HomeMy WebLinkAbout00 - Written CommentsReceived After Agenda Printed
July 28, 2015
Written Comments
July 28, 2015, Council Consent Calendar Comments
The following comments on items on the Newport Beach City Council agenda are submitted by:
Jim Mosher ( iimmosher(o),vahoo.com ), 2210 Private Road, Newport Beach 92660 (949- 548 -6229)
Item 1. Minutes for the July 14, 2015 Special Meeting, Study Session
and Regular Meeting
The page numbers below refer to Volume 62 of the draft minutes. The passages in italics are from the
draft with suggested changes shown in °fFikee t underline format.
General comment: The present minutes struck me as not up to the City's usual standard of clarity. The
suggested changes are primarily to correct obvious errors in grammar or meaning. Although most of the
other passages seemed grammatical, it appeared to me that the full content of many of them was
indecipherable without reference to the video.
Specific suggested changes and comments:
Page 377: Item SS2, last sentence: "... prior seawall failure, Grand Canal cap veneer spalleel
spallinp, and easement requirements."
Page 378: paragraph 2, sentence 3: "In response to his question regarding why the idea of a
soldier pile and whaler were was not considered on the west end in lieu of tie - backs, ..."
Page 379: paragraph 2, sentence 1: "Jim Dastur, Chair of the Balboa Island Improvement
Association Committee on Seawalls, ..."
Page 380: paragraph 1, sentence 1: "Council Member Muldoon agreed with Council Member
Petros regarding expediting emergency dredging in the area." [? The statement by Council
Member Petros that Council Member Muldoon is agreeing with does not seem to be recorded in the
minutes]
Page 380: paragraph 2, sentence 1: "Council Member Petrol fie complimented
staff and Mayor Selich."
Page 381:
Item IV.B, last paragraph: "Council Member Peotter recused himself because of the possible
effect of the matter on his personal finances."
Item VIII, last paragraph: "City Attorney Harp also announced that Council Member Peotter
recused himself on Item 1V.B (Initiation of Litigation) due to the effect of the matter on his
personal finances."
Since Item IV.B consisted of two matters, it is not clear from the minutes if Council
Member Peotter recused himself from one matter or both.
The statement also does describe the possible financial conflict in sufficient detail for the
public to understand what it was. See following comment on Page 393, Item 22.
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 2 of 10
Page 386: Item XVII: "Jim Mosher referenced the Special Meeting and F°"eved t' ha
comments implying the resolution was had been previously distributed to the City Council
and was then toned down."
Page 388: first paragraph, sentence 2: "He commented on the expedited process for "roof -top
solar systems" but noted references to photovoltaic systems on1v."
Page 389: paragraph 4 from end: "In response to Mr. FellFs Foot's question, ..."
Page 389: paragraph 2 from end: "Council Member Duffield commented on a mooring field off
Lido Island which is sempleted completely surrounded by residences with no commercial
ventures near it."
Page 390: line 1: "Lido Yacht Club, or any other staseholder stakeholder."
Page 390: paragraph 2, sentence 2: "... and commented on Duncan
McIntosh's marina project..."
Page 391: paragraph 3 from end: "... to fill the unscheduled vacancy on the to the Building and
Fire Board of Appeals."
Page 392: paragraph 4 from end: "City Clerk Brown announced that Roy Englebrecht was
reappointed to the Parks, Beaches and Recreation Commission for a four year terms term."
Page 393: Item 22, paragraph 1:
"Council Member Duffield recused himself from the Balboa Island Wine Festival and Balboa
Island Centennial Celebration items because he has a financial interest in the matters."
The preceding statement does not, to me, seem adequate to meet the requirement of Section
87105 of California's Political Reform Act, which says in relevant part:
(a) A public official who holds an office specified in Section 87200 who has a financial
interest in a decision within the meaning of Section 87100 shall, upon identifying a conflict
of interest or a potential conflict of interest and immediately prior to the consideration of the
matter, do all of the following:
(1) Publicly identify the financial interest that gives rise to the conflict of interest or
potential conflict of interest in detail sufficient to be understood by the public, except
that disclosure of the exact street address of a residence is not required.
