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HomeMy WebLinkAbout24 - Response to Grand Jury Report: "Welcome to the Neighborhood"Q �EwPpRT CITY OF s NEWPORT BEACH `q44:09 City Council Staff Report August 22, 2023 Agenda Item No. 24 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Seimone Jurjis, Community Development Director - 949-644-3232, sjurjis@newportbeachca.gov PREPARED BY: Jaime Murillo, Planning Manager, jmurillo@newportbeachca.gov PHONE: 949-644-3209 TITLE: Response to Grand Jury Report: "Welcome to the Neighborhood" ABSTRACT - For the City Council's consideration is approval of a response letter to the 2022-2023 Orange County Grand Jury Report, "Welcome to the Neighborhood- Are cities responsibly managing the integration of group homes?" pursuant to Penal Code Section 933.05(a) and (b). The City of Newport Beach (City) is required to comment on the findings and recommendations pertaining to matters under the City's control no later than September 8, 2023. RECOMMENDATIONS: a) Determine this action is exempt from the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) and 15060(c)(3) of the CEQA Guidelines because this action will not result in a physical change to the environment, directly or indirectly; and b) Approve the City's response to the 2022-2023 Orange County Grand Jury Report, "Welcome to the Neighborhood- Are cities responsibly managing the integration of group homes?" and authorize the Mayor to submit it to the Presiding Judge of the Superior Court pursuant to Penal Code Section 933.05 (a) and (b). DISCUSSION: The 2022-2023 Orange County Grand Jury report, "Welcome to the Neighborhood- Are cities responsibly managing the integration of group homes?" (Grand Jury Report) was released to the public on June 12, 2023. The Grand Jury Report serves as an investigation into the impact group homes have on neighborhoods when there is an over -concentration of these homes in a particular residential area. The Grand Jury Report identifies challenges introduced by pressure from residents, group home operators and government agencies, and provides recommendations to alleviate these challenges. The Grand Jury Report highlights the City of Newport Beach as a lead city in tackling the issue of group homes in 2008 with the adoption of the first comprehensive ordinance in Orange County. The Grand Jury Report also correctly identifies several constraints and challenges the City faces, such as litigation, tracking of unlicensed facilities, and State actions that weaken local control and enforcement. 24-1 Response to Grand Jury Report: "Welcome to the Neighborhood" August 22, 2023 Page 2 The City was also highlighted as a positive example of how cities can better inform community members about the challenges faced in regulating group homes, including the use of town hall meetings. Attachment A is a copy of the Grand Jury Report which includes findings and recommendations that are required to be addressed by each city pursuant to Penal Code Section 933.05(a) and (b). Staff has drafted responses to the Grand Jury Report which must be submitted to the Presiding Judge of the Superior Court with an informational copy sent to the Board of Supervisors within 90 days after the Grand Jury publishes its report. In accordance with Penal Code Section 933.05, the responses in Attachment B address the findings and recommendations of the Grand Jury Report. FISCAL IMPACT: There is no fiscal impact related to this item. ENVIRONMENTAL REVIEW: Staff recommends the City Council find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. NOTICING: The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the City Council considers the item). ATTACHMENTS: Attachment A — Orange County Grand Jury Report Attachment B — City of Newport Beach Draft Response 24-2 Attachment A Orange County Grand Jury Report 24-3 .•l } ]may ,dF � ! �t,'• F' l '4 f :,�,� i . � ..go- I.+ • � � i � - . A:'tip• .� �f°. - Yf; i+5,, T jj y '�$Y`Y"$$$"` f r• .'� L 7' /�����,�51 .. '4y,� �p5C + 1... 17a ,l 4 R ' r , yl l{ F+ I5J {yy�j I tip'`' .' ill 4yf' 10 ✓LC�—•. •u6T.Al"A}•�{'•iV.'i%t/+. ..Lr:tlry a�+ii ��� J1i5�+�.5%SY3 �J}�9Ii�F�'`'i{:ttT�y�� �;....�•.^�'.'.it'.1. i_Y._.e:1v..�.., 16'u�- �__.__ Welcome to the Neighborhood Are cities responsibly managing the integration of group homes? �.L ., O U J r9'IF0Yk County of Orange Grand Jury 2022-2023 TABLE OF CONTENTS SUMMARY....................................................................................................................................... 3 BACKGROUND................................................................................................................................. 4 REASONFOR STUDY........................................................................................................................ 6 METHODOF STUDY......................................................................................................................... 7 INVESTIGATION AND ANALYSIS...................................................................................................... 7 OCGroup Home Density............................................................................................................. 8 TrackingChallenges.................................................................................................................. 10 CommonNuisances.................................................................................................................. 11 LeadCities................................................................................................................................. 12 Cities Are Standing Alone.......................................................................................................... 12 Fearof Litigation Costs............................................................................................................. 13 StateActions............................................................................................................................. 17 HousingElement....................................................................................................................... 18 Educatingthe Public................................................................................................................. 19 How Has This Issue Evolved?.................................................................................................... 23 FINDINGS....................................................................................................................................... 24 RECOMMENDATIONS................................................................................................................... 25 RESPONSES.................................................................................................................................... 25 90 Day Response Required....................................................................................................... 27 GLOSSARY...................................................................................................................................... 29 BIBLIOGRAPHY.............................................................................................................................. 34 NOTICE.......................................................................................................................................... 40 ENDNOTES.................................................................................................................................... 40 24-5 WELCOME TO THE NEIGHBORHOOD SUMMARY Group homes are an important component in the healthcare and/or recovery of many people. These homes provide, among other things, Substance Recovery, Hospice Care, Residential Care for the Elderly, and Sober Living. When group homes are operated for the well-being of their residents and with respect for their neighbors, they can be an asset to their host community. However, they can occasionally become disruptive and the motivation for nuisance calls to local code enforcement. In extreme cases, the "curbing" of residents can contribute to the homeless population. Negative interactions with disruptive group homes often lead to neighborhood opposition and anger towards city officials. How cities respond to the anger of their constituents impacts their ability to successfully integrate group homes. Residents are more likely to respond positively when cities offer townhall style meetings with police, fire, code enforcement, legal, and subject matter expert involvement, especially where the subject is discussed objectively, and public input is encouraged and respected. Issues and concerns neighborhood residents have with group homes stem primarily from an over -concentration of homes in residential areas. Multiple cities in Orange County have attempted to manage integration of group homes into neighborhoods by enacting ordinances that include setting a minimum distance between group homes to avoid the problems associated with over -concentration. Most cities with such ordinances have not enforced them due to the fear of incurring litigation costs. The Grand Jury reviewed the challenges of successfully integrating group homes into neighborhoods, including pressures exerted on Orange County cities by residents, group home operators, and the State of California. The State of California has recently joined the group home debate, has altered the conversation, and raised the stakes. The State wields a large club with its power of approval of the required Housing Element. The California Housing and Community Development Department (HCD) is withholding approval for cities that have ordinances attempting to place limits or impose oversight on group homes. Cities are then vulnerable to a loss of control over zoning and permitting, as well as loss of State and regional funding. Some cities have decided to push back on the pressures put on them from HCD and the fight has been carried out on an individual city basis. The Orange County Grand Jury recommends that the County of Orange and cities join forces to create ordinances, pool resources for defense of lawsuits, and work together to generate awareness among legislators to improve regulations and management standards to ensure health and safety for group home residents. ORANGE COUNTY GRAND JURY 2022 12023 Page 3 of 42 24-6 WELCOME TO THE NEIGHBORHOOD BACKGROUND Orange County has 42 miles of beautiful coastline, three harbors, and 25 urban and wilderness parks - including 230 miles of riding and hiking trails. Orange County also has the dubious honor of having more than its share of our State's total number of group recovery and sober living residences. Frequently referred to as "The Rehab Riviera", several cities in Orange County have been dealing with pockets of over - concentration of these types of group homes. This has posed challenges for the residents in whose neighborhoods they are located, as well as the occupants of the recovery and sober living homes. Many of the homes in question are privately owned, unlicensed, unsupervised, and a challenge to monitor and regulate. When a neighborhood has multiple group homes, it becomes a more institutional environment; this alters the character of the neighborhood and defeats the purpose of the "integration" of people who are recovering. The Orange County coast is a magnet for sober living homes To address these shortcomings, multiple cities, and the County, on behalf of unincorporated areas, have enacted ordinances that manage the permitting and tracking of group homes. Several significant pieces of legislation have played a part in the expansion of group homes. These include California's Lanterman Mental Retardation Act (1988), the Federal Fair Housing Amendments Act of 1988, the California Community Care Facilities Act, and California's Substance Abuse and Crime Prevention Act of 2000 (Proposition 36). The resulting deinstitutionalization has had a positive effect on the lives of many people but has created a challenge for cities as they work towards the responsible integration of the group living arrangements necessary to accommodate the impacted population.' ORANGE COUNTY GRAND JURY 2022 12023 Page 4 of 42 24-7 WELCOME TO THE NEIGHBORHOOD Since deinstitutionalization, the State of California has resisted appeals from local cities to pass permitting laws, distancing requirements, or any type of regulation at all. There is a misconception that these regulatory ordinances are intended to discriminate against people who are disabled due to alcohol and drug addiction, and the State of California has cited this misconception as the guiding principle for its dogged challenge of most attempts by cities to manage the responsible integration of group homes into residential neighborhoods. Rather, such city ordinances are intended to protect those people who suffer from alcohol and drug addiction, as well as the neighborhoods where group homes are located. Licensed residential rehab programs are subject to the same local laws as single-family homes, and no more. State law imposes fewer restrictions on licensed rehab programs than other licensed group homes. The Community Care Facilities Act, from which alcohol and drug rehab facilities are exempt, imposes restrictions that protect the character of residential neighborhoods. Under this act, cities receive written notice of a proposed facility, and any city or county may request denial of the license based on overconcentration of residential care facilities. While alcohol and drug programs that provide 24-hour residential non -medical services to adults recovering from drug or alcohol abuse must obtain a State license, they cannot be regulated any differently from a single-family home if they serve six or fewer people. California Health & Safety Code Sections 1520.5 and 1267.9 state it is a policy of the State to prevent overconcentration of residential facilities that impair the integrity of