HomeMy WebLinkAbout02/01/2011, B1 - CONSIDERATION OF CURRENT AND PROPOSED REGULATIONS GOVERNING THE MAINTENANCE OF NEWSRACKS IN CITY RI council Mmtnj, I
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C I T Y OF SAN L U IS O B I S P O /
FROM: J. Christine Dietrick, City Attornee
Jay Walter, Public Works Director
SUBJECT: CONSIDERATION OF CURRENT AND PROPOSED REGULATIONS
GOVERNING THE MAINTENANCE OF NEWSRACKS IN CITY
RIGHT OF WAY
RECOMMENDATION
Direct staff to develop a standard protocol for enforcement of existing newsrack regulations and
coordinate with stakeholders to ensure permitting and maintenance compliance of new and
existing newsracks in City right of way.
DISCUSSION
As part of its consideration of the Downtown Beautification Project, Council expressed dismay
with the existing state of newsracks in the City. During that discussion, Council directed staff to
research the legality of newsrack regulation and enforcement and, if feasible, return to Council
with draft regulations governing the placement and maintenance of newsracks in City right of
way. At that time, Council indicated that it was interested in pursing regulations that would
facilitate distribution of publications from centralized, City-owned and maintained newsracks
(known as "condo boxes"), similar to those that had been showcased in a downtown
enhancement presentation by Chamber of Commerce President Dave Garth. The purchase of
such newsracks for the downtown area was included in the budget for the Downtown
Beautification Project.
Legal Background
Distribution of publications through newsracks is a well-established, protected right under the
First Amendment of the United State Constitution and the California Constitution. Accordingly,
the government's right to restrict free speech " `... is very limited: the government may enforce
reasonable time, place, and manner regulations as long as the restrictions "are content-neutral, are
narrowly tailored to serve a significant governmental interest, and leave open ample alternative
channels of communication."' (Gonzales v. Superior Court, 180 Cal.App.3d. 1116)
In 2000, the Tribune sued the City of Paso Robles alleging that the Paso's then newly enacted
newsrack regulations restricting the number and location of the racks throughout public areas
violated the newspaper's rights under the State and Federal Constitutions (a copy of the case is
available in the Council reading file). The trial court held that that the City's ordinance violated
the First Amendment to the United States Constitution because it was "...not narrowly-tailored
to address specific safety, economic or aesthetic concerns."The California Court of Appeal, in an
unpublished decision, affirmed the trial court's ruling"because City made no attempt to ascertain
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whether the restrictions were related to its purported concerns, and did not consider whether the
restrictions were narrowly tailored to achieve the goals set forth... The Court of Appeal decision
noted that "...staff did not seek input from citizens or appellants about the significance or
propriety of the goals stated, whether the new, additional restrictions are reasonably calculated to
achieve significant government goals, or whether more narrowly drawn, less restrictive
provisions might achieve such goals, as required by First Amendment jurisprudence."
Notwithstanding the outcome in the Paso case, the Court of Appeal acknowledged, and other
state and federal cases make clear, that a city may adopt and enforce ordinances governing the
manner, appearance, and location of newsrack distribution. There are numerous cases, at both
state and federal levels, holding that content-neutral ordinances adopted in reliance on records
demonstrating adverse impacts on governmental interests and regulations carefully crafted to
address those adverse impacts are permissible. More specifically, there is Ninth Circuit authority
upholding an ordinance requiring the distribution of publications exclusively through a limited
number of uniform distribution points in a special district area of Honolulu, Hawaii (Honolulu
Weekly, Inc. v. Harris, 298 F.3d 1037). Thus, it is clear that the City can regulate in this area,
generally, and may apply special, more restrictive requirements to its Downtown.
Current and Proaosed City Regulations
The City's current regulations governing newsracks, adopted in 1989, are located in Chapter
12.04 of the Municipal Code, Encroachments and Excavations, at Section 12.04.132 and, by
reference, Section 12.04.131 (Attachment 1). While the regulations are a subsection of more
generalized encroachment provisions, the current regulations do include most provisions
common to ordinances of this type. Specifically, the provisions require a permit for placement of
a newsrack and specify the permit application requirements; require payment of a fee, proof of
insurance, and indemnification of the City; and establish guidelines for placement and
maintenance, as well as authority for removal. Thus, the City has had regulations on the books
for many years, but has not pursued regular or aggressive enforcement of the regulations. Active
enforcement of the provisions may have slowed during the time of the Paso litigation as the
result of legal advice to be cautious in enforcement or apprehension that the City would become
embroiled in a similar dispute. Moreover, the Court in the Paso decision references voluntary
agreements between the newspapers and other local entities, including the City of San Luis
Obispo. Whatever the cause, enforcement over the years has not been consistent and it is clear
that many local distributors are not compliant with the City's current regulations.
The proposed regulations (Attachment 2) are not dramatically different from the existing
regulations, but would be a stand alone provision in the Municipal Code, perhaps making them
less prone to being overlooked by new entrants into the local distribution market. In addition, the
proposed regulations provide greater specificity as to the appearance and maintenance of the
racks; a more detailed statement of the process for removal and return of non-permitted or
violating newsracks; and an express prohibition of the distribution via newsrack of materials
prohibited from distribution to minors and/or openly displaying specified body parts. Most
significantly, the proposed regulations include separate provisions applicable only to the
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Downtown, limiting newsrack distribution to City owned "condo box" type racks in the
Downtown Core.
This office has reviewed the current City regulations and believes that the City's current
regulations are consistent with the requirements of First Amendment jurisprudence and avoid the
defects that resulted in the invalidation of the Paso ordinance. Likewise, the proposed
regulations are based on models that were drafted in accordance with constitutional requirements
and avoid constitutional defects, taking into consideration local circumstances. There are
significant distinctions between current and proposed City regulations and the invalidated Paso
regulations, including:
1. City regulations do not include a strict limitation on the number of newsracks in
the City, generally, or the downtown area, specifically.
2. All limitations relating to location of placement are narrowly drawn and related to
interference with pedestrian or traffic flow, interference with disabled access,
obstruction of the right of way in a manner that creates a hazard, or interference
with display windows, utility boxes or landscaped areas.
3. Nothing in either set of regulations limits the entry of new publications into the
distribution stream, although further consideration should be given to this issue if
Council wishes to pursue the "condo box approach."
