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LA515\1\1076121.v2 <br />2. Quasi-Judicial Nature of Many Public Hearings <br />Many of the public hearings listed in your staff report are quasi-judicial in nature. In those <br />contexts: <br />• Decision-makers must avoid off-the-record communications, <br />• Public input must be received in a controlled, transparent forum, <br />• Ex parte communications can undermine procedural fairness. <br />Receiving comments through social media direct messages risks creates an uneven record, <br />exposing the City to due process challenges. <br />3. Administrative and Staffing Burdens <br />City staff has correctly identified that allowing social media notices would require: <br />• Monitoring posts and inboxes, <br />• Logging or preserving messages as potential public data, <br />• Determining whether messages constitute public comment, <br />• Responding or redirecting inquiries appropriately. <br />This creates additional City staff workload and increases the risk of inconsistent handling of <br />public input. The City’s current notice enhancements already achieve transparency without <br />introducing this burden. <br />4. Public Confusion and Inconsistent Access <br />Even if labeled “supplemental,” social media posts may be perceived by the public as an <br />official or primary notice, which could: <br />• Cause confusion about where and how to submit public comment, <br />• Lead residents to believe commenting on social media is equivalent to testifying at a <br />public hearing, <br />• Cause residents to rely on these social media outlets for information and engagement, and <br />• Exclude residents who do not use or have access to social media platforms. <br />Enforcement and Liability Risks <br />Violations of the Open Meeting Law may result in: <br />• Civil penalties against individual Council members, <br />• Attorneys’ fees awards,