HomeMy WebLinkAboutCD-CA Ordinance Regulating Camping on Public Property____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: April 15, 2024
Disposition: Introduced Ordinance, waived further reading of Ordinance and referred to it by title
only
Agenda Item No: 6.b
Meeting Date: April 15, 2024
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
AMENDING CHAPTER 19.50 TO THE SAN RAFAEL MUNICIPAL CODE,
ENTITLED “CAMPING ON PUBLIC PROPERTY” REGULATING CAMPING ON
PUBLIC PROPERTY WITHIN THE CITY OF SAN RAFAEL
EXECUTIVE SUMMARY:
Staff recommends that the City Council adopt an ordinance amending the City’s regulation of camping
on public property. In July 2023, the City Council adopted Ordinance No. 2030 setting new spacing and
density rules for camping on public property by persons with no alternative shelter available. Among the
new rules, codified in Chapter 19.50 of the San Rafael Municipal Code (“SRMC”), a campsite, including
all camp facilities and personal property, have been limited to an area of 100 sq. ft. for one person and
200 sq. ft. for more than one person and cannot be located within 200 ft. of another campsite. Also, for
properties where camping is absolutely prohibited, two new restrictions were applied: i) no camping within
100 ft. of a playground, and ii) no camping within 10 ft. of public utility infrastructure. The new rules were
intended to mitigate the significant public health and safety impacts and hazards that are associated with
encampments in the City, 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.
Three days before Ordinance No. 2030 was to go into effect, several persons living on the Mahon
Creek Path filed a lawsuit in the U.S. District Court of the Northern District of California to challenge the
legality of the ordinance. The case is Boyd et al. v. City of San Rafael, N.D. Cal., Case No. 23-cv-
04085-EMC (“Boyd”). Following a brief Temporary Restraining Order (“TRO”), which paused the City’s
ability to enforce its ordinance, Judge Edward Chen issued a Preliminary Injunction Order (“PI Order”)
under which the City has been permitted to enforce its ordinance under Court-modified rules. These
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rules have been operationally impractical to implement, particularly as they involve the procedures to
administer the density and spacing requirements of the PI Order.
Staff recommend that the City Council adopt amendments to its camping regulations. Among other
changes, the amended ordinance would permit campsites of up to 200 sq. ft. for one person and 400 sq.
ft. for up to 4 persons camping together. The amended ordinance would eliminate the 200 ft. spacing
requirement, requiring only a 10-foot safety buffer zone around each campsite for ingress/egress and to
mitigate fire danger. An enforcement section is also included in the amended ordinance, specifying notice
and due process requirements. With these changes to the ordinance, the City’s goal is to effectively
regulate and enforce camping laws for the health and safety of all of the public, including residents who
are experiencing homelessness, and to refocus the City’s limited staff time and resources towards
developing more interim shelter options and long-term housing solutions.
RECOMMENDATION:
Introduce and waive further reading of an ordinance amending Chapter 19.50 to the San Rafael Municipal
Code regulating camping on public property.
BACKGROUND:
The City’s Response to Homelessness in the Community
The City of San Rafael seeks to end homelessness through partnerships and policies that create housing
and shelter for our residents with the fewest options and has made ending homelessness one of its key
Goals and Objectives for FY 23-25.
City and County staff and nonprofit partners working to end homelessness have successfully housed
hundreds of individuals experiencing homelessness in the City in permanent supportive housing.
Unfortunately, the overall number of individuals experiencing homelessness in the City, County, and
region remains high as additional community members lose their housing and fall into homelessness.
There are 107 shelter beds in the City for 348 total homeless individuals, according to the January 2022
Point In Time Count, leaving hundreds of unsheltered homeless individuals sleeping in tents, vehicles,
and other locations. Some individuals experiencing homelessness in the City, like in many other cities
throughout California, have established campsites on public property. This is most acutely concentrated
along the Mahon Creek Path and surrounding areas on Francisco Blvd. West and Andersen Drive, where
approximately 70 individuals live in large encampments.
Some of the City’s recent efforts to assist residents experiencing homelessness have included:
•Specialized Assistance For Everyone (SAFE) Team. City-funded Alternative Response Team
three-year pilot ($775K annually): Petaluma People Services Center provides mobile crisis
response to the community, especially to vulnerable populations, 12 hours/day and 7
days/week. The program dispatches a crisis intervention worker with an emergency medical
technician to respond to certain emergencies, such as suicide prevention and psychiatric
emergencies, instead of law enforcement. In its first year of operations, SAFE diverted more
than 250 calls from ambulances, emergency departments, and jails. Of SAFE’s 1,690 calls
where homelessness status data was collected, 1,070 of these calls (63.3%) were responses
to individuals experiencing homelessness.
•Affordable Housing Trust Fund contributions to 190 Mill Street (~$1.1M) and 3301 Kerner
Boulevard (~$2.1M), projects that together provide 40 shelter beds and 75 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 the County regional program for
frequent utilizers of emergency services who are unhoused ($260K), an Encampment
Resolution Funding Round 1 grant (ERF-1, $522K awarded), Downtown Streets Team
cleanup efforts in the Downtown area and at encampments in the City ($200K), and Dignity
on Wheels mobile showers ($36K).
•City and County are jointly funding a Housing-Based Case Manager to work with individuals
at the Mahon Creek Path.
•City staff and nonprofit organization partners conducted a survey of individuals staying at the
City’s encampments, using survey results to plan funding and program strategies.