Thus, staff does not believe there is any legal impediment to enforcement of the current
regulations or any insurmountable hurdle to the adoption of new regulations. However, if
Council wishes to pursue the adoption of new regulations, staff would recommend that Council
provide feedback on the draft and direct staff to conduct further meetings with stakeholders and
bring back a fully developed record: 1) identifying the.City interests Council is seeking to further
through adoption of regulations; 2) enumerating the nature and scope of concerns voiced by the
public and other stakeholders, as well as requested regulation; 3) reflecting the comprehensive
input of regulated interests to evaluate whether less stringent measures could be effective in
achieving the City's interests;.and 4) articulating how the proposed regulations serve to mitigate
or directly address the identified adverse impacts..
Stakeholder Feedback About Proposed Regulations
The proposed regulations were initially distributed to stakeholders in August of last year with a
request for review and feedback. Thereafter, staff attended a Downtown Association Board
meeting to explain the proposed ordinance and hear the perspective of downtown business
owners. That feedback was generally positive with some suggested areas for further
consideration, but a publication owner present at that meeting raised several concerns with the
approach proposed. His input was consistent with the initial and uniform response from other
publication owners and distributors who generally voiced strong opposition to regulations
mandating distribution through City owned condo boxes.
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In an effort to understand the concerns being raised, staff (Jay Walter and Christine Dietrick)
scheduled a series of three meetings last October to review and discuss the draft ordinance with
stakeholders to get feedback from those who. will be affected by any new regulation.
Representatives from several publications attended those meetings, as did Deborah Cash from
the Downtown Association. Staff received extremely valuable input in the course of those
meetings. Among the major concerns from local publishers were (specific areas of concern are
highlighted in Attachment 2):
1. Loss of investment in currently utilized newsracks
2. Loss of branding and visual diversity ariiong publications
3. Limited availability of spaces in"condo boxes"
4. Burdens of new regulation and fees in a challenging economy
5. City inability to regulate and maintain racks in good condition over time and
degradation of similar efforts in other jurisdictions
The consensus of all distributors in attendance at the meetings was that increased efforts to
heighten awareness of the current regulations, combined with more effective enforcement would
be effective in addressing Council's concerns and would not be unduly burdensome to the
publication owners and distributors. Deborah Cash indicated that she would convey the substance
of the discussion to her Board and determine whether they would support an effort to enhance
enforcement of current regulations, rather than to pursue new regulation. The Board's letter of
support and offer of assistance in implementing the approach is included as Attachment 3. At the
conclusion of the meetings, staff asked that the stakeholders review the City's current regulations
and provide input into any revisions they felt should be advised. Staff did not receive input that
any significant revision to the existing regulations was needed. Recently, staff again requested
confirmation that no major revisions were viewed as necessary and also requested that
stakeholders provide updates on the status of their compliance with current regulations.
Correspondence from stakeholders reflecting their compliance efforts and willingness to work
collaboratively with the City toward more effective regulation is also included as Attachment 3.
Next Steps
Obviously, successful ongoing regulation will require cooperation and renewed efforts on the
part of both City staff and stakeholders to ensure compliance with regulations and high levels of
commitment to maintaining newsracks in a functional and attractive condition. Recognizing
staff resource limitations and its role in preserving the downtown as an attractive and desirable
location for locals and tourists, the Downtown Association has offered to assist staff in efforts to
increase compliance by providing monitoring and reporting assistance. Similarly, several of the
stakeholders have voiced their willingness to increase regular communication and commitment
to keeping their newsracks in acceptable condition.
If Council agrees with the recommended approach, implementation of the renewed enforcement
efforts will fall largely to the Public Works Department because they issue and monitor
compliance with encroachment permits for the City. Public Works staff has identified the
following steps to begin the effort:
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1. Inventory all racks in the Downtown for location, condition, and contact information.
2. Contact each publisher to verify the above.
3. Ask each publisher to come in and get one encroachment permit for their rack
locations, and provide insurance as required.
4. Inform each publisher about the acceptability of their racks (appearance,
functionality) and give them notice to remove and replace by a date certain.
5. Work with the Downtown Association to get some assistance in monitoring the racks
and contacting the publishers when necessary with correction notices.
6. Monitor and track staff time over the first year to determine if a new fee resolution is
needed to help recover costs.
7. Evaluate after one year to determine if the publishers' desire to self enforce has been
effective or whether consideration of further regulation is warranted.
After one year, staff would propose to return to Council with information regarding the success
of this approach and make recommendations as to whether further regulation appears to be
necessary. It is anticipated that, by that time, staff would have a complete record sufficient to
support any further regulation.
CONCURRENCES
The Downtown Association concurs with staffs recommendation.
FISCAL IMPACT
The Downtown Beautification Project Budget currently includes funding for the purchase of new
City-owned newsracks. Council direction to proceed with the recommended approach could
result in a savings to the General Fund, or in reallocation of the budgeted funds toward some
other work as part of the Downtown project. There also could be some increase in fees received
from encroachment fee applications as staff undertakes a review of existing racks and permitting
status. There will be additional expenditures of staff time to enforce and monitor compliance
with the newsrack regulations.
ALTERNATIVES
1. Provide input on proposed regulations, direct staff to further develop a record to
proceed with completion of proposed regulations, and return to Council with an
amended draft ordinance for consideration.
2. Provide input on desired changes and direct staff to modify existing regulations.
ATTACHMENT
1. San Luis Obispo Municipal Code Sections 12.04.131 and 12.04.132
2. Proposed Newsrack Ordinance
3. Stakeholder Correspondence
T:Wttorney\Newsrack Ordinance\CAR,2011.2.1\CAR.Newsrack Ordinance Consideration.2011.2.1.doc
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ATTACHMENT 1
12.04.131 Special design concerns.
A. Any encroachment which does not meet established city standards for design and
construction shall be subject to review by the director and the community development director.
B. Any encroachment which will limit the amount of sidewalk available for pedestrians shall
further be reviewed to meet concerns for pedestrian safety and to ensure adequate area for
pedestrian passage. In residential areas a minimum of four feet of sidewalk shall be clear for
pedestrian passage. In areas with sidewalks subject to high pedestrian activity as determined by
the director, the width of the sidewalk which may be blocked by an encroachment shall be as
determined by the director.
C. Encroachments shall not be physically in contact with street furniture or street trees.
D. Encroachments shall not restrict pedestrian access to parked vehicles, to buses in bus
loading zones, or to access points of abutting property.
E. Encroachments shall not be allowed which in the opinion of the director constitute a
hazard to vehicles or pedestrians.
