BILL ANALYSIS Ó
SB 272
Page 1
Date of Hearing: June 30, 2015
ASSEMBLY COMMITTEE ON JUDICIARY
Mark Stone, Chair
SB
272 (Hertzberg) - As Amended June 25, 2015
SENATE VOTE: 37-0
SUBJECT: The California Public Records Act: local agencies:
inventory
KEY ISSUES:
1)Should A local agencY, other than a school district, be
required to create, post online, and Annually update a catalog
of the systems that it uses to collect and manage data?
2)DO the benefits of this bill justify the potential costs to
local agencies and the risk, however small, that posting
vendor and product details could expose system
vulnerabilities?
3)Given that the purpose of Public records ACT is to promote
access to existing documents, as opposed to requiring the
creation of new documents, should this bill be codified
somewhere other than in the public records Act?
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SYNOPSIS
The bill, according to the author, is intended to be a "first
step" in a more ambitious effort to bring the data management
practices of local governments into the digital age and provide
government, business, and private citizens with open access to a
growing body of government-collected information. Specifically,
this bill would require a local agency, other than a school
district, to create a "catalog" of all information technology
systems that it uses to manage data. The bill does not require
the disclosure of particular records or data sets; rather, it
requires a local agency to essentially make an inventory and,
based on this inventory, create and post online a catalog of its
data management systems, hardware, and software applications.
The catalog would include specified pieces of information,
including the identity of the system vendor and system product.
The author hopes that this catalog will provide the state with
an inventory of the systems currently used by local agencies, so
as to better plan and facilitate the development of more open,
accessible, integrated, and modern data management systems. The
bill is supported by a broad coalition of business and labor
groups who believe that easily accessible and open data will
spur economic growth and improve government services. The bill
is opposed by the local agencies that would be required by the
bill to create these catalogs. Opponents argue that the costs
of creating these catalogs will exceed the benefits; that the
bill is vague about what "systems" local agencies must include
in the catalog; that revealing vendors, products, and custodians
of data in the catalog could expose system vulnerabilities and
increase security threats; and that the measure imposes a
mandate on local government but avoids state reimbursement by
inserting the requirement in the Public Records Act. As noted
in the analysis, many areas of concern about the bill remain,
but may be resolvable. However, because the author and
stakeholders have been unable to reach agreement on these
concerns, the Committee encourages the author to continue
working with the opposition. The bill will be heard in the
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Assembly Local Government should it pass out of this Committee.
SUMMARY: Requires a local agency to create a catalog of
information technology systems, as defined, and to make the
catalog publicly accessible, as specified. Specifically, this
bill:
1)Makes legislative findings and declarations relating to the
changing manner in which government data is gathered and
maintained; the greater use and volume of electronic data; and
the need to make this data accessible in a manner consistent
with the California Public Records Act.
2)Requires a local agency to create a catalog of its information
technology systems, as defined, and to make that catalog
publicly available upon request in the office of the clerk of
the agency's legislative body. Requires the local agency to
post the catalog in a prominent location on its Internet Web
site, if the agency has a Website.
3)Requires the catalog to disclose a list of the information
technology systems used by the agency and, for each system,
disclose all of the following:
a) Current system vendor.
b) Current system product.
c) A brief statement of the system's purpose.
d) A general description of categories and types of system
data.
e) The department that serves as the primary custodian of
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system data.
f) How frequently system data is collected and updated.
4)Defines "information technology systems" to mean hardware and
software that collect, store, exchange, and analyze
information that the agency uses. However, "information
technology system" shall not include any of the following:
a) Information technology security systems, including
firewalls and other cybersecurity systems.
b) Systems that would be restricted from disclosure under
Government Code Section 6254.19, which generally exempts
from disclosure any record that would expose the
vulnerabilities of an information technology system of a
public agency.
c) The specific records that the information technology
system collects, stores, exchanges, or analyzes.
5)Requires local agencies to complete the catalog required by
this bill, and post it online, no later July 1, 2016;
thereafter, the agency shall update the catalog annually.
EXISTING LAW:
1)Provides, under the Public Records Act, that all public agency
records are open to public inspection upon request, unless the
records are otherwise exempt from public disclosure.
(Government Code Section 6250 et seq. All further statutory
references are to this code, unless otherwise indicated.)
