Minutes workload scales with the number of public bodies a government has, not its population. Open meeting law defines a “public body” by function, so a seven-member advisory subcommittee that meets quarterly generally owes minutes built to the same content standard as the full council. Count your boards, commissions, and committees — not your residents — to size the real workload.
Ask almost anyone to estimate how much work a government's minutes represent and they will reach for population. A town of 4,000 must be easy. A city of 400,000 must be hard. It is such a natural assumption that vendors price on it, staffing formulas assume it, and budget conversations rest on it.
It is wrong, and it's wrong in a way that consistently underestimates the burden on exactly the governments least equipped to carry it.
Minutes are not produced per resident. They are produced per meeting, per body. A government's minutes workload is a function of how many separate public bodies it has, how often each one meets, and how long each meeting runs. Population enters that equation only indirectly, and much more weakly than anyone expects. A small town with a planning board, a zoning board of appeals, a conservation commission, a finance committee, a historic district commission, a library board of trustees, a board of health, a school committee, and the dozen ad hoc committees those bodies spawn is not producing one set of minutes a month. It is producing dozens, and one part-time clerk is producing all of them.
This is the subcommittee multiplier, and it is the most under-discussed structural fact in the minutes business.
The number everyone quotes is the floor, not the ceiling
Start with the headline count. The U.S. Census Bureau's 2022 Census of Governments counted 90,837 governments in the United States. Setting aside the federal government, the 50 states and the District of Columbia, that breaks down into 3,031 county governments, 35,705 township and municipal governments, 12,546 independent school districts, and 39,555 other special-purpose local governments. Those figures are summarized in a March 2024 Federal Reserve Bank of St. Louis analysis of the Census data.
Ninety thousand governments is a striking number on its own. But the far more important thing about it, for our purposes, is what it excludes.
The Census Bureau only counts an entity as a government if it meets a specific test: it must be organized, have governmental character, and be substantially autonomous, meaning it determines its own budget and is not directly controlled by a parent government. That is a sensible definition for fiscal statistics. It is close to useless for estimating minutes.
Because every planning commission, zoning board of appeals, finance committee, personnel board, library trustee board, conservation commission, historic district commission, and ad hoc citizens' advisory committee sitting inside those 90,837 governments is invisible to that count. None of them sets its own budget. None of them is substantially autonomous. Every one of them is a separate public body that meets, deliberates, and owes a record.
Governance density is not linear in population
Even at the level the Census does measure, the assumption that bigger population means more government falls apart on contact with the data. The same St. Louis Fed analysis lays it out plainly.
| State | Local governments (2022) | Per 100,000 residents |
|---|---|---|
| Illinois | 6,930 | 55 |
| Texas | 5,533 | 18 |
| Pennsylvania | 4,851 | 37 |
| California | 4,494 | 12 |
| Rhode Island | 127 | 12 |
| Hawaii | 21 | 1 |
Illinois has more than 1.5 times as many local governments as California despite having less than a third of California's residents. Hawaii has 21 local governments; Rhode Island, with a smaller population, has 127. North Dakota and South Dakota run 330 and 209 local governments per 100,000 residents respectively, the only two states above 200.
Whatever governance density tracks, it is not headcount. It tracks history, state constitutional structure, annexation law, and how a state chose to organize schools and special districts a century ago. Which means a clerk's workload is largely determined by decisions made long before anyone currently in the building was hired.
The law counts bodies, and it defines them functionally
Here is where the multiplier stops being an operational nuisance and becomes a legal exposure. Open meeting statutes do not scope themselves to important bodies, or elected bodies, or bodies with decision-making power. They scope themselves functionally, and they sweep in advisory committees deliberately.
Massachusetts is unusually explicit. Under G.L. c. 30A, § 18, a "public body" is:
a multiple-member board, commission, committee or subcommittee within the executive or legislative branch or within any county, district, city, region or town, however created, elected, appointed or otherwise constituted, established to serve a public purpose
And the same section defines a subcommittee to include "any multiple-member body created to advise or make recommendations to a public body." Note what does the work there: however created. Not chartered, not elected, not budgeted. If a group of people was assembled to serve a public purpose and it advises a public body, it is itself a public body.
