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Home My WebLink About1994/06/13 Board of Appeals & Advisors Agenda Packet (3) :I.4etY\!\ /\ f ~b ...( ...c¡ § 19956.5 . (0 OUSING Dlv.13 Ubrary References Municipal Corporations $-269(4), 661, 756, C.J,S, Municipal Corporat,ons §§ 783, 794, 761. 1048. 1686, WESTLAW Topic No, 268, Notes of Decisions CoDOtnlctlon and oppUcatlon 1 requires all curbs and sidewalks to be con· structed so as to be usable by physical1y dis- abled persons; such requirements apply to 1. Conatructlon and application curbs and sidewalks intended for public use whether constructed with tublic or private This section, when read in conjunction with funds and regardless of were located. S~ the 1971 amendments to Gov.C. § 4450 et seq. Ops,Auy,Gen, 186, 4-16-74, , 19957. Exceptions from literal requirements of standards and speclfl- .. cations In hardship, etc., cases In cases of practical difficulty, unnecessary hardship, or extreme differ- ences, a building department responsible for the enforcement of this part may grant exceptions from the literal requirements of the standards and specifica- tions required by this part or permit the use of other methods or materials, but only when it is clearly evident that equivalent facilitation and protection are thereby secured, (Added by Stats,1969. c, 1560, p, 3166, § I, operative July I. 1970,) § 19957.5. Local appeals board; Jurisdiction; members; duties (a) Every city, county, or city and county may appoint a local appeals board composed of five members to hear written appeals brought by any person regarding action taken by the building department of the city, county, or city and county in enforcement of the requirements of this part, including the exceptions contained in Section 19957, (b) Two members of the appeals board shall be physically handicapped persons, two members shall be persons experienced in construction, and one member shall be a public member. (c) The appeals board shall conduct hearings on written appeals made under subdivision (a) and may approve or disapprove interpretations of this part and enforcement actions taken by lhe building department of the city, county, or city and county, All such approvals or disapprovals shall be final and conclusive as to the building department in the absence of fraud or prejudicial abuse of discretion. The appeals board shall adopt regulations establishing procedural rules and criteria for the carrying out of its duties under this part. (Added by Stats,1976, c. 700, p, 1714, § 1.) 218 ACCESS-PHYSICALLY HANDICAPPED ,§ 19959 Part 5.5 Noles or Decisions . Appeals board I local bWldins depar\IIIeftIlft mortins build- ing·-=œs,s requirements for physically bandi- I. Appeals board capped persons does not require that an apo. peals board be appointed to consider the mat· The subl1Ú55ion of a written appeal under 1er, 6S Ops.Atty,Gen, 83, 1-2~2, this .,uoo reprciins an action taken by a § 19958. Enforcement; building department defined The building department of every city, county, or city and county shall enforce this part within the territorial area of its city, county, or city and county. The responsibility for enforcing Chapter 7 (commencing with Sec- tion 4450) of Divisiot1 5 of Title 1 of the Government Code in its application under this part shall be by such building department within the territorial area of its city, county, or city and county, "Building department" means the department, bureau, or officer charged with the enforcement of laws or ordinances regulating the erection or con· struction, or both the erection and construction, of buildings, (Added by 8tats,1969, c, 1560. p, 3166, § I, operative July I, 1970,) Ubrary Rererences Words and Phrases (Perm,Ed,) Notes or Decisions Dutl.. t them to enforce the handicapped accessibility requirements and failure of the department to do so did not provide a basis for it to be t. Dutl.. required to indemnify city which was alleged Statul0J¡ responsibilities of the de,'bartment by restaurant owner, who had been sued by of rehabi itation to educate the pu lie and physically handicapped person, to have breach· work with officials of cities to encourage them ed its duty to prevent the construction of the to make all buildings accessible to the handi· restaurant in a manner which violated the law. capped does not impose a mandatory du\y on Slate ex