Rushed RV Ban on Tuesday City Council Agenda

To the Santa Cruz City Council,

Re: Item #25 on the Afternoon Agenda of the October 26, 2021 City Council meeting

HUFF (Homeless United for Friendship & Freedom) opposes the proposed ban on "oversized vehicle" parking city-wide during the nighttime hours of midnight to 5 PM.

A similar law passed in 2016 banning RV's at night was successfully appealed to the broader Coastal Commission which ruled overwhelmingly that the ordinance presented "substantial" issues and city authorities have not addressed those issues (as evidenced as well by the fact that the they never returned to the Coastal Commission). Since a significant portion of the City lies within the Coastal zone, those pressing this law would have to show substantial changes in storage and crime justification have happened. They have not. Until that happens, passage and enforcement of this law will be costly and futile. HUFF will again appeal this law if it is passed in its current form.

It limits public access unnecessarily to the Coastal Zone when there are (a) no adequate parking facilities for such vehicles, and (b) no evidence of a real "crime" problem connected with those vehicles.

It discriminates against poor people (and indeed anyone) who live in or drive the vehicles by denying them coastal access.

It puts a particular burden on those whose only affordable housing is a vehicle by making it illegal to park them at night city-wide.

The lack of specific provision for shelter and storage for unhoused people as supposedly mandated in the CSSO law has not been fulfilled. Nor are there any specific provisions for providing survival parking spaces for the vehicles to be criminalized at night.

City authorities posting signs and banning parking in coastal zones during the last few years have been in violation of the Coastal Commission's requirements and will be doubling down on the violations if this ordinance is passed.

It is particularly inappropriate during a pandemic, endangering both those whose only shelter are their vehicles as well as the broader community.

It discriminates against unhoused people by denying them the ability to apply for a permit, with its definition of "residents" as those who "customarily reside and maintain a place of abode with a street address number in the City of Santa Cruz or who own land within the City of Santa Cruz..." This excludes hundreds of unhoused people.

It was done with no determination of its impact on those living in their vehicles in the City and threatens their health and safety.

It is especially cruel and abusive considering the acknowledged shelter crisis.

Its provisions for Safe Parking spaces at night, do not currently exist and there are no plans for providing them.

It prejudices the right to travel, by eliminating the right to park a 20' long vehicle in Santa Cruz for those visiting.

It was passed without meaningful police documentation of the alleged problems justifying the unusual exclusionary policy--there is no documentation of nighttime "crimes".

It is being done without a procedure for consulting the neighborhoods involved as is the accepted practice for requiring permits to park in other cities (as well as in Santa Cruz for vehicles generally).

Santa Cruz' acknowledged and acute housing and storage crisis--going into winter a particular burden for those outside--will only be aggravated by empowering the seizure and towing of vehicles.

The law further privatizes and monetizes public parking space, already at a premium.

The number of permits allowed per year and the short periods they cover do not allow for adequate family and friend visitation for residents.

The staff has presented no survey indicating an actual public health and safety problem. Calls for service and technical code violations do not amount to actual crimes or conditions that require correction.

In addition given the infirmities in the proposed law (even as amended to limit the time of the parking bans), it will--when rejected by the Coastal Commission--put an undue burden on those whose homes and property is on the Coastal zone if the city chooses to authorize enforcement of the non-Coastal areas.

Please send this law back to the appropriate Commission or City Council committee for more public input with the individuals seriously affected (poor people who live in their vans, homeless service providers, tourists who visit the city, renters and residents who have friends whose home is their oversized vehicle).

Please request specific documentation on the abuses real and alleged that supposedly motivate this law to examine their exact extent in the last year to determine specific remedies rather than this overly broad attack that hurts poor and homeless people particularly. And shames our community generally.