HomeMy WebLinkAbout00 - Written CommentsReceived After Agenda
Printed January 24, 2022
Written Comments
January 25, 2022, City Council Agenda Comments
The following comments on items on the Newport Beach City Council agenda are submitted by:
Jim Mosher ( iimmosher(@-yahoo.com ), 2210 Private Road, Newport Beach 92660 (949-548-6229)
Item SS3. Housing Element Update
HCD informs the public about the status of the state's many General Plan Housing Elements
under the "Housing Element Compliance Report" button in the blue -bordered box of the same
name on its Housing Elements page; and, in a spreadsheet updated weekly, provides links to
the review letters sent.
I have not read all of those, but the letters received by our city on October 12 and January 14,
while disappointing, do not seem materially different from those sent to hundreds of other cities
and counties.
As of January 24, of the 197 SCAG jurisdictions, 44 cities and counties have proceeded to
adopt 6th Cycle Housing Elements.
Only 2 of the 44 (Ventura County and the city of Wildomar in Riverside County) have so far
managed to obtain certification. Both of those appear to have been adopted as is officially
required by October 15, 2021, but for which there is a 120 -day grace period ending February
12, 2022. Of the 42 other adopted 6th Cycle Housing Elements in the SCAG region, 16 have
been found out of compliance (including, in Orange County: Brea, La Palma, Laguna Niguel,
Mission Viejo, San Clemente, Tustin and Villa Park) and the remaining 26 are still under review.
14 SCAG jurisdictions have not yet submitted anything for review and the remaining 139 remain
in draft status. With 33 of those drafts still under review, only 2 (Imperial County and the City of
Duarte) have been found in compliance, while 98 jurisdictions have, like Newport Beach, been
told their submitted drafts been told revisions will be required before certification is possible.
In summary, with just 19 days left in the grace period for adoption of a certifiable 6th Cycle
Housing Element, HCD has found only 4 of the 197 SCAG jurisdictions to have submitted
something that has been or can be certified as written, and told 114 of the jurisdictions that what
they either adopted or submitted for review cannot be certified without revisions.
This can be compared to the experience of the 19 jurisdictions in San Diego County
("SANDAG"), which had the statutory deadline immediately preceding SCAG: April 15, 2021,
with a grace period for adoption ending August 13, 2021. As of January 24, 2022, with 1
adopted element still under review, only 7 SANDAG jurisdictions have been able to adopt
elements that HCD has certified. The remaining 8 adopted elements and 3 drafts have been
found out of compliance.
The planning areas with 6th Cycle due dates prior to SANDAG seem mostly to be in compliance,
now, with the exception of the city of Blue Lake in Humboldt County, which, with a statutory
adoption goal of August 31, 2019, has apparently not yet submitted anything, even for review.
The somewhat good news is that although late adoption of a certifiable element does appear to
trigger a 4 -year review cycle for the next submission, the HCD letters of compliance do not
seem to mention imposition of any of the other threatened sanctions (see, for example,
January 25, 2022, City Council agenda comments - Jim Mosher Page 2 of 11
compliance letter to city of Trinidad). This does not mean, however, that those sanctions are not
being imposed.
As to City staff's plans, the timeline presented as part of Item SS2 at the November 16, 2021,
Council meeting indicated that on December 9 the Planning Commission was going to review
the November 12 draft to be submitted to HCD on November 17, with the Council to adopt it on
February 8.
The Planning Commission did indeed review the November 12 draft as Item 3 at their
December 9 meeting. However, it now appears that if even the possibility of compliance is
desired, something substantially different will have to be adopted by the Council on February 8.
If a Planning Commission recommendation is required, that creates a very tight schedule for
comment and revision, since the only chance for the Planning Commission to review that at a
regular meeting will be on February 3 — and City staff has just posted a notice of cancellation of
that meeting, with a note that the Commission is not expected to meet again until February 17.
Item 1. Minutes for the January 11, 2022 City Council Meeting
The passages shown in italics below are from the draft minutes with suggested corrections
shown intr,*eo 'f underline format. The page numbers refer to Volume 65.
