Thursday, August 28, 2008

Cabaret hearing for Eli's club is inconclusive

The cabaret permit hearing for Eli’s Mile High Club, held August 28th at City Hall, was inconclusive. Various inspections need to be completed, testimony reviewed, and conditions proposed before any permit will be issued.

The twenty or so people in attendance appeared to be divided between Eli’s neighbors and those with some financial interest in the club (owners, employees, contractors, vendors, booking agents), with a few other interested parties thrown in. The half dozen immediate neighbors who attended expressed concerns about noise, parking, blocked driveways, loitering, rowdy behavior, tobacco smoke and misdeeds of prior owners. Sgt. Kyle Thomas of OPD voiced three concerns of the police department: diversion of resources to respond to problems typical of nightclubs, issues of compatible use with a club located in a residential neighborhood, and a concern the club would adversely boost crime statistics in the area (and thereby make Captain Toribio look bad). Supporters of the club pointed to its rich and long history as an entertainment venue and restaurant, the efforts the new owners are making to address residents’ concerns, and the jobs and tax revenue a successful nightclub would generate.

The new club owner, Geoffrey Melville, son of a blues musician, expressed his fervor to host live entertainment and his commitment to accommodate the neighbors to make it happen, while admitting a total lack of experience. Head of security Jason Herley, with some prior experience working at nightclubs back east, described the management’s response to recent incidents involving a blocked driveway, noise complaints and unruly behavior in a nearby park. The club will clear the patio area after 10 pm if it gets noisy, and will station doormen to monitor patrons as they exit. Plans are to have one security guard for every 45 patrons. Soundproofing professional Brian Hood stated that existing soundproofing had been poorly installed and that he would dramatically improve the noise situation, but that it was unrealistic to think that anything could completely block all noise.

Hearing Officer Barbara Killey questioned how club management would judge when the patio noise level was inappropriate or not. She rebuked property owner Mike McDonald for not taking responsibility for excesses allowed by previous club owners, and noted that the property owner was ultimately responsible for noise violations, with a $1,000 per day penalty possible. Mike’s note that he had spent some $80,000 in the past on soundproofing upgrades was brushed aside. Ms. Killey informed the owners that Oakland’s noise ordinance does not allow noise from a business to be heard over 50 feet away in any direction. She questioned the experience and capitalization of the new club owners and expressed doubt that a permit could be granted without a good track record being first established.

What was missing from the process was any sense of responsibility on the part of neighbors for their own welfare. Some houses in the area are over a hundred years old, with single-pane windows and no insulation—barely better than tents at blocking noise. The Hearing Officer stated that Eli’s must upgrade to meet current standards; the fact that it has offered entertainment for decades at that location in its current condition (or worse) is insufficient. But neighbors, apparently, have no responsibility to upgrade their own dwellings if they have problems with noise. Nor does one’s decision to live in a neighborhood in the shadow of a major freeway interchange, next to the BART tracks on a street with AC Transit buses, seem to bring with it any expectation that one should tolerate a high noise level.

It seems unlikely that a permit will be issued – or that the club will survive. A few neighbors are determined to close it down. The City’s attitude, as usual, is that businesses must meet ever higher standards regardless of cost, although City officials routinely wonder aloud why Oakland has little retail, a shrinking business tax base, and one of the nation’s highest percentages of consumer dollars spent in neighboring communities. The winners here may be a few close neighbors who bought property cheaply due to location, and likely will get a boost in value if condos are built on the land instead. The losers, as usual, will be the citizens of Oakland, who will lose an iconic cultural treasure.

Sunday, August 24, 2008

City graffiti clean-up fast but uncoordinated

Recently, a local resident documented 16 fresh “tags” that had appeared on Martin Luther King Jr. Way and reported them to the public works via their online form, as well as by e-mail to the public works call center. Most of the tags were painted over by Public Works within four business days.

To report graffiti, determine the address of the property, then call Public Works at 615-5566, or e-mail them at, or by filling out an online form. To find the online form, go to

However you report the problem, you will be given an incident number that you can use to inquire about progress in addressing your issue.

Councilmember Brunner’s office seemed confused about the scope of Public Works’ duties regarding graffiti. Copied on the request mentioned above, Ms. Brunner’s office (Geoffrey Johnson) contacted the resident who had reported the graffiti and stated that Public Works would not take action because the tags were on private property. Mr. Johnson volunteered to forward the matter to Code Enforcement, who would then determine who the property owners were, contact them, and give them 30 days to clean up their properties. That effort became moot within days, when Public Works painted over most of the graffiti.