(2) Recuse himself or herself from discussing and voting on the matter, or otherwise
acting in violation of Section 87100.
(3) Leave the room until after the discussion, vote, and any other disposition of the
matter is concluded, unless the matter has been placed on the portion of the agenda
reserved for uncontested matters.
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 3 of 10
(4) Notwithstanding paragraph (3), a public official described in subdivision (a) may
speak on the issue during the time that the general public speaks on the issue.
Since all the required recusals involve the public official having a real or potential "financial
interest in the matter," the passage about providing detail would be meaningless if it did not
require supplying additional detail specific enough for the public to understand the exact
financial interest requiring the recusal.
As with Item IV.BNIII (see page 381, above) the minutes accurately reflect what was said on
July 14`"; but what was said does not seem legally sufficient. Hopefully a clearer explanation of
the conflicts will be provided when the Special Events funding matter comes back at the present
meeting.
Page 396: last paragraph, sentence 2 from end: "He stated that Council Member Peotter's
statements have affected nW many people, ..."
Page 398: paragraph 5: "Denise Pennon commented people's reactions..."
Page 398: last line: "... the best rainbows she has seen have been in the Back Bay and
belongs belong to everyone."
Page 401: line 2 from end: "Ill. PUBLIC COMMENTS ON NON - AGENDA ITEMS"
Item 3. Adoption of Ordinance No. 2015 -23 Amending Newport Beach
Municipal Code Adding Chapter 15.18 Regarding Residential Rooftop
Solar Systems
1. Despite what the DISCUSSION in the staff report says, I believe this ordinance,
adopted, will "take effect' in 30 days, not "take affect."
2. Although it may seem a minor point to many, I think the administrative staff endorses a
poor policy when it allows important City documents to be signed in unclear ways. It
would seem to me that basic principles of transparency and accountability dictate that
the identities of those who sign official documents, and when they sign them, should be
clear and unambiguous. Taking ownership of a document that has received as little
public review as the text of the present ordinance seems particularly important. Yet
although the final page suggests this ordinance has been reviewed by "Aaron C. Harp,
City Attorney," a closer examination reveals that on some unknown date someone
merely initialed it "for" the City Attorney — as is quite often the case. In this particular
case, I would guess the initials might be those of one of our Assistant City Attorneys,
Michael -Sean Demetrio Torres (California Bar #238973), but that is only a guess, and
years from now even those in the City Attorney's office might not know for sure. Is it
that difficult to print the true signer's name and the date on which it was signed?
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 4 of 10
Item 4. Adoption of Ordinance No. 2015 -22 Relating to Hotel Guest
Registry Inspections
1. Regarding the DISCUSSION in the staff report:
a. I believe this ordinance, too, if adopted, will "take effect' in 30 days, not "take
affect."
b. The implication that adoption of the ordinance "will require hotel operators to
allow police officers to inspect their guest registries or registration cards" seems
a bit overblown. My understanding is it makes the inspection more difficult for
the police, and may arguably now require an administrative subpoena.
2. As to the substance of the ordinance, I continue to think the references, especially in the
surrounding code, to paper registries and cards sound antiquated. And I remain in the
dark as to whether this was reviewed as an opportunity to ensure there are adequate
inspection mechanisms by those other than the police to verify the Transient Occupancy
Tax is being properly collected.
Item 5. Bay Avenue Pavement Reconstruction — Notice of Completion
and Acceptance of Contract No. 5580 (CAP15 -0010)
1. The "Time Summary' portion of these notices of completion almost invariably indicate
the work was completed exactly as expected relative to the "Contract Completion Date
with Approved Extensions." This creates what I think may be the false impression that
City contractors normally complete their work within the time the public was originally
told. The reality would be much clearer if the report indicated both the originally noticed
completion date and the duration of the extensions. In the present case, Council and the
public were told at the time the contract was awarded (last line of page 2 of that staff
report) that construction would take 50 working days. The present report suggests it
was completed "on time," but it also suggests it took 62 working days, or (as I read the
two reports together) more than two weeks longer than originally planned. I suspect this
and even longer delays are typical.
