HomeMy WebLinkAboutCD Ordinance Regulating Camping on Public Property____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: July 10, 2023
Disposition: Waived further reading of the Ordinance and referred to it by title only, and
introduced the Ordinance, with recommended changes provided by staff
4856-0374-5897 v1
Agenda Item No: SM 4.a
Meeting Date: July 10, 2023
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Community Development
City Attorney
Prepared by: Chris Hess, Assistant CDD
Director
Genevieve Coyle,
Assistant City Attorney
City Manager Approval: ______________
TOPIC: ORDINANCE REGULATING CAMPING ON PUBLIC PROPERTY
SUBJECT: AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL ADDING
CHAPTER 19.50 TO THE SAN RAFAEL MUNICIPAL CODE, ENTITLED
“CAMPING ON PUBLIC PROPERTY” TO REGULATE CAMPING ON PUBLIC
PROPERTY WITHIN THE CITY OF SAN RAFAEL
EXECUTIVE SUMMARY:
Staff recommends that the City Council adopt the ordinance adding Chapter 19.50 to regulate camping
on public property in the City of San Rafael. The City currently regulates camping on public property in
several chapters and sections of the municipal code. Generally, camping is absolutely prohibited on
certain public property, including open space, city parking garages, and other properties that are
specifically prohibited due to public health, safety, or welfare concerns. For all other public property,
camping is prohibited, except where a person does not have alternative shelter available.
This proposed ordinance keeps the current framework regulating camping on public property in the City,
but would add reasonable time, place, and manner conditions on camping by persons who have no
alternative shelter available. Specifically, a camping area for one person would be limited to an area of
10 ft. by 10 ft. (100 sq. ft.). If two are more persons are occupying a camping area, the camping area
may be expanded to up to 10 ft. by 20 ft. (200 sq. ft. total). Camp facilities, camp paraphernalia and other
personal property would need to be stored and kept within these defined limits. In addition, under the
proposed ordinance, no camping area may be used, occupied, or located within 200 ft. of another
camping area. These restrictions are proposed to mitigate the significant public health and safety impacts
and hazards that are associated with encampments, where groups of persons camp at one location or in
close proximity to one another, and the adverse impact of waste, trash and other debris that is discarded
or left unattended on public property. For properties where camping is absolutely prohibited, the following
two restrictions would be added: i) no camping within 100 ft. of a playground, and ii) no camping within
10 ft. of public utility infrastructure. The new Chapter 19.50 would also consolidate all existing City
regulations governing camping activities in one chapter of the municipal code.
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RECOMMENDATION:
Introduce and waive further reading of an ordinance adding Chapter 19.50 to the San Rafael Municipal
Code regulating camping activity.
BACKGROUND:
Some individuals experiencing homelessness in the City, like that of many other cities throughout
California, have established campsites on public property. City staff and our nonprofit partners working
to end homelessness have successfully housed many chronically homeless individuals in publicly funded
shelter and permanent supportive housing. Unfortunately, the units and shelters available in the City are
typically full, except occasional turnover averaging two beds per week. Additionally, some individuals
experiencing homelessness have refused available housing or shelter when offered. The City recognizes
that the courts have held a right for individuals to camp on public property if they have no alternative
shelter available to them. However, the courts also have found that cities may adopt regulations on the
time, place, and manner of camping by persons with no alternative shelter and may abate public
nuisances related to camping activities.
The current City of San Rafael ordinance, at section 19.20.080(C) of the San Rafael Municipal Code
(SRMC) generally prohibits camping on public property as follows:
C. Camping.
1. No person shall camp, in any park, building or portion thereof, including the parking lot of any
such area.
2. No person shall use or store camp facilities or camp paraphernalia in any park, building, or
portion thereof, including the parking lot of any such area.
3. Nothing in this section shall be deemed to prohibit camping on all public property, including
parks, when there is no alternative shelter available to the person camping; provided that the city
manager may nevertheless absolutely prohibit camping at any time in one (1) or more specific
parks where such prohibition is determined to be a threat to the public, health, safety, or welfare.
In recent years, the City has absolutely prohibited camping in certain public parks, including Boyd Park,
open space, parking garages, and most recently Albert Park in March 2023. These prohibitions were
adopted to mitigate adverse public health, safety, or welfare impacts associated with camping activities,
especially those posed on shared public spaces for community and youth programs, and the concern
over public safety and wildfire risk. These prohibitions have been accompanied with significant outreach
and offers of assistance to try to connect individuals with resources and case management services.
