Why We Should Expect More Criminal Cases Charging Illegal Coordination Between Campaigns and Super PACs: A Former Prosecutor’s Perspective

Note: An earlier post on Perkins Coie’s In the Arena: Law and Politics Update discussed, from a campaign finance lawyer’s perspective, why the prosecution in United States v. Harber signals future jeopardy for operatives in down-ballot races who coordinate with hastily-formed “super PACs.” This post offers a different angle on the same question from Barak Cohen, senior counsel in Perkins Coie’s White Collar & Investigations practice and a former prosecutor in the Public Integrity Section of the U.S. Department of Justice. In his post below, Cohen explains how the considerations that drive public corruption prosecutions point toward this same increased risk.

As Brian Svoboda’s recent post on In the Arena  noted, DOJ’s prosecution of Tyler Harber may signal increased criminal enforcement of the campaign finance laws.  That post aptly concluded that these enforcement efforts will likely focus on smaller campaigns for seats in the House.  As a former prosecutor in DOJ’s Public Integrity Section (the DOJ component that specializes in such cases, and which helped prosecute Harber), I agree, and have some further reasons for why additional prosecutions like Harber’s–the first widely reported criminal case based on illegal coordination between a campaign and a “super PAC”–should be expected.

Any discussion of DOJ enforcement efforts in this area should be set against the backdrop of two unique features of campaign finance law.

First, establishing that a campaign finance offense has been committed requires DOJ to overcome significant evidentiary hurdles.  In cases like Harber’s, DOJ must prove that the defendant “knowingly and willfully” committed the putative offenses.  This is a particularly demanding standard of proof because it requires prosecutors to establish that the would-be defendant took prohibited action knowing what the law forbade, and violating the law notwithstanding that knowledge.  Satisfying this showing requires prosecutors to get inside a defendant’s head, and to determine, often circumstantially, what the defendant understood:  This can prove challenging, especially given the hyper-technical nature of campaign finance law and regulation.

Second, compounding this challenge is that the Federal Election Commission, the independent regulatory agency responsible for administering the financing of federal elections, has been and remains silent as to the law’s meaning.  As my colleague Karl Sandstrom, a former FEC Commissioner, has written, the FEC has done little to tell the public what the law is when it comes to many core issues of campaign finance regulation.  The agency’s silence means that it is hard for anyone, let alone DOJ, to claim understanding of election law.  Despite making it difficult to prove a defendant’s mental state, the FEC’s lassitude may invite action by prosecutors seeking to draw bright-line rules to fill the regulatory vacuum.

When DOJ aims to make a point through law-enforcement efforts, it generally takes one of two approaches.  Under the theory that “the bigger they are, the harder they fall,” DOJ may seek criminal charges against a few high-profile targets in order to achieve a broadly publicized deterrent effect.  Given the opacity of the law, this approach has not fared well for DOJ, as the government’s failed case against Presidential candidate John Edwards demonstrates.  In the alternative, the government may focus on prosecuting in relatively greater numbers “low-hanging fruit.”  That is, the government can hope to deter certain conduct by bringing many cases against relatively lesser targets who are unlikely to be able to mount serious defenses against criminal charges.  The Harber case suggests that the government may take the second approach.

According to his plea agreement, Harber’s conduct was both clear-cut and egregious.  Tyler Harber was the manager of a failed Congressional race in Virginia’s 11th District.  In the last two months of the race, Harber created and operated a super PAC to support the campaign that he managed, siphoned $138,000 from the super PAC for his own and his family’s benefit, and then lied repeatedly about his actions when questioned by the FBI.  The plea agreement suggests that the government had a strong case against Harber.

The government’s success in obtaining Harber’s conviction may embolden additional prosecutorial efforts.  Given the inherent challenges of prosecuting cases under the campaign finance laws, it is likely that the government’s efforts will focus, at least initially, on low-hanging fruit like Harber.  As Brian Svoboda previously explained, the environment most conducive to conduct like Harber’s exists in the fight for seats in down-ballot races, where staff tend to be less experienced, there are fewer internal controls, and campaigns have more limited access to outside expertise, such as lawyers.  To be sure, Harber’s conviction may lead to DOJ initiating investigations against higher-level targets.  The government may seek to build up to such cases after drawing what it would surely present as a clear line between legal and illegal conduct through smaller, more easily prosecuted, cases.  The key question is whether this will help fill a void left by the FEC, or invite prosecutorial overreach.

