HomeMy WebLinkAbout05 - CC-5 - Adoption of Resolution Approving Special - 7/18/2017CITY COUNCIL AGENDA REPORT
MEETING DATE: JULY 18, 2017
ITEM NUMBER: CC -5
SUBJECT: ADOPTION OF RESOLUTION APPROVING SPECIAL USE PERMIT SL -15-0014 TO
OPERATE A SOBER LIVING HOME SERVING SIX RESIDENTS AT 2152 RALEIGH
AVENUE
DATE: JULY 11, 2017
FROM: DEVELOPMENT SERVICES DEPARTMENT
PRESENTATION BY: SHERI VANDER DUSSEN, CONSULTANT
FOR FURTHER INFORMATION FIDEL GAMBOA (714)754-5625
CONTACT: Fidel.gamboa@costamesaca.gov
RECOMMENDATION:
Adopt the attached Resolution 17-48 reversing the Planning Commission's denial of
Special Use Permit SL -15-0014.
APPLICANT:
The applicant and property owner is Gregg Ohlhaver of Keystone Sober Living.
ANALYSIS:
At its meeting of June 20, 2017, the City Council voted to overturn the Planning
Commission's denial and to grant the Applicant a reasonable accommodation and
thereby approved this application. This Special Use Permit (SUP) will allow the continued
operation of a group home with six or fewer residents and one live-in house manager.
There are two existing licensed alcoholism and drug abuse recovery treatment facilities
with six or fewer residents within 650 feet of the subject property. Those facilities are
located at 687 Governor St. (482 feet from the subject property) and 679 Governor St.
(604 feet from the subject property). As a result, the SUP had been denied by the
Director of Development Services and the Planning Commission. The City Council
voted to overturn the denial based on the facts set forth in the attached resolution.
ENVIRONMENTAL DETERMINATION
The request is exempt from the provisions of the California Environmental Quality Act
(CEQA) pursuant to CEQA Guidelines Sections 15268 (ministerial projects), 15270
(disapproved projects) and 15301 (existing facilities).
CONCLUSION
At its meeting of June 20, 2017, the City Council voted to grant the Applicant's appeal
and reverse the Planning Commission's denial of Special Use Permit SL -15-0014.
Adoption of the attached resolution will properly document that action for the reasons
stated therein and formally authorizes the issuance of the Special Use Permit.
SHERI VANDER DUSSEN, AICP
Consultant
BARRY CURTIS, AICP
Director of Economic
Services
and Development
ATTACHMENTS: 1. Resolution 17-48 Reversing The Planning Commission's
Denial Of Special Use Permit SI -15-0014 To Operate A
Sober Living Home Serving Six Or Fewer Occupants At
2152 Raleigh Avenue
2. Staff Report prepared for City Council Meeting of June 20,
2017 with attachments
ATTACHMENT 1
RESOLUTION NO. 17-48
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
COSTA MESA REVERSING THE PLANNING
COMMISSION'S DENIAL OF SPECIAL USE PERMIT SL -
15 -0014 TO OPERATE A SOBER LIVING HOME SERVING
SIX OR FEWER OCCUPANTS AT 2152 RALEIGH AVENUE
WHEREAS, Gregg Ohlhaver of Keystone Sober Living (the "Applicant") operates
a sober living home serving six males at 2152 Raleigh Avenue, Costa Mesa (the
"Property") and has done so continously since 2004; and
WHEREAS, the City of Costa Mesa recognizes that while not in character with
residential neighborhoods, when operated responsibly, group homes, including sober
living homes, provide a societal benefit by providing disabled persons as defined by state
and federal law the opportunity to live in residential neighborhoods, as well as providing
recovery programs for individuals attempting to overcome their drug and alcohol
addictions; therefore, providing greater access to residential zones to group homes,
including sober living homes, than to boardinghouses or any other type of group living
provides a benefit to the City and its residents; and
WHEREAS, the City of Costa Mesa has adopted standards for the operation of
group homes, residential care facilities and state licensed drug and alcohol facilities that
are intended to provide opportunities for disabled persons, as defined by state and federal
law to enjoy comfortable accommodations in a residential setting; and
WHEREAS, the City of Costa Mesa has found that congregating sober living
homes in close proximity to each other does not provide disabled persons as defined in
state and federal law with an opportunity to "live in normal residential surroundings," but
rather places them into living environments bearing more in common with the types of
institutional/campus/dormitory living that the FEHA and FHAA were designed to provide
relief from for the disabled, and which no reasonable person could contend provides a life
in a normal residential surrounding; and
WHEREAS, the City of Costa Mesa has determined that a separation requirement
for such facilities will still allow for a reasonable market for the purchase and operation of
sober living homes within the City and still result in preferential treatment for sober living
homes in that non -disabled individuals in a similar living situation (i.e., in boardinghouse -
style residences) have fewer housing opportunities than disabled persons; and
WHEREAS, the Applicant filed special use permit (SUP) SL -15-0014 with the
City's Development Services Department to operate a group home with six or fewer
residents in an R1 zone; and
WHEREAS, there are two exisiting state licensed drug and alcohol facilities with
six or fewer residents located at 687 Governor Street, which is within apprxoimately 482
feet of the subject facility, and 679 Governor Street, which is within approximately 604
feet of the subject facility; and
WHEREAS, the applicant received notice of a scheduled Director's Hearing more
than seven (7) business days prior and received a written report prepared by staff
recommending denial of the SUP based upon the criterion established in Section 13-
311(b)(6)(iii) of the Costa Mesa Municipal Code; and
WHEREAS, a Director's Hearing was conducted on September 1, 2016 providing
the applicant with the opportunity to present any reasons and/or evidence why the special
permit should not be denied; and
WHEREAS, the Director provided a written notice to the applicant denying the SUP
pursuant to Section 13-311(b)(6)(iii) and included a statement of the right to appeal to the
Planning Commission and the time -limits therefore; and
WHEREAS, the Applicant appealed the denial of the application in a timely
manner; and
WHEREAS, on November 28, 2016, the Planning Commission considered the
appeal of the Director's determination at a regularly scheduled meeting open to the public,
at which time interested persons had an opportunity to testify either in support of or in
opposition to the Application and determined by a 5-0 vote to uphold the Director's denial
of the SUP; and
WHEREAS, on December 5, 2016, the Applicant appealed the decision of the
Planning Commission to deny this application in a timely manner; and
WHEREAS, on June 20, 2017, the City Council considered the appeal during a
duly noticed public hearing, at which time interested persons had an opportunity to testify
either in support or in opposition to the application; and
WHEREAS, at the time the Applicant filed SUP SL -15-0014 there were no other
permitted group homes or state licensed facilities within 650 feet of the Property; and
WHEREAS, the City has received no complaints regarding the Property or the
operation of the sober living home since it began operation in 2004; and
WHEREAS, the planned closure of arterial wall openings along Victoria St. and
Fairview Ave. will mitigate the proximity of the two exisiting state licensed drug and alcohol
facilities located at 687 Governor Street and 679 Governor Street; and
WHEREAS, Applicant indicated that he wished to apply for a reasonable
accomodation to be relieved of the location requirements of Section 13-311(b)(6)(iii); and
WHEREAS, good cause exists to relieve the Applicant from strict compliance with
the procedural requirements of Article 15 (Reasonable Accomodations) of Title 13
(Zoning) of the Costa Mesa Municipal Code; and
WHEREAS, granting a reasonable accommodation to relieve the Applicant of the
location requirements of Section 13-311(b)(6)(iii) is justified because the accommodation
is: requested by or on the behalf of one (1) or more individuals with a disability protected
under the fair housing laws; is necessary to provide one (1) or more individuals with a
disability an equal opportunity to use and enjoy a dwelling; will not impose an undue
financial or administrative burden on the City; is consistent with surrounding uses in scale
and intensity of use; will not, under the specific facts of the case, result in a direct threat
to the health or safety of other individuals or substantial physical damage to the property
of others; will not result in a fundamental alteration in the nature of the city's zoning
program; will not fundamentally alter the character of the neighborhood; will not result
in a substantial increase in traffic or insufficient parking; will not create an
institutionalized environment due to the number of and distance between similar
facilities; and as an established use for long term residents since 2004, this facility
provides a unique type of living environment at a relatively lower cost that is not
available in this specific neighborhood; therefore, approval of this accommodation is
necessary to ensure that individuals with a disability have an opportunity to enjoy this
type of residential setting.
NOW THEREFORE, the City Council of the City of Costa Mesa finds that the
above stated facts are true and correct and finds and resolves as follows:
BE IT RESOLVED, therefore, the facility located at the Property is a sober living
home. A reasonable accommodation is hereby granted to relieve the Applicant of the
location requirements of Section 13-311(b)(6)(iii).
