On February 12, 2026, the Governor's Office received an appeal from Conner Edwards, relating to the Washington Public Disclosure Commission's denial of a petition to amend or repeal WAC 390-16-105 (Mini campaign reporting—Eligibility). The Governor denied the appeal on April 14, 2026.

On February 12, 2026, the Governor's Office received the appeal you filed in response to the Public Disclosure Commission's decision to deny your petition to amend WAC 390-16-105. Under RCW 34.05.330(3), an agency's denial of a petition to repeal or amend a rule may be appealed to the Governor.

WAC 390-16-105 concerns eligibility for mini campaign reporting. The rule permits a candidate or candidate's authorized committee to follow the "mini" reporting option rather than the full reporting option if it meets certain conditions. One of the conditions is that "[n]either aggregate contributions nor aggregate expenditures exceed the amount of the candidate's filing fee provided by law plus a sum not to exceed $7,000." WAC 390-16-105 (1)(a). This rule is authorized by RCW 29B.20.030(8), which gives the Public Disclosure Commission authority to "[a]dopt rules relieving candidates or political committees of obligations to comply with election campaign provisions of this title, if they have not received contributions nor made expenditures in connection with any election campaign of more than [seven] thousand dollars." RCW 29B.20.030(8).1

Your petition asked the Public Disclosure Commission to amend WAC 390-16-105 to prohibit candidates, candidates' authorized committees, political committees, or continuing political committees from utilizing the mini reporting option starting January 1, 2032. Petition at 1-2. Your petition states that the change is needed because "[m]ini reporting prevents members of the public from viewing campaign finance information and creates an administrative burden for staff. PDC technological improvements have taken away the need for this option." Petition at 2.

The Commission denied your petition on February 12, 2026. The Commission's denial indicates that it reviewed your petition and supporting materials and considered your petition at its regular meeting on January 22, 2026. In its denial letter, the Commission states that according to PDC staff, "mini reporting is used by a significant number of campaigns and continues to provide a popular option for filers." Commission Response at 1. In some situations, PDC staff indicated, the use of mini reporting generates less work for them because fewer reports are filed and because the simpler process for filing reduces the amount of technical support small filers need. Commission Response at 1. The Commission acknowledged it may be more difficult for the public to access some campaign finance information under this option, but they consider the impact minimal on overall campaign finance transparency. Commission Response at 1. The Commission found that "the current system of full and mini reporting was sufficient since it properly balanced the need for transparency with the benefits of a less complicated reporting option for small campaigns." Commission Response at 2. Commissioners were concerned that "eliminating mini reporting would add to the reporting burden of small, unsophisticated campaigns and discourage candidates from filing for difficult to fill positions in small districts." Commission Response at 2.

The Commission committed to monitoring the use of mini reporting, "especially the process of transitioning from mini to full reporting, to determine if smaller changes could be made to improve the process." Commission Response at 2. It also states that it will continue trying to make full reporting less burdensome, and that once it makes progress on that goal, it can then reconsider whether to retain the mini reporting option. Commission Response at 2.

You appealed the Commission's denial of your petition on February 12, 2026. However, your petition does not identify any error in the Commission's decision to deny your petition to amend WAC 390-16-105. The Commission is appropriately positioned to balance different considerations and make a policy determination, and it has properly exercised that discretion here.