A graffiti abatement supervisor at Public Works could not be reached for comment about the appropriate scope of Public Works’ efforts.

While the speed of Public Works response was excellent, the quality of their remediation was spotty. Frequently, colors were poorly matched. Graffiti that was clearly visible from the locations of reported tags, but which was not included in the complaint, was not addressed. Graffiti on brick or tile was not remediated.

Public Works needs to update their techniques for graffiti removal. The anti-graffiti industry has made significant strides in recent years. Simply painting over graffiti with poorly matched paint leaves our neighborhood a patchwork crazy-quilt of colors.

The City needs to initiate a program of prevention that incents business owners to apply graffiti-resistant coatings to high-risk areas. Various coatings and compounds are now available that allow most graffiti to be easily washed, wiped or scrubbed off.

For example, SEI’s GPA-200 Graffiti Proofer Anti-Stick claims to allow easy removal from brick or masonry surfaces. The surfaces must be blast-cleaned before sealants are applied.

Graffiti Solution’s MaxAll is a non-stick coating the manufacturer recommends for all surfaces except those with low-gloss paints.

American Polymers claims its Graffiti Solution System will last 25 years and is easily removable itself, yet protects various surfaces, including brick.

JJB Solutions sells Power-ite, a graffiti removal gel and other removers that it states are effective on a variety of surfaces.

Due to issues with color matching, painting over graffiti should be the last resort, not the de facto response. Public Works needs to move into the 21st Century and apply new methods. The City needs to work proactively with business owners to prevent and respond to graffiti attacks.

Sunday, August 17, 2008

NCPC picks up ball dropped by Dellums

Last Fall, our City leaders announced with great fanfare that Beat 06X (including the area of JAMMI south of 40th St) and another beat in East Oakland had been selected for a special focus to fight crime and improve the neighborhood. Under the direction of the Mayor, City departments were to coordinate resources and work together to solve entrenched problems with a smorgasbord of City services. A committee (which included no community members) was said to be working on implementation. After a few months, nothing more was heard of the program.

The Beat 6 Neighborhood Crime Prevention Council has initiated what Mayor Dellums and his department heads seemed unable to do. On August 14th, the NCPC led a tour of Beat 6 for staff from various agencies. Along for the ride were representatives from CalTrans, Code Compliance, Public Works, OPD, the Alameda County Probation Office, Councilmember Nadel’s office, the Oakland Housing Authority, the West Oakland Project Area Committee and West Street Watch. (The Mayor’s Office was invited to send a representative, but no-one came.) Everyone piled into a van and took a two-hour ride, block by block, through most of the beat.

The group slowed or stopped frequently to discuss problems with individual properties, including graffiti, trash, illegal uses, weeds, crime, toxic contamination, vacant and boarded up conditions, untended yards, loitering, nuisances, potholes, dumping, abandoned cars, noise, stray animals, nonfunctioning streetlights, liquor stores, homeless encampments, litter, broken sidewalks, overflowing dumpsters, theft of recyclables, and the many other characteristics that blight our neighborhood. Participants were given clipboards to take notes, in the hope that the agencies represented would start to address specific conditions under their jurisdiction.

The fact that the leadership is coming from volunteer community members rather than paid elected leaders in itself is a sad comment on the current paralysis in Oakland City government.

Saturday, August 9, 2008

Eli's Mile High Club re-opens--but will it rock?

Eli’s Mile High Club, 3629 Martin Luther King Jr. Way, which closed May 1st due to a rent dispute between then-club owner Sam Marshall and the property owners, has re-opened under new management. The club is open M-Th 5 pm – 2 am and Fri-Sun from noon to 2 am. The bar boasts cheap drinks on certain nights, as well as a tasty Tillamook cheddarburger and fries.

But will the club offer live music, as it has for much of the past 34 years? The answer will depend upon the City’s response to club owner Geoffrey Melville’s application for a cabaret permit. A hearing on the application will be held on Thursday, August 28th at 3 pm in City Hall Hearing Room 2.

