TO: Board of Supervisors
FROM: Sheryl L. Bratton- Agency Counsel
REPORT BY: Chris R.Y. Apallas - Deputy Agency Counsel
SUBJECT: Amending Conflict of Interest Code

RECOMMENDATION
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Adopt a Resolution to amend the Napa County Groundwater Sustainability Agency’s Conflict of Interest Code. (No Fiscal Impact.)
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BACKGROUND
Pursuant to the Political Reform Act of 1974, local agencies are required to review conflict of interest codes, and, if changes are required due to changed circumstances, they are to submit an amended code to the code-reviewing body for approval. In 2022, minor edits adding a new position for Natural Resource Manager as well as changing disclosure categories for consultants serving on the Groundwater Sustainability Agency’s (GSA) Technical Advisory Group were determined to be necessary after the bi-annual review and were adopted.
After the filing period in 2025, staff took the opportunity to review the list of designated positions required to file Form 700s and found that various titles of positions for county employees needed to be updated and determined that many designated positions listed as part of the original adoption of the Conflict of Interest Code (COIC) in 2020 do not make or participate in making decisions as part of the NCGSA. When the GSA was formed in 2020, many of the County’s designated positions from its COIC were used as a model for the GSA. However, with several years of experience, GSA staff now have a better understanding of which positions should be included in the COIC going forward. Staff worked with affected department heads to develop the proposed revised list of designated positions.
Staff recommends approval of the attached Resolution, which will result in the adoption of the proposed revised Conflict of Interest Code subject to confirmation by the Board of Supervisors as the code reviewing body.
Requested Action: Adopt a Resolution to amend the Napa County Groundwater Sustainability Agency’s Conflict of Interest Code.
FISCAL IMPACT
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Is there a Fiscal Impact? |
No |
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Is it Mandatory or Discretionary? |
Mandatory |
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Consequences if not approved: |
If amendments to the Code are not approved, the GSA’s COIC will not be updated and will be overly broad. |
ENVIRONMENTAL IMPACT
ENVIRONMENTAL DETERMINATION: The proposed action is not a projected as defined by 14 California Code of Regulations 15378 (State CEQA Guidelines) and therefore CEQA is not applicable.