HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 01/11/2022 - TEMPORARY HOUSING FOR DISASTER RELIEFDATE:
STAFF:
January 11, 2022
Caryn Champine, Director of PDT
WORK SESSION ITEM
City Council
SUBJECT FOR DISCUSSION
Temporary Housing for Disaster Relief.
EXECUTIVE SUMMARY
The purpose of this work session is to share information with Council about potential regulatory barriers that
would prevent households in Fort Collins from hosting residents impacted by the Marshall/Boulder County Fire;
and to propose for Council’s consideration options to remove or reduce those barriers.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
1. What questions to Councilmembers have about the active housing relief efforts in Boulder County?
2. Do Councilmembers wish to advance a regulatory housing relief solution, and if so, what feedback do
Councilmembers have on the options and next steps?
BACKGROUND / DISCUSSION
Context: On December 30, 2021, the Marshall Fire destroyed an estimated 1,084 homes and anot her 149
residential structures in Superior and parts of Louisville (Boulder County). On January 4, 20022, members of City
Council asked staff to:
• Summarize available housing relief connections, matchmaking services and ensure Fort Collins is part of t his
network
• Evaluate potential regulatory barriers that would prevent households in Fort Collins from hosting evacuees;
and
• Propose mechanisms that would result in removing or reducing regulatory barriers
Summary of Housing Relief Efforts: The Fort Collins Office of Emergency Preparedness and Security has
been in ongoing contact with Boulder County Office of Emergency Management. The following is a summary of
what we are learning:
• Requests for support: We have offered support to the Boulder County OEM and Larimer County OEM and
confirmed there are no requests for assistance. Boulder County has officially switched their efforts from
response to recovery. That means immediate, short-term response is no longer active and they are pivoting
to long term issues and resource needs to rebuild, restore, etc. There is no indication of short term,
temporary housing needs.
• Status of Housing Relief Efforts: Boulder County OEM reported all emergency congregate sheltering
programs and the Red Cross are closed or offline due to lack of need (with exception of one family). It is
important to note that many of these homes were owner occupied. The insurance industry has robust
recovery response programs and move large resources in response to these types of disasters.
• Housing Assistance/Matchmaking: There are multiple ways for property owners/managers to make their
properties available and many programs to built in resources to make properties available. Here are the most
widespread programs actively connecting and listing available properties for residents impacted by the fire:
✓ Boulder Area Rental Housing Association
✓ Neighbor to Neighbor:
January 11, 2022 Page 2
✓ AirBnB Open Home
✓ Disaster Assistance Center
✓ Colorado Housing Search (statewide)
Potential Scenarios: City Staff conducted an initial review of potential regulatory barriers. As part of this
analysis, staff considered various scenarios through which housing relief could be offered in Fort Collins.
Understanding the scenarios helped to design program options that meet the needs of the community and ensure
we are considering all applicable codes, risks, and opportunities.
• Who: It is relevant to consider the relationship between the residents of the household and the impacted
resident in the evaluation of applicable regulations.
• Duration: The length of stay may vary depending on whether the impacted resident can return to their home
after minor repairs, or another housing option is secured. As noted in the update from Boulder County OEM,
short term, temporary housing needs have been met and while still unlikely, if housing needs exist, they would
be longer term in nature.
Summary of Applicable Regulations: Taking these scenarios into account, City Staff determined that our
occupancy limits could create barriers for a household to host impacted residents. Section 3.8.16 of the City’s
Land Use Code establishes allowances and limitations on the maximum occupants of a residential dwelling unit
(single unit, two unit, muti unit). Section 5.1.2 of the City’s L and Use Code definition of “Family” is linked to
occupancy limits and could also create barriers. It is also important to note the definition of “Occupancy” triggers
applicability when a guest stays a total of thirty (30) or more days. Based on these pro visions, here are examples
of scenarios and whether they would be permitted (assuming all other things are equal and in compliance):
✓ Permitted: A code defined “family” (of any size and configuration) can host multiple guests (not part of the
defined family) for less than thirty (30) days.
✓ Permitted: A code defined “family” (of any size and configuration) can host other members of their family
provided they are related by blood, marriage, adoption, guardianship, etc for any amount of time.
✓ Permitted: A code defined “family” (of any size and configuration) can host one additional person (not part of
the defined family) for more than thirty (30) days.
Not Permitted: A code defined “family” (of any size and configuration) could not host an additional “family” as
defined by our code, such as a single father and child for more than thirty (30) days.
Not Permitted: A code defined “family” (of any size and configuration) could not host two unrelated guests
for more than thirty (30) days.
