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HomeMy WebLinkAboutCONTINUED DISCUSSION re Resolution 42 03 e V Regular Agenda 615 Sheridan Street Q„ rt Port Townsend, WA 98368 Q� www.JeffersonCountyPublicHealth.org Public He54 JEFFERSON COUNTY BOARD OF COUNTY COMMISSIONERS AGENDA REQUEST TO: Board of County Commissioners Mark McCauley, County Administrator FROM: Pinky Mingo,Director of Environmental Public Health Josh Peters, Director of Dept. of Community Development Ariel Speser, Philip Hunsucker, Prosecuting Attorney's Office DATE: November] 2024 SUBJECT: In the Matter of Repealing Resolution No. 42-03 and Adding a Resolution Adopting Code Compliance Rules of Procedure Pursuant to Chapter 19.05.020(1)JCC STATEMENT OF ISSUE: In a joint effort to best serve Jefferson County's code compliance and enforcement needs, Environmental Health, Department of Community Development, and the Prosecuting Attorney's Office have collaborated on developing Code Compliance Rules of Procedure to further assist county departments in implementing Title 19 JCC. On July 28, 2003, the Board of County Commissioners adopted Resolution 42-03—In the Matter of re-establishing the County Policy on Complaint Review and Enforcement, which guided the County's compliance and enforcement. With the adoption of Title 19 JCC—Compliance Code on December 10, 2020, Resolution 42-03 was impliedly repealed. To avoid lingering concerns by county employees about whether Resolution 42-03 remains in effect, Resolution 42-03 should be expressly repealed. ANALYSIS: Developing and implementing a consistent approach to code compliance and enforcement is desired by the public,the Board of Commissioners, Public Health, DCD and other Jefferson County Departments working code compliance cases. Community Health Environmental Public Health Developmental Disabilities Water Quality 360-385-9400 360-385-9444 360-385-9401 (f) Always working for a safer and healthier community (f) 360-379-4487 J Staff respectfully request that the Board of Commissioners/Board of Health Repeal Resolution 42-03 and adopt a Resolution Adopting Code Compliance Rules of Procedure Pursuant to Chapter 19.05.020(1) JCC. Fiscal Impacts No fiscal impacts at this time. REVIEWED BY: /c 3/ Mark McCa , County Administrato ate Community Health Environmental Public Health Developmental Disabilities Water Quality 360-385-9400 360-385-9444 360-385-9401 (f) Always working for a safer and healthier community (f) 360-379-4487 STATE OF WASHINGTON COUNTY OF JEFFERSON In the Matter of Repealing Resolution No. 42- 03 and Adding a Resolution Adopting Code Compliance Rules of Procedure Pursuant to RESOLUTION NO. Chapter 19.05.020(1)JCC WHEREAS, Article XI, section 11 of the Washington Constitution, confers upon county legislative authorities a direct and extensive delegation of the police power to adopt such local police, sanitary and other regulations as are not in conflict with general laws; and, WHEREAS, RCW 36.32.120(7)provides that the county legislative authorities shall make and enforce, by appropriate resolutions or ordinances, all such police and sanitary regulations as are not in conflict with state law; and, WHEREAS,RCW 36.32.120(10)provides the county legislative bodies have the power to declare by ordinance what shall be deemed a nuisance within the county; to abate a nuisance at the expense of the parties creating, causing, or committing the nuisance; and to levy a special assessment on the land or remises on which the nuisance is situated to defray the cost, or to reimburse the county for the cost of abating it; and, WHEREAS,police power is that inherent and plenary power which enables prohibition of all things hurtful to the comfort, safety and welfare of society;and, WHEREAS, the scope of police power is broad, encompassing all those measures which bear a reasonable and substantial relation to promotion of the general welfare of the people;and, WHEREAS, developing code compliance policy and procedure for enforcement has been a long-term goal of Jefferson County, as reflected in Resolution 29-03 In the Matter of establishing a Policy on the Complaint Review and Enforcement adopted June 23, 2003, and Resolution 42-03 In the Matter of re-establishing the County Policy on the Complaint Review and Enforcement adopted July 28, 2003; and, WHEREAS, on December 10, 2020, Jefferson County Board of Health and Jefferson County Board of Commissioners adopted Ordinance No 09-1210-20 on Code Compliance in Unincorporated Areas of Jefferson County, codified in Title 19—Code Compliance; and, WHEREAS, Jefferson County departments are tasked with implementing Title 19 of the Jefferson County Code ("JCC"); and, WHEREAS, it is efficient for Jefferson County to have Code Compliance Rules of Procedure for all departments that is consistent, reasonable, and legally sound; and, WHEREAS, Chapter 19.05.020(1) JCC authorizes Code Compliance Rules of Procedure; and, 1 WHEREAS, Chapter 19.05.020(2)JCC authorizes amendments to Code Compliance Rules of Procedure through a motion by the Board of Commissioners and Board of Health; and, WHEREAS, Department of Community Development and Environmental Public Health have worked together, with assistance from the Prosecuting Attorney's Office, to develop Code Compliance Rules of Procedure in compliance with Title 19 JCC to further implement the intended goal of compassionate and effective code enforcement(Attachment A); and, WHEREAS, throughout Title 19 JCC, and particularly in Chapter 19.10.05 JCC, voluntary compliance is emphasized; and WHEREAS, Chapter 19.30.025 JCC authorizes department directors and their designees to enter into settlement agreements, including but not limited to: deferring penalty payments for up to three years and cancelling a portion of the penalty debt based on sustained and prolonged compliance when appropriate; and, WHEREAS, Chapter 19.30.030 JCC authorizes an Enforcement Fund for cost associated with abatements and code compliance enforcement; and, WHEREAS, Jefferson County recognizes that barriers to code compliance enforcement exist, and when those barriers are small and removing them is beneficial to the public,the departments are authorized to use enforcement funds for vouchers; and, NOW THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS AND BOARD OF HEALTH OF JEFFERSON COUNTY, STATE OF WASHINGTON: Section 1. Findings of Fact. The Jefferson County Board of Commissioners hereby adopts the above "Whereas" clauses as Findings of Fact. Section 2. Purpose. The purpose of this Resolution is to repeal Resolution No. 42-03 and Add a Resolution Adopting Code Compliance Rules of Procedure Pursuant to Chapter 19.05.020(1)JCC to further implement Title 19 JCC as reflected in Appendix A. Section 3. Repealing Resolution No. 42-03. The Board of Commissioners repeals Resolution No. 42-03 and adds Resolution -- 24, adopting Code Compliance Rules of Procedure pursuant to Chapter 19.05.020(1) JCC. Section 4: Adoption of Resolution — 24 Code Compliance Rules of Procured. The Code Compliance Rules of Procedure pursuant to Chapter 19.05.020(1) JCC, attached as Appendix A, are hereby adopted. Section 5: Effective Date. This resolution shall take effect immediately upon adoption. Section 6: Severability. If any one or more section, subsections, or sentences of this resolution are held to be unconstitutional or invalid, such decision shall not affect the validity of the remaining portion of this resolution and the same shall remain in full force and effect. 