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HomeMy WebLinkAbout8.3 Exparte Contacts Policy CITY CLERK File # DGJ[][Q]-[2d~ AGENDA STATEMENT CITY COUNCIL MEETING DATE: December 20, 2005 SUBJECT: Proposed Ex parte Contacts Policy Report Prepared by Elizabeth H Silver, City Attorney ATTACHMENTS: I. Proposed Resolution Pennitting Ex parte Contacts in Quasi- Judicial Proceedings (Option I) 2, Proposed Resolution Prohibiting Ex parte Contacts in Quasi- Judicial Proceedings (Option 2) 3. List of Quasi-Judicial Proceedings RECOMMENDATION: r// 1. Receive Staff presentation. 2. Receive pub1ic comments, 3, Deliberatc 4, Adopt Resolution lor 2, or provide direction, FINANCIAL STATEMENT: Nonc, DESCRIPTION: Ex parte contacts are communications or other information received outside the hearing process that are relevant in an adjudicatory matter before city officials, Ex parte contacts can also include site visits made by city officials outside the hearing process, No state statutes regulate ex parte contacts in administrative proceedings ofJoca] governing bodies, Additionally, the Municipal Code and City policies are silent as to ex parte contacts, Y ct, as is discussed below, ex parte contacts can result in constitutional due process issues and create the appearance of unfairness in City administrative proceedings. In order to avoid confusion and the appearance of impropriety, the City may wish to provide guidance to officia]s with regards to ex parte contacts through the adoption of the proposed ex parte contacts policy, -----------------------~---_.~~--------------------------------------------~~~------------~~------------------ COpy TO: Page 1 01'6 ITEMNO._~.~ Why should the City consider adoptíni a Policy Re¡:arding Ex tJarte Contacts? Both the United States and California Constitutions protect against the deprivation of procedural due process rights of parties in administrative proceedings where a property right is at stake, (U.S. Const" 14th amend" § I; Cal. Consl., art, I, § 7.) California law extends procedural due process rights for parties to administrative proceedings further than does federal law, (See Lockheed Shipbuilding and Construction Co, (1973) 35 Cal.App.3d 776, 780-81.) Due process before an administrative body requires a fair and impartial hearing before a neutral and unbiased decision-maker, (Nightlife Partners, Ltd, v, City of Beverly Hills (2003) 108 Cal.AppAtlt 8J, 90 (Nightlife Partners),) Tn fact, due process not only requires a fair and impartial hearing, it requires the appearance of a fair and impartial hearing, (ibid,) A California Appeals Court has held that the appearance of impartiality is especially important in administrative hearings due to the "broad applicability of administrative hearings to the various rights and responsibilities of citizens and businesses, and the undeniable public interest in fair hearings in the administrative adjudication arena," (Ibid.) The court reasoned that administrative hearings often affeet significant rights and serve as the first level of adjudicatory review. (Ibid.) Even before such cases broadening the concept of due process, the courts had held that due process requires that the decision must be based on the official record in the case. Thus, one court held that reliancc on information obtained from discussions with the parties outside ofthe hearing was improper because it resulted in an unfair hearing. (See Safeway Stores, Inc. v. City of Burlingame (1959) 170 Ca1.App.2d 637,645-47.) It is wel1~settled that due process protections do not attach in all administrative proceedings. (Horn v. County of Ventura (1979) 24 Cal.3d 605, 612 (Horn).) Rather, due process is guaranteed only in administrative quasi-judicial proceedings, and not in quasi-legislative proceedings. (Ibid.) Quasi-judicial proceedings involve an adjudicative function wherein city officials serve in a judge- like capacity, The purpose of a quasi-judicial proceeding is to apply a legislative rule to an existing set of facts. (Horn, supra, 24 Cal.3d at p. 613; Slrumsky v. San Diego County Employees Retirement Assn. (1974) II Cal.3d 28, 35, n.2 (Strumsky).) Quasi-judicial proceedings most often arisc in the context of an appeal from the Planning Commission to the City Counci1. For examplc, Planning Commission actions on site development revicw permits, conditional usc pennits, variances, and tentative subdivision maps can be appealed to the Council and all these are quasi-judicial actions. However, the Dublin Municipal Code provides for many other quasi-judicial proceedings. (See Attachment 3 for a List of Quasi"Judicial Proceedings provided in the Dublin Municipal Code.) Quasi-legislative proceedings are those in which city officials serve in a policy-making capacity. The purpose of a quasi-legislative proceeding is to create a rule of general applicability for future guidance. (Horn, supra. 