2020 OC ENDORSEMENTS #2: 12 Statewide Propositions





The 2020 state Propositions depicted in a way that (maybe) you’ll remember: Stem cell research funding; no Prop 13 privilege for office buildings; OK for state affirmative action; allow paroled  felons to vote; allow 17-year-olds to votes in primaries if 18 by election day; changing rules for resetting taxation of home values; imposing harsher criminal procedure and punishment rules; allowing rent control; changing rules on whether app drives are employees; requiring doctors on call in dialysis clinics; expanding power and funding of the state consumer protection agency; and ending cash bail in favor of threat assessment.

OK, these aren’t that all that complicated.  Let’s dive in!

(Key to this chart: “CI” is a “Citizens Initiative”; “LR” is a “Legislative Referendum”; “CA” is a “Constitutional Amendment”; “SS” is a “State Statute.”  Bonds are always numbered first.)

CISS Proposition 14 Bonds Issues $5.5 billion in bonds for state stem cell research institute & grants
CICA Proposition 15 Taxes Requires commercial and industrial properties to be taxed based on market value and dedicates revenue
LRCA Proposition 16 Affirmative Action Repeals Proposition 209 (1996), which barred state from discriminating or granting preferential treatment based on race, sex, color, ethnicity, or national origin in public employment, education, or contracting
LRCA Proposition 17 Suffrage Restores the right to vote to people convicted of felonies who are on parole
LRCA Proposition 18 Suffrage Allows 17-year-olds who will be 18 at the time of the next general election to vote in primaries and special elections
LRCA Proposition 19 Taxes Changes tax assessment transfers and inheritance rules
CISS Proposition 20 Law Enforcement Makes changes to policies related to criminal sentencing charges, prison release, and DNA collection
CISS Proposition 21 Housing Expands local governments’ power to use rent control
CISS Proposition 22 Business Enacted law, facing referendum, clarifies that app-based drivers are employees rather than independent contractors and enacts several labor policies related to app-based companies
CISS Proposition 23 Healthcare Requires physician on-site at dialysis clinics and consent from the state for a clinic to close
CISS Proposition 24 Business Expands the provisions of the California Consumer Privacy Act (CCPA) and creates the California Privacy Protection Agency to implement and enforce the CCPA
VR Proposition 25 Trials Replaces cash bail with risk assessments for suspects awaiting trial


Here are some notable endorsements — put your favorites in comments and I may incorporate them:

Gov. Newsom:  Yes on 14, 15, 16, 17, 18, 19, 25; No on 20, 21

CADEM: Yes on all, except for No on 20 and 22, and neutral on 24

CAGOP: No on all, except for Yes on 20 and 22 and neutral on 19

Sierra Club: Yes on 15, 16, 17, 25; No on 22

League of Women Voters of CA: Yes on 15, 16, 17, 18, 25; No on 19, 20, 24; neutral on 14, 21, 23; “no position” on 22.

California Federation of Teachers: Yes on 15, 16, 17, 18, 25; No on 20, 22

Now, before we discuss them, check out this fantastic graphic by artist and political analyst Alfred Twu showing who, as of Friday, October 2, was funding both sides, and by how much.  Snag and enlarge it if you’d like!

Artist, political analyst, and ballot measure geek pa excellence Alfref Twu tracks and depicts the state ballot measures and, here, who’s spending how much on them!

As Twu writes,

Who’s paying for that Prop? California’s $502,000,000+ ballot measure election donor list is topped by DaVita and Uber. Realtors, unions, landlords, and business associations are also big on the list.

Data is from the CA Fair Political Practices Commission Top Contributor list at http://fppc.ca.gov/transpa…/top-contributors/nov-20-gen.html

(That will, for example, affect my views of Props 22 and 23….)

Now let’s look at the twelve individual propositions:

PROP 14 is a relatively rare bird: an initiative bond measure, which is why it gets numbered first.  The proponents want to replenish the fund of money for grants to stem-cell researchers within the state. Arguably, this makes it easier for the state to attract and keep scientific talent, and to keep industries using these advances to develop medical approaches.