2)Requires a public agency to make non-exempt electronic public
records available to the public in any electronic format in
which it holds the information or, if requested, in an
electronic format used by the agency to create copies for its
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own or other agency's use. However, a public agency is not
required to release an electronic record in an electronic form
if its release would jeopardize or compromise the security or
integrity of the original record or of any proprietary
software in which it is maintained. (Section 6253.9.)
3)Provides that nothing in the Public Records Act shall be
construed to require the disclosure of an information security
record of a public agency, if, on the facts of the particular
case, disclosure of that record would reveal vulnerabilities
to, or otherwise increase the potential for an attack on, an
information technology system of a public agency. (Section
6254.19.)
FISCAL EFFECT: As currently in print this bill is keyed fiscal.
COMMENTS: California's Public Records Act (PRA) requires that
the documents and "writings" of a public agency be open and
available for public inspection, unless they are exempt from
disclosure. (Sections 6250-6270.) The PRA is premised on the
principle that "access to information concerning the conduct of
the people's business is a fundamental and necessary right of
every person in this state." A "public record" is defined to
mean "any writing containing information relating to the conduct
of the public's business prepared, owned, used, or retained by
any state or local agency regardless of physical form or
characteristics." A "writing" is defined, in turn, to include
any "handwriting, typewriting, printing, photostating,
photographing, photocopying, transmitting by electronic mail or
facsimile, and every other means of recording upon any tangible
thing any form of communication or representation, including
letters, words, pictures, sounds, or symbols, or combinations
thereof, and any record thereby created, regardless of the
manner in which the record has been stored." (Sections
6250-6252.)
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Public Record Access in the Digital Age. Since the PRA was
enacted in 1968, public agencies have increasingly created and
maintained records in electronic formats that can be searched,
indexed, copied, downloaded, and analyzed in countless and
creative ways. Reflecting this new reality, AB 2799 (Chapter
982, Statutes of 2000) required local agencies to disclose
non-exempt electronic records, where they existed, in an
electronic format, so long as doing so would not compromise the
integrity of the record. Importantly, AB 2799 clarified that
"Nothing in this section shall be construed to require the
public agency to reconstruct a record in an electronic format if
the agency no longer has the record available in an electronic
format." (Section 6253.9(c).) Similar efforts to promote
disclosure of electronic records have occurred at the federal
level. For example, in 2012 President Obama signed a U.S.
Office of Management and Budget memorandum directing federal
agencies to publish information online and in formats that can
be easily accessed, searched, and downloaded online using common
browsers and search engines. The executive memorandum declares
that "by December 31, 2019, all permanent electronic records in
Federal agencies will be managed electronically to the fullest
extent possible for eventual transfer [to the National Archives
and Records Administration] in an electronic format." (See OMB,
Memorandum M-12-18, August 24, 2012.
( https://www.whitehouse.gov/sites/default/files/omb/memoranda/201
2/m-12-18.pdf )
California has made similar efforts in recent years, albeit with
limited success. For example, SB 1002 (Yee, 2012) originally
set out to establish a statewide, integrated, open data portal.
In its final version, however, the bill more modestly required
the state's Chief Information Officer to conduct a study in
order to evaluate how the state might go about providing the
public with access to electronic records in an open,
standardized, and readily accessible format. This measure was
vetoed by Governor Brown, who noted in his veto message that he
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believed a legislatively-mandated study was not necessary to
achieve this objective.
In the current legislative session, four bills have been
introduced that seek to foster "open data" by one means or
another. Two of these bills apply to state agencies: SB 573
(Pan) would have the Governor appoint a Chief Data Office to,
among other things, create a statewide "open data portal,"
thereby creating a single point of entry to access data from
several state agencies. This bill is currently in the Assembly
Accountability and Administrative Review Committee. Similarly,
AB 1215 (Ting) would have created the California Open Data Act
to require state agencies to make public data available on an
Internet Web portal. That bill, however, was held in the
Assembly Appropriations Committee. One other bill, in addition
to the one which is the subject of this analysis, applies to
local agencies. AB 169 (Maienschein) requires any local agency
(other than a school district) that posts an electronic public
record on its Internet Web site to post the record in a format
that allows the record to be retrieved, downloaded, indexed, and
searched by a commonly used Internet search application. That
bill is awaiting hearing in the Senate Judiciary Committee.