reI. Cal. Dept. of Rehabilitation v. the part of the department to inform çjlY off¡· Superior Court. Alameda County (App.1 Dist. cers of the provisions of this section requiring 1982) 187 Cal.Rptr, I, 137 C,A.3d 282, § 19958.5. Violations; injunction: district or city attorney. attorney gen- eral The dislrict attorney. the city attorney, the Department of Rehabilitation acting through the Attorney General, or the Attorney General may bring an action to enjoin a violation of this part. (Added by 51815.1976, c. 869, p. 1979, § 3.) Ubrary References Injunction "'85(1). WESTLAW Topic No, 212, c.J.s. Injunctions § 162. § 19959. Alteration of existing pubUc accommodations Every existing public accommodation constructed prior to July I, 1970, which is not exempted by Section 19956, shall be subject to the requirements 219 ARY 1982] ATTORNEY GENERAL'S OPINIONS s¡ JD capable of holdIng (\1t: additional number of cartridges held by the attachment "the meanmg of F&G § 2U1O and 14 C.A,C. § 31 J. .'.' ~.. Opinion No, 81-too2-January 28. 1982 3JECT: APPEALS BOARD-The submisslon of a wntten appeal under Hea!!h & Sal. Code § 19957,5 regarding an action taken by a local building departmentln enforcing building access requirements for phys- Ically handIcapped persons does not reqUIre that an appeals board be appomted 10 consIder the mailer. The scope of the review powers of an appecti, board IS hmited to approving or dIsapproving the local building :iepartmecot" ,nterpretations of Health & Sal. Code §§ 19955-19959 and . '::1:' ~rne¡-¡t ð.ctlODS taken thereunder. P. city councilor county boðrd of sUr ¡sars may render the same decisions for the sð.me matters as may be rendered by an appeals board pursuant to Health & Sal. Code § 19957,5 if local law so allows, ,uestod by: MEMBER. CALIFORNIA STATE SENATE inion by: GEORGE DEUKMEJIAN, Attorney General Rodney 0, Lilyquisl. Depcity The Honorable Barry Keene, Member of the California Statt Senate, has requestt:d ~}pinion on the foHowing questions: I. Dot's tht submission of a wrim:n appeal under Health and Safety Code sf'ccion 157.5 rt:gð.rr.iHlg an actiun taken br a local building department in enforcing building 55 requirl:mcnts for physically handicapped persons require that an appeals board be >OÍnted co consider the matter? 2. What is the scope of the review powers of an appeals board appointed pursuant Health and Safety Code ,ection 19957.5! 3. Maya city council or county board of supervisors render the same decîsionsfor -same marters as may be rendered by an appeals board appointed pursuant to Health J Safety Code section 19957,5! CONCLUSIONS I ': submission of a written appeal under Health and Safety Code seccion 195', ðarding an action taken by a local building department in enforcing building :~s rtquirtmtnts for physically handicapped persons does not req.uire that an appeals IUd be appoinH:d to consider the matter. 2. The scope of the review powers of an appeals board appointed pursuant to 84 ATIORNEY GENERAL'S OPINIONS [VOLUME 65 Health and Safety Code section 19957.5 is limited co approving or disapproving the I, local building departmem's interpretations of Health and Safety Code sections 19955- " 19959 and enforcement actions taken thereunder. 3. ^ dty councilor counry board of supervisors may render the same decisions for the same matters as may be rendered by an appeals board appointed pursuant to Health and Safety Code section 19957,5 if local law SO allows, ANALYSIS The Legislature has enaCted a Starutory scheme (Health and Safery Code SS 19955- 19959)1 specifically requiring that public accommodations or facilities constructed in California with private funds' be accessible to physically handicapped persons, Such fa· cilities include auditoriums, hospitals. theaters. restaurants, hotels. motels. stadiums. and convention cemers (see § 19955); also covered arc passenger vehicle service stations, shopping centers, offices of physicians and surgeons, and office. building. (see S 1995 5,5), Under the statutory scheme, the local governmental body required to enforce the access requirements is the building department of each city and county. Section 19958 states: "The building department of every ciry. counry. or dry and county .hall enforce this part within the tetritOrial area of its city, county. or dty and coun· , ty .. ' r ¡ .. 