HomeMy WebLinkAbout00 - Written CommentsReceived After Agenda Printed
July 9, 2019
Written Comments
July 9, 2019, Council Consent Calendar Comments
The following comments on items on the Newport Beach City Council agenda are submitted by:
Jim Mosher ( ]immosher(c)yahoo.com ), 2210 Private Road, Newport Beach 92660 (949-548-6229)
Item 1. Minutes for the June 25, 2019 City Council Meeting
The passages shown in italics below are from the draft minutes with suggested corrections
indicated in cr°�4, rkeout underline format. The page numbers refer to Volume 64.
Page 130, Item 11: "PUBLIC COMMENTS — none"
Page 130, Item VII: "CLOSED SESSION REPORT— none"
Page 130, Item VI 11: "INVOCATION — Father Michael Laffoon, St. Mark Antiochian Orthodox
Church" [?]
Page 137, Item XVI, paragraph 4, sentence 2: "Public Works Director Webb discussed the
traffic study that was conducted and noted that the community is opposed to installing bike
lanes." [note: the spelling of the preceding speaker's name, "Cari Mock," may or may not be correct]
Page 137, Item XVI, last paragraph: " LindsejF Lindsay Fox discussed traffic issues on Clay
Street, ..."
Page 140, last paragraph before Item 21: "With Mayor Pro Tem O'Neill, Council Member
Duffield; and Council Member Avery voting no, the amended motion carried 4-3."
In addition to these suggested corrections, it might be noted that on page 130, Council member
Duffield commented on efforts to "keep the City's water clean" and at the top of page 131
Council member Brenner is quoted as commenting on efforts of the "Back Bay Conservancy."
In both cases, the minutes reflect what was said, but the latter was most likely a misstatement
(to the best of my knowledge, the organization being referred to calls itself the "Newport Bay
Conservancy") while the former is an example of comments sounding different when quoted out
of context: those present and hearing his full comment understood Council member Duffield
was talking about efforts to "keep the water in the bay clean," but readers of the minutes will
most likely assume he was talking about efforts to "keep the City's drinking water clean."
Such likely misunderstanding of what is written in the minutes is common. For example, in
paragraph 5 on page 136, 1 am quoted as making what could be read as a recommendation that
the City offer $40,000 per year to every business in the City. I hope those reviewing the video
will understand I did not "recommend" such a thing, but, on the contrary, suggested the Council
reflect on the inequity of offering money to some groups and not others, and the obvious
economic impracticality of correcting that unfairness by offering such a large sum to all.
When I encounter such things in the minutes (which is frequently), I rarely suggest a wording
that might be better understood, and have not done so here, in part because I have seen little
chance the suggestions will be adopted.
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 2 of 7
Item 3. Ordinance No. 2019-11: Amending the Newport Beach
Municipal Code to Allow Homeowners' Associations to Opt Out of the
Saturday Construction Noise Restrictions and Project Signage
Requirements
The introduction and adoption of ordinances on the consent calendar, with no debate,
discussion or revision, is always problematic. This ordinance -- prompted by some last minute
direction to staff from Council related to yet another consent calendar ordinance adopted on
June 11, but not yet in effect -- is no exception.
Originally part of something intended to address construction parking, the Saturday noise ban
and construction contact signage requirement was made applicable to a limited older "high
density" portion of the City based largely on a theory that residents in most of the rest of the City
paid dues to Home Owner Associations (HOA's) that already regulated construction activity and
signage in those areas in the way desired by the residents.
That assumption was flawed, and is now compounded by staff's belief, expressed in the report,
that residents who want one part of the original ordinance (say, the signage requirement) but
not the other (say, the Saturday ban) can do so by asking their HOA to opt out of the entire thing
and then enact regulations, binding on the properties within their area, to do whatever part or
parts they want.
The flaw in this is that most of the neighborhood associations in Newport Beach, including most
likely most of those listed in Attachment C to the staff report, and most likely including the
Newport Shores Community Association whose request seems to have prompted this
amendment, are not common interest developments with a governing board having real power
over their members' land use given them by the Davis -Stirling Act.