Purpose of this Bill. The bill presently before this Committee,
SB 272, is the other bill this session that applies to local
agencies. The bill's legislative findings and declarations
indicate the measure seeks to move government toward "a more
effective digital future" by assisting access to government data
through "online portals." However, unlike the bills discussed
above, the substantive provisions of SB 272 do not actually
require (or even encourage) local agencies to make existing
records more accessible (i.e. in an electronic format), much
less create open data portals. Instead, the author states that
SB 272 constitutes a first step toward that a larger "open data"
goal. Specifically, SB 272 would require a local agency (other
than a school district) to create a "catalog" of its
"information technology systems" - that is, the various hardware
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and software programs that it uses for data management purposes.
The bill also requires the catalog to be posted on the agency's
Internet Website, if it has one. The catalog would identify the
system used by the agency and include the following information:
(1) the current system vendor; (2) the current system product;
(3) a brief statement of the system's purpose; (4) a general
description of the categories and types of data used in the
system; (5) the department that serves as the custodian of the
system data; (6) how frequently system data is collected; and
(7) how frequently system data is updated.
Definition of "Information Technology System" A Work In
Progress. A prior version of this bill required a local agency
to create a catalog of the "enterprise systems" that it uses.
However, many stakeholders representing local agencies
reasonably expressed that the definition of "enterprise system"
in the bill was vague and uncertain. The Committee's search of
the Internet and other sources turned up no consistent
definition of the term "enterprise systems," although several
definitions collectively suggested an "integrated" information
technology system that an "enterprise" (a private or public
sector entity) uses to manage data across its several
departments or divisions. The term "enterprise system" is not
used elsewhere in statute. A more common and familiar term,
"information technology system," is used in the PRA. As most
recently amended, this bill uses the term "information
technology system," rather than "enterprise system." It defines
"information technology system" to mean the hardware and
software that the agency uses to collect, store, exchange, and
analyze the information that it collects. Perhaps more
significantly, the bill excludes certain items from the
definition of "information technology system," specifically
information technology security systems, including firewalls and
other cybersecurity systems; records that would reveal
vulnerabilities to, or otherwise increase the potential for an
attack on, an information technology system of a public agency;
and the specific records that the information technology system
collects, stores, exchanges, or analyzes.
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Although the definition of "information technology system" in
this bill remains too opened-ended, according to the opponents
of this bill, the overall purpose of the catalog is intended to
create an inventory of the computer systems, including
especially data management hardware and software, that a local
agency use to handle the data it collects. Opponents fear the
existing definition is still "overly broad and would require
that agencies list systems that are for internal purposes" that
would not be of use to persons seeking access to public records.
As noted below, the author and stakeholders may wish to
continue refining the definition of "information technology
system" if the bill passes out of this Committee and is referred
to the Assembly Local Government Committee.
Outstanding Issues and Concerns. This bill has been the subject
of numerous discussions between the author's office, Committee
staff, and associations representing local government entities
throughout the state. Although the most recent amendments
address many of the concerns of local agency representatives,
significant issues remain unresolved. The most important
concerns and sources of opposition relate to determining which
"information technology systems" must be included in the
catalog; whether vendor name and system product must be included
in the catalog; which local government office should be in
charge of creating and maintaining the catalog; and whether or
not the bill is properly placed in the Public Records Act. More
generally, opponents question whether the uncertain benefits of
the legislation are worth the time and money that will be
necessary for local agencies to comply with the bill's
provisions. The remainder of this analysis takes up these
issues in turn and recommends that the author commit to working
with stakeholders to address these concerns if the bill moves
out of this Committee and to the Assembly Local Government
Committee.
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Limiting Scope of "Information Technology Systems" to the
Agency's "Core Services." Opponents argue that the catalog
should be restricted to those "information technology systems"
that serve the "core functions" or "core services" of the local
agency. They argue that without such a limitation the catalog
could become unwieldy, as the agency would be required to
include every piece of hardware and every software application
that has been downloaded onto every one of the agency's
computers. For example, an Excel spreadsheet for routine
internal office operations could be construed as an "information
technology system" under this bill.
The problem with this proposal, however, is that "core services"
and "core functions" can be just as vague and uncertain as
"information technology system" or "enterprise system." The
Urban Counties Caucus has suggested to Committee staff that
"core services" could be defined as those which are "essential
to the public's health and safety." For a county, this could
include roads, jail, law enforcement, public mental health and
other social services. However, because different agencies
provide different services, it would be difficult to develop a
definition of what constitutes "core services" for all agencies.