2 Section 7: SEPA Compliance. This resolution is categorically exempt from the threshold determination and Environmental Impact Statement requirements of the State Environmental Policy Act under WAC 197-11-800(19). (SIGNATURES APPEAR ON THE NEXT PAGE) 3 APPROVED and ADOPTED this day of , 2024. JEFFERSON COUNTY BOARD OF COMMISSIONERS SEAL: Kate Dean, Chair Greg Brotherton, Member ATTEST: Heidi Eisenhour, Member Carolyn Gallaway, Date Clerk of the Board Approved as to form only: Philip C. Hunsucker, Date Chief Civil Deputy Prosecuting Attorney 4 APPROVED and ADOPTED this day of , 2024. JEFFERSON COUNTY BOARD OF HEALTH Kate Dean, Chair Amanda Grace, Vice Chair Greg Brotherton, Member Monica MickHager, Member Heidi Eisenhour, Member Kees Kloff, Member ATTEST: APPROVED AS TO FORM: Karen Abbott, Date Philip C. Hunsucker, Date Clerk of the Board Chief Civil Deputy Prosecuting Attorney 5 ATTACHMENT A JEFFERSON COUNTY CODE COMPLIANCE RULES OF PROCEDURE sO N e w � 4-c SIIING'C- /N.-4\e\ Alletson efitir Public Hea It Developed October 2024 Jefferson County Code Compliance Rules of Procedure Page 2 of 9 N'rqN6^J TABLE OF CONTENTS PURPOSE 3 AUTHORITY 3 SEVERABILITY 3 RULE 1 -COMPLAINCE 3 RULE 2 -ROLE OF DEPARTMENT DIRECTORS AND STAFF 4 RULE 3 -COMPLAINTS 4 RULE 4 -ENFORCEMENT 5 RULE 5 - SETTLEMENTS 6 RULE 6 -ENFORCEMENT FUND 7 RULE 7-VOUCHERS 8 RULE 8 -LIMITATIONS 8 RULE 9 -AMENDMENTS AND CORRECTIONS 9 Jefferson County Code Compliance Rules of Procedure Page 3 of 9 PURPOSE The purpose of these Code Compliance Rules of Procedure(Rules) is to further implement title 19 JCC by providing additional guidance for compassionate and efficient code enforcement to promote and protect the general public health, safety, and environment of Jefferson County residents. Title 19 JCC provides uniform and efficient regulation for civil code violations and public nuisances. Uniform and efficient procedures, and consistent application, is in Jefferson County's best interest to improve the delivery and cost effectiveness of code compliance services to the public. AUTHORITY JCC 19.05.020 authorizes these Rules and sets the scope and limitations on enforceability. Title 19 JCC outlines certain acts to be civil violations and establishes civil enforcement procedures and penalties, and also declares certain acts to be misdemeanors, punishable by a fine of not more than $1,000 or imprisonment in a county jail for not more than 90 days. JCC 19.10.020. These Rules hereby reference and incorporate the enforcement process authorized in title 19 JCC. These Rules confirm and authorize the enforcement discretion of directors to use written policies for staff to uniformly and efficiently process code compliance complaints that do not rise to the level of a rule, including the use of template documents. SEVERABILITY If any section, subsection, paragraph, sentence, clause, or phrase of these Rules is declared unconstitutional or invalid for any reason, such decision shall not affect the validity of the remaining parts of these Rules. RULE 1 - COMPLAINCE Achieving code compliance is one of the primary ways Jefferson County works to promote and protect the public safety, health, and environment of Jefferson County residents. (a) Voluntary compliance whenever possible It is the intent of Jefferson County to seek voluntary compliance from the person responsible whenever possible as outlined in chapter 19.10 JCC—Voluntary Compliance. (i) As reflected in chapter 19.15 JCC—Voluntary Compliance, it is Jefferson County's directive to encourage compliance using education, prevention, and voluntary compliance as a first step. PAN (. yEY' Jefferson County Code Compliance Rules of Procedure Page 4 of 9 �'`rj11NG��y (ii) Staff must be sensitive to the possibility that the person responsible may not be aware of regulations and give warnings prior to enforcement, unless there is potential of immediate adverse impact on the people or environment. Staff shall document warnings in writing whenever possible. (b) Non-Compliance. If voluntary compliance is not achieved, then staff shall move forward with enforcement escalation protocols to gain compliance pursuant to chapter 19.20 JCC—Notice and Orders. RULE 2 - ROLE OF DEPARTMENT DIRECTORS AND STAFF (a) Department Directors and Staff (i) As used in these rules,the term "director"has the same meaning as defined JCC 19.10.015(1), and includes a director's designee. (ii) As used in these rules,the term "staff'means county employees engaged in code compliance under title 19 JCC and includes Code Compliance Coordinators, Code Compliance Officers, Environmental Public Health Officer Designees. (b) Code Compliance Officers and Health Officer Designees (i) Staff shall make every effort to project a professional demeanor, even under difficult situations, and consider the intent of regulations when seeking compliance with the regulations. (ii) Staff should be fair, equitable, vigilant, and guard against the abuse of power. (iii) Department directors have the responsibility of providing on-going training to ensure staff have the knowledge and skills needed efficiently and effectively carry out compassionate code compliance enforcement pursuant to title 19 JCC following best practices and procedural steps consistent with these Rules. (iv) Staff should engage in early intervention when responding to code compliance issues. (v) Staff should create a visible and credible presence of the interests and responsibility of government in the eyes of the public. County presence may deter some individuals from further violating code requirements. (c) The role of directors