HomeMy WebLinkAbout20260727_Exhibit GCity ofSan LuisObispo, Office ofthe City Council, 990 Palm Street, San Luis Obispo, CA, 93401-3249, 805.781.7114,
slocity.org
September 16, 2025
Honorable Rita Federman, Presiding Judge of the Superior Court
1035 Palm Street, Room 355
San Luis Obispo, CA 93408
Subject: Response to San Luis Obispo County Grand Jury Report, Round and Round with Town and
Gown
Dear Presiding Judge Federman,
The City of San Luis Obispo has reviewed the San Luis Obispo County Grand Jury Report titled “Round
and Round with Town and Gown.” This formal response is submitted on behalf of the City Council,
City Manager, and Planning Commission, each of whom has provided input on the findings and
recommendations relevant to their roles. The City’s responses to the Grand Jury’s findings and
recommendations are provided below, with each item presented in italics, followed by the City’s
response.
PREFACE
The City of San Luis Obispo appreciates the Civil Grand Jury’s attention to the evolving relationship
between Cal Poly and the City, and the shared responsibility of fostering a safe and thriving
community for all. While the City’s responses directly address each finding and recommendation,
many of the findings reflect overlapping themes and omit important context, including external
factors that influence both the root causes of the issues and the City's ability to respond.
To provide a more complete picture, the City offers the following context:
i. Exhibit A to this letter includes the City’s previously submitted response to the Grand Jury’s
draft report, which identified numerous factual inaccuracies and offered clarifications in
good faith. Although this feedback was provided before the Grand Jury issued its final report,
none of the City’s suggested edits or corrections were incorporated. The City’s final response
included herein does not restate all of the information previously submitted and encourages
readers to consider Exhibit A alongside the report’s findings.
ii. Most of the City work referenced in this report—ranging from code enforcement and
neighborhood outreach to public safety and community planning—is funded by the City’s
General Fund, which is primarily supported by tax revenue from San Luis Obispo residents,
visitors, and businesses to benefit the entire community. The City must carefully balance its
limited staff and funding across a wide range of needs and neighborhoods. Concentrating
disproportionate resources in one area would be neither equitable nor sustainable.
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iii. The City plays a central role in responding to neighborhood concerns through enforcement,
education, and public safety coordination. However, several of the issues outlined in the
report—such as illegal gatherings, disruptive behavior, and group housing—are symptoms of
broader dynamics like student housing availability, rental market conditions, and campus
culture. While the City actively collaborates with Cal Poly, many of these root causes fall
outside its jurisdiction and require leadership from the university.
iv. The Grand Jury’s report does not include findings or recommendations directed to Cal Poly.
This is because, as a state institution, Cal Poly is not under the jurisdiction of the San Luis
Obispo County Grand Jury or the City of San Luis Obispo. While this explains the lack of formal
direction to the university, it represents a structural limitation of the report. By not
addressing a key stakeholder, namely Cal Poly, the report creates the impression that the
City alone is responsible for mitigating the negative impacts of student party culture.
v. These challenges extend beyond City limits since, Cal Poly, Cuesta, the City and the County
all have an important role to play. As recommended by the Grand Jury Ad Hoc Council
Committee, Council Members and City leadership will engage with Cal Poly, Cuesta and the
County to encourage their involvement in finding solutions.
vi. The landscape surrounding student gatherings and neighborhood impacts has evolved
significantly in recent years, particularly with the rise of social media. Events can now
escalate rapidly and gain widespread attention with little warning, making traditional
enforcement and outreach strategies more difficult to apply. Like many communities, the
City is navigating these challenges in real time and continually adapting its approach to
respond to this new reality.
vii. There are legal limits on the City’s ability to inquire into personal relationships among
residents or regulate who may live together in a private home. Focusing on residents based
on “student” status could create legal risks related to equal protection, fair housing, and land
use discrimination.
viii. Finally, as Cal Poly’s enrollment has grown in recent years, participation in Greek life has also
increased. While larger membership can contribute to more activity and potential
enforcement challenges, City data shows a sustained overall reduction in noise and
disruption across the community, even with rising student enrollment.
FINDINGS:
F1. Prior to 2025, the city failed to effectively provide a multi-pronged, cohesive approach to
manage or shut down large unsanctioned, costly and unruly events such as St. Fratty’s Day. This
created an unsafe environment, with increasing size of unruly crowds, property damage, injuries
and public disturbances.
