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HomeMy WebLinkAboutMaterials Rec'd After PacketFrom: robert rush [ mailto:rrush @usrealtygroup.com] Sent: Wednesday, June 02, 2010 1:30 PM To: rhawkins @earthlink.net; emcdaniel @sunwestbank.com; cwunsworth @roadrunner.com; eaton727 @earthlink.net; BHillgren @HighRhodes.com; scott.peotter @taxfighter.com; strataland @earthlink.net; Mulvihill, Leonie; Rowen, Kyle; Olson, Gaylene; Alford, Patrick; Lepo, David Cc: Henn, Michael; Kiff, Dave Subject: June 3rd Planning Com Hearing - Morningside Zoning Agreement Recommendations On June 3rd you will be hearing the matter of the Morningside Zoning Agreement, which is for the Public Benefit. But there are some areas in this Draft that need to be improved upon and can be by incorporating the following recommendations, as respectfully submitted herein: 1) IMPROVED COMPLIANCE VERIFICATION: a) The Morningside Agreement provides no meaningful, independent verification of "Client Caps" by the City. The Agreement proposes the City only inspect Rehab Facilities during business hours, when "Clients" are out of the house and relies upon extensive secondary and labor intensive techniques to verify compliance after the semi - annual rehab reports are received. The Agreement ignores "Bed Count" leaving Rehabs free to stack as many beds in a home as they want, without risking non - compliance. "Clients" pay up to $20,000 /mo for bed, food & therapy. A Rehab adding 1 extra "Client" over "Cap" at its 6 facilities can raise over $120,000 /mo more revenue or over $1 million /year — great incentive to violate "Client Caps." This becomes especially problematic since the periodic Morningside - generated reports, required by the City, don't appear easily or frequently validated once received, which is only a scant 2 times per year. Attempting to control the City's exposure to rehab over - concentration using a singular measuring criteria such as "Clients" or "Beds," presents serious shortcomings related to independently and meaningfully verifying compliance, but a simple combination of criteria (dual criteria approach) can easily solve the dilemma. Combining the two most agreed -upon and recognizable criteria to form "Client- Beds" (Operator would have a 36 Client cap and 36 Bed cap) would solve the problem to obtaining meaningful and independent verification (when you can't verify bodies - verify beds, etc). The Community, who wants assurance "Caps" are adhered to, benefits, as does the City via reduced Enforcement man -hours that, in the absence of dual criteria approach, would be needed to follow -up using alternate, labor intense methods. b) Streamlining Compliance Reporting /Monitoring— Morningside's Exhibit 1: Operational Conditions spans 4 pages, however, Exhibit 3 Compliance Report Template that is required to be filed with the City (only 2 times /year) only addresses 1 criteria, Bed Count or Client Count — doesn't make sense. Why not create a Compliance Matrix Checklist that Operators would file QUARTERLY (compliance is critical month -to- month, but quarterly filing would suffice) using Operational Conditions detailed in Exhibit 1. Rehabs fill -out or check -off the columns and boxes and submit — Code Enforcement verifies against City records and quarterly random sites inspections. 21 TRIGGERING MOST FAVORED NATION CLAUSE: "Person Per Bedroom" clause (Page 18/25, Item 16, attached)" gives Morningside a 50% operational advantage in bed count verbedroom over SLBTS and will trigger the "Most Favored Nation" clause in SLBTS Zoning Agreement (Page 14/19, attached). In trying to address "Total Bed Count," SLBTS's "Most Favored Nation" clause, Provision A, was inarticulately worded and misconveys its intent. Instead is written in generality, stating "an allowance of a percentage increase in bed counts greater than 30% above the number operated by the Operator at the time of the agreement." If SLBTS argued Morningside got an operational advantage of a 50% increase in bed count operated per room — they'd be correct and so it will trigger the Most Favored Nation clause resulting in more debate on impact and more City legal costs. Illustrated: For 36 "Clients" SLBTS rents 18 bedrooms vs Morningside's 12 bedrooms — hence the City has created an Economic Disadvantage from Bed Counts, by virtue of Morningside's Person Per Bedroom clause. The City should REVISE the Morningside "Persons Per Bedroom" Clause to allow only 2 Persons Per Bedroom consistent with SLBTS's Agreement. "Sober Living shall maintain its present policy not to allow more than 2 clients in the facilities unless the size of the structure warrants a larger occupancy for any single bedroom." Morningside structures presently support 3 Persons Per Bedroom and the Revised Language allows for that. Bob Rush Community Member (EXHffiIT "A") ZONING IMPLEMENTATION AND PUBLIC BENEFIT AGREEMENT (Pursuant to California Government Code §§ 65864- 65869.5) This Zoning Implementation and Public Benefit Agreement (the "ZONING AGREEMENT ") is entered into on 12010, by and between the CITY OF NEWPORT BEACH, a charter city ( "CITY ") on the one hand, and MORNINGSIDE RECOVERY, LLC, ( "MORNINGSIDE ") on the other. The CITY and MORNINGSIDE are collectively referred to as the "PARTIES." I. Recitals A. The City Council hereby finds this ZONING AGREEMENT is consistent with the provisions of California Government Code §65867, the City of Newport Beach Municipal Code Chapter 15.45, and the City's General Plan. B. On .2010. the City's Planning Commission held a public hearing on this ZONING AGREEMENT, made findings and determinations with respect to this ZONING AGREEMENT, and recommended to the City Council that the City Council approve this ZONING AGREEMENT. C. On , 2010, the City Council also held a public hearing on this ZONING AGREEMENT and considered the Planning Commission's recommendations and testimony and information submitted by City staff, MORNINGSIDE, and members ofthe public. On 2010, pursuant to applicable state law (California Government Code §§ 65864 - 65869.5) and local law (City ofNewport Beach Municipal Code Chapter 15.45), the City Council passed its Ordinance No. finding this ZONING AGREEMENT to be consistent with the City ofNewport Beach General Plan and approving this ZONING AGREEMENT. II. Definitions The following terms when used in this ZONING AGREEMENT shall have the meanings set forth below: A. "BLOCK" shall mean an area that is bounded on all sides by streets. In the Peninsula Zone, a BLOCK length is 617 feet, which is the calculable median block length within the City ofNewport Beach's Nonstandard Subdivision Areas. B. "CITY" shall mean the City ofNewport Beach and its City Council. C. "CLIENT" (or "CLIENTS ") shall mean any persons residing at any MORNINGSIDE FACILITY for the purpose ofrecovering from drug and /or alcohol abuse. D. "CONTROL" (including the terms "controlling," "controlled by," and "under common control with, ") shall mean the possession, direct or indirect, ofthe power to direct or cause the direction ofthe management and policies ofa person, whether through the ownership of voting securities, by contract, or otherwise. E. "FACILITY" (or "FACILITIES ") is a residential unit used or occupied by persons in recovery from alcoholism and /or drug abuse. Facilities may be "licensed facilities" or unlicensed "sober living homes." As used in this AGREEMENT, all facilities constitute "residential care facility" uses within the context ofthe City's zoning ordinance. D. "GENERAL PLAN" shall mean the 2006 General Plan adopted by the City Council on July 25, 2006, by Resolution No. 2006 -76. The Land Use Plan ofthe Land Use Element ofthe General Plan was approved by Newport Beach voters in a general election on November 7,2006. E. "LICENSED FACILITIES" shall mean alcoholism and drug abuse recovery facilities licensed by the California Department of Alcohol and Drug Programs ( "ADP "). F. "PARTY" or "PARTIES" shall mean either the CITY or MORNINGSIDE or any ofMORNINGSIDE's affiliates or both, as determined by the context. G. "PROPERTY" or "PROPERTIES" shall mean MORNINGSIDE's facilities at 112 39th Street, 4823 A River Avenue, 4823 B River Avenue, 5015 A River Avenue, 5015 B River Avenue, and 29 Ima Loa Court in Newport Beach. Additionally, this AGREEMENT may apply to parcels not yet identified upon which MORNINGSIDE may operate facilities pursuant to this AGREEMENT in the future. Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 2 H. "SOBER LIVING HOMES" shall mean alcoholism and /or drug abuse recovery facilities that are not licensed by the ADP. I. "7- and - OVER" shall mean any FACILITY licensed by the ADP to house more than 7 persons in recovery for drug and/or alcohol abuse. III. Agreement A. Terms ofAgreement. This ZONING AGREEMENT allows MORNINGSIDE a vested right to the following: 1.) MORNINGSIDE may operate FACILITIES housing up to thirty - six (3 6) CLIENTS in Newport Beach pursuant to certain operational guidelines described more particularly in Exhibit attached hereto. Except as described in Section A (3), below, MORNINGSIDE may not exceed 36 CLIENTS in Newport Beach. 2.) MORNINGSIDE may house up to 30 ofits 36 total CLIENTS in the Newport Beach "Peninsula Zone." The Peninsula Zone is more particularly defined in Exhibit "2" attached hereto; 3.) MORNINGSIDE can exceed its 36 CLIENT maximum only by acquiring 7- and -OVER FACILITIES that have obtained use permits under Chapter 20.91A ofthe Newport Beach Municipal Code. 4.) MORNINGSIDE shall conduct its OPERATIONS in Newport Beach in conformance with the Operational Guidelines attached hereto as Exhibit "1." 5.) MORNINGSIDE will comply with the following dispersal and distancing requirements for its FACILITIES in Newport Beach: a. Only one (1) treatment home or sober living facility (licensed or unlicensed by ADP) is allowed per BLOCK, and no FACILITIES facing each other; Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 b. No FACILITIES (licensed or unlicensed by ADP) within 1000 feet ofelementary schools or large, licensed day -care facilities. B. Significant Public Benefits. The significant public benefits that this ZONING AGREEMENT provides include, but are not limited to, the following: 1.) Settlement and avoidance of litigation costs, including the continued expenditure of attorneys' fees; 2.) Preservation ofthe regulatory ordinance that was the subject matter ofthis lawsuit; 3.) Avoidance ofpotential federal administrative proceedings; 4.) A reduction and limitation on the size of residential care operation in Newport Beach, including a limitation on LICENSED FACILITIES; 5.) Dispersal ofLICENSED FACILITIES and SOBER LIVING HOMES to reduce the concentration thereof in the City's residential districts; 6.) The placement of operational controls on said FACILITIES to reduce the perceived negative impacts on the City's residential neighborhoods; C, General Plan Consistency and Zoning Implementation. This ZONING AGREEMENT and the regulations applied herein to MORNINGSIDE will cause the City ofNewport Beach's zoning and other land use regulations to remain consistent with the GENERAL PLAN. D. Warranties and Representations. Both PARTIES represent they have legal authority to enter into this ZONING AGREEMENT and the remainder ofthe agreements and documents that comprise the settlement documents herein, and that the necessary authorizations have been obtained, by resolution or other action, and that the persons whose names appear as signatories below were authorized to accept this ZONING AGREEMENT on behalfofthe PARTY under whose name they signed. Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 4 1.) Each PARTY specifically represents and warrants that it has the legal authority to enter into a ZONING AGREEMENT ofthe type and kind herein, and, 2.) The City ofNewport Beach represents and warrants that this ZONING AGREEMENT and the regulations applied to PROPERTY are: a. Consistent with the GENERAL PLAN for the City of Newport Beach and any Specific Plans that apply to the area in which any portion ofMORNINGSIDE's PROPERTIES are located, and; b. Consistent with the Local Coastal Land Use Plan ( "CLUP ") for the City ofNewport Beach and that the CLUP has been approved by the California Coastal Commission. E. Operation ofproperty; Applicable Reeulations. Other than as expressly set forth in this ZONING AGREEMENT, during the term ofthis ZONING AGREEMENT, the terms and conditions concerning the operation of the PROPERTIES, including but not limited to the permitted uses, density, intensity ofuse, and the location of buildings involved, shall be those set forth in the City ofNewport Beach's ordinances and regulations, and the City ofNewport Beach shall not prevent operation ofthe PROPERTIES in compliance with the applicable regulations and all other applicable laws and regulations in Section I, below. F. Vested Rights. During the term ofthis ZONING AGREEMENT, except to the extent the City ofNewport Beach reserves its discretion as expressly set forth in this ZONING AGREEMENT or in the applicable regulations and all other applicable laws and regulations specified in Section I, MORNINGSIDE shall have the vested right, within the limits and constraints ofthe applicable regulations, to conduct OPERATIONS ofLICENSED FACILITIES and SOBER LIVING HOMES at its PROPERTIES. In the event Ordinance 2008 -5 is repealed by action ofthe City Council ofthe City ofNewport Beach or the electorate, or if a court ofcompetent jurisdiction declares the Ordinance invalid or unenforceable, this AGREEMENT shall remain in full force and effect. G. Police Power. In all respects not provided for in this ZONING AGREEMENT, the City ofNewport Beach shall retain full rights to exercise its police power to regulate the operation ofresidential care facilities on the Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 PROPERTIES provided such powers are applied consistently with the provisions of state law and the terms ofthis AGREEMENT. H. No Conflictine Enactments. During the term ofthis ZONING AGREEMENT the City ofNewport Beach shall not apply to the PROPERTIES any City- adopted ordinance, policy, rule, regulation, or other measure relating to OPERATION ofthe FACILITIES to the extent it conflicts with this ZONING AGREEMENT. I. Reservations ofAuthority. Notwithstanding any provisions set forth in this ZONING AGREEMENT to the contrary, the laws, rules, regulations, and official policies set forth herein shall apply to and govern OPERATIONS at the PROPERTIES: 1.) Procedural Regulations. Then current procedural regulations relating to hearing bodies, petitions, applications, notices, findings, records, hearings, reports, recommendations, appeals, and any other matter ofprocedure shall apply to the PROPERTY, provided that they are adopted and applied Citywide. 2.) Consistent City Regulations. Newport Beach City ordinances, resolutions, regulations, and official policies governing development and building that do not conflict with the AGREEMENT, or where MORNINGSIDE has consented in writing to the regulations, shall apply to the PROPERTIES. 