VA-11 Coordination Case Is a Wake-Up Call for Down-Ballot Races, Operatives

Last Friday’s sentencing of the manager of a failed Congressional race in Virginia’s 11th District suggests that, if there is to be a wave in the criminal prosecution of the campaign finance laws, it may come toward the bottom of the ticket. Smaller campaigns face the same competitive pressures as presidential campaigns and marquee Senate campaigns do. They play by the same rules. And yet these smaller campaigns operate in conditions that make the rules more likely to be disregarded and prosecutions more likely to succeed. In a post-Citizens United world, the VA-11 case is a powerful warning for “down-ballot” candidates, their staff and consultants.

All federal campaigns comply with limits and restrictions that are backed by criminal statutes. They file reports under penalty of false statement. And yet congressional and “down-ballot” campaigns are less likely to have the culture or infrastructure to comply with these laws. They have smaller budgets and less experienced staff. They are less likely to have basic financial controls, best practices, lawyers, or other outside support. Down-ballot campaigns depend more on external sources of accountability, whether from the national congressional campaign committees, their pollsters, or their media consultants.

This makes these smaller campaigns especially vulnerable to lapses in professionalism, and to the extreme results that can follow. This seems to be what happened in VA-11, as an April 2015 article in Campaigns & Elections strongly argued. The campaign manager’s claim at sentencing that he “got caught up in what politics has become” rings a bit hollow. The government alleged that, in the last two months of the race, he set up a super PAC solely to support his candidate, micromanaged it, arranged for it to pay him and his family $138,000, and then lied repeatedly to the Federal Bureau of Investigation when contacted a year later. This is not normal conduct. And yet ill-staffed, ill-supported campaigns are still more prone to it than others.

While smaller campaigns are more vulnerable to professional lapses, they are more vulnerable to prosecution at the same time. This is true also of “rifle-shot” super PACs that form quickly to make independent expenditures in a single race. Because these campaigns and PACs are transient enterprises, especially when the candidate loses, they lack the means to mount a legal defense when the race is over. The campaign is done, the PAC has terminated, the donors are gone, and the operatives must fend for themselves. This makes the operatives involved inviting targets for investigation and prosecution.

The current conversation about campaign finance regulation is almost entirely focused on the presidential campaign. But the Virginia case shows that the real action may be further down the ballot. If there will be more criminal enforcement of the coordination rules, it seems more likely to come in down-ballot races, where the asymmetrical system of limits bestowed by Citizens United is putting even more stress on the competitive and operational pressures with which campaigns already struggle sometimes to contend. We will know in a couple of years whether the Virginia case was an outlier—or the shape of things to come.

FEC’s McCain Decision Opens Still Another Path for Independent Expenditures

An overlooked enforcement decision by the Federal Election Commission involving Senator John McCain’s 2010 campaign may put another type of player onto a campaign field that has become increasingly dominated by super PACs, nonprofits and non-candidate groups—other candidates’ campaigns.

The FEC announced last Friday that it found no reason to believe that McCain’s campaign broke the law by making independent expenditures against Representatives in 2010. You can see the McCain ads here and here. (Full disclosure: the present author drafted the complaint against McCain. This post represents his own views, and not any client’s.)

At issue was a statute—52 U.S.C. 30102(e)—that allows a candidate’s principal campaign committee to “support” only that candidate. (A narrow exception allows the campaign to make contributions of up to $2,000 to other candidates.) The Commission had aggressively enforced this statute before:

What seems to have saved McCain, apart from the FEC’s apparent slowness to enforce—his matter remained open for nearly five years—was Citizens United v. FEC. The Commission relied on that landmark case, which held that independent expenditures presented an insufficient risk of corruption to justify limits on their financing, and said: “It is unlikely that independent spending by authorized committees would be deemed more potentially corrupting than independent expenditures by individuals, political parties, or corporations, each of which has been found to have a constitutional right to make unlimited independent expenditures. Therefore, the Commission dismisses the allegation.”

