Alhambra street (Photo - Frank Qiu).

      Alhambra street (Photo – Frank Qiu).

      A 2017 video shows then Alhambra Administrative Services Director, Chris Paulson, and Alhambra Code Enforcement Supervisor, Rafael Perez, giving a presentation to the West San Gabriel Valley Association of Realtors (WSGVAR) in which both Mr. Paulson and Mr. Perez encourage realtors to utilize Alhambra Code Enforcement to keep their listing prices high and ensure “a higher quality level of residents” in Alhambra.

      By Sean McMorris and Eric Sunada*

      During the presentation, both Mr. Paulson and Mr. Perez thank the WSGVAR for their $1,000 donation to Code Enforcement.

      Video Summary

      (You can find an itemized list of key portions of the video referred to at the end of this article).**

      The video opens with Mr. Paulson stating that Alhambra Code Enforcement and the real estate industry have very similar goals and that “our success is your success and vice versa.” He explains his familiarity with the real estate industry because his father, former Alhambra councilman, Mark Paulson, has been a realtor in Alhambra for the last 35 years.  More on this in a moment.

      Mr. Paulson goes on to describe Alhambra Code Enforcement as the “pretty police” that is “looking out for the curb appeal of your properties.” He states that both entities want “desirable neighborhoods” that “attract ‘high quality residents.'” To this end, Paulson offers code enforcement’s assistance to the real estate industry so realtors can sell properties and keep prices rising, which equates to higher commissions.

      At one point, Mr. Paulson invokes the “Broken windows” theory as the driving force behind Code Enforcement’s approach and suggests that the end goal is a city that consists primarily of well-educated, wealthy residents who patronize high quality businesses. Mr. Paulson ends by thanking the WSGVAR for their financial support. Mr. Perez then reiterates Mr. Paulson’s sentiments and encourages realtors to call if they feel that a property near one of their listings is affecting their bottom line, and Code Enforcement will respond by sending officers to investigate.

      Conflict of Interest?

      Should Alhambra Code Enforcement be accepting donations at all, let alone from a group where a quid pro quo relationship is blatant?  Does the acceptance of donations translate to preferred status and services on the real estate lobby’s behalf?

      Publicly available information shows that WSGVAR donated $1,000 in both 2017 and 2018 to Alhambra Code Enforcement for its annual Neighborhood Clean Up event.  There are other groups that contribute, including residents who volunteer their time and labor.  And cleaning-up one’s city is certainly a good thing, so long as it is not done for the profit of a particular group, especially at the expense of another.

      So here’s what’s most troubling: Early in the video, Mr. Paulson states that “We [code enforcement] are trying to help attract high quality residents who will patronize high quality businesses.” Several minutes later, Mr. Paulson expounds:

      If you invest in your rental properties you are going to be bringing in a higher quality level of tenants, which will be a higher quality level of residents for the city of Alhambra… you will be bringing in higher educated residents that have higher income levels that want to work and live and play in the cities that we work in.

      The video shows city management endorsing an enforcement-arm role against neighbors in response to complaints from realtors whose profits may be affected.  Given their ephemeral world of transactions, it stands to reason that realtor complaints are likely based on appearances where the façade is golden.

      It does not help that Alhambra implemented a contemptible real property nuisance code in 2015, the purpose of which was to “define as public nuisances and violations those conditions and uses of land that are offensive or annoying to the senses, detrimental to property values and community appearance, an obstruction or interference with the comfortable enjoyment of adjacent properties or premises (both public and private), and/or are hazardous or injurious to the health, safety, or welfare of the general public.”

      In general, code enforcement agencies exist to protect the health and well-being of a city’s residents, not its beauty beyond compliance to reasonable local ordinances. Nor are they to serve as stewards of a particular industry or demographic. Nuisances that are solely “annoying to the senses” are hardly a threat to one’s health and safety. Such ordinance clauses are too easily abused; effectively a hunting license to discriminate and harass. Yet, the city’s conflict with real estate interests goes further.

