HomeMy WebLinkAboutCA Group Home MoratoriumCITY OF.�
Agenda Item No: 12
Meeting Date: April 4, 2011
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: City Attorney
Prepared by: Robert F. Epstein, City Attorney City Manager Approval:
Lisa A. Goldfien, Dep. City Atty. II
SUBJECT:
A. Status Report Regarding Temporary Moratorium on the Establishment and
Operation within the City of San Rafael of Certain Large Group Homes that are
Transitory in Nature
B. Consideration of an Ordinance of the City Council of the City of San Rafael
Adopted as an Urgency Measure Making Findings and Extending a Temporary
Moratorium on the Establishment and Operation Within the City of San Rafael of
Certain Large Group Homes that are Transitory in Nature, and Declaring the
Urgency Thereof.
RECOMMENDATION:
Accept report and adopt the urgency ordinance.
BACKGROUND:
At its regular meeting on March 7, 2011, the City Council adopted Ordinance No. 1893, an urgency
ordinance temporarily prohibiting the opening and operation of any "unlicensed large group home" in any
zoning district within the City zoned for residential use. An unlicensed large group home is defined in the
ordinance as "a residential use of real property in a residential zoning district of the City operated, on
either a for-profit or not for-profit business basis, as a group home, not licensed by the State of California,
for the housing of seven (7) or more unrelated adults, not including onsite managers or operators, on a
month-to-month or similar transitory basis." By its terms, the moratorium does not apply to homes that
were already open and occupied on or before March 7, 2011, as demonstrated by a notarized declaration
under penalty of perjury certifying to such occupancy and submitted to the City upon written demand.
FOR CITY CLERK ONLY
File No.:
Council Meeting:
Disposition:
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
Although the City Attorney has opined that the specified group home use is not permitted under the City's
current zoning ordinance, he recommended adoption of the moratorium as a precautionary measure in the
event the City is challenged on this point. The purpose of the moratorium is to allow City planning and
legal staff a measured period of time in which to conduct a thorough review of the impacts of unlicensed
large group homes in various residential zones, the extensive federal and state case law governing the
regulation of this use, the applicability of the City's existing zoning regulations to the use, the regulatory
schemes of other California cities, and the need for any additional zoning ordinance amendments.
Although the temporary moratorium is limited to unlicensed large group homes, it does not legalize any
other use that is currently prohibited by the City's zoning ordinance. All issues relating to group homes
of any size and nature are being studied.
Ordinance No. 1893 was adopted pursuant to the authority of Government Code section 65858, and is due
to expire on April 21. The Government Code requires that, at least ten days prior to that time, the
legislative body must issue a written report describing the measures taken to alleviate the condition which
led to the adoption of the ordinance.
The Government Code also provides that the moratorium may be extended by the City Council following
a noticed public hearing, for an additional period of time up to ten months and fifteen days.
ANALYSIS:
A. Status Report Regarding Moratorium:
1. Information on new unlicensed large group homes: Since adoption of the moratorium,
staff has been advised by the attorney for the operators of the group homes at 201 Marin Street and 1
Culloden Park that there were nine (9) persons and two onsite managers living at 201 Marin Street on
March 7, 2011, and that there were fewer than seven (7) persons residing at 1 Culloden Park on March 7,
2011. The City Attorney has requested declarations from the operators attesting to these facts under
penalty of perjury, but as of the writing of this report, the requested declarations have not been received.
In the event staff does receive declarations as indicated, neither of these homes would be deemed to be
operating in violation of the moratorium. As noted above, however, this is not in itself an indication that
these houses are operating legally under the City's current zoning ordinance.
In addition, Community Development Department staff has scheduled and completed inspections
of both 201 Marin Street and 1 Culloden Park. A brief memo summarizing staff's findings is attached
hereto as Attachment B.
2. Input from the public: The City has continued to receive input from the general public
concerning the 201 Marin Street and 1 Culloden Park properties. The City Attorney has also met with the
attorney representing the operators of those properties, and with several attorneys who are neighbors or
are representing interested neighbors of those properties.