Notwithstanding these efforts, and with a scarcity of housing options to offer all individuals in need of
shelter, camping continues to be prevalent in the City. A 2022 survey of the number of people
experiencing homelessness regionally, known as the Point-In-Time Count, estimated that 1,121
individuals experience homelessness in Marin County (830 of these were unsheltered, and 291 in
shelters), including 348 individuals in the City of San Rafael (241 of these were unsheltered and 107 in
shelters). The City Council’s objective is to end homelessness in the City, and to this end has made
significant investments in solutions to homelessness, particularly including permanent supportive
housing. The City additionally conducts outreach and housing navigation to individuals experiencing
homelessness, and funds organizations to provide shelter and case management.
Some of the City’s recent efforts to assist residents experiencing homelessness have included:
• Affordable Housing Trust Fund contributions to 190 Mill Street (~$1.1M), 3301 Kerner Boulevard
(~$2.1M), providing up to 40 shelter beds and 32 units of permanent supportive housing.
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• Funding housing navigation, outreach and employment readiness services in the City. Contracts
include case management services through County regional program ($260K) and through
Encampment Resolution Fund grant ($522K), Downtown Streets Team cleanup efforts in the
Downtown area, and at encampments in the City ($200K), and Dignity on Wheels mobile showers
($36K).
• Additional $250K Encampment Resolution Fund grant awarded to City in June 2023, to be
deployed in 2024.
• Specialized Assistance For Everyone (SAFE) Team. City fundend Alternative Response Team
three-year pilot ($775K annually): provides mobile crisis to the community, especially to
vulnerable populations, 12 hours/day and 7 days/week, dispatches crisis intervention workers
with an emergency medical technician to respond to certain emergencies such as suicide
prevention and psychiatric emergencies instead of law enforcement.
• Community Mental Health Liaison full-time staff position conducts outreach to population
experiencing homelessness to build relationships and ensure adequate resource referral and
works collaboratively with the organizations providing services within the City.
• Establishing Homelessness and Housing division and three staff positions within the Community
Development Department, to maximize the City’s capacity to gain funding, set policies, coordinate
with partners and conduct community engagement in these key areas.
• Participating in the Countywide Coordinated Entry System, which has housed 600+ people since
launch.
The City has engaged in robust efforts to document, analyze, and address the issues stemming from the
impacts of individuals experiencing homelessness and related issues. City staff provides the following as
an update on the current state of camping activities in the City:
• Beginning in April 2023, the City has been receiving consistent and growing complaints related to
growing encampments at the Mahon Creek Path between Lincoln and Andersen Drive, along
Andersen Drive between Irwin and Rice Streets, on City Hall grounds, and at a City-owned parking
lot next to Falkirk Park. By far the majority of complaints and San Rafael Police Department calls
for service come from the encampment of approximately 33 tents (as of June 28, 2023) at the
Mahon Path (also known in the community as “Mahon Creek Path”).
• The City has also received community complaints of increasing criminal activity over the past two
months, in particular at the Mahon Path. The Marin County Major Crimes Task Force (an
interjurisdictional task force) conducted an operation at Mahon Creek Path recently and arrested
an individual camping there for methamphetamine trafficking. San Rafael Police Department
conducts daily proactive extra patrols by officers with 23 police response events. Patrols have
resulted in multiple arrests over the last month, citations for drug paraphernalia, and one medical
hospitalization. Nuisance complaints include loud music, severe intoxication, bonfires and
fighting, which can last into early morning hours at times.
• City staff counted 33 tents (or similar structures) at the encampment on Mahon Creek Path on
June 28, 2023, representing an increase from 27 tents on June 6 and 19 tents on May 18. Current
trends indicate that this number will likely continue to grow. Upon interviewing new arrivals to the
encampment, staff learned that several arrivals were displaced from other campsites due to a
CalTrans camp closure. Approximately half of the occupants have case management, and of
these six could be described as working on a path toward housing. This group is receiving
services and waiting for housing vouchers. Staff learned of at least one individual with a
subsidized apartment who chooses to camp at the Mahon Creek Path, and at least two individuals
who have left a stable shelter situation to stay in the encampment. At least one individual moved
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to shelter recently. Shelter space and voucher availability are both expected to remain scarce for
the foreseeable future until such time that adequate interim and permanent supportive housing is
created.
• Refuse and waste continues to be a problem at the Mahon Creek Path encampment, which the
City has addressed collaboratively with encampment occupants. Many occupants have kept
orderly campsites and used bags provided by the City to collect trash. Some other individuals
bring refuse into the camp and leave it in a sprawling, disorganized state. The City has removed
and discarded unclaimed refuse, but has not cleared campsites or belongings. The City’s
Department of Public Works has collaborated with Mahon Creek Path occupants in conducting
voluntary weekly pickups of trash every Thursday, taking trash items that are bagged or voluntarily
surrendered by the occupants themselves. These pickups have removed 1-2 truckloads of
garbage per week. The Downtown Streets Team also sends its volunteer teams weekly to
address scattered waste and has removed dozens of 50-gallon bags with each visit to the
encampment.