BE IT FURTHER RESOLVED, therefore, that based on the evidence in the record
and the findings contained in this resolution, the City Council hereby reverses THE
PLANNING COMMISISON'S DENIAL of Special Use Permit SL -15-0014 to operate a
sober living home at 2152 Raleigh Avenue.
BE IT FURTHER RESOLVED, therefore, that the City Council hereby authorizes
the DIRECTOR OF DEVELOPMENT SERVICES to issue a Special Use Permit to the
Applicant to authorize the continued operation of a sober living home at 2152 Raleigh
Avenue.
BE IT FURTHER RESOLVED that if any section, division, sentence, clause,
phrase or portion of this resolution, or the documents in the record in support of this
resolution, are for any reason held to be invalid or unconstitutional by a decision of any
court of competent jurisdiction, such decision shall not affect the validity of the remaining
provisions.
The City Clerk shall attest to the adoption of this resolution and shall forward a
copy to the Applicant, and any person requesting the same.
PASSED AND ADOPTED this 18th day of July, 2017.
ATTEST:
Katrina Foley, Mayor
APPROVED AS TO FORM:
Brenda Green, City Clerk Thomas Duarte, City Attorney
STATE OF CALIFORNIA
COUNTY OF ORANGE
CITY OF COSTA MESA
I, Brenda Green, City Clerk of the City of Costa Mesa, do hereby certify that the
above and foregoing is the original of Resolution No. 17-48 and was duly passed and
adopted by the City Council of the City of Costa Mesa at a regular meeting held on the
18th day of July, 2017, by the following votes:
AYES: COUNCIL MEMBERS:
NOES: COUNCIL MEMBERS:
ABSENT: COUNCIL MEMBERS:
Brenda Green, City Clerk
ATTACHMENT 2
CITY COUNCIL AGENDA REPORT
MEETING DATE: JUNE 20, 2017 ITEM NUMBER:
C�RpORFTEO �9 ..
SUBJECT: APPEAL OF THE DENIAL OF SPECIAL USE PERMIT SL -15-0014 TO OPERATE A
SOBER LIVING HOME SERVING SIX RESIDENTS AT 2152 RALEIGH AVENUE
DATE: JUNE 9, 2017
FROM: DEVELOPMENT SERVICES DEPARTMENT
PRESENTATION BY: SHERI VANDER DUSSEN, INTERIM ASSISTANT DIRECTOR
FOR FURTHER INFORMATION SHERI VANDER DUSSEN (714)754-5617
CONTACT: Sheri.vanderdussen@costamesaca.gov
RECOMMENDATION:
Uphold the Planning Commission's denial of Special Use Permit SL -15-0014; or
Reverse the Planning Commission's denial of Special Use Permit SL -15-0014; or
Remand this application back to the Planning Commission for further review.
APPLICANT:
The applicant and property owner is Gregg Ohlhaver of Keystone Sober Living.
ANALYSIS -
This Special Use Permit (SUP) would allow the continued operation of a group home with
six or fewer residents and one live-in house manager. The Director of Economic and
Development Services denied the SUP and the applicant appealed that decision to the
Planning Commission. On November 28, 2016, the Planning Commission voted to
uphold the denial of the application. The applicant timely filed an appeal of that decision
to the City Council.
Background
Under state law, a drug or alcohol treatment facility serving six or fewer residents that is
licensed by the Department of Health Care Services (DHCS) is considered to be a
residential use of property. Under Health & Safety Code section 11834.23, the City
generally cannot apply standards to a licensed facility that differ from those standards
applicable to a single family dwelling. However, these prohibitions do not apply to facilities
that are not state licensed.
The City Council adopted Ordinance 14-13 on October 21, 2014 revising the Costa
Mesa Municipal Code (CMMC) to establish conditions for granting a SUP to group
homes with six or fewer residents in an R1 zone. The ordinance became effective on
November 20, 2014. A sober living home is a type of group home for persons who are
recovering from drug and/or alcohol addiction. Persons recovering from addiction who
are currently not abusing drugs and/or alcohol are considered disabled under state and
federal law. Group homes serving disabled persons are not considered to be
boardinghouses. Rather, these facilities offer disabled persons the opportunity to live in
residential neighborhoods in compliance with state and federal laws. Upon adopting the
ordinance, the City Council found that without some regulation there is no way of ensuring
that the individuals entering into a group home are disabled individuals and entitled to
reasonable accommodation under local and state law, or that a group home is operated
professionally to minimize impacts to the surrounding neighborhood.
In enacting the ordinance, the City Council made the finding that housing inordinately
large numbers of unrelated adults in a single-family home or congregating sober living
homes in close proximity to each other does not provide the disabled with an
opportunity to "live in normal residential surroundings," but rather places them into living
environments bearing more in common with types of institutional/campus/ dormitory
living. Further, the City Council found that a 650 -foot distance requirement between
sober living facilities provides a reasonable market for the purchase and operation of
sober living homes within the City and still results in preferential treatment for sober
living homes in that non -disabled individuals in a similar living situation (i.e., in
boardinghouse style residences) cannot reside in the R1 zone. Specifically, CMMC
section 13-311(b)(6) provides in relevant part:
A special use permit for a sober living home shall also be denied, and if already
issued, any transfer shall be denied or revoked, upon a hearing by the director
under any of the following additional circumstances:
iii. The sober living home, as measured by the closest property lines, is located
within six hundred fifty (650) feet of any other sober living home or state licensed
alcoholism or drug abuse recovery or treatment facility. If a state licensed
alcoholism or drug abuse recovery or treatment facility moves within six hundred
fifty (650) feet of an existing sober living home this shall not cause the revocation
of the sober living home's permit or be grounds for denying a transfer of such
permit.
Project Description
The subject property is a two-bedroom, two bath single family home located in the west
side of Costa Mesa and surrounded by other homes with an R1 (single family
residential) zoning designation. The applicant describes the facility as a sober living
home for men. According to the City's records, this sober living facility was existing
when Ordinance 14-13 became effective.
The application was submitted in March of 2015 but was not deemed complete until
November 28, 2015. There have been no complaints to Code Enforcement regarding
- 9—
this property. There have been two calls for police service in the past five years. Both
involved medical aid.
There are two existing licensed alcoholism and drug abuse recovery treatment facilities
with six or fewer residents within 650 feet of the subject property. Those facilities are
located at 687 Governor St. (482 feet from the subject property) and 679 Governor St.
(604 feet from the subject property). The facilities located on Governor Street are
operated by Safe Harbor Recovery and provide residential detoxification services to
female populations. The licenses for the facilities on Governor Street were issued on
August 1, 2015.
On May 2, the City Council adopted a code amendment changing the process to
approve or deny SUP applications. This amendment became effective on June 2.
However, this application was processed under the former regulations. Under those
regulations, The Director of Economic and Development Services conducted a
Director's Hearing for the subject application on September 1, 2016. During the
hearing, Mr. Ohlhaver stated that he has been operating at the current location for 13
years and has strong ties to the neighborhood. After considering the facts pertaining to
the application, the Director sent a letter to the applicant denying the SUP on
September 7, 2016 due to the proximity of the two state licensed drug and alcohol
treatment facilities on Governor. On September 13, 2016, the applicant filed an appeal
to the Planning Commission pursuant to CMMC Sections 2-305(2) and 2-307.
In the letter requesting the appeal, Mr. Ohlhaver indicated that the subject facility is an
"alcoholism or drug abuse recovery or treatment facility" pursuant to California Health
and Safety Code Section 11834.02(a) and should not be treated differently than a
single family residence. He argues that his right to continue operating at the current
location is protected by the California Constitution and the Americans with Disabilities
Act. However, the subject facility is not licensed as an alcoholism or drug abuse
recovery or treatment facility. Because the facility does not have a DHCS license, it falls
under the definition of a sober living home and is subject to the City's regulations.
Mr. Ohlhaver also included a statement in his appeal letter that the facility does not
pose a new threat to the neighborhood because it has been located at that site for over
a decade and has operated without complaints or issues in the community. He further
poses the question as to why his facility should relocate even though it has been there
longer than the state licensed facilities. At its meeting of November 28, 2016, the
Planning Commission held a hearing to consider the applicant's appeal of the director's
decision. The Commission voted unanimously to uphold the denial of the SUP. The
Commission determined that the state licensed facilities located at 687 Governor Street
and 679 Governor Street have precedence over Mr. Ohlhaver's facility because they
are already considered permitted uses by definition.
ENVIRONMENTAL DETERMINATION
The request is exempt from the provisions of the California Environmental Quality Act
(CEQA) pursuant to CEQA Guidelines Sections 15268 (ministerial projects), 15270
(disapproved projects) and 15301 (existing facilities).
