to the Secretary prior to 5:00 pm the day
before the Commission meeting.
Public Hearing Comment
• During the public hearing, both written and oral comment relating to the
items being considered by the Commission may be provided.
• Written comments must be provided by email, mail, or personal delivery
to the Secretary by 5: pm the day before the public hearing.
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Open Public Meetings Act (OPMA)
Chapter 42.30 RCW
Legislative Declaration
• "The people, in delegating authority, do not give public
servants the right to decide what is good for the people to
know and what is not good for them to know."
• "The people insist on remaining informed so they may
retain control over the instruments they have created."
Rules
• Meetings declared open and public.
• All Meetings of the Governing Body Shall be Open and
Public — Gavel to Gavel
• All Persons Shall be Permitted to Attend any Meeting of the
Governing Body, Except as Otherwise Provided by Law
• The Purpose of the OPMA is to Allow the Public to View the
"Decision -making Process"
Open
Meetings
Important Definitions:
• Meetings — All meetings under State
Statute are considered Regular Meetings if
codified at a regular date, place, and time.
Any other meeting is considered a Special
Meeting. Meetings are considered to
occur when a quorum of the Membership
takes "Action."
• Action — Means the Transaction of Official
Business
• Public Testimony; All Deliberations;
Discussions; Considerations; Reviews;
Evaluations
• Final Actions — the OPMA is in Effect
Whether or Not "Final" Action is Taken
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• Regular Business Meetings
• Study sessions, workshops,
retreats, etc.
• Special Meetings
• Executive Sessions
• Attendance at Others'
Meetings
• Attendance at Social Events
• Serial Meetings
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Types of
Meetings
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Serial Meetings
• Serial meetings, or rolling meetings, occur when a quorum
of councilmembers take "action" (which includes
discussion) on city business.
• These would be covered by the OPMA.
• This can happen with emails, text messages, phone calls, in -
person meetings, etc.
• A quorum of members does not need to be on the same
email chain or phone call — successive discussions creating a
"tree" would be inappropriate.
• The only way it is permissible is if one member emails the
other members for the purpose of providing relevant
information and those other members merely "passively
receive" the information and no discussion follows either
directly in response or in other communication line
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Open Meetings
Use of Social Media
• When conducting city business using
social media, use disclaimers (or link)
• Clearly distinguish your personal view
from official City / entire Commission
position on a topic
• Avoid a quorum of the Commission
discussing city business using the same
social media platform or post
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Public Comment
• Public Meetings v. Public Hearings
• Public Meetings: public comment only taken at or
before regular meeting which final action is taken or
is otherwise required by state law
• Public Hearings: public comment taken before a
significant decision is made in order to provide due
process or when a specific statute or regulation
requires one.
• Purpose: one-way communication for members of public
to provide testimony to governing body on the record.
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Why does this matter?
Because there are penalties for noncompliance with
the OPMA
1. Personal Liability
2. Public Agency Liability
3. Improper Actions Void
4. Potential Grounds for Recall
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Takeaways for OPMA Compliance
• Is there a quorum or more of the governing body?
• Is there a serial meeting occurring?
• Is there just passive receipt of info related to agency business?
• Are you in listening/receiving mode?
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Well, let's get started now we've got a quorum."
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Public Records Act
Chapter42.56 RCW
• PRA is "a strongly worded
mandate for broad disclosure of
public records." Hearst v. Hoppe,
90 Wn. 2d 123 (1978).
• Requires all agencies to disclose
public records unless an
exemption applies.
• Imposes fines for non-
compliance.
• Act requires strict compliance
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What does the PRA require agencies to do?
• Appoint a Public Records Officer
• Adopt rules of procedure that
address production, proper
keeping, and fullest and timely
assistance in response
• Publish procedures describing
certain agency organization,
operations, rules, and other
items listed in PRA
• Publish PRA fee schedules
• Provide for a review
• Procedure for any denial of
records
• Publish information related to
where requests must be
submitted
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What does the PRA apply to?
"AGENCY"
An "agency" is defined as all
state agencies and all local
agencies (and all their
employees and appointed
officials) in Washington. RCW
42.5 6.010(1).
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"PUBLIC RECORD"
A "public record" is "any writing
containing information relating
to the conduct of government or
the performance of any
governmental or proprietary
function prepared, owned, used
or retained by any state of local
agency regardless of physical
form and characteristics." RCW
42.56.010(3).
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Searching and Providing Records
• Searches
• Agency must conduct adequate
search — consider all forms, all
locations, all possible search terms,
all possible forms of records
• Search criteria; time taken to
produce records, and areas searched
must all be documented
• Installments
• Records can and should be provided
in installments if the request is very
large or time-consuming
Statutory
Exemptions
LEMPT)
• Exemptions
• Not all records, or parts of records, are
disclosable — depends on the
information contained in the record and
if a legal exemption applies
• Exemptions are narrowly construed
• An Exemption Log must be prepared
and given to requestor noting legal
reason record/part of record was
redacted
• Privacy:
• There is no general "privacy" exemption in
the PRA
• Privacy is considered invaded only if
(1) highly offensive to the reasonable
person and (2) not of legitimate
concern to the public
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Duty to
Preserve
Records
Legal Penalties, Including Fines and
Imprisonment
RCW 40.16.010 Injury to public record.
Every person who shall willfully and
unlawfully remove, alter, mutilate,
destroy, conceal, or obliterate a record,
map, book, paper, document, or other
thing filed or deposited in a public office,
or with any public officer, by authority of
law, is guilty of a class C felony and shall be
punished by imprisonment in a state
correctional facility for not more than five
years, or by a fine of not more than one
thousand dollars, or by both.
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Enforcement and Penalties
Jurisdictions have been subject to
fines reaching several hundred
thousand dollars for PRA violations
- failing to provide responsive
records promptly.
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RCW 42.56.550(4)judicial
review of agency actions.
• Requestors - Awarded
Attorney Fees
• Discretion of the
court to award such
person an amount
not -to -exceed one
hundred dollars for
each day that he or
she was denied the
right to inspect or
copy said public
record.
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Records Retention
• Maintenance of Records:
https://www.sos.wa.gov/arch i
ves/recordsmanagement/man
ag i ng-city-records.aspx
• Local Gov't Common Records
Retention Schedule (CORE)
• Records in Native File Format
• Records Born Electronically
• As noted earlier, there can be
criminal liability for willful
destruction or alteration
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Duty to Produce Records
• Business Records (Public) vs. Personal Records (Private)
When Creating a Record as a Member vs. as an Individual
• Records Kept on City Equipment vs. Personal Equipment
• Business Records Received or Sent Outside of City
Resources
• What Do You Need to Keep?
• Primary Records vs. Secondary Records
• Cc'd Copies That You Do Not Proliferate as a New Record
• Transitory Records - Have No Retention Value
• What About Everything Else?
• Commission Archive
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QU ESTI 0 N S?
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