Robyn Few - BAYSWAN



Robyn Few

Sex Workers Outreach Project-NORCAL

912 Cole St. #202

San Francisco, CA 94117

1500. swopusa@

Table of Contents

Letter from Robyn Few, SWOP-NORCAL (with additional endorsements) summarizing opposition to proposed legislation by Supervisor Carmen regarding Massage Establishment regulations in the Health and Planning Codes.

Letters by David Bigeleisen, Attorney

Letter from Naomi Ackers, Directory of the St. James Infirmary

Letter to the Editor, San Francisco Chronicle, Jeffrey Klausner, MD

Letter to the Editor, San Francisco Chronicle, Carol Leigh, BAYSWAN

History of issues regarding massage establishment fines as described in

“Policing the Vice Squad: Investigations launched into money collected from massage parlor workers, By Renata Huang December 16, 1998

Supervisor Carmen Chu’s Proposed Legislation, “Penalties for violation of Massage Practitioner Licensing and Regulation Ordinance”

Digest of Supervisor Carmen Chu’s Proposed Legislation, “Zoning – New Controls for Massage Establishments"

April 16, 2009

San Francisco Supervisor

San Francisco City Hall

1 Dr. Carlton B. Goodlett Place

San Francisco, CA 94102

Dear Supervisor,

We would like to submit the following initial objections to the Legislation submitted by Supervisor Carmen Chu " [Penalties for violation of Massage Practitioner Licensing and Regulation Ordinance.] "

We strongly believe that this legislation punishes workers at the massage establishments and places an undue burden on owners of massage businesses, making it discriminatory.

Furthermore, those involved in these businesses have not been consulted in this process, and should certainly participate. Although Supervisor Chu and Mayor Newsom have cited exploitative working conditions as a central reason for their proposed ordinance, they have not received input from those currently working in this industry. In comparison, when the jurisdiction for issuing massage establishment permits was moved from the Police Department to the Department of Public Health, the massage owners and workers, were consulted and participated in the process, so it is clear that this participation would also be feasible in this case.

* Proposed revisions to Section 1918 are discriminatory because, while bars, clubs and other businesses are permitted to stay open late, massage businesses would be required to close at 10.

* Proposed revisions to Section 1928 are discriminatory against these businesses and adversely impacts the workers. The proposed amendment increases vulnerability to penalties for any violation. This is problematic, as these violations include offenses which may be seen as unconstitutional, such as dress codes.

Moreover, there is a substantial history of city officials illegally taking advantage of workers through fines. This issue needs to be researched thoroughly before any adjustments are made. Through the current legislative proposal fines would be increased, along with vulnerability to corruption. Based on our familiarity with the industry, and through anecdotal reports it is clear that the following article is not an isolated case.

(attached)

These proposed legislation adversely impacts working conditions through increased pressures, as well as the safety of women who work in massage establishments. Harassment and increased criminalization makes women less likely to be able to come forward and report rape or violence against them.

In addition, upon consultation with local attorneys, we believe Section C is overly vague, potentially resulting in a dragnet. It is a slippery slope and creates a bad precedent in regard to efforts to regulate other industries as well. This is also true of Section 1928.1. Although there may be State or Federal precedents, we have not researched whether there have been local precedents for this type of targeting of specific businesses.

* Proposed revisions to Section 1928.2 creates a new crime, a misdemeanor, for these businesses and workers, based on what is essentially an issue of permitting, a non-violent "offense."

Calling for new criminal penalties of 6 months in jail and $1000 fines increases numbers of people going to jail, breaks up families and causes unnecessary hardships for people struggling, like other workers, in an economic crisis.

At a time of serious cuts in city budgets and needed programs, targeting massage businesses and workers with more hearings, more civil penalties is costly, including the time and money that will be needed to process the proposed misdemeanor charges. This will place a greater burden upon both the already crowded court system and the health department, without sufficient resources to deal with these changes efficiently.

This proposed legislation is discriminatory against the populations impacted, including immigrants and women of color. Proposed criminal enhancements also have a serious impact on immigration status including deportation. Many people in San Francisco seek an alternative to the criminal and law enforcement approaches that these proposals represent. Your office should review the details about this population and consider issues of these discriminations in the context of this type of enforcement.

This summary is based on our initial analysis of amendments to as noted in the proposed legislation (attached). We will be reviewing this legislation further.

