EDUCATIONAL FACILITIES

Community College Sites


To promote the safety of students and comprehensive community planning the governing board of each district before acquiring title to property for a new community college site or for an addition to a present community college site shall give the planning commission having jurisdiction notice in writing of the proposed acquisition. The planning commission shall investigate the proposed site and within 30 days after receipt of the notice shall submit to the governing board a written report of the investigation and its recommendations concerning acquisition of the site.
The governing board shall not acquire title to the property until the report of the planning commission has been received. If the report does not favor the acquisition of the property for a community college site, of for an addition to a present community college site, the governing board of the district shall not acquire title to the property until 30 days after the commission's report is received.
EDUCATION CODE SECTION 81035

Elementary and Secondary School Sites and Facilities

A school district is not required to comply with city or county building ordinances. Government Code Section 53091 does require a school district to comply with city or county zoning ordinances of when such ordinance makes provision for the location of public schools, and the city or county has adopted a general plan. However, Government Code Section 53094 allows the governing board of the school district to render a city or county zoning ordinance inapplicable to proposed classroom facilities by vote of 2/3 of its members. The school board must notify the affected city or county within ten days of such action.

However, Government Code Section 53097 prevents a school district from exempting itself from drainage improvement, road improvement or grading ordinances or from conditions relating to the provision of onsite improvements. The district is required to consider local offsite improvement requirements, but need not comply with such improvements. If the district does not install offsite improvements as requested by the city or county, the city or county will not be liable for future injuries or damages resulting from failure to install the improvements. A 1988 California Attorney General's Opinion affirms the language of Section 53097. (71 Ops.Atty.Gen. 332 (1988))

Each local agency shall comply with all applicable building ordinances and zoning ordinances of the county or city in which the territory of the local agency is situated. On projects for which state school building aid is requested by a local agency for construction of school facilities the city or county planning commission in which said agency is located shall consider in its review for approval information relating to attendance area enrollment, adequacy of the site upon which the construction is proposed, safety features of the site and proposed construction, and present and future land utilization, and report thereon to the State Allocation Board. If the local agency is situated in more than one city or county or partly in a city and partly in a county, the local agency shall comply with such ordinances of each city or county with respect to the territory of the local agency which is situated in the city or county and shall not be applied to any portion of the territory of the local agency which is situated outside the boundaries of the city or county. Notwithstanding the preceding provisions of this section, this section does not require a school district to comply with the zoning ordinances of a county or city unless the city or county planning commission has adopted a master plan.

Each local agency required to comply with building and zoning ordinances pursuant to this section and each school district whose school buildings are inspected by a city or county pursuant to Section 53092 shall be subject to the provisions of the applicable ordinances of a city or county requiring the payment of fees. The amount of such fees charged however, to a local agency or school district shall not exceed the amount charged under the ordinances to nongovernmental agencies for the same services or permits...
GOVERNMENT CODE SECTION 53091

(a) Notwithstanding any other provisions of this article, the governing board of a local agency, by vote of four-fifths of its members, may render a city or county zoning ordinance inapplicable to a proposed use of property if the local agency at a noticed public hearing determines by resolution that there is no feasible alternative to its proposal, except when the proposed use of the property by such local agency is for facilities not related to storage or transmission of water or electrical energy, including, but not limited to, warehouses, administrative buildings or automotive storage and repair buildings. The governing board of a local agency may make such determinations at the time it approves an environmental impact report on its proposal required by Division 13 (commencing with Section 21000) of the Public Resources Code. Mailed notice of the public hearing shall be provided at least 10 days prior to the hearing, to the owners of all proposed facility and a notice shall be posted in a conspicuous place at the proposed site of such facility. If mailed notice as required above would result in notice to more than 250 persons, as an alternative to such mailed noise, notice may be given by placing a display advertisement of at least one-fourth page in a newspaper of general circulation within the area affected by the proposed facility and by posting such notice in a conspicuous place at the proposed site of such facility.
(b) The board shall, within 10 days, notify the city or county, whose zoning ordinance has been rendered inapplicable under subdivision (a), of such action. If such governing board has taken such action the city or county may commence an action in the superior court of the county whose zoning ordinance is involved or in which is situated the city whose zoning ordinance is involved, seeking a review of such action of the governing board to determine whether it was supported by substantial evidence. The evidence before the court shall include the record of the proceedings before the city, county, and district. The city or county shall cause a copy of the complaint to be served on the board. If the court determines that such action was not supported by substantial evidence, it shall declare it to be of no force and effect, and the zoning ordinance in question shall be applicable to the use of the property by such local agency.
(c) "Feasible" as used in this section means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.
GOVERNMENT CODE SECTION 53096