3. Legal research: City Attorney staff has reviewed numerous statutes, cases and articles
concerning the regulation of various types of group living arrangements. This complex area of law
requires consideration of federal constitutional principles of free speech, equal protection and due
process; the California State constitutional right of privacy; the federal Fair Housing Act ("FHA") and the
Fair Housing Amendments Act of 1988 ("FHAA"); the federal Americans with Disabilities Act ("ADA");
the California Health and Safety Code and Welfare and Institutions Code provisions governing licensed
residential care, health and treatment facilities; and principles and requirements of California planning
and zoning law. Among the relevant guiding principles established by these laws and the cases
interpreting them are the following:
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Pa2e: 3
a) Federal StatutoU protection of disabled persons under the FHA, FHAA, and
ADA:
• It is well established that individuals recovering from drug or alcohol addiction are considered to
be disabled under the Act. Corporation of Episcopal Church in Utah v. West Valley City (D.
Utah 2000) 119 F.Supp.2d 1215, 1219.
• The FHA as amended by the FHAA, makes it unlawful to discriminate in the sale or rental, or to
otherwise make unavailable or deny housing to persons falling within specified protected groups,
including persons with disabilities and families with children. 42 U.S.C. Section 3604(f)(1).
The FHA permits cities to impose "maximum occupancy restrictions," which the Supreme Court
has described as "ordinarily apply[ing] uniformly to all residents of all dwelling units." City of
Edmonds v. Oxford House, Inc. (1995) 514 U.S. 725, 733. Rules designed to preserve the family
character of a neighborhood, focusing on the composition of households rather than on the total
number of occupants that living quarters can contain, do not come within this provision. Id. at
734-35.
Under the FHA, it is a discriminatory practice to refuse to make a reasonable accommodation in
rules, policies, practices, or services when such accommodation may be necessary to afford [a
disabled] person equal opportunity to use and enjoy a dwelling. 42 U.S.C. § 3604(f)(3)(B). The
federal 9t" Circuit Court of Appeals has held that the FHAA imposes an affirmative duty on a
City to make reasonable accommodations in the application of its land use regulations to disabled
person residences. Gamble v. City of Escondido (9ttl Cir. 1996) 104 F.3d 300, 307.
• The Courts have recognized that a plaintiff may pursue three different theories against a
municipality in connection with the municipality's enforcement of its land use regulations to
establish discrimination against a protected group in violation of the FHAA: (1) disparate
treatment, (2) disparate impact, and (3) failure to reasonably accommodate persons with
disabilities. Id. at 304-305. See also, Louie v. Davis (N.D. Cal. 1998) 1998 WL 798890.
• Although a plaintiff is not required to prove discriminatory intent in order to show discriminatory
effect, in balancing disparate impact against a governmental interest, evidence of such intent
weighs heavily in the plaintiffs favor.
• The 9til Circuit Court of Appeals has held that "to allow the circumstance of facial discrimination
. . ., a defendant must show either: (1) that the restriction benefits the protected class or (2) that it
responds to legitimate safety concerns raised by the individuals affected, rather than being based
on stereotypes." Community House, Inc. v. City of Boise (9th Cir. 2007) 490 F.3d 1041, 1050.
• In addressing the issue of reasonable accommodation under the Americans with Disabilities Act,
it has been held that this is intended to be an interactive process that requires participation by both
parties. Corporation of Episcopal Church in Utah v. West Valley Ci supra, 119 F.Supp.2d
1215, 1222.
b) California Constitutional and statutor laws:
aws:
• California's constitutional right of privacy prohibits differential treatment of unrelated persons
living together as a family unit and persons living together who are related by blood, marriage,
and adoption. Adamson v. City of Santa Barbara (1980) 27 Ca1.3d 123. This rule does not
prohibit a City from regulating to preserve "residential character" by restrictions on transient and
institutional uses such as hotels, motels, boarding houses, clubs, etc. Id. at 133.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Pa2e: 4
Various provisions of the California Health and Safety Code and Welfare and Institutions Code
require that the City must treat certain licensed group homes for six (6) or fewer residents the
same as a single family residence, e.g., the City must allow such "small" licensed group homes in
any zone in which a single family residence is permitted. These include intermediate care
facilities for the developmentally disabled; community care facilities; residential care facilities for
the elderly; alcoholism and drug abuse facilities; pediatric day health and respite care facilities;
family care homes; foster homes; group homes for dependent and neglected children. Sober
living homes and parolee/probationer homes are among those group homes not currently licensed
by the State.
4. Next steps: Staff will continue to research the law as well as available factual
information pertaining to group homes in San Rafael. Based upon research done to date, the City
Attorney believes that the City retains some authority to regulate unlicensed large group homes, subject to
the availability to disabled persons and groups of the reasonable accommodation process. Therefore, staff
anticipates developing recommended amendments to the City's zoning ordinance. Staff will continue to
provide information to the community and to seek community input in this process, perhaps through a
community meeting.