ALTERNATIVES
As with any appeal of a decision made by the Planning Commission, the City Council has
several alternatives. The City Council may uphold the Planning Commission's decision to
deny this application. The City Council may also reverse the Commission's decision.
Finally, the City Council may remand the matter back to the Planning Commission for
further review. A draft resolution upholding the Commission's decision has been attached
to this report as that is the City's typical practice, but this does not obligate the Council to
uphold the Commission's decision.
CONCLUSION
The applicant has appealed the Planning Commission's denial of the Special Use
Permit application to operate a sober living home with six or fewer residents. The
Commission's action upheld a decision of the Director of Development Services to deny
the application. The facility complies with the criteria adopted by the City for sober
living homes, except for the required separation between similar facilities.
SHERI VANDER DUSSEN, AICP J�Y 17REVINO, AICP
Interim Assistant Director De elopment Services Department Consultant
ATTACHMENTS: 1. Resolution Denying Special Use Permit SL -15-0014
2. Map Depicting Separation Standard
3. Appeal of the Planning Commission's Decision
4, Staff Report prepared for Planning Commission Meeting of
November 28, 2016, with attachments
5. Planning Commission Resolution No. 16-64
6. Excerpt of the Minutes of the Planning Commission Meeting
of November 28, 2016
ATTACHMENT 1
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
COSTA MESA UPHOLDING THE PLANNING
COMMISSION'S DENIAL OF SPECIAL USE PERMIT SL -
15 -0014 TO OPERATE A SOBER LIVING HOME SERVING
SIX OR FEWER OCCUPANTS AT 2152 RALEIGH AVENUE
WHEREAS, Gregg Ohlhaver of Keystone Sober Living (the "Applicant") operates
a sober living home serving six males at 2152 Raleigh Avenue, Costa Mesa; and
WHEREAS, the City of Costa Mesa recognizes that while not in character with
residential neighborhoods, when operated responsibly, group homes, including sober
living homes, provide a societal benefit by providing disabled persons as defined by state
and federal law the opportunity to live in residential neighborhoods, as well as providing
recovery programs for individuals attempting to overcome their drug and alcohol
addictions; therefore, providing greater access to residential zones to group homes,
including sober living homes, than to boardinghouses or any other type of group living
provides a benefit to the City and its residents; and
WHEREAS, the City of Costa Mesa has adopted standards for the operation of
group homes, residential care facilities and state licensed drug and alcohol facilities that
are intended to provide opportunities for disabled persons, as defined by state and federal
law to enjoy comfortable accommodations in a residential setting; and
WHEREAS, the City of Costa Mesa has found that congregating sober living
homes in close proximity to each other does not provide disabled persons as defined in
state and federal law with an opportunity to "live in normal residential surroundings," but
rather places them into living environments bearing more in common with the types of
institutional/campus/dormitory living that the FEHA and FHAA were designed to provide
relief from for the disabled, and which no reasonable person could contend provides a life
in a normal residential surrounding; and
WHEREAS, the City of Costa Mesa has determined that a separation requirement
for such facilities will still allow for a reasonable market for the purchase and operation of
sober living homes within the City and still result in preferential treatment for sober living
homes in that non -disabled individuals in a similar living situation (i.e., in boardinghouse -
style residences) have fewer housing opportunities than disabled persons; and
WHEREAS, the Applicant filed special use permit (SUP) SL -15-0014 with the
City's Development Services Department to operate a group home with six or fewer
residents in an R1 zone- and
WHEREAS, there are two exisiting state licensed drug and alcohol facilities with
six or fewer residents located at 687 Governor Street, which is within apprxoimately 482
feet of the subject facility, and 679 Governor Street, which is within approximately 604
feet of the subject facility; and
WHEREAS, the applicant received notice of a scheduled Director's Hearing more
than seven (7) business days prior and received a written report prepared by staff
recommending denial of the special use permit based upon the criterion established in
Section 13-311(b)(6)(iii) of the Costa Mesa Municipal Code; and
WHEREAS, a Director's Hearing was conducted on September 1, 2016 providing
the applicant with the opportunity to present any reasons and/or evidence why the special
permit should not be denied; and
WHEREAS, the Director provided a written notice to the applicant denying the
special use permit pursuant to Section 13-311(b)(6)(iii) and included a statement of the
right to appeal to the Planning Commission and the time -limits therefore; and
WHEREAS, the applicant appealed the denial of the application in a timely
manner; and
WHEREAS, on November 28, 2016, the Planning Commission considered the
appeal of the Director's determination at a regularly scheduled meeting open to the public,
at which time interested persons had an opportunity to testify either in support of or in
opposition to the Application and determined by a 5-0 vote to uphold the Director's denial
of the SUP; and
WHEREAS, on December 5, 2016, the applicant appealed the decision of the
Planning Commission to deny this application in a timely manner; and
WHEREAS, on June 20, 2017, the City Council considered the appeal during a
duly noticed public hearing, at which time interested persons had an opportunity to testify
either in support or or in opposition to the application.
NOW THEREFORE, the City Council of the City of Costa Mesa finds and
resolves as follows:
The facility located at 2152 Raleigh Avenue (the "Property") is a sober living home.
Section 13-311 of the CMMC sets forth the required findings to be used in the
determination to approve or deny a SUP. There are state licensed alcoholism and drug
treatment facilities located at 679 and 687 Governor Street, both within 650 feet of the
Property. Pursuant to CMMC section 13-311(b)(6) in effect at the time action was taken
on the application, the SUP was denied upon a hearing of the Director.
BE IT RESOLVED, therefore, that based on the evidence in the record and the
findings contained in this resolution, the City Council hereby UPHOLDS THE PLANNING
COMMISISON'S DENIAL of Special Use Permit SL -15-0014 to operate a sober living
home at 653 Joann Street.
The City Clerk shall attest to the adoption of this resolution and shall forward a
copy to the applicant, and any person requesting the same.
PASSED AND ADOPTED this 20th day of June, 2017.
ATTEST:
Brenda Green, City Clerk
Katrina Foley, Mayor
APPROVED AS TO FORM:
Thomas Duarte, City Attorney
— 14-
STATE OF CALIFORNIA )
COUNTY OF ORANGE )
CITY OF COSTA MESA )
I, Brenda Green, City Clerk of the City of Costa
above and foregoing is the original of Resolution No.
adopted by the City Council of the City of Costa Mesa
20th day of June, 2017, by the following votes:
AYES: COUNCIL MEMBERS:
NOES: COUNCIL MEMBERS:
ABSENT: COUNCIL MEMBERS:
Mesa, do hereby certify that the
17 -XX and was duly passed and
at a regular meeting held on the
Brenda Green, City Clerk
ATTACHMENT 2
--16-
Appitcanl
Address:
Phone.
ATTACHMENT 3
CITY CLERK
City of Costa Mesa
16 DEC -S PH 4: 30
CITY a
r.S ,c ® Appeal of Commission Deciseon • $1,220.00
TA a��a �
Bi ❑ Appeal of Zoning Administrator!Staff Decision - $690.00
APPLICATION FOR APPEAL OR REVIEW
REQUEST FOR: Q APPEAL D REVIEW"
Decision of which appeal or review is requested_ (give application number, if applicable, and the date of the decision. if
k nnwn I
Decision by: P( CL^ v1 s PA O a YL1 r 5 i uv�
Reasons for recuestina aooeal or review.
Date: `; �/ r Signature: •',,`= L. ?'i; L + -
If you ars serving as the agent for another person, please identify the person you represent and provide proof of authorization.
"Review may be requested only by Commissions, Commission Members, City Council. or City Council Members.
For office use only— do not writs Blow this line REV 4-1.15
SCHEDULED FOR THE CITY COUNCIL/COMMISSION MEETING OF:
-19-
Keystone Sober Living
2152 Raleigh Ave Costa Mesa, CA
Katie Angel
Management Analyst
Community Improvement
City of Costa Mesa
77 Fair Drive
Costa Mesa, CA
RE: Letter of Appeal
Dear Ms. Angel:
1``l, ., . .-.1
�,ITY CLERK
ib DEC -5 FN k-* 30
i,.TY j CC,.,IA MESA
8
The California Building Code provides, in Chapter 3, definitions and classifications
which include R-3.0 designations. Section R-3 contains a list of building uses which would fall
under that section. That list SPECIFICALLY includes "Alcoholism or drug abuse recovery
homes (ambulatory only)." This is important because California's constitution and laws state that
Alcoholism and Drug Abuse recovery homes are not to be treated any differently than single
family residences within the state.
Furthermore, the California Health and Safety Code speaks to this issue strongly.