Nonetheless, opponents are probably correct that the existing
definition is too broad and would need to be limited in some
way. The Committee urges the author to continue working with
stakeholders to develop a more circumscribed definition of
"information technology systems" if the bill moves forward.
Inclusion of System Vendor and System Product. Another major
issue concerns whether an agency should be required to include
the system vendor and product in the catalog it creates and
posts on its Website. Several of the letters of opposition
contend that including this information will create a
cybersecurity risk. Opponents claim that providing this
information will make it easier for hackers and malware
distributors, who are familiar with the vulnerabilities unique
to certain brands of software or hardware, to breach or
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otherwise compromise agency systems and databases. The author
correctly points out, however, that contracts with service
providers are already subject to public records requests, and
therefore hackers who wanted to get this information could do so
under existing law. Opponents reasonably counter that the
catalog will make it considerably easier for hackers by
obviating the need for multiple and often time-consuming request
for public records and giving hackers the information that they
need in a single location. In addition, hackers may be
reluctant to make public record requests that will leave a trail
of their activity. Finally, opponents contend that contracts do
not always contain the most up-to-date information, as updates
and new products may be uploaded to the system without a change
in the contract. However, even if the security risk is small,
the Committee may wish to inquire how knowing vendor and product
information will help the public better access public records.
Members of the public generally want access to public records,
not the name of the vendor that operates the system managing
those records.
Who is Responsible for the Catalog? This bill requires that the
catalog be available upon request "in the office of the clerk of
the agency's legislative body." If the clerk is responsible for
making the catalog available upon request, then presumably the
clerk is also responsible for maintaining the catalog in its
office and, presumably, keeping the catalog up to date. The
California Association of Clerks and Elections Officials (CACEO)
opposes this bill, unless it is amended, and one of the
association's requested amendments is for the bill to leave it
up to the legislative body to determine which public entity or
official shall have responsibility for maintaining and updating
the catalog and responding to requests. In some cases, the
legislative body may choose to assign responsibility to the
clerks. In other cases, it may opt to assign responsibility to
a Chief Information Office, or an IT specialist. At any rate,
it seems reasonable for the legislative body to assign the
responsibility for maintaining the catalog and making it
available upon request to the party it chooses, who may or may
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not be the clerk of the legislative body.
Should this bill be placed in the Public Records Act? Although
the intent language in this bill proclaims that it serves the
purposes of the Public Records Act and Section 3 of Article 1 of
the California Constitution, this claim may be open to debate.
As an opponent of this bill concisely states, "SB 272 deals with
a listing of data systems. CPRA deals with records."
The purpose of the PRA is to ensure that people have the right
to access "the writings of public officials and agencies."
Although the PRA does not say so expressly, it is clear from the
legislative history of the PRA, case law interpreting the PRA,
and the overall statutory scheme that the purpose of the PRA is
to give people access to existing documents that are created and
maintained by a public agency in the normal course of its
business. (As discussed in Rogers v. Superior Court (1993) 19
Cal.App.4th 469, agencies are not required to recreate documents
that have been destroyed or discarded, and thus it would seem to
follow that agencies cannot be required to create documents that
do not already exist.) To be sure, this case law has focused on
the agency's obligation to the demands of a requester, not to
the demands of the Legislature. But since PRA was enacted in
1968, it has hewed to this purpose by addressing required
disclosures and exemptions the existing documents created and
maintained by public agencies; the Legislature has not, under
the PRA, required an agency to create new documents.
This proposal appears to expand the purpose of the PRA by
requiring the creation of new documents. The Committee could
not find any other provision of the PRA that requires an agency
to create a document in this manner. More revealingly,
provisions of the Government Code that do require the creation
of documents are not included within the sections that
constitute the Public Records Act (Sections 6250-6270, which
constitute Chapter 3.5 of Title 1, Division 7 of the Government
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Code), even though those provisions may be tangentially related
to public records and information practices. For example,
Government Code Section 11015.5 requires every state agency that
collects personal information electronically on the Internet, as
specified, to prominently display specified information about
the types of personal information it collects and the purpose
for which the information is collected. The section that would
be created by this bill appears to have more in common with this
provision than it does with the provisions of the Public Records
Act dealing with existing records.