• The Specialized Assistance For Everyone (SAFE) Team has proactively maintained a daily
presence at the Mahon Creek Path encampment over recent weeks, and has additionally
responded to calls for service, with most of these calls coming from Mahon Creek Path occupants.
The Specialized Assistance For Everyone (SAFE) Team has been dropping off food and health
supplies to campers weekly to help build a relationship with individuals that might require crisis
mental health services.
• The City’s Mental Health Liaison provides a daily presence offering resources, and major social
service agency partners, including Downtown Streets Team, St. Vincent de Paul Society, Ritter
Center and Marin County’s Health and Human Services who also provide regular outreach.
The City’s primary concern is one of public health and safety. When an encampment site is established,
where multiple persons camp in close proximity to one another in a concentrated area, it can generate
considerable garbage or waste, become a magnet for illegal activity, and create a substantial negative
impact on the neighboring community. City staff have been studying and analyzing alternative ways to
address the impacts that camping has on the community, as addressing homelessness continues to be
a challenge locally, regionally, statewide, and nationally. With these considerations in mind, and in
consultation with the City Attorney’s Office, staff are recommending an ordinance that would adopt
reasonable time, place, and manner conditions to mitigate ongoing public health and safety concerns.
ANALYSIS:
The proposed ordinance would add SRMC Chapter 19.50 regulating camping on public property. The
following summarizes the specific changes being proposed.
Existing Regulations (combined in Chapter 19.50)
Regulations prohibiting camping at certain public properties in the City would not change, except for
minor editorial updates. These regulations are currently located in several chapters and sections of the
municipal code, including those governing open spaces, parks, and parking garages. Under the proposed
ordinance, these regulations would be consolidated in the new Chapter 19.50 so that all of the City’s
regulations specific to camping activities are found in the new chapter.
Camping is absolutely prohibited on the following properties:
• Open spaces (moved from Section 19.10.060)
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• City parking garages (moved from Section 5.60.054)
• Public buildings and fenced areas, defined as “public facilities” (moved from Section 19.20.080)
Staff also proposes to keep the existing provision which allows the City Manager to absolutely prohibit
camping at any time on one (1) or more public properties, or portion thereof, where such camping is
determined to be a threat to public health, safety, or welfare. The City Council has previously relied on
this provision to prohibit camping at Albert Park and Boyd Park. However, Staff also recommends that
authority to adopt reasonable time, place, or manner conditions on camping on any one (1) or more public
properties be added to this existing provision. This would allow the City Manager to condition camping
activities, instead of absolutely prohibiting camping, on a certain public property in order to mitigate public
health, safety, or welfare impacts. This provision is moved from Section 19.20.080 to the new Chapter
19.50 in the proposed ordinance.
New Regulations
There are two areas of change to the City’s existing camping regulations included in staff’s
recommendation.
1. Additions to the list of public property where camping is absolutely prohibited.
Staff recommends some additions to the list of public properties where camping is absolutely prohibited.
Staff proposes to add the following two restrictions:
• No camping within 100 feet of a playground. This restriction is intended to mitigate the negative
health and safety impacts that nearby camping areas have on children’s playgrounds. This
restriction would apply to all children’s playgrounds located in parks identified in the Parks and
Recreation Master Plan and public and private schools.
• No camping within 10 feet of public utility infrastructure. “Public utility infrastructure” is defined as
public bathrooms, and electrical boxes, fire hydrants, and similar equipment used for providing
public utility services, but does not include light or electrical poles. This recommendation serves
to address incidents where persons have hacked into power supplies for illicit use, attached tents
and tarps to equipment, or otherwise impeded access to public utility equipment. The City can
enforce these activities through state law and other provisions of the municipal code; however
providing a 10-foot buffer would add clarity, and aid in maintaining and protecting public utility
infrastructure.
The following two restrictions are also added to the proposed ordinance, only for clarity purposes:
• No blocking or obstructing access to public facilities or private property
• No blocking or obstructing public rights-of-way and sidewalks
The City already enforces a “no camping” rule at these locations through enforcement of general
provisions in state and local law governing public access to the city’s rights-of-way, and public and private
facilities. Staff recommends adding these locations to the camping ordinance to facilitate enforcement.