and staff is to administer the will of the people as expressed through legislation and initiatives, and codified in state and local laws, including title 19 JCC. RULE 3 - COMPLAINTS (a) Citizen Complaints you CO f- Jefferson County Code Compliance Rules of Procedure Page 5 of 9 SHIN6C (i) Jefferson County does not accept anonymous complaints. (ii) The Citizen Concern/Code Compliance Form can be found on the Jefferson County website: https://www.co.jefferson.wa.us/formcenter/dcd-11/complaint- form-70 (b) Processing Complaints (i) All complaints shall be timely entered into an approved database for tracking purposes. (ii) Staff shall determine if the complaints are founded or unfounded. RULE 4 - ENFORCEMENT JCC 19.05.020(3)provides the legal authority for these Rules to use the enforcement mechanisms listed in JCC 19.10.025, which says: Jefferson County seeks to gain voluntary compliance and may... consider using one or more of the following code compliance tools, when appropriate, and depending on the severity of a specific violation: education, voluntary compliance, notice of violation, order of abatement, one-time penalty, daily penalties, stop work order,notice to vacate, and property liens. (a) Escalation (i) When a civil code violation has been established according to the provisions of JCC 19.20.010, and voluntary compliance efforts are unsuccessful, JCC 19.10.45 gives discretion to the director to escalate enforcement. (ii) This may include assessing per-day penalties, and putting a lien on the property for unpaid fines and recovery of county costs(staff time, attorney time, etc.). (iii) At each step in the escalation process,the director and staff shall provide opportunities for voluntary compliance. (iv) Directors maintain enforcement discretion. Nothing in these Rules prevents the director from enforcing the violation. JCC 19.10.045. (b) Liens on Liens on Properties Requirements for imposing liens on properties can be found in JCC 19.10.025(3)—Enforcement authority and administration and JCC 19.30.020 JCC —Recovery of costs. (i) All penalties and costs shall constitute a lien against the subject property. A lien for penalties imposed shall be recorded if the monetary penalties remain unpaid for 90 days. 2 Jefferson County Code Compliance Rules of Procedure Page 6 of 9 (ii) The County shall place a lien for any unpaid monetary penalties imposed,the cost of any proceedings, any abatement work performed, and all other related costs against the real property on which the monetary penalty was imposed. (iii) Liens shall run with the land but shall be subordinate to all previously existing special assessment liens imposed on the same property and shall be superior to all other liens, except for state and county taxes, with which it shall be on a parity. JCC 19.30.020(3)-(a). RULE 5 - SETTLEMENTS Settling a case helps provide the incentive to deter future violations and sends a message to the community that Jefferson County's goal is compliance,not the collection of penalties. (a) Settlement Authority (i) Directors and staff shall work cooperatively with property owners to settle penalties whenever appropriate. (ii) The director or designee is authorized to settle claims for monetary penalties incurred from the actions and processes related to code violations or nuisances when such settlement is in the best interest of the County. See examples in JCC 1 9.15.010—Voluntary compliance agreements and JCC 19.30.025—Settlement of monetary penalties and costs. (iii) In addition, the director shall consider the following factors: (A)Whether the person responsible responded to notices and cooperated to correct the code violation or nuisance; (B)Whether the person responsible failed to appear at the hearing; (C)Whether the code violation or nuisance was a repeat violation; (D)Whether the person responsible showed due diligence or substantial progress in correcting the code violation or nuisance; and (E)Any other relevant factors. JCC 19.30.025(1)(a)-(e). (iv) The director is authorized to settle claims for monetary penalties incurred under JCC 19.30.010 and costs incurred under JCC 19.30.020 when such settlement is in the best interest of the county. JCC 19.30.025(1). (v) In assessing violations for settlement, directors and staff shall consider the factors outlined in JCC 19.30.025(1)JCC. In settling penalties, directors shall have broad discretion to defer payment of a portion of the penalty for up to three years, unless a shorter time-frame is warranted. Mk = \ Jefferson County Code Compliance Rules of Procedure Page 7 of 9 (vi) All Voluntary Compliance Agreements shall fully comply with the necessary terms and conditions for Settlement Agreements as outlined in JCC 19.15.015. (vii) When a Settlement Agreement is entered into, staff and directors shall determine a reasonable and flexible compliance timeline. JCC 19.15.015. (viii) The director shall make an annual report to the Jefferson County Board of Commissioners regarding all settlements under title 19 JCC. JCC 19.30.025(2). (b) Costs that cannot be settled (i) The director shall not waive any assessed costs of code compliance or actual abatement costs incurred by the County, including associated interest thereon. (ii) Actual abatement costs are funds spent by the County to achieve physical abatement of the code violation or nuisance. JCC 19.30.025. RULE 6 - ENFORCEMENT FUND Title 19 JCC authorizes an Enforcement Fund. (a) Enforcement Fund Authorized Uses (i) Assessed penalties collected in relation to code enforcement efforts shall be deposited into the Enforcement Fund. (ii) All monies collected from the assessment of civil penalties, abatement costs,or other costs recovered for the work relating to civil code or nuisance enforcement shall be allocated to support expenditures for enforcement and abatement and shall be accounted for through the creation of an account in the fund for civil code enforcement and abatement costs or other appropriate accounting mechanisms. JCC 19.30.030.. (iii) The Enforcement Fund is administered by Jefferson County Environmental Public Health with a specific accounting for each department that contributes to the Enforcement Fund. (iv) Monies form the Enforcement Fund shall be used to support code compliance enforcement and abatement, including but not limited to, staff training, abatements, supplies,education and outreach,community clean up events, vouchers for fees and inspections, and recording fees related to code compliance enforcement. (v) Use of the Enforcement Fund must be approved