REPORT TO GOVERNANCE AND ETHICS COMMITTEE
SUBJECT
Title
Consideration and Possible Action on a Proposed New Council Policy for Ticket Distribution to City Officials
Report
BACKGROUND
As part of the Governance and Ethics Committee workplan, the Committee reviews City Council policies identified for review. In addition, consistent with the Committee’s annual workplan process, City staff may also recommend policies for review and consideration. This item is being brought forward by City staff for review and consideration.
Currently, the City of Santa Clara does not have an official ticket distribution policy. As the City of Santa Clara prepares for upcoming events in 2026 and beyond, staff identified the need to establish formal procedures for the acceptance and distribution of tickets or passes provided to the City. The proposed policy would ensure tickets received or purchased by the City of Santa Clara whether for community, cultural or ceremonial events are distributed in a transparent, equitable and legally compliant manner.
The City proposes an official Ticket Distribution Policy to comply with the California Fair Political Practices Commission (FPPC) regulations and state law governing the use and reporting of tickets received by public agencies. FPPC Regulation 18944.1 specifically mandates that agencies adopt a written policy if tickets or passes are to be distributed to officials and employees.
This proposed “Ticket Distribution Policy” establishes guidelines for the acceptance and distribution of event tickets or passes received by the City for use by City officials, including Councilmembers, other elected officials, and designated employees as designated by the City Manager, in compliance with the FPPC regulations. This proposed policy establishes clear guidelines and accountability to ensure that all ticket distributions are made for legitimate City-related public purposes, documented appropriately, and when appropriate, disclosed to the public through the FPPC Form 802 reporting process.
DISCUSSION
City staff reviewed ticket distribution policies from several cities, including San Jose, Mountain View, Oakland, Los Angeles, and Ventura.
The City of Santa Clara may be offered tickets or passes through the following scenarios which would be reviewed against the proposed policy guidelines for acceptance and distribution:
1. A request to the City to purchase tickets or table as a sponsor at a public event (e.g. Triton Museum Anniversary Gala event)
2. Complimentary tickets or passes received as part of sponsorship agreements or partnerships with event organizers (e.g. passes to Santa Clara Art & Wine VIP Hospitality booth)
3. Tickets to concerts, festivals, and community celebrations held at City-owned or regional venues.
4. Passes to cultural, educational, or sporting events such as collegiate games, community theater, or regional tournaments.
5. Admission to events recognizing civic achievements, business milestones, or volunteer service.
6. Tickets received as part of sponsorship agreements or partnerships with event organizers.
7. Passes provided through contracts for use of City venues, such as Levi’s Stadium (excluding NFL games), the Santa Clara Convention Center, or other public facilities.
8. Invitations to regional intergovernmental or ceremonial functions hosted by partner agencies.
The proposed Ticket Distribution Policy outlines procedures for the receipt, allocation, and reporting of tickets or passes that provide admission to an entertainment, recreational, or similar event (Tickets) that are:
a. Donated to the City by an outside source;
b. Acquired by the City by purchase or by sponsorship;
c. Received as consideration pursuant to a contract for City venue use; or
d. Obtained and distributed by the City through any other means.
The policy provides Definitions to clarify the references in the policy:
1. City Official: An elected official or City employee required to file a Statement of Economic Interests (Form 700).
2. FPPC: The California Fair Political Practices Commission.
3. Ticket: Any tickets or pass providing admission to a facility, event, or performance for entertainment, amusement, recreational, or similar purpose (defined in FPPC Regulations 18944.1 and 18946(d)).
4. Ticket Administrator: The City Manager or their designee responsible for implementing this policy.
5. Immediate Family: Spouse, registered domestic partner, or dependent children.
6. Designated Employee: Any employee authorized by the Ticket Administrator to receive tickets under this policy.
General Provisions:
All Tickets received by the City shall be subject to the following provisions:
1. The use of City distributed Tickets is a privilege, not a right.
2. Tickets not accepted by a City official may be reassigned at the discretion of the Ticket Administrator, with priority to City officials; family members may receive tickets if appropriate.