F1) The City disagrees with this finding. The City wishes to clarify that the reference to
unsanctioned, costly and unruly events” appears to focus exclusively on the St. Patrick’s Day–related
event commonly known as the “St. Fratty’s Day street party,” with no other recent examples cited in
the report. The City acts in accordance with law enforcement best practices and sound operational
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judgment, recognizing that treating every gathering or event as a potential escalation is neither
effective nor sustainable. Overcommitting resources without clear justification would strain limited
resources and erode community trust.
The San Luis Obispo Police Department (SLOPD) has decades of experience planning for and
responding to large-scale, unpermitted events, including the historical Mardi Gras and Poly Royal
celebrations. Those events, while initially sanctioned and promoted, evolved into significant public
safety concerns. In contrast, St. Fratty’s Day emerged organically, has never been officially permitted,
and gradually grew in scale (aside from a sharp decline during the COVID-19 pandemic years).
Each year, SLOPD developed robust operational plans in collaboration with Cal Poly, tailored to the
size and nature of the previous year’s event. These plans included meaningful public safety staffing
and extensive outreach campaigns. The department engaged in proactive communication efforts
through printed materials, door-to-door “knock and talks,” radio advertisements, direct messaging
via Cal Poly and Cuesta College, and meetings with community organizations such as Residents for
Quality Neighborhoods (RQN). SLOPD also issued multiple media releases and participated in campus
town halls with Cal Poly leadership and other City officials to reinforce a message of zero tolerance.
Data collected and analyzed, post-event, also clearly support these increased planning and
enforcement efforts and expanded partnerships to gain broader control over any illegal behavior.
To deter problematic behavior, the City has amended its Municipal Code multiple times. The Safety
Enhancement Zone ordinance 1 was first expanded in 2010 to include Halloween and St. Patrick’s Day
and was amended again in February 2024 to cover the two weekends leading up to St. Patrick’s Day—
the most likely timeframe for St. Fratty’s Day activity.
Despite these efforts, policing St. Fratty’s Day remains uniquely challenging. Unlike a formal event
with a central location, the gathering typically involves hundreds of people walking up and down
neighborhood sidewalks—behavior that is generally constitutionally protected. Many participants
live in the affected neighborhoods and are legally entitled to access their homes, further complicating
any efforts to restrict entry or mobility. In addition, the absence of a formal event organizer means
there is no single point of contact for coordination or accountability. Without anyone responsible for
managing the crowd or ensuring compliance with laws, the burden of enforcement falls entirely on
public safety agencies.
In 2024, the crowd size exceeded expectations and available staffing, despite the department’s
planning. This prompted a significant operational escalation for 2025, which included nearly a year
of planning with a dedicated cross-departmental and interagency planning group in coordination
with Cal Poly students and faculty. More than 300 law enforcement personnel were deployed from
agencies as far away as San Francisco and Ventura. The response included horse-mounted units,
motorcycle, bicycle, and foot patrols, as well as mobile teams and a fully staffed Department
Operations Center. A temporary Law Enforcement Campus with mobile booking and processing
capability was also established in coordination with the San Luis Obispo County Sheriff’s Office.
1 San Luis Obispo Municipal Code Chapter 9.22 (Safety Enhancement Zones) authorizes the City Council to
designate the entire city or specific areas as “Safety Enhancement Zones” during certain events or periods (e.g.,
Mardi Gras, St. Patrick’s Day, Halloween, and Cal Poly move-in weekend). During these times, fines for specified
offenses—such as open container, noise, unruly gatherings, and public urination—are doubled, up to $1,000,
and violations may be prosecuted criminally or administratively.
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Advanced technologies such as drones and mobile surveillance cameras were deployed alongside
outreach tools like targeted signage and materials distributed to known problem properties. These
efforts prevented the crowd from forming at any single location. No intersections or roadways were
illegally occupied or blocked because of pedestrians or crowds of people, and there were no reports
of property damage or injuries within the City of San Luis Obispo.
The City’s direct expenditures for the 2025 event exceeded $100,000 in overtime and equipment.
When including regular staff time and mutual aid support, the estimated total cost ranged from
700,000 to $800,000. This successful outcome—marked by a safe, uneventful day—was the result
of years of iterative planning, lessons learned, and strong relationships between the City, student
organizations, law enforcement partners, and neighborhood groups.
Cal Poly also significantly expanded its role in St. Patrick’s Day weekend planning, and according to
Cal Poly leadership, set clear expectations that past behaviors jeopardizing safety or property would
no longer be tolerated. The university hosted an alternative on-campus music festival that drew more
than 6,000 students and implemented new security measures, including prohibiting overnight guests
and restricting parking to students and staff from Friday, March 14, through Monday, March 17,
2025. It also activated its Emergency Operations Center for real-time coordination and partnered
with the City in planning and operations meetings, establishing a new standard of unified
communication and coordinated response for the future.
