Dear Judge Hernandez, The City of Lake Forest has reviewed the Orange County Grand Jury Report entitled,*

Group homes too close to one another contribute to the problems associated with overconcentration. The respondent agrees with the finding. The answer is inherent in the question. The question assumes that the homes are "too close," which by definition constitutes overconcentration.

Common nuisances are more likely and disruptive when sober living homes are concentrated in a small geographic area of a neighborhood. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The answer may vary depending on the facts of each specific case. How large is each facility? How are they run? What regulations govern them? How close is "concentrated"? How small is "small"? The City does not assume that sober living homes of any type, of any size, regardless of how they are run, are, as a category, a disruptive source of nuisance. www.lakeforestca.gov 100 Civic Center Drive Lake Forest, Remember the Past ~ Challenge the Future Lake Forest, CA 92630 DRUG USE (949) 461-3400 IS Fax: (949) 461-3511 TE ABUSE 6

Some cities have successfully addressed and informed community members about the challenges faced in regulating group homes. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The City does not know what all other cities do. Nor does the City have in-depth knowledge about what any other city might have done or not done to inform its residents about regulation of group homes. The City can only opine as to its own efforts. But it is unclear what successfully means in the context of this finding, as it is a subjective qualifier. Also, what does it mean to successfully address community members on this topic, versus successfully informing them? And what is meant by challenges? The City has taken steps to educate members of the public about federal and state laws that might apply to group homes, depending on the facts, but whether or not the City has been successful in those efforts remains unknown. We have no way to measure whether residents understand the law and its application to specific situations in the City or whether they are convinced of its wisdom from a policy matter.

Community satisfaction was minimal when cities took the traditional public comment approach towards addressing community complaints. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. It is unclear what is meant by community satisfaction or how this is measured. It is also not clear what is meant by the "traditional public comment approach."

Cities are not utilizing police, fire, and code enforcement complaints as a means of locating and tracking Group Homes. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The City cannot say with certainty what other cities do or don't do. There might be some city or cities somewhere that do use these kinds of complaints to track Group Homes, but the City does not know this to be the case. For its part, the City does not use police, fire, and code-enforcement complaints as a means of locating and tracking "Group Homes" per se. The City does not single out group-homes for regulation or tracking.

Cities are inhibited from enacting and enforcing ordinances due to fears over the potential cost of litigation. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The City cannot say with certainty what other cities do or don't do. There might be some city or cities somewhere that chooses to not enact or enforce ordinances due to fears over potential litigation, but the City does not know this to be the case. What is meant here by inhibited? What kind of ordinances? The potential for litigation and associated costs are likely a factor in considering any new regulation. For its part, the City does not single out group homes for particular regulation or tracking. Several cities have created an ordinance that requires a ministerial permit or registration

to operate a group home, however many of these cities do not enforce their ordinances. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The City cannot say with certainty what other cities do or don't do. There might be some city or cities somewhere that have adopted an ordinance that requires a ministerial permit or registration to operate a group home, and, if so, some of them might not be enforcing their ordinances. For its part, the City does not single out group homes for particular regulation.

City and County officials are deterred from regulating group homes by California Housing and Community Development's housing element approval process. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. What is meant by deterred? Prevented or merely discouraged? Regardless, the City cannot say with certainty what motivates or deters officials in other cities or counties. The City has no knowledge of whether they are deterred from regulating group homes or, if they are, by what. There might be some city or county official somewhere who takes a different approach to regulating group homes based on HCD's comments on housing elements. The City cannot speak for them. For its part, the City does not single out group homes for particular regulation, and the City strives to comply with the requirements of the Housing Element Law as it has been enacted. Cities have historically strategized and acted independently in addressing group home

challenges and solutions. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. The City lacks knowledge and information sufficient to reach this conclusion. The findings themselves presume a certain view of group homes that the City does not necessarily understand. Regardless, the City cannot say with certainty what other cities do or don't do. There might be some city or cities somewhere that have "historically strategized and acted independently in addressing group home challenges and solutions." The City cannot speak for them. For its part, the City does not single out group homes for particular regulation and acts independently to protect public health, safety, and welfare regardless of the nature of the use or the identify or ability of occupants. The City strives to follow all applicable laws regardless of what other cities or counties might do. Well-operated group homes can integrate smoothly into neighborhoods.

group homes. The respondent agrees with the finding. The City is aware that there have been over-doses, over-dose-related deaths, and assaults and other abuses at some unlicensed group homes. By definition, these occurrences indicate inadequate on-site supervision and oversight. Appropriate governmental oversight can serve to encourage appropriate on-site supervision and oversight for the benefit of the vulnerable populations who reside in the homes. The City supports efforts to provide appropriate oversight of unlicensed group homes. RESPONSES TO RECOMMENDATIONS Orange County cities and the County of Orange should address citizen concerns