'Building department' means the department. bureau. or officer \ charged with the enforcement of laws or ordinances regulating the erection or ì consrruction. or both the erection and construction. of buildings," ! The questions presented for analysis concern the enforcement actions taken by local ! building departments and the methods by which such actions may be reviewed. I, Ap¡1ointment of an Appeals Boatd , The first question presented is whether the filing of a written appeal rega.rding an enforcement action taken by a building department requires the appointment of an ap- peals board under section 19957 .~. We conclude that it does not. Local building department officials occasionally will be faced with complex prohlems in interpreting and enforcing the statutory access provisions. Of particular sig- nificance in this regard is the languagé of section 19957; "In case of practical difficulty. unnecessary hardship. or extreme differ- ences, a building departmenr responsible for the enforcement of this part may gram exceptiuns from the literal requirementS of the standards and specifica- I" tions required by this part or permit the use of other methods or materials. .' I All section refetenc!:S hereafter are to the Health and Safety Code unless ot:hcrwi5C indicated. I 2 Buildinpand facilities connruCted with public funds arc required 10 be acceøible 10 physically handi~ capped pmons punuanc to Government Cod~ sections 4450-4458. '. 1 . . è, :,'1~,dC~ -- ..&;'\ "{~k~ ~~~<- . :·'~:~r, ,.:',,: 'i.. JANUARY 1982] ATIORNEY GENERAL'S OPINIONS 8j but only when it is clearly evident that equivalent facilitation and protection are thereby secured." In 197(ì the Lt'gislature amended the statutory scheme {O indude a provision, sec· [Ion 1)1957.5, aothorizing the appointment of an appeals board to review decisions made by local building department officials, (Stars, 1976, ch, 700, § I.) The statute prov.ides: "(a) Every city. county, or city and count)' may appoint a local appeals board composed of five members to hear wrirren "appeals brought by any per- son regarding action taken by the building department of the city, count)', or city and coumy in enforcement of the requiremt'nts of this part, including [ht: exceptions conrainc:d in Section 19957. "(b) Two memhets of the appeals board shall be physically handICapped persons, tWO members shall be persons experienced in construction, and one membr:r shall be a public member. "lc) Th~ appeals board shall conduct hearings on written appt'als made unJt:r ~ubJiv¡sion la) and may approve or disåpprove imerpretations of this pan and enforcement actions taken by the building depanmem or the city, county, or city and county, All such approvals or disapprovals shall be nnal and conclusive as to the building department in the absence of fraud or preju~ dicial abuse of discretion. The appeals board shall adopt regulations establish- ing procedural rules and criteria for the carrying out of its duties under this part." In the situation presented to us for consideration, a written appeal has been submit~ ted. challenging an action taken by the local building department in enforcing sections 1995~-19959. Must an appeals board be created in order to review the written appeaP We believe that the answer may be found by applying well recognized principles of statutory construction, The cardinal rule in interpreting a statute is to "ascertain the in- tent of the Legislature so as to effectuate the purpose of the law." (Stltet Bait Mattrials v, Bo..d of Equal, (]959) 5] Ca!. 2d 640,645; accotd, California T,achm AiJII, v, San Di'go C.mmunity ColI'g' Di1l, (\981) 28 Ca!. 3d 692, 698,) . In determining leg¡slative intent. we first [urn to the words of the statute (Ml.lytr v. W"'mtn'i Comp, App,ab Bd, (1973) 10 Ca!. 3d 222, 230), giving the language irs usu· al and ordinary import, (PlOpl, v, B,lIici (1979) 24 Ca!. 3d 879, 884,) Hrrt, the Legislature has used the word "may" in authorizing cities and counties to appoint local appeais boards. "May" is usually permissive, as disringllishtd from "shall" which is ordinarily mandatory. (Webster's New Internat. Diet. l3d ed 1966) pp, ]683,2085; Hogya v, Superior c'u" (1977) 75 Ca!. App, 3d 122. 