Several neighbors of the club are opposed to the granting of the permit. One neighbor writes, “The last thing we want is loud shows, loud patrons, no parking and all the other BS that comes with this type of venue.” However, this neighbor predicts “If the club is run well, adequately sound proofed and supplied patron parking they would have no complaints from me and most of the neighbors.”

Another neighbor near the club is taping the late-night noise from patrons’ voices, as heard in his bathroom, to demonstrate the noise impact on his privacy. Much of the neighbors’ ire references transgressions of previous club owners, who apparently ignored valid concerns and allegedly violated various city ordinances.

The club has a rich history as the “home of the West Coast blues,” and in the 1980’s was patronized by celebrities who came to hear national blues artists. It is located in the shadow of the MacArthur freeway maze, and is across the street from the BART railroad tracks. Two AC transit lines run on MLK from 6 AM until as late as midnight—it's a noisy location by any reasonable standard.

Club manager Jason is hopeful that the neighbors will choose to work with the club’s management to find satisfactory solutions to their valid concerns. When discussing these issues recently with a local resident, he pointed out thick soundproofing, said to cost $50,000, that had been installed around the stage some years back in an attempt to alleviate the noise problem. It will be augmented, Jason said, by rubber floor mats that may help to absorb the bass. Jason plans to hold a community meeting at the club in advance of the cabaret permit hearing, to air neighbors’ concerns and start a dialogue to address those issues.

A member of the West Oakland Project Area Committee has suggested that redevelopment funds could be used to further soundproof the club, if indeed noise from inside the club is a valid concern and if soundproofing would effectively resolve the noise issue. City staff responded that such improvements might be considered under the Tenant Improvement Program, but at best the City would only pay half the cost. Other ideas that community members have offered are purchase of a large lot adjacent to the club for parking, limiting hours of operation or ages of patrons, and running a shuttle to BART or another parking lot.

If the club closes, it might well result in yet another boarded-up target for copper thieves, returning neither cultural value to the community, nor business tax revenue to the City. It would seem to be in the best interest of the community to find solutions that would make this historic club a community benefit.

Sunday, August 3, 2008

Bike lanes on 40th Street--will they happen?

The City of Oakland’s Bicycle Master Plan of 2007 calls for Class 2 bike lanes on 40th Street between Adeline and MLK (among other places). This route lies within the West Oakland Redevelopment Project Area.

Currently, the street consists of a parking lane, six feet wide; a traffic lane, 12 feet wide; a second traffic lane, 14 feet wide; then the 16 foot median, then the two similar traffic lanes and parking lanes going in the other direction. The total street width, therefore, is 80 feet, not including sidewalks and curbs.

A recent MacArthur BART bicycle access study evaluated alternatives for bicycle routes to and from the BART station. In February 2008, the City of Oakland’s Transportation Services Division released results of this study funded by the Metropolitan Transportation Commission. This synopsis states “On 40th St between Market St and Webster St, the study recommends narrowing the 16-foot median by six feet to add bicycle lanes while maintaining two travel lanes in each direction.[1]

The proposal calls for trimming the median by six feet, three feet on each side, leaving a ten foot median.

The minimum width for a travel lane on a street with buses is 11 feet; 12 feet is preferable[2]. The City of Oakland Bicycle Master Plan states that “with parallel parking, the bicycle lane must be at least 5’ wide and the parking lane at least 7’ wide.”

So, the minimum street width in each direction is: 7 feet for parking, 5 feet for the bicycle lane, 11 feet each for two traffic lanes equals 34 feet in each direction.

Therefore, the plan will increase the parking lane from six feet wide to seven feet. It will add a five foot bike lane. It will trim the first car lane from 12 feet to 11 feet and the second car lane from 14 feet to 11 feet. It will trim three feet off each side of the 16 foot median.

We should support this proposal for many reasons:

The street is already an informal bicycle route to and from MacArthur BART. Striping dedicated bike lanes will make bicycle travel on the street safer.

Reducing the width of auto lanes has been demonstrated to calm traffic. People drive slower in narrower lanes.

Twelve of the 14 street trees in the median along this particular stretch should be able to be preserved. Only two trees will likely need to be removed due to shrinking the median from 16 feet to 10 feet.

Widening the parking lane and adding the bike lane will have the effect of pushing auto traffic away from the curb. It currently is dangerous to get into a parked car when traffic is flowing on the street. It will be safer if the moving cars are six feet farther away from the parked cars.

