HomeMy WebLinkAbout19-41 - Upholding the decision of the Planning Commission to deny PA-17-10, Ohio House, 115 East Wilson StreetRESOLUTION NO. 19-41
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COSTA MESA,
CALIFORNIA, UPHOLDING THE DECISION OF THE PLANNING COMMISSION TO
DENY A REASONABLE ACCOMMODATION REQUEST TO DEVIATE FROM
CERTAIN LAND USE REQUIREMENTS OF THE ZONING CODE; AND TO DENY
CONDITIONAL USE PERMIT PA -17-10 TO ALLOW A SOBER LIVING FACILITY
OPERATED BY OHIO HOUSE HOUSING UP TO 45 OCCUPANTS AT 115 EAST
WILSON STREET, UNITS A THROUGH E
THE CITY COUNCIL OF THE CITY OF COSTA MESA, CALIFORNIA HEREBY
RESOLVES AS FOLLOWS:
WHEREAS, Ohio House (the "Applicant") currently operates a sober living facility
serving more than six persons at 115 East Wilson Street, Units A through E, Costa Mesa;
and
WHEREAS, the Applicant filed a request for a Reasonable Accommodation to
allow this facility to be located within 650 feet of a property that contains a group home,
sober living home or state -licensed drug and alcohol treatment faciltity; and an application
requesting approval of Conditional Use Permit PA -17-10 to allow the subject sober living
facility to serve up to 35 male adults with 10 live-in managers within five existing units;
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 and drug and alcohol treatment facilities, 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 and drug and
alcohol treatment facilities, than to boardinghouses or any other type of group living that
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
Resolution No. 19-41 Page 1 of 12
WHEREAS, the City of Costa Mesa has found that congregating drug and alcohol
treatment facilities and 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
drug and alcohol treatment and sober living facilities within the City and still result in
preferential treatment for sober living and drug and alcohol treatment facilities 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 City of Costa Mesa has determined that a group home, sober
living home or state -licensed drug and alcohol treatment faciltity shall be operated on a
single parcel of land; and
WHEREAS, the Applicant filed an application with the City's Director of Economic
and Development Services (the "Director") requesting an accommodation from the Costa
Mesa Municipal Code including the requirement that a group home, residential care
facility or state licensed drug and alcohol facility is at least 650 feet from another property
that contains a group home, sober living home or state licensed drug and alcohol
treatment facility, as well as a request to deviate from various zoning code requirements
including separation requirements the requirement to have a house manager; the need
for occupants of be actively participating in legitimate recovery programs; rules regarding
use of drugs and alcohol by residents and visitors; and the requirement for a good
neighbor policy as well as from single housekeeping unit standards; and
WHEREAS, the request for a Reasonable Accommodation and the Conditional
Use Permit application were processed in the time and manner prescribed by federal,
state and local laws, and the Director denied the request for the Reasonable
Accommodation in a letter dated November 27, 2017; and
Resolution No. 19-41 Page 2 of 12
WHEREAS, the Applicant appealed the Director's decision to deny a Reasonable
Accommodation on November 29, 2017; and
WHEREAS, on February 11, 2019 the Planning Commission conducted a duly
noticed public hearing, at which time interested persons had an opportunity to testify
either in support of or in opposition to the application and voted to deny the application;
and
WHEREAS, the Applicant appealed the decision of the Planning Commission in
a timely manner; and
WHEREAS, a duly noticed public hearing was held by the City Council on August
6, 2019, with all persons have the opportunity to speak for or against the proposal.
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
COMMISSION'S DECISION AND DENIES the Applicant's request for Reasonable
Accommodation and Conditional Use Permit PA -17-10.
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.
PASSED AND ADOPTED this 6th day of August, 2019.
ATTEST:
rK,, f & ,:Pe4_
Brenda Green, City Clerk
Katrina Foley, Mayor
APPROVED AS TO FORM:
Kimberly Hall Barlow, City Attorney
Resolution No. 19-41 Page 3 of 12
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss
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. 19-41 and was duly passed
and adopted by the City Council of the City of Costa Mesa at a regular meeting held on
the 6th day of August, 2019, by the following roll call vote, to wit:
AYES: COUNCIL MEMBERS: CHAVEZ, GENTS, REYNOLDS, MANSOOR,
MARK, STEPHENS, FOLEY
NOES: COUNCIL MEMBERS: NONE
ABSENT: COUNCIL MEMBERS: NONE
IN WITNESS WHEREOF, I have hereby set my hand and affixed the seal of the
City of Costa Mesa this 7th day of August, 2019.