We are also opposed to the conditional use requirements proposed as amendments to the Planning Code, "Zoning – New Controls for Massage Establishments," submitted by Supervisor Chu (digest attached, file located at ) which invoke many of the same concerns listed above. Given the history of discrimination against these businesses and individuals, obtaining specialized permits is an unfair burden and will stifle new businesses, creating an unfair advantage to current owners. As many concerned with this industry cite working conditions as primary concerns, this strategy negatively impacts workers, as they will not be able to find alternative work venues, which will substantially reduce their leverage in the workplace. These proposed revisions also drive this legal business underground, where workers are not able to access resources in cases of abuse. In this case as in the Health Code revisions above, the community of those impacted, workers and owners should participate in regulatory revisions. This is a partial response to the 50 page document which itemizes these changes to the Planning Code. We will be consulting with others regarding the details of these amendments.

In conclusion, we encourage your office to examine the issues carefully and dialogue with workers in the industry. We appreciate this opportunity to consult with you, and we are very interested in participating further on this issue.

Sincerely

Robyn Few,

Sex Workers Outreach Project-NORCAL

Carol Leigh

BAYSWAN

Stephany Ashley

St. James Infirmary

Harvey Milk Lesbian, Gay, Bisexual, and Transgender Democratic Club

Patricia West

Harvey Milk Lesbian, Gay, Bisexual, and Transgender Democratic Club

Shelly Resnick

Sex Workers Outreach Project-San Francisco

Acire Roche

Sex Workers Outreach Project-San Francisco

Naomi Ackers

Executive Director, St. James Infirmary

Rachel West

US PROStitutes Collective

Affiliations for identification purposes only.

David Michael Bigeleisen, Attorney

101 Howard Street, Suite 310

San Francisco, CA 94105

415-957-1717

Supervisor Eric Mar

City Hall

One Dr. Carlton B. Goodlett Place

San Francisco, CA 94102

RE: Proposed legislation amending rules regulating massage

establishments; Health Code Sections 1918, 1928, 1900, 1928.1, 1928.2

Dear Supervisor Mar:

I am writing to comment on proposed legislation to amend the laws regulating massage establishments.

The proposed changes in the law are presented in an attempt to combat or reduce human trafficking. I do not believe that the approach which is proposed will have any effect on human trafficking whatever. But I do believe that it will increase the cost to the city without enhancing the lives of our citizens.

The amendment to Section 1918 proposes to limit hours of massage establishments to a 10:00 P.M. closing time. How will two hours fewer of business limit human trafficking? This is underscored by the fact that nude dance clubs remain open much later.

The amendment to Section 1928 extends the washout period for new violations from one year to two. It also states that in determining a fine, a hearing officer may consider any relevant circumstance... Such language is vague. It will lead to inconsistent results and allow for arbitrary decision making.

A similar objection obtains as to proposed Section 1928.1 concerning cost recovery. How are the costs of inspection, investigation, hearing officer, court proceedings and attorneys’ fees to be calculated? Such a system will be very expensive to administer. There is no pattern or program currently in place that encompasses cost recovery of such breadth.

Increasing the penalties for violation of the Health Code to misdemeanor level is foolish in these times of dire economic shortage. The cost of prosecution of such offenses is quite large.

A substantial portion of the cost of defense will also fall upon the city, as many of the accused will be indigent.

At bottom, one must ask whether the costs of the proposed legislation will be justified by public benefit.

The city has but one inspector to police the current regulation of massage establishments. To enforce the proposed new laws will call for more work and more payroll. Prosecutions of misdemeanors will clog an already overwhelmed Court system.

There are already ample laws to punish human trafficking. If human trafficking is the vice to be addressed, then employ those laws.

The proposed legislation diverts valuable resources away from truly dangerous criminal cases. But it does not seriously address any health problems.

I recommend that you vote against these proposals.

Sincerely,

DAVID MICHAEL BIGELEISEN

[pic]

San Francisco Chronicle-Letters to The Editor

April 2, 2009

Recognize reality

Regarding "Going after massage parlors" (March 31): A whopping 41 percent of San Franciscans voted to decriminalize prostitution by supporting Proposition K this past November. Have city leaders forgotten that?

Centuries of efforts to repress prostitution have failed and only through the recognition that prostitution can be a safe and voluntary practice have policies aimed at reducing social harms like coercion and the spread of disease been effective. Now is not the time to go after prostitutes and their workplaces but the time to reach out and provide needed services and education.