My guideline on bonds is that they may be an appropriate means of finance when: (1) the benefit to be gained is to the benefit of people over the lifetime of the bond; (2) no other and better ways are availableto finance it; and (3) the benefit sought is significant enough to justify the principal and interest expenses.  I raise this because objections to the financing mechanism is one reason why the LWV did not endorse it.  Ryan will likely disagree, but I think that it passes all of these tests, so I favor it.  Stem-cell based medical advances will accrue primarily to the benefit to the benefit of people in the future, and delaying them simply delays medical successes.

The other persuasive argument against it is that the original creation of the granting agency came at a time when the public wasn’t yet willing to fund projects in these areas — which is no longer the case.  To which I answer: HUH?  We’re about to have a Supreme Court that will very likely eliminate abortions in many states — and possibly in all of them.  Federal money would not be available in a Pence Administration, at the least.  California has to, to some extent, operate as its own enlightened nation-state — and this is a significant part of that.

And, frankly, if we’re going to float a bond, this is exactly when to do it.  Interest rates are low and investors are howling to safe financial harbors.  YES ON 14.

PROP 15 is the long awaited “split roll” modification to Prop 13.  I understand that “starve the beast” types may want to oppose it on that principle — but for people concerned about equity, this is an obvious improvement.  (Yes, it will mean higher costs for those mainly large corporations who rent space in large office buildings.  But they won’t leave the state if this is the place where they can make money, as it will continue to be.)

Here’s what Prop 13 did(among other things): it “rolled back most local real estate assessments to 1975 market value levels, limited the property tax rate to 1 percent plus the rate necessary to fund local voter-approved bonded indebtedness, and limited future property tax increases to a maximum of 2% per year.”  The value of California property rose about 1000% from 1975 to 2004 — 11 times as high — and nationwide has gained about another 43% since then.    (California is probably higher; the national data only shows an increase from 1975 to 2004 of 275%.  Orange County is incidentally, probably well over the state average.)  It looks like there have probably been 10 years in the past 45 with inflation  under 2%, but lets pretend that that cap reduced taxes in every year.  With 2% increases annually, a $10,000 home in 1975 (yes, they existed) would have an assessment increase at most to $24,379 even if prices inflated to at least 2% (and it’s rarely below that) each year.  But prices actually went $from 10,000 to about $110,000.

What you need to understand is that Prop 13 was intended to help older people stay in the homes that they want to keep, even as their incomes reduced after retirement, by freezing their property tax assessments — yes. I remember how it was sold to voters; I was 18 at the time and it was my first election — and then it would be reassessed only when (and I’m writing this without looking it up) it was sold, perhaps sufficiently improved. had added owners, or inherited.

This notion made some sense because people don’t live forever.  We’re talking about maybe a 25 year benefit for most retirees, to keep their quality of living good, and that’s the sort of social expense we can absorb.  A young couple who bought into a neighborhood in 1978 and never moved their primary residence  would have also done very well, which has the advantage of enhancing neighborhood stability but the disadvantage of creating high disparities between neighbors.

(As an aside, the effect was also racially discriminatory as well.  Blacks and Latinos could not buy houses — partly due to discriminatory practices in the real estate industry, partly due to inability to get loans and similar factors — in neighborhoods where the property would most appreciate, and were more likely to face live experiences that would force them to move.  Prop 13 has never done much for their wealth.  But while a reason to vote Yes on 15, it’s separate from the larger argument.)

The big problem that Prop 15 addresses is that now large office buildings are help by incorporated holding companies or partnerships with fluid ability to transfer membership — who then lease and allow sub-lease anything up to entire buildings and to tenants who may appear to own the building for decades (perhaps over a century,)  In the absence of split roll, those entities are granted the same right of perpetual reassessment avoidance as individuals!

The problem should be obvious: corporations and even partnerships with fluid membership are potentially immortal.  The assessment that they received back in, oh, October 1980 — in the midst of what for almost 30 years the worst recession since the Great Depression — could literally remain in effect for as long as the financial and governmental system itself remains.

This wasn’t the plan; this wasn’t the pitch; but this is what happened.  And what that means is most all of the people who have bought property more recently, or rent from people who did, are paying a far greater share of property taxes (directly or in rent) than some of the world’s richest corporations in downtown LA.

I’m voting YES ON 15.

PROP 16: If you haven’t read the section just above on the racial impacts of Prop 13, you should do so.  That sort of huge discriminatory effect of even a facially non-discriminatory law is one of the main reasons why we states allow the state to use affirmative action in public hiring, contracting, and college admissions.  There are many, many others, such as the benefits of diversity in offices and campuses.