F. All encroachments which provide a public service such as newsracks or vending
machines shall have plainly posted on their face the name and phone number of the party
responsible for maintenance and operation. (Ord. 1131 § 5 (part), 1989)
12.04.132 Newsracks.
A. The council finds and declares that the uncontrolled placement and maintenance of
newsracks in the public right-of-way creates physical danger to the traveling public and the
numerous pedestrians that use the public rights-of-way in the city. The council finds that, in
recognition of the unique architectural features and basic heritage of the city, the clutter and
congestion of numerous disparate types of newsracks in the public rights-of-way is unsightly and
not in keeping with the nature of the city. The council also finds that, since the use,of such
rights-of-way is historically associated with the sale and distribution of newspapers and
publications, access to these areas for such purposes should not be unreasonably or absolutely
denied. The council finds that these strong and competing interests require reasonable
accommodation which can only be satisfactorily achieved through this section of the code which
provides for special accommodation of newsracks.
B. Newsracks are any self-service or coin-operated box, container, storage unit or other
dispenser installed, used or maintained for the sale or distribution of newspaper, news periodicals
or other news publications.
C. An application for a permit for newsracks shall be made within ten business days of the
placement of any newsrack in the public right-of-way.
D. Application for permits for newsracks shall be made in the same manner as that of other
encroachments as described in this chapter.
E. Permit fees, liability insurance, and indemnification requirements shall be the same as
that required for encroachments as described in this chapter.
F. Special Location and Operational Concerns for Newsracks.
1. Placement of newsracks shall be such that they are parallel to and no more than six inches
from the walls of adjacent buildings when present. Newsracks placed adjacent to the curb shall
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-;ATTACHMENT 1
be placed parallel to the curb face and shall be a minimum of six inches and not more than
twelve inches from the curb face to the back side of the newsrack. The rack shall face the
sidewalk.
2. Those encroachments which will limit the amount of sidewalk available for pedestrians
shall further be reviewed to meet concerns for pedestrian safety and to ensure adequate area for
pedestrian passage. In residential areas a minimum of four feet of sidewalk shall be clear for
pedestrian passage. In areas with sidewalks subject to high pedestrian activity as determined by
the director, the width of the sidewalk which may be blocked by an encroachment shall be as
determined by the director.
3. No newsrack shall be maintained opposite another newsrack.
4. No newsrack may be attached to public signs, benches, fire hydrants or other facilities in
the right-of-way. Newsracks attached to private property may be done so only with written
permission of the owner and occupant of the private property.
5. No newsrack shall be used for commercial advertising, signs or publicity purposes, other
than to state the name of the newspaper or periodical being sold.
6. Newsracks shall be maintained in good operating condition.
7. The installation of newsracks shall meet the same design concerns as identified for other
encroachments in Section 12.04.131.
8. The number of newsracks at a given location may be limited if, in the opinion of the
director, they will unreasonably interfere with or obstruct the flow of pedestrian or vehicular
traffic or access to parked vehicles.
9. Abandoned or inoperative newsracks must be removed from the right-of-way within
thirty days. Any newsracks left over thirty days may be removed and stored for up to thirty days.
The cost of removal and storage will be charged the owner in the event he or she chooses to
retrieve the abandoned newsrack. Those newsracks left unclaimed will be disposed of as
unclaimed property. (Ord. 1131 § 5 (part), 1989)
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ATTACHMENT 2
ORDINANCE NO. (2010 Series)
AN ORDINANCE OF THE CITY OF SAN LUIS OBISPO REPEALING SECTION
12.04.132 OF CHAPTER 12.04 OF THE MUNICIPAL CODE AND ADDING NEW
CHAPTER 12.05 TO THE MUNICIPAL CODE RELATING TO NEWSRACKS
BE IT ORDAINED by the Council of the City of San Luis Obispo as follows:
SECTION 1 Section 12.04.132 (Newsracks) of Chapter 12.04 (Encroachments and
Excavations) of the San Luis Obispo Municipal Code is hereby repealed in its entirety.
SECTION 2 A new chapter, Chapter 12.05, entitled Newsracks, is hereby added to the
San Luis Obispo Municipal Code to read as follows:
Chapter 12.05
NEWSRACKS
12.05.010 Purpose and Criteria for Regulations.
The purpose of this Chapter is to promote the public health, safety and welfare by regulating the
placement, appearance, servicing and insuring of newsracks within the public right-of-way in
order to:
A. Provide for pedestrian and driving safety and convenience;
B. Accommodate the flow of pedestrian or vehicular traffic, including reasonable ingress to and
egress from any residence or place of business, or from the street to the sidewalk by persons
exiting, or entering, parked or standing vehicles;
C. Consolidate and cluster newsrack locations within the public right of way to avoid adverse
aesthetic impacts associated with street furniture clutter;
D. Provide reasonable access for the use and maintenance of poles, posts, traffic signs or
signals, hydrants, mailboxes, and access to locations used for public transportation purposes;
E. Eliminate newsracks that may result in a visual blight on the public rights of way or that may
unreasonably detract from the aesthetics of ground floor uses adjacent landscaping and other
improvements;
F. Minimize damage to the public right of way;
G. Maintain and protect the values of surrounding properties;
H. Ensure adequate and timely maintenance and upkeep of newsracks;
I. Reduce unnecessary exposure of the City to personal injury or property damage claims; and
J. Provide for and maintain freedom of speech for newspapers and news periodicals using
newsracks for distribution.
12.05.020 Definitions.
A. "Downtown Core" is the area bounded by Santa Rosa, Palm,Nipomo and Marsh. This area is
consistent with the Downtown Pedestrian Lighting District.
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ATTACHMENT-
B. "Newsrack" shall mean any type of structure placed on or within the public right of way for
the vending, or free distribution, of publications.
C. "Person" shall mean any individual, corporation, partnership, or organization who has
installed, used or maintained, or intends to install, use or maintain, a newsrack in the public right
of way.
D. "Public right of way" shall mean any public sidewalk, street, or alley.
E. "Publications" shall mean newspapers, news periodicals, magazines, and advertisements.
F. "Responsible person" shall mean the person whom the City may notify or contact at any time
concerning a newsrack.
12.05.030 Permit required.
Every person subject to this Chapter shall apply and obtain a permit and no person shall install,
use or maintain a newsrack without a permit to do so. A person may apply for a master permit
covering any number of newsracks to be located outside the Downtown core. Distribution
within the Downtown Core shall be permitted only from City owned and maintained newsracks.