•Encampment Resolution Funding Round 2 (ERF-2, $250K awarded) grant awarded to the
City in June 2023, currently being deployed. Marin County and the City recently jointly applied
for Encampment Resolution Funding Round 3 (ERF-3, $5.9M application pending).
•Community Mental Health Liaison, Homelessness and Housing Analyst Position, and
Assistant Director of Community Development: full-time City staff positions that conduct
outreach to populations experiencing homelessness, ensure adequate resource referral, and
work collaboratively with the organizations providing services within the City, administer
funding, and implement policy.
•Participating in the Countywide Coordinated Entry System, which has housed 700+ people
since its launch in 2017.
•As the Mahon Creek Path Area encampment area has grown, the City has added six portable
restrooms and handwashing stations (two of these are ADA restrooms) and provides garbage
collection and hauling services to the encampment.
Marin County and the City jointly applied for $5.9M in State Encampment Resolution Funding Round 3
(ERF-3) in January 2024. If awarded, the grant would add contracts for one full-time outreach staff and
3 full-time case managers for the Mahon Creek Path Area encampment, provide funding for housing
transitions, and fund at least two years of interim housing operations. The ERF-3 grant would fund
security, sanitation, and cleanup efforts, including mobile showers and portable bathrooms. These funds
would facilitate the City’s ability to establish a safe camping area with services designed to place
individuals more quickly on a path to housing.
Ordinance No. 2030 Regulating Camping on Public Property
In July 2023, the City Council adopted Ordinance No. 2030, codified in Chapter 19.50 of the San Rafael
Municipal Code (“SRMC”), setting new rules for camping on public property. Ordinance No. 2030 kept
pre-existing prohibitions on camping on specific public property, including open space, city parking
garages, and other properties, and added new restrictions for playgrounds and public utility infrastructure.
Otherwise, camping is allowed by persons with no alternative shelter available.
Among the changes, Ordinance No. 2030 added spacing and density restrictions to mitigate the
significant public health and safety impacts and hazards that are associated with encampments in the
City, 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. Under
Ordinance No. 2030, a campsite, including all camp facilities and personal property, has been limited to
an area of 100 sq. ft. for one person and 200 sq. ft. for more than one person and cannot be located
within 200 ft. of another campsite. Also, two additional restrictions applied: i) no camping within 100 ft. of
a playground, and ii) no camping within 10 ft. of public utility infrastructure.
Lawsuit and Preliminary Injunction Order
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Three days before Ordinance No. 2030 was to take effect, several persons living on the Mahon Creek
Path filed a lawsuit in the U.S. District Court of the Northern District of California to challenge the legality
of the ordinance. The case is Boyd et al. v. City of San Rafael, N.D. Cal., Case No. 23-cv-04085-EMC
(“Boyd”). Following a brief Temporary Restraining Order (“TRO”), which paused the City’s enforcement
of its ordinance, in October 2023, Judge Edward Chen issued a Preliminary Injunction Order (“PI Order”).
The PI Order remains in effect during the pendency of the litigation or until further order of the court.
The PI Order allows the City to enforce its ordinance on the plaintiffs and at the Mahon Creek Path, but
subject to court-modified rules to “maintain some semblance of community, affording them an opportunity
for mutual protection and assistance while preserving the City’s goal of breaking up large encampments.”
In order to prevent “irreparable harm” to those camping in the City’s encampments, Judge Chen set
modified density and spacing restrictions, allowing up to 4 persons in 400 sq. ft. campsites, spaced at
least 100 ft. apart. In assessing the plaintiffs’ related Americans with Disabilities (“ADA”) legal challenges,
he further concluded that allowing a one-person increase in the number of campers (4 vs. 3) and a
corresponding increase in square footage to accommodate such clusters (400 sq. ft. vs. 200 sq. ft.) would
not be a fundamental alteration to the City’s existing regulation. Judge Chen further required the City to
ensure there was a process for clearly identifying permissible camping sites and an orderly process by
which those sites may be allocated or claimed.
Since the October 2023 PI Order, the City has attempted to implement the court’s rules by administering
campsite registration, resolving individual ADA claims over the amount of space allotted, and gaining
voluntary compliance among individuals camping at the Mahon Creek Path encampment. The
implementation of Judge Chen’s requirements, particularly the registration process for campers, has
been a challenging undertaking and has not effectively ameliorated problematic conditions at the
encampment.
The City’s primary concern for regulating camping on public property is one of public health and safety.
The existing regulation was intended to address 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, unregulated encampment, the public health and safety impacts and hazards
are concentrated in and around that property and have a significant negative impact on those living in
the encampment and the neighboring residents, businesses, and community. At locations where large-
concentration encampments have been established, like the Mahon Creek Path, the City responds to a
significant increase in the volume of public safety calls for service and complaints. The increased calls
for service at encampments include fires, sanitation, human waste, biohazards, litter and refuse,
abandonment of personal property, vandalism, theft, physical fights, public alcohol consumption and
intoxication, drug possession and use, obstruction of sidewalks and pathways, and disruptive behavior
of encampment occupants. The encampments also consume public spaces, preventing other members
of the public from using and enjoying these spaces.