As used in this chapter, "alcoholism or drug abuse recovery or treatment facility"
or "facility" means any premises, place, or building that provides 24-hour
residential nonmedical services to adults who are recovering from problems
related to alcohol, drug, or alcohol and drug misuse or abuse, and who need
alcohol, drug, or alcohol and drug recovery treatment or detoxification services.
California Health and Safety Code §I 1834.02(a).
In the instant case, the owner and operator has been providing care which meets this
definition for more than a deesde within Costa Mesa, with a business license issued by Costa
Mesa. However, the owner has not yet received licensing from the State of California under
11834 because, until now, Costa Mesa has not seen it to attack his right to operate at the
location. Costa Mesa's regulatory changes state that -group homes' are separate and distinct from
alcoholism or drug abuse recovery treatment facilities. The 650 foot separation requirement
applies to the special use permit requirements for group homes. As this facility has been
operating NOT as a group home, but rather as a 11834 entity simply without the license, and will
_,s_
soon have the license as well, it seems fair that more than a decade of faultless participation in
the community should be allowed to continue.
Furthermore, those recovering from alcoholism and drug abuse are considered under
Federal law to be disabled for the purposes of rights against discrimination. 28 C.F.R. §
35.104(1)(ii). Therefore restrictions, requirements and actions by local government actors which
would result in discrimination either on its face or through disparate impact. Requiring licensed
alcoholism and drug abuse treatment homes to conform to additional requirements, where no
private residences are required to do such, and where the treatment center can at LEAST as
clearly fall under R-3 classification, could be considered a discriminatory enforcement policy
which violates the Fair Housing Act under Federal law as well as California law through
California Government Code Section 12955.
The recent lawsuits, against Newport Beach and Costa Mesa, on behalf of this type of
drug and alcohol rehabilitation facility, have shown that this area of law is murky at best. While
a withdrawn appeal against Costa Mesa can be seen as a victory - that does not mean the
California regulations should still be flaunted when it comes to asymmetrical enforcement
against certain individual treatment facilities. Moreover, the cause of action against the 650 foot
rule was thrown out, initially, based upon ripeness. "To the extent that this allegation constitutes
an as-applied challenge to the Ordinance, it is unripe because Plaintiffs have not yet sought an
accommodation through the Ordinance's procedures." In the instant case, the- claimed reason for
the disapproval of this center was because it violated the 650 feet ordinance, and a claim against
such a rule would indeed be ripe at this point. The owner is currently seeking permit from the
city, and in the event this appeal is rejected, shall be seeking reasonable accommodation as well.
The owner in this case is simply seeking recognition of his long standing, unchanged
business which obviously cannot be a new threat to the character of the neighborhood because it
has been a part of that neighborhood for so many years. Moreover, the city has presented no
evidence that any complaints have been filed against this home or any other reason why the
residents of this home are, themselves, a threat to the community. Even presuming that the 650
foot ordinance would have withstood challenge past the trial court level, in this case enforcement
is being handled capriciously. This facility has been present at the current location for more than
a decade, so to say that this facility must move; rather than whatever more recent facility which
is within 650 feet, has no reasonable basis.
In summary, this residential treatment center has been licensed openly and for more than
a decade operating as an alcoholism and drug abuse recovery center which falls under the
protections of California's Constitution as well as Federal ADA and Constitutional protections.
tq -
This is reinforced and supported by the California Health and Safety Code explicitly and the
Federal Fair Housing Act by reference to such treatment centers. Moreover, Federal regulations
and case law shows that such recovering adults are protected from discriminatory actions by
being included in the definition of disabled persons, and any treatment specifically aimed at
making operation of centers such as this more difficult runs the risk or being found a
discriminatory action, an issue which has not been settled in court at this time despite the trial
court level dismissal of the Solid Landings Behavioral Health, Inc. case.
The owner requests an appeal hearing on this matter and further or in the alternative
requests to be informed of findings as to: why this facility must relocate under the 650 foot rule
rather than another, newer facility; why the new ordinance is being applied to a facility which
has no history of complaints or issues in the community; and why the owner cannot be granted
leave to operate pursuant to 11834 under California law as it has been with the tacit or explicit
permission of Costa Mesa through its granting of a business license for so many consecutive
years leading to the current matter.
Respectfully,
S-G�
Gregg Ohlhaver
Keystone Sober Living
2D
ATTACHMENT 4
PLANNING COMM/SS/ON
,AGENDA REPORT
MEETING DATE: NOVEMBER 28, 2016 ITEM NUMBER:
SUBJECT: APPEAL OF THE DENIAL OF SPECIAL USE PERMIT SL -15-0014 TO OPERATE A
SOBER LIVING HOME AT 2152 RALEIGH AVENUE
DATE: NOVEMBER 17, 2016
FROM: COMMUNITY IMPROVEMENT DIVISION/DEVELOPMENT SERVICES DEPARTMENT
PRESENTATION BY: SHERI VANDER DUSSEN, INTERIM ASSISTANT DIRECTOR/COMMUNITY
IMPROVEMENT DIVISION
FOR FURTHER INFORMATION CONTACT: KATIE ANGEL, MANAGEMENT ANALYST
(714) 754-5618 katie.angel@costamesaca.gov
PROJECT DESCRIPTION
The applicant applied for a Special Use Permit (SUP) to operate a group home with six or
fewer all-male residents at 2152 Raleigh Avenue on April 2, 2015. The Director of Economic
and Development Services/Deputy CEO denied the SUP and the applicant has appealed
that decision to the Planning Commission.
APPLICANT
The applicant is Gregg Ohlhaver of Keystone Sober Living
ENVIRONMENTAL DETERMINATION
The request is exempt from the provisions of the California Environmental Quality Act
(CEQA) pursuant to CEQA Guidelines Sections 15268 (ministerial projects), 15270
(disapproved projects) and 15301 (existing facilities).
RECOMMENDATION
Uphold the Director's denial of the SUP by adoption of a resolution
BACKGROUND
Under state law, a licensed drug or alcohol treatment facility serving six or fewer residents is
considered to be a residential use of property. Under State law, the City generally cannot
apply standards to such a licensed facility that differ from those standards applicable to a
single family dwelling. However, these prohibitions do not apply to facilities that are not state
licensed.
The City Council adopted Ordinance 14-13 on October 21, 2014 which established
conditions for granting a SUP to group homes with six or fewer residents in an R1 zone.
The ordinance became effective on November 20, 2014. A sober living home is a type of
group home for persons who are recovering from drug and/or alcohol addiction. Persons
recovering from addiction who are currently not abusing drugs and/or alcohol are
considered disabled under state and federal law. Group homes serving disabled persons
are not considered to be boardinghouses. Rather, these facilities offer disabled persons
the opportunity to live in residential neighborhoods in compliance with state and federal
laws. Upon adopting the ordinance, the City Council found that without some regulation
there is no way of ensuring that the individuals entering into a group home are disabled
individuals and entitled to reasonable accommodation under local and state law or that a
group home is operated professionally to minimize impacts to the surrounding
neighborhood. A purpose of the land use regulations provided in the ordinance is to mitigate
the secondary impacts from an over concentration of both group homes in a neighborhood.
SUPs are granted to a group home operator as a ministerial matter if the facility is in
compliance with the operating requirements found in CMMC sections 13-311 (a)(1)
through (a)(9).
In enacting the ordinance, the City Council made the finding that housing inordinately
large numbers of unrelated adults in a single-family home or congregating sober living
homes in close proximity to each other does not provide the disabled with an opportunity
to "live in normal residential surroundings," but rather places them into living environments
bearing more in common with types of institutional/campus/ dormitory living. Further, the
City Council found that a 650 -foot distance requirement between sober living facilities
provides a reasonable market for the purchase and operation of sober living homes within
the City and still results in preferential treatment for sober living homes in that non -
disabled individuals in a similar living situation (i.e., in boardinghouse style residences)
cannot reside in the R1 zone. Specifically, CMMC section 13-311(b)(6) provides in
relevant part:
A special use permit for a sober living home shall also be denied, and if already
issued, any transfer shall be denied or revoked, upon a hearing by the director
under any of the following additional circumstances:
iii. The sober living home, as measured by the closest property lines,
is located within six hundred fifty (650) feet of any other sober living
home or state licensed alcoholism or drug abuse recovery or
treatment facility. If a state licensed alcoholism or drug abuse
-2Z-
recovery or treatment facility moves within six hundred fifty (650) feet
of an existing sober living home this shall not cause the revocation of
the sober living home's permit or be grounds for denying a transfer of
such permit.
