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HomeMy WebLinkAbout09 - Newport Coast Recovery Staff ReportCITY OF NEWPORT BEACH CITY COUNCIL STAFF REPORT Agenda Item No. 9 October 27, 2009 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Office of the City Attorney David R. Hunt, City Attorney 949/644 -3131 or dhunt @city.newport- beach.ca.us SUBJECT: Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation — 1216 West Balboa Boulevard (Newport Coast Recovery, LP) (PA2008 -104) • Use Permit, UP 2008 -033 • Reasonable Accommodation, RA 2009 -009 ISSUE: Did substantial evidence support the Hearing Officer's denial of Newport Coast Recovery, LP's ( "Newport Coast Recovery") application for a use permit and for reasonable accommodations, and, if not, what action should the City Council take pursuant to Newport Beach Municipal Code section 20.91A.040 and 20.98.025? RECOMMENDATION: Staff recommends the City Council determine whether substantial evidence in the record supports the Hearing Officer's decision to deny Newport Coast Recovery's applications for the use permit and reasonable accommodations. If the City Council determines that substantial evidence supports the denials, the City Council should sustain the decisions of the Hearing Officer. If the City Council determines that substantial evidence in the record does not support any of the denials, the City Council must then choose between one of three possible actions: 1. Reverse the Hearing Officer's decision and authorize the issuance of a use permit or one of the requested reasonable accommodations to Newport Coast Recovery, subject to such conditions the City Council determines are appropriate based upon the evidence in the hearing record; or 2. Modify the Hearing Officer's decision denying the use permit and /or reasonable accommodation to Newport Coast Recovery based upon the evidence in the hearing record; or 3. Remand the matter to the Hearing Officer for further consideration, which remand shall include direction either to consider specific issues, or to conduct a de novo hearing on whether to grant, conditionally grant, or deny a use permit and /or reasonable accommodation to Newport Coast Recovery. Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 2 If the City Council determines the Hearing Officer's findings are not supported by substantial evidence and directs action be taken based upon choosing one of the three options above, staff recommends that a resolution be prepared setting out the determination of the City Council and the findings supporting that determination, and that the resolution be brought back for approval and adoption as the City Council's final decision on the matter. BACKGROUND: Newport Beach Ordinance No. 2008 -05 requires group residential uses that were in existence prior to February 22, 2008, and were not in conformity with the provisions of Ordinance No. 2008- 05 to apply for, and receive, a Use Permit in order to continue the nonconforming use at their current location. (Newport Beach Municipal Code ( "NBMC ") section 20.91A.020) Alternately, group residential uses housing disabled individuals may apply for exceptions from the provisions of the NBMC as a reasonable accommodation. (NBMC Chapter 20.98) All existing group residential uses subject to this requirement must have either received a use permit by February 22, 2009 or be within the administrative process in order to remain in operation past that date. (NBMC section 20.62.090) 1. Newport Coast Recovery's Use. Newport Coast Recovery operates an alcohol or drug abuse recovery and treatment facility licensed by the state to treat up to 29 men at 1216 West Balboa Boulevard. This use was in operation at the time the City enacted Ordinance No. 2008 -05. The facility is located in a seven - unit apartment building that was constructed in 1949 when the property was zoned R -3. The property was reclassified from R -3 to R -2 zoning in 1989 along with other properties in the area via enactment of Ordinance No. 89 -24. As a result, the subject structure is legal nonconforming and may continue at its location subject to the provisions of Chapter 20.62 of the NBMC (Nonconforming Structures and Uses.) NBMC Section 20.91A.020 requires nonconforming uses (as opposed to structures) in residential districts that were rendered nonconforming by the adoption of Ordinance No. 2008 -05 to apply for and receive a use permit to continue operation at their current locations. Newport Coast Recovery became a nonconforming use following adoption of Ordinance No. 2008 -05 because it is a Residential Care Facility, General- Licensed, located in a residential district zoned R -2 (Two - Family Residential) where, under Ordinance No. 2008 -05, such uses are not permitted or conditionally permitted. Newport Coast Recovery applied for a use permit within the time period required by Ordinance No. 2008 -05. 2. Use Permit Application and Hearing. Newport Coast originally submitted its application for a use permit on May 20, 2008. The application was not fully complete at the time of the initial hearing of the application held on December 8, 2008. Staff recommended a continuance of the hearing to allow the applicant to complete the application. The Hearing Officer continued the hearing to January 12, 2009 after taking testimony.' 'The full record of all Newport Coast Recovery use permit and reasonable accommodation proceedings at the Hearing Officer level is submitted to the City Council as Attachment 1 to this report, referred to as the Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 3 The continued hearing was conducted as scheduled on January 12, 2009. At that time, the application was complete. Staff recommended the Hearing Officer grant the use permit subject to the proposed conditions, which established strict operating standards and limited the facility's occupancy to 14 beds. (HR, NCR UP /RA 00562 - 00565) 3. First Hearing Officer Action. At the public hearings in December and January, the Hearing Officer heard testimony from City staff, the applicant, and the public. At the January 12, 2009 hearing, the Hearing Officer denied the application and directed staff to prepare a Resolution of Denial of the use permit, stating that he could not make key findings relating to the preservation of the neighborhood's residential character and overconcentrabon. (HR, NCR UP /RA 00614 - 00622) The Hearing Officer considered the proposed resolution at a hearing on January 22, 2009. (HR, NCR UP /RA 00688 - 00694) The resolution, subject to finalized wording, was approved by the Hearing Officer at that hearing. (HR, NCR UP /RA 00688- 00694) The Resolution of Denial was executed on February 4, 2009. (HR, NCR UP /RA 00714) 4. First Appeal of Hearing Officer Action. On February 11, 2009, Newport Coast Recovery filed an appeal of the Hearing Officer's decision for consideration by the City Council. (HR, NCR UP /RA 00129) a. After - Acouired Evidence While Newport Coast Recovery's appeal to the City Council was pending, staff was made aware of new information about the operations of Newport Coast Recovery. On March 25, 2009, the City Manager's Office received a complaint from a resident of Nevada, who reported that she had enrolled her minor son as a resident client at Newport Coast Recovery at 1216 West Balboa Boulevard in Newport Beach, and was not satisfied with the treatment he was receiving or the treatment environment. She reported she had concurrently assisted in enrolling her son's friend, also a.minor, at the same facility. After she was informed by City staff that Newport Coast Recovery was not authorized or licensed by either the California of Alcohol and Drug Programs ( "ADP ") or the Department of Social Services ( "DSS ") to treat minors, the complainant removed her son from Newport Coast Recovery on or about March 29, 2009. Her son's minor friend remained at the Newport Coast Recovery facility. On March 31, 2009, the mother of the minor remaining at Newport Coast Recovery called the. Office of the City Attorney and requested assistance in locating her son. City Attorney and City Manager staff worked with the Newport Beach and Costa Mesa Police Departments to locate the minor, who had been placed by Newport Coast Recovery staff in a sober living home for adult males in Costa Mesa after a relapse. "Hearing Record" Each page of the Hearing Record is numbered consecutively beginning with HR, NCR UP /RA 00001. References to the Hearing Record are denoted at "HR ", with the Bates stamp page number. Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 4 Costa Mesa Police Department officers reported that the minor was scheduled to return to Newport Coast Recovery that night. However, Newport Coast Recovery staff declined to accept the minor's return, stating that they were unauthorized to treat minors. The minor's mother removed him from the Costa Mesa sober living facility on April 1, 2009. (HR, NCR UP /RA 00095 - 00098) On April 1, 2009, Department of Social Services Complaint Officer Michael Valentine investigated the allegations and confirmed that Newport Coast Recovery had provided unlicensed care and supervision of minors at 1216 West Balboa Boulevard. He issued a Notice of Operation in Violation of Law to Newport Coast Recovery for housing minors without a required license. (HR, NCR UP /RA 00016 - 00018) b. City Council Action on Appeal. On April 14, 2009, the City Council heard Newport Coast Recovery's appeal of the Hearing Officer's denial of its use permit application. Staff and the City's counsel made a proffer of the after - acquired evidence. The City Council remanded the use permit application matter to the Hearing Officer for a new hearing, with direction to consider his prior decision in light of the after - acquired evidence. (HR, NCR UP /RA 00070- 00071) 5. Application for Reasonable Accommodation. On April 7, 2009, while Newport Coast Recovery's use permit appeal was pending, Newport Coast Recovery filed an Application for Reasonable Accommodation with the Newport Beach Planning Department. (HR, NCR UP /RA 00060 - 00067) The applicant submitted two alternate requests for accommodation: An exemption from the portions of NBMC Section 20.10.020 (Residential Districts: Land Use Regulations) that require Residential Care Facilities, General to be established only in residential districts zoned Multi - Family Residential (MFR) with a use permit, subject to the operational conditions recommended by City staff in the January 12, 2009 staff report for Use Permit No. 2008 -33, including a maximum occupancy of 14 residents, which was denied by the Hearing Officer, or, in the alternative. An exemption from the requirements specified in NBMC Section 20.91A.050 (Development and Operational Standards), including: • A waiver of the occupancy restriction of two persons per bedroom plus one staff member, and to allow a total occupancy of 18 residents; • An exemption from the parking requirements of one off - street parking space for each three resident beds, as specified in NBMC Section 20.66.030 (Off - Street Parking and Loading Requirements) for Residential Care, General use classifications, and to apply the off - street parking requirements applicable to Two - Family Residential (R -2) use classifications which requires two off- street parking spaces per dwelling unit; • Treat the use of the licensed residential care facility as a legal nonconforming use; Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 5 Apply the California Building Code provisions that were applicable at the time the residential care facility was established as relates to life and fire safety matters; and A waiver of the required finding specified in NBMC Section 20.91A.060 (D), relative to the compatibility of the use with the character of the surrounding neighborhood, which requires a finding that the continued use will not contribute to the changing of the residential character of the neighborhood, such as creating an overconoentration of residential care uses in the vicinity, and waiving the impact analysis contained in the Factors A through C which the Hearing Officer must consider in making or sustaining the finding with regard to the proximity of the use to schools, churches, playgrounds, day care centers, and alcoholic beverage outlets, and the application of the American Planning Association standard of permitting one or two such uses per block. Finding these requests to be ambiguously worded and, in some cases, contradictory, staff and outside counsel requested that Newport Coast Recoverys counsel clarify its requests for accommodation. (HR, NCR UP /RA 00081 - 00082, 00086) Newport Coast Recoverys counsel declined to do so. (HR, NCR UP /RA 00084, 00087- 00088) 6. Use Permit and Reasonable Accommodation Hearings. At the applicant's request, the hearing for Newport Coast Recovery's reasonable accommodation requests was scheduled on the same day as Newport Coast's remanded use permit hearing. The hearings for Newport Coast Recovery's use permit and reasonable accommodation requests were held on July 7, 2009. At the July 7, 2009 hearing, staff made the following recommendations: (1) Deny the use permit based on an inability to make a finding that Newport Coast Recovery operates in compliance with state and local law, pursuant to NBMC section 20.91A.060(A); and (2) Deny both requests for accommodation, based on the findings discussed in the July 7, 2009 staff report. At the July 7, 2009 hearing the Hearing Officer heard testimony from City staff, the applicant's counsel, and the public. Public testimony included testimony from parents of the two minors who had been admitted to Newport Coast Recovery while the use permit appeal was pending before the City Council. One parent appeared and testified in person, and another testified telephonically. One of the minors admitted.to the facility also appeared personally, and with his mother's consent made himself available to answer questions from the Hearing Officer. (HR, NCR UP /RA 00870 - 00875, 00881 - 00884, 00950 - 00952) After hearing the public testimony and arguments from the City and the appellant's counsel, the Hearing Officer indicated that he was inclined to affirm his denial of the use permit, based on his prior determination that granting the use permit would result in an overconcentration of similar facilities in the area. Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 6 After public testimony and arguments from the City and Newport Coast Recovery's counsel at the reasonable accommodation hearing, the Hearing Officer indicated he was inclined to deny both alternate requests for accommodation, also on the basis of overconcentration. (HR, NCR UP /RA 00960 - 00961) However, the Hearing Officer said that if Newport Coast Recovery could show that it offered a compelling, unique service not available elsewhere in the mid - Peninsula area, that could overcome his inclination to deny the reasonable accommodation. (HR, NCR UP /RA 00962) To fully address issues raised during the reasonable accommodation hearing, the Hearing Officer requested that the City and the applicant each provide supplemental written briefing on several issues as follows (HR, NCR UP /RA 00962): • The Hearing Officer asked the City and the applicant to address issues raised by the appellant's counsel regarding the City's Housing Element, Consolidated Plan, and Community Development Block Grant (CDBG) applications. The appellant's counsel had produced a collection of City documents at the hearing, which he said indicated a community need for the services of facilities such as Newport Coast Recovery. The Hearing Officer required a more complete explanation of the documents, to determine whether they demonstrated the necessity of accommodations to provide housing and services to the disabled. (HR, NCR UP /RA 00957 - 00958) • The Hearing Officer permitted briefing by the City on whether Newport Coast Recovery's two documented violations of state licensing laws created a "pattern and practice" of violating the law. (HR, NCR UP /RA 00958) • Finally, the Hearing Officer permitted briefing by Newport Coast Recovery to discuss and provide documentation for its assertions that Newport Coast Recovery provided a unique service as the only men's primary care facility within the City. Newport Coast Recovery's counsel had argued that accommodation was necessary to provide housing and services to the disabled, because it provided a unique service to the disabled as the only men's facility in the City that could accept patients with only 72 hours of detoxification. (HR, NCR UP /RA 00961) The Hearing Officer directed that the supplemental briefings be submitted to him within two weeks, and stated that he would make his final determination in writing after review and consideration of the briefings. (HR, NCR UP /RA 00963- 00965) On July 21, 2009, two weeks from the date of Newport Coast Recovery's July 7 hearing, the City's outside counsel submitted the requested supplemental briefing to the Hearing Officer and opposing counsel. (NCR, HR UP /RA 01001 - 01007) The City's briefing discussed the meaning of "pattern or practice" of violating state or local law as described in the NBMC, and clarified that NBMC section 20.91A.050(8) required that facilities in Newport Beach be operated in compliance with state and local law in order for a required finding to be made before a use permit can be issued. The City's briefing also addressed the significance of City documents that the applicant's counsel produced at the July 7, 2009 hearing, including documents taken from the City's application for federal CDBG funding and the City's annual performance report to HUD, and assertions by the applicant's counsel that the City's Housing Element is not in compliance with state law. The City's briefing included a declaration from Assistant City Manager Sharon Wood further explaining the significance of the documents submitted by the applicant's counsel at the July 7 hearing. (HR, NCR UP /RA 01005 - 01007) Appeal of Hearing. Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 7 Newport Coast Recovery's counsel submitted his supplemental briefing a week past the deadline established by the Hearing Officer, on July 29, 2009. (HR, NCR UP /RA 01009- 01042) This briefing addressed the state's. jurisdiction in the licensing of alcohol and drug recovery and treatment facilities, and staffs analysis of the elements of "necessity," "equal opportunity" and "reasonableness." The briefing also addressed the requested topic of the City s Housing Element and Consolidated Plans, and responded to the City briefing's explanation of these documents. The appellant's briefing did not address the question of whether Newport Coast Recovery was licensed to serve as a primary care facility, or whether it was the only men's facility in the City licensed to provide primary care services. The City objected to Newport Coast Recovery's late filing of its supplemental brief. In its objection, the City noted that Newport Coast Recovery's attorneys used the additional eight days to review and rebut the arguments set forth in the City's supplemental brief, an opportunity the City did not have. (HR, NCR UP /RA 01044 - 01045) The Hearing Officer accepted Newport Coast Recovery's late filing, but gave the City five days in which to submit a response to issues raised in Newport Coast Recovery supplemental brief. (HR, NCR UP /RA 01047) The City submitted its reply briefing within five days, on August 7, 2009. (HR, NCR UP /RA 01049 - 01062) 7. Hearinq Officer Action and Appeal. On August 18, 2009, the Hearing Officer issued a written order that denied the applicant's requests for reasonable accommodation. (HR, NCR UP /RA 01064 - 01070) The Hearing Officer determined that he could not make the three of the findings required to grant the reasonable accommodations, and directed staff to prepare a Resolution of Denial for his review and adoption, with findings consistent with the staff report and testimony presented at the hearings. Specifically, the Hearing Officer determined that he could not make a finding that the requested accommodation was necessary to afford disabled individuals an equal opportunity to use and enjoy a dwelling. The Order of the Hearing Officer stated that this decision was based on the analysis in the staff report, as well as evidence presented by staff and the public of alternate similar housing opportunities offering the same therapeutic benefit in the immediate vicinity and surrounding area. The Order also noted that the applicant had contended at the hearing that it provided a unique service as the only all -male residential primary treatment facility, and had requested that the record be left open so that it could provide further evidence of this in supplemental briefing. However, the applicant did not provide further information or evidence. Therefore, the Hearing Officer concluded that Newport Coast Recovery does not provide a unique or specialized value to the disabled in the community that is not generally available in other similar facilities in the Balboa Peninsula area. (HR, NCR UPiRA 01066 - 01067) The Hearing Officer also determined that he could not make a finding that the accommodation requests were reasonable, because granting the requests would result in a fundamental alteration to the City's zoning program. The Order cited the purposes enumerated in NBMC section 20.91A.010, particularly those concerning overconcentration, and noted that a primary therapeutic benefit for those in recovery is integration into residential settings within the community. The Order discussed the flexible standards for analysis and evaluation of overconcentration and institutionalization of a neighborhood specified in Ordinance No. 2008 -05, and how those flexible standards should be applied to afford disabled individuals an equal opportunity to reside in a neighborhood while preventing institutionalization. The Hearing Officer found that granting the requested accommodation would result in an overconcentration of facilities in the immediate area Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 8 of Newport Coast Recovery's facility, and would therefore undermine the purpose of the City's zoning scheme. (HR, NCR UP /RA 01067- 01068) Finally, the Hearing Officer determined that the requested accommodation would impose an undue financial or administrative burden on the City. The Order cited the testimony of numerous residents in the. vicinity of Newport Coast Recovery who testified that the facility's operations had required administrative and code enforcement staff time in the past. In addition, the Order cited City staff testimony of administrative staff and Police Department time assisting complainants about the facility's operation, and locating one of the minors entrusted to Newport Coast Recovery's care. The Order of the Hearing Officer also cited the Notice of Operation in Violation of Law issued by the Department of Social Services to Newport Coast Recovery on April 1, 2009 as evidence that supported a finding that the applicant did not operate its facility in accordance with applicable law, and that granting the accommodation would place an undue administrative burden on the City. (HR, NCR UP /RA 01068 - 01069) Staff prepared Resolutions of Denial for Newport Coast Recovery's use permit application as well as each alternate reasonable accommodation request, which were signed by the Hearing Officer on September 17, 2009. (HR, NCR UP /RA 01086 - 01118) On September 26, 2009, the applicant filed timely appeals with the City Clerk for City Council review of the Hearing Officer's denial of its use permit and two alternate reasonable accommodation requests, as allowed by NBMC sections 20.91A.040 and 20.98.025. A copy of the appeals is attached to this report as Attachment 2. DISCUSSION: Appeals of Hearing Officer decisions on reasonable accommodation requests, as well as appeals on use permits in residential districts, are heard by the City Council. (NBMC sections 20.91A.040 and 20.98.025.) Appeals from a Hearing Officer's decisions on use permits in residential districts and reasonable accommodation applications are subject to the "substantial evidence" standard under the Municipal Code. On appeal, the City Council reviews the administrative record from the Hearing Officer's previous proceedings, and determines whether the Hearing Officer's decision was supported by substantial evidence in the record. If the Hearing Officer's decision is supported by substantial evidence, it must be sustained by the City Council. If the Hearing Officer's decision is not supported by substantial evidence, the City Council may reverse, modify and/or remand the matter to the Hearing Officer. 