Proposed Ordinance – Amending Ordinance No. 2030 Regulating Camping on Public Property
Staff recommend that the City Council adopt amendments to its camping regulations. Among other
changes, the amended ordinance would permit campsites of up to 200 sq. ft. for one person and 400 sq.
ft. for up to 4 persons camping together. For safe ingress/egress and to mitigate fire danger, it would
require a 10-foot clearance area around each campsite be maintained free and clear of items and
property and establish a 10-foot setback to any other campsite, public utility infrastructure, and
neighboring private properties. An enforcement section is also included in the amended ordinance,
specifying notice and due process requirements. With these changes to the ordinance, the City’s goal is
to effectively regulate and enforce camping laws for the health and safety of all of the public, including
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residents who are experiencing homelessness, and to refocus the City’s limited staff time and resources
towards developing more interim shelter options and long-term housing solutions.
The City is focused on providing a compassionate response to homelessness by addressing its root
causes through housing and services and consistently expands its efforts toward both interim and long-
term solutions. The management of camping on City property is a necessary but small part of the City’s
response to homelessness. This management has consumed a significant amount of attention and
resources in the last year due to litigation around the City’s camping ordinance, including costs of outside
counsel, responding to the Court’s fact-finding process, attempting to implement court-ordered
processes, resolving individual ADA claims over amount of space allotted, and seeking voluntary
compliance while the City’s enforcement authority has been restrained by the Court. The proposed
amendments intend to provide the City with a regulatory framework that it can implement and enforce
with minimal resources. It aims to allow staff to redirect attention and resources toward furthering the
aforementioned solutions to end homelessness. By adopting this proposed amended ordinance that
reflects Court guidance on a citywide basis, the City hopes to retain its ability to enforce when necessary
and to manage public property for the safety of the entire community, including individuals experiencing
homelessness.
ANALYSIS:
The proposed ordinance would amend SRMC Chapter 19.50 regulating camping on public property.
Attachment 2 includes a redline of all proposed changes to Chapter 19.50 (as compared with Ordinance
No. 2030). The following summarizes the specific changes being proposed.
1. Certain properties prohibited to all camping (Section 19.50.030).
The City’s regulation lists several properties where camping is strictly prohibited due to threats to public
health, safety, and welfare. The amended ordinance would add one (1) new restriction:
No camping within 250 feet of a school property. This restriction is intended to mitigate the
potential health and safety impacts, including garbage, waste, and biohazards, that nearby
camping areas can have on children’s schools and their walking routes to schools. This restriction
would apply to all public and private schools up to Grade 12.
Following is a summary table of areas where camping would be prohibited under the proposed ordinance.
Table 1: Areas Where Camping is Prohibited
Areas where camping is prohibited Explanation of change to existing rule
Open spaces Same
City parking garages Same
Public Facilities (e.g., buildings) Same
Within 100 ft. of playgrounds Same
Within 250 ft. of schools New rule added.
Within 10 ft. of public utility infrastructure Moved to section 19.50.040 (time, place,
and manner restrictions) as a 10-foot
setback requirement.
Sidewalks and public rights-of-way Same
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In addition, the amended regulation would continue to allow the City Council or City Manager to prohibit
camping or adopt time, place, or manner conditions on camping on one or more public properties at any
time due to a threat to public health, safety, or welfare.
The City would maintain on its public website and in hard copy at the City Clerk’s office a City-wide map
of the following public properties prohibited to camping by the ordinance: open space property, parking
garages, those within 100 feet of playgrounds or 250 feet of schools, and those specifically prohibited to
camping by the City Manager or City Council (e.g., Boyd Park and Albert Park.)
2. Time, place and manner restrictions on public camping where no alternative shelter is
available (Section 19.50.040).
Camping on other properties (i.e., those not listed as “areas where camping is prohibited” above under
Section 19.50.030) is permitted only by persons who have no alternative shelter option available, subject
to time, place, and manner restrictions.
Under the proposed ordinance, the spacing and density rules would change as follows:
1)Maximum allowable campsite size. Staff recommend that the City Council allow camping in
spaces of up to 200 sq. ft. in size for one person or 400 sq. ft. for up to 4 people. This would align
with Judge Chen’s PI Order, setting a maximum size of 400 sq. ft. for 4 people. Over the last nine
months, the City received many ADA requests for accommodation, where individuals were
seeking more than the 100 sq. ft. of space. Therefore, staff recommend allowing a campsite of
double the size (from 100 to 200 sq. ft.) for one person when camping alone and 400 sq. ft. for
up to 4 people, as a way or preemptively accommodating needs for more space.
2)Removal of minimum spacing requirements. Staff recommends removing the campsite spacing
regulation. Judge Chen’s PI Order required the City to develop and administer an “allocation and
registration process” for campers to find permitted campsites that met the City’s spacing
requirements (set at 100 ft. in the PI Order). As discussed earlier in this staff report, those
procedures required to implement the spacing rule proved to be an ineffective and impractical
way to manage impacts of the encampments.
3)Addition of 10-foot clearance and setbacks. One of the primary objectives of the City is to make
the conditions safer for those camping in the City and neighboring communities. Many of the calls
for service at the City’s encampments concern fires, sanitation, human waste, biohazards, litter
and refuse, abandonment of personal property, and obstruction of sidewalks and pathways. With
elimination of the spacing requirements, it is important that areas around campsites are kept clear
for ingress/egress and to mitigate fire risk. This rule would require a 10-foot clearance area around
each campsite be maintained free and clear of all items, including trash, debris, and personal
property. This rule would also establish a 10-foot setback (safety buffer) to other campsites, public
utility infrastructure, and neighboring private properties (including buildings and fences). The City
has experienced an increase in complaints and calls for service from properties directly abutting
the encampments related to fires and individuals affixing camping equipment to fencing and
buildings. For clarity, the same 10-foot area can satisfy the setback and clearance requirements
(the ordinance does not require a 10-foot setback plus an additional 10-foot clearance area).