Under section 13-312(b), "Group homes that are in existence upon the effective date of
this chapter shall have one (1) year from the effective date of this chapter to comply with
its provisions". The operator submitted the SUP application for 2152 Raleigh on March
31, 2015. During the first year of the implementation of the ordinance, approximately 60
group home applications were received. The majority of those applications were missing
items required by the CMMC. Staff worked with the all of the applicants to request
complete information. Upon the one-year compliance deadline, staff determined which
locations had fully complied with the application requirements. Staff began to prepare
for the issuance of permits to locations which complied with the City's adopted criteria
and to prepare for Director's Hearings to consider the facts surrounding facilities that did
not meet the approval criteria established in the ordinance. The Director's Hearings
provide the applicant with an opportunity to present any reasons and/or evidence why the
SUP should not be denied. Following the conclusion of the hearing, the Director provides
a written notice to the applicant or permittee setting forth the decision within ten (10) days.
The decision of the Director is appealable to the Planning Commission.
The implementation of ordinance 14-13 (including processing applications) was delayed
by the issuance of an injunction by the 9th Circuit Court in Solid Landings v. City of Costa
Mesa on December 9, 2015. Once the injunction was dissolved in May, 2016 staff
reviewed the current status of all the SUP applications for group homes on file. Group
homes that met the requirements of the ordinance were issued SUPS and Director's
Hearings commenced for the facilities that did not comply with the City's standards.
The subject property is a five -bedroom single family home located in the west side of
Costa Mesa and surrounded by other homes with an R1 (single family residential) zoning
designation. The applicant describes the facility as a sober living home for men.
According to the City's records, this sober living facility was existing when Ordinance 14-
13 became effective.
There are two existing licensed alcoholism and drug abuse recovery treatment facilities
with six or fewer residents within 650 feet of the subject property. Those facilities are
located at 687 Governor St. (482 feet from the property line) and 679 Governor St. (604
feet from the property line). The facilities located on Governor Street are operated by
Safe Harbor Recovery and provide residential detoxification services to female
populations. The facilities at 687 and 679 Governor Street applied for a DHCS license
on December 4, 2014; these licenses were issued on August 1, 2015. In addition, the
facility at 687 Governor Street applied for a SUP on January 1, 2015. Safe Harbor
subsequently withdrew its SUP application after receiving the state license. As noted
above, state licensed facilities with six or fewer residents are considered residential uses
pursuant to State law and are exempt from land use restrictions that differ from those
restrictions applicable to single family dwellings.
_25—
The Director of Economic and Development Services/Deputy CEO conducted a Director's
Hearing for the subject application on September 1, 2016. During the hearing, Mr.
Ohlhaver stated that he has been operating at the current location for 13 years and has
strong ties to the neighborhood. After considering the facts pertaining to the application,
the Director sent a letter to the applicant denying the SUP on September 7, 2016 due to
the two state licensed drug and alcohol treatment facilities located within 650 feet of the
subject property. On September 13, 2016, the applicant filed an appeal to the Planning
Commission pursuant to CMMC Sections 2-305(2) and 2-307.
ANALYSIS
In the letter requesting the appeal, Mr. Ohlhaver contends that the subject facility is an
''alcoholism or drug abuse recovery or treatment facility" pursuant to California Health and
Safety Code Section 11834.02(a) and should not be treated differently than a single family
residence. He argues that his right to continue operating at the current location is
protected by the California Constitution and the Americans with Disabilities Act. Prior to
the Director's Hearing and preparation of this agenda report, staff reviewed the website
of the state entity that issues licenses to facilities pursuant to Health and Safety Code
Section 11834.02(a). The operation at 2152 Raleigh Avenue was not listed as a licensed
alcoholism or drug abuse recovery or treatment facility. Because the facility does not have
a DHCS license, it falls under the definition of a sober living home and is subject to the City's
regulations.
Mr. Ohlhaver also includes a statement in his appeal letter that the facility does not pose
a new threat to the neighborhood because it has been located at that site for over a
decade and has operated without complaints or issues in the community. He further
poses the question as to why his facility should relocate even though it has been there
longer than the state licensed facilities. In making the determination to deny Mr.
Ohlhaver's application, the Director determined that the state licensed facilities located at
687 Governor Street and 679 Governor Street have precedence over Mr. Ohlhaver's
facility because they are already considered permitted uses by definition.
ALTERNATIVES
A draft resolution denying the appeal has been provided. Should the Planning Commission
believe that findings exist to approve the special use permit application, this hearing should
be continued to allow staff to prepare the appropriate resolution for consideration at a
subsequent meeting.
CONCLUSION
The applicant has appealed the denial of the Special Use Permit application to operate a
sober living home with six or fewer residents. There are two state licensed facilities
within 650 feet of the subject property. Upholding the Director's decision and denying this
SUP will reduce the over concentration of sober living homes in the immediate area, help
to preserve the character of the neighborhood and provide the disabled with greater
access to live in a typical residential environment.
, "kkA � 6kjj CLU
SHERI VANDER DUSSEN, AICP
Interim Assistant Director
Community Improvement Division
(zit
JA EVINO, AICP
Economic Development and
Development Services Director/
Consultant
Attachments: 1. Vicinity and Zoning Maps
2. Letter from Director dated September 7, 2016 denying Special
Use Permit Application
3. Letter from Applicant dated September 13, 2016 appealing the
Director's denial
4. Draft Resolution Upholding the Denial of Special Use Permit No.
SL -15-0014
Distribution: Director of Economic Development & Development Services/
Consultant
Interim Assistant Development Services Director, Planning Division
Interim Assistant Development Services Director, Community
Improvement Division
Assistant City Attorney
Public Services Director
City Engineer
Transportation Services Director
Fire Protection Analyst
Applicant:
Gregg Ohlhaver, 3112 McKinley Way, Costa Mesa, CA 92626
25"-
ATTACHMENT
p
GNI J
` � • i ♦ � � 1
c .o
a�
n
' ♦ 1 l 1 � � • .
O
n �
O �
N
� ro
7 �
I
D
O
0
a 1
trn
v
WALLACE AVE
�
O
N
r J
m � (ju,► t
O
i
J
rn a Kyy �yy N t11
p �O
RALEIGH AVE o a � ,,�
ROJMW AV£
F1
to
r
4
a
STERLING AVE
�r
u
2,
� � g
� N ►.3 ',� � � �"`► •�,� chi
1^'
iD GT V
O g
o ? �
POMQNA AV
vCi m
m0
<• v
�
A � r
2 � 7e �
ml LL (A.1 CTtl
�+� �OAO�OI�•O� � N
o
r
100
d n 3 C1 c7 D /o
L+ � •2 �• 0 0 a Q
lV tV
Al 01
�
In
�
O
a
5!
V r fT
M
V •
6
WALLACE AVE
O
r N M
ca
W v r i7i
"�
�
� 01
•
o
RALEIGH AVEC
a
s
o
-
m
:_
N N N
N
NN W
W V
-
n
STERLING AVE
m �
S
31
�7
D
N j t2
ci W
N
V�V CD
V W
OC !C
V
cO �p
07 aD
of
N N
Z � IT
o � ',-
-' Qt�A A1C
POIMOMA AV
�
S
$v
3
••1
5 �d
iNi/ U7 v N
v
X. 4_
PALMILLA CT
-41 4
{ppb
�:
O
I I ❑ Eltos
O
I❑ _ 0011❑❑D❑��ii■❑❑❑CJ
A) 0
d' n
a
y
i
4
fD tD N N N
ATTACHMENT 2
September 7, 2016
CITY OF COSTA MESA
P.O. BOX 1200.77 FAIR DRIVE . CALIFORNIA 92828-1200
SENT VIA FEDEK EXPRESS & ELECTRONIC MAIL
Gregg Ohihaver
3112 McKinley Way
Costa Mesa, CA 92627
Application: Special Use Permit No. SL -15-0014
Property Address: 2152 Raleigh Avenue
Dear Mr. Ohlhaver:
Thank you for submitting your application for the City of Costa Mesa's Sober living Home Special Use
Permit and attending the Director Hearing on September 1, 2016. Present at that hearing were myself,
Tarquin Preziosi, Deputy City Attorney and Sheri Vander Dussen, Assistant Development Services
Director/Community Improvement Manager, I have thoroughly reviewed your application and the facts
presented at the Director Hearing. Your application is denied pursuant to City of Costa Mesa Municipal
Code (CM MC) requirements for group homes with six or fewer beds in an RS (single family) zone. CMMC
section 13-311(b)(6) provides in relevant part:
A special use permit for a sober living home shall also be denied, and if already issued, any
transfer shall be denied or revoked, upon a hearing by the director under any of the following
additional circumstances:
iii. The sober living home, as measured by the closest property lines, is
located within six hundred fifty (650) feet of any other sober riving home or
state licensed alcoholism or drug abuse recovery or treatment facility. If a
state licensed alcoholism or drug abuse recovery or treatment facility moves
within six hundred fifty (6SO) feet of an existing sober living home this shall
not cause the revocation of the sober living home's permit or be grounds for
denying a transfer of such permit.