COUNCIL AUTHORITY/MECHANISM
Through our City Charter and Municipal Code, Council has authority to remove regulatory barriers. The following
is a summary of this authority and a brief assessment based on this current circumstance. This information is
relevant for Council in determining the most prudent method to move forward. City Staff considered the following
factors:
• Demonstrated need and alignment with the status of Boulder County OEM Recovery efforts (as summarized
in the beginning of this report)
• Equity implications
• Level of administrative and enforcement complexity and alignment with the ability to respond quickly and
impact the most likely scenarios for housing needs
1. Municipal Code - Chapter 2; Article 6: Declaration of a Local Emergency: This code defines a local
emergency as a threat or extreme peril to the safety of person and property within the City. It allows Council
to adopt any ordinances, resolutions, rules, regulations necessary to address emergency and aid. The most
recent and applicable example is the Local Emergency for the COVID-19 Pandemic. The nexus between the
definition and its impact in Fort Collins was beyond dispute. This Local Emergency created a foundation for
subsequent temporary orders and emergency regulations to allow for response. The following are
considerations to inform Council’s discussion:
January 11, 2022 Page 3
• Demonstrated Needed: If Council would like to pursue this method, Council would need to identify clear
justification that the Marshall/Boulder Fire constitutes a Fort Collin s Emergency as defined by Code.
Upon declaring the Local Emergency, Council would also need to act on suspending various aspects of
several City Codes as summarized above.
• Administration and Enforcement: It is important to note in this circumstance, Council would be suspending
these codes ONLY for victims of the fire and their hosts. The specific applicability can create complexity
in administration and enforcement. It may also create complexity given there are current efforts to update
some of these LUC requirements.
2. City Charter - Article 8 Definitions: Issuance of an Emergency Ordinance: City Charter establishes
Council’s authority to initiate and act on an Emergency Ordinance. Article 8 defines an emergency as an
existing condition arising from unforeseen contingencies. This can include immediate dangers to public
property, health, peace, safety. An Emergency Ordinance is often used during a declared Local Emergency
and can be used in more isolated situations. The following are consideratio ns to inform Council’s
consideration of this mechanism:
• Demonstrated Needed: The City Charter allows the Council to enact an emergency ordinance “on
account of an emergency, to preserve the public property, health, peace or safety.” While this provis ion
does not require that there be a local emergency, it has generally been interpreted to mean that
emergency conditions of some kind are present in Fort Collins. The terms of an emergency ordinance
must articulate the rationale for finding emergency circumstances necessitate the use of an emergency
ordinance. To execute, Council would need to act on suspending various aspects of several City Codes
as summarized above and apply this discretion only to residents impacted by the fire using an ordinance
that makes the necessary findings.
• Equity: Council may consider the equity implications of providing City aid to a particular group of people
experiencing homelessness caused by the fire, but not others experiencing homelessness within the Fort
Collins community.
• Administration and Enforcement: It is important to note in this circumstance, Council would be suspending
these codes ONLY for victims of the fire and their hosts. The specific applicability can create complexity
in administration and enforcement. It may also create complexity given there are current efforts to update
some of these LUC requirements.
3. City Charter Article 1; Section 4 - Powers of City - Prosecutorial Discretion: City Charter also grants the
City powers to execute on their authority as a home rule municipal corporation. Within these powers, the City
may apply prosecutorial discretion and refrain from enforcing certain Code provisions against residents
impacted by the fire and the host household. This is a reactive approach where the City Enforcement Staff
would be given the direction not to enforce a specific code provision or provisions if brought to their attention.
The following are considerations to inform Council’s consideration of this mechanism:
• Demonstrated Need: Council would need to indicate support for the cause of action. In this case, the
cause would need to be linked to the specific impacts of the fire and the limitations of our regulations to
offer housing relief. The foundation for this approach is in the ackn owledgment that in enacting Code,
Council cannot possibly contemplate all the possible circumstances in which it will be applied. In some
situations, application of the literal letter of the law may be unconscionable and would serve no useful
purpose.
• Equity: Council may consider the equity implications of providing enforcement discretion/relief to a
particular group of people experiencing homelessness caused by the fire, but not others experiencing
homelessness within the Fort Collins community.
January 11, 2022 Page 4
• Administration and Enforcement: In some instances, taking a more formal action to waive requirements
gives those relying on the waiver more assurance than simply choosing not to enforce existing
requirements. It is unknown whether this distinction would have an impact here.