Following is a summary table of the time, place, and manner restrictions of the proposed new ordinance.
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Table 2: Proposed Ordinance Time, Place, and Manner Restrictions
New proposed time, place, and manner
restrictions Explanation of change to existing rule
Maximum allowable campsite size:
- 200 sq. ft. for 1 person
- 400 sq. ft. for up to 4 persons
Increased from:
- 100 sq. ft. for 1 person
- 200 sq. ft. for more than 1 person.
Minimum allowable distance to another
campsite:
- 10 ft.
Removed rule that campsites be spaced at
least 200 ft. apart and aligned spacing
requirement with the new setback and
clearance rules.
Minimum clearance and setbacks:
- 10 ft. clearance around each campsite
- 10 ft. setback from other campsites,
public utility infrastructure, and private
real property
New rule added.
In addition to the above changes, the amended ordinance clarifies that individuals with no alternative
shelter options in the City may use fabric tents for shelter and plastic pallets or sandbags to raise a tent
off of the ground, provided they are not affixed to public or private property, vegetation, or infrastructure.
These types of camping facilities and conditions are already permitted so these provisions are added for
clarification only.
3. Violations; Enforcement (Section 19.50.050).
In his PI Order, Judge Chen expressed concern that an individual or group camping legally could be
placed in jeopardy of violating the City’s distancing rules through no fault of their own, by another
individual or group camping too close to their established site. He also raised a “due process problem
regarding fair notice,” highlighting that unhoused individuals or groups may not know where they may
camp lawfully under the ordinance given the existing ordinance’s large separation requirements. These
concerns are largely addressed by eliminating the campsite spacing rules other than 10-foot
clearance/setback.
In addition, new enforcement and notice provisions are included. First, a rule has been added that no
person may be charged with a crime for violation of the camping regulations “unless their unlawful
conduct is knowing or willful.” Also, each person found in violation of the camping restrictions will receive
a written warning notice prior to criminal or other enforcement. The warning will include notice of the
violation, the actions that are required to be taken to comply, the specific timeframe to come into
compliance, and potential penalties for failure to comply. The City’s guidelines for removal and storage
of unattended personal property will also be provided with the notice. This is already standard practice
for the City’s enforcement of its camping regulations. Lastly, if a person is noticed for violation of the size,
occupancy, or clearance or setback requirements of the ordinance, they may request that the City provide
a physical demarcation of the allowed boundary to assist them in complying with the ordinance.
The enforcement rules set forth in the ordinance would be minimum obligations for the City to enforce its
camping regulations. As a standard practice, prior to enforcement of camping laws, the City works with
its non-profit community partners to provide additional notice and outreach, and where available, offers
assistance to affected persons.
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4. Definitions and other language updates.
In addition to the sections discussed above, other less substantive edits and minor revisions to the
ordinance have been made. For example, the definitions of “camping” and “open space” have been
revised to address vagueness challenges raised in the Boyd lawsuit and a definition of “school” has been
added. The definition of “public utility infrastructure”, where 10-foot setbacks would apply, has been
amended to include stormwater and electrical facilities. See Attachment 2 for a redline of all proposed
changes to Chapter 19.50.
Legal Analysis
This proposed ordinance complies with Martin v. Boise 920 F.3d 584 (9th Cir. 2019) (“Martin”) and other
caselaw interpreting that Ninth Circuit Court of Appeals 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 Ninth Circuit also stated that a city is 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. The City’s proposed ordinance does not prohibit individuals
from sleeping anywhere in the City, or otherwise engaging in the “universal and unavoidable
consequences of being human.” The holding in Martin, while restricting local governments from
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. In a subsequent case, Gomes v. County of Kauai, an ordinance
was found not to violate Martin, although that ordinance did restrict some camping locations and activities.
The court in Gomes concluded that the ordinance did not prohibit individuals from sleeping anywhere in
public as long as those individuals had other locations to sleep.
The PI Order issued by Judge Chen in the Boyd litigation is time limited and remains in effect during the
pendency of the litigation or until further order of the court. It is not a final ruling on the merits of the case
challenging Ordinance No. 2030; however, it provides some insight into how the court may rule on final
judgment. Judge Chen set restrictions of 100 sq. ft. per camper and up to 400 sq. ft. for campsites of up
to 4 persons, spaced 100 ft. apart. These rules were developed based on the court’s preliminary
injunction analysis of the plaintiffs’ various legal challenges, including those brought under the Fourteenth
Amendment (state-created danger theory and due process), the ADA, and the Eighth Amendment. The
proposed ordinance allows for double that size - 200 sq. ft. per individual camper - and up to 400 sq. ft.
for 4 persons. The proposed ordinance lifts the campsite spacing rules, affording the sense of community
that Judge Chen found important, but adds 10-foot clearance and setback requirements which are
necessary to protect the health and safety of all members of the public, including those currently
experiencing homelessness.
Furthermore, the proposed ordinance adds an enforcement section to address the court’s questions
concerning notice and due process. No person would be charged with a crime unless their unlawful
conduct is knowing or willful. Consistent with the City’s current practice, any person in violation of the
camping rules would be issued a notice that they are violating the rules and providing details on how to
come into compliance before any enforcement is taken. For noticed violations of the size, occupancy, or
clearance or setback requirements of the ordinance, the City would provide a physical demarcation of
the allowed boundary. Any removal of a campsite or seizure of property would not be completed without
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notice. In sum, the proposed ordinance addresses the potential legal issues identified by the court in the
Boyd litigation.