There are two existing state licensed alcoholism and drug abuse recovery treatment facilities with six or
fewer residents within 650 feet from the facility. Those facilities are located at 687 and 679 Governor
Street. During the hearing you mentioned that the City had previously sent you a checklist that you
belleve indicated that the 650 -foot separation requirement was non -applicable. Staff reviewed the
application file and found that on the Special Use Permit Application Processing Checklist dated May 5,
2105, "NJA" was listed as a comment next to the Item referring 650 feet separation requirement from
any other sober living home or state licensed alcoholism or drug abuse recovery or treatment facility.
The purpose of the checklist was to identify incomplete information In the application and request that
information from the applicants. The "N/A" indicated that no information was required from you
regarding this requirement to complete your application.
I also wanted to provide additional Information pertaining to your question as to whether another
facility on Raleigh Avenue had been issued a Special Use Permit. Our records indicate that the operator
of a sober living home located at 2186 Raleigh Avenue submitted a Special Use Permit application on
April 8, 2015, but the request was withdrawn on November 2S, 2015 because the facility was closed.
This determination can be appealed to the Planning Commission by filing an application for appeal with
the City Clank. Any appeal must be filed within seven (7) days of this date of denial, which is September
14, 2016 by 5:00 p.m., pursuant to Sections 2-305(2) and 2-307 of the Costa Mesa Municipal Code. Please
see attached ChapterIX, Title li of the Costa Mesa Municipal Code regarding appeal and review procedure.
A fee of $690.00 must accompany the application, in your request for an appeal, please summarize the
reasons for the appeal. If the application for appeal Is not submitted by the deadline, your time to appeal
will have expired.
Should you have any questions, please do not hesitate to call Katie Angel at 714.754.5618 between the
hours of 8:00 a.m. and 5:00 p.m.
Sincerely,
Gary Alrmstrong
Director of Economic and Development Services/Deputy CEO
Attachment: Ordinance Number 14-13
cc: Sheri Vander Dussen, Interim Assistant Director/Communlry improvement Division Manager
Fidel Gamboa, Acting Neighborhood Improvement Manager
Tarquin Preziosi, Esq., Deputy City Attorney
Katie Angel, Management Analyst
any other sober living home or state licensed alcoholism or drug abuse recovery or treatment facility.
The purpose of the checklist was to Identify incomplete information In the application and request that
information from the applicants. The "N/A" indicated that no information was required from you
regarding this requirement to complete your application.
I also wanted to provide additional information pertaining to your question as to whether another
facility on Raleigh Avenue had been issued a Special Use Permit. Our records indicate that the operator
of a sober living home located at 2186 Raleigh Avenue submitted a Special Use Permit application on
April 8, 2015, but the request was withdrawn on November 2S, 2015 because the facility was closed.
This determination can be appealed to the Planning Commission by filing an application for appeal with
the City Clerk. Any appeal must be filed within seven (7) days of this date of denial, which Is September
14, 2016 by 5:00 p.m., pursuant to Sections 2-305(2) and 2-307 of the Costa Mesa Municipal Code. Please
see attached Chapter IK, Title 11 of the Costa Mesa Municipal Code regardingappeal and review procedure.
A fee of $690.00 must accompany the application. In your request for an appeal, please summarize the
reasons for the appeal, If the application for appeal is not submitted by the deadline, your time to appeal
will have expired.
Should you have any questions, please do not hesitate to call Katie Angel at 714.754.5618 between the
hours of 8:00 a.m. and 5:00 p.m.
Sincerely,
7 4—
GaryArmstrong
Director of Economic and Development Services/Deputy CEO
Attachment: Ordinance Number 14-13
cc: Sheri Vander Dussen, Interim Assistant Director/Community Improvement Division Manager
Fidel Gamboa, Acting Neighborhood Improvement Manager
Tarquin Preziosi, Esq., Deputy City Attorney
Katie Angel, Management Analyst
Applican
Address:
Phone:
ATTACHMENT 3
r� t u t I V t` L, Costa Mesa
CITY CLERK City of Costa Mesa
16 SEP 13 AM 11: 05
❑ Appeal of Commission Decision - $1,220.00
LI i Y (i. yL lt,lSA ® Appeal of Zoning Administrator/Staff Decision - $690.00
BY _-- 1. (` _ _ _ , _ (FEES MUST BE PAID IN FULL AT TIME OF FILING APPEAL)
APPLICATION FOR APPEAL OR REVIEW
REQUEST FOR: MX- APPEAL ❑ REVIEW"
Decision of which appeal or review is requested: (give application number, if applicable, and the date of the decision, if
known.)
Decision by'.
Reasons for requesting appeal or review:
'If you are serving as the agent for another person, please identify the Gerson you represent and provide proof of authorization.
"Review may be requested only by Commissions, Commission Members, City Council, or City Council Members.
For office use only- do not write below this line
SCHEDULED FOR THE CITY COUNCIVCOMMISSION MEETING OF:
REV 9-1-15
Keystone Sober Living
2152 Raleigh Ave Costa Mesa, CA
Katie Angel
Management Analyst
Community Improvement
City of Costa Mesa
77 Fair Drive
Costa Mesa, CA
RE: Letter of Appeal
Dear Ms. Angel:
CLERK
" SEP 13 AN 11: 05
Cf TY C►T L TA h�ESa
9y
"Che California Building Code provides, in Chapter 3, definitions and classifications
which include R-3.0 designations. Section R-3 contains a list of building uses which would fall
under that section. "that list SPECIFICALLY includes "Alcoholism or drug abuse recovery
homes (ambulatory only)." This is important because California's constitution and laws state that
Alcoholism and Drug Abuse recovery homes are not to be treated any differently than single
family residences within the state.
Furthermore, the California Health and Safety Code speaks to this issue strongly.
As used in this chapter, "alcoholism or drug abuse recovery or treatment facility"
or "facility" means any premises, place, or building that provides 24-hour
residential nonmedical services to adults who are recovering from problems
related to alcohol, drug, or alcohol and drug misuse or abuse, and who need
alcohol, drug, or alcohol and drug recovery treatment or detoxification services.
California Health and Safety Code § 11834.02(a).
In the instant case, the owner and operator has been providing care which meets this
definition for more than a decade within Costa Mesa, with a business license issued by Costa
Mesa. However, the owner has not yet received licensing from the State of California under
11834 because, until now, Costa Mesa has not seen fit to attack his right to operate at the
location. Costa Mesa's regulatory changes state that `group homes' are separate and distinct from
alcoholism or drug abuse recovery treatment facilities. The 650 foot separation requirement
applies to the special use permit requirements for group homes. As this facility has been
operating NOT as a group home, but rather as a 11834 entity simply without the license, and will
soon have the license as well, it seems fair that more than a decade of faultless participation in
the community should be allowed to continue.
Furthermore, those recovering from alcoholism and drug abuse are considered under
Federal law to be disabled for the purposes of rights against discrimination. 28 C.F.R. §
35.104(1)(ii). Therefore restrictions, requirements and actions by local government actors which
would result in discrimination either on its face or through disparate impact. Requiring licensed
alcoholism and drug abuse treatment homes to conform to additional requirements, where no
private residences are required to do such, and where the treatment center can at LEAST as
clearly fall under R-3 classification, could be considered a discriminatory enforcement policy
which violates the Fair Housing Act under Federal law as well as California law through
California Government Code Section 12955.
The recent lawsuits, against Newport Beach and Costa Mesa, on behalf of this type of
drug and alcohol rehabilitation facility, have shown that this area of law is murky at best. While
a withdrawn appeal against Costa Mesa can be seen as a victory - that does not mean the
California regulations should still be flaunted when it comes to asymmetrical enforcement
against certain individual treatment facilities. Moreover, the cause of action against the 650 foot
rule was thrown out, initially, based upon ripeness. "To the extent that this allegation constitutes
an as -applied challenge to the Ordinance, it is unripe because Plaintiffs have not yet sought an
accommodation through the Ordinance's procedures." In the instant case, the claimed reason for
the disapproval of this center was because it violated the 650 feet ordinance, and a claim against
such a rule would indeed be ripe at this point. The owner is currently seeking permit from the
city, and in the event this appeal is rejected, shall be seeking reasonable accommodation as well.