24 Cal.3d at p. 613; Strumsky, supra, II Ca1.3d at 35, n.2.) As compared to a case-specific quasi-judicial decision, a quasi-legislative proceeding has a much broader scope that applics to future cases. Quasi-legislative proceedings in the City include, but are not limitcd to, actions on general plan amendments, specific plan amcndmcnts, zoning decisions and development agreements. Page 2 of6 It is notable that the State Administrative Procedure Act (AP A) seeks to ensure fair and impartial adjudicatory proceedings by prohibiting all ex parte contacts. Government Code § 11430,10. Although the AP A does not apply to local governments, a recent California Appeals Court decision used the provisions of the AP A as thc standard for imposing due process protections in an administrative proceeding. (Nightlife Partners. supra, ] 08 CaJ.AppAth at pp. 9] -92.) Still, in Flagstad v. City of San Mateo (1957) 156 Cal. App.2d 138, 141, the Court upheld a city council's decision to grant a variance for construction and operation of a service station, even though the councilmen had visited the proposed site outside the administrative proceeding. The Court held that the councilmen had fully disclosed the views from their indcpcndcnt invcstigation on the record, and persons protesting the variance were given the opportunity to challenge these views. (Ibid,) Thus, the current state of the law appears to be that ex parte contacts are pennissible provided that the naturc of thc contacts is disclosed on thc rccord of the proceeding so that the parties have an opportunity to rebut or otherwise provide their views on the information obtained from thc contacts. What Options does the City have in Adoptinl! an .Ex tJarte Contacts Policv? Given the state of the law, the Council may wish to consider the following two options when considering the adoption of an ex parte contacts policy. I. First, the City may permit ex parte contacts and require city officials to report these contacts on the record at a quasHudicial proceeding. (See Attachment 1.) Pennitting ex parte contacts imposes no limits on city officials and is therefore an easily-applied rule. Additional1y, city officials would not need to avoid contacts regarding pending adjudicatory hearings. The disclosure of ex parte contacts facilitates a more transparent hearing process and overall fairness because the contact is disclosed on the record at the commencement of the hearing. However, this policy provides less legal protection from charges of bias or unfairness than the second option. Furthermorc, the accuracy of the disclosurc of the contact is dependent on the recolle"iion of the City offi.cial and thus vulnerable to a challenge as an inaccurate or incomplete disclosurc. 2. Second, the City may prohibit ex parte contacts and require city officials to report any such contacts on the record at a quasi-judicial proceeding. (Sce Attachment2.) Prohibiting all ex parte contacts provides city officials with a bright-line rule in defining the communication they may have with the public and involved parties regarding a pending quasi-judicial proceeding. A prohibition on eX parte contacts fosters trust bctween the public and city officials and will prevent accusations of bias or unfairness. Although the ban sacrifices the valuable communication bctwcen a governing body and its constitucnts, this option goes the farthest toward assuring fair]y- conducted hearings. Finally, this option provides the most amount of protection from charges of bias or untìlirness, thereby reducing the possibility of litigation. What communications are covered bv the Proposed Ex varte Contacts Policy Options? Th.e Proposed Ex parte Contacts Policy options would apply to contacts such as individual conversations, written communications, electronic mails, telephonc calls, and visits to sites that are the subject of a quasi -judicial proceeding. Page 301'6 Thc Proposed Ex parte Contacts Policy options would not apply to communications made on the record at the proceeding. In all options, in the event that information is received outside the proceeding, the information must be discJosed on the record at the proceeding. To whom would the Proposed Ex tJarte Contacts Policv options applv'? The Ex parte Contacts Policy options would apply to all city officials that preside over quasi- judicial proceedings, including, but not limited to, members of the City Council, members of the Planning Commission, the Zoning Administrator, the City Manager or designee, and any other city employee or officer that acts as a decision maker in a quasi-judicial proceeding. An A¡;¡endas Should Include Time for Officials to Disclose anv Ex Parte Contacts We recommend each agenda that includes a quasi-judicial item include a timc for officials to disclose any ex parte contacts the member may have had, This will be a reminder to officials to disclose any such contacts. Each agenda would include a statement such as the following prior to the Staff prcsentation: "Disclosure of ex parte contacts (persons involved in ex parte contact, the content of the ex parte contact (what information was