The City’s interest is in protecting public health, safety, and welfare; preserving public property for the
enjoyment, safety, comfort, and convenience of all members of the public; enhancing and preserving the
orderly administration and management of public property; and preserving, protecting, and preventing
damages to public resources. The camping area location and size restrictions are aimed at keeping public
spaces in a clean and orderly condition, and in locations where potential 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 tents, bedding and tarps necessary to protect themselves from the elements in order to sleep.
It is important to note that this legal analysis of the proposed ordinance is based on existing judge-made
law. The PI Order relies heavily on precedent set by the Ninth Circuit in Martin. The U.S. Supreme Court
will hear oral argument in the case of City of Grants Pass, Oregon v. Johnson, U.S. Supreme Court, Case
No. 23-175 (“Grants Pass”) on April 22, 2024 and is expected to issue a decision in the case during this
term, which ends in June 2024. Relying on the Ninth Circuit’s decision in Martin, homeless advocates
filed a class action lawsuit against the City of Grants Pass, Oregon, challenging the City’s homelessness
policies. A District Court ruled against Grants Pass, which appealed the case to the Ninth Circuit. The
Ninth Circuit upheld the lower court’s decision and issued a decision that expanded upon its precedent
in Martin. In August 2023, the City of Grants Pass filed a Writ of Certiorari, asking the U.S. Supreme
Court to review the decision. The U.S. Supreme Court agreed to take the case on January 12, 2024. The
question at issue in Grants Pass is whether generally applicable laws regulating public lodging or camping
are considered “cruel and unusual” punishment, which is prohibited by the Eighth Amendment. The
anticipated ruling by the U.S. Supreme Court may change existing law, in which case staff would re-
evaluate these camping regulations.
This proposed ordinance represents the City’s efforts to address the use of public property by all and
seeks to balance the ability of the City to lawfully manage public property under existing law 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:
Since the adoption of the original ordinance in July 2023, City staff have worked closely with nonprofit
organizations, shelters, outreach teams, and Marin County Health & Human Services staff who work
closely with the population experiencing homelessness. The City has worked with these partners to
conduct an assessment of the individuals in the Mahon Creek Path Area encampment and to identify
health and safety measures as requested by these individuals. Since the survey, the City has provided
six portable restrooms and hand-washing stations in the vicinity of the encampment, including two
wheelchair-accessible toilets, and expanded its trash-hauling services. The County and the City jointly
applied for approximately $6M in ERF3 funding for programs to support people living in the surveyed
encampments in January 2024. The application includes funding for case managers, interim housing
projects/programs, and ongoing encampment support (i.e., waste management, public restrooms, etc.).
On April 10, City and County Staff, with four nonprofit community partners, conducted an “Assessment
Extravaganza” event on April 10 to address service gaps identified in the survey. Following this event,
nearly 100% of the encampment residents have been assessed for housing assistance or had their
assessments updated, and many completed benefit applications for medical care, mental health support,
food assistance, and more. Staff have also engaged the Ritter Center to dispatch Ritter’s Street Medicine
Van to provide focused services around identified mental and medical health care gaps in the
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encampments. The Street Medicine team will look for opportunities to match individuals in need to Ritter’s
psychiatry services and connect with underserved Spanish-speaking residents.
In addition, City staff have held regular meetings with Boyd lawsuit plaintiffs and homeless
representatives to better understand their issues, support individuals with special challenges, reduce the
impacts of the encampments on the surrounding local businesses and community, and work toward a
productive and collaborative working relationship.
City staff regularly conduct outreach and engagement with the individuals in the Mahon Creek Path Area
encampment and have provided dozens of replacement tents, service referrals, and gift-card incentives
for voluntary compliance with the City’s regulations. The City provides monthly updates to the community
about its efforts to end homelessness through an email newsletter with more than 2,000 active
subscribers. Additionally, City staff respond to a high volume of constituent complaints and concerns
about the Mahon Creek Path and other encampments. Staff respond to every complaint and concern and
take this feedback into consideration when developing recommendations to the City Council. Staff and
City officials also meet with representatives of the most impacted businesses and educate them about
the City’s efforts and limitations under existing federal law.
All of these parties, particularly individuals camping at the Mahon Creek Path, will continue to receive
education and engagement from City staff. If the proposed amendments are adopted, staff would provide
targeted outreach, which would include informative brochures and flyers in English and Spanish that
outline the changes to the ordinance, explain its purpose, and provide clear instructions on how to achieve
compliance and how to access alternative shelter resources and case management services. Materials
would also be distributed through social service agencies, the homelessness email newsletter, libraries,
community centers, and other relevant locations.
FISCAL IMPACT:
Costs incurred by the City of San Rafael associated with responding to impacts of homelessness are
largely borne by the City’s General Fund. While the City continues to pursue grant funding for the creation
of interim and permanent supportive housing units, Federal and State funding to provide locally-
administered programs and services are allocated to county governments who have the primary
responsibility for providing health and human services countywide.
The City’s Finance staff recently estimated the fully-burdened costs (including salary and benefits) of City
staff that work with homelessness in the City, including multiple staff in the Community Development and
the San Rafael Police Departments, and part-time staff costs within the City Manager's and City
Attorney’s offices, at $890,000 annually. All of these costs have been absorbed by the City’s General
Fund FY 2023-24 budget.
