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4. By requiring that hive maintenance materials (which I will assume is bee boxes) be placed in a bee proof container or indoors actually creates more nuisance for the city. Wild swarms of bees will move into empty equipment and not go into structures walls, attics and valve boxes. Who better than a beekeeper to deal with wild swarms? 5. There are hundreds feral or wild hives in the city. They will be attracted to the smell of the hive components, wax and honey when trying to find a home and may find a place in a neighbor's tree for an hour up to about 3 days before they move on. Unless the neighbor sees the swarm coming out of the beekeepers hive or a beekeeper with training goes into the hive code enforcement will not be able to determine if the swarm is the beekeepers or a wild swarm. So unless you train your code enforcement in beekeeping and they are allowed to open the beekeeper's hives all the beekeeper has to say is the swarm is not mine. For this reason I suggest you strike the swarm nuisance violation. 6. 1 have read through many codes on beekeeping in doing my research. In none of them do I find a penalty violation schedule like the one proposed. I suggest that instead you require that the beekeeper resolve the problem or remove the hive from the premises. The goal is to allow bees without them intruding on the neighbor's ability to enjoy their property and to safeguard the public. If the beekeeper is not able to take corrective measures to do so then instead of fining them it would be better to just require that they remove the hives. I would like to suggest an alternative similar to what the City of Fullerton just passed at their planning commission meeting. A set of Best Management Practices published on the cities website guiding beekeepers as to what the city expects. Then putting into code what the city considers a public nuisance, such as: The city will consider bees a public nuisance when any of the following occurs: a. Colonies of bees exhibit defensive or objectionable behavior or interfere with the normal use of neighboring properties. b. Bees or hives kept in anything other than a removable frame hive. c. Hives that are abandoned or not maintained on a regular basis. With these concerns in mind I respectfully request that you table this issue till a better code can be written. As I have expressed before I would be more than happy to assist your staff if they desire. Sincerely, Sean Crowley What follow is a copy of the Best management practices that I submitted to the staff when this whole process started. They were written to educate potential beekeepers and the public at large. I believe you will find them informative and helpful in making your decision. BEEKEEPING IN SANTA ANA The City of Santa Ana recognizing the importance of bees in our ecosystem has had the forethought to legalized beekeeping within the city limits. Santa Ana is a wonderful location to raise bees for honey, wax and other bee products. Bees are directly required to pollinate approximately 1/3 of the produce we eat. Indirectly bees are also responsible for products like alfalfa pollination to produce alfalfa seed which gives us meat and dairy products.