Simply put, Newport Beach is not Irvine, and even Irvine has areas that are not governed by a
local Davis -Stirling board having power to regulate activities in that area (see their footnote 2).
Before embarking on this attempted "fix," it might have been helpful to contemplate the only
similar opt -out provision I am aware of in the Newport Beach Municipal Code, which was the
2014 gas -powered leaf blower ban (see NBMC Sec. 6.04.055.B.3.a), where the opt -out
capability was indeed limited not only to true "residential common interest developments," but to
ones "responsible for establishing regulations or operating rules controlling the management
and maintenance of their exterior residential environment." The Leaf Blower Opt -out Procedures
were published on the City website, resulting in the patchwork of opt -outs illustrated on the
City's Leaf Blower Exemption Map. My intuition is that having a complex system like that in
which City rules apply to some areas, but not to others, means they are likely to be enforced
nowhere — as in my observation has been the result of the gas -powered leaf blower ban.
By its own description in Attachment B, the Newport Shores Community Association, although
possibly seeing itself as a "community association," appears to be nothing more than a
cooperative group operating a shared one -acre recreational facility, likely with a dues
requirement arising out of shared ownership of the facility. There is a similar group on my street,
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 3 of 7
where we have a shared pool and park. I find it likely the NSCA governing board can regulate
use of the shared lot. But if it's like my street, I find it equally unlikely they have any authority
over what the members can do on their own lots, or have any power to speak for them on things
unrelated to the shared lot. The letter also only says the Directors personally believe their
members would be opposed to the Saturday construction noise ban. It says nothing about
whether they want contact information posted on construction fences. Staff naively suggests the
NSCA Board ask the Council to opt them out of both and then have the NSCA impose the local
rules Newport Shores homeowners want. I doubt they can.
The above said, I have these additional thoughts about the proposed Ordinance No. 2019-11:
1. It's unusual to see an ordinance proposed without displaying a redline version showing
how it changes the existing code text. Perhaps in this case that's because...
2. Ordinance No. 2019-11 confusingly proposes to amend sections of the Municipal Code
which do not technically yet exist.
a. The staff report refers in multiple places to Ordinance No. 2019-9, which was
adopted on June 11, 2019, but the "Whereases" of the proposed new ordinance
make no mention of it.
b. Don't the "Whereases" need to explain this is amending a previously -adopted
ordinance?
3. Given the loose definition of "homeowners' association," Section 1 of the new ordinance
(top of staff report page 3-6) seems to place on the City the job of determining its
"geographical boundaries," which may not be as easy as it seems, since there may be
associations within associations and some of them may be self -declared chamber of
commerce like booster groups with vague boundaries.
a. I am also bothered by the idea that an exhibit adopted by ordinance may later be,
in effect, modified, willy-nilly, by resolution of the Council is strange.
4. Section 2, thankfully, and unlike the Leaf Blower Ordinance, does not give the purported
associations the power to unilaterally opt out of the City's laws, but only allows them to
petition the Council for an opt -out.
a. Even then, given it may be uncertain who the board submitting the letter actually
represents, it is unclear what kind of public noticing and hearing (before the
Council) on the matter staff contemplates — especially problematic since the
Council is supposed to make a finding as to how the opting -out of on area will
affect adjacent areas.
b. And whatever the merits of the organizations, it also bothers me that citizens
have to petition their government through a third party organization. That seems
un-American.
5. Section 3 is possibly the worst. In the previous Ordinance No. 2019-9, the Council
appears to have placed an identical map in two separate and unrelated portions of the
Municipal Code (specifically one copy in Title 10 and another copy in Title 15). The
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 4 of 7
present ordinance reaffirms the map is being added, separately, to the two titles, but
now makes the maps alterable by Council resolution.
a. Section 2 provides a mechanism that is clearly intended for altering the
"Designated High -Density Area" map in Title 10 per Section 1.
b. Section 3 appears to give a procedure for altering the "Designated High -Density
Area" map in Title 15, but it relies on Section 2 (which is part of Title 10).