The operators of the homes at 1 Culloden Park and 201 Marin Street, through their attorney, have
extended an invitation to the City Council to visit those properties. It is staff's recommendation and
request that, at this early stage of the moratorium, the Council should designate a committee of two of its
members to visit these properties, and to be the Council contact with staff on other matters related to the
moratorium.
B. Extension of Moratorium Ordinance:
Community Development Department and City Attorney staff have devoted substantial time to this issue
over the past month, however, more work remains to be done before staff will be prepared to return to the
Planning Commission and City Council with proposed zoning ordinance amendments. In addition, the
City Council will be deciding upon other unrelated staff work plan items for the 2011-2012 during the
upcoming budget adoption process. For this reason, it is recommended that Council extend the existing
moratorium through the end of this calendar year (December 31, 2011).
FISCAL IMPACT:
There will be no direct fiscal impact of the Council's extension of the moratorium ordinance, other than
the commitment of City Attorney and Planning staff time to the study and implementation of applicable
law.
OPTIONS:
1. Adopt the urgency ordinance as proposed to extend the moratorium through December 31, 2011.
2. Adopt the urgency ordinance with a modified expiration date.
3. Do not adopt the urgency ordinance, and direct staff to return to the Council with other options
for addressing the issues raised by unlicensed large group homes.
ACTION REQUIRED:
1. Accept status report.
2. Adopt ordinance by at least a four-fifths (4/5) vote.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 5
ATTACHMENTS:
A. Ordinance
B. Staff memo re inspections of 201 Marin Street, 1 Culloden Park
C. Proof of Publication of Public Hearing Notice
ORDINANCE NO.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY
OF SAN RAFAEL ADOPTED AS AN URGENCY MEASURE
MAKING FINDINGS. AND EXTENDING A TEMPORARY
MORATORIUM ON THE ESTABLISHMENT AND
OPERATION WITHIN THE CITY OF SAN RAFAEL OF
CERTAIN LARGE GROUP HOMES THAT ARE
TRANSITORY IN NATURE, AND DECLARING THE
URGENCY THEREOF
THE CITY COUNCIL OF THE CITY OF SAN RAFAEL, DOES ORDAIN AS FOLLOWS:
WHEREAS, the City Council has broad discretion pursuant to Article III, Sections 16
and 59 of the City Charter; California Constitution Article XI, Section 5; and the general law of
the state, including but not limited to the California Planning and Zoning Law (Gov. Code
§§65000 et seq.), to legislate for public purposes and for the general welfare, including but not
limited to matters of public health and safety; and
WHEREAS, the City currently regulates the permitted uses of real property within the
City pursuant to the provisions of its zoning ordinance, codified in San Rafael Municipal Code
Title 14; and
WHEREAS, the City's zoning ordinance contains a variety of definitions that concern
and/or define the residential use of real property, some of which relate to the residential use of
real property operated as a single facility for the purpose of housing and/or caring for groups of
unrelated adult persons with common needs and/or interests (hereinafter referred to generically
as "group homes"). For example, San Rafael Municipal Code Section 14.03.030 includes the
following definitions related to residential uses and/or group homes: "Bed and Breakfast Inn,"
"Boarding House," "Club," "Day Care Facility," "Dwelling Unit," "Residential Care Facility,
large," "Residential Care Facility, small," "Household," and "Handicapped;" and
WHEREAS, the City recently has been made aware of two independent business entities
that are planning to use residential property in the City in a manner not currently allowed under
the City's zoning ordinance, specifically, for the operation, on either a for-profit or not for-profit
business basis, of an existing single-family home in a residential zoning district of the City as a
group home, not licensed by the State of California, for the housing of seven (7) or more
unrelated adults, not including onsite managers or operators, on a month-to-month or similar
transitory basis (hereinafter "unlicensed large group homes"); and
WHEREAS, the City Council recognizes that numerous federal and state laws govern
the City's ability to regulate various kinds of group homes, whether they are serving disabled or
able-bodied persons, and the Council wishes to study these laws to determine whether additional
zoning regulations should and lawfully may be enacted; and
WHEREAS, pursuant to Government Code section 65858, in order to protect the public
health, safety or welfare, the City Council may, by at least a four-fifths (4/5) vote and without
following the procedures otherwise required prior to the adoption of a zoning ordinance, adopt