F2. The city has not effectively engaged in working together with community stakeholders to find
solutions for ongoing off-campus issues that negatively impact neighborhoods such as code
enforcement, noise issues, trespassing, property damage, and unruly events.
F2) The City disagrees with this finding. While the City acknowledges there is always room for more
effective engagement and will continue working to enhance collaboration with stakeholders, we
disagree with the assertion that the City has not effectively engaged. Addressing neighborhood
impacts related to off-campus student behavior has been a longstanding City priority, reflected in
policies, enforcement, and collaboration with Cal Poly, residents, and other stakeholders.
Efforts to address noise and other nuisance behavior often associated with students have long been
a top priority for our community. Housing and Neighborhood Livability – Healthy, Safe, and
Affordable was identified as a top community priority during the 2025–27 financial planning process.
Such efforts were also the focus of the Neighborhood Wellness goal, designated a Major City Goal
from 2011–2017 and an Important Objective through 2019. During that time, the City convened the
Neighborhood Wellness Community Civility Working Group, composed of residents, students, City
staff, and Cal Poly representatives. The group created a 90-page report which generated many
recommendations, several of which have been implemented. Notably:
Ordinance Changes:
o The Social Host Ordinance was adopted in 2009.
o The Noise Ordinance was revised in 2010 to reduce the warning period, impose
higher fines ($350–$1,000), and allow landlord citations for repeated violations.
o The Unruly Gathering Ordinance was updated, and a Start-of-School Safety
Enhancement Zone was established in 2015.
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o In 2024, the Safety Enhancement Zones for St. Patrick’s Day and Halloween were
expanded to cover additional weekends.
Education and Outreach:
o Extensive communications campaigns are conducted annually, including radio and
TV ads, social media, postcards, flyers, presentations to Cal Poly student groups, and
outreach to landlords.
o City staff provide weekly violation reports to Cal Poly’s Office of Student Rights and
Responsibilities (OSRR), including noise complaints and criminal activity involving
students.
o The City participates in off-campus housing fairs, Greek Life leadership trainings, and
new student orientation programs (SLO Days), reaching over 5,000 students
annually.
Program Implementation:
o A party registration pilot launched in 2017 has been successful in reducing noise
complaints and promoting voluntary compliance.
o Walking tours with neighborhood stakeholders were conducted before the
pandemic.
o Cal Poly Police were granted administrative citation authority within one mile off
campus.
o Since 2010, noise complaints have declined by 50%, from approximately 3,000
annually to around 1,450.
The City also participates in the Student Community Liaison Committee (SCLC), which brings together
Cal Poly, Cuesta College, the City, the County, and community groups to address housing, public
safety, and quality-of-life issues. City Leadership Team members regularly attend Residents for
Quality Neighborhoods (RQN) meetings to provide updates and gather feedback. In addition, staff
respond to dozens of community emails each year, using input to shape enforcement, outreach, and
policy. City staff from the Community Development Department and the Police Department meet
regularly with Cal Poly leadership and student groups, including the Interfraternity Council and Greek
Life staff, to discuss regulations, enforcement, and unpermitted gatherings. The most recent of these
engagements took place in January and March 2025. In addition, separate meetings between City
and Cal Poly leadership focused on discussing new approaches to Greek Life have been occurring and
are ongoing.
City enforcement staff also conduct in-person field inspections and outreach during investigations,
hand-delivering violation notices and educating residents on applicable codes. Staff have offered to
attend student events to support education and compliance. It’s important to note that enforcement
staff must assess each situation on a case-by-case basis, as applicable laws are written to provide
discretion in determining whether an activity constitutes a citable offense. This process can be
complicated by annual changes in residents at a property and by the nature of complaints, which
may range from small gatherings, such as a few people having dinner or playing basketball, to large,
disruptive parties. Each case is evaluated based on the facts, with an emphasis on whether the
conduct violates the law and can be successfully prosecuted.
As mentioned above, Housing and Neighborhood Livability was again identified as a top community
priority during the 2025–27 financial planning process. In response, the City Council adopted Housing
and Neighborhood Livability – Healthy, Safe, and Affordable as a Major City Goal, with multiple
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associated tasks2 focused on advancing this priority. The City remains committed to promoting
neighborhood safety and civility and will continue to refine its approach in partnership with
institutions and the broader community.
F3. The city has failed to effectively enforce municipal codes that prohibit fraternity and sorority
activity in R-1/R-2 zones in part due to the difficulty in identifying houses that are hosting
fraternity-type events, such as rush events and repeated parties. This inaction has resulted in an
increase of illegal fraternities holding events in residential neighborhoods making these areas
almost unlivable for most residents.
