HomeMy WebLinkAbout20 - Code Enforcement & Intense Residential OccupanciesCITY OF NEWPORT BEACH
CITY COUNCIL STAFF REPORT
Agenda Item No. go
July 10, 2007
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: City Manager's Office
Homer Bludau, City Manager
949/644 -3000 or hbludau @city.newport - beach.ca.us
SUBJECT: Code Enforcement and Intense Residential Occupancies (IROs)
ISSUE:
Should the City's approach to Code Enforcement change given greater intensities of residential
occupancies in our communities, including boarding houses masquerading as sober living
homes and some group homes that may need licensing but do not have it?
RECOMMENDATION:
1. Offer direction to the City Manager regarding his suggested approach to Code Enforcement
and intense residential occupancies (IROs); and
2. Approve proposed amendments to Council Policy K -9 (Code Enforcement) reflecting
changes in Code Enforcement's approach to neighborhood nuisances and Building and
Zoning Code violations.
DISCUSSION:
Parts of Newport Beach have long been characterized by homes, including duplexes, in close
proximity to each other. Setbacks are small, sometimes only 3', and properties are long and
narrow. West Newport is especially known for these types of residences. These same
neighborhoods have tended to attract a more transient population — renters who are college
students, recently out of college, and /or who desire a less serene living environment. At the
same time, many families share the neighborhood, both because of its relative affordability and
its proximity to the beach. Many long -time residents "put up with" the random loud party or late
night noise because they enjoy the vibrancy of the area.
Further, even long -time residents may move out of their homes in the summer and rent them
out for weekly accommodations. These "short -term occupancies" are governed by the City's
short -term lodging permits.
In recent years, three new uses have found their way to West Newport, the Balboa Peninsula,
and other areas of the community. These are:
1. Residential Treatment Facilities licensed by the California Department of Alcohol and
Drug Programs (DADP), where one of five different types of drug or alcohol rehabilitation
is being offered on -site. These five rehabilitation services are:
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 2
(a)
Detoxification;
(b)
1 -on -1 Counseling;
(c)
Group Counseling;
(d)
Treatment Planning; and
(e)
Educational Sessions.
DADP records (as of April 10, 2007) show that there are 24 DADP - licensed facilities in
Newport Beach, including 7 with more than 7 residents, 15 with six or fewer residents,
and two with no residents (the latter are outpatient medical offices).
2. Sober Living Homes, where individuals agree to live together in a sober environment,
sometimes under some supervision by a home manager, but where none of the five
rehab services are offered (if one or more of the 5 services are offered, then the home
needs a DADP license). We do not know how many unlicensed (unlicensed by DADP)
sober living homes are in Newport Beach - they are not required to register with us.
3. Boarding Houses, where individuals live together — not necessarily in a sober
environment — and individually pay rent to a landlord. Our code defines Boarding or
Rooming Homes as a residence or dwelling unit, or part thereof, wherein two or more
rooms are rented under two or more separate written or oral rental agreements, leases
or subleases or combination thereof, whether or not the owner, agent or rental manager
resides within the residence (NBMC §20.05.030). Boarding or Rooming Houses are
prohibited in all of Newport Beach's residential land use districts (NBMC §20.20.020).
Each of these three uses, separate from the traditional party house or short-term occupancy
use, brings about some code enforcement challenges. These include:
• Determining if a sober living home is actually providing rehabilitative services, thereby
needing a DADP license.
• Determining if a boarding house is masquerading as a sober living home or residential
treatment facility, therefore attempting to remain in a residential district illegally.
In addition to these potential code violations, we see the following code enforcement issues in
many IROs:
• Illegal construction (construction without permits, especially interior walls, doors,
windows, kitchens, bathrooms);
• Illegal dwelling units (creating a habitable 2ntl, 3'', or 4`" dwelling unit where one is not
allowed under the property's zoning);
• Operation of a home -based business without a residential business license or permit;
• Trash — left in alleys, overflowing cans, cans without lids, infrequent pickup that does not
meet the demand of the number of residents in the household; commercial service in a
residential neighborhood, cigarette butts left in curbs, gutters, sidewalks, planters;
• Crowded side setbacks, limiting or prohibiting the ability of emergency personnel to
access a back bedroom in the event of an emergency;
• Parking —for facility staff, residents (though many residents of some facilities have lost
their drivers licenses and instead use bicycles), house managers;
• Garages — because they are being used for storage, garages are often unable to
accommodate the parking required under the Code;
• Secondhand smoke — neighbors have complained about excessive secondhand smoke
from IRO residents. No NBMC provision gives adjacent residents any recourse in this
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 3
matter, except to shut windows and doors or to attempt to work with IRO residents to
limit smoking;
Profanity — neighbors have complained about excessive swearing or lewd speech by
IRO residents;
Noise — while party houses may be noisy on Friday and Saturday nights, neighbors
adjacent to IROs say that all hours of the day and night may be noisy at an IRO — with
loud music, loud profane speech, and more;
Transportation and Deliveries. Some IROs centralized transit by picking up and
dropping off IRO residents frequently. IROs can also have deliveries throughout the day
that a typical business would have — delivering medicines, meals, and laundry.