The sidewalk on much of 40th Street is absurdly narrow for the amount of pedestrian traffic on the street[3]. While this proposal does not directly address this shortcoming, it makes it safer for pedestrians to step into the street to avoid other pedestrians and to walk around cars parked in driveways[4]. It also will reduce the number of bicycles using the sidewalk.

The additional six feet of space between the curb and the first traffic lane will make it easier and safer for cars to park and to enter and exit garages.

Per Hui-Chang Li of the Community and Economic Development Agency (“CEDA”), West Oakland redevelopment funds could be used for bike lanes on the south side of 40th Street between Adeline and MLK[5], but not the north side, because the project area ends at 40th Street. Jason Patton, a Program Analyst with CEDA’s Planning and Zoning Services, estimates that some $250,000 might be needed to create the bike lane on the south side of 40th Street within the West Oakland Project Area[6].

CEDA anticipates tackling the entire project at once, not proceeding in phases. Therefore, design activities need to occur first, and construction is not likely to begin before 2010. It is anticipated that funding will come from multiple sources, including grants, redevelopment funds and BART station access funds.

Considering that the number of pedestrians using 40th Street to go to and from BART currently outnumbers the number of bicyclists, it would be prudent to ask if pedestrian improvements could or should be a part of the project as well. Undergrounding the utilities, which are on the same, heavily trafficked side of the street as the BART station, would free up sidewalk space for pedestrian movement.

(Due to the presence of utility poles, at many points on the south side of 40th Street the available sidewalk width is barely 3 feet, not the “6 to 15 feet” width that the Oakland Bicycle Master Plan trumpets as the typical sidewalk width in the City.)

[1] MacArthur BART Bicycle Access Study, City of Oakland, February 2008, p. 2.
[2] (This is per the minutes of the Oakland Bicycle and Pedestrian Safety Advisory Committee, 11/17/05.)
[3] The sidewalk is frequently 60” in width, not counting the curb. The Oakland Bicycle Master Plan draft EIR, March 2007, states “Sidewalks and walkways generally range from 6 to 15 feet in width. . .” (p. 4.A-1) and they don’t count the curb. So why is the 40th Street sidewalk only 60” wide?
[4] “Bicycle Lanes (Class 2) provide an added buffer between the sidewalk and the motor vehicle travel lanes.” Oakland Bicycle Master Plan, p. 4.A-17
[5] Specifically, the West Oakland Project Area’s northeastern boundary is one parcel west of the intersection of 40th Street and Martin Luther King Jr. Way. The CafĂ© Dejena building is in the Broadway/MacArthur/San Pablo redevelopment area.
[6] The entire project includes, of course, the bike lane on the north side of 40th St., but also bike lanes on 41st Street to Piedmont Avenue, and bike lanes on West MacArthur Blvd. Between Highway 24 and Broadway. Total estimated cost of the project is $800,000.

Friday, August 1, 2008

OHA's Step in the Right Direction

Greetings JAMMI!

Oakland has 254 scattered Oakland Housing Authority (OHA) public housing sites (not referring to Section 8). Many of these small public housing properties like those of your typical 4-unit complexes are strewn across all of Oakland, but especially in the flatlands. OHA recognizes the challenge of managing so many properties with limited number of staff from their OHA Police, Maintenance, and other supporting departments. As a result, many of these properties are currently blighted, crime-infested cancers that plague our communities.

West Street Watch (WSW) experienced two of these poorly managed buildings that housed and attracted significant drug and other illegal activities. Through a tedious and lengthy process, OHA was forced by WSW actions to evict the drug dealers and rehabilitate the deteriorated buildings. Our community, like all Oakland communities, deserve peace and should not need to take such extreme measures to resolve OHA problems.

WSW is encouraged to see new OHA leadership like Eric Johnson take control and move to create positive changes. One of his initiatives is to request from the US Department of Housing and Urban Development (HUD) to remove a restriction tied to OHA public housing properties that require that they be used solely for public housing. As reported by Mr. Johnson at the NCPC Beat 6X July 24th meeting, removing the restriction will allow OHA to consolidate the number of their properties that they would have to manage. Possibilities include demolishing some properties or selling others to developers. Furthermore, any displaced OHA public housing tenants will be provided Section 8 vouchers which can be used throughout all of the United States, excluding Hawaii.