JEFFREY KLAUSNER

San Francisco

(Jeffrey D. Klausner, MD, is Associate Clinical Professor of Medicine, AIDS and Infectious Diseases, UCSF*, President of the California STD Controllers' Association)

San Francisco Chronicle-Letters to The Editor

April 2, 2009

Supervisor Carmen Chu and Mayor Gavin Newsom's plan for the massage parlors ignores an important factor. The workers at these businesses are real people, with real opinions, and they should certainly have a say in the policies.

The Chronicle editorial ("Going after massage parlors," March 31) claims that the workers will not be affected, but that remains to be seen. I worked in this industry 20 years ago and I have followed these issues closely over the years. There are many ways in which the workers could be, and have been harmed by ill-conceived regulations developed for their supposed benefit. Instead of harassing these workers with insulting dress codes, the city should be creating a process to review the working conditions which includes the workers.

CAROL LEIGH

San Francisco

SF Weekly December 16, 1998

Policing the Vice Squad

Investigations launched into money collected from massage parlor workers

By Renata Huang

First of series located at:

The San Francisco vice squad's hush-hush practice of accepting cashier's checks from busted massage parlor workers appears to be at an end. The District Attorney's Office has effectively cut off the flow of money less than two weeks after SF Weekly reported that the vice division has been collecting tens of thousands of dollars in "restitution" from women it has arrested. But police officials claim they still have not been able to determine exactly how much money the vice squad collected from the women, nor to establish where all of it went.

Supervisor Leland Yee is now demanding an investigation of the practice, which continued for almost three years, and pressing for an accounting to see if all the money reached the city treasury.

Police spokesman Sherman Ackerson says Police Chief Fred Lau and other department brass did not know the vice squad was collecting money directly from people it arrested. Ackerson says Lau has also asked for an internal investigation. "It doesn't look good. This is a problem of perception," Ackerson says. "I don't think we want to be a collection service."

In the meantime, District Attorney Terence Hallinan's office has decided to reroute massage parlor cases in a way that will end the payments to the vice squad, according to Assistant DA Tim Silard.

In a Dec. 2 story, "Wages of Vice," SF Weekly reported on a little-known program used by the police and the DA's Office to clear out massage parlor cases. Women arrested in massage parlor raids -- either for actually soliciting sex or merely being present in a "house of ill repute" -- have been allowed to avoid prosecution by entering a diversion program run by California Community Dispute Services, a nonprofit agency.

The diversion "program," however, did not offer counseling, job training, or any other services that might constitute some sort of effort to help the women find another line of work.

Instead, the women simply agreed to pay money to CCDS and the vice squad in exchange for having the charges dropped. Payments to the vice squad, which appear to average about $100 for each woman arrested, were required to be in the form of cashier's checks specifically made out to the Vice Crimes Division of the Police Department and handed directly to a vice squad sergeant.

The practice raises troubling questions about the financial incentive for vice squad officers to step up arrests -- even if they have dubious cases -- and the propriety of the division demanding money to resolve criminal charges.

Vice squad officials say all of the money collected was properly deposited into a city account, but they have yet to produce a full accounting, although it has been more than two months since SF Weekly first asked for financial data on the program.

Apparently only the vice division maintained records of the money, and virtually no one else in the Police Department or city government knew about the practice, including the city's Treasurer and Controller's offices.

Supervisor Yee, among others, wants an explanation, and demanded an investiga-tion of the program during the board's Dec. 7 meeting.

"It seems to me any money that is somehow unaccounted for needs to be studied," Yee says. "The DA can't give us the number of cases that have been diverted. The police aren't sure of the disposition of the checks."

Equally troubling, Yee says, is that the diversion "program" has been doing nothing to actually help massage parlor workers get out of the business. "I assumed that if these women got arrested, they would have services provided to them," Yee says.

Yee says he met with Hallinan after reading SF Weekly's story and asked for details of the diversion process. But, Yee says, he was surprised at how little the DA seemed to know. "I thought he'd have a lot more information," Yee says. "I asked him how many massage parlor cases have been diverted by the DA's Office to this program, and he didn't know."

Yee says he has now sent formal letters to Hallinan, Lau, Budget Analyst Harvey Rose, and Controller Ed Harrington, asking each to probe the situation.