These problems can be compounded by the transitory nature of IRO residents — some residents
stay less than a week. Few stay more than 2 -3 months. New residents are constantly being
rotated in and out of facilities. Unless house rules are enforced regularly — assuming an IRO
has house rules — then neighbors adjacent to IROs have to keep contacting house managers to
complain about IRO residents' behavior.
Another change we can see coming involves short-term lodgings. As the Council is aware, we
will soon bring forward a code amendment on short-term lodging regulations. The amendment
will include additional operational conditions on these lodgings, including occupancy limits.
Code Enforcement will be obligated to address these when they are adopted.
Newport Beach's Code Enforcement Philosophy & History. Our Code Enforcement philosophy
is summarized within Council Policy K -9 (Code Enforcement) — generally:
• We don't initiate actions based solely on an anonymous complaint.
• Inspections on private property (other than what can be seen from the public right -of-
way) are not made unless there is sufficient evidence to support the issuance of an
inspection warrant.
• Complaints must be in writing, identify the reporting party, and state relevant facts.
• Complaints are considered to be confidential, with limited or no disclosure of the
reporting party's name.
• All Code Enforcement actions are done "such that the civil rights of the individual or
individuals who are the subject of the investigation are fully protected."
Generally, we only respond to private property code issues after a written complaint. There are
a few exceptions to that rule, however — illegal signs and banners, illegal vending,
encroachments into rights -of -way, observed water quality violations, and more. But an entire
neighborhood will not get a review of hedge opacity when a dispute arises with two properties.
Another aspect of our philosophy — not written in Council Policy K -9 — has been (generally) to be
more compassionate than aggressive in the case of individual homeowners or businesses that
seem to have put forth a good faith effort to resolve an issue. This manifests itself in, for
instance, a 30 -day grace period for correction of a violation instead of a 7 -day period. And
sometimes in an extension to that 30 -day period if the person is genuinely trying to remedy the
problem. Or in the issuance of a "Notice of Violation" (with no fine attached) for a first -time
offender. Or with a "Knock and Talk" for a business owner who may not have known to tell her
awning washers to use a recovery system for their wash water to protect the Bay.
As to staffing, as recently as 2002 -03, the City had two code enforcement officers. They
reported to the Planning Director. But when regional water quality regulations changed in
advance of Fiscal Year 2003 -04, the City increased its level of water quality education,
Cade Enforcement and Intense Residential Occupancies
July 10, 2007
Page 4
inspection, and enforcement. At the start of FY 03 -04, we created a new Code and Water
Quality Enforcement Division (reporting to the two Assistant City Managers) — the Division is
responsible for activities like:
• Enforcement of the City's Municipal Code, including planning, zoning, business license,
signage, refuse, noise, and water quality regulations;
• Defending violations before hearing officers and/or the courts;
• Compliance with the National Pollutant Discharge Elimination System's (NPDES)
reporting requirements, legal responsibilities, and meeting mandates, including field
inspections of City facilities, residential, commercial, and industrial properties, and public
works projects to ensure protection of water quality; and
• Administration of the City's urban runoff reduction plans, including water conservation.