an interim urgency ordinance to prohibit uses that may be in conflict with a contemplated general
plan or zoning proposal that the City is studying or intends to study within a reasonable time; and
WHEREAS, the potential operation of unlicensed large group homes in residential
neighborhoods of the City creates a current and immediate threat to the public safety, health, and
welfare, in that such operations reasonably threaten to cause adverse impacts to surrounding
neighbors, including impacts on or related to available parking, traffic, noise, outdoor lighting,
sanitation, litter, outdoor gatherings, and property values; and
WHEREAS, the potential operation of unlicensed large group homes in residential
neighborhoods of the City creates an additional current and immediate threat to the public safety,
health, and welfare, in that such operations reasonably threaten to undermine the overall goals
and purposes of the City's zoning ordinance with respect to the character of residential
neighborhoods and the fostering of harmonious and workable relationships among land uses to
mitigate or eliminate negative impacts caused by incompatible locations and uses; and
WHEREAS, for the reasons stated above, on March 7, 2011, the San Rafael City
Council adopted Ordinance No. 1893, a 45 -day moratorium on the establishment and operation
of unlicensed large group homes within the residential zones of the City. The purpose of the
temporary moratorium is to allow the City to (1) review and analyze the various definitions of
uses of property in the City's zoning ordinance, including those enumerated in the recitals above;
(2) consider potential amendments to those definitions and to the land use regulations related
thereto; and (3) research, draft, and adopt appropriate definitions, land use regulations, and any
other regulations, including, but not limited to business licensing regulations, governing
unlicensed large group homes or other group homes; and
WHEREAS, as required pursuant to Government Code section 65858, the City Council
has received and accepted a report from City staff on the measures taken to alleviate the
condition which led to the adoption of the ordinance; and
WHEREAS, the City Council finds that additional time is required for City staff to
thoroughly study the issues related to regulation of unlicensed large group homes and other
group homes; to draft appropriate amendments to the City's Municipal Code; and to hold
hearings and conduct reviews required for adoption of any such amendments, and that therefore
the temporary moratorium adopted in Ordinance No. 1893 should be extended; and
WHEREAS, the City Council hereby finds that it can be seen with certainty that there is
no possibility that the extension of the temporary moratorium ordinance may have a significant
effect on the environment, since this ordinance does not authorize construction or installation of
any facilities and, in fact, imposes greater restrictions on such construction and installation in
order to protect the public health, safety and general welfare. This ordinance is therefore exempt
from the environmental review requirements of the California Environmental Quality Act
2
(CEQA) pursuant to Section 15061(b)(3) of Title 14 of the California Code of Regulations.
NOW, THEREFORE, the City Council of the City of San Rafael does hereby ordain as
follows:
DIVISION 1. -- FINDINGS.
Pursuant to the provisions of Government code section 65858, the City Council of the
City of San Rafael hereby finds as follows:
The above recitals are true and correct and incorporated herein by reference.
2. Based on the recitals above, the City Council hereby finds and determines that the
establishment or commencement of operation of unlicensed large group homes in zoning districts
zoned for residential use in the City prior to the City completing a study of the existing and
potential impacts and regulation of such use would pose a current and immediate threat to the
public peace, health, safety, and welfare, and that a temporary moratorium on the establishment
of such use is therefore necessary.
3. This ordinance is necessary as an urgency measure to preserve the public peace,
health or safety.
DIVISION 2. -- EXTENSION OF MORATORIUM.
1. The temporary moratorium adopted by City of San Rafael Ordinance No. 1893 is
hereby extended to and including December 31, 2011.
2. During the term of this temporary moratorium, no unlicensed large group home,
as defined in this ordinance shall be opened and/or operated in any zoning district within the City
that is zoned for residential use; provided that this moratorium shall not apply to any such
business that was open and occupied by seven (7) or more unrelated adult tenants/clients (not
including onsite managers or operators) on or before March 7, 2011, as demonstrated by a
notarized declaration under penalty of perjury certifying to such occupancy and submitted to the
City upon written demand.