2. Also as is typical of these staff reports, the ENVIRONMENTAL REVIEW section says
the Council found the project exempt from CEQA. Although the ENVIRONMENTAL
REVIEW section of the original staff report at the time of contract award contained a staff
recommendation to that effect, as is also typical, there is nothing in the minutes to
suggest the Council ever acted on that recommendation by formally making a CEQA
finding. The mere statement of a recommendation in a staff report would not seem to
me to constitute a Council action.
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 5 of 10
Item 6. Big Canyon Reservoir Flow Metering Vault and Treatment
Improvements — Approval of Professional Services Agreement with
Stantec Consulting, Inc.
1. It is good to see the contract and scope of services is being presented to the Council
for public review.
2. It is curious that no information has been provided regarding the dollar amount of the
other three bids received for this work or how those proposals were scored by the
"review team."
Item 8. Plan Review Services - Amendment to the Professional
Services Agreements with VCA Code and JAS Pacific and Approval of
Budget Amendment
The history of this item is murky to me because:
1. Despite the City Charter Section 603(d) requirement for the City Clerk to "Maintain
separate books, in which a record shall be made of all written contracts and official
bonds," only the currently "active" contracts are readily available for public inspection in
the online Laserfiche contracts archive.
2. Even then, there is no City policy to document the authority under which most of the
contracts were signed.
As best I can tell from the staff report for Item 11 at the Council's July 24, 2012, meeting, the
original decision to outsource excess building inspection and building plan check tasks to VCA
Code Group was made by administrative staff in 2011 and resulted in an on -call contract signed
by an Assistant City Manager and effective September 1, 2011. Only when the dollar amount of
the effort began to exceed the City Manager's signing authority did it come to public notice in
the aforementioned item, which passed on the Consent Calendar without comment from the
Council.
The magnitude of the effort continued to grow with Item 6 on the July 23, 2013, Consent
Calendar (again authorized without Council comment) and JAS Pacific was added (again
without comment) as part of Consent Calendar Item 6 at the July 8, 2014, meeting.
In short, there has been no public discussion I can detect of the wisdom of this program which
began as one for the as- needed hiring of relief in -house personnel to handle overflow work, but
has grown to one of routinely outsourcing to private workers at private offsite facilities what were
once entirely in -house functions performed by City employees.
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 6 of 10
I find the result problematic on many levels.
1. One of the primary reasons for creating governments, and in particular municipal
corporations, is to provide needed civic services at cost and without profit. If a private
entity can provide the same service at a lower cost and make a profit, it would seem
the government is not operating very effectively. The solution, it would seem to me, is
not outsourcing, but rather making the government work as intended.
2. Even when acting in an in -house relief capacity, it is not clear the private contract
employees have the same ethical training as the regular City employees. When they
work unobserved at private off -site facilities the possibility they might be subject to
untoward influences multiplies.
3. 1 would think it might also cause morale problems for the regular in -house City
employees who may feel their position could soon be outsourced.
4. If an increasing number of traditional City services are to be preformed off -site by
privately hired and privately managed personnel, it amplifies the question of why we
need a City Hall of its present size.
As to the substance of what the Council is being asked to review and approve:
1. Since the dollar amounts currently paid to both firms apparently include a combination of
contract building inspector and contract plan review services, it is difficult or impossible
to deduce from the requested dollar increases how much increase in the contracted plan
review service staff expects, what fraction of the total plan review volume that
represents, or how much shift from in -house to off -site review staff anticipates.
2. At least some of what is promised in the staff report is not evident from the contracts,
which have rather vague, informal and quite different amended Scopes of Service.
a. The staff report says "VCA will collect 60% of the plan review fee and JAS will
collect 65% of the plan review fees collected by the City."
i. The VCA contract calls for the payment of fixed hourly rates in its new
Exhibit B (page 8 -10). They do not appear to be tied to the Council -
approved City Master Fee Schedule.
ii. The JAS contract cites its original Exhibit B (page 8 -68) which also has
fixed hourly rates, although it is not immediately obvious which rates
apply to which services in the City's Master Fee Schedule.