It is completely unclear if the "resolution" referred to in Section 3 is the same as
the resolution referred to in Section 1, or could be a separate resolution.
d. Staff (in its narrative on page 3-2) implies it believes a single Council resolution
alters both maps.
i. If that is the intent, wouldn't be wise to replace Section 3 with a statement
that for purposes of Title 15, the "Designated High -Density Area" is as
defined in Title 10.
ii. But that inextricably links the "Saturday Construction Noise Ban" with the
"Contact Information on Construction Fences Requirement," and it
sounded from the Council discussion on June 25 that the Council wanted
to be able to apply the two regulations independently of each other. If this
is the intent, it needs to be spelled out more clearly.
Item 8. Resolution No. 2019-70: Establishment of a Design Committee
for the Proposed Newport Beach Library Lecture Hall
Implicit in this hastily -conceived item seems to be the notion that the Board of Library Trustees —
an institution that has existed since 1920 (see Ordinance No. 166) and whose importance, like
that of the Council, was re -ratified (in Section 708) by the people's adoption of a City Charter in
1954/5 — is, at present, incompetent to guide and make recommendations regarding library -
related matters and needs a separately created body to handle aspects of them (much like the
Parks, Beaches and Recreation Commission was at some point deemed, likely without
consulting it, to need a separate, independent Commission to oversee our recreational harbor).
I am concerned:
1. The making of citizen appointments without advertising the opportunity to volunteer to
serve is arguably in violation of state law.
2. The committee is being created at the request of the Mayor, rather than the City's
Library Board.
3. The committee's purpose seems to be to cut the appointed Library Board out of further
involvement in the process.
4. In a reversal of roles, the proposed lecture hall, although described as a "Library Lecture
Hall" and on library grounds, seems to be envisioned more as an amenity for use by the
private Newport Beach Library Foundation than as a library facility.
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 5 of 7
To elaborate:
Impropriety of Appointments without Applications
When the Council agreed to put this item on the agenda, the request (June 25 Item XII, see also
Item 1 of the present agenda, the draft minutes of that meeting, page 131) included waiving
compliance with City Council Policy A-2, presumably regarding the appointment process for
committees. Nothing in the present staff narrative mentions this, but I find such a provision
buried in Exhibit 1 to the proposed resolution, near the bottom of agenda packet page 8-6.
Presumably, the procedure being ignored is the requirement to advertise unscheduled citizen
vacancies on City -created boards, commissions and committees (page 3 of Policy A-2).
I do not believe it is within the Council's power to waive that procedure, nor even if within its
power, do I believe it any more appropriate to name citizen members to this committee without a
formal application process than it would have been to name members without an application
opportunity to the recently created Homeless Task Force.
In the latter case, the Council was pleasantly surprised by the wealth of volunteer community
expertise it had a chance to tap into, and it is not clear why it would want to forgo such a
surprise in the current case.
The chance for local governments to avail themselves of such unexpected talent is, in fact, the
stated premise behind the so-called "Maddy Act" (Cal. Gov. Code Secs. 54970 - 54974).
Indeed, Sec. 54974 requires all California cities, counties, and other local agencies to advertise
every unscheduled opportunity for public members to serve on "any board, commission, or
committee" — and that is a mandate that cannot be waived, even by a charter city like Newport
Beach.
I appreciate that our City Attorney reads Sec. 54974 so narrowly as to make it to apply only to
openings that occur as a result of "resignation, death, [or] termination" (ignoring that it continues
with "or other causes"), but this leads to a doubly absurd result:
If the present vacancies being filled by appointment were not "unscheduled," then they
must have been scheduled — but if so, when and by whom? And if scheduled, why were
they not advertised then?
2. Although by the City Attorney's reasoning none of the present openings need to be
advertised, if any of the pre -selected citizen appointees refuse appointment, then the
identical opening does need to be advertised (because something similar to a
resignation has occurred).
and the law abhors interpretations that lead to absurd results.
Bypassing the Board of Library Trustees
The proposed resolution, worrisomely, says nothing about passing recommendations through
the BLT. Apparently all matters having to do with the Lecture Hall are being taken out of their
hands.
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 6 of 7
Indeed, under the proposed scheme, not only will the BLT have no role in making
recommendations about the design (or siting?) of the Lecture Hall -- aside from its one vote out
of five on the LHDC -- but it won't even be allowed to choose that one representative on the
LHDC. The Mayor will make the choice for them.