residential neighborhoods. Section 1520.5 states that the department shall deny an application for a new residential facility license if the department determines the facilities location is proximate to an existing residential facility therefore resulting in overconcentration. The statute recognized the need for a balanced policy to prevent overconcentration of residential care facilities which indicates an awareness and understanding of the impact of overconcentration on the integrity of residential neighborhoods. The statute defines overconcentration as less than 300 feet for some types of group homes and up to 1000 feet for others. At the time the statute was enacted it was specific only to certain types of group homes. However, the recent emphasis on providing more housing in California has eroded the intent of this act. Federal and State fair housing laws protect people with disabilities from housing discrimination. Recovering alcoholics and drug addicts are disabled for purposes of anti- discrimination laws. When people in recovery live together in a "sober living" home, cities cannot discriminate based on such disabilities, therefore an ordinance cannot treat sober living homes differently than other similar uses in single-family residential zones. Sober living homes are not required to be licensed and are not limited to six or fewer residents. Because no treatment is provided in these substance -free, mutually supportive living environments, no license is required. The limitation of most other group ORANGE COUNTY GRAND JURY 2022 12023 Page 5 of 42 24-8 WELCOME TO THE NEIGHBORHOOD homes to six residents is part of the State statute; however, confusion arises because the statute does not apply to sober living homes. There is only so much a city can do to respond to the complaints of its residents when dealing with an overconcentration of group homes in a neighborhood. It is important for city residents to be educated on the barriers faced by cities, and to work with their city to overcome these barriers. Current laws do not adequately address the need to manage the integration of group homes into neighborhoods. Courts should not be where the solutions are found. REASON FOR STUDY Many cities within Orange County have neighborhoods with a dense concentration of group recovery and sober living residences. In most circumstances, cities do not know where these group homes are located unless the homes generate a backlash from neighbors due to various types of disturbances. The Grand Jury examined how Orange County cities are managing the distancing of all types of group homes, and the impact group homes have on neighborhoods and group home residents when the homes are in close proximity to one another. Group homes, most often Recovery and Sober Living homes, and the nuisances that are commonly associated with them, are not new to Orange County. Neighborhood complaints, concerns from individuals living in or related to residents of group homes, the litigious nature of the relationship between cities and group home operators, and abuse of the healthcare system have been in play in Orange County for well over a decade. The Grand Jury began this study by looking at how cities are managing the influx and locations of group homes and identifying best practices where they are found. The working premise was that each city is responsible for the integration of group homes, which would serve to protect the residents of group homes while maintaining the existing neighborhood atmosphere. Has there been success addressing the issues associated with group homes and what does that look like? Are cities going it alone or are there county -wide efforts? Has there been progress made in this area? The Grand Jury approached the topic of group home integration seeking answers to these questions with the expectation that there were some systems in place resulting in the successful integration of group homes. The investigation took a winding road which revealed that, despite countless attempts at change, many of the problems that surfaced over a decade ago are still present. The Grand Jury found that successfully implemented solutions have become even more impactful in light of the State of California's heavy-handed entry into the debate. ORANGE COUNTY GRAND JURY 2022 1 2023 Page 6 of 42 24-9 WELCOME TO THE NEIGHBORHOOD METHOD OF STUDY The Grand Jury has evaluated official documents, examined news articles, visited multiple recovery/sober living websites, and assessed secondary sources. The Grand Jury reviewed numerous documents, including the 2022 State of California's Group Home Technical Advisory2 and the 1990 State of California Health and Safety Code.3 To better understand the impact of density, jurors attended townhall and city council meetings virtually, through recordings, and visited neighborhoods in several cities where there is a heavy concentration of group homes. The Grand Jury interviewed numerous subject matter experts, city managers, County and city officials, legislators, city attorneys, group home operators, and legal and real estate professionals. It also examined local, state, and national media reports and opinion pieces regarding group recovery and sober living residences. The Findings and Recommendations herein are based on this work. INVESTIGATION AND ANALYSIS Orange County has some of the heaviest concentrations of group homes and sober living residences in the nation.4 The densities are more than the local population can bear and residents believe the influx of the group home residents seriously impacts their neighborhoods. Similarly, group home and sober living industry experts cite negative impacts on the group home residents themselves. Operators can open a group home where they desire, without having a license or State - endorsed certification, and they can open as many group homes as they desire regardless of local need. Because regulation is slack, cities are challenged to track and regulate the density without any guidance or support from the State. Adding to these concerns is a recent State of California memorandum titled "Group Home Technical Advisory" that characterizes any attempts to regulate the homes as discriminatory.5 It seems that method of thinking has no positive effect on how the homes are run or on how the vulnerable residents in these homes are treated, and quite possibly has the opposite effect. ORANGE COUNTY GRAND JURY 2022 12023 Page 7 of 42 24-10 WELCOME TO THE NEIGHBORHOOD OC Group Home Density Reportedly, Orange County has more than its share of group homes in California, and the country for that matter, specific to housing individuals in need of Recovery/Sober Living Homes.6 There are no existing requirements for sober living homes with six or fewer residents to identify or register themselves as such. It is estimated that up to 36% of houses required to be licensed (those providing services) by the State of California as group homes for six or fewer residents are located in Orange County. In addition, there are hundreds of group homes not requiring licensing that exist in Orange County neighborhoods. This lack of identification makes it extremely difficult to estimate the total number of sober living homes in our communities.' As documented in numerous city council and townhall meetings, residents and activists have raised concerns about over -saturation and common nuisances to local community governing bodies (see Common Nuisances section). In many cases, these are neighborhoods in which multiple group homes are in close proximity (for example three in one cul-de-sac) or individual homes are run with little to no on -site supervision. Neighborhoods are losing their original character and familial aspect, with some becoming increasingly institutional and others experiencing more of a "frat house" feel. "Residents of these homes are moving in and out at an alarming, transitory rate" Residents of these homes are moving in and out at an alarming, transitory rate. Neighbors describe some of these group homes as taking no responsibility for the actions of their inhabitants. Rules and responsibilities are either not imposed or not enforced by the group home operators. The complaints are predominantly related to non -regulated group homes. Over the last several years, multiple cities in Orange County have sought to find a solution to alleviate these concerns. Several have performed due diligence to ensure that any action taken will provide for neighborhoods to remain neighborhoods, and that both the disabled and the recovering addicts needing to live in these types of group homes are in fact living in a normalized residential environment that provides the best opportunity to be successful in their recovery. ORANGE COUNTY GRAND JURY 2022 12023 Page 8 of 42 24-11 WELCOME TO THE NEIGHBORHOOD This is not simply a "Not In My Backyard" (NIMBY) issue or reaction as evidenced by the large number of homes that receive few or no complaints. The need for well -run Recovery/Sober Living Homes is not in dispute. Concerns arise when these homes are poorly run and/or when multiple homes are in close proximity, contributing to the problem of over -concentration. These two circumstances cause changes in the local neighborhood, and it is questionable whether they are aiding the very residents that they are meant to be assisting and whether residents of these homes are integrating into a normalized environment. To that end, various cities have introduced ordinances toward resolving the problem. Some of these include distancing requirements between group homes ranging from 300 to 1000 feet. Some ordinances require group homes to register or self -identify as such. California Health & Safety Code Section 1267.9 provides specific requirements for distancing of most types of group homes settings.$ These requirements are similar to the local city ordinances in that they provide certain spacing restrictions of between 300 and1000 feet. Sober Living Homes, however, are excluded from any distancing requirement by the State. Los Padres National Forest 3 Sant, "IrbaraIs 10, •• ■ y'1 Victorville 1 rrarita ■ ! jNfimpr ri ■ Angeles National Forest u! :.-.�, fir• ' - " . Santa r: Long Amboy ■ ■ Si San • ■ = W jagdLPQ is Forest •• •m Palm Lorin s Joshua Tree •+,.• ; National Park v • •Indio Fdlm Deser•�'■ ••. L Ca ■ ■ ■'■ "■..,- Anza-Borrego � 'ondido ■ Desert '� • State Park Go gle My Maps ..■olk� � ■ ■ '■ ■■ ■ MIIII Sal"f■iii Cleveland El �,7,ri r,,tinnal Fnrcct Keyboard shortcuts Points show the primary addresses ofall non -medical alcoholism and drugabuse recoveryor treatment facilities licensed and/or certified by the California Department of Health Care Services as of May 4, 2017 (Map by Ian Wheeler, Orange CountyRegister/SCNG) The State imposes licensing requirements on most types of group homes and provides for oversight by one or more State or County agency. Sober Living Homes with six or fewer residents are not required to be licensed by the State and have no regulatory ORANGE COUNTY GRAND JURY 2022 12023 Page 9 of 42 24-12 WELCOME TO THE NEIGHBORHOOD oversight. These two factors alone allow anyone to set up, open, and advertise this type of group home anywhere in California. Orange County seems to be the favored location, yet has no say in the siting or quantity of group homes in our residential neighborhoods. Tracking Challenges Just where are these sober living homes? All over. How do we know? We actually don't. There are few local ordinances requiring the registration, licensing, or declaration of any type of unlicensed sober living or recovery residence that has been established in a neighborhood. There are no widely adopted methods to track or monitor any aspect of such dwellings — their location, number of people residing in them, on -site management, or their ownership. The Grand Jury's research found that most sober living homes are not required by law to have any kind of State license. Some cities have enacted ordinances that require a permit or registration. When a sober living establishment is registered and a complaint is received, the complaint may be recorded and could be tracked, at least for the location of that specific home. WHERE THE REHABS ARE California has 1.854 reflab facilities. and mere than Ka If (1,117) aie in Los Angeles. San Bernardino. Orange and Riverside counties. The map below shows the coneentratIons of these centers and the ratio of rehabs per resident in some of our Coles. • • M # • LOS A€dGELES COLWY Lang Beacp 1121,935 f221 1 1{00 Rehabsger resrden- (00) Total rehabs Rehab center Snjee: CWorno 1 . ° iLe t nl Pub11c Hearth at ■ $AN BERNARDINO COUNTY • M a¢ iMpaes y, (25) r # 71 • s MINTY L. na Self 5,-}n Juan Capistrorw 111.163 11L286 (201 x�(29) s 3e'necula 115.932 (1e1 Is do Palm Springs �'ilS.df}T (t>t} AFF WERTZEN.SC" Except for the few cities with ordinances regulating sober living homes and the few homes that applied for registration or received ministerial permits, accurate tracking and monitoring remains challenging. Tracking is attainable if cities' code and law enforcement establish and actively utilize a searchable database that includes ORANGE COUNTY GRAND JURY 2022 12023 Page 10 of 42 24-13 WELCOME TO THE NEIGHBORHOOD information about police and fire calls, nuisance complaints or code infractions, and identification of type of establishment. The use of this information can help identify the location and density of group homes. Common Nuisances Residents living in cities with neighborhoods having a significant number of recovery and sober living homes complain that the proliferation of these group homes in recent years has become unmanageable, and that overconcentration is impacting the quality of life for everyone. For years, many citizens living in neighborhoods with an unrestrained growth of sober living homes have been voicing their concerns and frustrations over the lack of protection their communities are given. While many of these group homes adopt