12.05.040 Permit application.
The written application for a permit shall contain the following information:
A. For publications to be distributed within the Downtown core:
1. The name, address, telephone number and email address of the person applying for the
permit
2. The name, address, telephone number and email address of a responsible person; and
3. The number of publications to be placed in the newsrack.
B. For locations outside of the Downtown Core, the application for a permit shall contain the
information required by A.1, 2 & 3 above, along with the following additional information:
1. The type or brand of the proposed newsrack.
2. The number of newsracks and a diagram or description of the proposed location of each;
12.05.050 Action on the application.
The Public Works Department shall review the application and approve or disapprove the
application within 10 working days of the City's receipt of a fully completed application. The
Public Works Department shall approve the application and issue the permit if it finds the type of
newsrack and the proposed location of the newsrack meets the standards of this Chapter. If the
the application is denied, the Public Works Department shall immediately notify the person in
writing of the reasons for the denial.
12.05.060 Requirements and standards for newsracks.-Within Within the boundaries of the Downtown Core, publications shall be distributed only by hand
or via newsracks owned, placed, and maintained by the City.
B. At any other location within the City, but outside of the Downtown Core, the following
requirements shall apply:
1. Newsracks shall be kept clean and maintained in good working order at all times, freshly
painted and with unbroken hoods;
2. The name, address and phone number of a responsible person shall be displayed on the
hood of the newsrack in such a manner as to be readily visible and readable;
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ATTACHMENT
3. Frames and racks for individual newsracks shall be [As Approved by the Architectural
Review C_om_mission("ARC")] or a dimensionally equivalent model with the same style
hood, paneling and pedestal, as approved by the Public Works Director or his or her
designee;
4. Frames and racks for group newsracks shall be [As Approved by the_A_RC] or a
dimensionally equivalent model with each individual newsrack having the same style hood
and paneling.
--- -- -- ---- — —
5. The entire newsrack shall be primarilyconstructed of metal and the color of the frame
must be _ _ The _newsrack 'shall have painted panels of the
approved color on all four sides of the display casing;
__ �.
6. Individual newsracks shall be.supported by [style o f pedestal base] and be permanently
mounted. The pedestal base shall'be painted _ color and shall be bolted in-place iii
accordance with specifications provided by the Public Works Department, – --
7. Group newsracks in a multi-unit configuration shall be placed in such a manner as to
utilize no more than two horizontal rows of six newsracks per row and shall be no longer
than eight feet in length and no higher than five feet in height [Or as otherwise approved_by'
the ARC]. Group newsracks shall be bolted in place in accordance with standards provided
by the Public Works Department.
8. Newsracks shall not carry advertising except the name of the publication within the
newsrack itself may be placed on the bottom third of the plastic hood.
C. The following standards shall apply to all proposed newsracks:
1. Newsracks shall only be placed near a curb or adjacent to a wall or a building. In general,
newsracks should be located at the back of sidewalk facing the street right of way. Unless
otherwise approved by the Director of Public Works a newsrack placed"near a curb" shall be
placed not less than eighteen inches nor more than 24 inches from the edge of the curb and in
a manner that minimizes interference with entering and exiting parked vehicles to the
greatest extent possible. A newsrack placed "adjacent to a wall or building" shall be placed
parallel to such wall and not more than six inches from the wall.
2. No newsrack shall be placed_[We a_eed__t_o eval_uat_e feedback o_n_proposed standards_to_,
ensure_ we are allowing adequate outlets]
a. Within five feet of any marked crosswalk;
b. Within fifteen feet of the curb return of any unmarked crosswalk or street
intersection;
c. Within five feet of any fire hydrant or other emergency facility;
d. Within fifteen feet of any driveway;
e. Within fifteen feet of any sign marking a designated bus stop;
f. Within five feet of any bus bench, public bench, shelter, utility/power pole or bicycle
rack;
g. At any location whereby the clear space for pedestrian passageway is reduced to less
than feet;
h. Within three feet of any area improved with lawn, flowers, shrubs or trees;
i. In any location that restricts access to any underground or above ground utility
structure or box;
j. In any location that may be determined by the Director of Public Works so as to block
the access path of travel of visually impaired pedestrians in the public right of way;
k. Within three feet of any display window or any building abutting the public right of
way or in such a way as to impede or interfere with the reasonable use of such window
for display purposes;
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ATTACHMENT
1. Within 150 feet of another newsrack containing the same material except where
separated by a street or where it can be demonstrated that there is insufficient room in one
newsrack for the for the material which may be sold in one days or
in. Facing another newsrack, divided only by the width of a sidewalk
3. No newsrack shall be chained, bolted or otherwise attached to any permanently fixed
object except as provided herein nor attached to any tree, shrub or other plant, nor situated in
any landscaped area;
4. Only group newsracks shall be permitted m the Downtown Core:
5. Newsracks shall be maintained in a an, neat and attractive condition and in good repair
at all times.
6. Newsracks that have been damaged or stolen shall be repaired/replaced as soon as
practical unless the permit holder elects to abandon the location, in which event the permit
holder must promptly remove the newsrack and restore the location to its previous condition.
7. No issue or edition of any publicatiori shall remain in any newsrack for,more:than thirty,
days or one'regulaf distribution cycle, whichever isshorter;from the date of the.pulihcahon
D.. Notwithstanding subsections A and B of this Section, the Director of Public Works may
waive or modify the requirements or standards upon a showing of good cause, provided that such
waiver or modification would not endanger public health or safety. If the Director of Public
Works determines to waive or modify the requirements or standards, he/she shall provide notice
to the City Council who may choose to review that determination. No waiver or modification
shall be effective until one day following the first City Council meeting following the Council's
receipt of the determination. If the City Council chooses to review the determination,.that review
shall take place within 30 days and the waiver or modification shall not go into effect pending
Council action, except where the applicant demonstrates that there is no other feasible method of
distribution not requiring a waiver or modification.
12.05.070. Removal of newsracks.
A. Nonconforming newsracks.
'1. Ninety days after this Ordinance becomes effective any newsrack in violation of this
Chapter will be deemed nonconforming. The Public Works Department shall attach to the
newsrack a notice to correct and/or remove. In addition, the Public Works Department shall
make reasonable efforts to contact the responsible person and inform such person about the
violation. Within ten working days after the notice to correct has been ,attached to the
newsrack, the responsible person must either cure the violation or request a hearing with the
Public Works Department. If a hearing is requested, it shall be conducted within 10 days and
result in the issuance of a written decision, which decision is final.