1. Standard of Review — Use permits in districts zoned for residential uses, and reasonable accommodations. NBMC Chapters 20.91A and 20.98 establish procedures for approval, conditional approval or disapproval of use permits in residential districts and requests for reasonable accommodation. These chapters of the Municipal Code do not give the City Council the authority to address the issues "de novo," as the City Council would when reviewing decisions of the Planning Commission under NBMC sections 20.91.060 and 20.95.060. When considering permits for uses conditionally permitted in residential districts such as this one, and requests for reasonable accommodations, NBMC Chapters 20.91A and 20.98 establish the Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27. 2009 Page 9 City Council's standard of appellate review. Unlike procedures for appeals for use permits approved, conditionally approved or disapproved by the Planning Commission, NBMC section 20.91A.040 states: Decisions of the Hearing Officer may be appealed to the City Council. Notwithstanding Section 20.95.060, the standard of review shall not be de novo and the City Council shall determine whether the findings made by the Hearing Officer are supported by substantial evidence presented during the evidentiary hearing. The City Council acting as the appellate body may sustain, reverse or modify the decision of the Hearing Officer or remand the matter for further consideration, which remand shall include either specific issues to be considered or a direction for a de novo hearing. (NBMC section 20.91A.040 [Italics added].) Similarly, NBMC section 20.98.025(A) provides in part: ... notwithstanding Section 20.95.060, the standard of review on appeal shall not be de novo and the City Council shall determine whether the findings made by the Hearing Officer are supported by substantial evidence presented during the evidentiary hearing. The City Council, as the appellate body, may sustain, reverse or modify the decision of the Hearing Officer or remand the matter for further consideration, which remand shall include specific issues to be considered or a direction for a de novo hearing. (NBMC section 20.98.025.A [Italics added].) a. The "substantial evidence" test and abuse of discretion. When reviewing the decisions of a Hearing Officer on use permits and reasonable accommodation applications, the City Council is therefore required by NBMC sections 20.91A.040 and 20.98.025 to apply the "substantial evidence test." As discussed above, this means that the Council shall uphold the decision of the Hearing Officer if there is substantial evidence in the hearing record as a whole to support the decision the Hearing Officer made. Thus, the inquiry for the City Council is whether the Hearing Officer abused his discretion when he denied the applications for the use permit and the accommodations. The concept of "abuse of discretion" is well defined in the law. In finding abuse of discretion, the City Council shall consider whether the Hearing Officer's action was arbitrary, capricious, in excess of his jurisdiction, entirely lacking in evidentiary support, or without reasonable or rational basis as a matter of law. A prejudicial abuse of discretion is established if the Hearing Officer did not proceed in a manner required by law, or if his findings are not supported by substantial evidence in the record. (Sierra Club v. County of Napa (2004) 121 Cal.App.4 h 1490, 1497.) City staff, the applicant and members of the public may make comments regarding this issue at the City Council's hearing on the appeal. However, in making its determination, the City Council is limited to a review of the hearing record from the proceedings below. It may neither substitute its views for those of the Hearing Officer, nor reweigh conflicting evidence presented to him. The decisions of the Hearing Officer are given substantial deference and are presumed correct. (Id.) Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 10 The party seeking review (in this case, the applicant) bears the burden of showing that the Hearing Officer's decisions are not supported by substantial evidence in the record and the City Council "must resolve reasonable doubts in favor of the administrative findings and determination." (id.) "Substantial evidence" means "enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached." 121 Cal.App.0 at 1498. Such substantial evidence may include facts, and expert opinions supported by facts, but not argument, speculation, unsubstantiated opinion, or clearly erroneous evidence. (ld.) Although facts in the hearing record might lead the City Council to a conclusion different from the Hearing Officer's, the City Council may not overturn the Hearing Officer's decision on the grounds that an opposite conclusion based on the same set of facts would have been equally reasonable or more reasonable. It also may not weigh conflicting evidence and determine which side has the better argument. Instead, it must resolve all reasonable doubts in favor of the administrative finding and decision reached by the Hearing Officer. (Berkeley Keep Jets Over the Bay Committee v. Board of Commissioners of the Port of Oakland (2001) 91 Cal.App.4'h 1344, 1356.) In summary, the City Council may overturn the Hearing Officer's decision only if it finds that there are insufficient facts, or insufficient expert opinions supported by facts, in the hearing record to support the Hearing Officer's decision. b. Was the Hearing Officer's decision supported by substantial evidence? Staff recommends that the City Council review the administrative record, including the analysis in staff reports, the transcripts of the hearings, documents submitted by the public and the appellant, the City's and appellant's supplemental briefings, and the Order of the Hearing Officer. After review, the City Council should determine whether the Hearing Officer's decisions that certain required findings could not be made were supported by substantial evidence. 2. Appellant's Specific Grounds for Appeal. Appellant Newport Coast Recovery's grounds for appeal of the denial of the use permit are, to quote Newport Coast Recovery's appeal, "Denial with prejudice of application for a use permit, HO- 2009 -022." Newport Coast Recovery's grounds for appeal of its reasonable accommodation requests are, "Denial with prejudice of the request for a reasonable accommodation HO -2009- 023" and "Denial with prejudice of the request for a reasonable accommodation HO- 2009 -024." Therefore, the City Council should consider whether there is substantial evidence in the record that supports the Hearing Officer's decision to deny the use permit and reasonable accommodation requests 2 Appropriate Relief: 2Memoranda from staff who handled the administrative proceedings is attached, arguing the Council should sustain the hearing officer's decision and deny the appeal. Appellant has been given the opportunity to submit written argument of the issues (see email dated October 16, 2009 attached) but nothing has been received to date. We will forward any written submissions from appellant as soon as received. Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 11 Per NBMC sections 20.91A.040 and 20.98.025, the City Council may sustain, reverse or modify the decision of the Hearing Officer if it concludes that decision is not supported by substantial evidence. It may also remand the matter to the Hearing Officer for further consideration. If the City Council remands the matter to the Hearing Officer, NBMC sections 20.91A.025 and 20.98.025 requires that the Council either identify specific issues to be considered or direct that the Hearing Officer conduct a de novo hearing on the matter. Environmental Review: This application has been determined to be categorically exempt under the requirements of the California Environmental Quality Act (CEQA) under Class 1 (Existing Facilities). This class of projects has been determined not to have a significant effect on the environment and is exempt from the provisions of CEQA. The City Council's consideration of this Agenda Item does not require environmental review. Public Notice: This agenda item has been properly noticed as an appeal of a denial of an application for reasonable accommodation (published in the Daily Pilot and mailed to property owners and occupants within 300 feet of the subject property 10 days in advance of the hearing date) and in accordance with the Ralph M. Brown Act (72 hours in advance of the public meeting at which the City Council considers the item). CONCLUSION: Staff requests that the City Council determine whether the decisions of the Hearing Officer should be sustained or reversed, modified, or reversed with conditions, or remanded for further consideration. If the City Council reverses or modifies a Hearing Officer decision, staff recommends that a resolution be prepared setting out and memorializing the City Council's findings and conclusions, and will bring that resolution back for City Council review, comment, and adoption at the first available meeting. Submitted by: OF-ECE OF THE CITY ATTORNEY David R. Hunt, City Attorney Attachment 1: Hearing Record: Proceedings regarding Newport Coast Recovery, LP, and related documents. Memo to Hearing Officer from Planning Department dated July 1, 2009 for the July 7, 2009 Public Hearing - with attachments including: July 7, 2009 use permit staff report Attachment to use permit staff report— DSS Notice of Operation in Violation of Law July 7, 2009 reasonable accommodation staff report (with attachments) Attachments to July 7, 2009 reasonable accommodation staff report include: Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 12 Application for Reasonable Accommodation (PA 2009- 104)(RA 2009 -009) Minutes of City Council meeting, April 14, 2009 Correspondence with Applicant's counsel Email from Licensing Division of ADP Administrative record from May 20, 2008 to April 14, 2009 Memo from City Attorney to City Council addressing after - acquired evidence Memo from Assistant City Manager to City Council addressing after - acquired evidence and related police report Memo from City Attorney to City Council addressing Applicant's request for stay of appeal hearing, and related correspondence Staff report from City Attorney for April 14, 2009 appeal hearing Hearing Officer's Resolution of Denial of Use Permit Application for Appeal Memorandum from Assistant City Manager and Planning Department for April 14, 2009 hearing Administrative record as of April 14, 2009 Agenda for December 8, 2008 Public Hearing Staff report for December 8, 2008 Public Hearing Exhibits for December 8 staff report include use permit application, notice of incomplete application, and resident correspondence Staff Power Point presentation for December 8, 2008 Public Hearing Transcript of December 8, 2008 Public Hearing Agenda for January 12, 2009 Public Hearing Staff report for January 12, 2009 Public Hearing Exhibits for January 12, 2009 staff report include December 8 staff report and exhibits, and resident correspondence for January 12 Public Hearing Staffs Power Point for January 12 Public Hearing Transcript of January 12, 2009 Public Hearing Agenda for January 22, 2009 Public Hearing Correspondence from public for January 22 Hearing Proposed Resolution of Denial for Consideration at January 22, 2009 Hearing Revised Resolution of Denial presented at January 22, 2009 Hearing Staff's Power Point for January 22, 2009 Hearing Transcript of January 22, 2009 Public Hearing Resolution of Denial, adopted February 4, 2009 City Attorney letter to City Council, addressing Applicant's request for continuance of appeal to April 14, 2009 Correspondence submitted between February 4, 2009 and April 14, 2009 Correspondence submitted between April 14, 2009 and July 7, 2009 Agenda for July 7, 2009 Public Hearing Staff Power Point for July 7, 2009 Public Hearing Staff Attorney Power Point for July 7, 2009 Public Hearing Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation 1216 West Balboa Boulevard (Newport Coast Recovery) October 27, 2009 Page 13 Documents submitted to Hearing Officer prior to close of July 7, 2009 hearing Transcript of July 7, 2009 Public Hearing Supplemental letter brief submitted by City Supplemental letter brief submitted by Applicant City's objection to appellant's late filing Hearing Officer's acceptance of late filing, with leave for City to file response City's response to Applicant's supplemental brief Order of the Hearing Officer to Prepare Resolution of Denial of Request for Reasonable Accommodation Hearing Officer's Resolution of Denial — Use Permit Hearing Officer's Resolution of Denial — Reasonable Accommodation Request No. 1 Hearing Officer's Resolution of Denial — Reasonable Accommodation Request No. 2 Supplement to documents submitted prior to close of December 8, 2008 Public Hearing Attachment 2: Applications to Appeal Decision of the Hearing Officer Attachment 3: Staff Memoranda for October 27, 2009 Appeal Attachment 4: Email dated October 16, 2009 (A09- 004311 CC staff Report for 10.27.09 Agenda ATTACHMENT 1 Hearing Record Public copy available for review at City Clerk's office or online at www.newportbeachca.gov (Under City Government, Current Projects & Issues, Group Homes, Resolutions) Staff Report: Newport Coast Recovery - Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation ATTACHMENT 2 Applications to Appeal Decision of the Hearing Officer Staff Report: Newport Coast Recovery - Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation Brown, Leilani From: Steven Polin [spolin2 @earthlink.net] Sent: Saturday, September 26, 2009 12:58 PM To: Brown, Leilani; pbobko; Wolcott, Cathy; Kiff, Dave Cc: Chris Brancart; ebrancart@brancart.com; james dee; mnewman198o@,hotmail.com; Dana (CRT) Mulhauser; paul.e.smith Subject: appeal of newport coast recovery Attachments: AppealofHearingOfficersDecision use permit with signature.pdf; AppealofHearingOfficersDecision reasonable accommodation #1 with signature.pdf; AppealofHeadngOfficersDecision reasonable accommodation #2 with signature.pdf Follow Up Flag: Follow up Flag Status: Flagged Please find attached signed copies of the notice of appeal from the denial of its use permit application and requests for a reasonable accommodation. the original of documents are being mailed via first class mail. thank you. Steven Polin Steven Polin Law Office of Steven G. Polin 3034 TennysonStreet, NW Washington, DC 20015 202- 331 -5848 202 -537 -2986 (fax) soolin20earthlinlc net This transmission is protected by the Electronic Communications Privacy Act, 18 U:S.C. Sections 2510 -2521 and intended to be delivered only to the named addressee(s) and may contain information that is confidential, proprietary, attorney work - product or attomey- client privileged. If this information is received by anyone other than the named addressee(s), the recipient should immediately notify the sender by E -MAIL and by telephone 202- 331 -5848 and obtain instructions as to the disposal of the transmitted material. In no event shall this material he read, used, copied, reproduced, stored or retained by anyone other than the named addressee(s), except with the express consent of the sender or the named addressee(s). Thank you. CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA2008 -104 Application No. 2008 -033 Name of Appellant Newport Coast Recovery Phone 202- 331 -5848 Site Address 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing Officers decision September 17 2009 Name of Applicant Newport Coast Recovery (Description of application filed with Hearing Officer) Application for a use permit to continue for providing residential treatment services to person in recovery from alcoholism and substance abuse. Reasons for Appeal Denial with prejudice of the application for a use permit, HO- 2009 -022 Stevdf "G.Tfo-iin a �� Signature of Appellant FOR OFFICIBUSE ONLY: R ived Fee received 09/26/2009 Date s C.NDocu'ments and Settings%sobomy'Local SettingslTemporary Internet Files \Content.OuHoold277DB2P71Appeal of Hearing Officers Decision.doex Revised 02 -04-09 jjb CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA2008 -104 Name of Appellant Site Address Newport Coast Recovery Application No. 2009 -009 Phone 202- 331 -5848 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing Officer's decision September 17 Name of Applicant Newport Coast Recovery (Description of application filed with Hearing Officer) "EEO Request for a reasonable accommodation for requesting a waiver from the provisions of NBMC 20.10:020 or in the alternative a waiver from the provisions of NBMC 20.91A.050 Reasons for Appeal _ HO- 2009 -023 Steven Denial with prejudice of the request for a reasonable accommodation Signature of Appellant FOR OFFICE USE ONLY: Rece ed by r GyYy�se py6MnG. PYn GH aM.h..wi 4 Ar.