First, lines 67-68 could be read to prohibit a political subdivision from imposing content-based restrictions, including permissible content-based restrictions that advance a compelling governmental interest using the least restrictive means.   We suspect the bill is only meant to address TPM restrictions, which, by definition, must be content-neutral. Please consider eliminating any uncertainty by adding to the words “content-neutral” in the definitions of “generally applicable time, place, or manner restriction” and “individually applicable time, place, or manner restriction.”

Second, the requirement on lines 70-71 would be burdensome for SLC, which issues between 400 and 500 events permits a year without problem or controversy.  We like the idea of requiring the policy (practice or custom) to be stated in ordinance, and are happy to propose amendments to SLCC 3.50 to more clearly comply with this if it passed.  That will guide employees without requiring a full (legal?) analysis about narrow tailoring and alternative means of expression for each permit that either denied or modified a permit application.  Given the volume of requests SLC gets, this would have a fiscal impact on us.  Please consider eliminating this requirement, and perhaps replacing it with a requirement that the adopted policy was considered and implemented.  

Finally, an easy fix:  In line 42 “political subdivision” should be deleted.  Political subdivisions don’t “apply generally” to persons.  I think that usage in the bill confuses “political subdivision” with “ordinance, policy, practice, or other action” in 39-40.  The concept doesn’t need to be repeated in line 42 because the reference in the lead-in (in 39-40) to “ordinance, policy, practice, or other action” grammatically applies to everything in 41-43.