Yolo County Grand Jury • 2025-2026 • Agency Response

Response from Yolo County Board of Supervisors

20 pages
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Note: Missing finding numbers detected: F3, F4, F5

Findings 13 findings

F1 Page 1
Illegal fireworks businesses operated in Yolo County in violation of County ordinances for many years. Response. The County agrees with this finding. The County has prohibited the storage of dangerous fireworks and related activities in the unincorporated area since 2001. As the Report accurately notes, “Devastating Pyrotechnics obtained permits from State and Federal agencies to operate, although no local use permit or business license was ever obtained.” (Report at p. 11.) The County received no notice from ATF or the State Fire Marshal of the issuance or renewal of the approvals granted by those agencies. The County issued no local approval for fireworks activities at the site.
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Enforcement of those ordinances would have prevented death and destruction from the Esparto fireworks explosion. Response. The County disagrees with this finding. This finding improperly shifts accountability for the Oakdale Fire from the seven defendants indicted and charged with over two dozen criminal counts, including murder, to County staff that did not observe and could not reasonably foresee anything resembling the extensive, dangerous enterprise that ultimately developed on the site. As essential context, public records released by the County on August 28, 2025 establish the following facts: 1. The Chief Building Official and a building inspector visited the site on June 2, 2022. That visit was conducted in connection with an electrical meter release inspection for a new metal storage building that the landowner represented to the County, under penalty of perjury, would be used for agricultural purposes only, including farm equipment storage, and would not be a place of employment or used for the storage or handling of any hazardous or flammable materials.1 2. During the visit, County staff observed the metal storage building under inspection, which was nearly empty, and a row of approximately 25 Conex storage containers near the developed area of the property. Staff also observed a 200-amp service panel, a rated capacity that exceeds the limit permitted for structures qualifying under the County’s building permit exemption for certain agricultural structures. 1 False statements about the building’s intended purpose are now included as part of Counts 8 and 13 in the main indictment. Attachment A 3. Consistent with a “tip” the Chief Building Official received shortly before his visit, a property occupant represented that the 25 storage containers were used in connection with municipal fireworks displays and were currently empty. 4. Shortly thereafter, the Esparto Fire Protection District Chief2 advised the Chief Building Official that the pyrotechnic business: a. Was federally licensed through the ATF; b. That the row of approximately 25 containers observed during the meter release inspection contained “safe and sane” fireworks and functioned as a distribution center; and c. That “more dangerous materials” were stored in separate, smaller groups of containers that, in the Fire Chief’s assessment, “appear to meet fire separation requirements.” The Chief Building Official noted the need to independently verify that the containers met separation requirements. d. Performed fireworks repackaging and processing “outdoors to simplify the regulations they need to meet for their ATF license.” 5. On June 3, 2022, the building inspector sent the landowners’ authorized agent a “Notice of Corrections” listing issues to be addressed with the metal storage building, including the need for a building permit due to the 200-amp service panel. The landowners’ agent applied for a building permit and completed related paperwork between June 9, 2022 and August 26, 2022, representing in writing that the structure would be used for “agricultural equipment storage” and that hazardous materials, including flammable materials, would not be stored or handled inside. As the Report observes, aside from internal staff-level discussions, County staff did not take any further action to investigate fireworks activities at the Esparto site or determine to pursue enforcement efforts.3 The Grand Jury acknowledges that it “could not determine definitively” why those actions did not occur. (Report at p. 15.) Having made that concession, the Report nonetheless attributes the absence of further action to a “culture of tolerance” and to the involvement of property owners employed by the Sheriff's Office, rather than to the unremarkable conditions that staff actually observed during their visit. This claim relies on a single internal email in which the Chief Building Official advised a manager, just before his June 2, 2022 visit, that he would “tread lightly today” because the site was reportedly connected to “deputies that we work with.” Read in full, the email does not show or even suggest that County staff extended favorable treatment to the operation. The email explains that the purpose of the visit was to “gather more information and verify the reports,” and that staff would 2 The main indictment include various criminal counts indicating that the Fire Chief was also actively deceived by the principals of the businesses (e.g., Counts 8, 10, and 13). 