Page 221, Item XIII, Dixon, first bullet: "Attended the Aviation Committee meeting on
December 20, 2021, and announced the next meeting on January 24, 2022" [note: the
minutes are correct, but the January 24 meeting was canceled for undisclosed reasons]
Page 223, paragraph 2: "Harbor Commissioner Kenney requested that Council review and
approve the Harbor Commission 2022 objectives." [Was this intended to read "Harbor
Commission Chair Kenney'?]
Page 225, last paragraph: "Principal Planner Murillo utilized a presentation to discuss the
proposed Municipal Code and Coastal Land Use Plan Amendments related to cottage
preservation, previously approved incentives from January 28, 2020, a cottage preservation
example, and the California Coastal Commission c+rvrrw -t rai approval with modifications from
November 19, 2021." [note: The word "structural" was not used in the presentation. The
reason to insert it in the minutes, and the meaning it was intended to add, are unclear. The
CCC did not approve "structure." It approved words, with modifications.]
Page 227, paragraph 2: "In response to Council Member Dixon's questions, Deputy Public
Works Director Martin reported that public outreach and education will support the new bulky
item pickip ckup service effective January 15, 2022." [the noun or adjective, as used
here, is a single word]
January 25, 2022, City Council agenda comments - Jim Mosher Page 3 of 11
Item 5. Resolution No. 2022-8: Adopting a Memorandum of
Understanding with the Newport Beach Employees League (LEAGUE)
and Associated Salary Schedule
At the January 11 Council meeting, Mayor Muldoon clarified the Council had approved using
part of the City's CARES Act money to pay employees a one-time $2,000 cash bonus.
When was that decision made, and how would the public know this is the proposed
source of the money?
It is not mentioned in the staff report, including in the Fiscal Impact statement on pages 5-2 to 5-
3. Nor is it evident from the detailed budget breakdown on page 5-5, where it appears all the
increased payouts in the current fiscal year will be covered out of the General Fund, Water and
Wastewater Enterprise Funds and the Equipment Fund.
Item 7. Financial Statement Audit Results and Related Communication
The ACFR (formerly CAFR) is an important document that deserves wider exposure, but is not
in a format easily understood by non -accountants.
Some agencies summarize highlights from their ACFR in a "Popular Annual Financial Report."
Orange County does (calling it a Citizens Report). The Costa Mesa Sanitary District does (see
Item E.2 on their January 24, 2022, agenda).
I don't know how widely read these are, or if they are worth the investment, but the Council
might consider having Newport Beach City staff do this as well.
Item 8. Dredging Disposal Alternatives Analysis by a Private Party:
Harbor Commission Recommendation
The staff report mentions (on page 8-2) that sometime subsequent to the Council publicly
setting a 90 -day deadline for the residents' team to submit its proposals,' "the City Council
informally allowed 60 additional days." This is disturbing because the Council is not supposed to
give informal direction to staff, especially direction to override the decisions it makes in public.
It is unclear from the present report if formal written proposals were actually received, for all that
is provided for the Council's consideration is the minutes of the verbal discussion that occurred
at the October 13 Harbor Commission meeting, and with no explanation of the more than three
month delay in reporting that to the Council. From the minutes, it appears both staff and "Team
Palmer" gave presentations. Since Harbor Commission meetings are not video recorded, t
would have been helpful to include the slides from those in the present staff report.
' See minutes, Vol. 65, page 54. From those it appears the 90 days from May 25, 2021, was the time
within which the Harbor Commission was asked to return to Council with its recommendation regarding
the proposals, which were expected to be received for evaluation by the Commission's June 9 meeting.
January 25, 2022, City Council agenda comments - Jim Mosher Page 4 of 11
Item XVII. PUBLIC COMMENTS ON NON -AGENDA ITEMS
My attempt to comment on Item 20 (Approval of Proposed Residential Solid Waste Collection &
Recycling Contract with CR&R Inc.) was cut short by the 3 -minute limit for oral comments.
When cut off, I was attempting to ask about the indication on page 20-6 of the staff report that
although City staff claims to have negotiated a contract for $24.08 per month per household, of
the 24,000 households, "CR&R has identified 9,967 households currently with standard valet
service." Those 9,967 households will presumably continue to receive that service, for which
CR&R will bill them an additional $8.30 per month.
I asked about this again at the Newport Beach Chamber of Commerce's January 20 online
Government Affairs Committee meeting, where Director Webb and Deputy Director Martin
presented the roll-out of the new residential organics waste collection program.