3.) Public Health and Safety. Any Newport Beach City ordinance, regulation, rule, program, or official policy of general application that is necessary to protect persons on the PROPERTIES or in the immediate community from conditions dangerous to their health or safety, shall apply to the PROPERTIES. The City of Newport Beach may unilaterally enact any ordinance, regulation, rule, program, or official policy ofgeneral application necessary to protect persons from conditions dangerous to their health of safety. J. No Agency. Neither PARTY is acting as the agent ofthe other in any respect. Each PARTY is an independent contracting entity with respect to the terms, covenants, and conditions contained in this ZONING AGREEMENT. This ZONING AGREEMENT forms no partnership, joint venture, or other association ofany kind. The only relationship between the PARTIES is that ofa government Momingside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 6 entity regulating the operation of private property by the owner or lessee ofthe property. K. Effective Date. This ZONING AGREEMENT shall not become effective, and except as set forth in subsection (1) ofthis Section, neither PARTY shall have any rights or obligations hereunder, until the "Effective Date." 1.) This ZONING AGREEMENT shall become effective on: a. The 91'1 day following the City Council ofthe City of Newport Beach's passage ofthe ordinance approving this ZONING AGREEMENT, or b. Ifa referendum or other elective challenge to the ordinance approving this ZONING AGREEMENT qualifies for the ballot, then on the 31,1 day after the City Clerk ofthe City of Newport Beach certifies that the referendum or other elective challenge has failed to pass, or C. I f litigation is initiated to challenge this ZONING AGREEMENT prior to the Effective Date established in accordance with Section K (1) (a), and (b), above, then on the 31,t day after the litigation has terminated, or the time for appeal has expired, and the legal challenge has been unsuccessful. 2.) The term ofthis ZONING AGREEMENT shall commence on the Effective Date and shall expire at the conclusion ofthe 25th year thereafter. However in no event shall the term ofthis ZONING AGREEMENT exceed thirty (30) years after its execution. 3.) Stay of Ordinance 2008 -5 Pending Effective Date. Prior to the effective date ofthe ordinance adopting this ZONING AGREEMENT, or that date upon which it becomes clear that there will be no Effective Date, whichever is later, the CITY shall not otherwise enforce the provisions ofOrdinance 2008 -5 against MORNINGSIDE or its AFFILIATES. L. Amendment or Cancellation ofthe Zoning Agreement. Other than modifications ofthis ZONING AGREEMENT under section I subsection (3) of this ZONING AGREEMENT, this ZONING AGREEMENT may be amended or Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 cancelled in whole or in part only by mutual written and executed consent ofthe PARTIES in compliance with California Government Code section 65868, and City ofNewport Beach Municipal Code section 15.45.070. M. Enforcement. Unless amended or cancelled as provided in Section L, above, or modified or suspended pursuant to California Government Code section 65869.5, this ZONING AGREEMENT is enforceable by either PARTY despite any change in any applicable GENERAL PLAN or Specific Plan, zoning, subdivision, or building regulation, or other applicable ordinance or regulation adopted by the City (including by the City's electorate,) that purports to apply to any or all ofthe PROPERTIES. N. Periodic Review ofCompliance. CITY and MORNINGSIDE shall each comply in good faith with the terms of this ZONING AGREEMENT. The PARTIES shall review this ZONING AGREEMENT at least once every 12 months from the Effective Date for good faith compliance with its terms, consistent with Government Code sections 65865 and 65865.1 and City of Newport Beach Municipal Code section 15.45.080. At the reviews, MORNINGSIDE shall document the current status of its OPERATIONS. MORNINGSIDE also agrees to furnish evidence of good faith compliance with this AGREEMENT as the CITY may require in the reasonable exercise of its discretion, and after reasonable notice to MORNINGSIDE. On or before December 31,t and June 30"' of each year during the term of this ZONING AGREEMENT, MORNINGSIDE shall submit a Compliance Review Report, whose template is attached hereto as Exhibit "3." The requirement ofgood faith compliance shall be met upon the submittal to the CITY of an accurate Compliance Review Report showing information relating to facility locations and the number ofCLIENTS at each MORNINGSIDE FACILITY. The CITY shall have the right to audit the accuracy ofthe Compliance Review Report through the on -site inspections ofMORNINGSIDE's FACILITIES at mutually agreeable times during regular business hours. O. Events ofDefault. 1.) Default by Morningside. Pursuant to California Government Code section 65865.1, if the CITY determines that MORNINGSIDE has not complied in good faith with its obligations pursuant to this ZONING AGREEMENT, the CITY shall by written notice to MORNINGSIDE specify the manner in which MORNINGSIDE has failed to comply and state the steps MORNINGSIDE must take to bring itself into compliance. If MORNINGSIDE does not commence compliance within thirty Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 (30) days after receipt ofwritten notice from the CITY specifying the manner in which MORNINGSIDE has failed to comply and diligently pursue steps to achieve full compliance, then MORNINGSIDE shall be deemed to be in default under the terms ofthis ZONING AGREEMENT. The CITY may then seek available remedies as provided in subsections (3) and (4), below. 2.) Default by City. Ifthe CITY has not complied with any of its obligations and limitations under this ZONING AGREEMENT, MORNINGSIDE shall by written notice to the CITY specify the manner in which the CITY has failed to comply and state the steps necessary for the CITY to bring itself into compliance. If the CITY does not commence compliance within thirty (30) days after receipt ofthe written notice from MORNINGSIDE specifying the manner in which the CITY has failed to comply and diligently pursue steps to achieve full compliance, then the CITY shall be deemed to be in default under the terms of this ZONING AGREEMENT. MORNINGSIDE may then seek a specific performance or similar equitable remedy as provided in subsection (3) of Section 0, below. 3.) Specific Performance and Damages Remedies. The PARTIES acknowledge that remedies at law are generally inadequate and that specific performance is appropriate for the enforcement of this ZONING AGREEMENT. The remedy of specific performance or, in the alternative, a writ ofmandate, shall be the sole and exclusive remedy available to either PARTY in the event of the default, or alleged default, by the other. Prior to exercising such a remedy, the PARTY seeking to do so shall submit the matter to non - binding arbitration through JAMS or another mutually acceptable arbitrator. 4.) Recovery of Legal Expenses by Prevailing Party in Any Action. In any judicial proceeding between the PARTIES that seeks to enforce the provisions of this ZONING AGREEMENT, the prevailing party shall recover all of its actual and reasonable costs and expenses. These costs and expenses shall include expert witness fees, attorneys' fees, and costs of investigation and preparation before the initiation of the action. The right to recover these costs and expenses shall accrue upon initiation of the action. Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 P. Cooperation. Each PARTY covenants to take all reasonable actions and execute all documents that may be necessary to achieve the purposes and objectives ofthis ZONING AGREEMENT. Q. Force Majeure. Neither PARTY shall be deemed to be in default where failure or delay in performance of any of its obligations under this ZONING AGREEMENT is caused, through no fault ofthe PARTY whose performance is prevented or delayed, by floods, earthquakes, other acts of God, fires, war, riots or other hostilities, strikes or other labor hostilities, state or federal regulations, or court actions. R. Third Party Legal Challenge. Ifa third party brings a legal action challenging the validity or enforceability of any provision ofthis ZONING AGREEMENT or the applicable regulations or the manner in which the ordinance approving this ZONING AGREEMENT was processed and approved, including the application ofthe California Environmental Quality Act ( "CEQA ") to that process, the PARTIES shall defend the third party challenge jointly, and each party shall be responsible for its legal expenses incurred in connection with the challenge, except that either or both parties may seek recovery of all legal expenses from the third party challenger. S. Right to Assign. MORNINGSIDE shall have the right to transfer or assign the rights and obligations contained herein in whole to any person, partnership, joint venture, firm, or corporation at any time during the term ofthis ZONING AGREEMENT without the consent ofthe CITY. Upon the effective date of any such transfer or assignment, the transferor - assignor shall notify the CITY ofthe name and address ofthe transferee. Any assignment ofthis ZONING AGREEMENT must be pursuant to a sale or transfer ofMORNINGSIDE's rights in their entirety. Any sale or transfer ofthe PROPERTY shall include the assignment and assumption ofthe rights, duties, and obligations arising from this ZONING AGREEMENT to the transferee with respect to all ofthe PROPERTIES. MORNINGSIDE shall no longer be obligated under this ZONING AGREEMENT for the PROPERTY ifMORNINGSIDE is not in default under this ZONING AGREEMENT at the time ofthe sale or transfer. T. Zoning Agreement Binding on Successors and Assigns. The burdens ofthis ZONING AGREEMENT are binding upon, and the benefits ofthis ZONING AGREEMENT shall inure to, all successors in interest ofthe parties to this ZONING AGREEMENT. Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 10 U. Estoppel Certificate At any time, either PARTY may deliver written notice to the other PARTY that the PARTY certify in writing that, to the best of its knowledge: 1.) This ZONING AGREEMENT is in full force and effect and is binding on the PARTY; 2.) This ZONING AGREEMENT has not been amended or modified either orally or in writing. Ifthis ZONING AGREEMENT has been amended, the PARTY providing the certification shall identify the amendments; and, 3.) The requesting PARTY is not in default in the performance of its obligations under this ZONING AGREEMENT. Ifthe requesting PARTY is in default, the other PARTY must describe the nature ofthe default. The requesting PARTY shall execute and return the certificate within sixty (60) days following receipt. Any assignee ofa PARTY's rights and obligations hereunder, as referred to in this Section, shall be entitled to rely on the certificate. V. Further Actions and Instruments. Each PARTY shall cooperate with and provide reasonable assistance to the other PARTY to the extent consistent with and necessary to implement this ZONING AGREEMENT. Upon the request ofa PARTY at any time, the other PARTY shall promptly execute, with acknowledgement or affidavit ifreasonably required, and file or record the required instruments and writings and take any actions as may be reasonably necessary to implement this ZONING AGREEMENT or to evidence or consummate the transactions contemplated by this ZONING AGREEMENT. W. Notices. Any notice or demand that shall be required or permitted bylaw or any provision of this ZONING AGREEMENT shall be in writing. Ifthe notice or demand will be served upon a PARTY, it shall be personally served to the PARTY; deposited in the U.S. Mail, certified, return receipt requested, and postage prepaid; or delivered by a reliable courier service that provides a receipt showing date and time of delivery with courier charges prepaid. The notice or demand shall be addressed as follows: To City: City ofNewport Beach 3300 Newport Boulevard Post Office Box 1768 Newport Beach, California 92663 -3884 Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 11 Attn: City Manager Fax: 949-644-3020 With a copy to: City Attorney City ofNewport Beach 3300 Newport Boulevard Post Office Box 1768 Newport Beach, California 92663 -3884 To Operator: Momingside Recovery, LLC 3404 A Via Lido Newport Beach, California 92663 (949) 675 -0006 With a copy to: Mary Helen Beatificato Beatificato & Associates, APC 28562 Oso Parkway, Ste. D -424 Rancho Santa Margarita, California 92688 Either PARTY may change the address stated in this Section by notice to the other PARTY in the manner provided in this Section, and notices shall be addressed and submitted to the new address. Notice shall be deemed to be delivered upon the earlier of (a) the date received; or (b) three business days after deposit in the mail as provided above. X. Rules of Construction and Miscellaneous Terms. I.) Rules ofConstruction. The singular includes the plural; the masculine and neuter include the feminine; "shall" is mandatory; "may" is permissive. 2.) Time is ofthe essence. Time is ofthe essence regarding each provision ofthis ZONING AGREEMENT in which time is an element. 3.) Waiver. Failure by a PARTY to insist upon the strict performance of any ofthe provisions of this ZONING AGREEMENT by the other PARTY, and failure by a PARTY to exercise its rights upon a default by the other PARTY, shall not constitute a waiver ofthat PARTY's right to demand strict compliance by the other PARTY in the future. Momingside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 12 5.) Counterparts. This ZONING AGREEMENT may be executed in two or more counterparts, each ofwhich shall be identical and may be introduced in evidence or used for any other purpose without any other counterpart, but all ofwhich shaH together constitute one and the same ZONING AGREEMENT. 6.) Entire Agreement. Except for the Settlement Agreement, this ZONING AGREEMENT constitutes the entire agreement and supersedes all prior agreements and understandings, both written and oral, between the PARTIES with respect to the subject matter addressed in this ZONING AGREEMENT. 7.) Construction. This ZONING AGREEMENT has been drafted after extensive negotiation and revision. Both the CITY and MORNINGSIDE are sophisticated parties who were represented by independent counsel throughout these negotiations. The CITY and MORNINGSIDE each agree and acknowledge that the terms of this ZONING AGREEMENT are fair and reasonable, taking into account their respective purposes, terms, and conditions. This ZONING AGREEMENT shall therefore be construed as a whole consistent with its fair meaning, and no principle or presumption of contract construction or interpretation shall be used to construe the whole or any part of this ZONING AGREEMENT in favor of, or against, either PARTY. 8.) No Third Party Beneficiaries. The only parties to this ZONING AGREEMENT are the CITY and MORNINGSIDE. This ZONING AGREEMENT does not involve any third party beneficiaries, and it is not intended and shalt not be construed to benefit or to be enforceable by any other person or entity. 