by a director. (vi) Any disagreement between departments about the use of Enforcement Fund monies shall be resolved by a meeting between the respective department directors. Jefferson County Code Compliance Rules of Procedure Page 8 of 9 (vii) If the directors cannot reach an agreement,the impasse shall be brought to the County Administrator. (viii) After hearing from all respective departments involved, the County Administrator shall make the final decision regarding how the specific Enforcement Fund monies in dispute should be dispersed. RULE 7 - VOUCHERS Vouchers may be authorized in certain circumstances when it is believed in good faith to be the quickest and most expedient way to gain compliance. (a) Authority for vouchers Vouchers shall only be issued after consultation with the department's director or designee. (a) When vouchers are appropriate Vouchers may be appropriate when working with properties where the owners lack financial resources, the property is a victim of illegal dumping,the problem is relatively small and contained,the property is in probate,or other extenuating circumstances that warrant reducing the barrier to compliance. (b) Limitations on vouchers: (i) Vouchers are limited to one household every three years; (ii) Annual voucher expenditures shall not exceed$5,000; (iii) Vouchers have a limit of$250.00; and, (iv) Vouchers are not guaranteed and subject to budget constraints. RULE 8 - LIMITATIONS (a) No Additional Legal Rights These Rules do not create legal rights beyond those obligations and rights created by statute or other laws binding on Jefferson County. (b) Legal Requirements and Best Practices (i) The provisions of state law and title 19 JCC control, if there is any conflict with these Rules. (ii) These Rules include both statutory requirements and best practices. (c) No Additional Duty That is Not Already Imposed by Law Jefferson County Code Compliance Rules of Procedure Page 9 of 9 _` i No provision nor any term used in these Rules is intended to impose any duty whatsoever upon Jefferson County or any of its officers or employees, not already imposed by law. (d) No Basis for Liability These Rules are not intended to and shall not be construed to create or form the basis of any liability on the part of Jefferson County, or its officers, staff, or agents, for any injury or damage resulting from any action or inaction on the part of Jefferson County related in any manner to the enforcement of these Rules by its elected officials, officers, staff, or agents. RULE 9 -AMENDMENTS AND CORRECTIONS (a) Amendments and corrections to these Rules shall be made in accordance with JCC 1 9.05.020(2). (b) The Clerk of the Board of County Commissioners is authorized to make necessary technical, non-substantive corrections to these Rules including, but not limited to, the correction of scrivener's or clerical errors, references, numbering, section/subsection numbers and any references to them. w U Z Oa 4-1 031 < CU CO In a. 4..., ..,:„......, ... 2 0 11 ' n w 4-0 W r Y , aU Q 0 . T CO 0 . 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CI 0 U D U- Li) ( ) W U U , D i Q Q , V L.e ro in CU u C 0 0 zL.9a1 D > — 0 a) E ix 0 r1/ aJ _ nU u•� v r0 y� }' 0,.. ft— CO /W 0 Q W 0 Ts coV V L Q) ■ ■ coU 5 no -0 - v 06 O v1 U v ro VO Q m a > 4-1 LL E W kJ c V1 C in kJa) U > Ln O.no Ln 4J E a 2 L1 al a- LL ( D ro V1 +' ei v ' C O = O N 22 D ow c Q }.r V W U Q W W N O ^, ^ V / V —IN co ,k xri ., i; 4 i t , . .* t > - . O }' O w w 0) } n titr ...„): z D 0/ r,. O z �. Qvl I __. N O N ATTACHMENT A JEFFERSON COUNTY CODE COMPLIANCE RULES OF PROCEDURE (4sON \\ III NG 47--Ni%%*(1.ff Public Health Developed October 2024 �Al\ f0 fZ. Jefferson County Code Compliance Rules of Procedure Page 2 of 9 ~sirrtii�`y TABLE OF CONTENTS PURPOSE 3 AUTHORITY 3 SEVERABILITY 3 RULE 1 -COMPLAINCE 3 RULE 2 -ROLE OF DEPARTMENT DIRECTORS AND STAFF 4 RULE 3 -COMPLAINTS 4 RULE 4 -ENFORCEMENT 5 RULE 5 - SETTLEMENTS 6 RULE 6 -ENFORCEMENT FUND 7 RULE 7 -VOUCHERS 8 RULE 8 -LIMITATIONS 8 RULE 9-AMENDMENTS AND CORRECTIONS 9 Jefferson County Code Compliance Rules of Procedure Page 3 of 9 PURPOSE The purpose of these Code Compliance Rules of Procedure (Rules) is to further implement title 19 JCC by providing additional guidance for compassionate and efficient code enforcement to promote and protect the general public health, safety, and environment of Jefferson County residents. Title 19 JCC provides uniform and efficient regulation for civil code violations and public nuisances. Uniform and efficient procedures, and consistent application, is in Jefferson County's best interest to improve the delivery and cost effectiveness of code compliance services to the public. AUTHORITY JCC 19.05.020 authorizes these Rules and sets the scope and limitations on enforceability. Title 19 JCC outlines certain acts to be civil violations and establishes civil enforcement procedures and penalties, and also declares certain acts to be misdemeanors, punishable by a fine of not more than $1,000 or imprisonment in a county jail for not more than 90 days. JCC 19.10.020. These Rules hereby reference and incorporate the enforcement process authorized in title 19 JCC. These Rules confirm and authorize the enforcement discretion of directors to use written policies for staff to uniformly and efficiently process code compliance complaints that do not rise to the level of a rule, including the use of template documents. SEVERABILITY If any section, subsection, paragraph, sentence, clause, or phrase of these Rules is declared unconstitutional or invalid for any reason, such decision shall not affect the validity of the remaining parts of these Rules. RULE 1 - COMPLAINCE Achieving code compliance is one of the primary ways Jefferson County works to promote and protect the public safety, health, and environment of Jefferson County residents. (a) Voluntary compliance whenever possible It is the intent of Jefferson County to seek voluntary compliance from the person responsible whenever possible as outlined in chapter 19.10 JCC—Voluntary Compliance. (i) As reflected in chapter 19.15 JCC—Voluntary Compliance, it is Jefferson County's directive to encourage compliance using education, prevention, and voluntary compliance as a first step. Jefferson County Code Compliance Rules of Procedure Page 4 of 9 (ii) Staff must be sensitive to the possibility that the person responsible may not be aware of regulations and give warnings prior to enforcement, unless there is potential of immediate adverse impact on the people or environment. Staff