F3) The City disagrees with this finding. Zoning enforcement is inherently complex, particularly when
activity occurs on private property and affiliations with fraternities or sororities are informal or
unrecognized by the university. While the Grand Jury uses the term “illegal fraternities,” the City does
not consider this terminology accurate. Instead, this term appears to refer to residences suspected
of operating as fraternity houses in locations not allowed by the City’s zoning ordinance.
The City enforces municipal code provisions that prohibit fraternity and sorority activity in R-1 and R-
2 zones and addresses behaviors that constitute neighborhood nuisances or other code violations—
while also balancing constitutionally protected rights to privacy and free association. There are legal
limits on the City’s ability to inquire into personal relationships among residents or regulate who may
live together in a private home. Proactively monitoring private residential properties would not only
exceed available resources but also risk eroding public trust and infringing on privacy—values the
City is committed to upholding.
Consistent with standard code enforcement practices, zoning enforcement related to fraternity or
sorority activity is complaint-driven. Since November 2023, the City has investigated over 100
complaints and opened 42 enforcement cases related to unpermitted fraternity activity or
conditional use permit violations. Additionally, the City proactively issued advisory notices to 33
suspected fraternity or sorority houses in R-1 and R-2 zones to clarify zoning restrictions.
City staff regularly engage with Cal Poly officials and students to provide education on zoning
compliance and ensure Greek organizations understand the implications of their housing choices. As
recommended by the Grand Jury Ad Hoc Council Committee, Community Development staff will start
providing Cal Poly with mapping that identifies where fraternities and sororities may be located (R3
and R4 zones). The City also maintains an interactive online parcel viewer that lets users look up
zoning and parcel details, as well as other planning information, for any property in the city.
The City has also requested Greek life event location information from Cal Poly to aid enforcement,
education, and outreach efforts, but access to such data has been limited. Cal Poly has removed
2 Task 4b. Conduct a study session with Council on Code Enforcement priorities related to safe/livable neighborhoods and
receive feedback on priorities. Discuss potential updates to property maintenance standards.
Task 4d. Create a project plan and standard operating procedures for Community Development enforcement of zoning
code regulations pertaining to Greek houses. Consider potential updates to zoning code to facilitate efficient regulation of
Greek houses.
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event location data from its public reports—information that previously supported City enforcement
efforts. Enhanced cooperation from Cal Poly, particularly through improved information-sharing and
stronger enforcement of student conduct policies, would significantly strengthen the City’s ability to
address repeated violations linked to campus-affiliated groups residing off campus.
F4. The city has failed to consistently enforce CUPs such as the requirements for an annual list of
parties and events, notification to neighbors, and parking plans. Strict enforcement of these
conditions would contribute to a reduction of the disturbances in the neighborhoods.
F4) The City disagrees with this finding. The City enforces the conditions of Conditional Use Permits 3
CUPs) when violations are reported and substantiated. Over the past year, five fraternities were
found to be in violation of their approved CUPs. This resulted in four hearings before the Planning
Commission since November 2024 to consider revocation or modification of those permits. Three of
the permits were revoked (one is pending appeal review by the City Council) and one was updated.
The City will look into more proactive enforcement of specific conditions in use permits related to
the annual provision of names and telephone numbers for responsible parties, and annual list of
events to be held at CUP locations.
Between May and June 2025, the Planning Commission voted to revoke the CUPs for three fraternity
houses based on verified noncompliance with conditions of approval (as stated above, one is pending
appeal.) The City remains committed to enforcing CUPs fairly and consistently and will continue to
pursue enforcement actions when violations are confirmed.
F5. The current planning appeal fee structure in SLO disproportionately impacts ordinary citizens,
as the high costs consistently and or those raising concerns about community issues such as noise
or safety. While these fees may be justifiable for large-scale development appeals requiring
additional city resources, they hinder equitable participation in local decision-making processes.
F5) The City disagrees with this finding. It is free for any member of the public to report a potential
zoning or Conditional Use Permit (CUP) violation. Once a complaint is submitted, City staff investigate
and, if a violation is substantiated, may initiate enforcement action or bring the matter before the
Planning Commission—at no cost to the reporting party. This exact process has resulted in several
CUPs being reviewed in the past year.
The fee referenced in the report applies only to formal appeals of Planning Commission decisions,
not to complaints or reports of suspected violations. It is a critical distinction: raising concerns about
neighborhood impacts, such as noise or safety, does not require a fee.
