HomeMy WebLinkAbout00 - Written CommentsReceived After Agenda Printed
September 10, 2024
Written Comments
September 10, 2024, City Council Agenda Comments
The following comments on items on the Newport Beach City Council agenda are submitted by:
Jim Mosher ( jimmosherC@yahoo.com ), 2210 Private Road, Newport Beach 92660 (949-548-6229)
Item 1. Minutes for the August 27, 2024 City Council Meeting
The passages shown in italics below are from the draft minutes with suggested corrections
shown in st#ikeeu underline format. The page numbers refer to Volume 66.
Page 154, paragraph 1: "Jim Mosher questioned the transparency of who and how many
staff members would be receiving a bonus in Item 4 (Side Letter Agreements with Labor
Groups Representing City Employees), voiced concern about the message being sent to the
public about drinking alcohol on the beach in Item 5 (Waiving Council Policy B-8, and Section
A.1 of Council Policy B-13 to Permit an Annual Charity Volleyball Tournament and To Allow
for Alcoholic Beverages on a City Beach), and public education about waste management
programs and the validity of green waste diversion statistics in Item 20 (Response to the
Recommendations of the Orange County Grand Jury Report "Talking Trash: Recyclables and
Organic Waste')."
Comment: The minutes omit my opening remark about the difficulty of the public
commenting on 21 separate consent calendar items in a single 3-minute minute statement —
which is the primary reason I submit written comments in advance of the meeting. Although
not reflected in the minutes, in my August 27 remark, I mentioned (again) the City of Benecia
where, for the edification of both the Council and the public, the mayor reads the agenda title
of each consent calendar item before inviting requests for individual discussion of any of
them. See, for example, the video of the most recent mayor's reading of the consent
calendar from their September 3 meeting,' followed by his invitation to members of the
council and public to pull items for discussion.
Page 159, Item 12, paragraph 3: "Bill Gromes-ki Grabowski expressed his dissatisfaction
with and opposition to the proposed surf park and asked to not approve the project."
Page 161, paragraph 3 from end: "Jim Mosher inquired about the ratio of Be Well
fepfesentatives calls helping the general Newport Beach population to the homeless
population and asked if tithe ordinance makes it legal to sHew.allows people to sleep on
the grass during the day and move at night or if it is prohibited by another law." [see video]
Page 162, paragraph 8, next to last sentence: "She supported the police department and an
alternative policing regimen regimen, allocating resources to -for the new team, focusing on
quality of life and street exits, and beginning in-house prosecution."
Page 162, paragraph 9: "Councilmember Avery noted this issue is his number one
disappointment, the importance of public input, and the City needs to deuble redouble its
efforts and quickly."
' As I also noted, the city council in Benecia is scheduled to meet three times a month, on the 1st, 2nd
and 4th Tuesday, although they don't always do so. I misstated that they meet weekly, as the Council in
Santa Barbara does (with exceptions) per Section 506 of their charter.
September 10, 2024, City Council agenda comments - Jim Mosher Page 2 of 7
Item 3. Ordinance No. 2024-20: Adding Chapter 5.98 (Acceptance of
Cash by Brick -and -Mortar Businesses) to the Newport Beach
Municipal Code
As I have commented many times, introducing and then adopting ordinances on the consent
calendar, without Council discussion and with minimal public awareness, seems like a poor
practice (see contrasting comment about the City of Benecia under Item 1, above).
And this one seems particularly odd coming from a Council that generally seems to believe
cities should impose minimal restrictions on businesses. For consistency between jurisdictions,
don't the rules governing processing transactions seem like a matter that should be dealt with
on a statewide or national level?
Additionally, the staff report does not address any possible negative consequences of adopting
the measure, including real concerns about crime surrounding the accumulation and handling of
cash which this requires of business owners.
The Loomis armored car company, which naturally has an interest in promoting cash
transactions, maintains a database of Pro -Cash Legislation. As of October 2023, they were
aware of only two other California cities requiring acceptance of cash transactions: San
Francisco (with Ordinance No. 100-19 in 2019) and West Hollywood (with Ordinance No.
19-1085, also in 209).
The West Hollywood version has no exceptions as to kinds of business or size of transaction
other than that business people are not required to accept denominations larger than $100.
The proposed ordinance appears similar to the San Francisco one in its findings and structure,
although some of the detailed rules are different. For example, our Council is being asked to
substitute a $50 denomination limit in place of San Francisco's $20 bill limit. Additionally, San
Francisco, with a more limited "Professional Services" exception, requires medical and dental
providers to accept cash. Since the source' of the proposed code is not revealed, the reasons
for these differences are not explained in the staff report.