3. City staff is directed forthwith to (a) review and analyze the various definitions of
uses of property in the City's zoning ordinance, including those enumerated in the recitals above;
(b) consider potential amendments to those definitions and to the land use regulations related
thereto; and (c) research and draft appropriate definitions, land use regulations, and any other
regulations, including, but not limited to business licensing regulations, governing unlicensed
large group homes or other group homes; and
4. For purposes of this temporary moratorium, the following terms shall have the
following meanings:
A. "Group home" shall mean a residential use of real property operated as a
single facility for the purpose of housing and/or caring for a group of unrelated adult persons
with common needs and/or interests.
B. "Unlicensed large group home" shall mean a residential use of real
property operated, on either a for-profit or not for-profit business basis, as a group home, not
licensed by the State of California, for the housing of seven (7) or more unrelated adults, not
including onsite managers or operators, on a month-to-month or similar transitory basis.
5. Violations of this temporary moratorium may be charged as infractions or
misdemeanors as set forth in Section 1.16.060 of the San Rafael Municipal Code or may be
deemed a public nuisance and may be enforced by an action for injunction or civil penalties as
provided in Section 1.42.020, or any other remedy authorized by law.
6. The San Rafael City Manager is hereby authorized to direct all City Departments,
including the Code Enforcement Division of the Community Development Department and the
City Attorney to facilitate compliance with the purpose and intent of this temporary moratorium
using the enforcement powers described in the preceding paragraph.
DIVISION 3.
Pursuant to the pertinent provisions of Government Code section 65858, this interim
urgency ordinance shall expire and shall be of no further force and effect after December 31,
2011; provided however, that after notice and public hearing, the City Council may, upon an
affirmative vote of at least four-fifths of its members, extend this interim ordinance as provided
in section 65858, for an additional period of time, not to exceed a total extension period of
twenty-two (22) months and fifteen (15) days.
DIVISION 4.
If any section, subsection, sentence, clause or phrase of this ordinance is, for any reason,
held to be invalid, such decision shall not affect the validity of the remaining portions of this
ordinance. The City Council hereby declares that it would have adopted the ordinance and each
section, subsection, sentence, clause or phrase thereof,. irrespective of the fact that any one or
more sections, subsections, sentences, clauses, or phrases are declared invalid.
L!
DIVISION S.
This ordinance is hereby declared to be an urgency measure and shall become effective
immediately upon adoption by at least a four-fifths (4/5) vote of the City Council pursuant to
Government Code section 65858. The City Clerk is directed to publish forthwith a copy of this
Ordinance, 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.
ALBERT J. BORO, Mayor
ATTEST:
ESTHER C. BEIRNE, City Clerk
I, ESTHER C. BEIRNE, City Clerk of the City of San Rafael, certify that the foregoing
Ordinance was passed by the City Council of the City of San Rafael, California, by a vote of at
least four-fifths (4/5) of the members thereof, at a regular meeting held on Monday, the 4th day
of April, 2011, by the following vote, to wit:
AYES: Councilmembers:
NOES: Councilmembers:
ABSENT: Councilmembers:
ESTHER C. BEIRNE, City Clerk
Community Development Department
INTER -DEPARTMENTAL MEMORANDUM
DATE: March 30, 2011
TO: Rob Epstein, City Attorney; Lisa Goldfien, Deputy City Attorney
FROM: Paul Jensen, Planning Manager (415.485.5064)
Steve Buffenbarger, Deputy Chief Building Official (415:485.3369)
cc: Bob Brown, Community Development Director
SUBJECT: Building Inspection of Single -Family Residences at 201 Marin Street and One
Culloden Park Road
Today, a building inspection was conducted at 201 Marin Street and One Culloden Park Road.
The inspection was conducted by Steve Buffenbarger, Deputy Chief Building Official and Steve
Rupnow, Fire Inspector. Paul Jensen, Planning Manager was also in attendance. The findings
of this inspection are summarized as follows:
201 Marin Street (2:00pm inspection)
Main Level
The front den was converted to bedroom (three beds) in violation of a stop work
order. A building permit application has been filed and is pending issuance.
Middle bedroom (manager) - one bed
Back bedroom — three beds
Second Floor
Front bedroom — three beds
Back bedroom — two beds
Requirements:
• Secure building permit for conversion of den to bedroom and call for inspections on
work completed to date.
• Upgrade smoke detectors with smoke/carbon monoxide detectors
One Culloden Park Road (3:00pm inspection)
Basement level
•
Floor -to -ceiling height measured at 6'8"
• Appears that flooring was removed, exposing a concrete floor
• Walls and ceiling have been surfaced with sheet -rock; uncertain when the sheet -
rock was installed, but some construction dust was apparent.