The Planning Appeal fee was adopted by the City Council in 2024 following a comprehensive cost-of-
service study, public review, and Council deliberation. The fee is charged uniformly, regardless of
who files the appeal—whether a resident, applicant, or third party—and is based on the estimated
staff time and administrative costs required to process an appeal. To promote accessibility and public
3 A Conditional Use Permit (CUP) is a discretionary land use approval issued by the City of San Luis Obispo that
allows a property to be used in a way not typically permitted in its zoning district, provided specific conditions
are met to ensure compatibility with surrounding uses. CUPs are reviewed by the Planning Commission (or City
Council on appeal) following a public hearing process.
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participation, the City Council intentionally set the fee at a subsidized rate, below the full cost of
service, to ensure it is not overly burdensome.
F6. The Grand Jury encountered a lack of cooperation from the San Luis Obispo City Police
Department. While one sworn officer did participate in an interview, efforts to interview two
additional sworn officers were unsuccessful. This unwillingness to engage hindered the Grand
Jury’s ability to corroborate statements, obtain essential information, and maintain transparency
in its oversight role.
F6) The City disagrees with this finding. The Grand Jury was provided with unimpeded access to all
records, the Police Chief himself and the Police Department’s Public Affairs Manager, who is among
the most knowledgeable on these topics. These individuals participated in extensive interviews—one
lasting 90 minutes—and provided thorough written responses to multiple rounds of follow-up
questions. Additionally, the City submitted requested documentation, including thousands of current
and historical data points relevant to the Grand Jury’s investigation.
At no point was the City or any member of the Police Department served with a subpoena for
additional testimony or documentation. The department declined subsequent voluntary interview
requests only after providing full access to its most knowledgeable representatives: the Chief of
Police, the City Manager who directly supervises the Chief, and the designated staff lead on
operational issues related to the issues explored by the Grand Jury.
Further interviews with the patrol or shift-level personnel requested by the Grand Jury were not
appropriate or necessary, as those individuals have limited scopes of responsibility and were not
positioned to speak authoritatively about policy direction, broader planning efforts, or historical
context. The City’s goal was to ensure the Grand Jury received the most accurate and comprehensive
information possible, and that objective was met through detailed, direct engagement with senior
staff.
The City regularly receives inquiries from the Grand Jury on a wide range of topics, including property
annexations, municipal processes, and service delivery, and responds promptly and cooperatively to
each. This inquiry was no exception. Throughout the process, the City and Police Department
provided information with transparency and in good faith.
RECOMMENDATIONS:
R1. The SLO City Council should continue to work with Cal Poly to develop a multi-year plan to
ensure that the illegal street parties known as St. Fratty’s Day is completely eliminated.
R1) This recommendation has been implemented. While the term “St. Fratty’s Day” is no longer
used, the behaviors and risks linked to large, unsanctioned events remain a serious concern and the
City shares the goal of preventing them. Leading up to recent St. Patrick’s Day weekends, the City
and Cal Poly collaborated on coordinated messaging, joint planning, and proactive public safety
operations. These efforts, including promoting on-campus alternatives, engaging student leadership,
and focusing on high-risk properties, successfully prevented a major street party in 2025. The City
will continue partnering with Cal Poly to prevent illegal and unsafe gatherings associated with St.
Patrick’s Day in the future.
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R2. The SLO City Council, in collaboration with Cal Poly and other stakeholders, should implement
proactive measures to address future unsanctioned illegal street parties as they arise. Taking
immediate action can prevent these gatherings from escalating over time due to prolonged non-
enforcement. This approach would foster a safer community while promoting shared
accountability among all parties involved.
R2) This recommendation has been implemented. The City Council agrees in principle, and the City
takes proactive measures whenever possible. In advance of known high-risk weekends such as St.
Patrick’s Day, the City works closely with Cal Poly and regional law enforcement agencies to develop
and execute coordinated safety plans. These efforts include maximum police staffing, outreach to
student leaders beyond Greek Life, deployment of targeted public safety messaging, and pre-
positioning of mutual aid resources when appropriate 4.
As explained in the responses to Findings 1 and 3, there are practical and legal limits to how proactive
the City can be. Many unsanctioned gatherings are spontaneous and difficult to predict, and
excessive preemptive enforcement—particularly when events may not materialize—can erode
community trust and divert limited resources from other public safety needs. To address this, the
Police Department maintains detailed training protocols and response frameworks for managing
large, unpermitted events.
The City continues to promote early community reporting and encourages a “See Something, Say
Something” approach and strong collaboration with Cal Poly remains critical. The City would benefit
greatly from improved access to timely and accurate information about sanctioned student events
and party addresses—data that Cal Poly is uniquely positioned to provide. This would significantly
enhance the City’s ability to anticipate and plan for large gatherings, focus enforcement where it is
most needed, and ultimately reduce the risk of unsafe or illegal activity.