4. City Charter Article 1; Section 4 - Powers of City - Permitted Exemption: As described above, City
Charter grants the City powers to execute on their authority as a home rule municipal corporation. Within
these powers, the City can pro-actively grant exemptions to rules and regulations through a defined process
with criteria. The following are considerations to inform Council’s consideration of this mechanism:
• Demonstrated Need: Council would need to indicate support for the cause of action. In this case, the
cause would need to be linked to the specific impacts of the fire and the limitations of our regulations to
offer housing relief for those impacted. As a permit process, where residents are asking permission
through a review process, it is the applicant demonstrating the need.
• Equity: Council may find that equity implications are still present, but not as significant. By developing a
specific program, narrowly tailored to address housing barriers for those affected by the M arshall/Boulder
Fire, City Council can provide a reasonable and rational basis for this narrowly tailored form of relief.
• Administration: To execute, City Staff would develop a permit application, requirements, and review
criteria. Fort Collins households wishing to provide housing relief, would be the applicants. The City has
similar models in place and the resource demands to create this program would be minor. A permitted
exemption can be addressed as an exemption for this fire, or an exemption f or all future disasters.
• Enforcement: Enforcement of the permit may still be a challenge but can be minimized with
documentation on record and the opportunity for initial screening at the time of issuance. If Council
desires a temporary/timebound solution, a resolution with a deadline is needed. If Council prefers a
lasting change, then City Staff would develop an amendment to the Land Use Code.
CITY STAFF PROPOSED APPROACH - DISASTER RELIEF PERMIT EXEMPTION
Based on these considerations, City Staff found that all mechanisms presented challenges in terms of
demonstrated need, equity, administrative resourcing and enforcement complexity challenges. If Council is
inclined to offer a solution, City Staff recommend City Council deploy their authority und er City Charter Article 1;
Section 4 - Powers of City - Permitted Exemption. Through this authority, City Staff could create a Disaster
Relief Permit Exemption Program:
• Concept - Disaster Relief Host Permit: If Council supports this option, City Staff would create a new permit
that exempts households from the Occupancy codes if they are hosting residents impacted by the
Marshal/Boulder County Fire. This permit would be modelled after our Host Family Permit that allows
exemption from occupancy limits if you have an exchange student. The ability to issue this permit can be
timebound to align with the needs of this specific disaster, or Council could consider a permit that is generally
applicable to any current or future natural disaster. City Staff wi ll create an application, implement review
criteria and establish a process for issuing the permit.
• Baseline Requirements: City Staff would further recommend the following specific requirements and criteria
to minimize neighborhood impacts and maximize protection of public health and safety:
• Free permit
• Maximum of one additional household (defined based on legal definition of functional family)
• Maximum 12 months with one-time renewal (maximum of 24 months)
• Permitted anywhere within City boundary
• General Criteria/Review Discretion: ability to conduct an inspection; ability to consider history of chronic
nuisance or criminal activity; compliance with applicable Building Code and other life/safety codes (e.g.
habitable space and egress requirements); and provision of adequate parking
January 11, 2022 Page 5
Variations for Council Consideration: If Council supports this approach, staff would appreciate feedback on a
few variations of this program. The options are outlined in this table:
Requirement Variation #1 Variation #2
Dwelling type Single unit dwelling + two unit, multi unit
Owner/Renter Owner occupied + renter occupied
(w/landlord permission)
NEXT STEPS:
Below is a summary of the process options, next steps and timeline for Council’s consideration and direc tion to
City Staff:
Option #1 Option #2 Option #3
Approach Keep as is Explore Disaster Relief Host
Permit - Exemption for
Marshall/Boulder Fire
Explore Disaster Relief Host
Permit - General
Applicability (LUC
Amendment)
Next Steps 1. Staff will continue to
monitor demand 2.
Staff will alert Council
of any significant
impacts or trends for
consideration of next
steps
1. Finalize based on Council
feedback 2. Draft Ordinance 3. Jan
18: Council 1st Reading 4. Feb. 15:
Council 2nd Reading
1. Finalize based on Council
feedback 2. Draft Ordinance
3. Jan 14: P&Z Work Session
4. Jan 18: Council 1st Reading
5. Jan 20: P&Z hearing 6. Feb
15: Council 2nd Reading
ATTACHMENTS
1. Powerpoint Presentation (PDF)
Temporary Housing for Disaster Relief1-11-2022City Council Work SessionCaryn Champine, Meaghan Overton, Justin MooreATTACHMENT 1
2Questions for Council1.What questions to Councilmembers have about the active housingrelief efforts in Boulder County?2. Do Councilmembers wish to advance a regulatory housing reliefsolution, and if so, what feedback do Councilmembers have onthe options and next steps?