shall document warnings in writing whenever possible. (b) Non-Compliance. If voluntary compliance is not achieved,then staff shall move forward with enforcement escalation protocols to gain compliance pursuant to chapter 19.20 JCC—Notice and Orders. RULE 2 - ROLE OF DEPARTMENT DIRECTORS AND STAFF (a) Department Directors and Staff (i) As used in these rules, the term "director"has the same meaning as defined JCC 19.10.015(1), and includes a director's designee. (ii) As used in these rules,the term "staff'means county employees engaged in code compliance under title 19 JCC and includes Code Compliance Coordinators, Code Compliance Officers,Environmental Public Health Officer Designees. (b) Code Compliance Officers and Health Officer Designees (i) Staff shall make every effort to project a professional demeanor, even under difficult situations, and consider the intent of regulations when seeking compliance with the regulations. (ii) Staff should be fair, equitable, vigilant, and guard against the abuse of power. (iii) Department directors have the responsibility of providing on-going training to ensure staff have the knowledge and skills needed efficiently and effectively carry out compassionate code compliance enforcement pursuant to title 19 JCC following best practices and procedural steps consistent with these Rules. (iv) Staff should engage in early intervention when responding to code compliance issues. (v) Staff should create a visible and credible presence of the interests and responsibility of government in the eyes of the public. County presence may deter some individuals from further violating code requirements. (c) The role of directors and staff is to administer the will of the people as expressed through legislation and initiatives, and codified in state and local laws, including title 19 JCC. RULE 3 - COMPLAINTS (a) Citizen Complaints y ll� (U fJefferson County Code Compliance Rules of Procedure Page 5 of 9 (i) Jefferson County does not accept anonymous complaints. (ii) The Citizen Concern/Code Compliance Form can be found on the Jefferson County website: https://www.co.jefferson.wa.us/formcenter/dcd-11/complaint- form-70 (b) Processing Complaints (i) All complaints shall be timely entered into an approved database for tracking purposes. (ii) Staff shall determine if the complaints are founded or unfounded. RULE 4 - ENFORCEMENT JCC 19.05.020(3)provides the legal authority for these Rules to use the enforcement mechanisms listed in JCC 19.10.025, which says: Jefferson County seeks to gain voluntary compliance and may... consider using one or more of the following code compliance tools, when appropriate, and depending on the severity of a specific violation: education, voluntary compliance, notice of violation, order of abatement, one-time penalty, daily penalties, stop work order,notice to vacate, and property liens. (a) Escalation (i) When a civil code violation has been established according to the provisions of JCC 19.20.010, and voluntary compliance efforts are unsuccessful, JCC 19.10.45 gives discretion to the director to escalate enforcement. (ii) This may include assessing per-day penalties, and putting a lien on the property for unpaid fines and recovery of cGounty costs (staff time, attorney time, etc.). (iii) At each step in the escalation process, the director and staff shall provide opportunities for voluntary compliance. (iv) Directors maintain enforcement discretion..- Nothing in these Rules prevents the director from enforcing the violation. JCC 19.10.045.- (b) Liens on Liens on Properties Requirements for imposing liens on properties can be found in JCC 19.10.025(3)—Enforcement authority and administration and JCC 19.30.020 JCC —Recovery of costs. (i) All penalties and costs shall constitute a lien against the subject property. A lien for penalties imposed shall be recorded if the monetary penalties remain unpaid for 90 days. uN Jefferson County Code Compliance Rules of Procedure Page 6 of 9 .14Ntvdr". (ii) The County shall place a lien for any unpaid monetary penalties imposed,the cost efcost of any proceedings, any abatement work performed, and all other related costs against the real property on which the monetary penalty was imposed. (iii) Liens shall run with the land but shall be subordinate to all previously existing special assessment liens imposed on the same property and shall be superior to all other liens, except for state and county taxes, with which it shall be on a parity. JCC 19.30.020(3)-(a). RULE 5 - SETTLEMENTS Settling a case helps provide the incentive to deter future violations and sends a message to the community that Jefferson County's goal is compliance, not the collection of penalties. (a) Settlement Authority (i) Directors and staff shall work cooperatively with property owners to settle penalties whenever appropriate. (ii) The director or designee is authorized to settle claims for monetary penalties incurred from the actions and processes related to code violations or nuisances when such settlement is in the best interest of the County. See examples in JCC 19.15.010—Voluntary compliance agreements and JCC 19.30.025—Settlement of monetary penalties and costs. (iii) In addition,the director shall consider the following factors: (A)Whether the person responsible responded to notices and cooperated to correct the code violation or nuisance; (B)Whether the person responsible failed to appear at the hearing; (C)Whether the code violation or nuisance was a repeat violation; (D)Whether the person responsible showed due,diligence or substantial progress in correcting the code violation or nuisance; and (E)Any other relevant factors. JCC 19.30.025(1)(a)-(e).). (iv) The director is authorized to settle claims for monetary penalties incurred under JCC 19.30.010 and costs incurred under JCC 19.30.020 when such settlement is in the best interest of the county. JCC 19.30.025(1). (v) In assessing violations for settlement, directors and staff shall consider the factors outlined in JCC 19.30.025(1)JCC. In settling penalties, directors shall have broad discretion to defer payment of a portion of the penalty for up to three years, unless a shorter time-frame is warranted. Nii;b617"‘ Jefferson County Code Compliance Rules of Procedure Page 7 of 9 441inc�;,J (vi) All Voluntary Compliance Agreements shall fully comply with the necessary terms and conditions for Settlement Agreements as outlined in JCC 19.15.015.: (vii) When a Settlement Agreement is entered into, staff and directors shall determine a reasonable and flexible compliance timeline. JCC 19.15.015.