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2025-04-01 12.C Correspondence Moore

Pismo Beach City Council
April 1, 2025

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2025-04-01 12.C Correspondence Moore
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April 1, 2025
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Pismo Beach City Council
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From:Michael Moore
To:City Council
Cc:[email protected]; Moore Michael (The Be Moore Family) Subject:Urgent Request to Update Outdated Pismo Beach Massage Therapy Ordinance to Support Modern Massage School Operations
Date:Tuesday, April 1, 2025 11:35:01 AM
External Email
Dear Pismo Beach City Council Members,
I am writing to respectfully request an urgent review and update of the Pismo Beach Municipal Code, specifically Chapter 5.11, which governs massage establishments.

Our review demonstrates that significant portions of this ordinance are outdated, especially its regulations concerning massage schools, and are currently obstructing the establishment of vital educational and healthcare resources within our community.

Our analysis of the relevant sections of the code indicates the following:

Focus on Massage Establishments: The code primarily regulates "massage establishments," defined as businesses that offer massage therapy for compensation.

Definition of "School of Massage": The code defines "school of massage" (5.11.030) as any state-approved school in good standing with the California Massage Therapy Council (CAMTC).

Establishment Operating Requirements: Section 5.11.080 prohibits a massage establishment from operating as a school of massage.

Interpretation and Concerns: Outdated Regulations Impede Modern Practices While the code's intent to separate commercial massage businesses from massage schools is understandable, it creates a problematic gray area for essential massage school operations. The ordinance's current form is based on outdated concerns and fails to acknowledge the current regulatory landscape. This is particularly evident in two key areas:

Student Clinics: The ordinance does not recognize that a massage school, much like a cosmetology school, operates a student-run clinic as an integral part of its educational program. These clinics provide invaluable hands-on training for students, allowing them to develop practical skills under supervision. Students provide services to the public for a nominal fee, which helps offset operational costs. This is not a profit-driven venture but a necessary educational component.

It is crucial to emphasize that the California Massage Therapy Council (CAMTC) explicitly regulates student clinic hours to prevent exploitation. The CAMTC limits student clinic hours to a maximum of 75 hours per student, ensuring that students are not abused by being forced to work excessive hours for free. This regulation directly addresses the outdated concern that schools might exploit students, rendering the ordinance's current restrictions unnecessary and counterproductive.

Graduate Support: Modern massage therapy schools often provide crucial

support to new graduates to facilitate their transition into professional practice.

This can include offering opportunities for graduates to work as employees within the school or to sublease space within the school campus. These practices help graduates establish their own businesses and contribute to the community's wellness services.

The CAMTC also provides oversight in these situations, ensuring ethical and professional practices. Think of a hair salon that rents chairs to other independent contractors; this is what we ask is fair treatment, just like a hair salon or cosmetology school.

The current Pismo Beach ordinance, as interpreted, has been used to enforce rules regarding the proximity of different massage entities and the operation of student clinics within schools, creating significant and unwarranted challenges for institutions like MTI. These restrictions are based on outdated assumptions and prevent reputable schools from providing essential educational services and supporting the professional growth of their graduates.

Furthermore, it is essential to acknowledge the rigorous regulatory oversight of California massage therapy schools, including the Massage Therapy Institute (MTI), by:

The California Massage Therapy Council (CAMTC), governing both therapists and establishments, and, critically, setting strict limits on student clinic hours to prevent student exploitation.

The Bureau for Private Postsecondary Education (BPPE), overseeing institutions such as Cal Poly, UCLA, and Stanford, ensuring high standards for educational quality and ethical conduct. MTI is pursuing BPPE accreditation, with CAMTC approval to follow.

MTI's Value Proposition for Pismo Beach:

MTI is poised to enhance Pismo Beach's health and well-being through:

Research Partnerships: Collaborating with Stanford and Cal Poly to advance massage therapy research.

Community Outreach: Providing free or reduced-cost therapeutic massage to underserved populations (e.g., Spyglass Village) to address musculoskeletal issues, chronic pain, and reduce pharmaceutical dependence.

Clinical Integration: Facilitating clinical placements in local healthcare settings via Dr. Johanna Moore's professional network, integrating highly educated massage therapists into mainstream healthcare.

Supporting Evidence: Oakdale's Progressive Approach
We understand that this ordinance may require updating to reflect best practices. To support our request, we have attached a news article from Oakdale that highlights a recent and relevant example. The updated Oakdale ordinance now explicitly allows for the operation of student clinics and subleasing to other massage therapists, recognizing the value these practices bring to both education and the community.

Massage Ordinance Passes Unanimously
oakdaleleader.com
This example demonstrates that other cities are recognizing the need to modernize their regulations to accommodate reputable massage therapy schools and their essential functions.

We urge the Council to recognize the need for ordinance clarification and updates to facilitate the establishment of MTI and the substantial benefits it will bring to Pismo Beach. The current ordinance's outdated approach is actively hindering progress and preventing the community from accessing valuable wellness resources.

Thank you for your prompt attention to this critical matter.

Sincerely,
Dr. Johanna Moore, Owner
Michael Moore, Co-founder
Massage Therapy Institute

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