Lau, meanwhile, has ordered his own investigation into the accounting practices, and will pass the results on to Yee when they become available, spokesman Ackerson says.

The Controller's Office has asked the vice squad to produce a list of every cashier's check it has accepted from massage parlor workers since Jan. 1, 1996, when the program began. But so far, police have only coughed up a list covering the past six months. Without some form of outside scrutiny -- such as an audit -- there is no way of knowing if the list is complete.

"There's a concern because we're dealing with information provided by the police," Yee says. "We don't know how many individuals actually went through the diversion program and whether each of these cases had a paper trail."

Indeed, the paper trail -- or lack of one -- lies at the heart of the problem. According to Officer Tom Strong of the Police Department's fiscal department, the vice division has administered all bookkeeping for checks collected under the program. When checks come in, the vice squad does not turn them over to the Police Department's accounting division. Instead, Strong says, vice officers apparently take the checks to the bank personally, and presumably deposit them into a city account.

"The vice unit keeps its own copies of everything," Strong says. "They do their own accounting. It's our normal procedure."

So far, the vice squad has allowed only a few glimpses into its bookkeeping practices. What little has been revealed seems to raise even more questions.

For instance, the Police Department says that during fiscal year 1998 -- which ran from July 1, 1997, to June 30, 1998 -- vice accepted checks totaling somewhere between $7,200 and $7,500. But records from the CCDS diversion program appear to show that, in just the last six months of that fiscal year, there were about 370 arrests. If each of those women paid just $75 to vice, the total would be in excess of $25,000 for just one-half of the fiscal year.

History also seems to cast doubts on the scant financial data vice officials have been willing to release. During fiscal year 1997 -- which ran from July 1, 1996, to June 3, 1997 -- the vice unit says it collected $77,000 from arrested massage parlor workers, more than 10 times the figure claimed for fiscal year 1998.

But during the past two years, both the vice squad and Hallinan have boasted that they have been cracking down on massage parlors and making more arrests. The vice squad has yet to explain how arrests can increase while the amount of money coming in declines tenfold.

Some of the answers, presumably, will be forthcoming as the vice squad and police officials respond to inquiries from Yee and the Controller's Office.

In the meantime, Assistant DA Silard says Hallinan has decided to stop diverting massage parlor cases to CCDS. Instead, arrested massage parlor workers will now be sent to the Standing Against Global Exploitation (SAGE) program, which already handles the cases of arrested streetwalkers. The SAGE program offers job training, counseling, health services, English-as-a-second-language programs, and other assistance to help women get out of the sex industry.

Under the change, women arrested at massage parlors presumably will now be funneled into an actual diversion program. And, not coincidentally, the SAGE program does not include a method for the vice squad to collect money.

[Penalties for violation of Massage Practitioner Licensing and Regulation Ordinance.]

Ordinance amending Health Code Sections 1918 and 1928 to change the hours of permitted operation for massage establishments and to revise the penalties for violating Health Code Sections 1900 et seq., adding Health Code Section 1928.1 to provide for payment of the costs of administrative and other proceedings, and adding Health Code Section 1928.2 to provide for criminal penalties.

NOTE: Additions are single-underline italics Times New Roman;

deletions are strike-through italics Times New Roman.

Board amendment additions are double-underlined;

Board amendment deletions are strikethrough normal.

Be it ordained by the People of the City and County of San Francisco:

Section 1. The San Francisco Health Code is hereby amended by amending Sections 1918 and 1928 to read as follows:

SEC. 1918.  DISPLAY OF PERMIT; HOURS OF OPERATION.

(a)   Every permit to operate a massage establishment or solo practitioner massage establishment shall be displayed in a conspicuous place within the establishment so that the permit may be readily seen by individuals entering the premises. Every permit to operate an outcall massage service must be made available for inspection by the Department of Public Health at all times while providing massage services.

(b)   No massage establishment, solo practitioner massage establishment, or outcall massage service shall operate or provide massage services during the hours between 10 p.m.midnight and 7:00 a.m.

SEC. 1928.  VIOLATIONS AND ADMINISTRATIVE PENALTIES.

