1030 W. Canton Ave.
RUTH'S Suite 100
Winter Park, FL 32789
(407) 333-7440
HOSPITALITY GROUP www.rhgi.com
August 22, 2022
Long Beach City Council
Dear Mayor Garcia and Honorable Members of the City Council, Please accept this correspondence on behalf of the recently opened Ruth's Chris Steak House located at 180 East Ocean Boulevard, Long Beach ("RCSH Long Beach"). Attached to this letter is a letter from Broc Coward, Chief Operating Officer of the Downtown Long Beach Alliance, to the City Council regarding potential new regulations of food trucks within the City of Long Beach ("DLBA Letter").
RCSH Long Beach strongly supports the policy recommendations contained in the DLBA Letter and encourages the City Council to adopt regulations of food trucks consistent with the recommendations contained in the DLBA Letter. As you may know, RCSH Long Beach is a fine dining restaurant, and our valued guests generally expect that valet car parking service will be offered in connection with their dining experience and RCSH Long Beach has arranged for valet service at the location at a considerable monthly cost. We are advised by local management of RCSH Long Beach that food trucks regularly park in front of or near the RCSH Long Beach location on Ocean Boulevard and block access to the valet stand for RCSH Long Beach. We believe that Downtown will benefit from unimpeded access to the valet operation at RCSH Long Beach and this may be achieved only if food trucks are prohibited from parking in front of the restaurant.
Accordingly, we believe that, consistent with the policy recommendations contained in the DLBA Letter, Downtown will benefit from regulations that would establish location-based zones for food trucks and prohibit parking food trucks within 300 feet of brick and mortar restaurants such as RCSH Long Beach.
We greatly appreciate your consideration of this correspondence in your process of establishing new regulations of food trucks within the City of Long Beach.
Very Aruly yours,
Steve Meetre
Senior Corporate Counsel
August 23, 2022
Long Beach City Council
RE: City of Long Beach Food Truck Regulations (Item R-28) DOWNTOWN Dear Mayor Garcia and Honorable Members of the City Council,
LONG BEACH
ALLIANCE Please accept this correspondence on behalf of the Downtown Long Beach Alliance (DLBA) Board of Directors and enter into the public record for the City Council meeting scheduled for August 23, 2022, our policy recommendations regarding the potential forthcoming regulations of food trucks within the City of Long Beach.
The DLBA is a non-profit organization representing more than 1,400 businesses and 3,200 commercial and residential property owners within the two Business Improvement Districts (BIDs) in Downtown Long Beach. As a leading voice for the Downtown community, DLBA recognizes the benefit of food trucks in certain circumstances such as private functions, special events where local restaurant food booths are impractical, and locations or areas with very few dining options. However, Downtown is home to nearly 200 restaurants that provide a range of casual and fine dining experiences and a diverse offering of cuisine. Our restaurants have been a cornerstone to creating a vibrant and attractive Downtown entertainment district. After two years of experiencing a dramatic loss of business caused by fewer daytime office workers and conventioneers, the added burden on our community- invested restaurants forced to operate by a different set of standards with food trucks operating outside their front doors, may be the final straw. And every good operator of a brick-and-mortar business that we lose only postpones recovery of our city's main economic engine - Downtown.
In recent years, the number of food truck vendors has increased significantly in Downtown Long Beach, particularly along Shoreline Drive within the PD-6 Downtown Shoreline Development District. A growing number of those trucks have been observed ignoring regulations intended to protect nearby stakeholders from traffic hazards, ADA violations and public health nuisances. According to the City of Long Beach, there are 104 active "mobile food licenses," but it is unclear how many unpermitted trucks are in operation or whether there is adequate enforcement on the days and times when they are most prevalent. There are also concerns that trucks are not subject to the same rigor of uniform health and safety permitting, land use ordinances, or other practical regulations intended to protect the well- being of consumers and often applied to existing brick-and-mortar businesses. Taking these considerations into account, DLBA supports the following policy recommendations to mitigate ongoing negative issues:
Interdepartmental Coordination and Communication: Reduce information silos between multiple departments involved in food truck permitting (e.g., Public Works, Long Beach Police Department, Health and Human Services, Financial Management). We strongly support the creation of a Food Truck Coordinator, so long as their responsibilities and authority are clearly defined for departments, operators and the public.
100 West Broadway, Ste 120
Long Beach, CA 90802
T: 562.436.4259
F: 562.437.7850 DOWNTOWNLONGBEACH.ORG
2. Clear Permitting: Good faith operators are entitled to a fair and straightforward permitting process that discourages noncompliance through its streamlined process.
As such we agree that the City should require that all food truck operators have a City of Long Beach issued health permit. This will assist in the oversight and enforcement of health and safety standards that are expected of all food operators.
3. Location Based Zones: We would support the designation of specific operating zones, DOWNTOWN however they should be determined through a public process containing a LONG BEACH transparent set of criteria that includes verified access to restrooms and avoids ALLIANCE placing food trucks within 300 feet of brick-and-mortar restaurants.
4. Clear Reporting Process: Members of the public should have a way to report noncompliant operators, possibly through the GoLongBeach app.
5. Bolstered Enforcement: New and existing regulations must be consistently enforced to support a working permit system. This includes targeted enforcement outside of normal business days and hours when food trucks most often operate. Additionally, it has come to DLBA's attention that civil servants face the threat of interference from operators and even patrons while trying to enforce existing regulations or taking further actions to recoup unpaid citations. This requires additional and coordinated support from LBPD of other departments. Case in point, as many as 15 food trucks line up along Shoreline Drive every weekend (and half that on weekdays), regularly parking without paying meters, taking up two stalls, parking in red zones, and purposely stationing personal vehicles several feet away from curbs while poking into traffic lanes to create space in diagonal stalls for customers to access food order counters. However, regularly citing all trucks in violation and/or recouping unpaid citations by impounding trucks is very challenging and requires coordinated and unconventional methods of enforcement.
By keeping these basic principles in mind, DLBA believes the City can create a fair and effective regulatory system for food truck operations within Long Beach. We recognize that the development and approvals of a comprehensive ordinance will be an ongoing process, but we encourage enforcement of existing safety codes and look forward to working with the City and stakeholders to establish an ordinance that works for our entire Downtown community.
We look forward to further collaboration as the policy solidifies.
Sincerely,
Broc Coward
Chief Operating Officer
CC:
DLBA Board of Directors
Tom Modica, City Manager, City of Long Beach
Kelly Colopy, Director of Health and Human Services
Kevin Riper, Director of Financial Management
Eric Lopez, Director of Public Works
Christopher Koontz, Deputy Director of Development Services 100 West Broadway, Ste 120
Long Beach, CA 90802
T: 562.436.4259
F: 562.437.7850 DOWNTOWNLONGBEACH.ORC