• Currently appears to be used as storage (including bedroom furniture)
Main level
• Bedroom and den located at east end of building appear to have been combined
(walls removed); area is now an office
Rob Epstein and Lisa Goldfien
March 30, 2011
Page 2
Den used as a bedroom/sleeping room- one bed
Second Floor
Attic Floor
Bedroom One- two beds
Bedroom Two- two beds
Bedroom Three- three beds
Existing bedroom with 6'11 floor -to -ceiling height- three beds
Egress windows are substandard for emergency egress for a bedroom under current
conditions. As this is a pre-existing, so no changes are required.
Requirements:
• Basement is uninhabitable space based on substandard floor -to -ceiling height.
Basement area limited to storage use.
• Provide emergency egress to allow conversion from den to bedroom on main level
• Upgrade smoke detectors with smoke/carbon monoxide detectors
Clean-sober,bldg_inspection_3-30-11
Marin Independent Journal
150 Alameda del Prado
PO Box 6150
Novato, California 94948-1535
(415) 382-7335
legals@marinij.com
SAN RAFAEL,CITY OF
PO BOX 151560/CITY CLERK, DEPT OF PUBLIC
WORKS,1400 FIFTH AVE
SAN RAFAEL CA 94915-1560
PROOF OF PUBLICATION
(2015.5 C.C.P.)
STATE OF CALIFORNIA
County of Marin
FILE NO. 0003920739
I am a citizen of the United States and a resident of the County
aforesaid: I am over the age of eighteen years, and not a party to
or interested in the above matter. I am the principal clerk of the
printer of the MARIN INDEPENDENT JOURNAL, a newspaper of
general circulation, printed and published daily in the County of
Marin, and which newspaper has been adjudged a newspaper of
general circulation by the Superior Court of the County of Marin,
State of California, under date of FEBRUARY 7, 1955, CASE
NUMBER 25566; that the notice, of which the annexed is a printed
copy (set in type not smaller than nonpareil), has been published in
each regular and entire issue of said newspaper and not in any
supplement thereof on the following dates, to -wit:
3/23/2011
I certify (or declare) under the penalty of perjury that the foregoing
is true and correct.
Dated this 23th day of March, 2011.
Signature J
PROOF OF PUBLICATION
Legal No. 0003920739
CiTY OF SAN RAFAEL
NOTICE OF PUBLIC HEARING
BEFORE THE SAN RAFAEL CITY COUNCIL
The City Council of the City of San Rafael will hold
a public hearing concerning:
An Ordinance of the City Council of the City of San
Rafael Adopted as an Urgency Measure Making
Findings and Extending a Temporary Moratorium
on the Establishment and Operation within the
City of San Rafael of Certain Large Group Homes
that are Transitory in Nature, and Declaring the Ur-
gency Thereof
DATE/TIME: Monday, April 4, 2011, at 8:00 p.m,
LOCATION: City Council Chambers, City Hall,
144 Fifth Avenue,
San Rafael, CA
PURPOSEsTo receive public comments and to con-
sider adoption of a proposed ordinance to extend
a temporarymoratorium on the establishment and
operation within the City of San Rafael of certain
large group homes that are transitory in nature,
and declaring the urgency thereof
IF YOU CANNOT ATTEND: You can send a letter
with your comments regarding the proposed ordi-
nance to Esther C. Beirne, City Clerk, City of San
Rafael, P.O. Box 151560, San Rafael CA 94915-1560,
or you can deliver a letter to the City Clerk prior to
the City Council meeting on April 4011.
FOR MORE: For additional information regarding
the above, you can contact Paul Jensen Planning
Manager of the City of San Rafael at (415) 485.5064
Office hours are Monday -Friday, 8:30 AM to 5:00
PM.
Esther C. Beirne
City Clerk
City of San Rafael
rican Sign Lan uage Interpreters and
Alve listening deviices may be requested byy
g 415-485-3198 (TDD) or 415.485.5064 (volce)
ast 72 hours in advance of the Public Hearing.
es of documents are available In accessible
cats upon request. Public transportation is
able through Golden Gayte Tranggsit line 20 oprr
scat 415 454 0964 bTo allow Individuialsewith
ronmental Illness or multiple chemical sensi-
r to attend the Public Hearing, individuals are
ested to refrain from wearing scented prod -
475 March. 23, 2011,