California made such initiatives illegal when it passed Prop 209.  Prop 16 is designed to repeal that law and allows the use of such initiatives to the extent permissible by applicable federal and other state law.  The state should be able to right such wrongs.  YES ON 16.

PROP 17: This would allow convicted prisoners who have been paroled to vote.  Not a lot of spending on this one.  If someone has been rehabilitated, they should be re-enfranchised by law, not by the grace of the Governor.  YES ON 17

PROP 18:  Not a lot of spending on this one either.  It says that if someone will be 18 by Election day, one can vote in the primary preceding that election to help them winnow down the choices on who they’ll get to vote for.  Yes, they’re in high school, but it seems like a reasonable extension of the right to vote.  YES ON 18.

PROP 19:  This measure also deals with resetting property taxes.  It giveth with one hand (allowing people to retain their freeze on tax assessments when they move in certain circumstances) and taketh with the other (reducing the ability to retain whose assessment freezes).  I think that one can make a case for both on the merits — but looking at that funding chart I see that the California Association of Realtors — which has done so much to elect and pervert so many candidates — has spent $41 million, essentially unopposed, to get this measure passed.

You know what?  I can’t trust that one of their smart lawyers hasn’t figures out a way to get something terrible into the fine print — and they’ve done little to earn that trust.  Vote NO on 19.

PROP 20: There have been a variety of measures that have led to more humane treatment to those approaching, in, or having exited the criminal justice system.  It has been fueled — by its instigators more so than the instigated — by seeking the political benefits of bigotry and fake news about the effects of these measures, and instituting a careless and carefree attempt to roll them back.  If you want more jails and prisons, worse conditions, worse post-incarceration lives, etc. — if you think that it will really make your lives and our society safer and better — then you will want to support this.  If you realize what a crock all of that is — and that it doesn’t prevent crime (because misdemeanors aren’t usually committed by people good at thinking ahead and balancing interests) and leaves a more desperate population non-conducive to safety and social harmony — you should join the rest of us and vote NO on 20.

PROP 21: This allows cities and counties to enact rent control ordinances.  As Ryan will tell you, there is a strong argument that rent control has all sorts of negative and perverse effects.  On the other hand, failure to control rents (at a minimum) just exacerbates the problems of homelessness and bankruptcies.  It seems that giving local governments a sword to brandish, and let them decide whether and how to use it, is the wisest course because it allows for the greatest ability to respond to developing circumstances.  (I know that some will disagree.)  Things are worse than most of us realize, so I’ll vote YES on 21.

PROP 22: This is a referendum on the bill that re-designated many “independent contractors” in the gig economy — Uber, Lyft, and food delivery drivers are the prototypical examples — as employees.  This was the correct move under the law, based on well-established multi-part tests over who controls the means and processes of work — but the gig economy had been allowed to get away without doing it.  What that led them to enjoy — aside from not paying Worker’s Comp and Disability, and potentially any benefits  at all, and having to abide by any of the state’s work regulations — was essentially a huge competitive advantage over their competitors who did have to do such things.  Do they want to continue having this competitive advantage (which among other things denies workers their right to engage in collective action, for example to fight wage theft)?  Sure they do!  Do workers want them to be able to do it?  Well … looking at ads, you would think so, but there are lots of people who disagree — people who would like gig work if it came with safety and dignity — who cannot fund their own ads.

For our benefit — but I suspect also for their benefit — I will vote NO on 22.  The companies that can dump $185 million (and that’s just so far!) into this one proposition in this one election can afford to treat their employees like employees, just like everyone else must do.  If there’s money to be made, they’ll still make it.  If not, then maybe the unions can set up co-op enterprises to provide the same sort of service.

PROP 23:  Again, look back up at the graphic showing funding.  Just the two largest for-profit dialysis clinics alone — who have been accused of poor sanitary conditions, poor working conditions, and much else — have already poured in $86 million to fight against having to keep a medical doctor on hand while they operating.  (And also, to prevent them from slamming their doors closed without state permission, in order to start a panic.)  Their ads show kidney patients wailing about how they won’t be able to get dialysis if the for-profit clinics close.