� A w. lNMI M6 d42omm]B 1ltiAV6�Otm Fee received 09/26/2009 Date Date C:\Documents and Setdngs\sobomy\Local Settingsk1emporary Internet Files \Content.OuHook1277DB2P7ftpeal of Hearing Officer's Deasion.docx Revised 02 -04-09 bb CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA 2008 -104 Application No. 2009-009 #2 Name of Appellant Newport Coast Recovery Phone 202- 331 -5848 Site Address 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing Officer's decision September 17 2009 Name of Applicant Newport Coast Recovery for (Description of application filed with Hearing Officer) Request for a reasonable accommodation requesting a waiver from the provisions of NBMC 20.10.020 or in the alternative a waiver from the provisions of NBMC 20.91A.050 Reasons for Appeal Denial with prejudice of the request for a reasonable accommodation HO -2009 -024 SWen %- P`olin Signature of Appellant FOR OFFu-c Jifflac ONLY: Received Fee received 09/26/2009 Date q 1� Dat C:1Documents and Setfings%obomyUzcal Settingffemporwy IMemet FiieslCon tentOutbok%277DB2P7Wppeal of Hearing Officer's Dedsion.docx Revised 02 -04-09 jib ATTACHMENT 3 Staff Memoranda for October 27, 2009 Appeal Staff Report: Newport Coast Recovery - Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation CITY OF NEWPORT BEACH MEMORANDUM TO: Mayor and Members of the City Council FROM: Catherine Wolcott, Deputy City Attom Janet Brown, Associate Planner DATE: October 27, 2009 RE: Newport Coast Recovery (1216 West Balboa) Appeal — Reasonable Accommodation (PA2008- 104)(RA 2009 -009) Staff Analysis and Recommendation Regarding Hearing Officer's Decision On July 7, 2009, the City held a public reasonable accommodation hearing before Hearing Officer Thomas W. Allen to consider Appellant Newport Coast Recovery, LP's application for two alternate reasonable accommodations. On August 18, 2009, Hearing Officer Allen issued a written Order of Hearing Officer to Prepare Resolution of Denial of Reasonable Accommodation. Subsequently, the Hearing Officer adopted two Resolutions of Denial of Reasonable Accommodation on September 17, 2009. The staff report submitted by the Office of the City Attorney for this appeal sets forth the background of the application process, the public hearing, supplemental briefing submitted by the parties after the public hearing, and the Hearing Officer's Order to Prepare the Resolution of Denial. The City Attorney's staff report also discusses the "substantial evidence" standard of review that Newport Beach Municipal Code (NBMC) Section 20.98.025 establishes for appeals of Hearing Officer decisions granting or denying reasonable accommodation. This memorandum focuses on a discussion of evidence in the Newport Coast Recovery reasonable accommodation hearing's administrative record that supports the Hearing Officer's decision on September 17, 2009. Staff concludes that there is substantial evidence in the record to support the Hearing Officer's decision. I. SUBSTANTIAL EVIDENCE TEST GIVES DEFERENCE TO HEARING OFFICER'S FINDINGS Under the substantial evidence test, the Council must uphold the decision of the Hearing Officer if there is substantial evidence in the record to support the decision that the Hearing Officer made. If the City Council does not find substantial evidence in the record to support the Hearing Officer's decision, the City Council may reverse or modify the decision, or remand the matter for further consideration, which remand shall include specific issues to be considered or a direction for a de novo hearing. (NBMC §20.98.025(A)) City Hall a 3300 Newport Boulevard a Post Office Box 1768 a Newport Beach, California 92659 -1768 Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 2 The City Council is limited on appeal to a review of the record from the proceedings below. It may neither substitute its views for those of the Hearing Officer, nor reweigh conflicting evidence presented to him. The decisions of the Hearing Officer are given substantial deference and are presumed correct. (Sierra Club v. County of Napa (2004) 121 Cal.App.0 1490, 1497.) The party seeking review (in this case, the applicant) bears the burden of showing that the Hearing Officer's decisions are not supported by substantial evidence in the record and the City Council "must resolve reasonable doubts in favor of the administrative findings and determination." (ld.) "Substantial evidence" means "enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached." (121 Cal.App.4"' at 1498.) Although facts in the record might lead the City Council to a conclusion different from the Hearing Officer's, the City Council may not overturn the Hearing Officer's decision on the grounds that an alternative conclusion based on the same set of facts might have been equally reasonable. It may not weigh conflicting evidence and determine which side has the better argument. Instead, the City Council must resolve all reasonable doubts in favor of the administrative finding and decision reached by the Hearing Officer. (Berkeley Keep Jets Over the Bay Committee v. Board of Commissioners of the Port of Oakland (2001) 91 Cal.App.4'h 1344, 1356.) When reviewing an administrative decision under the substantial evidence test, the reviewing body considers all relevant evidence in the administrative record, beginning with the presumption that the record contains evidence to sustain the hearing officer's findings of fact. (TG Oceanside, LP v. City of Oceanside (2007) 156 Cal.App.4 h 1355, 1370 - 1371.) WHAT KIND OF EVIDENCE IS CONSIDERED "SUBSTANTIAL EVIDENCE ?" In general, substantial evidence has been defined as "evidence of ponderable legal significance ...reasonable in nature, credible and of solid value" (156 Cal.App.4'h at 1371.) It has also been defined as "relevant evidence that a reasonable mind might accept as adequate to support a conclusion." (ld) (citations and internal quotation marks omitted.) "If the word 'substantial' means anything at all, it clearly implies that such evidence must be of ponderable legal significance. Obviously, the word cannot be deemed synonymous with 'any' evidence. It must be reasonable in nature, credible and of solid value; it must actually be 'substantial' proof of the essentials which the law requires in a particular case." (DeMartino v. City of Orinda (2000) 30 Cal.App.4'h 329, 336) (internal quotation marks omitted.) Substantial evidence may include facts, and expert opinions supported by facts, but not argument, speculation, unsubstantiated opinion, or clearly erroneous evidence. (Sierra Club v. County of Napa, 121 Cal.App.4`h at 1498.) The testimony of a single witness can constitute substantial evidence. (Phelps v. State Water Resources Control Board (2007) 157 Cal.App.4"' 89,99) This memorandum highlights some of the evidence in the record that is consistent with the standards of substantial evidence established in the court's decisions quoted above. Some of Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 3 the evidence was provided through the written or verbal testimony of members of the public who had personal experience with Newport Coast Recovery, either as a neighbor or as a client. In certain matters, City staff testified to direct experience or knowledge of specific facts as well. The staff reports for the public hearing presented evidence as well as arguments to the Hearing Officer. III. SUBSTANTIAL EVIDENCE IN THE ADMINISTRATIVE RECORD SUPPORTS THE HEARING OFFICER'S DECISIONS In order for the Hearing Officer to approve or conditionally approve an application for reasonable accommodation, he or she must be able to make each of the five required findings following a noticed public hearing. If even one of the five required findings identified in NBMC Section 20.98.025(B) cannot be made, the Hearing Officer must deny the request. As shown in the two Resolutions of Denial for Newport Coast Recovery, the Hearing Officer determined that only two of the five findings required by NBMC Section 29.98.025(8) could be made. This memorandum discusses some of the evidence in the record that supports the Hearing Officer's decision that the other three required findings could not be made. The examples of evidence below are in no way an exhaustive list of the substantial evidence in the record; they are intended solely as an illustration for the City Council of the type of evidence in the extensive administrative record that support the decisions of the Hearing Officer. A. NBMC §20.98.025(B)(2) - Finding No. 2: The requested accommodation is necessary to provide one or more individuals with a disability an equal opportunity to use and enjoy a dwelling. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Discussion: The Order of Hearing Officer to Prepare Resolution of Denial of Request for Reasonable Accommodation ( "Decision of the Hearing Officer) (HR, NCR, UP /RA 01064 — 70) stated that the finding of necessity could not be made.' Staff believes the Hearing Officer largely based his decision on facts presented in the analysis of necessity in the July 7, 2009 staff report, from staffs testimony that there were many beds available in licensed recovery facilities offering similar services and setting on the Balboa Peninsula, and the testimony of a resident at the public hearing that many similar treatment facilities were nearby. The Hearing Officer's Order noted that specific substantially similar facilities were identified in the public hearing testimony. (HR, NCR UP /RA 01066 — 67) As NBMC Section 20.98.025(C)(4) authorizes the Hearing Officer to consider whether the existing supply of facilities of a similar nature and operation in the community is sufficient to provide individuals with a disability an equal opportunity to live in a residential setting, this evidence was appropriate to consider in determining necessity. ' All references to the administrative record are designated "HR, NCR UP /RA." followed by the page numbers. The designation means Hearing Record, Newport Coast Recovery, Use PermittReasonable Accommodation. Newport Coast Recovery— Appeal to City Council October 27, 2009 Page 4 The Decision of the Hearing Officer also noted that Newport Coast Recovery's counsel had argued that Newport Coast Recovery, as an all -male primary treatment facility, offered a unique recovery environment not available to the disabled elsewhere in the City, but Newport Coast had been unable to answer staffs questions as to whether the facility actually held that licensing category. Newport Coast Recovery's counsel asked that the record be left open to submit more evidence of the unique type of recovery services the facility provided. (HR, NCR UP /RA 00933 —36) The Hearing Officer's Order stated that although he left the record open to give Newport Coast Recovery the opportunity to provide additional information, the information was not provided. This led the Hearing Officer to conclude that Newport Coast Recovery does not provide a unique or specialized therapeutic value to the disabled in the community, not generally available in other similar facilities in the Balboa Peninsula area. (HR, NCR UP /RA 01067) Examples of evidence in the record that support the Hearing Officer's decision: Facility does not provide recovery services and recovery environment that are not available in numerous other facilities in similar locations and settings on the Balboa Peninsula. • Newport Coast Recovery's license from the California Department of Alcohol and Drug Programs ( "ADP ") — lists services that Newport Coast is licensed to provide. Non- medical detox not listed among the authorized services. (HR, NCR UP /RA 00194) Staff (Kill) stated at the July 7, 2009 reasonable accommodation hearing that Newport Coast Recovery's ADP license classification is "RES,' not "RES -DETOV RES -DETOX is the designation ADP confers on facilities it licenses to provide non - medical detox to its residents. Staff asked Newport Coast Recovery's operator to explain this at the April 14, 2009 use permit appeal hearing, since the operator stated all other facilities required 30 days of primary care prior to entrance. At the July 7, 2009 reasonable accommodation hearing, Newport Coast Recovery's attorney did not present evidence or testimony on this point, but said the primary care designation allowed the facility to accept residents after only 72 hours of detox. (HR, NCR UP /RA 00933 -35) • Staff (Wolcott) stated at the July 7, 2009 reasonable accommodation hearing that there are currently 207 beds in licensed recovery facilities which had received approval to operate from the City and were not subject to abatement. Most of these facilities were in similar physical settings and similar locations on the Balboa Peninsula and West Newport. (HR, NCR UP /RA 00902) The staff report for the July 7, 2009 reasonable accommodation hearing states that potential disabled residents seeking to live in a licensed recovery facility with 14 to 18 residents in an apartment building had alternative similar housing at Ocean Recovery's men's facility one block away, and a number of Sober Living by the Sea facilities housing up to 12 residents in duplexes throughout West Newport. (HR, NCR UP /RA 00033) Examples of the evidence supporting the Hearing Officer's decision that alternate requests from Request No. 2 were not necessary Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 5 Request for occupancy restriction waiver: Staff report for July 7, 2009 reasonable accommodation hearing — 'The Newport Coast Recovery facility is housed in a seven -unit apartment building. Even if subtracting the bedrooms used for office rather than residential functions, the Newport Coast Recovery facility still provides nine bedrooms. Under the standards of NBMC 20.91A.050(C)(2), this would set the maximum number of residents ... at 19. Newport Coast Recovery requests a maximum of 18 residents. Therefore, this requested accommodation is not necessary..." (HR, NCR UP /RA 00044) Accommodation of 18 residents: Staff report for the July 7, 2009 reasonable accommodation hearing — In order to show necessity for an increased number of residents, the applicant would need to provide evidence showing that 1) the accommodation was necessary for the facility's financial viability ...or 2); the requested accommodation is necessary to provide a therapeutic benefit (and thus directly ameliorate an effect of the handicap.) The applicant has not provided evidence to support either argument . . . The applicant has provided no information or evidence that suggests that Newport Coast Recovery requires 18 residents in order to be financially viable." (Staff did find necessity for resident clients currently in treatment at the facility, so that residents in treatment would not lose their current housing.) (HR, NCR UP /RA 00045) Parkin Requirements and Visitor Parking Restriction Waivers: Staff report for the July 7, 2009 reasonable accommodation hearing — 'The applicant's request to be subject to residential parking standards rather than the parking standards applicable to group homes is not necessary ... At the maximum requested resident occupancy of 18 residents, the facility already meets off - street parking requirements established by NBMC Section 20.66.030 for Residential Care Facilities, General." (HR, NCR UP /RA 00045) The applicant's request that the Hearing Officer impose not restrictions on visitor parking is also not necessary.... [Tjhe applicant has made no showing that the conditions placed on visitor_ parking would prevent family members from attending educational sessions at the facility. it has also made no argument or showing that waiver of the proposed visitor parking conditions in any way hindered the applicant's ability to provide housing and related services to the disabled. Thus, there has been no showing that the requested accommodation is necessary." (HR, NCR UP /RA 00046) Classification of Newport Coast Recovery as a legal nonconforming use: Staff report for the July 7, 2009 reasonable accommodation hearing — "The City has always treated Newport Coast Recovery as a legal nonconforming use in the past, and continues to treat Newport Coast Recovery as a legal nonconforming use under NBMC Section 20.91A.020.... Staff has processed Newport Coast Recovery's use permit application as it has processed all other applications for permits to continue existing nonconforming uses in residential areas. Therefore, the requested accommodation is not necessary to afford disabled individuals an equal opportunity to use and enjoy a dwelling ... By this request, applicant may be attempting to request a waiver from the application of any conditions imposed by Ordinance No. 2008 -05... this also is not necessary to afford disabled residents an equal opportunity to use and enjoy a dwelling. Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 6 Disabled individuals do not need such a broad waiver to be able to use and enjoy a dwelling within the City. The appropriate conditions which a use permit or reasonable accommodation can impose ... do not prevent disabled individuals from residing in the facility or receiving the services their disability requires ..." (HR, NCR UP /RA 00046) Application of California Building Code provisions pertaining to life safety in effect at time the facility was established: outlets: Staff report for the July 7, 2009 reasonable accommodation hearing — "The use of the structure at 1216 West Balboa Boulevard changed in 1997 from an apartment building occupancy to a residential care facility occupancy with more than six residents. The correct version of the California Building Code to apply would be the 1994 Building Code ... Because the 2008 Building Code supplies alternate and equally effective life safety protection provisions, the Newport Beach Fire Marshal is willing to apply the 2008 Building Code rather than the code in effect at the year a facility established. However, this is not a requirement. Therefore, the requested accommodation is not necessary. . . "(HR, NCR UP /RA 00047) Staff report for the July 7, 2009 reasonable accommodation hearing — "(Tjhe considerations to which the applicant is referring are not prohibitions or standards that stand as absolute bars to granting a use permit for a group home. Rather they are factors taken into consideration when determining in the context of a use permit hearing whether the proposed use would be compatible with surrounding uses. "!n analyzing overconcentration factors, and proximity to schools, parks and alcoholic beverage outlets in a reasonable accommodation setting ... staff considers whether, but for the specific factors named by the applicant, disabled individuals would be given an opportunity to reside at Newport Coast Recovery ... All three factors were considered at the January 12, 2009 use permit hearing by the Hearing Officer, who cited overconcentration and proximity to schools and alcoholic beverage outlets among his reasons for denying the applicant's use permit.. . However, other facts were also considered by the Hearing Officer, including evidence of persistently disruptive resident behavior, impacts of facility vans, and impacts of secondhand smoke. " "Some of the impacts of the latter category could be controlled with appropriate conditions. However, reports of continued disruptive conduct on the part of Newport Coast Recovery's facility residents presented evidence of impacts on neighbors that were not consistent with stated purposes of NBMC Chapter 20.91A ... The result for Newport Coast Recovery is that even if the factors which NBMC Section 20.91A.060(D) directs the Hearing Officer to consider are not considered, the findings necessary for a use permit still cannot be made. Therefore, the requested waiver is not necessary to provide disabled individuals with an equal opportunity to use and enjoy a dwelling. "(HR, NCR UP /RA 00047 — 48) Newport Coast Recovery— Appeal to City Council October 27, 2009 Page 7 B. NBMC §20.98.025(6)(3) - Finding No. 3: The requested accommodation will not impose an undue financial or administrative burden on the City as "undue financial or administrative burden" is defined in Fair Housing Laws and interpretive case law. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Discussion: The Decision of the Hearing Officer stated that granting Newport Coast Recovery's request would impose an undue administrative burden on the City. The Hearing Officer emphasized that numerous residents in the vicinity testified at past hearings regarding the conduct of the Newport Coast Recovery operation that had required City staff time to address in the past, and might continue to do so in the future. In particular, the Hearing Officer noted that administrative and police department staff had spent substantial time assisting complainants and, in one case, locating a minor entrusted to Newport Coast Recovery's care. The Decision of the Hearing Officer acknowledged the Notice of Violation in Operation of Law by the California Department of Social Services, evidence that supported a finding that Newport Coast Recovery did not operate its facility in accordance with applicable law, and that an undue administrative burden resulted. (HR, NCR UP /RA 01068 — 69) • March 31, 2009 Newport Beach Police Department Report by Lt. Frizzell — (HR, NCR UP /RA 00097 — 98) April 1, 2009 Complaint Investigation Report and April 1, 2009 Notice of Violation in Operation of the Law issued by the California Department of Social Services to Newport Coast Recovery for housing minors without a license — "You are hereby notified that the above referenced facility is operating without a license which is a violation of California Health and Safety Code, Section 1508 ... In accordance with Health and Safety Code Sections 1540, 1541, 1547 and other applicable laws, your continued operation without a license could result in civil and /or criminal action being taken against you." (HR, NCR UP /RA 00016 —18) Email from Joan Robbins (California Department of Alcohol and Drug Programs, Licensing Division) to Dave Kiff — "Newport Coast Recovery, 1216 West Balboa Blvd., Newport Beach is not approved as an adolescent waiver program." (HR, NCR UP /RA 00090) Staff (Kill) testimony at the July 7, 2009 public hearing — '[T]his comes about as a result of a discussion of a call that was made to me on or about April 1, March 30th of 2009, where a mother claimed to have had a 17 -year old child in treatment at Newport Coast Recovery for substance abuse. Among the troubling issues she raised with me were that apparently Newport Coast Recovery knowingly accepted at least up to two minor boys for treatment ... a subsequent investigation by the Department of Social Security Services which governs youth and youth facilities brought forth a claim by a Newport Coast staff member that they held an adolescent waiver that allows treatment of minors for the Newport Coast facility. Adolescent waiver is granted by ADP on a condition basis, but my follow -up call with ADP resulted in them telling me that there's no record of Newport Coast ever having had an adolescent waiver authorizing Newport Coast to treat adolescents." (HR, NCR UP /RA 00842) Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 8 Public testimony at the July 7, 2009 use permit public hearing of C. Willis, J. Willis and J. Golden -. (HR, NCR UP /RA 00870 — 873) (HR, NCR UP /RA 00881 — 883) C. NBMC §20.98.025(B)(4) - Finding No. 4: The requested accommodation will not result in a fundamental alteration in the nature of the City's zoning program, as "fundamental alteration is defined in Fair Housing Laws and interpretive case law. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Newport Coast Recovery's accommodation Requests No. 1 and 2 requested a waiver of the use permit requirement. When a reasonable accommodation request is made, the City must grant the request if it is both necessary to afford a disabled individual an equal opportunity to use and enjoy a dwelling, and reasonable. (HR, NCR UP /RA 00777) A request may be considered unreasonable if granting the requested accommodation would result in an undue financial or administrative burden on the City, or a fundamental alteration in the nature of a City program. "Fundamental alteration" has also been described as "undermining the basic purpose the requirement was put in place to achieve." (HR, NCR UP /RA 00778 — 79) The July 7, 2009 staff report and testimony for Newport Coast Recovery's Requests No. 1 and 2 considered whether granting the requested accommodations would fundamentally alter the nature of a City program. Both Requests No. 1 and 2 required the waiver of the use permit requirement. The Decision of the Hearing Officer determined that granting the waiver of the use permit requirement and accommodating Newport Coast Recovery's continued operation would result in a fundamental alteration in the nature of the City's zoning program. (HR, NCR UP /RA 01068) The Hearing Officer found the City seeks to avoid the overconcentration of residential care facilities, such that facilities are reasonably dispersed throughout the community and are not congregated or over - concentrated in any particular area so as to institutionalize that area. The Hearing Officer also found that a primary therapeutic benefit for those in recovery is integration into residential settings in the community. Therefore, the Hearing Officer found that dispersal of the facilities to avoid institutionalization of residential areas was a fundamental part of the use permit process in the R -2 zone. (HR, NCR UP /RA 01067 — 68) The Hearing Officer also noted the City Council developed flexible standards for analysis and evaluation of overconcentration, which followed the recommendations of the American Planning Association to avoid institutionalization of neighborhoods while affording the disabled an opportunity to reside there. For the same reasons he found granting a use permit would result in overconcentration at the January 12, 2009 and July 7, 2009 use permit hearings, the Hearing Officer found that granting the requested accommodation to waive the use permit requirement would result in an overconcentration of recovery facilities in the area. This would fundamentally alter the City's purpose of avoiding clustering and preserving the residential character of a mid - Balboa Peninsula neighborhood, and was therefore unreasonable. In addition, the Decision of the Hearing Officer stated that Newport Coast Recovery's violations of state law were not consistent with one of the operating standards that must be met for a use in a residential zone to obtain a use permit. One of the conditions that must be met is that the facility must be operated in accordance with state and local law. (NBMC § 20.91A.050(B)) (HR, NCR UP /RA 00888, 01002 - 03) The Hearing Officer determined that documented violations of state licensing laws constituted a basis for a finding that Newport Coast Recovery does not operate its facility in accordance with applicable law. (HR, NCR UP /RA 01069) Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 9 In deciding whether to issue a use permit, the Hearing Officer also considered the proximity of Newport Coast Recovery to other uses, which the NBMC directed him to consider. The evidence that supported the Hearing Officer's decision to deny the use permit application was based in part on the use's proximity to other types of uses. Examples of evidence supporting determination that granting the accommodation would alter fundamental nature of City's zoning program: Staff memorandum for April 14, 2009 use permit appeal —'The APA Standard reads as follows: 'Finding #5. Community residences should be scattered throughout residential districts rather than concentrated in any single neighborhood or on a single block. For a group home to enable its residents to achieve normalization and integration into the community, it should be located in a normal residential neighborhood. If several group homes were to locate next to one another, or be placed on the same block, the ability of the group homes to advance their residents' normalization would be compromised. Such clustering would create a de facto social service district in which many facets of an institutional atmosphere would be recreated and would change the character of the neighborhood. 'Normalization and community integration require that persons with disabilities be absorbed into the neighborhood's social structure. The existing social structure of a neighborhood can accommodate no more than one or two group homes on a single block (emphasis added). Neighborhoods seem to have a limited absorption capacity for service dependent people that should not be exceeded. Social scientists note that this level exists, but they can't quite determine a precise level. Writing about service dependent populations in general, Jennifer Wolch notes, At some level of concentration, a community may become saturated by services and populations and evolve into a service dependent ghetto.' From the APA's Policy Guide on Community Residences, September 22, 1997" (HR, NCR UP /RA 00136)" Staff testimony (Kiff) at the January 12, 2009 use permit public hearing — 1'll try to put something up on the screen to show folks what is coming. What the APA standard says, and it's Policy 4 — 'Halfway houses should be allowed in all single family zones by a special use permit due to their multi - family characteristics -- multiple family — that warrant the extra scrutiny provided by the use permit.'. . . Halfway houses are not, per se, incompatible with single family, but the heightened scrutiny of a conditional use permit hearing,' which is what we're doing right now, 'is warranted to assure that the proposed halfway house will be compatible with other land uses in the single family district The standards to apply are the same ones used by other special uses.'" (HR, NCR UP /RA 00608) • Staff report for the January 12, 2009 use permit public hearing - Diagrams with locations and addresses of other recovery facilities in Newport Coast Recovery's immediate neighborhood. (HR, NCR UP /RA 00533, 00552) Public testimony at the July 7, 2009 use permit hearing (Wood) — 'In the midst of the overconcentration of commercial rehab for - profit businesses, directly across the alley from our property is 1132 West Balboa, a for-profit commercial rehab business. Nearby, Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 10 at 1120 West Balboa Boulevard, is a non - licensed for - profit commercial or rehab business. Across the street, at 1115 West Balboa Boulevard, is another profit commercial rehab business. in the block --- in the next block north, at 1217 West Bay Avenue, is another for - profit commercial rehab business. Behind 1217 West Bay Avenue, at 1216 West Balboa Boulevard, is subject for - profit commercial rehab business. In this residential zone within the 1100 and 1200 blocks, there are five for - profit commercial rehab businesses. "(HR, NCR UP /RA 00942 — 43) Staff testimony (Kill) at the January. 12, 2009 use permit hearing, discussing the requirements of Ordinance No. 2008 -05 — "(Ujp on the screen is the text of the ordinance. And this is ... Section D of 20.91A.060. These are the findings that the Hearing Officer has to make, and I'm focusing on D, that's the one that Mr. Allen was referring to, where it says that 'The Hearing Officer needs to make a finding that the use will be compatible with the residential character of the surrounding neighborhood. In making this finding or sustaining a finding, the Hearing Officer' ... 'if appealed to the City Council, shall consider as appropriate the following factors:' First one is the proximity of schools and parks, outlets for alcoholic beverages. The second one is the existence of substandard physical characteristics of the area in which the use is located, such as lot width, set backs, etc.. .. if something . ..exists in the non - standard subdivision area, then the Hearing Officer can decide, whether, in light of that, it's appropriate to apply the APA standard of one or two such uses per block. And then it discusses this concept that in Newport Beach, block differences — block lengths vary quite a bit. The average calculable block length, though, is 711 feet. The median is 617. So then, it directs the Hearing Officer to apply the APA standard in a manner which eliminates those differences in block lengths. And then in making the determination, the Hearing Officer is supposed to be guided by those block lengths. And then there's an important sentence. It says, 'The Hearing Officer shall retain the discretion to apply any degree of separation of uses which he or she deems appropriate in any given case.' And then if refers to the APA document that i had on the screen earlier." (HR, NCR UP /RA 00613-15) Examples of evidence that integration into residential settings in the community is a Primary therapeutic benefit for those in recovery, and that dispersal of the facilities to avoid institutionalization of residential areas was consistent with the stated purpose of the use Permit requirement of Ordinance No. 2008 -05: Staff report for the July 7, 2009 reasonable accommodation hearing - "The HUD /DOJ Joint Statement says that, 'if a neighborhood came to be composed largely of group homes, that could adversely affect individuals with disabilities and would be inconsistent with the objective of integrating persons with disabilities into the community. Especially in the licensing and regulatory process, it is appropriate to be concerned about the setting for a group home. A concern about over- concentration could be considered in this context. "' (HR, NCR UP /RA 00034) Staff (Wolcott) testimony at the July 7, 2009 reasonable accommodation hearing — "The purpose of community -based care . . . as ADP has explained it to us, is to allow individuals in recovery to begin to reintegrate into the surrounding neighborhood and to learn the skills of living in a neighborhood. . . `(HR, NCR UP /RA 00914) Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 11 The Hearing Officer's Resolution of Denial also acknowledged the impact of the Newport Coast Recovery facility on immediate neighbors, and noted that overconcentration in combination with the.operator's inability to adequately control and supervise the facility's residents in a manner that allowed neighbors to have quiet enjoyment of their properties would fundamentally alter the character of the neighborhood. (HR, NCR UP /RA 01095) Examples of evidence that the character of the neighborhood was altered by Newport Coast Recovery's inability to adequately control and supervise facility residents and other impacts: • Public testimony at the December 8, 2008 and January 12, 2009 use permit public hearing — The use generates traffic in excess of other residential uses in the neighborhood — (N. Bacich) — °I have been in the garage and working, and in a 45- minute period, there [sic] was 18 vehicles that came up [to Appellant's property]. And several of them were white vans, so they must have been picking up [residents/ quite frequently ... And sometimes there would be multiple cars blocking the alleyway while people ran in and out So the car transport is a factor. "(HR, NCR UP /RA 00293) Traffic impacts — (P. Bacich) - "One Saturday, while we worked in the garage over there when we were turning tenants, we counted, l believe, 16 — I have it written down somewhere at home — 16 vehicles coming and going in a couple -hour period from the back alley [behind Appellant's property]" (HR, NCR UP /RA 00578 79) The Applicant has a history of doing work without permits, jeopardizing the safety of residents and neighbors — (Myers) "The 1216 West Balboa facility actually had a fire several years ago during the summer ... and apparently, they were doing some work in the garage converting the two --- there's two two -car garages there, along with another garage, like a carport. Both of those two -car garages have never been used as long as I've been down there. In fact, what they were doing is converting one of the garages into --- originally it was a gym. Now, l guess, it's a laundry room or whatever. But they were actually moving a gas pipe to a washer and dryer without the proper City permits. So that type of information, in addition to, you know, the smoking and everything else, and the proximity of our houses, gives me an extreme amount of uneasiness. Because .. , there is a probability of fire, and it actually occurred at that facility." (HR, NCR UP /RA 00307 — 08) Disruptive noise and behavior from residents of Newport Coast Recovery — (Myers) — "I mentioned earlier about my two young kids, ages 9 and 7. Well, there's constant profanity that occurs from the facility" (HR, NCR UP /RA 00309) ; (Myers) - `And the music is just glaring out of this facility ... I was sitting in my living room, which races West Bay. So our lot is, what, 30 by 90. So, 90 -plus feet away, my house is shaking from this music. The music was full of profanity. " (HR, NCR UP /RA 00584) Tenant Impacts, with direct financial burden on neighboring property owners. (P. Bacich — owner of duplex across alley from Newport Coast Recovery) — "We did have an incident about two years ago where we had a car keyed after our tenant had a confrontation with some of the people at the rehab facility. And they left subsequently because they were so frustrated in having, as he said, pissing matches with 20- year -olds on a regular basis." (HR, NCR UP /RA 00578) Newport Coast Recovery — Appeal to City Council October 27, 2009 Page 12 Tenant impacts — (Myers) — "I've lost tenants in my rental unit because of the proximity and the noise and profanity coming from this place. So I've had a financial burden.) (HR, NCR UP /RA 00315) (Although testimony in the section above was offered in the context of Newport Coast Recovery's various use permit hearings, it was included in the administrative record that accompanied the July 7, 2009 reasonable accommodation staff report, and supported the Hearing Officer's finding that granting the accommodation would undermine a fundamental purpose of a City program.) Examples of evidence that the facility was not operated in compliance with state and local law: • NBMC § 20.91A.060 — °ln addition to the findings required by Section 20.91.035, the Hearing Officer shall make the following findings before approving or conditionally approving an application for a use permit in a Residential District ..." (A) The use conforms to all applicable provisions of Section 20.91A.050." (HR, NCR UP /RA 00376, 00378) • NB MC § 20.91A.050(B) —"Management and Operation. The property shall be operated in compliance with applicable state and local law.. ." (HR, NCR UP /RA 00234, 01002 —04) See evidence of Newport Coast Recovery's violations of state law identified above in section of this memorandum that lists evidence that supports the Hearing Officer's finding that granting the requested accommodation would result in a financial or administrative burden. Treating the use as a nonconforming use- Staff report for the July 7, 2009 reasonable accommodation public hearing — "[T]he applicant may believe this request, if granted, would allow it to continue operation without the imposition of reasonable conditions required under a use permit. This is not the case ... However, if all provisions of Ordinance No. 2008 -05 applicable to this facility were waived, it would result in undermining two of the basic purpose the ordinance was put in place to achieve — promoting public health safety and welfare, and to implement the policies of the General Plan by ensuring that conditional uses in residential neighborhoods do not change the character of such neighborhoods, and protecting the recovery and residential integration of the disabled. (NBMC Section 20.91A.010)° (HR, NCR UP /RA 00053) Waiver of overconcentration requirements — Staff report for the July 7, 2009 reasonable accommodation public hearing — "Preventing overconcentration and excessive clustering of residential care facilities, so that facilities are not congregated or overconcentrated to the extent of institutionalizing an area, was one of the primary purposes the provisions of the current Zoning Code were put in place to achieve ... (C]ourts have recognized that the presence of too many group homes in a residential neighborhood can potentially undermine the very purpose of such a district and therefore be unreasonable. In United Newport Coast Recovery— Appeal to City Council October 27, 2009 Page 13 States. v. City of Chicago Heights, 161 F.Supp.2d 619, 837 (N.D.11l. 2001), the District Court stated, 'There may be situations in which the distance between the homes is so little, where there is already more than one group home within 1000 feet, or where the homes are so similar in nature or operation, under which a request for a special use permit would fundamentally alter the City's purpose of avoiding clustering and preserving the residential character of certain neighborhoods.' 'The HUD /DOJ Joint Statement on Group Homes, Local Land Use and the Fair Housing Act indicates that those agencies are also concerned with the appropriate setting for residential care facilities, and are not in favor of overconcentration that leads to institutionalization of a neighborhood. (See HUD /DOJ Joint Statement on Group Homes, Local Land Use and the Fair Housing Act, quoted in the analysis for Request No. One, Finding Two, above.)" (HR, NCR UP /RA 00053 — 54) CITY OF NEWPORT BEACH MEMORANDUM TO: Honorable Mayor and Members of the City Council FROM: Janet Johnson Brown, Associate Planner Catherine Wolcott, Deputy City Attorney DATE: October 27, 2009 RE: Newport Coast Recovery, LP Appeal of Hearing Officer's Denial of Use Permit No. 2008 -033 (PA2008 -104) for property located at 1216 West Balboa Boulevard — Staff Analysis and Recommendation Regarding Hearing Officer's Decision A public hearing was reopened on July 7, 2009 by Hearing Officer Thomas W. Allen to consider the remanded use permit application with regard to evidence acquired after the January 12, 2009, hearing closed. As noted in the staff report submitted by City Attorney David Hunt, the use permit application was remanded to the Hearing Officer by the City Council following a public hearing held on April 14, 2009 on Newport Coast Recovery's appeal of the Hearing Officer's denial of the use permit. At the conclusion of the July 7, 2009 public hearing during which testimony was provided by the applicant's legal counsel, City staff and the City's legal counsel, and members of the public, Hearing Officer Allen again determined the findings to approve a use permit as submitted by Newport Coast Recovery could not be made. Staff was directed to prepare a supplemental resolution to deny Use Permit No. 2008 -033. Resolution No. HO- 2009 -022 was issued on September 17, 2009 and is attached to the administrative record (HR, NCR UP /RA 01072 -84)'. This memorandum presents discussion of evidence provided in the administrative record for the use permit hearings in support of the Hearing Officer's decision on July 7, 2009 to deny Use Permit No. 2008 -033. Staff concludes that there is substantial evidence in the record to support the Hearing Officer's decision. In general, substantial evidence has been defined as "evidence of ponderable legal significance ...reasonable in nature, credible and of solid value" (156 Cal.App.0 at 1371.) For a complete discussion of what kind of evidence is considered "substantial evidence" please refer to the staff memorandum prepared for the Newport Coast Recovery Reasonable Accommodation applications attached to the Staff Report submitted by the Office of the City Attorney. USE PERMIT HEARINGS AND HEARING OFFICER'S DECISION All references to the administrative record are designated "HR, NCR UP /RA"" followed by the page number. The designation means Hearing Record, Newport Coast Recovery, Use Permit/Reasonable Accommodation. City Hall • 3300 Newport Boulevard • Post Office Box 1768 a Newport Beach, California 92659 -1768 Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 2 The Hearing Officer is designated by Newport Beach Municipal Code ( "NBMC ") Section 20.91A.040 to approved, conditionally approve, or disapprove a use permit to allow an existing group residential care facility to remain in operation. In order to issue a use permit, he or she must be able to make each one of eleven (11) findings identified in NBMC Section 20.91.035(A) and in Section 20.91A.060 following a noticed public hearing. These findings are summarized in the Findings Chart at the end of this memorandum. As shown in Resolution No. HO- 2009 -033 (HR, NCR UP /RA 01072 -84), the Hearing Officer made five (5) of the eleven (11) required findings and was unable to make six (6) of the eleven (11) required findings. This memorandum does not discuss the findings the Hearing