133.) Moreover, section 19957.5 contains both "may" and "shall" within irs provi- sions. "Ir has been held where the Legislature has used both words in the same section it must be prC'sumed to have atrached to them their orJinary meanings, (Na/lOnal Au/onto- 86 ATIORNEY GENERAL'S OPINIONS [VOLUME 65 hi/ule, Co, v, Garrison, 76 Ca!. App, 2d 415, 417; Cannizzo v, Guarante. Ins, Co,. 245 Ca!. App, 2d 70, 73,)" (H.gya v, Sup.rior Court, supra. 75 Ca!. App, 3d 122, 133, fn, 8; accord, In rt Richard E, (1978) 21 Ca!. 3d 349, 353-354,) This int~rpretation is consistent with the Legislature's dedaration that for PUrpose5 of inrtrprering the provisions of the Health and Safety Code, .. 'shall' is mandatory and 'may' is permissive," lS 16.) We have found nothing in the stacumry scheme [0 suggest a different imerpretation. Since the creation of an appeals board under section 19957,5 is discretionary with each city and counry. the submission of a written appeal chaHenging a building depart~ menr decision cannot act to force creation of such a board. . In answer (0 the first question, therefore, we conclude that the submission of a wricp ten appeal regarding an action taken by a local building depan-meor in enforcing the ptovisions of sections 19955-19959 does not requite the appointment of an appeals board under section 19957,5, , 2, Powers of an Appeals Board The second question presented concerns the scope of the review powers of an ap- peals board created under the provisions of section 19957.~. We conclude that the board is limited to reviewing the decisions made by the local buading depanment with /? regard [0 the: provisions of sections 19955-19959 and it may not delve into matters -~ outside the scope of the legislative scheme. The key language of section 19957. ') r~uiring interpretation is comained in subdi- vision (a) {the board shall "hear written appeals brought by any person regarding action ¡í taken by the building department .,. in enforcement of the requirements of this pan, it including the exceptions contained in Section 19957"} and in subdivision (c) [the board " I\' "may approve or disapprove interpretations of this part and enforcement actions taken by the building d;panment ", ") Besides those principles of statutory constuction mentioned with regard to the first l.) qllesri()n, we note that "legislation should be construed so as to harmonize its various " elements" (W.lls v, Marina City Properties, 1nr. (198\) 29 Ca!. 3d 781. 788) and "the " " various parts of a statutory enactment" must be considered "in the context of the statu- '!i tory framewotk as a whole," (Moyer v, Workmtn's Comp, IIpp,a/s Bd" supra, 10 Ca!. 3d k¡ 222, 230,) " j: Applying these principles, we believe that when the Legislature authorized appeals I boards to approve or disapprove "enforcement actions taken by the building depart· , mem." the legislature was referring only to actions taken with regard to enforcing sec- tions 19555-19559, In the context of the starutory scheme as a whole. no other definition of "enforce- ment actions" is appropriate. Subdivision (a) of section 19"57.5 refers solely to "enforce- men< of the tequirements of this pan [sections 19555-19559)," Although section ¡ 19958 speaks in terms of a building depanment official "chatged with the enforcement , " ~---'-- --,-,-- JANUAR Y t982J AlTORNEY GENERAL's OPINIONS 87 of laws or ordinances regulating the erection or consuucrion, or both the erection and construction, of buildings," such generalization is merely for purposes of idencifi.catÎon in defining "building department;" ic does nm purport to constitute a grant of authority such as is contained in the first sentence of the statute: "The building deparrmem of every city, couney. or city and couney shall enforce thiJ þarl within the territoral area of itS city, county. or ciry and counry," (lralics added.> Reading these various provisions together in light of the "principle that adminis· trative agencies have only such powers as have bten conferred on them, expressly or by implication, by constitution or statute" (Ferdig v. State Personnel Bd. (1969) 71 Cal. 2d 96, 103), we conclude in answer to the second qu~cion that the powers of an appeals board appointed under section 19957.5 are limited to approving and disapproving the local building deparrmenr's interpretarions of sections 19955-19959 and enforcemènt actions taken thereunder. . 