2. New time, place, and manner conditions.
In an effort to address ongoing issues of public safety and access to public property, staff recommends
incorporating the following conditions on camping areas occupied by persons with no alternative shelter:
a) Maximum physical space dimensions for camping areas
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i. A camping area occupied by one person shall not exceed 10 ft. by 10 ft., (100 sq. ft.
total), inclusive of camp facilities, camp paraphernalia, and personal property.
ii. If two or more persons are occupying one camping area, the camping area may be
expanded to an area that shall not exceed 10 ft. by 20 ft., (200 sq. ft. total).
iii. Personal property, trash or debris, or any other items stored or discarded outside the
camping area will be considered unattended personal property and will be stored or
discarded according to City policy.
b) Minimum distance to another camping area
i. No camping area may be used, established, or occupied within 200 feet of another
camping area.
These regulations are intended to restrict the proliferation of encampments and their attendant negative
impacts. The regulations would protect public health, safety, and welfare; preserve public property for the
enjoyment, safety, comfort and convenience of the public; enhance and preserve the orderly
administration and management of public property; and preserve, protect, and prevent damages to public
resources.
Each camping area would be limited in size to 10 ft. by 10 ft. (100 sq. ft.) when it is occupied by one
person and may be expanded to 10 ft by 20 ft. (200 sq. ft.) for two or more persons camping together.
This limits the amount of public space that a person may take over in order to sleep. It also requires
persons to maintain their camp facilities, equipment, and other personal property within the maximum-
permitted camping area, and prohibits them from storing or discarding items or trash beyond the camping
area. This is intended to mitigate the negative impacts of waste and debris that is discarded or left behind
on public property.
The proposed regulation would also prohibit establishing any camping area within 200 ft. of another
camping area. This is intended to prevent the establishment and proliferation of high-concentration
encampments. When groups of unsheltered persons camp in close proximity to one another on public
property, forming a larger encampment, the public health and safety impacts and hazards are
concentrated in and around that property and have a significant negative impact on the neighboring
residents, businesses, and community. At locations where large-concentration encampments have been
established, such as the Mahon Creek Path, the City responds to a significant increase in volume of
public safety calls for service and complaints as compared with locations where campsites are more
isolated and distanced from one another. The increased calls for service at encampments include
sanitation, human waste, biohazards, and litter and refuse; abandonment of personal property;
vandalism; theft; physical fights amongst the campers; public alcohol consumption and intoxication; drug
possession and use, including reports of drug overdose, requiring medical transport to the hospital;
obstruction of sidewalks, pathways, and other public rights of way; campfires; and disruptive behavior of
encampment occupants. The encampments also take over large public spaces and areas of parks,
preventing the public from using and enjoying these spaces.
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The following table summarizes provisions of the proposed camping ordinance.
Proposed Ordinance Denotes Change from Existing
Ordinance
Camping prohibited on certain public property:
Open spaces n/a
City Parking garages n/a
Public Facilities (e.g., buildings) n/a
City Manager may prohibit camping, or adopt time, place, or
manner conditions on camping, on one or more public
properties at any time due to threat to public health, safety, or
welfare
Underlined authority added
The City Council prohibited camping at Boyd Park and Albert
Park
n/a
Within 100 ft. of playgrounds New rule
Within 10 ft. of public utility infrastructure New rule
Public rights-of-way and sidewalks Added for clarity only *
Blocking access to public facilities and private property Added for clarity only *
Other public property not listed above:
Camping is prohibited, except where a person has no
alternative shelter available.
n/a
Where excepted, time, place and manner conditions apply:
- Camping area cannot exceed 10 ft. x 10 ft. (one person)
or 10 ft. x 20 ft. (two or more persons).
- All items must be kept/stored within maximum permitted
camping area.
- No camping area may be established within 200 ft. of any
other camping area.
New rule
* Currently enforced with other general state and local law.
Legal Analysis
This ordinance complies with Martin v. Boise (920 F.3d 584) (“Martin”), and other caselaw interpreting
that ninth circuit decision. In Martin, the court held that the Eighth amendment’s cruel and unusual
punishment clause prohibits the imposition of criminal penalties for sitting, sleeping, or lying outside on
public properties for individuals who cannot obtain shelter. The formula established in Martin is that the
government cannot prosecute homeless people for sleeping in public if there “is a greater number of
homeless individuals in [a jurisdiction] than the number of available” shelter spaces. However, the case
also stated that despite that holding, a city is also not required to provide shelter, or allow anyone to sit,
lie, or sleep on public property at any time and any place of their choosing.