The City also recognizes that part of the solution involves identifying safe, alternative venues for large
student gatherings outside residential neighborhoods. While constraints such as California
Department of Alcoholic Beverage Control (ABC) licensing and jurisdictional authority limit the City’s
ability to provide or manage these spaces directly, the City will assist in this effort by helping connect
partners or identifying opportunities through its Economic Development team.
The City considers this recommendation implemented and remains committed to proactive
measures.
R3. The SLO City Manager should develop and implement an ongoing formal process to identify
illegal fraternities to bring them into compliance.
R3) This recommendation has been implemented. Through the code enforcement process, the City
has identified properties that are suspected to house fraternities, in locations not allowed by the
City’s zoning ordinance or have been proven to house illegal fraternities. It is important to note, that
per the municipal code, fraternity members can live together in any zone in the City. As noted in the
City’s response to Finding #3 (F3), the City is legally limited in its ability to inquire into personal
relationships among residents or regulate who may live together in a private home. Additionally,
4 Activating mutual aid takes time and must be grounded in credible intelligence.
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targeting residents based on “student” status could create legal risks related to equal protection, fair
housing, and land use discrimination.
A violation occurs when fraternity members, who live together, also hold meetings or gatherings
associated with the fraternity within a house that does not have a Conditional Use Permit (CUP)5.
When events occur at these houses that violate the Municipal Code, the code enforcement team
follows City standards and practices to notify occupants and property owners of violations and assess
fines for non-compliance, as dictated by City regulations. Fines and enforcement actions escalate if
repeat events occur that are found to violate the Municipal Code.
The City has established processes for keeping records on these houses to inform future
enforcement. Discussion of code enforcement priorities will take place with the City Council as part
of the Housing and Neighborhood Livability Major City Goal, Tasks 4b and 4d, during the 2025–27
Financial Plan. These Tasks include a study session with the City Council to discuss Code Enforcement
priorities related to safe and livable neighborhoods to receive feedback on Council and community
priorities as well as the creation of a project plan and standard operating procedures for the
enforcement of zoning code regulation of Greek houses.
R4. The SLO City Council should initiate a task force to explore the creation of a “Student Overlay
Zone” near the campus that would allow for municipal code requirements to be introduced that
would differentiate it from the rest of the city and recognize the needs of a dynamic university
environment. This could facilitate changes to such things as density, parking, noise and fraternity
activities.
R4) This recommendation will not be immediately implemented because it is not reasonable at this
time. While the City Council agrees that neighborhoods near campus experience unique land use
and quality-of-life challenges, the concept of a zoning overlay that introduces separate municipal
code standards based on presumed student occupancy raises significant legal, equity, and policy
concerns. Two Major City Goal tasks adopted by the Council in June 2025 are closely aligned with this
recommendation and initiating a new task force before these tasks are complete is premature. While
these tasks cannot feasibly be completed within the six-month timeframe outlined in subdivision (b)
of Section 933, they are part of the City’s formally adopted work program to be completed during
the 2025-27 Financial Plan:
Housing and Neighborhood Livability Task 4b. Conduct a study session with Council on Code
Enforcement priorities related to safe/livable neighborhoods and receive feedback on
priorities. Discuss potential updates to property maintenance standards.
Housing and Neighborhood Livability Task 4d. Create a project plan and standard operating
procedures for Community Development enforcement of zoning code regulations pertaining
to Greek houses. Consider potential updates to zoning code to facilitate efficient regulation
of Greek houses.
5 CUPs can only be issued for uses allowed by the City’s Zoning Regulations in specific zoning districts. SLOMC
Chapter 17.156 defines Fraternities and Sororities as a residence for college or university students who are
members of a social or educational association that is affiliated and in good standing with the California
Polytechnic State University and where such an association also holds meetings or gatherings.
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Consideration of Legal Constraints:
Under current California state law, the City cannot reduce allowable residential density or increase
parking requirements for certain unit types (such as accessory dwelling units). These limitations
constrain many of the zoning tools typically associated with overlay zones. Moreover, municipal
regulations must be applied fairly and consistently across all residents. Creating zoning provisions
that effectively target or differentiate based on “student” status could expose the City to legal risk
related to equal protection, fair housing, and land use discrimination.
Existing Tools and Enforcement:
The City already uses a variety of municipal code tools—such as conditional use permits, noise
regulations, unruly gathering ordinances, and Safety Enhancement Zones—to address behaviors and
impacts associated with high-occupancy housing and disruptive gatherings. In fact, it enforces some
of the most rigorous fraternity-related zoning laws in the state and has taken proactive enforcement
action against group housing that is not allowed under current zoning.