provided, what was discussed, what was said), when the ex parte contact occurred and where the ex parte contact occurred)." Tf an ex parte contact has been made, the minimum amount of disclosure required includes the persons involved in the ex parte contact, the contcnt of the ex parte contact (e.g., what information was provided, what was discussed, what was said), when the ex parte contact occurred and where the ex parte contact occurred, A good way to remember this is "who/what/when/where". To What Proceedings would the Proposed Ex TJarte Contacts Policy options apply? To detennine when the Proposal Ex parte Contacts Policy applies, it is important to distinguish between quasi-judicial and quasi-legislative proceedings. The Proposed Policy options only apply to quasi-judicial proceedings. The Policy options do not apply to quasi-legislative proceedings. Becausc a quasi-judicial proceeding may render a decision that deprives the party before it of a property interest, the government must provide due process protections. (Horn, supra, 24 Ca1.3d at pp, 612-13.) Conversely, a quasi-Jegislative proceeding does not implicate due process protections, because there is no concern for a deprivation of a property interest. (Ibid.) Some proceedings may defy characterization as either a pure quasi-judicial or pure quasi- lcgislativc proceeding. When a proceeding involves both adjudicativc and legislative elements, it may be characterized as a mixed quasi-judiciallquasi-legislative proceeding: For purposes of the Proposed Policy options, mixed quasi-judicial/quasi-Iegislative proceedings are treated as quasi-legislative proceedings, The quasi-legislative function of a mixed proceeding is of foremost importance because the adjudication of the case cannot be decided until the legislation which applies to the case is settled. . Therefore, the primary element of a mixed procecding is lcgislative, and the Ex parte Contacts Policy would not apply. Mixed quasi-judiciallquasi-Iegislative proceedings in the City Page 4 of 6 include, but are not limited to, a site development permit or conditional use pennit approval that is contingent upon a General Plan amendment or a rezoning. For example, the SOITento at Dublin Ranch Area F project included both quasi-judicial and quasi- legislative actions. On September 13, 2005, the Planning Commission approved Master Tentative Tract Maps for Area F West (Tract 7641) and Area F East (Tract 7651), for the Sorrento at Dublin Ranch Area F project. (Planning Commission Reso, 05-52.) This vesting tentative map action constitutes a quasi- judicial proceeding. However, this tentative map approval was contingent upon the City Council's approval to amend the Planned Development for Dublin Ranch Area F North, to increase the number of units pennitted under the Plann.ed Development. (City Council Ord. 24-05.) Because the Sorrento at Dublin Ranch Area F project involved a quasi-judicial action contingent upon a quasi-legislative action, it would be treated as quasi-legislative; thus, the Ex Parte Contacts Policy would not apply. What if the Prohibition on ExtJarte Contacts 0l'tion (Attachment2) is adonted and is violated? Tf a city officer engages in ex parte contacts with a party to a quasi-judicial proceeding or inadvertently learns of information regarding the quasi-judicial proceeding, any issue regarding the ex parte contacts may be cured through disclosure on the record at a subsequent proceeding. (Flagstad v. City of San Mateo, supra, 156 Cal.App.2d at pp. 141-42.) Such disclosure on the record CUTes the Ex parte Contacts Policy violation because it affords aU partics the opportunity to hear and respond to the communication before the body. (Ibid.) The Policy also providcs that ifthc Policy is violated, it shaU not constitute independent grounds for invalidating the decision. Despite this lan6'Uage in the Policy, it would not prevent the parties from arguing that due process was violated, What if a Court Finds an Tmproper Ex tJarte Contact has been made? As elected officials responsible to an clectorate, it seems counterintuitive to adopt a policy which prohibits communication between city officials and city residents regarding pending quasi-judicial proceedings. However, a breach of due process rights for pcrsons involved in a pending quasi-judicial proceeding can have serious consequences, Two recent Court of Appeals due process cases invalidated decisions from administrative hearings where the hearing officials did not provide the "appearance of fairness." (Nightlife Partners, supra, 108 Cal.AppAth at p. 90; Quintero v. City of Santa Ana (2004) 114 Cal.AppAth 810, 817 (Quintero).) AdditionaUy, the Court in both decisions awarded attorney's fees to the plaintiff asserting a due process violation. (Nightlife Partners, supra, 108 Cal.AppAth at p. 99; Quintero, supra, 114 Cal.AppAth at p. 818.) Although both decisions addressed due process claims arising ITom the commingling of advisory and prosccutorial functions by city