Memo
1 To: Oliver Chi, City Manager
From: Lana Negrete, Mayor
Date: December 1, 2025
Re: A Request that the City Council Consider Directing the City Manager on Ensuring Accountability, Safety, and Transparency for Sober Living and Congregate Recovery Housing
On October 28, 2025, the City Council adopted new guidelines that I introduced which were aimed at improving transparency and community notification procedures related to proposed transitional housing, supportive housing, and behavioral-health programs located in Santa Monica. These new regulations were designed to ensure that when these types of projects are formally proposed, our community and the public have clear information about the planned initiatives, along with adequate time for a thorough review of ways to mitigate potential neighborhood impacts.
After these guidelines were adopted, the City confronted an unusual situation last week just prior to the Thanksgiving holiday break. An unpermitted sober-living / addiction recovery-related business began operating at 413 Ocean Avenue. Upon inspection, City staff discovered that:
• Up to 58 individuals had been moved into the building without permits, without a business license, and without a certificate of occupancy.
• Significant unpermitted construction work had been completed in the building, including bathroom remodels, electrical installations, HVAC units, and other improvements. • Based on the illegal operation, it was identified that the building’s electrical systems could be overloaded, creating unsafe habitability conditions. • The operator refused inspection access until pressed, and the facility appeared to be associated with multiple LLCs and operators that were not disclosed to the City.
Given that Santa Monica currently maintains strong standards for building safety, habitability, and property registration, staff was able to act quickly by using existing regulatory authority to effectuate the following:
• Issued Notices of Violation and administrative citations. • Conducted a multi-department inspection program for the site. • Issued an Order to Vacate the building due to unsafe conditions. • Issued a formal Habitability Determination, which triggered relocation benefits for those residents who were moved into the facility.
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2 Ultimately, the City’s actions resulted in the sober living facility operator shutting down their unpermitted operation and relocating the individuals who were moved into the property.
These tools were essential and effective for addressing an unsafe situation that was already underway. They ensured that vulnerable individuals were removed from harm and that the City could enforce basic safety, occupancy, and building requirements.
However, while the City was able to shut down the illicit activity at 413 Ocean – demonstrating an ability to effectively respond to such incidents – the situation also revealed that our current tools in Santa Monica are not designed to prevent this type of situation from happening again. Among the issues that exist for which a policy response is needed include the following facts:
• Our existing enforcement tools are reactive, not preventive. • The City had no mechanism to identify the operator, funding source, or intended use before residents were moved in.
• There is no local registration or disclosure requirement for sober-living or recovery housing operations, allowing operators to begin activities under complex LLC structures without notice.
• There is no requirement for operators claiming licensing exemptions to demonstrate how those exemptions apply.
• There are limited tools to prevent rapid, unannounced occupancy of multifamily buildings, particularly buildings in transition, redevelopment, or entitlement review. • Santa Monica lacks an early-warning, interdepartmental process specific to sober-living / recovery housing operations.
These gaps are now even more concerning because the City has also identified that a similar type of sober-living / addiction recovery operation may be contemplated at 825 Ocean Avenue, creating the risk of repeated patterns of unregulated occupancy along the Ocean corridor.
To address issues related to sober-living / congregate recovery housing operations, municipal entities across California have implanted neutral, health-and-safety-focused regulations that serve to achieve the following outcomes:
• Require registration of group homes and sober-living operations. • Mandate operator and ownership disclosure.
• impose objective safety and occupancy standards.
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3 • Require inspection access.
• Establish spacing standards to prevent over-concentration of sober-living type facilities in neighborhoods.
• Creating clear good-neighbor and operations requirements.
When developed carefully and applied neutrally, these regulations have been supported by the courts – including the Ninth Circuit – as legitimate ways to protect residents with disabilities and neighborhoods.
In thinking about the sober-living facility related issues at 413 Ocean, and in an attempt to build on the City Council’s October 28 policy direction, I respectfully request that the City Council support my request to direct that the City develop a legally compliant, preventive regulatory framework for sober living-type facilities that will allow Santa Monica to:
• Protect vulnerable residents from unsafe conditions.
• Ensure operators are transparent and accountable.
• Provide staff with clear authority before unsafe occupancy begins. • Maintain compliance with State housing and disability law.
To that end, I am requesting that the City Council vote to direct that the City Manager to return to Council within 90 days with policy options for regulating sober-living, recovery-housing, and other congregate living arrangements serving high-vulnerability populations, including but not limited to the following concepts:
1. Land-Use Clarification & Classification – Establish clear definitions and land-use classifications for sober-living homes, recovery housing, congregate living facilities, and similar uses, including thresholds that distinguish these uses from ordinary residential occupancy.
2. Local Registration & Operator / Ownership Disclosure – Require registration of soberliving and recovery facilities and mandate disclosure of operators, beneficial owners, LLCs, property managers, and any controlling entities.
3. Licensing / Exemption Documentation – Require operators to provide State or County licensing documentation – or justification for licensing exemptions – before operations begin.
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4 4. Safety, Occupancy, and Operational Standards – Establish objective standards related to maximum occupancy, room configuration, staffing, emergency protocols, house manager requirements, good-neighbor policies, and program operations.
5. Inspection Access & Enforcement Tools – Require inspection access as a condition of operation, and strengthen enforcement consequences when operators deny access, violate occupancy rules, or initiate operations without proper approvals.
6. Continuity-of-Care & Relocation Planning – Require relocation and continuity-of-care plans when sober-living or recovery facilities operate in buildings undergoing ownership changes, redevelopment, or major entitlement applications.
7. Interdepartmental Review Protocol – Establish a proactive early-identification protocol across City operations, including the City Manager’s Office, Police Department, Fire Department, Housing & Human Services Department, Building & Safety Division, Code Enforcement Division, and the City Attorney’s Office.
8. Community Notification & Transparency – Evaluate neutral, early community notification for registered sober-living facilities above a certain size or intensity.
9. Legal Review – Ensure all proposed regulations comply with State housing law, fair housing requirements, ADA obligations, and the California HCD Group Home Technical Advisory.
10. Implementation Timeline – Return to Council with draft regulatory measures, staffing, fiscal impacts, and an implementation plan within 90 days.
Please place this item on the December 9 agenda for full City Council consideration.