The proposed time, place, and manner conditions on use of public property do not form a citywide
camping ban as prohibited under Martin v. Boise. The City’s proposed ordinance does not prohibit
individuals from sleeping anywhere in the city, or otherwise engage in the “universal and unavoidable
consequences of being human.” The holding in Martin, while restricting local governments from
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criminalizing the act of sleeping, does not prohibit a city from controlling the use of public space to require
individuals to sleep anywhere in the city. As noted in a subsequent case, Gomes v. County of Kauai,
where an ordinance was found not to violate Martin, although that ordinance did restrict some camping
locations and activities, the court concluded that the ordinance did not prohibit individuals from sleeping
anywhere in the public as long as those individuals had other locations to sleep.
The City’s interest is in protecting public health, safety, and welfare; preserving public property for the
enjoyment, safety, comfort and convenience of the public; enhancing and preserving the orderly
administration and management of public property; and preserving, protecting, and preventing damages
to public resources. The proposed ordinance intends to abate public nuisance behavior and criminal
activity, such as drug trafficking, theft and violence, especially that occurs in high-concentration
encampments. The camping area location and size restrictions are aimed at keeping public spaces in a
clean and orderly condition, and in locations where harms to the community are reduced. These
regulations are intended to address some of the collateral impacts that camping in public spaces can
have, but otherwise does not prohibit the act of sleeping, or work to deprive individuals from using bedding
and other items necessary to protect them from the elements in order to sleep; it merely requires that
they be kept in a manner limiting the impact on the community.
Violation of the ordinance would result in the same consequences as the current ordinance. A person
could be cited. In addition, unabated conditions may result in removal of violating campsites, and/or the
temporary seizure and storage of personal property. Any removal of a campsite or seizure of property
would not be completed without proper notice. Further, under City policy, any actions to address
unremedied violations which may result in the removal of an encampment would include contacting
occupants of violating campsite with information about available housing support services. Note that this
ordinance does not place an affirmative obligation on the City to provide housing to violators of the
ordinance. The City, however, is working with the County of Marin and other community partners in order
to connect individuals with services.
This ordinance is a modest shift in the City’s efforts to address the use of public property and seeks to
balance the ability of the City to lawfully control public property with the fair treatment of individuals
experiencing homelessness. For the reasons presented above, staff recommends that the City Council
adopt the proposed ordinance.
COMMUNITY OUTREACH:
In designing and implementing the ordinance, City staff uses multiple communication channels and would
continue to do so should the ordinance be adopted by Council.
Staff have engaged, and would continue to engage nonprofit organizations, shelters, outreach teams,
and Marin County staff who work closely with the homeless population. This is done primarily through
weekly calls with the Marin Alliance to Solve Homelessness, and City staff presented regarding the legal
landscape and other community’s approaches on June 22. Upon adoption of the proposed regulations,
City staff would use this forum to continue to collaborate with the provider community to ensure a
coordinated and comprehensive approach. These agencies help to ensure clients’ understanding about
how to comply with the ordinance and refers individuals to appropriate resources and services.
City staff responded to a high volume of complaints and concerns about the Mahon Creek Path and other
encampments. Staff responds to every complaint and concern and takes this feedback into consideration
when developing recommendations to the City Council on how to address them.
The City’s Assistant Community Development Director and the City’s Mental Health Liaison met with
residents staying at the Mahon Creek Path, twice in an official capacity (with our visit communicated in
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advance). Their comments and our observations have been incorporated into staff’s recommendations
as well. The Mental Health Liaison keeps track, to the extent possible, of persons camping at the Mahon
Creek Path, their case management agency, and their status on the path to housing, and uses that
information to ensure referrals to available services.
Staff and City officials also met with representatives of the most impacted businesses, educated them
about jurisdictions’ efforts and limitations, and incorporated their concerns into the ordinance.
All of these parties, particularly to persons camping at the Mahon Creek Path, would continue to receive
education and engagement from City staff. If the proposed ordinance is adopted, staff would provide
targeted education may include informative brochures and flyers, in English and Spanish, that outline the
changes to the ordinance, explain its purpose, and provide clear instructions on accessing housing and
shelter resources. Materials would also be distributed through libraries, community centers, and other
relevant locations.
FISCAL IMPACT:
Adoption of the ordinance would result in City enforcement costs, some of which will be offset by reduction
in cleanup and enforcement costs the City bears managing the current situation. Encampment response
costs include the costs of retaining personal property held under the ordinance and cleanup of
encampments, which may involve the collection and disposal of trash and potential hazardous material
response. The San Rafael Police Department would be primarily responsible for enforcement and
handling of personal property, while the Department of Public Works would provide support for
coordinating the pickup and disposal of trash and hazmat response through its contractors.
First year cleanup costs would be accommodated and absorbed within the fiscal year 2023-24 budget.
The Department of Public Works proposed fiscal year 2023-24 operating budget includes $75,000 for
services related to homeless encampment cleanup, including the potential need for hazardous material
response.