2. If the violation is not corrected and/or the Public Works Department determines that the
newsrack is in violation of this Chapter, the City may remove and impound the newsrack and
make reasonable efforts to notify the responsible person of the impoundment. If the
responsible person fails to claim an impounded newsrack and pay the expenses of the
newsrack's removal and storage within 30 days of the newsrack's removal, the newsrack
shall be deemed unclaimed property and the City may dispose of it in accordance with law.
B. Abandonment.
If any newsrack installed under this Chapter does not contain the publication specified in the
application within 48 hours after release of the current issue, or if no publication is in the
newsrack for seven or more consecutive days, the newsrack shall be deemed abandoned and
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ATTACHMENT d-
nonconforming and the Public Works Department shall follow the procedures in Subsection A of
this Section. If a permit holder elects to abandon a newsrack location voluntarily, the permit
holder shall restore the public right of way to its original condition.
C. Public Nuisance and Abatement.
Any newsrack that is either placed in the public right of way without an authorized permit, or is
an existing permitted newsrack that should fall into a state of disrepair that violates provisions of
this ordinance, shall be deemed a Public Nuisance under Section 8.24.010 of the Municipal
Code. Racks that have been determined to be Public Nuisances shall be abated under provision
of Sections 12.05.070(A) and 12.05.070(B) above.
D. Imminent danger to the public.
If it is determined by the Director of Public Works or his or her designee that a newsrack poses
an immediate danger to the health or safety of pedestrians, bicyclists or motorists, the City may
immediately remove the newsrack, but shall give immediate notice to the responsible person that
the newsrack has been removed and reasons for its removal, and provide notification of a right to
a hearing to appeal the removal within 10 days of the removal.
12.05.080 Fees
The City Council, by resolution, shall establish appropriate permit fees in an amount sufficient
to cover the actual costs of the newsrack program including administration, annual permitting
and individual rack inspection, where applicable. This fee shall be adjusted annually for inflation
by the change in the Consumer Price Index commencing on July 1, 2012, and on July 1 of each
year thereafter. The cost to install, maintain, replace, remove and relocate any newsrack owned
or maintained by a permittee shall be at the sole expense of the responsible permittee.
12.05.090 Liability insurance and indemnification
Every person to whom the Public Works Department has granted a permit for a newsrack shall,
prior to the newsrack's installation, furnish to the City, in a form approved by the City Attorney,
(a) a certificate showing that the person has then in effect public liability and property damage
insurance, naming the City as an additional insured, in an amount not less than $500,000 and (b)
an agreement indemnifying, defending and holding the City, its officers and employees harmless
from any loss, operation or use of such newsrack. The policy of public liability insurance shall be
kept in force during such time as the newsrack remains in the public right of way.
12.05.100 Standards for materials in newsracks.
A. No publication which is prohibited by any state or federal law from sale or distribution to
minors shall be sold or distributed through newsracks.
B. No publication shall be sold in or distributed from newsracks in such manner as to expose to
the public view any photograph or drawing contained in or on the publication displaying any of
the following:
1. The genitals, pubic hair, buttocks, natal cleft, perineum, anal region or pubic hair region
of any person; or
2. Any portion of the breast, at or below the areola, or any female person.
12.05.110 Violations.
A. Any person who causes or permits a violation of Section 12.05.100 is guilty of a
misdemeanor.
B. Any publication that is in violation of Section 12.05.100 constitutes a public nuisance.
B1-12
C , ATTACHMENT x-
12.05.120 Severability
If any provision of this Chapter, or the application thereof to any person, is held invalid, such
invalidity shall not affect the other provisions of this Chapter, or the application of this Chapter
to other persons, which can be given effect without the invalid provisions..
SECTION 3. A summary of this ordinance, together with the names of Council
members voting for and against, shall be published at least five (5) days prior to its final passage,
in The Tribune, a newspaper published and circulated in this City. This ordinance shall go into
effect at the expiration of thirty (30) days after its final passage.
INTRODUCED on the day of 2011 AND FINALLY
ADOPTED by the Council of the City of San Luis Obispo on the day of
2011, on the following vote:
AYES:
NOES:
ABSENT:
Mayor Jan Marx
ATTEST:
Elaina Cano
City Clerk
APP D AS ' O
stine Dietrick
City Attorney
T:\Attorney\Newsrack Ordinance\CAR.2011.2.1\ATTACHMENTS.doc
B1-13
FTACH
J na
I JAN 4 1011.
our
PWS -I^f n� {h.!
THE MAGAZINE OF THE CENTRA!COAST �r�HSC, E
-_-'/i
January 4, 2011
J. Christine Dietrick, City Attorney
Jay Walter, Public Works Director
City of San Luis Obispo
919 Palm Street
San Luis Obispo, CA. 93401
Christine and Jay,
I received the e-mail regarding your upcoming Newspaper Rack presentation to the City Council on
February 1 st. Thank You for hearing us out in the October meetings and getting a better understanding
on our business. We welcome the self-regulation and enforcement of current City regulations approach. I
do plan on attending the Council meeting on the 1 st as well.
You asked us for an update on the number of racks in San Luis, proof of liability insurance and our rack
maintenance schedule. I have included the information below and in the following pages.
Not much has changed in the last seventeen years except our name. We purchased several publications
along the way absorbing them into one and eventually changing to our current name, Journal Plus
Magazine. We have a total of eight(8) racks in the City of San Luis and their locations have remained
constant over the years. The locations include: One rack at the parking lot entrance on Monterey Street,
three racks on Higuera Street (one each on the 700 block near Mission Mali, 800 block near Beverly's
and 900 block near First Bank) and four racks on Marsh Street (near the 7-11, Sports Authority, the Post
.Office and the bus stop at the Scolari's Shopping Center).
We are a monthly, but visit our racks weekly and check them for cleanliness, refill, adjust any movement
and:fix or replace if damaged_We also give each rack.a thorough cleaning during our delivery cycle.at
the beginning of each month.
As far-as a permit goes, we filled out the proper paperwork seventeen years ago and were told that
there was no need to re-apply unless we moved our racks - which we haven't.
If that process has changed, just let us know and we will follow through.
Included is the updated proof of liability insurance for your records.
If there is anything else you need, please feel free to contact me personally.