Notwithstanding any other provisions of this article, the governing board of a school district shall comply with any city or county ordinance (1) regulating drainage improvements and conditions, (2) regulating road improvements and conditions, or (3) requiring the review and approval of grading plans as such ordinance provisions relate to the design and construction of onsite facilities and improvements, and shall give consideration to the specific requirements and conditions of city or county ordinances relating to the design and construction of offsite improvements, the city or county shall not be liable for any injuries or for any damage to property caused by the failure of the school district to comply with those ordinances.
This section shall remain in effect only until January 1, 1991, and as of such date is repealed, unless a later enacted statute, which is chaptered before January 1, 1991, deletes or extends such date.
GOVERNMENT CODE SECTION 53097

Notwithstanding any other provisions of this article except Section 53097, the governing board of a school district, by vote of two-thirds of its members, may render a city or county zoning ordinance inapplicable to a proposed use or property by such school district except when the proposed use of the property by such school district is for nonclassroom facilities, including, but not limited to, warehouses, administrative buildings, automotive storage and repair buildings. The board shall, within 10 days, notify the city or county concerned of such action. If such governing board has taken such action the city or county may commence an action in the superior county of the county whose zoning ordinance is involved or in which is situated the city whose zoning ordinance is involved, seeking a review of such action of the governing board of the school district to determine whether it was arbitrary and capricious. The city or county shall cause a copy of the complaint to be served on the board. If the court determines that such action was arbitrary and capricious, it shall declare it to be of no force and effect, and the zoning ordinance in question shall be applicable to the use of the property by such school district.
This section shall remain in effect only until January 1, 1991, and as of that date is repealed, unless a later enacted statute, which is enacted before January 1, 1991, deletes or extends that date. If that date is not deleted or extended, then, on and after January 1, 1991, pursuant to 53094 of the Government Code, as amended by Section 1 of Chapter 760 of the Statutes of 1976, shall have the same force and effects as if this temporary provision had not been enacted.
GOVERNMENT CODE SECTION 53094

Plan Checking and Inspection Fees for Street Modification Adjacent to a State University Campus

A California Attorney General's Opinion notes that the Trustees of the California State University and Colleges are not required to pay a city's plan checking and inspection fees for construction modifications of city streets adjacent to a state university campus if personnel employed by the Trustees perform these same services. (62 Ops.Cal.Atty.Gen. 443 (1979))

Stadium Light Renovation on a High School Campus

A court of appeal ruling upheld a local school board's decision to exempt itself from a local zoning regulation that would have required a permit to replace decaying light poles with new, higher ones at a high school stadium that functions as a multi-use facility. Considering neighboring citizens' objections, the city took issue with the school board's invocation of Government Code Section 53094 to declare the city's zoning ordinance inapplicable to the district. But the court rejected the city's arguments, noting that the stadium "serves an important educational purpose . . and is directly used for student instruction." (City of Santa Cruz v. Santa Cruz Schools Board of Education, (1989) 210 Cal.App.3d 1)

University of California Improvement Construction Projects

In 1978 the California Court of Appeal ruled that a city could not enforce its construction permit fee ordinance when applied to a University of California improvement construction project. The court held that the university regents have virtually plenary power in regulating the university's affairs. As such, the University's project, which was solely for educational purposes, was not subject to municipal regulation, and was exempt from local zoning regulations and building codes. (Regents of the University of California v. City of Santa Monica (1978) 77 Cal.App.3d 130)