That won’t happen.  You know what will?  If they really do want to close, the state will take over the clinics, likely transferring them to new owners (such as medical schools and public hospitals) who can do them right.  Nobody dies.  Just some investors get cashed out earlier then they wanted, still having made a bundle.  When I vote yes, it will give some satisfaction to make there assholes pay for their scaring the hell out of dialysis patients, just to pad their profits.  YES on 23.

PROP 24:  This one’s sort of hard to explain.  It deals with Consumer Privacy, Consumer Protection, the California Consumer Privacy Act of 2018 (CCPA), and the proposed California Consumer Protection Agency, which would enforce that 2018 Act.  The ballot summary tells most of the story.  If enacted, it:

  • Permits consumers to: (1) prevent businesses from sharing personal information; (2) correct inaccurate personal information; and (3) limit businesses’ use of “sensitive personal information”—including precise geolocation; race; ethnicity; religion; genetic data; private communications; sexual orientation; and specified health information.
  • Establishes California Privacy Protection Agency to additionally enforce and implement consumer privacy laws and impose fines.
  • Changes criteria for which businesses must comply with laws.
  • Prohibits businesses’ retention of personal information for longer than reasonably necessary.
  • Triples maximum penalties for violations concerning consumers under age 16.
  • Authorizes civil penalties for theft of consumer login information, as specified

I hear horror stories about consumer privacy, and what happens in California is likely to affect the rest of the nation.  If this leads to cleaning up practices, it’s good.  Yes, it might lead to frivolous lawsuits — and will almost surely lead to accusations of frivolous lawsuits — but I find that the courts are pretty good with stanching those, and creating the agency could mean creating an pre-filing requirement for an administrative action that should keep gunk out of the system.

We’re a fifth of the way through the 21st century; we might as well learn to take on these sorts of issues before we land in a dystopia.  YES on 24.

Prop 25:  The Bail Bonds industry is slightly outspending proponents of this proposition that would eliminate cash bail in favor of risk assessments as to the risk of a person’s flight from justice or of causing harm to others.  Until those risks are acceptably low, people would stay in jail.  We would no longer have a system where people’s friends and family exacerbate their financial woes to get a loved one (or even liked one) out of incarceration.  We would no longer have a system where the wealthy can go free and the poor must stay incarcerated for years before their “speedy trial.”.  It would be a better world.

The bail bonds industry would not survive, but it might transform.  The bail bonds owners have the best contacts with bounty hunters, who will still be needed for when the risk assessment about flight risk fails.  More importantly, they have years of experience with judging flight risks (and probably risks of harm to others as well), and they might have an important role in the risk assessment process.  That would be a happy resolution as we move into a better world.

Not even the Republican Party opposes this.  While proponents list a long list of names, opponents list just a few — and lots of organizations, mostly industry trade associations, chambers of commerce, and (for some reason) the Howard Jarvis Taxpayers Association.  And their arguments proclaim “a right to bail” — which means presumably means a right to buy your way out of a bad situation even if it threatens others.  And they sneer that computers will be the ones to decide who stays or goes — but those computers will be based on distilled experience with previous outcomes!  What they really want, all in all, is profit and unfairness.

In a presentation I made today (Oct. 3) to the Anaheim Democratic Club on these propositions, Vern and Donna brought up some interesting points they

I say YES on 25!  Free (from bail, not on bail) at last!

But …

There is another side to the story, which Vern raised as part of my talk to the Anaheim Democratic Club on these 12 propositions, so I’ll present it and then explain where I think is misguided.

The Argument against Prop 25 in the State’s Official Voter Guide — and if you haven’t received that yet, check your voter registration address because they might have it wrong! — is a combined work of a retired judge, the Executive Director of the Crime Victims Alliance … and Alice Huffman, President of the California State Conference of the NAACP.  I take her arguments quite seriously, so let’s review them — but first, the ones that aren’t hers.

