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Commission Memorandum
REPORT TO: Honorable Mayor and City Commission
FROM: Greg Sullivan, City Attorney
Chris Kukulski, City Manager
SUBJECT: Discussion on amendments to the Bozeman City Charter including
the voter referendum required by Sect. 9.04(b) of the Charter
(whether to add two members to the City Commission to be
elected at the general election in November, 2011).
MEETING DATE: April 12, 2010.
AGENDA ITEM TYPE: Action.
RECOMMENDATION: Discuss possible amendments to the Bozeman City Charter
and direct staff to bring to you an ordinance transmitting ballot language to the Gallatin
County Election Administrator that would place before the voters at the general election
on November 2, 2010 an amendment to the Bozeman City Charter increasing the number
of commissioners from four to six.
BACKGROUND: On November 7, 2006, the voters of the City of Bozeman adopted
the Bozeman City Charter. The Charter became effective January 1, 2008. The purpose of
the Charter was to establish and enumerate the powers of the City, subject to specific
restrictions, and prescribe procedures and a specific governmental structure, including,
among others, the form of government (commission – manager), the number of
commissions (currently four), and the powers and duties of the Mayor. The Charter
serves as the City’s “constitution.”
The purpose of your discussion on April 12, 2010, is to discuss the voter referendum on
increasing the number of commissioners from four to six as required by Section 9.02(b)
of the Charter and instruct the City Attorney to develop an ordinance to transmit the
ballot language to the Gallatin County Election Administrator. Second, this agenda item
will provide you an opportunity to review the Charter and discuss other amendments you
may want to possibly transmit to the voters.
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I. Section 9.02(b): Referendum to increase the number of Commissioners.
The Charter specifically requires the voters to decide at the November 2, 2010 general
election whether to increase the number of city commissioners from four to six. Section
9.02(b) of the Charter states:
(b) Referendum on Increasing the Commission. At the general election in 2010, the
city commission shall place before the voters, with conforming charter amendments, the
issue of adding two members to the city commission. Should the voters approve said
increase, said commission members shall be elected during the regulation city election in
2011 and seated at the first regular commission meeting in January 2012.
The above clearly requires the city commission to place this referendum on the ballot this
coming fall.
Obviously, the Bozeman City Commission is currently composed of four members with
the Mayor also sitting as a voting member. Specifically, Section 2.02(c) of the Charter
states,
(c) Composition. The commission shall be composed of four members elected by the
voters of the city at large in accordance with provisions of Article VI and the mayor. The
mayor shall be elected as provided in §2.03(b).
Emphasis added.
The referendum will ask voters to decide upon changing the language in Section 2.02(c)
from four commissioners to six. It is important to note Section 9.01(b) only requires this
specific text amendment; by its terms Section 9.01(b) does not require any other
provision of the Charter to be amended.
II. Process for the Required Referendum.
Both Montana state law and the Charter contain important provisions related to
amendment of the Charter. Montana state law contains a specific provision regarding the
process for amendment to a local government charter:
7-3-103. Amendment of self-government charter or adopted alternative form of
government. (1) An amendment to a self-government charter or an adopted alternative
form of government may only be made by submitting the question of amendment to the
electors of the local government. To be effective, a proposed amendment must receive an
affirmative vote of a majority of the electors voting on the question. An amendment
approved by the electors becomes effective on the first day of the local government fiscal
year following the fiscal year of approval unless the question submitted to the electors
provides otherwise.
(2) An amendment to a self-government charter or an adopted alternative form of
government may be proposed by initiative by petition of 15% of the electors registered at
the last general election of the local government or by ordinance enacted by the
governing body. The question on amendment of a charter or an adopted alternative form
of government must be submitted to the electors at the next regular or primary election.
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(3) The local government, by ordinance, may provide procedures for the submission
and verification of initiative petitions.