The Code and Water Quality Enforcement Team today consists of:
• Code and Water Quality Enforcement Division Manager John Kappeler
• Code and Water Quality Enforcement Officer Cass Spence
• Code and Water Quality Enforcement Officer Shane Burckle
• Code and Water Quality Enforcement Officer Matt Cosylion
• Code and Water Quality Enforcement Officer Shannon Swafford
• Water Conservation Coordinator (vacant)
Going Forward. As noted in this staff report, IROs have brought a new dynamic to Newport
Beach. The City Manager believes that it's time, too, that Code Enforcement change its
philosophy to address the problems that can come with IROs. It is important to note that no
Code Enforcement action can be applied in a discriminatory manner. Therefore, to assure the
same fairness that Council Policy K -9 provides, this philosophy needs to apply to all IROs and
citywide. The new recommended philosophy is as follows:
• Severely limiting grace periods, and further limiting extensions;
• Requiring an appointment for an inspection set for the day the grace period ends;
• Issuing citations daily and on each violation, if appropriate, to ensure faster compliance;
• Increasing the monetary fines for illegal construction and illegal dwelling units;
• Use of civil court processes for illegal construction and illegal dwelling units;
• Having the option to act on an anonymous complaint;
• A more active use of Nuisance provisions in NBMC §10.50.020 (see attachments);
In addition to the above, the City Manager proposes that the City designate resources and staff
to the IRO issue in a more comprehensive, coordinated way. This would be done under the
specific direction of his office to assure organization -wide impact to our effort. At least initially,
Assistant City Manager Dave Kiff will be assigned a lead position to be assisted by contract
Code Enforcement staff, contract Special Counsel, and existing City staff. The IRO Team would
do the following:
1. Fairly and proactively implement the new regulations for all IROs via a comprehensive, code
enforcement -based investigative approach using the philosophy noted above.
2. Review and enforce all conditions of approval for IROs on any CUP or similar permit.
3. Serve as a liaison for affected residents, including being the focal point for all residents'
inquiries. Gather needed information to respond to inquiries on a timely basis in as factual
and candid a manner as possible.
4. Convene and direct the City's inter - departmental effort to coordinate IRO actions.
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 5
5. Serve as liaison to other entities, including DADP, IRO operators or managers, County
probation, and more.
6. Exchange best practices ideas with other jurisdictions impacted by IROs.
7. Consult with special counsel on implementation actions.
8. Brief the City Council as requested on actions /challenges.
9. Other duties as needed.
Organizationally, the division of duties between traditional code and water quality enforcement
and special attention given to IROs would look like this:
Assistant City Manager Kiff
Contract Code Enforcement
+help as needed from C &WOE ------
Contract Special Counsei
I
Liaison Groups
Fire, PD, Building, Impacted residents,
Planning, C &WQE, IRO managers,
City Attorney Reaulat m(DADP)
Assistant City Manager Wood
Code & WOE Division Mgr Kappeler
4 C &WO Enforcement Officers
To accomplish this effectively, Mr. Kiff will have to shed or defer doing many of the things he
does today. Where possible, his tasks will be re- assigned to others on a short -term basis.
Hopefully, after time, this process will become more effectively managed and the problems
associated with our IROs will lessen. At that time, I will consider re- assigning Mr. Kiff back to
other efforts. He believes he can be successful and accomplish the community's goals here,
and I trust that he has the commitment, knowledge, and background to do that.
Environmental Review: Council's approval of this item does not require environmental review.
Public Notice: This agenda item has been noticed according to the Brown Act (72 hours in
advance of the public meeting at which the City Council considers the item).
Funding Availability: Council approved $100,000 in start -up funds ($50,000 for contract code
enforcement and $50,000 for special legal counsel) for this effort within the FY 2007 -08 budget.
Submitted by:
Prepared by:
L4'Wl�� Z]fw�!� L [t
Homer Bludau Dav ff
City Manager Assistant City Manager
Attachments: Council Policy K -9 (as proposed to be amended) & NBMC on Nuisances
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 6
COUNCIL POLICY K -9
CODE ENFORCEMENT
PURPOSE
The City of Newport Beach devotes substantial resources to the enforcement of 961Iding,
MURiGipal and Z^n 4 ;9its - Ordinances. R �ldi g and Zon:ng -The City's Ordinances are intended
to protect and preserve public health and safety, the charm of our residential neighborhoods,
and the overall quality of life enjoyed by Newport Beach residents. The City Council
understands the importance of enforcing our Ordinances and is committed
to doing so. However, enforcement of these Ordinances affects the rights of these citizens who
are the subject of complaints or enforcement actions. Accordingly, the City Council directs that
all code enforcement activity shall be conducted in accordance with the following:
A. The City shai]- netmay initiate anj-a formal code enforcement action based °^,fin
anonymous GOFnplai4t
on any of the following:
• An enforcement officer's observation
• A written complaint:
• A complaint from an individual that an enforcement officer deems reliable.
B. Requests for inspections of private property not open to the general public or not visible
from adjoining public or private property shall not be made unless there is sufficient
evidence to support the issuance of an inspection warrant for the property that is the subject
of the request.