Deputy Director Martin explained that what CR&R calls the "standard valet service" applies in
congested areas where someone has to get out the truck to move the carts for collection. This
would appear to all collections by the new split -body trucks.
However, Deputy Director Martin implied the City would be paying this fee, and only the 29
households currently receiving the "premium valet service" would receive an extra bill from
CR&R (for $27.68).
Which is correct? Will the City be paying the $8.30 per month surcharge for "standard
valet service" or will nearly half the homes in Newport Beach be receiving a bill for this?
If the residents are paying, do they have any option for pickup by other than through "standard
valet service"? If not, how does this square with the City's requirement to provide residents with
free trash pickup?
If the City will be paying it, then this isn't really a $24.08 per month contract, is it?
The other comment of surprise to the NBCC host regarded the very limited set of container size
options being offered at no additional charge. Deputy Director Martin said the City will pay for
only one set per lot, regardless of the number of units on it, which he thought could be up to
four. So, for example, if there are four units on the lot, the City will pay for at most a single 96 -
gallon mixed waste cart (or, alternatively, two 32 -gallon carts) for the entire complex. Is this
correct?
Item 9. Resolution No. 2022-2: Creating the General Plan Update
Steering Committee (PA2017-141) - continued from the January 11,
2022 City Council meeting
As the Council knows, and as the full agenda title acknowledges, this item was continued from
the Council's January 11 meeting, where it was presented for approval as Item 5 on the consent
calendar (see my comments' from then).
2 In what may have been a too -hasty reading of the proposed Resolution No. 2022-2, 1 missed "and
confirmed by the City Council in the "Membership" line. But it remains unclear as to whether that means
the Mayor's appointments must be confirmed by the full Council, or only the appointees' qualifications.
January 25, 2022, City Council agenda comments - Jim Mosher Page 5 of 11
Since then, the staff report has been very slightly modified, mostly by adding an Attachment B
illustration of "General Plan Update Committees.
The previous staff report said in a single paragraph on page 5-2 that "the Steering Committee
will serve as a project coordinator for the General Plan update while the Advisory Committee will
be guiding changes to specific policies and goals in the individual elements" and that "City staff
will manage the selected consultant team and will support the work program of both
committees."
The new staff report substitutes two paragraphs for this, omitting the part about City staff, says
(on page 9-2) "The Steering Committee will lead the overall General Plan update effort and will
make recommendations to the City Council on forming the policy advisory committee. The
Steering Committee will provide oversight of the larger policy committee and provide periodic
reports to the City Council." and adding this information "The formation and make-up of the
policy advisory committee will be based on the recommendations by the Steering Committee.
However, it is envisioned to have 20 to 30 members of the community who will be responsible
for recommending changes to specific General Plan policies and goals. The policy advisory
committee will report to and seek direction from the Steering Committee."
The proposed Resolution No. 2022-2 has not been modified at all
Both the staff report and the resolution remain highly defective.
Has September 28 Council Committee Completed Its Work?
To back up, both staff reports refer to the Mayor appointing a General Plan Update Ad Hoc
Committee on September 28, 2021. Neither clarifies that the Mayor did not take this action on
his own. Instead, the entire Council, as part of Item 7 on the Consent Calendar, approved
Resolution No. 2021-87 (Creating the City Council Ad Hoc General Plan Update Committee)
and approved the Mayor's appointments to it.
Resolution No. 2021-87 set forth very specific tasks for the City Council Ad Hoc General Plan
Update Committee to accomplish, subsequent to its recommendations with regard to which, it
was to sunset. Specifically, Resolution No. 2021-87 says:
"The Committee is charged with making a recommendation to the entire City Council
regarding matters pertinent to updating the remainder of the General Plan including but not
limited to: the legal requirements of updating individual General Plan Elements, to identify a
resident -based committee, their role and responsibility with assisting staff with the update, to
shape the initial scope and priorities of the update, and to establish a general schedule."
The present staff report might charitably be understood as purporting to represent the Ad Hoc
General Plan Update Committee's recommendation with regard to its task "to identify a resident -
based committee, their role and responsibility with assisting staff with the update."