Return to Index

ENERGY RESOURCES

Atomic/Nuclear Energy Facilities in General


Through the Atomic Energy Act (42 USC 2011-2394, especially 42 USC 2012), the Federal Government has primary jurisdiction over atomic/nuclear energy resource development, use, and regulation. The State of California has entered into an agreement with the Atomic Energy Commission, pursuant to 42 USC 2021, to assume certain authority to regulate atomic energy (Health & Safety Code Section 25876). The California Atomic Energy Development Law (Health & Safety Code Section 25700-25772) sets forth the state's regulatory authority. Although Section 25732 of the law provides for state and local governmental coordination of programs, rules and regulations controlling atomic energy development, the nature and extent of local control are unclear. While Health & Safety Code Section 25840 requires city and county ordinances relating to radioactive materials or other sources of radiation to be consistent with state regulations, the law still is not clear that it relates to zoning regulation of atomic energy facilities (Longtin, p. 320).

Even though the Attorney General's Office deduced in 1978 that federal nuclear energy regulations preempt California's nuclear power plant siting and certification statutes, Government Code Sections 25524.1 - 25524.3 (61 Ops.Cal.Atty.Gen. 159 (1978)), a subsequent federal court case contradicts it in part. The federal Atomic Energy Act does not preempt state laws concerning atomic power plant siting, because state laws were enacted for purposes other than for radiation hazard protection. (Pacific Legal Foundation v. State Energy Resources Conservation and Development Commission (9th Circ. 1981) 659 F2d 903)

Coastal Zone Electrical Transmission, Generation, and Thermal Facilities

The California Energy Commission retains sole authority to certify all sites and related facilities, except those located in the specifically designated California Coastal Zone. A commission certification is issued in lieu of any state, local or regional agency, or federal agency permit, certificate, or entitlement for such a site and related facilities. Pursuant to Public Resources Code Section 25500, such certifications also supersede any applicable statute, ordinance, or regulation of any state local or regional agency. Public Resources Code Section 25110 defines a "facility" as any electric transmission line or thermal power plant. A 1977 Attorney General's Opinion describes the degree of the Energy Commission's jurisdiction over transmission line construction as related to power plants. (60 Ops.Cal.Atty.Gen. 239 (1977); Longtin, pp. 318-319)

In accordance with the provisions of this division, the commission shall have the exclusive power to certify all sites and related facilities in the state, whether a new site and related facility or a change or addition to an existing facility. The issuance of a certificate by the commission shall be in lieu of any permit, certificate, or similar document required by any state, local or regional agency, or federal agency to the extent permitted by federal law, for such use of the site and related facilities, and shall supersede any applicable statute, ordinance, or regulation of any state, local, or regional agency, or federal agency to the extent permitted by federal law.

After the effective date of this division, no construction of any facility or modification of any existing facility shall be commenced without first obtaining certification for any such site and related facility by the [State Energy] commission, as prescribed in this division.
PUBLIC RESOURCES CODE SECTION 25500.

Electrical Energy Generation, Storage, and Transmission Facilities and Substations

Government Code Section 53091 preempts local building and zoning ordinances from the siting of electrical power plants or substations, but Public Utilities Code Section 12808.5 requires municipal utility districts to make findings of consistency with the local general plan.

"....Building ordinances of a city or county shall not apply to the location or construction of facilities for the production, generation, storage, or transmission of water, waste water, or electrical energy by a local agency.

"Zoning ordinances of a county or city shall not apply to the location or construction of facilities for the production, generation, storage, or transmission of water, or for the production or generation of electrical energy, nor to facilities which are subject to section 12808.5 of the Public Utilities Code, nor to electrical substations in an electrical transmission system which receives electricity as less then 100,000 volts. Zoning ordinances of a county or city shall apply to the location or construction of facilities for the storage or transmission of electrical energy by a local agency; provided, that such zoning ordinances make provision for such facilities."
GOVERNMENT CODE SECTION 53091, IN PART

Thermal Power Plants

Public Resources Code Section 25120 defines a thermal power plant as a stationary or floating electrical generating facility using any source of thermal energy, with a generating capacity of 50 megawatts or more. Public Resource Code Section 25500 apparently preempts any local authority to regulate a thermal power plant's siting, but local agencies within whose boundaries the site is proposed are accorded the opportunity to review and comment on such applications by section 25519(e). Local agencies may comment on facility design, architectural features, highway access, landscaping, grading, public use of land in the facility's area, and other aspects. With certain exceptions, the Energy Commission may not certify a facility if it does not comply with state, local, or regional ordinances or standards, pursuant to Public Resource Code Section 25525.