iii. Closely related to this is the fact that the revised Master Fee Schedule
presented to the City Council as Item 19 at its July 14, 2015, meeting
proposed to increase the building plan check hourly rate charged
applicants by 53 %, to $228 from its present $149 (line item 93 in new
Shedule). If that truly represents the City's in -house cost, that could
mean "the City" is getting an increasingly good deal with these fixed price
contracts, but at the same time it makes it increasingly mysterious why
the City should be charging applicants $228 per hour for a service to
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 7 of 10
which it pays VCA only $95 and JAS only $75 or $85 ( ?) per hour? I
am also unable to find any provision in the proposed Master Fee
Schedule that contemplates the offering of expedited review for an
increased fee.
b. Neither contract or Scope of Services appears to express a clear understanding
of how the services will be allocated between in -house and off -site, or who will
determine that.
c. The reverse side of the proposed new "Plan Review Options" form (Attachment
CC 5, pages 8 -72 and 8 -73) makes promises to the public about the availability
of the outside plan reviewers which may or may not be assured by the contracts.
3. The proposed new "Plan Review Options" form (Attachment CC 5, pages 8 -72 and 8 -73)
is difficult to relate to the staff report.
a. The staff report says 80% of all plan checks are completed in a single day. Is
this new form intended for all reviews? Or just the other 20 %?
b. Perhaps related to that, I have trouble understanding how the in -house "overflow"
personnel provided by the contractors relate to this form. If one asks to use the
"City's Professional Plan Check Team" might one not still get a contract
reviewer?
c. The form seems designed to push business to the private firms, since it says a
review by in -house City personnel could take up to 15 business days while a
review by either of the outside firms is promised to take no more than 10
business days.
d. I am unable to find any explanation of why the "Accelerated Review" option is
available only from the outside contractors.
e. If the "Accelerated Review' option proves popular, will that degrade the response
time for standard reviews, giving the less well heeled citizens less service for
their fee?
f. I think it would be helpful to add to the form (or any other form like this) an
explanation that any change which a plan check reviewer — whether in -house or
contract — claims is needed to a project to bring it into compliance with building or
fire codes can be challenged (or an alternative solution proposed) for review by
the City's Building and Fire Board of Appeals. The existence of this little -used
citizens' body does not seem to be well known.
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 8 of 10
Item 9. Revocable License Agreement between the City of Newport
Beach and Sprouts of Promise to Operate a Certified Farmers' Market
Located at McFadden Square and Newport Pier and a Request for a
Reduced Rental Rate
Attendees at the most recent Balboa Village Advisory Committee meeting expressed
interest in a farmers' market type activity there, and it might be a more logical location
since there is no longer a commercial market in that area. Has staff considered that.
2. The argument regarding City Council Policy F -7 (Income Property), and the loss of
income if the Council does not go forward with the lease, seems doubtful since, as
Policy L -13 (McFadden Plaza and Pier Use) indicates, the location was never
contemplated as a commercial money- making site. The same argument would suggest
that to prevent a loss of potential income all public open space under City control should
be commercialized and rented out.
3. Closely related to this, the staff report informs the public the proposed rent is "below fair
market value" but I am unable to find any indication of what staff thinks the fair market
rent would be.
4. Since Policy L -13 indicates the present site and improvements were developed through
use of a 1990 assessment district, it would seem the views of those assessed as to what
is a proper use for it would be at least as important as those of City staff. Can they still
be identified? And have they been consulted? I am unable to find anything about that in
the staff report.
5. In the proposed contract, Recital "D" on the first page seems in error. Since the licensee
has never operated a farmers' market at the proposed location, shouldn't the phrase "to
continue" be deleted?
6. The exhibit on page 9 -23 illustrates a "Loading Area" that does not appear to part of the
License Areas depicted on page 9 -19. 1 am unable to find any explanation of the
Loading Area, or regulations on its use, in the contract.
7. Since the operation is proposed to be moved from an underutilized area to a highly used
one and could impact access to other visitor serving coastal resources, does it need a
Coastal Development Permit?
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 9 of 10
Item 10. School Resource Officer Program Agreement
1. With regard to Section 4.2 of the Agreement, I have trouble understanding how the
officers can be "on duty each day that school is in session" if the contract is limited to
four days per week at ten hours per day. Are these schools in session only four days a
week?