The owner in this case is simply seeking recognition of his long standing, unchanged
business which obviously cannot be a new threat to the character of the neighborhood because it
has been a part of that neighborhood for so many years. Moreover, the city has presented no
evidence that any complaints have been filed against this home or any other reason why the
residents of this home are, themselves, a threat to the community. Even presuming that the 650
foot ordinance would have withstood challenge past the trial court level, in this case enforcement
is being handled capriciously. This facility has been present at the current location for more than
a decade, so to say that this facility must move, rather than whatever more recent facility which
is within '050 feet, has no reasonable basis.
In summary, this residential treatment center has been licensed openly and for more than
a decade operating as an alcoholism and drug abuse recovery center which falls under the
protections of California's Constitution as well as Federal ADA and Constitutional protections.
This is reinforced and supported by the California Health and Safety Code explicitly and the
Federal Fair Housing Act by reference to such treatment centers. Moreover, Federal regulations
and case law shows that such recovering adults are protected from discriminatory actions by
being included in the definition of disabled persons, and any treatment specifically aimed at
making operation of centers such as this more difficult runs the risk or being found a
discriminatory action, an issue which has not been settled in court at this time despite the trial
court level dismissal of the Solid Landings Behavioral Health, Inc. case.
The owner requests an appeal hearing on this matter and further or in the alternative
requests to be informed of findings as to: why this facility must relocate under the 650 foot Wile
rather than another, newer facility; why the new ordinance is being applied to a facility which
has no history of complaints or issues in the community; and why the owner cannot be granted
leave to operate pursuant to 11834 under California law as it has been with the tacit or explicit
permission of Costa Mesa through its granting of a business license for so many consecutive
years leading to the current matter.
Respectfully,
Al�q
Gregg Ohlhaver
Keystone Sober Living
ATTACHMENT 4
RESOLUTION NO. PC -16-
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF COSTA MESA TO UPHOLD THE
DIRECTOR'S DENIAL OF SPECIAL USE PERMIT
APPLICATION NO. SL -15-0014 TO OPERATE A SOBER
LIVING HOME WITH SIX OR FEWER OCCUPANTS AT
2152 RALEIGH AVENUE
WHEREAS, Gregg Ohlhaver (the "Applicant") operates a sober living home
serving six males at 2152 Raleigh Avenue, Costa Mesa; and
WHEREAS, the City of Costa Mesa recognizes that while not in character with
residential neighborhoods, when operated responsibly, group homes, including sober
living homes, provide a societal benefit by providing disabled persons as defined by state
and federal law the opportunity to live in residential neighborhoods, as well as providing
recovery programs for individuals attempting to overcome their drug and alcohol
addictions; therefore, providing greater access to residential zones to group homes,
including sober living homes, than to boardinghouses or any other type of group living
provides a benefit to the City and its residents; and
WHEREAS, the City of Costa Mesa has adopted standards for the operation of
group homes, residential care facilities and state licensed drug and alcohol facilities that
are intended to provide opportunities for disabled persons, as defined by state and federal
law to enjoy comfortable accommodations in a residential setting; and
WHEREAS, the City of Costa Mesa has found that congregating sober living
homes in close proximity to each other does not provide disabled persons as defined in
state and federal law with an opportunity to "live in normal residential surroundings," but
rather places them into living environments bearing more in common with the types of
institutional/campus/dormitory living that the FEHA and FHAA were designed to provide
relief from for the disabled, and which no reasonable person could contend provides a life
in a normal residential surrounding; and
WHEREAS, the City of Costa Mesa has determined that a separation requirement
for such facilities will still allow for a reasonable market for the purchase and operation of
sober living homes within the City and still result in preferential treatment for sober living
homes in that non -disabled individuals in a similar living situation (i.e., in boardinghouse -
style residences) have fewer housing opportunities than disabled persons; and
WHEREAS, Gregg Ohlhaver filed special use permit SL -15-0014 to operate a
group home with six or fewer residents in an R1 zone; and
WHEREAS, there are two exisiting state licensed drug and alcohol facilities within
six or fewer residents located at 687 Governor Street and 679 Governor Street within 650
feet of the facility at 2152 Raleigh Avenue; and
WHEREAS, the applicant received notice of a scheduled Director's Hearing more
than seven (7) business days prior and received a written report prepared by staff
recommending denial of the special use permit based upon the criterion established in
Section 13-311(b)(6)(iii); and
WHEREAS, a Director's Hearing was conducted on September 1, 2016 providing
the applicant with the opportunity to present any reasons and/or evidence why the special
permit should not be denied; and
WHEREAS, the Director provided a written notice to the applicant denying the
special use permit which included a statement of the right to appeal to the Planning
Commission and the time -limits therefore; and
WHEREAS, the applicant appealed the denial of the application in a timely
manner; and
WHEREAS, on November 28, 2016, the Planning Commission considered the
appeal of the Director's determination at a regularly scheduled meeting open to the public,
at which time interested persons had an opportunity to testify either in support of or in
opposition to the Application and determined by a X -X vote to uphold the Director's denial
of the SUP.
NOW THEREFORE, the Planning Commission of the City of Costa Mesa finds
and resolves as follows:
The facility located at 2152 Raleigh Street is a sober living home. The City of Costa
Mesa Municipal Code Section CMMC section 13-311 sets forth the required findings to
be used in the determination to approve or deny a SUP. There are two state licensed
alcoholism and drug treatment facilities located at 687 Governor Street and 679 Governor
Street within 650 feet of the Property. Pursuant to CMMC section 13-311(b)(6), the SUP
shall be denied upon a hearing of the Director.
BE IT RESOLVED, therefore, that based on the evidence in the record and the
findings contained in this resolution, the Planning Commission hereby UPHOLDS THE
DIRECTOR'S DENIAL of Special Use Permit SL -15-0014 to operate a sober living home
at 2152 Raleigh Avenue.
The Secretary of the Commission shall attest to the adoption of this resolution and
Shall forward a rnpy to the applicant and any person requesting the same.
PASSED AND ADOPTED this 28th day of November, 2016.
Robert L. Dickson Jr., Chair
Costa Mesa Planning Commission
— �W'—
STATE OF CALIFORNIA )
)ss
COUNTY OF ORANGE )
I, Jay Trevino, Secretary to the Planning Commission of the City of Costa Mesa,
do hereby certify that the foregoing Resolution was passed and adopted at a meeting of
the City of Costa Mesa Planning Commission held on November 28, 2016 by the following
votes:
AYES. COMMISSIONERS
NOES: COMMISSIONERS
ABSENT: COMMISSIONERS
ABSTAIN: COMMISSIONERS
Jay Trevino, Acting Secretary
Costa Mesa Planning Commission
�3q
647 JOANN ST CM
RICHARD PERLLN
949 648-1699
1011 BRIOSO DR. SUITE#103, COSTA MESA, CA, 92627
?7
TUCKS M
Residential Service Facility Inspection
Item: 00592 CODE INVESTIGATION
05103.1013 By: MBT Action: CONT Comments: I
visited property and spoke to the 'director of Client
Services, Mark Boultinghouse. He told me that 8
clients were living at the property.
05!07"2013 By: MBT Action: CONT Comments:
Mailed out a VN for too many occupants for a RSF in a
R1 zone without a CUP. I gave 15 days to correct the
violation.
05.2312013 By: MBT Action: CONT Comments: I
had a phone conversation with property owner, Richard
Perlin. He told me that he did not receive my VN. He
provided me with his mailing address and I sent out a
new VN,
06/25/2013 By: MBT Action: AP Comments:
Re -inspected property. All violations have been
corrected. Voided citation 0020370. Mailed out hard
copy of voided citation and emaild both Mark and
Richard a copy of voided citation.
Item: 00595 FIELD OBSERVATION
05/03/2013 By: MBT Action: CONT Continents:
Residential service facility visit. Talked with
Director of Client Services. He informed me that
there were 8 clients living at the residence.
050712013 By: MBT Action: CO Comments:
Mailed out violation notice for too many occupants.
0507/2013
CI -13-0145
CIA 3-0145: Entries for Item:595 - FIELD OBSERVATIM49 05/23/2017
Comments
Residential service facility visit. Talked with
Director of Client Services. He Informed me
that there were 8 clients living at the
residence.
Mailed out violation notice for too many
occupants. Gave 15 days to comply.
Officer Brumbaugh and I went out and
Inspected property. We discovered that the
garage has illegally been converted into office
space. 3 bedrooms had 2 beds each, 1
bedroom had 1 bed. Total 6 +1 = OK.