The McCain decision is an odd case  involving a very odd statute. But it could have a significant effect on future elections. The decision makes clear that candidates face no legal barrier against making independent expenditures to support other candidates, so long as they do not coordinate with those whom they are supporting. This could prove significant especially in national elections, where Senate and House candidates are often eager to ally themselves with presidential candidates, as was the case in the Jenkins and Stupak matters. The decision could prove especially significant for nationally prominent candidates like McCain, who have a broad fundraising base and ample resources to spend.

Perkins Coie Lawyers on Two Panels at FEC Hearing

Today the Federal Election Commission holds a public hearing to consider whether to change its earmarking, joint fundraising, disclosure and affiliation rules in response to the Supreme Court’s decision in McCutcheon v. FEC.

  • Bob Bauer is scheduled to testify this morning at 9:45 EST. His comments, offered in his individual capacity, can be found here.
  • Brian Svoboda is scheduled to testify this afternoon at 2 EST on behalf of the Perkins Coie LLP Political Law Group, whose comments are here.

A full schedule of the witnesses is here. You can watch or listen to the hearing live.

FEC Publishes New Contribution Limits for the 2016 Election Cycle

Today the Federal Election Commission published in the Federal Register the contribution limits that will apply during the 2016 election cycle. The chart below summarizes the new limits, some of which were adjusted for inflation under the Bipartisan Campaign Reform Act of 2002:

TO/FROM:

Presidential
Candidate

Senate Candidate

House Candidate

National Party Committee

State Party Committee

PAC

Individual

$2,700 per election

$2,700 per election

$2,700 per election

$33,400 per calendar year

$10,000 per calendar year

$5,000 per calendar year

Multicandidate PAC

$5,000 per election

$5,000 per election

$5,000 per election

$15,000 per calendar year

$5,000 per calendar year

$5,000 per calendar year

Non-Multicandidate PAC[1]

$2,700 per election

$2,700 per election

$2,700 per election

$33,400 per calendar year

$10,000 per calendar year

$5,000 per calendar year

National Party Committee

$5,000 per election

$46,800 combined[2]

$5,000 per election

Unlimited

Unlimited

$5,000 per calendar year

State Party Committee

$5,000 per election

$5,000 per election

$5,000 per election

Unlimited

Unlimited

$5,000 per calendar year

Non-individual “person” (e.g., Tribes, partnerships)

$2,700 per election

$2,700 per election

$2,700 per election

$33,400 per calendar year

$10,000 per calendar year

$5,000 per calendar year


[1] A candidate’s authorized committee may only contribute $2,000 (not $2,700) per election to another candidate’s authorized committee, and may make unlimited transfers to party committees.

[2] This limit is shared by the national committee (e.g., the DNC or the RNC) and the national Senate campaign committee (e.g., the DSCC or the NRSC).

Reese Speaks at National Press Club on Nonprofit Political Activity

Political Law Group partner Ezra Reese spoke last week at the National Press Club in Washington, DC, in a panel discussion about whether the Internal Revenue Service should adopt clearer rules for nonprofit political activity. Reese has written here before about the Bright Lines Project, an initiative he has led with other nonprofit tax experts to seek better guidance for politically active nonprofits. Entitled, “A Rising Tide Will Lift All Boats: Evangelical and Progressive Perspectives on the Need for Clear Rules for Nonprofits,” the discussion followed a keynote speech by U.S. Senator Sheldon Whitehouse, and brought together speakers from the progressive, evangelical Christian, and campaign finance reform communities. You can watch a video of the discussion here.

Perkins Coie LLP Political Law Group Submits Comments to FEC on Post-McCutcheon Rulemaking

Today the Perkins Coie LLP Political Law Group submitted comments on an advance notice of proposed rulemaking, initiated by the Federal Election Commission in response to the Supreme Court’s decision in McCutcheon v. FEC. The FEC asked whether it ought to change its earmarking, affiliation, joint fundraising and disclosure rules in response to McCutcheon, which struck down the caps on the total, combined amount of political contributions that an individual may make over a two-year election cycle.

Previously, this blog probed the justices’ command of the earmarking rules at oral argument, reviewed the majority’s discussion of these same rules after the decision came down, and gave a basic rundown of the McCutcheon decision.

Below are the comments, which the Political Law Group submitted on its own behalf.

…..

On behalf of the Perkins Coie LLP Political Law Group, we submit these comments on the above-referenced advance notice of proposed rulemaking.  Our comments are not on behalf of any particular client.  However, as practitioners who work regularly with the Commission, we would like to offer some observations that the Commission may find useful.  We would request the opportunity to discuss them further at the hearing on February 11, 2015.