I presume that Huffman is not behind these talking points:

  • “Prop 25 will endanger public safety!”
    • No it won’t.  It may lead to more people being released on their own recognizance if they pass the risk assessment tests — and bear in mind that the computer algorithms, unlike judges, don’t have to worry about being voted out at the next judicial retention election — but there’s no reason to think that it will do more poorly (especially as it becomes refined with experience) than judges do anyway.  (One can of course eliminate all risk by keeping all accuseds in jail — but that leads to prison overcrowding problems and wholesale court-ordered releases of prisoners.)  It doesn’t, however, make sense that the people who can afford bail and thus get released are any less of a risk of flight or violence than people who have to stay in jail because they can’t afford bail.  Of course, if your view is that the poor are darker and darker people are more threatening to the cops, you may try to defend this view on that basis — but it’s really really racist.
  • “Prop. 25 tosses out the tool that ensures that defendants show up for trial!”
    • Prop 25 would get rid of bail.  It doesn’t have to get rid of bounty hunters.  If a court issuing a bench warrant wants to add issue an order that a bounty be put on a released defendant that flees justice, it can.  (And it might be less costly without paying the middleman.)
  • “Prop 25 will raise taxes because it costs money to implement!”
    • Actually, computerized everything tends to be cheaper.  Housing people in jail who can’t afford bail, but are not flight or retaliation risks, is what’s really expensive
  • “Prop 25 will overburden the courts with hearings appealing the decision made by the computer program!”
    • First of all, it doesn’t have to do that at all.  A challenge to a computerized assessment of threats could be challenged in an administrative court, like many other administrative appeals.  Or it could be done on a paper record rather than a full-blown hearing.  But more likely is that the program (which doesn’t require a salary) will be used just as a tool to aid the judge’s decision-making.
    • An algorithm is just a step-by-step recipe for how to make a decision — usually, but not always, a rational, decision, which I’ll get to below.  It’s dispassionate; it’s not inflamed by lawyers’ theatrics or worries about being voted out of office, It’s easily able to identify hidden factors that may make it more or less likely to recommend release (and that either side may try to hide).  It offers consistent advice, following the same rules, across judges and across all defendants before a judge, both on a given day and across days. It gives judges some cover for making unpopular — but nevertheless rationally appropriate — decisions.  It will save judges time and effort, especially because it can be programmed to spit out the exact basis of its recommendation, along with calculated probabilities for both flight and violence.
    • Seriously, there’s an entire cognitive psychology literature on how properly programmed computer algotithms make more rational and consistent decisions that even experts operating on their fallible attention and hunches.  And the best thing is that if a computer algorithm seems to be making errors, you can fix it.

Now let’s look at the two points for which Huffman is probably responsible.

  • Being based on information that includes racial profiling, computer programs would end up making recommendations “that have been proven to hurt communities of color.”
    • And I’ll repeat what I ended with above: you can fix it.  In fact, with a computer program, you can identify sources of racial bias more easily using this one weird trick: you run the profile multiple times to see why it is making decisions that disadvantage people of color, then you identify whether those bases of those decisions are improperly discriminatory, and then you change the value of those variables to see whether it leads to a different result.  If it does, then you can eliminate that consideration, refine it, or assign a lesser weight to it.  (You can’t do this with a judge, who may not even know the precise factors that are influencing their decisions.)  If, for example, the variable for “lives near gang members” is in the system, you can see what happens when you zero it out.  Ideally, the result is that it releases some persons of color who are not actually greater risks for flight or violence.  You can calibrate the system against the decisions made by the best judges, etc.  The computer doesn’t actually think; it calculates.  You’ve heard of “garbage in, garbage out”?  You can instruct it properly, and make sure that your computer isn’t being instructed with racist garbage.
  • Along the same lines, Huffman argues that a computer “will create more biased outcomes against people of color and those from economically disadvantaged areas.”
    • First, I think that those biases are already present within the current system, right?  In fact, those biases will be stronger because of judges’ existing worries about the consequences if the err by being merciful that leads to flight or violence.
    • Second, economically disadvantaged people have a harder time making bail.  The present system says that if the same exact person, posing the same exact risks, wins a $10,000 lottery the day after their arraignment, now they get to go free.  And that, I say, is nuts.
    • Third, and again: you can fix it.  In fact, this is the only kind of sentence recommending system that you really can fix.

I understand and honor these concerns — but let’s not fail to note that in these respects the present system already sucks.  We can refine the system, with an eye towards inc incorporating information about when computers err by letting people out, over time — and with enough people being released pending trial, it won’t take that long to make great initial strides.  We can refine the system in a similar way as how employment discrimination testers who submit identical job applications — one with a stereotypical African-American or Latino name and one with a name like “Jordan Brandman” or “Curt Pringle” — and see how  different factors lead to indefensibly discriminatory results.

