SDCTA Guidelines on Publicly Funded Advocacy
The California Supreme Court ruled in Vargas v. City of Salinas that, "the determination of the propriety or impropriety of the expenditure depends upon a careful consideration of such factors as the style, tenor and timing of the publication." Recognizing that interpretation of "style and tenor" of communication is subjective, SDCTA will continue to monitor communication materials issued by government agencies leading up to elections. Details on SDCTA's interpretation of Vargas can be found in the appendix. The following examples serve as a non-comprehensive guide for what SDCTA considers inappropriate use of public funds for advocacy for or against a ballot measure: 1. The use of public funds to purchase bumper stickers, posters, advertising "floats", or television and radio "spots". 2. The use of public funds to purchase any type of automotive wrap (e.g. bus wrap, car wrap, trolley wrap). 3. The use of public funds to make campaign calls or automated "robo" calls. 4. The use of public funds to create and maintain any social media website or other modern tech tools, e.g. Twitter, Facebook, etc. 5. The use of public funds for direct mail, media buys, and contracted services as a part of coordinated campaign during a period coinciding with upcoming elections. 6. The use of public funds for direct mail "surveys" that also make a case for increased revenue prior to public entity voting to placing the measure on the ballot. 7. The use of public funds for "push" polls that are intended to change the opinion of the voter. 8. The use of public funds for advertising on print and electronic media. These guidelines do not preclude elected officials from expressing their opinions and advocating for or against a particular outcome or policy.