Future costs are unknown and are dependent on changes in the homeless population and the amount of
enforcement associated with the proposed ordinance.
OPTIONS:
The City Council has the following options to consider on this matter:
1. Staff’s recommended action to introduce the ordinance adding SRMC Chapter 19.50 (Camping
on Public Property)
2. Introduce ordinance with modifications.
3. Direct staff to return with more information.
4. Take no action.
RECOMMENDED ACTION:
Introduce the ordinance adding Chapter 19.50 to the San Rafael Municipal Code Entitled “Camping on
Public Property” to regulate camping on public property within the City of San Rafael.
ATTACHMENTS:
1. Ordinance
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ORDINANCE NO. 2030
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL ADDING
CHAPTER 19.50 TO THE SAN RAFAEL MUNICIPAL CODE, ENTITLED “CAMPING ON
PUBLIC PROPERTY” TO REGULATE CAMPING ON PUBLIC PROPERTY WITHIN THE
CITY OF SAN RAFAEL
SECTION 1. FINDINGS
WHEREAS, the purpose of this ordinance is to enact regulations to address camping in or
on public property in the City of San Rafael. The City Council has authority to adopt this
ordinance pursuant to the California Constitution Article XI, section 7; and
WHEREAS, the City Council recognizes that the use, establishment, and occupation of
camping areas by persons with no alternative shelter, and the activities often attendant with
camping, have created adverse public health, safety, and welfare conditions within the City;
and
WHEREAS, the City, along with the County of Marin and community partners, have been and
are undertaking extensive actions to assist unsheltered persons in the City and region to find
shelter and needed services; and
WHEREAS, in the 2019 case of Martin v. City of Boise (920 F.3d 584), the federal Court of
Appeals for the Ninth Circuit held that the City of Boise’s criminal enforcement of its ordinance
banning camping on all public property was unconstitutional when applied to individuals who
had no alternative shelter available to them; and
WHEREAS, in consideration of the Martin v. City of Boise decision, and the present lack of
sufficient alternative shelter for all persons without shelter in San Rafael, the City has not
been strictly enforcing existing limits on camping in and on some public properties; and
WHEREAS, while the Martin v. City of Boise decision mandates that a city without sufficient
alternative shelter may not criminalize the act of sleeping on public property, it does not
require a city to allow camping on all public property, and does not prevent a city from
prohibiting camping on specified public properties, or enacting other time, place, and manner
conditions on camping; and
WHEREAS, the City Council recognizes and finds that there are public health and safety
hazards and public nuisance activities and conditions frequently associated with camping on
public property, and that there are certain public properties where the existence of campsites
is incompatible with the necessary use of the property by the public, or where camping
presents unacceptable hazards and/or costs to the City’s operations and to the public; and
WHEREAS, some unsheltered persons in the City live in makeshift shelters on public
property, such as tents, tarps, non-permanent boarded structures, and other non-substantial
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temporary structures, and accumulate, store, or leave behind garbage, debris, unsanitary
hazardous materials, sewage, or drug paraphernalia; and
WHEREAS, when groups of unsheltered persons camp in close proximity to one another on
public property, forming a larger encampment, the public health and safety impacts and
hazards can be concentrated in and around that property and can have a substantial negative
impact on the neighboring residents, businesses, and community; and
WHEREAS, camping on public property can lead to damage to public property, or hindrance
of the operation or protection of public infrastructure and utilities, creating a potential health
and safety hazard; and
WHEREAS, camping on public property can have a deleterious impact on the public use of
public property, businesses, private property, and economic development within the City; and
WHEREAS, by this ordinance, the City Council seeks to restrict camping on certain public
properties and to adopt reasonable time, place, and manner conditions on camping on public
property by persons without alternative shelter; and
WHEREAS, regulating camping on public property is necessary to protect public health,
safety, and welfare; preserve public property for the enjoyment, safety, comfort and
convenience of the public; enhance and preserve the orderly administration and management
of public property; and preserve, protect, and prevent damages to public resources.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL DOES ORDAIN
AS FOLLOWS:
SECTION 2. ADDITION TO SAN RAFAEL MUNICIPAL CODE. CHAPTER 19.50
Chapter 19.50 of the San Rafael Municipal Code, entitled “Camping on Public Property” is
hereby added to read in its entirety as follows:
Chapter 19.50 – CAMPING ON PUBLIC PROPERTY
19.50.010 - Purpose.
The purposes of this Chapter include but are not limited to: protecting public health, safety,
and welfare; preserving public property for the enjoyment, safety, comfort and convenience
of the public; enhancing and preserving the orderly administration and management of public
property; and preserving, protecting, and preventing damages to public resources. This
Chapter prohibits conduct that unreasonably interferes with the administration and lawful
uses of public property by establishing reasonable time, place and manner conditions related
to camping on public property.