I might observe that the proposed exception for single transactions over $5,000, identical in
wording to the San Francisco ordinance, makes little sense to me. The purported purpose of the
legislation is to empower consumers with no means to pay other than cash. But as illustrated in
the example provided in the San Francisco code (but not copied into ours), for a $7,500
purchase, the code requires a merchant to accept the first $5,000 in cash, but allows them to
refuse cash for the amount over $5,000. That means the only consumers who can complete the
transaction will be those with a non -cash means of payment. If so, why not require them to pay
the full amount that way, and avoid forcing the merchant to handle and store $5,000 in cash?
2 SB-926, co-authored by California state Senator Scott Wiener in 2020, who the Council in the past has
cited as an author of bad ideas, and banning refusal to accept cash at retail stores statewide, died in
committee.
3 Since I have not reviewed the other ordinances in the Loomis database, I do not know if the present
proposal was "borrowed" from a jurisdiction other than San Francisco.
September 10, 2024, City Council agenda comments - Jim Mosher Page 3 of 7
It would seem that if the intent is to empower cash -only consumers, there should be no limit on
the size of the transaction. Otherwise, they remain unable to participate in the larger purchases.
I might also note that although they would already be excluded as not providing services at a
permanent fixed location, City staff has found it important to include an exception for "services
provided at a person's residence, such as, construction, home repair, plumbing, cleaning, and
landscaping, or professional services." While I don't understand the theory under which those
would not have to accept cash, while the others would, I believe "person's residence" should be
"customer's residence," since it is unclear if the "person" referred to is the service provider or
the consumer.
I would additionally note that in its otherwise very similar definitions, San Francisco has
switched from the older, stuffier "shall mean" construction to the more concise and accurate
"means." I thought Newport Beach had made that switch in recently -adopted codes, as well,
and am disappointed to see it regressing.
Finally, I would note that San Francisco capitalizes defined words, such as "Brick -and -Mortar
Business," Cash" and Professional Services" when they appear in the code. That would seem a
useful practice for Newport Beach to adopt. Without it, readers cannot tell if they are
encountering a specially -defined word, or not.
Item 4. Ordinance No. 2024-18: Approving a Development Agreement
for the Residences at 1600 Dove Street (PA2022-0297)
The entitlements proposed to be protected by this Development Agreement were adopted
without much discussion at the August 27 meetings.
I previously commented that the Greenlight implications of adding 49 dwelling units not
previously allowed by the General Plan were not clearly disclosed, but instead relegated to a
May 23, 2024, Planning Commission staff report (page 22-182 of the August 27 Council staff
report). The 49 units were, in fact, all the Council could approve in statistical area L4 without a
vote of the electorate in view of the previous approval of the same applicant's request to add 64
units to its 1400 Bristol Street project. And with the Charter Section 423's 80% of previous
approvals rule, there will now be only 9 more units the Council is free to add to the Airport Area.
The pending approval without a public vote of a 2,577-unit Airport Area Environs residential
overlay (mostly in statistical area L4, but partially in other areas) will, of course, muddy that
calculation.
Although discussed in the staff report, there also seemed insufficient discussion of the proposed
extremely high density (for Newport Beach) seeking to be entitled, which was also relegated to
the prior Planning Commission staff report (see bottom of page 22-184). As indicated there, the
"planned" community in which this project would be built anticipates residential densities of 30 to
50 dwelling units per acre. The pending Airport Area Environs overlay would not increase the
upper limit, and would, indeed, allow densities as low as 20 du/ac. Density bonus units, by
definition, are offered in excess of the maximum density allowed by the code. But in this case,
even without considering the bonus units, the applicant is proposing to convert enough existing
office space to create a density of 55.8 du/ac, Waiving the code upper limit to allow both that
and adding the 49 extra base units raises the density to 75.5 du/ac, and then allowing the
September 10, 2024, City Council agenda comments - Jim Mosher Page 4 of 7
density bonus ends up with 113 du/ac. Allowing 113 du/ac where just 50 du/ac (75 with 50%
bonus units) was planned seems rather extreme. It caused one Planning COmmissioner to vote
"no," and may have provoked discussion by the Council if it had been more clearly disclosed.
Additionally, as I pointed out on August 27, this development agreement would be guaranteeing
a project that far too few affordable units to meet the Council's goal of entitling 2,707 units
through the addition of just 8.174 total base units to our General Plan. That requires 33% of
approved base units to be affordable. Here, with just 28 of 188 base units promised to be
affordable, we have just 15%.
