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City Council April 15, 2013 Page 2 law. Nevertheless, a major factor in the court's analysis would be the administrative interpretation of the disputed clause, so the court would give significant weight to the City Council's determination. Canons of Statutory Interpretation 1. Intention. The intent of the adopting body is the paramount rule of statutory construction. CCP Section 1859. In this case the legislators of Measure PP were the voters of Pleasanton. We have conflicting interpretations from two of the lead proponents of Measure PP (Ayala and Fox). However, after the fact statements from proponents are generally not given much weight by a reviewing court. The ballot arguments did not address the meaning of structure, but the argument against Measure PP charged that it would stop the by-pass road, and the proponents responded that was untrue. As pointed out by City Staff, if the less common meaning of"structure" was intended by the proponents, that definition should have been disclosed to the voters (and to each other!). The actual voters on Measure PP are thus unlikely to have considered this issue when voting. There is no dispositive indication of intent in the legislative record. 2. Plain Meaning. Without good reason from context or related laws, the court does not reach beyond the plain meaning of words in the statute. CCP Section 16. Again both sides have submitted extensive supporting documents, like the engineer's statement submitted by Ventana Hills group saying engineers do not consider roads to be a structure. The more common use of the word "structure", by far, is that structures have a three dimensional vertical component, like a building and not like a road. In fact, the very origin of the word structure in Middle English, structus, means to heap together. The weight of the evidence on a plain meaning interpretation of"structure" is that a road is not a structure. 3. Legally Defined Meaning. But CCP Section 16 and case law do recognize that technical words that have acquired a peculiar and appropriate meaning in law are to be interpreted in accordance with that meaning. As City Staff points out in the Planning Commission Staff Report, there is no technical definition in the City Code that resolves the road v. no road issue. The "road is a structure" group, led by Ms. Fox, located a definition from Govt. Code Section 65927 which explicitly includes a road as a structure. The fact that the statute had to spell out the intention to include a road as a structure is evidence that the more common plain meaning does not include a road as a structure. Moreover, a definition agreeing with Ms. Fox's desired interpretation, located after the fact from within 30,000