.;QQrG1_,
Brenda Gree City Clerk
Resolution No. 19-41 Page 4 of 12
EXHIBIT A
FINDINGS FOR DENIAL
The City's evidence consists of a staff report with attachments. The staff report
provided the factual background, legal analysis and the City's analysis supporting the
denial of the Applicant's request for a Reasonable Accommodation and the Conditional
Use Permit, based on the Applicant not meeting its burden to demonstrate compliance
with all required findings per the Costa Mesa Municipal Code (CMMC).
A. The subject property is located approximately 550 feet from a sober living facility at
165 East Wilson Street. The City approved a Conditional Use Permit (CUP) in 2016
for this facility (PA -16-03). The Applicant applied for Reasonable Accommodation on
October 27, 2017 to allow the subject sober living facility to be located within 650 feet
of the existing sober living facility (the Applicant's letter was dated September 12, 2017
but was received by the City on October 27, 2017). The CUP application was received
for Unit E on March 23, 2017 with CUP applications for the remainder of the units
received between October 27, 2017 and December 5, 2017. The applicant's request
for a Reasonable Accommodation to allow this sober living facility to be located within
650 feet of the sober living facility was denied by the Director of Economic and
Development Services on November 27, 2017. The applicant appealed the request
on November 29, 2017, but gave no reasons for the appeal. On February 11, 2019,
Planning Commission upheld the Director's denial of the requested Reasonable
Accommodation.
B. The Application does not meet the findings required by the Costa Mesa Municipal
Code for approval of a Reasonable Accommodation:
• The requested accommodation is necessary to provide one or more individuals
with a disability with an equal opportunity to use and enjoy a dwelling
The City recognizes that, while not in character with the residential neighborhoods,
when operated responsibly, group homes, including sober living homes, provide a
societal benefit by providing disabled persons the opportunity to live in residential
neighborhoods. These facilities provide recovery programs for individuals
attempting to overcome their drug and alcohol addictions. The City has
established separation criteria to ensure that an overconcentration of sober living
homes and licensed drug and alcohol treatment facilities does not occur in any
neighborhood, thereby, preserving the residential character for all who choose to
reside there.
The application established that the waiver of the separation requirement would
allow one or more individuals who are recovering from drug and alcohol abuse to
enjoy the use these dwellings. However, approval of the request is not necessary
to allow one or more individuals who are recovering from drug and alcohol abuse
to enjoy the use of a dwelling within the City.
Resolution No. 19-41 Page 5 of 12
The operation of a group home is inconsistent with the City's definition of a single
housekeeping unit. The City has established procedures to allow group homes in
residential neighborhoods; allowing a group to be considered a single
housekeeping unit is not necessary to allow the disabled to reside in residential
neighborhoods.
The City has adopted standards for sober living homes and licensed treatment
facilities in residential zones to ensure the disabled have the opportunity to live in
a typical residential neighborhood. The permit process ensures that sober living
homes and licensed treatment facilities comply with the City's standards. The City
specifically required all existing group homes to comply with the new regulations
within one year. The applicant's letter failed to provide a basis to "grandfather" this
facility when all other facilities in operation at the time the regulations were adopted
are also required to comply.
• The requested accommodation is consistent with the surrounding uses in scale
and intensity of use.
The subject facility does not operate as a single housekeeping unit, or even five
single housekeeping units, making it dissimilar to the composition of households
on surrounding properties. The facility is occupied solely by adults at a higher
occupancy than is typical in Costa Mesa. Each resident is allowed to keep a car
on the property. With 35 residents and 10 onsite managers, the facility provides
opportunities for parking conflicts with owners of nearby properties who also rely
on on -street parking. The City's intent in adopting its group home regulations was
to ensure an overconcentration of group homes did not occur in any neighborhood.
The facility would contribute to overconcentration given that it includes five units
on five individual lots.
• Whether the existing supply of facilities of a similar nature and operation in the
community is sufficient to provide individuals with a disability and equal
opportunity to live in a residential setting.
The City has received applications for 64 sober living homes and 11 licensed
treatment facilities that are subject to compliance with Ordinance Nos. 14-13 and
15-11. Twelve sober living homes serving six or fewer residents have been
approved by the City, and two sober living homes serving seven or more
residents have been approved by the City. In addition, there are 74 existing
state licensed drug and alcohol facilities in Costa Mesa that are exempt from
City regulation, or have already obtained the required Conditional Use Permit.