rules and regulations and attempt to be good neighbors, a citizen's primary method for reporting concerns about a disruptive home is initiating a nuisance complaint to their local law enforcement. Common Nuisances Secondhand Smoking Vomiting in Driveways Higher Noise Levels Curbing �i I Increased Foot Traffic n Box Truckr A Deliveries `u-01 Increased Street Parking 5ubstantial Rubbish @ Front Lawns Relapsing in Public Increased Traffic The outcry is that unregulated sober living residences make for bad neighbors. Sober living homes are not always bad neighbors, but when they are concentrated in a small geographic area or neighborhood, the common nuisances can become more visible and disruptive. Ultimately, this raises concerns about the potential or actual diminished character of the neighborhood. ORANGE COUNTY GRAND JURY 2022 12023 Page 11 of 42 24-14 WELCOME TO THE NEIGHBORHOOD Lead Cities Although the City of Costa Mesa has been front and center in the legal fights related to group homes, it was Newport Beach that first stepped into the arena in 2008. Three companies sued the City over an ordinance that was approved by the City Council in 2008 that regulated group homes for recovering addicts.9 Pacific Shores Properties, Newport Coast Recovery, and Yellowstone Women's First Step House sued Newport Beach for a total of $5.24 million. Still in place today, this ordinance was the first of its kind in Orange County and it established quiet hours, parking and smoking areas, and van routes. It also required the City's approval for new unlicensed homes for recovering addicts in certain neighborhoods. In 2015, the City reached the end of its seven-year legal battle over sober -living homes with a settlement agreement.10 11 According to the Orange County Register, which cites its own archives, Newport Beach spent at least four million dollars in legal costs on the cases. In 2008, there were 81 facilities and 614 total beds identified in Newport Beach. In 2021, there were a known 30 facilities with 210 total beds. Where did all those facilities and beds go?12 Perhaps to the City of Costa Mesa. In 2015, the City of Costa Mesa enacted their own ordinance (amended in 2017) after seeing a sharp increase in the number of sober living homes followed by a steep increase in the number of community complaints. On the heels of the ordinance came the legal challenges, and Costa Mesa prevailed in all challenges until January 2023 when two sober living homes, embroiled in litigation against the city, were handed a legal victory in federal court. The earlier dismissal was reversed and remanded by the Ninth Circuit Court of Appeals which ruled that asking operators of sober living facilities for proof of disability violates federal law barring discrimination against those with disabilities and bars discrimination in housing. "The well -funded operators are supported by industry organizations and associations in their lawsuits..." As the legal battle waged on, other local governments explored, advanced, or enacted regulation of sober living homes, including the County of Orange (2015), and Cities of Laguna Hills (2015), San Clemente (2016), Laguna Niguel (2016), San Juan Capistrano (2016), Anaheim (2020), and Huntington Beach (2020). Most of these entities, perhaps all, have chosen not to enforce their ordinances out of concern of potential litigation, and are waiting for Costa Mesa's litigation to conclude. Cities Are Standing Alone Multiple cities in the County have executed ordinances to regulate unlicensed group homes. With the exception of the newly formed South Orange County Sober Living and ORANGE COUNTY GRAND JURY 2022 12023 Page 12 of 42 24-15 WELCOME TO THE NEIGHBORHOOD Recovery Task Force, cities have not collaborated on solutions to shared and common problems. This has been done on an individual basis, with little collaboration among cities. Prior to drafting an ordinance, some cities study the details and effectiveness of other cities' actions, particularly the City of Costa Mesa's ordinance, and use that as a template to draft their own.13 Once enacted, few of the ordinances are being enforced. This lack of enforcement is due to a small number of very specific impediments and concerns. These include: • Fear of litigation costs due to lawsuits filed by group home operators against cities that have enforced ordinances. (The City of Costa Mesa has reportedly incurred over ten million dollars in legal fees in relation to group home litigation.) Fear of the State of California withholding approval of the Housing Element for cities that have ordinances related to the management of group homes, resulting in the potential loss of state funds and local zoning control. • Lack of enforcement resources. Most cities do not have the staff resources to enforce these ordinances. While individual cities take a wait -and -see approach to follow the progress of other cities that are standing up to the State, little progress is being made. The cities and County of Orange would benefit by working in partnership with one another to garner resources and create a coalition to promote change. While the newly constituted South Orange County Sober Living and Recovery Task Force is a good start, and the first tangible recognition of the need to work together, the Grand Jury recommends a countywide cooperative taskforce. Orange County's cities and unincorporated areas are demographically diverse.The active sharing of ideas, experiences, and information will be valuable to the overall process of developing a worthwhile model ordinance and plan for moving forward in the efforts to protect both the individual characteristics of Orange County neighborhoods, and all individuals living in those neighborhoods. Fear of Litigation Costs Cities are concerned about the high cost of litigation and the time required to defend ordinances regulating group homes. Private entities have challenged ordinances and in some cases won, and in other cases continued to pursue lawsuits in spite of opposition. In one case, the California Department of Housing and Community Development (HCD) requested that the California Department of Justice file a "friend of the court" application to intervene on behalf the litigant in its case against the City. ORANGE COUNTY GRAND JURY 2022 1 2023 Page 13 of 42 24-16 WELCOME TO THE NEIGHBORHOOD million Newport Beach Two examples of cities being involved in lengthy and costly lawsuits include Newport Beach and Costa Mesa. In 2007, Newport Beach had numerous sober living homes and was facing increasing pressure by residents to regulate them. In January 2008, Newport Beach passed an ordinance regulating sober living homes. The ordinance was carefully crafted to comply with State and federal law.15 By November 2008, several legal actions occurred. These included: 1. A lawsuit from a residents' group (the "Concerned Citizens of Newport Beach" or CCNB) arguing that the City did not go far enough in enacting Ordinance 2008- 05. CCNB also sued multiple operators and asked for $250 million in damages from the City; 2. Two group home operators (Pacific Shores Recovery and Sober Living by the Sea) filed complaints with the US Department of Housing and Urban Development (HUD) alleging that the City's ordinance and its practices have discriminated against disabled persons entitled to fair housing; 3. Multiple lawsuits were filed by Sober Living By the Sea (SLBTS) alleging that the City's group residential uses ordinance was facially discriminatory against persons in recovery. The City reached an agreement with SLBTS; 4. The City filed lawsuits against Morningside Recovery and Pacific Shores Recovery, alleging that some of their operations opened illegally during a short- term temporary moratorium against the establishment of new group residential uses. Pacific Shores Recovery has in turn alleged that the City's group ORANGE COUNTY GRAND JURY 2022 1 2023 Page 14 of 42 24-17 WELCOME TO THE NEIGHBORHOOD U residential uses ordinance was facially discriminatory against persons in recovery; 5. A cross -complaint by the City against Sober Living By The Sea and other operators that consolidated certain lawsuits in U.S. District Court. ^,f Chairs are packed during a discussion on sober -living homes in San Clemente in 2016. (Photo by Matt Masin, Orange County Register, SCNG) Subsequently, in 2009, three companies sued the City of Newport Beach over the ordinance, claiming it violated anti -discrimination and fair housing laws because individuals recovering from an addiction are a protected group. A federal judge ruled in favor of the City in 2011. The companies appealed the case and it went to the 9th Circuit Court of Appeals, where the Court's majority sided with the group homes, saying there was enough evidence to argue discrimination. The Court pointed to comments made during the 2008 hearing, which implied that the City Council was targeting recovery group homes. The City of Newport Beach asked the U.S. Supreme Court to review the case in 2014, but the Court declined. The City settled with the group homes for $5.25 million in 2015. The City's estimated legal costs exceeded four million dollars,16 for a total cost close to ten million dollars. The City of Costa Mesa waged a fierce and costly legal battle to regulate sober living homes for over five years. As noted in the section regarding the State's actions and attitude, Costa Mesa fashioned an ordinance within the limits of State and federal laws ORANGE COUNTY GRAND JURY 2022 1 2023 Page 15 of 42 24-18 WELCOME TO THE NEIGHBORHOOD in 2014.17 The City ultimately spent over seven million dollars in litigation, and prevailed in State and federal courts; however, in January 2023, a federal appellate court reversed and remanded the district court's 2020 ruling. Costa Mesa Ordinance 15-11 sets limited standards for three items that address important societal issues, none of which are discriminatory in nature: 1. Spacing (650 feet apart) 2. Background screening of the house manager 3. Process for evicting residents Spacing between group homes maintains the purpose of the facility and residential character of the neighborhood. Screening protects the residents of the facility. Through interviewees, the Grand Jury learned of group home managers with criminal backgrounds and who are themselves currently substance abusers. Standards for evictions are needed. Through interviews and newspaper articles, the Grand Jury learned of the practice of "curbing," putting residents out on the curb when their source of payment runs out or when they are in violation of house rules. This practice is believed to contribute to homelessness in Orange County. Costa Mesa's ordinance serves an important purpose, but the ordinance is still in litigation after several years and at an estimated cost of more than ten million dollars.18 Other Cities in California and Orange County are similarly facing lawsuits and costs associated with group home and sober living ordinances. Cities could pool resources to mitigate litigation cost concerns. A coalition of cities to spread costs is highly recommended. The Grand Jury learned that the lawsuits brought against cities are supported and enabled by an extremely profitable industry. According to John LaRosa at MarketResearch.com on February 5, 2020,19 the group home market is 42 billion dollars per year. Mr. LaRosa also noted that the industry needed to be cleaned up as many of the operators engaged in overbilling, patient brokering, and deceptive marketing. The well -funded operators are supported by industry organizations and associations in their lawsuits. Industry organizations include large groups such as the California Consortium of Addiction Programs and Professionals, Behavioral Health Associates, and National Sober Living Associates. The websites of any of these organizations and several others can be viewed to see the type of support often provided. The organizations not only provide support for lawsuits, but also assist in lobbying State and federal legislators. Many group home operators do not want any type of regulation, as evidenced by the Costa Mesa and Newport lawsuits, though the Grand Jury found some operators who welcome additional regulation to protect the industry from bad operators. In summary, the industry represents a formidable foe in lawsuits due to funding and industry associations. ORANGE COUNTY GRAND JURY 2022 12023 Page 16 of 42 24-19 WELCOME TO THE NEIGHBORHOOD State Actions Zoning ordinances are the primary control local governments have over city land use. The State of California has challenged the validity of group home ordinances, thereby inhibiting local governments in addressing group homes through zoning ordinances. If challenged, defense of the ordinances is costly and the alternative is to repeal them, a process that can be politically charged. When Costa Mesa originally prevailed in the lawsuits filed against their 2014 sober living ordinance, the Cities of Encinitas, Huntington Beach, Anaheim and the County of Orange adopted similar ordinances for sober living facilities. In May 2021, the California Department of Housing and Community Development (HCD) sent a letter to the City of Encinitas stating its ordinance was in violation of statutory prohibitions on discrimination in land use. HCD said the city must take immediate steps to repeal the ordinance. HCD's letter to the City of Encinitas noted "The City appears to take significant comfort from certain court opinions, several unpublished, appearing to reject specific, largely different and distinguishable challenges to a different group home ordinance in Costa Mesa, which were brought by private parties rather than the State of California. Those decisions are neither on point nor binding here. "This statement is misleading to the general public because it downplays judicial rulings favoring Costa Mesa's ordinance. In May of 2021, HCD sent a "Letter of Technical Assistance" to the City of Anaheim in which