19.50.020 - Definitions.
As used in this chapter, the following terms shall have the following meaning:
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A. "Camp" or "Camping" means using public property as a place of residence or for living
accommodation purposes, as evidenced by:
1. Remaining for prolonged or repetitious periods of time, not associated with ordinary
recreational use of public property, and
2. One or more of the following:
(a) Possessing camp paraphernalia; or
(b) Using or erecting camp facilities or other form of shelter; or
(c) Making a fire, cooking, or consuming meals; or
(d) Engaging in one or more of the following:
(i) sleeping or making preparations to sleep (including the laying down
of bedding for the purposes of sleeping); or
(ii) Unattended storage of personal belongings, including storing camp
paraphernalia or camp facilities.
The combined activities of (1) and (2) constitute camping when it reasonably appears,
in light of all the circumstances, that a person is using public property as a living
accommodation regardless of their intent or the nature of other activities in which the
person might also be engaged.
B. “Camp facility” means the use of a tent, hut, cot, bed, hammock, lean-to, shack,
vehicle, or other temporary physical shelter.
C. “Camp paraphernalia" means implements and equipment used for temporary
residence, including, camp facilities, tarpaulins, mattresses, sleeping bags, bedrolls,
blankets, sheets, pillows, luggage, backpacks, and cookware, cooking equipment,
kitchen utilities, and similar equipment.
D. “Camping area” means the primary physical area of occupation of a single camping
person. A camping area occupied by one person shall not exceed 10 ft. by 10 ft., (100
sq. ft. total), inclusive of camp facilities, camp paraphernalia, and personal property. If
two or more persons are occupying one camping area, the camping area may be
expanded to an area that shall not exceed 10 ft. by 20 ft., (200 sq. ft. total). In no event
shall any camping area, regardless of the number of occupants, exceed a space
greater than 200 sq. ft.
E. "Open space property" means any area described in San Rafael Municipal Code
Section 19.10.020.
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F. "Playground" means an improved outdoor area designed, equipped, and set aside
for children's play in a park or school that is not intended for use as an athletic
playing field or athletic court, and includes any playground equipment, fall zones,
surface materials, access ramps, and all areas within and including the designated
enclosure and barriers.
G. “Public facility” means any building, structure, or area enclosed by a fence located on
public property, whether secured, unsecured, locked, unlocked, open, or enclosed.
H. “Public property” means any real property within the jurisdiction of the City of San
Rafael, which is owned, managed, or controlled by the City of San Rafael.
I. "Public right-of-way" means any area described in San Rafael Municipal Code Section
11.04.020.
J. “Public utility infrastructure” means public bathrooms, and electrical boxes, fire
hydrants, and similar equipment used to provide public utility services, but does not
include light or electrical poles.
K. “Sidewalk” means any area in the City provided for the use of pedestrians, including
planting areas, driveway approaches, or parking strips, between the public vehicular
roadway and the edge of public right-of-way bordering, fronting, or adjacent to private
property.
L. "Store" means to put aside or accumulate for use when needed, to put for safekeeping,
or to place or leave in a location.
M. "Vehicle" means any wheeled conveyance, whether motor-powered, animal-drawn, or
self-propelled, and includes any trailer in tow of any size, kind, or description. For
purposes of this chapter, a vehicle does not include a pushcart, stand, display, pedal-
driven cart, wagon, showcase, rack, or other nonmotorized conveyance, used by a
sidewalk vendor engaging in sidewalk vending with a permit issued for such activity.
19.50.030 - Prohibited Camping on Certain Public Property.
A. Prohibited Camping
1. Open space property. No person or persons shall camp in or on any open
space property, or portion thereof.
2. Parking garages. No person or persons shall camp in or on the premises of
any parking garage, or portion thereof, owned or operated by the city.
3. Public facilities. No person or persons shall camp in or on any public facility,
or portion thereof, including the parking lot of any such area, or in a manner
that obstructs, blocks, or otherwise interferes with access to a public facility
or private property.
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4. Playgrounds. No person or persons shall camp within 100 ft. of any
playground.
5. Public utility infrastructure. No person or persons shall camp within 10 ft. of
any public utility infrastructure.
6. Public right-of-way and sidewalks. No person or persons shall camp in or on
any public right-of-way or sidewalk, or portion thereof, or in a manner that
obstructs, blocks, or otherwise interferes with use of or access to a public
right-of-way or sidewalk.