Return to Index

FERRY SERVICE

Ferry services that the Public Utilities Commission certifies do not need to obtain local use permits for downtown terminal sites. The Public Utilities Commission's certification of a ferry service constitutes a state granted authority which prevails over local zoning. (Harbor Carriers, Inc. v. City of Sausalito (1985) 46 Cal.App.3d 773)

Return to Index

FLOODING AND FLOOD CONTROL

Public agencies may not revise flood plain regulations or grant variances from them unless they obtain state or local flood control agency permission.
WATER CODE SECTION 8414.2.

Return to Index

GOVERNMENTAL BUILDINGS AND USES

As discussed in preceding sections of this paper's text, the U.S. Constitution and the California Constitution both contain language that courts have interpreted as authority for federal and state preemption of local regulation. In the context of land use planning, this authority is brought to bear in the siting of government buildings and uses of property. In short, state and federal governmental facilities need not comply with local building and zoning regulations. Probably several case law examples exist, but only the following two are described for purposes of illustration.

State Unemployment Offices

When the state leases a building in a tenant's capacity for use as an unemployment insurance office, its operation is not subject to local building and zoning ordinances unless the state legislature consents to such regulation. (City of Orange v. Valenti (1974) 37 Cal.App.3d 240)

U.S Postal Service Facilities

The U.S. Postal Service is exempt from county zoning regulations when it constructs a post office on land owned or leased by the federal government. (United States v. City of Pittsburg (9th Circ. 1981) 661 F.2d 783; 68 Ops.Cal.Atty.Gen. 310 (1985))

Return to Index

HAZARDOUS WASTE AND TOXICS

Conditional Use Permit Amendments for Hazardous Waste Facilities


(a) No city, county, or city and county, whether general law or chartered, which has issued a conditional use permit for a hazardous waste facility shall thereafter adopt an ordinance, rule, or regulation, or issue or amend any permit, which adoption, issuance, or amendment imposes additional restrictions on the types of hazardous waste which previously have been authorized to be accepted for disposal, treatment, or storage under the terms and conditions of any previously issued conditional use permit for that facility.
(b) This section does not apply to a modification or revocation of a use permit which is necessary to enforce the terms and conditions of the use permit, or to abate a nuisance, or to prevent an immediate threat to the public health and safety. Modification or revocation of an existing use permit may only occur after the city, county, or city and county orders the facility operator to abate the nuisance or correct the threat to the public health or safety, and the facility operator has failed to comply with the enforcement or abatement order.
(c) This section does not apply to an existing hazardous waste facility, as defined in Section 25148.
HEALTH & SAFETY CODE SECTION 25149.1

Existing hazardous waste facilities are defined as follows:
(a) Except as otherwise provided in subdivision (b), "existing hazardous waste facility" means a Class I disposal site, as defined in Section 2510 of Title 23 of the California Administrative Code on the effective date of this article, and which, in addition, is either:
(1) A facility operating as of May 1, 1981, pursuant to a grant of interim status by the department pursuant to Section 25200.5.
(2) A facility operating as of May 1, 1981, pursuant to a grant of interim status by the department pursuant to Section 25200.5.
(b) An "existing hazardous waste facility" does not include a facility which treats, disposes, stores, or recycles on the production site only hazardous wastes produced by the owner or lessee of such a facility.
HEALTH & SAFETY CODE SECTION 25148

Hazardous Waste Disposal and Treatment

The Federal Resource Conservation and Recovery Act and state hazardous waste management act do not preempt an ordinance declaring permanent disposal of hazardous wastes to be a nuisance. (Land Use Law, Dec. 1986, p. 22; see item 227, W. Va.)