- (viii) The director shall make an annual report to the Jefferson County Board of Commissioners regarding all settlements under title 19 JCC. JCC 19.30.025(2). (b) Costs that cannot be settled (i) The director shall not waive any assessed costs of code compliance or actual abatement costs incurred by the County, including associated interest thereon. (ii) Actual abatement costs are funds spent by the County to achieve physical abatement of the code violation or nuisance. JCC 19.30.025 JCC. RULE 6 - ENFORCEMENT FUND Title 19 JCC authorizes an Enforcement Fund. (a) Enforcement Fund Authorized Uses (i) Assessed penalties collected in relation to code enforcement efforts shall be deposited into the Enforcement Fund. (ii) All monies collected from the assessment of civil penalties, abatement costs,or other costs recovered for the work relating to civil code or nuisance enforcement shall be allocated to support expenditures for enforcement and abatement and shall be accounted for through the creation of an account in the fund for civil code enforcement and abatement costs or other appropriate accounting mechanisms. JCC 19.30.030.. (iii) The Enforcement Fund is administered by Jefferson County Environmental Public Health with a specific accounting for each department that contributes to the Enforcement Fund. (iv) Monies form the Enforcement Fund shall be used to support code compliance enforcement and abatement, including but not limited to, staff training, abatements, supplies, education and outreach, community clean up events, vouchers for fees and inspections,and recording fees related to code compliance enforcement. (v) Use of the Enforcement Fund must be approved by a director. (vi) Any disagreement between departments about the use of Enforcement Fund monies shall be resolved by a meeting between the respective department directors. Jefferson County Code Compliance Rules of Procedure Page 8 of 9 fS,,iN.� (vii) If the directors cannot reach an agreement, the impasse shall be brought to the County Administrator. (viii) After hearing from all respective departments involved, the County Administrator shall make the final decision regarding how the specific Enforcement Fund monies in dispute should be dispersed. RULE 7 - VOUCHERS Vouchers may be authorized in certain circumstances when it is believed in good faith to be the quickest and most expedient way to gain compliance. (a) Authority for vouchers Vouchers shall only be issued after consultation with the department's director or designee. (a) When vouchers are appropriate Vouchers may be appropriate when working with properties where the owners lack financial resources, the property is a victim of illegal dumping,the problem is relatively small and contained, the property is in probate, or other extenuating circumstances that warrant reducing the barrier to compliance. (b) Limitations on vouchers: (i) Vouchers are limited to one household every three years; (ii) Annual voucher expenditures shall not exceed $5,000; (iii) Vouchers have a limit of$250.00; and, (iv) Vouchers are not guaranteed and subject to budget constraints. RULE 8 - LIMITATIONS (a) No Additional Legal Rights These Rules do not create legal rights beyond those obligations and rights created by statute or other laws binding on Jefferson County. (b) Legal Requirements and Best Practices (i) The provisions of state law and title 19 JCC control, if there is any conflict with these Rules. (ii) These Rules include both statutory requirements and best practices. (c) No Additional Duty That is Not Already Imposed by Law :,os c aY�- to Jefferson County Code Compliance Rules of Procedure Page 9 of 9 No provision nor any term used in these Rules is intended to impose any duty whatsoever upon Jefferson County or any of its officers or employees, not already imposed by law. (d) No Basis for Liability These Rules are not intended to and shall not be construed to create or form the basis of any liability on the part of Jefferson County, or its officers, staff, or agents, for any injury or damage resulting from any action or inaction on the part of Jefferson County related in any manner to the enforcement of these Rules by its elected officials, officers, staff, or agents. RULE 9 - AMENDMENTS AND CORRECTIONS (a) Amendments and corrections to these Rules shall be made in accordance with JCC 19.05.020(2)4: (b) The Clerk of the Board of County Commissioners is authorized to make necessary technical, non-substantive corrections to these Rules including, but not limited to,the correction of scrivener's or clerical errors, references, numbering, section/subsection numbers and any references to them. r. x` t � " s � a Code Compliance � Rules of Procedure November 12, 2024 1 ° > fin.. M '',-'" .;• ., "'ate ., Pinky Mingo, Environmental Public Health and Water Quality Manager °`�• ,� Nicki Akins, Code Compliance Coordinator for DCD w Mn" Ariel Speser, Civil DPA ii BoCC Presentation 1 L 'II V. 1 II Historical Context of Code Compliance Legislation Comparison: July 2003 Resolution to Current Proposal Agenda Why Code Compliance Rules of Procedure? Niyi Who Benefits? (Spoiler: Everyone!) 4,v 6x --- --1 co 1 4, 4 Historical Context 1 cii4 , of Code 1 Compliance ,`ti Legislation /r , r ,4,..,,,. c::::7 -i __::Sf:.1.----- . 'IS .4 '1% f BoCC Presentation 3 : :Npv',014012:2024 1 Ordinance 09-1210-20 (Title 19 JCC Code ._. Compliance) Ordinance No. 07-0624-19 (Ch. 8.90 Public Nuisance) Historical Context of Code Resolution 42-03 (Re-Establishing Policy on Complaint Review & Enforcement) Compliance Legislation Proposed Code Compliance Rules of Procedure Process for Future Amendments to Proposed Code Compliance Rules of Procedure Q, ON (0i. Historical Context of Code Compliance Legislation =�01 Ordinance No. 09-1210-20 (December 2020): Adds an Entire Title to JCC on Comprehensive Code Compliance Adopts Title 19 JCC: Preempts Resolution WHEREAS, Jefferson County is exercising its constitutional and statutory authority to No.42-03 declare what shall be deemed a nuisance in unincorporated Jefferson County and is establishing a (Where Inconsistent) system for addressing nuisances in the county that is consistent with state law;and, WHEREAS, the BOH and the BoCC each have held a hearing and has received public comment on the draft ordinance proposed by staff;and, WHEREAS,in response to the public comment and testimony,additional improvements to the draft ordinance have been made,and, NOW,THEREFORE,be it ordained by the BOH and the BoCC as follows: Section 1. Adding