Overlay Zone Research and Next Steps:
City staff have completed an initial review of how other jurisdictions have approached similar
issues—such as Los Angeles’ Neighborhood Stabilization Overlay or Santa Clara’s code enforcement
overlay—to assess potential applicability in San Luis Obispo. While these examples offer useful
insights, they are often tailored to local legal frameworks and campus conditions. Notably, many
include annual permitting, inspection requirements, and enhanced noticing—tools that may be
adaptable in San Luis Obispo within existing zoning and code enforcement systems.
The City will continue to explore feasible strategies that balance neighborhood livability with a
growing student population. This includes:
Revisiting “responsible landlord” lease language.
Evaluating the feasibility of programmatic enhancements.
Improving coordination between enforcement and planning functions.
Enhancing collaboration with Cal Poly, especially around access to sanctioned event
addresses and off-campus behavior data.
R5. The SLO City Council should consider adopting a tiered planning appeal fee structure to promote
accessibility of community concerns by individual residents. Such a structure could ensure that
financial burdens do not deter public involvement.
R5) This recommendation will not be implemented because it is not warranted. The City Council
appreciates the Grand Jury’s interest in broadening access to the public process and agrees that
community participation is a cornerstone of good governance. As explained under the City’s response
to Finding #5 (F5), while planning appeals require a fee, the Planning Commission’s review of a use
permit, when initiated based on public complaints or information indicating a permit violation, does
not. For fraternities with CUPs, any member of the public may submit a code enforcement complaint
at no cost. Such complaints are investigated and, if warranted, can result in a re-review of the use
permit.
The current appeal fee structure was thoughtfully designed to balance public accessibility with the
need to recover a portion of administrative costs. Importantly, filing an appeal is only one of many
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ways residents can engage in land use decisions. Community members can provide input through
public comment, neighborhood meetings, and direct communication with City Council or the
Planning Commission.
While the City Council agrees that a full reassessment of appeal fees is not immediately warranted,
they are open to considering whether alternative pathways—such as creative mediation options,
structured neighborhood input sessions, or project-specific community liaisons—might more
effectively support early and meaningful engagement in the development review process.
R6.The SLO City Manager and the Planning Commission should move toward adopting more
uniform conditions for CUP’s [sic] and enforcement of existing requirements. Due to the time span
1971-2024) in which these CUPs were approved, the requirements are inconsistent. The City should
consider using future CUP violations to determine if it is appropriate to revise the conditions to
make them more relevant for today’s environment. This may require consideration of additional
code enforcement staff or alternative work schedules.
R6) This recommendation has been implemented to the extent practicable and appropriate. Over
the past decade, the City has been moving toward both the application of more uniform municipal
code requirements (standard conditions) for fraternity and sorority uses as well as the imposition of
more uniform conditions of approval for Conditional Use Permits (CUPs). Per the definition of Use
Permit in the Zoning Regulations (Section 17.158.046), CUPs are discretionary permits that may be
granted to provide for the accommodation of land uses with special site or design requirements,
operating characteristics, or potential adverse effects on surroundings, which are not permitted as
of right but which may be approved upon completion of a review process and, where necessary, the
imposition of special conditions of approval. Therefore, it is often necessary to impose non-standard
conditions on a CUP to address site specific concerns and issues, and therefore, the conditions cannot
be completely standardized.
Chapter 17.86.130 of the Municipal Code (Zoning Regulations) regulates fraternity and sorority land
uses to promote the quality of life in residential neighborhoods. This is accomplished by ensuring
that dwelling units housing multiple persons who are members of a fraternity or sorority provide
adequate support facilities for the intensity of the associated use, and that such uses are operated in
a manner that is not detrimental to the neighborhood in which they are located due to excessive
noise, inadequate off-street parking, general property maintenance, and similar potential impacts.
Per the Municipal Code, Fraternity and Sorority uses require a CUP in order to operate.
In 2018, the City updated Chapter 17.86.130 of the Zoning Regulations for fraternity and sorority land
uses, in part, to codify a set of standard conditions that would apply to fraternity and sorority land
uses. This update included resident occupancy limits, maximum number of persons allowed on site
for routine meetings and gatherings, requirements that a fraternity or sorority be affiliated with and
in good standing with the Interfraternity Council of Student Life and Leadership at Cal Poly, and
requirements that contact information be provided by the landlord to the City for responsible
persons. These uniform regulations apply to all new and existing fraternity and sorority land uses.