Thus, it is clear to adopt an amendment to the Charter only the voters can do so. See also
Sect. 8.02, Charter (discussed below). It is also clear a majority of the electors voting on
the referendum must vote in favor of the change from four to six commissioners.
As for the Charter itself, specific to the process for this referendum, Article VIII of the
Charter establishes standards and procedures for amending the Charter. While it could be
argued Section 9.02 of the Charter is self executing (meaning no formal action by the
Commission would be required) the Charter is silent on this issue. Therefore, to
determine the process for transmitting the ballot language to the Election Administrator
we need to refer to Section 8.01, which states:
Section 8.01 Proposal of Amendment.
Amendments to this charter may be framed and proposed:
(1) In the manner provided by state law, or
(2) By ordinance of the commission containing the full text of the proposed
amendment, or
(3) By report of a study commission created pursuant to state law, or
(4) By the voters of the city. Proposal of an amendment by the voters of the city
shall be by petition containing the full text of the proposed amendment and shall
be governed by the same procedures and requirements prescribed in Article VI
for initiative petitions until such time as a final determination as to the
sufficiency of the petition is made, except that there shall be no limitation as to
subject matter and that the petition must be signed by registered voters of the
city equal to that required by state law. In verifying petitions, the percentage of
required signatures shall be reduced pursuant to Section 6.03, above.
In addition to the above methods for amending the Charter, the Charter also speaks to the
process for “elections:”
Section 8.02. Election.
Upon delivery to the election authorities of the report of a charter commission or
delivery by the city clerk of an adopted ordinance or a petition finally determined
sufficient, proposing an amendment pursuant to §8.01, or as otherwise provided by
state law, the election authorities shall submit the proposed amendment to the voters of
the city at an election, pursuant to state law.
Emphasis added.
As is clear, no one provision of state law or the Charter provides a specific instruction on
how to transmit the required referendum language to the Gallatin County Election
Administrator. As such, the city must consider the important maxim of interpretations of
written law: where there are several provisions or particulars related to an issue or
question, such a construction is, if possible, to be adopted as will give effect to all. See
Sect. 1-4-101, MCA.
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When reading Sect. 7-3-103, MCA in concert with the provision in Section 9.01(b)
(requiring a referendum on increasing the number of commissioners) with the provisions
in Sect. 8.01(2) (requiring an ordinance when the Commission proposes a specific
Charter amendment) and the phrase in Section 8.02 (Election) which states “… [upon]
delivery by the city clerk of an adopted ordinance… the election authorities shall submit
the proposed amendment to the voters of the city… ” it is the City Attorney’s opinion the
Commission should adopt an ordinance to submit the required referendum to the voters. 1
The ordinance will contain the specific ballot language for an amendment to Section
2.02(c) of the Charter, as discussed above.
The timing of the submittal of the ballot language to the Gallatin County Election
Department is also critical. According to the Gallatin County Clerk and
Recorder/Elections Administrator Charlotte Mills the deadline for transmittal of ballot
language to the Gallatin County Elections Department is August 9, 2010. Clerk and
Recorder Mills requests the City provide the specific ballot language to her as early as
possible after the primary elections are complete in early June. As such, I recommend the
Commission establish a preliminary target date of the week of June 14, 2010 for
transmittal of the ballot language.
Prior to transmittal to the Gallatin County Elections Administrator, the ordinance
adopting the proposed language for the ballot must be effective. As you know, state law
requires provisional and final adoption of an ordinance to be separated by at least 12
days. After final adoption, the ordinance is not effective until 30 more days have elapsed.
Thus, to meet the tentative target week of June 14th, first reading of the ordinance will
need to occur on April 26, 2010 with final adoption to be had on May 10th. The effective
date of the ordinance would then be June 9th.
III. History of the Required Referendum.
The citizens of the city of Bozeman voted in June 2004 to create a local government
study commission. This vote was based on the mandate contained in Article XI, Sect.