3 Cities and counties generally have no duty to enforce local ordinances, including zoning codes, or to abate or take other action with regard to nuisances under California Health and Safety Code § 17980 and related authorities. Haggis v. City of Los Angeles (2000) 22 Cal.4th 490, 498; Sutherland v. City of Fort Bragg (2000) 86 Cal. App. 4th 13, 18- 19; Fox v. County of Fresno (1985) 170 Cal. App. 3d 1238, 1242. Attachment A thereafter “discuss how to proceed”—language describing measured conduct on an initial, information-gathering visit, not a decision to extend favorable treatment or to forgo enforcement. The events that immediately followed, including a number of emails, are consistent with that reading: the Chief Building Official documented the violations he observed, required additional permitting for the metal storage building, and discussed potential follow-up actions, and nothing indicates that he gave any weight to (or even further considered) the fact that the landowners were employed by the Sheriff’s Office. These actions refute the Grand Jury’s suggestion of an intention to shield the operation or the landowners. The more ordinary explanation is the more likely one. Nothing staff encountered—the empty new building, the nearby storage containers represented to be empty, the absence of any visible hazardous materials—presented an obvious, immediate hazard. The metal storage building under construction was represented by the landowners, under penalty of perjury, as a place to store farm equipment only, with an almond orchard under their ownership nearby. The local Fire Chief advised that activities elsewhere at the site included storage of “safe and sane” fireworks and that more hazardous materials, which were regulated by the ATF, were stored separately and appeared to meet fire-separation requirements. Altogether, nothing staff encountered presented an obvious, immediate hazard; the matter was treated as routine, was not assigned a high priority, and was not later revived for further investigation. In no way, however, can the absence of follow-up be equated with responsibility for the Oakdale Fire. The County rejects this finding on that basis. There are several specific reasons for this position. First, as explained above, the vast quantities of illegal explosives and dangerous onsite conditions that caused the July 1, 2025 explosion were not apparent at the site during the Chief Building Official’s June 2, 2022 visit to perform a meter release. Enforcement directed at the conditions that County staff understood to exist in June 2022 would have been directed at different, much less dangerous concerns than the conditions that caused the Oakdale Fire three years later. County staff cannot reasonably be blamed for failing to foresee that these conditions—chiefly, storage containers that the local Fire Chief believed were used for “safe and sane” fireworks and smaller groups of containers that the Fire Chief said were regulated by the ATF—would eventually evolve into conditions that the indictments allege included the storage, handling, and assembly of one million pounds of illegal explosives three years later. Second, primary regulatory authority over fireworks operations rests with the State Fire Marshal. Under Health & Safety Code §§ 12550, 12552, 12555, and 12590-12591, the State Fire Marshal—not the County—is vested with authority to license, inspect, and shut down pyrotechnic operations statewide. The State Fire Marshal issued and annually renewed Public Display, Wholesaler, and Importer/Exporter licenses to Devastating Pyrotechnics and Blackstar Fireworks at the Esparto address through July 1, 2025, including an Importer/Exporter renewal issued to Devastating Pyrotechnics on May 22, 2025—one day after the State Fire Marshal’s investigators seized approximately 500,000 pounds of that enterprise’s product, including illegal explosives, in the City of Commerce, California. By contrast, the County did not issue any approvals for fireworks operations at the site, and its legal authority over such operations is substantially more limited. As previously stated, the County received no notice from ATF or the State Fire Marshal of the issuance or renewal of these licenses. Attachment A Third, the indictments allege that the operators developed and expanded the enterprise through a sustained pattern of misrepresentation that defeated detection at every level of government for many years. The main indictment alleges that the principals obtained federal ATF licenses through front licensees to circumvent the disqualification of the principal operator, submitted a sworn building permit application falsely declaring agricultural-only use, fabricated lease agreements to legitimize the storage arrangement to regulators, and represented operations to local, state, and federal authorities—including ATF, FBI, the State Fire Marshal, and the Esparto Fire Protection District—as properly licensed and lawful. By contrast, County code enforcement operates on observable conditions and information reasonably available through routine inspection, complaint response, and permit review. It is not a criminal investigative function, and it is not equipped to penetrate an organized, multi-party scheme premised on falsified federal licenses, fraudulent permit applications, and other actions and representations that deceived many regulatory authorities into believing that key safety requirements were being met. Fourth, the Grand Jury's assumption that a County code enforcement letter in 2022 would have caused the principals to cease rather than greatly expand this