Title 19 JCC. The BoCC and the BOH have concurrent legislative authority regarding the adoption of Title 19 JCC and for the changes in the other Titles for which they have legislative authority as stated below. The BoCC and the BOH jointly adopt Title 19, as set forth in Appendix A. yO N Historical Context of Code Compliance Legislation = '� Ordinance No. 09-1210-20 (December 2020) — Comprehensive Code '.5 / C,� Corn •Hance Ordinance Adopts Title 19 JCC: Below Are Is the of Chapters Preempts Resolution Chapters: No. 42-03 (Where Inconsistent) 19.05 Introductory Provisions 19.10 General Provisions 19.15 Voluntary Compliance 19.20 Notice and Orders 19.25 Vehicle and Public Right-of-Way Nuisances 19.30 Penalties, Costs, and Settlements 19.35 Administrative and Hearing Examiner Appeals for Civil Code Violations 19.40 Hearing Examiner Appeals for Nuisances Historical Context of Code Compliance Legislation Ordinance No. 09-1210-20 (December 2020) Below Are of the Sections Adopts Title 19 JCC: Preempts Resolution sea,ons No.42-03 19.05.010 Purpose. 19.05.015 Liberal construction. (Where Inconsistent) 19.05.020 Code Compliance Rules of Procedure authorized. Y 19.05.025 Severabllity. Sec I 19.10.010 Applicability. 19.10.015 Definitions. 19.10.020 Declaration of public nuisance,misdemeanor. 19.10.025 Enforcement authority and administration. 19.10.030 Conference. 19.10.035 Guidelines regarding responses to potential violations. 19.10.040 Investigating potential violations. 19.10.045 Enforcing civil code violations. 19.10.050 Service of notices of voluntary compliance.notices of noncompliance,notices of violation,stop work orders.notices of violation and orders of abatement.and certificates of correction. 19.10.055 Right of entry. 19.10.060 Representation by attorney. 19.10,06S Certificate of correction. 19.10.070 Limitation of liability. 19.10.075 Denial of permits. 19.10.080 Suspension or revocation of permit. 19.10.090 Notice to title. Sections: 19.15.010 Notice of voluntary compliance. 19.15.015 Voluntary compliance agreements. Sec0ons. 19.20.010 Notice of violation. 19.20.015 Notice of violation and order of abatement. 1930.020 Stop work order. Historical Context of Code Compliance Legislation Ordinance No. 07-0624-19 (June 2019): Adds an Entire Chapter for Public Nuisance Enforcement Repealed and ("OCNT1 UFJEFFERsf Replaced STATE OF WASHIst,= by Title 19 JCC An Ordinance on PYMic%uisaace ORDINANCE NO.07462a-19 in Unincorporated Areas of Jefferson O Dunes WHEREAS,RCW 36,32.120(It1)pr..,ides that counties base the power to declare by WHEREAS,Article XI,section 1 I of the W uiiineton Cprotit331393.cinders upon county ordinance what shall he deemed a nuisance within the count};to abate a nuisance at the expense legislative authorities the police power to adopt such local poliice,sanitary and other regulations of the parties creating,causing,or committing the nuisance.and to levy a special assessment on as are not in conflict with general laws.and, the hind or premises sin which the nuisance is situated to defray the cost,or to reimburse the county for the cost of abating it,and. WHEREAS,Stuck Xf,section 11 of the Washington c onatatgam is a direct delegation 4 the police power to cites and*mutates.and the power delegated is as estenstse within their WHEREAS the Heard of County Ctnrunissionsers IRoCCl is exercising its constitutional -here as that possessed ha,the legislature.and. and statutory authoxrty to declare what shall he deemed a nuisance in unincorporated Jefferson Counts and is establishing a system for addressing nuisances in the county that is consistent with WHEREAS,RCN It.32.l2V 7j prsis i es that the county kgisatrse author-owl shall make cute law:and, and enforce,by appropriate resolutions or ordinances,all such police and sanitary regulations as are not in conflict with state law,and, WHEREAS,on June 17.2019.the RoO.'C held a hearing on and received public comment on the draft ordinance proposed by staff:and, WHEREAS,police passer is that inherent and plenary power which enables prohibition of all things hurtful to the comfit,safety and welfare of society,and. WHEREAS,in response to the public comment and testimony,additional improvements to the draft ordinance have been made, WHEREAS.the scope of police power is broad.encompassing all those measures which - r and substantial relation to promotion of the general welfare of the people.and, NOW.THEREFORE,he it ordained by the RloCC as follows: Section ; Vdd neat Ater i'tf}1CC Chapter 8f90 ACC shall be added as set forth m ‘rrsl43 k pti Historical Context of Code Compliance Legislation Ordinance No. 09-1210-20 (December 2020) `fis,,I (,; Public Nuisance Chapter 8.90 JCC (Nuisance Code) Zips .{ Codes New Compliance Provisions Title 19 Code) g To ether (Compliance New Compliance Code: 1. Based on Current Public Nuisance Code, Chapter 8.90 JCC. 2. Includes Public Nuisance Protections Now in Chapter 8.90 JCC. 3. If Adopted, Chapter 8.90 Would Be Repealed. (from 11/19/2020 BoCC & BOH Presentation) pX ri1-, Historical Context of Code Compliance Legislation Ordinance No. 09-1210-20 (December 2020): ,,.1 Adds an Entire Title to JCC on Comprehensive Code Compliance Adopts Title 19 JCC: Preempts Resolution WHFFREAS, Jefferson County is exercising its constitutional and statutory authority to No.42-03 declare what shall be deemed a nuisance in unincorporated Jefferson County and is establishing a (Where Inconsistent) system for addressing nuisances in the county that is consistent with state law;and, WHEREAS, the BOH and the BoCC each have held a hearing and has received public comment on the draft ordinance proposed by staff;and, WHEREAS, in response to the public comment and testimony,additional improvements to the draft ordinance have been made,and, NOW,THEREFORE,be it ordained by the BOH and the BoCC as follows: Section 1. Adding Title 19 JCC. The BoCC and the BOH have concurrent legislative authority regarding the adoption of Title 19 JCC and for the changes in the other Titles for which they have legislative authority as stated below. The BoCC and the BOH jointly adopt Title 19, as set forth in Appendix A. �yON CO � Historical Context of Code Compliance Legislation Resolution No. 42-03 (July 2003) X�N� In the Matter of re-establishing the Title 19 JCC County Policy on the Complaint Review RESOLUTION NO 42-03 and Enforcement (December 2020) Preempts Resolution WHEREAS Jefferson County enacted a Complaint Review and Enforcement Policy by No.42-03 passage of Resolution No.Y9-O3 on June 99,2005 to enforce locally adopted