But that recommendation is part of a larger scheme and can be understood only within the
context of the Council Committee's recommendations on "the legal requirements of updating
individual General Plan Elements" and "to shape the initial scope and priorities of the update"
and "to establish a general schedule" — regarding which we have heard nothing.
January 25, 2022, City Council agenda comments - Jim Mosher Page 6 of 11
The proposed Resolution No. 2022-2 appears to be punting these tasks to a new, vaguely
defined three-member committee.
Is this indeed the September 28 Council Committee's recommendation? Does that committee
have a spokesperson to confirm this? And is this its only and final recommendation, so that it is
now sunset?
Comparison to Earlier General Plan Steering Committees
As to the proposal in the staff report, the idea interposing a Steering Committee between the
City Council and a larger citizens General Plan Advisory Committee appears, without
acknowledging it, to be modeled after the last comprehensive update of the City's General Plan
in 2000-2006.
As previously noted, that General Plan Update Committee (which oversaw a still larger citizens
General Plan Advisory Committee) was first established by Resolution No. 2000-45 (while the
vote on Greenlight was pending), and refined by Resolution No. 2000-102, Resolution No.
2001-17 and Resolution No. 2003-21. These resulted in an 11 -member GPUC serving a similar
purpose to what is being proposed here. It consisting of 3 Council members appointed by the
Mayor, 7 additional representatives selected by designated City boards and commissions from
among their own members, plus 1 person designated by the Greenlight petitioners.
The proposed Resolution No. 2022-2 more specifically references and says it is "reestablishing"
the more recent General Plan Update Steering Committee, which was established for a slightly
different purpose by Resolution No. 2019-7 and refined by Resolution No. 2019-20. That
consisted of seven citizen members appointed by the Mayor from a public application pool and
confirmed by the full Council, plus the Mayor serving as an ex officio member without the right to
vote.
The staff report provides no explanation of why the September 28 Council Ad Hoc Committee is
recommending the creation of a Steering Committee, let alone why it is recommending one so
much smaller than the one the resolution says it is "reestablishing."
Proposed Resolution is Sloppily Written, Leaving Its Intent Unclear
Setting aside the complete lack of explanation of why the September 28 Council Ad Hoc
Committee deemed the creation of a Steering Committee to be desirable, the resolution is so
poorly written it's impossible to tell what, if anything, the Ad Hoc Committee recommended for
its structure.
Staff has modified the resolutions that created the committee it is "reestablishing," but ineptly.
Under "Membership," Resolution No. 2019-20 said:
MEMBERSHIP- Eight (8) total. The Mayor shall be an ex officio member
without the right to vote. Seven (7) residents appointed by
the Mayor and confirmed by the City Council.
The new resolution says:
January 25, 2022, City Council agenda comments - Jim Mosher Page 7 of 11
MEMBERSHIP: Three {3) members that meet the qualifications set forth
below and confirmed by the City Council.
That could mean the members have to be confirmed by a majority of the City Council. It could
also mean only that in adopting the resolution, the Council has confirmed "the qualifications set
forth below." Or it could mean that the Council's role is confined to confirming the member's
possess the listed qualifications.
As to those qualifications, the former resolution, which sought resident appointees only, said:
QUALIFICATIONS
OF APPOINTED
MEMBERS:
The new resolution says:
QUALIFICATIONS
OF APPOINTED
MEMBERS:
Appointed Committee Members shall be;
A. A resident of the City of Newport Beach ("City");
B. A registered voter in the City of Newport beach;
C. Appointed by the Mayor; and
D. Confirmed by the City Council,
Appointed Committee Members small be:
k One (1) resident of the City of Newport Beach,
B. One {1} registered voter of the City of Newport Beach.-
and
each;and
C One (I) Mayoral appointment_
That is a very strange perversion of the previous list. Rather than having to be a resident, a
voter, appointed by the Mayor and confirmed by the Council, it now says one member will be a
resident, one member will be a voter, and one member will be appointed the Mayor. And since
the assumption is that all three members will be appointed by the Mayor, the only reason for "C"
would seem to be to allow the Mayor to choose someone who is neither a resident nor a voter.
Likewise, since nearly all registered voters are residents, calling those out as separate
qualifications would seem to express an intent to appoint people who are one but not the other.