9.) Applicable Law and Venue. This ZONING AGREEMENT shall be construed and enforced consistent with the internal laws ofthe State of California. Any action arising under this ZONING AGREEMENT or brought by any PARTY for the purpose of enforcing, construing, or determining the validity of any provision ofthis ZONING AGREEMENT shall be filed and tried in the Superior Court of the County of Orange, State of California, or the United States District Court for the Central Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 13 District ofCalifornia. The PARTIES waive all provisions of law providing for the removal or change of venue to any other court. 10.) Section Headings. All section headings and subheadings are inserted for convenience only and shall not affect construction or interpretation ofthis ZONING AGREEMENT. 11.) Authority to Execute. The persons executing this ZONING AGREEMENT warrant and represent that they have they have the authority to execute this ZONING AGREEMENT on behalf of the entity for which they are executing this ZONING AGREEMENT. They further warrant and represent that they have the authority to bind their respective PARTIES to the performance of its obligations under the ZONING AGREEMENT. CITY: CITY OF NEWPORT BEACH In Keith D. Curry Title: MAYOR ofNewport Beach MORNINGSIDE RECOVERY, LLC C JEFFREY YATES Title: President MORNINGSIDE RECOVERY. LLC By: CANDACEBRUCE Title: ChiefExecutive Officer Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 14 APPROVED AS TO FORM: By: Leonie H. Mulvihill Title: ACTING CITY ATTORNEY CITY OF NEWPORT BEACH ATTEST: By: _ Leilani Brown Title: CITY CLERK CITY OF NEWPORT BEACH Morningside Recovery, LLC Zoning Agreement Exhibit "A" to Settlement Agreement 1193897 -7 15 Exhibit "1" to Zoning Agreement .i City ofNewport Beach Momingside Recovery, LLC EXHIBIT "1" OPERATIONAL CONDITIONS for MORNINGSIDE RECOVERY, LLC Occupancy Level. The operator of Momingside Recovery, LLC, hereinafter referred to as "Operator," is limited to housing a total of thirty-six (36) clients in recovery from drug and alcohol abuse in the City of Newport Beach, and shall limit occupancy ofits current facilities to the following: a. 4823 A River Avenue - 6 client maximum b. 4823 B River Avenue - 6 client maximum c. 5015 A River Avenue - 6 client maximum d. 5015 B River Avenue - 6 client maximum e. 1123 9th Street - 6 client maximum f. 29 Ima Loa Court - 6 client maximum The above occupancy levels reflect a maximum of thirty (30) clients in the Peninsula Zone and a maximum of six (6) outside of the Peninsula Zone. The boundaries of the Penirisula Zone are more particularly defined in Exhibit "2" of the corresponding Zoning Agreement. Operator may move clients from the above properties into other properties but must maintain the 30 client cap in the Peninsula Zone and 36 total client cap citywide, provided that Operator maintain the dispersion standards in Section III A, subsections 5 (a) & (b) of the Zoning Agreement. 2. Staffing. Operator shall have enough staff to appropriately and responsibly manage each facility; including at least one qualified manager on -site or on -call at all times (24 hours a day, seven days each week). 3. Governmental Referrals. Operator shall not provide any services to any client or house any client who has been referred or caused to be referred to a Momingside Recovery facility by any governmental agency, including but not limited to probationers or parolees, due to the limitations that Section 509.9 ofthe California Building Code places on Group I and R occupancies. 11287 - 0007 \1204428v1.doc Exhibit "2" to Settlement Agreement City ofNewport Beach Momingside Recovery, LLC 4. Assembly Uses. Assembly uses are prohibited in these facilities, except those that are limited solely to client residents of the facility and facility staff (and in some cases smallmeetings ofa client's family members with facility staff). 5. Medical Waste. Any and all medical waste generated through the operation of the facility shall be disposed of in accordance with the City of Newport Beach's Municipal Code, all other laws and best industry standards and practices. 6. Trash and Trash Enclosures. Operator shall comply with City code provisions pertaining to trash enclosures, and if directed by the Planning Director, shall secure and maintain commercial bin service at the subject properties. Operator shall provide a sufficient number of plastic trash cans with sealable covers to contain all ofthe refuse generated by the facility, which are to be used at all times. Trash cans shall be put out for pick up no earlier than 7:00 p.m. and before 8:00 p.m. on the evening before trash collection day, and shall be put back within the property by 6:00 p.m. on the day of collection. 7. Smoking and Tobacco Products. Per NBMC Section 20.91A.050(A), no clients, guests, or any other users of the subject. property may smoke in an area from which the secondhand smoke may be detected on any parcel other than the parcel upon which the use is located. Operator shall use its best efforts to contain secondhand smoke generated by patients, clients, customers, and staff within the lot line of the subject property. In addition, Operator will not allow clients, staff, or residents to litter cigarette butts on the ground, floor, deck, sidewalk, gutter, boardwalk or street. Operator's administrators and managers shall use their best efforts to ensure that its clients comply with the City's prohibition on clients' tobacco use on beaches, boardwalks, and piers(NBMC §11.08.080). This includes any meetings Morningside's clients participate in "off- site." 8. Parking. Operator shall keep garages and other parking spaces at its facilities open and available for parking for staff, and visiting family members' vehicles, cleaning persons' vehicles, and client transport vans at all times. Clients to the facility are not permitted to have personal vehicles at the facility. 9. Client Transport. Operator shall ensure that loading and unloading of passengers of the facility's transportation van shall occur only in open parking spaces or garage spaces. The van driver is prohibited from stopping or double - parking. in a traffic lane to load and unload passengers. In addition, client drivers shall respect all City rules regarding parking and /or stopping and waiting to load residents. Client transport vehicles shall not block adjacent alleys or street ends. Client drivers shall not leave vehicles in reverse gear if reverse has an audible back -up 112870007 \1204428v1.doc Exhibit "2" to Settlement Agreement City ofNewport Beach Morning-side Recovery. LLC warning sound. Client drivers shall speak to residents at a level protective of neighborhood peace, cognizant ofthe hour, to avoid waking neighbors. 10. Profanity and Lewd Behavior. Operator shall not tolerate lewd behavior, lewd speech, or profanity at the subject property. Profanity at a level audible to neighboring residents may result in an administrative citation issued by the City upon the property owner and operator. 11. Noise. Operator shall strictly adhere to the City's noise standards (NBMC- § 10.26.025; 10.26.030). Operator shall be responsible for minimizing clapping, stomping, or other noises at meetings or gatherings at the subject property, consistent with NBMC § 10.26.030. 12. Route Plans. Operator shall adhere to the Route Plans for transport of its staff, residents, clients, and customers. The Route Plans for all Momingside facilities are attached hereto as "Exhibit 4." Short-term interruptions, such as medical emergencies or street maintenance beyond Operator's control, are allowable modifications to the Route Plans. 