C. Written cGode enforcement complaints shall be made .^ ,.,:, ^^ and identify the
complainant, specific facts, acts, or events and occurrences which establish the violation
and describe any documentation which would establish a violation or is otherwise required
bylaw;
D. The City considers wxit48R code enforcement complaints to be confidential. The City will use
its best efforts to preserve the confidentiality of any complaint with the understanding that
the City will be required to disclose the identity of the complainant to the extent necessary- #e
obtain required by law;
E. All code enforcement activities, including investigative property inspections, requests for
consent to inspect, and related activities shall be conducted such that the civil rights of the
individual or individuals who are the subject of the investigation are fully protected; and
F. The City Council believes that nuisance -type violations (such as noise, trash violations, fire
Officers are encouraged to pursue violations aggressively with limited grace periods for
compliance, limited use of authorization of additional time after a grace period closes, and
criminal penalty authorizations: and
;=G. The provisions of this Policy do not apply to inspections of property requested by the
owner or to inspections conducted by the Building Department personnel pursuant to
construction being conducted, which is authorized, pursuant to an active permit issued by
the Building Department.
Adopted - June 26, 1995
Amended - October 10, 2006
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 7
NBMC §10.50.020
Nuisances
It is unlawful and a public nuisance for any person owning, leasing, occupying or having charge or
possession of any property in the City, to maintain, permit, cause or allow to exist on such premises, any
of the following conditions:
A. A fire hazard including but not limited to, any cut or uncut shrub, tree, grass, weeds, vines or other
vegetation; combustible refuse or waste; or other flammable material which by reason of its size, manner
of growth or location, constitutes a fire hazard to any structure, improvement or landscaping;
B. Any swimming pool, spa, pond, fountain or other body of water which is allowed to become stagnant,
unsanitary or unsafe or does not comply with the provisions of Chapter 15.09 of Newport Beach Municipal
Code;
C. The accumulation or storage of automobile parts, rubbish, trash, debris, rubble, broken -up asphalt,
lumber, concrete, plaster, tile, rocks, bricks, building materials, crates, cartons, containers, boxes, scrap
metal, trimmings from plants and trees, cans, bottles and barrels,
D. Vegetation, including but not limited to, trees, shrubbery, grass and plants which is overgrown, dead,
decayed or diseased such that it may:
1. Impede or present a danger to pedestrian or vehicular traffic,
2. Interfere with visibility on, or free use of, or access to, any portion of any public sidewalk, street, alley
or right -of -way, or
3. Harbor rats, vermin, insects and other situations likely to cause a hazard to the public safety;
E. Unsafe, unsightly, or poorly maintained property including but not limited to:
1. Storage or accumulation of household items, except furniture designed for outdoor use, barbecues
and plants, on patios, roofs, balconies, and in yards in such a manner as to be visible from a public
street, alley, sidewalk or other public right -of -way,
2. Private driveways or walkways maintained in an unsafe condition which create a hazard to
pedestrians,
3. Outside storage of any whitegoods, whether operable or not, in any area accessible to children who
are not under the care and supervision of the owner or person in charge of the property,
4. Broken windows, or doors,
5. The failure to secure and maintain from public access all doorways, or other openings into vacant or
abandoned buildings or structures,
6. Buildings or structures which are partially destroyed, partially repaired, abandoned or which remain in
the state of partial construction or disrepair for more than three months, unless the construction and
repairs are being accomplished pursuant to an active, open building permit.