they discuss Anaheim's land use regulations. One of the items discussed was a phone call they had with city staff to discuss concerns with the proposed Zoning Code Amendment for group homes. HCD's concern was that the ordinance "potentially conflict(s) with statutory prohibitions on discrimination in land use". Also in May of 2021, HCD sent a "Notice of Violation: City of Anaheim Notice of Violations of Housing Element Law and Anti -Discrimination in Land Use" regarding the denial of a conditional use permit for transitional housing. The California Department of Justice (DOJ) subsequently joined a civil lawsuit regarding the same action. HCD believes the City has failed to implement goals, policies, and program actions included in the housing element and failed to act consistent with Government Code requirements in applying standards to the approval of the Project. On December 21, 2022, HCD issued a document titled Group Home Technical Advisory.20 The executive summary includes the following: "In recent years, some local governments have amended their zoning ordinances to add new regulations for group homes, particularly for recovery residences - group homes that provide housing for persons recovering from alcoholism or drug addiction. These amendments have raised concerns that local governments are not complying with their affirmative obligations under state planning and ORANGE COUNTY GRAND JURY 2022 12023 Page 17 of 42 24-20 WELCOME TO THE NEIGHBORHOOD zoning laws to promote more inclusive communities and affirmatively further fair housing (AFFH). These amendments have also generated disputes and confusion over whether local governments are violating fair housing laws by discriminating against persons with disabilities or other protected characteristics." The document assumes the ordinances are not legally compliant and creates difficulties faced by cities trying to reasonably regulate group homes. The document is labeled a "technical advisory" but reads as a policy statement. There were apparently no public hearings regarding the document. "The document is labeled a "technical advisory" but reads as a policy statement... " These actions by HCD and DOJ, as well as litigation, are challenges municipalities face in adopting ordinances regarding group homes when the courts have found these ordinances compliant with State and federal laws. This was made evident through interviews with representatives of cities. Interviewees also expressed concern that HCD interpreted the laws as being overly restrictive on zoning ordinances and failing to protect the inhabitants of group homes. Housing Element In the State of California, all cities are required to develop a General Plan. The General Plan serves as a blueprint for the future, prescribing policy goals and objectives to shape and guide the physical development of the city. The General Plan is a comprehensive policy document that informs future land use decisions, and it is comprised of multiple elements.21 The Housing Element is one important part of a city or county's General Plan. Every eight years, every city, town, and county must update their Housing Element and have it certified by the California Department of Housing and Community Development (HCD). The most recent cycle of the new Housing Element has been heavily impacted by the State's laser focus on housing availability and affordability. On September 28, 2021, Governor Gavin Newsom signed a suite of bills to boost housing production across California which accompanies the Governor's $22 billion housing affordability and homelessness package and ongoing work by the State to spur more housing production, tackle barriers to construction, and hold local governments accountable. Taken together, the actions reflect the State's focus on creating more ORANGE COUNTY GRAND JURY 2022 12023 Page 18 of 42 24-21 WELCOME TO THE NEIGHBORHOOD affordable housing, faster and cheaper. "The acute affordability crisis we are experiencing in California was decades in the making, and now we're taking the necessary steps to fix it," said Governor Newsom.22 Although this is a response to a real need in California, the real -world consequences to the "build -build -build" solution are many. One of those can be seen in the State's myopic push for housing as it has mistakenly equated group homes with additional housing options. But housing is not increased by allowing the unbridled proliferation of recovery and sober living homes. The industry advertises heavily outside of California and brings many of their residents from out-of-state. It is not uncommon for some of these residents to be "kicked to the curb" (referred to as curbing) for various reasons, and because they are not local to Orange County, they have nowhere to go and ultimately face homelessness. HCD wields its power to review and approve State housing elements as a threat to deter city and county efforts to regulate group homes. Approval of the Housing Element has a big impact on a city's ability to enforce its general plan and to control what gets built and where it is built. Without the HCD's approval of the housing element, a door is opened to developers to bypass local zoning ordinances by utilizing a seldom used loophole known as Builders Remedy. Under that law, a developer may sidestep city approvals to construct a housing development if 20% of the project's homes are affordable housing.23 State funding programs for transportation, infrastructure, and housing often require or consider a local jurisdiction's compliance with Housing Element Law. These competitive funds can be used for fixing roads, adding bike lanes, improving transit, or providing much needed affordable housing to communities. In some cases, funding from state/federal housing programs can only be accessed if the jurisdiction has a compliant housing element.24 25 Educating the Public By the time the public has organized to bring their concerns to city leadership through a letter writing campaign, a joint written complaint, or a petition, their level of frustration has likely been building for quite a while. How city leadership deals with the concerns and frustrations of their constituency is likely to determine whether it will be a collaborative or an adversarial process to find a resolution. Educating the public on the reasons that cities have seemingly been unwilling to address the integration of group homes into Orange County neighborhoods is key to the success of collaborative problem solving. Cities have been squeezed from above by a combination of intense pressure from group home operators citing federal protections for the disabled, and the State of California's efforts to eliminate group home ordinances by withholding approval on cities' mandated Housing Element submission. They are also squeezed from below by ORANGE COUNTY GRAND JURY 2022 12023 Page 19 of 42 24-22 WELCOME TO THE NEIGHBORHOOD the people in neighborhoods which have been impacted by the over -concentration of group homes, and/or the level of nuisances generated by the group homes. "Some cities have used the multi -discipline, educational, townhall type response to the public outcry while others have not. The outcome can be quite different." A lack of understanding of the challenges faced by cities leads to the perception that they are unwilling to step up and regulate the various group home types that are springing up in neighborhoods. Public education will reveal that there is not an unwillingness of cities, or the public, to find resolutions, but rather there are many hurdles promulgated by State and federal agencies that often prevent opportunities for reaching a solution. Cities should work together, and with State legislators and other stakeholders, to look for ways to affect change at the State level as well as provide more focused public education that addresses these issues. In an effort to inform their citizens, some cities have used the multi -discipline, educational, townhall type response to the public outcry while others have not. The outcome can be quite different. To illustrate, we need look no further than a tale of three cities: Anaheim, Newport Beach, and Laguna Hills. Anaheim's group home issue heated up in October 2021 when Grandma's House of Hope requested a Conditional Use Permit (CUP) to use a large house as a transitional living home for 19 intractably mentally ill women.26 It was not Grandma's House of Hope's first group home in Anaheim; it was the latest in many previously successful CUP requests. Local residents coalesced against this CUP request in a vocal and organized manner. Whether it was the number of residents impacted, the descriptor of the group home residents as intractably mentally ill, or just one group home too many in this neighborhood, this organized effort to prevent the approval of the large group home attracted hundreds of local citizens and activists from both sides of the issue. It seemed that the majority of these people attended the planning commission meeting to voice their opinions during the public comment portion of the agenda and to let the City's Planning Commission see the strength of their numbers. ORANGE COUNTY GRAND JURY 2022 1 2023 Page 20 of 42 24-23 WELCOME TO THE NEIGHBORHOOD The Planning Commission was seemingly prepared to accept the staff recommendation for approval. Public comment took over five hours, most of which was overwhelmingly against the approval of the group home. The applicant and the Planning Commission both expressed surprise at the public backlash. Ultimately, the approval recommendation was scrapped, and the Planning Commission voted to deny the CUP. Grandma's House filed an appeal and the application for the CUP was heard by the City Council. The public attended that meeting in larger numbers than at the Planning Commission meeting and they were every bit as angry and frustrated as they were at the earlier meeting. In spite of robust response on the issue at the meeting of the Planning Commission just two months earlier, the Anaheim City Council was unprepared for the charged nature of the adversarial clash. Most speakers were passionate but respectful, while some were rude and offensive. It was essentially an angrier repeat of the first meeting and led to the same conclusion, a denial of the CUP.27 The affected public walked away with no better understanding of the reasons why these group homes are hard to regulate due to the pressures put on cities by the State of California. The applicant ultimately filed suit against the city alleging violations of the Housing Element Law, Housing Accountability Act, and statutes governing anti- discrimination in local land use laws. Nearly 200 people packed the Mission Viejo City Council chamber on March 29 for a Town Hall meeting regarding sober living homes. (Tomoya Shimura, Orange County Register, April 1, 2016) The City of Anaheim has not responded to the public concerns in an organized manner. It has not provided an opportunity for the public to come together in a townhall-like meeting where the City could address the issues and the challenges they face, have subject matter experts on hand for short presentations, and allow for comments and questions.28 ORANGE COUNTY GRAND JURY 2022 12023 Page 21 of 42 24-24 WELCOME TO THE NEIGHBORHOOD In direct contrast to Anaheim's response, we can look at the steps taken by the Cities of Newport Beach and Laguna Hills. Newport Beach was faced with a petition from its residents in 2007 after a rapid increase in the number of drug rehabilitation homes. The residents reported 103 treatment houses, nearly all on the Balboa Peninsula. There was a town hall hosted by (then) Assemblywoman Mimi Walters, R-Laguna Niguel, and (then) State Senator Tom Harman, R-Huntington Beach, and an estimated 200 people attended. It was an opportunity for dialogue as well as to learn about the constraints placed on cities by the State of California. Newport Beach responded to resident concerns again in late 2021 by organizing a community meeting with speakers from several city departments, a State Assemblywoman, the District Attorney, and a County Supervisor.29 so Hundreds attend the Sober Living Homes Town Hall meeting at the at the Laguna Hills Community Center on Thursday (Christopher Yee, San Gabriel Valley Tribune, May 13, 2016) We can also look at the steps taken by the City of Laguna Hills. In 2016, the City responded to public outcry regarding group home issues by hosting a Town Hall on the subject. The Town Hall was hosted by (then) State Senator Pat Bates and several other State and local legislators. Also in attendance were attorneys with extensive knowledge of the issue as well as other subject matter experts. More than 600 people attended, and it was an opportunity for the residents in attendance to gain a better understanding of the challenges the City faces in regulating unlicensed group homes, as well as for the City to hear the concerns and frustrations of attendees. Proving that, when cities work to ORANGE COUNTY GRAND JURY 2022 1 2023 Page 22 of 42 24-25 WELCOME TO THE NEIGHBORHOOD inform their constituents, and allow for a robust but respectful dialogue, they create an opportunity for collaborative problem solving.31 How Has This Issue Evolved? The timing of this investigation aligned with the required submission of the Housing Element portion of each city's General Plan. The State's disapproval of a city's Housing Element carries heavy consequences, and the State of California has used the withholding of this needed approval to coerce cities to abandon their group home ordinances. The Grand Jury was previously unaware of the power behind group home lobbyists and the number of proposed legislative bills that never made it to a vote. The State's policy - making role limits a city's ability to responsibly manage the integration of group homes and, as a consequence, the trajectory and focus of the study changed and widened with this knowledge. The Grand Jury looked