3. Individual Tickets recipients shall not sell, barter, exchange or transfer in any way Tickets received for any form of payment, reimbursement or other consideration.
4. City officials may only use the benefits included with the distributed Ticket. Any benefits offered within a venue that are not entitlements associated with the Ticket provided (e.g., other items such as food, drinks, souvenirs, VIP areas, or parking are not covered by this policy and may require separate Form 700 reporting by the receiving official.
5. Outside sources providing Tickets may not earmark such Tickets for distribution to specific individuals.
6. The City shall not accept, and this policy explicitly excludes tickets received from the San Francisco 49ers for NFL games. Should any individual officials choose to accept such tickets, they shall comply with all applicable laws and FPPC regulations. Complimentary tickets to special events or to the 49ers Museum at Levi’s Stadium are permissible and may be accepted and distributed for a public purpose.
7. All ticket distributions must comply with FPPC regulations and applicable laws.
Public Purpose:
Tickets shall only be distributed for legitimate City-related public purposes, including but not limited to:
1. Attendance at ceremonial occasions.
2. Official welcoming of visiting foreign officials and dignitaries.
3. Promotion of intergovernmental relations and/or coordination of resources with other governmental agencies, including but not limited to, attendance at an event with or by elected, appointed officials from other jurisdictions, their staff members, and their guests.
4. Economic Development outreach or planning.
5. Recognition of participation in City-sponsored or supported projects, community programs, and events.
6. Promotion of cultural, educational, recreational, and community events.
7. Recognition of volunteer, academic, athletic, or public service achievements by students, residents or businesses.
8. Redistribution to the public and City staff.
The following tickets are not covered by this Policy:
a. A ticket(s) provided by someone other than the City to a City official for admission to an event (Note: This policy only covers tickets provided to the City)
b. If the City official reimburses the City: Payment or reimbursement for the face value of the Ticket shall be made within thirty (30) days that the Ticket is distributed to the City official.
Distribution and Administration:
The City Manager or their designee shall manage the receipt and distribution of all tickets subject to this policy by:
a. Ensuring that Tickets distributed by the City under this Policy serve a City-related public purpose.
b. Ensuring Tickets distributed pursuant to this Policy are disclosed on the FPPC Form 802 (Attachment 2). The disclosure form shall include the following information:
i. The name(s) of the recipient of the Tickets.
ii. A description of the event for which Tickets were distributed.
iii. The face value of the Ticket.
If the Tickets do not have a face value stated or state something to the effect of “complimentary” or “promotional,” the Ticket Administrator will determine the value of the tickets or passes based on the reasonable cost for attendance at such an event.
iv. The number of Tickets provided to each person.
v. A description of the public purpose furthered by the Ticket distribution.
vi. An authorized signature verifying that the distribution of Tickets was made in accordance with the provisions of FPPC Regulations 18944.1 and 18942.
Disclosure and Reporting Requirements:
The City Manager or designee shall submit completed FPPC Form 802 to the City Clerk for posting on the City website within required timeframes established by FPPC regulations following the date of each ticketed event.
Next Steps:
If the Governance and Ethics Committee approves the proposed policy with any amendments, staff will prepare the Council policy and present it to the full City Council for consideration and approval.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(a) as it has no potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.
FISCAL IMPACT
There is no fiscal impact associated with the approval of the recommendation.
COORDINATION
This report was coordinated by the City Manager’s Office and the City Attorney’s Office.
PUBLIC CONTACT
Public contact was made by posting the Committee agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov or at the public information desk at any City of Santa Clara public library.
RECOMMENDATION
Recommendation
Approve for presentation to the City Council the proposed Council Policy for Ticket Distribution to City Officials, in the form presented, with such modifications as the Committee may authorize or direct.
Staff
Reviewed by: Maria Le, Assistant to the City Manager, City Manager’s Office
Approved by: Jovan D. Grogan, City Manager
ATTACHMENTS
1. Proposed Council Policy ("Ticket Distribution for City Officials")
2. Form 802 Agency Report of Ceremonial Role Events and Ticket /Pass Distributions