3. Powers of a City Councilor Couney Board of Supervisors The third qu~tion presemro concerns whether by authorizing the creation of an appeals board, the ugislacure intended to preclude any other administrative revie~' of access decisions made by local building deparrmenrs, In other words, if an appeals board is not established, may a city councilor couney board of supervisors review access deci- sions made by the building d~parcmem, and if an appeals board is created, ma>' the board's decision be reviewed by a city councilor couney board of supervisors? We con~ elude that the Legislature did not intend to remove any appellate review authority held by a city councilor couney board of supervisors. Local governments may and frequently do put appeal procedur~ in their local or- dinances. (See Cal. Const., arc. XI, §S 1-7; ß()ard of Perm;J A.þþta/¡ v. Control Permit Bm.u (1960) 186 Cal. App, 2d 633, 639-640; Sara. "Municipal Affairs" in California (1972) 60 Gal, L, Rev" 1055, 1077-1081 (hereafter "Saro").) Does section 19957.5 p~mpt this power, or dóes ir merely suggesr a particular manner in which the appeal process may be implemented? We view this matter as again one of statutory interpretation to which may be ap- plied the previously mentioned principles of construction. The phrase that demonstrates the Legislature's intem concerning the issue at hand is found in subdivision (c) of section 19957,5; "All such approvals or disapprovals [by the board] shall be final and conclu- sive as ID the building d,parrmenr Df Ih, riry, (Duney, or rily and IDunry," (lralics added,) The ~gislature has expressly declared that an appeals board decision only binds the local government insofar as constituting the decision of the building department. If the Legislature had intended to cut off any further administrative appeal co a city council or county board of supervisors, it could easily have used other language. (See Tracy Y. Mknlâpal Courl (1978) 22 Gal. 3d 760, 764; Safer v, Superior Cot'" (1975) 15 Gal. 3d 230,237-238,) Section 19957,5 simply does not purport to affect any rightS of appeals other than to ~tablish that the decision of an appeals board cons'titut~ the decision of rhe local building deparrmenr, 88 A1TORNEY GENERAL'S OPINIONS (VOLUME 65 Accordingly. if local ordinances allow, a city councilor counry board of supervisors mi\}' review d~cisions of a city or couney building department in interpreting and enforc- ing the provisions of sections 19955-19959. Where an appeals board has not been creat- ed, the department's decision could go directly to the city council or board of supervi- sors. Where an appeals board has been created. its decision would take the place of the building department administrator's decision and be reviewable as such to the city coun- cil or board of supervisors if local law SO provides. We have found no expression of legislacive intent in the statutory scheme as a I whole to suPPOrt a contrary conclusion. While the Legislature has dire([ro local building departments to administer the access provisions, we do not believe it has addressed the I issue of whether a local building department decision may be reviewed by a city council, . I board of supervisors, or other body. The designation of the building depanment as the I enforcement agency (§ 19958) merely reflects the fact thar the access requtrements wouid I normally be within its area of expertise rather than within the province of some other department such as police, fire, or sanitation. } Also, the specification of certain qualifica- tions for members of an appeals board (§ 199~ 7,~. subd, (b» cannot be said to preclude review outsidt: the building department appeals board process. Although the issue is a close one, we believe that in order for the Legislature to deny review of dty and county building department decisions by locally elected repre· stmatÎves, more expressive language is required than is now contained in sections , 11.)955·19959. This Îs especially true in this field of the Jaw where the "home rul~" i constitutional grant of authority to charter cities and counties may affect such a legisla· [Í\,t' decision. (See CaJ. Conic, art. XI, S~ 3-5; So"omll County Orgll,,;zllt;on of Public Em- ploym v, County of Sonoma (1979) 23 Ca!. 3d 296, 315-316; Ri."a v, City of Frem, (1971) 6 Ca!. 3d 132, 135; Sato, Jupra, at pp, 1077-1O8\.) In answer to the third qUeStion, we conclude that a city council or a county board of supervisors may render the same decisions for the same matters as