This is all very unusual, making it particularly strange that there is no explanation of why the
January 25, 2022, City Council agenda comments - Jim Mosher Page 8 of 11
Council Ad Hoc Committee would recommend such an unconventional Steering Committee
structure.
Moreover, the deletion for the requirement for the Mayor's selections to be confirmed by the
Council suggests that is no longer a requirement.
Indeed, whereas Resolution No. 2019-20 laid out a very detailed process for "Selection of
Appointed Members," the proposed resolution says:
SELECTION
OF APPOINTED
MEMBERS: Except as otherwise required by state law, the Mayor (or
his/her designee) shall have the discretion to determine the
process for selecting Committee Members and shall not be
requixed to form an "ad-hoc appointments committee" or
comply with any other procedural or tinting requirements set
forth in Council PDlicy A-2.
In other words, the Council is being asked to give the Mayor complete freedom in deciding how
the selections are made.
And while the next to last Whereas on page 9-5 says: "the City Council values and respects the
opinions, knowledge, and experiences of its residents, and desires residents to play an
important role in the General Plan update process," the staff report says, on page 9-2: "If the
Mayor decides for residents to apply for the opportunity to serve on the Steering Committee,
then the City Clerk will publish an advertisement for residents to submit applications for City
Council consideration." The strong implication is staff interprets the resolution to mean the
Mayor may choose not to include residents on the Steering Committee, or may choose to
appoint residents without an application process.
In other words, the Council is being asked to leave it up to the Mayor to decide if the Steering
Committee should consist of three Council members, three non -Council members, or any
combination of those, chosen in whatever manner the Mayor wishes.
Again, why is the September 28 Council Ad Hoc Committee making such a strange
recommendation?
One might consider heeding the wisdom of our City Charter, which, when the Council wants
citizen advice, as it seems to here, empowers the Council to appoint boards and commissions
to provide it. Article VII requires such advisory bodies to "be appointed by the City Council from
the qualified electors of the City, none of whom shall hold any paid office or employment in the
City government" who choose their own chair and serve for terms of four years. It is not clear
the Charter allows the creation of advisory bodies with alternative structures, such as being
proposed here.
January 25, 2022, City Council agenda comments - Jim Mosher Page 9 of 11
Item 10. Ordinance No. 2022-4: Multiple Vessel Mooring System
Clarifying Statements and Updates; and Resolution No. 2022-9:
Multiple Vessel Mooring System Plans and Specifications
Intuitively, one might think these floating platforms for tying vessels to would be most
appropriate in areas where the platform could be firmly secured at both ends (the "double
anchor" mooring fields), as opposed to securing them at one end only, leaving them free to
more with the winds and tides (the "single anchor" mooring fields). However, they are being
recommended only in the single anchor fields, all of which are controlled by two private yacht
clubs of which some of the people on the Harbor Commission making the recommendation are
members of.
The CEQA findings provided on staff report pages 10-4 and 10-5, and partially repeated in
Section 6 of the proposed ordinance on page 10-12, and Section 5 of the proposed resolution
on page 10-16, seem questionable. The first on page 10-4 applies to existing structures, but this
appears to be a plan to permit new structures. Most of the remainder say the action will not
result in an expansion of use. But that seems exactly the purpose, and nothing I can find in the
proposal limits how extensive the expansion could be. Indeed, it would appear the City could
approve the expansion of the entire single anchor mooring fields to this configuration if the yacht
clubs requested it.
Coastal Act Consistency
It might also be noted that the new standards state "The MVMS shall adhere to all provisions for
harbor structures as stated in NBMC Title 17 including, but not limited to, maintaining
appropriate measures to deter sea lions from boarding the MVMS" and refer to the amended
criteria as "a standard for the design of structures in Newport Harbor."
The choice of the term "structures" is both appropriate and significant, for the floats in question
are clearly structures rather than vessels. What the staff report does not mention is that the
placement of structures in the Coastal Zone is regarded as development that normally requires
a Coastal Development Permit. And when the structure is placed in the California Coastal
Commission's area of retained jurisdiction (which most all of the harbor is) the City's role is
normally limited to the issuance of an approval in concept, with the CDP being considered by
the CCC.
Do any of the MVMS that have been deployed since 2006 have CDP's? Will future
MVMS's require them?