First, the Commission should evaluate this proposed rulemaking versus other competing priorities.  The Commission must, of course, conform its rules with changes in the statute and judicial orders.  We appreciate that the Commission last year adopted a final rule to conform to the decision in McCutcheon v. FEC, 134 S. Ct. 1434 (2014), and took steps to conform its rules to the decision in Citizens United v. FEC, 558 U.S. 310 (2010).

There are other, major gaps in Commission rules that remain to be addressed:

  • The Commission has not yet revised its rules to account for so-called “Super PACs” in the wake of the decision of the United States Court of Appeals for the District of Columbia Circuit in SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. 2010) (en banc).
  • The Commission also has yet to revise its rules to account for so-called “hybrid PACs” following the United States District Court for the District of Columbia’s decision in Carey v. FEC, 791 F. Supp. 2d 121 (D.D.C. 2011).
  • In November 2014, the United States District Court for the District of Columbia vacated and remanded Commission rules governing the disclosure of electioneering communications in Van Hollen v. FEC, No. CV 11-0766, 2014 WL 6657240 (D.D.C. Nov. 25, 2014).  While a private intervenor is appealing the court’s order, the Commission is not.  And, however the case is decided on appeal, the rules governing disclosure of independent expenditures and electioneering communications by persons other than political committees will remain a confusing, asymmetrical tangle unless Congress or the Commission acts.
  • In December 2014, Congress enacted amendments to the Federal Election Campaign Act of 1971 that changed the contribution limits for national political party committees, partly so that they may finance presidential nominating conventions without public funds.  See Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113-235, § 101 (2014).In that same law, Congress also established building and recount accounts for the national parties.  Commission rules will have to be revised and conformed to these developments in the law.

Thus, there are a number of subjects on which the Commission, rather than considering whether it is advisable to add rules, mustchange the rules to comply with court orders, or to avoid major gaps between the current rules and actual practice.  Some of these subjects directly affect the “collection and presentation of campaign finance data.”  Id. at 62,363.  Sound administrative practice suggests that the Commission should turn to these subjects first.

Second, the areas addressed by the advance notice of proposed rulemaking all share certain attributes that should cause the Commission to act judiciously when proposing or making changes to the rules.  In particular, the earmarking, affiliation and joint fundraising rules involve very complex areas of law that have developed over decades, and in which the politically active have a strong reliance interest, having organized themselves around them.

The earmarking rules affect not simply how political parties and PACs collect and forward contributions from their adherents to candidates, but also how candidates can motivate their adherents to support the parties and PACs.  The litigation in EMILY’s List v. FEC,581 F.3d 1 (D.C. Cir. 2009)shows how over-eagerness to find support for a clearly identified candidate in a PAC’s fundraising appeal can result in a rule that is insufficiently tailored to meet First Amendment speech and association concerns.  The affiliation rules affect not simply anti-circumvention interests, but also associational freedoms: for example, they provide the framework within which the Commission imputes candidate and officeholder soft money fundraising restrictions to non-party, non-candidate groups.  Finally, the joint fundraising rules provide a transparent way for candidates and parties to solicit contributions together.

Wholesale changes in any one of these areas would require a substantial reordering of how candidates, parties and PACs now operate.  We are inclined to doubt that the advance notice of proposed rulemaking will elicit anecdotal or statistical evidence of a problem caused by McCutcheon, for which the solution would justify the cost of such changes at the present time.

Finally, the Commission should consider the asymmetrical impact that a rulemaking would have among the politically active.  After Citizens United, the world is divided even more sharply between entities which operate within FECA’s limits, restrictions and reporting requirements, and those which do not.  Changes to the earmarking, affiliation and joint fundraising rules would inevitably impact the former disproportionately, while doing little to provide more transparency about the latter’s financing.  Footnote 4 of the advance notice of proposed rulemaking neatly shows this: it states correctly that the earmarking rules and their “rationale do not apply to an independent expenditure-only political committee’s solicitations or any contributions it receives that are earmarked for specific independent expenditures.”  79 Fed. Reg. at 62,362 n.4 (brackets omitted).  While the Commission must lend force and effect to the statutes it enforces, it should move cautiously before further burdening the activities of candidates and committees that are already hard-pressed to compete with Super PACs, corporations and unregistered nonprofits under the constitutional and regulatory standards now in place.