attorncys, the reasoning of the cases is applicable to ex parte contacts by city officials. In Nightlife Partners, the Court held that "due process in an administrative hearing also demands an appearance of tìlirness and the absence of even a probability of outside influence on the adjudication," (108 CalAppAth at p. 90.) It would seem that such "outside influence" might be inferred from a city official's ex parte contacts outside the quasi-judicial proceeding. In Quintero, the Court hcld that the City "must exercise vigilance and caution, to ensure not only fairness, but the appearance of fairness." (114 Cal.AppAth at p. 817.) These due process cascs require the city officials to be impartial and fair, as weU as appear impartial and fair, when making decisions in administrative hearings. Page 5 of6 Finally, good public policy would seem to require that city officials execute their adjudicatory duties with fairness and impartia1ity. Prohibiting ex parte contacts fosters trust between city officials and city residents, and provides a clear rationale for why a city official must refrain from communicating about a pending adjudication. RECOMMENDATION Staff recommends the City Council hear Staff's presentation, consider any comments from the pub1ic, deliberate and adopt Option lor 2, or provide other direction Staff also recommends that the Council direct the Staff to include a time to disclose any contacts on any agenda that includes a quasi- judicial item. 786976-1; 114,1001 Page 6 01'6 \ lb OPTION 1 RESOLUTION NO. A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DUBLIN ESTABLISHING A POLICY REGARDING EX PARTE CONTACTS IN QUASI-mDICIAL PROCEEDINGS WHEREAS, the City Council, the Planning Commission, the Zoning Administrator, thc City Manager or designee, and other City officers conduct a number of quasi-judicial hearings in the course of pertorming their duties; WHEREAS, the due process clauses of the United States and California Constitutions impose certain requirements on local agencies that conduct such hearings, including a requirement that decision makers consider only that evidence that is presented at the hearing; WHEREAS, members of the City Council, the Planning Commission, the Zoning Administrator, and the City Manager or designee could potentially receivc information pertinent to quasi-judicial hearings outside of the formal hearing, which information is known generally as "ex parte contacts"; and WHEREAS, the City Council has detennined that it would be prudent to have a policy concerning ex parte contacts in quasi-judicial proceedings that applies to the City Council, the Planning Commission, the Zoning Administrator, the City Manager or designec, and other City Officials that make decisions in quasi-judicial proceedings; NOW, THEREFORE, the City Council of the City of Dublin does RESOLVE as follows: I. Purpose. Thc purpose of this policy is to ensure that decisions of the City of Dublin in quasi-judicial administrative ptoceedings are conducted in an impartial manner and comply with the requirements of Due Process under the Constitutions of the United States and the Statc ofCalifomia. 2. Policy. City Officials shall permit Contacts related to quasi-judicial proceedings. 3. Disclosure. City Officials shall disclose such Contacts on the record ofthe quasi-judicial proceeding, thereby affording interested persons the opportunity to hear and respond to the Contact. In preparing agendas for quasi-judicial hearings, City staff shall include an item for disclosure of ex parte Contacts prior to the opening of the public hearing. 4. Application, The Ex parte Contacts Policy shall apply only to quasi-judicial proceedings and shalJ not apply to quasi-legislative or mixed quasi-judiciallquasi-Iegislative proceedings. Page 1 of 3 ::t:T€t\\ '3. ~ \ ë...-~zD-DS- i ATI'A£;HM ENT ~CJD l 5. Effect of Violation. A violation of the Ex parte Contacts Policy shall not constitute independent grounds to invalidate any decision by City Officials. 6. Definitions. The following definitions shall apply to this policy: "Contacts" means the receipt of any information outside a quasi-judicial proceeding that is relevant in a quasi-judicial proceeding before City Officials. Contacts may include, but are not limited to, conversations, written communications, electronic mails, telephone calls, and visits to sites that are the subject of a quasi-judicial proceeding. "City Officials" means the City Council, the Planning Commission, the Zoning Administrator, the City Manager or designee, and any other city employee or officer that acts as a decision maker in a quasHudicial proceeding. "Disclosure" means, at a minimum, the persons involved in the ex parte contact, the content of the ex parte contact (e,g" what infonnation was provided, what was discussed, what was said), when the ex parte contact occurred and where the ex parte contact occurred. "Quasi-judicial proceeding" means a City proceeding in which a City Official applies cxisting legal standards to a particular set of facts that affects an individual or individuals. "Quasi-legislative proceeding" means a City proceeding in which City Officials create a rulc of general applicability for future guidance. Quasi-legislative proceedings in the City of Dublin include, but are not limited to, actions on general plan amendments, specific plan amendments, and zoning decisions. "Mixed quasi-judiciallquasi-Iegislative proceeding" means a City proceeding involving both adjudicative and legislative elements. Mixed quasi-judicial/quasi- legislative proceedings in the City of Dublin include, but are not limited to, sitc development pennit approval that is contingent upon a zoning ordinance amendment. 