Officer was able to make, as they are included in the Resolution. The six (6) findings the Hearing Officer was unable to make, and evidence that supports that decision, are discussed herein: A. NBMC §20.91.035 (A) Finding accord with the objectives of the site is located. HEARING made. Discussion. No. 1: That the proposed location of the use is in this code and the purposes of the district in which OFFICER'S DETERMINATION: This finding cannot be The context that the Hearing Officer used in regards to this finding (that the proposed use is in accord with the objectives of this code) was the location of the facility on the Balboa Peninsula. During the January 12, 2009 public hearing, staff provided the Hearing Officer information to show that these uses, each of which are called out in NBMC Section 20.91A.060(D), are proximate to Newport Coast Recovery and could be affected by or affect the operation of the subject use. (See location maps on page HR. NCR UP /RA 00533 -34, and Diagram A, below.) Each of the uses depicted on the location map are described below. • Within 300 feet: Balboa Horizons Recovery Services (11 -bed licensed treatment facility located at 1132 West Balboa Boulevard, with an approved use permit) is one block east of Newport Coast Recovery, on the same side of the street. • Within 300 feet and across the street: Newport Elementary School for students from Kindergarten through 5th grade located at 1327 West Balboa Boulevard. • Within 750 feet: Christ Church's large (44 children capacity) state - licensed day care center located at 1400 West Balboa Boulevard. • Within 1250 feet: Outlets for alcoholic beverages are the American Legion Hall located at 215 15"' Street and Fry's Market located at 115 15th Street. • Within 500 feet: Ocean Recovery's Men's Facility (ADP - licensed for 22 persons located at 1115 West Balboa Boulevard, with an approved use permit). • Within 40 feet: Ocean Recovery's pending "6 and Under' ADP - licensed facility for women dually- diagnosed with eating disorders and alcohol or drug dependency at 1217 West Bay Avenue. Newport Coast Recovery Appeal – Use Permit October 27, 2009 Page 3 Diagram A – Newport Coast Recovery's Location Map 5� E Vrf4100 , S�UU Ameri can LegionOfi']'C. � Chrlstchurd, NN�� t Ocean Recovery Ocean Recovery - -- m - - 10 Balboa Horizons F 4Vf W Fry's Market - - -� _ - -�. J., &AZ " ,,.. Newport Elementary -_ o q�F FRONrgzjEVrr, - ,� RQNrW. -._ - NC Recovery - a — - a411ft The Hearing Officer found the location of Newport Coast Recovery in relation to its proximity to Balboa Horizons, a licensed residential care facility; to Christ Church's large day care center licensed by the State of California Department of Social Services; to Newport Elementary School; and to facilities either selling or serving alcoholic beverages made the use incompatible with the surrounding residential character of the neighborhood. Staff believes that the information in the administrative record is supportive of the Hearing Officer's determination that the proposed use would be incompatible with the surrounding residential character of the neighborhood; and therefore, his determination that this first finding could not be made is justified by the record. B. NBMC §20.91.035(A) Finding No. 2: That the proposed location of the use permit and the proposed conditions under which it would be operated or maintained will be consistent with the General Plan and the purpose of the district in which the site is located; will not be detrimental to the public health, safety, peace, morals, comfort, or welfare of persons residing or working in or adjacent to the neighborhood of such use; improvements in the vicinity OFFICER'S DETERMINATION: Discussion. Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 4 and will not be detrimental to the properties or or to the general welfare of the city. HEARING This finding cannot be made. The Hearing Officer, as well as staff, viewed aspects of this finding as being similar to Finding No. 1 above. As discussed in the Resolution of Denial, the City's General Plan policy LU 6.2.7 directs the City to regulate day care and residential care facilities to the maximum extent allowed by federal and state law so as to minimize impacts on residential neighborhoods. Approval of a use permit for the facility would include conditions regulating the use and operational characteristics related to curfew hours, smoking, transportation of clients off -site, trash collection, delivery of goods, and types of services provided. Neighbors and residents testified at the public hearings that: Traffic generated by this use is excessive (Bacich) "/ have been in the garage working, and in a 45- minute period, there [sic] was 18 vehicles that came up [to Appellanrs property]. And several of them were white vans, so they must have been picking up [residents] quite frequently"); (Bacich) "One Saturday, while we worked in the garage over there when we were turning tenants, we counted, 1 believe, 16 — 1 have it written down somewhere at home — 16 vehicles coming and going in a couple -hour period from the back alley [behind Appellant's property] ); (HR, NCR UP /RA 00293,00578-9) • The Applicant's vehicles block alleyways and driveways (Bacich) And sometimes there would be multiple cars blocking the alleyway while people ran in and out So the car transport is a factor'); (HR, NCR UP /RA 0093) The Applicant uses the neighbors' trash cans when their own are full, and residents at the facility litter the neighborhood with cigarette butts (Bacich) "They do have trash pick -up, but somehow we always seem to get cigarettes and different things in the trash cans of our tenants ... [O]ne of the [sic] time we were working at our place, and opened up - - because all the trash cans were full, and one as full as the lasagna and probably a couple - - hundreds of cigarettes butts'); (HR, NCR UP /RA 00294) The Applicant has a history of doing work without permits, jeopardizing the safety of residents and neighbors, particularly given the `zero lot lines" in this neighborhood (Myers) '[w]hat they were doing is converting one of the garages into - - originally it was a gym. Now, I guess, it's a laundry room or whatever. But they were actually moving a gas pipe to a washer and dryer without the proper City permits. So that type of information, in addition to, you know, the smoking and everything else, and the proximity of our houses, gives me an extreme amount of uneasiness. Because there is a potential - - not potentiality, but there is a probability of tire, and it actually occurred at that facility); (HR, NCR UP/RA 00308) Profanity spoken by residents of Newport Coast Recovery and profanity in music played loudly at Newport Coast Recovery (Myers) "i mentioned earlier about my two young kids, ages 9 and 7. Well, there's constant profanity that occurs from the facility'); (HR, NCR UP /RA 00309) (Myers) "So our lot is, what, 30 by 90. So, 90 plus feet away, my house is shaking from this music. The music was full of profanity." (HR, NCR UP /RA 00584) (McBride), , "I don't want my son to hear that kind of language that I hear consistently coming from this house.... when I'm walking past); (HR, NCR UP/RA 00950) Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 5 Secondhand (McBride) "1 don't want my son ... or to inhale the second -hand smoking [sic] that I hear or smell in the alley when I'm walking past'); ( HR, NCR UP /RA 00950) Tenant impacts. Additionally, neighbors whose properties are adjacent to the Appellants' complained that they had lost tenants because of the noise, profanity and confrontations coming from Newport Coast Recovery. The loss imposed a direct financial burden on one of the neighbors. (Myers) "I've lost tenants in my rental unit because of the proximity and the noise and profanity coming from this place. So I've had a financial burden'); (HR, NCR UP /RA 00315) (Bacich) "We did have an incident about two years ago where we had a car keyed after our tenant had a confrontation with some of the people at the rehab facility. And they left subsequently because they were so frustrated in having, as he said, pissing matches with 20- year -olds on a regular basis.'). (HR, NCR UP /RA 00578) The quotes above are from certified transcripts of the three hearings for Newport Coast Recovery, held December 8, 2008, January 12, 2009, and July 7, 2009. From this testimony, it did not appear to City staff that the operator could adequately control the facility's ADP - allocated caseload of clients (29) in a manner that allows the neighbors quiet use and enjoyment of their homes. While staff recommended that the Hearing Officer consider a condition limiting the client caseload to fourteen (14) in the January 12, 2009 staff report, the facility had been operating at this lower level (or below) for a significant period of time. Neighbors' testimony led the Hearing Officer to believe that, even at a lower bed count, the applicant may not be capable of properly managing the facility. Further, and as noted, the subject property is proximate (within 300 feet) to Newport Elementary School located at 1327 West Balboa Boulevard and proximate (within 750 feet) to Christ Church by the Sea's Children's Center, a large day care facility licensed by the State of Califomia Department of Social Services located at 1400 West Balboa Boulevard with a capacity of 44 children. These facilities could be affected by the use due to residents of Newport Coast Recovery using the open recreational area associated with Newport Elementary School and the potential for residents of Newport Coast Recovery to loiter, smoke, and engage in offensive and disruptive behaviors incompatible with nearby school and daycare uses. In fact, one 35 -year Newport Beach resident testified she believed the conditions in the neighborhood had deteriorated so substantially that she removed her children from Newport Beach Elementary. (Deininger) (°Mr. Allen: 'You took your children out of Newport Elementary because of the conduct of the - -' Ms. Deininger.• 'Because of the atmosphere there.' Mr. Allen: `- - rehab facilities ?' Ms. Deininger: 'Yes.' "). (HR, NCR UP /RA 00296) The Hearing Officer found the operator's inability to effectively manage and control the proposed use would: (a) adversely impact the neighbors' quiet use and enjoyment of their homes; as well as (b) negatively affect other nearby uses. Based on testimony provided during the public hearings, the continued use of the subject property as a residential care facility in this location would be detrimental to the public health, safety, peace, morals, comfort, or welfare of persons residing or working in or adjacent to the facility. C. NBMC §20.91.035 (A) Finding No. 3: That the proposed use will comply with the provisions of this code, including any specific condition required for the proposed use in the district in which it would be located. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 6 Discussion. The Hearing Officer found that the facility does not comply with the provisions of the code, specifically with the operational standard stated in NBMC Section 20.91A.050(B), that the property shall be operated in compliance with applicable state and local law. As reported in the July 7, 2009 staff report, staff provided information that Newport Coast Recovery had accepted minor clients without the appropriate Department of Social Services (DSS) license or the adolescent waiver required by the Department of Alcohol and Drug Programs (ADP) to provide residential treatment to minors (HR, NCR UP /RA 00010 -11). This violation of state law resulted in the issuance of a Notice of Violation of Law to Newport Coast Recovery by DSS (HR, NCR UP /RA 00016 -18). Other supporting evidence provided to the Hearing Officer included a Newport Beach Police Department Employees Report dated March 31, 2009 (HR, NCR UP /RA 00097 -98) and an email from ADP dated April 3, 2009, confirming that ADP had not granted an adolescent treatment waiver to Newport Coast Recovery (HR, NCR UP /RA 00090). The Hearing Officer concluded from the information and testimony provided during the public hearing that Newport Coast Recovery was not being operated in compliance with state law, and therefore, that the use did not comply with the provisions of the Newport Beach Municipal Code. D. NBMC §20.91.035(A) Finding No. 4: If the use is proposed within a Residential District (Chapter 20.10) or in an area where residential uses are provided for in Planned Community Districts or Specific Plan Districts, the use is consistent with the purposes specified in Chapter 20.91A and conforms to all requirements of that Chapter. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Discussion. The Hearing Officer's discussion of this finding centers on NBMC Section 20.91A.060(D) again, similar to Finding No. 1. Staff concluded it was appropriate to apply the American Planning Association's ( "APA ") standard to this application. The APA Standard reads as follows: "Finding #5. Community residences should be scattered throughout residential districts rather than concentrated in any single neighborhood or on a single block. For a group home to enable its residents to achieve normalization and integration into the community, it should be located in a normal residential neighborhood. If several group homes were to locate next to one another, or be placed on the same block, the ability of the group homes to advance their residents' normalization would be compromised. Such clustering would create a de facto social service district in which many facets of an institutional atmosphere would be recreated and would change the character of the neighborhood. "Normalization and community integration require that persons with disabilities be absorbed into the neighborhood's social structure. The existing social structure of a neighborhood can accommodate no more than one or two group homes on a single block (emphasis added). Neighborhoods seem to have a limited absorption capacity for service dependent people that should not be exceeded. Social scientists note that this level exists, but they can't quite determine a precise level. Writing about service dependent populations in general, Jennifer Wolch notes, 'At some level of concentration, a community may become saturated by services and populations and evolve into a service dependent ghetto." Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 7 From the APR's Policy Guide on Community Residences, September 22, 1997, (HR, NCR UP /RA 00136) The City has incorporated the APA standard of "no more than one or two group homes on a single block' into NMBC §20.91A.060 (D)(3). Newport Coast Recovery is located in the mid - Balboa Peninsula area which, as defined by NBMC Section 20.91A.060(D)(2) is a part of the Nonstandard Subdivision Area characterized by properties with short setbacks and short blocks. Per NBMC Section 20.91A.060(D)(2), the Hearing Officer can determine the applicable block length for the mid - Balboa Peninsula area. He chose a median block length of 617 feet, as permitted under NMBC Section 20.91A.060(D)(3). While the NBMC defines a block as an area bounded on all sides by streets (NBMC Section 20.03.030), the Hearing Officer may use NMBC §20.91A.060 (D)(3) to extend a block beyond smaller streets like 12"' and 11°i Streets in an effort to "eliminate the differences in block lengths' to achieve a 617 -foot block standard. He did so in this instance. During the January 12, 2009 public hearing, the Hearing Officer noted that within the 617 -foot median block length where Newport Coast Recovery is located there is already one 11 -bed residential care facility (Balboa Horizons). He found the proposed use at 1216 West Balboa Boulevard was within the same extended 617 -foot block as Balboa Horizons, and determined the proposed use would result in an overconcentration of residential care facilities within the neighborhood. He used this information to direct staff to prepare a resolution that this overconcentration showed the proposed use was inconsistent with the purposes specified in Chapter 20.91A and would not conform to all requirements of that Chapter (HR, NCR UP /RA 00610 -22). The Hearing Officer reiterated his position on the denial of the use permit on the basis of overconcentration during the July 7, 2009 public hearing for the reasonable accommodation applications, stating "the primary focus of thinking remains the overconcentration issue that / think was founded in the first Resolution we did' (HR, NCR. UP /RA 00960). The Hearing. Officer also expressed his opinion on the matter of overconcentration in the Order of Hearing Officer dated August 18, 2009, in which he directed staff to prepare a resolution denying the reasonable accommodation (HR, NCR UP /RA 01068). E. NBMC §20.91A.060 Finding A: The use conforms to all applicable provisions of NBMC §20.91A.050. These development and operational standards are summarized as follows: 1. No secondhand smoke can be detectable outside the property. 2. Operations of the facility must comply with state and local law, and the submitted management plan, including any modifications required by this Use Permit. Each plan shall provide a contact name and number to the City. 3. In order to ensure that unlicensed residential care facilities operate in a manner consistent with state and federal law and established industry standards and to ensure that operators do not have a pattern or practice of operating similar facilities in violation of state or local Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 8 law, no services requiring a license can be provided if the facility does not have a license for those services. 4. There shall be no more than two persons per bedroom plus one additional resident, unless a greater occupancy is requested and granted. Occupancy must also comply with State licensing if applicable. 5. If certification from an entity other than ADP's licensing program is available, applicants must get that certification. 6. All individuals and entities involved in the facility's operation and ownership must be disclosed. 7. No owner or manager shall have any demonstrated pattern of operating similar facilities in violation of the law. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Discussion. The Hearing Officer determined this finding could not be made, specifically with regard to the second operational standard listed above (the facility must comply with state and local law), based on the newly acquired evidence and testimony presented during the July 7, 2009 reopened public hearing. As this finding is discussed in greater detail in NBMC Section 20.91.035(A) Finding No. 3 above (item #3), staff does not believe it necessary to restate the discussion here. F. NBMC Section 20.91A.060 Finding D: The use will be compatible with the character of the surrounding neighborhood, and the addition or continued maintenance of the use will not contribute to changing the residential character of the neighborhood, such as creating an overconcentration of residential care uses in the vicinity of the proposed use. In making this finding or sustaining such a finding, the Hearing Officer shall consider, as appropriate, the following factors: 1. The proximity of the use location to schools, parks, other residential care facilities, outlets for alcoholic beverages and any other uses which could be affected by or affect the operation of the subject use; 2. The existence of substandard physical characteristics of the area in which the use is located such as lot widths, setbacks, narrow streets, limited available parking, short blocks, and other substandard characteristics which are pervasive in certain areas of the City of Newport Beach, including portions of West Newport, Lido Isle, Balboa Peninsula, Balboa Island, Corona del Mar and Newport Heights, which portions were depicted on a map referred to as the Nonstandard Subdivision Area presented to the Newport Beach Planning Commission on September 20, 2007 and on file with the Director of Planning; and 3. Whether, in light of the factors applied in subsections 20.91A.D.1 and D.2, it would be appropriate to apply the American Planning Association standard of permitting one or two such uses per block. Median block lengths in different areas of Newport Beach widely range from 300 feet in the Nonstandard Subdivision Areas to as much as 1,422 feet in standard subdivision areas. The average calculable block length in much of the standard Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 9 subdivision areas is 711 feet and the calculable median block length is 617 feet. The Hearing Officer shall apply the American Planning Association standard in all areas of Newport Beach in a manner that eliminates the differences in block lengths. In making this determination, the hearing officer shall be guided by average or median block lengths in standard subdivisions of the City. The Hearing Officer shall retain the discretion to apply any degree of separation of uses, which he or she deems appropriate in any given case. A copy of the American Planning Association standard is on file with the Director of Planning. HEARING OFFICER'S DETERMINATION: This finding cannot be made. Discussion. The Hearing Officer's interpretation of this finding mirrored that of the previous finding in section D (finding #4) above, and staff incorporates examples of evidence cited in Section III(D) in this section. In addition, staff incorporates by reference the evidence cited in the October 27, 2009 staff memorandum that accompanies this memo, addressing evidence that supports