enterprise is speculative and difficult to reconcile with how the operators are alleged to have responded to actual regulatory pressure. For instance, based on the indictments and related court filings, those now charged with various crimes are alleged to have: • Continued and expanded operations at the Esparto site after a June 14, 2023 explosion at a San Jose storage facility that was storing explosives linked to Devastating Pyrotechnics; • Continued and expanded operations through the May 2025 State Fire Marshal seizure of about 500,000 pounds of consumer and commercial fireworks as well as significant quantities of illegal explosives in the City of Commerce; • Obtained renewed State Fire Marshal licensure through further misrepresentation after that seizure; and • Actively conspired—after seven of their workers died during the July 1, 2025 explosions and fires—to restart operations in Nevada or other states using different names. Altogether, in response to every serious accident or run-in with law enforcement, those now charged allegedly continued their illegal and dangerous enterprise undaunted. The loss of seven lives in the Oakdale Fire is a profound tragedy. The County’s disagreement with
F6 Page 1
The Community Services Department lacks appropriate formal training programs for new employees. Instead, instruction is provided informally via on-the-job mentoring. Response. The Department disagrees partially with this finding. The Department disagrees with F6 to the extent it concludes that appropriate formal training is absent and that new employees are instructed only through informal on-the-job mentoring. Both formal and on-the-job training are used, and the combination is appropriate for the multidisciplinary, field-based work the Department performs. New and existing staff are required or encouraged to pursue training through state and professional partners, including the California Association of Code Enforcement Officers (CACEO), the International Code Council (ICC), California Building Officials (CALBO), the Sacramento Valley Association of Building Officials (SVABO), and others, and management directs staff toward coursework suited to their assignments. Code Enforcement Officers must hold Penal Code section 832 certification as a condition of the position, and since 2022 staff have maintained CACEO's Certified Code Enforcement Officer (CCEO) certification and are encouraged to attend annual conferences to stay current with statewide standards. On-the-job training complements this formal instruction. Effective code enforcement requires applying general principles to specific cases—work learned through direct exposure to inspections, interdepartmental collaboration, guided case review, and consultation with subject-matter specialists. That experiential component cannot be fully replaced by classroom training. This combined approach has supported the transfer of institutional knowledge to new personnel. The Department nonetheless recognizes that more formalized onboarding, training documentation, and a structured continuing-education program would improve consistency and accountability, and it is assessing its current approach with those improvements in view. This finding is addressed further in the responses to
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Community Services Department employees are not trained on a wide variety of County ordinances that would increase public safety and County revenues. Response. The Department disagrees partially with this finding. The Department includes many divisions and functions, including planning, building, public works, environmental health, fleet management, and the Landfill, and the Department does not agree that it is practical or necessary to provide “training on a wide variety of County ordinances” to employees across the Department. However, the Department is assessing instances where more training focused on County ordinances relevant to specific job functions would be helpful. Attachment A The suggestion of a relationship between employee training and opportunities to increase County revenues is unclear and not supported by the Report. To the extent this is directed at code enforcement, while certain enforcement activities may result in revenue collection through permit fees and fines or penalties, these outcomes are incidental to the County’s core enforcement objectives. In most cases, staff work with property owners, businesses, and residents to resolve violations informally through education and other non-punitive measures before escalating enforcement to citations and penalties, which are generally reserved for situations involving significant public safety risks, environmental harm, or circumstances when voluntary compliance efforts have repeatedly been unsuccessful. This Finding is addressed further in the response to
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Yolo County lacks an effective electronic system for keeping track of code enforcement cases. Response: The Department disagrees partially with this finding. The Department currently uses “Clariti” to manage information relating to code enforcement matters. Clariti replaced an earlier system, “Trackit,” for most purposes on January 1, 2023. Clariti generally performs well for Code Enforcement operations and provides important recordkeeping capabilities. Clariti includes parcel-level information, complaint tracking, and permit information, but much information is maintained outside of Clariti in other formats and existing software platforms are not fully integrated across various divisions of the Department of Community Services. The Department agrees that a more integrated enterprise-wide system—or improved interoperability among existing systems—could enhance coordination, improve transparency, reduce inefficiencies, and strengthen cross-departmental collaboration. This Finding is addressed further in the responses to