7. Effective Date, This Resolution shall take effect immcdiatcly. 8. Severabtltty Clause. The provisions of this Resolution are severable and if any provision, clause, sentence, word or part thereofis held megal, invalid, unconstitutional, or inapplicable to any person or circumstances, such megality, invalidity, unconstitutionality, or inapplicability shall not affect or impair any of the remaining provisions, clauses, sentences, sections, words or parts thereof ofthc ordinance or their applicability to other persons or circumstances. Page 2 of 3 3~Î PASSED, APPROVED, AND ADOPTED this day of December 2005, by the following vote: AYES: NOES: ABSENT: ABSTAIN: Mayor ATTEST: City Clerk 793733-t; tt4,toOl Page 3 of 3 YGò' OPTION 2 RESOLUTION NO. A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DUBLIN ESTABLISHING A POLICY REGARDING EX PARTE CONTACTS IN QUASI-JUDICIAL PROCEEDINGS WHEREAS, the City Council, thc Planning Commission, the Zoning Administrator, the City Manager or designee, and other City officers conduct a number of quasi-judicial hearings in the course of performing their duties; WHEREAS, the due process clauses of the United States and California Constitutions impose certain requirements on local agencies that conduct such hearings, including a requirement that decision makers considcr only that evidence that is presented at the hearing; WHEREAS, members of the City Coundl, the Planning Commission, the Zoning Administrator, and the City Manager or designee could potentia1ly receive information pertinent to quasi-judicial hcarings outside of the formal hearing, which information is known generally as "ex parte contacts"; and WHEREAS, the City Council has determincd that it would be prudent to have a policy concerning ex parte contacts in quasi-judicial proceedings that applies to the City Council, the Planning Commission, the Zolling Administrator, the City Manager or designce, and other City Officials that make decisions in quasi-judicial proceedings; NOW, THEREFORE, the City Council of the City of Dublin does RESOLVE as follows: I. Purpose. The purpose of this policy is to ensure that decisions of the City of Dublin in quasi-judicial administrative proceedings are conducted in an impartial manner and comply with the requirements of Due Process under the Constitutions of the United States and the State of California. 2, Poltcy, City Officials shall not intentiona1ly make or rcccive Contacts related to quasi- judicial proceedings, 3. Disclosure. Tn thc event that Contacts are nonetheless recei ved, City Officials shall disclosc such Contacts on the record of the quasHudicial proceeding, thcrcby affording interested persons thc opportunity to hear and respond to the Contact. Tn preparing agendas for quasi-judicial hearings, City staff sha1l include an item for disclosure of ex parte Contacts prior to the opening of the public hearing. 4. Application. The Ex parte Contacts Policy shall apply only to quasi-judicial proccedings and shall not apply to quasi-legislative or mixed quasi~judicial/quasi-legislative proceedings. ATT1\CnMt~NT L Page I of 3 5~l 5. Effect of Violation. A violation of the Ex parte Contacts Policy shall not constitute indcpcndcnt grounds to invalidate any decision by City Officials. 6. Definitions. The following definitions shall apply to this policy: "Contacts" means the receipt of any information outside a quasi-judicial proceeding that is relevant in a quasi-Judicial procceding before City Officials. Contacts may include, but are not limited to, conversations, written communications, electronic mails, telephone calls, and visits to sites that are the subject of a quasi-judicial proceeding. "City Officials" means the City Council, the Planning Commission, the Zoning Administrator, the City Manager or designee, and any other city employee or oftìcer that acts as a decision maker in a quasi-judicial proceeding. "Disclosure" means, at a minimum, the persons involved in the ex parte contact, the content of the ex parte contact (e.g., what information was provided, what was discussed, what was said), when the ex parte contact occurred and where the ex parte contact occurred. "Quasi-judicial proceeding" means a City proceeding in which a City Official applies existing legal standards to a particular set of facts that affects an individual or individuals. "Quasi-legislative proceeding" means a City proceeding in which City Oftìcials create a rule of general applicability for future guidance, Quasi-legislative proceedings in the City of Dublin include, but are not limited to, actions on general plan amendments, specific plan amendments, and zoning decisions. "Mixed quasi-judicial/quasi-Iegislative proceeding" means a City proceeding involving both adjudicative and legislative elements. Mixed quasi-judiciallquasi- legislative procccdings in the City of Dublin include, but are not limited to, site development pennit approval that is contingent upon a 7:Oning ordinance amendment. 