the Hearing Officer's denial of reasonable accommodation Requests No. 1 and 2 Section III(D), pages 8 -13 of staff memorandum on Newport Coast Recovery requests for reasonable accommodation). Additionally, the Hearing Officer included a statement in his Order dated August 18, 2009, regarding the request for reasonable accommodation, that the granting the accommodation would result in an overconcentration of recovery facilities in the area (HR, NCR UP /RA 01068). Staff believes that there is sufficient evidence in the record to conclude that the Hearing Officer's action to determine that this Finding could not be made is justified by the record. Newport Coast Recovery Appeal — Use Permit October 27, 2009 Page 10 FINDINGS CHART FINDINGS REQUIRED TO APPROVE A GROUP RESIDENTIAL USE PERMIT NBMC Code Section What the §20.91.035 — A.1. That the use and proposed conditions will allow the use to be consistent with the General Plan and not be detrimental to public §20.91.035 —A.2. health, safety, peace, morals, comfort, or welfare of persons residing in or adjacent to the neighborhood of the use, and won't be detrimental to the properties or improvements in the vicinity or to the general welfare of the City. §20.91.035 — A.3. .... §20.91.035 —A.4. That the proposed use complies with Chanter 20.91A §20.91A.060 - A §20.91A.060 — F Delivery of goods is made within compatible hours and won't adversely impact the neighborhood. law., ATTACHMENT 4 Email dated October 16, 2009 Staff Report: Newport Coast Recovery - Appeal of Hearing Officer's Denial of Use Permit and Reasonable Accommodation Hunt, David From: Sent: To: Subject: CyAutold: CycomPath: CyMatterld: CyMultiRecMemos: CyStaffId: Mr. Polin and Mr. Brancart: Hunt, David Friday, October 16, 2009 9:40 AM Steve Polin Esq. (spolin2 @earthlink.net); Christopher Brancart Esq. (cbrancart@brancart.com ) Hearing October 27 and Agenda Materials (File: A09 -00583 Pacific Shores: RA Appeal) 2052127 C:lcycomsgll 2042134 N DRH We confirm the appeal of the denial of Pacific Shores' application for reasonable accommodation is scheduled for hearing by the City Council at its regular meeting on October 27, 2009. We will set the matter for a time certain immediately following the appeal in the Newport Coast Recovery matter so there is some certainty as to when the hearing will be held. We are in the process of preparing our staff report in the appeal. It must be to the City Clerk Wednesday morning, October 21, 2009, to go out with the regular agenda packet that afternoon. If you wish to have an written presentation routed to the City Council with the agenda packet, please provide it to us by close of business on Tuesday, October 20, 2009, and we will be sure it is routed with our staff materials. Thank you in advance for your anticipated cooperation. Please let us know if you have any questions or concerns. Sincerely, David R. � aS City Attorney City of Newport Beach 3300 Newport Blvd Newport Beach, CA 92658 -8915 (949) 644 -3131 city. newport- beach.ca. us CONFIDENTIALITY NOTICE: This email may contain material that is confidential, privileged and /or attorney -work product for the sole use of the addressee. Any review by, reliance or distribution by others or forwarding to others without express permission is strictly prohibited. If you receive this transmission in error, you are advised that any disclosure, copying, distribution, or the taking of any action in reliance upon the communication is strictly prohibited. Moreover, any such inadvertent disclosure shall not compromise or waive the attorney - client privilege as to this communication. If you have received this communication in error, immediately notify the sender. Thank you. Authorized hi Publish Advertisements of all kinds Including public notice% by Decree of the Superior Court of Orange County. California Vumtt September 29. 1%1, and A -24831 June 11, PROOF OF PUBLICAITiCA22 0 06 V -i. STATE OF CALIFORNIA) %.- ) ss. COUNTY OF ORANGE ) I am a Citizen of the United States and a resident of the County aforesaid: I am over the age of eighteen years, and not a party to or interested in the below entitled matter. I am a principal clerk of the NEWPORT BEACH - COSTA MESA DAILY PILOT, a newspaper of general circulation, printed and published in the City of Costa Mesa, County of Orange, State of California, and that attached Notice is a true and complete copy as was printed and published on the following dates: October 17, 2009 declare, under penalty of perjury, that the foregoing is true and correct. Executed on October 20, 2009 at Costa Mesa, California. i Signatumd =Mnsl 8 -tor 33 and RA2009 W9 KN/rosla Me%n Daily Pilot sa9gG Gkw RESDENTIAI (AAE FACRfrf USE lefRMfT AND REASONABLE ACCOMMODATION NEWPORT (OAST RE(OYERY, LP NOTICL 6 KREBY GNEN that me City Cou'll of to Cely of Newport Beach will conduct a pudic hearing on Oclope, 27. 2009. at 7W p.m n Me City Council Chambers (BUlOrlg A) at 330(1 Newport Boulevard. Newport Beare. Caklorora The City Coond wiry cunmde, an appeal of the (tearing DMrai decisions to deny the applications filed by Newport Coast Recovery. LP for Use Permit No 2008 -033. and Reasonable Accommodation No 2003009 for property located at 1216 Wet Balboa Boulevard. The appeals were tied by the applicant. Following n a brief description, of the appubuns. w War laawiF Nor. 2006032: An appheabon requesting Approval of a use permit to allow a residential Care facility to operate a acemed adull alcohol aria drug abuse recovery treatment fscity for an only RAaaadA, AgsnwlaaNn Na 2000-009: A Reasonable Accommadabon Application fa an e- nbng resdmlla care facility to opeele a keraec adult alcohol andior drug abuse recovery aric easement facility in an R 1 Drslrict. where such tae are nor permitted. The applicant requets rise fol 1. An exemption from the portions of FIRM[ Section 20.10.020 (Residential Districts. Land Use Regulations) that remove Residential Care Fault Les. Geoaal to be established only in residents disMcls zoned Multi Family Resdental (MFR' with a use permit. sublet( to Me opaationa conditions recommended by City slaty in the January 12. 2009 %left report for Use Permit No 200 &33, including a maximum occupancy of lit residents. which was denied by the Newml rational Standards). including a waiver of 1 upancy restriction of two persons per be in plus one staff member, and to allow if aceupancy of IS residents. An exemption from the parking remunemer one off- street parkin space for each Mr ident beds, as we<keed in NOMC Sect, mueements) la Residential Care. Genera use sanficaltons, and to apply the oft s1reet park reamrements applicable to Two-family Rev. ,',At (P 2) use classifications which requires o aB street parking spaces par dwelling unit, Treat the use of the licensed residential care dley as a legal nonconforming use, Apply the California Building Code provisions it were applicable at the time the residential 'e facility was established as relates to life d fire safety, outlays. and A waiver of the required finding specified in MC Section 20.91A060 (11), relative to the wpabbility of the use with to character of r surrounding neighborhood, which requires a ding Mal the continued use will not contribute the changing of the residential character of i neighborhood, such u creating an overcoe relate. of rmodenWl care uses in the vKimty. J waiving the impact analysis contained in the :Iors A through C which the Hearing Office, at consrMr in making or sustaining the finding I, regard to the proximity of the use to roots. churches, playgrounds. day care centers. I alcoholic beverage outlets, and the applve n of Me American Planning Association slim d of permitting one or two such uses par s activity has been determined to be calegorr ly exempt under the reauuemenls of the Idornia Envnonmenlal Quality Act (CEQA) der Class I (Existing Facilities). This class of elector has been determined not to have a ndmant effect on the environment and is emit from the provisions of CEQA. This noty is also Covered by the general rule that QA applies only to protects that have the lentil for causing a significant effect on the reconnect (Section 15061(b)(3) of the CEQA idelnes). 11 can be seen worth certainty that ere Is no possibility that this activity will have 4gp11Kant effect an the environment and II is I sublect to CE QA. interested parties may appear and peasant timony in regard to this application. It you ,binge this project in court. you may be lead to raising only those issues you Or more else raised It the public hearing scribed m this notice) Or in written cor- pondence delivered to the City. al. or prior the public hearing The staff report may be 'rowed at the City Clerk's Office, City of wp .1 Beach. 3300 Newport Boulevard, New 't Beach, California. 92663 or at the City of wport Beach weasite of wep.saay pKK to the hearing For more prmabon. cyn vGap) Fits 3232 or (949) 61a 32. To be added 10 . nermaoent notification I of these hearings, email I6resvn LA wlpeaMadaaa4w and ask to recave Mesa "RECEIVED AFTER AGENDA Brown, Leilani 1� 2 I7R" -1 1 From: Denys Oberman Id .oberman @obermanassociates.coml Sent: Wednesday, October 21, 2009 3:25 PM To: Brown, Leilani; City Clerk's Office Subject: Document re group residential use - please insert in Council package and into public record. Attachments: City- Correspondence re group residential use at 1216 W Balboa.doc Importance: High Please include this document in the information package concerning the Group Residential Use located at 1216 W. Balboa, Newport Coast Recovery that is being forwarded to City Council for 10 -27 meeting ----- -and, Please enter this document into public record. I appreciate your confirmation, and your assistance. Denys H. Oberman, CEO A OBERMAN OBERMAN Strategy and Financial Advisors 2600 Michelson Drive, Suite 1700 Irvine, CA 92612 Tel (949) 476 -0790 Cell (949) 230 -5868 Fax (949) 752 -8935 Email: d.obermanaobermanassociates.com CON FIDENTI A L,ITY NOTICE: 'nte documents accompanying this transmission contain confidential information belonging to the sender which is legally privileged. The information is intended only for the use of the individual or entity named above. If you are not the intended recipient, you am hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this telecopied information is strictly prohibited. If you have received th s transmission in error, please notify us imntodiately at 9491476-0790 or the electronic address above, to arrange for the return of the document(s) to us. October 20,2009 City of Newport Beach att: Dave Kiff ,City Manager and City Clerk 3300 Newport Blvd. Newport Beach, CA Re: Group residential care and treatment use- UP No. 2008 -033 and Reasonable Accomodation No. 2009 -009- Newport Coast Recovery, located at 1216 W. Balboa Blvd. Dear Dave, This letter confirms our prior discussion with you clarifying several prior testimonies in connection with this use. We hereby request that you enter this into the public record in advance of the appeal scheduled to be heard by Council on October 27,2009. Following is a summary of our corrections and amplification to Staff Reports and record of Public Hearings in connection with this Use. LOver- concentration of uses in the immediate neighborhood creating Institutionalization -There are currently 4 known residential care and treatment uses within 300 feet of one another, all within several hundred ft. of Newport Elementary School .Three of these have already been approved by the City - -1 132 W. Balboa Blvd( large female ADP); 1115 W Balboa(large male ADP); and 1217 W Bay Ave( small female - permitted by right). The fourth, subject Use at 1216 W Balboa, is less than 300 ft from Newport Elementary School and adjacent playground. In addition to these residential uses, the City has approved a large female ADP facility at 1601 W Balboa, and a small male facility at 900 W Balboa The American Planning Association has stated that drug/alcohol recovery facilities should be located at least 1,000 ft or more from one another,and has acknowledged that their impacts on the community(including those seeking legitimate recovery), are greater than those associated with other types of group homes(ex.,elderly). In presentations and discussion, staff reports documenting the hearing officer's ruling failed to mention the facility at 1115 W Balboa when addressing Over - concentration. 2. Repeated Illegal Business Practices - The record contains evidence of numerous illegal business practices demonstrated by this operator, including: illegal treatment of minors; health and safety, fire code violations; and others. The operator also illegally operated another residential facility at 1219 W Balboa, which was not identified in his CUP application, but which the operator admitted to in the December, 2008 public hearing(the initial CUP hearing). Page 2- Kiff correspondence re group residential use at 1216 W. Balboa 3. Public testimony concerning impacts- A petition concerning impacts and requesting UP denial and abatement was signed by 43 families with children attending and using Newport Elementary School and playground and was submitted to the City at the December, 2008 hearing. Additionally, several parents testified at the hearing. The City has a duty, both for the neighbors and those seeking legitimate recovery, to prevent Institutionalization associated with Over- concentration, and protect public health and safety. This neighborhood is heavily Over - concentrated with this type of use. This operator has proven to be irresponsible in his business practices, and has created risk both to his clients, and the community.This is precisely the reason that regulation is needed - -- regulation that the City has adopted and enforced with other uses (including other types of group homes). We request that the City to uphold the rulings of the Hearing Officer, an affirm the denial of both Use Permit and Reasonable Accomodation. Sincerely, Denys H. Oberman - prepared at the request of: RESIDENTS Of THE CENTRAL PENNINSULA STEVEN G. PCUN, ESQ. Attorney At law RECEIVED 7109 OCT 27 AMW32 c rl �s "'K : �ctober 27, 2009 SENT VIA ELECTRONIC MEAN David Hunt, Esquire City Attorney City of Newport Beach 3300 Newport Blvd. Newport Beach, CA 92663 Re: Dear Mr. Hunt, 3�V034 Tr.NNYSON ST. N.W. WAsmi%6ToN, D.C. 20015 TEL (202) 331 -5848 FAx (202) 537 -2986 SrouN2C'Qe_kRTnu x.Ner "RECEI'JE AFTER AGEP�OA PRINTED:" Appeal of Newport Coast Recovery, LLP Please be advised that as of October 23, 2009, Newport Coast Recovery, LLP (hereinafter "NCR "has ceased operations. Based on this change of status, its appeals of the denial of its application for a use permit and requests for a reasonable accommodation are moot in terms of its administrative remedies under the Newport Beach Municipal Code. Therefore, NCR will not be going forward on its appeal before the City Council on October 27, 2009. This should not be construed as a concession that the issues in the Newport Coast Recovery, LLP, el al v. City of Newport Beach, Case No. SACV 09- 701 -JVS (RNBx) are also moot since there are now important issues concerning damages. During the time period of 2002 -2008, Newport Coast Recovery located at 1216 West Balboa Blvd, was a viable business entity providing the only residential "men's only," "primary" drug and alcohol rehabilitation program in Newport Beach.' After the enactment of Ordinance No. 2008-005, Primary care facilities usually have a program lasting three to four weeks and are an intensive treatment type which requires a doctor or psychiatrist to examine the patient and refer them to the facility. Residents stay in the facility is on in- patient basis for the duration of their stay but are allowed visitors at specified times and only after their first week in treatment. The first week is generally a time for detoxification if needed or if it has not been completed in a hospital already, and also a time to settle in and become introduced to the recovery program. The program at a primary care facility will consist of intensive therapy groups, individual counseling and written work throughout the day. Also included are attendance at recovery meetings such as Narcotics Anonymous and Alcoholics Anonymous. In primary care facility, addicts begin the process of living each day without drugs, yet without much stress of exposure to the outside world as this may cause heavy emotional reactions resulting in the relapse of the resident. David Hunt, Esquire Page 2 October 23, 2009 NCR applied for a use permit. The City staff recommended approval of the use permit application. However, after hearing the complaints made by NCR's neighbors and from representatives of the Concerned Citizens of Newport Beach, the Hearing Officer denied the application and incorporated into his decision the unsupported, undocumented, generalized discriminatory animus expressed? The recommendation of the denial of NCR's use permit had a negative effect on NCR's business. This decision was appealed to the City Council. After being notified of "after acquired evidence" concerning allegations of providing residential treatment of two minors, the City Council remanded the matter for a further hearing on this issue. This was done over the objection of NCR in that this was a licensing issue and not a zoning issue. At the remand hearing it was apparent that the City expended considerable time and resources in creating an issue that NCR was operating in violation of its license, hence it was violating the laws of Newport Beach. NCR objected on the basis that only the California Department of Alcohol and Drug Programs hasj urisdiction concerning licensure compliance. As a result of the hearing, the publicity surrounding the treatment of the two minors, NCR began to receive extremely harassing and vituperative phone calls and emails. This phone calls and emails were not only directed to the NCR staff at work, but also to the homes of NCR's principals and their families. In addition, NCR's business was so adversely affected in the manner that the City chose to pursue and publicize this issue that it could no longer afford to stay in business, hence the closure of the NCR facility. NCR is preserving all the issues raised in my July 29, 2009 letter to Mr. Allen, which I have attached. cc: Christopher Brancart Newport Coast Recovery Catherine Wolcott Patrick Bobko Dana Mulhauser Paul E. Smith 'It should be noted that the same complaints were made by the public at the hearings of Balboa Horizons and Ocean Recovery, which are in same vicinity as NCR. The permits of these facilities were approved. STEVEN G. POLIN, ESQ. Attorney At Law SENT VIA ELECTRONIC MEAN Mr. Tom Allen Hearing Office City of Newport Beach Newport Beach, CA Dear Mr. Allen: RECEIVED 79 OCT 27 AM 11, 32 cf CliYj(lly'29 '2tlOt3 - "" Reasonable Accommodation Request Newport Coast Recovery 3034 "IT.Nwr -4 ST. N.W. WAsnIN6TON, D.C. 20015 TFi (202) 331 -5848 FAx (202) 537 -2986 SP0Un2@ranTnuNx.KeT Please consider this as additional supplemental to the record of the request of Newport Coast Recovery ( "NCR ") for a reasonable accommodation in the application of the City of Newport Beach's zoning code. STATE LICENSING AND COMPLIANCE, WITH STATE LICENSING In 2007, the City of Newport Beach commenced a campaign to convince state officials that the Department of Alcohol and Drug Programs ( "ADP ") should take into consideration whether a city has more than its fair share of substance abuse treatment facilities and whether overconcentration of such facilities should be part of the licensing criteria for application for new and renewed licenses. (See Exhibits A and B) (Health & Safety Code §§ 11834.01 - 11834.50. The City's position was rejected by the California Attorney General in opinion number 90Ops. Cal. Ally. Gen. 109. (See Exhibit C) The Attorney General opined in the negative to the question of whether the Department of Alcohol and Drug Programs can deny an application for licensure or suspend or revoke the license of an alcoholism or drug abuse treatment facility because the particular community already has more than a sufficient number of treatment facilities to meet the local need. Specifically, the Attorney General stated "... each licensure applicant must complete an application form, obtain a fire clearance, and pay a fee to the Department. (Sec also § 11834.09, subd. (b).) Sections 11834.01 and 11834.03 provide no authority for the Department to deny a license because the community already has an overconcentration of such facilities." The City is pre - empted by Health & Safety Code § 11834.01 - 11934.50 from denying a use permit or reasonable accommodation request by a facility licensed by ADP on the basis of overconcentration. In the same opinion, the Attorney General opined that only ADP has the authority to deny, suspend or revoke a license based on the standarjs set by the State Legislature. The City seeks to sidestep this requirement and use permit process as a vehicle to determine NCR's compliance with Tom Allen Hearing Officer July 29, 2009 2 its licensure requirements. The City seeks to make a record and convince the Hearing Officer that NCR acted in violation of state law in the admission of two minors into its facility. Both the City and the parents of the minors have complained to both the Department of Social Services ( "DSS ") and ADP about this incident. The City's only legal recourse is to complain to DSS and ADP about what it perceives to be NCR's violation of its licensure. A request for a reasonable accommodation is not a licensure compliance hearing or an adjudication on compliance with state licensure standards. The City