2. Although it is not obvious from Exhibit A (repeated as Attachment B to the staff report), it
appears that the "Annual Total for both School Resource Officers," from which the
School District's contribution is computed, has been prorated to reflect just the part of
the Total Compensation for the approximately ten months of the contract.
Item 11. Tentative Agreement with the Association of Newport Beach
Ocean Lifeguards
Like the tentative agreement with the Newport Beach Lifeguard Management
Association (presented as Item 13 at the Council's May 26, 2015, meeting), it is good to
see the contract publicly aired prior to the Council's commitment to it.
2. In view of the California Constitutional provision (Article XI. Section 10(a)) that "A local
government body may not grant extra compensation or extra allowance to a public
officer, public employee, or contractor after service has been rendered or a contract has
been entered into and performed in whole or in part, or pay a claim under an agreement
made without authority of law' it is disturbing to see the staff report say "The Agreement
includes changes to wages and benefits for the period July 1, 2014 through June 30,
2017'— that is, potentially changes to compensation for services rendered more than a
year ago. This term for the Agreement also appears in Clause 2 of the Preamble to the
MOU on page 11 -8 and Clause B.1 on page 11 -9. Yet in the summary of deal points I
am unable to find any changes retroactive to 2014. Is "2014" a typo for "2015 "?
Item 13. Appointment to the Finance Committee
1. I am troubled by the practice of individual Council Members being allowed to control
individual citizen appointments to the Finance Committee. Since the Committee already
includes three Council Members, if a citizen member either reports back to their
appointing Member on the Committee's activities, or is seen as representing their
appointing Member's views to the Committee, then there is an immense possibility for a
hub - and -spoke meeting of a majority of the Council in violation of the Brown Act. This
seems to me to be a structural problem with the current Finance Committee that needs
to be corrected.
2. Although even the City Attorney seems to acknowledge that the present vacancy on the
Finance Committee needed to be noticed to the public in general in compliance with the
Maddy Act (California Government Code Section 54970 et seq.), that process seems to
July 28, 2015, City Council Consent Calendar Comments - Jim Mosher Page 10 of 10
have been ineffective, for an email in the Committee appointments folder maintained by
the City Clerk indicates that the selection of a replacement had already been made
simultaneous with Councilman Duffield's notice of Jack Wu's resignation on June 30,
2015. 1 have no idea how the selection was arrived at, but when it is made prior to the
notice of a vacancy it hardly seems in compliance with the intent of the Maddy Act
(namely, to be sure the appointing officials are aware of the best talent available).
3. That said, it is disappointing that no one in the public other than myself responded to the
Clerk's advertisement by submitting an application. Perhaps they did not see the ad or,
unlike me, knew the selection was already a done deal.
4. In any event, it would seem the Council should at least know the full list of applicants
they might draw from. In the present case it is: Allan Beek (whose application was
submitted earlier this year when the possibility of citizen positions on a re- configured
Finance Committee was mentioned in the press), William O'Neill (Council Member
Duffield's nominee), and James Mosher (whose application was submitted in response
to the published ad).
5. Finally, I would like to observe that whatever his personal failings might be, I thought
Jack Wu did an excellent job on the Committee and made many positive contributions
towards its work.
Item 15. Commercial Marina Rental Rate Approach
1. In addition to mentioning that Council Member Muldoon requested this, in view of
Council Policy A -6 it would have been helpful to mention the meeting at which the full
Council authorized staff to expend resources pursuing it as a future agenda item. I
believe it was part of Item 23 at the May 12, 2015, meeting.
2. Even with that, it is difficult to understand the authority under which the administrative
staff could "freeze" commercial rental rates or take several of the other actions listed.
The minutes from May 12, 2015, indicate the decision was to schedule a vote at a future
meeting on "whether to have a third party look at commercial rental rates." Further
direction was never given at a noticed meeting of which I am aware (the June 16, 2015,
special meeting on mooring rental rates notwithstanding), so I don't think that vote ever
took place.
3. My personal guess is that harbor "property" is being grossly undervalued and the lion's
share of the profit from use of the public's waters is going to the private persons
privileged to lease or rent space, such as the commercial marina operators and
waterfront homeowners.