RE: F1 filing and disclosure agenda item 6-25-20 - supporting on-line disclosure Dear Chair Ammons and Commission Members, I had a conflict preventing me from appearing via phone during your public comment period today. Apart from the substance of my comments in support of having F1 forms available online, I want to urge the Commission to: 1. Add an email address on your agendas for submission of comments if someone can't attend in person or to comment on phone 2. Add email addresses for the Commission Chair and Commission Members on the Commission member page of the website. Despite hunting for an email today to submit comments, I found that I could only utilize this help page form. Therefore, I urge you to consider my comments even if this agenda item has to be reconsidered at an upcoming meeting. Substantive comments on F1 disclosure: It is vital for openness in government and public trust, as well as ensuring against public official violations of ethical obligations and corruption, for F1 financial disclosure forms of elected officials to be posted online. As Chair of the Local Government Committee, I approach this issue from the perspective that local elected officials from cities and counties to scores of special purpose districts consider a myriad of proposed governmental actions, including investments, which may benefit specific regions or properties, businesses or investment opportunities through actions such as comprehensive plans, zoning, grant programs, loans for economic development or creation of economic development areas, permitting, etc.. When these decisions arise, in order for the public to have full confidence and avoidance of any appearance of conflict of interest, the public and news media should have real time, easily obtainable access to research if elected officials have any financial interest in a matter in front of their governing body or agency. Posting F1 forms on the PDC website is the only way to provide this ready access. Reporters and the public often learn of a proposal in front of their elected officials with only hours or a few days before consideration. At that time, an official with a potential appearance of conflict of interest may have already been engaging in consideration of the matter, including voting to move the matter to a full council or commission agenda. (Indeed, I did not know the PDC was taking up a proposal to pull the F1 forms from on-line disclosure at its meeting today, until today). The public or a reporter should be able to go online and research if a range of elected officials considering a proposed grant, investment, land use decision etc. that may benefit properties or investments they have an interest in. Submission of formal requests for F1 forms, one at a time, with delay in receipt of forms will prevent the public and reporters from being assured that decision makers are meeting their duties to avoid the appearance o a conflict of interest. Disclosure is vital for all levels of government in Washington. It does not just affect legislators and trust in actions by individual legislators. At election time, voters should be able to easily access F1 forms when considering who they are casting ballots for. It is readily apparent that few, if any voters, would delay voting to submit a formal request for candidates’ F1 forms. Having them available on-line means that voters can do their own research and quickly ascertain if a candidate has financial interests that may cloud their judgment when making decisions at the level to which they seek office. There is no information required on an F1 form which would fall under sensitive information that the public does not have an interest in, for which there is a reasonable expectation of privacy, or which disclosure would unlock the door to fraud. Property owned and mortgages are on the public record and available by searching public records or by paying a small fee to any of the myriad businesses that provide property interest searches. But without disclosure on the F1, the ability of the public to ascertain if there is a property interest held by an elected official in a property that might benefit from public investment or action is nearly impossible – certainly infeasible for a concerned member of the public in the typical turnaround time from posting of a meeting notice until action. Financial investments are disclosed only with the name address of the bank, financial institution, insurance company, etc. and a very general range of disclosure. Ready access to determine if an elected official has an appearance of a conflict of interest in a matter before the elected body (or statewide office) is vital for public trust and preventing corruption. It is readily apparent that disclosure of a creditor to whom an elected official owes a substantial amount is vital to prevent any appearance of a conflict of interest if the creditor has business before the governing body or agency (the level of what constitutes substantial may be adjusted). Disclosure of any interest in a corporation, business, LLC, investment partnership etc. is vital when elected officials may be making decisions in regard to providing grants to businesses or decisions which benefit a property or investment held in the name of an LLC or other entity. By requiring elected officials to disclose these interests we create a positive duty allowing the public and news media to sort through disclosures on-line to ascertain if any of the elected officials have interests in a pending matter. It is inadequate to say that persons can ask for F1 forms one at a time. It is vital for confidence in elected officials that a concerned member of the public or news reporter can search and sort online to see if any elected officials across different offices have such hard to spot potential conflicts. In sum, just as we recognize that it is vital for the public and reporters to search on the PDC website for all legislators and candidates who receive contributions from one special interest, the public and news media should be able to sort through elected officials at various levels of office to ascertain if they share common investments that may benefit from public actions. I urge you to consider these comments and return F1 forms to be available online. ?w?w Representative Gerry Pollet Gerry.pollet@leg.wa.gov