7. Effective Date. This Resolution shall take etTect immediately. 8. Severabtlity Clause. Thc provisions of this Resolution are severable and if any provision, clause, sentence, word or part thereof is held illegal, invalid, unconstitutional, or inapplicable to any person or circumstances, such illegality, invaJidity, unconstitutionality, or inapplicability shall not affect or impair any of the remaining provisions, clauses, sentences, sections, words or parts thereof of the ordinance or their applicability to other persons or circumstances. Page 2 of 3 /.Q~ Î PASSED, APPROVED, AND ADOPTED this _ day of Deccmber 2005, by the following vote: AYES: NOES: ABSENT: ABSTAIN: Mayor ATTEST: City Clcrk 793732-1; tt4.1001 Page 3 of 3 7 Db -¡ A TT ACHMENT 3 List of Quasi-Judicial Proceedings provided in the Dublin Municipal Code Quasi-judicial proceedings in the city include, but are not limited to, actions on site development review pennits, conditional use permits, variances, and tentative subdivision maps, City Council hearings to close hazardous driveways; City Councilor Board of Appeals interpretations of the Fire Code; City Manager hearings to abate abandoned vehicles and appeals to City Council; Tax Administrator hearings for failure to collect or report transient occupancy taxes and appeals to City Council; Chief of Police hearings to suspend or revoke fortunctcl1ing permits and appeals to City Council; City Council hearings to review permits for parades; City Council hearings for delinquent payments of solid waste management services; City Manager review of recycling facility pennits and appeals to City Council; City Council review of revocation of permits under solid waste management ordinances; City Manager hearings to suspend or revoke animal fanciers permits and appeals to City Council; City Manager hearings to abate a vicious dog and appeals to City Council; City Manager hcarings to suspend or revoke pennits for cxotie animals and appeals to City Council; City Manager hearings to suspend or revoke licenses to operate bingo games and appeals to City Council; City Council hearings on appeal regarding public dancing permit issuance or conditions of issuance or the denial or revocation of such pennits by the Chief of Police; City Council hearings of adminsitrative decisions made by City Manager under the smoking pollution control ordinances; City Council hearings of decisions made by City Manager under heritage tree ordinances; City Manager hearings to determine whether property consititutes a public nuisance and to propose rehabilitation, repair, removal or demolition of such property and appeals to City CouneiJ; City Manager hearings regarding notices and orders to abate graffitti on private proprety and appeals to City Council; City Council hearings to determine whether weeds and refuse constitute a public nuisiance; City Council hearings to review City Manager's orders to abate fly nusinance; City Manager hearings regarding impoundment of newsracks; City Council hearings regarding initial application of cable television and communication sysytems franchise applications; City Council hearings to review Chief of Police's decision to deny or revok a peddler permits; City Manager hcarings regarding pennits for massage establishments and massage services; City Manager hearings to review City Engineer's decision on encroachments; City Council hearings regarding changes in street names; City Council hearings regarding establishment of underground utility distribution facilities district; City Council hearings to suspend or revoke grading pennits; City Council hearings regarding issuance, denial, cancellation, or conditioning of a permits under watercourse protection ordinances; City Council hearings regarding variances and violations of flood control ordinances; City Council hearings regarding application of building regualtion administration ordinances; City Council hearings regarding application of waste management plan ordinances; Alameda County Health Omcer or City Council hearings to detennine whether there is a public nuisance and wether to abate the nuisance; Well Standards Advisory Board or City Council hearings regarding violations under thc wells ordinances; and Planning Commision hearings and City Council hearings regarding proposed right-of-way lines. 794878-[: 114,IOO[ - I - A'I'TACHMENT "3