at broader factors influencing the group home industry, its influence, its effect on communities and often its seeming lack of real concern about its clients. The group home industry is immense, requires improved relations with cities, and needs more effective local governmental oversight. ORANGE COUNTY GRAND JURY 2022 12023 Page 23 of 42 24-26 WELCOME TO THE NEIGHBORHOOD FINDINGS In accordance with California Penal Code Sections 933 and 933.05, the 2022-2023 Grand Jury requires (or, as noted, requests) responses from each agency affected by the findings presented in this section. The responses are to be submitted to the Presiding Judge of the Superior Court. Based on its investigation titled "Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes?" the 2022-2023 Orange County Grand Jury has arrived at eleven principal findings, as follows: F1 Group homes too close to one another contribute to the problems associated with overconcentration. F2 Common nuisances are more likely and disruptive when sober living homes are concentrated in a small geographic area of a neighborhood. F3 Some cities have successfully addressed and informed community members about the challenges faced in regulating group homes. F4 Community satisfaction was minimal when cities took the traditional public comment approach towards addressing community complaints. F5 Cities are not utilizing police, fire, and code enforcement complaints as a means of locating and tracking Group Homes. F6 Cities are inhibited from enacting and enforcing ordinances due to fears over the potential cost of litigation. F7 Several cities have created an ordinance that requires a ministerial permit or registration to operate a group home, however many of these cities do not enforce their ordinances. F8 City and County officials are deterred from regulating group homes by California Housing and Community Development's housing element approval process. F9 Cities have historically strategized and acted independently in addressing group home challenges and solutions. F10 Well -operated group homes can integrate smoothly into neighborhoods. F11 There is a lack of regulatory oversight for the health and safety of residents of unlicensed group homes. ORANGE COUNTY GRAND JURY 2022 12023 Page 24 of 42 24-27 WELCOME TO THE NEIGHBORHOOD RECOMMENDATIONS In accordance with California Penal Code Sections 933 and 933.05, the 2022-2023 Grand Jury requires (or, as noted, requests) responses from each agency affected by the recommendations presented in this section. The responses are to be submitted to the Presiding Judge of the Superior Court. Based on its investigation titled, "Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes?" the 2022-2023 Orange County Grand Jury makes the following five recommendations: R1 Orange County cities and the County of Orange should address citizen concerns regarding group homes by providing an opportunity for an open dialog where an interdisciplinary panel of subject matter experts can share with attendees the challenges cities are facing in the management of group homes. To be implemented by July 1, 2024. (F3, F4) R2 By December 31, 2024, Orange County cities and the County of Orange should collaborate in their efforts to create ordinances for the regulation of group homes, including the development of model ordinances. (F6, F7, F9) R3 Orange County cities and the County of Orange should pool resources for defense of lawsuits challenging group home ordinances. To be implemented by July 1, 2024. (F6, F8, F9) R4 The County of Orange and Orange County cities should create a Task Force that includes representatives from OC cities, unincorporated areas, and other entities as appropriate and charge it with the responsibility of developing a plan to generate awareness among State legislators and regulators of the need for improved regulations and management standards to ensure health and safety for Group Home residents. To be implemented by July 1, 2024. (F2, F10, F11) R5 Orange County cities and the County of Orange should modify code enforcement report data collection forms to include a searchable field that enables the identification of a residence operating as a group home. To be implemented by July 1, 2024. (F5, F7, F11) RESPONSES California Penal Code Section 933 requires the governing body of any public agency which the Grand Jury has reviewed, and about which it has issued a final report, to comment to the Presiding Judge of the Superior Court on the findings and recommendations pertaining to matters under the control of the governing body. Such comment shall be made no later than 90 days after the Grand Jury publishes its report (filed with the Clerk of the Court). Additionally, in the case of a report containing findings ORANGE COUNTY GRAND JURY 2022 12023 Page 25 of 42 24-28 WELCOME TO THE NEIGHBORHOOD and recommendations pertaining to a department or agency headed by an elected County official (e.g., District Attorney, Sheriff, etc.), such elected County official shall comment on the findings and recommendations pertaining to the matters under that elected official's control within 60 days to the Presiding Judge with an information copy sent to the Board of Supervisors. Furthermore, California Penal Code Section 933.05 specifies the manner in which such comment(s) are to be made as follows: (a) As to each Grand Jury finding, the responding person or entity shall indicate one of the following: (1) The respondent agrees with the finding. (2)The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. (b) As to each Grand Jury recommendation, the responding person or entity shall report one of the following actions: (1) The recommendation has been implemented, with a summary regarding the implemented action. (2) The recommendation has not yet been implemented, but will be implemented in the future, with a time frame for implementation. (3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a time frame for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This time frame shall not exceed six months from the date of publication of the Grand Jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor. (c) If a finding or recommendation of the Grand Jury addresses budgetary or personnel matters of a county agency or department headed by an elected officer, both the agency or department head and the Board of Supervisors shall respond if requested by the Grand Jury, but the response of the Board of Supervisors shall address only those budgetary /or personnel matters over which it has some decision -making authority. The response of the elected agency or department head shall address all aspects of the findings or recommendations affecting his or her agency or department. ORANGE COUNTY GRAND JURY 2022 12023 Page 26 of 42 24-29 WELCOME TO THE NEIGHBORHOOD The Orange County Grand Jury requires and requests the following responses: 90 Day Response Required County of Orange Board of Supervisors County of Orange Board of Supervisors City Councils of: Aliso Viejo Aliso Viejo Anaheim Anaheim Brea Brea Buena Park Buena Park Costa Mesa Costa Mesa Cypress Cypress Dana Point Dana Point Fountain Valley Fountain Valley Fullerton Fullerton Garden Grove Garden Grove Huntington Beach Huntington Beach Irvine Irvine La Habra La Habra La Palma La Palma Laguna Beach Laguna Beach Laguna Hills Laguna Hills Laguna Niguel Laguna Niguel Laguna Woods F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 ORANGE COUNTY GRAND JURY 2022 12023 Page 27 of 42 24-30 WELCOME TO THE NEIGHBORHOOD Laguna Woods Lake Forest Lake Forest Los Alamitos Los Alamitos Mission Viejo Mission Viejo Newport Beach Newport Beach Orange Orange Placentia Placentia Rancho Santa Margarita Rancho Santa Margarita San Clemente San Clemente San Juan Capistrano San Juan Capistrano Santa Ana Santa Ana Seal Beach Seal Beach Stanton Stanton Tustin Tustin Villa Park Villa Park Westminster Westminster Yorba Linda Yorba Linda R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11, R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 F1, F2, F3, F4, F5, F6, F7, F8, F9, F10, F11 R1, R2, R3, R4, R5 ORANGE COUNTY GRAND JURY 2022 12023 Page 28 of 42 24-31 GLOSSARY ADU An accessory dwelling unit, usually just called an ADU, is a secondary housing unit on a single-family residential lot. These may be converted garages, backyard cottages, or granny flats, for example. Brokering A referral system where money or other inducements are exchanged by owners of disreputable homes to get new clients. The recipients may be residents, clinics, or even members of self-help groups such as AM 2-step programs. Code Enforcement Activity by local government agencies to identify and correct problems and abuses by citizens and businesses. Congregate Care Living A residential home that offers inpatient services to its residents. Generally, the care that this institution provides is more intense than what a skilled nursing care facility offers but less intense than what a general acute care hospital provides. Curbing The act of evicting residents, often done late at night, so-called because they and their belongings are sent to the curb. Eviction may occur when such residents' insurance runs out or for violating house rules. They frequently have nowhere to go and often have no resources, essentially rendering them homeless. Deinstitutionalization The closing (or reduction of services) of residential facilities, often referred to as mental hospitals, and the reliance on smaller, more personal "homes" as a means of rehabilitation. Detox Program or facility for assisting a person undergoing treatment from an intoxicating or addictive substance. 24-32 WELCOME TO THE NEIGHBORHOOD EBT Acronym for Electronic Benefit Transfer, previously known as Food Stamps, these are debit cards issued to eligible participants for the purpose of buying food and other necessities. Emotional Wellness Homes A facility where a person develops the ability to handle their emotions and varied experiences they encounter in life. Emotional wellness is an awareness, understanding, and acceptance of our feelings and the ability to manage and change challenges effectively. Good Neighbor Policy A set of principles and activities designed to provide a consistent means of communication between facilities that provide resident services and their respective neighbors. The Good Neighbor Policy is applicable for Residential Programs when residents and the services have a potential impact including but not limited to community safety, cleanliness, and security in the surrounding neighborhood(s). Group Home (GH)* A residential unit utilized as a supportive living environment for people meeting the legal definition of disabled. Provides housing only for a classified group of people. No medical care, services, or treatment can take place in a Group Home. Only State -licensed facilities can provide care, services, or treatment under State law (see Residential Care Facilities) Hospice A type of health care that focuses on the palliation of a terminally ill patient's pain and symptoms and attending to their emotional and spiritual needs at the end of life. Hospice care prioritizes comfort and quality of life by reducing pain and suffering. Housing Element Since 1969, California has required that all local governments (cities and counties) adequately plan to meet the housing needs of everyone in the community. California's local governments meet this requirement by adopting housing plans as part of their "general plan" (also required by the state). General plans serve as a local government's "blueprint" for how the city and/or county will grow and develop and include eight elements: land use, transportation, conservation, noise, open space, safety, environmental justice, and housing. ORANGE COUNTY GRAND JURY 2022 1 2023 Page 30 of 42 24-33 WELCOME TO THE NEIGHBORHOOD Integral Facilities Integral facilities means any combination of two or more facilities located on the same or different parcels, collectively serving seven or more persons, not including the licensee or members of the licensee's family or persons employed as facility staff, that are under the control or management of the same owner, operator, management company or licensee or any affiliate of any of them, and which together comprise one operation. Integral facilities shall include, but not be limited to, the provision of housing in one facility and recovery programming, treatment, meals, or any other service or services at another facility, or facilities, or by assigning staff, or a consultant or consultants, to provide services to or in more than one facility. Licensing A permit from an authority to own or use something or to do a particular thing or carry on a trade. In reference to this report's subject matter, licensing from a State or county agency or department. Like -for -Like Identifying the spacing of group homes by type, e.g., sober living within a given distance of sober living, assisted living within a given distance of assisted living, etc. Sober living near assisted living does not meet the like -for -like criteria. Model Ordinance A common set of policies and procedures developed by a government agency to oversee the licensing and operation of group homes. NIMBY Acronym for "Not in My Backyard". A term used, among other things, to identify citizens who object to having group homes in their neighborhood. Referral Facility Either a Residential Care Facility, Group Home, or Sober Living Home where one or more person's residency is per a court order or similar directive. Referral facilities must follow the permit procedure according to the base use classification, and are not permitted in the RL (Residential Low Density) zone. Rehab Riviera The nickname given to some sober living facilities in Southern California, referring to the climate. Often used as a selling point in advertising to emphasize the outdoor appeal of homes in the region. ORANGE COUNTY GRAND JURY 2022 12023 Page 31 of 42 24-34 WELCOME TO THE