Neither Health & Safety Code Section 25149 nor Government Code Section 66796.11 preempts reasonable local regulation of the disposal and treatment of toxic waste not amounting to an outright prohibition, even in the absence of findings of the Department of Health Services. Nor is such local regulation impliedly preempted by full state regulation of the field, since the language of Health & Safety Code Section 25149, when reasonably construed, indicates that the Legislature intended to permit reasonable local regulation of toxic waste disposal. (Casmalia Resources, Ltd. v. County of Santa Barbara, (Oct. 1987) 195 Cal.App.3d 827)

Hazardous Waste Management and Siting

Since the Resource Conservation and Recovery Act (RCRA) provides no guidelines for hazardous waste facility siting, states are free to devise their own guidelines and processes for such siting. (Duffy, P. 757)

Regardless, California defers to all local land use requirements during its site approval process. Local land use regulation of existing facilities may not be preempted. "Existing hazardous waste facility" is defined in the subsection immediately preceding. (Health & Safety Code Section 25147)

Nuclear Fuel/Radioactive Waste Importation and Storage

The Federal Atomic Energy Act of 1954 and Hazardous Materials Transportation Act (HMTA) both preempt a New Jersey township's ordinance prohibiting the importation of spent nuclear fuel or other radioactive waste for storage in the township. The Atomic Energy Act authorizes the Nuclear Regulatory Commission (NRC) to regulate radioactive material transportation and storage. Despite the Act's subsequent amendment and the NRC's issuance of regulations allowing for states to regulate certain matters by agreement, states may not regulate the construction or operation of any production facilities. The court conceded, however, that state regulations founded on economic concerns might not be preempted, the federal government nevertheless has complete control of nuclear energy generation's safety aspects, which the local ordinance sought to regulate. (Land Use Law, August 1986, pp. 19-20; Jersey Central Power & Light Company v. Township of Lacey (1985) 772 F.2d 1103 U.S. Court of Appeals, Third Circuit [intermediate court])

PCB Disposal Facilities Regulated by EPA

The federal Toxic Substances Control Act (TOSCA) preempts a local ordinance which closes a PCB disposal facility. Local exclusion of any hazardous waste facility would violate federal law, as a strong federal role is essential to oversee local government regulation of hazardous wastes. (Rollins Environmental Services, Inc. v. Parish of St. James, (Nov. 1, 1985) 54 U.S.L.W. 2248)

State Easements on Hazardous Waste Sites or Buffer Zones

Upon designation of land as hazardous waste property or border zone property pursuant to Section 25229, the director shall issue and cause to be served on the owner of the property and shall give notice to the legislative body of the city or county in whose jurisdiction the land is located and any other persons who were permitted to intervene in the proceeding, orders requiring all of the following:
(a) The execution and recordation of a written instrument which imposes an easement upon the present and future uses of all or part of the land which has been designated a hazardous waste property or a border zone property. Such easement shall permit the department or its representatives to enter the land, subject to Section 25185.5, to monitor problems regarding hazardous wastes. The easement shall be executed by all the owners of such land and by the director, shall particularly describe the real property affected by the instrument, and, if applicable, the location of the easement on the real property. The easement shall be recorded with the recorder of the county in which the land is located within 10 days of the date of execution and shall be indexed by the county recorder in the grantor index in the name of the record title owner of the real property and in the grantee index in the name of the department. The easement shall state that the land described in the instrument is subject to a hazardous waste easement. Notwithstanding any other provision of law, an easement executed pursuant to this section shall run with the land from the date of recordation and shall be binding upon all of the owners of the land, their heirs, successors, and assignees, and the agency, employees, or lessees of such owners, heirs, successors, and assignees. The easement shall be enforceable by the department pursuant to Article 8 (commencing with Section 25180). Notwithstanding any other provision of law, any easement held by the department shall not be sold or otherwise transferred to another person.
(b) The execution and service of a written instrument to accompany all lease or rental agreements relating to the land which has been designated a hazardous waste property or a border zone property. Health & Safety Code Section 25230. The instrument shall be prepared by the owner or lessor of the land and shall contain the following statement:
"The land described herein contains hazardous waste or is within 2,000 feet of land that contains hazardous waste. Such conditions render the land and the owner, lessee, or other possessor of the land subject to requirements, restrictions, provisions, and liabilities contained in Chapter 6.5 (commencing with Section 25100 of Division 20 of the Health & Safety Code) This statement is not a declaration that a hazard exists."
HEALTH AND SAFETY CODE SECTION 25230