(a)   Any person who violates any provision of this Article or any rule or regulation adopted pursuant to Section 1926 may, after being provided notice and an opportunity to be heard, be subject to an administrative fine not to exceed $1,000 for the first violation of any provision of this Article or any a rule or regulation in a 2412-month period, $2,500 for the second violation of any provision of this Article or any the same rule or regulation in a 2412-month period, and $5,000 for the third and subsequent violations of any provision of this Article or any the same rule or regulation in a 2412-month period; provided, however, that the schedule of administrative fines for a massage practitioner shall be as follows: not to exceed $250 for the first violation of any provision of this Article or a rule or regulation in a 2412-month period, $500 for the second violation of any provision of this Article or any the same rule or regulation in a 2412-month period, and $1,000 for the third and subsequent violations of any provision of this Article or any the same rule or regulation in a 2412-month period.

(b)   Any permittee who knowingly employs a massage practitioner who is not in possession of a valid permit or who allows such a massage practitioner to perform, operate, or practice in the permittee's place of business may, after being provided notice and an opportunity to be heard, be subject to an administrative fine not to exceed $1,000 for the first violation in a 2412-month period, $2,500 for the second violation in a 2412-month period, and $5,000 for the third and subsequent violations in a 2412-month period.

(c) In determining the amount of the administrative fine, the hearing officer shall consider any relevant circumstance presented by any of the parties, including but not limited to the nature and seriousness of the violation, the number of violations, the persistence of the violation, the length of time over which the violation occurred, the willfulness of the violation, and the impacts of the violation on the community.

(dc)   Administrative fines collected under this Section shall be used to support the Department of Public Health and its Health Code enforcement functions.

(ed)   Nothing in this Section shall preclude the prosecution of anyone under Health Code Section 1928.2, the laws of the State of California or the laws of the United States of America.

Section 2. The San Francisco Health Code is hereby amended by adding Section 1928.1 to read as follows:

SEC. 1928.1. COST RECOVERY.

Any person who is assessed an administrative fine or whose permit is suspended or revoked under this Article, regardless of whether any fine, suspension or revocation is held in abeyance, shall be liable to the City for its costs incurred in enforcing this Article including but not limited to the costs of inspection, investigation, administration, hearing officer, administrative proceedings, court proceedings, monitoring and attorneys' fees. Within ten business days of the termination of the administrative hearing or other proceeding, the Department of Public Health shall calculate the amount of costs.

Section 3. The San Francisco Health Code is hereby amended by adding Section 1928.2 to read as follows:

SEC. 1928.2. VIOLATIONS AND CRIMINAL PENALTIES.

(a) Any person who shall violate Health Code Section 1901 which requires a permit to engage in the practice of massage, Health Code Section 1905 which requires presentation of an identification card to any City health inspector, Health Code Section 1908 which requires a permit to operate a massage establishment, solo practitioner massage establishment, or outcall massage service, Health Code Section 1914(e) which prohibits the use of any room in which massage services are provided to be used as a sleeping room, Health Code Section 1915 which requires every permit holder or employer to ensure that a massage practitioner has obtained a permit, Health Code Section 1916 which requires a register of practitioners to be available for inspection, Health Code Section 1917 which prohibits the employment of any individual under the age of 18, Health Code Section 1918, which requires display of a permit and prohibits operation between the hours of 10 p.m. and 7 a.m., or any rule or regulation adopted pursuant to Section 1926, shall be guilty of a misdemeanor and upon conviction shall be punished by a fine not to exceed $1,000 and by imprisonment in the County Jail not to exceed six months, or by both. A person convicted of violating this Section shall be deemed guilty of a separate offense for every day such violation shall continue.

(b)   Nothing in this Section shall preclude the prosecution of anyone under the laws of the State of California or of the United States of America.

APPROVED AS TO FORM:

DENNIS J. HERRERA, City Attorney

By:

Linda M. Ross

Deputy City Attorney

Legislation available at:

LEGISLATIVE DIGEST

[Zoning – New Controls for Massage Establishments.]

Ordinance amending Planning Code Sections 790.60, 890.60 and 218.1 to restrict permitted accessory massage uses and to make all other massage establishments, except for chair massage in plain view of the public, subject to a conditional use permit; amending Planning Code Section 303 to list additional criteria for the Planning Commission to consider when analyzing conditional use applications for massage establishments; amending the tables at Sections 218.1, 714.1, 715.1, 810.1, 811.1, and 812.1, to change massage establishments from a permitted use to a conditional use in the PDR 1, or Light Industrial Buffer, and PDR 2, or Production, Distribution, and Repair Districts, and in the Broadway Neighborhood Commercial District, the Castro Neighborhood Commercial District, and the Chinatown Mixed Use Districts; adopting findings, including environmental findings and findings of consistency with the priority policies of Planning Code Section 101.1 and the General Plan.