Finally, there was no clear disclosure of how the public benefit fees associated with this
development agreement compare to the development impact fees discussed at the August 27
study session. One would think that to secure the additional privileges and guarantees of a
development agreement, a payment larger than the normal impact fees would be required. Will
this agreement generate more or less revenue than would have been generated without it?
For all these reasons, the Council may wish to rethink its support of this agreemen.
Item 5. Ordinance No. 2024-19: Amending Chapter 10.08 (Interference
with Public Access), Chapter 10.14 (Prohibition Against Camping in
Public Places), and Section 11.04.070 (Prohibited Conduct) of Chapter
11.04 (Parks, Park Facilities, and Beaches) of the Newport Beach
Municipal Code
At the August 27 meeting where this ordinance was introduced, I asked if it would allow a
person without money for lodging to exist in Newport Beach by sleeping (next to their
possessions) during the day on the grass in a public park and staying moving (with their
possessions) during the night. I did not receive an answer.
I guessed we could not make it illegal to be without a place of lodging, and surmised this might
be an option for a person without one. That was based on "open grass areas" being excluded
from the definition of ""Landscaped area" (staff report page 5-7) where sleeping is prohibited
(page 5-9), and the definition of "Unattended" (page 5-8) not seeming to require the person
claiming ownership of property to be awake (albeit they have to be present).
Item 7. Resolution No. 2024-67: Supporting Proposition 36, the
Homelessness, Drug Addiction, and Theft Reduction Act
It is good, and presumably non -controversial, to see that our City Council wants to reduce
homelessness, drug addiction, and theft.
However, the resolution supporting a proposition on the November 2024 ballot which it seems to
think will accomplish those goals, seems oddly disconnected from the election itself, both
because those goals do not seem things one can ensure through legislation and because no
proposition with such a title is expected to appear on the ballot.
September 10, 2024, City Council agenda comments - Jim Mosher Page 5 of 7
Instead, I find a Proposition 36 whose official title is "Allows Felony Charges and Increases
Sentences for Certain Drug and Theft Crimes." That seems more reasonable, since one can,
by legislation, define the charges and sentences associated with crimes.
The idea that creating felony charges for certain drug and theft crimes and increasing the
sentences imposed upon conviction will reduce homelessness, drug addiction, and theft seems
pure speculation. Indeed, I am unable to find anything about "homelessness" or "addiction" in
the official analvsis.
The alternative, and much more far-reaching, title seems to come, along with arguments in the
measures favor, from the proponents' petition. Indeed, Section 1 of the petition says "This Act
shall be known as The Homelessness, Drug Addiction, and Theft Reduction Act."
But that is proposed as an uncodified section, and as I understand it, laws are interpreted to do
what they say, not what is said about them. While the word "addiction" occurs a few times in the
codified text, "homelessness" does not, other than in the proposed Government Code
Subsection 7599.200(a): "This section shall be known as "Funding for the Homelessness, Drug
Addiction, and Theft Reduction Act."
I suppose it is the prerogative of proponents to pick whatever title they want for their petitions.
But why not call it something so good sounding that even fewer voters would ask for details,
such as the "Make America Safe for Babies Act"?
Item 9. Resolution No. 2024-69: Creating the Human Capital and
Compensation Ad Hoc Committee
I don't believe it's a good idea to form these ad hoc committees that meet privately and produce
recommendations, generally rubber-stamped by the rest of the Council, based on information
from unknown sources and of unknown accuracy,
That said, it is good to see staff seems to be attempting to be more transparent about their
creation in comparison to the recent past when the recommendations of "Council working
groups" were announced without who created the working group, or what it was tasked with,
ever being explained.'
It might be noted these are now being created at a rate making it difficult for the City Clerk to
keep track of which currently exist and which have terminated. Under "II. Council Committees"
on the current Boards, Commissions and Committees page the Clerk lists (without further
details) a "Ad Hoc Committee on Homeless Task Force," a "Ad Hoc Municipal Code and
Council Policy Review Committee" and a "Ad Hoc Residential Care Facilities Committee."
While under the same title, the Roster of Boards, Commissions and Committees lists (with more
information and membership) a "Ad Hoc Transit, Transportation, Parking and Mobility City
Council Committee," a "Destination Marketing Services Ad Hoc Committee" and a "Lower
Castaways Park Ad Hoc Committee."