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 is primarily responsible for enforcement
and handling of personal property, while the Department of Public Works or their contractors provide
support for disposal of trash and hazmat response. First year cleanup costs are accommodated and
absorbed within the Fiscal Year 2023-24 budget. The Department of Public Works’ proposed Fiscal Year
2024-25 operating budget includes $75,000 for services related to encampment cleanup, including the
potential need for hazardous material response. However, the actual encampment clean-up cost is
expected to be much higher overall. Staff is reviewing the City’s strategy for encampment sanitation as
recent hauling costs have reached as many as 4-6 loads twice a week, costing $26,000 per month. Staff
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 11
4856-0374-5897 v1
is actively building a list of approved contractors and deploying them in a more targeted manner, to reduce
this cost to a more manageable number. Hauling is time-intensive, and costs can be expected to remain
high, considering the hazardous conditions involved in dismantling certain camps, the large volumes of
trash generated, including through illegal dumping, and the relationship-building and care involved with
working with the encampment population.
Approximately 63% of the City’s alternative response calls through the SAFE team are for individuals
experiencing homelessness at any location in the City, costing the City $488,250 annually.
OPTIONS:
The City Council has the following options to consider on this matter:
1.Introduce the ordinance amending 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 amending Chapter 19.50 to the San Rafael Municipal Code Entitled “Camping
on Public Property” regulating camping on public property within the City of San Rafael.
ATTACHMENTS:
1. Ordinance
2.Redline of Chapter 19.50, showing changes from Ordinance No. 2030
ORDINANCE NO.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL AMENDING
CHAPTER 19.50 TO THE SAN RAFAEL MUNICIPAL CODE, ENTITLED “CAMPING ON
PUBLIC PROPERTY” REGULATING 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 camping in the City by persons with no
alternative shelter, and the activities often attendant with camping, have created adverse
public health, safety, and welfare conditions for the public, including those who live in the
City’s encampments; and
WHEREAS, the City, along with the County of Marin and community partners, has been and
is undertaking extensive actions to assist unsheltered persons in the City and region to find
shelter and needed services; and
WHEREAS, in the case of Martin v. City of Boise 920 F.3d 584 (9th Cir. 2019), 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, 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 temporary shelters on public
property, such as tents and tarps, and accumulate, store, or leave behind personal property,
garbage, waste, and biohazards; 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 real property, and economic development within the City;
and
WHEREAS, in July 2023, the City Council adopted Ordinance No. 2030, setting new spacing
and density rules and other restrictions for camping on public property by persons with no
alternative shelter available; and
WHEREAS, in the case of Boyd et al. v. City of San Rafael, N.D. Cal., Case No. 23-cv-04085-
EMC (“Boyd”), the Court issued a Preliminary Injunction Order under which the City was
permitted to enforce Ordinance No. 2030 under Court-modified rules which were
operationally impractical to implement, particularly as they involved procedures to administer
the Ordinance’s spacing and density requirements; and
WHEREAS, by this Ordinance, the City Council seeks to modify the regulations adopted
through Ordinance No. 2030 by allowing campsites of up to 200 square feet for one person
and 400 square feet for up to 4 persons camping together; eliminating the 200-foot spacing
requirement; requiring a 10-foot safety clearance around each campsite and 10-foot setbacks
from other campsites, public utility infrastructure, and private real property; specifying
enforcement notice and due process requirements; and making other language changes set
forth in the Ordinance; and
WHEREAS, by amending the City’s camping regulations, the City’s goal is to effectively
regulate and enforce camping laws for the health and safety of all of the public, including
residents who are experiencing homelessness; and
WHEREAS, for the reasons set forth above, this Ordinance is declared by the City Council to
be necessary to protect public health, safety, and welfare; preserve public property for the
enjoyment and safety of all members of the public; enhance and preserve the orderly
administration and management of public property; and preserve, protect, and prevent
damage to public resources, and the recitals above taken together constitute the City
Council’s statement of the reasons for adopting this Ordinance.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL DOES ORDAIN
AS FOLLOWS:
SECTION 2. AMENDMENTS TO SAN RAFAEL MUNICIPAL CODE CHAPTER 19.50
Chapter 19.50 of the San Rafael Municipal Code, entitled “Camping on Public Property”, is
hereby amended in its entirety to read 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 and safety of all
members of the public; enhancing and preserving the orderly administration and
management of public property; and preserving, protecting, and preventing damage 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:
A. “Camp” or “Camping” means use of space on public property for living
accommodation purposes such as sleeping activities, or making preparations to
sleep (including the laying down of bedding for the purpose of sleeping), or storing
personal belongings, or using any tents or shelter or other structure or vehicle for
sleeping. The above-listed activities constitute camping when it reasonably
appears, in light of all the circumstances, that the participants, in conducting these
activities, are using the area as a living accommodation regardless of the nature
of any other activities in which they may also be engaging.
B. “Camp facility” means a tent, cot, bed, hammock, vehicle, or other temporary
physical shelter.
C. “Camp paraphernalia" means implements and equipment used for camping,
including camp facilities, tarpaulins, mattresses, sleeping bags, bedrolls,
blankets, sheets, pillows, and cookware or cooking equipment.
D. “Campsite” means the primary physical area of occupation of one person camping
or up to four persons camping together, inclusive of camp facilities, camp
paraphernalia, and personal property.
E. "Open space property" means any area described in San Rafael Municipal Code
Section 19.10.020. The city will maintain on its public website and in hard copy at
the City Clerk’s office a map of all open space property meeting this definition.