Existing Law

Current law regulates Massage Establishments by requiring that these uses obtain a massage permit from the Department of Public Health, and by establishing distance or size limitations on these establishments. Thus, under current law a Massage Establishment cannot be established within 1,000 feet of another such establisment, except when the massage uses are accessory to hospital or medical uses, or large institutional uses, or when the only massage provided is chair massage, such service is visible to the public, and customers are fully-clothed at all times.

In addition, through practice and interpretations issued by the Zoning Administrator, several other limitations have been added to Massage Establishments. For example, in 1997 a Board of Appeals ruling was generalized to allow any massage establishment as accessory to a medical or personal service if accessed only through space controlled by such medical or personal service business, and where the massage does not exceed 300 square feet nor employ more than two massage therapists. In 2007, the Zoning Administrator issued another interpretation, limiting the total area of treatment rooms that could be devoted to accessory massage uses (not to exceed 1/3 of the area of treatment rooms in Neighborhood Commercial, South of Market, Chinatown Mixed Use, and Mission Bay Zoning Districts, and not to exceed 1/4 of the total area of treatment rooms in other areas).

Limits have also been placed on the hours that an accessory massage use may function (in South of Market and Chinatown Mixed Use Districts and Neighborhood Commercial Zoning Districts, not to exceed 1/3 of the total hours of operation of the business; in all other zoning districts, not to exceed 1/4 of the total hours of operation of the business).

Amendments to Current Law

Changes to the Definition of Massage Establishments. This Ordinance amends the definition of Massage Establishment in Sections 790.60, 890.60 and 218.1 of the Planning Code, to restrict permitted accessory massage uses, and to make all other massage establishments, except for chair massage in plain view of the public, subject to a conditional use permits. In so doing, it renders obsolete the Zoning Administrator interpretations, summarized above, that established location, maximum area or hours of operation limits on these establishments.

The Ordinance defines a permitted accessory massage use as a use where the massage use is accessed by the principal use and: (1) the principal use is a dwelling unit and the massage use conforms to the requirements of Section 204.1, for accessory uses for dwelling units in R or NC districts; or (2) the principal use is a tourist hotel that contains 100 or more rooms, a large institution, or a hospital or medical center.

The Ordinance defines two other types of Massage Establishments: establishments where the only massage service provided is chair massage, such service is visible to the public, and customers are fully-clothed at all time, and establishments that have received a conditional use permit from the Planning Commission, pursuant to Section 303 of the Planning Code.

The Ordinance lists criteria for the Planning Commission to consider when reviewing an application for a conditional use permit pursuant for a Massage Establishment, in addition to the criteria listed in Section 303(c). These criteria are: (1) Whether the applicant has obtained, and maintains in good standing, a permit for a Massage Establishment from the Department of Public Health or from the state's Massage Therapy Organization; (2) Whether the use's façade is transparent and open to the public; and (3) Whether the use includes pedestrian-oriented lighting.

The Ordinance makes clear that the Board may adopt more restrictive provisions for Massage Establishments, or prohibiting Massage Establishments in specific areas of the City.

Conforming Changes. In addition to changing the definition of Massage Establishments, the Ordenance makes a series of conforming changes to other sections of the Code. It amends Section 303 to list the additional criteria that the Planning Commission is required to consider when analyzing conditional use applications for Massage Establishments; it also amends the tables at Sections 218.1, 714.1, 715.1, 810.1, 811.1, and 812.1, to change massage establishments from a permitted use to a conditional use in the PDR 1 (or Light Industrial Buffer) and PDR 2 (or Production, Distribution, and Repair) Districts, and in the Broadway Neighborhood Commercial District, the Castro Neighborhood Commercial District, and the Chinatown Mixed Use Districts.

Background Information

This Ordinance simplifies the definition of Massage Establishments by restricting accessory massage uses to very small, residential uses, or large institutional uses, and by providing that in most other circumstances, massage uses shall require conditional use authorization from the Planning Commission. It also provides clear guiding principles for the Commission to consider when analyzing an application for a conditional use permit for a Massage Establishment.

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