13. Deliveries. Staff members in their private vehicles may deliver business products and other packages and goods to the facility during weekdays between the hours of9:00 a.m. to 5:00 p.m. 14. Hotline. Operator shall establish, provide public notice of, and operate a hotline for receiving inquiries and/or complaints in reference to its operation ofits facility. The phone number need not be staffed 24 hours a day seven days a week, but callers should be responded to within the next 24 -how period. Alternatively, the Operator shall provide area residents and the City with a contact name, phone number, and e -mail address that is available 24 hours a day, seven days each week. This contact shall be available to assist residents and the City with any problems or concerns arising from the facility. E -mails or messages left for the Operator's designated contact shall be returned promptly within a 24 -hour period from receipt. 15. Stakeholder Group. Upon invitation by the City, Operator shall participate in the activities of any stakeholder committee or group established by the City to address complaints and concerns of residents of the City regarding the operation of Residential Care Facilities in the City. 16. Persons per Bedroom. Operator shall not allow more than three clients to sleep in one bedroom. 11287- 0007 \120442gvLdoc Exhibit "2" to Settlement Agreement City ofNewport Beach Momingside Recovery, LLC 17. Building and Zoning. Operator recognizes that each of its facilities have specific setbacks from the side yards, front yard, and/or back yards per the City's Building and Zoning Codes. Operator will keep these setbacks clear of obstruction, including building obstruction. The orderly storage oftrashcans is acceptable in setbacks. 18. Facility Nuisances. The subject properties shall not be unsafe, unsightly or poorly maintained. If Operator receives a nuisance violation from the City in regards to any of these issues, Operator. shall correct the violation within seven days or contact the City directly to negotiate a mutually agreeable timeline. 19.' Beaches and Other Common Gathering Areas. Operator's use of the beaches for meetings, prayer, conversation, or other gatherings shall show due respect to non - resident visitors, residents, and other beachgoers, thus allowing them to take full enjoyment ofthe beach. Operator shall not conduct business on the beach (per NBMC §10.08.030). 20. Federal, State and Local Laws. Operator shall comply with all federal, state, and local laws. The issuance ofthis use permit shall not constitute a waiver ofthe requirements of any federal, state or local law, including the requirements of the California Building Code. 21. Affidavit of Disability. The Operator shall execute an affidavit declaring that all clients receiving services from this facility are disabled persons, as that term is defined by federal and state fair housing laws. 11287- 0007 \1204428v l .doe Exhibit "2" Depiction and Description of'Peninsula Zone" Depiction of Peninsula Zone: Description of Peninsula Zone: Starting at the mouth of the Santa Ana River: o The land area southerlybf the Newport and seminouk'Sloughs known as Newport Shores, and o . The land coastword ofPoft Coast Highway to Newport Boulevard known as Balboa Coves, West Newport Beach, lido Sands, and Newport Island; and o The land southerly ofa.line extending along the Federal Navigational Channel between Newport Boulevard and the Newport Haibor Jetty, known as the Balboa Peninsula. Lido Peninsula, Lido Isle, Bay Island, and Cannery. Village; a " d o Southward on Newport Boulevard. about 50 feet to Lower Newport Bay; and • All lands southedy of Lower Newport Bay be.tween Newport Boulevard down the Federal Navigational Channel within the Lower Bay, inclusive of Lido Isle and Bay Island and inclusive of the Balboa Peninsula, Exhibit" 3 'I to the Zoning Agreement Compliance Report Template (Date Report Submitted) This form covers the period of (month, day) through (month, day), 20 During-the above period, Momingside Recovery, LLC, managed or controlled the following facilities in Newport Beach: . _.__.i3289;i067h32f3'1- _. Morningside Recovery Travel Routes (draft #1) I NOTES: 1-With! n the boundaries of the above chart, Morningside's Client Transport routes are limited the following streets, except during emergencies or if approved routes are closed: Balboa Boulevard Newport Boulevard River Avenue (only between 5V Street and Balboa Boulevard — not the section of River Ave between 45th and 32nd Street) 32"d Street Coast Highway 2 - The General Rule for Morningside's Client Transportvans shall be that Morningside shall use major thoroughfares (Newport Boulevard and Balboa Boulevard) whenever possible, avoiding narrow neighborhood streets such as River Avenue between 45`h and 32nd Street). 3 —Access to Morningside's facility at 112 39th Street shall be from 39`h Street, 40th Street or 381h Street, and Seashore Drive. 4 —The City and Morningside shall work cooperatively to amend these routes whenever Morningside moves a facility. Attachment No. PC 4 Residential Care Facilities: Licensed and Unlicensed w NZ j L _ I 1 �t yG m_ _qo LL V u Ay e � 10 m v � J #6#'�dEEOdE¢¢ 1��3��313 dl:F �J�F99��a • 3i 3 s 5f 'Aif F9 y _L _ .. L _ I 1 �t yG m_ _qo LL V u Ay e � 10 m v � J #6#'�dEEOdE¢¢ 1��3��313 dl:F �J�F99��a • 3i 3 s 5f 'Aif F9 y Zoning Agreement Pogo 130119 (til Apply a policy directing clients or residents to avoid littering cigarette butts on the ground, floor, deck, sidewalk, gutter, or street. (c) Apply a policy reminding clients not to use tobacco on beaches, boardwalks, and piers consistent with City prohibitions against smoking in those areas. 5. Sober Uving shail comply with all City code provisions requiring 011 street parking In residential zones. 6. Sober Uving shall establish, provide public notice of and continuously operate a 24 hour per day hotline for receiving inquiries and /or complaints In reference to ils operation of its Facilities in the City. 7. Sober Uving shall apply the foilowing Quiet Hours to its patients, clients and customers occupying beds in ail Facilities which Sober Uving operates In the City. During these Quiet Hours, all residents will be Inside except during emergencies: Sunday through Thursday - 10 pm to 7 am; Friday through Saturday - 11 pm to 7 am. 8. Sober Living shail use good faith efforts to implement the Roule Plans for transport of its staff, residents, clients and customers which Sober Living submitted to the City as part of its applications for Use Pennits on file with City's staff as of July, 2008. A true and correct copy of those Route Plans are attached as Exhlb /1 F. Short-tenn interruptions, such as medical emergencies or street maintenance which are beyond Sober Living's conk . are allowable modifications to the Roule Plans. 9. Sober Living shail accept deliveries of goods and services to the Residential Care Facilities which it operates in the City only during customary times for such deliveries of goods and services to ooeur in residential areas of the Cily and in accordance with any City regUlation adopted which controls times for such deliveries on a citywide basis applicable to all residential properties. 10. Sober Living shall participate in the acWtiles of any stakeholder committee or group established by the City to address complaints and concerns of residents of the City regarding the operation of Residential Care Facilities in the City. 11 . Sober Living shall maintain its present policy not to allow more than two (2) clients per bedroom in the facilities unless the size of the structure warrants a larger occupancy for any single bedroom. C. General Constraints on Regulallon. 