The placement of this bill's language in the PRA is likely an
attempt to avoid the creation of a reimbursable local mandate.
The California Constitution provides that whenever the
Legislature or any state agency mandates a new program or higher
level of service on a local government, the state shall
reimburse the local government for the costs of that program or
increased level of service. (Cal. Const. art. XIII B, Section 6
[Also See Section 17514, which codifies this principle].)
However, Proposition 42 amended the state constitution to
eliminate the state's responsibility to pay local governments
for the costs that they incur in complying with the Public
Records Act. Historically those costs have included the
relatively modest burden of locating and physically retrieving
existing documents if and when a public record request is made.
Copying costs may be offset by modest fees collected from the
requester, so long as the fees do not exceed the actual costs of
copying documents.
Since Proposition 42 was approved by the voters in 2014, there
is more at stake for local governments when it comes to
legislative proposals for amending the PRA. Most notably, in
its official analysis of Proposition 42, the Legislative
Analyst's Office warned of the possibility that the state
legislature might be tempted to place new mandates in the Public
Records Act in order to avoid reimbursing local governments.
Specifically, the LAO summary wrote the following when
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estimating the potential costs to local governments:
Potential Effect on Local Costs: The measure could also
change the future behavior of state officials. This is
because under Proposition 42, the state could make changes
to the Public Records Act and it would not have to pay
local governments for their costs. Thus, state officials
might make more changes to this law than they would have
otherwise. In this case, local governments could incur
additional costs-potentially in the tens of millions of
dollars annually in the future. [Emphasis added.]
Unlike past amendments to the Public Records Act, this bill
does not exempt a category of public records from disclosure,
remove an existing exemption, or require the disclosure of an
existing document. Indeed, the bill says nothing about what
records should or should not be disclosed, which is the
primary purpose of the Public Records Act. Rather, this bill
would require local agencies to conduct an inventory of their
information technology systems and put it in the form of a
new catalog that must contain specified information without
reimbursing the agencies for the cost of doing so.
Conclusion: If this bill moves forward, the Committee
encourages the author, opponents, and concerned stakeholders
to consider the following before the bill is heard in the
Local Government Committee:
1)Whether to place further parameters around the definition
of "information technology systems."
2)Whether it is necessary to include the system vendor and
system product in the catalog.
3)Whether the legislative body should be free to identify an
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appropriate custodian of the catalog.
4)Whether the exemption for a "school district" should be
changed to the broader, but more commonly used, "local
educational agency."
ARGUMENTS IN SUPPORT: According to the author, "Local
government agencies throughout California possess a potentially
powerful tool for improving the lives of Californians: data. In
too many cases, however, local agencies - and the constituents
they serve - do not know what data they have collected or how to
access it. SB 272 will identify what information is being kept
by local agencies, how it is maintained, and who is responsible.
Publishing a catalog of this information will reveal how
accessible and usable the information is for public review and
analysis, and immediately empower Californians to utilize this
information." The author believes that harnessing the power of
this data "could help spur economic growth, tackle major
infrastructure issues and set millions of Californians on a path
toward upward mobility. Properly gathered and clearly
understood data would also help empower state and local agencies
to collaborate more effectively and improve service delivery."
A broad coalition of business groups and trade associations, led
by the California Manufacturers & Technology Association,
supports SB 272 because they say it will promote "open and
accessible local government practices." The coalition believes
that SB 272 is "a critical first step in the process of
providing uniformity in understanding where we are today with
regard to data collection systems. SB 272 moves California
forward in modernizing open government in California."
California Forward Action Fund (CFAF) believes that "this bill
will modernize California's approach to the California Public
Records Act and allow local governments to embrace open data in
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a smart, measured way." CFAF contends that Proposition 42
"paved the way for more innovation in local government record
disclosure and created energy to have cities, counties, special
districts to embrace open data principles. However, policy
makers must be careful and deliberate about local government
data as to not burden systems and staff with new state
requirements. SB 272 finds that balance."
Several other groups, from organized labor to the
high-technology business sector, support this bill because they
believe that requiring local agencies to create catalogs of
their data management systems will somehow lead to an integrated
and open data system, spur economic growth, and "empower" local
agencies to "work together more effectively and to intelligently
allocate resources to better deliver public services."