' This still seems to be the case with development agreements and other matters where Council members
will announce they participated in the negotiation, with no record of any publicly -announced authority for
them to do so.
September 10, 2024, City Council agenda comments - Jim Mosher Page 6 of 7
The absence of overlap between the two lists is a bit troubling, and leaves one wondering if
there are more or less than the ones listed. For example, at the August 27, 2024, Council
meeting, it was unclear if Item 24 (Homeless Outreach Services Biannual Update) included
concluding recommendations from the Ad Hoc Committee on Homeless Task Force (assuming it
still exists), and if it did, whether it has concluded its deliberations or will be continuing as a
standing committee (in which case, all its meetings should be noticed and open to the public).
The other disturbing trend is some of these ad hoc Council committees appear to end their
stated terms without providing any recommendation.
Item 14. City Hall and Limited Off -Site Holiday Closure (Beginning
Tuesday, December 24, 2024, Through Wednesday, January 1, 2025)
My recollection is these holiday closures originated because a former City Manager wanted to
have a week in which he didn't have to worry about managing City employees.
Even if their bargaining units acquiesce to this, I don't think it's fair to force employees to use
their personal time off at a particular time of year. I also don't think it's fair to residents and
businesses to have City services inaccessible. I think continuing to operate with a reduced
workforce would be preferable.
Additionally, a review of the Council meetings archive will reveal that prior to about 1985, the
Council, also, did not seem to feel a need to take off the last weeks of the year.
Item 15. Dismissal of a Civil Service Board Member
It is strange that City staff would have lost contact with this person appointed as part of Item 20
on June 27, 2023. 1 hope she is well, but also that the announcement of an unscheduled
vacancy will result in more applications than were previously received (with only three having
been available according to the draft minutes5 of the June 5, 2023, Civil Service Board meeting).
Although it is of limited relevance to the present agenda item, I might note that this board is
somewhat misnamed. I believe that based on its name, some of the applicants assume its
purview is limited to issues affecting the City's civil service employees, which are basically only
our sworn safety officers. However, City Charter Section 711 (Civil Service Board - Powers and
Duties) assigns to it a much broader scope. In addition to recommending changes to the civil
service rules and regulations, it is supposed to advise the Council "on problems concerning
personnel administration" (not necessarily confined to civil service employees), "Receive and
hear appeals submitted by any person employed by the City' (with its decisions final as to civil
service employees, but not as to others), and "Make any investigation concerning the
administration of personnel in the municipal service" when requested by the Council, City
Manager or any City employees association. In the years I have watched its activities, I have
never seen the Board receive an appeal from anyone other than a civil service employee, nor
conduct any investigation. That makes me think these Charter -assigned powers and duties
overseeing our non -Civil Service employees may not be widely known.
5 Approved minutes of the June 5, 2023, meeting do not seem to have been posted.
September 10, 2024, City Council agenda comments - Jim Mosher Page 7 of 7
Item 17. Ordinance No. 2024-21: Amending Title 21 of the Newport
Beach Municipal Code to Update Density Bonus Regulations to
Comply with State Law (PA2020-032)
Our Mayor, who is proud of the claim that the number of words in the Municipal Code has been
reduced rather than expanded during his time on Council, may be pleased that the Council's
August 23, 2022, request to the California Coastal Commission for permission to add over 7,000
words6 to Title 21 (mostly copying the obsolete words in Chapter 20.32), has been reduced to
an addition of under 400 words, confined to describing the special treatment of density bonus
applications in the City's coastal zone.
It may be less evident from the current staff report and the record of the April 12, 2024, CCC
meeting, where this matter was heard, that the suggested reduction in length was
recommended in a CCC staff addendum responding to correspondence received from a certain
resident of Newport Beach.
One might wonder if the lengthy Chapter 20.32 might benefit from similar treatment, rather than
yet another round of amendments and additions in late fall, as the current staff report suggests
may happen. Chapter 20.32 was last considered for amendment as Item 19 at the same August
23, 2022, meeting where the original Title 21 addition was proposed (and where a similar
comment was made by the same resident). In my comment on Item 10 on the July 26, 2022,
Council agenda, I observed that in 2020, City staff itself had suggested shortening the code by
deferring to state law without attempting to restate it.
s 7,319 is the word count of a plain text print-out of NBMC Chapter 20.32, which is similar to the originally
proposed Chapter 21.32. Part of that is likely to be a count of numbers rather than words. It also seems to
differ from earlier estimates for reasons unclear to me. But whatever the correct count, the proposal was
to add a lot of words to Title 21.