Issue "Pot -K" citation #020376,—$4-5-0.15 days
to correct all violatlons(6!21/13),_
Total Rows: 4
CI -15-0106: Entries for Item:592 - CODE INVESTIGATIO454 05/23/2017
Dab j Unlaw_
Notice sent to property owner MBT W0412015 1 00
g them to submit an application within 50
me this morning. We discussed the lfwlation 61
Notice and he had some questions, He told
me that he would be submitting an application
to come into compliance but then he knows
that he has a year, possibly 2, to come into
compliance. He said he plans on developing
an exit strategy and moving on. I believe he Is
suggesting that he will be selling at least one
of his properties.
1256: 1 received an email from Mark MBT 06112/2015 00
13oultinghouse (Victory House) today at O8:33, � 84
asking me to email the GH Application docs. I
sent him the docs via email today at 12:56 pm.
�i, SL -15-0041, was submitted on
Total Rows: 4
--12--
ATTACHMENT 5
RESOLUTION NO. PC -16- �q
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF COSTA MESA TO UPHOLD THE
DIRECTOR'S DENIAL OF SPECIAL USE PERMIT
APPLICATION NO. SL -15-0014 TO OPERATE A SOBER
LIVING HOME WITH SIX OR FEWER OCCUPANTS AT
2152 RALEIGH AVENUE
WHEREAS, Gregg Ohlhaver (the "Applicant") operates a sober living home
serving six males at 2152 Raleigh Avenue, Costa Mesa; and
WHEREAS, the City of Costa Mesa recognizes that while not in character with
residential neighborhoods, when operated responsibly, group homes, including sober
living homes, provide a societal benefit by providing disabled persons as defined by state
and federal law the opportunity to live in residential neighborhoods, as well as providing
recovery programs for individuals attempting to overcome their drug and alcohol
addictions; therefore, providing greater access to residential zones to group homes,
including sober living homes, than to boardinghouses or any other type of group living
provides a benefit to the City and its residents; and
WHEREAS, the City of Costa Mesa has adopted standards for the operation of
group homes, residential care facilities and state licensed drug and alcohol facilities that
are intended to provide opportunities for disabled persons, as defined by state and federal
law to enjoy comfortable accommodations in a residential setting; and
WHEREAS, the City of Costa Mesa has found that congregating sober living
homes in close proximity to each other does not provide disabled persons as defined in
state and federal law with an opportunity to "live in normal residential surroundings," but
rather places them into living environments bearing more in common with the types of
institutional/campus/dormitory living that the FEHA and FHAA were designed to provide
relief from for the disabled, and which no reasonable person could contend provides a life
in a normal residential surrounding; and
WHEREAS, the City of Costa Mesa has determined that a separation requirement
for such facilities will still allow for a reasonable market for the purchase and operation of
sober living homes within the City and still result in preferential treatment for sober living
homes in that non -disabled individuals in a similar living situation (i.e., in boardinghouse -
style residences) have fewer housing opportunities than disabled persons; and
WHEREAS, Gregg Ohlhaver filed special use permit SL -15-0014 to operate a
group home with six or fewer residents in an R1 zone; and
WHEREAS, there are two exisiting state licensed drug and alcohol facilities within
six ur fewer residents located at 687 Governor Street and 679 Governor Street within 650
feet of the facility at 2152 Raleigh Avenue; and
WHEREAS, the applicant received notice of a scheduled Director's Hearing more
than seven (7) business days prior and received a written report prepared by staff
recommending denial of the special use permit based upon the criterion established in
Section 13-311(b)(6)(iii); and
WHEREAS, a Director's Hearing was conducted on September 1, 2016 providing
the applicant with the opportunity to present any reasons and/or evidence why the special
permit should not be denied; and
WHEREAS, the Director provided a written notice to the applicant denying the
special use permit which included a statement of the right to appeal to the Planning
Commission and the time -limits therefore; and
WHEREAS, the applicant appealed the denial of the application in a timely
manner; and
WHEREAS, on November 28, 2016, the Planning Commission considered the
appeal of the Director's determination at a regularly scheduled meeting open to the public,
at which time interested persons had an opportunity to testify either in support of or in
opposition to the Application and determined by a X -X vote to uphold the Director's denial
of the SUP.
NOW THEREFORE, the Planning Commission of the City of Costa Mesa finds
and resolves as follows:
The facility located at 2152 Raleigh Street is a sober living home. The City of Costa
Mesa Municipal Code Section CMMC section 13-311 sets forth the required findings to
be used in the determination to approve or deny a SUP. There are two state licensed
alcoholism and drug treatment facilities located at 687 Governor Street and 679 Governor
Street within 650 feet of the Property. Pursuant to CMMC section 13-311(b)(6), the SUP
shall be denied upon a hearing of the Director.
BE IT RESOLVED, therefore, that based on the evidence in the record and the
findings contained in this resolution, the Planning Commission hereby UPHOLDS THE
DIRECTOR'S DENIAL of Special Use Permit SL -15-0014 to operate a sober living home
at 2152 Raleigh Avenue.
The Secretary of the Commission shall attest to the adoption of this reso tion and
shall forward a copy to the applicant, and any person requesting the same.
PASSED AND ADOPTED this 28th day of November, 2016.
Robert L. Dickson J Chair
Costa Mesa Planning Commission
STATE OF CALIFORNIA )
)ss
COUNTY OF ORANGE )
I, Jay Trevino, Acting Secretary to the Planning Commission of the City of Costa
Mesa, do hereby certify that the foregoing Resolution was passed and adopted at a
meeting of the City of Costa Mesa Planning Commission held on November 28th, 2016
by the following votes:
AYES' Dickson, Mathews, McCarthy, Sesler, Andranian
NOES: None
ABSENT None
ABSTAIN: None
k 11�
Jany Tr i ctin ecretary
Costa Mesa Planning Commission
ATTACHMENT 6
APPROVED MINUTE EXCERPTS FROM THE
NOVEMBER 28, 2016 PLANNING COMMISSION MEETING
(Public Hearing No. 3 — SLA 5-0014)
3. Application No.: SL -15-0014
Applicant: Greg Ohlhaver (Keystone Sober Living)
Site Address: 2152 Raleigh Avenue
Zone: R1
Project Planner: Sheri Vander Dussen
Environmental Determination: The request is exempt from the provisions of the
California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Sections
15268 (Ministerial Projects), 15270 (Disapproved Projects) and 15301 (Existing
Facilities).
Description: The applicant applied for a Special Use Permit (SUP) to operate a
group home with six or fewer all-male residents. The Director of Economic and
Development Services/Deputy CEO denied the SUP based on noncompliance with
the zoning code and the applicant has appealed that decision to the Planning
Commission.
No ex -parte communications to report
Sheri Vander Dussen, Interim Assistant Development Services Director/Community
Improvement Division, presented the staff report.
Commissioner McCarthy asked if the arguments in the appeal have merit because
Keystone Sober Living is not a state licensed facility. Tarquin Preziosi, Deputy City
Attorney, responded the issues raised in the appeal are for state licensed facilities
and the applicant is not a state licensed facility.
PUBLIC COMMENTS
Greg Ohlhaver, applicant, spoke about Keystone Sober Living and requested to
approve the special use permit for his facility.
Mr. Olhaver responded to Commissioner Sesler's questions about other services they
offer, how long the residents stay at the facility, and what it would take for his facility to
become state licensed.
Tim Lewis spoke in support of the applicant and Keystone Sober Living facility.
Jay Humphrey, Costa Mesa resident, stated concerns with sober living facilities
avoiding the City's group home ordinance by getting state licensed instead.
A Costa Mesa resident spoke in support of Keystone Sober Living facility and supports
the approval of the special use permit request.
Rob Harrison, former resident of Keystone Sober Living, spoke in support of Keystone
Sober Living facility.
Cindy Black, Costa Mesa resident, asked if a grant was possible to help the applicant
obtain a state license for his facility and if there was a way to help a good neighbor run
a good sober living facility in the City.
A former resident of Keystone Sober Living spoke in support of the application
The Chair closed the public hearing.
Commissioner McCarthy stated he will be supporting the Director's denial.
MOTION: Hereby move that the Planning Commission uphold the Director's
denial of Special Use Permit SL -15-0014 to operate a sober living home at 2152
Raleigh Avenue and include the environmental determination of exempt based
on ministerial projects and disapproved projects.
Moved by Commissioner McCarthy, seconded by Chair Dickson.
RESOLUTION PC -16-64 - A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF COSTA MESA TO UPHOLD THE DIRECTOR'S DENIAL OF
SPECIAL USE PERMIT APPLICATION NO. SL -15-0014 TO OPERATE A SOBER
LIVING HOME WITH SIX OR FEWER OCCUPANTS AT 2152 RALEIGH AVENUE
The motion carried by the following roll call vote:
Ayes: Dickson, Mathews, McCarthy, Sesler, Andranian
Noes: None
Absent: None
Abstained: None
The Chair explained the appeal process.