      Mr. Paulson’s father, Mark Paulson, is also a paid consultant for multiple contractors and developers with projects in Alhambra (see 2010, 2017 (amended), 2018 Filing Form 700). This is notable because Mark Paulson continues to be granted special privileges at city hall long after his tenure on the city council. For instance, in 2016, the city asked Mark Paulson to sit on the interview board and participate in the selection process for the city’s next Development Services Director, to which Mark Paulson accepted. After the selection process, an email exchange shows Mark Paulson requesting that the new Director schedule an “all-hands meeting to discuss status and next steps” for a hotel project in the City that he appears to be consulting on. (See emails attachment.)

      Other emails show Mark Paulson coordinating/orchestrating city council meetings for development projects. (See attachment). And in one instance, he ghost writes a letter for the mayor that is addressed to a developer (Mark Paulson serves as a consultant for the developer).[1] (See Rakovich project attachment) and (Paulson 2018 Form 700 {Ratkovich})

      Real estate brokers, developers, and others who have business dealings and also reside within the city may serve on local government so long as a strict code of ethics is followed.  But Alhambra appears to have breached this boundary.

      Alhambra City Hall (Photo - Frank Qiu).

      Alhambra City Hall (Photo – Frank Qiu).

      Violation of HUD Policy?

      Alhambra Code Enforcement has been subsidized for decades by Housing and Urban Development (HUD) Community Development Block Grant (CDBG) funds. Using code enforcement to ensure that areas look pretty so that realtors can increase their commissions does not align with HUD policy.

      CDBG funds exist to improve the quality of life of low-and-moderate-income residents.

      CDBG regulation makes code enforcement an eligible CDBG activity “where such code enforcement together with public or private improvements, rehabilitation, or services to be provided may be expected to arrest the decline of the area,” or aid in the prevention or elimination of slums or blight. HUD defines a “blighted structure” as exhibiting “objectively determinable signs of deterioration sufficient to constitute a threat to human health, safety, and public welfare.”

      HUD’s audit

      In June 2012, HUD conducted an audit of Alhambra’s use of CDBG funding in response to local oversight group inquiries.  It found violations in its use of such funding for code enforcement whereby these monies were not being used to help the lower income areas.

      HUD issued a notice in 2014 warning cities about the abuse of CDBG funds allocated to code enforcement divisions, noting that “code enforcement is defined as a process for gaining compliance with local ordinances and regulations regarding health and housing codes,” with “a greater emphasis on structural issues” (i.e. not aesthetic issues). HUD, therefore, “expects localities to emphasize health and safety issues in buildings” when utilizing CDBG funds for code enforcement operations. It is egregious that Alhambra is using CDBG funds as part of an effort whose goal is the provocation or penalization of residents who may lack the wherewithal to comply with superficial changes desired by a realtor.

      Paulson’s and Perez’s claims that code enforcement exists to enhance the “curb appeal” of properties to increase realtor commissions and bring a “higher quality level of resident” is wrong. The purpose of CDBG funds is to improve the livelihoods of low-to-moderate income households, not push them out to increase a realtor’s bottom line. How did we get a local government that holds profit above its people?

      Furthermore, if a majority of canvassing requests to Alhambra Code Enforcement from realtors results in claims against a minority class, then it could be a violation of Title VI of the Civil Rights Act, making code enforcement in Alhambra an ineligible CDBG activity.

      Adherence to a “Broken” Theory

      In the video, Administrative Services Director, Chris Paulson, speaks about George L. Kelling and James Q. Wilson’s controversial 1982 Broken Windows theory of policing as the driving force behind Alhambra Code Enforcement’s approach.  In short, the theory posits that if law enforcement agencies focus on addressing small things, like broken windows, they will prevent bigger crimes and general community disorder.

      It was famously employed in the 1990s by then Mayor Rudy Giuliani during a period of high crime rates in New York City (NYC). Crime rates began to drop—suggesting broken windows policing was the answer. But it now appears as a rush to judgment due to confirmation bias.