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Yolo County operational code enforcement procedures are ineffective, and not in a state of control. Response: The Department disagrees partially with this finding. The County’s ordinance framework—particularly Title 1, Chapter 5 of the Yolo County Code, adopted in 2020—reflects modern administrative enforcement practices, including standardized notice and citation procedures, hearing and appeal rights, nuisance abatement authority, administrative penalties, and cost-recovery mechanisms. Additionally, the Department believes that the code enforcement program is effective at addressing violations throughout the unincorporated area, that staff receive significant practical and ongoing training, and that interdepartmental coordination has improved over time. Room for improvement remains, but the Department does not agree that program procedures are “ineffective” or “not in a state of control.” This Finding is addressed further in the response to
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Yolo County’s systems are isolated across departments, which impedes effective exchange of specialized information. Response: The County disagrees partially with this finding. Attachment A Information exchange across departments and even across divisions of the Community Services Department is impeded by fragmented technology and reliance on informal coordination. For example, the Clariti case management platform is generally functional within Code Enforcement, but Environmental Health operates on a separate platform, supporting documentation is frequently maintained in shared drives outside the case management system, and various other functions are less than optimal. As a result, staff may be required to access multiple systems to obtain a complete understanding of a property history, active permits, prior violations, complaint activity, inspection records, or enforcement actions. In these and other ways, County technology systems are fragmented and create some inefficiencies and operational limitations. These challenges are mitigated by frequent collaboration and effective communication within the Department and with other County departments as needed. The Department is evaluating other potential ways to reduce these challenges, as reflected in its responses to
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Code enforcement activities are sometimes performed without documentation or effective procedures to evaluate the quality of the work and its timely completion. Response: The Department disagrees partially with this finding. In most circumstances, enforcement and regulatory activities are documented at a level appropriate for operational needs. Existing records systems, permit files, inspection reports, emails, photographs, case notes, and enforcement tracking systems collectively provide substantial documentation regarding Departmental activities and decisions. That said, the Department has not formalized the procedures necessary to consistently evaluate the quality and timely completion of code enforcement activities. The Department acknowledges that while staff routinely maintain records relating to complaints, inspections, notices, correspondence, enforcement actions, and case outcomes, the Department’s ability to systematically evaluate the progress and quality of work performed is hampered by the lack of formal procedures, defined timeframes, and a framework for consistent supervisory review. This Finding is addressed further in the responses to
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The lack of effective code enforcement procedures allows County staff to avoid challenging or uncomfortable cases by selectively prioritizing less critical activities. Response: The Department disagrees with this finding. The Department acknowledges that the current prioritization framework is informal, and that this environment can result in short-term reactive demands displacing longer-term enforcement priorities—not because anyone affirmatively chooses that outcome, but because no procedural framework to ensure consistent risk-based prioritization is in place. The Department disagrees that this procedural situation is something that County staff use to avoid challenging or uncomfortable cases. No evidence supporting this assertion appears in the Report. The Report’s characterization frames the conduct in terms of staff motive, and neither the Grand Jury’s record nor the Department’s work in coordination with Mr. Pytel supports it. The Grand Jury itself acknowledges that it “could not determine definitively” why officials did not take additional action regarding the Esparto referral. The Department believes, and expects Mr. Pytel’s assessment to confirm, that it has a strong service-oriented culture, significant institutional resilience despite resource Attachment A limitations, and a continued commitment to responsiveness and public service. Altogether, the Department’s primary challenges are no different than the systemic and operational challenges faced state-wide by public agency staff and cannot be imputed to staff motives.