Sincerely,
Steve Owens, Publisher
654 Osos Street, San Luis Obispo, CA 93401 • 805/546-0609 or 544-8711• Fax: 546-8827
e-mail: sloiournal@fix.net
B1-14
Re: Newsrack Ordinance Disr-ssionATTAR'1MENT3 Page 1 of I
Dietrick, Christine
From: Christopher Gardner[chris@tolosapress.com]
Sent: Tuesday, January 18, 2011 1:28 PM
To: Dietrick, Christine
Subject: Re: Newsrack Ordinance Discussion
Ms. Dietrick,.
I am sorry this is late in coming but here is some of the information you asked for.
SLO City News Newspaper Racks in Downtown San Luis Obispo
In 2010 Tolosa Press(parent company of SLO City News)purchased 55 newsracks. During the 4th quarter of 2010
we started installing these boxes in public and private areas. In the historic downtown core we have approximately
11-12 of these boxes. In other parts of the city there are approximately 20 other sites. By the end of 2nd quarter 2011
we hope to have all our racks in location. Since we have been working with the City and determining if a location
makes good sense not all of the locations are set.
We are in the process of acquiring the permits and are in communication with public works department.
We have the proper insurance secured.
We conformed to the Downtown"green"color of boxes.
We have recently hired a new distribution manager and have revamped our maintenance processes.
• Each delivery person is to report graffiti or damage of a particular box
• Distribution manager has a repair and maintenance kit.
• We have a quarterly report on the status of the newsracks(new locations, changed locations)
Each box contains contact information
on 12/29/10 4:40 PM, "Dietrick, Christine" acdietrick@slocity.org> wrote:
1) if you have had any meetings to discuss these issues since our meeting and any
suggestions that may have come from those meetings; 2)the number of racks you have in
town; 3) your permitting status under the current ordinance; and 4) your current approach to
rack maintenance (i.e. inspection schedule, replacement policy, contact person) and whether
you have undertaken any efforts to modify or enhance those efforts in light of Council's
direction to regulate in this area.
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1/24/2011 B1-15
e TACHMENT 3
Christine Dietrick
City Attorney
San Luis Obispo, CA
Dear Christine,
As per our previous correspondence, I am submitting some comments on the Proposed Updated Rack
Ordinance as it impacts our Real Estate Book business.We have served local Realtors for 22 years.
First of all, I doubt anyone disagrees that the situation in SLO can be improved.Abandoned,disfigured
or just plain run-down racks are a blight and there is no reason for it to exist. The recession brought a
birth of new publications that just didn't make it due to the length of the economic downturn and a lack
of understanding by some new publishers as to the.likelihood of earning sufficient ad revenues to stay in
business during a recession.This issue can be addressed fairly simply by observation of the policies,
warnings and city removal of abandoned displays or racks with extreme weathering, rust,graffiti, etc. I
think there are adequate provisions in the.ordinance to remedy this.
At this time The Real Estate Book has 14 polyurethane Green house-shaped racks in the downtown core.
We adjust the number of publications contained within them seasonally. Distribution is not static.A
well-managed operation like ours STOCKS UPWARD for major events like Wine festivals or Poly Royal,
summer, and STOCKS DOWNWARD during rainy seasons or Spring Break when students and their
families are gone.We try not to waste and constantly make adjustments.Thus I don't see the relevance
in providing the NUMBERS of publications in each rack. Surely city officials will not count them as often
as we do.The goal here should rather be to make sure they are never EMPTY for more than 5 days.
1) Permit/FEES... I agree with the ordinance but so much depends on real costs which are not
given. Hard to agree with anything completely until you know the price. Make it reasonable and
easy. We are an INDUSTRY that brings commerce to the city in other ways as well. We have
local employees,we live and work here,we shop at all the same stores that other residents do
and if someone buys or sells a car or a home or a sofa from one of the publications,they will
most likely turn-around and buy a new one from a local business.The city should not view us as
a nuisance or eyesore that inhibits tourism, but rather as a vital contributor to economic vitality.
And by the way,the TOURISTS love the publications. Every time I am out and about adding some
magazines to a rack I practically get knocked over by a local resident or tourist who is eager to
have one.We do fulfill a demonstrable need.The publishers could not stay.in business if-the
public did not value_and were not utilizing their product!
2) Racks in the core...just enforce the existing rules and things will look.better and be more
organized. Why have the city take on the added burden of buying and maintaining racks? Have
they estimated the costs and budgeted for additional employees to patrol, and others to order
and fix broken faceplates,clean soot and remove graffiti,eta? City budgets are stretched far
enough. Let the publishers maintain their own racks.
3) Rack design:Our parent company spent 30 years fine-tuning a rack design made specifically:
B1-16
ATTACHMENT 3
A) To be cleaner:With a pointed roof so trash/empty cans, cannot be placed on top of them.
B) Not to Rust: Made from polyurethane so they can't rust. What is the advantage of METAL
racks? Metal is not the most desirable material. Polyurethane lasts longer, holds color
better, can have rounded, rather than square,sharp edges. If you were on a bicycle and had
to suddenly swerve to save yourself from traffic or to keep from hitting a pedestrian, would
you rather plow into a metal, bolted rack that can NOT move that has sharp edges,or a
softer Poly rack with rounded corners that is not bolted down, but rather GIVES when you
hit it?Which rack is likely to cause greater injury?
C) Accessible to all people: Our design is the appropriate height to service the handicapped and
make the lid easy to open to get a publication from a wheelchair.
D) Flexible: Can be removed from the streets easily to be cleaned or repaired. Required bolting
is a disincentive.to publishers who do not have coins deposited in them to remove racks
when they are old and/or to take them into the shop for repairs. Why encourage 10 or 12
different publishers to be drilling holes in the sidewalks?And when/if they get abandoned
who will remove them and refill the holes? If they are abandoned the publisher is most
likely OUT OF BUSINESS so the city can plan on removing them and filling any holes.
Bolting simply limits flexibility. During the recent major retrofit downtown it was easy for us
to move racks out of the way when necessary because we weren't bolted. Or to remove
racks from the front of businesses that had moved or closed down. Bolting is an unnecessary
burden.
4) Limit Six News racks per Row: If I owned six different publications could I have ALL of the
spaces? How will they be distributed fairly amongst different publishers? This is a key issue.You
can end up encouraging a proliferation of magazines from one publisher if you don't limit the
number of slots any ONE publisher can have in one row.
5) Racks cannot be within 3 feet of lawn,flowers,shrubs or trees?Why not?Seems very
arbitrary. Do they damage flowers?