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 also includes any playground equipment, fall
zones, surface materials, access ramps, and all areas within and including any
designated enclosure and barriers.
G. “Public facility” means any building or structure on public property, whether
secured, unsecured, locked, unlocked, open, or enclosed, as well as any area of
public property enclosed by a locked fence.
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(K).
J. “Public utility infrastructure” means public bathrooms or infrastructure and
equipment used to provide public utility services, including electricity, gas, water,
stormwater, telecommunications, and sanitation services.
K. “School” means any public or private institution of educational learning up to and
including grade 12.
L. “Sidewalk” means any area in the city provided for the use of pedestrians,
including planting areas, driveway approaches, and parking strips, between the
public vehicular roadway and the edge of public right-of-way bordering, fronting,
or adjacent to private real property.
M. "Store" means to put aside or accumulate for use when needed, to put for
safekeeping, or to place or leave in a location.
N. "Vehicle" means any wheeled conveyance, whether motor-powered or self-
propelled, and includes any trailer in tow of any size, kind, or description.
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, or in a manner that obstructs, blocks, or otherwise
interferes with access to a public facility or private real property.
4. Playgrounds. No person or persons shall camp within 100 feet of any
playground.
5. Schools. No person or persons shall camp within 250 feet of the property
boundary of any school.
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 or more public properties, or portion thereof,
where such camping is determined to be a threat to the public health, safety, or
welfare.
C. The city shall maintain on its public website and in hard copy at the city clerk’s
office a current citywide map of all public property parcels prohibited to camping
by subsections (A)(1), (A)(2), (A)(4), (A)(5), and (B) of this section 19.50.030.
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 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. Campsite size and occupancy.
a. No campsite occupied by one person shall exceed an area of 200 sq. ft.,
inclusive of camp facilities, camp paraphernalia, and personal property.
b. No campsite occupied by more than one person shall i) exceed an
occupancy of four persons or ii) exceed an area of 400 sq. ft., inclusive
of camp facilities, camp paraphernalia, and personal property.
c. All camp facilities, camp paraphernalia, and other personal property shall
be stored and kept within the maximum permitted campsite area.
d. Items stored or discarded outside of the maximum permitted campsite
area shall be presumed to be unattended personal property or trash or
debris and may be stored or discarded according to city policy.
e. No person shall establish or occupy more than one campsite.
2. Clearance and setbacks.
a. A minimum clearance of 10 feet around all sides of any campsite allowed
under this section shall be maintained free and clear of trash, debris, and
personal property, including but not limited to camp facilities and camp
paraphernalia. Items stored or discarded within the 10-foot clearance
area shall be presumed to be unattended personal property or trash or
debris and may be stored or discarded according to city policy.
b. No campsite may be established or occupied within 10 feet of any other
campsite allowed by this section, public utility infrastructure, or private
real property, including a fence of such property.
3. Fabric tents, fabric tarps, or other similar non-permanent, removable items
may be used for temporary shelter within a campsite, provided they are not
affixed or tied to any public property, private real property, vegetation, or
infrastructure, except for the use of removable stakes to secure the item to
unimproved ground on public property.
4. Removable plastic pallets or sandbags may be used to temporarily raise a
tent or other camp facility off of the ground, provided that such items are not
affixed or tied to any public property, private real property, vegetation, or
infrastructure.
19.50.050 – Violations; Enforcement.
A. Enforcement of this chapter shall be pursuant to chapters 1.42, 1.44, and 1.46;
provided, however, that no person shall be charged with a criminal violation
unless their unlawful conduct is knowing or willful.
B. The city manager or their designee shall be responsible for enforcement of this
chapter.
C. For a first violation of this chapter, the city manager or their designee shall issue
a written warning notice to the person violating the chapter, informing that
person of the nature of the violation, the actions that are required to be taken to
comply with this chapter, the city’s guidelines for removal and storage of
unattended personal property, the timeframe to come into compliance, and the
potential penalties that will apply for future violations.
D. For violation of section 19.50.040(C)(1)-(2), related to the size, occupancy, and
clearance or setbacks of a campsite, the person camping shall be given 3
business days to come into compliance with this chapter. The city manager or
their designee shall provide upon request a physical demarcation of the allowed
boundary to assist the person camping to comply with this chapter.
19.50.060 – 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. COMPLIANCE WITH CEQA
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 4. 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
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 5. 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 Councilmembers 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 15th day of April 2024, and was passed and adopted at a
regular meeting of the San Rafael City Council on the _______ of ________ by the following
vote, to wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
KATE COLIN, Mayor
ATTEST:
LINDSAY LARA, City Clerk
4884-5376-6251 v3 1
Attachment 2. Redlines to Chapter 19.50, as compared with Ordinance No. 2030
Chapter 19.50 – CAMPING ON PUBLIC PROPERTY
19.50.010. - Purpose.
The purposes of this Chapterchapter include but are not limited to: protecting public
health, safety, and welfare; preserving public property for the enjoyment, and safety,
comfort and convenience of all members of the public; enhancing and preserving the
orderly administration and management of public property; and preserving, protecting, and
preventing damagesdamage to public resources. This Chapterchapter 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:
A. "“Camp"” or "“Camping"” means using use of space on public property as a place of residence
or for living accommodation purposes, such 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 activities, or making preparations to sleep (including the laying down of
bedding for the purposespurpose of sleeping);), or
(ii) Unattended storage of storing personal belongings, including storing camp
paraphernalia or camp facilities.