We appreciate the opportunity to comment on these matters.

Very truly yours,

Marc Erik Elias
Robert F. Bauer
Brian G. Svoboda
Rebecca H. Gordon
Ezra W. Reese

 

The Van Hollen Case and the FEC’s Power

One way of looking at a case like Van Hollen v. FEC is to evaluate its result. Did the decision promote anti-corruption goals, or impede them? Reform proponents have celebrated the result in Van Hollen, which vacated a 2007 rule that allowed corporations and unions to narrow their disclosure when sponsoring” electioneering communications”— issue ads that mention candidates on television or radio during the 30 or 60 days before an election. Some have noted that the decision will instead encourage these same groups to make independent expenditures instead and actually advocate the candidates’ election or defeat, under narrower disclosure requirements that still stand. Nonetheless, advocates for greater disclosure have celebrated the decision as a “victory for transparency,” as Commissioner Ellen Weintraub Tweeted last week.

Yet another way of looking at a case like Van Hollen is through the lens of agency power. Does the Federal Election Commission—charged with exclusive civil jurisdiction to interpret and enforce the campaign finance laws—have less room to act than before? When a court finds that the FEC’s decision-making process was irrational and based on a “clear error of judgment,” as the Van Hollen court found, then what does that say about how the FEC must approach its future decisions? For example, if the full FEC were to respond favorably to Commissioner Ann Ravel’s recent call for new rules “to address corruption and increase disclosure in the political process,” then might not a future litigant cite the Van Hollen case to argue that the agency overstepped its bounds when writing rules to require new disclosure?

One of the ironies of federal campaign finance law these days is that the biggest proponents of the FEC’s mission frequently seek to curb its power, while skeptics of campaign finance regulation favor creative uses of that same power.

On the reform side, this has largely resulted from McCain-Feingold. That law’s most vocal proponents saw the FEC’s rulemaking process as key to its effectiveness. When reform proponents did not obtain from the FEC the results they wanted on coordination, candidate appearances at party fundraising events, and state and local party spending, they went to court. Through the Shays litigation, they built a strong body of case law that struck down FEC action on general administrative law grounds. In the long term, the Shays cases may end up standing less for vigorous campaign finance regulation, and more for curbs on FEC decision-making—curbs which, in a different time and place, critics of regulation may try to interpose against agency rules or enforcement.

At the same time, the enforcement process has sometimes seen a high level of flexibility in interpreting statutes and rules toward deregulatory ends. To take just one example: the rule struck down in Van Hollen  provided that a corporation need only disclose donors who gave “for the purpose of furthering electioneering communications.” In MUR 6002 involving Sheldon Adelson’s Freedom’s Watch, it was contended that even this narrowed requirement applied only when a donor gave to further a specific advertisement. Might not a future FEC, one more sympathetic to regulation, try to use this same flexibility on other questions of statutory interpretation—perhaps in ways favoring regulation, as the FEC did in several matters that arose from the 2004 Presidential election?

None of this is meant to engage the result in Van Hollen. One can certainly argue that the FEC might have avoided defeat by writing the rules more carefully in 2007 or by defending them less glibly on remand in 2012. Rather, it is to say that, when the FEC loses in court on administrative law grounds, the reasoning—and not just the result—can have long-term consequences for agency power.

In Brief: The FEC’s New Citizens United Rules

Yesterday the Federal Election Commission adopted rules to implement the Supreme Court’s decision in Citizens United v. FEC. The rules will not take effect before the November 4 election, although they largely codify practices that have been understood to be lawful since Citizens United came down nearly five years ago.