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The Community Services Department employs only one full-time code enforcement officer to enforce County codes across nearly one thousand square miles of unincorporated Yolo County area. Response: The Department agrees with this finding. The Community Services Department currently employs one full-time code enforcement officer responsible for code enforcement activity across the unincorporated area of the County, and the Department accepts the Civil Grand Jury’s underlying concern that this staffing level is constrained relative to the County's geographic size and the volume of complaint-driven and proactive enforcement responsibilities the program carries. At the same time, the finding does not acknowledge that code enforcement responsibilities are shared with Building Services, Planning, Environmental Health, and other Community Services personnel who frequently identify and enforce codes or refer violations during their regular duties. Additionally, certain civil and criminal laws are enforced by law enforcement and/or directly by the District Attorney’s Office. The Code Enforcement Officer is a subject matter expert on the due process and enforcement mechanisms specific to the Yolo County Code to achieve voluntary compliance whenever possible, and compelled compliance otherwise. They work with other subject matter experts that know their portions of the Yolo County Code (and related state and federal laws, in some instances) in detail, such as Building, Planning, Environmental Health, and other staff. They are not responsible for all code enforcement activities occurring in the unincorporated areas of the County. This Finding is addressed further in the response to
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The Board of Supervisors has encouraged a laissez-faire attitude toward new construction and businesses located in unincorporated areas. Response: The Board disagrees with this finding. Code enforcement programs in most California cities and counties rely heavily on education and voluntary compliance, particularly for minor violations, rather than a strict “no tolerance” approach. The same has long been true in Yolo County. But the Board disagrees with the Grand Jury's assertion that it “encouraged a laissez-faire attitude” toward new construction and businesses, particularly to the extent the Grand Jury is suggesting by this finding that the Board endorsed turning a blind eye toward even serious County Code violations. In particular, the Board disagrees with and rejects this finding as applied to the Board’s current membership. Further, the Board is not aware of (and the Report fails to describe) any action, vote, resolution, or directive of a prior Board of Supervisors—including the Board as composed in mid-2022—that would provide the evidentiary basis that a finding of this gravity requires. In the Background section of the Report, the Grand Jury attempts to assess why County staff did not take any additional action (beyond requiring a building permit application) following the June 2, 2022 site visit and related information received at the same time, including information provided by the Chief of the Esparto Fire Protection District. The Report acknowledges that among all County staff interviewed, “no one could recall any further conversations or meetings about the site.” (Report at p. 15.) The Report later concludes that the Grand Jury “could not determine definitively” why staff did not take further actions. Yet despite acknowledging the lack of any evidence on this issue, the Report then offers many ideas that reflect its own guesswork. Such as: • “It is possible there may have been a reluctance to antagonize some sheriff's officials”; • “Perhaps, in the absence of a deliberate decision to take some action, enforcement at this particular property was never conducted”; and • “Although no County official could recall such a decision, Building Division officials may have decided that attempting to enforce the County ordinances was too much trouble.” There is no credible basis for such speculation. The Grand Jury appears to have intended this conjecture to provide context for its criticism of the Board. But the testimonial passages most directly relevant to the Grand Jury’s critique of the Board of Supervisors are also framed in similar terms: the Grand Jury “heard testimony” and “received testimony” that County employees “believe” the Board “wanted” them to take a tolerant approach toward code violations. The Board does not dispute that such testimony was received. However, the Board disagrees that testimony described in these terms—employees’ beliefs about what the Board wanted, with no identified Board action, vote, resolution, or directive, all layered on the Grand Jury’s own speculation about staff motives— provides any meaningful support for a finding that “the Board has encouraged employees to take a laissez-faire attitude toward new construction and business in the unincorporated area.” Attachment A Altogether, the record before the Grand Jury, as the Grand Jury itself describes it, does not support this finding, and the Board is aware of no other credible evidence that does. The Board must therefore strongly disagree with the Grand Jury’s finding that it fostered a tolerant or “laissez-faire” attitude toward new business and construction, and the Board rejects the Report’s baseless implication that any such attitude—rather than the very limited conditions existing in mid-2022, as detailed above—may have discouraged County staff from taking additional actions at the Esparto site.