Role Reversal
The staff report opens with a statement that "The City Library Department runs and manages
many popular programs and community events, including speaker forums." In fact, the vast
majority of the "speaker forums" at the Central Library are presented not by the Library
Department, but by the Newport Beach Library Foundation as completely independent
functions, with both content and presentation determined solely by the latter and its various
private committees.
Prior to posting an amended version, the staff report also telling opened by saying City staff was
working with the Foundation, rather than the Board of Library Trustees, on the Lecture Hall
project.
The Foundation was established in 1989 to assist in building, and creating an endowment for,
the expanded Central Library by supplementing the money raised by the existing Friends of the
Library organization. It was re -incorporated in 2000. There is also a Cooperating Agreement
with the BLT from that same year. The Foundation's sole stated purpose is to serve as a conduit
for contributions to fuel City programs and capital needs. It was never intended to provide
independent programming in competition with or as a replacement for the functions the money
was supposedly being raised to fund.
Disturbingly, at the June 25, 2019, Council meeting (where Mayor Dixon presented her request
to create the LHDC) the Council also made its annual appointments to the City's boards and
commissions, and, as part of that, Council member Brenner mentioned that in evaluating
candidates to replace the termed -out Ms. Johnson -Tucker (who is proposed to go onto the
LHDC) on the Board of Library Trustees it was important to find someone with fundraising
experience, as that would be needed to support the Lecture Hall process.
This would appear to be in conflict with former Council Policy A-5, now part of A-2, which
memorialized the division of labor between outside foundations and the City's boards by
prohibiting the city's boards, commissions and committees from engaging in fundraising. As Ms.
Johnson -Tucker herself said when on the BLT, administration and fundraising "require different
skillsets."
But Policy A-2 does say "An exception to this policy may be granted by the City Council on a per
project basis when circumstances justify the exception."
So it looks now like the Council sees such a justification, and expects the BLT to drive
fundraising to enhance the Foundation.
July 9, 2019, City Council Consent Calendar Comments - Jim Mosher Page 7 of 7
Additional Concerns
Beyond the above concerns, Exhibit 1 describes the committee reviewing and making
recommendations regarding the responses to a "Request for Proposals." It does not explain
who, if anyone other than staff, will participate in preparing the RFP or if there might be more
than one RFP and if so, who will be involved with them.
And although called a "Design Committee," the Purpose & Responsibilities section of Exhibit 1
ends (page 8-7) with a catch-all Provision E that could be read as empowering the LDHC, at its
own discretion, to take over all matters related to the Lecture Hall project, including possibly its
future use, even more completely bypassing the BLT — an impression enhanced by the thought
that the LDHC will continue to exist through the "opening" of the new facility.
Finally, Exhibit 1 empowers the Mayor to appoint the Chair and Vice Chair of the LDHC. It would
have seemed a courtesy to the remainder of the Council to have revealed who those will be if
the proposed list of members is confirmed.
Item 12. Amendment No. One with Hardy & Harper, Inc. for On -Call
Asphalt Repair Services
The staff report seems a bit confusing and incomplete.
The original request to Council (Item 6 on the July 11, 2017, consent calendar) involved two
asphalt vendors and resulted in two three-year contracts (C-8508-1 with Hardy & Harper and C-
8509-1 with NPG). Although the 2017 staff report did, at the very end of the discussion,
mention $200,000 per year for each vendor, the action requested of and approved by the
Council was clearly indicated as 1200,000 per vendor," presumably for the full three-year term
as indicated in the contracts.
Since a contract amendment has not previously been made, it appears that after two years the
originally approved $200,000 has not been entirely spent, and if staff is now anticipating a
$400,000 increase will be sufficient to cover three additional years of contracting with Hardy &
Harper (in addition to the dollar increase, staff is asking to extend the original term by two
years), it sounds like the actual spending has been, and is expected to remain, more in the
range of $100,000 per year.
It would have been helpful to indicate what the actual yearly expenditures on asphalt repair are,
and what the status of the separate on-call contract with NPG, Inc., is: that is, why does it, too,
not need amendment?