NEIGHBORHOOD Rehabilitation The action of restoring someone to health or normal life. Care that can help one get back, maintain or improve abilities. Residential Care Facilities (RCF)* A State Licensed residential facility where care, services, or treatment are provided to persons living in a community residential setting. Provide housing and care/treatment for the elderly, developmentally disabled, chronically ill, and chemical addiction treatment facilities, among others. RCFs that specifically provide drug and or alcohol abuse treatment are licensed by the Department of Health Care Services (DHCS) and are known as alcoholism or drug abuse recovery or treatment facilities. Homes are required to be licensed by the DHCS when at least one of the following services is provided: detoxification, group counseling sessions, individual counseling sessions, educational sessions, or alcoholism or drug abuse recovery or treatment planning. Residential Treatment Centers Sometimes known as rehab which is a live-in health care facility providing services for substance use disorders, mental illness, or other behavioral problems. Saturation Having several group homes within a neighborhood. Single Housekeeping Units Individuals occupying a dwelling unit that have established ties and familiarity with each other; share a lease agreement, have consent of the owner to reside on the property, or own the property; jointly use common areas and interact with each other; and share the household expenses such as rent or ownership costs, utilities, and other household and maintenance costs activities. Six or Under Homes with six or fewer residents. Under State law these may not be required to be licensed or registered. Sober Living Home (SLH)* Sober Living Homes are also group homes, but specifically for people recovering from a chemical addiction that meets the legal definition of disabled. Provides "housing only" that is primarily meant for people who have just come out of rehab and need a ORANGE COUNTY GRAND JURY 2022 12023 Page 32 of 42 24-35 WELCOME TO THE NEIGHBORHOOD place to live that is structured and supportive for those in recovery. For the purposes of the Ordinance, a Sober Living Home is not state licensed. No medical care, services, or treatment can occur in a Living Home. Only State licensed facilities can provide care, services, or treatment under State law (see Residential Care Facilities). Tracking A method to obtain data, monitor movements and a system to identify and map the location of group homes. Treatment Center A facility where a client or clients go under one roof for services to improve their physical or mental health. A residential treatment center (RTC), sometimes called rehab, is a live-in health care facility providing therapy for substances abuse use disorders, mental illness, or other behavioral problems. Residential treatment may be considered the "last-ditch" approach to treating abnormal psychology or psychopathology. *For the purposes of this report, the City of Huntington Beach's definitions of group living homes is being used as published on the city's website. ORANGE COUNTY GRAND JURY 2022 1 2023 Page 33 of 42 24-36 WELCOME TO THE NEIGHBORHOOD BIBLIOGRAPHY Teri Sforza, Will U.S. Supreme Court engage on Costa Mesa's sober living rules?, Orange County Register, Wednesday, March 15, 2023 Teri Sforza, Addiction centers flee Costa Mesa, move to less regulated OC cities, Orange County Register, Sunday, February 19, 2023 David Zisser, Letter from CA Department of Housing and Development to City of Huntington Beach Planning Department - RE "Ordinance to Ban "Builder's Remedy" Projects under the Housing Accountability Act (HAA) — Notice of Potential Violation", California Department of Housing and Community Development web site, Monday, February 13, 2023 Ring Bender Law, SoCal Recovery and Raw Recovery v City of Costa Mesa: Amici Curiae Brief Of The League Of California Cities, The Association Of California Cities Of Newport Beach, Fountain Valley, Mission Viejo, And Orange In Support Of Appellee's Petition For Rehearing En Banc, Court Filings, Thursday, February 9, 2023 Teri Sforza, Sober homes gain some ground in fight with Costa Mesa, Orange County Register, Sunday, January 15, 2023 Covenant Hills, Day Patient and Outpatient Addiction Treatment in Orange County, YouTube Posting, Friday, November 4, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, Orange County Sober Living I Sober Living Near You in SoCal (kaizenhouserecovery.com), Wednesday, October 19, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, Sober Living Homes for Men & W General Information omen - 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Drug & Alcohol Rehab (serenitylodgelakearrowhead.com), Wednesday, October 19, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, California addiction rehab centers (sunshinebehavioralhealth.com), Wednesday, October 19, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, Halfway Houses I % way Houses I Sober Homes in California (addictionblog.org), Wednesday, October 19, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, Requirements For California Rehabilitation and Sober Living Houses (hypogalblog.com), Wednesday, October 19, 2022 General Information, Links To Sober Living Group Homes, Advertisements And Blogs In Oc, A Place for Mom, Wednesday, October 19, 2022 Jeff Collins, These Southern California governments have approved housing plans, Orange County Register, Tuesday, October 18, 2022 Jeff Collins, Most Southern California cities miss complete new deadline to complete housing plans, Orange County Register, Tuesday, October 18, 2022 Alicia Robinson, Anaheim should allow home for homeless women with mental health issues, California Attorney General says, Orange County Register, Wednesday, October 5, 2022 Alicia Robinson, Anaheim should allow home for homeless women with mental health issues, California Attorney General says, Orange County Register, Tuesday, October 4, 2022 Public Notice — City of Mission Viejo, Council passes Sober Living and Group Home Ordinance to ensure such facilities operate with the confines of the law, City of Mission Viejo web site Home City of Mission Viejo, Wednesday, August 24, 2022 Public Notice, Council passes Sober Living and Group Home Ordinance to ensure such facilities operate within the confines of the law, City of Mission Viejo website https:Hcityofmissionviejo.org/, Wednesday, August 24, 2022 Teri Sforza, Rehab Riviera: New law hopes to keep misleading rehabs from misleading patients, families patients, families, Orange County Register, Wednesday, August 24, 2022 Teri Sforza, California rehab doctor pleads guilty to insurance fraud, Orange County Register, Tuesday, August 16, 2022 Vanessa Serna, Real -life Frankenstein' Beverly Hills surgeon and his girlfriend plead guilty to $600 Million fraud scheme: Used 'body brokers' to find drug addicts to get unnecessary shots so ORANGE COUNTY GRAND JURY 2022 12023 Page 35 of 42 24-38 WELCOME TO THE NEIGHBORHOOD they could bill insurance companies to fund their life of luxury, DailyMail.com, Tuesday, August 16, 2022 California Codes, Various Codes, California Code Search "Text" of the following— using "sober" and "living"., Monday, August 8, 2022 City of Laguna Beach Department of Community Development, City of Laguna Beach General Plan Housing Element, City of Laguna Beach Web Site 638115638915170000 (lagunabeachcity.net), Thursday, July 21, 2022 Matt Meyer, What is 'California sober' — and does it actually work?, Nexstar Media Inc Fox News San Diego, Saturday, June 25, 2022 Website Information Idea Flight, 9 Different Types of Group Home in California, Idea Flight Web Site Page 9 Different Types of Group Home in California - ideaflight, Friday, April 1, 2022 City of Westminster, Adopted Housing Element 2021-202-, City of Westminster website https://www.westminster-ca.gov/, Wednesday, January 26, 2022 Scott D. Tenley and Kelly M. Hagemann of Michelman & Robinson LLP, Federal Authorities Have Their Eyes On Sober Living Home Operators And Marketers, Especially In Orange County, Mondaq web site, Friday, November 19, 2021 City of Newport Beach, Community Meeting on Group Residential Uses Meeting Summary, City of Newport Beach web site City of Newport Beach I Home newportbeachca.gov), Monday, October 11, 2021 City of Newport.Beach, Power Point from Community Meeting Sober Living Homes, Group Homes, and State Licensed Residential Care Facilities, City of Newport Beach web site City of Newport Beach I Home newportbeachca.gov), Monday, October 11, 2021 City Newport Beach, Document comparing City of Newport Beach Group Home Ordinance to City of Costa Mesa Group Home Ordinance, City of Newport Beach web site City of Newport Beach I Home newportbeachca.gov), Friday, September 24, 2021 Staff, How to Open a Sober Living Home in California, Blog Post at Sober Living App, Tuesday, May 11, 2021 Web Site Posting, How Much Profit Can Be Made From a Halfway House?, HALFWAY GROUP LLC website How Much Profit Can Be Made From A Halfway House?.openupahalfwayhouse.com), Tuesday, February 2, 2021 County of Orange Press Release, Ending Rehab Riviera: Orange County First, County of Orange website, Thursday, October 1, 2020 County of Orange, County of Orange Group Home Ordinance, County of Orange website, Tuesday, July 28, 2020 ORANGE COUNTY GRAND JURY 2022 12023 Page 36 of 42 24-39 WELCOME TO THE NEIGHBORHOOD David Gorn, Doing the 'sober -living dance' on the Orange County coast, CalMatters, Tuesday, June 23, 2020 Elysia Richardson, Do Drug Treatment Centers Increase Local Crime Rates?, California Highlands Vista Drug Treatment Centers Web Site https://californiahighlandsvistas.com/blog/crime- rates/, Monday, February 10, 2020 Orange County Public Works, Fact Sheet on Group Home Requirements, County of Orange website https://myoceservices.ocgov.com , Saturday, February 1, 2020 Michelle Mears, Orange County Tackles Homeless Issue by regulating Group Homes, Glove, Friday, September 27, 2019 Michelle Mears, Orange County Tackles Homeless Issue by Regulating Group Homes, California Globe, Friday, September 27, 2019 City of Newport Beach, Group Home List, City of Newport Beach web site City of Newport Beach I Home newportbeachca.gov), Thursday, September 19, 2019 Frank Kim, OC County Executive Officer, Memo regarding proposed ordinance to regulate Sober Living Homes, County of Orange Web Site, Wednesday, June 19, 2019 California Department of Social Services,.Overview of the Group Home Rate Classification Levels, DSS Website information sheet, Thursday, April 4, 2019 Miami -Dade County Form, Miami -Dade County Group Home Application, Miami -Dade County Website.Group Home Application -no aff disc 2019 (miamidade.gov), Monday, April 1, 2019 Steven P. Dinkin, Utilizing the Safe Streets Now playbook, San Diego Union -Tribune, Sunday, January 13, 2019 Brady P. Horn, Aakrit Joshi, Johanna Catherine Maclean, Substance Use Disorder Treatment Centers And Property Values, National Bureau Of Economic Research, Tuesday, January 1, 2019 Teri Sforza, New rehab laws may revamp addiction treatment in California, Orange County Register, Thursday, September 27, 2018 City of Laguna Niguel, Group Home Permit Application, City of Laguna Niguel website https:Hcityoflagunaniguel.org/, Wednesday, July 4, 2018 William Leonard, Sober living homes in Orange County California, Sober Living Local, Saturday, May 5, 2018 Tony Saavedra, Teri Sforza, Death in rehab generates $7 million award, Orange County Register, Sunday, February 18, 2018 Teri Sforza, Tony Saavedra, Quest for sobriety often ends in sexual assault at some rehabs in Southern California, Orange County Register, Friday, January 19, 2018 ORANGE COUNTY GRAND JURY 2022 12023 Page 37 of 42 24-40 WELCOME TO THE NEIGHBORHOOD US Department of Health and Human Services, Ensuring Beneficiary Health and Safety in Group Homes Through State implementation, DHSS Web Site https://www.hhs.gov/guidance/document/joint-report-ensuring-beneficiary-health-and-safety- group-homes-through-state , Wednesday, January 10, 2018 Teri Sforza, Rehab Riviera: California testing Vermont's model to fight addiction, Orange County Register, Friday, December 29, 2017 Teri Sforza, Tony Saavedra, Scott Schwebke, Rehab Riviera: Industry struggling to get clean, Orange County Register, Friday, December 29, 2017 Teri Sforza, Rehab Riviera: Are drugs for drug addicts a solution or a crutch?, Orange County Register, Thursday, December 28, 2017 Tony Saavedra, Scott Schwebke, How a multimillion -dollar empire built around urine drug tests exposes flaws in California's rehab laws, Orange County Register, Sunday, December 17, 2017 Jordan Graham, Are drug rehab centers fueling homelessness in Southern California?, Orange County Register, Sunday, December 17, 2017 Teri Sforza, Are implants for opioid addicts a new hope or a new scam?, Orange County Register, Sunday, October 22, 2017 Teri Sforza, San Clemente's'discriminatory' rules on addiction treatment centers intact after suit settles, Orange County Register, Wednesday, July 5, 2017 Teri Sforza, California the over -regulator? Not for addiction treatment, Orange County Register, Friday, June 23, 2017 Teri Sforza, Addiction treatment: The new gold rush. 