alleges that NCR has engaged in a "pattern and practice" of violating state and local law. The City cannot deny a request for a reasonable accommodation on the basis of incident that may be a minor violation of its licensure requirements. One incident does not a "pattem and practice" make. See, United States v. Parma, 661 F.2d 562, 573 (6th Cir. Ohio 1981 xA pattern and practice suit necessarily involves a number of discriminatory acts.) ne City erroneously asserts that an investigation by two state agencies involving the same incident constitutes a pattern and practice of violating state or local law. DSS closed out its investigation without taking any action. ADP allegedly has stated that it will investigate the incident. Regardless of the outcome of the ADP investigation, this tribunal is without authority to use an alleged licensing violation as the basis for denying NCR's request of a reasonable accommodation. Matters relating to licensure are not proper matters for consideration in a zoning hearing. See. Oconomowoc Residential Programs v. City of Greenfield, 23 F. Supp. 2d 941, 958 (L•.D. Wis.1998); Oconomowoc Residential Programs, Inc. v. City of Milwaukee, 300 F.3d 775,785 (7th Cir. Wis. 2002)(Complaints about mistreatment of patients which does not result in refusal, revocation or suspension of license by the State agency found not to have a causal connection to matters relating to zoning.) The crux of the dispute raised by the parents of the minors is contractual in nature. It's a business dispute. It may or may not be a violation of NCR's license, and if it is it may be considered a minor infraction. There are appropriate forums and means for addressing such a dispute. Unfortunately for NCR, the Hearing Officer accepts the complaints of the parents at face value and has included the complaints to the findings in denying NCR's request for a reasonable accommodation.' NCR has operated as NCR at this location since 2002. It is quite obvious that the City staff has expended a considerable number of man hours to secure the testimony of the two parents, emailing ADP, amending and appending the staff report to put before the Hearing Officer one incident, which occurred in March, 2009. StafT'has alluded to other complaints it has received since the hearing which has not been shared with NCR or its attorneys. Notwithstanding the 'Many of the allegations of one of the parents about her contact with NCR cannot be verified. For instance, one of the parent's claims a demand has been made to both Mr. Newman and the attorneys for NCR. There is no such record of such a demand being made. The City has muddied the waters by bringing the parents into the hearing and giving a statement that is not subject to cross examination to complain about NCR. Tom Allen Hearing Officer July 29, 2009 immense expenditure of resources to convince by the City's Staff, it has failed to demonstrate a connection between issues of licensure and zoning. The City intentionally placed NCR in a position of facing serious allegations in a public forum without the ability or the legal means to respond. It is error and a violation of federal law to find that "NCR refused to respond to the allegations." NCR is prohibited by federal law from disclosing much less discussing its clients and substance abuse treatment history. See 42 U.S.C. 2901313-2; 42 CFR 2.22, et seq. REASONABLE ACCOMMODATION ANALYSIS The staff recommendation is that a finding cannot be made as to future residents concerning the necessity of residing in NCR. The staff concluded that there exist other similar facilities in close proximity to NCR that future residents could choose. (Staff report, page 13) This conclusion is contrary to the law on reasonable accommodation. Schwarz v. City of Treasure Island, 544 F.3d 1201, 1225 - 1226( 11th Cit. 2008X The availability of another dwellingsomewhere within the City's boundaries is irrelevant to whether local officials must accommodate recovering substance abusers in the halfway houses of their choice.) See Howard v. City of Beavercreek, 276 F.3d 802, 806 -07 (10th Cit. 2002) (analyzing whether the requested accommodation was necessary to afford the plaintiff an "equal opportunity to enjoy the housing ... of his choice "); Hovsons, Inc. v. Township of Brick, 89 F.3d 1096, 1103 (3d Cir. 1996xrejecting argument that township reasonably accommodated plaintiff by allowing construction of a nursing home in another area of town). 42U.S.C. 3604( I)( 3)( B) contains three operative elements: "equal opportunity," "necessary," and "reasonable." With respect to the phrase "equal opportunity," the House Report on the Fair Housing Act offers relevant context: The Fair Ilousing Amendments Act, like Section 504 of the Rehabilitation Act of 1973, as amended, is a clear pronouncement of a national commitment to end the unnecessary exclusion of persons with handicaps from the American mainstream. House Comm. on the Judiciary, Fair Housing Amendments Act of 1988, H.R. Rep. No. 711, 100th Cong., 2d Sess. 18, reprinted in 1988 U.S.C.C.A.N. 2173, 2179 (footnote omitted) (hereinafter 1988 U.S.C.C.A.N.) (emphasis added). A cogent analysis of "equal opportunity" can be found in Smith & Lee Assocs. v. City of Taylor, 102 F.3d 781, 794 -795 (6th Cit. 1996). The Court stated: We find persuasive the analysis of courts that define equal opportunity under the FHAA as giving handicapped individuals the right to choose to live in single - family Tom Allen Hearing Officer July 29, 2009 neighborhoods, for that right serves to end the exclusion of handicapped individuals from the American mainstream: The Act prohibits local governments from applying land use regulations in a manner that will exclude people with disabilities entirely from zoning neighborhoods, particularly residential neighborhoods, or that will give disabled people less opportunity to live in certain neighborhoods than people without disabilities. Bryant Woods Inn, Inc. v. Howard County, 911 F. Supp. 918, 946 (D. Md. 1996) (citation omitted); see also City of Edmonds v. Washington State Bldg. Code Council, 18 F.3d 802, 806 (9th Cir. 1994), afPd, I IS S. Ct. 1776 (1995) ( "Congress intended the FHAA to protect the right of handicapped persons to live in the residence of their choice in the community. "). Moreover, the phrase "equal opportunity," at least as used in the FHAA, is concerned with achievingequal results, not just formal equality. See City of Edmonds, 18 F.3d at 806 ( "The FIJAA imposes an affirmative duty to reasonably accommodate handicapped people. "); Proviso Assn of Retarded Citizens v. Village of Westchester, Ill., 914 F. Supp. 1555, 1563 (N.D. Ill. 1996) (rejecting city's argument that "because Plaintiffs are subject to requirements imposed on all groups of unrelated non - disabled people, they have an 'equal opportunity' to live in the ... dwelling "). 4 The City Staff ignores the requirement that a future resident's "equal opportunity" is a choice that person gets to make, not a choice the City can make by making one less dwelling unavailable or asserting as long as there are other facilities of a similar nature, then a residents "choice" of housing will be preserved. The Staff Report states that NCR failed to provide information as to what the optimum number of residents would make it financially viable. (Staff report, page 15). NCR is not required to put forward any information on financial viability unless it is seeking an accommodation in whole or in part on financial viability. The City has not put forward any case law that an applicant is required to demonstrate financial viability if it is not seeking an accommodation based on the same. The burden is on the City to show that the requested accommodation is unreasonable. The City has failed to do so. As was argued above, the City cannot claim that NCR committed "illegal acts" on issues involving licensing and refuse to grant an accommodation that involve land use and zoning. The City has consistently applied the wrong standard in determining whether the applicant's requests are reasonable. The standard is whether the request seems reasonable on its face. US Airways, Inc. v. Barnett, 535 U.S. 391, 401A02 (2002). The burden then shifts to the City to demonstrate that the requested accommodation is an undue burden financially or administratively or will fundamentally alter its zoning scheme. The City concedes that it will not be burdened financially or administratively. The City posits that granting the requested accommodation will cause a fundamental alteration to the City's general plan because it would allow more than one such facility per block and Tom Allen Hearing Officer July 29, 2009 5 would cause overconcentration. All requests for a reasonable accommodation in the land use context require an alteration to a "rule, policy, practice or procedure." An alteration is not a fundamental alteration. Allowing NCR to continue at a location it operated at since 2002 is not a "fundamental alteration" of the City's zoning ordinances. This is supported by the fact that the City has approved use permits for similar facilities in the same vicinity. The City's erroneously believes that granting the requested accommodation would result in an overconcentration of residential care facilities. Overconcentration arguments have been rejected as violating the Fair Housing Act. Oconomowoc Residential Programs, Inc. v. City of Milwaukee, 300 F.3d 775, 787 (7th Cir. 2002)(City's overconeentration argument resulting in disproportionate costs to emergency services for those facilities rejected); Reg'l Econ. Cmty. Action Program v. City of Middletown, 294 F.3d 35, 50 (2d Cir.2002XArgument that granting variance would cause an overconcentration of residential and social services facilities in the City found to be pretext for discrimination). Oxford house -C v. City of St. Louis, 843 F. Supp. 1556, 1577 (E.D. Mo. 1994), rev'd in part, 77 F.3d 249 (8"' Cir. 19%)(City's fear that it was being unduly singled out for an over- concentration of social service institutions has some basis in fact. These concerns, however, do not justify discrimination against the handicapped. Simply put, the complaint of "no more in my back yard" is just as unacceptable an excuse for discrimination against the handicapped as the discriminatory cry of "not in my back yard." ), See also, See Horizon House Developmental Services, Inc. v. Township of Upper Southampton, 804 F. Supp. 683, 698 ( "the FHAA rejects any notion that a Township can somehow avoid the anti- discrimination mandate by accepting some sort of'fair share' or apportionment of people with disabilities "), afj°d 995 F.2d 217 (3rd Cir. 1993). Adopting the discriminatory animus of the community opposition to the granting of the request for a reasonable accommodation and to support the overconcentration argument in a violation of the Fair Housing Act. Adopting assertions put forward to those who oppose NCR on the basis that the presence of the recovering alcoholics and substance abusers diminishes the quality of life becomes actionable discrimination becomes discriminatory when it is adopted by a city official in decisions to deny land use permits or requests for reasonable accommodations. The record is quite clear that the Hearing Officer is more than willing to accept without question each statement made by each member of the community concerning complaints about the conduct of what is thought to be residents of NCR. It should be noted that these same citizens appeared before the same Hearing Officer and presented the same complaints about the applications made by Ocean Recovery and Balboa Horizons. It is ironic that the complaints were not credited in those applications but were credited against NCR. The law is quite clear that "even where individual members of government are found not to be biased themselves," a group home provider may demonstrate a violation of the FHAA if it can show that "discriminatory governmental actions are taken in response to significant community bias." Tsomlwnidis v. City of West Haven, 129 F. Supp. 2d 136,152 (D. Conn. 2001), rev d on other groundv, 352 F.3d 565 (2d Cir. 2003). Accordingly, "a decision made in the context of strong, Tom Allen Hearing Officer July 29, 2009 0 discriminatory opposition becomes tainted with discriminatory intent even if the decision - makers personally have no strong views on the matter." Innovative Health Sys, Inc. v. City of White Plains, 117 F.3d 37, 49 (2d Cir. 1997); see also Samaritan Inns v. District of Columbia, 1995 U.S. Dist. LEXIS 9294,rev'd on other grounds, 114 F.3d 1227 (D.C. Cir 1997) (finding a violation of the FHAA when government officials were influenced by political pressure exerted by the area residents); McKinney Found. v. Town Plan & Zoning Comm'n, 790 I'. Supp. 1197, 1212 (D. Conn. 1992) (same); Support Ministries for Persons with AIDS, Inc. v. Village of Waterford, 808 F. Supp. 120, 134 (N.D. N.Y. 1992) (finding that zoning officials violated the FHAA when they bowed to political pressure exerted by those hostile to persons with alcohol and drug - related disabilities); United States v. Audubon, 797 F. Supp. 353,361 (D.NJ. 1991)( Discriminatory intent found where Audubon officials stated they agreed with or were responding directly to community opposition). See also Cmry. Hous. Trust v. Dept of Consumer & Regulatory Affairs, 257 F. Supp. 2d 208, 226 (D.D.C.2003). Unfortunately for all concerned, the unsupported discriminatory animus of the those opposed to NCR's applications have infected the proceedings and now forms the crux of the denial by the Hearing Officer. HOUSING ELEMENTS AND CONSOLIDATED PLANS The City misstates the actions of the Department of Housing and Community Development( "HCD ") in its review of the City's Housing Element Plan. In a letter dated October 24, 2008 to David Lepo, Planning Director, City of Newport Beach, the Deputy Director of HCD which advised the City that revisions were required in the City's Housing Element Plan to bring it into compliance with State law. In particular HCD found that the City's group home ordinance constituted a "constraint on persons with disabilities." HCD is requiring the City to provide a detailed description of the City's group home ordinance and analyze it for requirements that may constrain housing for persons with disabilities. (See Attached Exhibit D, at HCD 6). The other deficiency HCD found that is relevant to this applicant is that when the City amended its zoning code to address the issue of group homes, it failed to identify zones where transitional housing will be permitted and conditionally permitted. State Law, specifically SB 2, requires the City to demonstrate that transitional and supportive housing are treated as residential uses subject only to those restrictions that apply to other residential uses of the same type in the same zone. (Exhibit D, at HCD 5). Please contact me or my co- counsel, Christopher Brancart, if you need to discuss these issues further, or in need of additional information. Tom Allen Hearing Officer July 29, 2009 �<if�' cc: Patrick Bobko Catherine Wolcott Christopher Brancart Newport Coast Recovery Dana Mulhauscr Paul E. Smith "RECEIVED R AGENDA October 23, 2009 Dear Ms. Brown, We are requesting that this letter be included as part of the public record for the October 27'h, 2009 hearing regarding the Group Residential Use Permit appeal for Newport Coast Recovery at 1216 W. Balboa Blvd.. We are writing to you to voice our strong support to uphold the denial of the Group Residential Use Permit for this facility. This facility and its clients have consistently operated in a manner that is detrimental to the local neighborhood. Noise, profanity, illegal gatherings, excessive second hand smoke on adjoining properties, no full time supervision, utilization of parking garages for meeting rooms were all substantiated by the neighbors. This facility has also treated minors; which is in violation of Newport Recovery's license. Additionally, this facility is in close proximity to other previously approved residential care facilities which represents an over - concentration of these businesses in our neighborhood, and more importantly, the number of these businesses that are close to Newport Elementary School and playgrounds. We believe that the City of Newport Beach has done its due diligence and has compiled strong and compelling evidence that this permit appeal should be denied. We all support legitimate rehab /recovery efforts and programs. We do not support: • over - concentration of these facilities in our residential neighborhoods; • irresponsible, poor operators providing little or no supervision to large groups of at -risk individuals; • operators that violate their own license requirements. The City has already approved over 40 facilities in the Coastal/West Newport area alone. Enough is enough. The citizens and residents of this great community need to have their voices heard and rights upheld, as well. Sincerely, Terry and Laurie McKenzie 1151 West Balboa Blvd. Balboa, CA 92661 urr ter. �,T nr Washington, Lillian From: Kiff, Dave Sent: Monday, October 26, 2009 11:31 AM To: City Clerk's Office Subject: FW: Rehab homes and property values For the record. Dave From: Billings, Tom [ mailto :Tom.Billings@camoves.com] Sent: Monday, October 26, 2009 9:15 AM To: Henn, Michael Cc: Kiff, Dave Subject: Rehab homes and property values Dear Mike and Dave, I'm writing in support of stronger regulation and control of rehab homes in Newport Beach, particularly on the Peninsula and West Newport communities. As a realtor who recently held numerous open houses at 12th and Oceanfront, I wanted to share some information that you may not be aware of: -The 12th St. area has historically been a strong 'residential' neighborhood vs. heavier rental areas like West Newport. The emergence of several rehab homes in that area is changing that. -In addition to 1216 W Oceanfront, there are three other Rehab homes within 112 mile of the property I had listed. -As agents, we are required by law to disclose to prospective buyers and sellers 'environmental' concerns that could affect the quality of life in a neighborhood surrounding a home for sale. -A huge concern is the safety and health of children that attend Newport El which is one to two blocks away from these homes. -These homes negatively impact the values of properties in that area since it must be disclosed to prospective buyers and sellers. In this already challenging market due to economic conditions, having illegal rehab homes and their occupants moving into a residential neighborhood like 12 St. exacerbates the problem with a lessening of the quality of life and properly values that ultimately determine the character of our city. The quality and character of the peninsula and Newport Beach in general is one of safety, beauty and healthful lifestyles. That has clearly already changed but we can stop further decline by enforcing the law. In short, we all know how special Newport and the peninsula is. I urge you and the council to hold your ground and uphold the law because there is too much to lose by not doing so. Thank you, Tom Billings Brown, Leilani From: Steve Barnard [barnard.co @sbcglobal.netj Sent: Monday, October 26, 2009 11:48 AM To: Brown, Leilani "RECEIVED AFTER AGENDA Cc: 'Douglas M. Wood'; breasy @aol.com MN I EY' I D• 1102 Subject: City Council hearing re: 1216 W. Balboa Blvd. City Council c/o City Clerk I am writing to request denial of the appeal on 1216 West Balboa Blvd. The hearing officer made the correct decision at the hearing and it should not be reversed. Newport Coast Recovery, the operators, were, and are, in violation of state law, they cannot and did not control their clients which, in conjunction with the overconcentration of units in the area, is an overriding burden on the neighborhood. The testimony of a number of witnesses including the mother of one minor aged 18 now, who testified that Newport Recovery required her to pay $30,000. In advance to accept her son for admission to the facility on the representation that there would be an M. D. on call at all times. In fact, there was no M. D., he was the only minor and was housed with all adults with no supervision — a violation of state law. Newport Coast Recovery has not, does not and will not meet the state requirements to operate. These folks are exactly the type and character that the city should be removing from the drug and alcohol recovery scene. Again, I respectfully request that their appeal be denied. Stephen Barnard, 1100 West Bay Ave, Balboa, CA 92661 NOTICE OF PUBLIC HEARING GROUP RESIDENTIAL CARE FACILITY USE PERMIT AND REASONABLE ACCOMMODATION NEWPORT COAST RECOVERY, LP NOTICE IS HEREBY GIVEN that the City Council of the City of Newport Beach will conduct a public hearing on October 27, 2009, at 7:00 p.m. in the City Council Chambers (Building A) at 3300 Newport Boulevard, Newport Beach, Califomia. The City Council will consider an appeal of the Hearing Officer's decisions to deny the applications filed by Newport Coast Recovery, LP for Use Permit No. 2008 -033, and Reasonable Accommodation No. 2009 -009 for property located at 1216 West Balboa Boulevard. The appeals were filed by the applicant. Following is a brief description of the applications: • Use Permit No. 2008 -033: An application requesting approval of a use permit to allow a residential care facility to operate a licensed adult alcohol and/or drug abuse recovery treatment facility for men only. • Reasonable Accommodation No. 2009-009: A Reasonable Accommodation application for an existing residential care facility to operate a licensed adult alcohol and/or drug abuse recovery and treatment facility in an R -2 District, where such uses are not permitted. The applicant requests the following: 1. An exemption from the portions of NBMC Section 20.10.020 (Residential Districts: Land Use Regulations) that require Residential Care Facilities, General to be established only in residential districts zoned Multi- Family Residential (MFR) with a use permit, subject to the operational conditions recommended by City staff in the January 12, 2009 staff report for Use Permit No. 2008 -33, including a maximum occupancy of 14 residents, which was denied by the Hearing Officer; or, in the alternative. 