1. Most Favored Nation. it the City enters into an agreement with any operator of a Sober Uving Home or Licensed Facr�ty in the City which, includes one or more of the below three provisions and provides a materially more favorable regulatory treament to that operator than is afforded to Sober living hereunder, the more favorable regulatory provision or provisions shall then apply to Sober Living and shail be deemed to supersede any conflicting provision or provisions contained in this Zoning Agreement. Approvals within the Group Residential Uses Ordinance's Use Pennit process do not constitule agreements for the pUtpOses of this paragraph. Zoning Agreement Psge 14 of 19 The three provisions are: (a) An allowance of a percentage increase greater in bed counts greater than 30% above the number operated by the Operator at the time of the agreement; (b) Dispersion (i.e. one building per block and no faCiides on streets facing each odwr) less concentrated than for SLBTS under the tenns of this Agreement; and (c) Distancing from public elementary schools and large licensed day care thal Is less than for SLBTS under the tenns of this Agreement. 2. The City shall respect and adhere to the exemption in California Health and Safety Code §11834.23 that directs that the City apply the same building, fire, and other related codes to Facilities with six or fewer clients as It does for any single - family residential property provided that: (al The exemption Is not repealed or otherwise Invalidated by an appellate court decision; (b) The exemption is being applied to a single family dwelling unit (including condominiums) or a duplex; (c) SLBTS does not place non - ambulatory residents in their facilities; and (d) SLBTS does not accept referrals or placements within a St.BTS home for protective social care and supervision services by any governmental agency. 3. This Agreement, and, more specifically, these Applicable Regulations obviate the need for and shall supersede the processing or issuance of any Use Permit or Use Pennits concerning Sober Living's operations in the City. WEST NEWPORT BEACH ASSOCIATION P.O. Box 1471 Newport Beach, California 92663 www.westnewport.org PruyidenG Grain Bo tie c I hserrlee (hrners liaison 941293--0630 June 1, 2010 Vice President: 57ruron Boles Superior Ave. Liaison 949615 -4752 Secre[arvlhrem8ership; Via Email and Nand Delivery Lido Peninsula Resort 9491042 -3125 Robert Robert Hawkins, Chairman 9193466 -0605 949146&0605 Ken Brvant and Planning Commissioners 7'reasorerr City of Newport Beach ivpra 3300 Newport Boulevard .Ve Neivpori Shores Shores Newport Beach. Subsequent to the passage of the Sober Living Development 9491042 -5843 Newport Beach, California 92663 Hi.vurianr Mike dohnson Subject: Morningside Zoning Agreement West Oreanfrom 9491042 -3125 Dear Chairman Hawkins and Planning Commissioners: Directors: Ken Brvant As many of you know, the Board of Directors of the West Newport Beach klanaeredStreets Association ( "WNBA") has been an avid participant in the debate and eventual 9491644.6266 passage of the current ordinance regulating Drug Rehab Operators in the City of Morn ➢ryanr Newport Beach. Subsequent to the passage of the Sober Living Development ^'amnered$Ire4 "S Agreement, the City has apparently entered into a Zoning Settlement Agreement 949,'644 -6266 with Morningside. Mon. Fger Seashore Drive At first glance, WNBA. has two concerns with the agreement as presently 9491887 -()554 configured. Both concerns are focused on the long -term public benefit for k'icolai Glair residents of West Newport Beach. Riwr Aeuae 949/306 - 433? first, one of the objectives of Zoning Agreement is control the numbers of rehab ✓Inr wider patients or "clients" served by Morningside by capping the maximum number of ,Y ,eporl Island clients served during any given time period. However, the WNBA is concerned 9401Y.7-3-7827 about the City's true ability to enforce the client caps due to the absence of any .Inn OTIMnn meaningful, independent methods to verify Morningside's compliance. This is eart,aaeeees especially problematic since the periodic Morningside - generated reports, required 9490345 -8233 by the City, also do not appear to be able to be validated once received by the Rvere,fe phraips City. 9'eupari .Shores 9491650-7528 The City's ability to verify compliance with this Agreement appears to be limited to Robed Rush inspections which would be carried out "...at mutually agreeable times during RieedNepame regular business hours." Namely, the only times verification occurs is during the 949;515 -2977 hours when clients are likely to be out of the home at work or at treatment George Schroeder sessions. This fact renders such City - recommended inspections virtually ,vi<mhered s,n:cry meaningless. How does the city purport to count clients when clients are not on 9191846 -2628 site or in their beds? Pau! lirarkins 11'esl oceonfronl 711/556 -0800 Morningside Zoning Agreement June 1, 2010 Page 2 Secondly, we are also concerned about the limitation of three "clients" per bedroom. This is a significantly less restrictive provision than was incorporated in the similar Sober Living's Zoning Agreement which was 2 "occupied beds" per bedroom — with no explanation for the difference. And this difference is unusual since Morningside and Sober Living utilize the same types of residential duplex structures for their operations. More importantly, under Provision A of the "Most Favored Nation" clause of the Sober Living Zoning Agreement, it appears that they (Sober Living) will be entitled to use this less restrictive provision thereby significantly expanding Sober Living existing bed -count caps in the 'Peninsula Area. Why is the City increasing the Morningside "occupied beds" count by 50 %, from 2 to 3 (1/2 = 50 %)? It is our hope the planning commission will focus on these two WNBA concerns with the intent of recommending revisions to the proposed Morningside Settlement Zoning Agreement. At the very minimum, please delay approval of this agreement until further deliberation, study and additional community public hearings are conducted. Very truly yours, Craig Batley President West Newport Beach Association cc: Newport Beach City Council Members From: Barry Eaton [mailto:eaton727 @earthlink.net] Sent: Wednesday, June 02, 2010 8:13 PM To: McDaniel, Earl; Charles Unsworth Subject: [Fwd: Planning Commission Meeting June 3, 2010] -- - - - - -- Original Message -- - - - - -- Subject:Planning Commission Meeting June 3, 2010 Date:Wed, 2 Jun 2010 18:05:41 -0700 (PDT) From:cynthia koller <aracenbI(&,yahoo.com> To:Robert Hawkins <rhawkins(dearthlink.net>, Susan/Barry Eaton <eaton727kearthlink.net>, Scott Poetter <scott.peottergtaxfighter.com >, bhillgren(ahighrhodes.com, Earl McDaniel <emcdaniel(a,fullertoncb.com >, Michael Toerge <stratalandna earthlink.net> FOR THE RECORD and DISBURSEMENT ATTENTION PLANNING COMMISSIONERS: Robert Hawkins, Scott Peotter, Earl McDaniel, Michael Toerge, Barry Eaton, Bradley Hillgren, Charles Unsworth REFERENCE: MORNINGSIDE RECOVERY DEVELOPMENT AGREEMENT GENTLEMEN: I would like to preface this request by stating I /we are not against legitimate recovery. As I address this letter to you in my home the time is 7:57 am, I just watched and heard a speeding Momingside van come down River and take the corner at 39Th and River so fast she /he went up my curb on River and then the sound of the tire coming off the curb on 39Th as they sped to cross Balboa. I guess they were late. This happens daily at all different times AND IS EXTREMELY DANGEROUS. As I have been a constant target of harassment and intimidation from Momingside employees and their clients ( which I have documented at City Council Meetings and on city emails) from the time I first started to represent the residents of the peninsula to the city I am still amazed at the arrogant display of complete contempt for me, my family and my neighbors which in essence is against you as well. My understanding from Dave Kiff is they ARE NOT to be using 39Th on the 200 block or this end of River. I have several questions that I would like answered for the public. 