6) "Visually impaired Pedestrians"would probably see the racks better if they were not dark
green.The Real Estate Book's signature, original YELLOW rack design is safer.That's why fire
trucks are now yellow. So which is the true priority?Safety or blending? No emergency vehicles
are dark green fora good reason.
Most everything else in the proposal seems reasonable to our business. Thank you for inviting
us in and allowing us to give our opinions. It is very nice to be included in the process.
Sharon Biddle
Publisher- Real Estate Book of SLO County
Rebook@charter.net
PH 805-481-0494
WWW.Real EstateBook.Com
B1-17
ATTK WENT 3 Page 1 of 3
Dietrick, Christine
From: rebook@charter.net
Sent: Thursday, January 06, 2011 3:42 PM
To: Dietrick, Christine
Subject: RE: Newsrack Ordinance Discussion
Importance: High
Dear Christine,
Thank you for the update. This letter is to inform you that The Real Estate Book has
taken a major step to prepare our organization to best be in compliance with any SLO
rack ordinances.
After an extensive search and interview process we have recently replaced our street
distribution personnel with a new professional independent contractor firm that
specializes in publication distribution full time for a variety of publishing clients. Their
indepth experience with a variety of publications and in cities spanning all of San Luis
Obispo to Ventura will be invaluable in moving forward to meet all regulations. They
completed their first distribution run for us approximately 2 weeks ago, are familiarizing
themselves with our individual locations and requirments countywide, and are in the
process of helping us to analyze our current situation and make any needed
adjustments.
Because your recent notice came in the middle of the holiday period this is our first
opportunity to collectively address the concerns put forth in your most recent
notification. Because these new associates are now managing the task itis of utmost
importance to us that they first be given a reasonable amount of time to learn our
locations and evaluate publication movement within them before we submit additional
rack data or suggestions to you. We will make this a top priorty in the next several days
and will get.back to you on or before your Jan 14th deadline.
Thank you,
Sharon Biddle
Publisher - Real Estate Book of SLO County
Rebook@charter.net
PH 805 481-0494
WWW.Real Estate Book.Com
From: Dietrick, Christine (mailto:cdietrick@slocity.org]
Sent: Wednesday, December 29, 2010 4:41 PM
To: 'DistributorLATimesSFChronFresnoBee (du anedetty@sbcglobai.net)'; 'Information Press
(sa ndrama rsha If@ information press.net)'; 'mraike@HomesMagazine.com'; 'Mustang Daily'; 'New Times
(bob@ newtimesslo.com)'; 'Real Estate Book(rebook@charter.net)'; 'SLO County Journal
(slojournal@fix.net)'; 'Solstice Publishing (solst1ce222@aol.com)'; Target.Media Partners
(jackiek@targetmediapartners.com)'; Tolosa Press'; Tribune'; 'USA Today (sharwood@usatoday.com)';
1/24/2011 BI-18
Page 2 of 3
T,-ICH ENT 3
'Wally Tiedemann'
Cc: 'Deborah Cash'; 'David Garth (dgarth@slochamber.org)'; Walter, Jay
Subject: Newsrack Ordinance Discussion
Greetings Newsrack Stakeholders:
I am planning to bring an agenda item to the City Council on February 1, 2011 to get direction from Council about
how they wish to proceed with regulating newsracks in the City. A few months back, I circulated a draft of a
proposed ordinance (attached) crafted in accordance with Council direction to pursue a consolidated newsrack
distribution (or, as you have educated me, a"condo box") approach. Several of you met with Public Works
Director Jay Walter and me in October and you raised concerns with this approach. You asked that the City not
proceed with new regulations at this time, citing both economic and operational concerns. Instead; some of you
suggested that a combination of self-regulation and enforcement of current City regulations could adequately
address many of Council's aesthetic concerns with newsrack distribution.. The City's current regulations can be
found in the San Luis Obispo Municipal Code, Section 12.04.132 (available at
hftp://www.codepublishing.com/ca/sanluisobisr)o).
It is my intention to inform the Council of the concerns you raised and recommend that the City take an
incremental approach to regulation and enforcement with input from you, the Downtown Association, and the
Chamber of Commerce. The basis for this recommendation will be to allow you, as:stakeholders, an opportunity
to demonstrate that the type of regulation proposed by the draft ordinance may not be necessary and that the
desired goals can be achieved through existing regulation and cooperation with distributors. Obviously, support
for such a recommendation will require coordination and participation from you. To that end, I asked following our
meetings that you provide me with any input, concerns, or objections you may have to the existing regulations
and provide me with suggestions as to how you, as a group, would propose to coordinate, together and with the
City, to formulate a more effective newsrack management plan and regulatory approach. I haven't received any
input about objections to the City's current regulations, so my assumption is that everyone feels they can live with
enforcement of the existing provisions. If that is not the case, please let me know as soon as possible. I would
also appreciate it if you could provide me with information on the following: 1) if you have had any meetings to
discuss these issues since our meeting and any suggestions that may have come from those meetings; 2)the
number of racks you have in town; 3)your permitting status under the current ordinance; and 4) your current
approach to rack maintenance (i.e. inspection schedule, replacement policy, contact person) and whether you
have undertaken any efforts to modify or enhance those efforts in light of Council's direction to regulate in this
area. I will need to prepare and finalize a staff report no later than January 14 and I believe Council will want to
have this information to aid them in their decision-making process about how to proceed. I would also encourage
each of you to either attend the meeting or provide written comments in order to express your perspective on the
issue.
Thank you all so much for the valuable information you have provided to Jay and me and I look forward to working
further with you. Best wishes for a wonderful new year.
Christine
J. Christine Dietrick
City -Attorney
City of San Luis Obispo
Direct Liner 8o5-78r7i43
Fax: 8o5-78.r-7iog
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1/24/2011 Bl-19
- ATTACHMENT ,� `��'ir
JAN 2 1011 i•
18 January 2011 S!..0 �1TY ATTOR'.'`.`
® To: Christine Dietrick, San Luis Obispo City Attorney
Froze Deborah Cash, Executive Director
San Luis Obispo San Luis Obispo Downtown Association
Downtown
Association Re: News rack Ordinance
PO Boz 1402 The SLO Downtown Association Board of Directors on January 11 reviewed the
San Luis Obispo draft News Rack Ordinance scheduled to be discussed by the City Council on
California 93406 February 1, 2011.