2. An exemption from the requirements specified in NBMC Section 20.91A.050 (Development and Operational Standards), including a waiver of the occupancy restriction of two persons per bedroom plus one staff member, and to allow a total occupancy of 18 residents; 3. An exemption from the parking requirements of one off- street parking space for each three resident beds, as specified in NBMC Section 20.66.030 (Off-Street Parking and Loading Requirements) for Residential Care, General use classifications, and to apply the off -street parking requirements applicable to Two - Family Residential (R -2) use classifications which requires two off - street parking spaces per dwelling unit; 4. Treat the use of the licensed residential care facility as a legal nonconforming use; 5. Apply the California Building Code provisions that were applicable at the time the residential care facility was established as relates to life and fire safety matters; and 6. A waiver of the required finding specified in NBMC Section 20.91A.060 (D), relative to the compatibility of the use with the character of the surrounding neighborhood, which requires a finding that the continued use will not contribute to the changing of the residential character of the neighborhood, such as creating an overconcentration of residential care uses in the vicinity, and waiving the impact analysis contained in the Factors A through C which the Hearing Officer must consider in making or sustaining the finding with regard to the proximity of the use to schools, churches, playgrounds, day care centers, and alcoholic beverage outlets, and the application of the American Planning Association standard of permitting one or two such uses per block. This activity has been determined to be categorically exempt under the requirements of the Califomia Environmental Quality Act (CEQA) under Class 1 (Existing Facilities). This class of projects has been determined not to have a significant effect on the environment and is exempt from the provisions of CEQA. This activity is also covered by the general rule that CEQA applies only to projects that have the potenfial for causing a significant effect on the environment (Section 15061(bx3) of the CEQA Guidelines). It can be seen with certainty that there is no possibility that this activity will have a significant effect on the environment and 4 is not subject to CEQA. All interested parties may appear and present testimony in regard to this application. If you challenge this project in court, you may be limited to raising only those issues you or someone else raised at the public hearing (described in this notice) or in written correspondence delivered to the City, at, or prior to, the public hearing. The staff report may be reviewed at the City Clerk's Office, City of Newport Beach, 3300 Newport Boulevard, Newport Beach, Califomia, 92663 or at the City of Newport Beach website at www.citv.newport- beach.ca.us beginning on the Wednesday prior to the hearing. For more information, call (949) 644 -3232 or (949) 644 -3002. To be added to a permanent notification list of these hearings, e- mail ibrownPriewnortbeachca.aov and ask to receive these notices. Project File No.: PA2008 -104 Activity No.: UP2008 ZZ, A2009 -009 0 Leilaru I. Brown City Clerk T uioo�4saa wuwt w.dnda P+o4d M =o "amp �eP��Y4fnWdeY eP+ws 047 25104 047 251 22 ROGER V BOYVEY TECHENTIN THOMAS A 1139 W BALBOA BLVD 640 MAGNOLIA AVE NEWPORT BEACH, CA 92661 PASADENA, CA 91106 047 261 01 047 26102 JOHN WELLS EARL DEXTER 1140 W BAY AVE ���2659 NEWPORT BEACH, CA 92661 047 263 01 047 263 02 HARRIET V PHILLIPS ALBERT C WALTERS 481 VEREDADELCIERVO 1125 W BAY AVE GOLETA, CA 93117 NEWPORT BEACH, CA 92661 047 263 04 047 26320 DOUGLAS M WOOD DAVID LONGRIDE 1214 E BALBOA BLVD 8006 E EUCALYPTUS TRL NEWPORT BEACH, CA 92661 ORANGE, CA 92869 047 263 22 047 263 23 JOHN M SCIARRA GRACF M STFINHOFF 4,120 WOOOLEIGiI LN t 1.:t 1,;1; {i.1A !�_ "•iJ �:,: LA CANADA, CA 91011 NFWPORT BEACH, CA 92661 047 263 25 939 710 11 MARK M LUCAS DARWIN U812 N KALAHEO AVE #L 1249.5 W KAILUA, HI 96734 NEW,9w6<T BEACH, CA 92661 939 710 17 939 71.0 18 PATRICIA BOTWINICK MICHAEL K FLYNN 1201 W BALBOA BLVD 4738 E INGRAM ST NEWPORT BEACH, CA 92661 MESA, AZ 85205 939 710 22 HIRAM D CARRINGTON III 1710 N CATALINA AVE PASADENA. 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CA 92661 047 241 09 047 23424 047 234 24 RESIDENT RESIDENT RESIDENT 1219 BALBOA BLVD W 1219 BAY AVE W B 1219 BAY AVE W A NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 234 28 047 23428 04723429 RESIDENT RESIDENT RESIDENT 1208 BALBOA BLVD W C 1208 BALBOA BLVD W A 1208 BALBOA BLVD W B NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 241 16 047 251 04 047 263 23 RESIDENT RESIDENT RESIDENT 1212 OCEANFRONT W 1139 BALBOA BLVD W 1144 BALBOA BLVD W NEWPORT BEACH. CA 92663 NEWPORT RFACH. Ui 92661 NE% ^.1PORT BEACH. CA 92661 047 234 19 047 234 19 047 234 19 RESIDENT RESIDENT RESIDENT 1244 BALBOA BLVD W4 1244 BALBOA BLVD W 6 1248 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 234 19 047 234 19 047 234 19 RESIDENT RESIDENT RESIDENT 1244 BALBOA BLVD W 3 1244 BALBOA BLVD W5 1244 BALBOA BLVD W 1 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 T Aa3AV oD ooe t T mdn dW P In ARW w°°t°61e1E' T 09&S AmAy Weqo 91 ANIRfl w0r(u mmm ! W U96 NMPW4 n V rgdty { BMW Y MM to mbP3 047 234 19 047 241 12 047 24107 RESIDENT RESIDENT RESIDENT 1244 BALBOA BLVD W2 1205 BALBOA BLVD W 1225 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 261 01 047 263 25 047 241 11 RESIDENT RESIDENT RESIDENT 1140 BAY AVE W 1123 BAY AVE W 1209 BALBOA BLVD W 3 NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92663 047 241 11 047 241 11 047 240 01 RESIDENT RESIDENT RESIDENT 1209 BALBOA BLVD W 2 1209 BALBOA BLVD W 1 107 13TH ST NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 240 01 047 263 24 047 26324 RESIDENT RESIDENT RESIDENT 1327 BALBOA BLVD W 1150 BALBOA BLVD W 1/2 1150 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92661 047 263 24 047 232 06 047 234 27 RESIDENT RESIDENT RESIDENT 1148 BA_BOA BLVD V., 1210 BAY AVF W 1236 BALBOA BLVD 1°J NEWPORT BEACH, CA 92661, NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 939 710 12 939 710 11 047 24102 RESIDENT RESIDENT RESIDENT 1249 BALBOA BLVD W 112 1249 BALBOA BLVD W 1245 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 241 21 047 232 05 047 234 18 RESIDENT RESIDENT RESIDENT 1232 OCEANFRONT W 1220 BAY AVE W 1240 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 23314 047 233 12 047 233 12 RESIDENT RESIDENT RESIDENT 1300 BALBOA BLVD W 1305 BAY AVE W 1305 BAY AVE W 1/2 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH. CA 92663 047 24104 047 234 15 047 234 15 RESIDENT RESIDENT RESIDENT 1237 BALBOA BLVD W 1224 BALBOA BLVD W A 1224 BALBOA BLVD W B NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 2 32 02 047 241 05 047 234 10 RESIDENT RESIDENT RESIDENT 1236 BAY AVE. W 1235 BALBOA BLVD W 1201 BAY AVE W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 rl T —86P7 dnd04 awdre jade. na++ f ..noi c aledwai _ILaAN Mn T A113AV-09.OW1 .7 dn-ftjpmwaij w �ua`wi&IP i wao'tiwwAvAm op 4N emim N v X11 W Sues 939 710 18 939 710 17 RESIDENT RESIDENT 107 12TH ST 1201 BALBOA BLVD W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 939 710 21 047 261 02 RESIDENT RESIDENT 1229 BALBOA BLVD W 1136 BAY AVE W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92661 047 263 04 047 232 07 RESIDENT RESIDENT 1119 BAY AVE W 1206 BAY AVE W NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92663 047 251 23 047 234 22 RESIDENT RESIDENT 1140 OCEANFRONT W 1215 BAY AVE W A NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92663 047 234 09 047 25103 RESIDENT RESIDFNT 1205 BA's AV V: :: -11 BAUM;', BLVD'✓✓ lit NEWPORT BEACH, CA 92663 NEWPORT BLACK CA 92661 047 26320 047 234 03 RESIDENT RESIDENT 1132 BALBOA BLVD W 1223 BAY AVE W NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92663 047 26303 047 241 14 RESIDENT RESIDENT 1121 BAY AVE W 1200 OCEANFRONT W NEWPORT BEACH, CA 92661 NEWPORT BEACH, CA 92663 047 24124 047 234 21 RESIDENT RESIDENT 1240 OCEAN FRONT W 1231 BAY AVE W NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 23203 047 234 14 RESIDENT RESIDENT 1220 BAY AVE W 1216 BALBOA BLVD W 4 NEWPORT BEACH, CA 92663 NEWPORT BEACH, CA 92663 047 2.34 1.1 0.17 234 14 RESIDENT RESIDENT 1216 BALBOA BLVD \•V 3 1216 BALBOA BLVD W 1 IVFWPORT 61ACH, CA 92663 NEWPORT BFACFI, CA 92663 T_ -,- ...__.. �� .,a6oa dndodasodxa ia&Aa �09�5 �A1911V Waga6 N �IIR+fI +Nb 19"p%SuAMbpj 939 710 22 RESIDENT 1229 BALBOA BLVD W 1/2 NEWPORT BEACH, CA 92663 047 26103 RESIDENT 1132 BAY AVE W NEWPORT BEACH, CA 92661 04723208 RESIDENT 1200 BAY AVE W NEWPORT BEACH, CA 92663 047 234 22 RESIDENT 1215 BAY AVE W B NEWPORT BEACH, CA 92663 047 25103 RESIDENT 1141 BALBOA BLVD':' NEWPORT BEACH, CA 92661 047 241 23 RESIDENT 1236 OCEANFRONT W NEWPORT BEACH, CA 92663 047 241 24 RESIDENT 1242 OCEANFRONT W NEWPORT BEACH, CA 92663 047 234 21 RESIDENT 206 13TH ST NEWPORT BEACH, CA 92663 047 234 14 RESIDENT 1216 BALBOA BLVD W 5 NEWPORT BEACH, CA 92663 047 234 14 RESIDENT 1216 BALBOA BLVD W 2 NEWPORT BEACH, CA 92663 f .ML< at¢idwat "aw asn PLANNING DEPARTMENT 3300 NEWPORT BOULEVARD NEWPORT BEACH, CALIFORNIA 92663 PHONE. 949/644 -3200 FAX 949/644 -3229 Please see the attached radius map and mailing labels created for properties within a 300 -foot radius of the subject parcel located at 1216 W. Balboa Boulevard in the City of Newport Beach. County of Orange The property information was acquired through the Newport Beach GIS Web Mapping system. Further. the information is based upon the most up -to -date records of the county tax assessor and is deemed reliable, but is not guaranteed. - /a& / J 1,01w� October 15, 2009 Signature of Prreparer Date Prepared F \Users\PLN\Shared \PA's\PAs - 2008\ PA2008- 104\Mailing_Lists \Radius Map & Mailling Labels 06- 09 \Preparer's Statement doc 300 Foot Radius Map PA2008 -104 for UP2008 -033 1216 W BALBOA BOULEVARD 1416 1428 1412 1400 : :J 1420 1404 135u 1328 133U 1314 1415 1409 _ 1338 1324 1413 - 1316 13,),J 1411 1401 1325 - - -- -1306 1240 - 1405 1331 13231311)13 '236 1224 1210 1321 1226 1220 1400 1344 13111305 1352 1334 -__ 1309 1301 1225 1200 1130 1338 1321 1310 ° 206 1111215 1206 1131 1328 1312 'a 1119 1[13 1136 1120 1108 1409 1320 1300 $1240 1[11 1205 111c 1441 1401 1306 1244 1230 120Y 1201 1123 1116 1100 1034 1411 E14 1248 1224 1127 1115 1104 1042 eOq B1 1236 121E 1204 1111.191113 - 1030 1024 - -- 1105 D w 1211 1 ill l 103 1200 1108 1100 1327 v .. B llas .- 1406 105 IV/ 1249141 7 �6Q9 fi(VDW 11113611124 1114 1105110 7 019 - r` 1229 1/141100 _ 1015 1001 O AN FRO N! 1236 It35 1221 1209203 1108 1050 --- , 1011 W 1244 12251213 107 1145 1104 ;10403034 _ 1240 1228 "w*,Ay 4i 1141 1129 - 1036 10241012 1220 1210 1149 1133 1113 - - 10281016 1501 1224 12.4 - '1 0E IIOS 102010 1179 1115 1 1216 1200 1136 - 1111 1051 1140 1124 1101 1045 w 1128 1116 - 104310331017 1130 1112 1036 - 1037 1025 1005. -_ 1102 1032 1015 1001 1009 1100 1028 1016 107 1020 1008 0mmmmmmffm2stft 1012 1000 NOTICE OF PUBLIC HEARING GROUP RESIDENTIAL CARE FACILITY USE PERMIT AND REASONABLE ACCOMMODATION NEWPORT COAST RECOVERY, LP NOTICE IS HEREBY GIVEN that the City Council of the City of Newport Beach will conduct a public hearing on October 27, 2009, at 7:00 p.m. in the City Council Chambers (Building A) at 3300 Newport Boulevard, Newport Beach, California. The City Council will consider an appeal of the Hearing Officer's decisions to deny the applications filed by Newport Coast Recovery, LP for Use Permit No. 2008 -033, and Reasonable Accommodation No. 2009 -009 for property located at 1216 West Balboa Boulevard. The appeals were filed by the applicant. Following is a brief description of the applications: • Use Permit No. 2008 -033: An application requesting approval of a use permit to allow a residential care facility to operate a licensed adult alcohol and/or drug abuse recovery treatment facility for men only. • Reasonable Accommodation No. 2009-009: A Reasonable Accommodation application for an existing residential care facility to operate a licensed adult alcohol and/or drug abuse recovery and treatment facility in an R -2 District, where such uses are not permitted. The applicant requests the following: 1. An exemption from the portions of NBMC Section 20.10.020 (Residential Districts: Land Use Regulations) that require Residential Care Facilities, General to be established only in residential districts zoned Multi - Family Residential (MFR) with a use permit, subject to the operational conditions recommended by City staff in the January 12, 2009 staff report for Use Permit No. 2008 -33, including a maximum occupancy of 14 residents, which was denied by the Hearing Officer; or, in the alternative 2. An exemption from the requirements specked in NBMC Section 20.91A.050 (Development and Operational Standards), including a waiver of the occupancy restriction of two persons per bedroom plus one staff member, and to allow a total occupancy of 18 residents; 3. An exemption from the parking requirements of one off- street parking space for each three resident beds, as specified in NBMC Section 20.66.030 (Off - Street Parking and Loading Requirements) for Residential Care, General use classifications, and to apply the off- street parking requirements applicable to Two - Family [Residential (R -2) use classifications which requires two off- street parking spaces per dwelling unit, 4. Treat the use of the licensed residential care facility as a legal nonconforming use, 5. Apply the California Building Code provisions that were applicable at the time the residential care facility was established as relates to life and fire safety matters; and 6. A waiver of the required finding specified in NBMC Section 20.91A.060 (D), relative to the compatibility of the use with the character of the surrounding neighborhood, which requires a finding that the continued use will not contribute to the changing of the residential character of the neighborhood, such as creating an overconcentration of residential care uses in the vicinity, and waiving the impact analysis contained in the Factors A through C which the Hearing Officer must consider in making or sustaining the finding with regard to the proximity of the use to schools, churches, playgrounds, day care centers, and alcoholic beverage outlets, and the application of the American Planning Association standard of permitting one or two such uses per block. This activity has been determined to be categorically exempt under the requirements of the California Environmental Quality Act (CEQA) under Class 1 (Existing Facilities). This class of projects has been determined not to have a significant effect on the environment and is exempt from the provisions of CEQA. This activity is also covered by the general rule that CEQA applies only to projects that have the potentiaf for causing a significant effect on the environment (Section 15061(bx3) of the CEQA Guidelines). It can be seen with certainty that there is no possibility that this activity will have a significant effect on the environment and it is not subject to CEQA. Aft interested parties may appear and present testimony in regard to this application. If you challenge this project in court, you may be limited to raising only those issues you or someone else raised at the public hearing (described in this notice) or in written correspondence delivered to the City, at, or prior to, the public hearing. The staff report may be reviewed at the City Clerk's Office, City of Newport Beach, 3300 Newport Boulevard, Newport Beach, California, 92663 or at the City of Newport Beach website at www.city.newoort- beach.ca.us beginning on the Wednesday prior to the hearing. For more information, call (949) 644 -3232 or (949) 644 -3002. To be added to a permanent notification list of these hearings, e- mail jbrown(o)newporlbeachca qov and ask to receive these notices. Project File No.: PA200B -104 Activity No.: UP2008 -033 a d RA2009 -009 Leilani 1. Brown City Clerk AFFIDAVIT OF POSTING On 10/1(a 2009, I posted the Notice of Public Hearing regarding: NEWPORT COAST RECOVER, LP Date of Hearing: October 27, 2009 STEVEN G. POLIN, ESQ. Attorney At Lam L.eilani 1. Brown City Clerk City of Newport Beach 3300 Newport Blvd Newport Beach, CA 92663 Dear Ms. Brown: RECEIVED 2@9 OCT -I AR s 54 n CE Or T}a OTY CLEW CITY R'6Y�T EEO September ' Re: Appeal of Newport Coast Recovery 110- 2009 - 22,23,24 3034 TeNNYWN ST. N.W. WmtimGroN, D.C. 20015 RL (202) 331 -588 FAX (202) 537 -2986 SPOUN2@EARniuNK.Ner Please find enclosed signed applications to appeal the decision of the hearing officer filed on behalf of Newport Coast Recovery. Please call me if you have any questions. /' CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA2008 -104 Application No. 2009 -009 Name of Appellant Newport Coast Recovery Phone 202- 331 -5848 Site Address 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing Officers decision September 17 Name of Applicant Newport Coast Recovery 2009 for (Description of application filed with Hearing Officer) Request for a reasonable accommodation requesting a waiver from the provisions of NBMC 20.10.020 or in the alternative a waiver from the provisions of NBMC 20.91A.050 Reasons for Appeal Denial with prejudice of the request for a reasonable accommodation HO- 2009 -023 M � Steven x `Poiri ao.- �14 FOR OFFICE *E ONLY: Rece i ed by Fee received 09/26/2009 Date Date C:\Documents and Settings\sobomy\Local SettingsUemporary Internet Files \Content.Outlook\277DB2P7Wppeal of Hearing Officers Decision.docx Revised 02 -04-09 j)b Brown, Leilani /,. �/J A# S L From: Sent: i0rtn CCSvwc.� f Steven Polin [spolin2 @earthlink.net] n ii Saturday, September 26, 2009 12:58 PM To: Brown, Leilani; pbobko; Wolcott, Cathy; Kiff, Dave Cc: Chris Brancart; ebrancart@brancart.com; james dee; mnewmanl960@hotmail.com; Dana (CRT) Mulhauser; paul.e.smilh Subject: appeal of newport coast recovery Attachments: AppealofHearingOfficersDecision use permit with signature.pdf; AppealofHearingOff icersDecision reasonable accommodation #1 with signature.pdf; AppealofHearingOfficersDecision reasonable accommodation #2 with signature.pdf Follow Up Flag: Follow up Flag Status: Flagged Please find attached signed copies of the notice of appeal from the denial of its use permit application and requests for a reasonable accommodation. the original of documents are being mailed via first class mail. thank you. Steven Polin Steven Polin Law Office of Steven G. Polin 3034 Tennyson Street, NW Washington, DC 20015 202- 331 -5848 202- 537.2986(fax) sgolin2a> arthlinkynel This transmission is protected by the Electronic Communications Privacy Act. 18 U.S.C. Sections 2510 -2521 and intended to be delivered only to the named addressees) and may contain information that is confidential, proprietary, attorney work - product or attorney - client privileged. If this information is received by anyone other than the named addressee(s), the recipient should immediately notify the sender by E -MAIL and by telephone 202 -331 -5848 and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the named addressce(s), except with the express consent of the sender or the named addressee(s). thank you. CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA 2008 -104 2009 -009 #2 Application No. Name of Appellant Newport Coast Recovery phone 202- 331 -5848 Site Address 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing Officer's decision September 17 Name of Applicant Newport Coast Recovery 2009 for (Description of application filed with Hearing officer) Request for a reasonable accommodation requesting a waiver from the provisions of NBMC 20.10.020 or in the alternative a waiver from the provisions of NBMC 20.91A.050 Reasons for Appeal Denial with prejudice of the request for a reasonable accommodation HO- 2009 -024 Signature of Appellant MV, r- Fee received 09/26/2009 Date Date C:0ocuments and SettingstsobomylLocel SettingslTemporary Intemet FiledContent .Outlook1277DB2P7%Appeal of Hearing Officers Decision.docx Revised 02-04.09 jib CITY OF NEWPORT BEACH APPLICATION TO APPEAL DECISION OF THE HEARING OFFICER Project No. PA 2008 -104 Application No 2008 -033 Name of Appellant Newport Coast Recovery phone 202- 331 -5848 Site Address 1216 West Balboa Blvd., Newport Beach, CA 92661 Date of Hearing officers decision September 17 2009 Name of Applicant Newport Coast Recovery for (Description of application filed with Hearing officer) Application for a use permit to continue providing residential treatment services to person in recovery from alcoholism and substance abuse. Reasons for Appeal Denial with prejudice of the application for a use permit, HO- 2009 -022 A Stevo'G. Alin 09/26/2009 Signature of Appellant Date FOR OFFICEUSE ONLY: R eived y Fee received Date C:1Documents and SettirgMsobomySLocal SettingslTemporary Internet FileslContent Outlook1277DB2P7Wppeal of Hearing Officers Deasion.docx Revised 02 -04-09 bb