1. page 34 item G. In all respects not provided for in this ZONING AGREEMENT, the city of Newport Beach shall retain full right to exercises it's police power to regulate the operation of residential care facilities on the PROPERTIES provided such powers are applied consistently with the provisions of state law and the terms of this agreement. a. How does law enforcement police these homes with "full right" when the people in these homes are considered disabled and what special rights are they the "clients afforded because of this status? b. In the past on several occasions the residents of 39Th St. have seen several rehab "clients" become violent and break into homes in our neighborhood only to be handed over by the police to a "third party" and taken back to the home they were being treated in. What is the exact protocol of the police dept in these types of situations as we have been told differently by the City, Robin Clauson, the City Council and the police? c. Is the City currently triangulating with law enforcement, paramedics and fire as Robin Clauson stated at the IROC meeting to me and all attending? d. If not why not and will triangulation begin the departments be a implemented city policy. 2. page 37, item N The requirement of good faith compliance shall be met upon the submittal to the city of a accurate compliance review report showing information related to the facility locations and number of CLIENTS at each MORNINGSIDE FACILITY. a. Who in the city will be in charge of the audit and how will they determine if Morningside is complying on a day to day basis for the protection of the community? b. Why would the city let one of the most egregious operators operate in "in good faith" when they have never followed the rules of the city up and to this point in time? 3. page 39, item R Third party challenge. a. Could you explain why it is that the City, who works FOR THE RESIDENTS is taking the stand in this zoning agreement that if the residents were to sue Morningside, THE CITY would fight against the people (the residents) who they are suppose to represent? 4. page 42, item 6 Entire Agreement. Except for the Settlement Agreement, this ZONING AGREEMENT constitutes the entire agreement and supersedes all prior agree- ments and understandings, both written and oral, between the parties with respect to the subject matter addressed in this ZONING AGREEMENT. a. Can you explain how the city can "spot zone" for these businesses and can this create a situation where other businesses that want the same favor can sue the city for this favor and change the complete nature and integrity of our RESIDENTIAL neighborhoods? 5. page 45, item 3 GOVERNMENTAL REFERRAL. Operator shall not provide any services to any client or house any client who has been referred or caused to be referred to Morningside Recovery Facility by any governmental agency, including but not limited to probationers or parolees, due to the limitations that section 509.9 of the California Building Code places on Group 1 and R occupancies. a. THE WORDS "ALTERNATIVE SENTENCED" NEEDS TO BE ADDED TO THE ABOVE PARAGRAPH NEXT TO AND ADDITION TO THE STATEMENT "INCLUDING BUT NOT LIMITED TO PROBATIONERS, PAROLEES OR ALTERNATIVE SENTENCED ". IF THIS IS NOT ADDED TO THE LANGUAGE THE OPERATORS CAN STILL TREAT CARD CARRYING COURT SENTENCED, EXPUNGED OF ADDITIONAL CRIMES (spousal abuse) REHAB CLIENTS. 6, page 46, item 9 Client Transport. Operator shall insure that loading and unloading of passengers of the facility's transportation van shall occur only in open parking spaces or garage spaces. The van driver is prohibited from stopping or double parking in a traffic lane to load and unload passengers. In addition client drivers shall respect all city rules regarding parking and/or stopping and waiting to load residents. Client transport vehicles shall not block adjacent alleys or street ends. a. When residents call PD about the problems and complaints with the vans and law enforcement tells the residents "try to find which house the vans go to so we can go talk to the operators" is this going to be the only device the residents can use when being inundated by vans speeding up and down our streets, vans double parking in the Lido Village blocking the street completely, and vans blocking our alleys? b. Why can't the vans have a large visible number on both sides and back identifying the vans for police and city use. Residents could then call on traffic hazards and report the number. THIS NO WAY IDENTIFIES THE CLIENTS ON BOARD OR THE OPERATOR. THE RESIDENTS WOULD NOT KNOW WHO THEY WERE IDENTIFYING ONLY THE NUMBER ON THE VAN. THE PEOPLE INSIDE THE VAN ARE DISABLED, NOT THE VAN DRIVER OR THE VAN! THIS WOULD ALSO HELP THE CITY KEEP TRACK OF REPEAT OFFENDERS AND EGREGIOUS OPERATORS. page 48, item 21 AFFIDAVIT OF DISABILITY. The Operator shall execute an affidavit de- claring that all clients receiving services from this facility are disabled persons, as that term is defined by federal and state fair housing laws. a. Does this mean that every client would have an individual affidavit on them or is the affidavit pertaining to the group as a whole? b. Who determines when the "client" is disabled and when they become "NOT DISABLED" which gives them special considerations within the law and special favors in our city? c. Who really knows who is housed in these homes besides the operators and who in the city is charged with keeping track of the thousands of "clients" coming and going in and out of our residential neighborhoods? MAP OF TRAVEL ROUTES a.Can Momingside tell me /residents where it states that they can use vans on the 200 block of 39Th and River Ave. between 38Th and 39Th St which they constantly do? This agreement specifically states they can not use River between 51st and 32ND. So why make an agreement with someone who still DOES NOT FOLLOW the specifics in this agreement? b I am requesting as stated above to have these vans numbered in large graphic print to make the violators easy for the city to identify so when the residents call in on them they are not told to go follow the vans and "find out which homes they are going to so the police can speak with the operators ". I am working from home today and as I sat down to work at 12:59 pm another van came speeding around the comer, a female driver with short brown hair, WITH HER CELL PHONE TO HER EAR. SAME BEHAVIOR, UP THE CURB AND OFF THE CURB. I hope you can see why we are so concerned that Morningside one of the most flagrant operators in Newport Beach is being giving the right to do their business in our residential neighborhoods. Once again I am pleading for the words "ALTERNATIVE SENTENCED" be added as stated above in #5, item 3. The operator should have no objections if as they have stated, they don't service these clients. It also seems to me that whatever you, the Planning Commission decide to amend, it could make little difference as the agreement has been up the city's website as a "approved facility" for months. That being said I would hope that you would consider my comments and observations and do what is in your power to make these issues right for the protection and integrity of our residential neighborhoods. Thank you in advance for your time and consideration of these matters. Sincerely, Cindy Koller River Ave, West Newport Beach