Phone 805-541-0286
ww 8o5-townsl .c While the Downtown Association has long acknowledged that the blighted and
www.downtownsto.com g g g
unsightly condition of many of the news racks needs improvement, the idea of
first attempting a voluntary maintenance program to correct the problem, rather
than pursuing the option of mandatory placement in enclosed `condo' racks, is
palatable to and supported by the Board.
It is the Board's understanding that `going back to square one' and identifying all
racks and ensuring the permits for those racks are on file—as well as issuing to
permittees the guidelines and conditions with which they will be expected to
comply—should kick start the effort by all parties to begin the voluntary program.
We are cautiously optimistic that definite improvement will be noted within an
immediate period of official notice.
The Downtown Association also realizes that staying on top of permits and
maintenance will require a commitment of City resources to ensure compliance.
Because we believe that it's important to send a message that there will be no
tolerance for the status quo, we are willing to assist with the effort by providing
staffing assistance to keep an eye on the racks and report to the City when
something's amiss.
As well, the Board respectfully requests that there be some type of assessment
conducted at regular intervals to determine if the voluntary program is effective
and sustainable. Should it prove otherwise, perhaps at that point there would be a
stronger basis for mandatory compliance with a tighter ordinance.
The Downtown Association appreciates the City's commitment to resolving this
perennial and frustrating problem and we look forward to working together to
improve Downtown's appearance.
Cc: SLO Downtown Association Board of Directors
B1-20
y EACH. INT 3 Page 1 of t
A
Dietrick, Christine
From: Tiedemann, Wally [wtiedenmann@usatoday.com]
Sent: Wednesday, January 12, 2011 7:57 AM
To: Dietrick, Christine
Cc: Harwood, Sandra
Subject: FW: Newsrack Ordinance Discussion
Attachments: SLO Rack Application.doc
Dear Christine,
Thanks for bringing us up to date regarding the SLO news rack ordinance. As we discussed in our
October meetings, USA TODAY news rack are an important part of our brand and our pedestal rack is
recognized throughout the U.S. As to your questions:
1. USA TODAY has not met with any other publications in the SLO area since the October
meetings
2. USA TODAY has I I news racks in the downtown corridor covered by the ordinance.
3. I met with Matt LaFreniere in the Planning Department to review the original permits for USA
TODAY. We could not find anything so I am attaching the information and bringing Matta hard
copy on Wednesday 1/12/2011.
4. Inspection of the racks is done daily and weekly by the contractor that does daily delivery and
myself. Should there be a problem with a rack,the city can contact me directly 805-794-5969.
Each USA TODAY news rack also has a 800 Customer Service number you can call(800-USA-
0001)
USA TODAY would be willing to participate with other publications in the area to help self-govern racks
in the downtown area. Certainly if there is any USA TODAY news rack that is not in compliance or is an
issue please let us know and we will correct it.
Again our thanks and please do not hesitate to contact Sandra or myself if we can be of any assistance.
From: Dietrick,Christine [mailto:cdietrick@slocity.org]
Sent: Wednesday,December 29,2010 4:41 PM
To: 'DistributorLATimesSFChronFresnoBee(duanedetty@sbcglobal.net);'Information Press
(sandramarshall@informationpress.net)';'mraike@HomesMagazine.com;'Mustang Daily';'New Times
(bob@newtimesslo.com);'Real Estate Book(rebook@charter.net);'SLO County Journal(slojournal@fix.net)';
'Solstice Publishing(solstide222@aol.com);'Target Media PartnersOackiek@targetmediapartners.com);'Tolosa
Press';'Tribune';Harwood, Sandra;Tiedemann,Wally
Cc: 'Deborah Cash;'David Garth(dgarth@slochatnber.org);Walter,Jay
Subject:Newsrack Ordinance Discussion
Greetings Newsrack Stakeholders:
I am planning to bring an agenda item to the City Council on February I,2011 to get direction from Council about
how they wish to proceed with regulating newsracks in the City. A few months back, I circulated a draft of a
1/24/2011 Bl-21
ATTACHMENT 3 Page 2 of 2
proposed ordinance(attached)crafted in accordance with Council direction to pursue a consolidated newsrack distribution
(or,as you have educated me,a"condo box")approach. Several of you met with Public Works.Director Jay Walter and me
in October and you raised concerns with this approach. You asked that the City not proceed with new regulations at this
time,citing both economic and operational concerns. Instead,some of you suggested that a combination of self-regulation
and enforcement of current City regulations could adequately address many of Council's aesthetic concerns with newsrack
distribution. The City's current regulations can be found in the San Luis Obispo Municipal Code, Section 12.04.132
(available at http://www.codet)ublishine.com/ca/sanluisobisRo).
It is my intention to inform the Council of the concerns you raised and recommend that the City take an incremental approach
to regulation and enforcement with input from you,the Downtown Association,and the Chamber of Commerce. The basis
for this recommendation will be to allow you,as stakeholders,an opportunity to demonstrate that the type of regulation
proposed by the draft ordinance may not be necessary and that the desired goals can be achieved through existing regulation
and cooperation with distributors. Obviously,support for such a recommendation will require coordination and participation
from you.To that end,I asked following our meetings that you provide me with any input,concerns,or objections you may
have to the existing regulations and provide me with suggestions as to how you,as a group,would propose to coordinate,
together and with the City,to formulate a more effective newsrack management plan and regulatory approach. I haven't
received any input about objections to the City's current regulations,so my assumption is that everyone feels they can live
with enforcement of the existing provisions. If that is not the case,please let me know as soon as possible. I would also
appreciate it if you could provide me with information on the following: 1) if you have had any meetings to discuss these
issues since our meeting and any suggestions that may have come from those meetings;2)the number of racks you have in
town;3)your permitting status under the current ordinance;and 4) your current approach to rack maintenance(i.e.
inspection schedule,replacement policy,contact person) and whether you have undertaken any efforts to modify or enhance
those efforts in light of Council's direction to regulate in this area. I will need to prepare and finalizea staff report no later
than January 14 and I believe Council will want to have this information to aid them in their decision-making process about
how to proceed. I would also encourage each of you to either attend the meeting or provide written comments in order to
express your perspective on the issue.
Thank you all so much for the valuable information you have provided to Jay and me and I look forward to working further
with you. Best wishes for a wonderful new year.
Christine
J. Christine Dietrick
City Attorney
City of San Luis Obispo
Direct Line: 805-781-7143
Fax: 805-781-7109
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