No evidence has been submitted to indicate that the number of sober living
homes and drug and alcohol residential care facilities existing or potentially
allowed in compliance with the City's standards is inadequate.
Resolution No. 19-41 Page 6 of 12
• The requested accommodation will not result in a fundamental alteration in the
nature of the City's zoning program.
Ordinance 15-11 established requirements for sober living homes, group
homes, and licensed drug and alcohol treatment facilities in multi -family zoning
districts. When the City Council adopted this ordinance, it specifically included
a provision requiring a separation of at least 650 feet between such facilities.
The intent of this limitation is to ensure that sober living and drug and alcohol
treatment facilities do not occupy a disproportionate number of homes in any
neighborhood, and to avoid overconcentration of sober living and drug and
alcohol treatment facilities in any area. The City also sought to ensure that
disabled persons recovering from an addiction can reside in a comfortable
residential environment versus in an institutional setting. The City determined
that housing inordinately large numbers of unrelated adults in a single dwelling
or congregating sober living and drug and alcohol treatment facilities 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 the types of
institutional/campus/dormitory living that the state and federal laws were
designed to avoid. The subject property consists of five units on five individual
lots, which already contributes to an overconcentration of sober living homes in
the area. The site's proximity to another sober living home serving more than
six adults contributes to an overconcentration of sober living facilities in this
neighborhood. Granting the accommodation to consider this facility as a single
housekeeping unit and/or waive the separation standard will result in an
overconcentration of sober living facilities in this area that is in conflict with the
intent of the City's zoning program.
When the City adopted Ordinance 15-11, it specifically included provisions
requiring all existing group home operators to come into compliance with the
new regulations within one year of their adoption. The ordinance did not create
or recognize any previously legally existing non -licensed group homes and/or
group homes with 7 or more residents as uses that would be considered
nonconforming. Given the intent of the ordinance, it is not appropriate to grant
the reasonable accommodation to allow the subject facility to be "grandfathered"
and exempted from compliance with current regulations.
The application for reasonable accommodation failed to justify any reason to
waive compliance with the provisions of Section 9-374(b)(11) of the CMMC that
require the applicant to have a house manager; ensure all occupants, other than
the house manager, are actively participating in legitimate recovery programs;
prohibit the use of any alcohol or non-prescription drugs by any recovering
addict; have a policy regarding use and storage of prescription medications; post
house rules in a common area inside the dwelling unit; prohibit visitors who are
under the influence of any drug or alcohol; and maintain a good neighbor policy.
Resolution No. 19-41 Page 7 of 12
C. The Application does not meet the findings required by the Costa Mesa Municipal
Code for approval of a Conditional Use Permit:
• The proposed use is substantially compatible with developments in the same
_general area and would not be materially detrimental to other properties within the
area.
The facility consists of five units on five parcels with a common lot to hold the
project as a common interest development. Approval of this request will allow up
to 45 adults to occupy the site. With the exception of minimum required lot width
requirements, the site satisfies all applicable development standards.
The proposed occupancy of these units constitutes overcrowding pursuant to the
Housing Element of the General Plan, page HOU-23, which states:
Overcrowding is defined as a housing unit occupied by more than
one person per room. A severely overcrowded housing unit is one
with more than 1.5 persons per room. A room is defined as a
bedroom, living room, dining room, or finished recreation room, but
excludes kitchen and bathroom.
This definition is consistent with the Federal HUD standards, which generally
define "overcrowding" to mean housing units with 1.01 or more persons per room.
See 42 USCS § 5302(a)(10). Under this standard, all the units would be
overcrowded.
The subject property is located within approximately 550 feet of a sober living
facility located at 165 East Wilson Street. This facility is licensed to serve 11 adults
and was issued a CUP by the City in 2016 (PA -16-03).
Allowing multiple group homes, sober living homes and/or state -licensed drug and
alcohol treatment facilities to cluster in residential neighborhoods effects a
fundamental change to the residential character of the neighborhood.
Overconcentration of drug and alcohol treatment facilities and group homes
changes the residential character of a neighborhood to one that is far more
institutional in nature. Strong evidence exists that a supportive living environment
in a residential neighborhood provides more effective recovery than an
institutional -style environment. The City's zoning regulations address
overconcentration and secondary effects of drug and alcohol treatment facilities.
The goal of the regulations is to provide the disabled with an equal opportunity to
live in a residential neighborhood, while maintaining the residential character of
existing neighborhoods. Housing 40 to 45 residents in five units which operate as
an integral facility is not in keeping with the residential character of the
neighborhood.