7. Buildings, walls, fences or structures upon which the condition of the paint or exterior finish has
become so deteriorated as to permit decay, excessive cracking, peeling, chalking, dry rot, warping or
termite infestation,
8. Any front yard or landscaped setback area which, due to the lack of turf, other planted material,
decorative rock, bark or planted groundcover or covering causes excessive dust or allows the
accumulation of debris,
9. Landscaping, grounds, walls, fences, driveways, parking lots, irrigation systems, or sidewalks which
are maintained in such a condition so as to become defective, unsightly or unsafe,
10. Deteriorated parking lots, including those containing potholes, cracks, ponds or ridges,
11. Accumulations of grease, oil or other hazardous material on paved or unpaved surfaces, driveways,
buildings, walls, or fences, or from which any such material flows or seeps onto any public street,
sidewalk, alleyway, or other public or private right -of -way, and
12. The use of materials other than glass (or other rigid transparent or semitransparent material designed
for permanent installation in a structure) as a replacement or covering of window panes;
Code Enforcement and Intense Residential Occupancies
July 10, 2007
Page 8
F. The existence of any unlawful encroachment including signs, play equipment, trash or vegetation,
which obstructs or interferes with the free passage or use by the public, of any public sidewalk, street,
alley, beach, or other public right -of -way, or which may impede emergency access;
G. The use of any machinery or equipment which because of noise, odor, vibration, fumes or discharge
constitutes a health or safety hazard;
H. A violation of any of the terms or conditions of a use permit granted by the City of Newport Beach
I. A violation of any provision of the Newport Beach Municipal Code,
J. The parking or storage of any vehicle in the required front yard setback on private property other than
in a garage, carport or paved driveway leading to the garage or carport,
K. Repetitive, boisterous or unruly conduct by the owner or occupants of the property that occurs on the
property when that conduct: (1) is offensive to a person of ordinary sensibility; (2) continues after a written
or oral request to terminate the conduct; (3) is offensive to a considerable number of people; and (4) in
the opinion of the Enforcement Officer, results in any of the impacts described in Section 10.50.010 of this
chapter.
BANNAN, GREEN, FBANH & TERZIAN LLP
RFCIFIVED 555 SOUTH FLOWER YSTREET. A SUITE 2700
LOS ANGELES, CALIFORNIA 90071 �'RECEiV D A ER AGENDA
2107 JUL 10 PH 1- 40 TELEPHONE (213) 362 -1177 y O
FACSIMILE (213) 362 -1ISS PRINTED!'
- w .bgftlawxom
July 10, 2007
HAND DELIVERY
Honorable City Council
City Hall
3300 Newport Blvd.
Newport Beach, CA 92663
Re: Meetine of July 10, 2007; Agenda Item 20
Honorable Mayor and Members of the Council:
This firm represents Sober Living By The Sea ( "SLBTS ") which is a long -term
community based operator of facilities in Newport Beach for treatment and recovery of
persons suffering from alcohol and drug abuse. The purpose of this letter is to comment
on Item 20 on the July 10, 2007 Agenda relating to code enforcement for intense
residential occupancies ( "IROs ").
We have reviewed the staff report and recommendation on this item and generally
applaud the concept of resolving any issues raised by IROs through code enforcement.
My client has previously recommended this solution as a means of resolving complaints
against operations in such facilities for some time, most recently in the submission by C.
Edward Dilkes, Esq. to the Council on May 30, 2007.
However, we are troubled by several aspects of the recommendation. Although
there is a general reference to other types of facilities, the staff report appears to focus on
facilities licensed by the State Department of Alcohol and Drug Programs ( "ADP ") and
sober living facilities which need not be so licensed. It appears to us that most of the
problems described in the report, primarily related to loud noises and parties, apply to
other types of uses arising out of short term residential rentals to persons who are not in
any type of treatment or recovery. Every one of the complaints of the types of activities
described in the report can apply equally to non -IROs. Yet it appears that the intention of
the proposed program is to seek discovery of violations by ADP- licensed facilities and
unlicensed sober living homes. We believe that such an approach would not only be
discriminatory, and thus in violation of state and federal fair housing laws, we further
believe that it would be specifically violative of Health and Safety Code Section
11834.23 with respect to ADP - licensed facilities which require that they be treated the
same as single - family residences.
Honorable Mayor and
City Council
July 10, 2007
Page 2
It would be appropriate if similar efforts were to be aimed at resolving similar
complaints arising from the residents of single - family homes. But it appears that this is
not the case and that all this added effort will be focused on a single group of residences,
which by law must be treated as single - family residences, for the apparent purpose of
making it as difficult and expensive as possible to operate.
We are also concerned with what appears to be a proposed intrusion by city code
enforcement personnel on the nature and extent of treatment provided at ADP - licensed
facilities. Those facilities are to provide treatment in accordance with state law and ADP
regulations subject to ADP - licensure conditions. Only the ADP may enforce this state
law and license conditions.
It would appear from this report and recommendation that the resources of the
City are being mobilized and deployed in the guise of enforcing municipal ordinances but
with the underlying intent of applying those efforts in a discriminatory fashion for the
purpose of discouraging the operation of facilities serving the disabled and driving them
from the community.
We hope and trust that this is not the case and that the Council will make clear to
the staff that City ordinances are to be enforced in a non - discriminatory and even -handed
manner without any underlying intent to achieve a goal otherwise prohibited by law.
Sincerely,
RICHARD R. TERZIA
I'