As noted above, new fraternity and sorority uses require the approval of a CUP. In addition, if
conditions of an existing use permit are violated, the CUP is re-reviewed to determine if the use
permit should be revoked, or if conditions need to be updated, removed, or added. In order for the
reviewing authority to approve a CUP for a fraternity or sorority use, specific findings must be made
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related to ensuring the health, safety, and welfare of those living on the site and around the site,
consistency with the City’s General Plan, and consistency with zoning regulations and neighboring
properties.
Given that conditional use permits are site and project specific, conditions of approval within CUPs
for fraternities and sororities will vary to some degree to address the unique circumstances of each
proposal. However, the City has made a concerted effort to standardize and modernize conditions,
as appropriate. This provides clarity for CUP holders, City staff, and the public, and enhances the
ability of the City to enforce the conditions in a CUP.
For example, since 2024 the City has reviewed one new and four existing fraternity CUPs which has
led to the modernization of CUPs issued in the 80s and 90s to current standards. This has included:
removing outdated conditions that no longer apply and adding certain standardized conditions
related to establishing thresholds for re-review should violations occur, extending the hours of
compliance with a lower noise limit, requiring ongoing communications between fraternities and
their neighbors, prohibiting amplified noise-generating activities, and clarifying that exceptions from
the Noise Ordinance will not be approved. The City will continue to standardize conditions of
approval as appropriate as new reviews are undertaken. Where there is an opportunity for a
condition to become standardized as a uniform requirement in the Municipal Code, the City will
consider this change in a future update of the Zoning Regulations. For example, there has been an
update to a standard condition for when the re-review of a CUP should occur when there has been a
violation of the Municipal Code or CUP. This updated condition language would be considered for
inclusion in the Municipal Code as a uniform standard when the next update to the Zoning
Regulations occurs, which will likely be within the next year.
The City does enforce Conditional Use Permits. As noted above, the City conducted a re-review of
four existing CUPs because of verified violations of the conditions of approval, and several others are
pending re-review. This enforcement of the CUPs led to the revocation of three permits, and the
updating of one permit. The Community Development Department investigates all complaints
received and works closely with the Police Department to determine if a violation of conditions has
occurred that would lead to re-review of a Conditional Use Permit (such as a noise violation). In
addition, the Community Development Department takes input and complaints from the community,
which can and do lead to the re-review of CUPs for non-compliance at no cost to the community
member. Enforcement of CUPs is addressed on a complaint basis, similar to other code enforcement
activities in the City.
Assuming the last sentence of the Grand Jury’s recommendation is intended to suggest the City
should increase the level or hours of code enforcement activity, current staffing levels do not support
proactive enforcement of fraternity and sorority CUP regulations in that manner. Noise,
unauthorized events, and similar complaints related to fraternities during the fiscal year of 2024-
2025 represent approximately 6.5% of code enforcement complaints and responses and existing
code enforcement staff work during standard business hours, with staff available generally between
8am and 5pm. In 2024 existing staff responded to 1,400 complaints, alleging violations relating to
substandard housing, mold growth, significant building and fire code violations, land use, property
maintenance, unpermitted construction, animals, etc. Extending staff hours or increasing the number
of staff available to address fraternity and sorority enforcement would represent a significant
increase in ongoing costs to the public at a time when the City is forecasting future budget deficits.
Alternatively, redirection or adjustment of existing staff toward this effort would result in decreased
service levels and/or delays in addressing other community response workload. In limited instances
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where potential large-scale events (such as rush) were known ahead of time, Code Enforcement staff
have adjusted schedules or worked overtime in order to gather information in the evening or on
weekends to support enforcement actions. This can be useful in specific circumstances, but would
be disruptive to other code enforcement efforts and the budget if done regularly.
R7. The SLOCGJ recommends that the SLO City Manager create formal guidelines and provide
training outlining how the SLO City Police Department will respond to requests from the SLOCGJ
and other oversite bodies.
R7) This recommendation will not be implemented because it is not warranted. Grand Jury requests
vary in nature and scope and, by their nature, do not lend themselves to a uniform approach in each
instance. The Police Department is managed by the Chief of Police who is supervised by and
accountable to the City Manager. The City Manager has and will continue to review and provide
appropriate oversight and direction to her staff in providing responses to the Grand Jury, in
consultation with the City Attorney as needed. In the event a particular request directed to the Police
Department demanded confidentiality from the City Manager, the City Attorney’s Office would
review and advise the Department’s response and support communication to the City Council.
Respectfully,
City of San Luis Obispo Councilmembers
City of San Luis Obispo City Manager
City of San Luis Obispo Planning Commission
Cc: San Luis Obispo County Grand Jury
P.O. Box 4910
San Luis Obispo, CA 93403
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