Here—briefly—is what the FEC did:

  • The FEC rules will now expressly permit corporations and labor unions to make independent expenditures and electioneering communications—as Citizens United held that they must.
  • The FEC concluded that “the Court’s holding applies to all non-coordinated corporate and labor organization expenditures, regardless of whether they fall into the narrower statutory definition of an ‘independent expenditure.’” Yet the FEC left standing a wide range of restrictions on corporate fundraising activity that do not necessarily involve coordination with parties. These restrictions are a potential source of future controversy.
  • The FEC adopted its first explicit acknowledgement of so-called “Super PACs” in the regulations: it added a note to the rules, making clear that corporations and unions may make unlimited contributions to independent expenditure-only PACs and to the non-contribution accounts of  “Carey” PACs.  The FEC said it will undertake a separate rulemaking on Super PACs, but did not say when.
  • The FEC left standing the existing disclosure rules for corporate and union independent expenditures and electioneering communications. For electioneering communications, it left a gap between the treatment of corporations and unions, which must only disclose donations “made for the purpose of furthering electioneering communications”—and other unincorporated entities, which must disclose a far wider range of donors. This is an ironic application of the Court’s holding in Citizens United, which was “that the First Amendment does not allow political speech restrictions based on a speaker’s corporate identity.”
  • The new rules allow a corporation or union to establish a segregated bank account for making electioneering communications—although the narrowness of the general disclosure requirements, as discussed above, provides a compelling reason not to do that.
  • The new rules draw a confusing and potentially controversial distinction between partisan and non-partisan voter drives targeted to a corporation or union’s “restricted class.” It allowed corporations and unions to withhold information and help based on support for or opposition to a particular candidate or party. But in that case, the voter drive would not qualify as “nonpartisan,” would be treated as an expenditure, and apparently may not be coordinated with candidates or parties.

FEC Updates Rules in Response to Citizens United and McCutcheon, Approves Request on Presidential Nominating Conventions

At today’s public meeting, the FEC updated its rules in response to the Supreme Court decisions in Citizens United v. FEC and McCutcheon v. FEC, and approved an advisory opinion allowing the Democratic and Republican national party committees to establish separate committees to raise convention funds under a separate contribution limit.

While the decision in Citizens United, which allowed corporations, unions, and associations to spend unlimited amounts in elections, was handed down nearly five years ago, the Commission had yet to update its rules to conform to the decision. The delay was caused by a divide between the Democratic- and Republican-appointed Commissioners over whether updates to the rules should include provisions on the disclosure of campaign spending. Commissioners Walther and Weintraub argued that any new rules should address the disclosure issue; Vice-Chair Ravel, however, joined the Republican Commissioners in voting to update the rules, giving the Commission the four votes it needed to proceed.

Commissioner Weintraub was vocal in her opposition to the new rule, arguing that the Commission was “falling down on the job” by not requiring disclosure of all political expenditures. She said the Commission was “rigging the game” to prevent new disclosure regulations. Weintraub also brought up a list of other items on which she sought Commission regulatory action, including the ban on contributions from foreign nationals, coercion of employees and union members, and corporate facilitation rules.

In addition to the rules in response to Citizens United, the Commission unanimously approved rules implementing the Supreme Court’s decision in McCutcheon v. FEC, which invalidated the law’s aggregate limits on contributions from individual donors. The interim final rule would remove the invalidated cap on individual contributions from the Commission’s existing regulations.

The Commission also adopted an advanced notice of proposed rulemaking (ANPRM) on McCutcheon and announced that it will hold a hearing on February 11, 2015.  The subjects to be discussed include potential changes in disclosure rules, earmarking, and rules for political action committees and joint fundraising committees. The ANPRM also asked for comments on the agency’s presentation of campaign finance data.

After debating the Citizens United and McCutcheon rules, the Commission turned to a joint advisory opinion request from the Democratic and Republican national party committees. Perkins Coie’s Bob Bauer and Graham Wilson represented the DNC in the request. The parties filed the request after Congress passed a law stripping the presidential nominating conventions of their public funding. To make up the shortfall, the parties proposed to create separate committees, subject to the amount limitations and source restrictions, that would raise funds to finance the conventions. The Commission granted the request by a 4-2 vote. Commissioners Weintraub and Walther voted against the proposal, arguing that the matter would be better addressed through rulemaking.

Last, the Commission briefly discussed two identical advisory opinion requests from David Brat and Jack Trammell. Brat and Trammell are both candidates for Virginia’s 7th Congressional District seat, which Eric Cantor resigned in August after losing to Brat in the primary election. Both Brat and Trammell are professors at Randolph-Macon College, and both sought to continue receiving benefits from the college while taking a leave of absence to run for Congress. The Commission appeared poised to approve the requests, but the meeting was cut short when Vice-Chair Ravel had to leave to catch a flight.

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