      Crime rates were at unusually high rates across the U.S. in the early 1990s, not just in NYC, likely because of the crack cocaine epidemic. Those high crime rates began dropping in NYC and in cities all over the country just before Giuliani employed “broken windows.” A stronger economy, the end of the crack cocaine epidemic, harsher sentencing, and a reversion to the mean (unusual spikes in crime will eventually go back down to the norm) have all been attributed to the dramatic drop in crime in NYC and cities across the U.S. in the 1990s.

      But most troubling is the collateral damage invoked by “broken windows.” There was a dramatic spike in police misconduct complaints and lawsuits as well as police beatings in NYC right after it was adopted in 1993. It also ushered in an era of police profiling that culminated in “stop and frisk” policing that research shows unduly targets people of color.

      Classist/Racist Slippery Slope?

      Back to Mr. Paulson’s statements:

      If you invest in your rental properties you are going to be bringing in a higher quality level of tenants, which will be a higher quality level of residents for the city of Alhambra… you will be bringing in higher educated residents that have higher income levels that want to work and live and play in the cities that we work in.

      It is hard to reconcile these comments as not having classist/racist undertones. (It’s not a dog whistle, it’s a bull horn!)  “Higher educated residents that have higher income levels” is classist, and suggests that rather than help Alhambra’s struggling population the City prefers that they just go away. But such statements enter the realm of racism when statistical context is considered. Data shows that a majority of poor people in California and the U.S. are black and Latino, as well as a significant number of Asian Americans in the San Gabriel Valley.

      It’s important to note that historical practices by the real estate and finance industries contributed greatly to the makeup of the aforementioned data. These industries engaged in predatory practices or red-lining, which ultimately denied entry into home ownership, which, in turn, blocked a common path to increasing a household’s net worth.  Making up for this loss in upward mobility takes generations.  Even longer when local government engages in the type of purely profit-based agreement with realtors reflected in Mr. Paulson’s comments.

      The city of Alhambra has too often turned a blind-eye to its most vulnerable.  This video indicates that a focus is (maybe always was), there, but in a deliberate effort to squeeze our residents and neighbors with less disposable income in favor of those “higher quality” home buyers or renters with more.  This is serious because it borders on a policy of de jure displacement, detrimental to people’s lives and tearing the social fabric.

      City Comment and Public Perception

      When asked to comment on the video and emails, Alhambra City Manager, Jessica Binnquist, defended Mark Paulson’s sitting on the review board to hire a new Development Services Director and does not believe that his comments regarding city council meeting orchestration are relevant. “In the spirit of collaboration through the development process, we strive to provide excellent customer service to everyone, including Mr. Paulson,” said Binnquist. She further stated that “while a project applicant may have a vision of how they would like a process to be conducted, the project applicant does not control that process.” Ms. Binnquist did not comment on the views expressed by city management in the video.  Nor did she respond to questions regarding a letter ghost written by Mark Paulson on behalf of the mayor or that Mr. Paulson consults for the developer to which the letter is addressed.

      Ultimately, Alhambrans will have to make up their own minds about the statements in the video and how they reflect the values and policies of Alhambra City Hall.  These two community members are appalled.

      *Eric Sunada is the founder of Grassroots Alhambra and the local think tank San Gabriel Valley Oversight Group.

      **Video timeline and summary

      0.30 Chris Paulson: “we are the Code Enforcement Division in the City of Alhambra… We wanted to give you some information about what it is we do and how our mission goals and mission statement is very similar to the real estate profession. Our success is your success and vice versa.”

      0.54 Chris Paulson: “A little background about me aside from my official bio. I’m extremely familiar with the real estate industry. My father, Mark Paulson, works for Anthony Venti Realtors. So he’s been a realtor in the community for about 35 years.”

      2:30 Chris Paulson “You may not know us other than being the ‘pretty police.’ In other words,  we’re looking out for the ‘curb appeal’ of your properties.