'It's almost chic', Orange County Register, Friday, June 16, 2017 US Congress Committee on Energy and Commerce, Letter to Thomas E. Price, M.D. Secretary U.S. Department of Health and Human Services Regarding problems resulting from the dramatic surge of addiction treatment centers and "sober living' homes, Congressional Record, Tuesday, June 13, 2017 Scott Schwebke, Teri Sforza, Federal agents search Sovereign Health rehab in San Clemente, elsewhere, Orange County Register, Tuesday, June 13, 2017 California Department of Social Services Community Care Licensing Division, Power Point on Orange County Regional Office and what it does Newport Beach Meeting, Web Site of Department of Social Services www.ccld.ca.gov, Thursday, June 1, 2017 Teri Sforza, Detox can end in death at some 'non -medical' Southern California rehabs, Orange County Register, Tuesday, May 23, 2017 ORANGE COUNTY GRAND JURY 2022 12023 Page 38 of 42 24-41 WELCOME TO THE NEIGHBORHOOD Todd Harmonson, Sean Emery, O.C. District Attorney charges family, doctors with insurance fraud related to sober living homes, urine tests, Orange County Register, Tuesday, May 23, 2017 Teri Sforza, Tony Saavedra, Scott Schwebke, Lori Basheda, Mindy Schauer, Jeff Gritchen, Ian Wheeler, How some Southern California drug rehab addiction centers exploit addiction, Orange County Register, Sunday, May 21, 2017 Teri Sforza, Is there a link between neighborhood rehab programs and petty crime in California?, Orange County Register, Sunday, May 21, 2017 Staff Report, The Southern California rehab industry spans the nation, Orange County Register, Sunday, May 21, 2017 Jan Wheeler, Registered Rehabs Map, Orange County Register, Thursday, May 4, 2017 Mindy Schauer, Heroin's hold: One man's journey through the Southern California rehab industry, Orange County Register, Monday, May 1, 2017 CBS News, OC Neighbors Not Comfortable Next to Sober Living Homes, YouTube Posting, Tuesday, November 29, 2016 California Research Bureau, Sober Living Homes in California: Options for State and Local Regulation, California Research Bureau Publication in State Library https://www.Iibrary.ca.gov/crb/, Friday, October 7, 2016 Amy A. Mericle, Katherine J. Karriker-Jaffe,.Shalika Gupta, David M. Sheridan, Doug L. Polcin, Distribution and Neighborhood Correlates of Sober Living House Locations in Los Angeles, American Journal of Community Psychology, Thursday, September 1, 2016 Teri Sforza, California argues sober home ordinances are illegal, forcing cities to make expensive decisions, Orange County Register, Saturday, December 19, 2015 J Murphy - City of La Mesa Fact Sheet, Residential Care Facilities (or "Group Homes") in the City of La Mesa, City of La Mesa website http://www.cityofIamesa.com , Thursday, October 29, 2015 County of Orange published guideline, Orange County Adult Alcohol And Drug Sober Living Facilities Certification Guidelines, County of Orange Sheriff Departments website, Monday, January 27, 2014 Sober Living by the Sea, Drug Rehab and Alcoholism Treatment OC CA by Sober Living by the Sea, YouTube Posting, Wednesday, May 23, 2012 You Get Me3, Santa Ana Sober Living Homes, YouTube Posting, Saturday, July 3, 2010 Paul J. Weinberg, Alcohol And Drug Rehab Homes classic Nimbyism Or Everyone's Fair Share, Thomson Reuters/West Zoning and Planning Law Report, Wednesday, October 1, 2008 ORANGE COUNTY GRAND JURY 2022 12023 Page 39 of 42 24-42 WELCOME TO THE NEIGHBORHOOD City of Newport Beach, City of Newport Beach Residential Group Home Permit, City of Newport Beach web site City of Newport Beach I Home newportbeachca.gov), Friday, February 1, 2008 David DeBerry, Group Homes in the Neighborhood, Western City, Friday, September 1, 2006 NOTICE Reports issued by the Grand Jury do not identify individuals interviewed. Penal Code section 929 requires that reports of the Grand Jury not contain the name of any person or facts leading to the identity of any person who provides information to the Grand Jury. END NOTES Group Homes in the Neighborhood David Debarry, Jeff Bellinger, Western City 09-01-2006 https://www.westerncity.com/article/group-homes-neighborhood 2 Ibid. Division of Housing Policy Development. "Group Home Technical Advisory." California Department of Housing and Community Development, December 2022. https://www. hcd.ca.gov/sites/default/files/docs/planning-and-community/group-home-technical-advisory- 2022.pdf 3 CA Health & Safety Code Section 1267.9 4 Sforza, Terri. "California the over -regulator? Not for addiction treatment." Orange County Register, June 23, 2017. https://www.ocregister.c4om/2017/06/23/california-the-over-regulator-not-for-addiction- treatment s ibid . Division of Housing Policy Development. "Group Home Technical Advisory." California Department of Housing and Community Development, December 2022. https://www. hcd.ca.gov/sites/default/files/docs/planning-and-community/group-home-technical-advisory- 2022.pdf 6 Sforza, Terri. "California the over -regulator? Not for addiction treatment." Orange County Register, June 23, 2017. https://www.ocregister.c6om/2017/06/23/california-the-over-regulator-not-for-addiction- treatment/ California Research Bureau, Sober Living Homes in California: Options for State and Local Regulation, California Research Bureau Publication in State Library_Friday, October 7, 2016, https://www.library.ca.gov/crb/, 8 CA Health & Safety Code Section 1267.9 ORANGE COUNTY GRAND JURY 2022 12023 Page 40 of 42 24-43 WELCOME TO THE NEIGHBORHOOD 9Orange County Register Megan Nicolai, July 15, 2015, Newport Beach Settles legal battle over Sober - Living homes_ 10 Orange County Register Megan Nicolai, July 15, 2015, Newport Beach Settles legal battle over Sober - Living homes. 11 Los Angeles Times Susannah Rosenblatt, May 22, 2008, Sober living homes rushing to meet Newport's deadline. 12 Community Meeting on Group Residential Uses October 11, 2021 Meeting Summary https://nbpd.newportbeachca.gov/home/showpublisheddocument/70754/637703409585700000 13 New regional task force will tackle issues with sober living and recovery homes,News Category, City of Mission Viejo Public Notices, September 1, 2022, new regional task force will tackle issues with sober living and recovery homes I City of Mission Viejo 14 Grandma's House of Hope v. City of Anaheim and City Council of Anaheim Case No. 30-2022- 0124183-CU-WM-OJC 15 Newport Beach Ordinance 2008-05 16 Orange County Register Megan Nicolai, July 15, 2015, Newport Beach Settles legal battle over Sober - Living homes_ 17 City of Costa Mesa Ordinance Chapter 13-3001 18 Orange County Register Article, May 21, 2021 — State argues sober home ordinances are illegal, forcing cities to make expensive decisions 19 $42 Billion U.S. Addiction Rehab Industry Poised for Growth, and Challenges (marketresearch.com) 20 Ca Department Of Housing And Community Development, Group Home Technical Advisory, dated December 2022 21 Housing Element Update, 2021-2029 Planning Period FAQ & Fact Sheet,City of Arcadia https://cros9files.revize.com/arcadia/Shape%2OArcadia/Development%20Services/planning/Housing%20 Element%20Update/FAQ/Housing%20EIement%2OFact%2OSheet_FINAL.pdf 22 www.gov.ca.gov/2021/09/28/governor-newsom-signs-legislation 23 Growing List of Penalties for Local Governments Failing to Meet State Housing Law, Association of Bay Area Governments, June 2021, https://abag.ca.gov/sites/default/files/documents/2021- 06/Consequences%20of%20Non-Compliance%20with%20Housing%20Laws. pdf 24 Housing Element Update, 2021-2029 Planning Period FAQ & Fact Sheet,City of Arcadia https://cros9files.revize.com/arcadia/Shape%2OArcadia/Development%20Services/planning/Housing%20 Element%20Update/FAQ/Housing%20EIement%2OFact%2OSheet_FINAL.pdf 25 Housing Element Update, 2021-2029 Planning Period FAQ & Fact Sheet,City of Arcadia https://cros9files.revize.com/arcadia/Shape%2OArcadia/Development%20Services/planning/Housing%20 Element%20Update/FAQ/Housing%20EIement%2OFact%2OSheet_FINAL.pdf ORANGE COUNTY GRAND JURY 2022 12023 Page 41 of 42 24-44 WELCOME TO THE NEIGHBORHOOD 26 Walker, Theresa OC Register 10-25-2021 Housing for mentally ill homeless women draws heated Anaheim response https://www.ocregister.com/2021 /10/25/housing-for-mentally-ill-homeless-women-draws-heated-anaheim- response/ 27 Grandma's House of Hope v. City of Anaheim and City Council of Anaheim Case No. 30-2022- 0124183-CU-WM-OJC 28 City of Anaheim Planning Commission,PC Action Packets 8-30-2021 https://records.anaheim.net/CityClerk/DocView.aspx?id=2428318&dbid=0&repo=CITYOFANAHEIM 29 Many attend town hall on rehab houses,OC Register, 2-23-2007 Many attend Newport town hall on rehab houses — Orange County Register (ocregister.com) 30 Ibid. Many attend town hall on rehab houses 31 Sober Living Homes Town Hall ORANGE COUNTY GRAND JURY 2022 12023 Page 42 of 42 24-45 Attachment B Newport Beach Draft Response Letter 24-46 CITY OF NEWPORT BEACH 100 Civic Center Drive Newport Beach, California 92660 11 949 644-3004 1949 644-3039 FAX newportbeachca.gov cl �" August 23, 2023 Mayor Noah Blom The Honorable Maria D. Hernandez Mayor Pro Tern Presiding Judge of the Superior Court Will O'Neill 700 Civic Center Drive West Council Members Brad Avery Santa Ana, CA 92701 Robyn Grant Lauren Kleiman RE: Response to Grand Jury Report, "Welcome to the Neighborhood - Joe Stapleton Are cities responsibly managing the integration of group homes?" Erik Kenneth Weigand Dear Judge Hernandez: The attached is the City of Newport Beach `s formal response to the above - noted Grand Jury Report. If you or any members of the Grand Jury have questions about our response, please contact Jaime Murillo, Planning Manager, at (949) 644- 3209 or jmurillo(c�newportbeachca.gov. Sincerely, Noah Blom Mayor of Newport Beach 24-4 7 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 FINDING AGREE OR RESPONSE DISAGREE (Include portion of the finding that is disputed and include an explanation of the reasons) F1 Group homes too close to one another contribute to the Agree The overconcentration of residential care facilities can create an institutional environment problems associated with overconcentration. that defeats the purpose of community -based care and is inconsistent with the objective of integrating persons with disabilities into the community. The American Planning Association's Policy Guide on Community Residences states that community residences should be scattered throughout residential districts rather than being concentrated on any single block or in any single neighborhood. If several residential care facilities are located next to one another, or are placed on the same block, the ability of the residential care facilities to achieve normalization and community integration can be compromised. F2 Common nuisances are more likely and disruptive when Agree As stated in the Grand Jury Report, it is the City of Newport Beach's ("City") experience sober living homes are concentrated in a small geographic that when facilities are concentrated in a small geographic area, common nuisances may area of a neighborhood. be more visible and disruptive. For instance, when facilities are overconcentrated in a small geographical area, the City has received more inquiries related to the impacts of second-hand smoke, noise, deliveries, parking, medical testing/waste, and general waste removal/collection. F3 Some cities have successfully addressed and informed Agree As recognized in the Grand Jury Report, the City has had past success with town hall style community members about the challenges faced in meetings and continues to strive to keep residents informed regarding the topic of group regulating group homes. homes. The City agrees it is especially important to educate residents about the importance of creating housing opportunities for all segments of the community, the City's legal duty to affirmatively further fair housing, and the constraints imposed by both State and Federal law with respect to local regulation. The City maintains a website on group homes where residents can obtain information regarding City regulations, State laws forms and applications for operators of new facilities, links to State regulatory websites, and past community meeting presentations. While the Grand Jury Report highlights the 2007 town hall meeting, the City has held several community meetings, study sessions, and public hearings on this topic. The two most recent meetings were held on October 11, 2021, and April 4, 2022, and included local and State leaders and subject matter experts. The October 11, 2021, community meeting included CA Assemblywoman Cottie Petrie -Norris, Orange County Supervisor Katrina Foley; CA Senator Dave Min; Orange County District Attorney Todd Spitzer; and City Council Members Dianne Dixon, Joy Brenner, Duffy Duffield, and Will O'Neill. Discussion topics included an overview of current City regulations, the interaction of local laws with State and Federal laws including affirmatively further fair housing, and current and future efforts to promote legislative changes that better protect the residents of group homes and ensure that these homes are successfully integrated into residential neighborhoods. The April 4, 2022, community meeting included representatives from the CA Department of Social Services, Community Care Licensing Division providing an overview of their department, contact information, licensing and regulations. Assemblywoman Cottie Petrie - Norris was also present to discuss efforts at the State legislative level to ensure the welfare 24-48 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 FINDING AGREE OR RESPONSE DISAGREE (Include portion of the finding that is disputed and include an explanation of the reasons) of group home residents and promote the integration of group homes into surrounding communities. F4 Community satisfaction was minimal when cities took the Agree Occasionally, organized residents appear at City Council meetings to voice their concerns traditional public comment approach towards addressing during public comment on non -agenda items. Due to limits on the duration of public community complaints. comments, and the need for council members to focus on agenda items, residents are often frustrated and discouraged with the feedback received at regular public meetings. Community meetings that focus on community concerns provide a better forum for City leaders to communicate City policies and educate residents about the scope of local authority, and for City leaders to hear resident concerns. This type of forum generally results in a more collaborative process where residents feel heard, and concerns can be addressed. The community meetings discussed in the Response to F3 above, have enabled a much higher level of