WSW believes that OHA is taking a step in the right direction. WSW supports this innovative idea to reduce the number of scattered, uncontrollable OHA public housing properties. This will result in a manageable number of remaining properties. Please see below this post OHA's Frequently Asked Questions. A draft Application can be found at:

Please provide your endorsing comments to remove the public housing requirement to Ann Dunn, OHA Senior Policy Analyst at Comments are due September 6, 2008 and will aid in the approval of OHA’s application to HUD.


Regarding the Planned Disposition of Public Housing Scattered Sites

Question: What does Disposition mean?

Response: Disposition is the transfer or sale of a property from one entity to another. For the purpose of the proposed scattered site disposition, OHA plans to sell the scattered site properties to a non-profit corporation. The non-profit will be an affiliate of the Oakland Housing Authority and the Oakland Housing Authority Board of Commissioners will have a role in the decision making process with regard to the properties in the future.

Question: Why is the Oakland Housing Authority considering the disposition of its scattered site units?

Response: To increase and preserve the affordable housing opportunities for low-income families in Oakland. Over the last several years, the Oakland Housing Authority has received far less money from HUD to operate its public housing units than the actual cost of operating such units. One major goal of removing the units from the public housing program is to have enough income from Section 8 to manage, maintain and repair the properties.

Question: Why is OHA going to transfer the units to a non-profit corporation?

Response: The transfer of ownership to an affiliated non-profit organization is a necessary step to take the units out of the public housing program. The OHA Board of Commissioners will still have a role in making decisions about the properties.

Question: Why is ORA submitting a Disposition Application first and then submitting a request for vouchers only if the Disposition Application is approved? Why not ask HUD for both disposition approval and vouchers at the same time?

Response: HUD regulations require that the request for Section 8 vouchers be made only after a Disposition Application has been approved.

Question: What is the timeline for the disposition process and how soon will OHA know whether its application to HUD has been approved?

Response: There is no way to predict how long HUD may take to respond to the Disposition Application. As a very rough estimate, OHA has been advised that it may take three months or more before there is a decision. If HUD approves our application, it may be another year, or more, before vouchers are issued.

Question: What happens i f HUD does not approve the Disposition Application?

Response: If HUD does not approve of the disposition application, the units will remain in the public housing program and nothing will change.

Question: What happens if HUD does approve the Disposition Application but does not approve the request for Section 8 vouchers?

Response: OHA is making clear in its application to HUD that it will not move forward with the disposition if Section 8 vouchers are not provided. If the disposition application is approved, but the request for vouchers is not, OHA will not move forward with the disposition and the units will remain as public housing.

Question: If the disposition application is approved, and vouchers are issued, will current residents of the scattered site properties be required to move?

Response: No! No one will be required to relocate. Any family in good standing (current on their rent and in compliance with their lease) who wishes to remain in their unit after vouchers have been issued may do so.

Question: Who will be responsible for the management and maintenance of the units after the disposition?

Response: The non-profit corporation will be responsible for management and maintenance of the units.

Question: What do scattered site residents need to do now to get a voucher?

Response: There is nothing that needs to be done now. There is no application to complete, nor is it necessary to get on a waiting list.

Question: What if scattered site residents missed the public meetings where the disposition application was discussed? Will this hurt their chance of getting a Section 8 voucher?

Response: The purpose of the public meetings is to share information about the planned disposition and to hear resident feedback. Attendance at the meetings is not required and missing the meetings will not affect your ability to get a voucher in the future.

Question: If a family decides to stay in their current scattered site unit after they have been issued c Section 8 voucher, will the family be responsible for additional costs?

Response: No. Currently public housing residents are responsible to pay for their PG&E bill and OHA pays for water and Waste management (trash) costs. This will not change if vouchers are issued.

Question: What resources will the Oakland Housing Authority provide to families who wish to move after vouchers are issued?

Response: For a period of time after vouchers have been issued, OHA will pay for reasonable moving expenses for any family who wishes to move.
Question: If a resident chooses to move, will OHA provide money for security deposits?

Response: OHA will not provide money for security deposits_ OHA will provide information about organizations that may help with security deposits, but residents should be aware that help with security deposits is very limited. If a family remains in their current unit, no additional security deposit will be required.

Question: If a family decides to stay in their current scattered site unit after they have been issued a Section 8 voucher will their rent increase?