codes and ordinances in (Where Inconsistent) order to achieve compliance with the public policy;and, WHEREAS this policy was enacted because the County realizes that in the course of enforcement and compliant investigations,employees may encounter circumstances that require the employee to make decisions on how to proceed that could have the potential to impinge on property owner privacy and/or property rights and this policy is to provide employees with specific instructions on what is expected of them in the performance of their duties and how to conduct themselves when approaching a potential violation,conducting an investigation or responding to a citizen complaint; and, WHEREAS it was found that Attachment A which was part of Resolution No.49-05 was not updated to incorporate changes made by the Board of Commissioners to address citizen concerns with the original document and those changes are necessary. NOW,THEREFORE BEITRESOLVED,by the Board of County Commissioners that Resolution No.39-09(and Attachment A to it)is hereby repealed. BE IT FURTHER RESOLVED,that the Jefferson County Policy on Complaint Review and Enforcement has been updated with the requested changes embodied in Attachment A which is hereby incorporated as part of this resolution. ll\ Historical Context of Code Compliance Legislation l�r Resolution No. 42-03 (July 2003) — Appendix A (�i.s.„INC„-0 ATTACHMENT`A" s TI'ACNSIFNI'A^ '�FERSON COUNTY SECTION 40-Refefwpw ATFACNMF.NT`A^ POLICY ON CO4&WNT RENEWS ENFORCEMENT 41 Jeparaon spumy Cone,rxoimwee ark reputations recerenosn and d`plead....ermine I0 falls veer Wash dsanen0s POLICY 9TATFMENT:X e the post of County to mWrca Really erloplad 4.2 Reowed Cod.of W asheplun *00*non.lna raprsrtlrp Petty t 1 oyr.tj do.not Me remarry department 3000PIM take ell nartmente Y 3 Waehmgvn Stale Adndd9raeve Code tmmepx Ka mar,.dMem a depedmed of aka*and oNuramae n or.t a0vave wmp4arce a n 0n pub.p cv endo.ad 4 W01n6b1 Stile Consdulron County M.me reOreaM1e^ 4.5 Ufide3 Slates Cons.. 8 I 1 0.ly Comua a ohm Re ordont 1 aciwnaiy ornara.Jefferson 11 Meeaslnnl Form sorve the rece ntg�ntrmaWn. Jefferson Court.employees.in carrying and Us policy.wstl reep2IM cdva0Y and SECTION 5.0-O 0y4 5 i) Gate of c tm l the compmnl is recewaC aE eights of cedens and before 00*014 ern the e.g.measures metaled n to:n.ate ante.. Any wnnen vernal or other corn..alr type of d sent 5 1 C cereng: .n reported.me County E Name_ np co am is or pumcer of la special parry emngthe lo.oe-,Trost st.Marode,techon or of ti,u:e.Sad B.t.2 Empperxyakd...Mg1 mwrplans or repute regarepetit SECTION 1.0-Sub)ecl xan,Yaim$.orw en al ale pre. oargileramn.end...Mg not This Inky 0das the 001nta lobe bepa.d by all Jefferson County departments when 5.1 1 aetoneX 0Clatnn l s Pee ompbint tor when a ode,re...w S.:]The mm000 Y0 aM 01 notified o eaamg of the receiptor the...re respomin intsand emnrcng Proaons re...)Comets R.gumbry B.tt Emergency - nverified laarod. .rdayiven pm<omgent file rwmarb hrisala Ares M1Suro tBaeuO renstre snore-ant Ordinances ...lions apply n al persons,...entrees. plain Deal a rAny oda..4C w iat pre seuetloe 82 Confide..Complaints the PM.. on Covnly to aaept and nmagenc Pn1' SECTION 2.0-Port.. rs tot corrected 0medntey era,.progrims recurred Imm con ken4M reparang CM. ref gudepres tor rwporMry to caimnmrrpdents.basic 6 2 t The name of the OOITKwdml informant w confidennal recnrtny petty enforcement tom pyres for once.orresp respond. and tern to corn..n me 5.2 TM County:The room,.rorpueton 4erovm»J*Rers*Conn.-Weahn¢on mat a revealed to me Candy employee,however the rmme and Me County rant emee.damage*from an ied al l a timer Side aratw Xo...noes.0)Nssnt de»rtnerN,em01yeee.repreeedaevee *ion from confidential femme.maws wit not a shown n me moss..instance when eddy...a mltn4 thin mar-is a clear and present Ymdmen et appo-aee esdee. and retool.no.Mt am be Irwt.n a»peals ewe na.n,al can ha aa**- _.t an tan me goo Jefferson referenced 5.3 Enforcement AUMordy:TMppe�M,era responsible.to Nargfral 6.22 RXNson Count,Mall not act on cormants received from anonymous msunr.to cases of t. wolf..and br non-orenpiame Bounty mt..compliance xEnspoym Day p -+4a d Mask atl po then dle Not*ark Oder to Correct or fan o VON the tams and umatltionsMenu repot. � recourse BEFORE Empty.tetra Iw o ovi.ae tn... of Cortes/on Agreements.ITa Ednnrmmmt At ronry and the Endowment e 3 Coe...Reyle0 end Referral:Program s1911 MNI raspor4 only to a reported Older may M.ne same person darn st 0 or sums .venation a a.cod oil .on or rem n stab area of 22 Gem.Guidelines:Jefferson County,cam gm.. to De form.gu 51 r persona.s r- Iunsptc0on.Ca..cornea.arrow mil reedtpa refmMm0loeo Enforcement OMeeer:The pusnnlar 0a KM hcr to onbr* .pe end mare the ps.or Canty Departments wWMat...p rezponsiday for Mata of when eppmacnmy;apo(03.al.:s4tmr.. a) Ms.,the rights of pm.te wovedv when rm...an mwstiga[wn. nouns a Tel RSVP any other aprecaele state Kw.male M.M.a Of RC pact:No rreseaasi OdNrmra of this County The Enforcement P.m may ago a foe Cl _ n9 in,po�l re*a A osa0�n Mel *tnemse m Aumonry unless to crcumsnnws.statutes w ntRdamm delete Se M 10rnMerge el ea nvrowe0 and a delenlnation made met may are a darn)rajny ol ea. aymeng a ° amaapna,action..or ega500' apecw P„rtc3Ee.n the gpealed dagee bossNle, 5 5 dlNae and O.prtnnenle for the pumpsx M Ilea poky,04*atmtl•013*atl 6 Emergency Canplal orRepoN 0 any repan of an red. wWnrra Jarerson County0e0anmemz their Prisons.subdBNKns.atAllwy offices.and amodent ew+ cal a erore nwY«deem her warned a) Use a fiir.nil em,fly and melded approach I®rg goad common ern»W imminent a the* nn a corrected reason.. ...es ,m 11.romp rein re detemened a a an amen).ry. eiwi90"<Y,Ina srpeiaaar eill mode 4Mr6wm Oee+d Sap»aer ePawd.aM ib s.nnw SECTION0.0 Med.ONlun and...weft54.2 MtateC pe nt is a tlMerrnetnn by the appro.,.t cunrymono pra..andrammed..code.ordinance or fepM .al sl.t Jefferson Canty uffrs and ganmcm .spnele o enbsanmrd of 'om.codes o ewes.arWpap0Ecade Slate of 04090 bavkaa acronym Deportment 'slnand ewe nor be ed la arurO�Besed xd.eWm uc ummln Yed0*WrdW Washington Kea edrrmsfered m the Kcal Oval.except fe.orrrred W M pre xiMesng parry ardor their representative.w o onto enfoenforpersonae, d erm enforcement personae, or other such s'erXlem s e means or measures SECTION 6.0-Complaint Re*ew and Enforcement ble.ma not of an 6 1 Complaint or Report Receipt:Mon suepaclm vwenom am report.t ail X rot corsWia pe is ealwd»proses»a ea tro Opwnmenl due co Y deparen.re by telephone sale or Ntlere.me inspector of person - y 'n