Illinois reaches the same place by different drafting. The Open Meetings Act at 5 ILCS 120/1.02 defines public bodies to include subsidiary bodies "including but not limited to committees and subcommittees which are supported in whole or in part by tax revenue, or which expend tax revenue," and the Attorney General's guidance extends coverage to advisory committees appointed by a public body when a majority of their members also sit on the appointing body.
The pattern generalizes. Different states use different words, and the edges genuinely differ, so you have to check your own statute and your own attorney general's guidance. But the direction of travel is consistent almost everywhere: the law follows the function, not the title on the door.
And each of those bodies owes the same minutes
This is the part that converts a definition into a workload. The statutes generally do not scale the content requirement down for smaller or less powerful bodies.
Massachusetts again, at G.L. c. 30A, § 22(a). A public body shall create and maintain accurate minutes of all meetings, setting forth:
- the date, time and place
- the members present or absent
- a summary of the discussions on each subject
- a list of documents and other exhibits used at the meeting
- the decisions made and the actions taken, including the record of all votes
Read that list again with a seven-member advisory committee in mind. "A summary of the discussions on each subject" is not a formality. It is a drafting task that requires someone to have understood the meeting. There is no clause reducing the standard because the body is advisory, because it meets quarterly, or because only eight residents attended.
So the marginal cost of an additional public body is not small. It is close to a full unit of minutes work. Twenty bodies means roughly twenty times the drafting, twenty approval cycles, twenty postings, twenty retention obligations.
The advisory body is exactly where it breaks
If you were going to let something slide, the advisory subcommittee is the rational place. It has no binding authority. Nobody is watching. The press covers the council, not the historic district commission's document subcommittee. This is precisely the reasoning that produces backlogs, and it is precisely the reasoning courts have rejected.
The landmark is more than fifty years old. In Town of Palm Beach v. Gradison, 296 So. 2d 473 (Fla. 1974), decided May 1, 1974, a town council appointed a citizens' planning committee to guide consultants revising the town's zoning ordinances. The committee had no power to bind anyone; it made recommendations. The trial court found that its meetings with the planners "were not open to the public, nor were minutes taken," and that those meetings "were numerous and detailed."
The Florida Supreme Court held that the nature of the committee and its function "reached the status of a board or commission that to act legally must comply with the sunshine law." The committee, having been delegated de facto authority to prepare plans on which foreseeable action would be taken, had to "stand in the shoes" of the council. The zoning ordinance that emerged from the process did not survive.
Sit with the specific failure there. The council met in public. The ordinance was voted on in public. What sank it was an advisory body with no formal power holding detailed working meetings and keeping no record of them. The missing minutes were not a paperwork lapse; they were the defect.
How to size your own multiplier
Most governments have never actually counted. Before you can fix the workload you have to see it, and the exercise usually takes under an hour.
- List every multiple-member body. Standing boards and commissions, statutory committees, ad hoc committees, working groups, task forces, subcommittees of any of those. Include the ones that are dormant on paper but still legally constituted.
- Mark which ones meet, and how often. Actual frequency, not the frequency in the bylaws. A body that is supposed to meet monthly and meets four times a year is a different number.
- Multiply out the annual meeting count. This number is almost always two to five times what people guess before they do the exercise.
- Note who drafts each one. The pattern that matters: bodies where minutes are drafted by an unsupported volunteer secretary rather than by staff. That is where the standard drifts and the backlog starts.
- Flag the ones without a current, approved set of minutes on file. That list is your actual exposure, ranked.
Governments that run this audit are frequently surprised twice: first by the total, and second by how much of it sits with bodies nobody was thinking about.
What to do with the number
The strategic response follows directly from the arithmetic. If your workload scales with the number of bodies, the only durable fix is to drive the marginal cost of an additional body toward zero. That means the twentieth body should cost you almost nothing beyond the meeting itself.
In practice that comes down to a few things:
- One standard, every body. The advisory committee's minutes should be produced the same way as the council's, to the same template, at the same content standard. Different standards per body is how you end up with twenty different formats and no way to tell which ones are deficient.
- Do not let the process depend on the clerk personally attending. A workflow that requires the clerk in the room does not scale to forty bodies meeting on overlapping evenings. Something has to capture the meeting when nobody from the clerk's office is there — which is the practical case for recording every body, not just the marquee ones.