B. The city council or city manager may, by resolution or administrative order, absolutely
prohibit camping, or adopt time, place, or manner conditions on camping, at any time
in or on one (1) or more public properties, or portion thereof, where such camping is
determined to be a threat to the public health, safety, or welfare.
19.50.040 - Prohibited Camping on Other Public Property; Exception.
A. No person or persons shall camp in or on public property not listed under Section
19.50.030, or portion thereof, except as set forth below.
B. Exception. Nothing in this section shall be deemed to prohibit camping on public
property that is not listed under Section 19.50.030, or to prohibit the use of
minimal measures for staying warm or dry while sleeping on such property, when
there is no alternative shelter available to the person camping.
C. When the exception set forth in subsection 19.50.040(B) applies, the following time,
place, and manner conditions shall apply:
1. No camping area shall be used for any purpose other than for living
accommodation purposes. Living accommodation purposes includes sleeping
and making preparations to sleep, including the laying down of bedding for the
purpose of sleeping, by a person with no alternative shelter available to the
person camping.
2. In no event shall a camping area exceed the maximum physical space
dimensions permitted for a “camping area” as defined in Section 19.50.020.
a. All camp facilities, camp paraphernalia, and other personal belongings shall
be stored and kept within the maximum permitted camping area.
b. Items stored, kept, discarded, or otherwise existing outside of the camping
area shall be presumed to be unattended personal property or trash or debris
and may be stored or discarded according to city policy.
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3. No person shall use, establish, or occupy more than one camping area.
4. No camping area may be used, established, or occupied within 200 ft. of another
camping area.
19.50.050 – Conflict with Other Regulations.
To the extent that there is any conflict with any other provisions of this code, the standards
and regulations of this chapter shall prevail.
SECTION 3. AMENDMENT TO SAN RAFAEL MUNICIPAL CODE SECTIONS
19.20.080(C), 19.10.060(4), AND 5.60.054
San Rafael Municipal Code section 19.20.080(C), entitled “Prohibited activities: Camping”
shall be deleted and replaced with the following:
19.20.080(C) Camping. For laws and regulations regarding camping within the City of
San Rafael, see San Rafael Municipal Code chapter 19.50.
San Rafael Municipal Code section 19.10.060(4), entitled “Open space regulations: Camping”
shall be deleted and replaced with the following:
19.10.060(4) Camping. For laws and regulations regarding camping within the City of
San Rafael, see San Rafael Municipal Code chapter 19.50.
San Rafael Municipal Code section 5.60.054, entitled “Overnight parking in parking garages
prohibited” shall be deleted and replaced with the following:
5.60.054 Camping in City Parking Garages. For laws and regulations regarding
camping within the City of San Rafael, see San Rafael Municipal Code chapter 19.50.
SECTION 4. This ordinance was assessed in accordance with the authority and criteria
contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines,
and the environmental regulations of the city. The city council hereby finds that under section
15061(b)(3) of the State CEQA Guidelines, this ordinance is exempt from the requirements
of CEQA because it can be seen with certainty that the provisions contained herein would not
have the potential for causing a significant effect on the environment. It also finds the
ordinance is exempt from the requirements of CEQA pursuant to CEQA Guidelines sections
15307 and 15308 as an action by a regulatory agency taken to protect the environment and
natural resources.
SECTION 5. SEVERABILITY
Every section, paragraph, clause, and phrase of this ordinance is hereby declared to be
severable. If for any reason, any section, paragraph, clause, or phrase is held to be invalid or
unconstitutional, such invalidity or unconstitutionality shall not affect the validity or
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constitutionality of the remaining sections, paragraphs, clauses or phrases, and the remaining
portions or this ordinance shall continue in full force and effect unless amended or modified
by the city.
SECTION 6. EFFECTIVE DATE AND PUBLICATION
This ordinance shall be published once, in full or in summary form, before its final passage, in
a newspaper of general circulation, published and circulated in the City of San Rafael and shall
be in full force and effect 30 days after its adoption. If published in summary form, the summary
shall also be published within fifteen (15) days after the adoption, together with the names of
those Council members voting for or against same, in a newspaper of general circulation
published and circulated in the City of San Rafael, County of Marin, State of California.
Within fifteen (15) days after adoption, the City Clerk shall also post in the office of the City
Clerk, a certified copy of the full text of this ordinance along with the names of those
Councilmembers voting for and against the ordinance.
THE FOREGOING ORDINANCE was first read and introduced at a special meeting of the
San Rafael City Council on the 10th day of July 2023, and was passed and adopted at a
regular meeting of the San Rafael City Council on the 17th day of July 2023 by the following
vote, to wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
KATE COLIN, Mayor
ATTEST:
LINDSAY LARA, City Clerk