Response: Like public housing, Section 8 rent is based on income. However, unlike public housing, there are no flat rents in the Section 8 program. If a family decides to stay in their current scattered site unit, OHA will continue to calculate rent utilizing the public housing formula, including using flat rents. If the family later decides to move to a non-OHA unit, the Section 8 formula will be used to determine rent, which may result in a higher or lower rent amount, depending on the family's income and the rent of the new unit.

Question: What will happen to families who are not eligible for Section 8 vouchers?

Response: Any family in good standing (current on their rent and in compliance with their lease) who is not eligible for Section 8, or for whatever reason does not want to participate in the Section 8 program, will be provided the choice of moving to another public housing unit outside of the scattered site inventory or remaining in their current unit with a lease and rent amount determined under the rules of public housing. OHA will work with each family to ensure they understand all their options and make an informed decision.

Question: What are reasons a family may not be eligible for Section 8?

Response: Families in good standing (current on their rent and in compliance with their lease) with income that is at or below the income limit for the Public Housing Program (80% of AMI) will be eligible for the Section 8 Voucher. The Section 8 Program is generally limited to families earning up to 50% of AMI, but because scattered site residents will be treated as "continuing participants" OHA will be able to provide vouchers up to the 80% AMI limit. A family with income above 80% of AMI will not be eligible for Section 8. If this is the case, OHA will provide the family the choice of moving to another public housing unit or remaining in their current unit with a lease and rent utilizing the public housing formula, including using flat rents. Any resident who is not in good standing (not current on their rent or not in compliance with the terms of their lease) will not be eligible for Section 8. OHA encourages any family who is not currently in good standing to work with their property manager to resolve any issues, including entering into a repayment agreement for any back rent owed to OHA.

Question: How will OHA decide who gets the vouchers first? Is there a waiting listfor the residents of the scattered site units for the vouchers?
Response: OHA does not know at this point if HUD will provide vouchers all at once or will provide vouchers over several federal budget years. If vouchers are issued over time, OHA will develop a process for implementing the program property by property, based on the number of vouchers received as well as the physical needs of the property.

Question: How will residents know if and when the disposition application is approved and if and when Section 8 vouchers are awarded by HUD?

Response: OHA will keep residents informed of the status of the application process through notices to all scattered site residents when anything significant occurs. These notices will also be posted on the OHA website.

Question: If a family is given a Section 8 voucher, will it be for the same size unit as the family lives in currently?

Response: Vouchers are issued based on the current size of the household. If you choose to move with your voucher, your new voucher will be issued for your current household size, and any over or under housing of households will be corrected then. Families will be briefed to explain that they may have some flexibility for renting different sized units under Section 8.

Question: What will happen to families who have adult children living in the unit when the vouchers are issued? Will OHA issue more than one voucher per family?

Response: OHA will only receive one voucher per household. The voucher will be available only to the head of household on the current lease.

Question: Once (and if) the vouchers are issued, will families using them have to stay in Oakland?

Response: The vouchers will be like any other Section 8 vouchers. Once received, families will be able to move anyplace where vouchers are accepted (currently, any state in the United States, except Hawaii).

Question: Is the Oakland Housing Authority reopening its waiting list for the Section 8 Program?

Response: OHA is not reopening the Section 8 waiting list at this time.

Question: After disposition, who will be eligible to live in the units once a unit becomes vacant?

Response: Currently the units are available to families earning up to 80% of Area Median Income (AMI) (currently, 80% of AMI is $66,250 for a family of four). After disposition, the units will be further restricted to families earning up to 60% of AMI. Any family currently living in the units and earning over 60% of AMI will be allowed to stay in the unit, or to transfer to another public housing unit. Once units become vacant, any future occupants will be restricted to the 60% of AMI income limit. As units become vacant, OHA will provide first priority to families with Section 8 vouchers and may utilize project-based Section 8 resources to keep the units affordable.

Question: In the long term, what does the Oakland Housing Authority plan to do with the scattered site properties?

Response: Over the next five to ten years, or perhaps longer, OHA will look at each property on an individual basis to determine what options there are to preserve, repair or replace the scattered site units. Any future planning for the scattered site units will be done through a public process and witl resident consultation. In addition, the OHA Board of Commissioners will have a role in approving any plans for the scattered site properties.