ARGUMENTS IN OPPOSITION: Several associations representing
cities, counties, special districts, and an array of other local
agencies oppose this bill. All but one of the groups or
associations that originally only submitted letters of "concern"
have changed their position to "oppose unless amended."
The California Association of Clerks and Elections Officials
(CACEO) oppose this bill unless amended to address a number of
its concerns. First, the clerks oppose automatically
designating the "clerk of the agency's legislative body" as the
custodian of the agency's catalog. CACEO argues that, depending
upon the locality, the clerks, who may or may not be
knowledgeable about information systems, may not be the most
appropriate agency official to be responsible for the catalog.
CACEO therefore recommends that SB 272 be amended to authorize
the legislative body to designate the official that it deems
most appropriate. This "could be the IT director, chief
information officer or other appropriate official" to "act as
custodian of the completed catalog, and make the catalog
available to the public."
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CACEO is also "deeply concerned", especially in light of
Proposition 42, "that SB 272 would create yet another unfunded
mandate on local agencies" by placing its provisions in the PRA.
CACEO "sees no nexus between the subject of SB 272 and the
subject dealt with in the California Public Records Act. SB 272
merely deals with listing of data systems. The CPRA deals with
records . . . Amending the CPRA in the manner that SB 272
proposes would create confusion and a measure of conflict with
the CPRA as to what constitutes an identifiable record."
Therefore, CACEO believes that "SB 272 should be added to the
Government Code as a body of law separate from the CPRA."
The Urban Counties Caucus (UCC), the Rural County
Representatives of California (RCRC), and the California State
Sheriffs Association (CSAA), who originally wrote a joint letter
of "concern," now oppose this bill unless amended to, among
other things, narrow the definition of "information technology
systems" to include only the systems used to perform "core
services." They also ask the author to remove the "system
vendor" and "system product" from the catalog requirements. In
support of this proposed amendment, they write that "County IT
experts have raised a concern with asking for the name of the
vendor and the product version. Many of our modern county
software applications are connected to the Internet to provide
on-line services to residents and therefore could be vulnerable
to malicious hacking. It is unclear what the public benefit
would be in providing the name of the vendor and the product
version. We have also heard from an FBI cyber security expert
that providing this type of information should be a concern for
municipalities." UCC, RCRC, and CSAA, like many other local
government stakeholders, also oppose placing the provisions of
this bill in the PRA. They write: "Since the passage of
Proposition 42, local agencies cannot receive reimbursement for
the costs to comply with the California Public Records Act.
Therefore, the new requirements in SB 272 would be unfunded and
could be costly for counties to comply. To provide a catalogue
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of all these systems could be time-consuming and it is unclear
what benefit much of this information would provide to the
general public."
Finally, SB 272 was opposed by many school districts and other
local educational agencies, for many of the same reasons
articulated by other opponents. However, given that the most
recent amendments exempt school districts from the bill, they
will apparently remove their opposition to the bill, although at
the time of this writing only one entity - the California
Association of School Administrators - has formally removed its
opposition.
REGISTERED SUPPORT / OPPOSITION:
Support
AFSCME
Associated Builders and Contractors of California
Building Owners and Contractors of California
California Asian Pacific Chamber of Commerce
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California Broadcasters Association
California Business Properties Association
California Business Roundtable
California Forward Action Fund
California League of Food Processors
California Manufacturers & Technology Association
California Professional Firefighters
California Retailers Association
Commercial Real Estate Development Association
Family Business Association
Firearms Policy Coalition
International Council of Shopping Centers
Los Angeles Business Federation
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National Federation of Independent Businesses
San Diego Regional Data Library
San Francisco Technology Democrats
Sunlight Foundation
Urban Strategies Council
Concern
City of Roseville
Opposition
Association of California Water Agencies
California Association of Clerks and Election Officials
California Association of School Business Officials
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California County Superintendents Educational Services
Association
California Municipal Utilities Association
California Police Chiefs Association
California State Association of Counties
California State Sheriffs Association
City of Camarillo
City of Diamond Bar
Desert Water Agency
El Dorado Irrigation District
League of California Cities
Los Angeles Unified School District
Madera County Board of Supervisors
Municipal Information Systems Association of California
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Newhall County Water District
Orange County Department of Education
Rowland Water District
Rural County Representatives of California
San Diego Unified School District
Urban County Caucuses
Analysis Prepared by:Thomas Clark / JUD. / (916)
319-2334