Resolution No. 19-41 Page 8 of 12
The operator of a group home may request reasonable accommodation when
compliance with all of the standards is not possible. Section 13-200.62 (f) of the
Zoning Code sets forth the required findings to be used in the determination to
approve, conditionally approve, or deny a request for reasonable accommodation.
The Code specifies that all findings must be made in order to approve such a
request. The findings to deny this requested accommodation were enumerated
above.
The CMMC establishes criteria for approval of group homes in multi -family zones.
Group homes serving disabled persons as defined by state and federal law 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. Recovering alcoholics and drug addicts, who are not currently using alcohol or
drugs, are considered disabled under state and federal law. Standards for large
group homes are set forth in the Zoning Code. The intent of the regulations is to
preserve the residential character of the City's neighborhoods while providing
opportunities for the disabled to live in comfortable residential surroundings.
The City adopted standards for group homes in response to a proliferation of drug
and alcohol treatment facilities in the community. The City found that an
overconcentration of sober living homes and drug and alcohol treatment facilities
in the City's residential neighborhoods could be deleterious to the residential
character of these neighborhoods and could also lead to the institutionalization of
such neighborhoods. Drug and alcohol treatment facilities and sober living homes
generally do not function as a single housekeeping unit because they house
extremely transient populations; the residents generally have no established ties
to each other when they move in and typically do not mingle with other neighbors;
the residents have little to no say about who lives or doesn't live in the home; the
residents do not generally share expenses; the residents are often responsible for
their own food, laundry and phone; when residents disobey house rules they are
often just evicted from the house; and the residents generally do not share the
same acquaintances. The City found that the size and makeup of the households
in drug and alcohol treatment facilities is dissimilar and larger than the norm,
creating impacts on water, sewer, roads, parking and other City services that are
far greater than the average household. In addition, all the individuals residing in
a drug and alcohol treatment facility are generally over the age of 18, while the
average household in Costa Mesa has just 2.2 individuals over the age of 18.
Because of their transient populations, above -normal numbers of
individuals/adults residing in a single dwelling and the lack of regulations, drug and
alcohol treatment facilities and sober living homes present problems not typically
associated with more traditional residential uses. These issues may include the
housing of large numbers of unrelated adults who may or may not be supervised;
disproportionate numbers of cars associated with a single housing unit, which
causes disproportionate traffic and utilization of on -street parking; excessive noise
and outdoor smoking, which interferes with the use and enjoyment of neighbors'
Resolution No. 19-41 Page 9 of 12
properties; neighbors who have little to no idea who does and does not reside in
the home; little to no participation by residents in community activities that form
and strengthen neighborhood cohesion; disproportional impacts from the average
dwelling unit to nearly all public services including sewer, water, parks, libraries,
transportation infrastructure, fire and police; a history of residents congregating in
the same general area; and the potential influx of individuals with a criminal record.
Nevertheless, the City recognizes that while not in character with residential
neighborhoods, when operated responsibly, group homes, including drug and
alcohol treatment facilities, provide a societal benefit by providing disabled persons
the opportunity to live in residential neighborhoods. These facilities also provide
recovery programs for individuals attempting to overcome their drug and alcohol
addictions. The City's regulations provide group homes, including sober living
homes and licensed drug and alcohol treatment facilities, greater access to
residential zones than to boardinghouses or other types of group living
arrangements. This favorable access for group homes provides a benefit to the
City and its residents.
In response to the needs and concerns described above, the City established a
minimum separation of 650 feet between group homes, residential care facilities
and/or state -licensed drug and alcohol facilities. The City found that a separation
requirement will still allow for a reasonable market for the purchase and operation
of sober living homes and drug and alcohol treatment facilities within the City. The
requirement will still result in preferential treatment for sober living homes and drug
and alcohol treatment facilities in that non -disabled individuals in a similar living
situation (i.e., in boardinghouse -style residences) have fewer housing
opportunities than the disabled. The City determined that housing inordinately
large numbers of unrelated adults in a single dwelling or congregating sober living
homes and drug and alcohol treatment facilities 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 the types of institutional/campus/dormitory living that the state and
federal laws were designed to provide them relief from.