- Standardize the record, not just the document. Motions, votes, movers and seconders, attendance. If those are captured as structured fields rather than retyped prose, they stay consistent across bodies and across whoever is drafting this month. This is the same argument we made for getting off Word and email, but the multiplier makes it sharper: shared files don't just carry no rules, they carry no rules times forty.
- Treat the small bodies as the priority, not the leftover. The council's minutes will get done because everyone is watching. Build the system for the bodies nobody is watching, and the council comes along for free.
- Remember that the standard survives staff changes, and memory does not. With this many bodies, the conventions live or die on whether they're written into the process itself — a point we made at length about what actually breaks when a long-tenured clerk leaves.
The through-line
Population is a seductive proxy because it's easy to look up. It's also close to meaningless for this problem. Two towns of identical size can differ by an order of magnitude in how many public bodies they carry, and the one with more bodies has more minutes, more postings, more approval cycles, and more exposure, with no more staff and no more budget.
The law is unambiguous about why: it defines a public body by what it does, not by how important it is. A committee assembled to advise, however created, is a public body, and a public body's minutes are held to a single standard regardless of where it sits in the hierarchy.
So count your bodies. It is a better number than your population, it is probably larger than you think, and it is the only figure that honestly describes the job. Then build a process whose cost doesn't climb with it.
Frequently asked questions
Do advisory committees and subcommittees have to keep minutes?
In most states, yes. Open meeting laws typically define a “public body” functionally rather than by rank. Massachusetts, for example, defines it to include any “board, commission, committee or subcommittee … however created, elected, appointed or otherwise constituted,” and separately defines a subcommittee as any multiple-member body created to advise or make recommendations to a public body. Illinois reaches a similar result through its subsidiary-bodies language. Coverage does vary at the edges, so check your own state’s act and attorney general guidance.
What has to be in a committee’s minutes?
Generally the same things as the parent board’s. Under a representative standard, minutes must record the date, time and place, the members present or absent, a summary of the discussions on each subject, a list of documents and exhibits used, and the decisions made and actions taken including the record of all votes. Statutes usually do not reduce that content requirement for advisory or lower-profile bodies.
How many sets of minutes does a small town actually produce?
Far more than most people estimate. A town with a planning board, zoning board of appeals, conservation commission, finance committee, historic district commission, library trustees, board of health and school committee — plus the ad hoc subcommittees those bodies create — can easily produce dozens of separate minute sets a year. The only reliable way to know is to list every multiple-member body and multiply by its actual meeting frequency.
Does a bigger population mean more meeting minutes?
Not reliably. Governance density is not linear in population. The 2022 Census of Governments counted 6,930 local governments in Illinois against 4,494 in California, even though Illinois has under a third of California’s residents. Hawaii has 21 local governments while smaller Rhode Island has 127. How many bodies you carry is driven by state structure and history, not headcount.
Why do subcommittee minutes create legal exposure?
Because advisory bodies do the detailed work that a later challenge will ask you to produce, and they are the ones most likely to be skipped. In Town of Palm Beach v. Gradison (Fla. 1974), an advisory planning committee with no binding authority held detailed working meetings that were not open and for which no minutes were taken; the resulting zoning ordinance did not survive. The missing minutes were the defect, not a technicality.
Sources: Amy Smaldone & Mark L.J. Wright, "Local Governments in the U.S.: A Breakdown by Number and Type," Federal Reserve Bank of St. Louis Regional Economist (Mar. 14, 2024), citing the U.S. Census Bureau 2022 Census of Governments · U.S. Census Bureau, 2022 Census of Governments – Organization (released Aug. 24, 2023) · Mass. G.L. c. 30A, § 18 (definitions) and § 22(a) (minutes) · 5 ILCS 120/1.02 and Illinois Attorney General Open Meetings Act guidance · Town of Palm Beach v. Gradison, 296 So. 2d 473 (Fla. May 1, 1974). Statutes are cited as illustrations of a cross-cutting principle, not as a survey — coverage of advisory bodies varies at the edges, so check your own state's act and attorney general guidance. This article is general information, not legal advice.
Ryan Wilson is the founder and CEO of Govably, which builds AI-assisted agenda and minutes software for city, county, and school-district clerks.