23 (4)
Attachment to Letter dated September 15, 2020
Anaheim Lighthouse Comments on Ordinance No.
Proposed Ordinance & Zoning Code Amendment No. 2020-001-0170
City of Anaheim
1.The seventh “WHEREAS” contains reference to the Department of Alcohol and Drug
Programs (“ADP”). ADP no longer exists for several years. They were replaced with the
Department of Health Care Services (“DHCS”). This was addressed in the second draft.
2.The nineth “WHEREAS” has a typo on line four “and non-state”. Separate “and” and
“non”. This issue was addressed in the second draft.
3.The thirteenth “WHEREAS” states Anaheim has 205 licensed and/or certified alcoholism
and drug abuse recovery or treatment facilities providing 205 beds. The City of Anaheim
is the largest city in Orange County by population with 347,000 residents. The 205 beds
represent .059% of the total population, which is miniscule;
4.The sixteenth “WHEREAS” says, “overconcentration of these facilities in residential
neighborhoods may lead to the institutionalization and commercialization of such
neighborhoods…” This is a clearly false assumption inasmuch as they represent on
.059% of the total population of the City of Anaheim;
5.The twentieth “WHEREAS” cites a 1997 study by the American Planning Association to
support the proposition that “limiting the number of recovering addicts that can be placed
in a single-family home enhances the potential for their recovery…” This is a study that
is 23 years old. It is NOT prepared by a “clinically qualified” organization that has
studied addiction treatment for the last 23 years where significant strides have been made
in the treatment field. At least cite a clinically qualified study. This looks like a boot
strap argument to anyone in the addiction field. If there is a study regarding the number
of addicts living in a home, it could be cited, but it is highly doubtful;
6.The twenty-first “WHEREAS” argues that sober living homes do NOT “provide the
disabled with an opportunity to ‘live in normal residential surroundings’ but rather places
them into living environments bearing more in common with the types of institutional,
campus, and/or dormitory living that the FEHA and FHAA were designed to provide
relief from for the disabled, and which no reasonable person could contend provides a life
in a normal residential surrounding…” Sober living homes were never intended to do
that. They are intended to be a temporary intermediary step between institutions and
home. This is consistent with every clinical study and several national institutions who
proscribe a “continuity of care” curriculum for recovery, such as, ASAM, SAMHAS and
the Department of Mental Health. This “WHEREAS” misses the point completely as
written;
7.The twenty-second “WHEREAS” points out some non-essential and irrelevant
distinctions between a sober living environment and a single residential housing unit.
The first one (1) is not true. Recovering addicts generally have more significant ties than
a family. Their ties are life threatening and of utmost importance. A normal household
has ties that are not “chosen”. The second (2) one is not correct either. The “head” of the
“family” makes that decision, just as the head of the family makes that decision in a
normal household. It is really a hair-splitting distinction. The same with the third (3)
one. There is no “sharing” of costs between the parents and the children. The parents
pay for everything. Additionally, what significance is that? Number (5) is not true either.
First, most all sober living homes operate in a similar fashion as a normal household.
There are rules to follow. When broken, they are afforded additional chances to comply.
Only when a member fails to comply in a repeated manner they are asked to leave, unless
it is a cardinal transgression. This is similar to a normal household. That is why there are
so many juveniles in juvenile halls in Orange County;
8.The twenty-third “WHEREAS” is really incorrect. ALL neighborhoods have parking
problems when teenagers drive. Many households have 5 or 6 cars, depending on how
many teenagers live there;
9.The twenty-fourth “WHEREAS” is not correct. The City of Newport Beach, for
instance, has such a parking problem on the peninsula and in Newport Heights, that ALL
those areas have parking restriction and a sticker system. They have extended the
parking restriction into the Dover Shores area. This is ONE city in Orange County. It
has zero to do with sober living homes. It has everything to do with tourists and
teenagers, especially in Newport Heights by the high school. Parking problems in cities
cannot be blamed on sober living homes. This is especially true in Anaheim, where 205
beds represent only .059% of the total population;
10.The twenty-fifth “WHEREAS” is misleading. The distance requirements of the “State
Law” applies ONLY to mental health facilities. Again, at .059% of the total population,
there can be no valid argument related to “overconcentration” in Anaheim;
11. The twenty-sixth “WHEREAS” again is based on the fiction that there “may” be an
overconcentration of sober living homes in the City of Anaheim. Again, the City of
Anaheim is the largest city in Orange County. .059% sober living beds to population
ratio is infinitesimal. You cannot make a serious argument that this number represents a
threat of overconcentration in Anaheim. Therefore, there is no need, nor any basis, for
this legislation and the distancing requirements;
12.The twenty-seventy “WHEREAS” makes little sense at all. The recovering addict DOES
get preferential treatment to assist in their recovery. Both the State and Federal
government believe this is a socially beneficial situation and that is why they formulated
the State and Federal Fair Housing and Employment Acts and the Cal. Health and Safety
Code, sections 11830, et. seq.;
13.The twenty-eighth “WHEREAS” states reasons for this legislation, which are really
unnecessary. There are existing nuisance laws and other personal protection laws that
can be used to assure facilities are not operated in a way that constitutes a nuisance; as
stated above, there cannot be a valid argument regarding “overconcentration” of
neighborhoods; and, the City of Anaheim can provide sober living homes community
housing resource information in person or on its website.
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