The Federal Housing Act Amendments (FHAA), 42 U.S.C. § 3601 et seq., provide
that a city "commits discrimination under the FHAA if it refuses to make reasonable
accommodations in rules, policies, practices, or services, when such accommodation
may be necessary to afford [the disabled] equal opportunity to use and enjoy a
dwelling." Budnick v. Town of Carefree, 518 F.3d 1109, 1119 (9th Cir. 2008).
The FHAA requires a city to provide a requested accommodation if such
accommodation "(1) is reasonable, and (2) necessary, (3) to afford a handicapped
person the equal opportunity to use and enjoy a dwelling." Oconomowoc Residential
Programs, Inc. v. City of Milwaukee, 300 F.3d 775, 783 (7th Cir. 2002); 42 U.S.C. §
3604(f)(3)(B).
Resolution No. 19-41 Page 10 of 12
The applicant requested relief from the Zoning Code requirement that a sober living
home or drug and alcohol treatment facility be located at least 650 feet from another
property that contains a group home, sober living home or state -licensed drug and
alcohol treatment facility. The request for a Reasonable Accommodation was denied
by the Director of Development Services on November 27, 2017 because another
sober living or drug and alcohol treatment facility exists within 650 feet of the subject
property. The applicant appealed the decision on November 29, 2017 but gave no
reason for the appeal.
The facility is located within approximately 550 feet of a City -approved sober living
facility serving 11 occupants at 165 East Wilson Street, approved under PA -16-03.
The facility contributes to overconcentration and does not comply with the City's
adopted standards for separation between group homes, residential care facilities
and state -licensed drug and alcohol facilities. Further, pursuant to CMMC Section
13-323(b), the Planning Commission and the City Council did not find that approval
of this CUP application would not result in an overconcentration of sober living
homes and licensed treatment facilities in this neighborhood.
• Granting the conditional use permit will not be materially detrimental to the health
safety and general welfare of the public or otherwise iniurious to property or
improvements within the immediate neighborhood.
The City has found that overconcentration of sober living homes, drug and alcohol
treatment facilities, and other group homes changes the character of a residential
neighborhood to one that is more institutional in nature. This change in
neighborhood character can compound secondary effects related to noise, traffic,
and parking. In these neighborhoods, street life is often characterized by large
capacity vans picking up and dropping off residents and staff; staff in scrubs
carrying medical kits going from unit to unit, and vans dropping off prepared meals
in large numbers. The City has experienced frequent Fire Department
deployments in response to medical aid calls. In some neighborhoods, Police
Department deployments are a regular occurrence as a result of domestic abuse
calls, burglary reports, disturbing the peace calls and parole checks at drug and
alcohol treatment facilities. Large and often frequent Alcoholics Anonymous or
Narcotics Anonymous meetings are held at some drug and alcohol treatment
facilities. Attendees of these meetings contribute to the lack of available on -street
parking and neighbors report finding an unusual amount of litter and debris,
including beverage containers, condoms and drug paraphernalia in the wake of
these meetings. These types of impacts have been identified in other communities
as well. The facility will contribute to the overconcentration of sober living and drug
and alcohol treatment facilities in this neighborhood, which could lead to negative
impacts in the neighborhood. Code Enforcement has already received a complaint
alleging trash and cigarettes in the alley abutting this site.
Resolution No. 19-41 Page 11 of 12
There are only 20 parking spaces on the site available to serve 35 adults as well
as the 10 on-site managers. Approval of this CUP could result in conflicts with
residents of nearby properties for the use of on -street parking spaces.
• Granting the conditional use permit will not allow a use density or intensity which
is not in accordance with the general plan designation for the joM2eLly
The proposed use is consistent with the City's General Plan. However, an
overconcentration of group homes, sober living homes and licensed treatment
facilities for alcohol and drug addiction is not consistent with the General Plan. The
City's regulations are intended to preserve the residential character of the City's
neighborhoods. The City Council has determined that an overconcentration of drug
and alcohol treatment facilities would be detrimental to the residential character of
the City's neighborhoods. The proposed facility is located within 650 feet of another
sober living or drug and alcohol treatment facility, contributes to overconcentration,
and is therefore, not consistent with the intent of the General Plan.
D. The Costa Mesa City Council has denied the requested Reasonable Accommodation
and Conditional Use Permit PA -17-10. Pursuant to Public Resources Code Section
21080(b) and CEQA Guidelines Section 15270(a), CEQA does not apply to this
project because it has been rejected and will not be carried out.
E. The project is exempt from Chapter IX, Article 11, Transportation System
Management, of Title 13 of the Costa Mesa Municipal Code.
Resolution No. 19-41 Page 12 of 12