could be rendered by an appeals .board appointed pursuant ro section 19957,5 if local law so provides, , Opinon No, 81-1113-January 28, 1982 SUBJECT: COASTAL DEVELOPMENT PERMIT-With certain specified exceptions, counties and the state are required to obtain a costal devel, opment permit from a city in order to develop public property located within that portion of the coostal zone under the city's jurisdiction, where the city's local coostal program has been certified pursuant to the Califor- nia Coostal Act of 1976. J Th~ Legislatur~ has mad~ this abundantly cI~ar by defining "building d~rrment"' for purposes of the ¡{¡\tUtory Kh~me as ·'the deparrment, bureau, or offic~r charged with the enfot(~mC'nt of laws or ordinances regulating the er«tion or conStruction, or both the erection and con$(ruction, of buildings." (S 19958.) .. . - 110 '.1 UNIFORM BUILDING CODE -,. ,> ...--- .. '-rl oece ccc C'<: c (2) The governing bodies where funds of counties; municipalities or other polit- C.OOC,O.CO~ A C ;cal subdivisions are utilized except (ß otherwise provided above. ¡ A O.CCC..CC c (3) The building department of every city, county, or city and county within ¡he A O.c:CCC...·C c territorial area afits city. county, or city and county. where private funds OTe uli- A I¡zed. "Building department" means the department. bureau or officer charged oecct?G.ec c A with the enforcement of Jaws or ordinances regulating the erection or construe- ,.CCOOeVC¡ c lion, or both the erection and construction, of buildings. A o. CCc. .~'« IIÀ D, SJHcial Cotulilionsfor Penons with _s Requiring ApJHø/s Action {".GGGGG0G. C Ratifu:ation. Whenever reference is made in these regulations to this section. the A I I c findings and determinations required 10 be rendered by the local enforcing agency A C shall be subject to ratification through an appeals process. A E. Authority Cited---.(;overnmenJ Code Section 4450. C A F Reference--Governmenl Code Sections 4450 through 4458 and Health and C A Safety Code Sections 19952 through 19959, C A (Amendments to Section 110 (10) effective April 1 ,1994.] c A I c 11. OSAISSS-Office of the State Architect. Structural Safety Section. A C Application-Public elementary and secondary schools, community col- A C lege buildings and state-owned or state-leased essential services build- -A ings. C A Enforcing Agency-Structural Safety Section. Office of the State Architect. c ) A Authority Cited-Education Code Sections 39152 and 81142, and Health C A and Safety Code Section 16022. c A Reference--Education Code Sections 39140 through 39157, and 81130 c A through 81147, and Health and Safety Code Sections 16000 through C A 16023, c The Structural Safety Section of the Office of the State Architect has been I A C delegated the responsibility and authority by the Department of General A C Services to supervise and review the design and observe the construction "A C of public school buildings, the structural systems and related details of A hospital buildings and state-owned or state-leased essential services c A buildings. C A The applicable building standards are as follows: C I A C A. Administrative Regulotions A c (1) School Buildings; Sections 4-301 through 4-355. Group 1. Chapter4, Part A "...._^-,:_..~-., C 1, Title 24, California Code of Regulations. A (2) Hospital Bwlding6; Chapter 7, Part 1, Title 24. California Code of Regula . OCCCC:CGC! C A tions. C o.cce..O( A (3) State-owned or State-leased Essential Services Buildings; Sections 4-201 C I OLe DO . (; e1 A through 4·249, Chapter 4. Part 1, Title 24, California Code of Regulations, C O.CC CO.C( A B. Techni£1Ú Regulations c G(, UC e..t:.C1 A Various model codes adopted by reference into the State Building Standards C o.e CC..C·~ A Code. Title 24, Parts 2, 3, 4. 5 and 7, California Code ofRegulations.!or school C OLCCO....C' 4.6 OCTOBER 1, 1993 0.(.. C, 06QH': c;¡ j f f ~~ ]:nfj'l if i" if I ¡ I I~ i~I~~]~I~~]]ø~ I i] 1~... ~e !1_B'B'n~~B'H§B' lB'i ~ ~. ,.§~ B', '¡.~~B'.e:' 6~B'B'1~ ~B' a I v~~I~i t 11~ 1~~"'ttljltl~111 ~It II ¡llltl~.~t i)I'81§1)!'~1}1 Ilt!1~il I .!I~§i.§~B' B'i.!íB's ~o!l!'::S 1i~ S "".If I .!í,;v "'~ :5B' ~ "}1'$1f .¡¡!; øi¡ itl1'Jìf!itlfillt¡~'f111{~111111j'fI11 ä ~ If! 11 ...') a B i 8 I.U is ~ .f j § ~ i e.f It S·5 I I ~.f §-¡]~~~I~'§'§JI ~~I~~i1t]lllltl~~t~~I~tl ~11 ·r .r ~' '~H.. 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