A. or using any tents or shelter or other structure or vehicle for sleeping. The
combinedabove-listed activities of (1) and (2) constitute camping when it
reasonably appears, in light of all the circumstances, that a person isthe
participants, in conducting these activities, are using public propertythe area as a
living accommodation regardless of their intent or the nature of any other activities
in which the person mightthey may also be engagedengaging.
B. “Camp facility” means the use of a tent, hut, cot, bed, hammock, lean-to, shack,
4884-5376-6251 v3 2
vehicle, or other temporary physical shelter.
C. “Camp paraphernalia" means implements and equipment used for temporary
residencecamping, including, camp facilities, tarpaulins, mattresses, sleeping
bags, bedrolls, blankets, sheets, pillows, luggage, backpacks, and cookware, or
cooking equipment, kitchen utilities, and similar equipment.
D. “Camping areaCampsite” means the primary physical area of occupation of a
singleone person camping person. A or up to four persons camping area occupied
by one person shall not exceed 10 ft. by 10 ft., (100 sq. ft. total),together, 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. The city will maintain on its public website and in hard copy at
the City Clerk’s office a map of all open space property meeting this definition.
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 also includes any playground equipment, fall
zones, surface materials, access ramps, and all areas within and including theany
designated enclosure and barriers.
G. “Public facility” means any building, or structure, or area enclosed by a fence
located on public property, whether secured, unsecured, locked, unlocked, open,
or enclosed, as well as any area of public property enclosed by a locked fence.
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. (K).
J. “Public utility infrastructure” means public bathrooms, and electrical boxes, fire
hydrants, and similar or infrastructure and equipment used to provide public utility
services, but does not include light or electrical polesincluding electricity, gas,
water, stormwater, telecommunications, and sanitation services.
K. “School” means any public or private institution of educational learning up to and
including grade 12.
K.L. “Sidewalk” means any area in the Citycity provided for the use of pedestrians,
including planting areas, driveway approaches, orand parking strips, between the
public vehicular roadway and the edge of public right-of-way bordering, fronting,
or adjacent to private real property.
4884-5376-6251 v3 3
L.M. "Store" means to put aside or accumulate for use when needed, to put for
safekeeping, or to place or leave in a location.
M.N. "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 real property.
4. Playgrounds. No person or persons shall camp within 100 ft.feet of any
playground.
5. Public utility infrastructure.Schools. No person or persons shall camp within
10 ft.250 feet of the property boundary of any public utility
infrastructure.school.
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.
C. The city shall maintain on its public website and in hard copy at the city clerk’s
office a current citywide map of all public property parcels prohibited to camping
by subsections (A)(1), (A)(2), (A)(4), (A)(5), and (B) of this section 19.50.030.
4884-5376-6251 v3 4
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.
1. Campsite size and occupancy.
a. No campsite occupied by one person shall exceed an area of 200 sq. ft.,
inclusive of camp facilities, camp paraphernalia, and personal property.
b. No campsite occupied by more than one person shall i) exceed an
occupancy of four persons or ii) exceed an area of 400 sq. ft., inclusive
of camp facilities, camp paraphernalia, and personal property.
a.c. All camp facilities, camp paraphernalia, and other personal
belongingsproperty shall be stored and kept within the maximum
permitted campingcampsite area.
b.d. Items stored, kept, or discarded, or otherwise existing outside of the
campingmaximum permitted campsite area shall be presumed to be
unattended personal property or trash or debris and may be stored or
discarded according to city policy.
e. No person shall use, establish, or occupy more than one camping
campsite.
2. Clearance and setbacks.
3.a. A minimum clearance of 10 feet around all sides of any campsite
allowed under this section shall be maintained free and clear of trash,
debris, and personal property, including but not limited to camp facilities
and camp paraphernalia. Items stored or discarded within the 10-foot
clearance area shall be presumed to be unattended personal property or
4884-5376-6251 v3 5
trash or debris and may be stored or discarded according to city policy.
4.b. No camping areacampsite may be used, established, or occupied within
200 ft. of another camping area10 feet of any other campsite allowed by
this section, public utility infrastructure, or private real property, including
a fence of such property.
3. Fabric tents, fabric tarps, or other similar non-permanent, removable items
may be used for temporary shelter within a campsite, provided they are not
affixed or tied to any public property, private real property, vegetation, or
infrastructure, except for the use of removable stakes to secure the item to
unimproved ground on public property.
4. Removable plastic pallets or sandbags may be used to temporarily raise a
tent or other camp facility off of the ground, provided that such items are not
affixed or tied to any public property, private real property, vegetation, or
infrastructure.
19.50.050 – Violations; Enforcement.
A. Enforcement of this chapter shall be pursuant to chapters 1.42, 1.44, and 1.46;
provided, however, that no person shall be charged with a criminal violation
unless their unlawful conduct is knowing or willful.
B. The city manager or their designee shall be responsible for enforcement of this
chapter.
C. For a first violation of this chapter, the city manager or their designee shall issue
a written warning notice to the person violating the chapter, informing that
person of the nature of the violation, the actions that are required to be taken to
comply with this chapter, the city’s guidelines for removal and storage of
unattended personal property, the timeframe to come into compliance, and the
potential penalties that will apply for future violations.
D. For violation of section 19.50.040(C)(1)-(2), related to the size, occupancy, and
clearance or setbacks of a campsite, the person camping shall be given 3
business days to come into compliance with this chapter. The city manager or
their designee shall provide upon request a physical demarcation of the allowed
boundary to assist the person camping to comply with this chapter.
19.50.060 – 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.