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The Board of Supervisors has not provided adequate resources for the enforcement of building and safety codes. Response: The Board disagrees with this finding. As context for this response, the Board of Supervisors is the governing body of the County. Its principal role is to set Countywide policy—expressed through its formal actions and the County Code, General Plan, Strategic Plan, and other official actions. The Board allocates resources through the annual budget process, ensuring limited County funding is allocated in an appropriate manner that balances community needs, Board priorities, and federal and state mandates. The Board does not directly dictate most aspects of how County functions and services are carried out at the department level by the approximately 1,650 employees of the County. Such decisions are left to the sound discretion of department heads in coordination (as needed) with the County Administrator. This Board asserts that it has faithfully funded the Building Division of the Department of Community Services at a level sufficient to discharge its inspection and enforcement duties under the California Building Code and related uniform codes. Such services are also supported by fees on building permits and related approvals, as is customary across the state. The Board is unaware of any connection between the resources it approves through the annual budget process for the Building Division and the deficiencies alleged in the Report, particularly relating to conditions on the Esparto Site. Indeed, the Chief Building Official successfully engaged with representatives of the Esparto Site owners to require a building permit for the (as they misrepresented) agricultural storage building then under construction. In connection with that matter or otherwise, at no point was the Board apprised that the Chief Building Official or other Building Division staff lacked the resources necessary to perform their work to enforce building and safety codes. In fact, the Report acknowledges the success of the Building Division’s efforts in this regard. (Report at p. 13, stating, “The property owner agreed to the full permitting process, including revisions, fees, and inspections.”). To the extent this finding is directed at the resources allocated by the Board through the annual budget process to support code enforcement—a distinct function from “building and safety code” enforcement—the Board also disagrees with this finding. This Board has consistently funded code enforcement and related functions—such as Environmental Health, the Agricultural Commissioner, and the Consumer Fraud and Environmental Protection Unit of the District Attorney’s office—at a level consistent with its best understanding of what is needed to protect public health and safety. This Board has done so even though some such functions, including code enforcement, are entirely discretionary (see footnote 3, above) and the Board has no obligation to fund them at any particular level or at all. Attachment A
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At the time (2022–2023) building permits were issued for the Machado property the following County officials failed to enforce California Fire Code and Yolo County Fireworks Ordinances: (a) Department of Community Services Chief Assistant Director; (b) Principal Planner; (c) Chief Building Official; (d) Supervising Hazardous Materials Specialist; (e) Code Enforcement Officer; (f) Building Inspector(s); (g) Esparto Fire Protection District Chief; (h) Yolo County Sheriff’s Lieutenant; (i) Yolo County Sheriff’s Esparto Resident Deputy. Response: The Board disagrees partially with this finding. Except as necessary to provide factual context, the following response does not address the portion of this finding relating to the former Sheriff’s Lieutenant now charged with various crimes in People v. Chee, et al., out of respect for those proceedings and the ongoing investigation occurring in connection therewith. The Board acknowledges that there are no records indicating that County staff took any enforcement action relating specifically to fireworks in the 2022-2023 timeframe, including under the California Fire Code or the County Fireworks Ordinance. County records show instead that the Chief Building Official required the property owner to obtain a building permit for an agricultural storage building after viewing certain building features, including an electrical panel, at the conclusion of the June 2, 2022 inspection. The final certificate of occupancy (concluding the building permit process) was issued on April 20, 2023, and authorized the building to be used for commercial storage for Building Code reasons.4 The indictments filed in People v. Chee, et al. identify the landowner’s affirmative misrepresentations in this regard as the basis for various felony charges. The Board expresses no position as to other staff positions identified in this finding, given their lack of direct responsibility for enforcing the California Fire Code or the Fireworks Ordinance. Generally: • Enforcement of the California Fire Code rests primarily with State Fire Marshal, local fire protection districts, and Building Division staff (including the Chief Building Official). • Fireworks are regulated at both the state and local level, with the State Fire Marshal and CAL FIRE responsible for enforcing provisions of the State Fireworks Law (California Health & Safety Code sections 12500 et seq.). • Responsibility for enforcing violations of the Fireworks Ordinance relating to dangerous fireworks storage rests primarily with Code Enforcement (staffed by a Code Enforcement Officer and supervised by the Chief Building Official, addressed previously in this response). While the Sheriff’s Office is authorized to enforce some provisions of the Fireworks Ordinance, its enforcement role on storage and other property use matters is secondary to County code enforcement staff. Lastly, the Esparto Fire Protection District Chief is the chief of an independent special district and is not an employee subject to the Board’s direct oversight. The Board takes no position on individual conduct within the Esparto Fire Protection District. 4 This is the lowest-level occupancy that can be certified under the Building Code, and it allows the farm equipment storage activities represented as the landowners’ intended use. A commercial storage occupancy does not authorize the storage or handling of explosives or dangerous fireworks. Attachment A III. FINDINGS DIRECTED TO THE DEPARTMENT OF COMMUNITY SERVICES The Department of Community Services provides the following responses to Findings F6-F13. Some of the following responses were prepared with input from Darren Pytel, the former City of Davis Police Chief (2015-2024) who is currently serving as an extra-help attorney in the Office of the County Counsel. During his 41-year tenure with the City of Davis, Mr. Pytel managed code enforcement for 14 years and developed close familiarity with its operations. Mr. Pytel is concluding an independent assessment of the County’s code enforcement program to inform ongoing work directed at enhancing its effectiveness.

Recommendations 10