3Work Session Overview• Summary of housing relief efforts in Boulder County• Options to temporarily remove barriers• Proposed approach and considerations• Proposed next steps
4Context• Dec 30, 2021: • The Marshall Fire resulted in an estimated 1,084 homes destroyed, and another 149 residential structures damaged in Superior and parts of Louisville (Boulder County)• January 4, 2022: • Fort Collins City Council asked staff to evaluate potential regulatory barriers that would prevent households in Fort Collins from hosting evacuees; and propose temporary solutions
5Summary of Housing Relief Efforts•Requests for support: • Boulder County OEM has not accepted offers of support• Boulder County has officially switched their efforts from response to recovery• There is no indication of short term, temporary housing needs•Status of Housing Relief Efforts: • Boulder County OEM reported all emergency congregate sheltering programs and the Red Cross are closed or offline due to lack of need • Many homes were owner occupied and the insurance industry has robust recovery response programs•Housing Assistance/Matchmaking:• Boulder Area Rental Housing Association• Neighbor to Neighbor: • AirBnB Open Home• Disaster Assistance Center• Colorado Housing Search (statewide)
6Context• Staff considered various scenarios in their analysis:• Relationship between the households• Length of stay• Accommodations offered: spare bedrooms, additional space (e.g. basement apartment)• Staff determined the greatest barrier in Fort Collins to support the ability to house residents impacted by the fire is the occupancy regulations:• Any accommodation under 30 days is not subject to codes• Any accommodation over 30 days would be controlled by our occupancy regulations• Examples:•Permitted:A code defined “family” can host other members of their family provided they are related by blood, marriage, adoption, guardianship, etc for any amount of time.•Not Permitted: A code defined “family” could not host an additional “family” as defined by our code, such as a single father and child for more than thirty (30) days.
7Options to Temporarily Remove BarriersDemonstrated Need Equity Administration and EnforcementDeclaration of EmergencyClear justification this is a Fort Collins emergencyN/A Complexity of various codes, a specific group, and active code update effortsEmergency OrdinanceEvidence there are emergency conditions present in Fort CollinsProviding aid to a particular group of people experiencing homelessnessComplexity of various codes, a specific group, and active code update effortsCity Powers –Prosecutorial DiscretionSupport that regulations limit our ability to address impacts from the fireEnforcement discretion/relief to a particular group of people experiencing homelessness Passive approach that may not offer certaintyCity Powers –Permitted ExemptionSupport that regulations limit our ability to address impacts from the fireLess significant as a narrowly defined programPro-Active approach that creates process and ability to monitor
8Proposed Approach – Disaster Relief Host Permit•Concept: Disaster Relief Host Permit• New permit that exempts applicants from Occupancy Code• Modeled after our Host Family Permit• Timebound • Concise application requirements, criteria and process• Applicable only to Marshall/Boulder County Fire
9Disaster Relief Host Permit – Baseline RequirementsRequirements, Information, CriteriaPurpose of permitDemonstrated loss of housing from a natural disaster impacting the regionPermit FeeFreeAllowable #Maximum of one additional household (defined based on legal definition of functional family)Expiration/RenewalMaximum 12 months with one-time renewal (maximum of 24 months)ApplicabilityAnywhere within City boundaryGeneral Criteria/DiscretionAdditional conditions; inspection; history of chronic nuisance or criminal activity; assessment of habitable space; provision of egress; adequate parking
10Disaster Relief Host Permit – Variations for DiscussionRequirement Variation #1 Variation #2Allowable dwelling typeSingle unit dwelling + two unit, multi unitOwner/RenterOwner occupied + renter occupied (w/landlord permission)
11Disaster Relief Host Permit – Process OptionsProcess Option #1 Process Option #2 Process Option #3ApproachKeep regulations as is Disaster Relief Host Permit –Exemption for Marshall/Boulder FireDisaster Relief Host Permit –General Applicability (LUC Amendment)Next Steps*1 . Staff will monitor2. Alert Council if demand elevates1. Finalize based on Council feedback2. Draft Ordinance3. Jan 18: Council 1st Reading4. Feb 15: Council 2nd reading1. Finalize based on Council feedback2. Draft Ordinance3. Jan 14: P&Z Work Session4. Jan 18: Council 1st Reading5. Jan 20: P&Z hearing**6. Feb 15: Council 2nd Reading*we do not anticipate the volume of applicants will require new resources; in the future, if needed an appropriation ordinance would be considered; if Council supports Options 2 or 3 staff will also initiate necessary communication and outreach methods to create awareness**adjusted process sequence to expedite; needs Council support
12Questions for Council1.What questions to Councilmembers have about the active housingrelief efforts in Boulder County?2.Do Councilmembers wish to advance a regulatory housing reliefsolution, and if so, what feedback do Councilmembers have on theoptions and next steps?