Huffman is right that there are tremendous problems in the bail system.  But letting some (more likely to be of color) people out a “10% of $100,000 cash equivalent bond” while others (more likely to be white) out on their own recognizance does not solve the problem — in fact, it only intensifies it for those who must liquidate property or from whom they must borrow money.

She’s right about the problem — but she’s wrong to be opposing the best means of potentially solving it.

[Adding to this story: a reputable publication reports that Huffman has been taking money from the bail bonds industry write columns (in Agran-style fake newspapers claiming to represent minorities) to oppose Prop 25 — as well as Props 15 and 21 — and to support Prop 22!

Judge for yourself:

According to public records at the California secretary of state’s office reviewed by the Prospect, the Committee to Protect the Political Rights of Minorities is an independent political group run by none other than Alice Huffman, who is both its treasurer and its controlling officeholder. It’s funded by advocacy groups behind those very propositions. In late August, the committee received $100,000 each from No on Prop 21 and No on Prop 15, both of which Huffman, and Minority News, have come out strongly against. And if that weren’t enough, those payments weren’t even made directly to Huffman’s committee. Rather, they were made to an intermediary: AC Public Affairs, Huffman’s personal consulting firm that she runs in parallel to her post as the president of the state’s NAACP chapter. The Committee to Protect the Political Rights of Minorities has also made outgoing payments, in the amount of $155,000, to both AC Public Affairs and the California NAACP. Huffman founded AC Public Affairs in 1988, 11 years before she was elected president of the state’s NAACP chapter.

The Committee to Protect the Political Rights of Minorities is the outgrowth of an extremely peculiar operation that Huffman has set up for herself, and while to any layperson it might seem impossibly corrupt, it’s technically not illegal. Huffman, the 2004 chairwoman of the Democratic National Convention, has been paid more than $1.2 million so far this year by ballot measure campaigns that she or the California NAACP has endorsed, via payments made to AC Public Affairs, her consulting firm. She’s taken money from campaigns funded by commercial property owners fighting property tax increases, major corporate landlords opposing rent control, and even the particularly odious bail bond industry fighting an initiative to end cash bail, all issues that affect the state’s Black population. In turn, she’s used her platform, via the NAACP, her Committee to Protect the Political Rights of Minorities, or simply her personal brand, to endorse those measures, all without disclosing her direct financial incentives.

Huffman has long had a reputation as an endorsement for purchase among those in the know in California politics. But her dual position as leader of one of the foremost civil rights groups and pay-for-play consultant is particularly important in this election cycle, as racial justice has risen to the forefront of political priorities, especially for Democrats. In a state like California, functionally a one-party state, Huffman is uniquely positioned to influence the outcome of various measures with her endorsement.

That’s why 2020 has produced a record-setting windfall for her side hustle. According to CalMatters, “Huffman was especially sought after this year” in the wake of the hundreds of Black Lives Matter protests that occurred throughout the country. Huffman’s cashing in on that popular movement has garnered some criticism from activists and those who feel like she’s set up a standard where the endorsements of prominent Black rights groups are for sale to the highest bidder. Indeed, AC Public Affairs has received $590,000 from the No on Prop 15 campaign, $280,000 from the No on Prop 21 campaign, $200,000 from No on 25, and $85,000 from the Yes on Prop 22 campaign, according to public records.

Huffman has also been paid to support cigarette makers and pharmaceutical companies.  How she can still show her face within the Democratic Party, and withstand censure from the NAACP, is shocking. Let’s remember her name.

With all due respect to the NAACP (and maybe ACLU?), I’m still YES on 25.

Vern is at present a NO.  That might now change, if he agrees that she’s a klepto.  (UPDATE:  It did not.)

About Greg Diamond

Somewhat verbose attorney, semi-retired due to disability, residing in northwest Brea. Occasionally runs for office against bad people who would otherwise go unopposed. Got 45% of the vote against Bob Huff for State Senate in 2012; Josh Newman then won the seat in 2016. In 2014 became the first attorney to challenge OCDA Tony Rackauckas since 2002; Todd Spitzer then won that seat in 2018. Every time he's run against some rotten incumbent, the *next* person to challenge them wins! He's OK with that. Corrupt party hacks hate him. He's OK with that too. He does advise some local campaigns informally and (so far) without compensation. (If that last bit changes, he will declare the interest.)