      3:07 Chris Paulson: “How we can really help you [realtors] and how you can help us as well”

      4:30 Chris Paulson: “Ensuring desirable neighborhoods. I think we’re both on the same page when it comes to that… As I just heard all of the different listings, those prices would not be high if you did not have a good local code enforcement team that was going out there to make sure that your listings look good and all the properties around your listings look good. We are trying to help attract high quality residents who will patronize high quality businesses.”

      5:03 Chris Paulson: “We definitely believe we are supportive of the business environment. That’s why we’re here today, not to scold or anything like that, but to offer our assistance of how we can help you sell listings and keep the prices rising.”

      6:25 Code Enforcement Philosophy: Broken Windows Theory slide. Chris Paulson: “So, another code enforcement philosophy is actually one of my favorite theories that I learned in grad school at Pepperdine, It’s the Broken Windows theory.”

      7:45 Chris Paulson: “We also encourage as a result of this theory…”

      8:00 Chris Paulson: “If you invest in your rental properties you are going to be bringing in a higher quality level  of tenants, which will be a higher quality level of residents for the city of Alhambra… you will be bringing in higher educated residents that have higher income levels that want to work and live and play in the cities that we work in.” (in other words, we do not want poor people in our city? Is this close to racial profiling?)

      9:00 Chris Paulson: “Thank you for your very generous donation of $1,000 to code enforcement… “

      9:35 Chris Paulson: “We thank you for your financial support.” (real estate industry subsidizing code enforcement? Is there a conflict of interest here?)

      33:20 Rafael Perez: (PowerPoint slide) Collaboration with Real Estate Professionals – For Sale Residential Properties. “Our collaborative effort—this would be something new that we are starting here—is that if you have a listing in the area and in that immediate track of homes you see that the property is not being maintained, we encourage you to contact us… We will go out to the neighbor—that track of homes—and we’ll flyer them. We’ll try to educate them and encourage them to  maintain that property because we realize that it’s a struggle and sometimes just having people be aware that they need to maintain their home also helps you guys [realtors] be able to sell that home.”

      34:52 Rafael Perez: “Again, we thank you for your support. There’s the email. We encourage you that if you have a listing in the area and you see that there are houses in that track or surrounding that area, you can email us those addresses and we will go out and canvass.


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      1. Veronica Alvarez says:

        Stop the over developing, I agree, stop the corruption, absolutely, but don’t you dare discourage a clean well maintained city. I have been fighting with this backwards city for years. It seems the city could care less about the filthy streets with litter and the homes that were once well maintained giving way to dry grass, weeds and dirty yards. We as home owners have a responsibility to maintain our property because eye sores affect us all. If you are okay with a rundown neighborhood, then go find one to live in. I have lived in Alhambra for nearly 30 years and have personally seen the demise of some of our neighborhoods. Why? because some of our residents don’t care or don’t know any better. Alhambra’s job is to educate them. I am all for quality residents, and excuse me, quality residents come in all colors, just as those who choose to let their homes and neighborhoods go, and choose to litter our streets come in all colors. Why don’t you focus on the city’s continuing to allow massive multi family edifices, the way they remove trees- hmmm, I wonder whether they are in the same bed with their arborist. They are going to remove many trees in the Marengo development. Shame on the city for allowing this environmental mistake. Those trees provide clean air to those who live so close to the freeway. They provide shade, cooling and beauty. Alhambra does not need more multi unit buildings. Alhambra needs to do more, not less to clean up this city!!!

      2. JH says:

        Finally, someone is catching on to them. Alhambra building and safety is also corrupted. For an example, Ayla Jefferson, CBO, Building Official for Alhambra also works for Transtech Engineers, Inc. If you Google her name and also search Transtech Engineers, Inc, you will see that she’s been awarding Alhambra building projects to her side company. Total confilt of interest. She should be investigated to see if she pocketed any money. She also hires people from Transtech and places them at Alhambra building & safety.

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