Title 17 Revisions
As to the substance of the proposed revisions to the Newport Beach Municipal Code shown in
redline on page 10-5, it is unclear why all the references to "Harbormaster" are being
replaced with "Harbor Department." Normally decisions are made by persons or
commissions, not by "departments," and the remainder of Title 17 is written that way. Why
January 25, 2022, City Council agenda comments - Jim Mosher Page 10 of 11
would this passage be any different? Who decides if a "department" has made a decision? And
can it be appealed?3
Harbor Design Criteria Revisions
As to the proposed changes to the Harbor Design Standards (Criteria?), the standards
themselves seem a strange mix of actual design standards interspersed with operational
regulations that would seem to belong more logically in the NBMC. For example, Vessel
"Rafting" at the top of page 10-30 is entirely an operational regulation, not a design standard at
all. The MVMS "standards" are a similar mix.
Moreover, the entire Harbor Design Standards document has an odd structure as indicated by
the Table of Contents on pages 10-21 and 10-22. For example, the entirety of Section "I.
WATERSIDE DEVELOPMENT" falls under the single subheading "A. DOCKS." That is, there is
no subheading "B." Why is this and what is the point of subheading "A"?
And in reference to my earlier comment, while this document refers to approvals by various
departments, that is not the style in Title 17.
That said, the proposed insertion of a new Subsection I.A.6.e, as presented on pages 10-15 and
10-16, is very poorly written:
1. For example,
"Multiple Vessel Mooring System (MVMS) allows multiple vessels to be secured to a
floating platform which is secured to a single anchor mooring system in Newport
Harbor. This allows multiple vessels to side -tie to the floating platform therefore
increasing vessel capacity at a mooring location. The intent of the MVMS is to provide
increased small -boat storage at a mooring location within the single anchor mooring
fields."
is not only ungrammatical, but it contains many repetitive phrases for no obvious
purpose. It could presumably be condensed without loss of meaning to:
"A Multiple Vessel Mooring System (MVMS) is a floating platform secured to a single
anchor mooring in Newport Harbor that allows multiple vessels to side -tie to it,
increasing vessel storage capacity at the mooring location."
2. Similarly, proposed Subsection I.A.6.e.3.(e) says: "Coolers, benches, furniture, boat
covers, trash, debris, or other items shall not be used or stored on the MVMS at any
time." What does "using trash" mean? And is this intended to prohibit storing a cooler or
boat cover in the dock box?
3 Note further that NMBC Sec. 17.65.010 provides only "for the appeal or call for review of the decisions
of the Public Works Director, the Community Development Director, Risk Manager, Harbormaster and
Harbor Commission under this title." There is no mechanism in Title 17 for the appeal or call for review of
decision made by the "Harbor Department."
January 25, 2022, City Council agenda comments - Jim Mosher Page 11 of 11
Mooring Specification Changes
Finally, the staff report includes an Attachment F (Offshore Mooring Specifications) on pages
10-81 and 10-82. Since nothing about this is referenced in the Recommended Action on page
10-1, the Council does not appear to be asked to approve this. Who has the authority to make
the changes shown?
Item 11. Resolution No. 2022-10: Adopting the 2022 Key and
Management Compensation Plan for the Period January 1, 2022,
through December 31, 2025, and Amending the City's Salary Schedule
Will the adoption of this resolution in any way, directly or indirectly, affect the benefits for which
the City Council members are eligible?
Item 12. Third Amended and Restated Employment Agreement for
City Manager
The Discussion in the staff report is not clear as to which of the highlighted provisions are
changes from the existing contract, nor is it easy to discover this.
The City's website continues to have a City Budget & Salary Information page that formerly
linked to the contracts of the City Manager and other major employees, but it no longer contains
that salary information. Instead, those links are now on a separate Human Resources Employee
Contracts page not linked to from the "Salary Information" page.
Among the changes not clearly disclosed it appears the severance benefit has been increased
from six month's pay to eighteen month's pay.
One thing that has not changed is the Section 3.D provision allowing the Council to set annual
goals for the City Manager.
It seems strange to me that the public does not know what those goals are. There seems no
public policy justification for keeping them secret. By contrast, see, for example, Item E.5 from
the Costa Mesa Sanitary District's January 24, 2022, agenda, in which their Board will be
publicly reviewing their General Manager's 2021 Performance Goals.