Toxic Cleanup Sites

In 1988, a federal district court held that federal law preempts local governments decisions to deny permission for toxic cleanup sites. Under contract with the federal government, a private corporation agreed to decontaminate land used for radioactive thorium waste material storage. Maywood Borough sought to prevent conveyance of the site from the corporation to the government on the basis that the previous site plan and subdivision approval were not granted under local ordinances and state statute. However, the court found that energy and water development appropriations for 1984, 1985, and 1986 carried forth Congress' environmental goals and its specific intent to facilitate the site's decontamination. The court added that the appropriations authorized the site's acquisition for the express purpose of fulfilling the objective of decontamination. (Borough of Maywood v. United States (1988) 679 F.Supp. 413)

In its ruling, the court noted that the Constitution's supremacy clause invalidates state laws that conflict with an act of Congress, that the local planning board's denial of the site plan approval conflicted with Congress' clean-up directives, and therefore the planning board's denial is preempted.

Variances on Hazardous Waste Sites

(a) Except as provided in subdivision (c) of this section, after the director has provided notice in compliance with Section 25222 and a hearing or decision regarding specific land is pending, or after a hearing has been conducted and a decision has been made pursuant to Section 25229 that land is a hazardous waste property, then none of the following shall occur on the land without a specific variance approved in writing by the department for the land use and land in question:
(1) Any new use of the land, other than the use, modification, or expansion of an existing industrial or manufacturing facility or complex on land land which is owned by, or held for the beneficial use of, such facility or complex as of January 1, 1981, and which is a hazardous waste property as defined in Section 25117.3
(2) Subdivision of such land, as that term is used in Division 2 (commencing with Section 66410) of Title 7 of the Government Code, except that this paragraph shall not prevent the division of a parcel of land so as to divide that portion of the parcel which is designated a hazardous waste property from other portions of such parcel not so designated.
(b) Except as provided in subdivision (c) of this section, after the director has provided notice in compliance with Section 25222 and a hearing or decision regarding specific land is pending, or after a hearing has been conducted and a decision has been made pursuant to Section 25229 that land is a border zone property, then none of the following shall occur on the land without a specific variance approved in writing by the department for the land use and land in question:
(1) Construction or placement of a building or structure on the land which is intended for use as any of the following, or the new use of an existing structure for the purpose of serving as any of the following:
(A) A residence, including any mobilehome or factory built housing constructed or installed for use as a permanently occupied human habitation, except that the addition of rooms or living space to an existing single-family dwelling or other minor repairs or improvements to residential property which do not change the use of the property or increase the population density does not constitute construction or placement of a building or structure for the purposes of this paragraph.
(B) A hospital for humans
(C) A school for persons under 21 years of age
(D) A day care center for children
(E) Any permanently occupied human habilitation other that those used for industrial purposes
(2) Subdivision of such land, as that term is used in Division 2 (commencing with Section 66410) of Title 7 of the Government Code, except that this paragraph shall not prevent the division of a parcel of land so as to divide that portion of the parcel which is designated a border zone property from other portions of such parcel not so designated.
(c) This section shall not apply to a portion of a parcel of land which is determined by the director to meet all of the following requirements:
(1) The parcel has been previously classified as a class II-1 disposal site as defined in Section 2510 or 2511 or Title 23 of the California Administrative Code.
(2) The portion of the parcel is physically isolated from the remainder of the classified parcel by the construction of a freeway, as defined in Section 332 of the Vehicle Code, which divides the classified parcel.
(3) The portion of the parcel has not been used as a hazardous waste disposal site.
(4) The portion of the parcel does not contain or overlie hazardous waste.
HEALTH & SAFETY CODE SECTION 25232

Return to Index

HEALTH SERVICES

Alcoholism Recovery Facilities


Whether or not unrelated persons are living together, an alcoholism recovery facility which serves six or fewer persons shall be considered a residential use of property for the purposes of this article. In addition, the residents and operators of such a facility shall be considered a family for the purposes of any law or zoning ordinance which relates to the residential use of property pursuant to this article.

For the purpose of all local ordinances, and alcoholism recovery facility which serves six or fewer persons shall not be included within the definition of a boarding house, rooming house, institution or home for the care of minors, the aged, or the mentally infirm, foster care home, guest home, rest home, sanitarium, mental hygiene home, or other similar term which implies that the alcoholism recovery home is a business run for profit or differs in any other way from a single-family residence.