9(2) of the Montanan Constitution, that the voters of a local government shall
periodically (every 10 years) determine whether to undertake a review of the local
government. That provision states:
Section 9. Voter review of local government. (1) The legislature shall, within four
years of the ratification of this constitution, provide procedures requiring each local
government unit or combination of units to review its structure and submit one alternative
form of government to the qualified electors at the next general or special election.
(2) The legislature shall require an election in each local government to
determine whether a local government will undertake a review procedure once
every ten years after the first election. Approval by a majority of those voting in the
decennial general election on the question of undertaking a local government review is
necessary to mandate the election of a local government study commission. Study
1 Historically, ballot language has been submitted via Resolution. E.g. both the June 2004 ballot language
on the local government study commission and the November 2006 language on the charter itself were
transmitted by Resolution. Section 8.01 of the Charter appears to have amended that historic process.
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commission members shall be elected during any regularly scheduled election in local
governments mandating their election.
Emphasis added.
The Montana Legislature implemented this constitutional mandate through adoption of
specific procedures for a local government study commission located at sections 7-3-171
et seq., MCA.
After electing to create the study commission, the voters of the city of Bozeman then
elected study commissioners by vote in November 2004. The study commission
subsequently spent the following two years developing a recommendation for a “charter”
form of government and the draft of the Charter. As stated above, the voters adopted the
Charter proposed by the study commission on November 7, 2008.
Several provisions of the City of Bozeman Local Government Study Commission Final
Report (August 8, 2006) (the “Final Report”) (attached)2 contain information on the
purpose behind the required referendum. Specifically, Sect. II-B of the Final Report
provides a description in the section titled “Key Provisions of the [Charter] Proposal” as
to why the study commission included Sect. 9.01(b). This section of the Final Report
states:
3. Vote on Increased Representation. The charter provides that at the general election in
2010, the City Commission shall place on the ballot the question of whether two
members should be added to the City Commission, bringing its membership to seven. If
approved, four Commissioners will be elected in 2011 and will be seated in January
2012. This provision is in anticipation of the city's population reaching 40,000 by
2010 and that seven Commissioners may better represent the increased population.
Emphasis added. Final Report, pg. II-2.
The U.S. Census Bureau’s Population Estimate Program estimate in July 2009 estimates
the city’s population as of 2008 to be 39,442.
Exhibit F (“Charter Commentary”) of the Final Report also includes a statement on the
purpose behind the referendum. This commentary includes “specific recommendations”
on key issues that were before the Study Commission. Important in those
recommendations is a discussion on methods to “improve representation on the city
commission.” Final Report, pg. IV,-23 - 24. The Study Commission worked with a citizen
focus group and other stakeholders to examine the efficacy of commissioners elected “at-
large” versus electing commissioners based on wards or districts. The Study Commission
eventually rejected the establishment of wards or districts at the time of the development
of the Charter when it stated, “… it is premature for Bozeman to move to a pure ward system
or mixed system at this time.” Id. The Study Commission then provided the following
statement regarding the increase in the number of city commissioners: “We conclude that
2 The Final Report contains the complete text of the Charter. See Final Report at pg. IV-4 (Exhibit B).
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with the prospect of Bozeman reaching a population of 40,000 by the year 2010, that the
voters should consider increasing the size of the commission at that time.” Id.
It is important for the City Commission to understand the next time the voters will be
asked whether to create a study commission will be in 2014.
FISCAL EFFECTS: As with other elections, the Gallatin County Election
Administrator will require the City to pay for costs directly associated with this ballot
question. At this time, we are not certain as to the precise costs. We will provide more
information on these costs will be provided with the first reading of the ordinance
adopting the specific ballot language.
ALTERNATIVES: The Commission may consider directing staff to develop other
amendments to the Charter to be presented to the voters this coming fall.
Attachments: Bozeman Local Government Study Commission Final Report, 8/8/06
Report compiled on: April 7, 2010
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