communication between City officials, City staff, State representatives and the community. These meetings highlighted that there are current issues with State regulations, outside the local control, that must be addressed for community concerns to be addressed. F5 Cities are not utilizing police, fire, and code enforcement Partially The City utilizes all possible means of comprehensively tracking code enforcement complaints as a means of locating and tracking Group Disagree complaints, regardless of whether they relate to group homes or not. The City's Police, Homes. Fire, and Code Enforcement departments maintain records related to all code violations. The City, however, does not use such resources to specifically locate and track group homes. The City complies with all State and Federal fair housing laws with respect to the use of its resources and enforcement of its laws. F6 Cities are inhibited from enacting and enforcing ordinances Agree On January 22, 2008, the City Council approved Ordinance No. 2008-5 with the intent of due to fears over the potential cost of litigation. maintaining zoning protections for residential districts, while benefiting disabled persons who wished to live in those districts. The ordinance balances the protections granted to persons with disabilities under the Federal Fair Housing Act, Fair Housing Act Amendments (42 U.S.C. Section 3601) and other State and Federal laws, while also ensuring that homes for disabled persons are integrated into the residential character of the neighborhood. As extensively documented in the Grand Jury Report, the City has been involved in several lengthy and costly lawsuits defending the 2008 ordinance. The City implements its existing ordinance within the bounds of the State and Federal fair housing laws. F7 Several cities have created an ordinance that requires a Partially The City partially disagrees with this finding as it relates to the City. To the extent allowed ministerial permit or registration to operate a group home, Disagree by State and Federal fair housing laws, the City implements its ordinance regarding group however many of these cities do not enforce their homes, requiring a permit for certain larger and/or unlicensed facilities. As necessary, the ordinances. City also implements its reasonable accommodation ordinance to ensure that all persons have an equal opportunity to use and enjoy residential dwellings. 24-49 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 FINDING AGREE OR RESPONSE DISAGREE (Include portion of the finding that is disputed and include an explanation of the reasons) The City cannot confirm whether other cities enforce their ordinances. F8 City and County officials are deterred from regulating group Agree The Grand Jury Report accurately identifies this issue. The Housing Element component homes by California Housing and Community of a local government's General Plan is required by State law to be updated periodically Development's housing element approval process. and is subject to review and approval by the California Department of Housing and Community Development ("HCD"). The City's current group home regulations have been in effect since 2008 and the permitting procedures were analyzed as part of the 4th and 5th Cycle Housing Element reviews and found in compliance with Housing Element law. However, during the 6th Cycle Housing Element review, the permitting process for group homes proved to be an issue that HCD focused on, not just for Newport Beach, but for all cities. The City's 6th Cycle Housing Element update was submitted to HCD a total of four times for review. During their review, HCD commented that the City should analyze the City's application requirement for residential care facilities serving 7 or more persons as a constraint on housing for person with disabilities. Specifically, HCD commented that "The element should analyze the process as a potential constraint on housing for persons with disabilities, considering the process'impact on approval certainty, timing, supply, and other relevant factors. Depending on the results of a complete analysis, the element should add or modify programs to ensure zoning permits group homes objectively and with approval certainty." Given the complexities associated with the regulation of group homes and that cities approach this issue in different ways, the City found that it can be difficult to explain to HCD how the City's regulations are in full compliance with all applicable State and Federal laws. Ultimately, the City and HCD agreed to adopt Housing Policy Action 3P (Residential Care Facilities) committing the City to review and amend the permitting procedures, application requirements, and development standards applicable to residential care facilities for 7 or more persons. The addition of this policy resolved HCD's correction regarding this issue. The City's 6t" Cycle Housing Element was ultimately found compliant with State Housing Element law on October 5, 2022. F9 Cities have historically strategized and acted Agree In October of 2021, the City Council formed a Residential Care Facilities Ad -Hoc independently in addressing group home challenges and Committee with the intent of ensuring local standards are consistent with State and solutions. Federal law, recommending legislative positions regarding State and Federal law, and reviewing and recommending code enforcement protocols and updates. Through this effort, the City has acknowledged that it cannot solve these issues alone and that collaboration, especially with State officials, is needed. Since the creation of the Residential Care Facilities Ad -Hoc Committee, City officials and staff have attempted to involve other cities and especially State representatives in identifying issues and pursuing legislative changes as evidenced by the community meetings referenced in Response to Finding 3. 24-50 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 FINDING AGREE OR RESPONSE DISAGREE (Include portion of the finding that is disputed and include an explanation of the reasons) The City is open to working more with other cities and counties, and especially State representatives, to pursue updates and legislative changes to better protect residents of group homes and safely integrate group homes into neighborhoods in cities across California. F10 Well -operated group homes can integrate smoothly into Agree In 2009, the City entered into a Zoning Agreement with the largest residential care facility neighborhoods. operator in the City. The Zoning Agreement is reviewed on an annual basis and the operator has consistently been found to operate in good faith with the terms of the Zoning Agreement. The agreement establishes: a maximum number of beds in the City; minimum separation between facilities and other operators; operational regulations on offices, staff, vehicles, deliveries, smoking, trash, medical waste, quiet hours, etc.; inspections of the interior and exterior of all facilities by Code Enforcement; and abiding by Good Neighbor Policies. The Zoning Agreement has proven to work well for the City residents and the operator. It prevents overconcentration in neighborhoods and minimizes disturbances to adjacent residents. If impacts increase or change for some reason, there are action plans required to immediately address them, which are reviewed annually. The City also has a good relationship with other long-standing operators with conditional use permits or reasonable accommodations that went through a regulatory review process lawfully. Many of these operators have been in operation since 2008/2009 with very few complaints because there are conditions and regulations in place to address problems or disturbances. F11 There is a lack of regulatory oversight for the health and Partially The City partially disagrees with this finding because, to the extent allowed by State and safety of residents of unlicensed group homes. Disagree Federal law, the City does regulate "unlicensed" (i.e., non -State licensed) group homes. Specifically, the City does not permit unlicensed facilities within the single- and two -unit residential zoning districts and limits facilities within the multi -unit residential zoning districts. A reasonable accommodation may be requested to allow unlicensed facilities in all residential districts. However, the City acknowledges that there are significant limitations placed on the City that prohibit the City from ensuring "unlicensed" group homes are properly regulated to protect the health and safety of residents. The City is an advocate for the return of local control since the lack of regulatory oversight creates additional impacts to the community. 24-51 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 RECOMMENDATIONS ACTION SUMMARY/EXPLANATION (1-4 Below) R1 Orange County cities and the County of Orange should address 1 As recognized in the Grand Jury Report and as outlined in Finding 3, the City has had citizen concerns regarding group homes by providing an past success with town hall style meetings and continues to strive to keep residents opportunity for an open dialog where an interdisciplinary panel of informed regarding the topic of group homes. The City agrees it is especially important subject matter experts can share with attendees the challenges to educate residents about the importance of creating housing opportunities for all cities are facing in the management of group homes. To be segments of the community, the City's legal duty to affirmatively further fair housing, implemented by July 1, 2024. (F3, F4) and the constraints imposed by both State and Federal law with respect to local regulation. R2 By December 31, 2024, Orange County cities and the County of 4 As noted in the Grand Jury Report, the City was the first city in Orange County to Orange should collaborate in their efforts to create ordinances adopt a comprehensive ordinance addressing the issue of group homes. The City's for the regulation of group homes, including the development of ordinance has been working well and addresses the specific local issues that are model ordinances. (F6, F7, F9) applicable to the City of Newport Beach. Because each city has its own local issues, the City does not believe a one size fits all "model ordinance" approach is warranted. As noted in Finding 8, the City has committed to HCD that it will review its ordinance to determine if any updates are appropriate. In addition, the City is happy to share its ordinance as a model and collaborate with other cities needing assistance in their efforts to develop their ordinances. R3 Orange County cities and the County of Orange should pool 4 The City supports local control and has expended significant funds on lawsuits where resources for defense of lawsuits challenging group home the ability of cities to manage their own affairs are at issue, including, but not limited ordinances. To be implemented by July 1, 2024. (F6, F8, F9) to, the regulation of group homes. However, the City must make decisions on whether to participate in litigation involving issues of local control, including other cities regulation of group homes, on a case -by -case basis. While the City is open to collaborating with the County of Orange and other Orange County cities to obtain greater clarity in State and Federal law and to ensure that cities can exercise local control related to land use matters; the City will need to continue to evaluate litigation measures involving other cities on a case -by -case basis. R4 The County of Orange and Orange County cities should create a 3 The City is collaborating with the County of Orange and other Orange County cities. Task Force that includes representatives from OC cities, The City is working with the Sober Living Task Force, started by the City of Mission unincorporated areas, and other entities as appropriate and Viejo, and will be hosting the September 8"', 2023, meeting. charge it with the responsibility of developing a plan to generate Additionally, the City will leverage its existing relationships with State agency awareness among State legislators and regulators of the need representatives and State legislators to participate in the effort as well. for improved regulations and management standards to ensure health and safety for Group Home residents. To be implemented by July 1, 2024. (F2, F10, F11) R5 Orange County cities and the County of Orange should modify 4 The City collects information regarding code enforcement matters, while code enforcement report data collection forms to include a acknowledging that State and Federal laws require the City to respect the privacy searchable field that enables the identification of a residence rights of persons with disabilities. The City does not believe any further action is warranted; however, to the extent that the State maintains information related to State 24-52 Welcome to the Neighborhood - Are cities responsibly managing the integration of group homes? ORANGE COUNTY GRAND JURY 2022 RECOMMENDATIONS ACTION SUMMARY/EXPLANATION (1-4 Below) operating as a group home. To be implemented by July 1, 2024. licensed residential care facilities, the City will ensure that it informs the public about (F5, F7, F11) how to access this information on the City's website. The City believes it is important for the public to know which facilities are licensed by the State, rather than the City, and the process for addressing concerns regarding State regulated facilities. ACTIONS (1) The recommendation has been implemented, with a summary regarding the implemented action. (2) The recommendation has not yet been implemented, but will be implemented in the future, with a time frame for implementation. (3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a time frame for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This time frame shall not exceed six months from the date of publication of the Grand Jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor. 24-53