This section shall not be construed to forbid any city, county, or other local public entity from placing restrictions on building heights, setback, lot dimensions, or placement of signs of an alcoholism recovery facility which serves six or fewer persons as long as the restrictions are identical to those applied to other single-family residences.

This section shall not be construed to forbid the application to an alcoholism recovery facility of any local ordinance which deals with health and safety, building standards, environmental impact standards, or any other matter within the jurisdiction of a local public entity. However, the ordinance shall not distinguish alcoholism recovery facilities which serve six or fewer persons from other single-family dwellings or distinguish residents of alcoholism recovery facilities from persons who reside in other single-family dwellings.

No conditional use permit, zoning variance, or other zoning clearance shall be required of an alcoholism recovery facility which serves six or fewer persons that is not required of a single-family residence in the same zone.

Use of a single-family dwelling for purposes of an alcoholism recovery facility serving six or fewer persons shall not constitute a change of occupancy for purposes of Part 1.5 (commencing with Section 17910) of Division 13 or local building codes. However, nothing in this section is intended to supersede Section 13143 or 13143.6, to the extent those sections are applicable to alcoholism recovery facilities providing care for six or fewer residents.
HEALTH & SAFETY CODE SECTION 11834.23

Return to Index

HOMESTEADS CREATED BY PROBATE COURT

When a probate court creates a homestead and a local subdivision ordinance conflicts with it, the local subdivision ordinance does not apply. In 1983 the California Supreme Court ruled that a local subdivision ordinance which conflicts with the state homestead law and would "materially interfere" with the probate court's exercise of its discretion in considering the family's and the creditors' interests in the property is ineffective. The court noted that the state constitution allows cities and counties to make and enforce ordinances as long as they are not in conflict with general laws. (Wells Fargo Bank v. Town of Woodside, (1983) 33 Cal.3d 379)

This decision superseded a 1981 Attorney General's opinion regarding court-ordered physical divisions of real property in a partition action. The opinion indicated that such partitions must comply with the requirements of the Subdivision Map Act, local ordinances adopted under the Act, zoning ordinances, and the general plan for the area in which the property is located. (64 Ops.Atty.Gen. 762 (1981))

Return to Index

HOSPITALS

". . . It is the intent of the Legislature to preempt from local jurisdictions the enforcement of all building standards published in the State Building Standards Code relating to the regulation of hospital projects and the enforcement of other regulations adopted pursuant to this chapter, and all other applicable state laws, including the plan checking and the inspection of the design and details of the architectural, structural, mechanical, plumbing, and electrical systems, and the observation of construction. The Office of Statewide Health Planning and Development shall assume these responsibilities by establishing, maintaining, and operating separate, but coordinated, plan review and field inspection units within the office.
HEALTH AND SAFETY CODE SECTION 15001, IN PART

All lands necessary for the use of state hospitals except those acquired by gift, devise, or purchase, shall be acquired by condemnation as lands for other public uses are acquired.
The terms of every purchase shall be approved by the Department of Mental Hygiene. No public street or road for railway or other purposes, except for hospital use, shall be opened through the lands of any state hospital, unless the Legislature by special enactment consents thereto.
WELFARE & INSTITUTIONS CODE SECTION 4104.

All lands necessary for the use of state hospitals except those acquired by gift, devise, or purchase, shall be acquired by condemnation as lands for other public uses are acquired.

The terms of every purchase shall be approved by the State Department of Developmental Services. No public street or road for railway or other purposes, except for hospital use, shall be opened through the lands of any state hospital, unless the Legislature by special enactment consents thereto.
WELFARE & INSTITUTIONS CODE SECTION 4444.

Return to Index

HORSE RACING

State regulations preempt a county's authority to exclude horse racing from the entire county, for the state has occupied the field where horse racing is concerned. This decision creates a preemption for horse racing where it is permitted by the state. (Desert Turf Club v. Board of Supervisors (1956) 141 Cal.App.2d 446; Longtin, p. 116)

Return to Index

Prepared by:
State of California
Governor's Office of Planning and Research
1400 Tenth Street
Sacramento, CA 95814
916-445-0613