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41 <br />The <br />Saber Living <br />Network <br />June 17, 2016 <br />City Council <br />Community Development Department <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />Re: Comments on proposed ordinance regarding multiple tenancies in single apartment units <br />The Sober Living Network sets standards for, certifies and supports approximately 500 <br />independent sober living homes in Southern California, and has been performing this service for <br />over 20 years. Through our Orange County Sober Living Coalition we have been active in Santa <br />Ana for most of that time. Our expertise is in standards and support services through which <br />sober living homes operate as true community assets. We are co-founders of the National <br />Alliance for Recovery Residences (NARR), the national standard-setting and advocacy <br />organization for sober living homes and other types of recovery residences. NARR and the <br />Network regularly consult with state and local governments on best practices for individual <br />providers and for statewide systems of residences. We are not attorneys, but we do encounter <br />discriminatory and at times hostile environments from time to time. We have extensive <br />experience in fair housing matters where the rights of disabled individuals are affected or <br />threatened. We often advise local governments on permissible zoning regulations in situations <br />where fair housing rights are an issue. Our experience in California and elsewhere suggests that <br />local governments are often induced by local residents to violate their obligations to persons <br />with disabilities. <br />We were alerted to your pending moratorium, immediate penalties for perhaps hundreds of <br />existing Santa Ana landlords, and the underlying rationale for these actions by a well-regarded <br />addiction recovery services provider who is a member of our organization. <br />In reviewing the proposed ordinance, a few things raise concerns. Sober living households <br />operate as single family -like units, and are protected in their access to housing by California and <br />Federal law. Although most sober living homes are sited in single-family dwellings and <br />neighborhoods, many utilize multifamily dwellings. Fair housing laws are applicable regardless <br />of the dwelling type. The proposed ordinance fails to distinguish between uses that are <br />protected by law and those that are not. <br />Specifically, the law would make the following provisions effective immediately, and for a <br />period of at least 45 days and perhaps longer at the discretion of the City Council: <br />P.O. Box 5235 1 Santa Monica, CA 90409 1 (310) 396-5270 <br />www.soberhousing.net I info@soberhousing.net <br />