Since most local ethics commissions do not have the authority to
initiate their own investigations or draft their own complaints
(although in many cases this authority is not expressly withheld),
there is a special role that former EC members, especially chairs,
can play: filing complaints that no one else will file.
According to a
Santa Fe Reporter blog post this week
, a former chair of the
city's Ethics and Campaign Review Board filed a complaint against a
mayoral candidate participating in that city's public campaign
financing program, as well as against four PACs which supported the mayor's
candidacy but, according to the complaint (attached; see below),
were not acting fully independently.